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Note to: Darl Hood (NRR)
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J. Harrison (Reg. III) t From:
William Paton
SUBJECT:
INTERVENOR REQUEST FOR DISCOVERY IN THE MIDLAND,QA HEARING 4
This is to confinn information we discussed at length on Wednesday, April 6, 1983.
On Tuesday, April 5,1983, a conference call was held between the Licensing Board and all parties to the Midland OM proceeding. The subject was dis-covery requests by Intervenor Stamiris. We have been engaging in informal discovery with Mrs. Stamiris, but the process has broken down. Intervenor is not satisfied with the discovery she has received to date.
Intervenor Stamiris is now represented by the attorneys for the Government Accountability Project. They indicated to the Board during the conference call their dissatisfaction with the discovery they had received to date and indicated that if they could not obtain the discovery they felt they needed that they would ask to delay the QA hearing which is now scheduled to being April 26, 1983. Mr. Eisenhut has recently indicated very strongly that this proceeding should not be delayed.
The Board urged the Staff to do everything possible to satisfy Intervenors' discovery requests.
Intervenors have agreed to have their formal discovery request in the Staff's hands not later than Friday, April 8,1983. Pursuant to Board Order the Staff i
is to file its' response not later than Friday, April 15, 1983. The purpose of this memo is to alert all concerned that 0 ELD will distribute copies of the formal discovery requests as soon as possible after receipt on Friday, April 8th. We hope all parties will be able to give the matter immediate j
attention to avert any possibility that the Staff causes a delay in the proceeding by reason of our inability to respond to discovery.
William D. Paton Counsel for NRC Staff
.i cc: E.Adensam(NRR)
R.Hernon(NRR)
R. Warnick (Reg. III)
W. Shafer (Reg. III)
S. Lewis (Reg. III)
' APR 11 1983 8406120204 840517 e
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i Ul;ITED STATES OF AMERICA PRINCIPAL STAFF NUCLEAR REGULATORY COFNISSION I
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AT0t11C SAFETY AND LICENSING BOARD 3p J AO T N
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Before Administrative Judges Charles Bechhoefer. Chairinan Qi/cous R4A
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hedag masF Dr. Frederick P. Cowan
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Dr. Jerry Harbour g
FILEN'IL P at ASLBP Nos. 78-389-03 OL 80-429-02 SP In the Matter of Docket Nos. 50-329 OL 50-330 OL CONSUMERS POWER COMPANY Docket Nos.'50-329 OM (111dland Plant, Units 1 and 2) 50-330 OM April 5,1983 MEMORANDUM AND ORDER.
(Telephone Conference Call.. April 5, 1983)
On April 5.1983, the Applicant initiated a telephone conference N'
call, in accordance with the agreement: reached at the evidentiary
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hearing on Friday, April 1,1983.: In addition to the Board Members, the following participated':
W. Paton and M. Wilcove, for the NRC Staff D. Stahl. P. Steptoe, R. Lauer, and J: Brunner for the Applicant L. Bernabei and B. Stamiris, for Ms. Stamiris M. Sinclair. pro 3 1.
At the hearing on April 1. the Board heard argument concerning the Applicant's objections to one of Ms. Sarbara Stamiris' discovery requests (Tr. 14138-196). Ms. Stamirit had previously requested documents discussing, inter alia, "any findings or recomendations" of a (h
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1980); see also Consumers Power Co. (Midland Plant, Units 1 and 2),
ALAB-691,.16 NRC fn. 27 (September 9.1982); and (4) that there has not thus far been an adequate showing, as centemplated by 10 CFR i 2.740(b)(2), that'Hs. Stamiris has a
" substantial need" for the drafts and is " unable without undue hardship i
to obtain the substantial equivalent of the materials by other means."
We perceive that there would be a " substantial need" for these drafts only if they included material facts additional to those in the f,inal report which, we understand, has been made available to Hs. Stamiris.
The Applicant claims that the material is' cumulative.
If this be so, we believe that the work product privilege should be upheld.
As a result, we ruled that the Applicant should provide an affidavit to support its claim that.the material is cudulative--i.e.,
that the drafts include no material facts additional to those in the final report.
(In its affidavit, the Applicant *,ill set forth its basis for determining materiality.) Assuming the Applicant provides such an affidavit, we deny the requested production of documents.
(Ifthe Applicant cannot or will not provide the affidavit, we find that the necessarj showing of " substantial need" will have been satisfied and that the documents should be made available to Ms. Stamiris.)
2.
During the conference. call, we also discussed a dispute between Ms. Stamiris and the NRC Staff concerning the Staff's response
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to discovery req
- Jests. Ms. Stamiris has apparently not been able to obtain documents from the Staff through informal discovery. The Staff e
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cited tHW' broadness of the requests and the burden of compliance.
Hs. Stamiris claims that her reouests have'been considerably narrowed during the past week.
We approved the following procedures for settling t' is n
.fy dispute:
1.
Ms. Stamiris will provider her narrowed discovery request to the Staff, in writing, to be received by no later than Friday, April 8 (and by Thursday, April. 7 if possible).
2.
During the wtrk of April 11. Ms. Stamiris' counsel will
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meet with the Staff and negotiate concerning the narrowed request.
3.
The Staff will have in the Board's hands by Friday.
April 15, its response to those aspects of the discovery request which remain in dispute.
4 The Board will -review the request and response during the week' of April 18-22 and inform parties of its ruling no later than April 22.
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The parties should keep in mind the possible'effect of open discovery requests in scheduling particular witnesses.
3.
Mr. Stahl, informed the Board that the Applicant intends to i
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exercile the subpoenas previcusly issued by this Board on July 8,1982
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j for purposes of deposing nercers of the Government Accountability t
Project (GAP) concerning matters at issue in this proceeding that are alleged in confidential officavits to GAP; The Applicant reiterated that it does not seek to learn the identity of the confidential affiants t
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e to GAP aYthis ' time, but that it may move at a later date to learn the
.. names of. and depose, the confidential affiants. The Staff indicated that it had no objection to the Applicant's proceeding at this time to.
depose the GAP representatives prior to completion of the Staff investigation of the matters alleged in the confi,dantial affidavits.
The Board noted that two.of the. persons for whom it ha'd issued subpcenas had subsequently entered their appearance as counsel for Ms. Stamiris and that questions of privilege might be present with respect to certain areas of inquiry. The Board will resolve disputes of l
this nature if any such questions arise ~as a bsult of the depositions we have authorized.
IT IS 50 ORDERED.
FOR THE ATOMIC SAFETY AND LICENSING BOARD l
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Charles Bechhoefer, Chairman ADMINISTRATIVE JUDGE l
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The Staff understands this request to be for documents associated
- with the formulation of the program..
This listing of documents is through: March 25, 1983.
It does not include certain internal documents which are repetitive of infonnation contained in the documents which are included in the lf> E[jfCff 11 sting.
y = Coo g u'. tv h is = $ & 62 !?
1.
Ltr; J.W. Cook to J.G. Keppler and. H.R. Denton, dtd September 17, 1982, subject:
Independent Assessment, Pg. 4.
2.
Ltr; J.W. Ccok to J.G. Keppler andiH.R.Denton, dte September 17, 1982, subject: Additional Assessment Programs, Pg. 2.
3.
Ltr; J.W. Cook to J.G.Keppler and H;R.Denton, dtd October 5, 1982, subject:
Independent Review Program.
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Memorandum T.M.; Novak to RtH..Vollmer, dtd October 7,1982, subject: Independent Review Program - Midland Units 1 and 2.
5.
Ltr; B.Pi Garde to J.G. Keppler and H.R. Denton, dtd October 22, 1982, subject:
Independent Review Program.
6.
Memorandum to Docket from D.5.. Hood, dtd November 8,1982, subject: Sumary of October 25, 1982 Meeting on Independent Design Verification Program.
7.
Ltr; B.P. Garde to J.G. Keppler and H.R. Denton, dtd November 11, 1982, subject: Independent Review Program.
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Ltr; J.E. Brunner to W.D. Paton, dtu November 8,'1982, subject:
Stone and Webster.
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Memorandum to Docket from D. Hood dtd November 22, 1982, subject: Summary of November 5,1982'Neeting en Independent Assessment of Auxiliary Underpinning.
1D. Ltri J.W. Cook to J.G. Kappler and H.R. Denton dtd December 3, 1982, subject: Midland Plant Independent Review Program.
- 11. Ltr; J.W. Cook to J.G. Keppler, dtd December 6,1982, subject:
Third Party Independent Assessment.
- 12. Ltr. J.G; Keppler to B.P. Garde, dtd December 14, 1982, subject: Third Party Design Review.
- 13. Analysis of Consumers Power Company's Proposed Construction Completion Plan By the Government Accountability Project Citizens Clinic on behalf of the Lone Free Council. presented to the NRC at Midland, Michigan, February 8,1983, prepared by B.P. Garde.
14 Ltr; H.A. Levin to J.G. Keppler and DIG. Eisenhut, dated February 9,1983, forwarding Revision 1 of Tera Corporation's Project Quality Assurance and Engineering Program Plans for the Midland Independent Design and Construction Verification Program.
- 15. Memorandum to Docket from D. Hood dated February 22, 1983 docketing.
H. Levin letter of February 9.1983.
- 16. Ltr; H.A. Levin to J.G. Keppler and DJG. Eisenhut, dated February 17, 1983, subject: Midland. Independent Design Verification Program, and forwarding Revision 2 to the Project I
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Quality Assurance Plan.
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17 Memorandum to Docket from D. Hood dated February 23, 1983 docketing H.A. Levin 1tr of February 17, 1983.
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- 18. Memorandum to Docket from from D.H6od dated March 2,1983 l
docketing two pages omitted from memorandum of February 22, 198'3.
- 19. Ltr; 8.P. Garde to J.G. Keppler datedi March 10, 1983
Subject:
j Construction Completion Plan.-
- 20. Memorandum T.M. Novak to R.J. Mattscrr, R. Vollmer, R.G.
i Warnick, J.M Taylor, F. Speis; dated March 11, 1983;
Subject:
Request for Review of Tera's Engineering Program Plan and Project quality Assurance Plan for Midland Independent Design and Construction Verification Program.
- 21. Ltr; H.A. Levin to J.G. Keppler and D.G. Eisenhut; dated March 18, 1983 forwarding additional information on Midland IDCV Program regarding independence, qualifications, scope, reporting and status.
- 22. Memorandum to Docket from D. Hood dated March 21, 1983 docketing
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H.A. Levin 1tr of March 18, 1983.<.
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- 23. Ltr; H.A. Levin to J.G. Keppler and D.G. Eisenhut; dated March 18, 1983 forwarding information. on independence and j
qualifications with respect to independent overview of the j
Midland Construction Complet. ion Plan.i
- 24. Ltr; D.G. Eisenhut to J.W, Cook, dated March 22, 1983, subject:
j Selection of Additional System for. Midland Plant Independent f
Design and construction Verification Program.
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- 25. Transcript of NRC Commission Meeting /Public Meeting on March 14, 1983 regarding briefing on interim independent design verification program.
- 26. Ltr; B.'P Garde to D.G. Eisenhut, dated March 7,1983 commenting on February 8,1983 Meeting and Construction Completion Program.
