ML20091L129
Text
.
Eik <.RdD
..k e a,,,
,[*.
NUCLEAR REGULATORY COMMISSION UNITED STATES
~~
2 WASHINGTON. D. C.20555
~
. s.... /
s j
SEP 2 71979 Docket No. 50-329/330 MEM0MNDuri FOR: George C. Gower, Acting Executive Officer for Operations j
t Support IE FROM:
Harold D. Thomburg, Director, Division of Reactor Construction Inspection IE
SUBJECT:
COMMENTS ON NEEDED ACTION ON MIDLAND ENFORCEMENT PACKAG RIII tranu package wo.nitted an enforcement package to me dated April 3,1979 and that
. sent to X005 as directed by J. Davis's memorandum of March 21, 1979.
RCI proviit,,d ccmnents on the enforcement package in a memorandum dated June 13, l';19 (see Enclosure 1) to X005 for coordination. We have not seen any posittiins in writing from NRR on the package. Since that date there have.
b en several meetings (8/1,8/3 and 8/16) which addressed, at least in part, l. _..
t e questi'os centering around further action on the enforcement package.
De meetiness were attended by personnel from NRR, ELD and IE. The various
- **']c] n"cessary to make a finding on a material false statement were
,g a.
Is the statement false?
b.
Is the statement material?
Under what circu:nstances or in what frame of mind was the statement made c.
~
(willful, deceitful, careless disregard)?
As a result. of these meetings and the subsequent discussions by telephone wi NRR represi.ntatives, we are of the opinion that the enforcement action shoul be taken on Item 1 of the package as a material false statement in that the fill used at the site was net the type stated in the FSAR as having been uset (rantlam vs engineered structural fill). The HRR conclusions on the other fou l
items were thac the statements were not material and indicated " poor QA perfonnance." on the part of the licensee.
CONTACT:
II. E. Shewmaker, IE 49-27551 Gddf.,hMCd '
-/G l'IfZ/@{h 8406070343 840517 PDR FOIA RICE 84-96 PDR
SEP 2 71979 G. C. Gower Further, it is our opinion that the fact that there are four clear instances of conflicting statements in the FSAR vs what was actually done'. is evidence of improper internal coordination and failure on the part of the licensee to These constitute assure that accurate information was being provided in the FSAR.
sufficient facts to make a finding that the material false statement was made This would make the material false in careless disregard of the facts.
statement subject to a civil penalty vs actions allowed under the Administrative Procedures Act for the "seccnd chance."
We strongly reconnend that X005 advise RIII to prepare the enforcement package this matter. We understand that
'in this manner and that we proceed quickly on there is a reluctance by some'in the NRC against finalizing an action on material false statements while the bigger questions of the QA program and work being done at the site as corrective actions which are not yet approved In our opinito, the two matters by the NRC are being considered for action.are distinct and IE shoul on the false statenent.
If you have any questions, please contact us.
d2e.Ad Harold D. Thornburg Director Division of Reactor
- ~
Cmstruction Inspection, IE cc:
G. W. Reinmuth, IE J. G. Keppler, RIII/
T. W. Brockett, IE D. Hood, NRR C. E. Norelius, RIII e
b l
-w, e
~~
rc c: g g.,,...,,.
j yss r
- j.a ade,
UNITEo STATES
- k
- y,e,,('
l,A
,k NUCLEAR REGULATORY COMMISSION
- #~ ~
~
'.1
- REGION lli 799 moostvELT meAo g
ggg CLEN eLLYN. ILLINots 60137
- f 7
,J..,., j
-l l.'.h ' t 9
j
+
v
'\\
'. d,'f.,,. '
s' [ "
. r.'
'. ip w r.
// '/.'.' li Tebruary 15, 1979
- ~
h.ik5 f.<.-
ME*CRANDUM TOR:
H. D. Thornburg, Director, Division of Re ctor F
I./);*)
Construction Inspection, IE
,s s
/
TROM:
James G. Reppler, Director
., '-%g/
s.
SU3 JECT:
MIDLaSD SDS:ARY REPORT
\\
/
-.n i
bG' i
The attached report, which represents Regien III's overall assessment of the Midland construction project to date fro a regulatory standpoint, was discussed with you and representatives frc= your staff, NRR, and CI'_D during our meeting at HQ's on February 6,1979. During that g-eeting, it was conclude.d,_that..this.zeport_should_be..providad to OEI.D M
fc_r ; rant.:::1 tal.to._t.he_].i_ censing Board and the vag g_panies to the 2
Kaaring. As such, this infor=ation is b~eing forwarded fcr your action.
p jI
/
g a s.8
( /
We believe the neeting was quite useful in receiving feedback from the various NRC people it.iolved relative to our position on the status of this facility.
i
)
? lease centact ce if you have any questions regardin5 chis natter..
u. SAL A
[/JamesC. Kap5ar p
Director
'\\
Attachcent:
- Midland Su= nary Report s
8
.p l.
i g.
'-},p 4,k p
'W-l*'
4
- W y\\
b.:
g A
- Y
/
~
(
/./f.f/ fif 4/6'dFO3.3s l
b
/...
]
MIDLAND SUM"ARY RT.? ORT Taeility Data
' Docket Nuchers 3'29 and 50-330
, Construe:1on Per=its
- CPPR-81 and CPPR-82 i
l Per=Its Issued
- Dece=ber 14, 1972 i
Type Reactor
- PWR; Unit 1, 492 MRe*; Unit 2, 818 Mk's 4
NSSS Supplier
- Babcox & k'ilcox l
Design /Censtructor
- Bech:e1 Power Corpora: ion i
Tuel Load Da:es
- Uni: 1,11/81; Unit 2,11/80 S:atus of Construction - Unit 1, 52%. Unit 2, 56 ; Engineering 80
- A;picxt:stely one-half the stea= production for Unit 1 is dedicated, 1
by centrae:, to be supplied to Dow Chemical Corporation, through ap;repriate iscla:icn heat exchangers.
Capability exists to alternate i
to Uni: 2 fer the staa: source upon denand..
l Chrenelo;ical Listint of Ma$er Events
]
July 1970 5:ar: of Cens:ruc: ion under exenp:ien
~
l 9/29-33 &
S1:e inspec:fon, four ite-. ef nonce pliance identified, j
10/1/70 ex:ensive review during CP hearings
[
'1971 - 1972 Plant in mothballs pending.CP t
)
12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of i
j nonco=pliance identified 11/73 Inspection at site, four items of nonce =pliance identified l
(caduald problee) precipitated the Show Cause Order 12/29/73 Licensee answers Show Cause order con =1cs to improvements on QA program and QA/QC staff I
l 12/3/73 Show cause or, der issued suspending cadwelding operation 12/6-7/73, Special inspection conducted by RIII & HQ personnel
~
12/17/73 show cause order nodified to allow cadualding based on inspection findings of 12/6-7/73
/
w.,
-,---v.
nn,,.
w-..--
.,...w.-.
w.-a
i 12/5/7d' CP reported that rebar spacing out of specificatien 50 locations in t' nit 2 containment 3/5 & 10/75 CP reported that 63 f6 rebar were either missing or r.isplaced in Auxiliary Building.
