ML20091M737
| ML20091M737 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/22/1982 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Miller D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-10, FOIA-84-96 NUDOCS 8406120071 | |
| Download: ML20091M737 (1) | |
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October 22, 1982 Docket No. 50-329 Docket No. 50-330 Mr. D. B. Miller Site Manager P.O. Box 1963
.$tidland, MI 48640
Dear Mr. Miller:
We. have reviewed Quality Assuia'nce Plans MPQP-1, Revision 4 and MPQP-2, Revision 1, dated October 12, 1982 respe ctively. We have no concerns with the organizational and typographical corrections made to these documents.
These documents are authorized for implementation.
In. the future, pleas,e be advised tha*, organizational and typographical changes need not receive prior Region III authorization for. implementation. We would -
request that these affected revisions be distributed to our staff in the usual manner.
Changes in the intent of the plans, however, will continue to require staff authorization.
Should you have any questions regarding this letter, please feel,. free to contact me.
W. D. Shaf Chief Midland section cc:
See Attached 1.ist 8406120071 840517 PDR FOIA RICE 84-96 PDR e
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'E ATOMIC SAFETY AND 1.lCENslNG BOA ~lD PANEL
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Docket Nos. 50-329 and 50-330 OL' 0/RA lEUF J 50-329 and 50-330 OM A/s.A vff 1@
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DEPcost ELO PIfORANDUM FOR: William D. Paton, Staff Counsel DEETP M
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Ch*Ples Bechhoefer, Board Chairman,0L l
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SUBJECT:
CLARIFICATION OF LETTER, W.D. SHAFER, CHIEF MIDLAND SECTION, NRC REGION III TO D. B. MILLER, SITE MANAGER, MIDLAND PROJECT, DATED OCTOBER 22, 1982 The Board has recently received the referenced letter. We believe that it would be useful for-the phrase " organizational * *
- changes" in the second paragraph to be clarified.
The Board assumed on first reading that the term was used in the same context as in the first paragraph in the letter--i.e., that the organiza-tional and typographical changes that need not receTve prior approval of Region III staff refer to organizational changes in the Quality Assurance Plans. On the other hand, as used in the second paragraph, " organizational
- = = changes" could be construed as referring to structural changes in the Quality Assurance Organization. We request that the Staff clarify this possible ambiguity in tne instructions being given to the Applican_t.
The Staff may wish to address this ambiguity as a preliminary matter during the hearing session scheduled to begin November 15, 1962.-
FOR THE ATOMIC SAFETY AND LICENSING BOARD f/
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charles Eecnnoef er, chairman <l..)
ADMIh1STRATIVE JUDGE cc: Service List SIv p
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Docket No. 50-329
}j Docket No. 50-330 i
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D." 3. Miller Site Manager F.O. Box 1963 Midland, MI 48640 i
Reference:
Imtter dated October 22, 1982, to D. B. Miller from W. D. Shafer, Chief, Midland section C
Dear Mr. Miller,
+v-The above referenced letter discusses when revisions to Quality Assurance Plans MPQP-1 and MPQP-2 will require -prior Region III authorization.
ne Board has requested that we clarify' our statement that organizational cha:.ges cc.uld be implemented without prior. regional approval.
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e Se types of organisation danges that will not require prior regional authorization are typographical corrections or title changes-that do not i
include a reassignment of responsibility.
Changes to the organizational structure, reassignment of responsibility and l
changes to the intent of the plan (which includes the organization charts) will 1
require prior Region III authorization.
, should you have any questions regarding this letter, please feel free,to contact me.i e,
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W. D. Shaf.
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Resident Inspector, RIII The Honorable Charles Bechhoefer, AsLB The Monorable Jerry Mazbour, ASIA The Honorable Frederick P. Cowan,1st.m The sonorable Ralph 5. Decker, ASLB Michael ::? iller monald callen, Michigan Public service Commission Myron M. Cherry Barbara Stamiris Mary sinclair Wendell Marshall colonel stave 3. Gadlar (P.E.)
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JRTNCIPAL STAFF Ygg UNITED STATES OF AMERICA NUCLEAR REGULATORY C0fMISSION gfp3 go
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In the Matter of gt CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & OL 50-330 OM & OL (MidlandPlant, Units 1and2)
SUPPLEMENTAL TESTIMONY OF R.J. COOK, R.N. GARDNER, R.B. LANDSMAN AND W.D. SHAFER WITH RESPECT TO QUALITY ASSURANCE Q1. Please state your names and positions with the NRC.
