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CONSUMERS POWER CO.
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Mr J G Keppler, Regional Administrator y
US Nuclear Regulatory Ccanission Region III Rg'..
799 Roosevelt Road Ay._
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MIDLAND PROJECT RESPONSE TO DRAFT SALP REPORT FILE 0.6.1 SERIAL 17485 On April 26, 1982, Mr J G Keppler and members of the NRC Region III staff met with Consumers Power Company personnel in Jackson where the NRC presented the observations and findings of the Midland SALP board for the period July 1, 1980 to July 30, 1981. At the conclusion of that meeting we were informed l-that we should make written comments to the Region III office within 20 days of that meeting date. This letter transmits Consumers Power Company's response to the draft SALP evaluation report and to other comments made by.
Mr Keppler at that meeting.
Our general reaction to the SALP evaluation can be summarized as follows: We support the SALP goals and objectives because we believe it is vital to have l
an active and continuing dialogue with those who have direct regulatory responsibility for the Midland Nuclear Plant. We do believe, however, that the SALP process has not yet reached maturity and there are areas where the process can be made more effective. With regard to the specific contents of the draft SALP report, we are concerned with what we believe is an unnecessarily negative characterization of the inspection results for the period covered by the SALP report. Because of this concern and o " belief that the facts do not support the characterization presented by the authors of the draft SALP report, we have spent considerable time reviewing the detailed information on which the draft SALP report was based, and this analysis forms the basis of our attached response. We believe a careful review of this material will enable Region III management to. understand the basis for our l
concern and to gain an appreciation for our perspective in this matter.
In addition t the review of the draft SALP report, Mr Keppler made several comments at the April 26 meeting regarding his own participation in both the NRC team inspection of May 1981 and his subsequent testimony in the ASLB hearings on the soils matter. In order to respond to those comments we have also included additional material and analyses that directly respond to Mr Keppler's comments.
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Our detailed response to the SALP report and Mr Keppler's comments has been divided into three attachments transmitted with this letter. A description of each of the attachments follows.
- is a detailed review of the entire draft SALP report and the inspection results upon which the SALP report was based. We conclude that the details of the SALP analysis support a more positive conclusion than was presented at the SALP meeting. The basis for this suggestion is that there appears to be considerable overstatement of the actual severity of the inspection findings, some factual errors and omissions within the draft SALP report itself, and further, there are some assignments to this SALP evaluation of events that occurred prior to the SALP evaluation period, all of which contribute to an unnecessarily harsh characterization of the Midland Project regulatory performance during this SALP evaluation period. Attachment I also i.
contains our comments on the SALP process.
1 to this letter is a comparison of Mr Keppler's testimony in the 1
Midland soils hearing with the specifics of the draft SALP report. This detailed comparison concludes that even with the generally negative l
characterization of the Midland Project by the SALP board, there is still no contradiction of Mr Keppler's prior testimony by the draft SALP report nor any need, in our opinion, for him to modify that testimony.
The third attachment to this letter entitled " Analysis of Current and Future l
Quality Activities With Regard to Remedial Soils Work," addresses specific questions raised by Mr Keppler at the conclusion of the SALP meeting. This attachment points out that there appear to have been considerable regu11 tory difficulties experienced by the Midland Project during the past two' months, mainly because of the inability of the NRC staff and the Company to finalize the quality assurance program coverage requirements for the soils remedial work, particularly for the underpinning activities. Attachment 3 points out that this difficulty appears to have been generally resolved and that there are numerous reasons for confidence that with the regulatory requirements properly defined, the remaining soils work can be carried out in a fully l>
satisfactory manner.
b Consumers Power Company urges the Region III management and staff to carefully consider the information and reasoning contained in this response to the April 26, SALP meeting. We believe that there is ample basis for the Region Administrator to reaffirm his 1981 overall team inspection findings in his overall conclusion to the 1980/1981 SALP evaluation.
Finally, as noted previously, we were disappointed with the negative tone of the draft SALP report. We take very seriously the comments made by the Region III SALP board members and will do whatever we can from the applicant's point of view to engender productive working relationships with the staff and to be responsive to the staff's concerns. Nevertheless, we must disagree with some of the materi=1 in the draft SALP report, and we request the opportunity to meet with g e3 and his staff to revieu the detailed contents of this response.
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Dis'tribution: Keppler (3 copies)
CC: Atomic Safety & Licensing Appeal Board CBecthoefer, ASLB 191 Cherry,Esq FPCowan, ASLB RJCook, Midland Resident Inspector SGadler JHarbour,-ASLB DSHood RBLandsman WHMarshall BStamiris MSinclair 4
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BCC: WRBird, P-14-418A JEBrunner, M-1079 DMBudzik, P-24-517 NRC Corres File, P-24-517 AJBoos, Bechtel AA MLCurland, Midland LHCurtis, Bechtel AA MADietrich, Bechtel-Midland WDGreenwell, Bechtel AA GSKeeley, P-14-113B d
MIMiller, IIAB-Chicago JAMooney, P-14-115A JARutgers, Bechtel AA TJSullivan, P-24-624A DMTurnbull, Midland RAWells, P-14-113A oc0582-2048a102
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CONSUMERS POWER COMPANY RESPONSE TO THE DRAFT SALP REPORT FOR THE MIDLAND NUCLEAR PLANT t
Reference:
1.
NRC letter; J A Hind to J W Cook; dated April 20, 1982; with
- Enclosures 1 and 2.
This response isiin three parts. The first part provides a general response to the 4;;.
SALP appraisal and SALP process as a whole. The second part provides our detailed i
_ response to Enclosure 1 of the reference, the Significant SALP Report Findings. The l
third part provides a detailed response to Enclosure 2 of the reference, the Pre-liminary SALP Report, dated March, 1982, covering the* assessment period of
, July 1, 1980 to June 30, 1981.
Part 1 - General Response A.
We are encouraged by the general statements to the effect that the NRC sees pro-l
- gross in Consumers Power Company's overall quality assurance program and in its management. Undoubtedly, there has been improvement in our regulatory performance-from the 79/80 assessment period to the 80/81 period and from the 80/81 period to the present. Literally, dozens of actions have been taken in
. order to achieve this improvement. These. actions have been communicated to the NRC.
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In May, 1981, Mr Keppler and members of his staff performed an extensive team inspection from which they concluded that "... the scope and depth of this NRC t'
inspection was such that the identified noncompliances do not contravene our a
g conclusion that Consumers Power-Company has established en~ effective organisation for the management of' construction and implementation of quality li assurance at the site."
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B.
We are, however, disappointed by the overall negative tone of the draft SALP (I
Report. Nonetheless, we continue to be dedicated to attaining two goals F p
1.
First and foremost, to ultimately assure that the as-built configuration of the plant is in conformance with all regulatory and design requirements; 1
- and, i
l 2.
To continue to improve our regulatory performance.
W C.
We weicone feedback relative to our regulatory performance--the sooner the better. We have encouraged such feedbacx in a number of ways, and we shall continue to do so.
A number of meetings with Region III management and staff j.
l' have been at our initiative. On numerous occasions we have proposed the establishment of routine, periodic meetings to exchange information with Region III's home office staff. On our own initiative, we submitted our Prooperational Testing Manual in order to obtain Region III review and comments at an early l
' date. Our specific invitation may have contributed to Mr Keppler's personal participation in the NRC team inspection conducted in May,1981. We have proposed that an NRC Inspector be on site as much of the time as possible to assess our remedial soils work. Of course, at the completion of NRC inspec-tions, exit interviews with the Inspectors are a routine feedback mechanism.
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D.
In reviewing how to improve the Company's overall regulatory performance, it
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becomes evident that the most timely regulatory feedback is that which is received before the accomplishment of the work in question. While both' Consumers and the NRC attempt to achieve this objective, we believe both our organizations have fallen short in this area.
It is our re"==aadation that the NRC consider scheduling seminars for the various ongoing nuclear construction jobs as they approach each major phase.
'One purpose of these seminars would be to review the detailed quality programs T
and procedure for each major new activity at each job. This review would verify that all programmatic requirements at the detailed level were in place prior to the work or could be upgraded before the fact to meet Region III expectations. In addition, the NRC inspection specialists could review with the applicant's quality personnel typical detailed inspection plars used by the NRC in their on-site inspections. At the same time, discussions of actual experience from other earlier construction sites could aske the Licensees for current construction sites more aware of and responsive to potential problems in f
.the work aras about to begin.
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We in industry have tried to accomplish this objective with our various regional and industry groups, and by reviewing inspection reports from other jobs.
However, these efforts suffer by lack of NRC input at detailed working levels.
4 We urge the NRC to consider this type of an approach to supplement.their other inspection programs.
A specific benefit to Midland's futu're performance has already occurred as a result of this concept. It was mentioned at the SALP meeting that we had submitted our Test Program Manual to Region III some time ago in order to obtain feedback prior to the start of detailed systems testing. Even though some testing has already taken place, we are delighted to report that follow-up from the April 26 seating has resulted in the scheduling of a detailed NRC review of the Midland test program for later this month.
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E.
We recognize that the SALP process is a relatively new one and that the NRC is attempting to develop an approach to the SALP reviews that will be timely, fair
[1 and based on the best available information. This second SALP Report is a major improvement over the first, National SALP Report which was issued in the fall of 1981. Nonetheless, our review of this SALP Report discloses additional improvements which can be achieved in meeting the objectives of the SALP 3
process.
First, there appears to be no consistent format in characterizing the areas which are being evaluated. The assessment can be made by functional engineering areas such as soils, containment, piping, etc; or it can be made on the basis of discrete engineering activities such as design, procurement, construction, etc.
'The current SALP Report has both categorizations which leads to an inevitable double counting of deficiencies identified during a reporting period. The report itself recognizes this probles, but discounts it.
We appreciate the need perceived by Region III for singling out certain specific wcivities, such as ll design control, for separate treatment in the SALP Report. However, the overlap l'
of function and activity categories detracts substantially from the systematic
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1-3 Region III to express its particular concern with a designated activity other than the SALP Report.
Second, the rankings do not appear to be consistent. For example, no items of noncompliance were identified with respect to the Fire Protection, Containment and other Safety-Related Structures, and Preservice Inspection areas. Yet Fire Protection was rated a " Category 1" while Containment and other Safety-Related j}
Structure and Preservice Inspection were rated a " Category 2."