3 3/12/75
, RIII hald r.anagement meeting with CP e
S e
e 9
9 e
4 en e
9 e
e O
e b
O 4
+
O
(
s-9 0
e O
2
f
'3 8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building 3/22/76 CP reporte'd that 32 #8 rebar were omitted in Auxiliary Building. A stop-vprk order was issued by CP 3/26/76 RIII inspector requested CP to' inform RIII when stop-verk order to be lifted and to investigate the cause and the extent of the problem. Additional rebar proble=s identified during site inspection
~3/31/ 7'6 CP lif ted the stop-verk order 4/19 thru RI!I perfor=ed in-depth QA inspection'at P.idland 5/14/76 5/11./76 RIII manage:ent discussed inspection findings with site personnel 5/20/76 RIII manage:ent meeting with CP President, Vice President, and others.
6/7 & 8/.76 RIII follow up meeting with CP manage:ent and discussed C
the CP 21 correction co it=ents y
4 Overall rebar omission reviewed by (R.'E. Shev=aker 6/1-7/1/76 I
7/25/76 CP stops concrete placanent verk when further rebar' place:ent errers found by their overview program.
PN-III-76-52 issued by RIII i
8/2/76 RIII reco= sends HQ notice of violation be issued 8/9 - 9/9/76 Pive week full-time RIII inspection conducted
~
1
'8/13/76 5,etice issued i
10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28'/77 Unit 2 bulge of contain=ent liner discovered 1
4/19/77 Tendon sheath omissions of Unit i reported i
4/29/77 IA1 issued relative to tendon sheath placement errors 5/5/77 Manage =ent meeting at CP Corporate office relative to IAL regarding tendon sheath problem i
t x./
1 e
f j
y e,
- - *e-,y m--
..-------,w r-g---
~
(
' 0's
{
5/24-27/77 Special inspection by RIII. RI and F.Q personnel to deter'=ine adequacy of QA program implementation at Midland site 6/75 - 7/77 Series of meetings and letters between CF and NRR on applicability of Regulatory Guides to Midland.
Co=ittents by CP to the guides was responsive 7/24/78 Construction resident inspection assigned 8/21/78 Measurements by Bechtel indicate excessive settlerient of Diesel Getieratoi Building.6f ficially reported to RIII on September 7, 197S 12/76 - 1/79 Special investigation / inspection conducted at Midland sites Bechtel Ann Arbor Engineering cffices and at CP corperate offices relative to Midland plant fill and riesel Generator building settlement proble:
(
1
?
g e
e O
e e
G O
(.
t 4
elected Maior Events Past Preblems 1.
Cadveld Solicine Probier.and Shev Cause Order A routine inspection, conducted on Novecher
..we.'r 6-8, 1973, as a resul: of intervenor infor ation, identified eleven examples of four nonce:pliance ite=s relative to rebar Cadwelding operations.
These ite=s were su=arized as :
(1) untrained Cadweld inspectors; (2) rejec:able Oldvelds accepted by QC inspectors; (3) records inadequate in establish cadwelds met p}s/
requirements; and (4) inadequate procedures'.
As a result, the licensee stopped work on cadeeld operations I
on Neve:bar 9,1973 vhich in turn stopped rebar installation 0N The lies::see agreed not to resure work until the NRC reviewed and accepted their corrective action.
However, Shev Cause order was issued on December 3,1973, suspending Cadweldins operatiens. On Dece=ber 6-7, 1973 RI!I and HQ personnel conducted a special inspection and deter =ined that constructien activity could be resu ed in a manner censistent with quality criteria.
ne show cause order was modified on December 17, 1973, alleving resu:ption of Cadwalding operations based on
- he inspectica results.
De licensee answered the Shov Cause Otder en DeceE.er I
29, 1973, cc::1::ing to revise and impreve the OA =a.uals and procedures and =ake QA/QC persennel changes.
l e*W Prehearing cenferences were held en March 28 and May 30, 1974, and the hearing began on July 16, 1974 On Sep:e=her 25, 1974, the Hearing Board found that the licensee was i=ple:enting its QA progra: in conpliance with rel;ulations and that constr):ction should net be stopped.
2.
_Rebar 6:ission/ Placements Errors I,eading to IA1.
Initial identification a.ad report of rebar nenconfor:ances occurred during an NRC inspection conducted on Dece ber 11-13,
~ ' ~
1974 The licensee infor=ed the inspector that an audit, had
' h e-652' - 9" of Unit 2 centainment. identified rebar spacing problems at e 7',' to
'~ ~
reported per 10 CTR 50.55(e) and was identified as a ite: ofThis ite: vas sub nonce:pliance in repor: Nos. 50-329/74-11 and 30-330/74-11.
Additional rebar deviations and omissions were identified in March and August 1975 and in April, May and June 1976.
Inspection
, report Nos.
30-329/76-04 and 50-330/76-04 identified five
- c.. q "/ ; '
ner.:c=pliance ite=s regarding reinforcement steel deficiencies.
..ewtius.
P er*f-6
-a,.
l g,
d.. e.
e a
Y'.3
. '.y.
+
k,,,-
Selected Maior Events Past Preblees 1.
Cad eld Snlicine Problem.and Shev Cause Order A routine inspection, conducted on Novecher 6-8, 1973, as a result of intervenor information, identified eleven exa ples s
.of four nonce:pliance items relative to rebar Cadeelding operations. These ite=s were su=arized as: (1) untrained
- y Cadweld inspectors; (2) rejectable Oldwelds accepted by QC inspectors; (3) records inadequateto establish cadwelds met requirer.ents; and (4) inadequate procedure's.
I j
As a result, the licensee stopped work on cadweld operations N on Nove:bar 9, 1973 vhich in turn stopped rebar installationCL
- he licensee agreed not to resute work until the NRC revieved and accepted their corrective action. Novaver, Show cause Order was issued on Dece_bar 3,1973, suspending Cadwalding operatiens. On Dece=ber 6-7, 1973 RIII and HQ personnel conducted a special inspectien and deter =ined that constructica activity could be resumed in a =anner consistent with quality criteria. The show cause order was modified on Dece=ber 17,
(
1973, alleving resu=ption of Cadvelding operations based on the inspectics results.
i
~he licensee answered the Show Cause Order en Dece=ber 29., 1973, cen:.itting to revise and i: prove the OA =anuals and precedures and =ake QA/QC personnel changes.
prehearing cenferences were held en March 26 and May 30, 1974, and the hearing began on July 16, 1974 On Septe ber 25, 1974, the Hearing Beard found that the licensee was i=plementing its QA progra in compliance with re1;ulations and that constr}:ction should not be stopped.
