ML20091P405
| ML20091P405 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/08/1983 |
| From: | TERA CORP. |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-08, CON-BOX-8, FOIA-84-96 NUDOCS 8406130050 | |
| Download: ML20091P405 (12) | |
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i-I, MIDLAND INDEPENDENT DESIGN VERIFICATION PROGRAM
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i PRESENTATION OUTLINE I
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PROGRAM STATUS l
e INTER-RELATIONSHIP BETWEEN THE DESIGN AND f
CONSTRUCTION PROCESS AND THE MIDLAND IDV i
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PHILOSOPHY OF REVIEW e
BASES FOR SAMPLE SE _ECTION i
e SCOPE OF DESIGN VERIFICATION e
SCOPE OF CONSTRUCTION VERIFICATION e
REPORTING PROCESS -
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e SCHEDULE i
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PROGRAM STATUS i
e PROJECT QUALITY ASSURANCE PLAN j
DEVELOPED, APPROVED, AND UNDER IMPLEMENTATION INCLUDES PROJECT CONTROL PROCEDURES, INSTRUCTIONS AND REPORTING REQUIREMENTS i
l-e ENGINEERING PROGRAM PLAN l
DEVELOPED, APPROVED, AND UNDER IMPLEMENTATION 44 DESIGN TOPICS /5 CATEGORIES OF REVIEW IS CONSTRUCTION TOPICS /S CATEGORIES OF REVIEW e
DESIGN VERIFICATION IN PROGRESS FOR AFW SYSTEM DESIGN CHAIN IDENTIFIED PROJECT EXPERIENCE UNDER REVIEW TO ASSIST IN FOCUSING THE DESIGN VERIFICATION e
CONSTRUCTION VERIFICATION RECENTLY INITIATED INITIAL AS-BUILT CONFIGURATION VERIFICATION FOR PIPING / SUPPORTS NEARING COMPLETION l
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TERA CORPORATION
INTER-RELATIONSHIP BETWEEN THE MIDLAND DESIGN AND CONSTRUCTION PROCESS AND THE MIDLAND IDV PROGRAM I
d-l 10 CFR 50, APPEPCIX A l i
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J e SMP i
e RegCwides F5AR Ato OTPER l
REVIEW OF DE5tCN o bestry UTILITY CRITERIA Ato Stoneerds COMMITMENTS COMMITMINTS a
e N555 Criterie l
DE51CN INPUT 5 l
REvtEW OF 37 IMPLEMENTING A-E.N555 VEtCOR DOCUMENTS ENCNEERING m
IMPLEMENTNG ST Ato ARDS, OOCUMENTS o
g PROCEDURES I
DEllCN PROCE55 e Desi Centrol e E4reeting e GA/
Eveket; ens CtECK OF CONFIRMATORY e Celewletiere CALCULATCNS AND C ALCULATCNS OR 1
EVALUATONS EVALUATCNS 5
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l DESIGN CHANCES l t
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CHECK OF DESIGN OUTPUTS i
DRAWWC5 APC e Ore.%
, 5PECIFIC ATCNS e Specificatiers i
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1f 17 CHECK OF SUPPUER ICY
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l FABRICATIONACT y E5 DOCUMENTATION
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517E CONSTRUCT!(Pd ACTIVlflE5
- Y" e Construction e5 C
Central
,p REVIEW OF STORACE O
e OA/QC e Erection.kutal-Arc MANTENANCE NS I
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M&TATm DOCUMENTATION if l Fifl0 CMANGES l 1r o
VERIFICATION /
INSTALLED 5TRUCTURES.
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OVER.NSPECTION
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SYSTEMS APC VERIFICATION OF.
COMPONENT 5 PHYSICAL l
ACTIVITIES -'
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CONFIGURATION REVIEW OF VERIFICATION ACTivtTIES l
TURNOVER FOR FUNCTCNAl.
TE5TNG H OPERATIONS l
DESIGN AND CONSTRUCTION PROCESS MIDLAND.lDV PROGRAM i
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i GOAL i
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e PROVIDE AN INDEPENDENT EVALUATION OF THE l
GUALITY OF THE MIDLAND PLANT DESIGN AND CON-STRUCTION Il' l
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PHILOSOPHY OF REVIEW SELECT A REPRESENTATIVE SAMPLE OF ENGINEERED SYSTEMS, e
COMPONENTS', AND STRUCTURES WHICH WILL FACILITATE:
AN INTEGRATED ASSESSMENT OF IMPORTANT PARA-I METERS AFFECTING THE FUNCTIONAL CAPABILITY OF THE TWO SYSTEMS, AND THE ABILITY TO EXTRAPOLATE FINDINGS TO SIMI-LARLY DESIGNED FEATURES WITH A HIGH DEGREE OF CONFIDENCE CONSIDER POSITIVE AND NEGATIVE FINDINGS WHICH WILL ALLOW. A e
BALANCED VIEW OF OVERALL QUALITY e
ASSESS ROOT CAUSE AND EXTENT OF IDENTIFIED FINDINGS e
REVIEW CORRECTIVE ACTION TAKEN TO ADDRESS FINDINGS t
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BASES FOR SAMPLE SELECTION i
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SIMILAR TO SYSTEM SELECTION CRITERIA IMPORTANCE TO SAFETY INCLUSION OF DESIGN / CONSTRUCTION INTERFACES l
ABILITY TO EXTRAPOLATE RESULTS
.i DIVERSE IN CONTENT SENSITIVE TO PREVIOUS EXPERIENCE 4,
ABILITY TO TEST AS-BUILT INSTALLATION i
e STRONG RELIANCE UPON ENGINEERING JUDGMENT e
POTENTIAL USE OF STATISTICAL TECHNIQUES TO ESTABLISH SAMPLE SIZE FOR REPETITIVE PRODUCTION ACTIVITIES (E.G., CON-CRETE AND STEEL PROPERTIES, WELDING RECORDS, ETC.)
i e
INDUSTRY DESIGN / CONSTRUCTION EXPERIENCE l
I INDUSTRY OPERATING EXPERIENCE e
e PROJECT DESIGN / CONSTRUCTION EXPERIENCE -
AREAS EXPERIENCING REPEATED PROBLEMS AREAS WHICH MAY NOT HAVE RECEIVED EXTENSIVE PRIOR 5
REVIEW e
AREAS WHERE FINDINGS HAVE BEEN IDENTIFIED l?
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I INITIAL SAMPLE REVIEW MATRIX FOR THE AUXILIARY FEEDWATER SYSTEM j
MIDLAND INDEPENDENT DESIGN VERIFICATION PROGRAM f
SCOPE OF REVIEW i
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L AFW SYSTEM PERFORMANCE REQUIREMENTS X
X X
SYSTEM OPERATING LIMITS ACCIDENT ANALYSl5 CONSIDERATIONS X
X X
X SINGLE FAILURE TECHNICAL SPECIFICATIONS X
X t
SYSTEM ALIGNMENT /SWITCHOVER X
X REMOTE OPERATION AND SHUTDOWN X
SYSTEM ISOLATION / INTERLOCKS X
X OVERPRESSURE PROTECTION X
COMPONENT FUNCTIONAL REQUIREMENTS X
X X
X SYSTEM HYDRAULIC DESIGN X
X X
SYSTEM HEAT REMOVAL CAPABILITY X
X X
COOLING REQUIREMENTS X
WATER SUPPLIES X
X' PRESERVICE TESTING / CAPABILITY FOR OPERATIONAL TESTING X
POWER SUPPLIES X
X ELECTRICAL CHARACTERISTICS X
PROTECTIVE OEVICES/ SETTINGS X
X X-INSTRUMENTATION X
X X
X CONTROL SYSTEMS X
X X
ACTUATION SYSTEMS X
. NDE COMMITMENTS X
MATERIALS SELECTION X
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INITIAL SAMPLE REVIEW MATRIX FOR THE AUXILIARY FEEDWATER SYSTEM MIDLAND INDEPENDENT DESIGN VERIFICATION PROGRAM (CONTINUED)
SCOPE OF REVIEW 1
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II. AFW SYSTEM PROTECTION FEATURES X
SEISMIC DESIGN o PRESSURE BOUNDARY X
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PIPE / EQUIPMENT SUPPORT X
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e EQUIPMENT GUALIFICATION X
X X
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HIGH ENERGY LINE BREAK ACCIDENTS X
e PIPE WHIP X
X X
X e JET IMPINGEMENT X
ENVIRONMENTAL PROTECTION X
ENVIRONMENTAL ENVELOPES X
X X
X X
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e EQUIPMENT QUALIFICAIlON X
X X
X e HVAC DESIGN X
FIRE PROTECTION X
X X
MISSILE PROTECTION X
SYSTEMS INTERACTION X
X X
111. STRUCTURES THAT HOUSE THE AFW SYSTEM SEISMIC DESIGN / INPUT TO EQUIPMENT X
X X
X WIND & TORNADO DESIGN / MISSILE PROTECTION X
FLOOD PROTECTION X
HELBA LOADS X
CIVIL / STRUCTURAL DESIGN CONSIDERATIONS X
e FOUNDATIONS X
X X
e CONCRETE / STEEL DESIGN X
X X
X e TA*S X
X X
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INITIAL SAMPLE REVIEW MATRIX FOR THE AUXILIARY FEEDWATER SYSTEM MIDLAND INDEPENDENT DESIGN VERIFICATION PROGRAM SCOPE OF REVIEW r!
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MECHANICAL e EQUIPMENT X
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X X
e PIPING X
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X PIPE SUPPORTS X
X X
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e EQUIPMENT X
X X
X X
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e TRAYS AND SUPPORTS X
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CONDUlT ANDSUPPORTS X
e e CABLE X
X X
X X
I I!!. INSTRUMENTATlON AND CONTROL e INSTRUMENTS X
X X
X X
e PIPING / TUBING X
X e CABLE X
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X X
X X
e DUCTS AND SUPPORTS X
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STRUCTURAL e FOUNDATIONS X
X o CONCRETE X
X X
STRUCTURAL STEEL-X X
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l SCOPE OF CONSTRUCTION VERIFICATION REVIEW i
e REVIEW OF SUPPLIER DOCUMENTATION SAMPLING CHECK AGAINST DESIGN SPECS AND DRAWINGS; l
REVIEW OF i
DR'AWINGS i
j TEST REPORTS l
CERTIFIED MATERIAL PROPERTY REPORTS STORAGE AND INSTALLATION REQUIREMENTS OPERATION AND MAINTENANCE REQUIREMENTS I
e REVIEW OF STORAGE AND MAINTENANCE DOCUMENTATION RECEIPT INSPECTION DOCUMENTATION STORAGE, INCLUDING IN-STORAGE AND IN-PLACE MAINTE-NANCE REQUIREMENTS INCLUDING PARAMETERS SUCH AS TEM-
- PERATURE, HUMIDITY, CLEANLINESS, LUBRICATION, ENERGlZATION, ETC.
- OBSERVATION OF ON-GOING ACTIVITIES e
REVIEW OF CONSTRUCTION / INSTALLATION DOCUMENTATION IMPLEMENTATION OF PROPER REQUIREMENTS SUCH AS EREC-TION SPECIFICATIONS, INSTALLATION REQUIREMENTS, CON-STRUCTION PROCEDURES, CODES AND STANDARDS, ETC.
REVIEW OF DESIGN CHANGES, FIELD MODIFICATIONS, ETC.
EVALUATION OF DOCUMENTATION FOR ITEMS SUCH AS CON-l CRETE, WELDING, BOLTING ACTIVITIES, ETC.
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SCOPE OF CONSTRUCTION VERIFICATION REVIEW (continued)
OBSERVATION OF ON-GOING CONSTRUCTION ACTIVITIES i
e REVIEW OF SELECTED VERIFICATION ACTIVITIES CABLE SEPARATION, PIPE SUPPORT, AND BOLTING OVER-
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INSPECTION PROGRAMS, ETC.
OBSERVATION OF VARIOUS WALKDOWN ACTIVITIES (E.G.,
SYSTEMS INTERACTION - SEISMIC 11/l)
COLD HYDROS COMPONENT AND SYSTEM FUNCTIONAL TESTING PROGRAMS CONSTRUCTION COMPLETION PROGRAM VERIFICATON OF PHYSICAL CONFIGURATION e
INSTALLATION OF SYSTEM IN ACCORDANCE WITH PIPING AND INSTRUMENTATION DIAGRAMS i
INSTALLATION OF COMPONENTS AND PIPING IN ACCORDANCE WITH ARRANGEMENT DRAWINGS AND ISOMETRICS (APPROXI-MATE LOCATION AND'ORIENTATidN)
INSPECTION OF SELECTED FEATURES FOR COMPLIANCE WITH DESIGN DETAILS (APPROXIMATE DIMENSIONS)
VERIFICATION OF IDENTITY (EGUIPMENT PART NUMBERS, ETC.)
IN ACCORDNACE WITH DRAWINGS, SPECIFICATIONS, OR SCHE-MATICS l
.l GUALITY OF WORKMANSHIP t
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TERA CORPORATION
ANALYSIS of I
CONSUMERS POWER COMPANY'S PROPOSED CONSTRUCTION COMPLETION PLAN By the GOVERNMENT ACCOUNTABILITY PROJECT CITIZENS CLINIC l
On behalf of the LONE TREE COUNCIL Presented to the NUCLEAR REGULATORY COMMISSION i
AT MIDLAND, MICHIGAN February 8,1983 4
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Prepared by:
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Billie Pirner Garde, Director Citizens Clinic Thomas Devine, Legal Director Marya C. Young, Investigative Staff Govemment Accountability Project of the Institute for Policy Studies i
1901 Que Street, N. W.
- Washington, D. C. 20009
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I On behalf of the Lone Tree Council and concerned Michigan citizens and nuclear workers, the Government Accountability Project (GAP) recommends that the Nuclear l
Regulatory Commission (NBC or Commission):
- 1) withhold approval of the Corstruction Completion Plan (CCP) proposed by f, Consumers Power Company (Consun ers) for the Midland Nuclear Power Plant until the Commission discloses the quality assurance (QA) violations that made the CCP i
necessary;
- 2) restructure the multiple proposed audits / third-party reviews into one comprehensive independent third-party review;
- 3) require a separate public meeting to deal specifically with the specific metho-dology and procedures to be used in the third-party review;
- 4) modify the Construction Permit to maintain suspension of all safety-related I
work until tne entire third-party review program, including but not limited to third-k party selection, scope, procedures and other methodological considerations, is approved and incorporated into the Construction Permit;
- 5) request Consumers to release the new cost and projected completion date
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estimates; and
- 6) immediately halt the ongoing soils work until the quality assurance implemen-
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tation auditor is approved.
I.
BACKGROUND The Government Accountability Project is 'a project of the Institute for Policy Studies (IPS), Washington, D.C. The purpose of GAP's three clinics -- Federal.
Government Clinic, Citizens Clinic and Nuclear Clinic --is to broaden the understanding of the vital role of the public employee, private citizen and nuclear worker, respectively, in preventing waste, corruption or health and safety concerns. GAP also offers legal and strategic counsel to whistleblowers, provides a unique legal education for law student interns, brings meaningful and significant reform to the government workplace, and exposes government actions that are repressive, wasteful or illegal, or that pose a threat to the health and safety of the American public. ' Presently, GAP provides a
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~s program of multi-levei assi '%,de for governinent empiqyees.,ritizems and corporate X
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.r employees wl.o report illegal, wasteful or improper actions.; GAP alto regularly monitors governmental reforms, offera expertise to Executive Branch offices ~and agencies, and state l
l and local governmental bodies, and responds to requests by Congress and state legislatures i
l for analysis of lagialation to make government more accountable to.the public, In March 19 2, GAP's Citizens Clinic became actively inuly%
ed with the Midland 3
x Nuclear Power Plant. The.Lont -Tree Council asked GAP to pursue alleghtlons'from
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workers of mt.Jor problemqt th a Midland plant. After our preliminary investigatloc, we a-s s
j compiled. pix affidavits which we filed with the NRC on June 29, 1982 Slace' then we have filed four additional affidavit.4 rehlting from the heating / ventilation / ale co3 itloping (IIVAC) d s
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system's quality assurance break;ovn revel,ations. - We are also preparing'an a spanded _
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.affidnvit from'nrfe of bur original vittiesses, Mr. E. Earl Kent, who_ has alleged seri_og a
yeldinz construction nroblems at - he MidlanLg11.c. Other alarm)ng allegattuns, rangqig
. 3 from securitylystem breakdowns to worker,,aarety problems, have come to our attention recently. As a result, we have erpnnrfod our investigation of the kidgid plant.
In Oc%ber and November 1982, GAP participatedJ.n two other public rneetings at NRC offices lhethesda, Marylagt.