- 27. Memurandum to Docket from D.Hoodidated March 14, 1983 docketing B.P. Garde ltr of March 7.1983.
- 28. Ltr; J.G. Xeppler to B.P. Garde-dated March 25, 1983, subject:
Response to Letter of March: 10, 1983.
- 29. Ltri J.G. Keppler to J.W. Cook dated Fe.bruary 24, 1983 approving Stone and Webster to perform independent assessment of soils remedial work activities and requesting expanded scope.
- 30. Ltr; J.W. Cook to J.G. Kepp.ler dated February 11, 1983, subject: INPO Self-Initiated Evaluation.
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hotice of Significant Licensee Meeting on February 8,1983 to 9
discust Midland integrated Construction Completion Program and I
third party assessment effort.. dated January 11, 1983.
- 32. Ltr; J.G. Keppler to J.W. Cook acknowledging receipt of January 10, 1983 ltr and confirming meeting of February 8, 1
1983.
- 33. Ltr; E. Adensam to H. Levin. dated March 23, 1983, subject:
Service List for IDCV Program Correspondence.
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All of these documents e:: cept those preceded by an asterisk (*) are j
available in the local public document room in Midland, Michigan and in the public document room in Washington, D.C.
Those documents preceded'by an asterisk (*) are enclosed.
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Harold R Denton, Director Of fica of Nuclear Reactor Regnistion Division of Licensins US Nuclear Reguistory Cc==ission Wsshing:en. DC 20555 J G Xeppler Adninistration, Region III US Kuclear Regulatory Co= mission 799 Rocaevelt Road Glen Illyn, IL 60137 HIDLAND NUCI2AR CCGENI?ATION PLuiT MIDLAND DCC"GT NOS 50-329, 50-330 NIDI.AND ?LANT INDEPENDINT P3VIIW' PROGRAM FILE: '31.1.5 SERIAL: 19750 Pl?I?2NCE3: (1) J V COCX IITTER To E R DENTON AND J G IEPPIER, SIRIE 18879 DATED 10/5/82 (2) NRC SW.ARY DATID 11/8/B2 CT 10/25/32 EEETING ON INDEPINDE'fr DESIGN W3IIICATICN Referanca (1) provided a description of the Mid1 tad Plant Independent Review Referenes (2) su.wsarized the October 25, 1932 tseeting wherein Prosram.
consu:sers Power Co pany and their contractors, Management Analysis Coepany -
(MAC) sad Tera, discussed in more detail'the Independent Reviev Progran.
Duri;23 this meeting, questions posed by the Staff were responded
- to by the Ceepany and its' contractors.
At the end of the meeting, Censumers Power Company req'uested the Staff to p; ovide the applicant with policy $.uidance on the proposed Independent Raview Program. The Staff agreed to provida preliminary feedback to Csnsu=ers Power 29,.1982 and to arrange for additiccal meetings as deemed Co=pany by October This was subsequently done and an additional meeting was held on appropriate.
hovember 5,1982 to provide tha !GR St.aff core details of the Stena and Webster third party assessment of the implecentation of tha soils underpinning-verk.
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Based up:n the meeting of October 25, 1982 and subsequent f andback fro.:- the NRC Staff, Co'nsumers gover proposes the followin2 changes to tce Independent Review p:ogram as subsitted in Rafarenes (1) and discussed at the October 25, 1952 coe-ing:
(1) The th se specific evaluativas will not be combined into a single progrom with coordination of the individual :spo:ts by 21AC.
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(2) The Tera Indayendent Design Verificatica (IDV) effort vill ha completa17 separate from tus MAC effort wi-J neither subcontracter hanng cembers f:om their compacy involved in the other company's efforts.
The Te s IDV will be on the Auxiliary Feedwater Systa: ( WJS) as (3) originally planned, and.will also be implacanced en another tystem which the Staff is to select based on three candidates provided by Const=srs Povar Cocyany on a risk assessment basis. The three candidata systems proposed by Consu=ars Power Company are:
Electric Power System (Diesel Canara:or) a.
b.
Safeguards Chilled Wate: System c.
Contaicment Isolation System (4) Tha Ters IDV vill be expanded to include a core in-depth review of construction activities to provide assur:.n=e of as-built construction adequacy of the systems included in the Ters (ILV).
(5) For the IDV, any discussions' batveen project persen=e1 and Ts:s on confirmed findings vill take place in formal e.seti=gs with the tGC being notified of the noetings in time to attend, if they desire.
(6) For the INPO Construction Project Evaluation, a copy of the fir.a1 report will be given to the NRC when it is sent to I.VPO.
We believe that this letter documents the conclusions reached betvaan our l
organizations regarding -Je Midland Independent Reviav.
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CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASL3 EMCherry, Esq FPCowan, ASL3 RJCook, Midland Resident Inspector
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SGstler, Esq JIfarbewe, ASL3 GHsestesd, Marstead Engineering oc1132-02722100
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- bi ed61rnon Conswuers Panasse's Speakaus asyset for the son GaMnse Consumers Power Company today announced new dates for the completion of the Midland Nuclear Cogeneration Flant and a new cost estimate for the. project.
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The coupletion of Unit 2 the plant's lead wait, will be shifted by 14 months from late July 1983 until the first of October 1984.
The coimmercial operation date will likewise shift by 14 months, until February 1985.
The Unit 1 fuel load date is now February 1985, a change of 13 months and its cosmeercial operation date is projected for August 1985, a change of 12 nonths.
The cost of the project is nov estimated at $4.43 billion.
The new cost and schedule were announced this a f ternoun in Jackson at the Company's annual meeting by John D. Selby, chairzan of the board. A press confer-ence was held in Jackson following the meeting.
Selby said the principal reasons for the changed schedule were tne auxiliary building underpinning program and the remaining work to complete the plant and implement revised quality ceintrol and quality assurance programs to meet require-mente and expectations of the Nuclear Regulatory Cosumission...
In remarks to the media, Vice President James W. Cook seide
- j.,.... O "The develooseent of the new project schedule is the result of a complete analysis of project status and the evaluation of our plc...iing and work performed over the past several years.
Our previous schedule was set in. June 1980 and at that time we projected Unit 2 fuel load in July 1983. Many of the conditions we evaluated at that time have changed significantly and our new data reflects i
our re-analysis.
The most significant single factor tied to protect completion 1s the rev=ed i al soils work on s i t e,.
The evolution of regulatory review and construction status of this activity has developed into the pacing ~ item pl a nt,-g:ompleti on. "
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' Site Manager Don Miller said that the Company staff that wi!! eperate the plant Is almost fully assembled and is supporting testing and preoperations!
pr ogr ams.
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"The eeployees at Midland have shown their dedication and conuitment to i
support successful completion and plant operation and their continued "Mforts
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will be evident in the final phases of co pleting the project," he said. ~,
"We have a procedure in, place whereby we. request authorir'ation free the NRC, t o proceed with soils work activities.
For those activities authorized, we have reached and sustained excellent production rates and have proven we can have an e f fective quality prograe overseeing the soils work.
Six of the 57 temporary piers have been or soon w!!! be conpleted.
k*e have requested author-c inscion on ' additional work. There remains a great deal of work to be done with the remedial so81s program, but we have not experienced any unexpected problems i
with work accomplished to date."
4-12-83 j
9 Consumers Power James W Cook Company vic. r, is. - e i... s.ri..
.s and Constru. tion
,oeneral offices: 1945 West Perne!t Roed, Jackson, Me 49201 e (517) 788 o453 i
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3 September 17, 198 PRINCIPAL STAFF
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ra Harold R Denton, Director p.
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US Nuclear Regul,atory Commission t f;$g g-Washington, DC 20555
..... 3 James G Keppler A--
Regional Administrator US Nuclear Regulatory Commission ReF on III i
79L Roosevelt Road Glen Ellyn, TL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT MIDIAND DOCKET NOS 50-329, 50-330 OUALTTY ASSURANCE PROCRAM IMPLEMENTA :0N FILE: 0485.lf. SERIAL:
1663u
REFERENCE:
CPCo Letter Serial 18845, 9/17/82, " Quality Assurance Prograai Implementation for Soils Remedial Work" The referenced letter summarized Consumers Power Company's discussions with the NRC management regarding the implementation of the Quality Assurance Program for the Midland soils remedial work. In addition to the discussions specifically related to soils, the total Midland Quality Assurance Program implementation was reviewed and areas were identified where additional efforts should be directed to insure successful overall project implementation and the performance of the primary inspection function (QC) on site. In response to these concerns Consumers Power mad, two significant new commitments which are conceptually described in the following paragraphs. Additional documentation will be provided as the details of these commitments are worked out.
Quality Control Function l
i In order to improve the performance of the Quality Control function and to make it more responsive to direction from the Quality Assurance organization, i
the responsibility for directing the entire Quality Control function will be i
assumed by Consumers Power. The Quality Control group will functionally report to MPQAD. The programmatic aspects now in place will continue to be used and the combined inspaction resources of both Bechtel and CPCo w'ill be I
integrated. This reorganization will be fully implemented as soon as the appropriate procedur.1 changes are finalized. The integration of the QC i
l resources for soils into MPQAD has already been accomplished as a separate j
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Independent Verification - Total Project l-Consumers Power proposes a new and expanded approach for verifying the overall l
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quality of the project. This approach will'give a broader overview than the assessments currently being recommended by the NRC for other NTOL plants. The 4
assessment which is suggested for Midland is to combine an INPO type j'
construction project evaluation, which is a broad " horizontal" type review of many aspects of current project operations with the detailed " vertical slice" i
review of all aspects, current and historical of a critical plant system or subsystem. The entire review will be performed by one or more independent contractors who are currently being selected. With the assistance of the selected contractors, the detailed plans for this extensive independent i
assessment will be finalized and presented to NRC management shortly for their concurrence prior to initiating the major work activities.
The INPO portion of the program will be initiated ism diately at.least through the planning phase to comply with the INPO schedule aad industry commitments to the NRC. The INPO construction program evaluation for Midland will differ j
from the majority of the industry's self-initiated evaluations in that an independent contractor rather than utility personnel will carry out the INPO evaluation. The results will then be overviewed by the INPO staff to assure adequacy and consistency with other evaluations.
Additional Assessment Programs 7
In addition to the above, Consumers Power has proposed to retain a qualified third party for an assessment of the underpinning activities as detailed in the referenced letter.
l Consumers Power Company has also initiated other appraisals to assess the adequacy of the Quality Assurance Program..Two major recent examples of this j.
practice that have occured are as follows.
4 In 1981, Management Analysis Company (MAC) conducted an assessment which j
focused on performance in three major areas as follows:
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Adequacy and timeliness of both part nd process corrective actions taken on a sample of the historical hardware problems that have been identified at Midland over its lifetime.
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The degree to which the physical characteristics of selected supplied components and parts meet their respective quality requirements.
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Th'e overall adequacy of the Quality Assurance Program with'particular 4
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documentation review efforts and personnel qualifications.
This assessment has been completed, the results were positive and all'open i
items have been resolved and closed. The final report has been previously l
t submitted to the NRC.
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l A Bechtel Corporate Staff project evaluation was initiated in April 1982. A report on the results of this assessment is being finalized at this time. The i
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l purpose of this evaluation was to review the Midland engineering activities to detarmine if design criteria have been Laplemented and if the design, j
assumptions, design methods, and the design processes are satisfactory.