2.
Rebar 6:issien/Placeeents Errors 1.eading to IA1, Initial identification and repert of rebar nonconfo::ances occurred during an NRC inspection conducted on Dece ber 11-13, 1974. The licensee inferned the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7 to 652' - 9" of Unit 2 containment. This ite= vas subsequently reported per 10 CTR 50.55(e) and was identified as a ite: ef nonce =pliance in report Nos. 50-329/74-11 and 50-330/74-11.
Additional rebar deviations and omissions were identified in
(- ',,
March and August 1975 and in April, May and June 1976.
Inspectien
, report Nos. 50-329/76-04 and 50-330/76-04 identified five j'
noncompliance ite=s regarding reinforce =ent steel deficiencies.
f,
5 P
Licensee response dated June 18, 1976, lis:ed 21 separate ite=s (co=mitments) for corrective action. A June 24, 1976 letter provided a plan of action schedule for imple=enting the 21 it e=s. The licensee com=itted not to resure concrete place:ent work until the items addressed in licensee's June 24 le:ter were resolved or implacented.
This co=nitment was doce=ented.in a R111 letter to the licensee dated June 25, 1976.
Although not sta= ped as an IAL, in-house memos referred to it as such.
~
Rebar installation and concre:e place ent activities were resu ed in early July 1976, folloving co:pletion of the items and verificatics by RIII.
Addi:ional action taken is as follows:
a.
Bv the NRC (1) Assign =ent of an inspector full-time on site fo:
five weeks to observe civil verk in progress (2) II managecen: castings Eith the licensee at their corporate of fices (3) Inspection and evaluation by Headquarter persennel b.
By the Licensee i
(1) June 18, 1976 letter ce==1::ing to 21 items of corrective action i
(2) Establish =ent of an overview inspec:fon prograt to provide 100% reinspection of a: bed:ents by the licensee following acceptance by the contractor QC personnel c.
3v the contractor Personnel changes and retraining of personnel (1)
(2) Frepared technical evaluation for acceptability of each identified construction deficiency I
(3) 1= prove =ent in their QA/QC program coverage of civil work (this was imposed by the licensee) 3.
Tenden Shea:h place:en: Errors and Resul:1nt I= mediate A:tien Le::er (IAL) p.
" On April 19, 1977, the licensee repor:ed, as a Part 50 Section 50.55(e) ites, the inadvertent emission of evo hoop tenden sheaths fro: a L' nit I centain=ent cencrete placement a:
l 6,
.~
3'.
.,O elevation 703' - 7".
1 located at an elevation in the next higher concreteThe te
- part, placement lift to pass under a steam line penetrat
.it was where they were omitted.
Tailure to rely on the proper source docu=ents by construction and inspection personnel, contributed to the omission.
(
An IAL was issued to the licensee on April spelled out six licensee co:::itzents for correction which 29, 1977 which included:
(1) repairs and cause corrective actica to procedures and training of construction and inspe (2) j personnel.
n i
A special QA progra:
The inspectien tes: vas made up of persennel fro: RIinspection F.Q.
was the concensous of the inspecters that the licens KIII, and
, it progra: vas an acceptable progra: and that the Midland ccnstruct construction projects.an activities were cc:p* arable to most other I
The licensee issued its final reviev en site was ee.."--ted and dotu:ented in repert.so.
ugust 12, 1977. Tinal 50-329/;;_og, j
Current preble:s i
t.pusessyr.
1.
plant Till - Diesel Generater Suildint Settlement The licensee infor ed the RIII office on Septe=ber 8 i
diesel generator foundatiens and structures were
- 1972, i
j expected.
Till m'aterial in this area was placed between 1975 and 1977 with construction starting on diesel generator building in sid-1977.
' vith the spring run-off water. Tilling of the cocling pond began in early 197 has increased approximately 21 feet and in turn increas'ingOv
..At.;-
r.:.
i the site sound water level.
{
It is not known at this time vhat effect (if any) the higher site ground water level has had on the plan fill and excessive settle =ent of the Diesel 1
Generator guilding.
i initially the PSAR indicated an underdrain systa= vould beIt i level but that it later was deleted. installed to maintain the g
,g",
'.'a m I,
.e I
. ~.
e 7
p...
,, - - ~. - - -,.., -,.,, _. - -. - -.. - -. - _ - - -
,....,m m.
,,.m
i 1
I l
'"*g The NRC activities, to date, include:
Transfer of lead responsibility to NRA frem II by me=o a.
dated Nove=ber 17, 1978 l
b.
Site meeting on Decenber 3-4, 1978, berveen NRR, II,
. Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel Generator Building settlement RIII conducted an investigation / inspection relative :o the c.
plant fill and Diesel Generater 3uilding settlement i
The Constructor / Designer activities include:
I a.
Issued NCR-1482 (August 21, 1975) b.
Issued Management Corrective Action Report (MCA7.) No. 24 (Sep:e:bar 7, 1978)
J Prepared a prepesed corrective actica option regarding l
c.
placere:t of sand overburden surcharge to accelerate and achieve proper co=paction of diesel generater j!
building sub scils Pre *isinary review of the results of the RIII investiga:Len/
t inspectica in:e the plant fill / Diesel Genera: r 3=ilding se::le=ent proble= indicate many events cccurred be:veen j
i la:e 1973 and early 1975 which should have alerted 3ech:e1 l
and the licensee to the pending proble. These events included scace:fer:ance reports, audi: findings, field =e=es to engineering and proble a with the ad inistration buildfes i
' fill which caused codifica:ic: and replace en: of the already j
poured foe:ing and replacement of the fill material snLth lean I
concrete.
i 2.
Insteetion and Quality Documentation to Establish Acceptability j
of Ieutement 4
This proble: consists of two parts and has just recently been l
identified by RIII inspec: ors relative to Midland. The secpe and depth of the problem has not been de:er=ined.
The first part concerns the adequacy of engineering evaluatien l
of quality documentation (test reports, etc.) to determine if the documentation establishes that the equipment meets
+
f specification and environ = ental require:ents. The licensee, f
1 1
g I
9 8
, -,, - ~. -, - -. -
,. -. ~,
b L Dccanek y
av0AV6.i fA0jMm I
(Q on Nove=ber 13, 1978, issued a cons:ruction deficiency repeft (10 CTA 50.55(e)) relative to this matter. Wether the recon..____ %.
was triggered by RIII inspector inquiriestor by IE Circular or Bulletin is not known.
An interim report dated November 28, 1976 was received and stated Consumers Power was pursuing this catter not only for Bechtel procured. equipment but also for NSS supplied equipsent.
I'"
l.
The second part of the proble= concerns the adequacy of 4 quip =ent acceptance inspection by Bechtel shop inspectors.