We believe that the major' criteria in evaluating licensee performance should be
.the number and seriousness of items of noncompliance identified by NRC for a l
given unit of inspection time. We are not suggesting that.there is no room for subjective judasent in the appraisals of each area. What seems to occur, however, is a lack of consistency from area to area in applying the factors which shape that judgment. Moreover, we note that most of the specific items discussed were the subject of testimony before the ASLB conducting the soils hearings. Yet no review of that testimony seems to have taken place.
,1 Finally, the time period during which the Licensee's performance is being evaluated is unclear. Part V of the Preliminary SALP Report does indicate that the noncompliances and deviations in the HVAC area were reported also in the first SALP report. However, one ites of noncompliance listed in the Piping i
Systems and Support Performance Evaluation related to an apparent nonconformance that took place in November, 1973, but was identified during an NRC inspection during the SALP evaluation period. In addition, all of the 50.55(e) reports t
' cited in the Preliminary SALP Report represented design deficencies which-occurred long before the SALP period. If those are the groundrules for the SALP process, they should be clearly stated. The Licensee and the public will then recognize that the evaluation rests not only on events which occurred during the 7
evaluation process, but also on events identified during the evaluation period, regardless of when they took place.
What follows is a response to specific statements in the Preliminary SALP Report.
Those specific statements are either direct quotations from, or characterizations of, items which were included in various NRC inspection reports. We have responded
. in writing to each inspction report and refer you to those responses for the details of the Company a position regarding each ites. However, some of the characterizations of the findings of the inspection reports in the Preliminary SALP Report'are incomplete. For your convenience, we have susmarized our responses to each of the inspection findings, as well as clarifying the content in which those findings arose, as appropriate.
1,
Part 2 - Response to Enclosure 1. Sinnificant SALP Report Findinas I'
A.
General Observations 1.
We are pleased that the Preliminary SALP Report noted the " improvements in i-the overall quality assurance progras"; that we have " established an effective organization for the management of QA/QC activities"; and that "the numbers and qualifications of personnel in the QA/QC organization (s) i oc0582-0039a167 4
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1-4 and the overview and audit functions performed were found to be above that normally found at other construction sites."
i 2.
Also, we are pleased that for the Support Systems (HVAC) area the Preliminary Report recognized our resolution of the problems which existed during the previous SALP period prior to July 1, 1980. This resolution was realized through considerable expenditures of resources. We believe this demonstrates our responsiveness to problems with concrete actions.
3.
The general observations relative to the less technical administrative areas are of concern to us.
We do not view our past responses as argumentative merely because they provide additional facts or reasoning which may not have boca available for presentation to the NRC Inspector at the time of the exit interview or because they provide information with which the NRC Inspector disagrees. The Staff, in at least two instances in the soils hearing, testified that making legitimate appeals is entirely proper, and is part of the normal give and take betvean the NRC Staff and the licens u.
It is disappointing that the Preliminary SALP Report does not embrace the essence of that testimony and also of our management conference on this subject. At that conference, we were told not to be reluctant to appeal on any legitimate issue, but to discuss our differences with Region III prior to submitting any written appeal in order to facilitate its resolution. This suggestion has. bun adopted.
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B.
Pipinz Systems and Supports 1.
We agree with the Preliminary SALP Auport ites relating to the unavailability of Committed Preliminary Design Calculations (CPDCs) to support the drawings for small bore piping. This, in our opinion, was the major quality deficiency that occurred during this SALP period. Upon discovery of the unavailability of the CPDCs, we stopped the design work, began immediate correctiv6 action, and did not resume the work until both we and the NRC Staff were assured that the process had ban. corrected. gen with the design crecess defici4ncy identified it is heartening to report inst not a minela nina seement reauira.1 r - rk am a v== nit of this
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situation.
2.
We also note with pleasure that the informal current rating in the Piping Systems and Supports area as of this time is " Category 2" based on Mr R Cook's statements made during the April 26 presentation of the Preliminary SALP Report. This improved rating is, we assume, based upon recognition of our positive and effective corrective actions in this area.
C.
Electrical Power Supply and Distribution 1.
While we understand that any noncompliance is "less than desired" and also understand the Staff's particular interest in our ambitious cable pulling schedule, we do not understand the apparently negative observations in this area. The implication given is that were it not for the NRC's advice, we would have had an inadequate number of QA/QC personnel available to support the cable pulling schedule. This is an erroneous implict. tion. We believe we have always supported the cable pulling activities with the appropriate oc0582 0039a167
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t number of QA/QC personnel. In fact, the amount of cable pulling carried out j
by the Company could not have been completed without adequate QC personnel, l
because in process inspection is required to verify cable pulling tensions.
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- 2. -We also believe that the seven items identified during this period were not excessive and were of relatively low consequence. These items are discussed
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i more fully in the third part of this Attachment.
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D.
Soils and Foundations t
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1.
We view the finding in this area especially harsh because it is predicated l
on some relatively minor items of noncompliance, and on misinformation in i-the Preliminary SALP Report, as demonstrated in the third part of this Attachment.-
2.
Reference is made to " limited QA/QC coverage." At no time has the QA/QC staff been insufficient to cover the ongoing work. At one time the NRC advised us of the need for additional personnel to cover future work. We were fully aware of and agreed with that need, and we have staffed and are staffing to meet it.
Also, in our opinion, there has never been any inadequacy in the qualifications of the QA/QC personnel assigned to the remedial soils work. The QA Engineers so assigned are all degreed civil engineers.
Part 3 - Resnonse to Enclosure 2. Preliminary SALP Resort A.
Section I. Introduction
!t Our comments on this section.are found in our general comments provided in Part
,l 1, above.
i 3.
Section II. Criteria a
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1.
Our general comments relating to the manner in which evaluations are made i
y are contained in Part 1, Paragraph E, above.
l-C.
Section III. Summary of Reevlts b
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Our comments on this section are found in our general comments provided in
-Part 1. Paragraphs A and 3, above.
t D.
Section IV.1. Performance Analysis of Quality Assurance p
- 1. - It is gratifying, 'as noted earlier, that the NRC recognises our above normal efforts with regard to the Quality Assurance organisation and program, with l.
regard to our overinspections and audits, and with regard to our p
aggressiveness in assuming the primary inspection responsibility for the MVAC installation.
p 2.
Seven of the eight items identified from the May,1981, inspection and referenced in this section of the Preliminary Report are duplicated elsewhere in the report under the Soils, Piping and Supports, and Electrical oc0542-0039a167 e
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Sections. Therefore, we will address these noncompliances specifically in the other sections.
l 3.
The eighth item from the May, 1981 inspection dealt with the correction of l
adverse quality trends. Action was taken to provide a procedural change to cause the more timely closeout or verification that correction has been made in response to an adverse trend.
Our trend analysis activity is among the most comprehensive anywhere, in terms of scope and sophistication. Such an activity is not spscifically required by NRC regulations or ANSI standards. Should not credit be given for this?
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4.
This section of the Preliminary Report also refers to another inspection I
" indicating questionable QA managerial control (because) the licensee failed to fully evaluate the technical capability of the i
principal supplier of services for soil boring activities."
I This is an unfair and incorrect summary of what occurred.
The original NRC Inspection Report states:
"The technical capabilities of Woodward-Clyde (principal supplier of services for soil boring activities) were not evaluated prior to commencement of drilling operations on April,2, 1981."
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.g Our original letter of response stated:
"On March 31, 1981, Consumers Power Company approved Woodward-g Clyde consultants as the principal supplier of services for the soils boring and sample program based upon meetings (between March 3 and 11, 1981) with Woodward-Clyde consul-tants.
.. Woodward-Clyde consultants were considered qualified as documented by letter serial 12134, dated April 8, 1981, N Ramanujav to File B.2.5.4 (Attachment 1).
k Even though this letter is dated April 8, 1981, it documents steps taken prior to April 2, 1981, in qualifying Woodward-Clyde. Woodward-Clyde consultants were approved by Oral Communication Report serial 11883, R C Hirzel to R C Bauman, dated April 2, 1981, (Attachment 2).
Both of these documents
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(Serials 12134 and 11883) were presented to Dr Ross Landsman of the Nuclear Regulatory Coanission on April 9, 1981."
g This is not " questionable QA managerial control." This is not " failure to fully evaluate the technical capchility of the principal supplier." The e
documentation was provided to the NRC Inspector.
The actual noncompliance was failure to provide our Procurement Department with the letter doc'unenting the approval of Woodward-Clyde prior to the commencement of activities.on April 2.
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Also, this same paragraph of the Preliminary SALP Report states:
5 "The NRC identified 15 deficiencies in the principal supplier's quality assurance program manual indicating that the licensee had not adequately reviewed and approved the procedures prior to preparation of drilling activities."
,1 We are concerned both about the substantive and procedural implications of lF this comment. The 15 items referred to were generated as a result of our j
quality assurance programmatic requirements. The NRC Inspector participated with us in the initial and timely review of Woodward & Clyde's quality t
assurance manual. We welcomed his participation and anticipate that it will 4
<j continue, at least through the conclusion of the soils remedial work. But it is simply counterproductive and unnecessarily adversarial for the NRC 2.
Inspector to "take credit" for having identified these deficiencies.
Indeed, he did not'do so.
In any event, the important point is these items B
were uncovered in a routine review,'in accordance with established quality 1.
assurance practices. Had they gone undetected past the review stage, some sight have risen to the level of " deficiencies." Our timely handling of 4
these matters is inappropriately characterized as a deficiency in the Preliminary SALP Report, when in fact it represents the proper functioning of the Quality Assurance Program.
E.
Section IV.2. Performance Analysis of Soils and Foundations 1.
The second paragraph of this section of the Preliminary SALP Report, states:
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"Every inspection involving regional based inspectors and addressing. soils settlement issues has resulted in at least one significant item of noncompliance."
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The correctness of this statement depends upon how the term " inspection" is defined. It has been customary to define an inspection in terms of the
' duration of_the inspection trip. For example, if an Inspector visits the site for three days in the first week, leaves and does not return until the 9
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third week,' at which time he visits the site for two days, the practice has been to view these as two separate inspections. However, the practice of M
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the NRC Inspector in this area has been to combine, into a single NRC Inspection Report, the results of two or more inspection trips. If an NRC inspection is defined as the inspection performed during a single trip, this statement in the Preliminary SALP Report is incorrect.
