ML20091P029
| ML20091P029 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/11/1984 |
| From: | Gallagher E AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-11, FOIA-84-96 NUDOCS 8406120565 | |
| Download: ML20091P029 (1) | |
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
(
Before the Atomic Safety and Licensing Board
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In the Matter of
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CONSUMERS POWER COMPANY
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Docket Nos.
50-329-OM
)
50-330-OM (Midland Plant, Units 1 and 2)
)
50-329-OL
)
50-330-OL
)
NUCLEAR REGULATORY COMMISSION STAFF / CONSUMERS POWER COMPANY OUALITY ASSURANCE STIPULATION 1.
Prior to December, 1979, there were quality assurance deficiencies related to soil construction activities under and around safety-related structures and systems at the 3
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Consumers Power Midland Plant construction site (" Midland") in that (i) certain design and construction specifications related to foundation-type material properties and compaction require-ments were not followed; (ii) there was a lack of clear direction and support between the contractor's engineering office and construction site as well as within the con-tractor's engineering office; (iii) there was a lack of control and supervision of plant fill placement activities which contributed to inadequate compaction of foundation material; and (iv) corrective action regarding nonconformances related to plant fill was insufficient or inadequate as evidenced by repeated deviations from specification require-ments.
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2.
Consumers Power agrees not to contest the I
NRC Staff's conclusions that the events referred.to in para-graph 1 constituted a breakdowm in quality assurance with wm -- __-
respect to soils placement at Midland and constituted an adequate basis for issuance of the order of December 6, 1979.
3.
The quality assurance program satisfies all requisite NRC criteria.
Further, as a result of revisions in
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the quality assurance program, the improved implementation of that program, and other factors discussed in testimony submitted by James G. Keppler, the NRC has reasonable assu"ance that t p+
4 quality assurance and quality control programs will be appropriately implemented with resp q future soil 4 con-IO
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k(#(a struction activities including remedial actions taken as a result of inadequate soil placement.
s One of the Attorneys for Consumers Power Company l
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One of the Attorneys for the Staff of the Nuclear Regulatory Commission Date: June 5, 1981 b
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION lk l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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COPSUMERS POWER COMPANY
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Docket Nos. 50-329-0M & OL
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50-330-0M & OL (Midland Plant, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of NUCLEAR REGULATORY COMMISSION STAFF / CONSUMERS POWER COMPANY. QUALITY ASSURANCE STIPULATION in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 8th day of June, 1981.
- Charles Bechhoefer, Esq.
Ms. Mary Sinclair Atomic Safety and Licensing Board 5711 Summerset Street U. S. Nuclear Regulatory Commission Midland, Michigan 48640 J,.
Washington, D.C.
20555 Philip P. Steptoe, Esq.
Administrative Judge Ralph S. Decker Michael I. Miller, Esq.
Route #4, Box 190D Ronald G. Zamarin, Esq.
Cambridge, MD 21613 Alan S. Farnell, Esq.
Isham, Lincoln & Beale One First National Plaza Dr. Frederick P. Cowan 42nd Floor 6152 N. Verde Trail Chicago, Illinois 60603 Apt. B-125 Boca Raton, Florida 33433
- Atomic Safety and Licensing Board Panel Frank J. Kelley U. S. Nuclear Regulatory Comission Attorney General of the State Washington, D.C.
20555 of Michigan Steward H. Freeman
- Atomic Safety and Licensing Assistant Attorney General Appeal Board Panel Gregory T. Taylor U. S. Nuclear Regulatory Comission Assistant Attorney General Washington, D.C.
20555 Environmental Protection Division 720 Law Building
- Docketing and Service Section Lansing, Michigan 48913 Office of the Secretary U. S. Nuclear Regulatory Commission Myron M. Cherry, Esq.
Washington, D.C.
20555 1 IBM Plaza Chicago, Illinois 60611
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James E. Brunner, Esq.
Jeann Linsley Consumers Power Company Bay City Times 212 West Michigan Avenue 311 Fifth Street Jackson, Michigan 49201 Bay City, Michigan 48706 Ms. Barbara Stamiris Paul C. Rau 5795 N. River -
Midland Daily News Freeland, Michigan 48623 124 Mcdonald Street Midland, Michigan 48640 Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 Wendell H. Marshall, Vice President Midwest Environmental Protection Associates RFD 10 Midland, Michigan 46640 James R. Kates 203 S. Washington Avenue Saginaw, Michigan 48605
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William D. Paton C'ounsel for NRC Staff
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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C0i45UMERS POWER COMPANY
)
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50-330 OM & OL (Midland Plant, Units 1 and 2)
)
NRC STAFF TESTIMONY OF EUGENE J. GALLAGHER WITH RESPECT TO QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6, 1979 Q. 1.
Please state your name and position'with the NRC.
A.
My nace is Eugene J. Gallagher.
I am a civil engineer with the U.S. Nuclear Regulatory Commission. Since February,1981, I have been assigned to the Reactor Engineering Branch, Division of Resident and Regional Reactor Inspection, Office of Inspection and Enforcenent.
Prior to February,1981, I was a reactor inspector assigned to the Region III, Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement.
I was assigned to the Midland Plant (among others) from October,1978 until January,1981.
Since October of 1978, I have spent approximately one year of effort performing inspections, reviewing quality control records and procedures, observing work activities, reviewing Consumers Power Company (hereaf ter Consumers) responses to 50.54(f) questions 1 and 23, attending caetings and presentations by Consumers and Bechtel regarding the soil settlement natter at the Midland Plant.
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2.
Have you prepared a statement of professional qualifications?
A.
Yes, a copy of this statement is attachment No. 17.
Q. 2.
Please state the nature of the responsibilities that you had with respect to the Midland Plant, Units 1 & 2, from October,1978 to December 6,1979.
A.
As a civil engineer inspector for the Region III office of Inspection and Enforcement I conducted five inspections prior to Decem-ber 6,1979 in order to (1) ascertain whether adequate quality assurance plans, instructions and procedures had been established for the con-struction of the foundation of safety related structures, (2) provide an independent evaluation of the performance, work in progress and completed work to ascertain whether activities relative to foundation construction were accomplished in accordance with NRC requirements, and (3) review the quality related records to ascertain whether these records reflected work accomplished consistent with NRC requirenents and license commitments.
The results of these ins'pections prior to December 5,1979 are contained 1
in the following NRC inspection reports:
50-329/78-12; 50-330/78-12, conducted October 24-27, 1978 (Attachment No. 2).
50-329/78-20; 50-330/78-20, conducted December 11,1978-January 25, 1979 (Attachment No. 7).
50-329/79-06; 50-330/79-05, conducted March 28-29, 1979 (Attachment No. 8).
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50-329/H-10; 50-330/79-10, conducted May 14-17, 1979 (Attachment No.10).
50-329/79-19; 50-330/79-19, conducted September 11-14, 1979 (Attachment No.12).
Q. 4.
Please state the purpose of this testimony.
A.
The purpose of this testimony is to identify the quality assurance deficiencies which contributed to the soil settlement problem at the Midland Plant prior to the issuance of the December 6,1979 Order.
Q. 5.
What is ~" quality assurance" comprised of?
A.
" Quality assurance" comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, systen, or component will perfonn satisfactorily in service. Quality assurance includes quality control.
(10 CFR 50, Appendix B, Introduction).
Q. 6.
What is " quality control" comprised of.
A.
Quality control comprises those quality assurance actions related to 'the physical characteristics of a material, structure, component or system which provide a means to control the quality of the material, structure, component or system to predetemined requirements.
(10 CFR 50, Appendix B Introduction).
Q.
7.
Are soils work activities subject to 10 CFR 50, Appendix S?
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. x A.
General Design Criterion 1 of 10 CFR 50, Appendix A (Quality Standards and Records) requires that " structures systems and components important to safety be designed, fabricated, erecte; and tested to quality standards commensurate with the importance to safety functions to be perfomed... A quality assurance program shall be established and implemented in order to provide adequate assurance that these structures, systems and components will satisfactorily perfom their safety function..."
General Design Criterion 2 of 10 CFR 50, Appendix A (Design bases for protection against natural phenomena) requires " structures, systems and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perfom their safety functions...".
10 CFR 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants (I-Purpose) states, "It is the purpose of these criteria to set forth the principal seismic and geologic considerations which guide the Commission in its evaluation of the suitability of proposed sites for nuclear power plants and the suitability of the plant design bases established in consideration of the seismic and geologic characteristics of the proposed sites..."
Paragraph IV (Required Investigation) states "the investigations shall include the following:
"Detemination of the static and dynamic engineering properties of the caterials ' underlying the site.
Included should be properties needed to detemine the behavior of the underlying material du' ring earthquakes and the characteristics of the underlying material in transmitting earth-
.- quake induced motions to the foundation of the plants, such as seismic wave velocities, density, water content, porosity and strength..."
fiidland Plant, Units 1 and 2 FSAR, Section 3.2.2.1, " describes the method of identifying and classifying those plant features designed to withstand the effects of earthquakes, and to which the requirements of Appendix B to 10 CFR 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, have been applied... structures, systems, and components which are required to support seismic Category I structures, components, and systems are also designed for Category I seisnic loads". Table 3.2-1 provides a listing of structures, com-ponents, and systems and 1dentifies those which are seismic Category I.
Those structures include the containment building, auxiliary building, deisel generator building, service water pump structure and retaining walls and foundations for barated water storage tanks.
The soil foundation work activities for these Category I structures are subject to 10 CFR 50, Appendix B requirements in order to assure that these structures will satisfactorily perfom their safety functions.
Q. 8.
When did Consumers first become aware of the apparent excessive settlement of the diesel generator building?
Consumers first reported the excessive settlement of the diesel generator building orally on August 21, 1978 to the Region III, on-site NRC resident inspector. Written notification was made on September 29, 1978 in the fom of a 10 CFR 50.55(e) notification of a significant deficiency in construction (attachment 1).
This report states that the o
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' diesel generator building and foundations settlement was greater than anticipated at that time (mid August,1978).
In fact, the settlement values at that time (less than 6 months after the start of construction of the diesel generator building) were approaching the total settlement values for the 40-year life.
Q. 9.
Under what circumstance is a 10 CFR 50.55(e) report.equired?
A.
By the tems of the regulation, a 50.55(e) report is required for each deficiency found in design.and construction which if it were to remain uncorrected could affect adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the i
plant and which represents:
(1) A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of
[10 CFR 50], Appendix B; or (2) A significant deficiency in final design as approved and released for construction such that the design does not confom to the criteria and bases stated in the safety analysis report or construction pemit; or (3) A significant deficiency in construction of or signifi-cant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction pemit or to otherwise establish the adequacy of the structure, systen, or component to perfom its intended safety function; or (4) A significant deviation from perfomance, specifications which will require extensive evaluation, extensive redesign or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and basis stated in the safety analysis report or construction pemit or to otherwise establish the adequacy of the structure, system or component to perform its intended safety function.
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Consumers submitted a 50.55(e) report with respect to the soil settlement problem by its letter of September 29, 1978 (Attachment 1).
Saveral interim reports were subsequently submitted through November 2, 1979. Consumers' initial 50.55(e) interim report (Attachment 1) states that the event was reportable under 10 CFR 50.55gl(iii) which is the equivalent of (3) above - a significant deficiency in construction.
Q. 10. When did you conduct your first inspection at Midland with respect to soils?
A.
An inspection was conducted on October 24-27, 1978 the results of which are contained in NRC inspection report 50-329/78-12; 50-330/78-12 (hereaf ter NRC Report 78-12) dated November 17, 1973 (Attachment 2). The purpose of the inspection was to provide Region III management with a preliminary evaluation of the extent of the soils problem based on initial investigative borings, the type of foundation material, review of construction specifications and license commitments.
Items 1(a) through (f) of that report provided a summary of Consumers 50.55(e) report and information Consumers provided while I was onsite.
Items 2 through 8 of that report are the results of my review and observations made during the inspection.
I would like to bring to the attention of the board that the third paragraph of the transmittal letter for NRC Report 78-12 and the inspection summary results therein that indicate that no items of noncompliance were identified are erroneous. At the time of the inspection the identified inconsistencies (item 3) and failure to follow
. t specifications requirements (item 4) did constitute noncompliances.
I intended to (and did in fact) conduct further investigations with respect to the soils work activities and these noncompliances. The results of this further investigation of each of these items described in NRC Report 78-12 are further discussed in NRC Report 78-20 and are identified as itens of noncompliances.
Q. 11. What actions did the office of Inspection and Enforcenent take subsequent to the initial inspection of October 24-27, 1978?
A.
We met with Consumers to discuss the October 24-27, 1978 W inspection and NRC Report 78-12 on December 4,1978 (See Attachnent 3).
Members of the NRC Office of Nuclear Reactor Regulation (NRR) were also present as a result of a transfer of lead responsbility that had been executed on November 17, 1978. Bechtel initially addressed the items in NRC Report 78-12. The NRC also emphasized that while attention to remedial action is important, detemination of the exact cause is also quite important for verifying the adequacy of the remedial action, assessing the extent of the matter relative to other structures, and in precluding repetition of such matters in the future.
The director of the Region III Office of Inspection and Enforcement then initiated an investigation to obtain information concerning the circumstances of the soil settlement occurrence to detemine whether (1) a breakdown in the quality assurance progran had occurred. (2) whether the occurrence had been reported properly and (3) whether the final
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safety analysis report which had been submitted by Consumers was con-sistent with the design and construction of the Midland project.
Q. 12. Summarize your preliminary investigation findings.
A summary of the preliminary investigation findings were pre-sented to Consumers on February 23, 1979 at the Region III office. These findings are documented in Attachment 4.
In summary, the findings related to quality assurance deficiencies, are:
The FSAR did not correctly state the type of fill material supporting safety related structures. This is a violation of 10 CFR 50 Appendix B quality assurance criterion III. (Design Control)
The FSAR included conflicting values for the settlement of the diesel generator building founded on spread footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterion III.