A1. My name is Ronald J. Cook.
I am the Senior Inspector for the NRC at the Midland plant.
My name is Ronald N. Gardner. I as an Inspector for the NRC,
?.egion III.
My name is Ross B. Landsman.
I as an Inspector for the NRC, Region III.
My name is Wayne D. Shafer.
I am the Chief Midland Section.
Office of Special Cases for the NRC, Region III.
Q2. Have your professional qualifications previously been submitted in this proceeding?
A2. Yes.
$Y Q3. What is the purpose of this testimony?
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A3. This testimony supplements the "NRC Staff Testimony of R.J. Cook, R.N. Gardner, R.B. Landsman, and W.D. Shafer With. Respect to Quality Assurance," dated October 29, 1982.
(October 1982 testimony.)
Q4. Dr. Landsman and Mr. Gardner, in your response to question 2 of your October 1982 te'stimony, you state that CPC committed to developing a program for the retraining and requalifying of QC e
personnel, but had not yet submitted the program. Has that program i
been submitted?
A4. Yes. However, there has been no formal submittal of the QC retraining and recertification program. Rather, we received copies of the procedures by which QC inspectors would be trained and certified. These procedures do require a combination of written and oral examination for the requalification of QC inspectors, as CPC had committed to do. Also, these procedures conform to the requirements of ANSI (American National Standards Institute, Inc.)
1 N45.2.6(1978)
Q5. Dr. Landsman and Mr. Garderer, do you monitor the training, qualifying, and certifying of QC inspectors?
AS. Yes. We have monitored the training, qualifying and certifying of j
, C inspectors and will continue to do so. Recently, we were Q
concerned with the manner in which training for non-soils t
inspectors was being conducted. We felt that the pace of it was too rushed. As a result, instructors were not always prepared.
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questions raised by trainees could not always be answered, and instructional materials were not always available at the classes.
To CPC's credit, they acknowledged this problem, suspended the,
training program, and are taking steps to improve it. When training of rion-soils inspectors is resumed, we will monitor the program to assess whether its deficiencies have been corrected. As for other areas of the requalification and recertification program, we have found no significant problems.
Q6. Dr. Landsman, in your response to question 4 of your October 1982 testimony, you discuss the QA program for underpinning activities.
Is there supplementation to that testimony.?
l A6. Yes. That supplementation is contained in the " Supplemental Testimony of John W. Gilray, Ross Landsman and Wayne Shafer with Respect to the Quality Assurance Program for the Underpinning Activities of the Service Water Pump Structure and Auxiliary Building."
i Q7. Dr. Landsman, in your response to question 6 of your October 1982 testimony, you state that with respect to quality assurance overview of remedial soils work, it was your assessment that CPC's QA staff was not "consensurate with the complexity of the task."
'Are you still of that opinion?
1 A7. Yes. I still am concerned about the lack of previous QA experience of certain MPQAD supervisory personne1 responsible for overviewing remedial soils work.
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Since July, 1982, there was established in MPQAD a separate group responsible for overviewing remedial soils work. As indicated by the following excerpts from inspection reports. I have documented a i
large number of NRC identified concerns with respect to the implementation of remedial-soils work.
A.
Inspection Report 82-18 (Attachment 5, Octcher 1982 testimony)
Section 1.
" Licensee Action on'Previously Identified Items" last paragraph (procedural requirements for dewatering well fines monitoring)
Section 2.
" Functional or Program Areas Inspected" subpart (b)
. Slope Layback at Auxiliary Building Access Shafts i
subpart(c)
BWST Foundation Grouting B.
Inspection Report'82-20 (Attachmentla)
Section 1.
Review of Training Program for Remedial Soils Activities C.
Inspection Report 82-21 (Attachmen'tIb)
I section 1.
Review of Remedial Soils QC Recertification Program.
D.
Inspection Report 82-22 (Attachment 4 to Supplemental Testimony Assurance) ppler With Respect to Quality of iJames Ke l
Perimeter Dike' Amor Stone Section 25.
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Inspection Report 32-26 (Attachment'Ic)
" Licensee Actions on Previously Identified Items,"
subpart (a)
Documentation <cf Training
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Remedial Soils Work Activities j
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Had the QA supervisors in question had greater QA experience I feel that there would not have been this many NRC identified concerns.