Bechtel Corporate Management was asked to initiate this assessment in order to certify that the Midland project met all the standards expected of any Bechtel project. To carry out this assignment the assessment team was specifically chosen to be independent from the Bechtel Ann Arbor Power Division. The team consisted of senior experienced personnel with appropriate expertise having previously performsd similar work on other projects. A Consumers Power representative was a direct participant on the assessment team. The final report will be sent to the NRC upon completion and whatever other documentation or discussion as may be requested will be provided.
Conclusion Based on the (1scussion outlined above and in the reference letter, Consumers Power believes that steps have been caken to insure both the successful implementation of the remaining work to complete the plant and a verification program, including quality records, test program results, and third party assessments, that will certify the adequacy of the plant as constructed.
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CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB
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RJCook, Midland Resident Inspector
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RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harste'ad Engineering DSHood, NRC (2)
DFJudd, B&W JDKane, NRC FJKelley, Esq RBlandsman, NRC Region III l
WHMarshall l
JPMatra, Naval Surface Weapons Center W0tto, Army Corps of Engineers WDPatton, Esq SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers e
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oc0982-4024a-66-100 I
4 CONSUMERS POWER COMPANY j
Midland Units 1 and 2 Docket No 50-329, 50-330
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Letter Serial 18850 Dated September 17, 1982 i
At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as as. ended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits information regarding the implementation of the Consumers Power Company Quality Program for the Midland Plant.
1 CONSUMERS POWER COMPANY By
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JW ok, Vice President Project Engineering and Construction Sworn and subscribe.d before me this day of e
./,as Notary Public Bay County, Michigan My Commission Expires 7' - r/ -
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Vice President - Projects, Engsneering end Construction Generei Offices: 1945 West Parnali Road, Jeckson, MI 49201 e (517178&o453 eptembe [r17, 1982 i
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US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PIANT MIDLAND DOCKET NOS 50-329, 50-330 QUALITY ASSURANCE PROGRAM IMPLEMENTATION FOR SOILS REMEDIAL WORK tile: 0485.16 SERIAL: 18845 This letter summarizes recent discussions with NRC management regarding implementation of soils remedial construction and presents the Company's documentation of those discussions.
BACKGROUND The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co.
Follow-up discussions with the NRR staff and Region III Inspectors led to the conclusion that the Quality Assurance Program and its definition was adequate; however, there was concern that certain aspects were not being or might not be satisfactorily implemented.
l Consumers Power has performed an in-depth review of the implementation plans l
for the Midland soils work activities. This review included the areas of l
design and construction requirements and plans, organization and personnel, I
project controls and management involvement. The results of this review and I
the proposed steps to assure the successful implementation of all aspects of the work were discussed with the NRC management in a meeting held in Chicago l
on September 2, 1982.
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STEPS TO IMPROVE IMPLEMENTATION i
A number of new steps have or are being taken by Consumers Power Co to enhance 4
the implementation of the quality progran with regard to the soils remedial work. These measures touch upon all aspects of the work, from design to post-l construction verification and include the following:
4 (1) Retaining a third, party to independently assess the implementation of the auxiliary building underpinning work; (2) Integrating the soils QA and QC functions under the direction of MPQAD; (3) Creating a " Soils" project organization with dedicated employees.nd single point accountability to accomplish all work covered by the ASLB order; (4) Establishing new and upgraded training activities, including a special quality indoctrination program, specific training in underpinning activities, and the use of a sock-up test pit for underpinning construction training; (5) Developing a quality improvement program (QIP), specifically for soils remedial work; l
(6) Increasing senior management involvement in the soils remedial project through weekly, on-site management meetings wherein both work progress i
and quality activities are reviewed; (7) Improving systems for tracking of and accounting for design commitments.
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What follows is a description of the soils implementation plan, as it will be 3
carried out using the new approaches outlined above, together with other specific aspects which we believe will be criticial to the successful performance of the job. The discussion is limited to the implementation i
features specific to soils, is divided into areas roughly describing the
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progression of the job from design to completion and ends with a description of organizations, management involvement and NRC overview.
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1 DESIGN ADEQUACY AND IMPLEMENTATION
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The design for the required remedial activities is in an advanced state; l
design details and adequacy have been reviewed by numerous organizations. A special.ACRS Subcommittee reviewed the soils activities and commented favorably on the thoroughness and conservatism of the review and remedial approaches. Numerous submittals to the NRC have been presented to' clarify the i
design intent. It is our understanding that the Staff is completing its l
detailed review of all design aspects 'and is in the process of issuing an SSER. This advanced state of design has permitted the early development of a thorough planning effort and assisted in the organization and development of a detailed training effort. Following-up on. design activities, the Project has assigned to the site a design team comprised of experienced structural and geotechnical engineers under the Resident Engineer. This team will monitor f
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l and review the field implementation as specified in design documents, resolve on a timely basis routine construction questions requiring engineering I
i response and administer the specific contingency plans _immediately if any
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problem should arise during the underpinning work. Additional engineering i
resources for the soils work will continue to be located in Ann Arbor.
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IMPLEMENTATION OF DESIGN FEATURES AND COMMITMENTS All soils activities covered by the ASLB Order of April 30, 1982 are covered j-under soils-specific QA plans. These plans require that appropriate procedures are in place to accomplish the work in a quality manner and that i
detailed inspection plans be developed and utilized. Additionally, a Work j-Authorization Procedure and Work Permit System insure that the NRC and CP Co have specifically authorized and released the work. Under this system, the i
NRC reviews proposed work details, asks for additional information when f.
necessary and authorizes construction activities in advance. CPCo then authorizes the work to proceed.
i To further assure that commitments made to the NRC are properly accounted for a
in design documents, Consumers Power and Bechtel review the.-itten records of commitments and insure that they are being incorpor..ted into d esign documents.
The Project is currently undertaking an additional review of past correspondence to create a computer listing of commitments. This computer j
list will be periodically reviewed to insure that commitments are incorporated in design or construction documents in a timely fashion.
l PERFORMANCE OF PROJECT CONSTRUCTION, QUALITY ASSURANCE AND QUALITY CONTROL j
ACTIVITIES To assure that project construction, quality assurance and quality control personnel correctly carry out their appointed tasks, a number of measures have t
been taken, including a reorganization of quality control, upgraded training l
programs, direct Company involvement in construction scheduling and control, l
and utilization of a. contract format to minimize any cutting of corners by contractors. These elements of enhanced performance are described more specifically below.
l First, the project has reorganized the Soils QA-QC effort, creating an j
integrated organization with single point quality accountability under the l
MPQAD. This new organization is expected to improve QC performance, increase p
CPCo involvement in the management of-the quality control function and improve-i QA-QC interfaces.
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i Second,- extensive training programs for the soils underpinning work have been-I developed. This overall training program, which includes the major l
Construction and Quality organizations involved in soils work, covers both general training in quality and specific training' relative to the construction procedures.
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The majority of the personnel associated with Remedial Soils work have
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attended a special Quality Assurance Indoctrination Session. The QA
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indoctrination has been provided to Bechtel Remedial Soils Group, CPCo l
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Construction, QC, QA, Mergentime and Spencer, White and Prentis (SW&P) personnel down to the craft foreman level. This training consists of one three-hour session covering Federal Nuclear Regulations, the NRC, Quality Programs in general and the Remedial Soils Quality Plan in detail.
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With regard to the work procedures, a requirement on both Mergentime and SW&P l
is that specific training on the procedures be provided prior to initiating j
any qinality related construction activity. The identification of individuals to receive this training is spelled out in each procedure pertaining to a specific construction activity. Completion of the specific training requirements is a QA hold point which must be satisfied oefore work can proceed.
i In further recognition of the importance of training to the underpinning work, the Company is utilizing a mock-up test pit as part of its training program for underpinning construction. The purpose of this test pit is to provide specific training in the construction of a pier, bell and grillage assembly from initial issuance of design drawings through completion of construction.
This allows supervisory and craft personnel to perform work under the l
conditions, requirements and restraints which will be encountered when the actual underpinning starts. It also allows the various quality organizations l-to inspect the work and insure that their concerns and requirements are i
properly reflected in the procedures.
h Third, to further enhance the performance of key project organizations, Consumers Power will maintain control over scheduling, both through the 3
l construction authorization process and by frequent meetings with the involved contractors and subcontractors. Each week, underpinning subcontractors will j
present proposed construction work to the Company. In addition, to assure the best quality work, the major subcontracts were entered into on a time-J material basis. This should improve subcontractor attention to detail and i
j acceptance of owner direction in the performance of specific construction activities.
I Last, the Company is establishing a separate Quality Improvement Program (QIP) for the soils project. Although not part of the formal Quality Assurance program, the QIP is a management system that should be helpful in communicating and reinforcing project policies and expectations to all project i
participants. To launch this effort, an indoctrination program will be i
i presented to all individuals, stressing the absolutes of Quality and the l
concept of "Doing it right the first time." Measurements specific to soils will be developed for those critical areas which are indicative of a " quality product". Tracking these activities will provide an indication of the l
effectiveness of the program. The QIP will provide mechanisms for individual j
" feedback" from all individuals involved, including the craft personnel.
6 INDEPENDENT ASSESSMENT t
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A third party will be retained to independently appraise the initial phases of the construction of the auxiliary building underpinning. This consultant will i
be mobilized as soon as possible and, after familiarizing itself with the design, will evaluate the auxiliary building underpinning construction work at t
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5 the site. If significant problems or adverse trends are observed, the third party assessment program will be extended in both scope and duration until a satisfactory conclusion can be drawn. The initial evaluation will be carried out over a three-month period.
The independent assessment will be conducted by a team of nuclear plant construction and quality assurance experts. This team will.' supplemented by i
the additon of an underpinning consultant who will review the soils design documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consistent with industry standards. The assessment will further assure that the QA Program is being implemented satisfacto-ily and that the construction is being implemented in accordance with the cons *ruction documents.
Arrangements are being made with Stone and Webster Engineering Corp to assume the lead role in this appraisal. They will be assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc who will provide underpinning expertise.
The NRC will be apprised of all findings of this independent assessment in a timely manner.
ORGANIZATION, MANAGEMENT INVOLVEMENT AND NRC OVERVIEk' The project organization formed for the performance of the soils remedial work incorporates single-point accountability, dedicated personnel to the extent practical, minimum interfaces-particularly at the working level, and a quality organization integrating QA and QC. The soils project organization is tailored to the task at hand. The entire organization, including quality i
assurance and quality control are staffed with well qualified, experienced personnel, augmented by design consultants and construction subcontractors nationally recognized in the underpinning field.
The soils remedial effort will also include a high level of senior management involvement. Project senior management will conduct weekly in-depth reviews on site of all aspects of the work ir.cluding quality and implementation of commitments. In addition, the reporting chsins to the senior project personnel have been shortened. The Company's CEO is briefed on a regular i
basis and schedules bi-monthly briefings on all aspects of the project i
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including soils. During the bi-monthly briefings, the CEO normally tours the j
Midland site.
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Complementing the CPCo management role, NRC Region Management overview of the j
construction process will be enhanced by monthly meetings, agreed upon by the Region, to overview the results of the quality program and the progress of the soils project. These meetings will cover any or all aspects of the project of general or special interest to the NRC management.