(Design Control)
The conpaction requirement for clay material was not fol-lowed. This is a violation of 10 CFR 50 Appendix B criterion V. (Instructions, procedures and Drawings) quality assurance The compaction requirement for sand was not correctly translated into the construction specifications. This is a violation of 10 CFR 50 Appendix B quality assurance criterion V. (Instructions, Procedures and Drawings)
Moisture control was not properly implemented. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI.
(Corrective Action) 4 Soil was not protected from frost action nor removed prior to resuaing work. This is a violation of 10 CFR 50 Appendix B quality assurance criterion !!!. (Design Control)
The root causes of nonconfonning conditions were not ade-quately corrected to preclude repetition. This is a violation of 10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Action)
The settlement calculations for the diesel generator building were based on conditions of foundation type, load intensity and
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. soil compressibility other than the actual conditions. This is a violation of 10 CFR 50 Appendix B quality assurance criterion III.
(Design Control)
Consumers did not adequately investigate the extent of the soil problem after the s~ettlement of the administration building footings. This is a violation of 10 CFR 50 Appendix B quality assurance criterionXVI..(CorrectiveAction)
Program changes were not implemented to preclude erroneous selection of the laboratory compaction standards (maximum density and optimum moisture content) af ter the settlement of the administration building footings. This is a violation of -10 CFR 50 Appendix B quality assurance criterion XVI. (Corrective Accion)
[We subsequently determined that the last two items should not have been listed as quality assurance deficiencies because the adminis-tration building is not subject to quality assurance requirements.]
. Concrete material was permitted to be used in lieu of fill material without consideration of the effects on structures. This is a violation of 10 CFR 50 Appendix B quality assurance criterion V.
(Instructions, Procedures and Drawings)
Personnel directing the soils operation were not trained in the area of soil work, nor was a geotechnical soils engineer present on-site as required. This is a violation of 10 CFR 50 Appendix 8 quality assurance criterion II. (Quality Assurance program)
Inspection procedures were relaxed from original procedural requirements which provided insufficient hold points to ascertain back-fill material was installed properly. This is a violation of 10 CFR 50 Appendix B quality assurance criterion X. (Inspection)
The sampling (surveillance) plan was infrequent and inade-quate to verify conformance. This is a violation of 10 CFR 50 Appendix B quality assurance criterion X. (Inspection)
Based on the above findinga it was my conclusion and it is my conclusion now that:
(1) There was inadequate control and supervision of the plant fill.
(2) Corrective action regarding nonconforaances was' inadequate.
(3) Construction specifications and design bases were not followed.
(4)
Interface between design organization and construction was i nadequa te.
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(5) The FSAR contained inconsistent, incorrect and unsupported statements.
Q. 13. Did Consumers respond to these findings?
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Yes. Subsequent to the February 23, 1979, a meeting was held at the Region III office on March 5,1979 during which Consumers responded to the NRC investigation findings. Consumers response was documented in their submittal which was revised March 9,1979 (Attach-ment 5). During this meeting the NRC Staff reiterated it's concern expressed on December 4,1973 for assessment of the extent of the matter relative to other structures, and stated that its concern was not limited to the narrow scope of the diesel generator building but extended to various buildings, utilities and other structures located in and on the plant fill.
In addition, the NRC Staff expressed concern with the implementation of Consumers quality assurance programs.
Consumers March 9,1979 response (Attachment 5) failed to identify root causes of the quality assurance deficiencies and corrective actions to preclude repetition of these quality assurance deficiencies.
Q. 14. Did the NRC transmit the detailed investigation results to Cor.sume rs ?
A.
The investigation results were sent to Consumers on !! arch 22, 1979; the details of which are contained in NRC investigation report 50-329/78-20; 50-330/78-20.
(Attachment 7). This report indicated that the findings of the investigation continued to be under review by the NRC 7
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Staff and that ups ; the completion of that review Consumers would be advised of the enforcement action to be taken by the NRC. NRC Report 78-20 contains a more detailed discussion of the investigation findings summarized in response to Question 15 of this testimony.
Q. 15. What action was taken to detemine whether enforcement action should be taken?
A.
On g h_21._1979 the NRC sent Consumers a request pursuant to 10 CFR 50.54(f) to obtain additional infomation regarding the ade-quacy of the. plant fill and the quality assurance program for the Midland site.
(Attachment 6).
I provided input into the 50.54(f) request.
Question 1 of 22 of the 50.54(f) letter requested information regarding Consumers implenentation of the quality assurance program. 0 1979 Consumers subnitted the initial response to Question 1 (Attachnent 9). The NRC review concluded that the infomation provided was not sufficient. During a July 18, 1979 meeting, Consumers presented s
the results of its investigation into the probable cause of the settle-ment problem and the NRC expressed several points of disagreement with these results (see meeting summary dated October 16, 1979, Attachment
% 13].
On September 11, 1979 the NRC issued Question 23 which contained a request for additional quality assurance infomation. On November 13, 1979 Consumers Power Co. submitted revision 4 to the 50.54(f) submittals which contained their response to' Question 23 (Attachnent 14) including specific corrective actions and commitments for implementation of its quality assurance program.
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In its responses to 50.54(f) Question 23, Consumers identified and discussed the root causes for quality assurance deficiencies. As discussed more fully below, information in the response to Question 23 supports the allegation in NRC's December 6,1979 Order Modifying
)pf Construction Permits (Attachment 15) that there was a breakdown in quality assurance.
i Q. 16. What action was taken with respect to enforcement?
A.
On Dectmber 6,1979 an Order Modifying Construction Permits was issued jointly by the NRC Office of Nuclear Reactor Regulation and the Office of Inspection and Enforcement as a result of the investigation findings and the conclusions of the NRC Staff af ter reviewing responses to the 10 CFR 50.54(f) requests of March 21, 1979 and September 11, 1979.
One of the bases for the issuance of the December 5,1979 ' Order, was the breakdown in quality assurance with respect to soil activities.
(See paragraph III of the December 6,1979 Order).
As more fully discussed in _this affidavit, the facts contained in Part II of the December 6,1979 Order (including Appendix A) insofar as they relate.to quality assurance, are true.
Q. 17.
Before discussing what actually occurred at Midland with regard to the implementation of the quality assurance progran in the i
soils area, please state the significance of soil campaction and the factors which affect soil compaction.
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A.
When soil is employed as a structural or construction material, it must have adequate engineering propt:.* ties to perform it's intended design function without excessive defomation or settlement.
Compaction of soils is an effective technique for increasing the soil density and attaining the desired engineering properties of soil materials such as acceptable strength, resistance to deformation and resistance to the flow of water. Specifying the attainment of a maximum soil density is an accepted engineering practice for measuring the effectiveness of the compactive effort.
The density that can be achieved by compaction depends on (1) the soil type, (2) moisture control, (3) type of compaction equipment, (4) placenent thickness of the soil layer to be compacted, and (5) the magnitude of the compaction effort (for example the number of passes of the compaction equipment). Satisfactory performance of the soil can be achieved provided these factors are properly specified and controlled during construction under an effective quality control and quality assurance program.
G. P. Tschebotarioff, author of " Foundations, Retaining & Earth Structures", Second Edition, McGraw Hill, states in paragraph 1-8 (Special tieed for Construction Quality Control) that "In foundation work this need [for construction quality control) is much greater than in any branch of civil engineering.... Constant attention to every detail of construction procedures is therefore a cust in all foundation work.
Above all, con'tinuous competent on-the-site inspection is essential..."
This illustrates the special character of the geotechnical field, in comparison to other construction activities.
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Q.
18.
Identify the 13 quality assurance deficiencies discussed by Consuners in its response to 50.54(f) Question 23.
Qces A.
(1)
Inconsistencies between construction specifications and consultant reports.
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(2) Lack of. formal revisions of specifications to reflect clarification of-specification requirenents.
Ogn (3)
Inconsistency of design basis within the FSAR relating to diesel generator building fill naterial and settlement values.
yt (4) Inconsistencies between the settlement calculations and the original design basis of the diesel generator building.
y3 (5)
Inadequate design coordination in the design of the duct h (6) Insurficient conpactive effort used in backfill operation.
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(8) Inadequate quality control inspection of placenent of fill.
E7 (9)~ Inadequate soil noisture testing.
28 (10)
Incorrect soil test results.
D (11) Inadequate subcontractor test p ocedure.
30 (12) Inadequate corrective action for repetitive nonforning
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Inadequate qua.lity assurance auditing and nonitoring of t.
a'nt fill work activities.
These itens are discussed below, seriatin.
Q. 19. Sunnarize Consuners and NRC discussion of inconsistencies iden-tified between construction specifications and consultant reports.
(Iten13(1))
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. A.
Discussion of this quality assurance deficiency is contained in (1) flRC Report 73-20, pages 9,10,16 and 17, (2) Consuaers response to 50.54(f) Question 1 at appendix I, page 1 (1 A.1) and page 3 (1 B.1) (3)
Consumers response to 50.54(f) Question 23 at pages 23-G and 23-7 (sub-section 3.1) and (4) Consumers Answer to flotice of Hearing, appendix 1(e) and (f).
This quality assurance deficiency existed between 1973 tnrough the substantial redu: tion in construction during 1978-79 without correction.
Consultant reports were submitted by Consumers to the flRC as PSAP.
attachnents. Consumers indicated that consultant reports were subject to being "nisconstrued as connitaents". Tne Danes & Moore report, entitled
" Foundation Investigstion and Prelininary Explorations for Borrow
'taterials, Proposed fluclear Power Plant", dated June 28, 1968 was subnitted as PSAR anendnent I and a supplenent to this report dated, 11 arch 15,1969 was later subnitted as PSAR anendnent 3.
Tnis report contained criteria relating to compaction and frost protection of the foundation naterial which were disregarded during actual construction.
In response to an 14RC question Consuners also submitted PSAR anendment 9 dated 3/20/70 which states in part, "the design criteria for these Class ! structures will be nodified to renove all natural sands with a relative density less than 75% and to replace these sands with a controlled backfill compacted in accordance with page 16 to the report titled " Foundation Investigation and Preliminary Explorations for Borreu Material Proposed fluclear Power Plant, dated Itarch 15, 1969." Since the Danes and floore report was submitted as part of the application, and was
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specifically referenced in Amendment flo. 9 NRC considered the designated conpaction criteria to be design connitnents by applicant.
Page 16 of the Danes and !!oore report indicated the conpaction j
criterion for sands supporting structures to be a nininun 85". relative
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density. Contrary to this, Bechtel construction specification C-210 f
l required compaction of sand to not less than 80" relative density.
In addition, the 80% relative density criteria was also not net in nonerous cases as will be discussed in Question 20 of this testinony.
Page 15 of the Danes and toore report indicated "that all frozen soils be renoved or reconpacted prior to resumption of operations."
ConstructionspecificationC-210("ConstructionforPlantFoundationand l
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Cooling Pond Dikes") did not address instructions for renoval or L
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recompaction of frozen / thawed naterial upon resunption of soil work.
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In addition to the above inconsistencies Dames & Itoore report (page
- 15) states that "all fill and backfill naterials should be placed at or 1
near optinun noisture content in nearly horizontal lifts approxinately sit to eight inches in loose thickness". Contrary to the above, the
.j Bechtel construction specification C 210, section 12.5.3 and C-211
(" Specification for Structural Backfill"), Section 5.2.2 stated, "in no' case shall the unconpacted lift thickness exceed 12 inches."
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Consumer's states the root cause of these inconsistencies as being that "During the preparation and early revisions of the PSAR there were i
no procedural requirements or nethods for docunenting the deposition of-consultant reconnendations in the PSAR". Consuners answer of notice of hearing (appendix, allegation 1(e) and 1(f)) "adnits to this allegation".
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.,_ The above responde fron donsuners supports the NRC finding that inadequate design control neasures were estabiished to assu're that i
license requirements to the NRC were translated'into consiruction specifications.' Thes'e inconsistencies violate'10 CFR 50, Appendix B s
Ci"terion III, Design Control.
Q.
- 20..Sunnarize Consuners & HRC discussion regarding lick of formal revisions of specifications to reflect clarifications of s
... e specification requirenents. (Iten 18(2))
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Discussion of this quality assurance deficiency is contained in t
(1) MAC RepBrt 72-20, pages 9-14, (2) Consumers response to 50.54(f) g.
3 Question 1 at ippendix I, pages 1 (t 'k.2) and page 3 (t S.2) (3) Con-J s
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suners response'to,50.54(f) question 2 Pat pages 23-8 and 23-9 (sub-M w
se: tion 3.2), and (4) Consumers answer to N:itice ofsHearing, appendix, s
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allegation,2(bf(1):
"s This quality assurancc;deficiench pisted fron ai ently as June 1974 s.
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dhrough -tha "substadtial' ~reductfon'iri sdil's'copstruction during 1978-79 s
.without correction. i m
,s Bechtel spe-ifihation C 510 centain[d conflicting requirenents in
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. sections l'3.7 'and'12.4' r'elatf 90..to the laloratory compaction standard to-Q 3
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be used.. Bechisl interoffice cenoranda, telexei and telEcons were used y,
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-in an attempt to clarify theiinkent o'f specification requirenents.
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..' Clarifications p' rov'ided through these nethods were takin by the user to 3-A-
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no'dify the specification',requirenents'pithout a design change or j
,g xy, specification change notice to the specification requirement..Conse-V U
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I quently, certain activities were not accomplished according to instruc-tions and procedures; specifically, the compaction criteria used for fill naterial was 20,000 foot-pounds (FT-LBS) of energy rather than a compactive energy of 56,000 FT-LBS as specified in Bechtel construction specification C-210, section 13.7.
Consumers states the root cause of this quality assurance deficiency as being " Engineering Project Instruction 4.49.1 did not address the use of interoffice nenoranda, nemoranda, telexes, twx's, etc. which night be interpreted by the user as modifying the requirenents of the specifica-tions." (Attachment 14).