It should be noted, however, that no problem with CPC's perfomance of actual underpinning activities has been so significant to warrant a recomendation that this work be halted. I also note that in the response to this question. I an expressing my personal opinion and not the Staff's opinion.
I Q8. Mr. Shafer, what is the Staff position as to the lack of quality assurance experience of certain management personnel within MPQAD, as discussed by Dr. Landsman in the response to the previous question?
A8. With respect to the positions in question, there are no regulatory requirements which dictate the level of QA experience for the persons who fill those positions. Accordingly, the Staff will monitor the activities of the CPC employees in question until the Staff is satisfied with their managerial performance.
Q9. Dr. Landsman, in your response to Question 9 of your October,1982 testimony, you discuss the Staff evaluation of drawing 7220-C-45.
You state that CPC needed to take the following two steps for the submittaltobeacceptable;(1)revisethedrawingtoprovideQ controls for the permiter and baffle dikes adjacent to the ECWR and
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(2) reconfinn that no seismic category I underground utilities extend beyond the Q areas of the drawing. Has CPC done so?
A9.
In a letter from James W. Cock to Harold R. Denton, dated December 10, 1982 CPC confinned that they tava taken the above-mentioned two steps.
(Attachment 2). The Staff now finds drawing 7220-C-45 to' be acceptable.
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UNITED STATES 3*.
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Consumers Power Company ATIN: Mr. Jesses W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen:
This refers to the routine safety inspection conducted by. Messrs. B. Burgess, R. Cook, R. Gardner, and R. I,andsman of this office on August 20 through September 20, 1982, of activities at Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permitr No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. J, A. Mooney at the conelt.sion of the inspection.
The enclosed ch of our inspection report 10satifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-tarviews with personnel.
No items of noncompliance with NRC requirements were identified during the ccurse of this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a ec,py of this letter and the enclosed inspection report will be placed in the NRC's Public Document' Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has bein 9-e
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delayed such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be estab-lished. Consistent with Section 2.790(b)(1), any such application sust be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the i
claim that the information should be withheld from public disclosure.
This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Sinc.r.ly,
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R. F. Warnick, Acting Director Office of Special Cases Inclosure: Inspection Reports No. 50-329/82-20(OSC) and No. 50-330/82-20(0$C) cc w/ enc 1:
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Resident Inspector, RIII
'Ibe Honorable Charles Rechhoefer ASLE The Honorable Jerry Harbour, ASL3 The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASL3 Willian Paton, ELD Michael Miller Ronald callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Sadler (P.E.)
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U.S. NUCIIAR REGULA'It)RY COMMISSION REGION III Reports No. 50-329/82-20(05C); 50-330/82-20(OSC)
Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant Units 1 and 2 Inspection At: Midland Site, Midland, MI i~
Inspection Conducted: August 20 through September 20, 1982 i
Inspectors:
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Inspection Summary I
Inspection on Anaust 20 throuah September 20.1982 (Reports l
No. 50-329/82-20(OSC): 50-330/S2-20(OSC))
j Areas Inspected:
Review of Remedial Soils work activities, review of training
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program for Resedial Soils activities, inspection of materials used by Zack-j Company, and review of protective tagging procedure. The inspection involved 1
113 inspector-hours onsite by four NRC inspectors and 14 inspector-hours of j
inoffica direct inspection effort.
J Results: No items of noncompliance or deviations were identifed during this
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inspection.
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DETAILS Persons Contacted Consumers Power Company J. A. Mooney, Executive Man,ager
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- 3. W. Marguglio, QA Director D. Miller, Site Manager W. R. Bird, MPQAD M. L. Curland, Site QA Superintendent-J. P. Foley, MPQAD L. P. Kettren, MPQAD J. K. Meisenheimer, MPQAD
- 3. H. Peck, Construction Superintendent R. M. Wheeler, Technical Section Mead Bechtel Pove Corocration L. E. Davis, Site Manager J. W. Darby, Resident Engineer M. A. Dietrich, PQAE/MPQAD Other licensee and contractor personnel were routinely contacted during the course of these inspections.
Functional or Prorras Arems Insnacted 1.
Review of Trainina Pronran for Remedial Soils Activities The inspectors reviewed the training program initiated by the licensee for personnel involved in the future Remedial Soils activities.
Remedial Soils training is primarily obtained through attendance of a special Quality Assurance (QA) Indoctrination Session and during con-struction of a mock-up test pit. In addition, both Mergentine and Spencer, White and Frantis (SW&P) personnel require specific procedure training prior to initiating any quality related construction activities.