- 2. 'The Preliminary SALP Report states:
"There was a failure to initiate audit corrective action concerning che rareview of the FSAR and references to L
determine if design documents had modified the FSAR and if so that changes had been made to the FSAR."
a This item is duplicated in the Preliminary SALP Report in the section
. dealing with Design Control. Read carefully, the item reflects a failure to
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rereview of the FSAR. The need.for the corrective action was, in our view, of minor importance.
The FSAR rereview was an extensive, as well as intensive effort spanning 18 months and involving three companies--Consumers Power Company, Bechtel, Babcock 8 Wilcox. Bechtel, alone, spent an excess of 10,000 manhours on this effort prior to its completion in September, 1980. This effort p
resulted in a clarification and upgrading of the content of the FSAR. Two audits were made by the Consumers Power Company Quality Assurance Department ll to assess the adequacy of the FSAR rereview effort. Both audit teams
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concurred that the rarevicw had been accomplished conscientiously and.
effectively, assuring that design changes had not modified the FSAR or, if so, that such changes had been subsequently reflected in the FSAR.
I The ites given in the Preliminary SALP Report stems from our audit finding to the effect that all of the design documents which were rereviewed were not listed in block 8 of the rereview fcts as required by the rareview procedure. The instructions for block 8 indicated that the rereviewers were 4
to list the design documents to be rereviewed, to indicate whether or not any conflicts existed between the design documents and the FSAR, and then to indicate the necessary resolution. The audit showed that some rereviewers had listed only the design documents which contained conflicts, and had indicated the required resolutions. In essence,-therefore, these rereviewers did not understand the block 8 instructions to require a complete listing of documents--those which did not contain. conflicts as well as those which did.
Nevertheless,' the. technical correctness of the rereview was validated, as
-follows: Rereview packages which did not provide a complete list of the
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. reviewed documents were identified, and a large sample of them was selected.
The packages selected were those which were most likely to contain design document conflicts. The packages were re-rereviewed. From this re-rereview, it was ascertained that not a single package contained even a single unresolved conflict. At this point, the rereview process was
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approximately 80 percent complete (recall that it was an 18 month effort).
l.
While there appeared to be some misinterpretation of the block 8 procedural l,
requirement, all the rareviewers appeared to understand the intent of the rareview effort and were adequately resolving any conflicts between the design documents and the FSAR. Based on this, it was decided not to rewrite the procedure for block 8 and not to redo the block 8 document listings. It L
was thought that such actions only would have confused the process at this point in time. After an exchange of correspondence with the NRC on this ites, however, we agreed to change the procedure and to provide additional training to the reviewers.
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'At the completion of the FSAR rareview effort, another sample of packages
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was re-rereviewed by the audit team with the same results, thus verifying t
the adequacy of the remaining 20 percent of the effort which had not been subject to the initial audit re-rereview. In essence, then, the two audit re-rereviews confirmed the adequacy of the entire effort.
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I Attachment I l-9 4
In testimony before the Soils Hearing Board, Dr Landsman indicated that the block 8 condition did not call into question the technical effectiveness of
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the rereview, which Dr Landsman specifically found adequate (TR.p-4857, 4930).
3.
The Preliminary SALP Report notes:
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.j "Three examples of failure to translate applicable regulatory requirements and design criteria into design documents."
A
'Ihis item is also duplicated in the Design Control section of the y
Preliminary SALP Report.
3 a.
The first example given is:
" Failure to maintain a coordination log cf Specification Change Notices (SCNs)."
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In response, there are three separate coordination logs in the civil discipline. These loss are maintained by three different people. The Drafting Supervisor maintains the coordination log for drawings and drawing change notices. The remaining documents, including SCNs, are covered by two other coordination logs which are maintained by Discipline Aides.
During the Region III inspection, the Company could not immeQ ately document that all coordination had been included on an SCN log. The problem was made worse by the fact that the NRC Inspector'was l
inadvertently shown the wrong log. Also the NRC Inspector felt that l
applicable procedures required all revisions of specifications, whether b
technical or clerical in nature, including those merely incorporating
.previously approved or coordinated SCNs, be reviewed by Geotech and so noted in the log. Although the Company disagreed with this u
interpretation, the proccdure was modified, making it clear that lq clerical revisions merely incorporating previously reviewed changes need not be re-coordinated or re-reviewed by Geotech. At the request of the Region III Inspector, the Company also committed to review current revisions of civil, Q specifications to insure appropriate coordination of changes was carried out.
t In any event, this is hardly something which can be properly l;
characterized as a " failure to translate applicable regulatory requirements and design criteria into design documents."
b.
The second example given is:
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" Failure to correctly translate Specification Change Notice No SCN-9004 as a requirement into Revision 20 of Specification C-208."
l This item arose as a resn'.t of a slight difference in wording between an SCN and the specification, after incorporation of the SCN into the l
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l l-10 specification, relative to the Geotechnical Engineer's responsibilities for establishing the laboratory compaction test frequency. The SCN was issued to describe the responsibilities of the newly assigned on-site Gec%c.hniel Engineer. The specification after incorporation of the SCN, used terms different from and more general than the SCN to describe the geotechnical engineer's responsibility for the establishment of the frequency for laboratory compaction testing. In our view, the intent of both the SCN and the specification was the same, although the NRC 4
Inspector did not agree. Subsequently, any difference in wording was eliminated. Again, this situation appears to be very harshly characterized as a " failure to translate applicaole regulatory requirements and design criteria into design documents."
l c.
The third example given in the Preliminary SALP Report is:
" Failure of Engineering Department Project Instruction No EDPI 4.25.1, Revision 8 to establish adequate measures for design i
interface requirements."
In response, the EDPI was revised to state that it is the responsibility of the originator of a design change to coordinate the change with all groups which are affected by, or involved with, the revised portion of the document, regardless of whether the change is technical or editorial. This procedural change was made to eliminate the previous option of the Group Supervisor to uaive the need for the coordination or interface when, in his judgment, it was unnecessary. This coordination is now required r.en for editorial changes. Adequate coordination had i
been accomplished prior to the EDPI revision.
The need for this added conservatism introduced by the EDPI revision is a matter of opinion and Consumers Power Company has accommodated the NRC's concern in this regard. However, there was never any " failure to translate applicable regulatory requirements and design criteria into l
design documents" and to characterize this item.in that way is erroneous and unfair.
b4.
lThe Preliminary SALP Report gives the following ites:
I I
f
" Failure to establish test procedures for soils work activities."
l l
l The NRC Inspector found that US Testing did not previously determine the r
rhoostat setting which produced the maximum density. However, US Testing did previously determine the rhoostat setting that produced the maximum amplitude required by ASTM D2049. Tests were reperformed to verify that the u
maximum rheostat setting yields the maximum amplitude givct in the relative density table used for the project. Results were documented and supplied to the NRC. This is far different from a " failure to establish test e procedures" as stated in the Preliminary SALP Report. Again, the Report's I
com ants are a gross generalization and a misrepresentation of the factual si 4ation.
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In this situation, the NRC Inspector did not accept an ASTM Standard procedure called out in the specification and imposed his own personal
~
preference as to the technical requirement.
The' Preliminary SALP Report also indicates a:
s'
" Failure to suuply a qualified on-site Geotechnical Engineer."
h-
' As part of the original response to soils issues, a Geotechnical Engineer was assigned to be on site. The resumes of the assigned engineer ("the first engineer") and of another applicant to the position ("the second
- 9 engineer") were reviewed by Mr E Gallagher, then the cognizant NRC Inspector. Mr Gallagher expressed his opinion to our Mr Horn that the
, second engineer was preferable because of his many years of field i'
-experience. We cannot say whether or not Mr Gallagher noticed that the second engineer was not a degreed engineer (although Mr Gallagher reviewed
't_-
the man's resume). On the basis of Mr Gallagher's opinion, the first engineer was removed and the second engineer was assigned to the site.
Subsequently, another NRC Inspector, Dr Landsman, became cognizant in this area. Dr Landsman who was accompanied by Mr Gallagher during this inspection, was advised of the original coordination with Mr Gallagher, but Dr Landsman held an opinion different from Mr Gallagher because the second
!i engineer did not have a civil engineering degree. Dr Landsman then cited the Company with a deviation for failure to provide a qualified Geotechnical engineer-for the job. Immediately thereafter, the first engineer was y.
reassigned to the on-site position. Dr Landsman concurred with this assignment. In view of these facts, the citation seems to us unfair.
The Preliminary Report also states:
_"It was noted in.NRC Inspection Reports No. 50-329/81-12; 50-330/81-12 that a sufficient number of qualified personnel were not available for the complex nature of the remedial soils work.. This had previously been identified in NRC Inspection Reports No. 50-329/81-01; 50-330/81-01, referenced previously as a deviation to a commitment."
Inspection Reports No. 50-329/81-01; 50-330/81-01 deal with the deviation relative to the on-site Geotechnical Engineer. This was covered in Paragraph 5, immediately above. By the placement of this item in two different parts of the Preliminary Report, the appearance is given of two different items when, in fact, there is only one.
NRC Inspection Reports No. 50-329/81-12; 50-330/81-12.merely indicated the NRC's advice to the effect that additional QA/QC personnel would be needed 3
'~
to' accommodate the forthcoming remedial soils work. We agreed with this NRC observation. We were not cited for any noncompliance on that score in these
.y inspection reports. We now have 8 full time and 2 part time QA/QC persons employed in MPQAD and 27 QA/QC persons employed by both MPQAD and Bechtel Quality Control to cover remedial soils work--appropriate for the current workload, also taking into account the time necessary to assure their adequate training and certification. Five more persons are due on site by oc0582-0039al67
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.c fI 1-12 mid May. Additional personnel are being sought to fill the 2 remaining 3
authorized positions. The Preliminary SALP Report gives the impression of 4
an inadequacy with regard to the quantity of personnel when, in fact, quite j
the opposite situation exists.
F 7.
Finally, another ites referenced in this section of the Report is duplicated in the Quality Assurance Section of the Report.. Please refer to Part 3, Paragraph D.4, above.
d-
- 8...In summary, while we find this section of the Preliminary Report inaccurate and overstated, we fully recognize the special sensitivities involved in the remedials soils area, and we are especially dedicated to the implementation of the quality controls and assurances required by law and engineering prudence.
4
- F.