- These meetings dealtzith Corrumers' pr posalg to n
the NRC Staff on a soils remedial construction implemen'fdon audit and,an indepehdent i
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review pr,ogr$hl th4 was to assure the Staff of construction qu,alft'ytind the j'as-built" condition 'of the facilityr GAP stiutnitted its analysis of the.Septeuther 17 arvi October 5 proposals ik October 27 and Nolen be 11lett,ets, respectiv$ly h GAP,l'omnients re-vealed substantial weaknedses in the programd, inadequate Wocointidtodpdge program
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cdequacy, and basic lack ofindepend?nce of the proposed mainjadepayent review con-N 1
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Followitig those meetings, $he '.3RC Staff--Ql) 5dseted4 14anagenynt Analysis
(\\i, Corporation g.fAC[due to laci ind!pehdence; (2(, req [tcete(that the Ter'ra Corporation
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review a s)ctgiftIf ty system in its' brtical sllee" pla 4rodested expansion otthe
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review of the "as-built"j ondition of the plant; and (4) fail (d to take a position on the Stone
& Webster a,udit of soll thrpinning work'.
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In Inte Novemberdhe NRC Region III,Spectal Secti" fon the Midland plant completed p
s an extensive inspectGd"6f the' hardware and material 'In the n,u. clear plant's dieseliene z,
l rator building.. Accud fqto NRC public statements, 'tliisjn6pdction revealed major
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problems related to the quality assurance of the plant and included an extensive backlog i
of quality assurance / quality control documentation,' inability to provide materials trace-ability, unqualilled and/or uncertified welders, and other serious problems.
Yet, in spite.of the major revelations df inadequate construction practices, in late 9
g December,thg NQRStaff permitted soils remedial work to begin., It is GAP's position, well known to the Staff, that this premature approval violates the June 1982 request of the Advisory Committee on Reactor Safeguards (ACES) to NRC Chairman Nunzio Palladino.
The June 8 letter further states that ACRS would defer its own " recommendation regarding l
operation at full power until we have had the opportunity to review the plan for an audit of plant quality...." This assessment, according to the letter, should include "... Midland's design adequacy and construction quality with emphasis on installed electrical, control, and mechanical equipment as well as piping and foundation... design and construction problems, their disposition, and the overall effectiveness of the effort to assure appropriate quality. "
Finally, in the past two months GAP has continued its attempt to determine the seriousness of the situation and the adequacy of proposed solutions for the Midland plant.
Our efforts at working with the Office of Inspection and Enforcement (IE) and Office of Investigation (OI) staffs have been frustrating.. For example, although NRC letters and public presentations responding to GAP's October 22 and November 11 requests were informative, they failed to provide the key methodology necessary to assess the adequacy of the program. When GAP investigators attempted to pursue the questions at the public meeting, they were told "to allow the NRC time to ask for those documents." (NRC Public l
. Meeting, Bethesda, Maryland, November 5,1982.) Subsequently, GAP repeated the request l
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q,i in its November 11 letter. Over two-and-one-half months after the original request, G AP dth' finally received the NRC's response: "You may wish to request access to the documents
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f ii from Consumers Power." (December 14,1982 letter fr'om James G. Keppler to Billie L Garde.)
It is clear that the NRC Staff plans to evade or ignore public requests for the minimum information necessary to complete a responsible review of the proposed independent audit.
Our experiences at the William H. Zimmer plant in Ohio and at the LaSalle plant in Illinois have led us to be extremely skeptical of the NRC Staff's conclusions about the safety of nuclear power plants. In those cases the Staff either deliberately covered up or i
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missed major QA violationi's+ niants 97% and 100% complete, respectively. T6 illustrato,
.l after the Staff virtually ig. aced GAP an9 lysis and granted appreval lbr full power operations i
at LaSalle, the plant was able tefoperpte for lesh than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before beir,g shutdown due to a hardware broAdown. At Ziremer, the Staff-epproved Quality Confirmation Plan was :
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so ineffectige that on Novembar 12,1982 the Commission suspended all kafety-related constructier
- :'n As a result,' ther'e is o bista for confidence in an NRC-ajpror_ed CCP on faith.
l The basis for this e:ttraorc.' ark remedy must be full disclosed s,s well as'ihe methodology for an independent review. It order to accomplish this goal,jhr Regingal_A_dmIn!strator should be suspending all conbruc) ton until the above recommendations (lafra, at 1) are incorpot sted into the Construction PermiC" 3
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7 II. GROUNDS FOR SUSPENSION OF A CONSTRUCTION PER31IT,
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Legal Requiremenks. <;
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The 1sw gives the doinmission broad discretion to" revoke, auspend or1 modify the I
construction permit n NRC licenshe.
2 U. S.
. $5236 states that:--
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" : A, license or ccustruction permit may be revoked, suspended or modified.in whole or In'part, for shy material false stafement to the
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l applldatf(n f6r license or in the pupplemental or other sta}ement of
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fact requirrid'by th~e applicant; or he'cause of conditions rev'ealed by~
', tl.e application for licsuse or_ststemept pf fpet or any repart, record. -
v,snection, or other means wh"! chb. uldbarr. ant the Commission' to.
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^, refuse:to grant a lic'ense on an original s, plic9 tion; or for failure to y
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f construct or opernea a fdeility in eccdr;iars03vith'the terms of the !
I construction permit or,licetise or the technicM. specifications in the appil'anttor,; or for thiviolation Offd failure to obseive.anyif the
'termsind provisions of this chip $r"or df snyhgulation'of the Commission.
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Part 50.100 of Title 10 of the Code of Federal Regulations states ~the same criteria for m
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' the revocaliad,2 suspension or modifi$at!on cFa construction permit.
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The FRChhs a mandstory dutyp,ssercise this authority when tiscessary. (According.
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w to the decision'in Natural Resources Defens4 Council v. U.S. Nuclear Replatory Comints-er-
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e r s-o e!cn, 582 P.2d IE l14 ~4r, d;;78), 'under the Atomic Energy'Act of 1054," the NRC is
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required'to'detcrmino this tbdre%iRbe adequate protection of the health an3 safsty of the
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.public. ; T!ps.ede of sagg) t be resolvedgfoy the Commi_ssion issues' a con n-
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permit;. (PortenCty. Ch~. cf Iznak Walton League v. AtomicIncrgy Commission,I
- 515 F.2d
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513, 524 (7th Cir.1975).)
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I B. Criteria to Exercise Discretion According to 10 C.F.R. 52.202, the NRC "may institute a proceeding to modify, g
suspend, or revoke a license or for such other action as may be proper by serving on the licensee an order to show cause which will: (1) allege the violations with which the licensee is charged, or the potentially hazardous conditions or other facts deemed to be sufficient ground fur the proposed action." As interpreted by the Proposed General Statement of Policy and Procedure for Enforcement Actions, published in the Federal Register, 44 Fed.
R_eg. 66754, Oct. 7,1980 (10 C.F.R.fl2.202, 2.204), suspending orders can be used to remove a threat to the public health and safety, the common defense and securityor the environment. More specifically, suspension orders can be issued to stop facility con-struction when further work would preclude or significantly hinder the identification and correction of an improperly constructed safety-related system or component; or if the licensee's quality assurance program implementation is not adequate and effective to provide confidence that construction activities are being properly carried out. Moreover, orders can be issued when the licensee has not responded adequately to other enforcement action or when the licensee interfores with the conduct of an inspection or investigation or for any reason not mentioned above for which license revocation is legally authorized. In order to i
help determine the significance of violations within this list, the Commission established
" severity categories" ranging from the most fundamental structural flaws (Severity I), to minor ted.atcalities (Severity VI). 44 Fed.R_e_g, at 66758-59.
Region III's enforc'ement criteria are consistent with these guidelines. For example, in a February 26,1981 meeting on the Zimmer plant, Regional Administrator Keppler explained that if there is faulty construction and the program to control the problem is j
inadequate, there is no choice but to stop the project. This criterion was illustrated through the example of an across-the-board breakdown in a quality assurance program.
(February 26,1981 Transcript of Taped Meeting Between Members of the Region III Staff.
and Representative of the Government Accountability Project and Mr. Thomas Applegate,
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at 127,129.)
C.
Specific Bases for Suspension
'I The Region III Staff has characterized the problems at Midland as both extremalv_ $
, Detroit Free Press,.
serious and directly relating to a quality assurance breakdown.
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December 5,1982.)
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In light of two previous amendments to Mr. Keppler's testimony before the Atomic Safety and Licensing Board and a pending third revision, it is apparent that the only course 4
of action available to the NRC is to modify the construction permit now, before construction
- resumes, i
- 1. Safety-related defects GAP's review of inspection reports, interviews with nuclear workers, and review of j
the ASLB hearing testimony reveals an historical pattern of increasingly significant safety-related problems at Midland, including failures to comply with the law and NRC regulations, as well as to correct past non-compliances.
j Although the GAP investigation and analysis of NRC records is far from complete, j
significant threats to the safety of the MMland plant include the following:
l
- a. Welder quallfication 4
10 C.F.R. 50, Appendix B, Criterion IX requires--
Measures shall be es.tablished to assure that special processes, including welding, heat treating, and nondestructive testing, are j
controlled and accomplished by quallfled personnel using quellfled procedures in accordance with applicable codes, standards, spect-fications, criteria, and other special requirements.
At Midland welder qualification problems are well known to the public. On December 2, j
1982 Consumers laid off all of the welders of the Zack Company. They were trained by a i
vendor, l hoton Testing, that was not NRC-approved. Although Consumers has publicly characterized this as "only a paper work problem" (Norman Saari to local NBC Channel 5 television, January 1982),. it remains a serious unanswered question about the Midland plant. Until the public knows the extent of " uncertified / unqualified welders, it is virtuallv impossible to datarmine the adequacy of any plan -- short of a 100% reinspection of all unqualified welds performed by welders whose qualifications have not been verified.
2.-. Documentation and care of welding equipment As seen above, Criterion IX requires careful verified maintenance of welding equipment. For example, portable ovens,~'or." caddies," must be plugged in at all times,,
, except during transport to and from the rod sh'ack. Affidavits submitted by G AP in June
- l; reveal serious problems with welding equipment,; welding rods, and a failure ~to comply t
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with either e cofessional codes or NRC requirements.
i In fact, the NBC's own report into the initial Zack allegations confirmed that the welding rods had not been adequately controlled by attendants. Attendants did not even know that'the weld rods were to be heated. At least one caddy was slightly warm and another "relatively cold." The ovens apparently had been unplugged for "quite a while."
The QC inspector also found welding equipment that was uncalibrated. /
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Inadequate corrective action for welding violations Of course, once violations are identified, the utility is legally obligated to, correct i
them. 10 C.F.B. 50, Appendix B, Criterion XVI, requires, in part--
f Measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly
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j identu.ed and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
It is all too clear that Cons.umers did not take seriously the $38,000 fine for identified Zack deficiencies or the order to ensure compliance with the law. The December 1982
-l Zack welder lay-off may be prophetic of what the public can expect if Consumers is put in charge of the plant's completion, i
4 Electrical cables i
10 C.F.R. 50, Appendix B, Criterion XV requires--
Measures shall be established to control materials,' parts, or components which do not conform to requirements in order to pre-vent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documen-tation, segregation, disposition, and notification to affected or-ganizations. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures.
GAP witnesses revealed widespread inaccuracies in the use of electrical cables critical to safe operation of the plant, and shutdown in case of an accident.' In September 1982 the NRC ordered 100% reinspection of all cables on site. Currently, the public has
'l no idea how many nonconforming cables are being found on site. Witnesses inside the plant have reported to GAP that only a small percentage of those discovered are being i
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- NRC Region III investigation into allegations of Mr. Dean Darty, March 1979.
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reported. In one affidavit, a witnessereported that others have been replaced without documentation.
The violations summarized above provide only a few examples of the suspect safety corsponents at Midland. Other whisticblowing disclosures to Region III referred to welding standards below ASME specifications; undersized welds; anchor bolts improperly installed; excessive weight on electrical conduits; hollow walls; corrosion in the small bore piping; unapproved design modifications; and other safety defects.
Even if management systems and security measures were sound, the physical i
deficiencies already documented at Midland justify a suspension of construction. Before i
j permitting work to continue, the Commission should thoroughly assess the damage through independent tests; monitor the results of a comprehensive, independent audits; and modify the construction permit to include the changes.
l D.
Quality Assurance A licensee's quality assurance program is its internal structure of checks and balances to guarantee safe operations. Every applicant for a construction permit is re-quired by the provisions of10 C.F.R. 550.34 to include in its preliminary safety analysis j
report a description of the quality assurance program to be applied to the design, fabri-l cation, construction and testing of the structures, systems and components of the facility.
Quality assurance comprises all those planned and systematic actions necessary to provide l
adequate confidence that a st ructure, system or component will perform satisfactorily in a
service. Each structure, system or component must be documented, inspected and.
periodically audited to verify compliance with all aspects of the quality assurance program.
The cause of the safety defects described above is an inadequate quality assurance i
program, which has been in shambles for a decade. In fact, in 1973 the original Midland I
licensing appeal board members felt so strongly about QA violations that the Director of I.
Regulations pointed out that even though the Appeals Board'could not take action on the IE findings--
[H),ad the construction permit' proceeding still been before our Board l-at the time that the results of the November 6-8 inspection were on-nounced, it is a virtual certainty th'at we would have ordered forth-l 3
l with a cessation of all constraction activities.....
(November 26,' 1973 Letter from L. Manning Muntzing, Director of Regulations, re:
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- Quality Assurance Deficle1cies Encountered at Midland Facility, p. 2.)
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i The 1973 warning should have served as notice to both Bechtel and Consumers Power t
j to resolve their QA problems. Quite the contrary, however, they ignored the notice. So did the NRC Staff' The OA problems at. Midland continued unabated.
Both the 1979 and 1980 Systematic Assessment of Licensee Performance 'SALP) l reports give notice of further and expanded problems at Midland. The problems identified 3
then (lack of qualifications of QC inspectors, continuation of work prior to corrective action) are similar to those cited as causes in the recent stop-work order. The reports also included acknowledgements of excessive QA backlogs and lack of timeliness. (SALP Report 1980.) Consumers' failure to learn from its mistakes passed the stage of accidental oversight long ago.
The lack of quality assurance at Midland has been a continuous concern to Region III.
l In the spring of1982 at the release of the 1981 SALP rating, Mr. Keppler publicly reported ij that it was necessary to change previous testimony before the ASLE
- h had provided a
" reasonable assurance" that the plant would be constructed in accordance with nuclear construction regulations. The revised testimony was submitted October 27,1982
/lthough the original testimony was not m'odified substantially, it is clear that QA problems at Midland are unresolved, f
Unfortunately, the Region III Staff seems satisfied with the basis upon which the Construction Completion Plan is developed: put Consumers in charge of the program, t
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The public already has had an opportunity.to preview the results of Consumers' r
l internal policy with the Zack debacle ove'r the past three years. Its performance has been disappointing, at most.
Although the NRC fined Consumers $38,000 for Zack's non-compliance with federal-regulations and forced a major QA reorganization, further actions by the utility revealed -
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a determina tion to hide problems -- regardless of the consequences. In _ fact, a Decem-i ber 22,1982 NRC report about the revelations of a quality assurance breakdown at Zack headquarters acknowledges the role that Consumers played.in the response to,the 1979 '
citation:
On September 2,- 1981,.the services of a Senior Quality Assurance Engineer'from Project' Assistance Corporation (consultants) were retained by Consumers Power Company for assignment at Zack for the purposes of establishing a' formal dooument control system
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and performing an indapth review of the conditions described by '
- j Zack in their September letter (Zack notified Consumers of (a]
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10 CFR 50.55(e) on August 28,~ 1981).
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, Consumers Power Company, unlike the two other utilities receiving materials from Zack, j
did not notify the NRC about the major problems in QA documentations. Those problems included falsified and altered documentation.
This example of the utility's response to the discovery of any major problems com-pletely undermines the assumption upon which the Construction Completion Plan is based --
voluntary disclosure of QA violations. This assumption is both historically inaccurate and structurally flawed.
j D. Maximizing Human Errors i
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" Human error" recently has been recognized as the Achilles Heel of even the most i
well-constructed plants. At Midland the phrase " comedy of human errors"would be more i
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appropriate if the potential consequences were not so disastrous.
l A key cause of human error is intoxication, which the NRC recognized last summer in proposed fitness-for-duty regulations. Our disclosures have reported widespread drunkenness on the job. Witness siter witness has confirmed the routine of red-eyed employees who did their work under the handicap of an alcoholic stupor. Witnesses have l
also confirmed the frequent use of marijuana and stronger drugs. Intoxication weakens j
the capacity to install safety components,just as it debilitates the ability to drive or to 1
i engage in almost any other activity. At a minimum, the widespread use of drugs and I
liquor on-the-job increases the significance of a superficial quality control program.
l There are likely to be more defects ' A nuclear plant constructed by drunken employees is likely to stagger into an accident.