The licenses has indicated that a new Quality Improvement Plan. (QIP) will be initiated within 4-6 weeks.
The inspectors reviewed the records and loss to determine which person-nel had attended the special QA Indoctrination Saasion. The licensee's records and logs documenting the attendance at these sessions vers inadequate resulting in the licensee having difficulty in determining
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which personnel had attended and which personnel needed to attend these sessions. Further, the inspector determined that the Mergentine and SWEP training in specific procedures was documented only for superin-tendents, field engineers, etc. Except for two proceduras, there was no uocumented training provided for craft foresen or craft workman.
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The Resident Inspector and another Midland Team Inspector examined a prototype pit resembling the pit and legging considerations needed for the construction of Pier 12 for the actual underpinning work. The prototype pier is being constructed in the parking area by the main
, gate and was examined as a portion of the NRC review of training for individuals involved in the underpfnaine work. Construction of the prototype pier has revealed the need for some modifications in soil supporting techniques used at the base of the excavation.
In addition, the inspector determined that the licensee has not, as yet, provided training for the remedial soils emergency procedures such as C-200 and OP-41. During the exit meeting on September 15, 1982, the inspector informed the licensee that the training program, to date, was not well documented and in some instances, such as training in emergency procedures and training for craft foremen and craft workmen in work procedures, was not complete. The inspector informed the licensee that.
prior to initiating future remedial soil work activities, these tra'ning program deficiencies would have to be corrected. In addition, the licsnsee would have to ensure that all deficiencies identified during mesckup test pit activities were adequately addressed in their program.
l Tnis matter is considered an open item (50-329/82-20-01; 50-330/82-20-01).
2.
Remedial Soils Work Activities The inspectors reviewed and authorized the following work activities during the report period:
Calibration of jacks and gauges for the FIVP modification work.
a.
b.
Robar mapping of the existing BUST foundation.
Stripping of waterproof membrane from BWST valve pit walls.
c.
d.
Installation of the permanent security fenec.
Placing armor stone on the N.E. cooling pond dike.
e.
Installation of devatoring wells and piezaeeters for SWPS dowatering.
f.
Installation of utilities in non-Q soil for the technical support 3
center.
h.
Backfill of two abandoned temporary dowatering ejector holes.
i.
Probing for shallow utilities around SWPS.
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Coro drilling SVPS for temporary dewatering wells, k.
Reinstalling piping, pipe hangers and electrical facilities for the EWSTs.
1.
Hydro testing of new service water pipe after replacement.
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Relocating fire line by SWPS.
No items of noncomplaance or deviations were identified.
3.
Midland Section De Office of Special Cases was formed in July 1982 to address the significant inspection activities at the Midland and Zimmer ten-i struction sites. Mr. R. F. Warnick is Acting Director of this office, no Midland Section consists of W. D. Shafer, Section Chief R. N. Gardner and Dr. R. 3. Landsman from the Regional Office, and R. J. Cook, who remains the Senior Resident Inspector. Mr. 3. L. Burgess has been assigned as the Resident Inspector effective August 29, 1982.
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Zack Material Inspection During the month of August, the Zack Company issued a potential 10 CFR Part 21 to the Region III office (Letter to Region III from the Zack Company, dated August 2, 1982). The Part 21 addressed a possible dis-
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crepancy between the welder of record and the welder who say have performed the actual velds. In response to the Part 21. Region III requested an inspection to determine if material manufactured by the Zack Company in Cicero, Illinois was received onsite during the inspection period.
na Resident Inspectors conducted a random sampling of Zack HVAC
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material from various' storage locations onsite. The inspectors traced traveler reference numbers painted on the individual pieces to traveler documentstion. Of the 20 pieces identified, 5 were determined to be manufactured by the Zack facility in Cicero Illinois. The inspector reviewed shipment documentation and receipt inspection reports to confirm material traceability.
5.
Verkman's P otective Taas l
The inspector reviewed Midland Plant Procedure 20A2.1, Revision 3 titled
" Workman's Protective Tagging." The review was conducted by the resider.t inspector to ascertain the effectiveness of the plant tagging procedure.
In addition, the inspector reviewed the switching and Tagging Los and the Workman's Protective Tag Log. No major discrepancies were identified.