Section IV.3, Performance Analysis of Containment and Other Safety-Related Structures I
- 1.
The cracks in the BWST foundation are also referred to in the section of the Preliminary SALP. Report dealing with Design Control.
G.
Section IV.4. Performance Analysis 'of Pipinz Systems and Supports 1.
Item a(1) of this section of the Preliminary SALP Report states that:
"Bechtel Purchase Order.did not specify applicable codes for purchase of 60,000 pounds of E-7018 electrode."
e The original statement of the ites, from NRC Inspection Reports No. 329/80-20-01 & 330/80-21-01 was as follows:
"Bechtel Corporation Welding Standard WFMC-1, Revision 8, 4
s dated January 4, 1971, ' Welding Filler Material Control Procedure Specification,' Paragraph 2.1, states, in part, that'... welding filler material ordering information shall g
- include the appropriate requirements of the job engineering specification, the applicable Code and this procedure specification....'
' Contrary to the above, on July 10, 1980, the (NRC) Inspector established (that) Bechtel Purchase Order No. 7220-F-5780, dated November 2, 1973, for 60,000 pounds of E-7018 electrodes did not specify the applicable Code.'"
First, note that the Preliminary SALP Report statement omits any reference to the November 2, 1973, date. The Bechtel Purchase Order for the E-7018 electrode was issued on November 2, 1973. -We question whether we should be d
cited in this assessment period for_an event which occurred 7 years prior to the assessment period.
Second, at the time of the' procurement, a revision of WFMC-1, dated May, 1973, was' applicable, whereas the citation referenced the January 4, 1971 oc0582-0039a167 G
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1-13 revision of hTMC-1. The procurement was made in accordance with the May, j
1973 specification. The procurement documentation reflected complete j
compliance with the requirements. Although these facts wera not available a
immediately during the period of July 8-10, 1980, when the NRC Inspector was making the inspection, these facts were provided in our original response to the citation on August 25, 1980.
In addition, Consumers Power Company has performed an audit of the procurement documentation for weld filler materials procured from 1973 through 1980. This, too, was reported to the NRC in the August 25, 1980 responsa.
2.
Item a(2) in this section of the Preliminary Report indicates that an Authorized Nuclear Inspector's hold point was bypassed for the pressurizer surge piping.
This item was detected by the NRC Inspector on September 24, 1980. By September 25, corrective action had been taken and verified by the NRC Inspector.
3.
Items a(3) and (4) indicate that large bore pipe restraints, supports and anchors were installed incorrectly and that QC Inspectors did not detect the incorrect installations.
' It is highly unusual to cite a licensee twice for what is essentially a single QA defect (one citation for the construction defect and another for not having detected the defect).
The NRC Inspector found 7 cases of' apparent nonconformances to design I
requirements. He stated that he was using cursory inspection techniques.
+
Upon our further inspection, we agreed that 3 of the cases were defects, but with more refined inspection techniques our investigation indicated that 2 cases were within tolerance, I case was a result of obvious post-inspection damage that would be che:ked for during walkdown inspection, and 1 case was for work yet to be inspe:ted initially. The 3 real defects were of a relatively minor nature, and nous of them impaired the function of the l,
l.
hangers even though they constitute a legitimate basis for the NRC's l.
finding.
1 On the basis of these findings, we agreed to make an extensive sampling reinspection of hanger, installations which were made prior to 1981. The ence of additional minor results of this reinspection have C ' [__
,y.
defects and may necessitate fu er re tion a results have been made 7g j'
available to the NRC and now are by both the NRC and l'
Consumers Power Company.
b l'
4.
Item a(5) in this section of the Preliminary Report, dealing with the availability of Committed Preliminary Design Calculations for small bore pipe and piping suspension systems, is duplicated in another section of the draft SALP Report dealing with Design Control and Design Changes and is'the major contributor to the Significant SALP Report Findings for Piping Systems l
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t and' Supports given in 7.nclosure 1 to the Reference. Correspondingly, our response to this item is covered in Part 2, Paragraph B of this attachment.
-5.
Ites a(6) indicates:
" Failure to adequately control documents used in site small bore piping design activities."
The original ites from NRC Inspection Report No 50-329/81-12 and 50-330/81-12 stated that:
"g (one) outdated specification was maintained at the small bora piping design group work location and revised calculations were not marked ' superseded' in accordance with the procedural requirements (our emphasis)."
4
+
After careful checking, this finding was determined to have been an isolated case.
Nevertheless, the calculations were checked and were found to be correct.
Training was conducted of all persos.sel.in this group. An audit was made.
A procedure was changed to require that the specific revision number of the specification on which the calculation is based be documented in the calculation. package.
6.
Item a(7) indicates that Consumers Power' Company audits did not:
j
" Include a detailed review of system stress' analysis and (did not) follow up on previously identified hanger calculation inconsistencies."
In response, the above statement refers to the fact that we did not audit for the availability and correctness of the Committed Preliminary Design
' Calculations as discussed in Part 2, Paragraph B, and Part 3, Paragraph G.4, above..The audits.that were made previously in this area concentrated on i-the completed calculations, rather than.the preliminary calculations. The
~
audit checklist for this area has since been adjusted to reflect a l,
-requirement relative to the preliminary calculations.
S l.
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Section IV.S. Performance Analysis of Safety-Related Components 1.
As a result of the two original items, from which the two items in this section of the Preliminary SAI.P Report are drawn, Consumers Power Company issued a formal Stop Work Order to Babcock & Wilcox and a letter to the NRC stating that the work stoppage would remain in effect until the corrective actiens had been completed and reviewed by the NRC. Corrective actions were taken, as follows: The installation procedure for this ~ activity was revised
- j.
to clarify the method of installation and to specify the required dimensional checks. The indoctrination and training of the personnel performing the installation and of the personnel inspecting the work was strengthened. The Consumers Power Company overview inspection plan for this activity was revised. The NRC Resident Inspector verified these actions.
2.
Again, it is encouraging that today's rating in this area, as stated by Mr R Cook during the April 26 seating, is a strong " Category 2," or even, j
perhaps, a " Category 1," based on the aggressiveness of our overview t
efforts. We recognize the particular importance of this area, and we intend t
to continue our agressive overview of this area.
I.
Section IV.6. Per formance Analysis of Support Systems (HVAC) 1.
We appreciate the " Category 1" rating for the period in question and on an informal basis for the current period, as well, as stated by Mr R Cook during the April 26 meeting.
3-2.
It should be noted that the' civil penalty was imposed for condit' ions which 4
existed prior to the assessment period in question.
a
-3.
The 17 items referred to were all identified as a result of investigations which were completed prior to June 30, 1980, and, therefore, prior to the a
start of the assessment period in question. This may be observed by review s=
of the individual items given in NRC Inspection Reports No. 50-329/80-10; 50-330/80-11. Although these Inspection Reports are dated January 12, 1981, they clearly provide findings that were available prior to June 30, 1980.
During management meetings held on March 24 and 28, 1980, these investigation findings were discussed extensively.
i,:
J.
Section IV.7. Performance Analysis of Electrical Power Supply and Distribution q
,[
1.
Item a(1) in this section of the Preliminary SALP Report indicates a failure
)
L to establish procedures for temporary support of cable.
The four damaged cablas were repaired. The procedure was revised to require that coiled cables be properly supported, protected from damage and prevented from violating the minimum bend radius.
- 2.. Item a(2) in this section of the Report indicates that electrical a
contractors did not verify conformance to Paragraph 3.1 of Project Quality Control Instruction E-5.0.
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This item was an isolated incident of two wires violating separation standards inside a control panel. The cable routing was rearranged to provide the required separation, and the separation was verified by inspection. Electrical-crafts and inspection personnel were _ formally reinstructed with regard to the separation requirements. Installation and inspection aids were provided to these personnel.
l, 3.
Item a(3) indicates a:
l
" Failure to identify'and. control nonconforming components."
n Because of the general nature of this ites, wa are not swa to what it refers. After a thorough review of the NRC Inspection Reports for this assessment period, however, we believe that it refers to an ites from NRC Inspection Reports No. 50-329/81-11; 50-330/81-11, as follows:
n "On April 23, 1981, the (NRC) Inspectors identified 14 instances in which cable tray in the upper and lower cable spreading areas were not installed in accordance with the separation requirements delineated in the Midland FSAR and which had not been identified and controlled to prevent inadvertent use or installation...."
,.c I
. Consumers Power Company documented the nonconforming condition for a few cases on a Nonconformance Report issued in May, 1979, long before the NRC Inspectors' finding.
I. ate in 1979, it was determined that the existing l'
Marinite barriers were not the most suitable separation device for our plant G
configuration. This resulted, in January, 1980,..in the removal of the
)
requirement for the tLarinite barriers. In the spring of 1980, a study was 1
conducted to determine whiclii kind of barriers would be more suitable when j
the required spatial separation is not possible. hro things resulted free this study--first, that barrier installation would be accomplished best H
after cable pulling was complete; and second, that there was no risk in
['
reworking cable trays after cable pulling to install the barriers, if ll needed. In August, 1980, a new barrier was chosen and SAR and design l
changes were made in April and June, 1981, respectively to reflect these l ;..
changes.
l L
This is a lengthy discourse, we realize, but in essence, the main points are as follows: we were well aware of the condition.- At the time, we made a conscious decision not to provide any more inspection to identify additional 2
i specific cases where separation was not maintained. We were aware that the design was being changed, that the construction process was being changed, a
and that the final Bechtel Quality Control inspection for this condition would be carried out at the conclusion of the construction process. -The Bechtel Project Quality Control Instruction E-3.0, " Final Electrical Area Completion Activities," was revised to reflect the inspection for separation l,
and, as needed, for the installation of barriers at the. completion of the cable pulling activities. Correspondingly, we were holding open our Nonconformance Report to assure that these changes were correctly p
implemented. There was no inadvertent " failure to identify and control."
(
It was a conscious and knowledgeable decision.
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This information was provided to the NRC on July 16, 1981, in our response to the NRC Inspection Report..Considering the explanation supplied to the Staff, we believe that there was no' item of noncompliance and that this ites should not have been in this Preliminary SALP Report.
- I 4.
~ Item a(4)' indicates a:
- j
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" Failure to translate design criteria into drawings and l {..
specifications."
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I This inspection finding related to whether or not the color coding of
.j
-instrumentation process lines was required. Based on our reading of the f
t applicable codes and standards, it was not, and we stated this position in
- i.