HI, RESTRUCTURE THE MULTIPLE AUDIT / THIRD-PARTY R EVIEWS
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INTO ONE COMPREHENSIVE. INDEPENDENT REVIEW In October and November 1982, two meetings were held to review Consumers proposed resolution for major quality assurance problems. These proposals and subsequent com-ments provided by GAP were made prior to completion of the major NRC inspection in
- November. Presumably, the audit suggested in the Construction Completion Plan (see i.
l CCP, at 16 and Figure 1.1) will incorporate those audits already discussed last fall.
l However, the CCP as proposed falls to resolve basic third-party review questions.
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The CCP states: "This sect!on describes third party evaluations that have been f
performed and are planned to assess the effectiveness of design and construction activity implementation." Yet, closer scrutiny of the proposal shows that it falls to include even the most basic information about the promised third-party review. In fact, although the CCP states that an INPO evaluation has been completed, there is no indication of what that i
report revealed.
I Most significant, the entire CCP is premature until all the third parties eventually chosen have completed their evalustions. The point of the third-party reviews is to define the QA violations.and deficiencies at \\lidland. By rushing into the CCP before that process has begun in some areas, the utility is putting the cart before the horse. In effect, the utility's CCP is competing with the third-party program. At best, the two " reforms" will be operating simultaneously, stumbling over each other. Depending on the results of the
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l outside reviews, CCP work may have to be redone -- consistent with the costly tradition f
at Midland of doing the same work over and over.
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A. The INPO Construction Evaluation This evaluation is limited by definition. It is only a "self-initiated evaluation."
Neither the NRC nor GAP found the Management Analysts Corporation (MAC) adequately independent to provide a truly independent review of the problems at Midland. In fact, they f
have been involved in at least two other major audits of the plant -- neither of which turned j
up any of the significant construction deficiencies now facing Consumers.
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A December 14,1982 Region IIIletter to GAP underscored the NRC position on MAC:
The INPO and biennial QA sudit are not an acceptable substitute for the third party review.... Questions were raised concerning whether r
Management Analysis Company was sufficiently independent to assume t
lead responsibility for the independent review.
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Although the MAC analysis may have provided a tool for Consumers to judge the quality of the plant, it simply is not an independent third-party evaluation. Instead, it was a test ofINPO's ability to assess the "as-built" condition of the plant. Its adequacy is completely unknown, because the public does not even know if the INPO evaluation discovered the same
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Saws that the NRC found in its inspection.
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. B. The Independent Construction Overview This is the " meat" of the third-party review plan, yet it remains an ambiguous promise from Consumers to the NRC. Although the schedule (CCP, at 18) indicates that the scope has been defined and the consultant selected, this information has not yet been j
shared with the ptblic. Until and unless the scope of the third-party review has been defined and the audit contractor selected, it is premature to make any judgments on the role and adequacy of the third-party review. Further, it is clearly inappropriate to indi-cate that a legitimate third-party review has been in place from the beginning of this l
reform effort,,as Figure 1-1 suggests.
I At Diablo Canyon the Commission set out very clear criteria by which an independent auditor would be chosen. / At Zimmer GAP and the NRC are currently embroiled 11 a debate over the application of these guidelines in the selection of Bechtel for that role.
At Midland we again request that the NBC reestablish the fading legitimacy of the Commission's third-party reform efforts by requiring Consumers to provide the details of the selection process, the identification of the third party and the methodology by which it will accomplish its review.
We are alarmed that even in the sketchy details provided in the CCP, the proposed third-party review is only to be conducted for six months, " top management" will deter-mine "what modification, if any, should be made to the consultant's scope of work." At e i
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minimum, the NRCsshould recognize that any Construction Completion Plan must be based on the results of completed third-party findings, as well as an ongoing commitment for the duration of the project. The third-party review program must provide a comprehensive view of the as-built condition of the plant, and an independent assessment of all future construction. Nothing less will provide the public with any assurance that the Midland plant can operate safely, s
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- In a letter of February 1,1982, Cha.rman Palladino explained to Congressmen Dingell and Ottinger the criteria according to which an independent auditor would be chosen at Diablo Canyon:
l (1) Competence: Competence must be based on knowledge of and experience l
with the matters under review.
(2) Independence : " Independence means that the individuals or companies selected must be able to provide an objective, dispassionate technical judgment, provided solely on the basis of technical merit. Independence also means that the design verification program must be conducted by companies or individuals not previously involved with the activities...they will now be reviewing."
(3) Integrity : "Their integrity must be such that they are regarded as respectable companies or individuals."
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. C.
The Independent Design Verification (IDV) i The Tera Corporation already is conducting the " vertical slice" of the project.
Because the auxiliary feedwater system selected by Tera has already been the subject of I
numerous audits, GAP suggested that it is not representative of potential problems at Midland. The NRC agreed and ratuired Tera to review a second system.
Although that system has not yet been selected, we understand that Consumers has nominated three systems for review, of which one willbe chosen by the NRC. Since October 22, GAP has recommended that the second system should be a safety aystem with a history of QA violations. Specifically GAP suggested the HVAC system. Certainly l
if the CCP's third-party review is to determine the plant's safety, it thould be able to account for the most troubled systems.
In Mr. Keppler's October 12,1982 letter to Billie Garde, he agreed with that j
position:
I My decision regarding the independent audit of Zack work at Midland will be based on findings of[NRC inspections] and the licensee's third party independent assessments.
The fragmented and overlapping approach of the NBC, the utility and the " Independent" i
auditors is self-defeating. It must stop, if Midland is to progress from a theoretical design to an operating plant. A truly independent, objective review must first be completed. Only then can a CCP begin to operate legitimately, with ongoing oversight from the outside auditors and the NRC.
IV. HEJECT CONSUMERS' CONSTRUCTION COMPLETION PLAN i.
On April 8,1981 Region III management overruled its investigative staff's recom-mendations to suspend construction at the William H. Zimmer Nuclear Power Station near Cincinnati, Ohio. Instead, the NRC lasued an Immediate Action Letter which, inter al's,
required the Cincinnati Gas & Electric Company to develop a. Quality Confirmation Program q
(QCP). On November 12,1982 the utter failure of the QCP forced the Commissioners to suspend all safety-related construction at Zimmer. Unfortunately, the Construction t
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j jf Completion Plan proposed for Midland bears a striking resemblance to the key flaws that doomed the QCP. In some cases, the CCP exacerbates the painful mistakes of Zimmer.
More specifically, the Construction Completion Plan--(a) is permeated by an inherent confilet-of-interest; (b) institutionalizes a lack of organizational freedom for the l
quality assurance department; (c) fails to specify inspection procedures and evaluation criteria; and (d) is not comprehensive, k
A.
Inherent Conflict of Interest The foundation of the CCP is to complete " integration of the Bechtel OC function into the Midland Project Quality Assurance Department (MPQAD) under Consumers Power Company management...." (CCP Executive Summary, at 3.)
Since Consumers has always played a significant role in the MPOAD, in effect the
" reform" calls for the utility to second-guess its own previous decisions. This is the equivalent of the fox offering to do a better job of guarding the henhouse. If anything, the CCP intensifies the conflicts of interest in the QCP.
At Zimmer the utility only imposed quality assurance violations clandestinely; at Midland the utility has openly participated ir.
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decisions to break the law, t
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Lack of Organizational Freedom for the Quality Assurance Department j
The organizational premise of the CCP is a " team" concept that integrates construction, engineering and quality assurance personnel. The " team manbers will be physically located together to the extent practicable...." Although' the proposal does not specify the identity of Team Supervisors, there is only one MPQAD representative among six specified in the plan. (CCP, at 8.)
The CCP supposedly is the reform to compensate for a quality assurance breakdown.
Unfortunately, the plan would violate the criteria of 10 C.F.R. 50, Appendix B, Criterion !
' even for a healthy nuclear construction organization. The regulations require organizational freedom for QA functions. The QA department is required by law to serve as an independent check and balance on the construction program. The CCP turns that premise on its head by reducing OA representatives to a token minority on construction-dominated " teams."
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C. Failure to Specify Inspection Procedures and Evaluation Criteria The proposal promises to develop and revise the procedures that will be used to conduct the reinspections. (CCP, at 8-9,12.) Neither the procedures nor the evaluation criteria for the inspections are specified, beyond vague references to professional codes.
l This issue is the heart of the quality verification program. Unfortunately, at present the methodology of the program is a mystery. As a result, it is impossible to judge whether the CCP will represent a thorough reinspection or a superficial skimming. Further, the necessity to establish new QC procedures casts a shadow over all the current inspection procedures.
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Lack of Comprehensiveness CCP reinspections will only cover " accessible" completed construction, an undefined
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term. " Inaccessible" items will be handled by paperwork reviews. (CCP, at 10.) Further.
the proposal defines-out from coverage "[t] hose activities that have demonstrated effective-ness in the Quality Program implementation...." (Id_., at 20.) Included in this latter category are activities such as "HVAC Installation work being performed by Zack Company,"
and "[rlemedial[sloils work which is proceeding as authorized by NRC."
This piecemeal approach effectively surrenders any pretentions that the CCP will provide a definitive answer to the Midland QA problems, even if the program were other-wise legitimate. To illustrate, the necessity for the reinspections in the first place is the inaccuracy of current quality records. Paperwork reviews will not contribute anything new.
The list of systems that have " demonstrated" quality effectiveness suggests the utility has completely lost touch with reality, or expects that the NRC Staff and the public have taken leave of their senses. Both the Zack HVAC and soils remedial work have been among the most scandal-ridden embarrassments of the Midland project. The crude
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deficiencies and violations have led to fines, multiple criminal investigations, and public humiliation for Ct.,nsumers. The utility has only been able to continue soils remedial work by manipulating the public hearing process to circumvent NRC Staff enforcement orders. The list of " proven" systems proves only that Consumers is determined to I
impose the same nightmare on Midland that the Quality Confirmation Program represented f
at Zimmer. Hopefully, the NRC Staff will not be fooled again.
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' D.
Flaws in the CCP Program Implementation and Quality Program Review By their terms, Section 5 (Program Implementation) and Section 6 (Ouality Program Review) indicate that the CCP simply reflects the " status quo" attitude of Midland's management that propelled Consumers into this particular construction / regulation night-mare in the Srst place.
Although the CCP proposal is premature, inadequate, and fatally flawed, the language of the proposal reveals that management believes the Midland plant's OA program is
" basically sound" (CCP, at 15), even in the face of deliberations by legal and advisory bodies on Consumers' ability to adequately implement any OA plan, no matter how sound.
The amount of management influence and interference has already been a subject of j
NRC concern. (See NRC Memorandum from C. E. Norelius and R. L. Spessard to James i
E. Keppler, June 21, 1982.) Yet, the CCP proposes as an answer to increase management
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involvement at every step of the implementation process (CCP, at 13-15). Farther, the l
implementation falls to refer to how the inevitable conflicts between management officials
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watching the calendar and conscientious QA officials trying to do their jobs will be resolved.
The only clue that GAP has as to how Consumers plans to change the mindset of its i
demoralized workers is the Quality Improvement Plan (QIP) mentioned extensively in the fall proposals. This plan, referred to as the catalyst for ensuring new commitment and l
compliance to quality standards on the Midland site, is, according to the NRC officials familiar with it, on incentive-bonus concept for construction workers who "do the job L
Like the right the first time." (NBC-GAP Telephone Conversation, January 27, 1983.)_
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Bechtel cost-plus contract, the Quality Improvement Plant is a series of rewards for d
_doing the same job a worker was hired to do right in the first place. A quality improvement plan that bases critical construction adequacy on " prizes"_ given to its workers reveals a l
serious misunderstanding on the part of Consumers about the ultimate value of its work.
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V. - IMMEDIATELY HALT THE ONGOING SOILS WORK UNTIL THE l
QUALITY ASSURANCE IMPLEMENTATICE AUDITOR IS APPROVED Two significant milestones in the soils work have now been approved to proceed
. underneath the turbine building. This Staff approval is entirely inappropriate given the i
legal and advisory controversy over this operation. It is inexcusable to allow work to g
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1 proceed without the independent audit upon which Mr. Keppler based his " reasonable I
assurance" testimony (October 27,1982 Testimony to the Midland ASLB), and upon which I
the ACRS is depending to complete their own technical assessment before granting a full power license. Further, in light of administrative hearings which cover the adequacy of r
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the soils quality assurance implementation (OM Proceedings), the NRC Staff approval is l
an insult to the court and to the citizen intervenors struggling to achieve a measure of fairness in the proceeding.
GAP's view on Stone & Webster, the proposed third-party for QA implementation j
audit, is documented in our October 22, 1982 letter. As an update and summary we believe l
that Stone & Webster meets only one of the three criteria for a legitimate third party.
Yes, Stone & Webster has demonstrated economic independence from Consumers, dis-l closing other minor construction contracts with Consumers as well as their finsacial
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independence. But, Stone & Webster has not demonstrated its competence. Its long history of nuclear plant construction includes massive cost overruns, major Quality Control problems, significant design errors and poor construction management. Further, Stone & Webster's corporate integrity remains the subject of much skepticism, particularly in light of its six-month involvement on the Midland site without NBC approval of their l
work.
1 However, if the NRC is going to appmve Stone & Webster -- as seems obvious --
and hold it responsible under 10 C.F.R. Part 21 for reporting violations or QA failures, then the Region should so so. Someone other than Consumers must watch the QA imple-I mentation of critical soils work.
l VI. ENCOURAGE CONSUMERS TO RELEASE THE NEW COST ESTIMATE j
AND PROJECTED COMPLETION DATE INFORMATION l
Although neither cost nor scheduling is an NRC concern, both are critical concerns of the residents of Centrsfl Michigan who must constantly balance the risks and costs of this nuclear plant. If public confidence is ever to be restored in the Midland facility, it will come after Consumers demonstrates candor and openness with the public. It would l
benellt everyone to have the yoke of the December 1984 "on-line target date" removed as
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soon as possible from the necks of the nuclear workers.
Likewise, the new cost projection is unknown by local residents. GAP sources indicate a $4-billion-plus price tag, but that was an estimate which did not include the major stop-work order in December of last year.
If the plant is ever going to be included in the Michigan rate base, Consumers should begin today to adopt a new and candid approach to all of its problems. Public trust simply cannot be testored on anything less than honest admissions.
VII. CONCLUSION There are too many questions about the Midland Nuclear Power Plant left unanswered at this time. These questions are forming the basis for growing public skepticism about the NRC's ability or willingness to regulate nuclear power. In Central Michigan this uneasiness and distrust have led previously inactive citizens and local government bodies to beccme involved in their own protection. The citizens' desire to be informed about the ultimate safety of the Midland plant led them to request assistance from the Citizens Clinic of the Government Accountability Project. Our investigation into worker allegations and analysis of the situation confirms the needs for a comprehensive answer.
Midland needs a verification program implemented by a truly independent company with no stake in the outcome of its audit. This independent third party is not serving a client's requirements, but rather the public interest in ensuring tne quality of constr'iction at the plant. That third party must be accountable only to the NRC and the public.
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[ganaC0'o NUCLEAR REGULATORY COMMISSION N j.
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i Docket No. 50-329 Docket No. 50-330 l
MEMORANDUM FOR:
D. G. Eisenhut, Director, Division of Licensing NRR FROM:
R. F. Warnick, Acting Director, Office of Special' Cases
SUBJECT:
REPORT ON MIDLAND DESIGN AND CONSTRUCTION PROBLEMS, THEIR DISPOSITION, AND OVERALL EFFECTIVENESS OF THE j
EFFORT TO ASSURE APPROPRIATE QUALITY i.
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In a letter to Chairman Palladino dated June 8, 1982, entitled, ACRS Interim Report on Midland Plant, Units 1 and 2, Dr. Paul S. Shewman.
Chairman of the Advisory Committee on Reactor Safeguards, requested "a report which discusses design and construction problems, their disposition, and the overall effectiveness of the effort to assure j
appropriate quality."
Supplement No. I to the Midland Safety Evaluation Report (SSER 1) indicates Region III would prepare such a report for the period from the beginning of construction through June 30, 1982. The SSER 1 also indicates that a final report will be issued on the above subjects for 4
the period from July 1,1982 through the completion of construction.
The enclosed report is submitted in response to the first part of above referenced request and commitments. We request it be forwarded i
i to the ACRS. A final report will be submitted following completion of
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construction.
.f It is our understanding that NRR has lead responsibility for the disposition of some of the construction problems. This is noted in the 1
(See item III, paragraphs H.10 and J.8.)
report.