One itesi was identified during the review pertaining to the lie.ensee's corrective action system. The inspector was unable to determine if items identified as nonconforming during preoperational testing by the opera-tions department were transfered to the corrective action tracking sys. tem of the production and testing groups. This item will be reviewed during a future inspection and is considered an open item.
(50-329/82-20-02; 50-330/82-20-02)
I No items of noncompliance were identified.
6.
Extension of SALP III Reporting Period Consumers Power Company corporate management was informed that the SALP III period would be cetended from the original period termination date of June 30, 1982 to Decembe:: 31,19A2. The decision to extend the period was based on alleving the licensee time to implement those comments from the SALP II period which might help improve the licensee performance
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in those areas classified as Category III for the period ending June 30, 1981.
I 7.
Radiation Monitorinz system Equissent - Inferior Workmanship - 50.55(e) Item During the reporting period, the licensee performed an inspection in conjunction with the Rechtel Power Corporation of Victoreen Inc., the manufacturers for the radiation monitoring equipment. This joint in-spection found that at least 80*. of the 820 electronic modules examined would require rework to make them usable. This inspection also revealed s-
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1 that 12 of the 19 QA program criteria had not been adhered to and that use of the workmanship standard had been deleted without approval of the licensso.
D e modules examined had not been completely inspected and/or fune-tionally tested. However, the poor workmanship being used in the manufacture of the modules puts the reliability of the modules in jeopardy.
De licensee has invoked hold shipment restrictions on items slated for the Midland Site and stopped further processes for inspection and testing activities.
Manufacture of the modules had not been stopped at the end of this reporting period.
3.
Modified Auxiliary Feedwater Neader 4
During the reporting period, the licensee has continued to modify the steam generators to accomodate an external feedwater header. De holes for the Unit 2 steam generators have been sized with the excep-tion of two holes in one steam generator and one hole in the other steam generator. Work has recently commenced for sizing the holes for the Unit I steam generators. All 1/2 inch diameter pilot holes have been located and drilled.
Progress on the modifications for the steam generators has been monitored by a Regional Based inspector and the Resident Inspector, including observation of work performed on the sock-up located onsite.
9.
Open items Open items are matters, not otherwise categorized in the report, that require followup during a future inspection. Open items identified during this inspection are discussed in Section 1 and 3.
- 10. Exit Interview n e inspectors met with licenses representalves at the conclusion of the inspections on September 15, 17 and 21, 1982. De inspectors summarized the scope and findings of the inspection. De licensee acknowledged the information.
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NUCLEAR REGULATORY COMMISSION g,
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- .0a ser Docket No. 50-329 /f2.-2.8 Docket No. 50-330/g2-2.(
Consumers Power Company ATTN:
Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201
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Gentlemen:
This refers to the routine safety inspection conducted by Messrs. W. Shafer, R. Cook, R. Gardner, R. Landsman, and 3. Burgess of this office on September 20 to October 12, 1982, of activities at Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Pez1mits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. J. A. Nooney at the conclusion of the inspection.
The enclosed copy of our inspection report idesitifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
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During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If this report contains any information lj that you (or your contractors) believe to be exempt from disclosure under l-10 CPR 9.5(a)(4), it is necessary that you (a) notify this office by tele-phone within ten (10) days from the date of this letter of your intention to file a request for withholdings and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to l
withhold such information. If your receipt of this letter has been delayed g
such that less than seven (7) days are available for your review, please notify this office promptly so that a new due date may be established. Con-l sistent with Section 2.790(b)(1), any such application must be ammied by t t Ii
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an affidavit executed by the owner of the inforn.lon which identifies the document or part sought to be withheld, and '. ch contains c ~ full statement of the reasons which are the bases for the claim that tbr information should I
be withheld from public disclosure. His section further requires the state-ment to address with specificity the considerations listed in 10 CFR 2.790(b)(4).
Se information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response te this letter will be placed in the Puolic Document Roce.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, kljnf..kkbnuk.
R. F. warnick, Acting Director, office of Special Cases
Enclosures:
1.
Appendix, Notice of violation 2.
Inspection Reports No. 50-329/82-21 No. 50-330/82-21 oc w/encias DMB/ Document Control Desk (RIDS) mesident Inspector, RIII h e Honorable Charles Bechhoefer, ASLB Se Honorable Jerzy Harbour, ASIA The Honorable Frederick P. Cowan, ASLB he Honorable Ralph S. Decker, ASLB Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry
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Barbara stamiris Mary sinclair Wendell Marshall Colenel stave J. Gadla'r (P. E.)