Consumers Answer to tiotice of Hearing (appendix, allegation 2(b.)(1),
"adnits to this allegation".
c' The above response fron Consuners supports the i4RC finding that inadequate procedures for design control were established for the control of specification changes affecting the design bases. The lack of formal specification revisions violates 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings.
Q. 21. Sunnarize Consumers and f1RC discussion of inconsistencies of design bases within the FSAR relating to diesel generator b'uilding fill naterial and settlement values. (Iten 18(3))
A.
Discussion of this quality assurance deficiency is contained in (1) ilRC Report 78-20,'pages 6-8, (2) Consumers response to 50.54(f)
Question 1 at Appendix I, page 2 (1 A.3) and page 4 (1 B.3), (3)
Consuners response to 50.54(f) QunYon 23 at pages 23-10 and 23-11
. l(\\
(subsection 3.3) and (4) Consumers Answer to Notice' of Hearing, Appendix, 1(a).
This quality assurance deficiency existed fron late 1977 until FSAR revision 18 dated February 28, 1979.
Consumers response states that the FSAR submitted to the NRC (through Anendment 17) contained certain inconsistencies:
"a.
Tables 2.5-9 and 2.5-14 identify the foundations under the diesel generator building to be cohesive fill. The actual material specified and used wss randon fili, [ defined in FSAR Table 2.5-21 as any naterial free of hunus, organic, or other deleterious naterial also referred to as zone 2 naterial],
which includes cohesive and cohesionless naterial and concrete.
b.
FSAR Subsection 3.8.5.5 indicates a settlement of 1/2 inch for shallow spread footings (such as the diesel generator building).
FSAR Table 2.5-48 [which is referenced in FSAR i
section 2.5.4] indicates a settlenent of the diesel generator building of approximately 3 inches."
Consuners response continue,s:
"The. inconsistency between subsections 2.5.4 and 3.8.5 with respect to the settlement values [h inch vs. 3 inches] resulted because the two subsections were prepared by separate organizations (Geotechnical Services and Civ'il Engineering),
neither of which were aware of the nultiple display of similar infornation in the opposite subsection.
The inconsistency between FSAR Subsection 2.5.4 and the project design drawing (Drawing 7220-C-45) with respect to the fill naterial resulted because at the time of FSAR preparation the Geotechnical Services personnel preparing the FSAR were unaware, in this case, of the status of the design drawing prepared by Civil Engineering."
Consuners stated the root cause of these inconsistencies as being "the control document did not provide sufficient procedural control for preparation and review of the FSAR."
(The control docunent establishes procedure for preparation and control of Safety Analysis Reports.)
l l l (
Consumers Answer to Notice of Hearing (Appendix 1(a)), "Adnits to
~
this allegation" that " inconsistencies were identified in the license application and in other design basis documents".
The above response fron Consumers supports the NRC finding that inadequate design control neasures were established.
These inconsistencies'of design bases violates 10 CFR 50, Appendix 3, Criterion III, Design Control.
Q. 22. Sunnarize Consumers and NRC discussion of inconsistencies that were identified between the settlement calculations and the original design basis of the diesel generator building. (Item 18(4))
A.
Discussion of this quality assurance deficiency is contained in (1) HRC Report 78-20, pp. 20-1, (2) Consumers response to 50.54(f)
Question 1 at Appendix I, page 2 (1 A.4) and page 4 (1 B.4), (3)
Consumers response to 50.54(f) Question 23 at pages 23-12 and 23-13 (subsection 3.4), and (4) Consumers Answer to ilotice of Hearing, Appendix, allegations 1(b),(c) and (d).
This quality assurance deficiency existed from liarch 1977 until it was identified during an NRC investigation in 1978.
Consumers reponse to 50.54(f) states that:
"Settlenent calculations: for the diesel generator building-differ from the design requirenents in the following ways:
(1) A uniforn load of 3,000 pef was used rather than the 4,000 psf shown in Figurc. 2.5-47 in the FSAR.
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O O k (2) An index of.001 was used rather than the index of.003 shown in Table 2.5-16 in the FSAR.
(3) The calculations assumed a nat foundation rather than a spread footing foundation, which is the actual design condition.
and that, "The results of these erroneous calculations were included in the FSAR."
Consumers states one of the root causes of this quality assurance deficiency is:
" Diesel generator building foundation design changes initiated by Project Engineering were not coordinated with Geotechnical Services, as required by the control docunents."
Consuoer's Answer to Notice of Hearing (appendix, allegations 1(b),
(c) and (d)) adnits to this allegation for the diesel generator building.
The above response from Consumers supports the NRC finding that inadequate design control neasures were established to assure proper design control interfaces for-the diesel generator building. These inconsistencies violate 10 CFR 50, Appendix B, Criterion III, Design Control.
Q. 23.
Sunnarize Consumers and NRC discussion of the inadequate design coordination in the design of the electrical duct banks of the diesel generator building. (Item 13(5))
A.
Discussion of this quality assurance deficiency is contained ~in (1) HRC Report 78-20,'pages 23-24, (2) Consuners response to 50.54(f)~
question 1 at appendix I, page 3 (1 A.5) and page 5 (! B.5),-(3) Con-l L
1 l-
.. suners response to 50.54(f) question 23, pages 14-16 (subsection 3.5),
and (4) Consuners Answer to Notice of Hearing (appendix, 2(a)).
NRC determined that lean concrete naterial was permitted to be used in lieu of soil naterials without qualification as to location.
Consequently, lean concrete naterial was used around the electrical duct banks which were to pass through the foundation of the diesel generator building. This resulted in restricting the free movement of the founda-tion which contributed to the differential settlement of the building.
Consumers response states that, "Four vertical duct banks were designed and constructed without sufficient clearance to allow a relative vertical movenent between the duct bank and the building, and therefore restricted the settlement of the diesel generator building."
and that, "Neither electrical nor civil drawings show how or where to accon-plish the transition from the stub-up size to the underground duct i
size, nor do they show firm definition of duct size."
s Consumers identified the root cause of this quality assurance deficiency as being,
" Failure of the drawings to provide Construction with the information necessary to prevent interference."
Consumers Answer to Notice of Hearing (appendix, 2(a)), however, denies that instructions provided to field construction for substituting lean concrete for zone 2 naterial caused differential settlement.
Based on the NRC review if lean concrete naterial had not been used
~
around the electrical duct banks, free rovement could be achieved between -
the diesel generator building foundation and duct banks. This lack of free novement did contribute to the lack of. uniform settlenent. This was denonstrated by the innediate vertical-novenent of the structure once it was freed from the duct bank.
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This failure to provide adequate procedure and instructions to 1
assure activities have been satisfactorily accomplished violates 10 CFR 50, Appendix B., Criterion V, Instruction, Procedures and Drawings.
Q.
- 24. Sunnarize Consumers and NRC discussion of insufficient compactive effort used in backfill operation. (Iten IS(6))
A.
Discussion of this quality assurance deficiency is contained in (1) NRC Report 78-20 pages 9-14, (2) Consumers response 50.54(f) ques-tion 1 at appendix I, page 10 (1 A.1, 3.1) and (3) Consuaers response to 50.54(f) question 23, pages 23-17 and 23-18 (subsection 3.5)
This quality assurance deficiency existed from the inception of the
^
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plant fill operation in 1974 through the substantial reduction in soils construction in 1978-79.
Effective compactive effort depends on the size and type of con-paction equipment, the nunber of passes of the equipnent and the thick-ness of the soil layer being compacted. Soil specifications and field procedures should have required a " test fill" to denonstrate that a spegific piece of compaction equipment with a specific method (i.e.,
nunber of passes and soil layer thickness) could achieve the required in-place density. The in-process density tests would then serve as a continuous verification that the equipment selected and established nethod could cons'istently satisfy the requirements. The practice of qualifying compaction equipnent to a specified method is an acceptable industry practice. The practice of qualifying equipment was not enployed at the liidland site prior to placement of plant area fill activities.
8
.- Consumers response stated that, "There are no records available to indicate that the various types of compaction equipaent used for structural backfill were evaluated or qualified to handle the specified lift thicknesses and that appropriate lift thicknesses were established for each type of equipaent,"
~
and that, "Tnere were no field control documents or procedures to define requirements for the qualification of soils conpactio.' equipment.
There were no control docunents to govern the requirements for control measures pertaining to soils placement and conpaction."
Consumers stated that the root causes of insufficient conpactive effort used in backfill operations are, (1)
"The Quality Assurance Progran requirement to establish responsibility for measures to control the placenent and conoaction of soils and the qualification of construction equipment was not adequately inplenented, and (2) " Reliance was placed on in-place test results, or on the evaluaticn of the test results, for evaluating compaction equipnent.
Satisfactory soil test results, or evaluations of test results, inplied that adequate compactive effort was obtained and equipnent capability ond fill placement nethods were not questioned."
Consumers also admitted that, "Tnese [in-place] soil test results or their evaluations were in error in nonerous cases."
Incorrect soil test results will be discussed below in Question 31.
The above response from Consuaers supports the NRC finding that inadequate procedures were developed for'the construction of-the plant-area fill in order to assure that equipnent and nethods used were capable of obtaining the required compaction.
The failure to establish adequate procedures to assure use of.appro-priate compaction equipment violates.10 CFR 50, Appendix B, Criterion.V,
- nstructions, Procedures and Drawings.
l
26 -
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Q.
25.
Summarize Consumers and NRC discussion of insufficient technical direction in the field. (Iten 18(7))
A.
Discussion of this quality assurance deficiency is contained in (1) URC Report 78-20, pages 24-26, (2) Consumers response to 50.54(f),
question 1 at appendix I, page 10 (1 A.2 and B.2), (3) Consuners response to 50.54(f) question 23, pages 23-19 and 23-20 (subsection 3.7) and (4)
Consumers Answer to Notice of Hearing, aopendix, allegation 2(b)(2).
This quality assurance deficiency existed fron 1974 through the substantial reduction in construction in 1978-79.
Consuners response to 50.54(f) stated:
"Tne Danes & Moore Report.[pg.16] and the Civil-Structural Design Criteria 722C-C-501, Revision 9, Section 6.1.1 state, in part.
" Filling operations shall be perforced under the technical super-vision of a qualified soils engineer...."
" Technical direction and supervision were provided by Field Engineers and Superintendents who were assigned the responsibility for soils placement. The direction and supervision were not sufficiently employed."
and that, 4
"The technical direction and supervision provided were not properly deployed to overcone the lack of documented instructions and pro-cedural controls."
Consuners. states the root cause of this quality assurance deficiency as,
" Reliance on test results, or the evaluations. of testiresults, and surveillance by quality control instead of providing sufficient technical direction though documented instructions anc' procedural controls."
Consumers Answer to Hotice of Hearing (appendix, 2(b)(2)), "Adnits to this allegation" that soil activities were not accomplished under the i
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1
. - (.
technical supervision of a qualified soils engineer who would verify that
-all naterials would be placed and compacted in accordance with specifications criteria.
^
The above response from Consumers supports the NRC finding that technical supervision by a qualified soils engineer was not provided as required by procedures and instructions. The failure to implement pro-cedures to assure sufficient technical direction in the field violates 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings.
Q.
25.
Sunnarize Consumers and NRC discussion of inadequate quality control inspection of placement of fill. (Iten 13(8))
Discussion of this quality assurance deficiency is contained in (1)
HRC Report 73-20, pages 25-29, (2) Consumers response to 50.54(f) ques-tion 1 at appendix 1, page 13 (1 A.1) and page 14 (1 3.1), (3) Consuners response to 50.54(f) question 23, pages 23-21 and page 23-22 (subsec-
-tion 3.3) and (3) Consumers Answer to Notice of Hearing (Appendix 3).
This quality assurance deficiency existed from 1974 through the sub-stantial reduction in construction in 1978-79.
Consumers response stated that,
" Quality Control inspection of soils work did not identify defi-ciencies which nay have contributed to placement of fill that appears to have densities in place that.are lower than those specified."
and that, e
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28 -
"The inspection of soils was accomplished by " surveillance," and did not require verification of the controls specified in Specifications 7220-C-210 and 7220-C-211. Soil test results, or the evaluations of soil test results, were used as the basis for quality verification."
~
Consequently, adequate quality control verification of the soils work was not accomplished ~and resulted in the work not being perforned in accordance with requirenents to achieve the required compaction.
Consuners states two of the root causes as being, (1)
"Too nuch reliance was placed on the Quality Control Inspector's ability, without sufficiently specific inspection instructions," and (2)
" Reliance was place on soil test results, or on the evaluation of soil. test results, which were in error in numerous cases."
Consuaers Answer to Notice of Hearing (appendix,3) adnits "the degree of inspection or witnessing was reduced by going to a surveillance (sampling plan)" and that "the sampling (surveillance) plan was inade-quate in that it did not specify conditions or criteria under which there would be increased sampling or a return to 1000 inspection."
The. above responses froc Consumers. supports the NRC finding that adequate quality control inspection was not provided for the verification of soil work activities.
The inadequate quality control inspection of placement of fill violates 10 CFR 50, Appendix B, Criterion X, Inspection.
Q.
27.
Summa.rize Consuners and HRC discussion of inadequate soil noisture -testing. (Iten 18(9))
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Consumers identifies three of the root causes of inadequate noisture testing as being, (1)
" Reliance was placed on the infornal incorrect interpretations of the-specification relative to moisture testing.
(2) Reliance was placed on Quality Control surveillances of noisture testing.
(3) Reliance was placed on tne incorrect results of the density tests, or on the incorrect evaluation of the results, to the exclusion of the noisture test results."
Incorrect soil test results are discussed in response to Question 23.
Consuners Answer to Hotice of Hearing, (appendix, 4(a)) " denies this allegation to the extent that it is inconsistent with" a prior response subnitted by Consumers. That prior response is preliminary finding 6 of Attachnent 5.