CONCLUSION
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Based on the discussion outlined above, CP Co believes that the soils program has been thoroughly and critically evaluated and that all prerequisites for l
successful implementation have been or are being accomplished. The Company's l-program, with the initial overview from the independent implementation j
assessment, and the continuing overview by the NRC staff and management should I
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provide adequate assurance that the remedial soils activities will be successfully completed.
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CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harstead Engineering DSHood, NRC (2)
DFJudd, B&W JDKane, NRC FJKelley, Esq RBLandsman, NRC Region III WHMarshall JPMatra, Naval Surface Weapons Center W0tto, Army Corps of Engineers WDPatton, Esq SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers BStamiris
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CONSUMERS POWER COMPANY Midland Units I and 2 Docket No 50-329, 50-330 Letter Serial 18845 Dated September 17, 1982 i
i 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 Commission's Rules and Regulations thereunder, Consumers Power Company submits information regarding the implementation of the Consumers Power Company Quality Program for the Midland Plant soils remedial work.
CONSUMERS POWER COMPANY By b
J 1p/ Cook,"Vice President Projecars, Engineering and Construction
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i Sworn and subscribed before me this /'/a day of,, g /9_E4 d
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Bay County, Michigan My Commission Expires 5'- F- ((
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UNITED STATES e
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MEMORANDUM FOR: Region III Files FROM:
Rotrert F. Warnick, Acting Director, Office of Special Cases
SUBJECT:
MEETING BETWEEN NRR AND REGION III RE CONSUMERS POWER COMPANY PERFORMANCE AT MIDLAND (DN 50-329; 50-330) i On July 26, 1982, R. F. Warnick and James G. Keppler met with E. G. Case, D. G. Eisenhut, R. H. Vollmer, R. O. Tedesco, T. H. Novak, W. D. Paton, and J. Rutberg to discuss the performance of Consumers Power Company at the Midland site.
During the meeting reference was made to information contained in two memos from the RIII staff. The first memo dated June 21, 1982 is from C. E. Norelius and R. L. Spessard and concerns suggested changes for the Midland Project. The second memo dated July 23, 1982 is from R. J. Cook and concerns the licensee's performance at Midland. Copies of the memos are attached.
The meeting resulted in the following recommendations:
1 (1) Region III should obtain the results of the recent audit by KMC'.
(2) Schedule a public meeting between NRC and CPC management in Midland, Michigan, to obtain licensee commitment to accomplish (3) and (4) below.
(3) The licenses should obtain an independent design review.
(A vertical slice from design thru completien of cocetruction.)
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i (4) The licensee should obtain an independent third party to continuously monitor the site QA implementation and provida periodic reports to f
the NRC. Region III is to provide a suggested outline for the contin-4 uous monitoring function.
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Robert F. Warnick, Acting Director Office of Special Cases l
Attachments: As stated l
cc w/ attachments: Meeting-participants l
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UNITED STATES j
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NUCLEAR REGULATORY COMMISSION 3-
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GLEN ELLYN,ILLINol$ 60137 June 21, 1982 f
l MEMORANDUM TOR: James G. Keppler, Regional Administrator i
FROM:
C..E. Norelius, Director, Division of Engineering and Technical Programs R. L. Spessard, Director Division of Project and Resident Programs
SUBJECT:
SUGGESTED CHANGES FOR THE MIDLAND PROJECT i
I Historically, the Midland Project has had periods of questionable quality assurance as related to construction activities and has had commensurate i
regulatory attention in the form of special inspections, special meetings.
and orders. These problems have been given higher public visibility'than most other construction sites in Region III. As questions arise regarding the adequacy of construction or the assurance of adequate construction, we are faced with determining what regulatory action we should take. We are again faced with such a situation.
Current Problem The current problem was caused by a major breakdown in the adequacy of soils work during the late 1970's. Because of the increased regulatory attention given the site, we expect that exceptional attention would be i
given to this activity and that licensee performance would be better than other. sites or areas which have not had such significant problems and i
therefore have not attracted this level of regulatory attention. However, that does not appear to be the case and Midland seems to continually have more than its share of regulatory problems. The following are some of the specific items which are troublesome to the staff.
Technical Issues 1.
In the remedial soils area, the licensee has conducted safety related
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activities in an inadequate manner in several instances - removal of dirt around safety related structures, pulling of electrical cable, i
I drilling into safety related utilities.
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In the electrical area, in trying to resolve a problem of the adequacy
-i of selected QC inspectors' work conducted in 1980, the licensee 3
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greater significance than we would attach to similar findings).
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In the pipe support area, in trying to resolve a problem of the adequacy of QC inspections conducted in 1980, the licensee has portrayed only a small percentage of defects of " characteristics" identified and has not addressed the findings in terms of a large percentage of snubbers which may be defective because of the charactoristics within each snubber that may be defective (e.g., if l
only one characteristic was defective out of 50 reviewed on a single hanger, the percentage is small; but if the one defective characteristic makes the hanger defective the result would have a much greater significance level). The licensee had done a detailed statistical analysis in an attempt to show that the small percentage of characteristics were found rather than broadly approaching the problem with significant reinspections to determine whether or not construction was adequate.
j Communications h,
Multiple misunderstandings, meetings, discussions, and communications seem to result in dealing with the Midland Project. Some examples are:
1.
NRC staff attending a meeting in Washington on March 10, 1982, heard the Consumers Power Company staff say that electrical cable pulling related to soils remedial werk was completed. It was determined to be ongoing the next day at the site.
2.
When Region III attempted to issue a Confirmatory Action Letter, 4
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J. Cook informed W. Little of his understanding that both J. Kappler I
and H. Denton had agreed that the subject of the CAL was not a I
safety related item subject to NRC regulatory jurisdiction. Such l
agreements had not in fact occurred and following a mee;ing, Consumers l
Power Company issued their commitments in a letter to Region III.
i 3.
In reviewing a licensee May 10, 1982 letter, responding to the Board Order, the NRR staff had an unsigned letter and Region III had a signed copy both dated the same date but differing in content.
4.
Recently a Region III inspector in closing out and exiting from his inspection described the exit meeting as being the most hostile he j
had ever participated in.
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The responses to any Region III enforcement letters issued to Midland are more lengthy and 3EJ argumentative than are any other responses from any other licensee in Region III. This point was made in the SALP response provided by Midland,and the SALP response in itself from Midland is an example of the type of response which we commonly receive from the site.- The length of the response is at least as long'as the initial SALP report.
6.
Multiple requests for briefing meetings and other statements by the utility to the effect that we should review procedures in developmental 1-stages imply that Midland wants the NRC to be a part of their construction program rather than having us perform our normal regulatory function.
Staff Observations 1.
With regard to corrective actions of identified noncompliances, the Midland response seems to leen towards doing a partial job and then writing up a detailed study to explair why what they have done is sufficient rather than doing a more complete job and assuring 100%
corrective action has occurred. In the detailed writeups that are prepared, it is the staff's view that the licensee does not always represent the significance properly,and the analyses and studies often raise more questions than they solve; thus time appears to have been wasted in writing an analysis rather than in fixing the problem.
j 2.
Midland site appears to be overly conscious with regard to whether e
or not something is an item of noncompliance and spends a lot of effort on defending whether or not something should be noncompliance as opposed to focussing on the issue being identified and taking corrective action. This appears in part to be due to their sensitivity of what appears in the public record as official items of noncompliance.
i This sensitivity may have resulted from the extended'public visibility which has attended construction of the facility. The staff's view is that the Midland site would look better from the public standpoint and be more defendable from NRC's standpoint, if they concentrated on fixing identified problems rather than arguing as to the validity of citations.
This type of view was expressed by the utility during a recent effort to clarify in detail that certain construction items on the soils remedial work should not be subject to NRC's regulatory action.
3.
The Midland project is one of the most complex and comp 1'mpted ever i
undertaken within Region III. The reason is that they are building two units of the site simultaneously and additionally have an underpinning construction affort which in itself is probably the equivalent of building a third reactor site. The massive construction effort and the various stages of construction activity which are involved make the site extremely comp 1f)ted'to manage. This activity appears to cause a lot of pressure on the licensee management.
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Mr. J. Cook, the Vice President responsible for the Midland site is an extremely capable and dynamic individual. However, thesa t
i characteristics in conjunction with the complexity and immenseness i
of operation as set forth in 3, above, may actually be' contributing i
to some of the confusion which seems to exist. The staff views that (1) he is too much involved in detail of plant operations and there are times when the working level staff appears to agree and be ready to take action where Mr. Cook may argue details as to the necessity for such action or may argue as to the specific meaning of detailed work procedures, (2) this kind of push may lead to such things as letters both signed and unsigned appearing in NRR and causing confusion, (3) this push may lead to some animosity at the licensee's staff level if NRC activities are looked on as slowing progress of construction at the site.
Recommendations It appears essential that some action be taken by NRC to improve the regulatory performance of the Midland facility. The following specific suggestions are nada.
1.
The company must be made aware and have emphasized to them again that their focus should be on correcting identified problems in a complete and timely manner.
4 2.
We should question whether or not it is possible to adequately manage i
a construction program which is as complex and diverse as that which currently exists at Midland. We would suggest specifically that the following activities be considered:
i s.
That the licensee cut back work and dedicate their efforts to i
getting one of the units on line in conjunction with doing the i
soils remedial work.
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That they have a separate management group all the way to a l
possible new Vice President level, one of which would manage the a
i construction of the reactor to get it operational and the second to look solely after the remedial soils and underpinning activities.
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3.
Consumers Power Ccapany should develop a design and construction verification program by an independent contractor. This would provide an important additional measure of credibility to the design and construction adequacy of the Midland facility.
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James C. Keppler 6/2/1/82 We vould be happy to discuss this with you.
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C. E. Norelius Director Division of Engineering and 4
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0, 799 ROOSEVELT ROa0 OLEN ELLYN,itLINO48 s0137 July 23, 1982 MEMORANDUM FOR:
R. F. Warnick, Director, Enforcement and Investigations Staff FROM:
R. 'J. Cook, Senior Resident Inspector, Midland Site
SUBJECT:
INDICATORS OF QUESTIONABLE LICENSEE PERFORMANCE - MIDLAND SITE l-I As per our conversation of July 21, 1982, the following is a list of those items that various inspectors consider to be indicative of questionable licensee performance:
1.
One of the leading items is the over-inspection performed on electrical QC inspectors which was done in response to NRC concerns idantified in the May 1981 team inspection. The licensee found weaknesses in the inspections performed by some electrical QC inspectors pertaining to not identifying the mis-routing of cables. This item culminated in an item of noncompliance. The licensee did not expaad the overview activity to a degree necessary for an acceptable resolution to the identified weak-ness - even after a meeting in RIII. Tl}is item has not been resolved to the satisfaction of the NRC although our position has been clearly defined.
s As a partial' response to the team inspection concern, the licensee presented the NRC with an audit report which would demonstrate a response to our con-cern of questionable electrical QC inspections. However, the audit report stated that it (the audit report) did not address the NRC concerns.
2.