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g ndix' NOTICE OF VIDIATION Consumers Power Company Dockst No. 50-329 i
Docket No. 50-330 As a result of the inspections conducted on September 20 to October 12, 1982, and in accordance with the NRC Enforcement Policy, 47FR9987 (March 9,1982),
the following violations were identified:
10 CFR 50, Appendix B, Criterion VI, states in part that, " Measures shall be established to control the isemance of documents..."
Consumers Power Company Quality Assurance Program Policy No. 6, Revision 12, e dated April 2,1982, states in part, that, " Documents which prescribe activities affecting quality... are... controlled... and distributed according to a controlled distribution... The assigned holders of the document are respon-sible for maintaining the latest revisions of the documents."
Contrary to the above, the inspectors determined the following two examples gf noncompliance:
1.
The QA department was using a controlled copy of PQCI UP-C-1.013 to make up QC recertification exam questions.
This copy of the PQCI was different from a controlled copy obtained from the QC records vault. Both documents were marked revision 0 and dated 8/20/82. There were two pages that were differ-ent dealing with the same interface doclament UP-C-1.008.
Furthermore, during the inspection, the licensee could not produce the. controlled distribution list for tre referenced PQCI.
2.
Two controlled copies, Manual numbers 1456 and 1369A, of the Bechtel " Quality Control Notices Manual", Procedure G-6.1, which controls PQCZs, were not of the latest revision.
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This is,a severity Inve11Y violation (supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required' to submit to this office within thirty days of the date of this Notice a written statement or explan-ation in reply, including for each item of noncompliance (1) corrective action taken and the results achieveds (2) corrective action to be taken to avoid further noncespliances and (3) the data when full compliance will be achieved.
Considera-tion may be given to extending your response time for good cause shown.
NOV o e er I
PflL l%~ Ab Dated
- 1. 7. Warnick, Acting Director p Ilin hag Office of Special Cases 2(,, O b R ' l I f N s
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.- c U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-329/82-21(Osc) s 50-330/82-21(OSC)
Docket Nes. 50-329: 50-330 Licenses No. CPPR-81 CPPR-82 Licensee: Constaners Power Ccapany 1945 West Parnall Road Jackson, MI 49,201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 1
h Inspection At Midland Site, Midland, MI i
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Inspection Conducted: SeptendEr 20 through October 12, 1982 Inspectors: A L. Burgess
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R. J. Cook s.
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R. N. Gardner
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traka.6-Approved By:
W. D. Shafer, Chief Midland Section
// Jo N Inspection summary Inspection on September 20 through October 12,1982 (Reports No. 50-329/82-21 (OSC) :
[
50-330/82-21 (OSC) )
Areas Inspected: Review of Remedial Soils QC recertification program; examination of site conditions: conditions for limited site fire' main capability and repairs; management meetings and examination of the Zimmer site. The inspection involved 180 inspector-hours on site by four NRC inspectors.
Results: Of the areas inspected, one item of noncompliance was identified with j
two examples: Severity Level ly, failure to maintain the latest revision of documents.
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,DE" FAILS Persons Contacted Consusers' Power Company J. A. Mooney, Executive Manager D. B. Miller, Site Manager M. L. Curland, Site Project QA Superintendent D. E. Mora, MPQAD, Civil J. K. Meisenheimer, MPQAD, Soils B. H. Peck, Construction Superintendent J. Schaub, Midland Project Office R. M. Wheeler, Technical Section Supervisor Bechtel Power Corporation M. A. Dietrich, Project QA Engineer J. Fisher, Manager, Remedial Soils M. M. Blendy, QC, Civil J. W. Darbey, Resident Engineer S. D. Kirker, QC, Civil i
other licensee and contractor personnel were routinely contacted during the i
i course of these inspections.
Functional or Program Areas Inspected 1.
Review of Remedial Soils CC Recertification Program Consumer Power Company letter to the NRC, dated September 17, 1982, " Quality Assurance Program Implementation for Soils Remedial Work", identified the licensee's actions in regards to integrating the Soils QA and QC functions under the direction of MPQAD. In response to this letter, the licensee was required to initiate a recortification program for all Bechtel QC inspectors integrated into the Soils QA/QC organisation. -The licensee subsequently i,
informed the NRC that the recertification of Bechtel QC inspectors would be accomplished through oral examinations. A schedule of these examinations was submitted by the licensee at the request of the NRC.
lt on September 23-24, 1982, the Region IIT inspectors conducted an inspection of the Bechtel QC recertification activities being accomplished by MPQAD.
lj During this inspection, the inspectors determined the following:
The inspectors observed that-in administering the oral examina-s.
