ML20091P254
| ML20091P254 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/08/1984 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-08, CON-BOX-8, FOIA-84-96 NUDOCS 8406130003 | |
| Download: ML20091P254 (30) | |
Text
{{#Wiki_filter:9 e Midland Nuclear Power Plant. Units 1 and 2 Docket No. 50-329 Docket No. 50-330 i 4 I i REPORT ON DESIGN AND CONSTRUCTION PROBLEMS FOR PERIOD FROM START OF CONSTRUCTION THROUGH JUNE 30,1982 i Report Requested by Advisory Committee on Reactor Safeguards 1 y, a406130003 840517 FOR FOIA PDR RICE 84-96 , e.- A
e 4 \\ , 9' 1 I. Introduction j The following report prepared by the NRC, through its Region I.II office, discusses Midland construction problems, their disposi, tion, and the overall effectiveneas of the Consumers Power Company's efforts to ensure appropriate quality. The report was prepared at the request of the Advisory Committee on Reactor Safeguards and in response to commitments made in Supplement No.1 of the Safety Evaluation Report. The report covers the period starting with the beginning of construc-tion up to June 30, 1982. A final report will be issued on the above j subjects for the period from July 1, 1982 through the completion of l construction discussing the overall quality of plant construction. i l 4 i 9 i i 1 i i k 'l i I I i v'8 ,,r_- 9 ..i
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l l II. Summary and Conclusions of Overall Effectiveness Since the start of construction, Midland has experienced some,signifi-cant problems resulting in enforcement action (enforcement statistics are summarized in Table 1). Following the identification of each of these problems, the licensee has taken action to correct the problems i and to upgrade the QA program and QA/QC staff. The most prominent action has been an overview program which has been steadily expanded r to cover safety related activities. In spite of the corrective l actions taken, the licensee continues to experience problems in the implementation of quality in construction. ] Significant construction problems identified to date include: (1) i 1973 - cadweld splicing deficiencies (Paragraph C.2); (2) 1976 - robar omissions (Paragraph F.5); (3) 1977 - bulge in the Unit 2 Containment Liner Plate (Paragraph G.3); (4) 1977 - tendon sheath location errors l (Paragraph G.4); (5) 1978 - Diesel Generator Building settlement (Para-graph H.10); (6) 1980 - allegations pertaining to Zack Company heating, ventilating, and air conditioning (HVAC) deficiencies (Paragraph J.7); (7) 1980 - reactor pressure vessel anchor stud failures (Paragraph J.8); (8) 1981 piping suspension system installation deficiencies (Paragraph K.4); and (9) 1982 - electrical cable misinstallations l (Paragraph L.2). i Consumers Power has on repeated occasions not reviewed problems to j the depth required for full and timely resolution. Examples are: j (1) rebar omissions (1976); (2) tendon sheath location errors (1977); (3) Diesel Generator Building settlement (1978); and (4) Zack Company I HVAC deficiencies (1980). In each of these cases the NRC, in its 4 investigation, has determined that the problem was of ~ greater j significance than first reported or that the problem was more generic s r l j than identified by Consumers Power Company. s The Region III inspection staff believes problems have kept recurring at Midland for the following reasons: (1) Overreliance on the architect- { engineer, (2) failure to recognise and correct root causes, (3) failure { to recognize the significance of isolated events (4) failure to review isolated events for their generic application, and (5) lack of an j { aggressive quality assurance attitude. 1 l A history of the Midland design and construction problems and their disposition, as identified and described in NRC inspection reports,. ] is contained in the following section (III). This history is for the period from the beginning of construction through June 30, 1982. l r i 1 'h i s 2 x,%,4,,, .m i e, p A t'+-+L D
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~ 's I. III. Desian and Construction Problems As Documented in NRC Inspection Reports A. 1970 Six inspection reports were issued in 1970. In July 1970, construction activities authorized by the Midland Construction i Permit Exemption commenced. A total of four items of noncom-pliance were identified in 1970. These items are described below: i Tour items of nonconformance were identified in Inspection Report i Nos. 50-329/70-06 and 50-330/70-06 concerning the installation of concrete. The nonconformances regarded: (1) concrete placement activities violated ACI Code; (2) laboratory not performing tests per PSAR; (3) sampling not per ASTM; and (4) QA/QC personnel did not act on deviations when identified. Licenses corrective actions included: (1) Bechtel to provide a report attesting to the Auxiliary Building base slab where lack of consolidation was apparent; (2) a commitment to perform tests at frequencies specified in the PSAR; and (3) a commitment to train workers and the inspection staff. This matter was discussed during the Construction Permit Hearings and is considered closed. B. 1971-1972 Three inspections were conducted during this period. No items of noncompliance were identified. Midland construction activities were suspended pending the pre-construction permit hearings. On December 15, 1972, the Midland Construction Permit was issued. C. 1973 Eleven inspection reports were issued in 1973 of which two per-tained to special management meetings, two to vendor inspections, one to an audit of the architect engineer, and six to onsite I inspections. A total of six items of noncompliance were identified during 1973. One significant construction problem was identified involving deficiencies in cadweld splicing of robar (see Paragraph 2). These items / problems are described below: 1. Noncompliances involving two separate Appendix B criteria with five different examples were identified during a special audit of the architect engineer.'s Quality Assurance i Program. The noncompliances were documented in Inspection Report Nos. 50-329/73 08 and 50-330/73 08. The items of v noncompliance regarded (1) inadequate requirements for quality record retention; (2) inadequate drawing control; (3) inadequate procedures; and (4) unapproved specifications used for vendor control. Licensee corrective actions included: (1) revision of Bechtel Nuclear Quality Assurance t Manual; (2) revision of Midland Internal Procedures Manual; (3) personnel instructed to audit the status of the drawing stick files weekly; (4) project administrator assigned the 3 +g.= .*m3 .m ,..c,.e.-.. -1
J l responsibility for maintenance of master stick file; and (5) project engineer and staff to perform monthly surveillance of project record file. Inspection Report Nos. 50-329/74-03 and 50-330/74-03 concluded that appropriate corrective actions had been taken by the licensee relative to the identified violations. 2. One significant construction problem was identified during 1973. It involved cadweld splicing deficiencias and resulted in the. issuance of a Show Cause Order. Details are as follows: A routine inspection, conducted on November 6-8, 1973, identified eleven examples of four noncompliance items relative to rebar cadwelding operations. The noncompliances l were documented in Inspection Report Nos. 50-329/73-10 and i 50-330/73-10. These items were summarized as: (1) untrained cadweld inspectors; (2) rejectable cadwelds accepted by QC inspectors; (3) records inadequate to establish cadwalds me* requirements; and (4) inadequate procedures. l 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. A Show Cause Order was issued on December 3,1973, formally suspending cad-l welding operations. On December 6-7, 1973, Region III and l Headquarters personnel conducted a special inspection and determined that construction activities could be resumed in a manner consistent with quality criteria. Licensee corree-tivi actions included: (1) the revision of the Bechtel l specification to reflect requalification requirements; (2) j development of instructions requiring that work specifications be reviewed prior to Class 1 work; (3) the establishment of provisions for Consumers Power QA review of work procedures; and (4) the establishment of procedures for the audit of Class 1 work. The Show Cause Order was modified on December 17, 1973 . allowing resumption of cadwelding operations based on inspection results. The licensee answered the Show Cause Order on December 29, 1973 committing to. revise-and improva the QA manuals and procedures and make QA/QC personnel changes. On September 25, 1974, the Hearing Board found that the licensee was implementing its QA program in compliance with' regulations and that construction should not be stopped. 1D. 1974 Eleven inspection reports were' issued in 1974 of which one pertained to a vendor inspection, one to an inspection at the licensee's ' corporate offices, and nine to onsite inspections. Three items:of noncompliance were identified during 1974 'i - These items are described below: 4_ '4 1-
i 1. One noncompliance was identified in Inspection Report No. 50-329/74-01 and 50-330/74-01 concerning the use of unapproved procedures during the preparation of containment building liner plates for erection. Licensee corre4tive actions included: (1) intensive review of liner piste 4 records for accuracy; (2) issuance of nonconformance report; i (3) requirement imposed that unapproved copies of procedures transmitted to the site be marked " advance copy;" and (4) identification of procedure approval status. The licensee's actions in regards to this matter were reviewed and the noncompliance closed by the NRC as documented in Inspection Report Nos. 50-329/74-01 and 50-330/74-01. 8 2. One noncompliance was identified in Inspection Report Nos. 50-329/74-04 and 50-330/74-04, concerning the use of a weld method which was not part of the applicable weld pro-j cedure. Licensee corrective actions included: (1) issuance of a nonconformance report; (2) repair of subject welds; (3) reinstruction of welders; and (4) increased surveillance i l of containment liner plate field fabrications. The i licensee's actions in regards to this matter were reviewed J j' and the noncompliance closed by the NRC as documented in Inspection Report Nos. 50-329/74-04 and 50-330/74-04 3. One noncompliance was identified in Inspection Report Nos. 50-329/74-11 and 50-330/74-11 concerning the failure of QC inspections to identify nonconforming rebar spacing. This violation is discussed further in the 1976 section of this report, Paragraph F.5. E. 1975 ? j Seven inspection reports were issued in 1975 of which one j pertained to a meeting in Region III, one to an inspection at the licensee's corporate offices, and five to onsite inspection. No noncompliances were identified in 1975, however, the licensee in March and August of 1975 identified additional rebar deviations and omissions. This matter is further discussed in the 1976 section of this report, Paragraph F.5. .F. 1976 1 Nine inspection reports were issued in 1976 pertaining to nine onsite inspections. A total of seventeen items of noncompliance were identified during 1976. One significant construction problem was identified involving rebar omissions / placement errors and the issuance of a Headquarters Fotice of violation (see Paragraph 5). These items / problems are described below: 4 5 m
j t j 1. Three items of noncompliance were identified in Inspection Report Nos. 50-329/76-01 and 50-330/76-01. These items 5 regarded: (1) inadequate concrete oven temperature controls; (2) no measures to control nonconforming aggre-gate; and (3) failure to dispose of nonconforming aggregate i as required. Licensee corrective actions included:: (1) implementing a requirement for the reverification of oven temperature controls every three months; (2) removal of nonconforming aggregate from the batch plant area; .l (3) modification of subcontractor's QA manual; and (4) training of subcontractor's personnel to the revised QA manual. The corrective actions implemented by the 4 licensee in regards to these noncompliances were subse-i quently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/76-02 and 50-330/76-02. 2. Two items of noncompliance were identified in Inspection _ Report Nos. 50-329/76 02 and 50-330/76-02. These items regarded: (1) the Vice President of Engineering Inspection did not audit test reports as required; and (2) corrective actions required by audit findings had not been performed. Corrective actions taken by the licensee included revising the U.S. Testing QA manual. The licensee's corrective 4 actions taken in regards to these matters were subsequently reviewed and the items closed by the NRC as documented in i Inspection Report Nos. 50-329/76-08 and 50-330/76-08. t 3. Three items of noncompliance were identified in Inspection 3 Report Nos. 50-329/76-08 and 50-330/76-08. These items regarded: (1) inadequate classification, review, and l approval of field engineering procedures and instructions; i (2) inadequate documentation of concrete form work j deficiencies; and (3) inadequate control of site storage of post tension embedmonts. Licensee corrective actions included: (1) revision of the Bechtel Nuclear QA manual; i (2) revision of Bechtel field procedure for " Initiating and Processing Tield Procedures and Instructions;" (3) initiation of Bechtel Discrepancy Report; (4) training-sessions for Bechtel QC; and (5) revision of storage insptction procedures. The licansee's corrective actions in tegards to these items were subsequently reviewed and the items closed by the NRC as documented.in Inspection Report Nos. 50-329/77-01 and 50-330/77-01. 1 4. Two items of noncompliance were identified in Inspection, c Report Nos. 50-329/76 09 and 50-330/76-09. These items-regarded: (1) noncompliance report not written to identify' broken reinforcing steel; and (2) hold down Jstuds for the reactor vessel skirt were not. protected. Licensee corrective actions included: (1) inspection of all rebar' dowels; (2) initiation of new field procedure; and (3) initiation of new i 'k i. 5 i 6 t 13'
{ procedure for inspecting reactor vessel and steam generator anchor bolts. The licensee's corrective actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/77-01 and 50-330/77-01. ~ t 5. One significant construction problem was identified during l 1976. It involved rebar omissions / placement errors and the issuance of a Headquarters Notice of Violation. Details are as follows: During an NRC inspection conducted in December 1974 the licensee informed the inspector that an audit had identified rebar spacing problems in the Unit 2 containment. The failure of QC inspectors to identify the nonconforming rebar spacing was identified in the 1974 NRC inspection report as an item of noncompliance. (See the 1974 section of this report, Paragraph D.3.) This matter was subsequently reported by the licensee as required by 10 CFR 50.55(e). Additional rebar deviations and omissions were identified i in March and August 1975 and in April, May and June 1976. Five items of noncompliance regarding reinforcement steel deficiencies were identified in Inspection Report Nos. 50-329/76-04 and 50-330/76-04. These items regarded: (1) no documented instructions for the drilling and place-ment of reinforcement steel dowels; (2) nonconformance reports concerning reinforcement steel deficiencies were not adequately evaluated; (3) inadequate inspections of reinforcement steel; (4) Anadequate evaluations of a nonconformance report problem relative to 10 CFR 50.55(e) reportability requirements; and (5) results of reviews, i interim inspections, and monitoring of reinforcement steel i installations were not documented. The licensee's response, dated June 18, 1976, listed 21 separate items (commitments) for corrective actions. A June 24, 1976 letter from the licensee provided a plan of action schedule for implementing the 21 items. The licensee suspended concrete placement work until the items i addressed in the licensee's June 24 letter were resolved or I implemented. This commitment was documented in a Region III Immediate Action Letter (IAL) to the licensee, dated June 25, 1976. f j Rebar installation and concrete placement activities were resumed in early July, 1976 following satisfactory completion I of the corrective actions and verification by Region III as ) documented in Inspection Report Nos. 50-329/76-05 and 50-330/76-05. i l I k y l 4
~ .~. 1 A subsequent inspection to followup on reinforcing steel placement problems identified two noncompliances. These j noncompliances are documented in Inspection Report Nos. 50-329/76-07 and 50-330/76-07. The noncompliances regarded: (1) failure to follow procedures; and (2) in-adequate Bechtel inspections of rebar installations? The inspection report documents licensee corrective actions which included: (1) removal of cognizant field engineer and lead Civil engineer from the project; (2) removal of lead Civil Quality Control engineer from the project; (3) reprima'nd of cognizant inspector; (4) additional training given to cognizant foremen, field engineers, superintendants and Quality Control inspectors; and (5) assignment of additional field engineers and Quality Control engineers. The licensee's actions in regard to these items were reviewed and sto items closed by the NRC as documented in i Inspection Report Nos. 50-329/76-07 and 50-330/76-07. .l As a result of the rebar omissions and placement errors, a Headquarters Notice of Violation was issued on August 13 .j 1976. Additional actions taken by the licensee included the establishment of an overview inspection program to provide 100* reinspection of embedments by the licer. ce following acceptance by the contractor Quality Control personnel. Additional actions taken by the contractor included: (1) per-sonnel changes and retraining of personnel; (2) preparation of a technical evaluation for the acceptability of each identified construction deficiency; and (3) improvement in the QA/QC program coverage of civil work. ) C. 1977 i Twelve inspections pertaining to Unit 1 and fifteen inspections pertaining to Unit 2 were conducted in 1977. Ten items of non- ' compliance were identified during 1977. Two significant construction problems were identifed involving a bulge in the Unit 2 containment liner plate (see Paragraph 3) and errors in the placement of tendon sheathings (see Paragraph 4). These items / problems are described below: - t 1. Five examples of noncompliance with Criterion V of 10 CTR 50, Appendix B, were identified in Inspection Report Nos. 50-329/77-05 and 50-330/77-08..The examples of noncompliance r~egarded: (1) inadequate clearance between concrete wall and pipe,. support plates; (2) assembly of pipe a supports using handwritten drawing changes; (3) inadequate 1 preparation and issue of audit reports; (4). inadequate review l of nonconformance reports and audit' findings-for trends; and I (5) inadequate tagging of defective measuring equipment. Licensee corrective actions included: (1) clarification of 8-r 1 1 -m~ ,-+ +,. -... -, +. .+.-s --,.-w- -+---..w.ri enm- + -- - - - ~ g
\\ -l design and acceptance criteria contained in pertinent specifications; (2) modification and review of Quality Control Inst ructions ; (3) issuance of two field procedures relative to field modifications of piping hanger drawings; (4) 4taffing of additional QA personnel at the site; (5) closer management l attention; and (6) additional training in the area of tagging. l {- The licensee actions in regard to these items were subsequently l reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/77-08, 50-330/77-11, 50-329/78-01, i and 50 330/78-01. 2. Three items of noncompliance were' identified in Inspection Report Nos. 50-329/77-09 and 50-330/77-12. The items re-garded: (1) failure to follow audit procedures; (2) failure j j to qualify stud welding procedures; and (3) inadequate welding inspection criteria. Licensee corrective actions } included: (1) administrative instruction issued to require I the audit manager to obtain a semi-monthly audit findings t status report from the project manager; (2) administrative instruction issued for the close out and followup of internal corrective action requests; (3) revision of Quality Control Instruction; (4) special inspections and audit; and (5) prescribing specific acceptance criteria. i The licensee's actions in regard to these items were sub-sequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/78-01, 50-330/78-01, 50-329/78-05, and 50-330/78-05. I 3. A significant construction problem involving a bulge in the Unit 2 containment liner plate was identified in 1977. Details of the liner plate bulge follow: The' initial identification by the licenses of a bulge in the Unit 2 liner plate occurred on February 26, 1977. The liner plate bulge occurred between column line azimuths j 250 degrees and 270 degrees and between elevations 593 and i 700. Inspection. Report No. 50-330/77-02 documents a special inspection concerning the liner plate bulge. This report further identifies an item of ncncompliance relative to the failure of the licensee ~to report the bulge deficiency pursuant to the requirements of 10 CFR 50.55(e). The licensee's corrective actions in regard to this item were l reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/77-14. The cause of the liner plate bulge was determined to be ' due to a leaking 2 inch water line installed in the con-tainment concrete as a: construction convenience. It was theorized that the water line froze, started to leak, allowing water to seep behind the liner. 'The water line ~ was supplied by a construction water pump that was set to cycle between 100 and-130 PSI. This pressure was considered' to be sufficient to cause the liner plate bulge. 9 f A_ss,-, y z
t i A meeting was held on April 4, 1977 at the Ann Arbor, Hichigan Office of Bechtel to review the original design and construction concept of the contsinment liner, the procedures and actions taken during the removal of pulge i affected zones, the investigation activities and results, j and to ascertain the concepts involved in the licensee's proposed repair program. The containment liner bulge deficiency repair was started 2 on August 1, 1977. Inspection Report No. 50-330/77-11 docu-ments the observed fit up and welding of the first four foot lift of replacement liner plate installed. The completion of j repair and the repair records were subsequently reviewed as documented in Inspection Report No. 50-330/79-25. i 4 A second significant construction problem involved tendon sheath placement errors and resulted in an Immediate Action l Letter (IAL). Details are as follows: f The licensee reported, on April 19, 1977, the discovery of an error in the Unit 1 containment building which resulted in two tendon sheathings (H32-036 and H13-036) being mis-placed, and two tendon sheathings (H32-037 and H13-037) being. omitted. As shown on pertinent vendor drawings, these four tendons were to be deflected downward to clear the two main steam penetrations at center line elevation 707' 0". Concrete had been placed to a construction joint at elevation 703' 7" approximately one week before these tendon deficiencies were discovered. Corrective actions resulted in the rerouting of tendon sheathing H32-037, originally planned for below the penetration, to a new alignment above the penetration. Tendon sheathing H13-037 was installed below the penetration. Tendon sheathings H32-036 and H13-036 did not require modification. The tendon sheath placement errors and the past history of rebar - placement errors indicated the need for further NRC evaluation of the licensee's QA/QC program.. As a result, an IAL was issued to the licensee on April 29, 1977. Licensee commitments addressed by.this IAL included: (1) NRC notification prior to repairs or 3 modifications involving the placement of. concrete in the area of I the misplaced and omitted tendon sheaths; (2) identification of the cause of the tendon sheath deficiencies and implementation of required corrective action; (3)' expansion of the licensee's 9QC overview program; (4) NRC notification of all embedmont-placement errors identified after QC acceptance; (5) review and, revision of QC inspection procedures; and (6) training of construction and inspection personnel. I 4 10 4 4 e a rws* -4 M U a s o.4-4 cm,.mp,J.,, ..un,wa, ..%+ ,,o 5'
j A special QA program inspection was conducted in May 1977 as + documented in Inspection Report Nos. 50-329/77-05 and i 50-330/77-08. The inspection team was made up of personnel i from Region I, Region III, and Headquarters. It was the con- ] sensus of opinion of the inspectors that the license,e's program i l I was acceptable. The licensee issued the final 50.55(e) report on this matter on August 12, 1977. Final onsite review was conducted and documented in Inspection Report Nos. 50-329/77-08 and 50-329/79-15. l H. 1978 i i Twenty-two inspections and one investigation were conducted during 1978. A total of fourteen items of noncompliance were identified in 1978. One significant construction problem was identified involving .l. excessive settlement of the Diesel Generator Building foundation (see 2 Paragraph 10). These items / problems are described below: 1. Three items of r.oncompliance were identified in Inspection l Report Nos. 50-329/78-03 and 50-330/78-03. These items j regarded: (1) inadequate inspections of welds on cable tray supports; (2) inadequate control of welding voltage and amperage as required by AWS; and (3) inadequate documentation of repairs on purchased equipment. Licensee corrective actions included: (1) additional training given Quality Control Engineers and craft welders; (2) revision of pertinent technical specifications and weld acceptance requirements; (3) revision of welding procedures; (4) revisions of vendor QA manual; and (5) reinspections and engineering evaluations. The licensee actions in regard to these items were subsequently reviewed and the items closed by the' NRC cs documented in Inspection Report Nos. 50-329/78-15, 50-330/78-15, 50-329/79-25, 50-330/79-25, 50-329/81-12, 50-330/31-12, 50-329/79-22, and 50-330/79-22. 2. .Two items of noncomplience were identified in Inspection Report Nos. 50-329/78-05 and 50-330/78-05. These items regarded: (1) inadequate control of welding filler material; ). and (2) inadequate protection of spool pieces. Licensee corrective actions included: (1) additional instructions given to welding personnel; (2) generation of nonconformance report to require Bechtel to perform a thorough inspection of the' facility,: correct and document discrepancies noted, and instruct craft personnel. The licensee actions in-regard to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/78-05, 50-330/78-05, 50-329/79-22, and 50-330/79-22. ( 3. Two examples of noncompliance with one 10 CFR 50 Appendix B -} criterion were identified'in Inspection Report Nos. 50-329/78-07 1 and 50-330/78-07. -These examples regarded: (1) inadequate i. .{- ) 11 1 4.., . ~ _. - -,.-..,c. -w.,,. _. h
l control of drawings; and (2) inadequate drawing control pro-4 cedures. Licensee corrective actions included: (1) Zack and l Bechtel revised drawing control procedures; and (2) extensive ] audits of drawing controls. The licensee actions in regard to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/79-25 1 and 50-330/79-25. 4. One item of noncompliance was identified in Inspection Report,No. 50-330/78-09 concerning inadequate backing gas 9 flow rate during welding operations. Licensee corrective actions included: (1) revision of Bechtel welding pro-cedure specifications; (2) revision of Bechtel Quality i Control Instruction; and (3) additional training for all j welding Quality Control Engineers. The licensee's actions in regard to this item were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/78-16. 5. Two items of noncompliance were identified in Inspection Report Nos. 50-329/78-13 and 50-330/78-13. The items regarded: (1) inadequate inspection of weld joints; and (2) inadequate storage of Class IE equipment. Licensee i corrective actions included: (1).'evision of welding specifications; (2) additional ins. ructions to QC in-spectors; (3) additional overinspeccions; (4) upgrade of administrative procedures; and (5) actions to bring storage environment within controlled specifications..The licensee's actions in regard to these items were reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/78-13 and 50-330/78-13. l-6. Tro items of noncompliance were identified in Inspection j Report Nos. 50-329/78-15 and 50-330/78-15. These items regarded: (1) nonconforming welds on Main Steam Isolation Valve support structures; and (2) inadequate corrective action taken to repair nonconforming Nelson Stud weld attachments. Licenses corrective actions included: (1) responsible welding Quality Control Engineer required to attend training course; (2) defective welds reworked; and (3) engineering evaluation. The licensee's actions in regard to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection-Report Nos. 50-329/79-22, 50-330/79-22,'50-329/79-25 . l-and 50-330/79-25. e 7. One deviation was identified in Inspection Report No. 50-330/78-16 concerning the failure to meet ASME code-requirements for nuclear piping. Licensee corrective actions included the determination that the impact test values of the pipe material in question met the code requirements -and the UT thickness measurements made by ITT Grinnell were in error and 1 12 q. s-.. O w -
i voided by measurements made by Bechtel. The licensee's actions in regard to this item were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/79-24. 8. One item of noncompliance was identified in Inspecti'n o Report Nos. 50-329/78-17 and 50-330/78-17 regarding the failure to follow weld procedures pertaining to the repair welding of cracked welds on the personnel air locks. The licensee's corrective actions included steps to revise affected drawings and to update the stress analysis report for the air locks. The corrective actions taken by the j licensee will be reviewed during future NRC inspections. 9. One item of noncompliance was identified in Inspection Report .j Nos. 50-329/78-22 and 50-330/78-22 concerning the failure to perform specified maintenance and inspection activities on Auxiliary Feed Pumps. Licensee corrective actions included: (1) training of pertinent Quality Control engineers; (2) transition of personnel in QC department relative to storage and maintenance activities; and (3) inspections and evaluations of omitted maintenance. The licensee's actions in regard to this item were subsequently reviewed and the j item closed by the NRC as documented in Inspection Report Nos. 50-329/78-22 and 50-330/78-22. 10. One significant construction problem was identified during 1978. It involved excessive settlement of the Diesel Generator Building foundation. Details are as follows: l The licensee informed the Region III office on September 8, 1978, per requirements of 10 CFK 50.55(e), that settlement 4 of the Diesel Generator foundations and structures was greater than expected. Till 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 Region III investiga-tion / inspection into the plant fill / Diesel Generator building settlement problem' indicate many events occurred between late 1973 and early 1978 which should have. alerted Bechtel and the licensee to.the pending problem. These events included ncn-conformance reports.c audit findings, field memos to engineering, and problems with the administration building fill which caused modification and replacement of the already poured footing and replacement of the fill material with lean concrete. / Causes o'f the excessive settlement included': (1) inadequate placement method - unqualified compaction equipment and-( -excessive lift thickness; (2) inadequate testing of the soil material; (3) inadequate QC inspection procedures;-(4)- l unqualified Quality Control inspectors and field engineers; l and.(5)'overreliance on inadequate test results. i. 1 7.- 13 I '. O u ._a s , _,. +. -.,
i Lead technical responsibility and program review for this issue was transferred to NRR from IE by memo, dated November 17, 1978. During 1978.the licensee conducted soil borings On the area of the Diesel Generator building and in other plant '. fill areas. ? In addition, a team of consultants who specialize in soils was retained by the licensee to provide an independent evaluation and provide recommendations concerning the soil conditions existing under the Diesel Generator building. g As previously stated, an investigation was initiated in December 1978 by the NRC to obtain information relating to design and construction activities affecting the Diesel l Generator Building foundation and the activities involved in i the identification and reporting of unusual settlement of the building. The results of the investigation and additional l developments in regard to this matter are discussed in the j 1979 section of this report, Paragraph I.11. I. 1979 Thirty inspection reports were issued in 1979 of which one pertained to an onsite management meeting, two to investigations, one to a vendor inspection, one to a meeting in Region III, and twenty-five to onsite inspections. A total of seventeen items of noncompliance were identified in 1979. These items are described below: 1. One item of noncompliance was identified in Inspection Report [ Nos. 50-329/79-10 and 50-330/79-10 concerning inadequate-measures to assure that the design basis was included in drawings and specifications. Licensee corrective actions included: (1) revision to Midland TSAR; and (2) revision to i pertinent specification. The licensee's actions in regard to this item were subsequently reviewed and the item closed by the NRC as documented in Inspection Report ? Ncs. 50-329/79-19 and 50-330/79-19. t 4 2. Three items of noncompliance were identified in Inspection Report Nos. 50-329/79-12 and 50-330/79-12. The items were: (1) inadequate corrective action in regard to drawing controls; (2) discrepancy in Zack Velding Procedure Specification; and (3) inadequate control.of purchased . i material. Licensee corrective actions included: (1) audit of drawing control program;-(2) revision to drawing control requirements; - (3) revision of Zack Welding Procedure Speci, . fication:- (4) review of other Zack procedures; (5) missing data added to documentation packages; and (6) audits of other: documentation packages., The actions taken by the licensee-i I were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-01 50-330/61-01, 50-329/80-15, 50-330/80-16, 50-329/79-22, and 50-330/79-22.- .14 a .,w um% ~-w, uwe- - --y a'
6 4 l i i: 3. One item of noncompliance was identified in Inspection Report No. 50-330/79-13 concerning the failure to inspect j all joints and connections on the Incore Instrument Tank as prescribed in the hydrostatic test procedure. Licenses corrective actions included a supplemental test of the Incore Instrument Tank and the initiation of a supplemental test report. The licensee's actions in regards to this matter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/80-38. 4. One it'em of noncompliance was identified in Inspection Report No. 50-330/79-14 concerning the use of a wad of [ paper in making a purge das during welding activities. Licensee corrective actions included: (1) revision of pertinent procedures; (2) revision of pertinent Quality Control inspection checklist; and (3) training sessions for welders and Quality Control inspectors. The licensee's actions in regards to this matter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/80-16. 5. One item of noncompliance was identified in Inspection Report Nos. 50-329/79-18 and 50-330/79-18 concerning inadequate controls to protect materials and equipment from welding activities. Licensee corrective actions y included training sessions for cognizant Field Engineers, Superintendents, General Foremen and Foremen. The licensee's i actions in regards to this matter were subsequently reviewed-and the item closed by the NRC as documented in Inspection Report Nos. 50-329/80-15 and 50-330/80-16. 6. Two. items of noncompliance were identified in Inspection i Report Nos. 50-329/79-19 and 50-330/79-19.~ These items regarded: (1) failure to ensure that appropriate quality 4 i standards were in the specification for structural backfill; and (2) Quality Control inspection personnel performing con-tainment prestressing activities were not being qualified as required. Licensee corrective actions included: (1) revision - of pertinent specification; (2) examination given to Level I and Level II inspector; and (3) reinspection of selected tendons. The licensee's actiona in regards to these items F -were subsequently reviewed and the items, closed by the NRC as documented in Inspection Report Nos. 50-330/80-09, 50-329/80-04 and 50-330/80-04.