Exa:ples of this proble: include:
(1) Decay Heat Renoval Pu=ps released by the shop inspector and shipped to the site with one pump asse= bled backwards, (2) electrical pene: rations inspected and released by the shop inspector for shipment to the site. Site inspections to date indicate abou:
25% of the vendor wire te minations were imp operly cri= ped.
Ins ectien Eis:erv The construe:icn inspection program for Midland Units 1 and 2 is approxima:ely 50% ec:ple:e.
This is censis:ent with status of construction of the :vo units.
(Unit 1 - $2 ; Unit 2 - 56*)
In te=s of required inspection precedures approximately 25 have been co:pleted, 33 are in progress and 36 have ne: been initiated.
[
.e routine inspec:ica progra: has no: identified an unusual.nu=ber of enforce en: items.
enly ene is directly attributable to RIII enferce=en:Of the selected =ajor events de i
{
activity (Cadwald splicing).
ne other vere identified by the licensee and reported
}
th:cush the deficiency reper: sys:e: (50.55(e)). The Midland data for 1976 - 75 is tabulated below.
4 Nu:ber of Nu=ber of Inspector Hours Year
_Nencoceliances
- Inseections On Site d
1976 14 i
1977 5
12 6t.8 9
646 l
1978 11 18 706 b
.n.
.. r A resident inspector was assigned to the Midland site in July 1978.
M.1.}
j
~:
i The on site inspection hours shown above does not include his inspection w
i ti=e.
The licensee's QA progra: has repeatedly been subject to'in-depth reviev by IE inspectors.
Included are:
1.
July 23-26 and August 8-10, 1973, inspection report Nos. 50-329/73-06 i
and 50-330/73-06:
A detailed review was conducted relative to the l
i= pie entation of the Consumers Power Company's QA manual and Bechtel
'd'e!
j
(
. Corporation's QA program for design activities at the Bechtel Ann l
/ Arbor office.
The identified concerns were reported as discrepancies s
l relative to the Par:
F ~~~N' 50, Appendix B, criteria requiremen:s.
l 7
- e.. s m
em
,.,~,
,_f
- ~
_u i
2.
September 10-11, 19'73, report Nos. 50-329/73-08.and 50-330/73-08:
l A detailed red ev of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving three' separate g
Appendix B criteria with five different examples, were identified.
3.
February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A
,follevup inspection at the li,censee's corporate office, relative to the items identified during the September 1973 inspection (above) i
'along with other follovup.
4.
, June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the licensee's corporate office to review the j
new corporate QA progra= manual.
~
5.
August 9 through September 9, 1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA progra=
implementation on site primarily for rebar installation and other civil engineering work.
6.
May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special l
. inspection conducted at the site by RIII, IE and RI personnel i
to exa:ine the QA program implementation on site by Consu=ars Power Cc=pany and by Bechtel Corporatien. Although five exa=ples i
j cf noncompliance to Appendix 3 Criterion V, were identified, the i
conse: sus of the inspectors involved was that the program and its j
i=ple=entation for Midland was considered to be adequate.
Although the licensee's Quality Assurance progrs= has under gene a nu:bar of revisions to strengthen its provisions, no current concorri exist
~
regarding its adequacy. Their Tcpical QA Plan has been reviewed and accepted by NER through revision 7.
Implacentation of the progra= has i
been and continues to be subject to further review with the mid-construction progra= review presently scheduled for March or April 1979.
i j
Censumers Pever Cc=pany expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This began in 1975 with a cor itzent early in their experience with rabar inst'allation problems and was further co:=itted by the licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.
This overview inspection activity by the licensee has been very effective l
as a supple =ent to the constructor's own progra=.
Currently, this l
program is functioning across all significant activities at the site.
p:ferce=ent Histerv i
Approximately 6 months after restart of construction activ1 ties (11 months after CP issuance) an inspection identified four noncompliance ite=s regarding cadualding activities. This resulted in a show cause order l
being issued on Dece_ber 3,1973. This enforcement action was aired publicly"during hearings held by the Ato ic Safety Licensing Board
(,
in May 1974. The hearing board issued its decision in September 1974
\\
~
(
i
/0 l
1 i
l,,
,,~,e-.,
n,-....,
-,.n,-
...---.--ww.--
-.-,~,,n.enw.,,
.w
..,,~-.m.,-
n-,--.,-,--n.,
9 that concluded that construction could proceed with adequate assurance of quality.
~
l Identification of reinforcing bar problems began in December of 1974 vith the l'icensee reporting improper spacing of rebar in the Unit 2 containment vall.' Turther reinforcing bar spacing and/or omission of rebar was identified in August 1975 and again in May 1976 with the citations of 5 nonco=.pliances in an inspection report. An II:HQ notice of violation was issued regarding the citations in addition to the licensee issuing a stop work order. The licensee issued a response letter dated June 18, 1976 committing to 21 iteos of corrective action. A Bechtel prepared technical assessment for each instance of robar deficiency was sub itted to and review by II:HQ who concluded that the structures involved vill satisfy the SAR criteria and that the function of these structures vill
'be maintained during all design conditions. The RIII office of NRC performed a special five week inspection to assess the corrective action l
i=ple entatica without further citatien.
l The licensee reported that two hoop tenden shea:hs were omitted in cencre:e place =en:s of Unit 2 containment vall in April 1977. An I:=ediate Action Letter was issued to the licensee on April 29, 1977 listing six ite=s of licensee co. 1:=ents to be completed. A special inspecti'en was perfor=ed on May 24-27, 1977 with four NRC inspectors (1-EQ, 1-7.1, and 2-RIII). Although five ite:s of nonec=pliance vere iden:1fied, i: vas the censensus of the inspectors that the QA/QC j
progra: in effec: vas adequate. The constructors nonec:for=ance report previded,an alternate method of installatics for the tenden sheaths that was accepted.
~
The 7.III office of inspecticn and enforcement instituted an aug=en:ed i
on site it'spection coverage progra: during 1974, this program has con:inued in effec: ever since and is still in effect. It is noted that 1
the nonce:pliance hiscory with this program is essentially the sar.e as j
the history of other RIII facilities vi:h a comparable status of l
ccustruction. Turther on site inspection aug=entations was accocplished 1
Vith the assign =ent of a full time resident inspector in August, 1978.
)
The nonco:pliance history for the Midland Project is provided in the l
following table.
1 i
i 6 g e
Y g
ENToncD1.yr Ac zoyg O
1 inco:pliances Criteria (10 CTR 50 Appendix 3)
( ) Nu ber of Occurrances V, X, XI,.n'I
.,; w r,s s.. w. v.s y ~ a ~ '= v Construction haulted pending CP 11 V(5) XIII, XV, XVII
..... ~.
V(2) X*I k
l V(4)
X, XII, XV, XVI, xyII, xyrgy V(5) 10 CTR 50.55(e) tee =
v(t) vz(I), vzz, :x(3), n.1 focedures Draving Centrcl k*c k
>1
{.