Please contact me if you have any questions.
j
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R. F. Warnick.. Acting Director 1-
. Office of Special Cases J
Enclosure:
As stated j
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T. Novak, NRR-D. Hood, NRR lR.;Hernan, NRR l
T. Harpster, IE j
'D. Allison, IE 1
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Midland Nuclear Power Plant, Units 1 and 2 Docket No. 50-329 Locket No. 50-330 t
b Ri. PORT ON DESIGN AND CONSTRUCTION PROBLEMS FOR PERIOD FROM START OF CONSTRUCTION THROUGH JUNE 30, 1982 e
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i Report Requested by Advisory Committee on Reactor Safeguards 1
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Introduction
~The following report prepared by the NRC, through its Region III office, discusses Midland construction problems, their disposition, and the overall effectiveness 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 *o commitments made in Supplement No. 1 of the Safety Evaluation Report.
The report covers the period starting with the beginning of construc-
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tion up to June 30, 1982. A fir.a1 report will be icsued on the above subjects for the period from July 1, 1982 through the completion of csnstruction discussing the overall quality of plant construction.
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i 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 and to upgrade the QA program and QA/QC staff. The most prominent action has been an overview program which has been steadily expanded to cover safety related activities. In spite of the corrective actions taken, the licensee continues to experience problems in the implementation of quality in construction, f
Significant construction problems identified to date include:
(1) 1973 - cadweld splicing deficiencies (Paragraph C.2); (2) 1976 - rebar omissions (Paragraph F.5);.(3) 1977 - bulge in the Unit 2 Containment Liner Plate (Paragraph G.3); (4) 1977 - tendon sheath location errors (Paragraph G.4); (5) 1978 - Diesel Generator Building settlement (Para-I graph H.10); (6) 1980 - allegations pertaining to Zack Company heating,
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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 misinsta11ations (Paragraph L.2).
i Consumers Power has on repeated occasions not reviewed problems to the depth required for full and timely resolution. Examples are:
(1) rebar omissions (1976); (2) tendon sheath location errors (1977);
(3) Diesel Generator Building settlement (1978); and (4) Zack Company HVAC deficiencies (1980). In each of these cases the NRC, in its I
investigation, has determined that the problem was of greater significance than first reported or that the problem was more generic than identified by Consumers Power Company.
1 The Region III inspection staff believes problems have kept recurring at
. j Midland for the following reasons: (1) Overreliance on the architect-engineer, (2) failure to recognize 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 aggressive quality assurance attitude.
A history of.the Midland design and construction problems and their disposition, ins 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.
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Table I DFORCFMEBR STATISTICS t '
itEAlm}tfARTERS saumamrt.taseCES/ NurrscE or civ t s.
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ouurns ticuirvers cr/
SICNartCANT CONSTRUCTIOtl PROBl.DtS sinrei rtalets DLVIATIuttS
- Vlot AT a uN PINAl. TIES Gl.s SanM GU$F askDt ks i-
- YEAR, 1:70
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1971 2
0 0
0 0
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1974 J
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0 0
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(Bulge in Containment t.1 ster and
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(TsuJon -
2 TenJan Stwath in=tallation treurm) i I277
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I St. casts) 0 I978 23 14 0'
O O
O 1 (plemul Ceneratur Bles. Settlement)
(Dimmut Generator I Bldg. Settlement) 0 Jo 17 0
0 0
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'37 21
.O I (Zack) I (Z.sck) 0 2 (Zack llVAC & Reactor Ancter Stude)
(ripe Suspen= ton
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0 0
I symtem) 0 1 (ripe suspension System)
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1 III. Design 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 Permit Exemption commenced. A total of four items of noncom-pliance were identified in 1970. These items are described below:
Four items of nonconformance were identified in Inspection Report Nos. 50-329/70-06 and 50-330/70-06 concerning the installation of coucrete. The nonconformances regarded:
(1) concrete placement l
activities violated ACI Code; (2) laboratory not performing tests j
per PSAR; (3) sampling not per ASTM; and (4) QA/QC personnel did I
not act on deviations when identified. Licensee corrective
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actions included:
(1) Bechtel to provide a report attesting to
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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 inspections. A total of six items of noncompliance were identified during 1973. One significant construction problem was identified involving deficiencies in cadweld splicing of rebar (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 Program. The noncompliances were documented in Inspection Report Nos. 50-329/73-08 and 50-330/73-08. The items of 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 Manual; (2) revision of Midland Internal Procedures Manual; l
(3) personnel instructed to audit the status of the drawing stick files weekly; (4) project administrator assigned the F
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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.
Cne significant construction problem was identified during 1973. It involved cadweld splicing deficiencies and resulted i
in tha, 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 were documented in Inspection Report Nos. 50-329/73-10 and 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 met requirements; and (4) inadequate procedures.
.As a result, the licensee stopped work on cadweld operations on November 9, 1973, which in turn stopped robar 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-welding operations. On December 6-7, 1973, Region III ar.d Headquarters personnel conducted a special inspection and determined that construction activities could be resumed in a manner consistent with quality criteria. Licensee correc-tive actions included:
(1) the revision of the Bechtel 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 I 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 j
Order on December 29, 1973 committing te revise and improve the QA manuals and procedures and make QA/QC personnel changes.
On Sep; ember 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.
D.
1974 Eleven inspection reports were issued in 1974 of which one
]
pertained to a vendor inspection, one to an inspection at the i
licensee's corporate offices, and nine to onsite inspections.
Three items of noncomplianca were identified during 1974.
l These items are described below:
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t One noncompliance was identified in Inspection Report 1.
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 corrective actions included:
(1) intensive review of liner plate records for accuracy; (2) issuance of nonconformance report; (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.
2.
One noncompliance was identified in Inspection Report Nos. 50-329/74-04 and 50-330/74-04, concerning the use of a 4
weld method which was not part of the applicable weld pro-cedure. Licensee corrective actions included:
(1) issuance of a nonconformance report; (2) repair of subject welds; (3) reinstruction of welders; and (4) increased surveillance of containment liner plate field fabrications. The licensee's actions in regards to this matter were reviewed and the noncompliance closed by the NRC as documented in Inspection Report Nos. 50-329/74-04 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 3
of QC inspections to identify nonconforming rebar spacing.
This violation is discussed further in the 1976 section of i
this report, Paragraph F.5.
E.
1975 i
1 Seven inspection reports were issuew.n 1975 of which one 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 f'
section of this report, Paragraph F.5.
F.
1976 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 Notice of violation (see Paragraph 5).
These items / problems are described below:
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Three items of noncompliance were identified in Inspection Report Nos. 50-329/76-01 and 50-330/76-01. These items regarded:
(1) inadequate concrete oven temperature controls; (2) no measures to control nonconforming aggre-gate; and (3) failure to dispose of nonconforming aggregate as required. Licensee corrective actions included:
1 (1) implementing a requirement for the reverification of f
oven temperature controls every three months; (2) removal of nonconforming aggregate from the batch plant area; j
(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 licensee in regards to these noncompliances were subse-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 j
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 actions taken in regards to these matters were subsequently
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reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/76-08 and 50-330/76-08.
3.
Three items of noncompliance were identified in Inspection Report Nos. 50-329/76-08 and 50-330/76-08. These items regarded: (1) inadequate classification, review, and approval of field engineering procedures and instructions; (2) inadequate documentation of concrete form work deficiencies; and (3) inadequate control of site storage of post tension embedmonts. Licensee corrective actions included:
(1) revision of the Bechtel Nuclear QA manual; (2) revision of Bechtel field procedure for " Initiating and Processing Field Procedures and Instructions;"
(3) initiation of Bechtel Discrepancy Report; (4) training sessions for Bechtel QC; and (5) revision of storage inspection procedures. 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, 4.
Two items of noncompliance were identified in Inspection 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 studs 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 t
i 6
1 9
I I
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.
5.
One significant construction problem was identified during 1976. It involved robar 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 l
an item of noncompliance.
(See the 1974 section of this j
report, Paragraph D.3.)
This matter was subsequently reported by the licensee as required by 10 CFR 50.55(e).
t Additional rebar deviations and omissions were identified 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 reinfo cement steel deficiencies were not adequately evaluated; (3) inadequate inspections of reinforcement steel; (4) inadequate evaluations of a nonconformance report problem relative to 10 CFR 50.55(e) reportability requirements; and (5) results of reviews, g
interim inspections, and monitoring of reinforcement steel installations were not documented.
The licensee's response, dated June 18, 1976, listed 21 l
separate items (commitments) for corrective actions. A June 24, 1976 letter from the licensee provided a plan i
I of action schedule for implementing the 21 items. The licensee suspended concrete placement work until the items addressed in the licensee's June 24 letter were resolved or implemented. This commitment was documented in a Region III Immediat.: Action Letter (IAL) to the licensee, dated June 25, 1976.
Rebar installation and concrete placement activities were resumed in early July.1976 following satisfactory completion of the corrective actions and verification by Region III as documented in Inspection Report Nos. 50-329/76-05 and 50-330/76-05.
7
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A subsequent inspection to followup on reinforcing steel placement problems identified two noncompliances. These 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 i
lead Civil Quality Control engineer from the project; (3) reprimand 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 the items closed by the NRC as documented in Inspection Report Nos. 50-329/76-07 and 50-330/76-07.
As a result of the rebar omissions and placement errors, a j
Headquarters Notice of Violation was issued on August 13, 1976.
. Additional actions taken by the licensee included the establishment of an overview inspection program to provide
-100*. reinspection of embedmonts by the licensee following 4
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 3
l construction deficiency; and (3) improvement in the QA/QC program coverage of civil work.
4 f
G.
1977
-l 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 l
. 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:
1.
Five examples of noncompliance with Criterion V of
,11 10 CFR 50, Appendix B, were. identified in Inspection Report Nos. 50.-329/77-05 and 50-330/77-08. The examples.
of noncompliance-regarded: -(1) inadequate clearance between concrete wall and pipe, support plates; (2) assembly of pipe supports-using handwritten drawing changes; (3) inadequate preparation and issue of audit reports; (4) inadequate. review of nonconformance reports and audit findings 1for trenda; and-(5). inadequate tagging of defective measuring equipment.
' Licensee corrective actions included: (1) clarification of
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3 design and acceptance criteria contained in pertiaent specifications; (2) modification and review of Quality Control Instructions; (3) issuance of two field procedures relative to field modifications of piping hanger drawings; (4) staffing of additional QA personnel at the site; (5) closer maxge:sent attention; and (6) additional trainin's in the area of tagging.
The licensee actions in regard to these items were subsequently reviewed and the items closed by the NRC as documented'in Inspection Report Nos. 50-329/77-08, 50-330/77-11, 50-329/78-01, and 50-330/78-01.
9 12.
Three items of noncompliance were' identified in Inspections Report Nos. 50-329/77-09 and 50-330/77-12. The items re.
.)
garded: -(1): failure to follow audit procedures; (2) failure '
to qualify stud welding procedures; and (3). inadequate welding inspection criteria. Licensee corrective actions included: (1) administrative instruction issued to require the audit manager to obtain a semi-monthly audit findings ',
q status report from the project manager; (2) administret'ive instruction issued for the close out and followup of 4
f internal ~ corrective action requests; (3) revision of Quality Control Instruction; (4) special inspections and j
audit;.and (5) prescribing specific acceptance criteria, s
j The. licensee's actions in regard to these items were sub-t
.sequently reviewed and the items closed by the NRC as t -
i documented in Inspection Report Nos. 50-329/78-01, 50-330/78-01,50-329/78-05,and50-330/78-05.]
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A significant construction problem involving-a bulge in the Unit:2 containment liner plate was-identified in 1977.'
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Details of the liner plate bulge fs11cw:
5 The initial identification)by the;1icensee,pf a bulge in the Unit 2' liner pla b occurred on, February'2s D1977. The;
'j liner plate bulge ocentred bjtween ' column'line asinuths -
250 degrps i nd 270 depossord between elevations 593 and s
700.: Inspection Report Go.~ 30-330p7-02 documents 'a D -
specialSiQp'ection.concerning the Minor plata bulge. This'd w report further>idsantiag an' item of noncompliance relative,
to th'a failure pf Ihe;11ce'anae;to report the' bulge deficiency pursuant to the,ypquipmepts' of.10 CFR 50.55(e).. The
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licensee's corpeqtive detions in regard to this"it d ware reviewed and tfw -ites c1' g M by the ARC as1 documented in a o
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-due tdfa' leaking 2' inch water line installed in the con- 'A J ainment concrete as arconstruction convenience. lit was
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allowing water'to seep behind the liner..,The water.line-l t
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,a:, H cycleLbetween 100 and 130 PSI..This pressure was' considered G,
to be sufficient to,couse'che-liner plate bulge.--
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A meeting was held on April 4, 1977 at the Ann Arbor, Michigan Office of Bechtel to review the original design and construction concept of the containment liner, the procedures and actions taken during the removal of bulge affected zones, the investigation activities and results, and to ascertain the concepts involved in the licensee's proposed repair program.
The containment liner bulge deficiency repair was started 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 repair and the repair records were subsequently reviewed as documented.in Inspection Report No. 50-330/79-25.
4.
A second significant construction problem involved tendon sheath placement errors and resulted in an Immediate Action Letter (IAL). Details are as follows:
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 i
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 modifications involving the placement of concrete in the area of 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 QC ovarview program; (4) NRC notification of all embedmont placement errors identified ofter QC acceptance; (5) review and revision of QC inspection procedures; and (6) training of construction and inspection personnel.
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A special QA progt m inspection was conducted in May 1977 as documented in Inspection Report Nos. 50-329/77-05 and 50-330/77-08. The inspection team was made up of personnel from Region I, Region III, and Headquarters. It was the con-sensus of opinion of the inspectots that the licensee's program was acceptable.
The licensee issued the final 50.55(e) report on this matter on August 12, 1977. Final onsite review was conducted and l
documented in Inspection.'teport Nos. 50-329/77-08 and 50-329/79-15.
l H.
1978 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 excessive settlement of the Diesel Cenerator Building foundation (see Paragraph 10). These items / problems are described below:
1.
Three items of noncompliarice were identified in Inspection Report Nos. 50-329/78-03 and 50-330/78-03. These items 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) saditional training given Quality Control Engineers and craft welders; (2) revision of pertinent technical i
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 itects closed by the NRC as 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, 50-330/81-12, 50-329/79-22, and 50-330/79-22.
2.
'lito items of noncompliance were identified in Inspection Repari. 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 correci.ive actions included:
(1) additional instructions given to welding personnel; (2) generation of nonconformance g
report to require Bechtel to perform a thorough inspection of the facility, correct aad 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 1.
a criterin Mrs identified in Inspection Report Nos.. 50-329/78-07 R
and'506559/78-07. These examples regarded:
(1) inadequate.
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control of drawings; and (2) inadequate drawing control pro-cedures, uicensee corrective actions included:
(1) Zack and 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 and 50-330/79-25.
4.
One item of nor. compliance was identified in Inspection Report,No. 50-330/78-09 concerning inadequate backing gas flow rate during welding operations. Licensee corrective actions included:
(1) revision of Bechtel welding pro-cedure specifications; (2) revision of Bechtel Quality Control Instruction; and (3) additional training for all welding Quality Control Engineers. The licensee's actions i
in regard to this item were subsequently reviewed and the item closed by the NRC as documented in Inspection Report l
No. 50-330/78-16.
I 5.
Tko 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 1E equipment. Licensee corrective actions included:
(1) revision of welding specifications; (2) additional instructions to QC in-spectors; (3) additional overinspections; (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.
I 6.
TVo items of noncompliance were identified in Inspection Report Nos. 50-329/78-15 and 50-330/78-15. These items i
regarded:
(1) nonconforming welds on Main Steam Isolation Valve support structures; and (2) inadequate corrective action taken to repair nonconforming Nelson Stud weld attachments. Licensee 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 3
Report Nos. 50-329/79-22, 50-330/79-22, 50-329/79-25 and 50-330/79-25, 7.
One deviation was identified in Inspection Report No. 50-330/78-16 concerning the failure to meet ASHE 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 12
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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 Inspection l
Report Nos. 50-329/78-17 and 50-330/78-17 regarding the i
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 licensee will bs reviewed during future NRC inspections.
9.
One item of noncompliance was identified in Inspection Report l
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:
i (1) training of pertinent Quality Control engineers; (2) transition of parsonnel in QC department relative to storage and maintenance activities; and (3) inspections and evalustions of omitted maintenance. The licensee's actions in regard to this item were subsequently reviewed and the 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 l
Generator Building foundation. Details are as follows:
4 j
The licensee informed the Regica III office on September 8, 1978, per requirements of 10 CFR 50.55(e), that settlement of the Diesel Generator foundations and structures was greater than expected.
Fill material in this area was placed between 1975 and 1977, with construction starting on the diesel generstor building in mid-1977. Review of the results of the Region III investiga-tion /inspectior. 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 non-i conformance reports, audit findings, field meaos to engineering, I
and problems with the administration building fill which caused
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modification and replacement of the already poured footing and replacement of the fill material with lean concreto.
j.