- 7.. One item of noncompliance was identified in Inspection.
Report Nos. 50-329/79-20 and 50-330/79-20 concerning inadequate controls _for welding activities pertaining to' - 4.16 KV switchgear. -Licensee corrective actions' included: (1) correction.of relevant records; (2) additional training 4 for Quality Control Engineers; and-(3) additional training for the Quality Control Document Coordinator.: The licensee's- '. actions were subsequently reviewed and the ites closed by 4 the NRC as documented in Inspection Report Nos. 50-329/80-15. j and 50-330/80-16. i I! 15 l r 0 i r a.. . + -. g. w. .p w w g 7g,h g-
i I/ 8. One item of noncompliance was identified in Inspection Report No. 50-330/79-22 concerning inadequate weld rod controls. Licensee corrective actions included a training session for cognizant welding personnel. The actions taken by the licensee in regards to this matter were subse.quently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/E0-01. 9. One item of noncompliance was identified in Inspection i Report,Nos. 50-329/79-26 and 50-330/79-26 concerning failure i to follow procedures relative to the shipment of auxiliary 1 feed water pumps to the site with nonconforming oil coolers. Licensee corrective actions included: (1) reinstruction given to cognizant engineer; and (2) Supplied Deviation 3 t Disposition Request (SDDR) generated by the vendor. The I licensee's actions in regards to this matter were reviewed l and the item closed by the NRC as documented in Inspection ' Report Nos. 50-329/79-26 and 50-330/79-26. 10. One item of noncompliance was identified in Inspection Report Nos. 50-329/79-27 and 50-330/79-27 concerning the violation of QC Hold Tags. Licensee corrective actions included: (1) a training session for Construction Super-visors and Field Engineers; and (2) a Field Instruction on Quality Control Hold Tags was issued. The licensee's actions in regards to this matter were subsequently t' reviewed and the item closed by the NRC as documented in Inspection Report Nos. 50-329/81-04 and 50-330/81-04. 11. As a followup to the.significant construction problem identified in 1978 (see Paragraph H.10), an investigation was initiated in December, 1978 to obtain information relating to design and construction activities affecting the Diesel Generator Buildir.g foundations and the activities involved in the identification and reporting of unusual settlement of the building. The investigation findings were documented in Inspection Report Nos. 50-329/78-20 and 50-330/76-20, dated March 22, 1979. Information obtained during this investigation indicated: (1).a lack of control and supervision of plant fill activities contributed to the inadequate compaction of foundation material; (2) correctivs t action regarding nonconfermances related to plant fill.was ,1 insufficient or inadequate as evidenced by the repeated ~ deviations from specification requirements; (3) certain design bases and construction specifications related to foundation type, material properties, and compaction requirements were not'followed; (4) there was a lack of clear direction and support between the contractor's e-engineering office and construction site personnel; 'and (5) the FSAR contained inconsistent, incorrect and unsup-ported statements with respect to foundation type, soil properties, and settlement values. Nine examples of noncompliance involving four different 10 CFR 50, Appendix B riteria were identified in the subject inspection report. e i. 16 i j %. M-. - - ~,- i n. m. .-~m m%...-r 4 _s
I i Meetings were held on February 23, 1979 and March 5,1979 at the NRC Region III office to discuss the circumstances associated with the settlement of the Diesel Generator j Building at the Midland facility. The NRC staff st4ted that it's concerns were not limited to the narrow scope of the i ] settlement on the Diesel Generator Building, but extended to j various buildings, utilities and other structures located in and on the plant area fill. In addition, the staff expressed concern with the Consumers Power Company Quality Assurance Program. Under the authority of Section 182 of the Atomic i Energy'Act of 1954, as amended, and Section 50.54(f) of 10 CFR Part 50, additional information was requested j regarding the adequacy of the fill and the quality assurance j program for the Midland site in order for the Commission to determine whether enforcement action such as license modifi-cation, suspension or revocation should be taken. Question 1 of the 50.54(f) letter dated March 21, 1979 requestad i information regarding the quality assurance program. On April 24, 1979, Consumers Power Company submitted the initial response to the 50.54(f) request, Questions 1 through 22. As a result of the NRC staff review of Question 1, the NRC concluded that the information provided was not sufficient for a complete review. Subsequently, on September 11, 1979, the - NRC issued a request for additional quality assurance informa-tion (Question 23). On November 13, 1979, Consumers Power Company submitted Revision 4 to the 50.54(f) responses which included response to Question 23. As a result of the Region III investigation report and CPCo responses, the NRC i { issued an Order modifying construction Permits No. CPPR-81 and No. CPPR-82, dated December 6, 1979. This order j prohibited further soils related activities until the submission of an admendment to the application seeking approval of the Remedial Soils work with the provision that the order would not become effective in the event that the licensee requested a hearing. Due to the licensee's decision to request a hearing this order forms the basis for the ongoing ASLB Hearings. During 1979, the licensee continued soil boring operations in order to identify and develop the quality of material in the plant area fill and beneath safety related structuras. The licensee completed a program regarding the application of a surcharge of sand material in and around the Diesel ~ Generator Building. This surcharge was an attempt to accelerate any future settlement of the Diesel Generator Building by consolidating the foundation material. Additional developments in this matter are discussed in the 1980 section of this report, Paragraph J.9. E i { 17 i .w-e=me -e-mw.e,.= - mme-e e, +.w.a w, . - =
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4 t i J., 1980 -f Thirty-seven inspection reports were issued in 1980 of which two pertained to meetings at the licensee's corporate office.jone to a meeting in Glen Ellyn, two to investigations, and thirty-two to onsite inspections. A total of twenty-one items of noncompliance were identified during 1980. Two significant construction problems were identified involving quality assurance problems at the Zack Company (see Paragraph 7) and deficient reactor vessel anchor studs (see Paragraph 8). These items / problems are described below: 1. TVo items of noncompliance and one deviation were identified in Inspection Report Nos. 50-329/80-01 and 50-330/80-01. i 1 These items regarded: (1) a welder welding on material of thickness which exceeded his qualified range; (2) failure to date and sign the cleanliness inspection of Unit 2 Service Water System valve; and (3) failure to implement a design change or prepare a Field Change Request. Licensee correc-l tive actions in regards to the items of noncompliance ~' included: (1) testing and qualification of the subject welder; (2) reinstruction of QC engineer; (3) review of the inspection records for additional valves; and (4) the revision of applicable turnover procedures. The licensee's actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/80-20, 50-330/80-21, 50-329/82-04 and 50-330/82-04. 3 2. One item of noncompliance was identified in Inspection Report No. 50-329/80-09 concerning the failure to maintain levelness requirements during core support assembly lifts. l The licensee's corrective actions in response to the item j of noncompliance included the issuance of a nonconformance report and the commitment to ensure compliance with Quality e I Control procedures. The licensee's corrective actions in regards to this matter will be reviewed during subsequent .NRC inspectie 2. 3. One item of noncompliance was identified in Inspection Report Nes. 50-329/80-20 and 50-330/80-21 concerning the failure of a Bechtel-purchase order for E7018 welding rods to specify the applicable codes. Licensee commitments in regards to corrective actions included an audit of the ordering and receiving records of weld filler material. The licensee's corrective actions in regards to this matter will be reviewed during subsequent NRC inspections. 4. One item of noncompliance was identified in Inspection Report Nos. 50-329/80-21 and 50-330/80-22 concerning the failure to perform an audit of Photon Testing, Inc. for services to qualify Zack Company welders. Licensee correc-tive actions included an audit of' Photon Testing, Inc. The licensee's actions in regards -to this matter were subsequently 1 i reviewed and,the item ricsed by the NRC as documented in f- . Inspection Report Nos. 50-329/81-03 and *.0-330/81-03. U i 18 . {l -
!j t 5. One item of noncompliance was identified in Inspection Report Nos. 50-329/80-28 and 50-330/80-29 concerning the bypassing of a hold point on a Pressure Surge System weld. The inspection report further identifies that actiorg had been taken to correct the identified noncompliance and to -- i prevent recurrence. The item is closed. 6. One item of noncompliance was identified in Inspection Report Nos. 50-329/80-31 and 50-330/80-32 concerning I substantial delays by the licensee in making 10 CFR Part 21'reportability determinations. Licensee corrective actions included training sessions for key personnel in recognizing 10 CFR 21 reporting obligations. The licensee's actions in regards to this matter were subsequently reviewed I and the item closed by the NRC as documented in Inspection j Report Nos. 50-329/81-07 and 50-330/81-07. 7. A significant construction problem involving quality assurance i problems at the Zack Company, the heating, ventilating, and air condition contractor was identified in 1980. Details of the Zack problem follow: During March and April, 1980 the NRC received numerous allegations pertaining to the Zack Company. The Zack t l Company is the heating, ventilation and air conditioning (HVAC) subcontractor at.the Midland construction site. The allegations dealt with material traceability, violations 4 of procedures, falsification of documents, and the training of quality control inspectors. i As the result of the allegations, an investigation was initiated by the NRC. During the initial phases of the i investigation, the NRC determined that Consumers Power Company had issued a Management Corrective Action Request (MCAR), dated January 8, 1980, pertaining to the Zack Company. 'The MCAR showed that Zack had failed to initiate corrective action in a timely manner on a large number of 4 nonconformance reports and audit findings and had failed to address other requirements and commitments of the quality program. -l Consumers Power Company had issued seven nonconformance reports during the period of May 23_to October 2, 1979 all of which recommended 100'. reinspection of work.as a corrective i action. The investigation determined.that as of March 19, i 1980, corrective action had not been completed on any of the nonconformance reports. Based on preliminary i ndings during the investigation, which revealed some instances of continued nonconformance l in the implementation of Zack's Quality Assurance Program, an Immediate Action Letter. (IAL) was issued to the licensee j on March 21,:1980. The IAL stated the NRC's understanding that a Stop Work Order had been issued to the Zack Corpora-j- tion for all its safety related construction activities. 19-j _.e ,w p a 4-
Seventeen examples of noncompliance involving eight different 10 CFR 50, Appendix B, criteria were identified during the investigation. The investigation findings are documented in Inspection Report Nos. 50-329/80-10 and 50-330/80-11. The licensee's actions in regards to the items of noncospliance were subsequently reviewed and the Atems closed by the NRC as documented in Inspection Report Nos. 50-329/82-15 and 50-330/82-15. 1 On June 30, 1980, the NRC received from the licensee a letter documenting a Program Plan for resumption of safety related work by the Zack Company. The licensee identified that corrective actions required prior to. lifting the Stop j Work included: (1) the review and approval of all Field 1 Quality Control Procedures and specific Weld Procedure Specifications; (2) the review and approval of the revised Zack QA Manual; (3) the training and certification of the QC personnel; and (4) the training of site production personnel. Subsequent to followup NRC inspections to determine the effectiveness of licensee corrective actions, it was determined by the NRC, on August 14, 1980 that HVAC safety -related work could resume. The Bechtel Power Corporation released the Zack Company from the Stop Work Order by letter dated August 14, 1980. As a result of the aforementioned investigation findings, the NRC imposed a Civil Penalty, on January 7, 1981, on Consumers Power Company for the amount of $38,000. 8. The second significant construction problem involved reactor pressure vessel anchor stud failures. Details are as follows: On September 14, 1979, Consumers Power Company personnel notified the NRC of the discovery of a broken reactor vessel anchor stud on the Midland Unit I reactor vessel. l On October 12, 1979,- this condition was reported under the j _ requirements of 10 CFR 50.55(e). Tvo other studs were sub-1.1 sequently found to be' broken. As this condition reflected .a significant deficiency, an NRC investigation was initiated in February 1980 to review the materials, manufacturer, + and installation of the studs. The investigation findings, as' documented in Inspection Repo'rt Nos. 50-329/80-13*and 50-330/80-14, indicate several Quality Assurance deficienciest (1)' lack of licensee involvement; (2) failure to advise the heat treater of different. heats of { material; (3) inadequate document review; (4) failure to respond to indications that the studs were deficient; -(5) failure to review materials previously purchased when the r-purchase specification was revised; and (6) miscalculation of 20 e ~
4 j the stud stress area resulting in a slight over-specification stressing of the studs (this item was identified by the licensee). 1 i Three items of noncompliance were identified in the'-inspec-tion report. These items regarded: (1) failure to identify Subsection NT of the ASME Code as the applicable requirement for the reactor vessel anchor bolts; (2) failure to establish measures to assure that purchased material conforms to the procur,ement documents; and (3) failure to establish measures to assure that heat treating and nondestructive tests were controlled in accordance with applicable codes and specifi-cations. Licensee commitments in regards to corrective actions included: (1) a commitment to conduct a review to confirm that safety related low alloy steel bolting and/or component support materials, which have been tempered and l quenched and are 7/8" or greater in diameter, have been j procured in accordance with proper codes and standards; (2) a commitment to obtain KRR approval of the acceptability of the Unit 2 reactor vessel anchor bolts and (3) a commit-ment that actual plant modifications to compensate for the defective bolts would not be started on Unit I until approval of the design concept was received from NRR. l The stud failure mechanism was identified as stress corrosion cracking which propagated to the point that the studs failed by cleavage fracture. Tests indicated that some studs 1 utilized in Unit 2, although of different material and heat treatment, have above specification surface hardness readings. The final report per 50.55(e) requirements was submitted by the licensee on December 1, 1981. NRR has the lead-responsibility for evaluation and approval of the licensee's proposals for resolution of this mattar. 9. A special inspection was conducted in December, 1980 at the Bechtel Power Company Ann Arbor, Michigan offices to verify implementation of the specific commitments and action items reflected in Consumers Power Company response to 10 CFR 50.54(f) questions (regarding excessive settlement of the Diese1' Generator Building foundations). The results of this inspection were documented in Inspection Report Nos. 50-329/80-32aand 50-330/80-33. Tw'o items of noncompli-i ance were identified regarding: '(1) failure to provide adequate corrective actions with regard to identified audit, results; and (2) inadequate design control.- Licensee corrective actions included: (1) revision of procedures; (2) revision of specification; and (3) audit of TSAR sections. The licensee actions were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-12, 50-330/81-12, 50-329/81-19 and 50-330/81-19. 21 v y --t-- y. iir
=. l Additional information regarding this matter is discussed in l the 1981 section of this report, Paragraph K.6. K. 1981 { Twenty-three inspection reports were issued in 1981 of wh'ich one pertained to a management meeting and twenty-two to onsite inspections. A total of twenty-one items of noncompliance were identified during 1981. One significant construction problem was identified involving deficiencies in piping suspension system in-stallations (see Paragraph 4). These items / problems are described below: 1. Two items of noncompliance were identified in Inspection Report Nos. 50 329/81-04 and 50-330/81-04. Thece items regarded: (1) failure to account for all tools and materials used in a controlled clean room area; and (2) inadequate procedure for the installation of the Unit 2 vent valves in the core support assembly. Licensee correc-l tive actions. included: (1) the upgrading of personnel and equipment logs; (2) the addition of new logs; (3) issuance .of a formal Stop Work Order for further work on the instal-i lation of vent valves; (4) the revision of installation procedures; (6) training and indoctrination of personnel performing vent valve installations; and (5) the revision of the overview inspection plan. The licensee's actions in regards to these items were reviewed and it was determined that action had been taken to norrect the identified non-compliances and to prevent recurrence. This determination' is documented in Inspection Report Nos. 50-329/81-04 and 50-330/81-04 i 2. One item of noncompliance was identified in Inspection Report Nos.- 50-329/81-08 and 50-330/81-08 regarding the failure to provide adequate storage conditions for Class IE j equipment. Licensee corrective actions included: (1) addi-tional training for Bechtel maintenance engineers; (2) an audit of maintenance activities; and (3) reinspections of I affected equipment.. The li:ensee's actions in regards to this matter were subsequently reviewed &nd the item closed by the NRC as documented in Inspection Report Nos. 50-329/81-23 j and 50-330/81-23. 3. Tour items of noncompliance were identified in Inspection-Report Nos. 50-329/81-11 and 50-330/81-11. These items regarded: (1) inadequate procedures for the temporary support of cables and for the routing of cables into equip- ~ ' ment; (2) failure of QC inspectors to identify inadequate cable separation; (3) inadequate control of nonconfr-ming' raceway installations; and (4) failure to translate the TSAR requirements into instrumentation specifications. Licensee corrective actions in regards to (1) and (2) above,. 7 p included: (1) the revision of cable pulling procedures - l 22 L .+ +aw r 3 A
I 4 (2) the repair of damaged cables; (3) training given to the termination personnel and the involved QC inspector; and (4) the. revision of the cable termination procedure. The j licensee's actions in regards to these items were shbsequently i reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-20, 50-330/81-20, - t 50-329/82-03 and 50-330/82-03. Licensee commitments in regards to corrective actions pertaining to items (3) and i (4), above, included: (1) the addition of required barriers on pert,inent raceway drawings; (2) the revision of Project Quality Control Instruction; (3) and the revision of the instrumentation specification. The licensee's actions in t j regards to these items will be reviewed during subsequent NRC inspections, i l l 4. Eight items of noncompliance were identified during a special indepth team inspection to examine the implementa-tion status and effectiveness of the Quality Assurance i Program. The results of the inspection are documented in Inspection Report Nos..50-329/81-12 and 50-330/81-12. l l Three of the items of noncompliance regarded: (1) failure 4 l to take adequate corrective action concerning the trend analysis procedure; (2) failure of QC inspections to I identify a nonconforming cable bend radius; and (3) failure to take adequate corrective action in regards to the lack i i of rework procedures. Licensee corrective actions in regards to items (1) and (2) above, included: (1) the issuance of a new procedure for trending; (2) the revision of cable termination procedures; and (3) additional train-ing given to the responsible QC inspector. The licensee's j actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/82-02, 50-330/82-02, a 50-329/82-03 and 50-330/82-03. The licensee's commitments in regards to corrective actions pertaining to item (3) above, included: (1) the development of Administrative Guidelines and Instructions for rework; and (2) the revision of field procedures. The licensee's actions in regards to this item will be reviewed during subsequent NRC inspections. The remaining five items of noncompliance identified in Inspection Report Nos. 50-329/81-12 and 50-330/81-12 are i considered to be a~significant construction problem. j Safety related pipe support and restraint installations -and QC inspection deficiencies in regard to those instal-lations were identified. The'five items of noncompliance pertaining to this issue regarded: (1) failure to install large bore pipe restraints, supports and anchors in accordance with design drawings and specifications; (2) failure of QC inspectors to reject.large bore pipe restraints, supports and anchors that were not installed in accordance with . design drawings and specifications;-(3) failure to prepare, I 23 1 l 7
i review and approve'small bore pipe and piping suspension system designs performed onsite in accordance with design control procedures; (4) failure to adequately control documents used in site small bore piping design act4vities; and (5) failure of audits to include a detailed review of system stress analysis and to follow up on previousl;y iden-I tified hanger calculation problems. Licensee corrective actions in regards to items (3) through (5) included: (1) the review and upgrading of small bore piping calculations (2) audits of small bore piping activities; (3) revision of Engineering Directive; (4) additional training in QA pro-cedures; and (5) audits of document control. The licensee's actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/82-07 and 50-330/82-07. hsaresultoftheadversefindings,anImmediateAction I Letter (IAL) was issued by the NRC on May 22, 1981 acknow-l 1 edging the NRC's understanding that the licensee would i not issue fabrication and construction drawings for the { installation of the safety related small bore pipe and piping suspension systems until requirements identified in the IAL had been completed and audited. The IAL requirements were subsequently reviewed and determined to have been satisfactorily addressed. This is documented in Inspection Report Nos. 50-329/81-14 and l 50-330/81-14 l The licensee's actions in regards to noncompliance items j (1) and (2) above, are discussed in Paragraph I of the following report section for 1982(L). 6 5. One item of noncompliance was identified in Inspection Report Nos. 50-329/81-14 and 50-330/G1-14 concerning i inadequate design centrols involving the Bechtel Resident Engineer's review of the field engineers redline drawings for small bore piping. Licensee corrective actions included: (1) a 100% review of all questionable systems; and (2) the revision of a Project Instruction. The ifcensee's actions in regards to this matter were subsequently reviewed and.the item. closed by the NRC as documented in Inspection Report Nos. 50-329/82-07 and 50-330/S2-07. ,t f 6. In January, 1981 an inspection was conducted by the NRC to verify whether adequate corrective actions had been imp 4e-mented as described in the Consumers Power Company response' to Questions 1 and 23 of 10 CFR 50.54(f) submittals (regarding excessive settlement of the Diesel Generator Building foundation). The findings during this inspection, which include three items of noncompliance and one deviation, are documented in Inspection Report Nos. 50-329/81-01 and t 24 A m - 1 %~
J 30-330/81-01. The items of noncompliance and the deviation j regarded: (1) failure to develop test procedures for soils I work activities; (2) failure to have soils laboratory l records under complete document control; (3) failuri to have j explicit instructions for the onsite Geotechnical Ehgineer's review of test results; and (4) failure to have a qualified Geotechnical Engineer onsite. Licensee corrective actions J included: (1) revision of Quality Control Procedures and Specification; (2) development of new Quality Control Procedures; and (3) the addition of a qualified Geotechnical ~, Engineer. The licensee's actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-12 and 50-330/81-12. k 7. In March 1981, an inspection was initiated by the NRC to verify the licensee's Quality Assurance Program for the ongoing soil borings. The soil borings were performed f by the licensee in response to a request from the Corps } of Engineers for additional soil information for their review of the licensee's 10 CFR 50.54(f) answers. The i findings of this inspection, which includes one item of noncompliance, are documented in Inspection Report Nos. 50-329/81-09 and 50-330/81-09. The noncompliance regards the lack of evaluation of Woodward-Clyde technical capabilities prior to the commencement of drilling opera-tions. Licensee commitments in regards to corrective a j actions included: (1) the review, for compliance, of Midland Project major procurements and contracts; and 1 i (2) the review and revision of pertinent precedures. The licensee's corrective actions in regards to these items will I be reviewed during subsequent NRC inspections. s L. 1982 i Fourteen inspection reports have been issued during 1982 covering the period through June 30, 1982 of which two ' pertain to a.anage-mant meetings, one to an investigation, one to the SALP meeting, and ten to onsite inspections. During this period of time seven items of noncompliance were identified. One significant i construction problem was identified involving electrical: cable l misinstallations (Fee Paragraph 2). These items / problems are j discussed below: ii 1. The licensee conducted reinspections to determine the seriousness of the safety related support and restraint installation and QC inspection deficiencies identified in Inspection Repert Nos.150-329/81-12 and 50-330/81-12. The results of the reinspections are documented in Inspection Report Nos. 50-329/82-07 and 50-330/62-07. From a sample L size of 123 safety related supports and restraints installed and inspected by Quality Control, approximately 45*. were p l-identified by the licensee as rejectable. t 25 ' 1