,_g;
- mw.
- re rm***W"""#
-l hased.%terial 101 Processes L
(
18 - Test Equipment I
e
, e s * * ' f ~ * '
y e,
rts
~___-.:*
. g-.m,,,,,.,
.. "Z...
- * ' ~
E5 9
. u. n yi. r ~ -
..a. * ~.....,, s -. > 9 v *..
I
.',7 " J '*, *1J.M ' u.. S :!R :.:. '..' < : >.
i
. m W. 4.'ei.d,'
. 9 % ret,.+..u+..t4 et Aa *%*Wu 4.4
.a f 19
- I ' ** ** M " " o -(
d___
f i
..,,sm we,.... a..
i
- ENTORCD2NT ACTIONS f
Nonco=pliances
\\
Criteria (10 CTR 50 Appendix 3)
Year
- Total
( ) Number of Occurrances V, X, XI,.XVI 1970 4
I 1971-1972 0
construction haulted pending CP 9
II V(5) IIII, XV, XVII 1973-1974 3
V(2) X1t 1975 0
1976 10 V(4)
X, XII, IV, IVI, XVII, XVIII 1977 5
V(5) 10 CTR 50.55(e) ite=
1978 11 V(4) VI(2), VII, IX(3), XVI
~
Criteria-II QA Progra:
V Instructicas Procedures Drawing Centrol k*crk VI Document Control VII Centrol of Purchased Material J
{
EX Control of Special Processes 1
X Inspection III Control Haasuring - Test Equipment XIII
.Eandling - Storage IV Nonconfo'r=ing Parts XVI Corrective Actions XVII QA Records XVIII Audits
- ,g s.
Il O
s O
e.-r-
~
s
~
Su.arv and conclusions Since the start of construction Midland has experienced so=e significant proble=s resulting in enforcement action. In evaluating these proble=s they have occurred in clu=ps:
(1) in Septe=ber 1970 relative to i= proper place =ent, sa=pling and testing of concrete and failure of QA/QC to act on identified deficiencies; (2) in Septe=ber 1973 relative to draving con:rol and lack of or inadequate procedures for control of design and.
procure =ent ac:1vities at-the Bechtel Engineering offices: (3) in Nove=ber 1973 rela:ive to inadequate training, procedures and ' inspection of cadveld activities; (4) in April, May and June 19'!6 resulting fro:
a series of RIII in-depth QA inspections and =eetings to identify underlying causes of weakness in the Midland (A progra= i=ple=entation relative to e_ bed:ents.
(The nonco=pliance ite=s identified involved inadequate quality inspection, corrective action,' procedures and docu=enta:ien, all pri=arily concerned vi:h installation of reinforce =en:
steel); (5) in April 1977 relative to tendon sheath o=issions ; and (6) in August 1976 concerning plant soil foundations and excessive se:tle=ent of the Diesel Generator Building.,
yellowing each cf these proble= periocs (excluding the last which is still under investigati.on)2, the_. licensee has been responsive and has taken extensive action to evaluate and correct the proble= a=d to up-grade his QA picgra= and QA/QC staf f.
The most effective of these licensee actiens has been an oprview progra which has been s:cadly expanded to ecver al= cst all safe:y related activities.
The evalua: ion be:h by the licensee and IE of the structures and -
equip =en: affec;ed by these proble=s (again except the las:) has es:ablished :ha:- they fully neet design require =ents.
Since 197/.' these proble=s have 'either been identified by the licensee's quality progra= or provided direction to our inspectors.
Looking at the underlying causes of these'proble=s two co==cn threads c=erge:
(1) Consumers Pever historically has tended to over rely on Bechtel, and (2) insensitivity on the part of both Bechtel and Consu=ers Power to recognira the significance of isolated events.or, failure to adequately evaluate possible generic application of these events either of which would; have led to early identificatien and avoidance of the proble: including,the'last on plant fill and diesel generator building settle =ent.
Norvithstanding the above, it is our conclusien that the pr'oble=s experienced are not indicative of a broadbreakdown in the overall quality assurance progra=. Ad=ittedly, deficiencies have occurred which should have been identified earlier by qur.lity centrol personnel, but the l
licensee's progra= has beenYeffective in the.ulti= ate' identification and
(
subsequen: corrtetion oflthese deficiencies. While ve cannot dis =iss the l
possibili.cy that proble=:.' cay, have gone undetected by the 11censee's I
overall quality assurance progra=, our inspection progra= bas not iden:1fied sig=1ficant proble=s overlooked by the licensee - and this inspectien effort has utilizad nacy diffe:ent inspectors.
N
['
l 1
t
\\
0
1 e
?.'
s.
D.
e i
e The RIII proje:t inspectors believe that continuation of:
(1) resident site coverage, (2) the licensee overview progran including Ats recent expansion into engineering design / review activities, and (3) a continuing inspection progran by regional inspectors vill provide adequate assurance that. construction vill be perforned in accordance with requirenents and that any significant errors and deficiencies will b'e identified and corrected.
e e
e e
e e
e e
P D
e e
9 O
e 0
e e
e e
e D
e 9
O e
e O
/
f a
- ?pa.%,%
/
/ ' f o. (t Ar UNITED STATES
! y,,, g,j '
NUCLEAR REGULATORY COMMISSION REGION lit
- , A.q, ' /
=
5'""
s>
IX d/h.Hl817 N, '. j [
CLEN ELLYN. ILLINOls 60137 3
5 -
-/
October 18, 1979
(
er /./c j,; j MEMORANDUM FOR:
R. C. Knop R. Cook D. W. Hayes T. Vandel D. H. Danielson F. Jablonski K. Naidu E. Lee G. Maxwell G. Gallagher W. Hansen K. Ward P. Barrett I. Yin FROM:
G. Fioretti, Chief, Reactor Construction and Engineering Support Branch'
SUBJECT:
MIDLAND 40NSTRUCTION STATUS REPORT AS OF OCTOBER 1,1979 The attached report was finalized based on your feedback requested in my memo of October 5,1979. If you stiLL feel adjustments are necessary i
please contact me.
If you consider the-report characterizes your current assessment of the Midland project, please concur and pass it
~
along promptly.