Ity reading of that prior response leads ne to conclude that the requirenents for noisture conditioning prior to conpaction (as set forth in the second paragraph of this answer) was not verified in that " prior to August 1,1977 there were no noisture measurenents nade at the borrow area or when the loose fill was placed prior to or during compaction" and after August 1,1977 "noisture measurements were nade at the borrmi area but' were not compared to' the laboratory standards".
Tnis failure to take adequate corrective action to assure appro-priate soil' noisture testing _ violates 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.
Q.
28.
Sunnarize Consumers and NRC discussion of incorrect soil test results.(Iten18(10))
6
e 31 -
A.
Discussion of this quality assurance deficiency is contained in (1) Consumers response to 50.54(f) Question 1 at appendix I, page 13
-(1 A.3) and.page 15 (113.3) and (2) Consumers response to 50.54(f) Ques-tion 23, pages 23-26, 23-27 and 23-23 (subsection 3.10).
This quality assurance deficiency existed from 1975 through the
~
substantial reduction in construction in 1978-79.
A review of the soil test reports indicated fill density tests contain the following types of errors: (1) incorrect soil identification, (2) incorrect selection of laboratory standard (naxinun density and optinua noisture content) to be used for field control of in-place field density tests, (3) erroneous field density test data for those tests which indicate the soil to be in excess of 1001 saturated, a physical inpossibility, (4) calculation errors, and (5) improper clearing of failed test results. (See Bechtel July 1973 report referenced below.)
Gased on a Bechtel report to Consuners entitled, " Review Of U.S.
Testing Field & Laboratory. Tests On Soils", dated July 1979 (Attachnent 11), "Since more than one half of the test results for relative density and percent compaction fall outside the possible theoretical comparison limits, it must be concluded that these results are suspect and should not be used alone for acceptance of the plant ared fill". The Bechtel report also concludes that as a result of incorrect soil identification, incorrect selection of the laboratory standard, and erroneous field density test data, "there is no rational neans of deternining which test results are valid and which are not."
Consuners response to 50.54(f) requests identified the root cause of incorrect soil test results as, b
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... N.
" Technical procedures available to control the testing were inade-quate, and the technical direction of the testing operations did-not avoid or detect the incorrect soil test results."
This failure to provide adequate procedure to assure correct soil
~
test results violates 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings.
Q.
29.
Sunnarize Consumers and !tRC discussion of inadequate subcontractor test procedures. (Iten 13(11))
A.
Discussion of this quality assurance deficiency is contained in (1) Consumers response to 50.54(f) Question 1, at appendix I, page 13 (5 A.4) and page 15 (5 B.4) and (2) Consuners response to 50.54(f) Ques-tion 23, pages 23-29, 23-30 and 23-31 (subsection 3.11).
~
This quality assurance deficiency existed froa 1974 through the substantial reduction in construction in 1973-79.
Consuners response to 50.54(f) s tates that, "The procedures used for soils testing did not cover the following activities:
1.
Developing and updating _the family of proctor curves; 2.
Visually selecting the proper proctor curves; 3.
Dev' eloping additional proctor curves for changing naterials occurring between nornal frequency curves; and 4
Using alternative nethods of deternining the proper laboratory naxinun density where visual comparison is not adequate."
Consumers identifies the root 'cause of this quality assurance deficiency as being, O
" Adequate technical procedures for control of the-testing were not prepared."
This failure to provide adequate procedural controls for the soil testing activities violates 10 CFR 50, Appendix B, Criterion V, Instruc-tions, Procedures and Drawings.
Q.
30.
Summarize Consumers and NRC discussion of inadequate corrective action for repetitive nonconfonaing conditions. (Iten 18(12))
A.
Discussion of this quality assurance deficiency is contained in (1) NRC Report 78-20 pages 17-20, (2) Consuaers response to 50.54(f)
Question I at Appendix I, pages 21 (t A.1 and B.1) and (3) Consumers i
response to 50.54(f) Question 23, pages 23-32 and 23-33 (subsection 3.12), and (4) Consumers Answer to Notice of Hearing, Appendix 4(b).
This quality assurance deficiency existed fron 1974 through the substantial reduction in construction in 1978-79.
Consuners response states that, "Tnere were nonconfornances reported which are considered to be repetitive. These include, but are not linited to: CPCo [Censuners]
Nonconformance Reports QF-29, QF-52, QF-68, QF-120, QF-130, QF-147, QF-172, QF-174, QF-199, and QF-203; CPCo Audit Findings F-77-21 and F-77-32; and Bechtel Nonconformance Reports 421, 686, 698, and 1005."
A full description and supporting details of each of the above non-confornances ars discussed in Attachment 5, item 8.
Consumers states that the root causes of inadequate' corrective a:: ion for these repetitive nonconforning conditions as being.
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"1.
The conditions under which nonconforaances are considered to be repetitive are not adequately defined in the control docunents.
2.
The trending activity did not provide tinely responses to repetitive product nonconforning conditions."
Consumers Answer to Hotice of Hearing, appendix 4(b) states that
- the,
" Licensee admits that corrective action it initially took with regard to nonconformance reports related to plant fill did not 4
prevent nonconfornances at a later date in the area of plant fill construction."
Consuners reponse supports the NRC finding that inadequate a
corrective action was taken to assure that the cause of the condition was deternined and corrective action taken to preclude repetition.
This failure to_take adequate corrective action to preclude s
repetitive conditions violates 10 CFR 50, Appendix B, Criterion XVI, Corrective Action.
~
Q.
31.
Sunnarize Consuners and URC discussion of inadequate quality assurance auditing and nonitoring of plant fill work activities.
(Iten 18(13))
4 A.
Discussion of this quality assurance deficiency is contained in (1) Cons.urars response to 50.54(f) Question 1 at appendix I, page 21-(5 A.2) and page 22 (1 B.2) and (2) Consuners response to 50.54(f) Ques-tion 23, pages 23-34 and 23-35 (Subsection 3.13).
-This quality assurance deficiency existed 'fron 1974 through the substantial reduction in construction in 1978-79.
Consumers response states that, 9
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"The Bechtel Quality Assurance Audit and lionitor Progran did not identify the problens relating to the settlenent. This lack of identification of problems by the audit progran contributed to a conclusion that soils operations were adequately controlled."
dnd that, "In the case of soils operations, Quality Assurance auditing and nonitoring found that quality-related activities were being perforced as planned, quality verification activities (pricarily soil testing) were being performed, and the soil test results, or their evaluation, provided evidence of compliance with the established standards. The auditing and nonitoring did not identify the policy and procedure inadequacies."
Consumers identified the root cause of inadequate quality assurance auditing and nonitoring as being,
" Quality Assurance audit and nonitoring was oriented more toward evaluating the degree of compliance with established procedures rather than toward the assessment of policy and procedural adequacy or toward the assessment of product quality."
This failure to provide adequate quality assurance auditing and
/
nonitoring of the plant area fill violates 10 CFR 50, Appendix B, Criterion XVIII, Audits.
4 Q. 32.
What is the cause of the soil settlement problen at the l1idland Plant, Units 1 and 2?
Since the quality assurance progran in effect from 1974 through 1979 was ineffective in establishing and inplenenting sufficient quality assurance / quality controls to assure proper design, inspection and control of soils work under and around safety related structures 'I conclude that prior to Decenber 5,1979 tnere was a breakdown in the quality assurance progran.
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The foregoing quality assurance deficiencies resulted in the plant
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area fill being insufficiently compacted.
This failure to properly com-s pact the plant area fill was the cause of the soil settlement problem at l
the Midland Plant, Units 1 and 2.
~
CONCLUSION The quality assurance deficiencies related to soil construction activities under and around safety related structures and systems arising froa improper implementation of the quality assurance program provide adequate bases to modify the construction permits by suspending those soil construction activities.
203
}{$L LIST OF ATTACHMENTS Ib 1.
September 29, 1978: Initial 10 CFR 50.55(e) Report from Consumers 1
Power Co.
2.
November 17, 1978: NRC Inspection Report 78-12.
3.
Janua ry 12, 1979: Summary of. December 4,1978 meeting.
5 Februa ry 23, 1979: NRC Presentation of Preliminary Investigation f' 's Findings of the Settlement of the Diesel Generator Building.
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e
. r 5.
tiarch 9, 1979: Consumers Discussion of NRC Inspection Facts Resulting From NRC Investigation of the diesel generator building.
6.
March 21, 1979: NRC 10 CFR 50.54(f) Request Regarding Plant Fill, p
7.
March 22, 1979: NRC Inspection Report 78-20. -
8.
April 9, 1979: NRC Inspection Report 79-06 gi j g, f,Q(3"Ad-Jer % s 9.
April 24, 1979: Consumers Response to 10 CFR 50.54(f), Question 1.
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- 10. June 6, 1979: HRC Inspection Report 79-10. gj'j,s,[y,%
- 11. August 10, 1979: Bechtel Review of U.S. Testing Co. Field &
Laboratory Tests on Soils.
3-Til'* *9 -
NRC Inspection Report 79-19. g>v 5,P.y;,,.w.o c> d b 5=?L Sk-
- 12. October 1, 1979:
Meeting. 5 ca D e eF G C
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- 13. October 16, 1979: Summary of July 18, 1979 14 November 13, 1979: Consumers Response to 10 CFR 50.54(f), Question 23.
December 6, 1979: Order Modifying Construction Pennits.
April 16, 1980: Consumers Answer to Hotice of Hearing.
1.
Professional Qualifications of Eugene J. Gallagher.
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9
f, UNITED STATES OF AttERICA NUCLEAR REGULATORY COMit!SSION l
BEFORE THE AT0l11C SAFETY AND LICENSING BOARD In the Matterof
)
CONSU!!ERS POWER COMPANY Docket Nos. 50-329 OM & OL
)
50-330 01 & OL (iiidland Plant Units 1 and 2)
)
TESTIMONY OF JOSEPH D. KANE WITH RESPECT TO THE QUALITY QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6, 1979 Q.1. Please state your name and position with the NRC.
A.
fly name is Joseph D. Kane. tiy position with the U.S. Nuclear
!!egulatory Commission is Principal Geotechnical Engineer and I an assigned to the Geotechnical Engineering Section of the Hydrologic and Geotechnical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
Q.2. Have you prepared a statement of professional qualifications?
A.
Yes. A copy of this statement is attached.
Q.3. Please state the nature of the responsibilities that you have had with respect to the flidland Plant, Units 1 & 2.
A.
fly review involvement with the liidland project essentially began in November 1979 when I was assigned the responsibility of serving as technical nonitor for the interagency contract between the NRC and the U.S. Army Corps of Engineers, Detroit District (hereafter the Corps). The purpose of this interagency contract was to-obtain the
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service of expert technical personnel froa the Corps to assist the f!RC in the safety review of the liidland project in the field of geotechnical engineering. fly responsibilities as contract technical monitor include assisting the Corps in their review efforts, exanining and commenting on their evaluation reports and coordinating the Corps review efforts with other itRC Branches in technical areas of overlapping safety concern.
In addition I have assisted in preparation of interrogatories and responses to interrogatories with regards to the soil settlement problem at the Midland plant.
Since flovember 1979 my involvement in the review of the ;iidland project has steadily increased to the point that it is now the major portion of my work at f1RC.
In addition to responding
(
to Consuners appeal actions (e.g., the appeal of the June 30, 1980
\\
request for additional borings and laboratory testing) and participation in discovery deposition proceedings, I an extensively involved in the assessment of the adequacy of the renedial measures proposed by Consumers. These remedial fixes are necessary to address the nany problens caused by the unanticipated settlement of safety related' structures and piping due to the inproperly compacted plant fill.
t Q.4. Please state the purpose of this testimony.
A.
The purpose of this testimony is to-supplement the testimony prepared by Eugene J. Gallagher.
In response to-question 32,.Mr.
Gallagher stated that quality assurance deficiencies resulted in the plant i
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1 f.. (
My (es' inforiy ifemonstrates that -
fill being insufficiently compacted.
t if the original compaction control requirements set forth in the PSAR had been followed, the plant fill settlement problem would not have occurred.
Q.5. What is the ' asis for your response to Question 4?
b A.
As indicated in Mr. Gallagher's testimony in response to Question 22, the flRC at the PSAR licensing stage considered the designated mininum compaction criteria and recommended moisture content placenent control to be design and construction commitments by CPC.
(The compaction criteria and moisture control requirement at the PSAR stage are summarized in Table 2.5.4, sheet 3 of the FSAR in response to flRC question 352.15). The significance of these commitments is extremely important to the expected performance of the plant fill. The engineering profession widely recognizes the importance of adequate controls on compaction and noisture content for soils which are intended to satisfactorily support structures.
This wide recognition comes about because of the acknowledged relationship between the state of a soil's compactness and the soil's accepted behavior as an engineering material. CPC, when they indicated that soils which were to support structures would be compacted to a stated percentage of a laboratory established maximun density at a moisture content near optimum, were, in effect, convincing the flRC Staff at the-CP Stage that engineering properties of compressibility and shear strength would be acceptable.
What has been experienced at Midland (i.e., the plant fill significantly i
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settling under its own weight; foundation supporting safety related structures having very low penetration resistance to spoon samplers; and extensive cracking of structures founded on coapacted fill) proves that soils were not compacted to the designated mininua compaction criteria established at the PSAR stage.
Q.6. Do other engineers share your conclusion that the cause of the plant fill settlement problem resulted from inadequate compaction or construction of an unsatisfactory plant fill?
A.
Yes. Engineers fron both the Corps and the NRC staff have the opinion that inadequate compaction and failure to attain the niniaun compaction criteria designated at the PSAR stage are the major
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reasons for the settlement problen at Midland.
In addition, in ny
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a opinion, statenents obtained in the discovery depositions from Bechtel and their consultants support this conclusion. The following is from lines 7-10 at page 97 of the deposition of Sherif Afifi (Bechtel employee) taken on October 29, 1980; BY HR. PAT 0ll:
Q.