,ij tions, MPQAD would excessively repeat the questions, allowing the i;
examinee several attempts to correct previously incorrect examina-
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Se inspectors observed that in administering the oral examina-tion, MPQAD would mark questions, which the examinee failed to correctly answer, as NA, when the question was relevant to the pertinent PQCI.
c.
The inspectors observed that the technical portion of the oral examination lacked the technical content necessary to establish the examinee's level of comprehension of the activity addressed by the subject PQCI.
d.
H e inspectors observed that the QA examiner used a controlled copy of PQCI UP-C-1.013 to make up the exam questions. his copy was different from another controlled copy obtained from the QC records vault. Both documents were marked revision 0 and dated S/20/82. More were two pages that were different deal-ing with the same interface document, UPHl'-1.008.
his failure to control documents is in nonecaqpliance with 10 CFR Part 50, Appendix B, criterion VI, as described in the Appendix of the report transmittal letter (50-329/82-21-1A 50-330/82-21-1A).
Furthermore, during the inspection, the licensee could not produce the controlled distribution list for the referenced PQCI.
The inspectors, while attempting to ascertain why the PQCIs were different, reviewed ten copies of the Bechtel " Quality control Notices Manual", Procedure G-6.1, which controls PQCIs. During the review / one controlled copy of G-6.1 had pages missing from iihe procedure. Two other copies, Manual numbers 1456 and 1369A, of G-6.1 were not of the latest revision. his is another example of noncongpliance to 10 CFR 50, Appendix B, Criterion VI, as described in the Appendix of the report transmittal letter (50-329/82-21-01B; 50-330/82-21-015).
During the exit meeting, the licensee committed to review the cenplete PQCI control process.
Subsequently,,megion III issued a confirmatory Action Letter (CAL) on September 24, 1982, regarding the licensee's commitments in regard to the problems identified in the remedial soils QC requalification program. The licensee coenitments identified by the CAL included: (1) the issuan:e of a Stop Work for all work on remedial soils with the exception of those contin-uous activities such as maintaining the freeze walls (2) the suspension of all examinations relating to remedial soils QC requalifications: (3) the decerti-fication of all remedial soils QC personnel previously certified; (4) the establishment of a retraining program for all QC personnel who fail the recer-l tification examinations and (5) the development of a written examination for all remedial soils QC recertifications.
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2.
Site Tours At periodic intervals during the report period, tours of selected site areas were performed. R ose tours were intended to assess the clean 11-ness of the siter storage conditions of equipment and piping being used in site constructions the potential for fire or other hazards which might have a deleterious effect on personnel and equipments and to witness con-struction activities in progress. A system walk down was performed of portions of the decay heat removal and component cooling water systems prior to the witnessing of initial performance testing.
3.
Limited Site Fire Main Capability As a result of inspection effort into the qualification of QC Inspectors for the remedial soils irork, a Stop Work was envoked on September 24, 1982.
However, at the time of the Stop Work, the licensee was in the process of i.
making a tie-in between the temporary construction fire main and the perma-nont site fire main. Sis tie-in was being made to facilitate remedial soils work at the Service Water Suilding. Although no excavation was involved, the work was being controlled by use of an excavation permit (WP-106). Se Stop Work negated the excavation permit and subsequently any work being performed under the excavation permit.
The licensee became fully aware of the Ifmited fire main' capacity on Septem-ber 25, 1982, and completed working on the fire main tie-in to restore fire main capacity. The licensee notified the NRC that technically the work may have violated the Stop Work, but when considering the limited fire main capacity, it'was more prudent to take emergency measures to restore the sys-tem to normal capacity. The Resident Inspector was informed of these actions and examined the system tie-in. No excavation work was in process as the excavation for access to the fire maire had been performed at an earlier time.
The NRC concurred with the licensee emergency action to restore the fire main capacity.
(Asference 1tr. Warnick to Cook dtd. October 5,1982).
4.
Management Meetings
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i Cn September 29, 1982, a meeting was conducted at the Ramada Inn Central in Midland, Michigan. The purpose of the meeting wts to discuss the integra-tion of Quality control (QC) activities into the Midland Project Quality Assurance Department (NPQ4D).