G. Fioretti, Chief Reactor Construction and
Enclosure:
As stated Engineering Support Branch cc:
J. G. Keppler Wb l
/
2 t i
/- !?. 2'/ lb'f,
g, f-2;70t~7 ~~~ -
.Qv e
h MIDLAND
SUMMARY
REPORT UPDATE Facility Data _
Docket Number 329 and 50-330 Construction Permits
- CPPR-81 and CPPR-82 l
~
Permits Issued
- December 14, 1972 Type Reactor
- PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS
- Babcock and Wilcox l
Design / Constructor
- Bechtel Power Corporation Fuel Load Dates
- Unit 1, 4/82; Unit 2,11/81 Status of Construction
- Unit 1,54%; Unit 2, 61%; Engineering 82%
l
- Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers.
i Chronological Listing of Major Events July 1970 Start of construction under exemption 9/29-30 E Site inspection, four items of noncompliance identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified J1/73 Inspection at site, four items of noncompliance-identified (cadweld problem) precipitated the Show Cause Order 12/29/73 Licensee answers Show cause order commits to improvements on GA program and GA/GC staf f i
12/3/73 Show cause order issued suspending cadwelding operation 12/6-7/73 Special inspection conducted by RIII and He personnel 12/17/73 Show Cause Order modified to allow cadwelding based on inspection findings of 12/6-7/73 s
\\
']
12/5/75 CP. reported that rebar spacing out of specification 5; locations in Unit 2 containment 3/5 & 10/75 CP reported that 63 #6 rebar were either missing or misplaced in Auxiliary Building 3/12/75 RIII held management meeting with CP h
O s
l.
.. i
a l
'- 'N 8/21/75 CP reported that 42 sets of #6 tie bars were missint
\\.
in Auxiliary Building 3/22/76 CP reported that 32 #8 rebar were omitted in. Auxiliary Building. A stop-vork order was issued by CF 3/26/76 RIII inspector requested CP to inform RIII when stop-verk order to be lif ted and te investigate the cause and the 1
extent of the problem. Additional rebar problems identified during site inspection by NRC 3/31/76 CP lif ted the stop-vork order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 RIII management discussed inspection findings with 1
site personnel 5/20/76 RIII management meeting with CP President, Vice President, and others.
6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction coc=1tments 6/1-7/1/76 Overall rebar omission reviewed by 7/28/76 CP stops concrete placement work when further rebar placement errors found by their overview program.
PN-III-76-52 issued by RIII 8/2/76 RIII recommends HQ notice of violation be issued g/9 - 9/9/76 Tive week full-time RIII inspection conducted
'8/13/76 Notice issued I
10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of containment. liner discovered by Licensee 4/19/77 Tendon sheath omissions of Unit I reported 4/29/77 IAL issued relative to tendon sheath placement errors a
5/5/77 Management meeting at CP Corporate Offica relative to IAL regarding tendon sheath problem N =
q
\\
5/24/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of GA program implementation at Midland site.
6/75 - 7/77 Series of meetings and Letters between CP and NRR on applicability of Regulatory Guides to Midland.
Commitments by CP to the guides was responsive.
7/24/78 Construction resident inspection assigned.
8/21/78 Measurements by Bechtet indicate excessive settlement of Diesel Generator Building. Officially reported to RIII on September 7,1978.
12/78 - 1/79 Special investigation / inspection conducted at Midland sites,Bechtel Ann Arbor Engineering offices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement problem.
2/7/79 Corporate meeting between RIII and CPC to discuss project status and future inspection activities. CPC informed construction performance on track with exception of diesel / fill problem.
2/23/79 Meeting held in RIII with Consumers Power to discuss diesel generator building and plant area fitt problems.
3/5/79 Meeting held with CPC to discuss diesel generator building and plant area fitt problems.
3/21/79 10 CFR 50.54 request for information regarding plant fill sent to CPC by NRR.
5/5/79 Congressman Albosta and aides visited Midland site to discuss TMI effect on Midland.
5/8-11/79 Mid-QA inspection conducted.
4. -
Sionificant Maior Events Past Problems 1.
Cadweld Splicing Problem and Show Cause Order A routine inspection, conducted on November 6-8,1973, as a result of intervenor information, identified eleven examples of four noncompliance items relative to rebar Cadwelding operations.
These items were summarized as:
(1) untrained Cadweld inspectors; (2) rejectable cadwelds accepted by QC inspectors; (3) records inadequate to establish cadwelds met requirements; and (4) inadequate procedures.
As a result, the Licensee stopped work on cadweld operations on November 9,1973 which in turn stopped rebar installation and concrete placement work. The Licensee agreed not to resume work until the NRC reviewed and accepted their corrective action.
However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1973, RIII and HQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The Show Cause Order was modified on December 17, 1973, allowing resumption of Cadwelding operations based on the inspection results.
The Licensee answe.'ed the Show Cause Order on December 29, 1973, committing to refise and improve the QA manuals and procedures and make QA/QC personnel changes.
Prehearing conferences were held on March 28 and May 30, 1974, and the hearing began on July 16,1"74.
On September 25,1974, the Hearing Board found that the Licensee was implementing its QA program in compliance with regulations and that construction should not be stopped.
2.
_Rebar Omission / Placements Errors Leadino to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection conducted on December 11-13, 1974.
The Licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to 652' - 9" of Unit 2 containment. This item was subsequently reported per 10 CFK 50.55(e) and was identified as a item of noncompliance in reports Nos. 50-329/74-11 and 50-330/74-11.
Additional rebar deviations and omissions were identified in March and August 1975 and in April, May and June 1976.
Inspection report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.
. l
, h Licensee response dated June 18, 1976, Listed 21 separate items (commitments) for corrective action. A June 24, 1976. Letter provided_a plan of action schedule for implementing the 21 items.
The Licensee suspended concrete placement work until the items addressed in Licensee's June 24 Letter were resolved or implemented.
Th1s commitment was documented in a RIII letter to the licensee dated June 25,1976. Although not stamped as an IAL, in-house J
memos referred to it as such.
Rebar installation and concrete placement activities were satisfactorily resumed in early July 1976, following completion of the items end verification by RIII.
Additional action taken is as follows:
a.
By the NRC (1) Assignment of an inspector full-time ensite for five weeks to observe civil work in progress.
(2)
IE management meetings with the Licensee at their corporate offices (3)
Inspection and evaluation by Headquarters perscnnel b.
By the Licensee (1) June 18, 1976 Letter committing to 21 items of corrective action.
(2) Establishment of an overview inspection program to provide 100% reinstection of embedments by the Licensee following acceptance by the contractor GC personnel.
c.
By the Contractor (1) Personnel changes and retraining of personnel.
(2) Prepared technical evaluation for acceptability of each identified construction deficiency.
(3)
Improvement in their QA/QC program coverage of civil work (this was imposed by the Licensee).
3.
Tendon Sheath Placement Errors and Resultina Immediate Action Letter CIAL)
On April 19, 1977, the Licensee reported, as a Part 50, section
~50.SS(e) item, the inadvertent omission of two hoop tendon sheaths wgF O
O m.,
~
v s
.r
\\
from a Unit 1 containment concrete placement at elevation 703' - 7" due to having already poured concrete in an area where the tendons were to be directed under a steam Line. The tendons were subsequently rerouted in the next higher concrete lift.
An IAL was issued to the Licenser on April 29, 1977, which spelled out six Licensee commitments for correction which included:
(1) repairs and cause corrective action; (2) expansion of the Licensee's QC overview program; (3) revisions to procedures and training of construction and inspection personnel.