.our original response to the NRC. At least one other licenses has the same position and is maintaining it.
However, we have acceded to the NRC conce in this area by agreeing to identify the instrument process lines with a t s N
digit alpha designator, and the specification has been changed to add.
s
.new requirement. We are also not clear whether this requirement a as generally or only in Region III, since the Draft Regulatory Guid this subject makes no mention of the requirement.
5.
Item a(5) indicates a:
/
" Failure to identify during inspection that a e forming condition with regard to minimum installed e
radius existed."
/
(l The condition referred to was. discovered by a C users Power any
- j i
employee who was accompanying the NRC Inspector during his insp tion. A lE Consumers Power Company Nonconformance Report was written to doc b the
.i condition for the single cable in question. In addition to physical ys s
~
c' correcting the condition, the Bechtel Quality Control Inspector who f-I'
-originally inspected the cable was given an 8-hour training program in all phases of cable termination.
6.
Item a(6). indicates:
- " Failure to take prompt corrective action with regard to the raceways.provalofproceduresforthereworkofelectrical lack of a y
We agreed that this was an entirely appropriate finding and Bechtel 7
l-.
Construction and Bechtel Quality Control developed and issued the necessary administrative guidelines and instructions. Recently NRC Inspectors have l:
conducted a follow-up inspection and determined that the rework controls l'
have been properly implemented and carried out.
il Li 7.
Item a(7) indicates:
I;
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" Failure to provide adequate storage conditions for (three items)."
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Attachment i 1-18' The storage conditions for each of the items was immediately corrected. The Bechtel Maintenance Engineers were given additional training in accordance with the requirements of the field maintenance procedure. Consumers Power Company performed a comprehensive audit in this area to assure compliance with the field maintenance procedure.
4 8.
It' shou _id be noted that each of the foregoing items is a Severity Level V or j,
VI, relatively low severity levels.
We are gratified that our informal current rating is " Category 2," as stated by Mr R Cook during the April 26 meeting.
I 9.
In two places in this section of the Preliminary SALP Report reference is made to the quantity of Bechtel Quality Control personnel being employed, with the implication that this quantity may be insufficient. To our 4- _.
!p knowledge it was not; nor is it now. In addition, in response to NRC concerns we have demonstrated both the. qualifications of these personnel and the process by which they are certified.
K.
Section IV.8. Performance Analysis of Instrumentation and Control Systems
~No comment.
' L.
Section IV.9. Performance Analysis of Licensina Activities 1
Comments pretaining to our responsiveness to Staff requests for information regarding the " Soils" issue should certainly be qualified by noting the novelty or uniqueness of this technical review and the evolutionary nature of the Staff's positions. It is useful to note that as this review draws tc, its l!-
conclusion, the Advisory Committee on Reactor Safeguards (ACRS) subccomittee on the Midland soils questions characterized the Staff review as exhaustive and possibly an example of overkill. In addition, the ACRS subcommittee questioned the Staff extensively on whether portions'of their review and requirements went I-beyond what was necessary to protect public health and safety. We are gratified l'
that the Staff finds-our more recent replies to be responsive and of high quality. We are striving to maintain this trend and improve communications with the Staff.
M.
Section IV.10. Performance Analysis of Fire Protection We appreciate NRC's " Category 1" rating in this area =ad 4t= recomnition of our efforts.
I '
r N.
Section IV.11. Performance Analysis of Preservice Inspection In view of the extensive amount'of preservice inspection which was performed during the period corresponding to this SALP Report and continuing into the current period, with no items of noncompliance, we fail to understand why this
^^Lategory 2,".
area is not rated as " Category 1 insr...u m oc0582-0039a167 i
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Section IV.12. Performance Analysis of Desian Control and Desian Changes 1.
Items a(1)(a) and (b) given in this section of the Preliminary SALP Report are duplicates of items given in Section IV.2.
As such, our specific '
response to these items is given in Part 3, Paragraphs E. 2 and 3, and will not be repeated here.
- 1 2.
Item a(2) in this section of the Report is a duplicate of an item covered in Section IV.4.
As such, our specific response is provided in Part 3, it Paragraph G.4 and will not be repeated here.
3.
Item a(3) in this section of the Report is a duplicate of an item given in Section IV.7 of the Report. As such, our specific response is given in Part 3, Paragraph J.4 and will not be repeated here.
4.
The five 10CFR50.55(e) items listed in this section of the Preliminary Report relate to designs'which were completed long before the start of the i;
SALP period in question--in fact, years before. Car identification of these items during this assessment period indicates continuing design reviews, j.
improved design control and our rigid compliance with the reporting *
' requirements of 10CFR50.55(e).
5.
We also call your attention to five inspections of Bechtel Power Corporation,' Ann Arbor Division, engineering firm for the Midland Plant, I..
conducted between January, 1979 and September, 1981 by the Vendor Inspection Branch of Region IV. The inspection covered a wide variety of design l~
activities. For example, the October 7-10, 1980 inspection encompassed l.
design verification, design interface, and design inspection activities.
The March 31-April 3,1981 inspection covered computer program control, technical personnel background verification, design change control and design corrective action. The two specifically referenced inspections were conducted during the SALP appraisal period. In all five inspections, there were a total of 6 nonconforming items identified, all of a relatively minor nature (nonconformances or deviations rather than violations). In two of the inspections no items of noncompliance we.e found. In our view, these a
l~
inspections are indicative of a high degree of compliance within design segments of the Midland Project, and would clearly support a higher rating i
than the one given in this area.
(The five inspection reports are documented in letters dated April 16, 1981; October 14, 1981; November 5,1980; June 15,1979; and January 19, 1979, to o
.the Bechtel Power Corporation, Ann Arbor Division, from Uldis Potapors, Chief Vendor Inspection Branch.)
C 6.
Considering the nature of Items a(1)(a) and (b) and a(3), and the unfairness of a citation for activities long before the period in question, we are disappointed by a " Category 3" rating in this area.
('
We believe that design control is one of the most difficult and important i
aspects of nuclear power plant projects. Design control has been doubly difficult for the Midland Project mainly because of the durat' ion of the project and the incorporation of a multitude of new regulatory requirements i
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1-20 into the design as.it progressed. We do not dismiss for a moment our obligation. to monitor and improve our own efforts in this area and we continue to institute our own internal programs to increase our confidence
?'
in the quality of the overall design effort. We raise this concern with the preliminary SALP evaluation bec.mse the only significant finding in the SALP period that indicates a design conuol problem was the small bore piping lack of design package cover sheet,.shich taas concluded to be an isolated 1
event. On the other hand, we believe that the Region IV inspection reports and the seven 50.55(e) reports referenced provide strong indications that the design control area is improving.
P.
Section IV.13. ' Performance Appraisal of Reportina Requiremer+s and Corrective
. Action I
1.
In this section of the Report, it is stated that:
"The licenses failed to make a timely determination for the need to, submit a 10CFR50.55(e) Report to the NRC based on a 10CFR Part 21 Report from Transamerica DeLaval, Inc."
Consumers Power Company has always adopted a conservative attitude towards reporting under 10 CFR 50.55(e). We believe the industry practice in this regard varies, depending upon the amount of analysis undertaken and discretion exercised in determining whether a deficiency could have an adverse impact on safety. In the past, Region III has stated that the Company does a " good job" reporting under 10 CFR 50.55(e).
i:
In this specific case, the DeLaval Part 21 Report was sent to Bechtel and was misrouted, such that Consumers Power Company and the appropriate Bechtel personnel were not aware of the Part 21 Report on a timely basis. In the final analysis, the condition was determined not to be 50.55(e) reportable.
Corrective actions were taken. They. included issuing letters to suppliers I-to advise them of the person to whom Part 21 Reports should be submitted, E
conducting training sessions at the site for key personnel to assure that
~
misdirected Part 21 Reports set correctly redirected, and issuing periodic menos reiterating the information offered in the trainir4 session.
2.
This section of the Preliminary SALP Report also'ststes:
" Expeditious resolution of noncompliances is often delayed by inadequate licensee responses. The licensee has a tendency to spend too much time trying to justify why a finding is not a noncompliance rather than devoting the time to correcting the basic problem. Nine of 22 items of noncompliance were contested (excluding HVAC system noncompliances). Two of the a
contested noncompliances were retracted, but time and effort were lost in timely resolutions. Similar attitudes and responses have been observed regarding Company audit findings.
i; This attitude is reflective of the licensee corrective action system and becomes a detriment to quality."
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1-21 In response, let's deal with the statistics first. 'No of the nine appeals (excluding HVAC) were granted, or 22 percent. Five other HVAC items were appealed, and two of those appeals were granted, or 40 percent. Combined, 14 items were appealed,-4 appeals were granted, or 29 percent. Of those not granted, the merits of the appeal are well documented.
j While there may be some unavoidable delay because of appeals, in no instance has an appeal precluded timely corrective action. In addition, the Staff has repeatedly testified in the Soils hearing that the Applicant should appeal when necessary or appropriate.
During a meeting on October 5, 1981, NRC's Region III management made-it clear that NRC's concern was with the administrative process,by which appeals were made, not with the appeals themselves. They stated that appeals should be made and dispositioned informally, if possible, prior to the issuance of NRC Inspection Reports or, at the latest, prior to our written response to the NRC findings. We agreed with this suggestion and assured the NRC that such appeals, if any, would be made accordingly. It is disappointing that the substance of this management discussion was not reported in the Preliminary SALP Report.
Q. -Section V.A. Noncompliance Data 1.
It is important to recognize that the noncompliances and deviations given in the table for Midland Unit,1 are identical to those given in the table for Midland Unit 2 in the large majority of cases. We recognize that this is so stated in the footnote to both tables.in the Report.
I.
L 2.
At this point, it is appropriate to reiterate from our response given in Part 3 Paragraph I.3, that the 17 items associated with the HVAC were all l-identified as a result of investigations which were completed prior to June ji 30, 1980 and, therefore, prior to the start of the assessment period in l
question. This can.be seen by review of the individual items given in NRC l.