Doctor, do you have any opinion as to what caused the extensive settlement problem in the plant fill at tiidland?
A.
Inadequate compaction.
The following is from lines 18-25 at page 15 and lines 1-3 at page 16 of the deposition of Dr. Ralph B. Peck (Bechtel consultant) taken on January 13, 1981; Q.
All right. What is your opinion of the quality of the soils placement that had taken place prior to your being hired.on the Midland project?
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1 MR. FARNELL:
Are you talking about the whole power plant? Or are you talking about specific parts of it?
MR. J0NES: The soils portions of the project with which he was closely associated.
A.
My opinion, or perhaps you could say it was ny conclusion was that the fill beneath the diesel generator building area and sale neighboring. areas was not a satisfactory fill.
The following is from lines 5-16 at page 41 of the deposition of Dr.
Alfred J. Hendron (Bechtel consultant) taken on January 27, 1981; Q.
With respect to your construction of the fill do you have any opinion as to the quality of that work?
Were you going to speak?
MS. BLOOM:
Yes, I was going to -- I think we have outlined what kind of work we are talking about here.
MR. J0NES:
Construction of fill?
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THE WITNESS:
I think when a fill is settle two to four inches under its own weight.and some places have a very low slow
[ sic] count which obviously something went wrong and I cannot say whose fault or what it might have been, but, there were some bad fills there, not as good as it should have been.
I shouldn't say bad fills, there is a difference.
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PROFESSIONAL QUALIFICATIONS AND EXPERIENCE NAME:
Joseph D. Kane ADDRESS:
'7421 Miller-Fall Road Derwood, MD 20855 EDUCATION:
B.S. Civil Engineering 1961 Villanova University M.S. Civil Engineering 1973 Villanova University Post-degree studies, Soils and Foundation Engineering University of California 1972 University of Maryland 1978 PROFESSIONAL REGISTRATION:
Registered Professional Engineer (1966) - Pennsylvania 12032E PROFESSIONAL SOCIETY:
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American Society of Civil Engineers x
EMPLOYMENT POSITIONS:
February 1980 - Present Principal Geotechnical Engineer U.S. Nuclear Regulatory Comission -
May 1977 - February 1980 Geotechnical Engineer U.S. Nuclear Regulatory Commission October 1975 - May 1977 Soils Engineer U.S. Nuclear Regulatory Comission August 1973 - October 1975 Supervisory Civil Engineer Chief, Soils Design Section U.S. Army Corps of Engineers Philadelphia District January 1963 - August 1973 Civil Engineer Soils Design Section U.S. Army Corps of Engineers Philadelphia District l
January 1962 - January 1963 Design Engineer McCormick - Taylor Associates Philadelphia, Pa.
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Professional Qualifications -[
and Experience Joseph D. Kane PROFESSIONAL EXPERIENCE
SUMMARY
1975 to Present In f1RC Division of Engineering, Geotechnical Engineering
-Section, Mr. Kane has specialized in soil mechanics and foundation engineering.
Experiences in this position have included the following:
a.
Evaluation of the foundation adequacy of proposed sites for nuclear facilities with respect to design and operational safety. This work has included evaluation of geotechnical, soils and rock mechanics, foundation and earthquake engineering related aspects.
The results of this review effort are summarized in a safety evaluation report for each of the proposed facilities which have included nuclear power plants, nuclear fuel reprocessing plants and uranium mill tailings waste systems.
b.
Serving as a technical adviser for soil and foundation engineering related aspects in the development of regulatory guides, acceptance and perfomance criteria
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that are intended to assure construction and operational safety of nuclear facilities.
c.
Serving as a technical representative for the Office of Nuclear Reactor Regulation on the f4RC Advisory Group concerned with federal dam safety.
d.
Serving as an instructor for the Office of State Programs in the training of state personnel who are responsible for construction and operational inspections of uranium mill tailings embankment retention systems.
1963 to 1975 During this period Mr. Kane was employed with the U.S.
Amy Corps of ingineers, Philadelphia District and attained the position, Chief, Soils Design Section, Foundations and Materials Branch, in 1973.
Professional experiences with the Corps of Engineers have included the following:
a.
The embankment and foundation design of four large multi-purpose earth and rockfill dams with appurtenant structures (spillways, inlet and outlet structures, control towers, flood protection facilities, etc.).
Responsibilities ranged from tha initial planning of
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Professional Qualifications :f and Experience Joseph D. Kane subsurface investigations to select the most feasible sites through all design stages which were culminated in the final preparation of construction plans and specifications. This work included planning and evaluation of laboratory testing programs, studies on slope stability.
' seepage control and dewatering systems, settlement, be3 ring capacity, liquefaction 3 embankment safety instrumentation and slope protection.
b.
Served as'a technical consultant to field offices charged with construction inspections for assuring completion of structures in compliance with design analysis and contract specifications. Participated in the development of needed modifications during construction whenever significant changed site conditions were uncovered.
- c.. Directed the efforts of engineers in the Soils Design Section in other fields of civil work projects that '
included the embankment and foundation design of
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levees, waterfront pile supported structures and disposal basins for the retention of hydraulic dredge waste.
1962 to 1963 Served as design and project engineer for private consulting firm. This work included the design of large federally funded highways, a race track and various structures constructed to provide a Pennsylvania State park marina.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & 0L 50-330 04 & OL (Midland Plant, Units 1 and 2
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NRC STAFF TESTIMONY OF JAMES G. KEPPLER WITH RESPECT TO THE QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6, 1979 Q. 1.
Please state your name and position with the NRC.
A.
My nane is James G. Keppler.
I am Director of the U.S.
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Nuclear Regulatory Commission's Region III (Chicago) Office and have held 7
that position since September, 1973. A statement of my professional experience is attachment 1.
Q. 2.
Please summarize your past involvement with Consumers Power Company's implementation of quality assurance at the Midland site prior to December 6,1979.
A.
In connection with our on-going assessnent of quality assurance inplementation at Midland, ny staff developed a chronological listing of major events and problems at the site which includes quality assurance deficiencies. These events and problems are set forth in attachment 2 (dated February 15,1979) and attachment 3.(dated October 18,1979).
I was personally involved in deciding the regulatory actions taken for the more significant problems described in attachments 2 and 3.
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When did you first learn of the apparent excessive settlement of t'.'e' diesel generator building?
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A[ I'm not certain as to the actual date I personally became 4
aware of the dieseF generator building settlement problem; however, a written 10 CFR 50.55(e) notification was made to Region III by the q
licensee on September 25, 1978 concerning the problem.
I became personally involved with the problem following an NRC inspection on
, 0,ctober 24-27, 1978 which was conducted as a followup to the licensee's report of the matter. This inspection was conducted by Eugene J.
m.
1 Gallagher of-my staff and is documented in attachment 2 of his testimony._.
lAfter being briefed on the inspection findings by fir. Gallagher, I diracted my staff to conduct a comprehensive investigation into the matter to determine whether the problem had been reported to the NRC in a
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' timely manner, to verify the degree of conformance with commitments made by the licensqe in the Final Safety Analysis Report, and to assess the root cause(s) 0f tha problem.
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Summarize the-investigation findings sarid your role in the
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assessmedt'of thesF. tindings.
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The detailed infestigatkr hr
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Attachmenth 4.and 7 -to the te'stimony of Eugene J.'Gallagher.
Five Region s
bl nanagemek representatives (including myself) were briefed initially by the investigation team on February 16, 197F.
Based on thosc detailed
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.w nvestigation findlings, it was our unanimousqonclusion that the -
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implementation of the quality assurance / quality control progran for assuring the proper soil foundation for the site was ineffective.
In addition, several of the commitments in the FSAR related to this work had not been adhe' red to. With respect to the reportability consideration, we agreed that the T1RC had been informad of the proble.a in a timely manner once it had been identified. Based on this briefing, I instructed my staff to set up a meeting with Consumers Power Company to inform them of our investigation findings. Two meetings were held with the licensee relative to this investigation (February 23, 1979 and !! arch 5,1979).
I participated in both meetings. A summary report of these meetings (Attachments.4 and 5 to the testimoni of Eugene J. Gallagher) was provided to the licensee in my letter dated tarch 15, 1979.
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Q. 5.
Surrarize subsequent actions taken by you with respect to the soil settlement problem.
A.
Following the ilRC investigation and related meetings with the licensee, Region III management reached the following conclusions:
(1) The technical issues associated with improperly compacted soil needed review and evaluation by flRR. This conclusion resulted in my memorandum of March 12, 1979 to lir. Thornburg (attachment 5).
(2) The deficiencies identified with respect to implementation of the quality assurance program were limited to soils wo'rk.
Since the q
original soil placement activities had been substantially completed, no attempt was made at this time to. stop soil work.
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(3) Several commitments in the FSAR were incorrect and required review by HRR and ELD to determine whether they constituted naterial false statements.
This conclusion resulted in my memorandum of April 3, 1979 to.Mr. Thornburg.
Q. 6.
What was the disposition of your recommendations and how does that action relate to the Order that was issued on December 6, 1979?
A.
On March 21, 1979 the NRC's Office of Nuclear Reactor Regulation issued a 10 CFR 50.54(f) request to Consumers Power Company
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requiring the licensee to provide additional information regarding the adequacy of the plant fill and the root causes and corrective actions to be taken regarding quality assurance deficiencies.
I participated in meetings at headquarters which led to the issuance of the December 6,1979 Order Modifying Construction Permits.
I supported issuance of that Order.
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,f JAMES G. KEPPLER - BIOGRAPHICAL INFORMATION James G. Keppler has been Regional Director of the Nuclear Regulatory Commission's Region III Office of Inspection and Enforcement since 1973.
(The Nuclear Regulatory Commission was formed in January 1975 to take over the regulatory functions of the old Atomic Energy Commission (AEC).
The research and developmsnt activities of the AEC were assumed by the Department of Energy.).
The Regional Offic'e in Glen Ellyn is responsible for inspection and enforcement activities at NRC licensed facilities in eight midwestern states. This encompasses 20 nuclear power plants now in operation, 21 plants licensed for construction or under licensing review, 12 operating research reactors, four fuel facilities and approximately 3700 byproduct materials licenses -- generally for medical, industrial, research or educational applications.
Mr. Keppler joined the AEC in 1965 as a reactor inspector. Prior to his present post as Regional Director, he was Chief of the Reactor Testing and Operations Branch in the AEC Headquarters in Bethesda, Maryland.
He is a 1956 graduate of LeMoyne College in New York State.
Mr. Keppler's.
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experience in the nuclear field includes nine years with General Electric Company, first in its Aircraf t Nuclear Propulsion Department and later in its Atomic Power Equipment Department.
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February 15, 1979
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h MEMORANDUM FOR:
H. D. Thornburg, Director, Division of Raaetor Construction Inspection, IE FROM:
James G. Esppler, Director SU3 JECT:
MIDLAND SLHMA.RY REPORT The attached report, which represents Region III's overall assessment of the Midland construction project to date from a regulatory standpoint, was discuased with you and representatives from your staf f, h'RR, and OELD during our meeting at HQ's on February 6,1979. During that meeting, it was concluded that this report should be provided to OELD for transmittal to the Licensing Board and the various parties to the Hea ring. As such, this information is being forwarded for your action.
We believe the meeting was quite useful in receiving feedback from the
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various NRC people involved relative to our position on the status of
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this facility.
Please contact me if you have any questions regarding this matter.
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James C. Imppler Director Attachnent:
Midland Sum.ary Report 1
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MIDLAND SLT'ARY REPOR*
Facility Data
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Docket Numbers 329 and 50-330 Construction Permits
- CPPR-81 and CPPR-82 Per its Issued
- December 14, 1972 Type Reactor
- PWR; Unit 1, 492 We * ; Unit 2, 818 We NSSS Supplier
- Babcox & Vilcox Design / Constructor
- Bechtel Power Corporation Fuel Load Dates
- Unit 1, 11/81; Unit 2, 11/60 Status of Construction - Unit 1, 52%, Unit 2, 56*; Engineering 80*;
- Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Che Ical Corporation, through appropriate isolation heat exchangers. Capability exists to alternate to Unit 2 for the stea= source upon demand.
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Chronological Listing of Major Events July 1970 start of Construction under exemption 9/29-30 &
Site inspection, four ite=s of noncomplia'nce identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 11/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order 12/29/73 Licensee answers Show Cause Order cor::.its to improvements on QA program and QA/QC staff 12/3/73 Show Cause Order issued suspending cadwelding operation 12/6-7/73 Special inspection conducted by RIII '& HQ personnel 12/17/73 Show Cause order modified to illow cadwelding based on inspection findings of 12/6-7/73 k
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12/5/7d CP reported that rebar spacing out of' specification 50 locations in Unit 2 containment
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3/5 & 10/75 CF reported that 63 f6 rebar were either cisjsing er r.isplaced in Auxiliary Building
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3/12/75 RIII held management meeting with CP i
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_CPreportedthat32#8rebarwereomitted14 Auxiliary Building. A stop-work order was issued by CP
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3/26/76 Rill inspector requested CP to inform RIII when step-wcrk order to be lif ted and to investigate the cause and the extent of the problem. Additional rebar probleer identified during site inspection 3/31/76 CP lifted the stop-werk order 4/19 r.hru RIII performed in-depth QA inspection at Midland 5/1c/76 5/14/76 RIII =anagement discussed inspet. tion findings with site personnel 5/20/76 RIII management meeting with CP 7 resident, Vice President, and others.
6/7 6 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction com=itments 6/1-7/1/76 Overall rebar omission reviewed by R. E. Shew aker 7/28/76 CP stops concrete placement work when further rebar place =ent errors found by their overview program.