On August 30, 1982, the licensee was informed of the NRC's position that the licensee shall reinspect all the supports and restraints installed prior to 1981 and perform sample reinspections of the components installed after 198{. The licensee has agreed to perform the reinspections. 2. One significant construction problem was identified during 1982. It involved electrical cable misinstallations. j Details are as follows: During the special team inspection conducted in May 1981, the NRC identified concerns in regards to the adequacy of inspections performed by electrical Quality Control inspec-tors. These concerns were the result of the NRC's review of numerous Nonconformance Reports (NCR) issued by Midland i Project Quality Assurance Department (MPQAD) personnel during reinspections of items previously inspected and accepted by Bechtel QC inspectors. The NRC required the licensee to perform reinspections of the items previously inspected by the QC inspectors associated with the MPQAD NCRs. The licensee, in reports submitted to the NRC in May and June 1982, reported that of the 1084 electrical cables reinspected, 55 had been determined to be nisrouted in one or more vias. This concern was upgraded to an item of non-compliance and is documented in Inspection Report Nos. 50-329/82-06 and 50-330/82-06. On September 2,1982, the licensee was informed by the NRC that a 100*. reinspection of class 1E cables installed or partially installed before March 15, 1982 was required. In addition, the licensee was required to develop a sample reinspection program for those cables installed after March 15, 1982. The licensee has-agreed to perform the reinspections. 3. Three examples of noncompliance to one 10 CFR 50 Appendix B Criterion were identified in Inspection Report Nos. 50-329/82-03 and 50-330/82-03. These examples regarded: (1) failure to follow procedures concerning drawing changes; (2) inadequate specification resulting in the undermining of BWST No. 2 valve pit; and (3) inadequate control of changes to procedures. 7te licensee's response to the identified item of noncompliance is presently under review. Corrective actions taken by the licensee in regards to this item will be a reviewed during future inspections. l 4. Four examples of noncompliance to one 10 CFR 50 Appendix B Criterion and a deviation were identified in Inspection Report Nos. 50-329/82-05 and 50-330/82-05. The examples of noncompliance and the deviation regarded: (1) failure to review and approve a Mergentine (the soils contractor) field procedure prior to initiation of work; (2) inadequate . control of specification changes; (3) inadequate acceptance i 26 1 L
~ s. 4 j criteria for dewatering specification; (4) inadequate instruction to prepare or implement reinspection plans; and (5) inadequately qualified remedial soils staff. The correc-tive actions.taken by the licensee in regards to this item will be reviewed during future inspections. l S. One item of noncompliance was identified in Inspection Report Nos. 50-329/82-06 and 50-330/82-06 concerning the licensee's failure to establish a QA program to provide controls over the installation of remedial soils instrumentation. This item I resulte'd in the issuance of a letter by the licensee on March 31, 1952 confirming the licensee's suspension of all underpinning instrumentation installation activities until: (1) approved, j controlled drawings and procedures or instructions were developed to prescribe underpinning instrumentation installation activities; (2) plans were established to inspect and audit instrumentation 4 . installation activities; and (3) Region III had concurred that l (1) and (2), above, were acceptable. A followup inspection by Region III in April 1982 identified that the licensee had developed acceptable drawings, procedures, and instructions for underpinning instrumentation installations such that instrumentation installation activities could be resumed. An additional followup inspection on August 23, 1982 determined that the installation of underpinning instrumentation for the Auxiliary Building was complete and acceptable. This 4 item will remain open pending the licensee's development of drawings, procedures, and instructions for the future installation of underpinning instrumentation for the Service Water Building. [ 6. One item of noncompliance and a deviation were identified in Inspection Report Nos. 50-329/E2-11 and 50-330/82-11. The items }l regarded: (1) inadequate anchor bolt installation; and (2) the use of unapproved installation / coordination forms during remedial soils instrumentation installations. The licensee's responses to the identified items of noncompliance are presently under review. Corrective actions taken by the licensee in regards to these items will be reviewed during future inspections. ] t The ASLB issued an order modifying Construction Permits No. CPPR-81 and No. CPPR-82, dated April 30, 1982. This order-suspended all remedial soils activities on "Q" soils for which the licensee-did-not have prior explicit approval. The ASLB issued another order, dated May 7, 1982 clarifying the April 30, 1982 order. This order only includes those activities bounded by the limits identified on Drawing C-45. As a result of past Region LII findings,'the Region III Administrator. created a special Midland Section staffed with individuals assigned solely to the Midland project. Since the formation of the Midland Section a work authorization procedure has been developed by ' Region III and the' licensee to control work and ensure compliance to the ASLB Order. { 27 ~ms .a le.,... a m
6 Remedial Soils activities performed by the licensee thus far in 1982 involve: (1) the drilling of a number of wells which function as part of the temporary and permanent dewatering systems; (2) the installation of the freeze wall associated with the Auxiliary Building Underpinning activity; (3) the completion of the initial work on tha access shaft; and (4) the completion of the A2xiliary Building instrumentation for l remedial soils activities. l t I o 4 k i f i s' a I i i 28 i ^ ' %i. W
.n _.. ?s w - I^ k -[. in naa 1 g //6,u/t/g o,, UNITED STATES NUCLEAR REGULATORY COMMISSION g l yRINCIPAL STAFF / wasHWGTON. D. C. 20555 g3 g ggy j \\,,,,,,,/ March l'4, 1983 !O/RA E3/ A /Pk ' P Af) /P / SLO ~ Docket Nos: 50-329 GWA / dC and 50-330 ' 4tSF / I J ov. ML / i FILE evJ/- /01,/ i 1 APPLICANT: Consuners Power Company /,, FACILITY: Midland Plant, Units 1 and 2
SUBJECT:
DOCKETING OF MARCH 7,1983, LETTER FROM GOVERNMENT ACCOUNTABILITY PROJECT On March 7,1983, Ms. Billie Garde of the Government Accountability Project (GAP), a citizens interest group, delivered to the NRC's Director of the Division of Licensing the enclosed letter consisting of GAP's comments on the " Construction Completion Plan" described in a January 10, 1983, letter from Consuners Power Company. Ms. Garde briefly summarized portiens of the contents of the letter. NRC members present for Ms. Garde's summary were D. Eisenhut, R. Warnick, T. Novak E. Adensam and D. Hood. Ms. Garde's letter is enclosed for docketing and future reference purposes, fa t. S '~h Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing Enclcsure: As stated 4 cc: See next page i A Ii f 4 i MAR 211933 ^ v v ' 9 cr f p ~ /. r1 CW/ ^ '
) MIDLAND Mr. J. W. Cook Vice President Conswers Power Company 1945 West Parnall Road Jackson, Michigan 49201 i cc: Michael I. Miller, Esq. Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq. Division of Radiological Health Alan S. Farnell, Esq. Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza, Lansing, Michigan 48909 Sist floor Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq. St. Paul, Minnesota $5108 Consmers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office ~ Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Divisio,n Constners Power Company 720 Law Building.- 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 l Mr. Wendell Marshall Mr. Walt Apley i Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL) Battelle Blvd. Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. 1. Charak, Manager NRC Assistance Project Mr. R. B. Borsta Argonne National Laboratory i Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Connission, Cherry & Flynn Region III Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 ' ' ~ Chicago, Illinois 60602 I i i i j f .6
s 'j i 2-j Mr. J. W. Cook i i i l cc: Lee L. Bishop Harmon & Weiss 1725 I Street, N.W., Suite 506 l Washington, D. C. 20006 i i Mr. Ron Callen f Michigan Public Service Commission 1 6545 Mercantile Way P.O. Box 30221 Lansing, Michigan 48909 Mr. paul Rau Midland Daily News 124 Mcdonald Street Midland, Michigan 48640 Billie Pirner Garde Director, Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W. Washington, D. C. 20009 e e e f k %g ?! 4 9 g l o ~
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) GOVERNMENT ACCOUNTADILITY PROJECJ j i Institute for Policy Studies l 1901 Que Street. N.W., Washington. D.C. 20000 (202)234-9082 j i l March 7, 1983 I l Mr. Darrell Eisenhut, Director Division of Licensing U.'S. Nuclear Regulatory Cocmission Washington, D. C. i
Dear Mr. Eisenhut:
On February 8,1983, the Government Accountability Project (GAP) attended two public meetings in Midland, Michigan on behalf of the LONE TREE COUNCIL, concerned citizens, and several former and current employees working on the Midland Nuclear Power Plant, Units 1 and 2. As you know, the large public turn-out for both the daytime meeting between Consumers Power and various Regional and Washington-based offices of the Nuclear Regulatory Commission (NRC) and the evening session between the NBC and the general public included spirited debate and lengthy presentations. These meetings, although highly beneficial to the education of the Michigan public about the nuclear facility being constructed in Midland, did not allow for the type of technical questions and detail about the Construction Ccmpletion Plan (CCP) in which GAP is partiqularly interested. Therefore, I appreciate this opportunity to address a number of concerns - that we have regarding issues presented at the public meeting and contained in the detailed CCP submissions. In order to complete our own continuing analysis of the Midland project, I would hope that you can provide answers to and/or I conunents on the enclosed questions. Pending further public meetings and detailed review of basic elements of. I the Construction Completion Plan, I assume that your verbal requests to Consumers i Power (Consumers) management to " hold off" on making any constitments will be I translated into a firm NBC directive. As you know, Consumers has had a history of misinterpretations and miscomununications it. relation to many of the aspects surrounding'the Midland plant. The public understood quite clearly what your instructions were: if those have changed I suggest that you concinue to express those. changes to the pu' ic through the appropriate local media representatives. l -1 t I. REQUESTS FOR FURTHER INFORMATION i \\ A. The relationship between the Washington NBC offices (NRR, DOL, etc.) and the Regional management. and on-site Midland Special Team and Inspector. It is unclear where the authority lines for approval of various elements of the Midland construction project are drawn. GAP investigators, staff and attorneys are continually getting unclear ' signals from the various regulation divisions as to who is making what decisions and when..Since it has been noted by the NBC staff itself that "[ Consumers] seems.to possess the unique ability to search all factions of the.NRC until they i ~ fA D jf ..,._ v..- w w m.. m,w ....e~ a.. .r ')
l l i l ~ ) i i l a. f i j Mr. Darrell Eisenhut March 7, 1983 have found one that is sympathetic to their point of view - irregardless of the impact on plant integrity,"V it seems critical to establish once and for all the authority lines within the NPC that Consumers must re-spond to. We are particularly concerned about the apparent transferring of responsihi-lity for the on-site inspectors and the Midland Special Section Team to the Regiopal t j Administration and Washington-based NRC officials. Although I am sure that you have l read the testimony of Mr. Kappler, submitted to the Atomic Safety and I.icensing Board (ASLB) on October 29, 1983, and attached memorandum from the staf f members that are more directly responsible for the Midland project, I have included them with this letter for your renewed attention following the results of the Diesel Generator Building inspection. (Attachment #1.) l There have been a number of incidents within the last several months where . } Regional personnel (RIII team or on-site) have indicated one answer pertaining to j construction work, and then other action was taken after approval from NRR. Several examples of this that are fairly. recent are: 1. A February 8,1983 conference call between Consumers, Bechtel and the NRC regarding the discussion of loading sequence for pier load test and background settlement readings did not include any Region III per-sonnel, most particularly Ross Landsman. Although I do not know the details of his exclusion, I am concerned that he was not a participant in the call, or in the decisionmaking process., 2. At the recent ASLB hearings NRR and RIII personnel were asked about the projected timeline for Consumers to approach the Feedwater Isolation Valve Pit jacking work. RIII personnel seemed confident that work would not begin on this until at least late March or early April, yet work ac-tually was begun on the same day as the' conversation, February 17, 1983. 1 i 3. The NRC has taken a position that "no major discrepancies" have been found in the soils remedial work to date. Yet: (a) two cracks, in-cluding one 10 millimeters by 7 inches long, have been discovered in the valve pit.M -(b) A February 15, 1983 memorandum from R. B. Landsman to R. F. Warnick identifies three specific concerns since the beginning of the underpinning work that - to GAP - indicate serious flaws in the perception of Consumers about the seriousness of the work they. are en-gaged in. These include craftworkers not receiving' the required amount t. of training, argunerr with Consumers about techniques that show a pri- . { ority to deadlines instead of quality, and a. major flaw in the Stone E Webster independent assessment. (Attachment #2.) Given our experiences with the NRC inspection efforts, I am particularly. anxious' to have the on-site /special section team members have as much direct input-into the review / licensing process as possible. - Although I do not always agree with j . their decisions or their actions, I am more comfortable with their version of the facts on the Midland site. M emorandum from R. J. Cook to R. F. Warnick, July 23, 1982. M E ccording to the Midland' Daily News, February 24, 1983, Construction Technology. A had performed an " independent" analysis of the cracks before the Midland team even-had the opportunity to camplete its own investigation or review. 4 e- _.t.__.
l f. + .g Mr. Darrell Eisenhut March 7, 1983 1 l B. The guidelines and timetable by which the independent third-j party auditor will be chosen. l It is not at all clear what guidelines, if any,'your office intends to employ in the review or monitoring of the selection process for the third-l party auditor of the Midland facility. We are extremely distressed at the way that both Stone & Webster (S&W) and the TERA Corporation were approved { by your office. We feel that the approval was more by default than by i aggressive review of the proposals, contracts and criteria as presented to the NRR offic's. Further, it is very clear to us that the Regional per-3 sonnel involved in the initial contact with the Stone & Webster organization gave the impression that S&W's on-site activities were authorized. Even if f that impression was only technically incorrect, it is a serious breach of public trust by the Regional staff. We recommend that your office adopt the prudent position that Consumers 1 follow the nominating process used for Diablo Canyon's independent assessment. Al-i though Midland's problems have not yet reached the stage of major public controversy i such as Diablo or Zinumer, it is clearly evident that the sensationalism of the prob-lems with the soils settlement and the cost of the Midland facility will move it more into the public eye as it reaches completion. If there was any doubt as to the active interest of the Midland community in regards to the Midland facility, the February 8,1983 public meeting should have { dispelled that misconception. The consnunity surrounding the plant is extremely t attentive to the issues and concerns raised by the nucleaf facility -- the debate will continue. To choose another, more congenial approach to identifying the firm that will be responsible for the congletion of the plant would be a grave mistake in our opinion. C. The plans that the NRC staff has made to determine the actual "as ~ built" condition of the rest of the buildings and systems on the Midland site in the wake of the findings in the Diesel Generator Building inspection. The aggressive efforts of the DGB inspection were a solid step forward in t deternLining the extent of the problems at the Midland facility. However, it is unfortunate that the inspection did not expand to other buildings. The public must have confidence that all the problems have been identified, as well as basic factors about how the problems were caused and how-they are t
- going to be fixed if there is ever any hope for restoring faith in the
~ safety of the plant. f D. The methodologies' that are to be employed in the t'echnical review of generic problems on the site, such as determining the accuracy-of quality control / quality assurance documentation made suspect-by the flawed process, and the training and recertification of all the welders who were trained -by Photon Testing,.Inc. i The-two items mentioned above, as well as problems that have resulted from the ZACK corporation, unidentifiable electrical' cables, untrained quality control inspectors, material traceability inaccuracies, etc., must.be ad- - dressed in any workplan to identify the problems on the site. It is not j~ clear whether the NRC staff, the NRR staff or the independent auditor is to l' I i .... ~.. - -......... - = ~ e e.- -sew +- ,e e-- g no
r o j l l i l l Mr.' Darrell Eisenhut March 7, 1983 l be responsible for identification bf all of the problems prior to the start up of construction activities on the site. l t E. The resolution of what is and what is not "Q" work in regards to the soils remedial work should be handled in a public forum. -l The "Q" debate between NRC staff members - including Regional management and the on-site inspectors - as well as between the NRR and NRC staff i has been a topic of considerable concern to us. The resolution of these issues has critical implications for the rest of the i soils work project. Because it has been a major item of discussion l in the hearings currently underway in Midland, as well as among l the staff, we believe that it would be beneficial for you to receive i the position that concerned citizens have taken. I have suggested that those residents who have been following this issue very closely Prepare a position statement for your office on the "Q" soils issue. II. COMMENTS CONCERNING THE THIRD-PARTY REVIEWS It is our understanding that there are currently three separate independent audits being conducted (or considered) at the Midland facility. These ares (1) The Stone and Webster Corporation's third party independent assessment of the soils remedial work activities. A February 24, 1963. letter from Mr. Keppler. 3 l to Cona.mers outlines the scope of the S&W assessment. It significantly broadens i the original scope of S&W's review. As a result of the expansion of S&W's responsibilities, and apparently a close monitoring of their work by the RIII team, Mr. Keppler approved the release of additicnal underpinning work for construction.- We request the following documents in reference to the S&W approvals i a. The criteria that NRC officials used to judge the adequacy of the l initial S&W work. b. The methodologies which the S&W personnel are utilizing to provide their QA overview and assessment of the design packages, inspector requalification and certification program, and training programs. c. The details of the expanded work contract which will assess the actual underpinning work on safety-related structures. (2) The Independent Design Verification and vertical slice review being ~ performed by the TERA Corporation. We have recently received the detailed,- Engineering Frogram Plan from TERA on'the Midland Project. Although extremely impressed with some of TERA's procedures, organisation and structure there are -a number of areas which raise serious questions. f
- a. ~What specific reporting procedures does TERA have to follow in regards to findings, corrective action reports, controversies -
g among their own staff over issues of noncompliance or questionable 3 accuracy,.and internal reporting. Figure 1-1 clearly indicates that + 4 -I ......J.~.'_,. 4..... 4 - - - -. y ,wy-
Mr. Darrell Eisenhut March 7, 1983 TERA intends to notify the NRC at the same time as Consumers, but at the February 8 meeting there was a very clear example of that not actually happening because of miscommunication between TERA and the 1 NRC. i b. What is the difference between a Corrective Action Report as referenced in the QA Audit Procedures and a Non-Conformance Report as required by 10 CFR Part 21. ( A similiar " informal" nonconformance reporting procedure at the William H. Zimmer plant caused innumerable problems for both the NRC' and the licensee.) We would ask that the C.A.R.'s be forwarded to the NRC, or preferably be written up as NCR's immediately upon identification of an iten of non-ccmpliance. Any discretion between informal and formal procedures should be limited to the judgement of the NRC. c. What is the intent and scope of the " EXCEPTIONS" referred to in Part 1.1 of the plan? d. Who controls the Administrative decision making process between Consumers and TERA over specific points of technical controversy? e. What documents will be forwarded to the NRC in support of the various findings - whether favorable or unfavorable - during the course of the two vertical slice reviews? (Further comments and questions about the TERA plan will be forthcoming under separate cover when we are able to finish our review.) (3) The overall independent third-party assessment. Instead of providing your office with our detailed ( and lengthy) analysis of the flaws and shortcomings of the CCP as introduced by Consumers in the Jr.nuary 10, 1983 j ~ letter and the public meeting we have decided to. wait for further detail to be provided by Consumers on their plan. We are somewhat anxious about this, as we understand that there have been detailed discussions going on between the NBC and Consumers. As you know, similar events at the Zinuner plant led to increased public skepticism and an even greater loss of confidence in the NRC process. I We strongly encourage your office and the Regional Administrator to consider the process of choosing a third-party auditor as important and delicate as was the process at Zinener. If there is to be a " closed door" approach to Midland we request that you articulate that at.this time. If you do not we will assume that the NBC intends to follow a fully public process of nomination and selection. t l Thank you for your time, we look forward to answers to our questions ) in the near future. Sincerely, s' BIIIIE PIRNER Director, Citizens Clinic .y
y, mm Amcem #1 i 10/29/82 4 l ) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OM & OL ) 50-330 OH & OL ~ (MidlandPlant, Units 1and2) ) j TESTIMONY OF JAMES G. KEPPLER WITH RESPECT TO QUALITY ASSURANCE Q.1 Please state your name and position. A.1 My name is James G. Keppler. I am the Regional Administrator of the NRC's Region III office. My professional qualifications have been l, I l previously submitted in this proceeding. Q.2 Please state the purpose of your testimony. A.2 In my testimony to the Board in July 1981, I testified cr..ae more significant quality assurance problems that had been experienced in connection with the Midland project and the corrective actions taken by Consumers Power Company and its contractors. I stated that, while many significant quality assurance deficiencies have been identified, it was I cur conclusion that the problems experienced were not indicative of a ( l breakdown in the implementation of the overall quality assurance program. i I also noted that while deficiencies have occurred which should have been . identified earlier, the licensee's QA program had been effective in. the ultimate identification and subsequent correction of these deficiencies. Furthermore, I discussed the results of Region III's special quality 3 s i l S' o V w&:ng~. - ~ . ~ - - - - - - - - 1 wv i I . :n ,..i.