A special QA program inspection was conducted in early May 1977.
The inspection team was made up of personnel from RI, RIII and HQ.
Although five items of noncompliance were identified, it was the concensus of the inspectors that the Licensee's program was an acceptable program.
The Licensee issued it's final report on August 12, 1977. Final review onsite was conducted and documented in report No. 50-329/77-08.
Current Problems 1.
The Licensee informed the RIII office on September 8,1978, per requirements of 10 CFR 50.55(e) that settlement of the diesel generator foundations and structures were greater than expected.
FILL material in this area was placed between 1975 and 1977, with construction starting on the diesel generator building in mid-1977.
Review of the results of the RIII investigation / inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit l
findings, field memos to engineering and problems with the administration building fill which caused modification and replacement of the already poured footing and replacement of the fitt material with Lean concrete.
Causes of the ~ excessive settlement include (1) inadequate. placement method - unqualified compaction equipment and excessive lift thickness; (2) inadequate testing of the soit material; (3) inadeouate QC inspection procedures; (4) unqualified quality control inspectors and field engineers; (5) over reliance on inadequate test results.
1 I
l i
7-s eaw-=
I l
l i[
\\
The proposed remedial work and corrective action are as fotLows:
(1) Diesel Generator Building - apply surcharge load in and around building to preconsolidate the foundation material.
Continue to monitor soil response to predict Long-term settlement.
(2) Service Water Pump Structure - Install piles to hard glacial tiLL to support that portion of the structure founded on plant fill material.
(3) Tank Farm - FILL has been determined to be suitable for the support of Borated Water Storage Tanks. Tanks are to be constructed and hydro tested while monitoring soil response to confirm support of structures.
(4) Diesel Oil Tanks - No remedial measure; backfill is considered adequate.
(5) Underground Facilities - No remedial work is anticipated with regards to buried piping.
(6) Auxiliary Building and F. W. Isolation Valve Pits - Installed a number of caissons to glacial tiLL material and replace soil material with concrete material under valve pits.
(7)
Dewatering System - Installed site dewatering system to provide assurance against soit liquidification during a seismic event.
The above remedial measures were proposed to the NRC staff on July 18,1979. No endorsement of the proposed actions have been issued to the Licensee to date. The Licensee is proceeding with the above plans.
The NRC activities, to date, include:
a.
Lead technical responsibility and program review was transferred to NRR from IE by memo dated November 17, 1978.
b.
Site meeting on December 3-4, 1978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action related to the Diesel Generator Building settlement.
c.
RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement. Findings are cor.tained in Report 50-329/78-20; 330/78-20 dated March 1979.
d.
NRC/ Consumers Power Company /Bechtel meetings held in RIII office to discuss finding of investigation / inspection of site settlement (February 23,1979 and March 5,1979).
~~'\\
NRC issue of 10 CFR 50.54(f) regarding plant fitt dated March 21, e.
1979.
f.
Several inspections of Midland site settlement have been performed.
The Constructor / Designer activities include:
a.
Issued NCR-1482 (August 21,1978) b.
Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978) c.
Prepared a proposed corrective action option regarding placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel generator building sub-soils.
d.
Issued 10 CFR 50.55(e) interim report number 1 dated September 29, 1978.
e.
Issued interim report No. 2 dated November 7,1978.
f.
Issued interim report No. 3 dated June 5,1979.
g.
Issued interim report No. 4 dated February 23,1979 h.
Issued interim report No. 5 dated April 30, 1979
- i. Responded to NRC 10 CFR 50.54(f) request for information onsite settlement dated April 24,1979. Subsequent revision 1 dated May 31,1979, revision 2 dated July 9,1979 and revision 3 dated September 13, 1979.
- j. Meeting with NRC to discuss site settlement causes and proposed
~
resolution and corrective action taken dated July 18,1979.
Information discussed at this meeting is documented in letter from CPCo to NRC dated August 10, 1979.
k.
Issued interim report No. 6 dated August 10, 1979 L.
Issued interim report No. 7 dated September 5,1979 2.
Review of Quality Documentation to Establish Acceptability of Equipment The adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes that the equipment meets specification and environmental requirements is of concern. The Licensee, on November 13, 1978, issued a construction deficiency report (10 CFR 50.55(e)) relative to this matter. An interim report dated November 18, 1978 was received y
y
, i
i m
i and stated Consumers Power was pursuing this matter not only fo-Bechtel procured equipment but also for NSS supplied equipment.
l 3.
Source Inspection to confirm Conformance to Specifications l
The adequacy of equipment acceptance inspection by Bechtet shop inspectors has been the subject of several noncompliance /nonconformance reports.
Consumers Power has put heavy reliance on the creditability of the Bechtet vendor inspection program to insure that only quality equipment has been sent to the site. However, the referenced nonconformance reports raise questions that the BechteL vendor inspection program may not be effectively working in all disciplines for supplied equipment. Some significant examples are as follows:
(1) Decay heat removat pump being received with inadequate radiography.
The pumps were returned to the vendor for re-radiography and l
repair. The pumps were returned to the site with one pump assembled backwards. This pump was again shipped to the vendor for reassembly.
CPCo witnessed a portion of this reassembly and noted in their audit that some questionable techniques for establishing reference geometry were employed by the vendor.
The pumps had been shop inspected by BechteL.
/ (2) Containment personnel air Lock hatches were received and installed with vendor supplied structural weld geometry which does not agree with manufacturing drawings. The personnel air Lock doors had been vendor inspected.
(3) Containment electrical penetrations were received and installed with approximately 25% of the vendor installed terminations showing blatant signs of inadequate crimping. These penetrations were shop inspected by 3 or 4 Bechtet supplier quality representatives (vendor inspectors).
(4) 350 MCM, 3 phase power cable was received and installed in some safety related circuits with water being emitted from one phase.
(5) A primary coolant pump casing was received and installed without all the threads in one casing stud hole being intact. The casings were vendor inspected by both Bechtet and B8W.
Additional IE inspections wiLL be conducted to determine if CP has thoroughly completed an overview of the Bechtet shop inspector's function and that equipment already purchased has been reviewed to confirm it meets requirements.
4.
"C" List Equipment There have been instances wherein safety related construction components and their installation activities have not-b+sa 'dentified on the "Q" j
(
List.
j 4 j
o.
f
N This shortcoming could have affected the cuality of work perforced during f abrication due to the absence of quality controls identified with "Q" list items.
Examples of nun "0" list activities identifiec which should be "Q" listed include:
Cable Trays Components of Heating and Ventilation System The Licensee wiLL be advised to review past as weLL as future construction activities to confirm that they were property defined as "Q" list work or components.
5.
Management controls a.