During the dialogue for the underpinning and remedial soils work, a large amount of emphasis has been placed on the settling data for the structures involved. During a meeting in HQ on March 10, 1982, the need for QC reqaire-ments on remedial soils instrumentation were explicitly delineated. However, one week later, the NRC inspectors found soils work instrumentation instal-lation was started the day after the March 10, 1982 meeting without a QC/QA umbrellas that the licensee's QA Auditor and QA Engineering personnel were not approached pertaining to the.need for QA coverage for this soils settle-ment instrumentation that there were strong indications that the licensee had mislead the NRC in relating that the work was essentially complete when 9
indeed it was nots and presently, the licensee management informs our inspec-tor that items are ready for his review when in actuality they are not, our conversations with licensee personnel - other than management - cenfirm that the items are not ready for review.
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3.
Historically, one of the NRC questions has been, "Who is running the job - Bechtel or Consumers?" The following example would allow one to j
believe it is Bechtel: As a part of the resolution to our findings in 1 -
~l the soils settlement instrumentation installation, the NRC insisted that l
the licensee generate a Coordination / Installation Form to cover interface between different evolutions of instrumentation installation. The lican-see would call our inspector for his concurrance on the adequacy of the 3
form - the inspector would approve Consumers Power Company's form, but then would find out that Bechtel did not want to work to Consumer's form -
the form that was generated to resolve regulatory concerns. This event has occurred twice and was considered as a deviation during a more recent inspection. The opinion of the staff is that if Consmers generates a form that will aid them in not incurring regulatory difficulty, and which l
has had NRC input, the licensee should demand that the contractor comply j-with these policies instead of the contractor dictating the regulatory j
environment under which they will work.
f 4.
Deficiencies in material storage conditions has continually been a concern l
l to the NRC and has resulted in items of noncorpliance. To the inspectors, i
the ability to maintain quality storage is indicative of how rigorous or j
slipshod the constructor's attitude *is towards construction. The licensee j
has attested to entice the constructor to do better in maintaining the j
material storage conditions, but still the licensee's auditors and the l
NRC have negative findings in material storage conditions and negative j
discussions with the contractor.about the validity of the, finding.
5.
At periodic intervals, the support of cables, particularly in the control i
room area, which are awaiting further routing or termination, has met with j
the disapproval of the NRC inspectors. These discrepancies also include l
l cables without covered ends being on the floor in walk areas that are in j
j a partially installed status. This is also another indicator of slipshod l
workmanship which has been brought to the constructor's attention at various times, but was last noted during a recent inspection.
6 In the area of instrumentation impulse line installation and marking, the licensee has had separability violations which has required removal of all installed impulse lines. Also, the NBC, because of this and significant adverse operational conditions, insisted that the installed impulse lines be identified. Although the licensee plans to mark the impulse' lines, there was an inordinate amount of resistance to marking the lines - even though there had been instances of mis-matched channels because of iden -
tification confusion.
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1 R. F. Warnick 3
July 23, 1982
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I 7.
An example of reluctance in placing the responsibility for quality work-manship at the foreman and/or worker level has recently been identified.
4 The NRC inspectors'noted that some drop-in anchors were improperly instal-l led and obviously did not adhere to the installation procedures. The
)
licensee's attitude indicated this was not a valid finding because QC had 4
not inspected the item. The NRC inspectors treat this as indicative that slipshod workmanship is tolerated in the hopes that QC will find the mistakes.
l 8.
I. ate in 1981, the licensee decided to move the QA Site Superintendene into 3
i another position and cover this site function by sharing the site t
. be-tween the QA Director and the QA Manager. After a January 1982 meeting with the NRC at RIII, the licensee opted to fill the QA Superintendent spot with j
another person. In the spring of the year, the NRC inspectors were following up on welding allegations and approached the QA Superintendent. The QA j
Superintendent was familiar with the alleged poor welding and had established what the NRC inspectors determined to be a responsive plan to resolve the questionable QC welding inspe% ions. At the Exit Interview, the QA Director
)
did not appear to back the QA Site Superintendent's proposed plan which had j
tacit NRC approval. The NRC inspector classified in writing and with just cause that the Exit Interview was the most hostile exit interview he had j
j ever encountered.
9.
During a recent inspection, it was noted by the NRC inspector that fill dirt was piled and being covered with a mud mat at a nominal 1:1 horizontal to i
vertical slope when the specification called for a 1 31 horizontal to verti-cal slope. A constructor Field Engineer witnessed the wrong slope being installed and justified and defended the slope after being informed of the specification requirement. This is another example of the constructor having an attitude which precludes quality workmanship.
l 10.
Jedifferent times, NRC inspectors have experienced difficulty in getting j
information which is controlled by the contractor, such as supporting cal-culations and qualifying information to justify a given installation. A recent example is: the NRC inspector informed the licensee and the contrac-tor he wanted to see resumes of persons ?.nvolved in the remedial soils work.
There is an obligation to the NRC to supply a precise number of " qualified" persons on the soils work. The inspector was informed he could not get these l
roccrds as they were personal. The inspector ultimately did get the informa-1 tion after bringing it to the attention of licensee upper management. How-i aver, this indicates an isplied unwillingness of the constructor to share information with the NRC and somet.imes with the licensee.
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July 23, 1982 4
- 11. The licensee oftentimes does not demonstrate a " heads up" approach to i
their activities. The following are examples of the licensee operating in an environment using tunnel vision
" blinders".
[
1 a) During a recent NRC inspection, the inspector challenged the ability to maintain the proper mix ratio on high pressure grout. This was l
done after the inspector noted that the operator could never maintain the proper mix ratio without continual manual control - which was not available when the grout is applied. The licensee's apathetic atti-i tude did not allow them to stop the grout application until the next l
day when this became an issue at the exit interview.
j b) At one point in time, the company doing drilling on site for the remedial soils work cut into a safety related duct bank between the I
diesel generator building and the service water building. The Consu-mars Power Site Manager's Office (the production people) stopped work because - from a quality standpoint conditions were so deplorable.
However, the Site Manager's Office did not have responsibility in this i
area - the Midland Project QA Department had this responsibility and j
i did not invoke their authority to prevent the drilling work from get-ting out of control - or to bring it back into control..
j c) The NRC inspector recently witnessed the licensee setting up to drill l
a well hole in safety related dirt using a technique which was not i
authorized. If the inspector had not brought this to the licensee's j
attention, the licensee would have violated an Order addressing reme-l dial soils work and also the Construction Permit. When the licensee was queried as to the availability of the QC/QA personnel who would prevent such activity from happening, the NRC inspector was informed j
that this was (another) misunderstanding.
The NRC inspectors have been informed by our contacts on site that there 4'
are memoes written to the effect that " peripheral vision" thould be cur-tailed and communication with the NRC stiffled. The NRC has not read
}
these memoes yet - but plans to in the near future, provided they really exist and infer what we have been informed.
)
I 12.
The licensee seems to possess the unique ability to search all factions-of the NRC until they have found one that is sympathetic to their point of view - irregardless of the impact on plant integrity. Some examples of this are:
I a) The NRC soils inspector informs the licensee that soils stabilisation I
grout comes under the Q program. The lice.ases is not particularly l
l happy with this position. Unknown to the inspector, the licensee argues his point with NRR to have the grout non-Q = using only those
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arguments which support his (the licensee's) position. The licensee L
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July 23, 1982 t
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has the advantage of the NRC inspector'c technical and regdatory j
basis for supporting his (the inspector's) position, and therefore l
avoids mention of thic during the discussions with NRR. However, the licensee's QA program, which has already been approved by NRR, states that all the remedial soils work is Q unless RIII approves a l
relaxation on a case by case basis. It appears the licensee does not wish to acknowledge the prior agressents with the NRC.
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f b) Since the failure of auxiliary feedwater headers in asW steam genera-l t
tors, discussions have transpired between the NRC inspectors and the l
site personnel.' These discussions have indicated that the licensee j
i was maintaining a conservative approach and were entertaining the l
cencerns expressed by the NRC which were stimulatsd primarily by gross mistakes in attempting the mofification at operating Bsw plants. The licensee's corporate personnel were annoyed that the NR': inspectors i
would not give approval to start the modification until aR the pre-l paratory work had been accomplished as this would tend to impact the schedule and the modification to the steam generators could become a scheduling nuisance. The licensee corporate personnel contacted the NRC inspectors involved to " reason with them".
However, the corpor-ate personnel, (including a representative from Saw) were unable to j
answer the concerne of the NRC inspectors but did mention that the NRR operational Project Manager indicated that it was alright to proceed 1
with the modification. The licensee corporate personnel.could not state what the position of the NRR Construction Project Manager was on this issue - only that they had found some form of approval from same-i one in the NBC.
c) At times, when Immediate Action Letters or other forms of escalated i
j l
enforcement become imminent, the licensee attempts to " appeal" their i
case with individuals in the regional management who are removed from the particulars of the tentative enforcement action. The licensee at-l tempts to get these persons to agree to specific portions of the issue j
which would indicate that the licensee is "really not all that bad".
Nowever, the "real" issues, as identified by the NRC inspectors are being masked.
d) During inspections of the remedial soils work, the NRC inspector has i
been informed by the licensee that certain findings and areas of inspec-tion were not within the purview of his (the inspector's) inspection j
program because they were in essence considered non-Q and that by virtue of prior agreement with the Regional Administrator were escluded from enforcement action. Nowever, the NRC inspectors would subsequently find
}
that there was no such agreement between the Regional Administrator and the licensee - only a philosophical discussion as to what, in general terms, constituted an item of noncompliance.
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l-R. F. Warnick 6
July 23, 1982 j
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h above indicators support the reputation the licensee has for being j
i argumentative. Their apparent inability to accept an NRC position with-out diligently searching to find a " softened" position results in numer-ous hours of frustrated conversations between all parties involved to i
resubstantiate (usually the original position) a position based on tech-l nical and regulatory prudency.
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13.
h licensee has been classified publicly by the NRC as being argumenta-3 l
tive. The licensee continues to exhibit this trend, as evidenced by the i
following examples:
[
a) Essentially every item of noncompliance receives an argumentative j
answer which addresses only the specificity of the item of noncom-pliance and selectively avoids any concept which would support the essence for the item of noncompliance. For example - in the instance l
of the improperly installed drop-in anchor mentioned above, it was the fact that QC had not inspected the installation of the bolt which j
was important to the licensee. However, the real enforcement issue was that components were being improperly installed.
I b) The cycle II SALP made critical. evaluations of the licensee's perfor-i mance in several areas. The licensee's response to this SALP report i
was argumentative over specific details and did not seem to acknowl-
)
edge that the consensus of opinion of the NRC inspection staff was i
that there were areas where the licensee's performance was weak.' h licensee's argumentative position is in the form of "we really are not f
all that bad" when the records, findings and observations of the NRC l
inspectors support just the opposite position.
I c) h "Q-ness" of the remedial soils work has continually been an argu-l mentative topic of discussion which ultimately resulted in a NQ meeting on March 10, 1982. At this meeting, the "Q-ness" of the remedial soils 1
work was specified and later documented with the meeting minutes. Now-ever, the licensee did not wish to abide by this position and a subse-l quant meeting was held in RIII to further clarify the NRC position.