assurance inspection of May 18-22,1981, which reflected favorably on the l effectiveness of the Midland Project Quality Assurance Department, which was implemented in August 1980. The thrust of my testimony was that I { had confidence that the licenseee's QA program both for the remedial soils work and for the remainder of construction would be implemented - i effectively. It was not until April 1982 that I was made aware of additional problems with the effectiveness of implementation of the QA program. The problems came to my attention as a result of the April 1982 meeting between NRC and Consumers Power Company to discuss the Systematic Assessment of Licensee Performance (SALP) report for Midland and the discussions held within the Staff in preparation for that meeting. The-SALP report addressed the Midland site activities for the period July 1, 1980 through June 30, 1981. During this period, the sails work activities were rated Category III. the lowest acceDtable rating given by the SALP rev% nmeau-During the April 1982 public r.eetir.g on the SALP findingt, Mr. Ronald J. Cook, NRC Senior Resident Inspector at Midland, stated that i as of that date he would rate Consumers Power Company soils work Category III, the same rating as it received for the SALP period. He had similar consents on other work activities. ' Based on my July 1981 ta*Hmanv, I expected Consumers Power Company would be rated a Category I or II in the soils area, as well as other areas, by April 1982, and I was certain that iny July 1981 testimony had left that ~ impression with the Board. i I I I 1 e ...,...-..7_ .--....,..,.y ..._.m
\\ 3-On the basis of the above, I de.cided it was appropriate to supplement my July 1981 testimony. l Q.3 What actions have been taken by Region III in response to the j information contained in your previous answer? A.3 I_ met with tha NRr suoervisors and insDectors who had been closely involved with Midland during the past year to get a better understanding of their concerns. As a result of these meetings, I concluded that the oroblems beina exoerienced were ones of orecram imnlementation rather. l than problems with the OA orngram itself. Because of my concerns I requested the Region III Division Directors most actively involved with the Midland inspection effort to try to identify the fundamental problems and their causes'and to provide me with their recomendations to resolve these problems. They provided me with an assessment of technical and comunications problems experienced by the licensee and made recomendations with respect to the licensee's workload, institution of independent verification programs, and QA organi:ation realignments. This response is included as TAttachment A.] (Memorar.dum from Norelius and Spessard to Keppler, dated ~ June 21, 1982) 1 n Julv loa 7 f reengnhed that more NRC reenurese were nninn tn have 1 .j to be _orovided in overseeing activities at Midland and created the Mfica l of Saecial caeae Intc) to manage NRC field activities at Midland (and,. Zimmer). Mr. Robert Warnick was assigned Acting Director. A Midland l Section was formed comprised of a Section Chief, two regional based * ~ l .._ _._.__.. _..... m..., _ _ _.... _ _,
) 1 4 inspectors, and two resident inspectors (the second resident inspector reportedonsiteinAugust1982). Before meeting with representatives of the Office of Nuclear Reactor j Regulation (NRR)todiscussoptionsforNRCactioninconnectionwith ~ Midland, Mr. Warnick requested Senior Resident Inspector Cook td provide a sumary of the indicators of questionable licensee performance. 1 Mr. Cook provided a memorandum documenting a number of problems and concerns,whichisincludedaspttachmentB.)(MemorandumR.J.Cookto R. F. Warnick, dated July 23,1982) Mr. Warnick and I met with representatives of NRR on.1n1v 26.1982 to discuss Consumers Power Company's perfonnance. This meeting resulted V in recomended actions concerning third carty reviewt of past work and ongoing work which are described in AttachmentC) (Memorandum,Warnick ~ to Files, dated August 18,1982)' l Following the meeting with NRR, Mr. Warnick discussed with members j of the Midland Section positions concerning third party reviews developed at the n.eeting with *iRR. The mamhart of the Mic: land Section were not 1 convinced the reenernanded actions were the kne+ enintinn. tince the i causes of the problems had not been clear 1y idenn fiad-Instead, they proposed a somewhat different approach consisting of an augmented NRC l inspection effort coupled with other actions to strengthen the licensee's ' QA/QC organization and management. This proposal is documented in Attachment D.. (Memorandum, Warnick to Keppler, dated August 18,1982)' l In response to these suggestions, Mr. Darrell Eisenhut. Director. - Division of Licensing, NRR, and I met with top corporate management representatives from Consumers Power Company on August 26t 1982, and ~ l - -. _. - - - - - - =
s. aaain on September 2,1982, to discu,ss NRC's concerns and possible ( !recomended solutions. Because it was not clear to the NRC staff why Consumers Power was having difficulty implementing their QA program, we requested them to develop and propose to the NRC, actions which would be ~ implemented to improve the QA program implementation and, at the same - time, provide confidence that the program was being implemented prope'rly. Consumers Power subsequently presented its proposal for resolution of the identified problems in two letters dated smotember 17. 1982, which are included as Attachments E and F. (Letters Cook to Keppler and Denton, dated September 17,1982) _These arconsals were lackino in detail. earticularly with resnart to the plant indeoendent review orogram. Following a meeting between NRC staff members and Consumers Power Company in Midland on September 29, 1982, Consumers Power submitted a detailed plan to NR'C on October L 1982 concerning the planned third party activities (Attachment G). Consumers Power Company's proposals ((Attachments E F, and G)/ are current 1v under rev' m by NRC. Q.4 Do you believe that soils remedial work at the Midland plant should,, be permitted to continue? A.4 Yes. This portion of any testimony discusses what has been. aconnplished and what will be' accomplished in the ne'ar future to provide e basis for continued construction at the Midland plant. We expect that Consumers Power Company will have independent third party' assessments of the Midland construction project. These assessments will-include reviews of safety related work in progress and of completed 'k }
~. -6 work activities. The scope of, and. contractors for, the third party assessments are presently under review by the NRC staff. l Along with the independent t'"ru party reviews, t'ie Office of Special Cases, Midland Section, has expanded its inspection effort and j has taken actions to assure compliance with the Licensing Board's April 30, 1982 requirement that the remedial soils work activities ~ l receive prior staff approval. Specifically, the Midland Section has {,L) established a procedure for staff authorization of work activities i proposed by Consumers Power Company (Attachment H. Work Authorization Procedure, dated August 12,1982), and (1), has caused a stop of the remedial soils work on two occasions once in August 1982 and again in September 1982 (Attachments I and J. Confirmatory Action Letters dated 4 August 12, 1982, and September 24, 1982, respectively). The Section has i i also start.d an insoection of the work activities which have been accomplished by Consumers Power Company in the last twelve months in the diesel consratar hn41 ding,the <arvice water buildina and other safetv l clated arsas. This inspection as started during October 1982 and is t j continuing as of the filing date of this testimony. Based upon (1) the third party assessments of the plant which will j be performed, (2) the increased NRC inspection effort, and (3) the work authorization controls by the NRC, I believe that soils remedial work at the Midland plant may continue. As demonstrated by the previous / stop-work effected in the remedial soils area, the staff will +=ba whatever action is n e.e-en mesure that construction is in accordance ~ with applicable reunir.m.nts and standards. i i i I i N
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.=w i 7 /vio UNITED STATg5 NUCLEAR REGULATORY COMMISSION i j REGION Ill -Q e j 7se noossystr noso g' otan sLLym.itunoss eotrr. June 21. 1982 MDERANDUM TOR: James C. Kapplar. Regional A<f=fnistrator FROM: C. E. Morelius. Director. Division of Engineering and Technical Programs
- 1. L. Spessard. Director. Division of Project and Resident Progrsas
SUBJECT:
SUCCESTED CHANCIS FOR THE MIDI.AND PROJECT l Historically, the Midland Project has had periods of questionable quality i assurance as related to construction activities and has had commensurate l regulatory attention in the form of special inspections, special meetings, and orders. These problems have been given higher public visibility than most other construction sites in Region III. As questions arise regarding the adequacy of construction or the assurance of adequate construction we are faced with determining what regulatory action we should taka. We are again faced with such a situation. Current Froblem The current probles was caused by a major breakdown in ':he adequacy of l soila work during the late 1970's. Because of the increased regulatory attention given the site, we expect that exceptional attention would be given to this activity and that licenses performance would be better than other sites or areas which have not had such significant problema and therefore have not attracted this level of regulatory attention. However, j that does not appear to be the case and Midland seems to continually have more than its share of regulatory problems. The following are some of the speci2ic items which are troublesome to the staff, i Technical Issues i 1. In the remedial scils area, the licensee has conducted safety related t activities in en inadequate manner in several instances - removal of dirt around safety related structures, pulling of electrical cable, j l drilling into safety related utilities. \\ t o' i e4 O e m nieln 16 - q,, D cf / O er'-8[.. . - ~ ~v J .t.
?.a-~a. -.- ? w ~ ~ :' ^ } ** " '* " ; ~ . ~ - -~ ~ -- *- l l I James G. Rapplar 6/21/82 2. In the electrical area, in trying to resolve a problem of the adequacy of selected QC inspectors' work conducted in 1980, the licensee scompleted only part of the reinspection even when problems were identified,and appears inclined to accept that 5I of electrical cables may be misrouted (their characterization of "misrouting" may imply greater significance than we vuuld attach to similar findings). 3. In the pipe support' area, in trying to resolve a problem of the adequacy of QC inspections conducted in 1980, the licensee has portrayed only a small percentage of defects of " characteristics" i identified and has not addressed the findings in terms of a large percentage of snubbers which any be defective because of the { characteristics within each snubber that say be defective (e.g., if j only one characteristic was defective out of 50 reviewed on a single hanger, the percentage is small; but if the one defective characteristic 1 sekas the hanger defective the result would have a much greater significance level). The licensee htd done a detailed statistical, analysis in an attempt to anow that the saa11.oercentage of characteristics i were found rather than brone y approaching the probles vita significant reinspections to determine whether or not construction was adequate. Conesunications Multiple misunderstandings. meetings, discussions, and consunications seen i to result in dealing with the Midland Project. Some examples are: 1. NRC staff attending a meeting in Washington on March 10, 1982, heard the Consumers Power Company staff say that electrical cable pulling i I related to soils remedial work was completed. It was determined to be ongoing the next day at the site. 2. When Region III attempted to issue a Confirmatory Action Latter, J. Cook informed V. Little of his understanding that both J. Rappier and E. Denton had agreed that the subject of the CAL was not a safety related itaa subject to NRC regulatory jurisdiction. Such agreements had not in fact occurred and following a meeting. Consumers Power Company issued their comeitsents in a letter to Region III. t 3. In reviewing a licensee May 10, 1982 letter, responding to the Board Order, the NRR staff had an unsigned letter and Region III had a signed copy both dated the same date but differing in content. 4 Recently a Region III inspector in closing out and aziting from his inspection described the exit meeting as being the most hostile he had ever participated in. 4 ... * * * * * ~ ' ~ 4
'O ..v. a.....,:... ~. ~ d l James *C. Esppler 6/21/82 I ~~ 3. The responses to any Region III enforceaant letters issued to Midland are more lengthy and " eel argumentative than are any other responses from any other licensee in Region III. This point was l ande in the SEP response provided by Midland,and the SEP response in itself from Midland is an emaaple of the type of response which we commonly receive from the site. The length of the response is at least as long as the initial SEP report. ~~~ ~ ~6. Multiple requests for briefing 'seetings and other statements by the y-- utility' to the effect that we should review procedures in developmental stages imply that Midland wants the NRC to be a part of their construction . program rather than having us perform our normal regulatory function. l Staff Obserestions i 1. With regard to corrective actions of identified noncompliances, the Midland response seems to lean towards doing a parcial job and then writing up a detal. led study to explain why what they have done is sufficient rather than doing a more couplete job and assuring 100% corrective action has occurred. In the detailed writeups that are prepared, it is the staff's view that the licensee does not always represent the significance properly,and the analyses had studies often raise more questions than they solves thus time appears to have been wasted in writing an analysis rather than in fixing the problem. 2. Midland site appears to be overly conscious with regard to whether J or not scaething is an ites of noncompliance and spends a lot of i i effort on defending whether or not something should be noticompliance j l as opposed to focussing on the issue being identified and taking corrective action. This appears in part to be due to their sensitivity of what appears in the public record as official items of noncompliance. This sensitivity any have resulted from the extended public visibility which has attended construction of the facility. The staff's view is that the Midland site would look better from the public standpoint and be more defendable from NRC's standpoint, if they concentrated on fixing identified problems rather than arguing as to the validity of citations. This type of view was expressed by the utility during a recent effort to clarify in detail that certain construction itene on the soils remedial work should not be subject to ERC's regulatory action. 3. The Midland project is one of the most complex and cosp11Agted ever undertaken within Region III. The reason is that they are building two units of the site staultaneously and additionally have an underpinning construction. effort which in itself is probably the equivalent of building .a third reactor site. The sessive construction effort and the various stages of construction activity which are involved make the site autremely comp 14sted to manage. This activity appears to cause a lot of pressure on the licensee management. 0 a . ~.. Y,,.
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i James C. Esppler 6/21/82 4. Mr. J. Cook. the Vice President responsible for the M4Atand site is en extremely capable and dynamic individual. Eevever, these characteristics in conjunction with the complexity and immensenes,s of operation as set forth in 3, above. may actually be contributing to some of the confusion which seems to exist. The staff vieve that (1) he is too much involved in detail of plant operations and there are 4 I times when the working level staff appears to agree and be ready to taka action where Mr. Cook any argue details as to the necessity for such action or any argue as to the specific meaning of detailed work 1 l procedures. (2) this kind of push may lead to such things as letters both signed and unsigned appearing in NRR and causing confusion. (3) this push may lead to some animosity at the licensee's staff level if NRC activities are looked on as slowing progress of construction at j } tse site. t 1 Recce endacions i i It appears essential that some action be taken by NEC to improve the regulatory performance of the Midland facility. The following specific suggestions are made. 1. The company must be made aware and have emphasized to them again that their focus should be on correcting identified problems in a complace and timely manner. 2. We should question whether or not it is possible to adequately manage a construction program which is as complex and diverse as that which i currently exists at Midland. We would suggest specifically that the following activities be considered: i a. That the licensee cut back work and dedicate their efforts to setting one of the units on line in conjunction with doing the soils remedial work. b. That they have a separate mensgement group all the way to a possible new Vice President level, one of which would annage the construction of the reactor to get it operational sad the second i to look, solely after the remedial soils and unde'rpinning activities. 3. Consumers Power Company should develop a design and construction verification program by an independent contractor. This would provide v an important additional asasure of credibility to the design and construction adequacy of the Midland facility. i 3 t ,e
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[./ Q q g g NUCLEAR REGULATORY COM.*.i!SSION )*,, .I REGIONlil "? f rse moossvett moao (pd g =.vr.. j stam sLLvw. ILLahois setzt July 22, 1982 PEMolUWiDUM FCRs R. F. Warnick, Director, Inforcement and Investigations Staff FROM: R. J. Cook, Senior Resident Inspector, Midland Site SU3 JECT: INDICATCRS OF QUISTIC!G31.E I,ICI:3II PI75 ??.Mi:3 - MI:~.A!!D I SITE As per our conversation of July 21, 1982, the following is a list of th:se items that various inspectors consider to be indicative of questionahle licensee perfor ance: 1. One of the leading itens is the over-inspection perforned on electrical QC inspectors whl=h was done in respense to NRC concerns identified in j the May 1981 team inspection. The licensee found weaknesses in the j inspe=tions perfo=ed by s==a electrical QC inspectors pertaining to not idan ifying the mis-routing of cables. This item e.riminated in an itam of noncompliance. The licenses did not expand the overview activity to a degree necessazy for an ac:eptable resolution t the identified weak-ness - even after a meeting in RIZI. This ita= has not been resolved to the satisfaction of the NRC although our position has been clearly defined. I As a partial response to the team inspection concern, the li:n.see ; resented the NRC with an audit report which would demonstrate a response to our con-corn of ques.ionable electrical QC inspec. ions. However, the audit report stated thdt it (the audit report) did not address the ERC concerns. 2. During the dialogue for the underpinning and remedial soils work, a large amount of emphasis has been placed on the settling data for the struttures involved. During a meeting in NQ on March 10, 1982, the need for QC require, ments on remedial scils instr-mentation were amplicitly delineated. However, one week later, the NRC inspe= tors found soils work.. instrumentation instal-lation was started the day after the March 10, 1982 seating without a QC/QA i umbrellas that the licensee's QA Auditor and QA ragineering personnel were not appr: ached pertaining to the need for QA coverage for this soils se.ttle-ment iretr=entations that there were strong indica. ions that the licensee had mislead the NRC in relating that the work was essentially complete when indeed it was not; and presently, the licensee manage =ent informs our inspec-tor that itans are ready for his review when in actuality they are not. Our conversaticas with licensee pers=nnel - other than management - confirm that the items are not ready for review. l Nes kN82. q u, ~a n i s e c2 v a y v _,,y y .e
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-. u. '. ..La.... - u -., .;.;.u 6.,. .,s.,n, ,,..._s.... R. F. Warnick 2, July 23, 1982 i 3. Historis.11y, one of the NRC questions has been, "Who is running the job - Bechtel or consumers?" The following amasple would allow one to believe it is Bechtel: As a part of the resolution to our findings in the soils settlement instrumentation installation, the NRC insisted that I the licensee generate a Coordination / Installation Form to cover interface between different evolutions of instrumentation installation. The lican-l see would call our inspector for his concurrance on the adequacy of the 4 form - the inspecter would approve consumers Power company's form, but then would find out that Be:htel did not want to work to consumer's form - the form that was generated to resolve regulatory concerns. This event i has oc.urred twice and was considered as a deviation during a more re=ent inspection. The opinion of the staff is that if censumers ganarates a for:s that will aid them in not incurring regulatory difficulty, and which 6 has had NRC input, the lica?see should demand that the contractor co= ply with these policies instead of the contrartor dictating the regulatory i I environment under which they will work. ~ l I 4. Deficiencies in material storage conditions has continually been a con =ern to the NRC and has resulted in items of noncomplis.nca. To the inspectors, t l the ability to maintain quality stcrage is indicative of how rigorous or slipshod the constructor's attitude is towards construction. The licensee ) has attestad to entice the constru= tor to do better in saintaining the material storage conditions, but still the licensee's auditors and the NRC have negative findings in material f.torage conditions and nega.ive dis ssions with the con.ractor about the validity of the finding. 5. At periodic intervals, the support of cables, particularly in the control i roca area, which are awaiting further routing or termination, has met with the disapproval of the NRC insp.ectors. These discre;ancies also include cables without covered ends being on the floor in walk areas that are in a partially installed status. This is also another indicator of slipshod work =anship which has been brought to the acestructor's attention at various times, but was last noted during a recent inspection. 6 In the area of instruentation impulse line installation and marking, the j li=ensee has had separability violations which has required removal of all installed impulse lines. Also, the NRC, because of this and significant adverse operational osaditions, insisted that the installed impulse lines be identified.
- Although the licensee plans ta mark the impulse lines, there was an inordinate amount of resistance to ssrking the lines - even though there had been. instances.of mis-sat =hed channels he:ause of iden-l tification confusion.
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..a .o.. l A. T. Warnick 3 July 23, 1982 i 7. '*i example of reluctance in placing the responsibility for quality work-manship at the foreman and/or worker level has recantly been identified. The NRC inspectors noted that some drop-in anchors were improperly ins.al-led and obviously did not adhere to the installation procedures. The licensee's attitude indicated this was not a valid finding because QC had not inspected the item. The NRC inspectors treat this as indicative that slipshod workr.anship is tolerated in the hopes that QC will find the mistakes. l 8. Z. ate in 1981, the licenses decided to move the CA Site Scperintendent into i another pcsition and cover this site function by sharing the site ti=e be-i -r -- ~- ~ tween the Qi Director and the CA Manager. After a January 1982 eseting with the NRd at RIZI, the licensee optad to fill the QA Seperintendent spot with another person. In the spring of the year, the NRC inspectors were fo11: wing up on welding allegations and approached the QA Superintendent. The GA Superintendent was familiar with the alleged poor welding and had established what the NRC inspectors determined to be a responsive plan to resolve the questionable QC velding inspections. At the Exit Interview, the GA Cirector did not appear to back the GA Site superintendent's proposed plan which had taci NRC approval. The NRC inspector classified in writing and with just cause that the Exit Interview was the sust hostile axit interview he had ever encountered. 9. During a recent inspection, it was noted by the NAC. inspector that fill dirt i was piled and being covered with a mud sat at a nominal lili horizontal to vertical slope when the speelfication called for a 1\\:1 horizontal to verti-j cal slope. A constructor Field Engines wi.nassed the wrong slope being l installed and justified and defended the slope after being infor=ed of the specification requirement. This is another exa.-ple of the constr :scr i having an attitude which precludes quality work =anship. - 10. Edifferent times, NRC inspectors have experienced difficulty in getting infor. ation which is controlled by the contractor, such as sapporting cal-culations and qualifying infomation to justify a given installation. A recent example is: the NRC inspector info:med the licensee and the contrac-tot he wanted to see resunes of persons involved in the remedial soils werk. There is an obligation to the NRC to supply a precise number of " qualified" persons on the soils work. De inspector was informed he could not get these records as they were personal. De inspector ultimately did get the infor=a-tion after bringing it to the attentiers of lit ansee' upper manage =ent. Now-ever, this indicates an implied unwillingness of the constructor to share I information with the NRC and some'.1=es with the licensee. e 1 l I I I wu.we . = - +=w w
a,, 4 R. F. Warnick 4 July 23,1982 i i i 4
- 11. The licensee oftentimes does not demonstrate a " heads up" approach to l
their activities. The following are examples of the licensee operating in an environment using tunnel vision " blinders". a) During a recent NM inspection, the inspector challenged the ability j to maintain the proper six ratio on high pressure grout. This was done after the inspector noted that the operator could never maintain l the proper nix ratio without continual manual control - which was not l t available when the grout is applied. The licensee's apathetic atti-tude did not allow them to stop the grout application until the next day when this be=ame an issue at the exit inters-tow. = t b) At one point in time, the campany doing drilling on site for the renedial soils work cut into a safety related duct hank her.'een the diesel generator building and the service water building. ne consu-mars Power Site Manager's Office (the production people) stopped work j because - from a quality standpoint conditions were so deplorable. p$k Mowever, the Site Manager's office did not have responsibility in this ] ajq area - the Midland ___ Project QA Department had this resoonsibility and did not invosa sneir ausnority to prevent the drilling work from get-l W ing out of. control - or to bring it back into control. e i v" ) c) The N M inspector recently witnessed the licensee set".ing up to drill e a well hole in safety related dirt using a technique which was not t authorized. If the inspector had not brought this to the li=ansee's attention, the licensee would have violated an order addressing reme-i dial soils work and also the construction Permit. Whar. the 11:e..see was queried as to the availability of the QC/;A persor..el who would prevent such activity from happening, the NRC inspector was informed that this was (another) misunderstanding. l De NM inspectors have been informed by our contarts on site that thers 1 ) are memoes written to the effect that " peripheral vision" should be cur-talled and sessunication with the NRC stiffled. The Nac has not read these memoes yet - but plans to in the near future, provided they really j exist and infer what we have been informed.
- 12. T.ie licensee seems to possess the unique ability to search all fas. ions et the NRC until they have found one that is sympathetic to their point of view - irregardless of the impact se plant integrity. Same examples, of this are:
i a) The NRC soils inspector informs the licensee that soils stabilization grovt esses under the Q program. The liesasse is not partisularly happy with this position. Onknown to the inspector, the lisensee arpnes his point with NRR to have the grout non-g - using only those arguments which support his (the licensee's) position. The licensee I i { L r
.J..o. ....,,g..., ,m,.._,, ,.,,,,;._.g,,, g 1 l' i R. F. Warnick 5 July 23, 1982 h has the advantage of the NRC inspector's technical and regulatory basis for supporting his (the inspector's) position, and therefore avoids mention of this during the discussions with NRR. Bowever, l the licensee's QA program, which has already been approved by NRR, 4 states that all the remedial soils work is Q unless AIII approves a relaxation on a case by case basis. It appears the licensee does 'not wish to, acknowledge the prior' agreements with the NRC. j t b) since the failure of auxiliary fee 6 tater headers in R&W steam genera- .-tors, discussions have transpired herseen the NRC inspectors and the ._.__ site personnel.., These discussions have indicated that the lirensee was maintaining a conservative approach and were entertaining the i concer=a expressed by the NRC which were stimulated primarily by gr=ss mistakes in attempting the modification at operating Ba*4 plants, ne ] licensee's corporate personnel were anncyed that the NRC inspectors would not give approval to start the modification until g the pre-1 paratory work had been accomplished as this would tend to i=,act the schedule and the modification to the steam generators could beco=e a i scheduling nuisance. De licensee corporate personnel contacted the j NRC inspectors involved to.* reason with thes". Iowever, the c=rpor-j ate personnel," (including a representative from asW) were unable to j answer the concerns of the NRC inspectors but did mention that the NRA opera.ional Project Manager indicated that it was alright to proceed with the modification. ne licensee corporate personnel.could not I state what the posi. ion of the NRR Ccnstruction Pr= ject Manager was on this issus - only that they had found some form of approval from some-i one in the NRC. l I i c) At times, when Ireediate Action utters or other forms of escalated l enforcement become i= r.inent, the licenses attempts to " appeal" their -t-case with individuals in the regional management who are removed from I the particulars of the tentative enfor= ament action. Se licensee at-tesyts to get these persons to agree to specific portions of the issue which would indicate that the licensee is "really not all that had". However, the 'real" issues, as identified by the NBC inspectors are being masked. 1 l d) During inspections of the remedial soils wonk, the NRC inspector has ~ been informed by the licensee that certain findings and areas of inspee-tion were not within the purview of his (the inspector's) inspection i program because they were it' essence considered non-Q and that by virtue of prior agreement with th's Regional Administrator were excluded from i enforcement action. However,' the NRC inspectors would subsequently find i that there was no such agreement between the Regi'onal Administrator and the licensee - only a philosophical discussion as to what, in general l teams, sonstituted an item of nonsempliance. i I 1 4 4 ~1 -~ -~--.