Causes of the excessive settlement iacluded:
(1) inadequate-l placement method - unqualified compaction equipment and excessive lift thickness; (2) inadequate testing of the soil material; (3) inadequate QC inspection procedures; (4) unqualified Quality Control inspectors and field engineers; j
and (5) overreliance on inadequate test results.
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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 in 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 soll conditions existing under the Diesel Generator building.
i 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 t
Generator Building foundation and the activities involved in the identification and reporting of unusual settlement of the building. The results of the investigation and additicnal developments in regard to this matter are discussed in the 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
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onsite inspections. A total of seventeen items of noncompliance were identified in 1979. These items are described below:
i 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 ir.cluded in drawings and specifications. Licensee corrective setions included: (1) revision to Midland FSAR; and (2) revision to pertinent specification. The licensee's actions in regard to this item were subsequently reviewed and the item i
closed by the NRC as documented in Inspection Report Nos. 50-329/79-19 and 50-330/79-19.
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 Welding Procedure Specification; and (3) inadequate control of purchased 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 packagese The actions taken by the licensee were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-01, 50-330/81-01, j
50-329/80-15, 50-330/80-16, 50-329/79-22, and 50-330/79-22.
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One item of noncompliance was identified in Inspection Report No. 50-330/79-13 concerning the failure to inspect all joints and connections on the I core Instrument Tank as prescribed in the hydrostatic test procedure. Licensee corrective actions included a supplemental test of the Incore Instrument Tank and the initiation of a supplemental l
test report. The licensee's actions in regards to.this ratter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/80-38.
4.
One item of noncompliance was identified in Inspection t
Report No. 50-330/79-14 concerning the use of a wad of paper in making a purge dam during welding activities.
Licensee corrective actions included:
(1) revision of l
pertinent procedures; (2) revision of pertinent Quality Control inspection checklist; and (3) training sessions j
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 f
from welding activities. Licensee corrective actions included trainin3 sessions for cognizant Field Engineers, Superintendents, General Foremen and Foremen..The licensee's actions in regards to this matter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report Nos. 50-329/80-15 and 50-330/80-16.
4 6.
Two items of noncenpliance were identified in Inspection Report Nos. 50-329/79-19 and 50-330/79-19. These items regarded:
(1) failure to ensure that appropriate quality standards were in the specification for structural backfill; and (2) Quality Control inspection personnel performing con-tainment prestressing activities were not being qualified as 4
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 actions in regards to these items 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 walding activities pertaining to 4.16 KV switchgear, Licensee corrective' actions included:
(1) correction of relevant records; (2) additional training
-for Quality Contro1' Engineers; and (3) additional training-for the Quality Control Document Coordinator.- The licensee's-l actions were subsequently reviewed and the item closed by the NRC as documented in Inspection Report Nos.'50-3?9/80-15
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.and 50-330/80-16.
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One item of noncompliance was identified in Inspection Report No. 50-330/79-22 concerning inadequate weld rod controls. Licenses corrective actions included a training session for cognizant welding personnel. The actions taken 3-by the licensee in regards to this matter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report No. 50-330/80-01.
9.
One item of noncompliance was identified in Inspection j
Report Nos. 50-329/79-26 and 50-330/79-26 concerning failure to follow procedures relative to the shipment of auxiliary t
feed water pumps to the site with nonconforming oil coolers.
Licensee corrective actions included:
(1) reinstruction l
given to cognizant engineer; and (2) Supplied Deviation Disposition Request (SDDR) generated by the vendor. The 3l licensee's actions in regards to this matter were reviewed and-the item closed by the NRC as documented in Inspection Report Nos. 50-329/79-26 and 50-330/79-26.
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10.
One item of noncompliance was identified in Inspection 4
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- 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-i visors and Field Engineers; and (2) a Field Instruction
,3 on Quality Control Hold Tags was issued. -The licensee's j
actions in regards to this matter were subsequently i
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 l
relating to design and_ construction activities affecting the Diesel Generator Building-foundations and the activities involved 'in the identification and reporting of unusual
- sett1',aent of the building. The investigation findings ware documented in Inspection Report Nos. 50-329/78-20 and.
50-330/78-20, dated March 22, 1979. Information obtained during this investigation indicated:
(1) a lack of control J'
and supervision of plant fill activities contributed to the inadequate compaction of foundation material; (2) corrective.
. action regarding nonconformances related to plant fill was 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 engineering office and construction site personnel; and (5) the TSAR contained-inconsistent, incorrect and unsup-1 ported statements with respect to foundation type, soil properties, and settlement values. Nine examples of.
noncompliance involving'four different 10 CTR 50, Appendix B Criteria were. identified in the-subject inspection report.
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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 Building at the Midland facility. The NRC staff stated that it's concerns were not limited to the narrow scope of the settlement on the Diesel Generator Building, but extended to various buildings, utilities snd 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 Energy'Act of 1954, as amended, and Section 50.54(f) of 10 CFR Part 50, additional information was requested regarding the adequacy of the fill and the quality assurance 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
.j of the 50.54(f) letter dated March 21, 1979 requested information regarding the quality assurance program. On 1
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 Novesber 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 issued an Order modifying construction Permits No. CPPR-81 and No. CPPR-82, dated December 6, 1979. This order 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 5
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 aad beneath safety related structures.
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.
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1980 Thirty-seven inspection reports were issued in 1980 of which two pertained to meetings at the licensee's corporate office, one to a meeting in Glen Ellyn, two to investigations, and thirty-two to l
onsite inspections. A total of twenty-one items of noncompliance I
were identified during 1980. Two significant construction problems i
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.
Two items of noncompliance and one deviation were identified in Inspection Report Nos. 50-329/80-01 and 50-330/80-01.
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-tive actions in regerds 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 E0-330/82-04.
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.
The licensee's corrective actions in response to the item of noncompliance included the issuance of a nonconformance report and the commitment to ensure compliance with Quality Control procedures. The licensee's corrective actions in regards to this matter will be reviewed during subsequent NRC inspections.
j 3.
One item of noncompliance was identified in Inspection l
j Report Nos. 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.
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4.
One item of noncompliance was identified in Inspection Report Nos. 50-329/80-21 and 50-330/80-22 concerning the j
failure to perform an audit of Photon Testing, Inc.
for 3
services to qualify Zack Company welders. Licensee correc-tive actions included an audit of Photon Testing, Inc. The l
licensee's actions in regards to this matter were subsequently reviewed and the item closed by the NRC as documented in Inspection Report Nos. 50-329/81-03 and 50-330/81-03.
18
i 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 ident!.fies that action had been taken to correct the identified noncompliance and to prevent recurrence. The item is closed.
6.
C;e item of noncompliance was identified in Inspection Report Nos. 50-329/80-31 and 50-330/80-32 concerning substantial delays by the licensee in making 10 CFR 3
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 j
and the item closed by the NRC as documented in Inspection Report Nos. 50-329/81-07 and 50-330/81-07.
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7.
A significant construction problem involving quality assurance problems at the Zack Company, the heating, ventilating, and air l
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 Company is the heating, ventilation and air conditioning I
(HVAC) subcontractor at the Midland construction site.
The allegations dealt with material traceability, violations of procedures, falsification of documents, and the training of quality control inspectors.
As the result of the allegations, an investigation was initiated by the NRC. During the initial phases of the 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 nonconformance reports and audit findings and had failed to address othcr requirements and commitments of the quality program.
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 action. The investigation determined that as of March 19, 1980, corrective action had not been completed on any of the nonconformance rep rts.
j Based on preliminary findings during the investigation, which revealed some instances of continued nonconformance in the implementation of Zack's Quality Assurance Program, an :Immadiate Action Letter.(IAL) was issued to the licensee on March 21, 1980. The IAL stated the NRC's understanding-that a Stop Work Order had been issued to the Zack Corpora-tion for all its safety related construction activities.
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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 *n regards to the items of noncompliance were subsequently reviewed and the items closed by the NRC as documented in Inspection Report K.. 50-329/82-15 and 50-330/82-15.
On June 30, 1980, the NRC received from the licensee a letter. documenting a Program Plan for resumption of safety l
related work by the Zack Company. ine licensee identified that corrective actions required prior to lifting the Stop i
Work included: (1) the review and approval of all Field i
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
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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 l
related work could resume.
4 The Bechtel Power Corporation released the Zack Company from the Stop Work Order by letter dated August 14, 1980.
l7 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-cor.struction 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.
On October-12, 1979, this condition was reported under the requirements of 10 CFR 50.55(e). Two other studs were sub-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.
l The investigation findings, as documented in Inspection Report.
Nos. 50-329/80-13 and 50-330/80-14, indicate several Quality Assurance deficiencies;. (1) lack of licensee involvement; (2) failure to advise the heat treater of different heats of material; (3) inadequate document review; (4) failure to L
respond to indications that the studs were deficient; (5) failure to review materials previously purchased when the purchase specification was revistd'; and (6) miscalculatio.t of I
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the stud stress area resulting in a slight over-specification stressing of the studs (this item was identified by the l-licensee).
Three items of noncompliance were identified in the inspec-tion report. These items regarded:
(1) failure to identify Subsection NF 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 procurement documents; and (3) failure to establish measures to assure that heat treating und 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 quenched and are 7/8" or gcmater in diameter, have been procured in accordance with prcper codes and standards; (2) a commitment to obtain NRR approval of the acceptability 1
of the Unit 2 reactor vessel anchor bolts and (3) a commit-ment that actual plant modifications to compensate for the 4
defective bolts would not be started on Unit I until approval of the design concept was received from NRR.
i f.
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
. utilized in Unit 2, although of different material and heat treatment, have above specification surface hardness readings.
t 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 matter.
I 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 s the Diesel Generator Building foundations). LThe results'of this inspection were documentediin Inspection Report
'Nos. 50-329/80-32 and 50-330/80-33.. Two items of noncompli-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; 4
^^(2) revision of specification; and (3) auditiof FSAR sections.
The licensee actions were subsequently-reviewed and the items closed by tha NRC as documented in Inspection Report Nos. 50-329/81-12, 50-330/81-12, 50-329/81-19 and 50-330/81-19.
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Additional information regarding this matter is discussed in j
the 1981 section of this report, Paragraph K.6.
i K.
1981 Twenty-three inspection reports were issued in 1981 of which 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-sta11ations -(see Paragraph 4).
These items / problems are described below:
1.
Two item. of noncompliance were identified in Inspection
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Report Nos. 50-329/81-04 and 50-330/81-04. These items regarded: (1) failure to account for all tools and materials used in a controlled clean room area;,and l
(2) inadequate procedure for tne installation of the Unit 2
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vent valves in the core support assembly. Licensee correc-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-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 correct the identified non-j compliances and to prevent recurrence. 'This determination is documented in Inspection Keport Nos. 50-329/81-04 and 50-330/81-04 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 1E
-equipment. Licenses corrective actions included:
(1) addi-tional training for Bechtel maintenance engineers; '(2) anE audit of maintenance activities; and (3) reinspections of affected' equipment. The licensee's actions in regards to-this matter were subsequently reviewed and the l' em closed by the NRC as documented in Inspection Report Nos. 30-329/81-23 and'50-330/81-23.
3.
Four 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'*.nd for the routing of cables into. equip-ment; (2) failure.of QC_ inspectors to identify inadequate cable separation; (3) inadequate, control of nonconforming raceway installations;'and (4)' failure to translate the FSAR requirements-into instrumentation specifications.
1 Licensee corrective actions in regards to (1) and.(2) above,
' included: (1) the' revision'of~ cable pulling procedures;
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(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 licensee's actions in regards to these items were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-20, 50-330/81-20, 50-329/82-03 and 50-330/82-03. Licensee commitments in regards to corrective actions pertaining to items (3) and (4), above, included:
(1) the addition of required barriers on pertinent raceway drawings; (2) the revision of Project j
Quality Control Instruction; (3) and the revision of the instrumentation specification. The licensee's actions in regards to these items will be reviewed during subsequent NRC inspections.
t 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 Program. The results of the inspection are documented in Inspection Report Nos. 50-329/81-12 and 50-330/81-12.
i.
Three of the items of noncompliance regarded:
(1) failure i
to take adequate corrective action concerning the trend analysis procedure; (2) failure of QC inspections to identify a nonconforming cable bend radius; and (3) failure l'
to take adequate corrective action in regards to the lack l'
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 actions in regards to these items were subsequently
',l reviewed and tne items closed by the NRC as documented in Inspection Report Nos'. 50-329/82-02, 50-330/82-02, 50-329/82-03fand 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 considered to be a significant construction problem.
Safety related' pipe support and restraint inscallations 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 restreints, supports.
and anchors-that were not installed in accordance with design. drawings and specifications; (3)-failure to prepare,.
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.l review and approve small bore pipe and piping suspension I
system designs performed onsite in accordance with design i
control procedures; (4) failure to adequately control documents used in site small bore piping design activities; and (5) failure of audits to include a detailed review of system stress analysis and to follow up on previously iden-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 Rnport Nos. 50-329/82-07 and 50-330/82-07.
1 As a result of the adverse findings, an Immediate Action Letter (IAL) was issued by the NRC on May 22, 1981 acknow-1 edging the NRC's understanding that the licensee would 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
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determined to have been satisfactorily addressed. This is documented in Inspection Report Nos. 50-329/81-14 and 50-330/81-14.
The licensee's actions in regards to noncompliance items (1) and (2) above, are discussed in Paragraph I of the following report section for 1982(L).
5.
One item of noncompliance was identified in Inspection Report Nos. 50-329/81-14 and 50-330/81-14 concerning inadequate design controls involving the Bechtel Rssident 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
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(2) the revision of a Project Instruction. The licensee'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 50-330/82-07.
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6.
In January, 1981 an inspection was conducted by the NRC to l:-.
verify whether adequate corrective actions had been imple-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-
- J Building foundation). The findings during this inspection, l
,l-which include three items of noncompliance and one deviation, i
are documented in Inspection Report Nos. 50-329/81-01 and i
24 I
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50-330/81-01. The items of noncompliance and the deviation
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regarded:
(1) failure to develop test procedures for soils work activities; (2) failure to have soils laboratory records under complete document control; (3) failure to have explicit instructions for the onsite Geotechnical Engineer's review of test results; and (4) failure to have a qualified Geotechnical Engineer onsite. Licensee corrective actions included:
(1) revisian of Quality Control Procedures and Specification; (2) development of new Quality Control Procedures; and (3) the addition of a qualified Geotechnical Enginedr. The licensee's actions in regards to these items i
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.
1' 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 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 findings of this inspection, which includss one item of noncompliancs, 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 actions included:
(1) the review, for compliance, of Midland Project major procurements and contracts; and (2) the review and revision of pertinent procedures. The licensee's corrective actions in regards to these items will be reviewed during subsequent NRC inspections.
^
L.
1982 Fourteen inspection reports have been issued during 1982 covering the period through June 30, 1982 of which two pertain to manage-ment 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 construction problem was identified involving electrical cable misinsta11ations (see Paragraph 2).
These items / problems are l
discussed below:
t-1.
The licensee conducted reinspections to determine the seriousness of the safety related support and restraint L
. Inspection Report Nos.r50-329/81-12 and 50-330/81-12. The installation and QC inspection deficiencies identified in results of.the reinspections are documented in Inspection Report Nos. 50-329/82-07 and 50-330/82-07. From a sample size of 123 safety related supports and restraints installed i
and inspected by Quality Control, approximately 45% were 4
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l' 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 1981. The licensee has agreed to perform the reinspections.
2.
One significant construction problem was identified during i
1982. It involved electrical cable misinsta11ations.
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 I
of numerous Nonconformance Reports (NCR) issued by Midland j
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 e
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 misrouted in one or more vias. This concern was upgraded to an item of non-compliance and is documented in Inspection Report Nos. 50-329/82-96 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 uns 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 1
Nos. 50-329/82-03 and 53-330/82-03. 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. The' 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 reviewed during future inspections.
.I 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 l-
=of noncompliance and the deviation regarded:
(1) failure to review and approve a Mergentine (the soils contractor) field procedure pr!.or to initiation of work; (2) inadequate control of specification changes; (3) inadequate acceptance 26
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criteria for dewatering specification; (4) inadequate j
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.
5.
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 resulted in the issuance of a letter by the licensee on March 31, j
1982 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; 3
(2) plans were established to inspect and audit instrumentation installation activities; and (3) Region III had concurred that (1) and (2), above, were acceptable, i
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 L
determined that the installation of underpinning instrumentation i
for the Auxiliary Building was complete and acceptable. This j
item will remain open pending the licensee's development of drawings, procedures, and instructions for +he future installation of underpf.nning instrumentation for the Service Water Building.
6.