Still, the topic of "Q-ness" is being argued by the licensee, even though i
the ASLB has issued an Order further defining the "Q-ness" of the soils
?
work. It might be noted that a hearing is in process over this soils issue and the NBC's position on "Q-ness" has been expressed during these testimonies.
)
- 14. During a recent episode, the licensee wanted to continue excavation of soils in proximity to the Feedwater Isolation Valve Pit (FIVP). However, the licon-i see wanted to perform this evolution without determining that the temporary supports of the FIVP were adequate. Making this determination would have an impact on schedulins,'as stated by the licensee. The FIVP supports were f
f installed without a Q usbrella and subsequent inspections did reveal several l
discrepancies in the installation of the support structure.
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7 4-R. F. Warnick 7
July 23, 1982 1
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4 15.
During the limited remedial soils work which has transpired, the licensee l
has managed to penetrate Q-electrical duct banks, a condenser header drain line, an abandoned sewer line, a non-Q electrical duct bank and a 72-inch
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circulating water line. All of these occurances have happened because of j'
NRC as to the adequacy of review prior to attempting to drill, the N E a lack of control and attention to details. Whenever approached by the l
receives responses which strongly suggest that the time was not taken to 1
4 l
perform these reviews - perhaps taking this time would impact on the j
schedule.
16.
By virtue of an earlier ALAB order, the licensee is required to perform i
trend analyses for nonconforming conditions. These trend analyses have, l
in the past, masked the data such that obvious trends are not obvious and has resulted in negative findings by the NE.
This was addressed in one of the earlier SALP meetings. Decently, while performing a review of l
hanger welding data, the NBC inspector found that the statistical data had j
been diluted to the point that the number of unsatisfactory hangers could not be determined from the trend analyses or tha type and degree of non-4 conforming conditions which were being idantified pertinent to the hanger fabrication.
l
- 17. The licensee continually would use the N E staff as consultants and clas-7 sifies a regulatory and enforcement position as counter productive. This is reflected by the licensee not wishing to perform Q-work without obtain-ing NE prior approval and then addressing only those areas where the NE j
has voiced a regulatory concern - provided,it is convenient to the licensee.,
i This attitude has particularly prevailed in the remedial soils issue and to a lesser degree in the electrical installation areas. The preferred NE inspector mode would be for the licensee to generate his program to esta-1 j
blish quality and then the NK would approve or disapprove. However, the j
i licensee requires consultation with the NRC to establish his level of l
quality requirements.
i.
The above is not intended to be a complete list of all discrepancies which indi-
}
cate questionable licensee performance as this would require a more extensive j
review of the records and inspection personnel involved than time permits. Also, j-there has been no attempt to systematically document the enforcement and unre-j solved items list as these are contained in other information sources.- However, i
the listing is rather comprehensive of the types of situations and attitudes which l
prevail at the Midland site as observed by the NRC inspector staff.
1 l
When considering the above listing of questionable licensee performance attributes, j
the most damning concept is the fact that the NRC inspection effort at Midland has l
been purely reactive in nature for approximately the last year, and that these indicators are what have been observed in approximately the last six months. If i.
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July 23, 1982 these are the types of items that have become an NRC nuisance under a reactive inspection program, one can only wonder at what would be disclosed under a rigorous routine inspection and audit program.
Sincerely, l
1 i
6 R. J. Cook j
Senior Resident Inspector i
Midland Site Resident Office l
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cc W. D. Shafer j
D. C. Boyd i
R. N. Gardner R. B. Landsman B. L. Burgess i
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UNITEO STATES q
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NUCLEAR REGULATORY COMMISBeON
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asesomem feoseasoveLTRent
\\*ese etenettvu ettenessesser i
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i July 23, 1982 I
8 secoeuuanst rom
- a. F. unrnisst, Director, Enforcement and Investigations 4
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staff i
FEDIts
- a. J. Cook, sealer Resident. Easpector, Midland site s m7ECT:
ftIDICMCIIB Cr QUESTICIlhBLE LImm PERFOggWusCE - MIDEARE l
SITE i
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As per our conversation of July 21, 1942, the fo11 cuing is a list of those itmos that. varios inspectoss consider to be indicative of aguentionable licensee perfosmance:
1.
One of the 1=== Hag items le the over-inspection performed om electrical QC i ;ni- = which was done in respease to sinc comoerne identified in the May 1981 team inspection. The licensee found weaknesses in the /
', b.,.. 'Ydentifylad' thrata-routing"of eah onl~gC~laspectors' pertaining to a $
i-, risimo performed by. sons. el
-M, I
. This item culminated la an ites r...,..
of memonoplianos. The liconoce did a( empend the overview activity to i
l adegreenecessaryforanacceptableresolutieptotheidentifledweek-
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mess-evenafterameet1ElmRII).'Thisitanhasnotbeenresolvedto i
the satisfacties of the Inc although our position has been clearly defined.
i As a partial respamme to the team inspection concern, the licensee presented I
the unc with an audit report which would demometrate a response to our one-I corn of aguestionable electrical gc inspections. Bouever, the audit report j
stated that it (the endit report) did not address the NRC concerns.
t 2.
During the dialogue for the,underysaming' and iremedial. sella weg a large l
j amount. of emphasis has been placed on the settling data for the structures i
involved. During a meeting in leg en March 10, 1982, the need for QC require-l
[au 4 meets en remedial soile instrumentation were explicitly delineated. Bowever, 3 4.,,. e cl '.. one week later, the NRC inspectore found soila work instriemontation instal-lation was started the day after the March 10, 1982 meeting without a QC/gh
,,...y, umbrellas that the lioenece's QA haditor and QA Bigineering personnel were
', ', ^ " ' ' "
not appre e pertaining to the need for Qh coverage for this soils settle-ment imetriementations that there were struseg indications that the licensee j
had mislead the Isac la relating that the work was essentially complete when indeed it was mots and presently, the licensee menagement informs our inspee-ter that. items are reser for his review when la actuality they are not. Our conversations with licensee paroonns! - other than management - confirm that the items are not ready for revies.
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R. F. Warnisk 2
July 23,1982 l
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3.
Eistorically, one of the NRC questions has been, "Who is rimalag th9 jeb - Bestel'or ConEgnerstf he following esample would allow one to
~
s believe it is ned tal's As a part of the resolutica to our findings in
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the soils setti m instrumentation installation, the NRC insisted th e the licemees generate a Coordination / Installation Foss to cover interface 2
between different evolutions of instrimmentation installation. De lioan-
&c.h?e!
see would on11.our inspector for his concurrance on the adequacy of the form - the inspector would approve Consumers Power Company's form, but i
,.,' T then would fim3 out that Bochtet did not west to work to coastmor's fory -
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f m e m..,, i the fosa that was generated to resolve regulatory concerns. nis event has soeurred tuiosf and was considered as a deviation during a more recent inspection. Ma opinion of the staff is that if Consumers generates a form that will aid them in not incurring regulatory difficulty, and which has had MRC input, the licensee should demand that the contractor comply j
with these policies imet.ed of the contr.csor dieteting the z.guistory j
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environment under which they will gosk.
d.
,Dafidendiey1my=*-41 conditions /has contianally been a concern l
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to the NRC and has resulted in tems of - - p14ance. M the inspectors, S,,v -
the ability to maintain quality storage is indicative of how rigorow or l
9 slipshod the sometreeter's attitude
,towards constr W. S e licensee
* #.' ' g 4 has attested to' entice the ooms to do better in maintaining the
~
i material storage conditions, but still the licensee's auditors and the NRC have negative fieSings in material storage conditions and negative discussions with the contractor about the validity of the findias.
)
S.
At periodic intervals, the'styport of M particularly in the contzel S., k.,- _.
room nr, which are awaiting further routing or termination, has met with
,s,d /
the disapproval of the NnC inspectors. S ese discrepancies also include j
'oables without covered endy being en the fleee in walk areas that are in l
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a' partially ' installed status. 21s is also another indicator of s11pahed worha==Mp which has been brought to the constructor's attention at various i
times, but was last noted during a recent,iaspoeties.
4
'In the area of on M ~line installatig 'and'ma'rkind the
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licensee has had violations which has required removal of all l
installed impulse lines. Also, the NRC, because of this and significant i
'/-f~f adverse ' operational ocediticas, insisted that the insem11=a ingulee lines
'A w.!/cs-vW be identified.. Although the licensee plans to mark the impulse lines, there was ma lamedianto asse5k et resistanes to,sarking the lines / even though there had been instances Af mis-estched A--
Se boomune of iden-j tifiestion confusion.-
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R. F. Narmlek 3
July 23, 1982 i
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/ 7.
An omaaple of reluctance in placing the responsibility for quality work-b, '.? " # ""- menship at the foreman and/or worker level has recently been identified.
?*FR[y he NRC inspectors acted that some drey la wereimproperlyimet$
'" # h
- Mand abwiously did not meere tFthe'installa procedures. The l
' "fd M> e h a pfesanee's attitude _indiosted this was met a valid finding because OC A
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g'a W isspiitied~tb E i The Mac inspectore treat this as indicative tha l
slipshod *aaah==== hip tolerated in the hopes that QC will find the mistakes.
l S.
Late in 1981, the licensee decided to move the gh site superintendent inte another position and ouver this site faction by sharing the site time be-1 tween the Oh Director and the Oh Manager. After a January 1982 meeting with l
!i the Mac at RIII, the 11-- opted to fill the Ok superintendent spot with j
' 0 g, # /' [/' d' N another person. In the spring of the year, the Mac inspectors were following Se, c-f n ;4 ter en welding allegations and approached the gh Superintendent. He gh i
"cAj. Sgerintendent was familiar with the,=11avaa peer weldiep and had established I
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,,n what the InlC inspectors determined to be a responsive plan to resolve the rcrel:,),m,f gunstionable QC welding inspections. At the Enit Interview, h_
(did nos appear tiheek.the, gh site 2,- _' 7 - - ]e prayesed h.% !...,,, g :'i' p r. NaC a,pprove$ The NaC 4
, der classified in writing th just l
j osuse that the Emit Interview was the sme.t_heet11e. emit intervie.s h_e hadj
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During a reemat inspection, it was acted by the ERC inspecter that till dirt fe d e/. h i..., was piled and being covered with a sua met at a asednal 1:1% horisontal to 3
vertical slope when the specification called for a 14:1 horisontal to verti-O '" ' 4 *'**i cal slope. A constructor Field Engineer witnessed,@~s1^
hath "def55eftdelipe'infb halag r ',p(fiastalled ad just.,1fli(
~ m ia is amether emample of the st &hter 2/C m
epiirfreutiairr,ee F havtag 'an attituse which precludes quality ma=4r===ake.
r
, 10. atdifferent times, MC t-5%. hoseT5erienced difficulty la gettiap Be e,,r,,/ i M/ 1afa===**== ubiah ht1=a liy thi~eentrM ~ such as etyperting 'sel-h f ue su,p colations'and gus11fying=information to justify a given installation. A recent osample les the unC inspector infenned the licensee and the sentree-i
- "I,,
- tot he wanted to see reemma of permans involved in the remedial soils week.
i Sere is an obligation to the Mac to sgply a precise number of
- qualified" l
i perseas en the soila week. Se inspector was infawama he could not get these l
l resores as they were personal. The in m ultimately did get the informa-i tien after bringing it to the attention of liosasee upper management. New-i over, this indicates as implied useillingness of the oomstructor to share l
Satosustion with the unC and sometimes with the liconese.