1 .e / R. T. Warnick 4, July 23, 1982 l' The above indicators support the reputation the licensee has for being argumentative. noir apparent inability to ac=ept an NRC position with- ~ i out diligantly searching to find a " softened" position results 'in numer-l ous hours of frustrated conversations bets een all parties involved to 1 resubstantiate (usually the original position) a pcsition based on tech-nical and regulatory prudency. 13. ne licensee has bien classified publicly by the NM as being argu=anta-tive. De licensee-continues to axhibit this trend, as' avidenced by the following examples: j a) Issentially every item of nonec=pliance receives an argume..tative answer which addresses only the specificity of the item of noncom-P11ance and selec.ively avoids any concept whl=h would support the essence for the item of noncompliance. For exa.ple - in the instance I of the improperly installed drop-in ancher =entioned above, it was the fact that QC had not inspected the installation of the bolt which was important to the licensee. However, the real enforcament issue was that components were being improperly installed. b) ne cycle 22 sA*.7 made critical evaluations of the licen.see's perfor-t mance in several areas. De licensee's response to this SAZ.7 report was arfumentative over specifi details and did not seem to acknowl-edge that the consensus of opir. ion of the NM inspection staff was that there we.*e areas where the licensee's perfor=ance was weak. De lizensee's ary rsentative pcsition is in the fcrm of "we really are no: all that had" when the records, findings and oksarvations of the mc inspectors support just the opposite p sition. c) ne "q-ness" of the remedial soils work has continually been an argu-mentative topic of discussion which ultimately resulted in a I; meeting cc. March 10, 1982. At this meeting, the "Caness" of the remedial soils wh was specified and later doc.anented with the meeting minutes. Now-ever, the li=ensee did not wish to abide by this position and a subse-quent meeting was' held in R222 to further elarify the NRC position. Still, the topic of "C-ness" is being argued by the licensee, even though the As*J has issued an Order further defir.ing the "C-ness" of the soils work. It might be noted that a hearing is in.procese over this soils issue and the N E's position on "Q-noss" has been expressed during these I testimonies. ? I 14. During a re=ent episode, the li=ensee wanted to continue es=avation o' scils in proximity to the reedwater Isolation Valve pit (FIVP). Nowever, the lican-see wanted to perfozs this evolution without determining that the temporary supports of the FIVF were adequate. Making this determination would have en impact en scheduling, as stated by the licensee. Se FIVF supports were installed without a g umbrella and subsequent inspections did reveel several discre;ancies in the installation of the support structure. O i 2 V e r .e massea 6@M ee $13W9.- 99 6 - M s,.y .ee+ e. m.. y. m_ g
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- 15. During the limited remedial soils work which has transpired, the licensee has managed to penetrate Q-electrical duct banks, a condenser header drain line, an abandoned sewer line, a non-Q electrical duct bank and a 72-inch,
circulating water line. All of these occurances have happened because of a lack of control and attention to details. Whenever approached by the NRC as to the adequacy of review prior to attempting to drill, the NRC re:sives responses which strongly suggest that the time was not taken to - perfom these reviews - perhaps taking this time would impact on the s:hedule. 16. By virtue of an earlier A'A3 order, the licensee is required to perfo:n trend analyses for nonconfo ming conditions. These trend analyses have, in the past, masked the data such that ebvious trends are not ebvious and has resulted in negative findings by the NRC. This was addressed in one of the earlier SALF meetings. Recently, while perf rr.ing a review of I hanger welding data, the NRO inspector found that the statistical data had I been diluted to the point that the naber of unsatisfactory ha..gers could not be dete==ined f ca the trend analyses or the type and degree of non-confor=ing conditiens which were being identified pertinent to the hanger fahri:a. ion.
- 17. The licansee cor. tin'ually would use the NMC staff as consultants and clas-sifies a regulatory and enfor:ement position as counter productive. This is refle:.ed by the lizensee not wishing to perform S-wcrk without obtain-ing NRC prior approval and then addressing only these areas where the NRC has voiced a regulatory =ones:n - ; ovided it is convenient to the licensee.,
This at itude has particularly prevailed in the renedial soils issue and to a lesse~r degree in the electrical installation areas. Tae preferred Na: inspe= tor mode would be for the licensee to generate his progra:n to esta-blish quality and then the NR: would approve or disapp-ove. However, the licensee requi:ss consultation with the NRC to establish his level of .1 quality requirements. The above is not intended to be a complete list of r11 discrepancies which indi-ate questionable licensee performance as this would require a acre extensive seisw of the records and inspection personnel involved than time permits. Also, there has been no attasyt to systematically do:.anent the. enfor:ement and u.re-solved items list as.these are contained in other information sources. kowever, j the listing is rather comprehensive of the types of situations and attitudes which prevail at the Midland Site as observed by the NRC inspector staff. Whe. considering the above listing of questionable li=ensee performan=e attributes, the acst damning concept is the fact that the NRC inspection effort at Midland has 1 been purely reactive in nature for approxi=stely the last yest, and that these indicators are what have been observed in a;pecximately the last six mor.ths. If 1 e 8 g 4 1 -.~
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)..;. . A :,.. .. _;.,wwa .J ). o e i R. F. Warnick 8 July 23, 1982 = \\ ~ these are the types of itans that have become an NRC nuisance under a reactive inspection program, one can' only wonder at what would be disclosed under a rigorous routine inspection and audit program. sincerely, 8 j R. J. Cook Santor Besident Znspector Midland Site Resident Office se W. D. Shafer D. C. Boyd i R. N. Gardner I R. 3. Landsman
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..: p....... ~k--'" ~ ~ ~ ~ ~ ' ) i Inclosure 3 " *.,I umiso svares NUCLEAR REGULATORY COMMISSION f 2! I toe mooseve6v nomo - / h<. ~6 ) i e6s= e 66v=. sw=ois seis, % **" * / August 18, 1982 l MEMORANDW. FOR: Region III Tiles TROM Robert T. Warnick,, Acting Director, Office of Special Cases SV3 JECT: ~ MIETING BETWEEN NRR AND RECION III RI CONST.;%ERS 70k'IR COMPANY PEPJORY.UfCE AT MIDLAND (DN 50-329; 50-330) I t on July 26, 1982 R. F. Varnick and Ja=es C. Kappler met s-ich E. C. Case. l D. G. Eisenhut, R. H. Voll=ar, R. C. Tedesco, T. H. Novak, V. D. Pa::n, and ~ j J. Ruthers to discuss the perfor ance of Consu=ars Pouer Ccepany at the } Midland site. l During the meeting reference was made to infor=ation contained in two memos from the RIII staff. The first memo dated June 21, 1982 is from C. E. Norelius and R. L. Spessard and concerns suggested changes for the Midland Project. The second memo dated July 23, 1982 is.from R. J. Cook and concerns the licensee's perfor=ance at Midland. Copies of the somos i are attached. The meeting resulted in the fEllowing recon =endations i / (1) Region III should obtain the results of the recent audit by EMC. i i (2) Schedule a public meeting between NRC and CPC ma=agement in Midland, Michigan, to obtain licensee com=itzent to acco=plish (3) and (4) below. (3) The licensee should obtain an independent design review. (A vertical slice from design thru complettom of construction.) i (4) The licenses should obtain an. independent third party to continuously monitor the site QA implementation and provide perio' dic reports to the NRC. Region III is to provide a suggested outline for the contin-i nous monitoring function. r- ' 8dM Robert T. Warnick, Acting Director Office of Special Cases { Attach =ents: As stated ce v/ attachments: Meeting participants I p05 II/LifU l /d a f ~ 'hf-De6'S*.#1D ,O+- .m.. y--
's 7 v.-... ...,:2,,.:. d......... x :,c ; _u ~ e ) M64'Y D l August 18, 1982 G.- o MIMRANDUM FOR: James G. Espplar, Engianal Administrator , FECK2, Robert 'F. Warnick, Acting Director, Office of special Cases SUMECT: CONSUMERS POWEE-MIDI.&ND 02! 30-329; 30-330) I lihan you created the Offica of Special Cases and a special Midland Section staffed ith individuale assigned selsly to that project, you indleased your concern with the Midland Project. You did this in spita of the faver-able findiase of the special team taspeccias conducted in May,1981, and the i feverabia tassimony you gave before the Atonia Safety and Licensing Board 4 i em July 13, 1981. You indicated your eeneers was based as the Systaastic 1 Assessment of Licensee Performance (SAI.P) report for the period July 1, 1980 to Jaa 30, 1981, the taspection findings since those dates, and the neme j of Jane 21, 1982, by C. E. Nerelius and R. L. Spessard outgesting certais l chasses be made at the Midland Project (copy attached as Esclosurin 1). f At my request 1. J. Cook prepared a sumary of indicatore of questionable 11aease performance at Midled. A espy of Cook's asao dated July 23, 1982 is attached as Insleeurs 2. Because of your azpressed concerns, yes and I ant with representatives from i i i NER en J ly 26, 1982 to disensa Midland and Consumers Power Company (CPCo) performanca. That meeting aise resulted is recomended astians. A summary j of the meeting is attaehad as Ensleeste 3. 1 Follesing the meeting with NRR, I diseassed the ressamendaties of that meet-tag with our Senter Easident Inspeesse, other ammbers of the asw Midland Section, and former Section and Braseh Chiefs who are intimately f=111-with wui-d. I Later that week (July 30) I spent a day at the Midland.ette. I attanded the emit meeting fellestag landsman's and Gerdaer's inspectias, met with CFCs j and Bechtel manasseest to get segoniated with them, and toured the plant ette. On July 31, 1982 I espressed my appeeftles to the reesessendations we bad 4ame a up with in the NIX asettas. My appeetties was based sa (1) epialme espressed l by the Senter Resident Inspector, a Engion III Braneh Qitef formerly reopensi-ble for the NBC taspectism of Midled, and a Constructies Seeties Chief vbe has been intiastely assestated with taspections of Midland regarding the proposed j metiens: (2) my visit to the ette; ed (3) the tambility of Eagisa III to l articulate the problem (s) at Midland which the above referenced recaennesdatises I were enppened to selve. 1 indicated that we needed to better identify our ' pha e,emac4hm ane d as.e shap sem..?A camatve thaam enn,. acus. e a= = = a .h..1111.......... %.........Ild74........ I ..I .w .a........w. l a.rs h Ny l......... r.... ( =aceaawaieosam bacu es.e CFFICIAL Rs'.;ORD COPY M0S 1//d//T;r n ...__s, , - ~. ~. -......., ~. - _,.
?. w.7. 7.. ., e;....... James C. Esppler August 18, 1982 I On August 3, 1982, ammbers of the Midled Section*aet with you to discuss my appeettion to the resosaseada:: loss sosias from the meeting with NFJt. The pres and sans of the recommendations together with ot.her alternati as were ~ discussed. The meettag somsluded with you agreeing to giw. the Section u til Anguet 11 to determina a better propeeed sourse of acties to resolve NEC soncerns about Midland. To this and the Midised Section est together sa August 4 and again on August 5 following our publia meeting with CFCo on the SALF II report. Seversi alter-natives were discussed i' cinding stopping all work on ena unit, have an inde-i a ~ ' pendent third party monitor all past and current construction work, stopping worlt in selected areas, performing a construction appraisal team inspection, placing all site QC work under CFCo. and establishing a augamated NEC taspee-tion effort. ? Although some aanbers of the Midled Sectica thouphs that stronger actions should be takaa, all aanbers of the Sectica agreed they could support an augmented NRC I inspection effort coupled with other estions te strengthen the licensee's QC/QA j erg eisation ad annagement. These recommended actions are attached as Enclosure 4. It is recosmsended the proposed actions to improve the licensee's perforammes be discussed with NER and then the licensee. l Bebert F. Warnich Acting Director Cffice.of Special Cases ~ Atspehments t As' stated b l l 0 4 i U t sw=..< > ser>l.........................*.............................. i ............................................p......................... =acanew sia.ie.em macwes.e OFFICIAL RECORD CCPY .f . -,. ~
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NUCt. TAR REQUI.ATOAY COMMISSION 'l J/ eEoloN til "f l 2 too moossvtLT poAs e<s. s m...+ o,s.q,. g*****j FEB 2 4 S83 Docket No. 50-329 f i Dockat No. 50-330 Consumers Power Company ~ j ATIN: Mr. James W. Cook _ Vice Fre'sident Midland Project. j 1945 West Parnall Road Jackson. HI 49201 Gentlemen We have reviewed your proposal to have the Stone and Webster Corporation (S&W) perform the third party independent assessment of the soils remedial work activities. The staff has received sworn statements from the S&W Corporation and from the key S&W personnel (Attachments A and 5 respectively) attesting to corporate and individual independence. The staff has also reviewed a letter. J. E. Brunner to W. D. Faton, dated November 15,1982 (Attachment C) which describes the contracts j undertaken by S&W for the Consumers Power Company and indicates that S&W or its subsidiaries have no holdings of Consumers Power Company e The attachments to this letter have been subsequently notarized. l stocks. The staff has considered the qualifications of both the S&W organization and the individuals proposed as team members to conduct the independent review of Consumers Power Company's management of the Midland soil project. Inputs to this review included the information supplied in the above submittals, the staff's existing knowledge of S&W performance at other nuclear power plants and information as to S&W personnel competence. Our ovaluation of these documents revealed that th's competence and f,- independence criteria have been met as set forth isi Chairman Falladino's letter to Congressmen ottinger and Dingell of February 1.1982. Based on our reviews we have determined that the S&W Corporation is e an acceptable organisation to perform the third party assessment of the soils remedial work however, the scope of the S&W sesessment should be broadened to include the following: h Wh , _A /r f, {7 %,3n F s
I _ = _ - - - I O, 3 ri. m. J . consumers Fever company t f (1) Fravide a QA overview and assessment of the design work packages. 6 l to ensure accuracy and adequacy. L (2) Frovida a QA overview and assessment of the QC inspector requalifi-estion and certification prestas. (3) Frevida a QA overview and assessment of the trainiss condu all personnel in the soils remedial work effort. l / (4) Erpand the work contreet to include an assessment of all underpinning work on safety-related structures on which underpinning work is l done while your contract with Scone and Webster is in affect. In addt. tion, the Midisad Sectica has reviewed Consumers Power Company's l performance regarding the installation of Piere U12 and E12 and has ) concluded that no major discrepancias were identified during this work t (Mamorardum,1. Landsman to R. F. Warnick, dated 2/15/83. Attachment D). 14, 1983 (Attachment E) Stone and Webster in their letter dated February also indicated that no major performance problema have been identified. They have stated that in thstr opinion additional underpinning work could be released for construction. Based on the inclusion of the previously described contract changes, your performance record regarding Piers V12 and E12. and the acesytability of I the Stone and Webster Corporation as the third party independent reviewer, l we conclude that underpinning activities of safety-related structures any Please submit documentation of the expansion of the third party The work activities I proceed. assessment to include the four areas identified above. will be authorised in accordance with the approved HRC/CPCo Work Authorisati Procedure. Should you have any questions regarding this letter plasse contact Mr. 3. F. Warnick of my staff. sincerely, l i Original signed by A. Sort hvis James G. Esppler Eastonal Administrator Enclosures As stated as w/encif See attached distribution list ~ t
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a. ..) '.r., .FFR 2 4 rao3 3-Consumers Power Company I ec w/ enc 1: DMB/ Document Control Desk (RIDS) Resident Inspector. RIII The Honorable Charles Bechhoefer. ASLB The Honorable Jerry Harbour. ASLB The Honorable Frederick F. Cowan. ASIB 1 The Honorable Ralph S. Decker. ASLB l William Faton. ELD i Michael Miller Ronald Callen. Michigan
- - Public Service Commission l
Myron M. Cherry Barbara Scamiris a __ _ Mary Sinclair ~ Wendell Marshall Colonel Steve J. Gadler (F. E.) i. e i l t l l t I l 9
. eg ~M ATTACHMENT D f / ib. Tebruary 15. 1983 J I I I I
- 1. Y. Warnick Director. Office of special Cases MEMDEANDUM 701:
W. D. shafer Chiaf. Midland section .2EEDs
- 1. 3. Landsman, teactor Inspector. Midland section FEDH:
LICENSEE FIRFORMARCE ON PIZ1512E and 12W gUBJECT: XIII on December 9.1982, authorised CPCo to initiate work activities pertaining to the drift. excavation and installation of Fiars 12E and i Subsequent *o that authorization the licenses began work on ~ 12W. Due to the Diesel Generator Building Inspection I December 13, 1982. i have had only enough time to perform five inspections to detarmine the acceptability of the licensea's work in regards to these piers including renoval of fill concrete, shaf t excavation and bracing. bell escavation and bracing, ar.d reinforcing details and proposed concreting activities. I have identified three concerna since underpinning work began which have been subsequently corrected or are in the process of being ( corrected by the licenses. They are: I That the craftverkmen were act receiving the required amount of a) The licensee specialised remedial soils maderpinning training. ? has agraad to expand the scope of craf t training, but does set have the details workad out to date. i That the licensee wanted to use a super plasticiser as an additive b) to the concrete six in lieu of good concreting practicas i.e.. The licenses af ter what I consider to be consolidation by vibration. escessive discussions' finally agreed to vibrate all underpinning soscrete in accordance with good engineering practica. That the third party independent aseessment team is not reviewing i c) the design documents for technical adegnacy., They are only doing implementation review to assure that the design documents are being l From discussions with Stone and Webster personnel. it,. j followed. was determined that this important parameter was not included The licensee is presently considering incinding in their contract. this in the contrset documents. Resides these three concaras so other issues or deviations from regulatory requirements have been identified. l ~ l 1 a f f l % DC3 2 l-fW14-u-
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STONE & WEBSTER MICHIGAN, INC. ...a egm P.O. Box 2325. RosroN. MassacMuscrrs 02107 .h l [ m i ML I l i, OL l P i LU ' 3-) February,14, 1983 Mr. J. C. Keppler J.0. No. 14358 Administrator, Region III MPS-8 t U.S. Nuclear Regulatory Commission 799 Roosevelt Road i,' ~ -~ Clan Illyn, IL 60137 i RET DOCKET No. 50-329/330 MIDIAND FLANI - UNITS 1 AND 2 INDEPENDENT ASSESSMENT OF AUXILIARY BUII.DINC UNDERPINNING ASSESSMENT OF UORK ON PIERS U12 AND E12 As of February 11, 1983 the Stone & Webster - Parsons Brincherhoff Assessment Team has observed the excavation, placing of reinforcement. and concreting of underpirsing pier W12, and the excavation, and In addition, the placing of reinforcement for underpinning pie'r Z12. Assessment Team has reviewed the drawings, procedures and.other documents pertaining to the underpinning work and has observed the performance of the Quality Assurance and Quality Control Organisations during the pro-grass of the work. During the period that the Assessment Team has been on site, daily meetings have been held with Construction, Quality and Engineering personnel to obtain additional information and discuss observations. The Assessment Team has issued twenty Weekly Reports to the U.S. These reports have described the Nuclear Regulatory Commission. activities of the Assessment Team and summarized their observations I findings. The Assessment Team has issued a total of five Nonconformance Four of these Nonconformance Identification Reports have been Reports. The ressining open closed out to the satisfaction of the Assessment Team. 10, 1983 and Nonconfdraance Identification Report was issued on February the Assessment Team feels that it can be closed out in the near futu without impacting the progress of the underpinning. The underpinning work is being performed in accordance with the construction As the work has progressed.the procedures have and quality procedures. based upon experience gained during the construction of been modified feels that shese sinor changes The Assessment Tess piers V12 and 112.are appropriate and will have a positive effect on the qu pinning work. i FEB 5 53 9 1 ' c7>sn -s-i, a vu et s v m^;.g. e --- - - -.---- ~, _ _...m --m-o e w -,----,v-s-m o --ou- -m -m-. w
. ~ 1 a 1 February 14, 1983 2 g f the Based upon these observations and findings, the Assessment Team is o This will benefit the quality of the work by allowing the co to main-teams from piers W12 and E12. tain the experienced labor If you have any questions, please contact me at (617) 589-2067. I A.S. Lucks Project Manager i t ( i 4 9 k 1 I e b I l t L. i N "N ** * ** *uesp e p.,w ep.. 6 ~ g
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=== -==.-. sue s==u sim oescree l a c mau. = = peue mmsm taur. an am m A asub Roy Joists Y:: T '."..",..^ :. ~. COMMITTEE ON INTERIOR. 7"n". 'A'.:7 2,
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u.s.mouss on nPRESENTAMES EL"O 07.* '.*u a'Em E 1"i,ran WASMNGTON, D.C. 2515 N N.O a"== U..n N m' g g r,=,==. *in =,,f,*g;llp. June :2, 1983 O'O'u' T "' '""".- C "'- "3" ".".". :ll" '"' Cta*. t." % - 4.~"A" ' ** I The Honorable Nunzio Palladino. Chairman. United States Nuclear Regula' tory Commission Washington,,D. C. 20555-
Dear Mr. chairman:
I am writing to request the presence of Messers. James Keppler, R. M. Gardner, Ross Landsman and Ronald J. Cook at the subcom-mittee.on Energy and the Environment's hearing on the Midland, Michigan nuclear power, plant on' June 16 at 9:45 a.m Others who have been invited to testify'at the hearing are: ~ Governor James Blanchard, Midland ' Mayor Joseph Mann, repre-sentatives of Consumers Power Company.and representatives of Midland intervenor. groups.. we expect a most informative hearing and look forward to se.eing yon on the 16ths + 8 nce e ,i ll ^ r t MORRIS 110. UD)l.L Chairman ' / s l, ? ( ( l' ( 3 aa v i g 3G3 1C3.CA\\Q.....
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COMMITTEE ON INTERIOR ^ " * * " " ' " " ' * * " " ... ~ w,,,,,,, = rt.;L':'1
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!EL*Cch 1";; L*",,%,, WASHINGTON, D.C. 20515 DirCks d, "'* d., May 6, 1983 / Roe OM '** M!lNCIPAL STAFF Rehm
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v DN Stello V A 8;s DeYoung , "",,,ga A'" m MB6 Jgd 0 Dentor. =agh "I @ M er >=,"'_=;.'"*,,, (, lh' q ~ GCunnirgham =,"*"*',",*lll.2 EDO R/F The Hon. Nunzio Palladino (' Chairman x , flLEy 1 United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Chairman:
On June 16, the liouse Interior Committee's Subcommittee on Energy and the Environment will conduct a hearing to address the NRC's procedures for handling' ccustruction iguality issues at Midland nuclear power plant. The hearing will focus on the regulatory 4 actions relating to the remedial soils problem and the breakdown of the quality assurance program. i 1 would welcome testimony f rom you or your representative on June 16 for the purpose of presenting the views of the NRC in regard i to these matters. i The hearing vill convene at 9:45 a.m. in the Committee's hearing room which is located in Room 1324 of the langworth House
- Office Building.