One item of noncompliance and a deviation were identified in Inspection Report Nos. 50-329/82-11 and 50-330/82-11. The items 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.
The ASLB issued an order modifying Canstruction Permits No. CPPR-81 and No. CPPR-82, dated April 30, 1982. This order suspended all l
remedial soils activities on "Q" soils for which the licensee did not have prior explicit approvel. 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 j.
Drawing C-45.
As a result of past Region LII findings, the Region III Administrator F
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 develeped by Region III end the licensee to control work and ensure ccmpliance to the ASLB Order.
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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 the access shaft; and (4) the completion of the Auxiliary Building instrumentation for remedial soils activities.
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oLEN E LLYN, ILLINolS 60137 f
August 18, 1982 MEMORANDUM FOR: James G. Keppler, Regional Administrator FROM:
Rob'ert F. Warnick, Acting Director, Office of Special Cases C'JBJECT:
CONSUMERS POWER-MIDLAND (DN 50-329; 50-330)
When you created the Office of Special Cases and a special Midland Section j
staffed with individuals assigned solely to that project, you indicated your concern with the Midland Project. You did this in spite of the favor-able findings of the special team inspection conducted in May,1981, and the favorable testimony you gave before the Atomic Safety and Licensing Board on July 13, 1981. You indicated your concern was based on the Systematic Assessment of Licensee Performance (SALP) report for the period July 1, 1980 t
to June 30, 1981, the inspection findings since those dates, and the memo of June 21, 1982, by C. E. Norelius and R. L. Spessard suggesting certain changes be made at the Midland Project (copy attached as Enclosure 1).
Ac my request R. J. Cook prepared a summary of indicators of questionable license performance at Midland. A copy of Cook's memo dated July 23, 1982 is attached as Enclosure 2.
Because of your expressed concerns,' you and I met with representatives from NRR on July 26, 1982 to discuss Midland and Consumers Power Company (CPCo) performance. That meeting also resulted in recommended actions. A summary i
of the meeting is attached as Enclosure 3.
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j Following the meeting with NRR, I discussed the recommendations of that meet-ing with our Senior Resident Inspector, other members of the new Midland Section, and former Section end Branch Chiefs who are intimately familiar i
with Midland.
l Later that week (July 30) I spent a day at the Midland site. I attended th'e l
j exit meeting following Landsman's and Gardner's inspection, met with CPCo and Bechtel management to get acquainted with them, and toured the plant site.
i i
On July 31, 1982, I expressed my opposition to the recommendations we had come l
I up with in the NRR meeting.
My-opposition was based on (1) opinions expressed by the Senior Resident Inspector, a Region III Branch Chief formerly responsi-ble for the NRC-inspection of Midland, and a Construction Section Chief who has
'been intimately associated with inspections of Midland regarding the proposed actions; (2) my visit to the site; and (3) the inability of Region III to l
articulate the preblem(s) at Midland which the above referenced recommendations were supposed to solve.- I indicated that we needed to better identify our concerns and the prescribe actions that would resolve-these concerns.
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).s James G. Keppler August 18, 1982 i
On August 3, 1982, members of the Midland Section met with you to discuss my opposition to the recommendations coming froni the meeting with NRR. The pros and cons of the recommendations together with other alternatives were discussed. The meeting concluded with you agreeing to give the Section until August 11 to determine a better proposed course of action to resolve NRC concerns about Midland.
To this end the Midland Section met together on August 4 and again on August 5 following our public meeting with CPCo on the SALP II report. Several alter-natives were discussed including stopping all work on one unit, have an inde-pendent third party moci or all past and current construction work, stopping t
work in selected areas, performing a construction anpraisal team inspection, placing all site QC work under CPCo, and establishing an augmented NRC inspec-tion effort.
Although some members of the Midland Section thought that stronger actions should be taken, all members of the Section agreed they could support an augmented NRC inspection effort coupled with other actions to strengthen the licensee's QC/QA organization and management. These recommended actions are attached as Enclosure 4.
It is recommended the proposed actions to improve the licensee's performance be discussed with NRR and then the licensee.
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Robert F. Warnick, Acting Director
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MEMORANDUM FOR: James G. Keppler, Regional Administrator i
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FROM:
C. E. Norelius, Director, Division of Engineering and Technical Programs R. L. Spessard, Director, Division of Project and Resident Programs
SUBJECT:
SUGGESTED CHANCES FOR THE MIDLAND PROJECT j
Historically, the Midland Project has had periods of questionable quality assurance as related to construction activities and has had commensurate regulatory attention in the form of special inspections, special meetings, and orders. These problems have been given higher public visibility than most other construction sites in Region III. As questions arise regarding the adequacy of construction or the assurance of adequate construction, we are faced with determining what regulatory action we should take. We are again fcced with such a situation.
Current Problem The current problem was caused by a major breakdown in the adequacy of soils work during the late 1970's. Because of the increased regulatory attention given the site, we expect that exceptional attention would be given to this activity and that licensee performance would be better than other sites or areas which have not had such significant problems and therefore have not attrscted this level of regulatory attention. However.
that does not appear to be the case and Midland seems to continually have more than its share of regulatory problems. The following are some of the i
specific items which are troublesome to the staff.
Technical Issues 1.
In the remedial soils area, the licensee has conducted safety related activities in an inadequate manner in several instances - removal of dirt around safety related structures, pulling of electrical cable, drilling into safety related utilities.
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In the electrical area, in trying to resolve a problem of the adequacy of selected QC inspectors' work conducted in 1980, tSe licensee completed only part of the reinspection even when problems were identified,and appears inclined to accept that 5% of electrical cables i
may be misrouted (their characterization of "misrouting" may imply i
greater significance than we would attach to similar findings).
3.
In the pipe supp' ort area, in trying to resolve a problem of the adequacy of QC inspections conducted in 1980, the licensee has i
portrayed only a small percentage of defects of " characteristics" identified and has not addressed the findings in terms of a large i
percentage of snubbers which may be defective because of the
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characteristics within each snubber that may be defective (e.g., if only one characteristic was defective out of 50 reviewed on a single hanger, the percentage is small; but if the one defective characteristic i
makes the hanger defective the result would have a much greater significance level). The licensee had done a detailed statistical analysis in an attempt to show that the small percentage of characteristics were found rather than broadly approaching the problem with significant reinspections to determine whether or not construction was adequate.
Communications Multiple misunderstandings, meetings, discussione, and communications seem to result in dealing with the Midland Project. Some examples are:
1.
NRC staff attending a meeting in Washington on March 10, 1982, heard the Consumers Power Company staff say that electrical cable pulling related to soils remedial work was completed. It was determined to be ongoing the next day at the site.
I 2.
When Region III attempted to issue a Confirmatory Action Letter, J. Cook informed W. Little of his understanding that both J. Keppler and H. Denton had agreed that the subject of the CAL was not a safety related item subject to NRC regulatory jurisdiction. Such agreements had not in fact occurred and following a meeting, Consumers Power Company issued their commitments in a letter to Region III.
o 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 l
copy both dated the same date but differing in content.
4.
Recently a Region III inspector in closing out and exiting from his inspection described the exit meeting as being the most hostile he had ever participated in.
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James G. Keppler 6/21/82 5.
The responses to any Region III enforcement letters issued to 3
Midland are more lengthy and 35@ argumentative than are any other responses from any other licensee in Region III. This point was made in the SALP response provided by Midland,and the SALP response in itself from Midland is an example of the type of response which we commonly receive from the site. The length of the response is at least as long.as the initial SALP report.
6.
Multiple requests for briefing meetings and other statements by the utility to the effect that we should review procedures in developmental stages imply that Midland wants the NRC to be a part of their construction program rather than having us perform our normal reguletory function.
i Staff Observations 1.
With regard to corrective actions of identified noncompliances, the Midland response seems to lean towards doing a partial job and then writing up a detailed study to explain why what they have done is sufficient rather than doing a more complete job and assuring 100%
corrective action has occurred. In the detailed writeups that are prepared, it is the staff's view that the licensee does not always represent the significance properly,and the analyses and studies often raise more questions than they 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 or not something is an item of noncompliance and spends a lot of effort on defending whether or not something should be noncompliance d
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 may have resulted from the extended public visibility which has attended construction of the facility. The staff's view is that the Midland site would look better from the public standpoint and be more defendable from NRC's standpoint, if they concentrated on fixing identified problems rather than arguing as to the validity of citations.
This type of view was expressed by the utility duting a recent effort to clarify in detail that certain construction items on the soils remedial work should not be subject to NRC's regulatory action.
3.
The Midland project is one of the most complex and compliacted ever undertaken within Region III. The reason is that they are building two units of the site simultaneously and additionally have an underpinning construction effort which in itself is probably the. equivalent of building a third reactor site. The massive construction effort and the various stages of construction activity which are involved make the site extremely complf)ted to manage. This activity appears to cause a lot of l
pressure on the licensee management.
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Mr. J. Cook, the Vice President responsible for the Midland site is an extremely capable and dynamic individual. However, these characteristics in conjunction with the complexity and immenseness i
of operation as set forth in 3, above, may actually be contributing I
to some of the confusion which seems to exist. The staff views that (1) he is too much involved in detail of plant operations and there are times when the working level staff appears to agree and be ready to take action wher's Mr. Cook may argue details as to the necessity for such action or may argue as to the specific meaning of detailed work procedures, (2) this kind of push may 1 sad to ruch things as letters both signed and unsigned appearing in NRR and causing confusion, (3) this push may ler.d to some animosity at the licensee's staff level
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if NRC activities are looked on as slowing progress of construction at the site.
Recommendations I
i It appears essential that some action be taken by NRC to improve the regulatory performance of the Midland facility. The following specific suggestions are made.
1.
The company must be made aware and have emphasized to them again that their focus should be on correcting identified problems in a complete 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 currently exists at Midland. We would suggest specifically that the following activities be considered:
a.
That the licensee cut back work and dedicate their efforts to getting one of the units on line in conjunction with doing the soils remedial work.
b.
That they have a separate management group all the way to a possible new Vice President level, one of which would manage the construction of the reactor to get it operational and the second to look solely after the remedial soils and underpinning activities.
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3.
Consumers Power Company should develop a design and construction verification program by an independent contractor. This would provide an important additional measure of credibility to the design _and i
construction adequacy of the Midland facility.
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I C. E. Norelius Director Division of Engineering and Technical Programs f\\
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.R.L.Spess}ard, Director
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GLEN ELLYN,ILLINots 80137 July 23, 1982 i
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i MEMORANDUM FOR:
R. F. Warnick, Director, Enforcement and Investigations Staff FROM:
R..J.
Cook, Senior Resident Inspector, Midland Site I
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SUBJECT:
INDICATORS OF QUESTIONABLE LICENSEE PERFORMANCE - MIDLAND SITE 1
As per our conversation of July 21, 1982, the following is a list of those 1
items that various inspectors consider to be indicative of questionable licensee performance:
1.
One of the leading items is the over-inspection performed on electrical QC inspectors which was done in response to NRC concerns identified in the May 1981 team inspection. The licensee found weaknesses in the inspections performed by some electrical QC inspectore pertaining to not identifying the mis-routing of cables. This item culminated in an item of noncompliance. The licensee did not expand the o**erview activity to a degree necessary for an acceptable resolution to the identified weak-ness - even after a meeting in RIII. This item has not been resolved to the satisfaction of the NRC although our position has been clearly defined.
As a partial response to the team inspection concern, the licensee presented j
the NRC with an audit report which would demonstrate a response to our con-1 corn of questionable electrical QC inspections. However, the audit report j
stated that it (the audit report) did not address the NRC conce'rns.
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amount of emphasis has been placed on the settling data.for the structures involved.' During a meeting in HQ on March 10, 1982, the need for QC require-ments on remedial soils instrumentation were explicitly delineated. However, l.
one week later, the NRC inspectors found soils work instrumentation instal-lation was started the day after the March 10, -1982 meeting without a QC/QA umbrella that the_ licensee's QA Auditor and QA Engineering personnel were not approached pertaining to the need for QA coverage for this soils settle-ment instrumentation that there were strong indications that the licensee l
had mislead the NRC in relating that,the work was essentially complete when indeed it was nots and presently, the. licensee management informs our inspec-l tor that' items are ready for his review when in actuality they are not. Our l
conversations with licensee personnel - other than managemant - confirm that L-the items are not ready for review.
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Historically, one of the NRC questions has been, "Who is running the job - Bechtel or Consumers?" The following example 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 the licensee generate a Coordination / Installation Form to cover interface i
between different evolutions of instrumentation installation. The licen-see would call our inspector for his concurrance on the adequacy of the form - the inspector would approve Consumers Power Company's fom, but i
then would find out that Bechtel did not want to work to Consumor's form -
i the form that was generated to resolve regulatory concerns. This event i
has occurred twice and was considered as a deviation during a more recent inspection. The opinion of the staff is that if Consumers generates a j
form that will aid them in not incurring regulatory difficulty, and which has had NRC input, the licensee should demand that the contractor comply with these policies instead of the contractor dictating the regulatory environment under which they will work.
4.
Deficiencies in material storage conditions has continually been a concern to the NRC and has resulted in items of noncompliance. To the inspectors, the ability to maintain quality storage is indicative of how rigorous or slipshod the constructor's attitude is towards construction. The licensee has attemted to entice the constructor to do better in maintaining the material storage conditions, but still the licensee's auditors and the NRC have negative find' 'gs in material storage conditions and negative discussions with the contractor about the validity of the finding.
5.
At periodic intervals, the support of cables, particularly in the control room area, which are awaiting further routing or termination, has met with the disapproval of the NRC inspectors. These discrepancies also include
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cables without govered ends being on the floor in walk areas that are in I
a partially installed status. This is also another indicator of slipshod workmanship which has been brought to the constructor's attention at various times, but was last noted during a recent inspection.
6 In the area of instrumentation impulse line installation and marking, the licensee has had separability violations which has required removal of all installed impulse lines. Also, the NRC, because of this and significant adverse operational conditions, insisted that the installed impulse lia.es be identified. Although the licensee plans to mark the impulse lines, there was an inordinate amount of resistance to marking the lines - even though there had been instancea of mis-matched channels because of iden-tification confusion.
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7.
An example of reluctance in placing the responsibility for quality work-manship at the foreman and/or worker level has recently been identified.
The NRC inspectors noted that some drop-in anchors were improperly instal-l led and obviously did not adhere to the installation procedures. The licensee's attitude indicated this was not a valid finding because QC had l
not inspected the item. The NRC inspectors treat this as indicative that slipshod workmanship is tolerated in the hopes that QC will find the mistakes.
8.
Late in 1981, the licensee decided to move the QA Site Superintendent into another position and cover this site function by sharing the site time be-tween the QA Director and the QA Manager. After a January 1982 meeting with the NRC at RIII, the licensee opted to fill the QA Superintendent spot with another person. In the spring of the year, the NRC inspectors were following up on welding allegations and approached the QA Superintendent. The QA Superintendent was familiar with the alleged poor welding and had established what the NRC inspectors determined to be a responsive plan to resolve the questionable QC welding inspections. At the Exit Interview, the QA Director did not appear to back the QA Site Superintendent's proposed plan which had i
tacit NRC approval. The NRC inspector classified in writing and with just cause that the Exit Interview was the most hostile exit interview he had ever encountered.
9.
During a recent inspection, it was noted by the NRC inspector that fill dirt l
was piled and being covered with a mud mat at a nominal 1:1 horizontal to vertical slope when the specification called for a 1 il horizontal to verti-cal slope. A constructor Field Engineer witnessed the wrong slope being installed and justified and defended the slope after being informed of the specification requirement. This is another example of the constructor having an attitude which precludes quality workmanship.
10.
Atdifferent times, NRC inspectors have experienced difficulty in getting information which is controlled by the contractor, such as supporting cal-culations and qualifying information to justify a given installation. A recent example is: the NRC inspector informed the licensee and the contrac-tor he wanted to see resumes of persons involved in the remedial soils work.
There is an obligation to the NRC to supply a precise number of " qualified" persons on the soils work. The inspector was informed he could not get these records as they were personal. The inspector ultimately did get the informa-tion after bringing it to the attention of licensee upper management. How-ever, this indicates an implied unwiJlingness of the constructor to share information with the NRC and sometimes with the licensee.
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The licensee of tentimes does not demonstrate a " heads up" approach to l ?. ~,
their activities.
"he following are examples of the licensee operating
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in an environment using tunnel vision - " blinders".
f' a) During a recent NRC inspection, the inspector challenged the ability 4
to maintain the proper mix ratio on high pressure grout.
This was done af ter the inspactor noted that the operator could never maintain the proper mix ratio without continual manual centrol - which was not r i 2E:
available when the grout is applied. The licensee's apathetic atti-tude did not allow them t > stop the grout application until the next day when this became an issue at the exit interview.
b) At one point in time, the company doing drilling on site for the remedial soils work cut into a safety related duct bank between the diesel generator building and the service water building. The Consu-mers Power Site Manager's Office (the production peopla) stopped work because - from a quality standpoint conditions were so deplorable.