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on September 28, 1982, the Midland Inspection Site Team met with members of Stone s Webster and Consumers Power Caspany. The meeting was conducted to introduce the Third Party Independent Assessment Team members for remedial soils work and to explain their function onsite.
on September 22, 1982, the Midland Inspection Site Team met in the regional office to discuss with consumers Power company the management of Quality Control personnel onsite. One of the issues discussed was how Consumers i;
Power Company could manage and supervise Bechtel QC inspectors without jeopar-dising the Bechtel owned."N" stasy.
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Resident Inspector Visit to Zimmer Nuclear Power Station On October 7 and 8,1982, the Senior Resident Inspector (SRI) toured the l
El-r Nuclear Power Station. This tour was performed to compare the l
uniqueness of regulatory difficulties between the 24=aar and Midland Sites -
both plants have been assigned special attention through Inspection Teams
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assigned to the Office of Special Cases, RIII.
I It appeared to the SRI that inadequate structural steel, welding material i
traceability and the extensiveness of rework (excluding soils work) were l
more profound at the 21===r Station than at Midland. It was apparent that there was little similarity between the ' exact nature of nonconforming con-ditions at the Zinner and Midland Plants.
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6.
Exit Interview The inspectors met with licensee representatives at the conclusion of the inspection on September 24, 1982. The inspectore sunnarized the scope and findings of the inspections The licensee acknowledged the information.
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o om sons m p wi n s.Jan=a. usmeset st71tseoess December 10, 1982 PRINCIPAL STAFF F
Rarold R Denton, Director '
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Division of I,1cenaing JO'u NMN*
US Nuclear Regulatory Commission Epcapy d'W 2 Weshington, DC 20555 ospscs
' st o l DEsTP HIDLAND NUCLEAR C0 GENERATION PIANT m.
MIDIAND DOCKET NOS 50-329, 50-330 pt flLE M
l REVIEW OF SEISMIC CATEGORT I UTIIITIES l,
WITHIN DRAWING C-45 BOUNDARIES FILE:
0485.16 SERIAL:
19732 REIIRENCE: D EISENHUT OutC$ EETTER 70 J W C00r DATED MAY 25, 1982 Items 1 through 3, inclusiv'e, identified in Enclosure 7 to the above referenced NRC correspondence of May 25, 1982 requested that Consumers Power Company revise Drawing 7220-C-45 to extend Q-listed controls of soils activities to several areas in the sicinity of safety-relsted structures.
l Item 4 of Enclosure 7 requested that Consumers Power Company reconfirm that no Seismic Category I underground utilities extend beyond the Q-listed area boundaries identified on drawing C-45.
Revision 9 of Drawing 7220-C-45 is the current drawing revision which resolves the feur NRC items of concern identified in Zaclosure 7.
Revision 9 of Drawing 7220-C-45 along with several other revised documents incorporates those NRC requests identified as Items 1 through 3 of Enclosure 7.
We have also completed a careful review of the undergound utility locations on as-Installed field sketches and wish to. confirm that no Seismic Category I utilities are located outside those Q-listed areas shown on Revision 9 of Drawing 7220-C-45.
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- j; RJCook, Midland Resident Inspector R$ Decker, ASI3 SGadler, Esq JEarbour, ASLB, GRarstead, Earstead Engineering DSnood, NRC (2)
DFJudd, 36W FJEelley, Esq RBLandsman, ARC Region III WIDiarshall
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JPHatra, Naval Surface Weapons Center i l-W0tto, Army Corps o,f Engineers.
WDFatton, Esq i
SJPoulos, Geotechnical En2ineers j
BSingh, Army Corps of Engineers i
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,e CONSLHERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 19732 Dated December 10. 1982 At the ' request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the t
Commission's Rules and Regulations thereunder correspondence which resolves several concerns, Consumers Power Company submits and closes four action items identified in the NRC's correspondence of May 25, 1982. These concerns relate to an extensic.n of Q-listed controls to soils activities in the vicinity of CONSUMERS POWER COMPANY safety-related structures and to a reconfirmation of the location of Seismic Category 1 underground utilities.
By
/s/ J W Cook J W Cook, Vice President Projects, Engineering and Construction l
Sworn and subscribed before me this 13 day of December,1982
/s/ Barbaia P Townsend Notary Public Jackson County, Michigan.
My Commission Expiressentember 8.198h I
O oc0982-0232a100-14 p.,_..
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