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- 2. F. Warmick 4
July 23,1982
- 11. S e licensee oftentimes does not demometrate a " heads g* approach to their activities. The following are amaspies of the 11oenees operating is an envi
- using tummel vision ; g a) Dering a recent NaC inspection,' the inspector shallenged the,ppility l
5. d q i ng _
to malatala the peeper min ratio on*high presesse groof.. This was wer,[done after the inspector noted that the operator could never mala the proper six ratio without contianal manual contzel - which was not 7"2^Nm available when the groot is applied. % e J1 Q 's apathetic atti-tode'did me( allow them to ~etop the groot quotal the mesg6 gh this beoene an issue at the emit intervier.
b) At one point in time, the oospany doing drilling on site for the remedial soils work cut into a safety related duct bank between the diesel generator building and the service water building. De Conse-more Poser Site Manager's Office (the predaction people) stopped weak becamos - from a quality stanApnint coeditions were to deplorable.
However, the site manager's office did not have responsibility in thie area - the Midland Project m Department had this responsibility and did not invoke their authority to prevent the drilling week from get-ting out of centrol - or to bring it had into control.
1 Se NaC inspector recently witnessed the fiosasse setting g to drill
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I, a well hole la safety related dirt using alischalFe whie was not? "
a > J/ so
7e~M'==df If the imepector had not brought this to the licensee's
# ' ' y "'" y attmation, the licensee would have violated an order addressing reme-dial soils work and also the Construction Pe mit. When the licensee l
f# "/"
- was queried as to the availability of the gC/04 personnel who would l
l prevent and activity from happening, the unC inspector was informed that this was (acother) mienderosanding.
The unc inspectors have been infeemed by our contacta en site that there are mescos written to the effect that " peripheral vision' should be cur-tailad and communication with the NBC etiffled. The MaC has not read i
these aseoes yet - but plans to in the amar future, provided they really exist and infer what we have been infoemed.
)
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- 12. The licensee seems to possess the unique ability to sear & all factions j
- "c of the unc until they have letme one that is sygathetic to their point 4
P' of view - irregardless of the tapest on plant integrity. Some emaaples F,6",f 6.'.wc of this ares kA. m uV.D!<J a) The Mac soils inspector informs the licensee that solis stabilisatiam eg m, 4,., m d,
groot comes under the g program. S e liosasee is not particularly l g f",
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'"y""rh happy with this position. Unknown to the inspector, the licenses argues his point with Nam to have the grout non-g - uslag only those i
arinsents whi& support his (the licensee's) position. S e licensee i.
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July 23,1982 l
has the advantage of the unc inspector's technical and regulatory j
j hemis for oggerting his (the a, _-,gg s) posities, and therefose e
l avoids menties of this durigg the disensions with NER. Bewever, the 11eemose's gh program, whid has already been appsowed by anR, I
states that all the :===di=1 seils week is 9 unless RIII appsoves a l
solamation en a case by case basis. It appears the licensee does met wish to acknowledge the prior agreements with the unc.
l b) siaen the failure of ausiliary feedwater heedess in ban steam genera-4 l
tese, disconstems have transpised between the unc 4- _ - L e and the f
i site persammel. These discussions have indicated that the lisemeen wee maintaining a onesesvetive appesee and were estertaining the eeneesso asyseemed by the unc which were stimolated primarily by grues i
l aistakes in attempting the modifteetion at operating ban plante. The i
liessese's earporate possensel were anseyed that the unc inspectees j
weeld met give appsovat to start the modifiestion tantil aQ the pre-l paratory work had been =a===pti=had as this use14 toad to impact the schodele and the modifiention to the steen generatore emeld heeses a scheduling a=i
. The liesesee oesperate perseemel oestaeted the sac inspectose lavelved to "zeemen with them". Neuever, the serpos=
i ate possammel, (incluelas a -u :- ^~8ve frem aAa0 wese unable to answer the senserne of the anc inspeetees but did mention that the IRA
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f operational Project manager ladiested that it was alri$t to pressed I
with the modificaties. Se licensee earporate possammel aseld met state that the peoition of the Isut Opnetslettion Pseject Manager was en this amene - only that they had faend some foes of approval from same-i one in the Inc.
l c) At times, when Immediate astian Inttese er other fases of escalated entereement beesme <==a===*, the tiemme attasyte te appeal their j
eene with individeals la the sogional management who ase removed fsum l
the particolare of the tentative enfermement acties. Se 11eenson at-tasyts to get these pereens to mysee to specific portions of the issus 1
weich would ladicate that the licensee is "really met all that bed".
neuever, the "real" issues, as identified ty the usc 4-
^ z ase heing meshed.
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d) Daring inspections of the remedial soils week. the NRC inopoeter has boom informed by the 11sensee that certata f8=di=9= and areas of inspee-
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tian wese met within the parview of hia (the inspector's) inspection program hesamos they were in essense esmoidosed non-9 and that by virtue of prior asseement with the Regional heministrator were emeladed fses enfermement esties. Bewever, the Inc lampesters weeld of x.
ly find that there wee as eash agreement hotseen the Regional Waiatrater and the lisensen - enty a philosophiest diseaseien as to what, in general tesmo, enentituted an item of amnesmplianos.
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R. y. Bernid 6
July 23,1982 j
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h aheve indicatore support the reputation the 11oessee has for being i
asgumentative. Their apparaat inability to accept am BBC posities with-out diligently seerding to find a " softened" posities resulte la mamme-eus house of frustrated eenversations between all parties inte,19ed to i
rosestantiate (usually the original position) a position based on tee-alcal and. WE^r i prudemey.
1 The licensee has been classified publicly by the Inc as being,arguentakj f)fp wa pM tivej, The lloemsee contiases to methit this trend, as evidenood by the j
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" fell'owing samepless t
a) Essentially overy ites of noncomplianos receives an asgienestative j
gassuer whid addresses only the specifielty of the iten of ass.aom-l,, / -
p11ameo and selectively avoids any esasept which would siggert the
), *f essemos for the item of aseousplianos. For esagle - in the lastamme f
1 of the impseperly installed esey-in enshoJ amationed above, it see the fact that Oc had met inspected the inee=11mties of the helt which l
j was important to the Licensee. Bouever, the real enfaseement lease wee that P*= were being impsoperly imee.11 a.
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h) The,cVele rz isQ =ada critical evaluations of the licensee's perfor-mance'la several areas. m licensee's response to this,hhts report
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was anguinatative over specifie details and 414 not seem te esmaew1-r l
Af' esse saat the eensensus of opinien of the unc inspeetien staff wee that there were areas where the licensee's performanos was weak. The liconese's s';guneatative position is in the form of "we smally are not all that had* when the recorde, findings,and cheervattene of the Mac Lampactose sigpert just the oppeelte posities.
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j e) The,Q of the r===ad,nengle 'ak has ses*A===11y been as angw-anstative topic of discussian'which ultimately resulted la a EQ meeting j
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f'pf on Mard 10, 1902. At this meeting, the "g-mese" of the somedial== Alm i
"gh work was specified and later doo-==*ad with the meeting minutes. Bow =
ever, the 11amasse did not vlak to abide by this position and a seduce-quant meeting was held la REII to further clarify the NaC peelties.
j Still, the topie of "Q-mese" is being asgued by the licensee, even theegh l
the Asta hee issued an Order further defining the *0-mees" of the selle 3
I weak. It might he meted that a hearing is la procese over this soils asses and the unc's peelties en '9-ness" has been eereened during these I
testisemies.
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- 14. During a recent episode, the licanoes wanted te ;eent15si esoawatimm'ef soil)
/M c,,..,ja peoensity to the Fe e eter zootation wh1,e pihrIw). neuever, the 11ema-
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een wanted to perfeem this evolution without detesminime that the - _ - - ---T l
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'this"detame==tles would have as
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.. M ca adeduling, as stated by the 18mammaa. The FIVF supports were j
. e installed without a Q umbrella and subsequent inspectione did reveal several diser.--des in the lasta11ation of the seppert structues.
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July 23,1982 t
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- 15. During the limited remeMal seile vogh whid has transpireJ. _the.11eenog
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,hes managed to penetrate 9-electrical east henke, a a*=a===a-header draisyf lin Tsain absindemed sewer lies, a men-g eldstrieal^4iset hest and a 72-iaa$
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[eirculating'veterh] All of these ecourances have happened beesume oY i
a%efef'esetN1*and~attenties to detailg. menever approached by the i
unc as to the adagency of revies prior to attempting to drill, the unc l
reenives reopeases whis stremely suggest that the time was not taken to perfoem these reviens - poshaps taking this time would impoet as the I
eeedule.
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1s. er virtue of an earlier asas onder, the 11 emsee is required to perfeen l
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, trend asa W for meneenfeeming eenditions. nees treed analyses have,
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in the past, meshed the data sueh that obviene trends are met ekviene and l
,' has seem1*.ed in negative findings by the NBC. This was addressed la one l
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of the earlier ShLP meetings. Recently, while performing a FeFiGW of A ^ "I'
p e - L[< > - V,hengerweldingdeqp,theNBCinsposterfoundthatthe,'etatisticaldatah i
heim~diluee(to the pe&at that the atmher of unsatieiestery hangere could met he estesmiaed from the trend analyses or the type and dessee of non-oonfeeming senditises whid were being identified partiment to the hanger i
i fabriestion.
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- 17. Se licensee contime 11y would,ume the M staff am'eseemitante and i
safias a.,1 1-i and enforeement position as oeunter productive 7 l
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is==flestad by the 11eemene met wining te,perf==
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addressing emir f d"' 'l J;ing unc sraer aspreval l
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- pewided it is ont to'the'l ammese.
t 218 attitude %. particularly prweiled in the 4 lasser degree in the electrical lastellatish a, remedial sette$seen and to i
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- A n 'Jc7 h mode would he'for the 11eensee to generate his program to este-M bliek vreality and than the unc would approve er disappseve. Newever, the l
j liesasse requires esmoultation with the WRC to establish his level of i
quality seguisements.
1 The above is met latended to be a emiplete list of g diserspenoies whid ind1=
j este ques *i===h1= lieenees perfeemenos as this weeld require a more entensive review of the sooerde and inspection pernammet lavelved than time pesuite. Also, l
j there has been no attempt to systematically deement the enforeement and tare-selved items liet as these are contained la ether information seuroes. Neuever, i
the listing is rather easysehensive of the types of siteetiene and attitudes which prevail at the Midland Site as cheerved by the NRc inspecter staff.
men eeneidering the above listing of questionable licensee performenee attributes, l
the most doening essesyt is the feet that the NBC inopoetion effort at Midland hae
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been purely reactive in nature for approximately the last year, and that these indientere are what have been shoorved la appremiantely the last ein months, if
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i these are the types of items that have become am NBC nuisance wider a reactive inspection program, ces can only wonder at what would he dioeleoed under a rigorous routine inspection and medit progras.
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.g f.Cj) W T Problems-As Perceived or Identified by Region 11I 1.
Responses - failure to address root cause and take full and decisive action.
2.
Bechtel over-ruling Consumers 3.
Material storage 4.
Cable support and storage 5.