Should you wish to present a prepared statement, please provide 1 75' copies of the statement to the Cierk of the Subcommittee at least 24 hours in advance of the hearing. I am also requesting that 1 witnesses be prepared to summarize their statements in 10 minutes or '{ less. Additional information may be submitted for the record. In the event that you believe that you will need additional time to I summarize your statement, please inform either Henry Myers or Mark Brand of the Cormittee staff. They can be reached at (202) 225-8331. I appreciate your cooperation and look forward to a most I productive and informative hearing. I 1 Kingerely, J' 5/10..To DCA for Appropriate yye p Action..Cpys to: EDO RF.. ~ 83-1812 MoRP.ls K. UnAtt Chairman i y s-MAY 161983 ~ m o ~ - c;. u. I ,9 m y e,,, r,- - +,,,, e .w--,,e-- w
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{.3C.lt E Ye,7 UNITED STATES !(Tg.< % NUCLEAR REGULATORY COMMISSION ~ I m
- d WASHINGTON, D. C. 20555
]_ {ggpg i %; *C 'f June 1, 1983 dTBA i a/aAlg -g-( g QA Docket Nos. 50-329/330 Wi 80 f Wi I I . 3 t l # pitel W M
- I APPLICANT:
Consumers Power 9mpany b i FACILITY: Midland Plant. Units 1 & 2 I
SUBJECT:
SUMMARY
OF APRIL 19-21, 1983 CASELOA" c0 RECAST PANEL MEETING l On April 19 and 21, 1983, members of the NRC Caseloau.o pcast Panel met with Consumers Power Company (CPCo) and Bechtel to review construction f completion schedules which CPCo completed February 18, 1983 and announced April 12, 1983 for Midland Plant, Units 1 & 2. On April 20, 1983 the Panel toured the plant to observe construction progress. The purpose of the meeting and tour is to provide for an assessment by the Panel of construction completion. Meeting attendees are listed in Enclosure 1. is the meeting and tour agenda. Enclosure 3 shows some of the slides used during CPCO's presentations. 1 CPCO's previous and revised estimates are: 7/80 Estimate 4/83 Estimate Difference (Mos.) l Unit 2 7/83 10/84 14 t Unit 1 12/83 2/85 13 t- ] Overall plant completion is estimated by CPCo to be about 83f, complete; engineering is about 76% complete; design 94%; and underpinniag 4%. i l CPCo finds there are three separate critical paths for constnetion completion: (1)asocalled" aboveground" pathway,(2)auxilh.c/ building underpinning, and (3) the licensing / hearing pathway. Aboveground Pathway This pathway is primarily based upon rework of large and small bore pipe supports. However, installation of three HVAC systems, penetration sealing, and installation of mirror type pipe insulation also presently have zero or. negative schedule float. s O 4 Oo'n +-n c ., p s y 4'. q a,3,y a.g-}- r) tw 3
i. m l 2-6 ~ A letter of March 29, 1983, notes CPCO's intent to reinspect all installed safety related pipe supports without regard to the time of their installation or turnover. CPCo estimated the new support reinspection procedure, training and certification of inspection personnel, QA program revisions, and other support activities would be in place in time to comence reinspections during the week of April 11, 1983. CPCo plans to use three inspection teams (about 50 inspectors) and expects to complete hanger reinspections in June 1983. Only, two inspectors had been certified as of April 15, 1983 l and had started hanger inspections. The hanger reinspection pathway is the critical path for the " Construction Completion Plan" (CCP) described in CPCo's letters of January 10 and April 6,1983 (and subsequently on April 22, 1983). + CPCo noted that 544 of 850 total subsystems (64%) have been turned over and accepted. Some systems were accepted with multiple " exceptions" (punchlist open items such as design changes, and corrective actions). CPCo's schedule for preoperational testing, acceptance testing, flushing and specific tests for both units provides a total duration of 14 months. Forty-five percent of the systems have been initially checked out. About 4% of the total of 683 tests have been completed as of March 31, 1983. Of these 683 tests, CPCo plans to complete 95% of the 268 preoperational tests and 128 acceptance tests prior to the Unit 2 fuel load. Currently, no preoperational tests have been completed (two are in progress); one acceptance test has been completed and none are in progress. The testing program for about 134 systems were noted to be constrained by the CCP. The present schedule assumes little rework of hanger (about 850 out of 7000) will be needed for both units. At least seven 50.55(e) reports are considered by CPCo to have some potential for schedule impact in that reviews and tests are not complete and cannot be l fully assessed at this time. These seven are: t 50.55(e) Report No. Management Corrective. Subject Action Report (MCAR) No. 1. 80-04 40 High-energy line break analysis (HELBA) pipe 1 whip restraints 2. 80-09 458 Low alloy quenched and - tempered bolting - 3. 82-12 .63 Design of steel embedments that use tension bars and . shear lugs 4. 81-01 46 Deficiencies of Lt.mitorque - valve operators. 5. 82-01 55 Deficiencies in electrical components associated with main steam isolation-valve actuators, and non-safety related equipment wired as ' Class lE -s. a +,yr'- T y-9A-w a M-P .=m-- cem,,-w' - - ae.m- -=5 m
7 6. 82-07 59 Safety related equipment 4 cooled by non-safety related HVAC system 7. 83-02 67 Clearances between electrical control cabinets and panels Auxiliary Buf1 ding Underpinning Pathway Six of the 57 underpinning piers have been installed since December 13, 1983, and a pier load test (pier W-ll) was in progress. The construction sequence will utilize an existing Utility Access Tunnel (UAT) to gain early access beneath the southern corners of the Control Tower. The revised construction scheme utilizing the UAT is reflected in CPCO's current completion forecasts. CPCO's schedule assumes NRC will approve loading of fuel innediately after transfer of the EPA load to the permanent wall (i.e. in advance of EPA and FIVP soil consolidation beneath the wall; pier lockoff and grouting; replacing of backfill beneath EPA and FIVP; and structural stiffening at critical elevation 659 feet). CPCo estimates that these latter activities will be completed by late January 1985. Licensing / Hearing Pathway CPCo considers that con.pletion of the present soils "0M" hearing and "0L" hearing is also critical to the new Unit 2 fuel load estimate. CPCo's estimated need dates for the hearing are: Complete "0M" hearing session August 1,1983 Initial Decision on "0M" matters Mid October 1983 Completion of "0L" hearing session Mid May 1984 Initial Decision on "0L" matters Early July 1984 ~ ^ Staff Conclusions The Caseload Pr.nel noted that the information provided during the meeting and observations made during the site tour would be further reviewed before the Panel's completion estimates are reached. Ma ~ /b7 Darl Hood, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated i cc: See next page I w 'w' V
[ e n t i MIDLAND j i Mr. J. W. Cook l Vice President Consumers Power Company i 1945 West Parnall Road Jackson, Michigan 49201 cc: Michael I. Miller, Esq. Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq. Division of Radiological Health Alan S. Farnell, Esq. Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza, Lansing, Michigan 48909 Sist floor Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq. St. Paul, Minnesota 55108 { Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Micland, Michigan 48640 5711 Summers 0t Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Company 720 Law Building.- 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Micnigan 49201 l Mr. Wendell Marshall Mr. Walt Apley i Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL) Battelle Blvd. Mr. Roger W. HUston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsus Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator i U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III - Suite 3700 799 Roosevelt Road - Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 I e d- -es=-++ - < s-sg., man = ir M 7 ee-g w,1
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q ~ = f, . Mr. J. W. Cook i l cc: Mr. Ron Callen Michigan Public Service Commission 6545 Mercantile Way P.O. Box 30221 Lansing, Michigan 48909 Mr. Paul Rau Midland Daily News. 124 Mcdonald Street Midland, Michigan 48640 Billie Pirner Garde l Director, Citizens Clinic for Accountable Government Government Accountability Project! Institute for Policy Studies 1901 Que Street, N.W. } Washington, D. C. 20009 Mr. Howard Levin, Project Manager TERA Corporation 7101 Wisconsin Avenue Bethesda, Maryland 20814 Ms. Lynne Bernabei Government Accountability Project 1901 Q Street, N.W. Washington, D. C. 20009 i si i t me e u
9 , Supplemental page to the Midland OM, OL Service List Mr. J. W. Cook, t cc: Commander, Naval Surface Weapons Center ATTN: P. C. Huang knite Oak Silver Spring, Maryland 20910 i Mr. L. J. Auge, M4 nager Facility Design Engineering Energy Technology Engineering Center i P.O. Box 1449 l Canoga Park, California 91304 4 i Mr. Neil Gehring l U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq. Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Frederick P. Gowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 J Jerry Harbour, Esq. - l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Geotechnical Engineers, Inc. ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 I P = \\ l l. l r ~ ~ e m-4 y =,, y v
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9
u 9 i ENCLOSURE 1 CASELOAD FORECAST PANEL VISIT April 19, 1983 NAME ORGANIZATION D. Hood LB4/DL/NRR R. G2rdner Region III, NRC, IE B. Harshe CPCo - Safety & Licensing ( J. Mooney Exec. Mgr. - CPCo j R. McCue CPCo - Technical Supt. D. Miller, Jr. CPCo - SHE Manager J. DeMeest Public N. Saari CPCo - Pub. Affairs j L. Shane Midland Daily News J. Leech CPCo - Safety & Licensing W. Bird CPCo - Mgr. Quality Assurance J. Schaub Asst. Proj. Mgr. - Midland CPCo J. Post CPCo - Purchasing Dept. D. Fredlund BPC - Project Planning D. Perry CPCo - Design Production G. Xeeley CPCo Project Manager-J. Cook CPCo,'V.P. Proj. Eng. & Const. I D. Ronk CPCo, Section Head, Midland Project Mgr. F. Buckman _CPCo - Exec. Mgr. W. Lovelace NRC/Ron j D. Sedgwick Saginaw News i G. Slade CPCo - SMO A. Mollenkopf Mgr. - Sch. & Cost - CPCo R. Wells. Exec. Mgr. - QA t~ i a 6
i i ENCLOSURE 1 (continued) ATTENDEES April 21, 1983 NAME ORGANIZATION D. Hood LB4/DL/NRR J. Harrison USNRC/RIII/OSC R. Gardner RIII/OSC/IE B. McCue CPCo - Technical Dept. A. Mercado CPCo - Technical Dept. D. Miller, JR CPCo - SMD
- 0. Fredlund BPC - Project Ping.
A. Mollenkopf CPCo - Sch. & Cost R. Wells CPCo - MPQADF F. Buckman CPCo - Project Office N. Saari CPCo - Public Affairs L. Shane Midland Daily News M. Clayton DOW s . I E i-+m-
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J ~\\ i ENCLOSURE 1 (continued) 4 CASELOAD FORECAST VISIT April 20, 1983 SITE SESSION i i NAME ORGANIZATION l D. Hood LB4/DL/NRR i R. Rice CPCo - Tech. Dept. - Primary Mech. R. Orosz CPCo -Tech. R. McCue CPCo - Tech. Dept. Supt. D. Miller, JR. CPCo .A. Mercado CPCo Tech. Dept. - Scheduling A. Hollenkopf CPCo - Schedule & Cost W. Lovelace NRC/RM J. Harrison USNRC/RIII R. Gardener USNRC/RIII i I J - s. 1 N w h v-- "? W
i 3 L ENCLOSURE 2 l pg. 1'of 2 }. MIDLAND PLANT UNITS 1 & 2 NRC CASE LOAD FORECAST PANEL APRIL 19 & 21,1983 SUMHARY AGENDA Topic Presenter 1. Opening Remarks Darl Hood 2. Introduction and Project Organization Jim Cook 3. Results of Replanning Effort Jim Cook I 4. Schedule Replanning Effort Alan Mollenkopf 5. Schedule Critical Paths (other than soils Alan Hollenkopf and licensing) l 6. Design & Engineering Fred Buckman 7. Procurement Jim Post 8. Construction Progress Overview Don Miller Lunch Break i j 9. Construction Completion Program (CCP) A. Status & Plan Don Miller { B. Verification Program Roy Wells C. IDV & Third Party Overview Programs Gil Keeley
- 10. Test Program Status and Plan Don Miller
~ 11. Soils Remedial Work Status & Plan Jim Mooney & John Schaub
- 12. Post TMI (NUREG 0737) Changes Bruce Harshe
- 13. Plant Licensing Plan Nate Leech
- 14. 10 CFR 50.55(e) Dnpacts Walt Bird Dinner Break - ( Approximate )
')
- 15. _ Plant Operational Readiness Gerry Slade
~ NOTE: If. necessary some presentations may be def erred until i Thur sday 4/21/83, 8:30 am. E m + % w-w 4 g
3 pg. 2 of 2 I + I ENCLOSURE 2 (continued l 4 TOUR - CASE IAAD FORECAST PANEL - APRIL 20, 1983 AREA ENGINEER (S) DURATION p.ereo i T/Bs, D/G's, SW JS'Kreple 1 - 2 Hrs & CW, Evaporator Auxiliary, Building TASpelman/ 1 - 2 hrs j GWRowe l 1 i BREAK 4 Confined Space Entry Training % hr Electrical and I&C RD0rosz 1 hr containments JTWalton ih - 2 Hrs i i Remedial Soils RHWieland 1 Hr i 4 i t m e E d h -e m he w / ew $ P h.e & Sa' r -a$-- 4 w. e
m i m I i i 1 ENCLOSURE 3 SELECTED VIEWGRAPH SLIDES AND HANDOUTS April 19 & 21, 1983 1 - l I } s 9 O I -++4.are., ~
f ;* g gjnj u-8 i MIDLAND PROJECT REPLANNING l g SCHEDULE CONCLUSIONS (1) (2) (3) MILESTONE PREVIOUS CURRENT AMONTHS e Unit 2 Fuel Load' July 83 Oct 84 14 G Unit 2 Operation Dec 83 Feb 85 14 i: j 9 Unit 1 Fuel Load Dec 83 Feb 85 13 4 O Unit 1 Operation f July 84 Aug 85 12 J t (1) Established July 1980 i (2) Recommended April 1983 (3) Rounded To Nearest Month i-l h
t(I">'i~lll i i v////>1 h l l NRC CASELOAD FORECAST PANEL l SIMPLIFIED MODEL -0VERALL PROJECT SCHEDULE Licensing .......m. i (250 Activities) i - Fuel ) Aboveground Plant -Load Commercial l Engineering Operation Construction Check-Out v power i CCP & Test Ascension ~ implementation T/O's i Underpinnincj Complete Soils (2900 Activities) (
... = -. - - 6 NRC Caseload Forecast Panel j RESULTS OF WORKING LINE SCHEDULE DEVELOPMENT (AB0VEGROUND PLANT)
- COMPLETED INITIAL SCHEDULE - FEBRUARY 18, 1983
./ l e WORKING LINE CRITICAL PATHS aje", (0 OR NEGATIVE FLOAT TO AUGUST 1,1984 UNIT 2 F.L.) }<^T - LB PIPE SUPPORTS (BASE) 1 l - SB PIPE SUPPORTS (BASE) - HVAC DUCT 8 HANGERS INSTALLATION - SB PIPING - MECHANICAL / INSTRUMENTATION - CONSTRUCTION j PUNCHLIST ITEMS .) - PENETRATION SEALS e 8
- 8 .e ! (d'j,;)?I'p', -,,D. NRC Caseload Forecast Panel O~ 'I, ,o-ESTABLISilING Tile BASELINE PROJECT SCHEDULE '(AB0VEGROUND PLANT)
- REEVALUATE WORKING LINE ASSUMPTIONS
- 0 WORK RESTART DELAYED .1 MONTH i
- ALLOWANCE FOR UNCERTAINTIES 1 MONTH
- RESULTS OF VERIFICATION EFFORT - UNFORESEEN TESTING / ENGINEERING PROBLEMS
- CHANGE TO WORKING LINE SCHEDULE 2 MONTHS g
t
a 9 NRC Caseload Forecast Panel i PROJECT REPLANNING SCllEDULE
SUMMARY
MAJOR TESTING SClinDULE MILESTONE _S REQUIREMENTS UNIT 2 UNIT 1 C HYDRO REFUELING CANAL 12/10/83 2/2/84 l_ D RCS COLD HYDR 0 1/10/84 3/14/84 J HOT FUNCTIONAL TEST 5/5/84 7/19/84 l M FUEL LOAD 10/1/84 2/9/85 1 R COMMERCIAL OPERATION 2/28/85 8/9/85 ) i 4 9
i . - -.. - - ~. - - 10 4 j 1 NRC Caseload Forecast Panel 3ASELINE SCHEDULE CRITICAL PATHS (MAJOR WORK)- FLOAT PATH DESCRIPTION (MONTHS) 1. SOILS - AUX BLDG UNDERPINNING 0
- - =.
'5.', ac ~; 2. INSTALLATION OF LB 8 SB PIPE SUPPORTS (BASE) 0 (22 SYSTEMS - 59 LB & 163 SB SUPPORTS) 3. INSTALLATION OF LB 8 SB PIPE SUPPORTS (SEISMIC) 0 (6 ' SYSTEMS - 6 LB 8129 SB SUPPORTS) f '[ e>> *,',;"'[ ,,,4,,, 4. INSTALLATION OF HVAC SYSTEMS 0 (3 SYSTEMS) ' e {.I., "' ' 4,_., 5.- PENET 4 il0N SEALING (FUEL LOAD) "'",, w 2 f, r,.,...., r,..,..x....,. 0 7,,. l 6. PIPE INSULATION (SECONDARY PATH)iC.<.A.< 0 g 7. RELOCATION OF CLASS 1E PANELS (MCAR 67) (RCS HYDRO) +2 ,i 8. 0-LISTED DEVICES IN NON-0 ENVIRONMENT , <.v A. / e,.,i,,,,.,,,,j +3 (MCAR - 59) (1/2 GJA-1-FUEL LOAD) 9. MOTOR OPERATED VALVES (MCAR - 46) (FUEL LOAD) +4 10. HELBA PIPE WHIP RESTRAINTS (UNIT 2) r c. c rg ).'J/.... +6
_..2.._. t / 13 'i NRC Caseload Forecast Panel BASELINESCHEDULECONFIDENCI e CONSERVATIVE ESTIMATE OF NEW 8 3 MODIFIED SEISMIC LB 8 SB PIPE SUPPORTS e CONSERVATIVE PIPE SUPPORT COMPLETION DEMAND - SEISMIC 45 DAYS PRIOR TO HFT - BASE PRIOR TO SYSTEM T/0 j i-e HANGER TEAMS - EFFICIENT WORK PROSECUTION e ACHIEVABLE INSTALLATION RATES 1 h \\ I' j i h
- t t
s t MIDLAND PROJECT REPLANNING LARGE PIPE HANGER INSTALLATION (BECHTEL) Hangers Total To-Go g200 Base 15,485 888 a Seismic 965 965 f 4 Average 1980/82 - 175/Mo Total Pit E Peak Demand 16,450 1,854 0 150 b 150/Mo For 5 Mo h ~ c Avera'ge 1980/82 4 100 117/Mo congested Areas g 29 , Q 50 d l- <C i 5-M AlMlJlJ lAlSlOlNlD JlFlMlAlMlJ lJ l g 1983 1984 i l
l s ,a lv, / ?..f e 50.55(E) REPORT STATUS 14 CLOSED BY NRC 18 AWAIT NRC REVIEW 1 39 ARE WORKING 71 TOTAL REPORTED SEVEN ITEMS BEING PRESENTED, ARE ONES WHICH HAVE SOME POTENTIAL FOR SCHEDULE IMPACT IN THAT ALL REVIEWS, TESTS FOR ENGINEERING ARE NOT COMPLETE, WHICH IN TURN RESULTS IN SOME SCHEDULE RISK. i - 4/18/83 l WO944 M fw & e p W4 8-#h e=M Mh 8--.w,e, I .m ,g,
i .s ) HIGH-ENERGY LINE BREAK ANALYSIS (HELBA) PIPE WHIP RESTRAINTS MCAR 40 (80-04) DESCRIPTION OF PROBLEM l CONTRARY TO INTENT OF BN-TOP-2, THE STEADY-STATE THRUST FORCES WERE USED IN THE ENERGY BALANCE TECHNIQUES FOR THE DESIGN OF HELBA PIPE WHIP RESTRAINTS RATHER THAN THE TRANSIENT PEAK THRUST FORCES. } l STATUS ~ 83 RESTRAINTS REQUIRE MODIFICATION. CALCULATION FINALIZATION IN PROGRESS - INTEGRATED INTO NORMAL HELBA PRODUCTION WORK. DESIGN DRAWINGS ARE BEING REVISED. i 4 TASKS TO RESOLVE EXPECTED COMPLETION DATE COMFLETE DJSIGN EFFORT JUNE, 1983 COMPLETE PLANT MODIFICATIONS PRIOR TO HFT SCHEDULE IMPACT NO KNOWN IMPACT ON SYSTEMS TURNOVER OR FUEL LOAD. ~ ~}: Ij! WRB 4/18/83 O 4. ...e
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t- ] 1 - l LOW' ALLOY QUENCHED AND TEMPERED BOLTING MCAR 45B (80-09) DESCRIPTION'0F PROBLEM IDENTIFICATION SPECIFIC BOLTING FAILURES TO MEET REQUIRED SPECIFICATIONS RESULTED IN A COMMITMENT TO REVIEW ALL LAQTS BOLTING AND COMPONENT SUPPORTS 7/8 INCH IN DIAMETER OR GREATER. i STATUS RECEIPT INSPECTION UTILIZING HARDNESS SAMPLING WAS IMPLEMENTED IN MAY, 1982. ' COMMONWEALTH AND APEICH REVIEWS IDENTIFIED APPROXIMATELY 65 000 i LAQTS ITEMS TO BE EVALUATED BY A SAMPLING PLAN DEVELOPED BY SAI. .i THE 6000 ITEMS REQUIRING PHYSICAL TESTING IS WELL UNDERWAY WITH THREE NCRS WRITTEN TO DATE ON MATERIAL LOTS EITHER TOO HARD OR Si I ' f' TOO SOFT. TASKS TO RESOLVE EXPECTED COMPLETION DATE COMPLETE TESTING OF REMAINING LAQTS ITEMS AND REVIEW.BY SAI-AUGUST, 1983 .. FINALIZE-IDENTIFICATION OF ITEMS. REQUIRING ENGINEERING D,SPOSITION VI A NONCONFORMANCE REPORTS AND OBTAIN SAME DECEMBER,11983 1 4 :* e s 6,w .w..e - E-e. %ge.. -w _~ =
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80-09 (CONT'D) SCHEDULE IMPACT INDETERMINATE UNTIL TEST PROGRAM IS COMPLETED. TO DATE RESULTS, OF THE APPROXIMATELY 50% BOLTS TESTED, BOLT REPLACEMENT FOR THE i THREE NCRS HAS NO SCHEDULER IMPACT. I 1 l 'k e +,4m w-p < b y a + --, - a v 2 ,49.,w.._ o y s s
_ _, _.. ~. 9 3 DESIGN OF STEEL EMBEDMENTS THAT USE-TENSION BARS AND SHEAR LUGS MCAR 63 (82-12) DESCRIPTION OF PROBLEM THE ACI 349 CODE, APPENDIX B, ISSUED AUGUST 1979, SPECIFIES THAT l SHEAR LUGS IN EMBEDMENT DESIGNS SHALL BE CONSIDERED EFFECTIVE j ONLY IN COMPRESSION ZONES. MIDLAND EMBEDMENT DESIGNS WERE l COMPLETED AND INSTALLED BEFORE THIS DATE AND CONSIDERED THAT SHEAR LUGS ACCOMODATE ALL SHEAR LOADS AND THAT TENSION BARS ACCOMMODATE ALL TENSION LOADS. g STATUS ENGINEERING HAS IDENTIFIED APPROXIMATELY 2,500 EMBEDMENTS HAVING i SHEAR LUGS. EVALUATION IN PROGRESS TO DETERMINE WHICH OF THESE EMBEDMENTS IDENTIFIED HAVE SHEAR LUGS IN TENSION ZONES. TASKS TO RESOLVE EXPECTED COMPLETION DATE TESTING PROGRAM IS BEING DEVELOPED TO DETERMINE THE EFFECTIVITY OF SHEAR LUGS LOCATED IN TENSION ZONES FOR MIDLAND DESIGN -TBD 4 WRB .} 4/18/83 ~ i 'k g e wep ee e v-r v = S 'Twe
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.g 1.t 82-12 (CONT'D) REVISE THE DESIGN CRITERIA ESTABLISHED FOR NEW DESIGNS AND MODIFICATIONS T'O EXISTING EMBEDMENTS TO ENCOMPASS ALL EMBEDMENT DESIGN, MODIFICATION AND EVALUATION. MAY, 1983 .i SCHEDULE IMPACT IT IS EXPECTED THAT THE TEST PROGRAM WILL SUBSTANTs, T EXISTING MIDLAND DESIGN. I . q WRB 4/18/83 .f.~.,.,.