PN-III-76-52 issued by RIII 8/2/76 RIII recomends HQ notice of violation be issued
&/9 - 9/9/76 Five week full-time RIII inspection conducted
~/13/76 Notice issued 8
10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of containment liner discovered 4/19/77 Tendon sheath omissions of Unit I repor.ted i
4/29/77 IAL issued relative to tendon sheath placement errors l.
l 5/5/77 Management' meeting at CP Corporate Office rdlative to i
IAL regarding tendon sheath problem
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5/24-27/77 Special inspection by RIII, RI and HQ persennel to deter =ine adequacy of QA program implementation at Midland site r
6/75 - 7/77 Series of meetings and letters between CP ad! NPS on
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applicability of Regulatory Guides to Pddland.
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Com=itments by CP to the guides was responsive 7/24/78 Construction resident inspection assigned 8/21/78
. Measurements by Bechtel indicate excessive settle:ent of Diesel Generator Building.Of ficially reported to RIII on September 7, 1978 12/78 - 1/79 Special investigation / inspection conducted at Midland sites Bechtel Ann Arbor Engineeringcffices and at CP corperate offices relative to Midland plant fill and Diesel Generator building settlement problem
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Selected Major Events 1
Past Problees i
1.
Cadueld Splicing Problem and Show Cause Order i.
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7 A routine inspection, conducted on November 6-8, 1973, as a result of intervenor information, identified eleven examples 4'
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of four noncompliance items relative to rebar Cadvelding operations. These items were sum =arized as:
(1) untrained
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Cadweld inspectors; (2) rejectable Qidwelds accepted by QC 4}
inspectors: (3) records inadequate to establish cadwelds met g
requirements ; and (4) inadequate procedure'.
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i As a result, the licensee stopped work on cadweld operations en November 9,1973 which in turn stopped rebar installation 0 Ihe licensee agreed not to resume work until the NRC reviewed l
and accepted their corrective action. However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1973 RIII and HQ personnel conducted a special inspection and determined that construction j
activity could be resur:ed in a manner consistent with quality criteria. The show cause order was modified en December 17, j
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i 1973, allowing resumption of Cadwelding operations based on the inspection results.
i The licensee answered the Show Cause Order on December 29, 1973, I
committing to revise and improve the QA manuals and procedures and make QA/QC persennel changes.
i Prehearing conferences were held on March 26 and May 30, 1974, and the hearing began on July _16,1974. On September 25, 1974, j
the Hearing Board found that the licensee was implementing its j
l QA program in compliance with regulations and that construction I
should not be stopped.
1 2.
Rebar omission / Placements Errors Leading to-IAL I
Initial identification and report of rebar nonconformances l
occurred during an NRC. inspection conducted on December 11-13, l
1974 The licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to i
l 652' - 9" of Unit-2 containment. This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of i
i noncompliance in report Nos. 50-329/74-11 acid 50-330/74-11.
Additional rebar deviations and omissions.were identified in-3 March and August 1975 and in April, May and June 1976.. Inspection
, report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.
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f, Licensee response dated June 18, 1976, listed 21 separate ite=s (co=nitments) for corrective action. A June 24, 1976 letter provided a plan of action schedule for imple=enting the 21 ite=s.
The licensee com:itted not to resume efpncrete i
place =ent work until the items addressed in licenbee's June 24 7
- letter vere resolved or imple=ented.
This coc=itment was documented in a RIII letter to the licensee dated June 25, 1976.
Although not stamped as an IAL, in-house =emos referred to it as such.
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Rebar installation and concrete place =ent activities were resu=ed in early July 1976, following completion of the items and verification by RIII.
Additional action taken is as follows:
a.
By the NRC (1) Assignment of an inspector full-time on site for five weeks to observe civil work in progress (2) IE management meetings with the licensee at their corporate of fices I
(3) Inspection and evaluation by headquarter perscnnel b.
By the Licensee (1) June 18, 1976 letter coc=itting to 2.1 ite=s-of corrective action (2) Establishment of an overview inspection progra to provide 100* reinspection of embed =,ents by the licensee following acceptance by the contractor QC personnel c.
By the Contractor (1) Personnel changes and retraining of personnel (2) Prepared technical evaluation for acceptability of each identified construction deficiency (3)
I=provement in their QA/QC program coverage of civil work (this was i= posed by the licensee) 3.
Tendon Sheath Placement Errors and Resulting Immediate Action Letter (IAL)
' On April 19, 1977, the licensee reported, as a Part 50, Section l
50.55(e) item, the inadvertent e=ission of two hoop tendon
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sheaths from a Unit 1. containment concrete placement at 6
I elevation 703' - 7".
The tendon sheaths were, for the cost part, located at an elevation in the next higher 4cncrete placement lift, except that they were diverted t6 the lower place ent lift to pass under a steam line penetr(tion and it was where they were omitted.
Failure to rely ~en the proper source documents by construction and inspection
' personnel, contributed to the emission.
An IAL was issued to the licensee on April 29, 1977, which spelled out six licensee commitments for correction which included:
(1) repairs and cause corrective action; (2) expansion of the licensee's QC over view progra=; (3) revisions to procedures and training of construction and inspection personnel.
A special QA program inspection was conducted in early Fay 1977, The inspection team was made up of personnel froc RI, RIII, and 2
HQ. Although five items of noncocpliance were identified, it was the concensous of the inspectors that the licensee's progra: vas an acceptable program and that the Midland construction activities were ce= parable to most other j
construction projects.
The licensee issued its final report on August 12, 1977. Final review on site was conducted and documented in report No.
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50-329/77-08.
Current Problems 4
1.
Plant Till - Diesel Generator Building Settlement The licensee informed the RIII of fice on Septe=ber 8,1978, of per requirements of 10 CTR 50.55(e) that settlement of the diesel generator foundations and structures were greater than
- expected, i
Till material in this area was placed between 1975 and 1977, with construction starting on diesel generator building in mid-1977. Tilling of the cooling pond began in early 1978.
with the spring run-of f water. Over the year the water level has increased approximately 21 feet and in turn increasing the site gound water level.
It is not known at this time what effect (if any) the higher site ground water level has
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had on the plan fill and excessive settlement.of the Diesel Generator Building. It is interesting to note however, that initially the PSAR indicated an underdrain system would be installed to maintain the ground water at its normal (pre pond) level but that it later was deleted.
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l The NRC activities, to date, include:
Transf er of lead responsibility to NRR from ;1E by me=o a.
dated November 17, 1978 i
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Site meeting on December 3-4, 1978, between 17Jt, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel-Generator Building settlement c.
RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement The Constructor / Designer activities include:
a.
Issued NCR-1482 (August 21, 1978) b.
Issued Managecent Corrective Actic.n Report (MCAR) No. 24 (Septe=ber 7,1976) c.
Prepared a proposed corrective action option regarding placement of sand overburden surch.'rge to accelerate and achieve proper co:paction of ditsel generator building sub soils
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Preliminary review of the results of the RIII investigation /
inspection into the plant fill / Diesel Geaorator Building settlenent problem indicate many events occurred between late 1973 and early 1978 which should have alarted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit findings, field memos 4
to engineering and proble=s with the administration building fill which caused modification and replace =ent of the already poured footing and replacement of the fill material with lean concrete.
2.
Inspection and Quality Docu=entrtion to Establish Acceptability of Equipment This problem consists of two parts and has just recently been identified by RIII inspectors relative to Midland. The scope and depth of the problem has not been determined.
Ths first part concerns the adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes that the equipment meets specification and environ = ental requirements. The licensee, t
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on Nore ber 13, 1978, issued a construction deficiency report (10 CTR 50.55(e)) relative to this matter. Whether the reper.t_...
was triggered by RIII inspector inquiriesfor by IE Circular or Bulletin is not known. An interim report datep November 28 1978 was received and stated Consumers Power was pursuing this 7
matter not only for Bechtel procured equipment but also for
- NSS supplie_d equipment.
The second part of the problem concerns the adequacy of equip =ent acceptar.ce inspection by Bechtel shop inspectors.
Examples of this proble= include:
(1) Decay Heat Removal Pu=ps released by the shop inspector and shipped to the site with one pump assembled backwards, (2) electrical penetratier.4 inspected and released by the shop inspector for shipment to the site. Site inspections to date indicate about 25% of the vender wire ter=inations were improperly crimped.
Inspection Historv The construction inspection program for Midland Units 1 and 2 is approximately 50% ce=plete. This is consistent with status of construction of the two ur.it s.
(Unit 1 - 52%; Unit 2 - 56%)
In terms of required inspection procedures approxicately 25 have been completed, 33 are in progress and 36 have not been initiated.
The routine inspection program has not identified an unusual number of enforcement items. Of the selected major events described above, only one is directly attributable to RIII enforcement activity (Cadweld splicing). The other were identified by the licensee and reported through the deficiency report system (50.55(e)). The Midland data for 1976 - 78 is tabulated below.
Number of Number of Inspector Hours Year Noncocpliances Inspections on Site 1976 14 9
646 1977 5
12 648 1978 11 18 706 A resident inspector was assigned to the Midland site in July 1978.
The on site inspection hours shown above does not include his inspection time.
The licensee's QA program has repeatedly been subject,to'in-depth review by IE inspectors.
Included are:
1.
July 23-26 and August 8-10, 1973, inspection report No:s. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the impfementation of the Consumers Power Company's QA manual and Bechtel Corporation's QA program for design activities at the Bechtel Ann Arbor office. The identified concerns were reported as discrepancies k'
relative to the Part 50, Appendix 3, criteria requirements.
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September 10-11, 1973, report Nos. 50-329/73-08 and 50-330/73-08:
A detailed review of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving thre( separate Appendix 5 criteria with five different examples, werd identified.
3.
February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A i
followup inspection at the liceasee's corporate office, relative to i
the items identified during the September 1973 inspection (above) along with other followup.
4.
, June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: Special
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inspection conducted at the licensee's corporate office to review the new corporate QA program manual.
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August 9 through September 9, 1976, report Nos. 50-329/76-08 and 50-330/76-08: special five-week inspection regarding QA program implementation on site primarily for rebar installation and other civil engineering work.
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May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: special inspection conducted at the site by RIII, IE and RI personnel to examine the QA program implementation on site by Consumers Power Company and by Bechtel Corporation. Although five exa=ples of noncompliance to Appendix B Criterion V, were identified, the
. 7 consensus of the inspectors involved was that the program and its i
g implementation for Midland was considered to be adequate.
1 Although the licensee's Quality Assurance program has under gone a number l
of revisions to strengthen its provisions, no current concern exist regarding its adequacy.
Their Topical QA Plan has been ' reviewed and accepted by NRR through revision 7.
Implementation of the program has j
been and continues to be subject to further review with the mid-construction program review presently scheduled for March or April 1979.
Censumers Power Company expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This began in 1975 with.a commitment early in their experience with rebar installation i
problems and was further committed by the licensee in his letter of June 18, 1976, responding to. report Nos. 50-329/76-04 and 50-330/76-04.
This overview inspection activity by the licensee has been very effective l
as a' supplement to the constructor's own program.
Currently, this program is functioning across all significant activities at the site.
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Enforcement History Approximately 6 months af ter restart of construction activities (11 months i
af ter CP issuance) an inspection identified four noncompliance items regarding cadwelding activities. This resulted in a show eause order l
being issued on December J,1973. This enforcement action was aired publicly"during hearings held by the Atomic Safety Licensing Board in May 1974. The hearing board issued its decision in Septe Ler 1974
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that concluded that construction could proceed with adequate assurance of quality.
l Identification of reinforcing bar problems began in Decembe of 1974 vith the licensee reporting improper spacing of rebar in the Unii 2 conta1==ent 4
I vall. Further reinfo.rcing bar spacing and/or omission of rebar was identified in August 1975 and again in Ma" 1976 with the citations of 5 noncompliances in an inspection report. An IE:HQ notice of violation was issued regarding the citations in addition to the licensee issuing a stop work order. The licensee issued a response letter dated June 18, 1976 co==1tting to 21 items of corrective action. A Bechtel prepared j
technical assessment for each instance of rebar deficiency was submitted i
to and review by IE:HQ who concluded that the structures involved vill satisfy the SAR criteria and that the function of these structures will be maintained during all design conditions. The RIII office of NRC performed a special five week inspection to assess the corrective action i=ple=entation withoat further citation.
The licensee reported that two hoop tendon sheaths were omitted in concrete place =ents of Unit 2 containment vall in April 1977. An I:=ediate Action Letter was issued to the licensee on April 29, 1977 q
listing six ite=s of licensee com=itments to be completed. A special inspection was perfor=ed on May 24-27, 1977 with four NRC inspectors (1-HQ, 1-RI, and 2-RIII). Although five items of noncocpliance were
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identified, it was the consensus of the inspectors that the QA/QC
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progra: in effect was adequate. The constructors nonconformance report provided an alternate method of installation for the tendon sheaths 4
that was accepted.
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The RIII office of inspection and enforcement instituted an augmented 3
on site inspection coverage program during 1974, this progr,am has continued in effect ever since and is still in effect.
It is noted that I
the nonce:pliance history with this program is essentially the same as the history of other RIII facilities with a comparable status of V
l construction. Further on site inspection aug=entations was accomplished i
kith the assignment of a full time resident inspector in August, 1978.
Ihe noncompliance history for the Midland Project is provided in the following table.
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ENTORCEMENT ACTIONS Noncompliances
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Criteria (10 CTR 50 Appehdix B)
Year
- Total
( ) Number of Occurtances 5
1970 4
V, X, XI, XVI 1971-1972 0
Construction haulted pending CP 1973 9
II V(5) XIII, XV, XVII 1974 3
V(2) X*1 1975 0
1976 10 V(4)
X, XII, XV, XVI, XVII, XVIII 1977 5
V(5) 10 CTR 50.55(e) item 1978 11 V(4) VI(2), VII IX(3), XVI
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Criteria II QA Program V
Instructions Procedures Drawing Control Vork -
VI Document Control VII Control of Purchased Material IX Control of Special Processes X
Inspection XII.