Impulse line separation and identification 6.
Drop-in anchors not properly installed 7.
QA Lirector failed to support QA Site Superintendent 8.
Constructors field engineer failed to take action when out of spec condition was identified.
9.
Bechtel reluctant to give information to NRC 10.
Licensee wears blinders in addressing problems - grout & drilling 11.
Licensee seeks NRC opinion and plays one part of NRC against another.
12.
Licensee is argumentative 13.
Feedwater Isolation Valve Pit excavation 14 Drilling into underground pipes and duct banks 15.
Ilangern - Licensee tried to minimize significance and extent of problem. Aptroximately 43% have deficiencies.
16.
Licensee using NRC as consultants 17.
Electrical cables - 51 misrouted 18.
Soils - NRC keeps finding problems 19.
Reluctance to put responsibility of quality work on construction foreman.
They want to inspect quality in, rather than build it in.
20.
QC failing to identify problems.
)
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INDICATIONS OF 14 ADEQUATE QUALITY CONTROL INSPECTIONS AT MIDLAND Electrical (Aprl! 28, 1981 to Present)
Noncompilance 329/81-11-03: Failure of Quality Control Inspections to identify inadequate Internal separation of Class it and non-class it electrical cables (one example).
Noncompilance 330/81-12-07: Failure of Quality Control Inspections to identify a violation of the minimum bend radius of a Class lE cable.
Noncompliance 329/82 06-011 330/82-06-01: Fallure of Quality Control inspections to identify 55 misrouted Class it cables and 66 nonconforming l
cable reel numbers.
Noncompilance (Report not complete): The noncompilance pertains to non-l conforming separation of Class it cables. The root cause was determined l
to be due to inadequate design control, however, approximately 30 Class It cables had previcusly t>een Installed and Inspected without Quality Control identifying the.wnconforming separations.
Mechanical (May 18-22,1981)
I Noncompliance 329/81-12-12; 330/81-12-13: Failure of Quality Control Inspections to Identify that 6 of 7 previously inspected large bore pipe restraints, supports and anchors had not been Installed in accordance with design drawings and speelfications.
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DRAFT NOTES t
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TheMidlandSectionrecommendsthatthefollowingactionsbeconsidered by Region !!! in an offort to (1) improve the Licensee's regulatory attitude and performance, and (2) provide increased assurance that completed and l
ongoing construction work is acceptable.
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1.
Establish an augmented inspection effort by the NRC.
t A.
Inspections should be concentrated in the following ten areast (1) Soils (2) Electrical (3) !8C f
(4) High Pressure Piping (5) Hangers and Supperta (4) Corrective Action System - including identification, documentation, resolution, and prevention of future events.
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(7) Receipt, Storage, and Handling (4) Structural Steel i
(9) Subcontractor Welder tualification i
(10) Management overview System l
S.
The effort as initially conceived will test from e to 12 months but it could last longer.
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It is prorosed that the inspections be performed by the f
Midland Section and 5 contract inspectors assigned full-time to the Midland Section and Located onsite. The Midland Section uould be as follows:
(1) Shafer l
(2) Gardnsa (3) Landsman (4) Cook l
j (5) Burress (6) Welding 8 NOT-Contracted (7) Mechanical-Contracted (8) Electrical-Contracted (9) 1 & C - Contracted 1
(10) Startup & Test-Contracted (11) Secretary (Full Time) 2.
Require the licensee to have an independent third party look at a vertical slice of a safety-related system from design through com-I pletion of construction.
3.
Require the licensee to have att GC inspectors report to CPCo.
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4.
Convince CPCo tha6 Curtand should be in charge of QA onsite and that he should report directly to Cook.
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Conduct NRC exits with Construction Manager (Don Miller) and QA 1
Manager.
6.
NRC should get commitments in writing and should give release on hold points.in writing.
7.
CPCo should convince Bechtel that quality must be built into the plant. It cannot be inspected into it.
If Leo Davis is convinced this is the most important thing his management wants, then it will be done.
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NUCLEAR REGULATORY COMMISSION
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REGION ill 3-k
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799 ROOSEVELT ROAD 1
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o GLEN ELLYN,lLLINotS 60137 l
June 21, 1982 e
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MEMORANDUM FOR: James G. Keppler, Regional Administrator FROM:
C. E. Norelius, Director, Division of Engineering and Technical Programs R. L. Spessard, Director, Division of Project and Resident Programs
SUBJECT:
SUGGESTED CHANGES FOR THE MIDLAND PROJECT Historically, the Midland Project has had periods of questionable quality assurance as related to construction activities and has had commensurate regulatory attention in the form of special inspections, special meetings, and orders. These problems have been given higher public visibility than most other construction sites in Region III. As questions arise regarding the adequacy of construction or the assurance of adequate construction, we are faced with determining what regulatory action we should take. We are again faced with such a situation.
Current Problem The current problem was caused by a major breakdown in the adequacy of soils work during the late 1970's. Because of the increased regulatory attention given the site, we expect that exceptional attention would be given to this activity and that licensee performance would be better than other sites or areas which have not had such significant problems and therefore have not attracted this level of regulatory attention. However, that does not appear to be the case and Midland seems to continually have more than its share of regulatory problems. The following are some of the specific items which are troublesome to the staff.
Technical Issues 1.
In the remedial soils area, the licensee has conducted safety related activities in an inadequate manner in several instances - removal of dirt around safety related structures, pulling of electrical cable, j
l drilling into safety related utilities.
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In the electrical area, in trying to resolve a problem of the adequacy of selected QC inspectors' work conducted in 1980, the licensee completed only part of the. reinspection even when problems were identified,and appears inclined to accept that 5% of electrical cables may be misrouted (their characterization of "misrouting" may imply greater significance than we would attach to similar findings).
I 3.
In the pipe supp' ort area, in trying to resolve a problem of the adequacy of QC inspections conducted in 1980, the licensee has
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portrayed only a small percentage of defects of " characteristics" identified and has not addressed the findings in terms of a large j
percentage of snubbers which may be defective because of the l
characteristics within each snubber that may be defective (e.g., if l
only one characteristic was defective out of 50 reviewed on a single hanger, the percentage is small; but if the one defective characteristic i
makes the hanger defective the result would have a much greater significance level). The licensee had done a detailed statistical analysis in an attempt to show that the small percentage of characteristics j
were found rather than broadly approaching the problem with significant reinspections to determine whether or not construction was adequate.
I Communications Multiple misunderstandings, ametings, discussions, aad communications seem-to result in dealing with the Midland Project. Some examples are:
1.
NRC staff attending a meeting in Washington on March 10, 1982, heard the Consumers Power Company staff say that electrical cable pulling related to soils remedial work was completed. It was determined to 2
be ongoing the next day at the site.
2.
When Region III attemp,ted to issue a Confirmatory Action Letter, J. Cook informed W. Little of his understanding that both J. Keppler 3
I and H. Denton had agreed that the subject of the CAL was not a safety related item subject to NRC regulatory jurisdiction. Such i
agreements had not in fact occurred and following a meeting, Consumers Power Company issued their commitments in a letter to Region III.
3.
In reviewing a licensee M y 10, 1982 letter, responding to the Board a
.j Order, the NRR staff had an unsigned letter and Region III had a signed I
copy both dated the same date but differing in content.
4.
Recently a Region III inspector in closing out and exiting from his inspection described the exit meeting as being the most hostile he had ever participated in.
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James G. Keppler 6/21/82 l
5.
The responses to any Region III enforcement letters issued to Midland are more lengthy and 7555 argumentative than are any other responses from any other licensee in Region III. This point was made in the SALP response provided by Midland,and the SALP response j
in itself from Midland is an example of the type of response which we commonly receive from the site. The length of the response is at least as long'as the initial SALP report.
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t 6.
Multiple requests for briefing meetings and other statements by the utility to the effect that we should review procedures in developmental stages imply that Midland wants the NRC to be a part of their construction program rather than having us perform our normal regulatory function.
Staff Observations 1.
With regard to corrective actions of identified noncompliances, the Midland response seems to lean towards doing a partial job and then writing up a detailed study to explain why what they have done is sufficient rather than doing a more complete job and assuring 100%
corrective action has occurred. In the detailed writeups that are prepared, it is the staff's view that the licensee does not always represent the significance properly,and the analyses and studies often raise more questions than they solve; thus time appears to have been wasted in writing an analysis rather than in fixing the problem.
2.
Midland site appears to be overly conscious with regard to whether or not something is an item of noncompliance and spends a lot of effort on defending whether or not something should be noncompliance as opposed to focussing on the issue being identified and taking corrective action. This appears in part to be due to their sensitivity 5
of what appears in the public record as official items of noncompliance.
This sensitivity may have resulted from the extended public visibility which has attended construction of the facility.- The staff's view is i
that the Midland site would look better from the public standpoint and be more defendable from NRC's standpoint, if they concentrated on fixing identified problems rather than arguing as to the validity of citations.
i This type of view was expressed by the utility during a recent effort
]
to clarify in detail that certain construction items on the soils remedial work should not be subject to NRC's regulatory action.
3.
The Midland project is one of the most complex and complidcted ever undertaken within Region III. The reason is that they are building two units of the site simultaneously and additionally have an underpinning construction effort which in itself is probably the equivalent of building
.a third reactor site. The massive construction effort and the various stages of construction activity which are involved make the site extremely compl$)ted to manage.- This activity appears to cause a lot of pressure on the licensee management.
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4-6/21/82 James G. Keppler 4.
Mr. J. Cook, the Vice President responsible for the Midland site is an extremely capable and dynamic individual. However, these j
characteristics in conjunction with the complexity and immenseness of operation as set forth in 3, above, may actually be contributing
~
to some of the confusion which seems to exist. The staff views that (1) he is too much involved in detail of plant operations and there are times when the working level staff appears to agree and be ready to 4
take action where Mr. Cook may argue details as to the necessity for 1
such action or may argue as to the specific meaning of detailed work procedures. (2) this kind of push may lead to such things as letters l
both, signed and unsigned appearing in NRR and-causing confusion.
(3) this push may lead to some animosity at the licensee's staff level if NRC activities are looked on as slowing progress of construction at the site.
)
i Recommendations It appears essential that some action be taken by NRC to improve the regulatory performance of the Midland facility. The following specific suggestions are made.
1.
The company must be made aware and have emphasized to them again that their focus should.be on correcting identified problems in a (g%
complete and timely manner.
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2.
We should question whether or not it is possible,to adequately manage b
l a construction program which is as complex and diverse as that which i
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currently exists at Midland. We would suggest specifically that the g(
following activities be considered:
a.
That the licensee cut back work and dedicate their' efforts to getting one of the units on line in conjunction with doing the soils remedial work.'
j b.
That they have a separate management group all the way to a possible new Vice President level, one of which would manage the construction of the reactor to get it operational and the second to look solely after the remedial soils and underpinning activities.
3.
Consumers Power Company should develop a design and construction verification program by an independent contractor. This would provide an important additional measure of credibility to the design and 1
f
. construction adequacy of the Midland facility.
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James C. Keppler
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6/2/1/82 We would be happy to discuss this with you, t
-$ $ l]N.bn C. E. Norelius Director Division of Engineering and Technical Programs t
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R. L. Spessard, Director Division of Project and Resident Programs r
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