Inspection Reports No. 50-329/80-10; 50-330/80-11. Although these Inspection Reports are dated January 12, 1981, they clearly provide findings that were available prior to June 30, 1980. During management meetings held on March 24 and 28, 1980, these investigation findings were extensively discussed. In conversations with NRC Inspectors, we were advised that these l:
items - are included in this SALP Report because they were inadvertently excluded from the earlier Report, and that they have to be covered somewhere. We believe that the earlier SALP Report should be revised to C
reflect these items. The presence of these items in this SALP Report bears unfavorably and unfairly upon the overall impression offered by the Report
.for the period in question.
R.
Section V.B. Licensee Report Date h
1.
The twelve 50.55(e) Reports listed herein further demonstrate our l7 cooperative approach with regard to the submittal of 50.55(e) Reports, as lf stated earlier in our response given in Part 3, Paragraph 0. 4 and 5.
oc0582-0039a167 i,
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S.
Section V.C. Licensee Activities
,)
i No comment.
T.
Section V.D. Inspection Activities 1.
The results.of the May 18-22, 1981, NRC team inspection evoked the following i
q conclusion, as given in NRC Inspection Reports No. 50-329/81-12; 50-330/81-12:
'?This was an in-depth inspection to examine the implementation status and effectiveness of the current QA Program, to determine whether previously identified quality assurance problems,were sufficiently precluded from occurrence in otuer areas, and to ascertain whether management involvement in-the QA Program was sufficient and effective.
Although eight items of noncompliance were identified during this inspection, it is our (NRC) judgment that the scope and depth of this NRC inspection was such that the identified noncompliances do not contravene our conclusion that Consumers Power Company has' established.an effective organization for the management of construction and implementation of quality assurance at the site."
U.,Section V.E. Investimations and A11emations Review No investigations or allegations were pursued during the assessment period s
corresponding to this SALP Report, including investigations and allegations for HVAC. This supports our earlier assertions that reference to the 17 HVAC items should be deleted entirely from this Report.
V.
Section V.F. Escalated Enforcement Actions 1.
The civil penalty was imposed for conditions which existed prior to the-assessment period corresponding to this SALP Report.
2.~ Under the heading of " Confirmatory Action Letter" are two examples of inspection findings that appear to be characterized in'an overly harsh ~
manner. We have beca told in prior conversations that letters of committment by the licensee with regard to inspection findings and which r
commit to actions desired by the NRC do not constitute an escalated enforcement action. Obviously, we misunderstood. Not only are these letters categorized.snder the escalated enforcement heading, but the text directly states that these were in fact the licensee equivalent of an a
immediate action letter. It was our understanding that Region III agreement to a licensee letter of commitment represented a Region III management decision that the item in question was downgraded in severity and did not represent an escalated enforcement action.
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Section V.G. Management Conferences
- l 1.
'nio of these management cerferences' were at Consumers Power Company's request.
2.
We strongly support the need for more management conferences with top and intermediate level NRC management participation, especially focused en attaining mutual understanding as to the standards that will be applicable to Midland inspections.
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' COMPARISON OF TESTIMONY OF JAMES G KEPPLER BEFORE THE ASLB ON JULY 13-14, 1981 WITH FINDINGS IN THE DRAFT SALP REPORT
~
Introduction i
On-July'13-14,'1981, Mr James G Keppler, the Director of the Region III Office of. Inspection and Enforcement, testified that the NRC has reasonable assurance that quality assurance and quality control prograes at Midland will be.
appropriately' implemented with respect to future soils construction activity, including remedial actions. In March 1982, Region III issued its Preliminary SALP Report on the Midland Plant. Nothing in the SALP Report contravenes Mr Keppler's testimony regarding reasonable. assurance. All of.the information contained in the-SALP Report was known to Mr Keppler at the time he testified.
1.
Quality Assurance
!}
- F a.
SALP Analysis The report notes the creation of the MPQAD and Consumers Power's assumption of responsibility for onsite quality control and quality assurance functions for the installation of the HVAC systems. It also lists the findings of NRC Inspection Report No 81-12. The report i.
concludes:
-The licensee is rated Category 2 in his overall quality assurance ll capability. Notwithstanding weaknesses identified in specific areas, the licensee has been responsive in establishing an overall l'
effective organization for the management of construction and
(*
' implementation of quality assurance at the site.
t-[
b.
Prior Testimony
.i Mr.Kepple testified extensively garding NRC Inspection No 81-12,M f
the MPQAD and the Zack matters.
Mr Keppler initiated NRC
,1 Inspec MPQAD.pon No 81-12. for the purpose of determining the efficacy of the
.Mr Keppler personally inspected the w inspectors at the conclusion of the inspection,gk of the NRC
- participat
'draftingtheinspectionreport,andsignedthefinalreport. gin Mr Keppler concurred in the report's conclusion that, although some g'
problemswereidentified,theMPQADgndthequalityassuranceprogram at Midland were working quite well.-
Mr Keppler also described the corrective actions Consumers Power had taken with regard to Zack,-and concluded that the Zag problem did not indicate a broader breakdown in quality assurance.-
6 rp0582-2030a173 U
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2.
Soils and Foundations a..
SALP Analysis The SALP Reports lists the soils-related noncompliances and deviations
~ identified in NRC inspections of Midland during the SALP evaluation period (July 1, 1980 to June 30,1981). The report concludes that:
4
'The licensee is rated Category 3 in this area. The enforcement
~
- j history indicates that additional licensee attention is warranted.
b.
Prior Testimony The evidence before the Licensing Board shows that Mr Keppler was d
thoroughly. familiar with the 1980-81 enforcement history relating to p
soils issues when he made his judgment regarding reasonable assurance p
at Midland. Mr Keppler was Regional Director of Region III during this period an SALPanalysis.gsignedalloftheNRCinspectionreportslistedinthe
- i He testified in de
!j problemsidentifedinthesereports.glaboutmanyofthesoils He explained that all of the soils problems identified in 1980-81 were carefully reviewed and
- reassessed, and all pertinent records covering sumuser 1980, to May 1981 were examined, in assurance in May 1981.3grriving at the conclusion of reasonable Mr Keppler specifically noted that the historfof soils work at Midland did not contravene his judgment of reasonable assurance. The soils problems, he testified,."can be largely attributed to the failure to fully recognize the importance of the application of quality assurance to soils work (but) the
- i importance of quality assurance to soils work and to consequent remedial actions Consumers Power.1 g the Midland site is now fully recognized" by I
3.
Containment and Other Safety-Related Structures s.
SALP Analysis "The licensee is rated Category 2 in this area. The licensee's j?
performance appears to be satisfactory; no significant strength nor weaknesses were identified."
i:
l' I
b.
Prior Testimony l
Mr Keppler did not testify on this subject.
I i
l; 4.
Pipina Systems and Supports i.
[ -
t-a.
SALP Analysis i!
ll The Report lists seven items of noncompliance identified by NRC Staff l+
inspections during the evaluation period. Based on five of these s
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. items, an Immediate Action Letter (LU,) was issued on May 22, 1981.
3
.The report concludes:
I The licensee is rated Category 3 in this area. The enforcement history is indicative of weaknesses in the implementation of.the quality assurance program.
b'. Prior Testimony
'l Mr Keppler te=tified regarding the p
'NRCInspectionNo81-12inMay1981.gyngproblemsidentifiedduring i
He explained that problems
.withpipingsystemsareanindustrgideconcernthatisreceiving considerable Region III ~ attention.-
Problems are in this area at'almost every nuclear site inspected.gng identified The NRC Staff
' inspector who identified the piping problems at Midland is at the forefront of knowledge in this area, an incidentsatMidlandtobesignificant.gidnotconsiderthe i
NRC Inspection No 81-12 confirmed that the methodology of the design, installation and qua
!j.
_ control inspection of the piping and support system was acceptable
' It was the unanimous view of the inspection team that the problems identified were isolated, and not~ indicative of weaknesses in the implementation of the program.g major programmatic -
l:
5.
Safety-Related Components l
a.' SALP Analysis l:
'The report lists the two items of noncompliance which culminated in 1,
- Consumers Power's issuance of a letter of understanding on January 22, 6:
1981. The report concludes:
The licensee'is rated Category 2 in this area. The above
' enforcement was aimed at an isolated instance and may have been b
-directly related to change in NSSS QC personnel changes. The L
' licensee had in the past and since this episode maintained
-adequate QA control for the assembly of NSSS equipment.
b.
Prior Testimony-H No testimony was given on this subject.
s 6.
Support Systems
~
a.
SALP Analysis
- The report notes the quality assurance deficiencies and the Civil Penalty of the previous SALP evaluation period. It commends Consumers Power's " aggressive action" in taking over complete responsibility for j:
quality assurance and quality control in HVAC installations; this l:
action resulted in significant improvement in control over the l -:
installations and in correction of identified weaknesses. The report i
concludes:
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The licensee'is rated Category 1 in this area. Management
.i.
' attention and involvement has been aggressive in accepting full QA/QC responsibility and supporting this organization with an adequate number of skilled personnel.
I
' b.1 Prior Testimony 4
?l-
'MrKepplertestifiedthattheHVACprgensproblemdidnotindicatea broad breakdown in quality assurance.
7.
Electrical Power Supply and Distribution
- t i,
a.
SALP Analysis.
The report listed seven noncompliances identified during the evaluation period and concluded:
u N
The Licensee is rated Category 3 in this area. The enforcement i;
history indicates a lack of management attention and involvement.
This is evident by apparent inadequate preplanning and assignment i.
of priorities as activities increased, a poor understanding of procedures for control of activities and minimal QC Staffing for the magnitude of the activities.
b.
Prior Testimony MrKepplertestifiedthatelectrical'workwasextensglyreviewed, during the May 1981 NRC Staff inspection of Midland.-
The
~
inspection team reviewed five areas within electrical work: quality assurance records, quality assurance implementing procedures, quality control personnel, visual inspection of electrical work activities, b;
.and Consupers Power's actions gjpreviously identified items.21/ Only four problems were identified.-
These problems were isolated and
(.
notindicativeofanymajorprgammaticweaknessesinthe implementation 'of the program.-
The inspection report also 1-commended Consumers Power for several aspects of their electrical work i.
program. First, the program and its implementation regarding l
calibration of termination tools was judged to be satisfactory.24/
l Second,ConsumersPowerhadtakentimelyandcomprehgyiveactionsto correct areas addressed on previous NRC inspections.-
Finally, the quality g urance (electrical) organization was found to be strong and capable.
I.
tl.
l' 8.
Instrumentation and Control Systems
- a. -SALP Analysis t,.