Control Measuring - Test Equipment XIII Handling - Storage XV Nonconforming Parts XVI Corrective Actions XVII QA Records XVIII
" Audits 4
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Su=arv and Conclusions Since the' start of construction Midland has experienced some significant problems resulting in enforcement action.
In avr.luating these problems they have occurred in clumps:
(1) in September 1970 relatiive to improper placement, sacpling and testing of concrete and failure of DA/QC to act on identified deficiencies; (2) in September 1973 relative to drawing 3
7 control and lack of or inadequate procedures for control of design and procurecent activities at the Bechtel Engineering offices : (3) in
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November 1973 relative to inadequate training, procedures and inspection of cadueld activities; (4) in April, May and June 1976 resulting from a series of R111 in-depth QA inspections and meetings to identify i
underlying causes of weakness in the Midland Q4 program implementation i
relative to embedments.
(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, all primarily concerned with installation of reinforcement steel); (5) in April 1977 relative to tendon sheath omissions ; and (6)
L in August 1978 concerning plant soil foundations and excessive settlement of the Diesel Generator Building.
Following.each of these problee periods (excluding the last which is 4
still under investigation), the licensee has teen responsive and has
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taken extensive action to evaluate and correct the problem and to up-j grade his QA prograr. and QA/QC staff. The most effective of these
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licensee actions has been an overview program which has been steadly
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expanded to cover almost all safety related activities.
The evaluation both by the licensee and II of the structures and equipment affected by these problems (again except the last) has established that they fully meet design requirements.
i Since 1974 these problems have either been identified by the licensee's l
quality program or provided direction to our inspectors.
leoking at the underlying causes of these probleus two common threads emerge:
(1) Consumers Power historically has tended to over rely on Bechtel, and (2) insensitivity on the part of both Bechtel and Consumers l
Power to recognize the significance of isolated events or failure to adequately evaluate possible generic application of these events either of which would have led to early identification and avoidance of the problem including the last on plant fill and diesel generator building l
settlement.
Notwithstanding the above, it is our conclusion that the problems experienced are not indicative of a broadbreakdown in the overall quality i
assurance program. Admittedly, deficiencies have occurred which should have been identified earlier by quality control personnel, but the 7
i licensee's program has been effective in the ultimate identification and.
I subsequent correction of these deficiencies. While we cannot dismiss tha.
possibility that problems *may have. gone undetected by the licensee's overall quality assurance program, our inspection program has not identified r
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significant problems overlooked by the licensee -- and this inspection
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effort has utilized many different inspectors.
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The RIII project inspectors believe that continuation of:
(1) resident site coverage, (2) the licensee overview program including,Jts recent expansion into engineering design / review activities, and (3) a continuing inspection program by regional inspectors vill provide adeguate assurance that construction vill be perforined in accordance with requirements and that any signif1 cant errors and deficiencies will.be identified and corrected.
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e' " '" ' N UhlTED $TATES 8,,,
NUCLE AR REGULATORY COMMISSION i
le 'It E
RE GION ill L a'W#., /
73, coostvt ti RO AD E~?,y%.g ci.tu ILtvu. imsois som p
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October 18, 1979 Y
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2 MEMORANDUM FOR:
R. C. Knop R. Cook
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D. W. Hayes T. Vandet C
D. H. Danielson F. Jablonski K. Naidu E. Lee G. Maxwell G. Gallagher W. Hansen K. Ward P. Barrett I. Yin FROM:
G. Fiorelli, Chief, Reactor Construction and Engineering Support Branch
SUBJECT:
MIDLAND CONSTRUCTION STATUS REPORT AS OF OCTOBER 1,1979 s..
The attached report was finalized based on your feedback requested in sy memo of October 5,1979. If you stiLL feet adjustments are necessary please contact me.
If you consider the report characterizes your current assessment of the Midland project, please con' cur and pass it along promptly.
E. Fioretti, Chief 4
Reactor Construction and
Enclosure:
.As stated Engineering Support Branch cc:
J. G. Keppler l
i bM.J[ di J gf.7,g Ibpr 1
MIDLAND
SUMMARY
REPORT UPDATE Facility Data Docket Number 329 and 50-330 j
Construciion Permits-
- CPPR-81 and CPPR-82 Permits Issued
- December 14, 1972 Type Reactor
- PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS
- Babcock and Wilcox Design / Constructor
- Bechtel Power Corporation Fuel Load Dates
- Unit 1, 4/82; Unit 2, 11/81 Status of Construction
- Unit 1, 54%; Unit 2, 61%; Engineering 82%
- Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers.
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Chronological Listing of Major Events July 1970 Start of construction under exemption 9/29-30 &
Site inspection, four items of noncompliance identi~fied, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP l
12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 31/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order 12/29/73 Licensee answers show Cause Order commits to improvements on GA program and QA/QC staff 12/3/73 Show cause order issued suspending cadwelding operation 12/6-7/73 Speclat inspection conducted by RIII and:HQ personnel J 2/37/73 Show Cause order modified to allow cadwelding based on inspection findings of 12/6-7/73
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12/5/75 CP. reported that rebar spacing out of specification 50
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locations in Unit 2 containment 3/5 & 10/75 CP reported that 63 #6 rebar vere either missing or misplaced in Auxiliary Building I
3/12/75 RIII held r.anagement meeting with CP -
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1 8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building 3/22/76 CT reported that 32 f 8 rebar were omitted in Auxiliary Building. A stop-vork order was issued by, CP 3/26/76 RIII inspector requested CP to inform RIII when stop-vork order to be lif ted and to investigate the cause and the extent of the proble=. Additional rebar problems identified
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during site inspection by NRC 3/31/76 CP -lif ted the stop-verk order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 KIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CF President, Vice President, and others.
6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction co==1t=ents 6/1-7/1/76 overall rebar omission reviewed by R. E. Shev=aker
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.\\7/28/76,
C7 stops concrete place =ent work when further rebar
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placement errors found by their overviev progra=.
PN-III-76-52 issued by RIII 3/2/76 RIII reco=cends HQ notice of Miolation be issued g/9 - 9/9/76 Tive week full-time RIII inspection conducted
~/13/76 Notice issued 8
10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77.
Unit 2 bulge of contaic=ent liner discovered by Licensee 4/19/77 Tendon sheath o=issions of Unit 1 reported 4/29/77 IAL issued relative to tendon sheath placement errors 5/5/77 Management meeting at CP Corycrate Office: relative to IAL regarding tendon sheath problem 9
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5/24/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implemeniation at Midland site.
j 6/75 - 7/77 Series of meetings and Letters between CP and NRR on applicability of Regulatory Guides to Midland.
Commitments by CP to the guides was responsive.
7/24/78 Construction resident inspection assigned.
8/21/78 Measurements by Bechtel indicate excessive settlement of Diesel Generator Building. Officially reported to RIII on September 7, 1978.
12/78 - 1/79 Special investigation / inspection conducted at Midland
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sites,Bechtel Ann Arbor Engineering offices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement problem.
2/7/79 Corporate meeting between RIII and CPC to discuss project status and future inspection activities.
CPC informed construction performance on track with exception of diesel / fill problem.
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Meeting held in RIII with Consumers Power to discuss 2/23/79 i
diesel generator building and plant area fill problems.
3/5/79 Meeting held with CPC to discuss diesel generator building and plant area fill problems.
3/21/79 10 CFR 50.54 request for information regarding plant fill sent to CPC by NRR.
5/5/79 Congressman Albosta and aides visited Midland site to discuss TMI effect on Midland.
5/8-11/79 Mid-QA inspection conducted.
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Sionificant Maior Events Past Problems 1.
Cadweld Splicing Problem and Show Cause Order _
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I A routine inspection, conducted on November 6-8,1973, as a I
result of intervenor information, identified eleven examples of four noncompliance items relative to rebar Cadwelding operations. These items were summarized as:
(1) untrained Cadweld inspectors; (2) rejectable Cadwelds accepted by QC inspectors; (3) records inadequate to establish cadwelds met requirements; and (4) inadequate procedures.
As a result, the Licensee stopped work on cadweld operations on November 9, 1973 which in turn stopped rebar installation and concrete placement work. The Licensee agreed not to resume work until the NRC reviewed and accepted their corrective action.
However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. on December 6-7, 1973, RIII and HQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The Show Cause Order was modified on December 17, 1973, allowing resumption of Cadwelding operations
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based on the inspection results.
The licensee answered the Show cause Order on Deceiber 29, 1973, committing to revise and improve the QA manuals and procedures and make QA/QC personnel changes.
Prehearing conferences were held on March 28 and May 30, 1974, and the hearing began on July 16, 1974. On September 25,1974, the Hearing Board found that the Licensee was implementing its GA program in compliance with regulations and that construction should not be stopped.
2.
_Rebar omission / Placements Errors t.eadino to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection conducted on December 11-13,1974.
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The licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' ~ 7" to 652' - 9" of Unit 2 containment.
This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of noncompliance in l
reports Nos. 50-329/74-11 and 50-330/74-11.
Additional rebar deviations and omissions were identified in March and August 1975 and in April, May and June T976.
Inspection report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.
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Licensee response dated June 18, 1976, Listed 21 separate items l
(commitment s) for corrective action. A June 24,1976 Letter provided a plan of action schedule for implementing the 21 items.
The Licensee suspended concrete placement work until the items addressed in Licensee's June 24 letter were resolveB or implemented.
This commitment was documented in a RIII letter toithe Licensee dated June 25,1976. Although not stamped as an Ikt, in-house memos referred to it as such.
Rebar installation and concrete placement activities were satisfactorily resumed in early July 1976, following completion of the items and verification by RIII.
Additional action taken is as follows:
a.
By the NRC (1)
Assignment of an inspector full-time ensite for five weeks to observe civil work in progress.
(2)
IE management meetings with the Licensee at their corporate offices C3)
Inspection and evaluation by Headquarters personnel b.
By the Licensee (1) June 18,1976 Letter committing to 21 items of corrective action.
(2)
Establishment of an overview inspection program to provide 100% reinspection of embedments by the Licensee following acceptance by the contractor QC personnel.
c.
By the Contractor (1)
Personnel changes and retraining of personnel.
(2) Prepared technical evaluation for acceptability of each identified construction deficiency.
(3)
Improvement in their QA/QC program coverage of civil work (this was imposed by the Licensee).
3.
Tendon Sheath Placement Errors and Resultino Immediate Action
.l Letter CIAL) i on April 19, 1977, the Licensee reported, as a Part 50, Section 50.55(e) item, the. inadvertent omission of two hoop tendon sheaths l
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from a Unit 1 containment concrete placement at elevation
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703' - 7" due to having already poured concrete in an area where the tendons were to be directed under a steam Line.
The tendons were subsequently rerouted in the next higher conc 6ete lift.
i An IAL was issued to the Licensee on April 29, 1977., which spelled out six Licensee commitments for correction which included:
(1) repairs and cause corrective action; (2) expansion of the lic~ensee's. QC overview program; (3) revisions to procedures and training of construction and inspection personnet.
A special QA program inspection was conducted in early May 1977.
The inspection team was made up of personnel from RI, RIII and HQ.
Although five items of noncompliance were identified, it was the concensus of the inspectors that the Licensee's program was an acceptable program.
The Licensee issued it's final report on August 12, 1977.
Final review onsite was conducted and documented in report No. 50-329/77-08.
Current Problems 1.
The Licensee informed the RIII office on September 8, 1978, per requirements of 10 CFR 50.55(e) that settlement of the diesel generator foundations and structures were greater than expected.
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FILL material in this area was placed between 1975 and 1977, with construction starting on the diesel generator building in mid-1977.
Review of the results of the RIII investigation / inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtet and the Licensee to the pending problem. These events included nonconformance reports, audit findings, field memos to engineering and problems with the administration building fill which caused modification and replacement 4
of the already poured footing and replacement of the fill material with Lean concrete.
i Causes of the,estessive settlement tactadas (1) inadeauste. placement methed - unau'alified compaction equipment and excessive lif t thickness; (2) inadequate testing of the soit material; C3) inadeauste et inspection procedures; (4) unaualified quality control inspectors and field engineers; (5) over reliance on inadequate test results.
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The proposed remedial work and corrective action are as follows:
(1)
Diesel Generator Building - apply surcharge load in and around building to preconsolidate the foundati6n material.
continue to monitor soit response to predict Lbng-ters settlement.
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(2). Service Water Pump Structure - Install piles to hard glacial tiLL to support that portion of the structure j
founded on plant fill material.
(3)
Tank Farm - Fill has been determined to be suitable for i
the support of Borated Water Storage Tanks.
Tanks are to be constructed and hydro tested while monitoring soil e
response to confirm support of structurec.
(4)
Diesel Oil Tanks - No remedial measure; backfill is considered adequate.
i (5) Underground Facilities - No remedial work is anticipated with regards to buried piping.
(6)~ Auxiliary Building and F. W. Isolation Valve Pits - Installed a number of caissons to glacial tiLL material and replace soit material with concrete material urider valve pits.
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(7)
Dewatering System - Installed site dewatering system to 2
provide assurance against soit Liquidification during a seismic event i
The above remedial measures were proposed to the NRC staff on l
July 18,1979. No endorsement of the proposed actions have
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been issued to the Licensee to date. The Licensee is proceeding I
with the above plans.
1 The NRC activities, to date, include:
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a.
Lead technical responsibility and program review was transferred to NRR from IE by memo dated November 17,1978.
J b.
Site meeting on December 3-4, 1978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed J
corrective action related to the Diesel Generator Building settlement.
c.
RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement.
Findings are contained in Report 50-329/78-20; 330/78-20 dated March 1979.
d.
NRC/ Consumers Power Company /Bechtet meetings held in RIII office to discuss finding of investigation / inspection of site settlement (February 23,1979 'and March 5,1979).
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NRC issue of 10 CFR 50.54(f) regarding plant fill dated March 21,
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1979.
f.