However, the Site Manager's Office did not have responsibility in this area - the Midland Project QA Department had this responsibility and did not invoke their cuthority to prevent the drilling work from get-ting out of control - or to bring it back into control.
c) The NRC inspector recently witnessed the licensee setting up to drill a well hele in safety related dirt using a technique which was not authorized. If the inspector had not brought this to the licensee's attention, the licensee would have violated an Order am Iressing reme-dial soils work and also the Construction Permit. When the licensee was queried as to the availability of the QC/QA personnel who would prevent such activity from happening, the NRC inspector was informed
- e this was (another) misunderstanding.
The NRC inspectors have been informed by our contacts on site that there are memoes written to the effect that " peripheral vision" should be cur-tailed and ccm anication with the NRC stiffled. The NRC has not read i
che=r aemoes yet - but plans to in the near future, previded they really l
exist and infer what we have been informed.
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12.
The licensee seems to possess the unique ability to search all factions of the NRC until they have found one that is sympathetic to their poirt of view - irregardless cf the impact on plant integrity. Some examples of this are:
al The NRC soils inspector informs the licensee that soils stabilization grout comes under the Q program. The licensee is not particularly happy with this position. tinknown to the inspector, the licensee argues his point with NRR to have the grout non-Q - using only those arguments which support his (the licensee's) position. The licensee
R.
F. Warnick 5
July 23, 1982 has the advantage of the NRC inspector's technical and regulatory basis for supporting his (the inspector's) position, and tnerefore avoids mention of this during the discussions with NRR.
- However, the licensee 's QA program, which has already been approved by NRR, states that all the remedial soils work is Q unless RIII approves a relaxation on a case by case basis.
It appears the licensee does not wish to acknowledge the prior agreements with the NRC.
b) Since the failure of auxiliary feedwater headers in B&W steam genera-tors, discussions have transpired between the NRC inspectors and the si'.e personnel. These discussions have indicated that the licensee was maintaining a conservative approach and were entertaining the concerns expressed by the NRC which were stimulated primarily by gross mistakes in attempting the modification at operating B&W plants. The licensee's corporate personnel were annoyed that the NRC inspectors would not give approval to start the modification until all the pre-paratory work had been accomplished as this would tend to impact the schedule and the modification to the steam generators could become a scheduling nuisance. The licensee corporate personnel contacted the NRC inspectors involved to " reason with them".
However, the corpor-ate personnel, (including a representative from B&W) were unable to answer the concerns of the NRC inspectors but did mention that the NRR Operational Project Manager indicated that it was alright to proceed with the modification. The licensee corporate personnel could not state what the position of the NRR Construction Project Manager was on this issue - only that they had found some form of approval frem some-one in the NRC.
c) At times, when Immediate Action Letters or other forms of escalated enforcement become imminent, the licensee attempts to " appeal" their case with individuals in the regional management who are removed from the particulars of the tentative enforcement action. The licensee at-tempts to get these persons to agree to specific portions of the issue which would indicate that the licensee is "really not all that bad".
However, the "real" issues, as identified by the NRC inspectors are j
being masked.
d) During inspections of the remedial soils work, the NRC inspector has been informed by the licensee that certain findings and areas of inspec-l tion were not within the purview of his (the inspector's) inspection program because they were in essence considered non-Q and that by virtue of prior agreement with the Regional Administratot were excluded from enforcement action. However, the NRC inspectors would subsequently find that there was no such agreement between the Regional Administratcr and the licensee - only a philosophical discussion as to what, in general terms, constituted an item of noncompliance.
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Julv 23, 1982 The above indicators support the reputation the licensee has for being argumentative. Their apparent inability to accept an NRC position with-out diligently searching to find a " softened" position results in numer-I ous hours of frustrated conversations between all parties involved to resubstantiate (usually the original position) a position based on tech-nical and regulatory prudency.
13.
The licensee has been classified publicly by the NRC as being argumenta-tive. The licensee continues to exhibit this trend, as evidenced by the following examples:
a) Essentially every item of noncompliance receives an argumentative answer which addresses only the specificity of the item of noncom-pliance and selectively avoids any concept which would support the essence for the item of noncompliance. For example - in the instance e
of the improperly installed drop-in anchor mentioned above, it was j
the fact that QC had not inspected the installation of the bolt which
,j was important to the licensee. However, the real enforcement issue was that components were being improperly installed.
b) The Cycle II SALP made critical evaluations of the licensee's perfor-mance in several areas. The licensee's response to this SALP report was argumentative over specific details and did not seem to acknowl-l edge that the consensus of opinion of the NRC inspection staff was that there were areas where the licensee's performance was weak. The licensee's argumentative position is in the form of "we really are not all that bad" when the records, findings and observations of the NRC
]
inspectors support just the opposite position.
c) The "Q-ness" of the remedial soils work has continually been an argu-mentative topic of discussion which ultimately resulted in a HQ meeting on March 10, 1982. At this meeting, the "Q-ness" of the remedial soils work was specified and later documented with the meeting minutes. How-ever, the licensee did not wish to abide by this position and a subse-quant meeting was held in RIII to further clarify the NRC position.
Still, the topic of "Q-ness" is being argued by the licensee, even though the ASLB has issued an Order further defining the "Q-ness" of the soils work. It might be noted that a hearing is in process over this soils issue and the NRC's position on "Q-ness" has been expressed during these testimonies.
14.
During a recent episode, the licensee wanted to continue excavation of soils
~
in proximity to the Feedwater Isolatior. h lve Pit (FIVP). However, the licen-see wanted to perform this evolution wi@.aut determining. that the temporary -
supports of the FIVr were adeq' tate. Making this' determination would have an j
impact.on scheduling, as stated by the licenseeJ The FIVP supports were installed without a Q umbrella and subsequent-inspections did reveal several i
discrepancies in the installation of the support structure.
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July 23, 1982 4
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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 j
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 receives responses which strongly suggest that the time was not taken to perform these reviews - perhaps taking this time would impact on the
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schedule..
16.
By virtue of an earlier ALAB Order, the licensee is required to perform trend analyses for nonconforming conditions. These trend analyses have, in the past, masked the data such that obvious trends are not obvious and has resulted in negative-findings by the NRC.
This was addressed in one of the earlier SALP meetings. Recently, while performing a review of j
hanger welding data, the NRC inspector found that the statistical data had j
been diluted to the point that the number of unsatisfactory hangers could not be determined from the trend analyses or the type and degree of non-conforming conditions which were being identified pertinent to the hanger fabrication.
i 17.
The licensee continua 1Lly would use the NRC staff as consultants and clas-sifies a regulatory and enforcement position as counter productive. This i
a i
is reflected by the licensee not wishing to' perform Q-work without obtain-ing NRC prior approval and then addressing only those areas where the NRC has voiced a regulatory concern - provided it is convenient to the licensee.
This attitude has particularly prevailed in the remedial soils issue and to j
.a lesser degree in the electrical installation areas.
'Ihe preferred NBC.
inspector mode would be_for the licensee to generate his program to esta-
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blish quality and then the NBC would approve or disapprove. However, the 1
licensee requires consultation with the NRC to establish his level of i~
quality requirements.
The above is not intended to be a complete list of all discrepancies which indi-cate questionable licensee performance as this would require a more' extensive review of the records -and inspection personnel. involved than time-permits..Also,
- there has been no attempt to systematically '. document-the enforcement and unre-solved items -list, as these are contained in ~other information sources. - However,.
'the listing is'rather comprehensive of the types of situations and attitudes which -
l-prevail.at the Midland site as observed by the NRC inspector staff.
When considering the'above listing of. questionable licensee performance attributes,.
the most' damning concept is the fact that,the NRC inspection effort at Midland has-l been purely reactive in nature for.approvinately the last year, and tha' ' these
' indicators are what have'been observed. in approximately the last six months.
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these are the types of items that have become an NRC nuisance under a reactive inspection program, one can only wonder at what would be disclosed under a rigorous routine inspection and audit program.
Sincerely, i
R. J. Cook i
Senior Resident Inspector Midland Site Resident Office cc:
W. D. Shafer D. C. Boyd R. N. Gardner R. B. Landsman B. L. Burgess 4
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+*p NUCLEAR REGULATORY COMMISSION REGloN lli
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E 799 ROOSEVELT RoAo oLEN ELLYN, ILLINotS 60137 August 18, 1982 MEMORANDUM FOR: Region III Files FROM:
Robert F. Warnick, Acting Director, Office of Special Cases
SUBJECT:
MEETING BETWEEN NRR AND REGION III RE CONSUMERS POWER COMPANY PERFORM #NCE AT MIDLAND (DN 50-329; 50-330)
On July 26, 1982, R. F. Warnick and Junes G. Keppler met with E. G. Case, D. G. Eisenhut, R. H. Vollmer, R. O. Tedesco, T. H. Novak, W. D. Paton, and J. Rutberg to discuss the performance of Consumers Power Company at the j
Midland site.
During the meeting reference was made to information contained in two memos from the RIII staff. The first memo dated June 21, 1982 is from i
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 J
and concerns the licensee's performance at Midland. Copies of the memos are attached.
i The meeting resulted in the following recommendations:
l (1) Region III should obtain the results of the recent audit by KMC.
'I (2) Schedule a public meeting be, ween NRC and CPC management in Midland, Michigan, to obtain licensee commitment to accomplish (3) and (4) below.
(3) The licensee should obtain an independent design review.
(A vertical slice from design thru completion of construction.)
(4) The licensee should obtain an independent third party to continuously monitor the site QA implementation and provide periodic reports to the NRC. Region -III is to provide a suggested outline for the contin-uous monitoring function.
Roosk Fu) &
Robert F. Warnick, Acting Director Office of Special Cases 1
i' Attachments: As stated
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NUCLEAR REGULATORY COMMISSION w
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OLEN ELLYN,ILLINots 80137
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June 21, 1982 MEMORANDUM FOR: James G. Keppler, Regional Administrator
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FROM:
C. E. Norelius, Director, Division of Engineering And Technical Programs
_ j R. L. Spessard, Director Division of Project and Resident Programs t
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SUBJECT:
SUGGESTED CHANGES FOR THE MIDLAND PROJECT I
Historically, the Midland Project has had periods of questionable quality assurance as related to construction activities and has had commensurate regulatory attention in the form of special inspections, special meetings, and orders. These problems have been given higher public visibility than most other construction sites in Region III. As questions arise regarding the adequacy of construction or the assurance of adequate construction, we are faced with determining what regulatory action we should take. We are l
again faced with such a situation.
j Current Problem I
The current problem was caused by a major breakdown in the adequacy of l
soils work during the late 1970's. Because of the increased regulatory attentior. given the site, we expect that exceptional attention would be given to this activity and that licensee performance would be better than other sites or areas which have not had such significant problems and l
therefore have act attracted this level of regulatory attention. However, that does not' appear to be the case and Midland seems to continually have more than its share of regulatory problems. The following are some of the specific items which are troublesome to the staff.
Technical Issues
.1.- In the remedial soils area, the licensee has conducted safety related activities in an inadequate manner in several instances - removal of dirt around safety related structures, pulling of electrical cable, drilling into safety related utilities.
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In the electrical area, in trying to resolve a problem of the adequacy of selected QC inspectors' work conducted in 1980, the licensee completed only part of the reinspection even when problems were identified,and appears inclined to accept that 5% of electrical cables may be misrouted (their characterization of "misrouting" may imply greater significance than we would attach to similar findings).
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" identified and has not addressed the findings in terms of a large percentage of snubbers which may be defective because of the characteristics within each snubber that may be defective (e.g., if only one characteristic was defective out of 50 reviewed on a single hanger, the percentage is small; but if the one defective characteristic makes the hanger defective the result would have a much greater j
significance level). The licensee had done a detailed statistical analysis in an attempt to show that the small percentage of characteristics were found rather than broadly approaching the problem with significant reinspections to determine whether or not construction was adequate.
Communications Multiple misunderstandings, meetings, discussions, and communications seem to result in dealing with the Midland Project. Some examples are:
1.
NRC staff attending a meeting in Washington on March 10, 1982, heard the Consumers Power Company staff say that electrical cable pulling related to soils remedial 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 Letter, J. Cook informed W. Little of his understanding that both J. Kappler 4
and H. Denton had agreed that the subject of the CAL was not a safety related item subject to NRC regulatory jurisdiction. Such agreements had not in fact occurred and following a meeting, Consumers Power Company issued their commitments in a letter to Region III.
3.
In reviewing a licensee May 10, 1982 letter, responding to the Board Order, the NRR staff had an unsigned letter and Region III had a signed
- copy both dated the same date but differing in content.
4.
Recently a Region III inspector in closing.out and exiting from his
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had ever participated in.
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James G. Keppler 6/21/82 5.
The responses to any Region III enforcement letters issued to Midland are more lengthy and 7dsi argumentative than are any other responses from any other licensee la Region III. This point was made in the SALP response provided by Midland,and the SALP response in itself from Midland is an example of the type of response which we commonly receive from the site. The langth of the response is l
at least as long as the initial SALP report.
i 6.
Multiple requests for briefing meetings and other statements by the utility to the effect that we should review procedures in developmental stages imply that Midland wants the NRC to be a part of their construction program rather than having us perform our normal regulatory function.
Staff Observations 1.
With regard to corrective actions of identified noncompliances, the
-1 Midland response seems to leen towards doing a partial job and then writing up a detailed study to explain why what they have done is sufficient rather than doing a more complete job and assuring 100%
corrective action has occurred. In the detailed writeups that are prepared, it is the staff's view that the licensee does not always represent the significance properly,and the analyses and studies often raise more questions than they solve; thus time appears to have l
been wasted in writing an analysis rather than in fixing the problem.
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2.
Midland site appears-to be overly conscious with regard'to whether
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or not something is an item of noncompliance and s.' ends a lot of effort on defending whether or not something should be noncompliance as opposed to focussing on the issue being identified and taking corrective action. This appears in part to be due to their sensitivity of what appears in the public record as official items of noncompliance.
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This sensitivity may have resulted from the extended public visibility which has attended construction of the facility. The staff's view is l
that the Midland site would look better from the public standpoint and be more defendable from NRC's standpoint, if they concentrated on fixing identified problems rather than arguing as to the validity of citations.
This type of view was expressed by the utility during a recent effort to clarify in detail that certain construction items on the soils l
remedial work should not be subject to NRC's regulatory action.
3.
The Midland project is one of the most complex and comp 11 Acted ever undertaken within Region III.~
The reason is that they are building
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two units of the site simultaneously and additionally have'an underpinning 0
construction effort which in itself is probably the equivalent of building a third reactor site. The massive ' construction effort and the - ":ious stages of construction activity which are involved make the site extremelycomp14stedtomanage. This activity appears to cause a lot of
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pressure on the licensee management.
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Mr. J. Cook, the Vice President responsible for the Midland site is an extremely capable and dynamic individual. However, these char.cteristics in conjunction with the complexity and immenseness of opera. ion as set forth in 3, above, may actually be ' contributing I
to some of the confusion which seems to exist. The staff views chat l
(1) he is too much involved in detail of plant operations and there are l
times when the working level staff appears to agree and be ready to l
take action where Mr. Cook may argue details as to the necessity for such action or may argue as to the specific meaning of detailed work procedures, (2) this kind of push may lead to such things as letters both signed and unsigned appearing in NRR and causing confusion.
(3) this push may lead to some animosity at the licensee's staff level if NRC activities are looked on as slov 7rogress of construction at the site, Recommendations g
It appears essential that some action be taken by NRC to improve the regulatory performance of the Midland facility. The following specific suggestions are made.
1.
The company must be made aware and have emphasized to them again i
that their focus should be on correcting identified problems in a i
complete 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 currently exists at Midland. We would suggest specifically that the following activities be considered:
a.
That the licensee cut back work and dedicate their efforts to getting one of the units on line in conjunction with doing the soils remedial work.
b.
That they have a separate management group all the way to a possible new Vice President level, one of which would manage the construction of the reactor to get it operational and the second to look solely after the remedial soils and underpinning activities.
3.
Consumers Power Company should develop a design and construction verification program by an independent contractor. This would provide an important additionni measure of credibility to the design and construction adequacy of the Midland facility.
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James G. Kappler 6/2/1/82 We would be happy to discuss this with you.