"The Licensee is not rated in this area because a minimal amount of 1:
instrumentation installation and minimal inspection effort during this I
evaluation period."
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b.
Prior Testimony-
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~,_
There was no testimony on this subject.
7, 9.
Licensing Activities t.
a.
SALP Analysis
?U "The Licensee is rated Category 2 in this area. Early responses' il during the evaluation period were lacking.in responsiveness. However, j-the more-recent responses tend to be substantive and of acceptable
! =
quality."
b.
Prior Testimony y
[
Mr Keppler did not testify on this subject
- 10. -Fire Protection Ib a.
SALP Analysis "The Licensee is rated Category 1 in this area. Management attention has resulted in a high level of performance in this area."
b.
Prior-Testimony There was no testimony on this subjec,t.
11.
Preservice Inspection ii a.
SALP Analysis 4
The Licensee is rated Category 2 in this area. The Licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified."
b.
Prior Testimony There was no testimony on this subject.
- 12.. Desian Control and Design Chanaes I'
a.
SALP Analysis The report notes four design control related noncompliances identified by NRC inspections and five licensee-controllable Construction Deficiency Reports indicating a lack of quality assurance in design control during the evaluation period. The report concludes:
The licensee is rated Category 3 in this area. The amount of re-engineering that has transpired in electrical, civil and piping areas and the specific design control weaknesses discussed in rp0582-2030al73
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Soils and Foundations, Piping Systems and Supports and Electrical
- L Power Supply and Distribution indicate significant weaknesses in ik overall design control.
3 b.
Prior Testimony LMrKeppler.didnotconsidertheprog}yssidentifiedinthepiping system to be a significant concern.--
He also testified that a-noncompliances identified by NRC inspections in the soils area, l[
althougho{
assurance.-87oncern,didnotcontravenehisjudgmentofreasonable q:
Another NRC Staff witness, Mr Gilray, confirmed that h
the two soils noncompliances referenced here by the SALP Report were not substantive and did bring the adequacy of Consumers Powers proceduresintoquestionggj f
The May 1981 NR 3pspectionaffirmedthe adequacy of the electrical program at Midland Mr Keppler did identify design control as a significant quality related problem.377' l
g 13.
Reporting Requirements and Corrective Action I
a.
-SALP Analysis 1
l The. report notes that Consumers Power contested several apparent items-Jof noncompliance during the evaluation period, and concludes:
l.
The Licensee is rated Category 3 in this area. The licensee l
responses to enforcement items and internal audit findings are often delayed requiring repeated submittal to obtain acceptable L
resolutions.
t-r.
F.
'b.
Prior Testimony i-,-:
(;
Mr Keppler testified that~ Consumers Power had responded to all items of noncompliance identified in NRC inspection reports. He noted that Consumers Power agrees with some such items'and disagrees with others.
Mr Keppler stated that the fact that Consumers Power does not agree with an apparent item of noncompliance is not a sign of poor management attitude. If there is a valid reason to disagree with the item, he added, then they should disagree with it.
This is a nor part of the give and take between the NRC Staff and the licensee.ggJ
.l'
[
t-1/
Keppler, Tr 1884-47, 1981-77, 1981-83, 1998-2002, 2004-09, 2076-84.
2/
.Keppler, Tr 1973-76.
3/'
Keppler, Tr 1935-36, 1964-66, and prepared testimony at p 4, following Tr 1864.
4/
Keppler, prepared testimony at pp 4-7, following Tr 1864.
5/
Keppler, Tr 2078-79.
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NRC Staff Exhibit No 1; Keppler, Tr.
7/
Keppler, Tr 1973.
8/
Keppler, Tr 1935-36, 1964-66 and prepared testimony at p 4, following Tr 1864.
9/
NRC Staff Exhibit No 1 (NRC Staff Inspection Report No 81-12); Staff Exhibit No 3 (NRC Inspection Report No 81-09), Gallagher, prepared testimony, Attachment No 3, (NRC Inspection Report No 80-32/80-33),
following Tr, 1754.
10/
Keppler, Tr. 1935-36, 1964, 66 1887, 1942, 2002-09, 2013-2017 and prepared testimony at pp 4-5, 7 9, following Tr 1864.
11/
Keppler, Tr 1913-14, 1977, 1982-83, 2083.
12/
Keppler, prepared testimony at p 8, following Tr 1864.
13/
Keppler, Tr 2004-09, 2017, 1942.
14/-
.Keppler, Tr 2006-09.
15/
Id.
16/
Id.
17/
Id, prepared testimony, Attachment No 2, at p 5, following Tr 1864.
18/
Id, prepared testimony at p 8, following Tr 1864.
19/
Id., at p 4.
20/
Keppler, Tr 2076-78, and prepared testimony at p 7, following Tr 1864.
l+
21/
Id, prepared testimony, Attachment No 2, at p 11, following Tr 1864.
' ~
22/
Id, at p 11-12.
?
j 23/
Id, prepared testimony at p 8, following Tr 1864.
24/
Id, prepared testimony, Attachment No 2 at p 12, following Tr 1864.
i.
l; 25_/
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[:
26/
M 27/
See discussion supra under " Piping Systems and Supports."
28/
See discussion supra under " Soils and Foundations."
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Gilray, Tr 3742-43 (testifying regarding the soils noncompliances identified in NRC Inspection Reports No 80-32 and 80-33) 9 30/
See discussion supra under " Electrical Power Supply and Distribution."
3_1/
Keppler, prepared testimony at p 4, following Tr 1864.
M 32/
Keppler, Tr 2083-84 e.?
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o 3-ANALYSIS OF CURRENT AND FtTNRE QUALITY ACTIVITIES j'
WITH REGARD TO REMEDIAL SOILS WORK J
l.
'At the April 26, 1982 SALP meeting Region Administrator, Mr J G Keppler,.
expressed concern that his staff.had informally characterized the ongoing
. soils and-foundation work as only minimally acceptable. Mr Keppler asked CP r
Co's management to commest on its. impression of this characterizacion and *.o provide its suggestion as to how this assessment could be improved.
)
The following consists of a brief analysis of what Consumers Power perceives
~
j to be the basis for this informal characterization and a description of some j
'of the current organizational and programmatic features of the soils y
activities that lead us to conclude that prospects are excellent for the
- satisfactory execution of the remaining soils and foundation work.
- o The soils-related activities at the Midland job site are currently at a
-relatively low level pending completion of tho'NRC staff's technical review
]
and release, by the NRC, of the major portion of the remedial work still to be undertaken. The work that has been done thus far in 1982 is concentrated in i
two areas. -First, a significant number of wells have been drilled at the site, as part of the plant dewatering systems, as part.of the freeze wall G
- associated with the auxiliary building underpinning activity and to support the site drawdown tests. Second, the major contractor for the auxiliary
. building underpinning work was mobilized; the initial work on the access shaft ~
was completed; and, in parallel the detailed underpinning construction
- lanning and continuing technical review with the NRC staff of subsequent work i:
p d
was carried out. Very little work in the other remedial soils areas has been accomplished during this period.
- ]
ij In resp = Mn to Mr Keppler's comments at the SALP meeting, we believe that
..the basis for the staff's informal negative comments regarding the current
't-
' soils quality assurance activities can be traced to one specific area of j
concern and one more broadly-based general concern. A discussion of each of these follows.
I
~A specific area of work which may have been of concern to the staff, and one
[{
of immediate concern to Consumers, relates to the controls on the drilling and excavation activities that have been recently carried out. Because the number
'l.'
of NCR's that had been written in this specific area and the severity of the f
most recent occurrence (drilling into an electrical duct bank), the Company f.(I concluded that even with the formal controls that were previously in place, additional controls were required. As a result on April 28. the C-ay I
1-issued a stoo work on all drillin?.
(This Consumers Power stop work direction 1
preceded the,ASLB Order of April 30, 1982.) As of May 12, the stop work order had not been removed, nor will it be until a new detailed drilling and F
- excavation control procedure has been fully reviewed and accepted by Consumers Power Company. While there had been other corrective. action taken prior to the CP Co stop work order, the Company is confident that the comprehensive l
revisions to the prior control procedures on drilling and excavation will preclude errors of the type recently experienced, and will assure that future
. <rp0582-0091a100 I
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E drilling and excavating work will bs carried out in a satisfactory and
~
controlled manner.
1 The general and considerably more significant area of inferred NRC concern can only.be identified as the lack of timely agreement between the Company and the j
NRC on the specific quality assurance coverage requirements to be imposed on y
the remedial soils work, particularly those to be imposed on the underpinning n.
work. The lack of timely resolution of this issue, the apparent ii misunderstanding regarding the Company's commitments, and the contentious
- [
atacsphere at the March 10, 1982 meeting on this subject and at the subsequent
- l' inspection undoubtedly contributed to the negative rating informally expressed q
. by the staff.
n 1
When the auxiliary building undarpinning work started with the first partial NRC release for construction of the vertical access shaft, CP Co presented a 3
special quality assurance plan encespassing, in our opinion, appropriate portions of the underpinning work. This plan was initially presented to the
- i staff at a meeting in Region III headquarters on January 12, 1932 and documented in a letter dated January 7, 1982. While the initial staff 4f response to the plan appeared to be favorable, no official NRC conclusion was a
expressed. It became evident during the time between January and early March that at least one individual within the NRC staff believed that an extensive l:
modification of the program coverage under the QA plan, MPQP-1, should be required. This preference for expanded NRC requirements became an NRC staff H
working level position, formally expressed to the Company at the meeting on p
March 10, 1982. As a result of that meeting, the NRC Region III inspector
};
apparently concluded that Consumers had committed to fully accepting the NRC R
Staff position that essentially all to-go underpinning work should be Q-listed, unless exceptions are agreed upon. 'the NRC's meeting minutes reflect i
no such commitment. In fact, no commitment was made. This misunderstanding, g
and others -arising out of follow-up discussions with the staff, has apparently it.
affected Region III's feelings toward our soils quality assurance program and
. personnel. It is, therefore, not surprising that the NRC Region III staff f
considers the quality assurance activities in the soils and foundation area to be in need of improvement based on its recent experience.
(It should also be 1
noted that the NRC SALP Board held its second and final meeting on March 23,
?