Several inspections of Midland site settlement have been performed.
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The Constructor / Designer activities include:
a.
Issued NCR-1482 (August 21,1978) b.
Isrued Management Corrective Action Report (MCAR) No. 24 (iepteaber 7) 1978) c.
Prepared a proposed corrective action option regarding placement of sand overburden surcharge to accelerate and achieve proper compection of diesel generator building sub-soils.
d.
Issued 10 CFR 50.55(e) interim report number.1 dated September 29, 1978.
e.
Issued interim report No. 2 dated November 7,1978.
f.
Issued interim report No. 3 dated June 5,1979.
g.
Issued interim report No. 4 dated February 23, 1979
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h.
Issued interim report No. 5 dated April 30, 1979 1.
Responded to NRC 10 CFR 50.54(f) request for in fermat'.on onsite settlement _ dated April 24, 1979.
Subsequent revision 1 dated May 31,1979, revision 2 dated July _ ?,1979 and revision 3 dated September 13, 1979.
- j. Meeting with NRC to discuss site settlement'causes and proposed resolution end corrective action taken dated July 15, 1979.
Information discussed at this meeting is_ documented in letter from CPCo to NRC dated August 10, 1979.'
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Issued interim report No. 6 dated August 10, 1979 t'.. Issued interim repori: No. 7 dated September 5,1979
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Review of Guality Docu.?entation to Establish Accept ability of Equipment The adequacy of.engineerang evaluation'of quality documentation
-(test reports, etc.) to determine if the documentation establishes that the' equipment meets specification and environmental: requirements is of concern. The Licensee, on November 13, 1978, issued a construction deficiency report (10 CFR 50.55(e)) relative to this matter. An interim report dated November 18,-1978 was received h
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and stated Consumers Power was pursuing this matter not only for e
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Bechtel procured equipment but also for NSS supplied equipment.
Source Inspection to confirm Conformance to Specificatifns 3.
The adequacy of equipment acceptance inspection by Bechtet shop inspectors has been the subject of several noncompliance /nonconformance report Consumers Power has put heavy reliance on the creditability of the BechteL~~ vendor inspection program to insure that only quality equipment has been sent to the site.
However, the referenced nonconformance reports raise questions that the Bechtet vendor inspection program may not be effectively working in all disciplines for supplied equipment.
Some significant examples are as follows:
(1) Decay heat removat pump being received with inadequate radiography.
The pumps were returned to the vendor for re-radiography and repair. The pumps were returned to the site with one pump assembled backwards. This pump was again shipped to the vendor for reassembly. CPCo witnessed a portion of this reassembly and noted in their audit that some questionable techniques for establishing reference geometry were employed by the vendor.
The pumps had been shop inspected by Bechtet.
/ (2) Containment personnet air Lock hatches were received and installed with vendor supplied structural weld geometry which does not
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agree with manufacturing drawings. The personnel air lock doors had been vendor inspected.
(3) Containment electrical penetrations were received and installed with approximately 25% of the vendor installed terminations showing blatant signs of inadequate crimping. These penetrations were shop inspected by 3 or 4 eechtet supplier quality representatives (vendor inspectors).
(4) 350 McM, 3 phase power cable was received and installed in some safety related circuits with water being emitted from one phase.
(5) A primary coolant pump casing was received and installed without att the threads in one casing stud hole being intact. The casings were vendor inspected by both Bechtet and B&W.
Additional IE inspections wiLL be conducted to determine if CP has thoroughly completed an overview of the Bechtet shop inspector's function and that equipment already purchased has been reviewed to confirm it meets requirements.
4.
"a" List Equipment There have been instances wherein safety related construction components e and their installation &ctivities have not-been-4dentified on the "Q" list.
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This shortcoming could have affected the quality of work performed during fabrication due to the absence of quality controls identified j
with "Q" list items. Examples of non "Q" list activities identified which should be "Q" listed include:
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Cable Trays l
Components of Heating and Ventilation System t
The licensee will be advised to review past as well as future I
construction activities to confirm that they were properly defined as "Q" list work or components.
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Management Controls Throughout the construction period CPCo has identified some of a.
the problems that have occurred and reported them under the require-ments of 10 CFR 50.55(e). Management has demonstrated an openness by promptly identifying these problems. However, CPCo has on repeated occasions not reviewed problems to the depth required for full and timely resolution.
Examples are:
Rebar omissions (1974)
Tendon sheath location error (1977)
Diesel generator building settlement (1978)
Containment personnel access hatches (1978)
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In each of the cases listed above the NRC in it's investigation has determined that the problem was of greater significance than first reported or the problem was more generic than identified by CPCo.
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This incomplete wringing out of problems identified has been discussed with CPCo on numerous occasions in connection with CPCo's management I
of the Midland project.
There have been many cases wherein nonconformances have been identified, b.
i reviewed and accepted "as is."
The extent of review given by the licensee prior to resolving problems is currently in progress.
I In one case dealing with the repair of airlock hatches, a determination was made that an incomplete engineering review was given the matter.
3 Inspection History I
. The construction inspection program for Midland Units 1 and 2 is approximately
' 60% complete.
This is consistent with status of construction of the two units.
(Unit 1 - 54%; Unit 2 - 61%).
The licensee's QA program has i
repeatedly been subject to in-depth review by IE inspectors; The following highlight these inspections.
1.
July 23-26,and August 8,-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06:
A detailed review was conducted relative to the implementation of the Consumers Power Company's QA manual and Bechtel Corporation's GA program for design activities at the Bechtel Ann l (
Arbor office.
The identified concerns were reported as discrepancies relative to the Part 50, Appendix B, criteria requirements.
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2.
September 1D-11,1973 report Nos. 50-329/73-05 and 50-330/73-08:
A detailed review of the Bechtel Power Corporation QA program for Midland was performed.
Noncompliances involving three separate Appendix B criteria with five different examples, were t,dentified.
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February 6-7, 1974, report Nos. 50-329/74-03 and 50-330R4-03: A followup inspection.at the Licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along with other followup.
4.
June 16-17,1975, report Nos. 50-329/75-05 and 50-330/75-05: special inspection conducted at the Licensee's corporate office to review the new corporate GA program manual.
5.
August 9 through September 9,1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA program implementation onsite primarily for rebar installation and other civit engineering work.
6.
May 24-27,1977, report Hos. 50-329/77-05 and 50-330/77-08: special inspection conducte'd at the site by RIII, IE AND RI personnel to examine the QA program implementation onsite by Consumers Power Company and by Bechtel Corporation.
A,Lthough five examples of noncompliance to Appendix B, Criterion V, were identified, the consensus l
of the inspectors involved was that the program and its implementatiai for Midland was considered to be adequate.
7.
May 8-11,1979, a mid-construction QA inspection covering purchase control and inspection of received materials design control and site auditing and surveillance activities was conducted by a team of inspectors. White some items wiLL require resolution, it was concluded the program was adequate.
The Licensee's Quality Assurance program has undergone a number of revisions to strengthen it's provisions. The company has expanded it's EA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This war done in 1975 with a commitment early in their experience with rebar installation problems and was further c'ommitted by the Licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.. This overview inspection activity by the Licensee has been a positive supplement to the constructor's own program, however, currently our inspectors perceive the overview
. activities cover a small percentage of the work in some disciplines.
1This has been brought to the Licensee's attention who h'as responded with a revised overview plan.
RIII inspectors are reviewing the plan as well
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as determining it's effectiveness through observation.of construction work.
A specific area brought to the attention of the Licensee was the lack of overview in the instrumentation, installation area. The licensee has responded to this matter with increased staff and this item is under j
review by RIII inspectors.
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The RIII office of inspection and enforcement instituted an augmented onsite inspection coverage program during 1974, this program has continued in effect until the installation of the resident inspector in July 1978.
Enforcement History il
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Noncompliance Statistics
. Number of Number of Inspector Hours Year Noncompliances Inspections Onsite 1976 14 9
646 1977 5
12 648 1978 18 23 1180
- 1979 to date 7
1i 429 A resident inspector was assigned to the Midland site in July 1978. The onsite inspection hours shown above does not include his inspection time.
- Through August 1979 b.
An investigation of the current soils placement / diesel generator building spttlement problem has revealed the existence of a material false statement.
Issuance of a Civil Penalty is.. currently being
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contemplated.
Summary and Conclusions Since the start of construction Midland has experienced some significant problems resulting in enforcement action. These actions are related (1) to improper placement, sampling and testing of concrete and failure of QA/QC to act on identified deficiencies in September 1970; (2) to drawing control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering offices in September 1973; (3) to inadequate training, procedures and inspection of cadweld activities in November 1973; (4) to a series of RIII in-depth SA inspections and meetings which identified underlying causes of weakness in the Midland QA program implementation relative to embedments in April, May and June 1976.
(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, alL primarily concerned with installation of reinforcement steet); (5)
.to tendon sheath omissions in April 1977; and (6) to plant soit foundations
,and excessive settlement of the Diesel Generator Building relative to inadequate compacted soil and inspection activities in August 1978 through 1979.
Following each of these problem periods, the Licensee has taken action to correct the problems and to upgrade his QA program and QA/QC staff.
The most prominent action has been an overview program which has been steadly expanded to cover safety related activities.
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The evaluation both by the Licensee and IE of the structures and equio-ment affected by these problems (again except the last) has established that they fully meet design requirements.
. Looking at the underlying causes of these problems two commin threads emerge:
(1) utilities historically have tended to over reti on A-E's
- (in this case, Bechtel) and (2) insensitivity on the part of both
- Bechtel and-Consumers Power to recognize the significance of isolated events or failure to adequately evaluate possible generic applicatien of these events either of which would have led to early identification and avoidance of the problem.
Admittedly construction deficiencies have occurred which should have been identified earlier but the Licensee's QA program has ultimately identified and subsequently, corrected or in process of correcting these deficienc The RIII inspectors believe that continuation of (1) resident site coverage, (2) the Licensee ove view program, (3) the Licensee's attention and resolution of identified problems in this report, (4) ceasing to permit work to continue when quality related problems are identified with construction activities and (5) a continuing inspection program by regional. inspectors wiLL provide adequate assurance that construction wiLL be performed in accordance with requirements and that any significant errors and deficiencies wiLL be identified and corrected.
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UNITED STATES j [( y ?.j NUCLE A R R EG ULATOR Y COMMISSION i
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EAR 15 B73 e
Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTS:
Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, M1 49201 Gentle =en:
Tnis refers to the meetings conducted on February 23, 1979, and March 5, 1979, between Consumers Power Company, Bechtel Corporation and NRC representatives held at the Region III office. I.isting of attendees to the meetings are enclosed as Attachment No. 4.
The meetings, conducted in connection with g
the investigation of the settlement of the Midland diesel g
generator building and plant area fill, represent a continu-ation of that effort.
A separate report of the investigation conducted during Dece=ber 11-13, 18-20, 1978, and January 4-5, 9-II' 22-25, 1979, by Messrs. E. J. Callagher, G. A. Phillip and G. F. Maxwell of this office vill be issued in the near future.
During the meeting of February 23, 1979, the NRC su==arized their preliminary investigation findings. These s m ry findings are provided in Attachment No. 1.
That meeting was subsequently followed by a second meeting held on March 5, 1979, during which Consumers Power Company repre-sentatives responded to the preliminary investigation findings identified in Attachment No. 1.
Those responses, which include a revised " Consumers Power Company Discussion of NRC Inspection Facts" report, are provided in Attachments No. 2 and No. 3.
Based on our investigation, review of your responses, as well as discussions during the March 5, 1979, meeting, our findings are as follows:
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EiR 151373 Consu=ers Power Co=pany a.
The quality assurance progra: for obtaining proper soil co=paction of the Midland Site was deficient in a nu=ber
- of areas, e
b.
Soil of the type used in the foundation of the diesel generator building is also located, to varying degrees,
under other Class 1 structures and plant area piping.
c.
Several inaccurate statements are contained in the FSAR with respect to the soil foundations.
In addition to the above findings, we continue to be concerned with the following matters:
a.
Although you have stated that inadequate soil co=paction contributed to the settlement of the D/G building, you have not determined what other factors contributed to the settlement.
b.
Because similar foundation materials were placed under other Class I structures, identified on page 3 of Attach-
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ment No. 3, we have concerns regarding the ability of
's the structures and co=ponents to fulfill their intended design functions under all required design bases for the life of the plant.
c.
We are concerned whether your current course of action on the settlement, which consists of preloading and consolidating the underlying supporting materials, vill resolve the problem on a long tarm basis.
As you are aware, the March 5, 1979, meeting was concluded with your informing us that within two weeks you would provide additional soils exploratory information that might account for the differences berveen the fill supporting the diesel generator building and that of the other Class I structures. You also stated that in the event the available information is insuf fi-cient to demonstrate resolution of the settle =ent problem, a further course of action would be provided.
In that this matter is related to plant design,,ve are forwarding it to our NRC Headquarters staf f for further review and evaluation. We vill keep you informed of their action in this matter.
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g;R 151373
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Consumers Power !
Company Based on a March 9,1979, telephone conversation with a member of your staff who informed us that the report contains no proprietary information, this report vill be placed in the NRC's 1
Public Document Roo=.
Sincerely, Cy _
, k y (2JamesG.Keppfer Director Attachments:
1.
KRC Presentation of Investigation Findings of the settlement of the Diesel Generator Building and Plant Area Fill dtd 2/23/79 2.
Consumers Power Company Discussion cf NFC Inspection Facts Resulting from the NRC Investigation of the Diesel Generator Building Settlement (revised 3/9/79) 3.
Consumers Power Company Response to NRC Question on the Condition of Soils Under
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All Other Plant Areas dtd 3/5/79
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4.
Attendence List at 2/23/79 and 3/5/79 Meetings cc v/ attachments:
Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Ronald Callen, Michigan Public_
Service Co==ission Dr. Wayne E. North Myron M. Cherry, Chicago c
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