) DEFICIENCIES IN LIMITOROVE VALVE OPERATORS MCAR 46 (81-01) DESCRIPTION OF PROBLEM A ). THE USE OF UNDERRATED TERMINAL BLOCKS IN LIMITORQUE i OPERATORS. B) THE USE OF TERMINAL BLOCKS WITHOUT PROPER ENVIRONMENTAL QUALIFICATION IN LIMITORQUE OPERATORS. C) ADDITIONAL CONCERNS REGARDING QUALIFICATION OF VARIOUS LIMITORQUE OPERATOR COMPONENTS. STATUS i EVALUATION TO DETERMINE THE EXACT NUMBER OF VALVES OPERATORS TO BE REPLACED IS IN PROGRESS. TASKS TO RESOLVE EXPECTED COMPLETION DATE IDENTIFY ~AND ISSUE P.O. FOR REPLACEMENT PARTS SEPTEMBER 9, 1983 COMPLETE INSTALLATION JUNE 8, 1984 2 1.GHEDULE IMPACT NO KNOWN' IMPACT ON. SYSTEM TURNOVER OF FUEL LOAD. i 4/18/83-
') ') j DEFICIENCIES IN ELECTRICAL COMPONENTS ASSOCIATED i MSIV ACTUATORS, AND NON-0 EQUIPMENT WIRED AS CLASS IE MCAR 55 (82-01) DESCRIPTION OF PROBLEM i MAJOR SAFETY-RELATED ELECTRICAL COMPONENTS OF THE MSIV SYSTEM WERE FOUND TO BE NONCONFORMING TO THE SEPARATION CRITERIA 0F REGULATORY GUIDE 1.75, QUALITY ASSURANCE PROGRAM, AS REQUIRED l BY 10 CFR 50, APPENDIX B, OR ANSI 45., 2 AND THE PROJECT l SEISMIC REQUIREMENTS. A REVIEW OF FOUR ADDITIONAL EQUIPMENT PACKAGES (M125C (0) NUCLEAR STAINLESS STEEL VALVES 150 THROUGH 400 POUND RATINGS i 2 1/2" AND LARGER, (M-149 (0) AIR HANDLING UNITS, (M-150 (0) AIR FILTERING UNITS, AND (M-154 (Q) HVAC ISOLATION VALVES, HAS REVEALED THAT SOME NON CLASS 1E DEVICES HAVE BEEN WIRED INTO CLASS 1E CIRCUITS (MCAR 55, REVISION 1) 1 STATUS REPLACEMENT COMPONENTS WERE ORDERED AND ARE EXPECTED TO BE SHIPPED OVER THE NEXT THREE MONTHS. A REVIEW OF ALL. SAFETY-RELATED MATERIAL REQUISITIONS THAT INCLUDE PROCUREMENT'0F ELECTRICAL COMPONENTS AND ACCESSORIES FOR SIMILAR POTENTIAL NONCONFORMANCES AND DEFICIENCIES IS IN PROGRESS. AN ACTION PLAN IS BEING DEVELOPED TO RESOLVE THE EXPANDED SCOPE OF MCAR 55. i L,.. - ~. ~. -,. J
s k. a .. -. ~. ) l 82-01 (CONT'D) TASKS TO RESOLVE EXPECTED COMPLETTON DATE I RECEIVE MSIV REPLACEMENT COMPONENTS AND INSTALL DECEMBER, 1983 IDENTIFY AND ACCOMPLISH MODIFICATIONS l FROM ONGOING REVIEW TBD I SCHEDULE-IMPACT INDETERMINATE UNTIL REVIEW IS COMPLETE. PROBLEMS IDENTIFIED TO DATE HAVE NO IMPACT ON FUEL LOAD. a 1 1 i I e - O I ~ 1 -l c j 4
i !j a 9 0-RELATED EQUIPMENT COOLED BY NON-0 HAVAC SYSTEM MCAR 59 (82-07) - Ju DESCRIPION OF PROBLEM SAFETY-RELATED DEVICES LOCATED IN PORTIONS OF THE AUXILIARY BUILDING ARE COOLED BY NON-Q HEATING, VENTILATING, AND AIR-CONDITIONING (HVAC) SYSTEMS. LOSS OF THESE NON-Q HVAC SYSTEMS FOLLOWING VARIOUS DESIGN BASIS ACCIDENTS COULD RESULT IN ROOM ENVIRONMENTAL TEMPERATURES THAT COULD EXCEED THE SPECIFIED DESIGN TEMPERATURE OF 104F. UNDER THESE CONDITIONS, THE SAFETY-RELATED EQUIPMENT IN THFSE ROOMS MAY NOT OPERATE RELIABLY, AND BOTH TRAINS OF REDUNDANT Q-LISTED EQUIPMENT ARE AFFECTED BY LOSS OF THE NON-0 HVAC SYSTEM IN MANY INSTANCES. STATUS l REVIEW OF THE PROJECT DESIGN DRAWINGS TO DATE HAS IDENTIFIED 57 -l AREAS CONTAINING APPROXIMATELY 1100 ITEMS OF CLASS 1E ELECTRICAL EQUIPMENT, DEVICES, AND INSTRUMENTS IN THE AUXILIARY BUILDING THAT ARE COOLED BY NON-Q HVAC SYSTEMS. TASKS TO RESOLVE EXPECTED COMPLETION DATE ACTIONS TO. FINALIZE RESOLUTIONS UNIT II JULY, 1984 ARE IN PROGRESS UNIT I DECEMBER, 1984 A. UPGRADE SELECTED AUXILIARY [ BUILDING HVAC SYSTEMS TO Q j STATUS TO LIMIT THE EFFECT OF THE PEAK ROOM TEMPERATURE WITHIN THE CURRENT ENVIRONMENTAL QUALIFICATION ENVELOPE OF THE ~ EQUIPMENT l . ~. .......... ~., -
~ l ] l 1 82-07 (CONT'D) B. RELOCATE THE CLASS 1E DEVICE TO ANOTHER AREA WHERE THE PREDICTED PEAK ENVIRONMENTAL TEMPERATURE IS WITHIN THE ENVIRONMENTAL QUALIFICATION EN' ELOPE OF THE V EQUIPMENT i C. REPLACE THE CLASS 1E DEVICE, WHICH DOES NOT QUALIFY FOR THE PREDICTED PEAK ROOM TEMPERATURE, WITH ONE THAT QUALIFIES D. QUALIFY THE EXISTING CLASS 1E DEVICE FOR TEMPERATURES GREATER THAN OR EQUAL i TO THE CALCULATED PEAK ROOM ENVIRONMENTAL TEMPERATURE SCHEDULE IMPACT j NO KNOWN IMPACT ON FUEL LOAD. WRB . 4/18/83 [ s 4 4
i m ) ELECTRICAL CONTROL CABINETS / PANELS CLEARANCES MCAR 67 (86-02) D i DESCRIPTION OF PROBLEM k CLASS 1E ELECTRICAL CONTROL' CABINETS / PANELS THAT ARE NOT MEANT 4 1 i 1 l TO BE PHYSICALLY ATTACHED TO EACH OTHER AND ARE SEISMICALLY ' l QUALIFIED INDEPENDANTLY MUST NOT INTERACT WITH EACH OTHER OR + ADJACENT STRUCTURES DURING A SEISMIC EVENT. THE REQUIRED CLEARANCES HAVE BEEN CALCULATED FOR THE CLASS 1E CABINETS / PANELS j BASED ON THE RECOMMENDATIONS OF BC-TOP-4A (TOPICAL REPORT, SEISMIC ANALYSIS OF STRUCTURES AND EQUIPMENT-FOR NUCLEAR POWER PLANTS, REVISION-3, NOVEMBER,1974) AND COMPARED TO THE EXISTING CLEARANCES. THOSE CABINETS / PANELS WHOSE EXISTING CLEARANCES IS ] LESS THAN_THAT CALCULATED ARE CONSIDERED TO POSE POSSIBLE [ SAFETY / QUALIFICATION PROBLEMS SUBJECT TO ADDITIONAL EVALUATION. i a j STATUS L, ~ 1 NUTECH AND/OR SUPPLIERS'ARE REVIE ING EXISTING INSTALLATIONS WITH PROXIMITY PROBLEMS TO DETERMINE ACCEPTABILITY. ] BsW IS ANALYZING THEIR CLASS 1E CRD; TRIP BREAKER CABINETS - TO FINALIZE THE DEFLECTIONS DETERMINE WHETHER PROXIMITY: PROBLEM EXISTS' 4
- WRB 1
4/18/83 I r -1 u. . -., ;. m - .._,a....__.._, .w..m _-_ m. ~ y ~. ~. _..
4 .,l j . 02 (CONT'D) 3 TASKS TO RESOLVE EXPECTED COMPLETION DATE ACTUAL MOVING OF PANELS TO PROVIDE REQUIRED CLEARANCES ON HOLD PENDING 'NUTECH' REVIEW OF ALTERNATIVE i S01.UTION AND ANALYSIS OF EXISTING 1 INSTALLATION APRIL 25, 1983 UNINSTALLED CLASS 1E. PANELS l - ADD NOTES TO APPROPRIATE LOCATION DRAWINGS SHOWING MINIMUM CLEARANCES JUNE, 1983 B&W SEISMIC QUALIFICATION ANALYSIS MAY 31, 1983 i { SCHEDULE IMPACT y i NO SCHEDULE IMPACT EXPECTED. i e b WRB i 4/18/83 e =****ee rmsg
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.....-.._.:....2. 4-f. 1-i i SLTE FIANAGFJIENT l OFFICE = t j e 6 e 4 PERSONNEI. i Al) MIN Pl. ANT l 4 CONSTRUCTION TECitNICAI. SUPT I.ICENSINC/PRC 3-. PUBl.IC AFFAIRS s 1 I. 3 g CIIP OPS MAINT SCllEDUI.E 2 supt supt supt t l + a PLANT HP OTilERS t L t y b e m
i ., _.. -. _ _ ~. --m-.__- l ,. ~ ACTUAL AND ANTICIPATED CPCO AND CONTRACT EMPIAYEES THROUCE 1985 T l -I r 1100 -
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4 --a--.. g l i 1 OPERATIONS DEFAR118 TNT TRAINING STATUS '3 As of March 31, 19R3 I COLb LICENSE U of H SIMULATOR REQUIRED OBSERVATION 1 TOTAL FUND. SYSTEM Rx TRAINING B&W SHO HCHT TRAINING 27 24 24 24 20 27 24 i SS
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1. q MIDLAND PLANT PROCEDURE STATUS (MARCH 1983) + NUMBER DRAFT IDENTIFIED COMPLETE APPROVED i 1 l ADMINISTRATIVE PROGRAM j PROCEDURES 305 250 213 I (82%) (70%) 3 TECH SPEC SURv
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0 I (1%) (0%) I UORKING LEVEL PROCEDURES OPS + 322 320 195 (99%) (60%) MAINT '336 312 290 (93%) (86%). CHEM 111 109 97 (98%) (87%) ~ HP 130 111 84 (85%) (65%) TEST PROGRAM 729 610 322 '(84%) (44%) WITHDREW ALL APPROVED PROCEDURES 4TH QUARTER 1982, Dus TO NOD STANDARDS' REQUIREMENTS CHANGES. + MANY SYSTEM PROCEDURES REQUIRE SUBSTANTIAL REVISION DUE TO CHANGES SINCE ORIGINALLY, APPROVED. ,... ~,..
'~ G j i EMERGENCY PREPAREDNESS STATUS Pl.ANS AND PROCEDURES EMERGENCY Pl.AN oSUBMITTED-FEB 1982 i o SER ISSUED JUNE 1982 e REVISION PLANNED (I i m m ) }iAY 1983 i,- IMPLEMENTING PROCEDURES c 100% DRAFTED l 0 65% FINAL l MIDLAND, BAY AND SAGINAW COUNTY EMERGENCY PLANS o SUBMITTED TO FEMA SEPT 1982 o INITIAL FEMA FINDINGS ' ISSUED DEC 1982 i c RESUBMITTED TO FEMA APRIL 1983 ASLB PREPARATION ( oDIRECT TESTIMONY PREPARATION HAS BEGUN e t ^
m '-hw e y 99m. . - ~ EMERGENCY PREPAREDNESS STATUS SEP TRAINING CPCo PERSONNEL o 60% 1982 o REMAINDER 1933 NON-CPCo PERSONNEL ~ c HOSPITAL NOV 1982' cEMERGENCY ROOM ~ cAMBULANCE ATTENDANTS 4 REQUALIFICATION oSCHEDULED 1983 i DRILLS oACTUAL DEC 1982 FEB 1983 c PLANNED QUARTERLY 9 EXERCISES' c TWO TRAINING TEAMS c ACTUAL DEC 1982 eINCLUDED G0CC MAR 1983 c PLANNED QUARTERLY i ~
9 3 EMERGENCY PREPAREDNESS' STATUS SEP SYSTEMS / FACILITIES SM 8e 9e 44 4E 4E 9E mO c0 M M9 59 m n SYSTEM FACILITY POLICE RADIO LINK / / BULK POWER BASE STATION / HEALTH PHYSICS BASE STATION i l' / OPERATIONS REPEATER / CONSTRUCTION REPEATER / SECURITY SYSTEM REPEATER / EMERGENCY YARD LIGHTING / UNINTERRUPTABLE POWER SUPPLY / COMMON COMPUTER / TSC DOMESTIC WATER / TSC SEWAGE / TSC UPS SECURITY SYSTEM CONSOLES / COMPUTERS / PLANT ACCESS / SECURITY MONITORING Nov 1983 PusLIC ADDRESS GROUPS 1 & 2 DEC 1983 Aux BUILDING RADIATION MONITORS JAN 1984 PLANT DRMS COMPUTERS JAN 1984 .{} "t 1/^ s
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1 EMERGENCY PREPAREDNESS STATUS SEP SYSTEMS / FACILITIES PUBLIC WARNING SYSTEM f 1 oINSTALLATION COMPLETE o PARTI AL TEST MAR 1983 oIN SERVICE MAY 1983 4 GENERAL OFFICE CONTROL CENTER c PROCEDURES COMPLETE o TRAINING COMPLETE c EXERCISED FOR PALISADES AND B.!G ROCK PLANT EMERGENCY OPERATIONS FACILITY
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I ,+ /2 / uv, I +/: ' i :, 4 i ~ 1 - l INDEPENDENT THIRD PARTY REVIEWS k i Independent Design Verification (IDV) Construction Implementation Overview (CIO) Soils Remedial Activities 4' 4 6 l S e 'h 5 +, %.r e4 - u2 -'M N*~+M'
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W = m W l p IDV (a) System Selection , Aux FW' -Electric Power System (Diesel Gen) -HVAC (Control Room Habitability) (b) Scope (Design) -Review of Design Criteria & Commitments -Review of Implementation Documents 1 -Review of Calculations & Evaluations -Evaluation of Drawings 8 Specifications (c) Scope (Construction) -Review of Supplier Documents -Review of Storage 8 Maintenance Do.cuments -Review of Construction Installation Documents i -Review of Selected Verification Activities -Verification of Physical Configuration (d) Expansion of Scope Possible if Gener,1c Findings (e) Status Started 11/82 Meetings 10/25/82, 2/8/83, 4/13/83 With NRC PQ4M issued 11/11/82 Findings a Protocol (Region III. letter 3/28/83) G e --=v-e e *- A g-e-s. --==.a IP
=. G G CIO (a) Purpose 6 m m- + d.r P (b) Scope -Development of An Assessment Program and Preparation of a Project Quality Plan -Assessment of Adequacy 8 Compilance with CCP Procedures and Inspection Plans -Monitoring of the Implementation of the CCP by Evaluating: --Conformance of Installed Hardware to. Design Info in Specs a Drawlngs -Cempleteness of CP Co a Bechtel's Procedures Regarding. Construction Activities Personnel Qualifications, Training Programs, and Organizational Practices --Compliance of CCP Teams With Prescribed Procedures ..,. :c t. ~ . --Compliance of IR Personnel With Applicable Procedures --Compliance of Construction Activities with Applicable Procedures. --Audits of Management Reviews of CCP a Hold Points (c) Protocol (d) Status - -Selection of SaW -April 6, 1983 Letter to Keppler Drafting PGAM ' l. On Site 4/20/83 =>d* +%w4 -4 v e.wr.. w e a ++ + ew i n%.- - w i, m eme + 4-m. we. p
n .c,, .. \\ I ~ CCP OUALITY ACTIVITIES ACTIVITY .STATils QC INTEGRATION WITH MPQAI) COMPLETED 1-17-83 VERIFICATION OF QUALITY PQCI REVISIONS ONGOING INSFECTOR TRAINING /RECERTIFICATION ONGOING DEVELOPMENT OF QUALITY VERIFICATION PLAN MGMT REVIEW 4-N-83 PROCEDURE REVIEW AND DEVELOPMENT ONGOING , SUPPORT OF Q SYSTEM TEAMS ORGANIZATIONAL ALIGNMENTS IN P90GRESS PROCEDURE REVIEW / APPROVAL ONGOING MPQAD INTERFACE PROCEDURES IN PROGRESS j IN PROCESS INSPECTION PLAN ~ IN PROGRESS i PROGRAMMATIC REVIEWS REPORT TO MGMT 5-18-83 l. HANGER REINSPECTION l l 100% REINSPECTION OF 7000 HANGERS IN PROGRESS OVER 50 INSPECTORS DEDICATED STAFFING IN PROGRESS I
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m.. ;.._ _. _ _ Bg1N_SPECTION SCOPE AN.i ASSUMPTIONS I i SCOPE - 139,000 CLOSED IR'S REPRESENT POPULATION l l - COMBINED PQCI'S - RECEIPT INSPECTION - DOCUMENT REVIEW - OVERINSPECTIONS PREVICUSLY DONE - 101,500 CLOSED IR'S SUBJECT TO VERIFICATION (EST) - 79,500 HARDWARE REINSPECTION - 22,000 PRIMARILY DOCUMENTATION REVIEW l ASSUMPTIONS t l 1 - PLANNING BASED UPON 45,000 UNITS OF REINSPECTION - 4 INSPECTION hours PER UNIT (AVO) REQUIRED FOR REINSPECTION - WORK FORCE OF 250 TO 350 ' INSPECTORS .r.... 1,. r- - SCHEDULE BASED UPON;7 DAY WEEK AND 5 INSP-HOURS PER DAY - NRC APPROVAL OF CCP IN MAY D e t k: j. L l 1 q ~
CUMULATIVE REINEPICTION MAN ll0URS FOR VER'IFICATION PHALE 500 - f s 8ttE000 MAN-HRS ] MAXIMUM g_ 350 INSPECTORS y aa 300 - dK 8 250 INSPECTORS i .i B l ~ t1 E' 200 - 180,000 INSP-ilRS E PLAN l, E i -j 88,000 INSP-HRS ,100 - MININun e i l l l l l l l l l 1 l APA May JuME Jul AUG SEPT OCT. Nov DEC JAN FEs MAa 1983 198tl
e ( FIGURE 1-1 O C 2-CONSTRUCTION COMPLETlON PROGRAM 8CHEMATip g ' Pila 8E 1 PHASE 2 .O ~ SECTION PLANNING lMPLEMENTATION PLANNING IMPLEMENTATION PRE, PAR ATION. 2 OF THE PLANT OAIOC REORGANIZATION l - PilASE 1 PHA8E 2 4 PLANNING PLANNING MANAGEMENT p REVIEW ' COMPLETED INSPECTIONS EVALUATION SYSTEMS 5 -AND COMPLETION ^ ^' MANAGEMENT AND _l-REVIEW INSPECTION STATUS d a f 6 OUALITY PROGRAM REVIEW T THIRD PARTY REVIEWS 8 SYSTEM LAY UP J 0 CONTINUING WORK ACTIVITIES t } b
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310 i t 9 3 0-SYSTEMS TD-GO 187 d I RECHTEL 13fl BAW. CONSTRUCTION 8 ZACK ll5 i-187 l i i NON-0 SYSTEMS T0-60................ 123 0-o- i3 3-g a E dn .. O O.i IIBMILLER/fi-15-83 5 O ~3 63 e
e P FIGURE 1-1 CONSTRUCTION COMPLETlON PROGRAM 80HEMATip
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SECTION ~Pl.ANNING lMPLEMENTATION PLANNING IMPLEMENTATION (%..q;.Gru I; Il':/!v'.3 e 3 RE ON d ~ - PilASE 1 DY PHA8E 2 ? 4 PLANNING PLANNING 1 VERIFICATION,k M6NAGEMENT , op, REVIEW
- COMPLETED lN8PECTIONS EVALUATION SYSTEMS 5
,8' - /.- 7/U/ AND COMPLETION INSTALLATION - REVIEW WORK MANAGEMENT AND REVIEW INSPECTION l 6'/jf, i 6 QUALITY PROGRAM REVIEW 7 THIRD PARTY REVIEWS 0,..., t 8 SYSTEM LAY UP --Av//peOb3 G*< *[l// ~ " O O CONTINUING WORK ACTIVITIES -- @ g.gsy,
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9 + ~ - - - - * - ~ ' - '_i V ~ ~ O E 8 'i r g SECTION 9.0 .i '4 ag CONTINUING WORK ACTIVITIES a f 'c 1 DESCRIPTION: THOSE ACTIVITIES TilAT llAVE DEMONSTRATED EFFECTIVENESS IN Tile QUALITY PROGRAM '2a IMPLEMENTATION WILL CONTINilE DilRING IMPLEMENTATION OF THE CONSTRilCTION i n a COMPLETION PROGRAM. l THESE ARE: 5 1. NSSS INSTALLATION OF SYSTEMS AND COMPONENTS BEING CARRIED OUT BY B&W CONSTRUCTION COMPANY l l 2. HVAC INST LLATION WORK BEING PERFORMED BY ZACK COMPANY. WELDING ACTIVITIES CURRENTLY ON HOLD WILL BE RESUMED AS THE IDENTIFIED PROBLEMS ARE RESOLVED I. l 3. POST SYSTEM 'IURNOVER WORK, WillCH IS IINDER THE DIRECT CONTPOL OF CONSUMERS ~ l POWER COMPANY, WILL BE RELEASED AS APPROPRI ATE IISING ESTARLISHED WORK o g AUTil0R17.ATION PRCCEDilRES J 3 fl. HANGER AND CADLE RE-INSPECTIONS, WilICH WILL PROCEED ACCORDING TO SEPARATELY k ESTABLISHED COMMITMENTS TO NRC SI 3 5. REMEDIAL SOILS WORK WilICil IS PROCEEDING AS AUTHORIZED BY THE NRC O f. 6. DESIGN ENGINEERING WILL CONTINilE AS WILL ENGINEERING d SUPPORT OF OTilER PROJECT ACTIVITIES ~ 3 !d
~- l ~ -^ }, j '<.U:, l ' ' l ', '. 1 I 'l MAJOR EVENTS SINCE AUGUST, 1981 l CCP Inftiated - December, 1982 1 - Remedial Soils Work Start - August, 1982 4 l - Turnover First System for Cold Hydro - May 1982 Completed 500 Turnovers - October,1982 Placed HP Boilers in Service - August, 1982 I I i Turbine - Generators on Turning Gear - Unit 2 June, 1982 + Unit 1 November, 1982 - Commenced Area Turnovers for CPCo Control 4.4pkh .),.,4p,[3 CQ ,llY"') Lss j? l%; i M e e m I, - m .-m. g e e-t-
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i .__m..._... .. ~ i; ~ CONSUMERS POWER COMPANY MIDLAND UNITS 1 a 2 1 a BULK COMMODITY COMPARISON ~ i .i 4 \\]. CoteeDDITY CURRENT 1 COMPLETE PREVIOUS 1 COMPLETE ESTIMATE ESTIMATE 3/27/83, ESTIMATE 7/26/81 INCREASE / DECREASE i Large Pipe 280,000 99 282,000 94 (2,000) i Small Pipe-325,350 95 307,550 78 17,800 h Large Pipe Bangera 15,834 92 15,350 82 484 f Small Pipe Bangers 18,260 80 17,740' 43 520 Cable Tray 93,300 99 85,000 96 8,300 Exposed Metallic
- }
Conduit 610,000 90 554,000 76 56,000 ) ' ii Wire and Cable 10,750,000 93 10,300,000 58 450,000 M' Connections 356,000 81 385,000 32 (29,000). f Instrument Tubing 175,000 65 205,000 22 (30,000) i.. e 7, d
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to CONSUMERS POWER COMPANY = i .'ilDLAND UNITS 1 a 2 l e BULK COMMODITY STATUS (AS OF 3/27/83) 1 COMMODITT TOTAL QUANTITY INSTALLED 'ID-DATE UNIT 1 2 TOTAL 1 2 TOTAL PIPING Large Pipe LF 85,525 194,475 280,000 84,855 192,470 277,325 Small Pipe LF 110,277 215,073 325,350 105,306 204,960 310,266 Large Pipe Hangers EA 5,064 10,770 15,834 4,623 9,965 14,588 small Pipe Hangers EA 5,930 12.330 18,260 5,042 9,648 14,690 ELECTRICAL } Cable Tray LF N/A N/A 93,300 N/A N/A 92,574 Exp. Metallic Conduit LF 141,463 468,537 610,000 131,918 419,378 551,296 3 j Wire and Cable LF N/A N/A 10,750,000 N/A N/A 9,946,929 'l Connections EA N/A N/A 356,000 N/A N/A 288,690 e INSTRUMENTATION Tubing LF N/A N/A 175,000 N/A N/A 113,890 Y ee 9
9 7 i CONSUMERS POWER COMPANY MIDLAND PLANT UNITS 1 & 2 PEAK INSTALLATION RATES OVER.FIVE MONTH PERIOD i i i SMALL PIPE BANCERS CONNECTIONS: INSTRUMENT TUBING ACTUAL AVERACE 515/MO 13,737 9175 PEAK RATE (SEPT. 81 THROUCH.JAN. 82) ACTUAL VS. FORECAST 54% 72% 57% (oto) ACTUAL VS. FORECAST 186% 181% 115% (NEW)- 1 i e O l 1-l 2 l l 2.~.