Throughout the construction period CPCo has identified some of the problems that have occurred and reported them under the require-ments of 10 CFR 50.55(e). Management has demonstrated an openness by promptly identifying these problems. However, CPCo has on repeated occasions not reviewed problems to the depth required for full and timely resolution.
Examples are:
Rebar omissions (1974)
Tendon sheath location error (1977)
Diesel generator building settlement (1978)
Containment personnet access hatches (1978)
In each of the cases Listed above the NRC in it's investigation has determined that the problem was of greater significance than first i
reported or the problem was more generic than identified by CPCo.
This incomplete wringing out of problems identified has been discussed l
with CPCo on numerous occasions in connection with CPCo's management
~
of the Midland project.
)
b.
There have been many cases wherein nonconformances have been identified, reviewed and accepted "as is."
The extent of review given by the Licensee prior to reso!ving problems is currently in progress. In one case dealing with the repair of airlock hatches, a determination was made that an incomplete engineering review was given the matter.
Inspection History The construction inspection program for Midland Units 1 and 2 is approximately 60% complete. This is consistent with status of construction of the two units.
(Unit 1 - 54%; Unit 2 - 61%). The Licensee's GA program has i
repeatedly been subject to in-depth review by IE inspectors. The following highlight these inspections.
1.
July 23-26,and August 8-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the implementation of the Consumers Power Company's GA manual and Bechtel Corporation's GA program for design activities at the Bechtel Ann Arbor office. The identified concerns were reported as discrepancies relative to the Part 50, Appendix B, criteria requirements.
c _
i
( ~'}
2.
September 10-11, 1973 report Nos. 50-329/73-08 and 50-330/73-08:
A detailed review of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving three separate Appendix B criteria with five different examples, were identified.
3.
February 6-7, 1974, report Nos. 50-329/74-03 and 50-330/74-03: A followup inspection at the Licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along wi*h other followup.
4.
June 16-17,1975, report Nos. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the Licensee's corporate office to review the new corporate QA program manual.
S.
August 9 through September 9,1976, report Nos. 50-329/76-08 and j
50-330/76-08: Special five-week inspection regarding QA program implementation onsite primarity for rebar installation and other civil engineering work.
6.
May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE AND RI personnel to I
examine the QA program implementation onsite by Consumers Power Company and by Bechtel Corporation. Although five examples of noncompliance to Appendix B, Criterion V, were identified, the consensus of the inspectors involved was that the program and its implementstion for Midland was considered to be adequate.
i 7.
May 8-11,1979, a mid-construction GA inspection covering purchase control and inspection of received materials design control and site auditing and surveillance activities was conducted by a team of inspectors. While some items wiLL require resolution, it was concluded the program was adequate.
The Licensee's Quality Assurance program has undergone a number of revisions to strengthen it's provisions. The company has expanded it's QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This was done in 1975 with a commitment early in their experience with rebar installation problems and was further committed by the Licensee in his Letter of June 18,1976, responding to report Nos. 50-329/76-04 and 50-330/76-04. This overview inspection activity by the Licensee has been a positive supplement to the constructor's l
own program, however, currently our inspectors perceive the overview activities cover a smaLL percentage of the work in some disciplines.
This has been brought to the Licensee's attention who has responded with a revised overview plan. RIII inspectors are reviewing the plan as well as determining it's effectiveness through observation of construction work.
A specific area brought to the attention of the Licensee was the lack of overview in the instrumentation installation area. The Licensee has responded to this matter with increased staff and this item is under review by RIII inspectors.
\\.l
s tN The RIII office of inspection and enforcement instituted an auamented onsite inspection coverage program during 1974, this program has continued in effect until the installation of the resident inspector in July 1978.
Enforcement History a.
Noncompliance Statistics Number of Number of Inspector Hours Year Noncompliances Inspections Onsite 1976 14 9
646 1977 5
12 648 1978 18 23 1180
- 1979 to date 7
18 429 A resident inspector was assigned to the Midland site in July 1978. The onsite inspection hours shown above does not include his. inspection time.
- Through August 1979 b.
An investigation of the current soils placement / diesel generator building settlement problem has revealed the existence of a material false statement.
Issuance of a Civil Penalty is currently being
(
contemplated.
Summary and Conclusions Since the start of construction Midland has experienced some significant problems resulting in enforcement action. These actions are related (1) to improper placement, sampling and testing of concrete and failure of QA/QC to act on identified deficiencies in September 1970; (2) to drawing control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering offices in September 1973; (3) to inadequate training, procedures and inspection of cadweld activities in November 1973; (4) to a series of RIII in-depth QA inspections and meetings which identified underlying causes of weakness in the Midland QA program implementation relative to embedments in April, May and June 1976.
(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, aLL primarity concerned with installation of reinforcement steet); (S) to tendon sheath omissions in April 1977; and (6) to plant soil foundations and excessive settlement of the Diesel Generator Building relative to inadequate compacted soit and inspection activities in August 1978 through 1979.
Following each of these problem periods, the Licensee has taken action to correct the problems and to upgrade his QA program and QA/QC staff.
The most prominent action has been an overview program which has been steadly expanded to cover safety related activities.
l !
4 91.6 f }
The evaluation both by the licensee and IE of the structures and equip-ment af fected by these problems (again except the last) has established l
that they fully meet design requirements.
Looking at the underlying causes of these problems two common threads emerge:
(1) utilities historically have tended to over rely on A-E's (in this case, Bechtel) and (2) insensitivity on the part of both Bechtet and Consumers Power to recognize the significance of isolated events or f ailure to adequately evaluate possible generic application of these events either of which would have led to early identification and avoidance of the problem.
Admittedly construction deficiencies have occurred which should have been identified earlier but the licensee's QA program has ultimately identified and subsequently, corrected or in process of correcting these deficiencie The RIII inspectors believe that continuation of (1) resident site coverage, (2) the licensee overview program, (3) the licensee's attention and resolution of identified problems in this report, (4) ceasing to permit work to continue when quality related problems are identified with construction activities and (5) a continuing inspection program by regional inspectors will provide adequate assurance that construction will be performed in accordance with requirements and that any significant errors and deficiencies will be identified and corrected.
i m,,--
w v
, - * = - -
1 DETERMINE:
- 7 The Staff will consider the past history of problems that have occurred to date during the construction of the two units at the Midland site. It is to be determined
- 1) whether the known problems constitute a breakdown in the QA program significant enough to warrant some escalated enforcement action,
- 2) whether there is any lack of confidence by the staff to accept construction completed to date in all areas as if the issuance of an OL were in the insnediate future and
- 3) whether there are unresolved problems known but not identified by individual staff members and
- 4) whether any actions are necessary by the staff to assure that all construction completed to date is acceptable and
- 5) what actions, if any, are necessary in the future to preclude future problems.
i l.
i i
e I
e l
f
/
<p Q-M / M if
/
' /
b
---.,,..-,,,.m-.
,y w.
- - -