.C if h.L-C. E. Norelius Director Division of Engineering and Technical Programs
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\\ *h,/ g.fCt+f k R. L. Spessard, Director Division of Project and Resident Programs I
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i REGION lil 790 ROOSEVELT MoAO s
GLEN ELLYN,ILLINolS 90137
- e*ee July 23, 1982 MEMORANDUM FOR:
R. F. Warnick, Director, Enforcement and Investigations Staff FROM:
R. J. Cook, Senior Resident Inspector, Midland Site
SUBJECT:
INDICATORS OF QUESTIONABLE LICENSEE PERFORMANCE - MIDLAND I
SHE
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As per our conversation of July 21, 1982, the following is a list of those t
items that various inspectors consider to be indicativa of questionable j
licensee performance:
1.
One of the leading items is the over-inspection performed on electrical QC inspectors which was done in response to NRC concerns identified in the May 1981 team inspection. The licensee found weaknesses in the inspections performed by some electrical QC inspectors pertaining to not identifying the mis-routing of cables. This item culminated in an item of noncompliance. The licensee did not expand the overview activity to I
a degree necessary for an acceptable resolution to the identified weak-l ness - even after a meeting in RIII. Th,is item has not been resolved to the satisfaction of the NRC although our position has been clearly defined.
As a partial response to the team inspection concern, the licensee presented the NRC with an audit report which would demonstrate a response to m r con-corn of questionable electrical QC inspections. However, the audit report stated that it (the audit report) did not address the NRC concerns.
2.
During the dialogue for the underpinning and remedial soils work, a large amount of emphasis has been placed on the settling data for the structures involved. During a meeting in HQ on Marr.h 10, 1982, the need for QC require-ments on remedial soils instrumentation were explicitly delineated. However, one week later, the.NRC inspectors found soils work instrumentation instal-lation was started the day after the March 10,'1982 meeting without a QC/QA umbrellas that the licensee's QA Auditor and QA Engineering personnel were not approached pertaining to the.need for QA coverage for this soils settle-ment instrumentation; that there were strong indications that the licensee had mislead the NRC in relating that the work was essentially complete when indeed it was nots and presently, the licensee management informs our inspec-tor that items are ready for his review when in' actuality they are not. Our conversations with licensee personnel - other than management - confirm that the items are not raady for review.
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Historically, one of the NRC questions has been, "Whu is running the job - Bechtel or Consumers?" The following example would allow one to believe it is Bechtel: As a part of the resolution to our findings in
'f the soils settlement instrumentation installation, the NRC insisted that
]
the licensee generate a Coordination / Installation Form to cover interface between different evolutions of instrumentation installation. The licem-see would call our inspector for his concurrance on the adequacy of the form - the inspector would approve Consumers Power Company's form, but then would find out that Bechtel did not want to work to Consumer's form -
l the form that was generated to resolve regulatory concerns. This event has. occurred twice and was considered as a deviation during a more recent inspection. The opinion of the staff is that if Consumers generates a form that will aid them in not incurring regulatory difficulty, and which has had NRC input, the licensee should demand that the contractor comply with these policies.instead of the contractor dictating the regulatory environment under which they will work.
4 l
4.
Deficiencies in material storage conditions has continually been a concern I
to the NBC and has resulted in items of noncompliance. To the inspectors, the ability to maintain quality storage is indicative of how rigorous or j
slipshod the constructor's attitude is towards construction. The licensee i
1 has attemted to entice the constructor to do better in maintaining the l
material storage conditions, but still the licensee's auditors and the j
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NRC have negative findings in material storage conditions and negative
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discussions with the contractor about the validity of the finding.
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5.
At periodic intervals, the support of. cables, particularly 'in the control room area, which are awaiting further routing or termination, has met with 1
the disapproval of the NRC inspectors. These discrepancies also include i
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 workmanship which has been brought to the constructor's attention at various times, but was last noted during a recent inspection.
1 i
6 In the area of instrumentation impulse'line installation and marking, the l.
licensee has had separability violations which has required removal of all installed impulse lines. ' Also, the' NBC, because of this and significant -
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adverne operational conditions, insisted that the installed impulse lines be identified. Although the licensee plans to mark the impulse lines, l
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there was an inordinate amount of resistance to marking the lines - even l
though there had been instances 'of mis-matched channels because of iden-tification confusion.
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An example of reluctance in placing the recponsibility for quality work-manship at the foreman and/or worker level has recently been identified.
The NRC inspectors noted that scue drop-in anchors were improperly instal-led and obviously did not adhere to the installation procedures. The licensee's attitude indicated this vna not a valid finding because QC had not inspected the item.
The NRC ' a pectors treat this as indicative that slipshod workmanship is tolerated in the hopes that QC will find the mistakes.
8.
Late in 1981, the licensee decided to move the QA Site Superintendent into another position and cover this site function by sharing the site time be-tween the QA Director and the QA Manager. Af ter a January 1982 meeting with the NRC at RIII, the licensee opted to fill the QA Superintendent spot with another person.
In the spring of the year, the NRC inspectors were following up on welding allegations and approached the QA Superintendent. The QA Superintendent was familiar with the alleged poor welding and had established what the NRC inspectors determined to be a responsive plan to resolve the questionable QC welding inspections. At the Exit Intersiew, the QA Director did not appear to back the QA Site Superintendent's proposed plan which had tacit NRC approval. The NRC inspector classified in writing and with just cause that the Exit Interview was the most hostile exit interview he had ever encountered.
9.
During a recent inspection, it was noted by the NRC inspector that fill dirt was piled and being covered with a mud met at a nominal 1:1 horizontal to vertical slope when the specification called for a 1 :1 horizontal to verti-cal slope. A constructor Field Engineer witnessed the wrong slope being installed and justified and defended the slope after being informed of the specification requi rement. This is another example of the ecnstructor having an attitude which precludes quality workmanship.
10.
Atdifferent times, NRC inspectors have experienced difficulty in getting information which is controlled by the contractor, such as supporting cal-culations and qualifying information to justify a given installation. A recent example is: the NRC inspector informed the licensee and the contrac-tor he wanted to see resumes of persons involved in the remedial soils work.
There is an obligation to the NRC to supply a precise number of " qualified" persons on the soils work. The inspector was informed he could not get these records as they were personal. The inspector ultimately did get the informa-tion after bringing it to the attention of licensee upper management.
How-ever, this indicates an implied unwillingness of the constructor to share information with the NRC and sometimes with the licensee.
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11.
The licensee oftentimes does not demonst rate a " heads up" approach to i
their activities. The following are examples of the licensee operating I.
in an environment using tunnel vision
" blinders".
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a) During a recent NRC inspection, the inspector challenged the ability i
to maintain the proper mix ratio on high pressure grout. This was done after.the inspector noted that the operator could never maintain the proper mix ratio without coni.inual manual control - which was not available when the groui; is applied. The licensee's apathetic atti-
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tude did not allow them to stop the grout application until the next i
day when this became an issue at the exit interview.-
l'j b) At one point in. time, the company doing drilling on site for the j
remedial soils work cut into a safety related duct bank between the l
Miesel generator building and the service water building. The Consu-mars Power Site Manager's Office (the production people) stopped work 4
- because - from a quality standpoint conditions were so deplorable.
i' However, the Site Manager's Office did not have responsibility in this i
area - the Midland Project QA Department had this responsibility and did not invoke their authority to prevent the drilling work from get-ting out of control - or to bring it back into control..
1' c) The NRC inspector recently witnessed the licenses setting up to drill l
a well hole in safety related dirt using a technique which was not
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authorized. If the inspector had not brought this to the licensee's I
attention, the licensee would have violated an order addressing reme-dial soils work 'and also the Construction Permit. When the licensee was queried as to the availability of the QC/QA personnel who would prevent such activity. from happening, the NRC inspector was informed that this was (another) misunderstanding.
- The NRC inspectors have been informed by our contacts on site that there are memoes written to the effect chat " peripheral vision" should be cur-tailed and comununication with the NRC stiffled. The NBC has not read these memoes yet - but plans to in the near future, provided they really exist and infer what we have been informed.
- 12.. The licensee seems.to possess the unique ability to search all factions of the NRC until they have found one that is sympathetic to their point-of view - irregardless of the impact on plant integrity. Some examples I:
of this 'are:
' a) The NRC soils ' inspector. informs the licensee that soils stabilization
-grout comes under the Q program. The licensee is not particularly happy with -this position.. Unknown to the : inspector, ~the licensee :
argues his point with NRR to have the grout non-Q - using only those-arguments which support his (the licensee's) position. The licensee t !
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July 23,1982 i
has the advantage of the NRC inspector's technical and regulatory i
basis for supporting his (the inspector's) position, and therefore i
avoids mention of this during the discussions with NRR.
- However,
' the licensee's QA program, which has already been c.pproved by NRR, states that all the remedial soils work is Q unless RIII approves a relaxation on a case by case basis. It appears the licensee does not wish to acknowledge the prior agreements with the NRC.
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j b) Since the failure of auxiliary feedwater headers in B&W steam genera-j tors, discussions have transpired between the NRC inspectors and the site personnel. These discussions have indicated that the licensee s
l was maintaining'a conservative approach and were entertaining the concerns expressed by the NRC which were stimulated pri'narily by gross mistakes in attempting the modification at operating B&W plants. The licensee's corporate personnel were annoyed that the NRC inspectors would not give approval to start the modification until all the pre-paratory work.had been accomplished as this would tend to impact the schedule and the modification to the steam generators could become a scheduling nuisance. The licensee corporate personnel contacted the NRC inspectors involved to " reason +11th them".
However, the corpor-i ate personnel, (including a representative frem B&W) were unable to answer the concerns of the NRC inspectors but did mention that the NRR l
operational Project Mainger indicated that it was alright to proceed i
with the modification. The licensee corporate personv l could not state what the position of th. NRR Construction Project Manager was on l
this issue - only that they had found some form of approval from some-one in the NRC.
c) At times, when'Inmedia L Action Letters or other forms of escalated i
enforcement become isuminent, the licensee attempts to " appeal" their 1.
case with individuals in the regional management who are removed from the particulars of the tentative enforcement action. The licensee at-tempts to get these persons to agree to specific portions of the issue
- which would indicate that the licensee is "really not.all that bad".
However, the "real" issues, as identified by the NRC ihspectors are being masked.-
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d) During inspections of the remedial soils work, the NRC inspector has l'
been informed by the licensee that certain findings and ~ areas of inspec-tion.were not within the purview of his (the inspector's) -inspection il program because they were in essence considered non-Q and that by virtue of prior agreement with the Regional Administrator were excluded from -
enforcement action. However, the NRC inspectors would subsequently find '
that there was no such agreement between the Regional Administrr. tor and the licensee - only'a philosophical discussion as to what, in jeneral terms,' constituted an item of noncospliance.
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The above indicators support the reputation the licensee has for being argumentative. Their apparent inability to accept an NRC position with-
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out diligently searching to find a " softened" position results in numer-t ous hours of frustrated conversations between all parties involved to resubstantiate (usually the original position) a position based on tech-nical and regulatory prudency.
13.
The licensee has been classified ptblicly by the NRC as being argumenta-tive. The licensee continues to exhibit this trend, as evidenced oy the following examples a) Essentially every item of noncompliance receives an argumentative answer which addresses only the specificity of the item of noncom-pliance and selectively avoids any concept which would support the essence for the item of noncompliance. For example. - in the instance of the improperly installed drop-in anchor mentioned above, it was the fact that QC had not inspected the installation of the bolt which was important to the licensee. However, the real enforcement issue was that components were being improperly installed.
b) The Cycle II SALP made critical evaluations of the licensee's perfor-mance in several areas. The licensee's response to this SALP report was argumentative over specific details and did not seem to acknowl-j edge that the consensus of opinion of the NRC inspection staff was that there were areas where tne licensee's performance was weak. The I
licensee's argumentative position is in the form of "we really are not all that bad" when the records, findings and observations of the NRC inspectors support just the opposite position.
c) The "Q-ness" of the remedial soils work has continurlly been an argu-mentative topic of discussion which ultimately resulted in a HQ meeting on March 10, 1982. At this meeting, the "Q-ness" of the remedial soils work was specified and later documented with the meeting minutes. How-ever, the licensee did not wish to abide by this position and a subse-l quent meeting was held in RIII to further clarify the NRC position.
till, the topic of "Q-ness" is being argued by the licensee, even though the ASLB has issued an order further defining the "Q-ness" of the soils work. It might be noted that a hearing is in process over this soils issue and the NRC's position on "Q-ness" has been expressed during these testimonies.
14.
During a recent episode, the licensee wanted to continue excavation of soils in proximity to the Feedwater Isolation Valve Pit (FIVP). However, the licen-see wanted to perform this evolution without determining that the temporary supports of the FIVP were adequate. Making this determination would have an impact on scheduling, as stated by the licensee. The FIVP supports were installed without a Q umbrella and subsequent inspections did reveal several discrepancies in the installation of the support structure.
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July 23, 1982 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 duce 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 i
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NRC as to the adequacy of review prier to attempting to drill, the NRC j
receives responses which strongly suggest that the time was not taken to perform these reviews - perhaps taking this time would impact on the j
schedule.
i 16.
By virtue of an earlier ALAB Order, the licensee is required to perform trend analyses for nonconforming condition.. These trend analyses have, in the past, masked the data such that obvious trends are not obvious and J
has resulted in negative findings by the NRC.
This was addressed in one of the earlier SALP meetings. Recently, while performing a review of hanger welding data, the NRC inspector found that the statistical data had been diluted to the point that the number of unsatisfactory hangers could not be determined from the trend analyses or the type and degree of non-conforming conditions which were being identified pertinent to the hanger
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fabrication.
17.
The licensee continually would use the NRC staff as consultants and clas-sifies a regulatory and enforcement position as counter productite. This i
is reflected by the licensee not wishing to perform Q-work without obtain-
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ing NRC prior approval and then addressing only those areas where the NRC has voiced a regulatory concern - provided,it is convenient to the licensee.,
l This attitude has particularly prevailed in the remedial soils issue and to q
a lesser degree in the electrical installation areas. The preferred NRC f,
inspector mode would be for the licensee to generate his program to esta-blish quality and then the NRC would approve or disapprove. However, the licensee requires consultation with the NRC to establish-his level of quality requirements.
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The above is not intended to be a complete list of all discrepancies which indi-cate questionable licensee performance as this would require a more extensive review of the records and inspection personnel involved than time permits.
Also,.
there has been no attempt to systematically document the enforcement and unre-j.
l solved items list as these are contained in other information sources. However, 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.
When considering the above listing of questionable licensee performance attributes, the most damning concept is the fact that the NRC inspection effort at. Midland has been purely reactive in nature for approximately the last year, and that these 1
indicators'are what have been observed in approximately the last six months. If l
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these are the types of items that have become an NRC nuisance under a reactive inspection program, one can only wonder at what would be disclosed under a rigorous routine inspection and audit program.
Sincerely, l
.l-i R. J. Cook Senior Resident Inspector Midland Site Reaident Office cca W. D. Shafer i
D. C. Boyd R. N. Gardner R. B. Landsman B. L. Burgess i
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" MIDLAND-ACTIONS RECOMMENDED BY THE MIDLAND SECTION, OFFICE OF SPECIAL CASES" i
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1.
Establish an augmented inspection effort by the NRC.
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Inspections should be concentrated in the folloaing ten areas:
a.
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(1)
S,*ls (2) Electrical i
1 (3) I&C (4) High Pressure Piping j
(5) Hangers and Supports (6) Corrective Action Svatem - including identification documentation, resolution, and prevention of future events.
(7) Receipt, Storage, and Handling (8) Structural Steel (9) Subcontractor Welder Qualification j
(10) Management Overview System 1
b.
The effort as initially conceived will 7.ast from 6 to 12 months but it could last longer.
It is proposed that the inspections be performed by the Midland c.
Section and 5 contract inspectors assigned fulltime to the Midland Section and located onsite. The Midland Section would be as follows:
(1)
W. D. Shafer, Chief, Midland Section (2)
R. N. Gardner, Project Manager (3)
R. B. Landsman, Inspector (4)
R. J. Cook, Senior Resident Inspector (5)
B. L. Burgess, Resident Inspector r
(6) Uelding & NDT-Contracted I
(7) Mechanical-Contracted (8) Electrical-Contracted (9) I & C - Contracted (10) Startup & Test-Contracted (11) Secretary (Fulltime) 2.
Require the licensee to have an independent third party look at a vertical slice of a safety-related system from design through completion of construe. ion.
3.
Require that all QC it.soectors be independent cf Bechtel, reporting only to CPCo.
4.
Conduct NRC exits with Construction Manager.
5.
NRC should get comnitments in writing and should give release on hold points in writing.
6.
It is proposed that Mr. Keppler and Mr. Denton meet with Consumers Power Company and Bechtel top ranagement to ensure that steps are taken to correct the followingt i
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1 a.
The Site QA Superintendent is not being given the latitude and senior management support needed to perform his job effectively, b.
Senior management is not being made aware of or is not dealing with QA problems.
c.
We are convinced that Bechtel has cost and scheduling as their fore-most consideration. Quality is taking a back-seat with management.
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