) D G"" D E M 0 o SA ~1 0 o D sT" 2 e. r. N I R \\ C" 8 4 3 2 L O O i' 1 1 Nf' V rL Oi T t I S S L M 8 ) D" A a E L T' L C o U A' A E t F T 3" R a S 1^ 0 ( ~ J '4 N N E" F u 0 I 4 T t E L A T 0 0 J (K" A o 1 t Ou" c o o M TE T T .R' TO" A E l iN M F p J ~ D N l ~ Y O 2 R le t A E l 8 I i S M G N T O N O A U R H T I C AI N E A ~ 3 J 0 D W EL N O Pl ~, 0 f -[ r J, 1 l ,~ A P A ,i I L P T M S D l L S I l LN M E = = A 0 A M I = 2 U M-M 2 S l 7 S t O F C J l D N 0, S s A 2 J 0, 0, J 1 M' s A / M F ~ J 0 0 S O 2 1 ] !I 6e! i i? i .l
7220 MIDLAND UNITS Ia.2 CONSUMERS POWER COMPANI Tim. TD 6 0 I N5 M t.t. ATION to BASED OM %EGulREMENT5 TO TERMINATION surront ws ratuscT nutaunm 3CMEDULE INSTALLATION t TOTAL FORECAST 356,000 .TO DATE (3/03) 288.890 i 1 '.400 O h. 7 maas' 32r tu.: .2.t- .21' * --. v-x 300 w 1 O s p ill s / s 57' L)NI T2 FUEL LO.\\D l l 100 o J F M A,M J J A 3 O N 'D J F MA MJ J A S O N D J F MAMJ J A S O N D 1982 1983 100'4
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'l 9 s j 1 9 CONSUMERS POWER COMPANY MIDLAND UNITS 1 & 2 PRODUCTIVITY (AS OF MARCH 27, 1983) ~ -il 4 COMMODITT PERFORMANCE FACTOR UNIT EATES TO-DATE TO-DATE Large Pipe 1.00 5.48 ME/LF Small' Pipe 0.99 4.56 MH/LF Large Pipe Rangers 1.05 120.84 ME/EA + Small Pipe Hangers .1.04 45.23 ME/EA Conduit 0.97 1.83 Mn/LF Wire and Cable 0.92 O.08 MH/LF Connections 0.93 0.91 ME/EA ll PERPORMANCE FACTOR = Actual Manhours Calculated Manhours l 1 "m . -., ~.. -. ~ - - - - = - - - ~ - -
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- -....... - ~. - - - ~ - - - - ~~ ~ ~ ~ ' [' y.. n.c ~ l j 4//i/ii OVERALL PROCUREMENT STATUS ll ) e DELIVERED TO JOBSITE ] . Approximately 97% of Valves; Balance Due by 9/83 . Approximately 98% of instrumentation; Balance Due by i 8/83 i I . Approximately 92% of Hangers; Balance to Be Released During Remainder of 1983 i ) s I . - Approximately 99% of Power and Control Cable; Balance Due by 6/83 o \\ l PROCUREMENT PRESENTATION WIW83 2 &301641 L E
~ INCOMPLETE MAJOR PURCHASES DESCRIPTION P.O. y NO. (Vendor) STATUS J-2441 Radiation Monitoring (Victoreen) Complete Delivery by S183 J-28S with Exception of New Q Modules. New Q Modules to () be Delivered First Quarter of l 1984 M-56 Chilled Water Pumps and Motors Complete Delivery by 9/83 (Goulds/ Reliance Electric) M-146 Chiller Upgrade Complete Delivery by 8/83 (Carrier Corporation) .M-1541 Halon and Tornado Dampers Complete Delivery by 7/83 M-387 (Pacific Air Products) M-224 Unit Coolers (American Air Filter) Complete Delivery by 9/83 ) M-238 MSIV Electrical Modifications Complete Delivery by 7/83 (Bonney Forge Engineered Valve Division M-106 Hanger Components (ITT Grinnell) Deliveries to Continue Through Balance of 19143 as Released by Engineering PHOCUREMENT PRESENTATION 4/14183 2 G 301602 e
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3 i ' PERC2NY CMPLEY3 i t 1 E! 191 arch 1083 1 Current Forecast 3 'I o ALLLENGINEERING 7G% l ~ o DESIGN 04 % v. hi . Cable Routed Complete CL% .. Exposed Metallic Conduit issued 03 % Small Pipe issued 99 % .j 1 Small Pipe Supports issued 05 % u . Large Pipe Supports issued 97 % l 12G Juli J
l 4 MIDLAND Pt ANI UNITS 1 AND 2 JOS 7220 ElJGIIAEEsser4G lA AHl40064 CHAl3GES IlletOUGil DLCkMtslet IWJ2 (Hecorscilletaus) from Deceanber 1Wol Foreceal) l _ Mann.ours (1,000 ) l I hevi Descripilon. Total DECEMBER 1981 FORECAST u,9u0 1 SCHEDULE CHANGE 1,100 2 HVAC 336 3 SOfLS 267 4 LARGE PIPE 212 i 5 SMALL PIPE 133 . 'j 4 SPACE CONTROL GROUP tow 7 HELBA 100 i l 8 CONSTHUCilON COMPLETION Ph0GHAM FF - I 9 SPAllAL SYSit M INILHACllON FF s l ') 10 STHUCTURAL VEHitlCAilON 60 - 11 O DEVICES IN NON O COpLLD AMEAS 52 12 EOulPMENT ENVIRONMENIAL QUAlltICAllON 49 i. 13 NRC SULLETIN 79-14 49 1 14 INCORPOHATION OF CHANGt DOCumtNis 48 i ' 15 SORT - 41 i 16 SEISMIC ANALYSIS OF Cast E TH AY SilPPOHIS 36 j 17 GEt4LHAL FCRIFCN CON'alHUGilON buPPUNI 3h 18 FILE CLOSEOUT AND JOtt CLLANUP 35 19 RELOCATION OF RESIDENTS 34 i i 20 EMutD ANALYSIS 25 21 CONTROL ROOM MOOlFICATIONS 25 'l I 22 CAR DISPOSITIONS 22 23 RESOLUTION OF MIOSHA INILHFtRENCES 21 24 INDEPENDENT DESIGN HLVitWS 18 25 OE ACTIVITIES 1S l-26 NRC HEAHINGSIOUFSTIONS SUPPORT 10 27 MISCELLANLOUS NON SCOPE CHANGES 92 1 28 MISCLLLANEOUS SCOPE CHANGES 226 ~ j HOUNDING (6L ? ' - 3.300 3,300 CURRENT ESTIMATED ENGINEEHitlO 100% 13,200 f.1AHHOUR FORECAST AFTER FUEL LOAD CONTINulNO SEHVICE AGHEEMENT _ 250,, j 13,450 i l; Meft AND UNITS 1 AND 2 [. f t lif4LIAHy 1983 \\\\
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....l. t SOILS SCHEDULE ~ i l 1982 1983 19811 l JFMAMJJAS0ND JFMAMJJAS0ND J F f1 A M J J A S 0 N D I Diesel Generator Building - Crack Repair Prior To First Refueling Borated Water Storage Tank % st'$ 4 d. 1 Underground Piping 36" Pipe Replacement
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1 .I l SOILS SCHEDULE ~ I AUXILI ARY BUILDING i i 1982 1983 1 9'8 4 85 ~ JFMAMJJASOND JFMAMJJASOND JFMAMJJASOND JF Access Pit ) Temporary underpinning ,. s. : < 3 6 4,g.. g 3.e. g,4 7 s-------.--- Mass Excavation f4 -@ $.-MU6 @t Pour Permanent Wall isttaw Load Transfer l S011s Consolidation Smit Lockoff 8 Grout l Complete Backfill l
l ~ MIDLAND PROJECT REPLANNING SO1LS (UNDERPINNING) LINKAGE TO FUEL LOAD s i EVENT: e Start of Solls Consolidation BASIS: e Load Transferred To Permanent Wall e Demonstrate Building lias Structural Capability To Fulfill Safety Function Required For Fuel Load 8 Low Power Physics Test e Present Evaluation for NRC Approval ( h
s APIILIAFY PUILDII;C 17'DEFFTCI?'G FACT SFFET i { A. Dewaterine Vertical Freeze Holes 248 f Angled Freeze Holes 79 Thermal Moni, tor Poles 39 Fjecters 78 Pfezemeters 13 TEtal Poles Drilled 457 Linear Feet Freeze Header 3,036 i Linear Feet Dewatering Header 3,410 t ' l B. Access Shafts (East and West) i i l Depth Each Shaft 76 Feet Excavated Haterial - Shaf ts 8,889 Cubic Yards i C. Temporarv Underninning 4 Length of Access Drifts 1,106 Porizontal Feet Excavated Material - Drif ts ~ 1,474 Cubic Yards Number Temporary Piers 57 j Excavated Material - Piers 3,550 Cubic Yards l ReinforcinF Steel - Piers 295 Tons Structural Steel - Piers 803 Tons Concrete - Pfers 3,550 Cubic Yards -l D.. Permanent Underoinning . Mass Excavation 7.957; Cubic Yards Permanent Wall: ~ Length: 600 Feet Width: 6 Feet- . Height: 35 Feet l Wall Concrete 4,287 Cubic Yards Wall Peinforcing Steel 326 Tons Slab Concrete 257 Cubic. Yards Elab Reinforcing Steel 30 Tons t, ' E. Summarv-i' . Total Materia 1 L Excavated 21,870 Cubic Yards Total Reinforcing Steel' 651 Tons Total Concrete. 8,095 Cubie Yards p i FS/LET2. = x: n .o seem __+, m e-o.+ v.w e n - wcw v - + 7-w' '4 '*~~'t =?vm ; m-~~-**-
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= s t i C-195 _] Scoce: 3 The scope of the C-195 contract is to underpin the control Tower and Electrical a Penetration Areas (EPA) of the Auxiliar-f Euilding and a pertion of the Turbine Building. The project has been broken down into four phases of work which includes the installation of the East and West Access Shafts, 54 underpinning piers and six grillage beam suppo'rt assemblies. The piers and grillage beam assemblies = a will temporarily support *he Control Tower, EPA and Turbine Buildings until the i per=anent underpJnning wall can be constructed and the building loads transferred 7 to the wall. General: = { Mergentime, the prime contractor for the Auxiliary Euilding, will accomplish this work by excavating drifts (tunnels) from both the East and West Access Shafts. The drifts will only advance as far as the next scheduled pier location. At this point, the pier will be excavated, lagged, rebar installed, instrumentation } and embedded items installed and concrated. j Once the concrete has acnievt.d the specified strength, the pier will be jacked j against the building and the load transferred to the pier. The drift will then i procede to the next pier and the same process followed. This method will i continue from both sides until all the piers and grillage systems have been installed and the load te=porarily transferred. Once the Control Tower, EPA and Turbine Building have been supported te=porarily, j Mergentime will begin mass excavating the area in stages to the final elevation 3 of 571' During the mass excavation, the Contractor will install a strut system 5 to brace the piers as the excavation procedes, since excavation is on only one T side of most piers. Mass excavation of the Access Shafts will coincide with the 4 mass excavation under the building. m After mass excavation is complete, the Cont ractor will construct a six foot wide, l 35 feet high wall approximately 600 L.F. long, (4,287 cubic yards of concrete). l This will serve as the new foundation for the building once the load has been 3 l transferred from the piers to the wall. When the load has been transferred to the permanent wall, the " ballroom" will be backfilled on the way out, as well as tile Access Shafts. 5 Pertinent Data: j Pier Concrete 3550 C.Y. i i Wall Concrete 4287 C.Y. + Miscellaneous Concrete 600 C.Y. Rebar (Total) 1,274,784 lbs. ~ Material Removed 21,870 C.Y. ~ A attd_ wA. Mi
s } SERVICE WATER PUMP STRUCTUPE UNDEPPINNING Phase I 1: Agreed Quantities as of 11/19/82 FACT SHEET A. Devataring Ejectors (Inside) 33 Piezameters (Inside) 3 Ejectors (Outside) 47 Piezometers (Outside) .j[ Total Holes 92 Linear Feet 8" Dewatering Header 1,375 Linear Feet 10" Dewatering Header 345 _j B. Access Shaft [ 1. Soldier Piles 27.each 1 2. Sheeted Pits for S.P. 3377 Sq. Ft. 3. Excavation Sheeted Pits for S.P. 109 CTS. 4. Concrete for S.P. 16.5 CYS. i-l 5. Lean Flyash Concrete for S.P., 65.3 CTS. i 6. Lagging 2700 Sq. Ft. 7. Excavation 981 CTS. .8. Structural Steel (Struts, vales, bracing) 95 Ton C. Approach Pits. Underpinning Piers, & Tunnel 1. Excavation 680 CTS. 2. Pier Reinforcing 52 Ton 3. Lagging 10.585 Sq. Ft. -l .l 4. Concrete 670 CTS. 5. Backfill and Tunnel Concrete 46 CTS. '.l-6. Anchor Bolts & Plates Etc. 47-Ea. 7. Hydraulic Jacks (Estimated) 50 Es. - I FS/LET2 r.; ~.. . ~. -
O F, l Summary of Underpinning of Service Water Pump Structure i The scope of the work involves two Phases, I and II. Phace I entails work related to the actual underpinning of the Service Water Pump Structure. j Phase II involves excavation and rebedding of piping. l Phase I work begins with the location of utilities within the eerk area, both for excavation and installation of dewatering wells. After all utilities are located, approximately 47 dewatering wells will be installed outside of I the building. Concurrently with this operation, 33 dewatering wells will be [ placed in the,, Service Water Pump Structure and the Circulating Water Intake Structure. Also, a total of 12 piezometers are to be installed. The installation of soldier piles will be the next activity. This will consist of 27 total soldier piles being installed; 20 will be placed in i drilled holes, and the remaining seven will be placed in sheeted pits. Once .j the soldier piles have been installed, the Access Shaft excavation can begin. l Lagging and bracing will be installed as the shaft is dug. An estimated 785 cubic yards of excavated material will be removed from ground elevation down to elevation 618. From the Access Shaft,. access pits will be dug to-enable the pier excavations i to proceed. A total of 20 piers are to be installed in a predetermined j sequence. After Pits 1,1A, 2 and 2A are installed, a tunnel will begin being excavated under the Service Water Pump Structure, next to the Circulating Water Intake Structure. This tunnel will be approximately 6' x 6' x 30' in length upon completion. The above will catail, for all piers, 680 cubic yards of excavation, 670 cubic yards of pier concrete, and 102,425' pounds of rebar. The tunnel will have 50 cubic yards of excavation. Once a pier is installed, jacking will ta'ke place to transfer the load to the [ pier. After the load is transferr'., the pier will be wedged to maintain the a applied load. 14rge anchor bolts, connecting the pier to the Service Water i Pump Structure will be tightened to maintain contact between the building 4 j and the pier. This process will be repeated for each individual pier. 4 After all piers have been loaded, the access tunnel will be backfilled with a 4 lean concrete mix. Additional work for the Phase II operation will include probing for utilities, installation.of dowatering wells, installation of soldier piles, excavation, lagging and bracing. This, work is being done to uncover certain utilities which must be rebedded. The actual embedmont will be perfereed by Bechtel forces. Quantities for this work have not been calculated by the Field. l 4 m.
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4 4 c, i l-F .j AUXILIARY BUILDING SCOPE ITEM QUANTITY BUDGET RATE C' Horizontal Drift. ~1,106 ft 3 If/cs ~ Pier Excavating 3,550 cy 3 vf/cs l Pit.. Reinforcing Steel 295 T 500 lb/cs 1 Pier Concrete 3,550 cy 7'cy/cs i Mass Excavation 7,957 cy 10 cy/cs Permanent Wall Concrete 4,287 cy 29 cy/cs I I e j. e e + [ 1 ..+, .mn. s-W+ W
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PRODUCTIVITY CHART ~ AUX BLDG UNDERPINNING 302 PLACE PIER REBAP. JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 3500 3000 s 2500 t
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l ... ~..... --~ --- - ~ - - -. - - - - - ~ ~ - - - - - PRODUCTIVITY CHART ~ 3 AUX BLDG UNDERPINNING 404 PIER CONCRETE JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC l 25 .) 20 '>a 'i ' E t i S b 15 =a C3 l O M Q. .10 - R.- p A 7 CY/CSit 5 l 1 l 1 0
... ~. - - - -... _.. _.. _ - - - ~. - t g ' MIDLAND PROJECT REPLANNING LICENSING SCHEDULE 1983 1984 AlM J J A SlO N D J F M A M JlJ A S O i M Hearings Comptete Liaigg;EE Fact Finding CP issues Complete p.t . ~ Initial Decision Hearings i 7SA l INTERVENOR CONTENTIONS y....- Y tt***w+=weecusseen%e SSER +3 i SSER*4 Y OPEN ITEM CLOSEOUT (NRC Staff) i V r Dmitm!arimmuvta nmum-wrcMHF1 i i (,;l 4 FINDINGS OF FACT M j Operating f License I } in ts n l o,' D j i INITIAL DECISION M / JNL 4/19/83
q p;. in.( SER OPEN ITEM STATUS CLOSED BY SSER +1 AND +2 TYPE OF ITEM COMPLETED / TOTAL NUMBER j OUTSTANDING ITEMS O/17 CONFIRMATORY ISSUES 9/32 LICENSING CONDITIONS 1/11 I ~ PROJECTED COMPLETION FOLLOWING SSER +3 i TYPE OF ITEM COMPLETED / TOTAL NUMBER i i OUTSTANDING ITEMS 10-1/2/17 CONFIRMATORY ISSUES 25/32 LICENSING CONDITIONS 2/11 O JNL 4/19/83 i t a h-e 1 M
t i SER OPEN ITEM STATUS (CONT'D) PROJECTED COMPLETION BY END OF 1983 i TYPE OF ITEM _ COMPLETED / TOTAL NUMBER OUTSTANDING ITEMS 16/17 (2 HALVES REMAINING-EMERGENCY i l PLANNING & SEISMIC QUALIFICATION)
- i CONFIRMATORY ISSUES 31/32 LICENSING CONDITIONS 4/11 I
PROJECTED COMPLETION BY FUEL LOAD TYPE OF ITEM COMPLETED / TOTAL NUMBER OUTSTANDING ITEMS 17/17 CONFIRMATORY ISSUES 32/32 LICENSING CONDITIONS 8 t/11 I JNL 4/19/83 ~~ y ,- - +-=.._~..,, _.,,e, ,,,,.-,-y. c..,
S l SER ITEMS ALREADY CLOSED BY SSER'S OUTSTANDING ITEMS DESCRIPTION OF ITEM 01-5 PORTIONS OF SOILS SETTLEMENT ISSUES i CONFIRMATORY ISSUES DESCRIPTION OF ITEMS 4 Cl-3 PROGRAM FOR MASONRY WALL EVALUATION Cl-5 SUPPLEMENTAL ECCS CALCULATIONS Cl-8 EVALUATION OF ENVIRONMENT NEAR DHR SUCTION VALVES Cl-9 ADEQUACY OF BWST TO PROVIDE BORIC ACID TO RCS Cl-10 MFW OVERFILL PROTECTION l Cl-13 LOWEST SERVICE METAL TEMPERATURE i Cl-28 APPLICABILITY OF POWER TRAIN CODE Cl-29 S/G WATER INVENTORY AS. A FUNCTION i OF POWER LEVEL Cl-30 LOSS OF FLOW TRANSIENTS l l. LICENSE CONDITIONS DESCRIPTION OF ITEM ~ LC-1 GROUNDWATER MONITORING l JNL 4/19/83 1 ? Y -.*q, ,or-4 y v g-y9w
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i i SER ITEMS TARGETED FOR CLOSURE IN SSER #3 (TENTATIVELY SCHEDULED FOR JUNE 1983) 1 l OUTSTANDING ITEMS DESCRIPTION OF ITEMS 01-1 EXPLOSIVE HAZARDS (NATURAL GAS ISSUE) 01-3 TORNADO MISSILE PROTECTION 01-6 ENVIRONMENTAL QUALIFICATION REVIEW (ONLY-NOT SEISMIC PROTION) d i 01-7 NATURAL CIRCULATION COOLDOWN ANALYSIS l 01-8 HPI LINE MAKEUP NOZZLE CRACKNG 01-9 REACTCA VESSEL HEAD VENTS ^ 01-1 0 CONTAINMENT VALVE TESTING-SECONDARY VALVES 01-1 1 CONTAINMENT VALVE TESTING-DHR/RBCWS VALVES 01-1 3 AFW RING HEADER MODIFICATION l 01-1 6 SHUTDOWN DECAY HEAT REMOVAL (3RD AFW i PUNP) l 01-1 7 PUMP AND VALVE OPERABILITY JNL 4/19/83 l y-- w ,,,-py- .----,--y,v-,-.wy-,-,,- .--e,--,-e-.,.e.,ww-w--,v.- ,-.,-.w.,.m -w. , - ~ ..,m-um-,, m m.-- ..-m---
l 3 I ~ SER ITEMS TARGETED FOR CLOSURE IN SSER #3 (TENTATIVELY SCHEDULED FOR JUNE 1983) I CONT'D CONFIRMATORY s ISSUES DESCRfPTION OF ITEMS Cl-1 PMF EFFECTS ON COOlJNG POND DIKE j Cl-4 NDEPENDENT ANALYSIS OF PIPING SYSTEMS i Cl-7 NATURAL CRCULATION TESTING Cl-11 CHARPY DATA FOR WF-70 Cl-12 S/G COMPARTMENT FAN OPENING DATA Cl-14 CONTAINMENT PENETRATION CATEGORIZATION l Cl-15 SETPOINT METHODOLOGY DOCUMENTATION 1 - Cl-17 NON-CLASS 1E INPUTS TO CLASS 1E CONTROL CIRCUITS Cl-18 ECCAS AUXILIARY RELAY TESTING Cl-19 AFW PUMP SUCTION TRANSFER LOGIC l TESTING Cl-20 AFW SYSTEM AUTOMATIC LEVEL CONTROL l Cl-22 COMMON CAUSE CONTROL SYSTEM FAILURES i Cl-23 EVALUATE LOAD SEQUENCER JNL 4/19/83 8* 1 a ,+.,e-m,.,, ~-e-r m... ._s.., 9 - + r-- N y ~ n,- y -me a-w -c-ww.aca--y-e,s.9w eg i,pw,m,vye-s e e m e-w-+m sene---ire-.g+9+- am-,e-e--,-'-- w-a - - - - ---he-*-
e m w %e--He-e~ i SER ITEMS TARGETED FOR CLOSURE IN SSER #3 (TENTATIVELY SCHEDULED FOR JUNE 1983) I CONT'D i CONFIRMATORY - ISSUES DESCRIPTION OF ITEMS Cl-26 INTEGRATE ISEG WITH OTHER SAFETY GROUPS ij Cl-27 PHYSICAL SECURITY AND SAFEGUARDS PLANS .CI-31 RCP LOCKED ROTOR / SHEARED SHAFT W/TT l AND LOOP i i LICENSE l CONDITIONS DESCRIPTION OF ITEMS LC-2 INADEQUATE CORE COOLING INSTRUMENTATION JNL 4/19/83 ,+e ,.. m. w .pp.9 -.,+%. a =,a=. .4 .eme e m*- .-,y. -.,,.r ,,,,..,..,_,,_,e,,,,,m, ,r-..-..,,.-,....~,,m ,m. , _ _,,._,,.,.,,_.,_...- _,.m..-,
[ 3 i SER ITEMS ~ TARGETED FOR CLOSURE AFTER i SSER +3 BUT BEFORE 12/31/83 i i OUTSTANDING ITEMS DESCRIPTION OF ITEMS 01-2 TURBINE MISSILE HAZARD EVALUATION Of-4 RCS/ CORE COMPONENT ANALYSIS ^ I 01-5 NSSS PIPING SEISMIC ANALYSIS .j 01-1 2 APPENDIX R FIRE PROTECTION 01-14 EMERGENCY PREPAREDNESS (DOWNGRADE TO CONFIRMATORY) l 01-15 CONTROL ROOM DESIGN - DCRDR REPORT i JNL 4/19/83 - w-e---e-y- -e-Wm .-e-----p. e m-- . -ve-2 g-r,e-* ,-t-%.-
._L_ a a q b %eA ~ [ SER.lTEMS TARGETED FOR CLOSURE AFTER SSER +3 BUT BEFORE 12/31/82 (CONT'D) 3 CONFIRMATORY ISSUES DESCRIPTION OF ITEMS Cl-2 LOCA AND JET IMPINGEMENT AND STRESS INTENSITIES Cl-6 CODE RELIEF REQUEST I l Cl-16 S/G LEVEL REFERENCE LEG HEATING l ' Cl-24 SYSTEM VOLTAGE TEST Cl-25 TURBINE INSPECTION PROGRAM i Cl-32 SELECTED SOILS SETTLEMENT ISSUES (SIESMIC MARGIN REVIEW, FOUNDATIONS, i CONCRETE CONTAINMENT EVALUATION, OTHER SEISMIC CAT.1 STRUCTURES) l 1 LICENSE CONDITIONS DESCRIPTION OF ITEMS LC-7 CONTROL OF HEAVY L.OADS i LC-8 SECONDARY WATER CHEMISTRY 1 MONITORING AND CONTROL PROGRAM JNL 4/19/83 _......... _ ~ _ w. v.-L --tv e r-e v.,- ,r-wew. -r .-c -3 m-, -.,- - - - -,ew..-ww-,-. +.w-e---e. ..w-~ 44- - -. -. + r .- - -.. - - - - - --+ - -
S i SER ITEMS TARGETED.FOR CLOSURE IN 1984 l OUTSTANDING ITEMS DESCRIPTION OF ITEMS 4 01-6 SEISMIC AND ENVIRONMENTAL QUALIFICATION OF EQUIPMENT (SEISMIC PORTION) l 01-1 4 ~ EMERGENCY PREPAREDNESS l 4 P CONFIRMATORY ISSUES DESCRIPTION OF ITEMS l Cl-21 REMOTE SHUTDOWN OPERATION TESTING P ) 9 JNL 4/19/83 i I f
1 1 . ~ ~ ~ e l a SER ITEMS TARGETED FOR l CLOSURE IN 1984 (CONT'D) f LICENSING t CONDITIONS DESCRIPTION OF ITEMS LC-3 RELIEF / SAFETY / VALVE TESTING (."FL) y LC-4 INSERVICE INSPECTION PROGRAM (PFL) I LC-#E AFW LEVEL CONTROL TEST (PFL) LC-G Pos7 AC.C.1 D ENT.5 AM PL WG LC-9 B&W ON-SHIFT - STARTUP NXPERIENCE l LC-10 EMERGENC
Y. PROCEDURE
S - ATOG 4 LC-11 SMALL BREAK LOCA MODEL (PFL) ~ l PFL - POST FUEL LOAD JNL 4/19/83 ( t 5 l l e -n...-- a me.- r mev-*--e--v-W-w* -r -vw*w-ww-*i-v-+ree-T-, a-wm- --w-w -w-r,Pt n,rw 'twa-"w gr- - -.p3+ -,+mga:.y-e -vp-g--,--aw> p w ww-ygewe--+w ye.e 4e 9-e-,9-+.ew,.4,e. e. i.---9mem , g y>-_p--p-w--
l ) MAJOR NRC SITE VISITS EVENT TENTATIVE TIMEFRAME CONTROL ROOM REVIEW VISIT MAY 1983 t 4 INSTRUMENTATION & CONTROL VISIT 4TH QUARTER 1983 j ELECTRICAL VISIT 4TH QUARTER 1983 i FIRE PROTECTION VISIT 4TH QUARTER 1983 l l SEISMIC QUALIFICATION REVIEW TEAM VISIT 4TH QUARTER 1983 EMERGENCY PLANNING APPRAISAL 2ND QUARTER 1984 i SECURITY VISIT l 3RD QUARTER 1984 EMERGENCY PLANNING EXERCISE 3RD QUARTER 1984 1 1 1 t l l JNL 4/19/83 I e. , - - -,. ~, - -, e -,r, m ,_-a ..,.r,,, .e,,-__.-nm-, re.w,,,. .,e.e,-,--, -, --,eo,~,,}}