1982.) The Company also agrees that it is extremely difficult to avoid
[
regulatory difficulties unless both parties have a common understanding and y
agreement as to the scope of applicable requirements. The major issue with j
regard to QA program coverage was resolved at the management level meeting W
held on March 30, 1982 in Glen Ellyn and documented by the April 5, 1982 k
letter of J W Cook to J G Keppler, in which the Company agreed to "Q" list essentially all of the to-go underpinning work. However, the staff has still not formally acknowledged its concurrence with that letter. This concurrence
.I would be of significant assistance in documenting the conclusion of the staff's review of program requirements and permitting the redirection of resources from program definition to successful program execution.
l l
Resolution of the concerns noted above will make a significant contribution to the remaining soils work. In addition, the following considerations should provide added confidence that excellent results will be obtained in the f
remaining soils construction activities.
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i Dedication of a high quality proft.suional staff to the underpinning and other soils work is of paramount importance to its successful completion. Because of the complexity and importance of the underpinning work as the dominant
~
~,
factor in the soils remedial program, a mini project of dedicated groups has t
been set up to focus attention on the soil.s activities, with particular
-emphasis on the underpinning._ The technical' qualifications of the individuals staffing these activities emphasize previous related experience. At the site, 1
specific underpinning groups have been formed within Bechtel construction,
]-
-Bechtel quality control and MPQAD, all staffed with individuals having significant applicable technical experience esd academic credentials. Both Bechtel resident engineering and Bechtel engineering in Ann Arbor have dedicated remedial soils groups. The onsito resident engineering office will have four geotechnical engineers and at least two structural engineers i
dedicated to supporting tho' field activities. Consumers Power Company home-1-
. office soils activities are currently staffed with two experienced geotechnical engineers.and several experienced structural engineers who have been active in the design reviews and prior licensing evaluations and who will continue to follow the soils remedial work throughout the duration of the
. construction. The overall Consumers Power Company project management of soils is also organized as a mini project, and the senior Consun. ors Power Company L
individual has had significant nuclear power plant experience at the project manager level.-
1 In addition to the on-staff individuali for Consumers Power Company, Bechtel and the major subcontractors, significant consulting resources are also integrated into the soils work. The desian consulting firm for the auxiliary building underpinning has a staff man oasite to coordinate with his home y
office _ personnel. All the major consultants will be asked to periodically review the job progress as the underpinning work proceeds.
To assist some of the technical specialists in fully understanding all of the y
quality requirements on the job, some additions to the staff are also planned.
The Bechtel underpinning construction group leader, who oversees and interacts S
with the underpinning subcontractors, will have quality consultant on his i
- staff to assist him in any and all quality-related matters.
It is also
]-
anticipated that the underpinning quality control organization will be j.
augmented to enhance its breadth of leadership.
^s C
We believe that the NRC themselves can significantly assist in the successful i
completion of the underpinning and other soils, remedial activities by expanding the presence of their lead inspector on the site as the work s
progresses. Specific steps to facilitate this NRC interaction were agreed upon, as documented in the April 5, 1982 letter referenced above, and complemented by day-to-day working agreements.
A second area'which r,hould significantly assist in the successful completion of the remedial soils work, particularly the underpinning activities, is the degree of'dssign completion prior to the work entering the major construction
(
phase..Because of the extent and thoroughness of the NRC staff review, there 3
.is a more complete design for the underpinning activities than is normally in sL place for other construction activities. Essential completion of the calculations for the underpinning work before the major construction phase a-rp0582-0091a100 q-
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begins'will'ainimize the kind of major design changes that can occur in f
. nuclear plant structural design process because of calculation revisions.
There will, of course, be design changes as the work progresses, but the degree of-calculat$on completenass reached prior to initial drawing release will significantly contribute to the stability and success of the construction process.
In addition.to the degree of completeness in the underpinning design activity, t.
the interface review called for by the quality assurance plan for the j
. underpinning activity, MPQP-1, is also substantial.
These reviews will also contribute to both the validity of the design and the general understanding of design requirements and quality attributes by all persons participating in the-underpinning activities.
In addition, MPQP-1 directly inserted quality 1
assurance (and through quality assurance, quality control) comments into the i
design raview cycle, a significant requirement above and beyond the quality assurance program for the balance of the plant.
The number of procedural controls that have been or are being instituted for this work should also engender confidence that the critical underpinning activities will be satisfactorily controlled.
Judging from the work to date, W
there will be more than 50 specific work procedures developed for the underpinning work.
MPQP-1 calls for integration of inspection hold points directly in these construction work procedures.
As a result of these steps, the procedural controls for the underpinning work will be more extensive than those for any other activities, with the possible exception of NSSS primary loop activities, covered by the QA program for. the balance of the project. The extent'of the construction procedures automatically increases the scope of the training activities and of the inspection plans which are developed based on the specific work procedures.
q.
Finally, as a result of the extensive discussions with the NRC staff'regarding
.the coverage of the "Q" program, MPQP-1 is being applied to essentially all of the underpinning work still to be done. While this application may or may not be completely consistent with a strict definition of what is " safety-related,"
it should lend added assurance that the work in total, and the safety-related H
work in particular,.will be carried out successfully.
E In light of the foregoing, it is hoped that the Region III management can gain g
en appreciation of Consumers Power Company's perception of recent events and i.
that both the Region III management and staff can develop added confidence that the to go soils work, particularly the extensive underpinning activities, can and will be carried out up to the expectations of both the applicant and the NRC.
J~
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a rp0582-0091a100 N
it
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e To:
DBMiller From:
BHPeck
Subject:
USNRC EXIT MEETING Date:
October 19, 1982 CCi.
.4 This memorandum documents an N g ting held
- A list of attendees is attached. 4 ~ru u a 7 b^'J
^
- 7 '* ' *" 3'
'3 d o. azhedvol.
Mr. R. Cook began the ' meeting by stating that after the first four days of effort, the NRC has gotten into more areas than initially planned. The issues to be discussed are considered preliminary, and comunication of status to us is the purpose of th& meeting.
NRC Inspectors Cook and Landsman have been looking at Diesel Generator Building o
to get a story. After they have conpleted their review, they will see what it says. The concerns at this point are as follows:
a.
1C231 Generator Control Panel - Bolts not installed to;r' drawing.
Ed Jones has armation on this. There was no number on the l
fct n p /4 l,
briginal FCR$ gettkted "another"'to get signature.
I b.
Terminations in Panel 1C231 were inspected. Problems with internal wiring paration were identified. This problem l
was documented by MPQAD on NCR 075,. in. June,1982. The NRC will review the resolution of this NCR.
c.
Foundation bolts for IC111 - open item on traceability. Some missing washers were also noted.
1
- -~ -
-:-:=--~.-----------
- .4-Pega 2 f-d.
Potential Item of Non-Compliance - IC112 defective terminations oninternalwiringdoneinthevendor'sshopMbrokenstrands, The NRC felt there was poor workmanship inside the etc.
panel. A QA overinspection coupleted earlier, and it was -
'not known if these items had been picked up. - Mr. 'Ed Jones.
will follow up.
- Mr Paul Barret stated he had an open item on the in-process QC inspection of hangers built to the ASME code. Mr. Barret needs to verify in-process inspections:.for the correct welder, procedure.and fit-tp during fabrication.
He'also had unanswered questions in the following areas:
.a. ' Rusty welds on hangers and grouted anchor bolts in Bay 2 j
of Diesel Generator Building.
b, Control of distribution of redline changes. Changes should go through Document Control, not Field Engineering.
4 crddr,w Mr. Barret also comented that the insulatien-of welds and piping looked j:
good. He reviewed the controlled process from Engineering to Construction which looked good..
O l
f Mr..R. Cook reported on the following items reviewed by Dr. Landsman:
a.
Hilti, drop-in anchors,.in the Diesel Generator Building looked good.
- e b.
The NRC is still looking at an FCR procedure over the issue of re rir<d FCN's.
6 1
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Page 3 c.
A pipe hanger over the Diesel Generator engine (for Diesel exhaust) was reviewed.in detail.
~
sevd
~
This item is still open, pending resolution of questions an
. Q" vs. "non-Q", weld p'ainting, documentation, inspection and welding to a. beam.
Mr. Wayne Shafer discussed comunications between the NRC and personnel on site as it related to an incident that came up yesterday with a Bechtel field engineer.
The NNC has the right to talk to anyone, however an individual has a right to ask that his supervisor be presenty C. Shafer said it was permissible for an individual to say I don't know Mr if he doesn't, however, all answers should be given honestlyp He acknowledged the existence of our matrix of comunications with Bechtel, but stated that we need to correct this. d V
4 as kn [ J d/
[Mr. J. W. Cook stated that our policy will meet the needs of the NR d
l All organizations will understand this policy of communications, and it will be e:xplained to everyone. D C. D. B. Miller pointed out that he would be issuing an interface procedu Mr l
in the near future for communications with the NRC.
l BHP /1rb l
Attachment l
1 e
=.'
-~
NRCIEUT.. MEETING NOTES CM-&WD982)
$^M^f MM4 c_llit&Ma13ati+d g
1.
Issues coming up are preliminary. C=mmications with us.
2.
Paul Barret (other contacts:
R. Corcoran, R. Marl, F. Schulmeister, and D. Vokal) - In-process QC inspection on hangers built to ASME code - he had a question on this. Still working on.. Wants to verify in-p.rocess ik inspection during fabrication. Right welder, void procedure and fit-up.
Verify doing fabrication.
3.
Have gotten into more areas initially than originally planned.
M 4.
Looking at[Ines_el-GeneratoriBuntnng-t@ ght a story. Will then see what.i it says.
C23LGen Control Pahe*1 pB61ts7not installed to a drawing.
!EdJoneshasinformationonthis. No niraber on the FCR, i
/ generated "another" to get signature. Still sort of open.
r b.
Inspected terms in panel. LI.ntleTrinatwinng, separation.
(See NCR 075, dated 6/82). NRC to review resolution.
/
- c. gycn.to1M open item on tracer.bility.
1C111 - missing washers.
IC112 6 on f
internal wiring (by shop), broken strands, etc. (4 specifics).
' Poor workmanship in panel. QA overinspection completed.
(Maybe not picked up - Ed Jones needs to check).
\\
e.
General concern on' wire separation throughout the plant.
f.
WeMdYufsLibnf (Paul Barret)
~
tvNelcs _an hangers and bolts (grouted anchors - bolted to drawings)
(Bay 2 of Diesel Generator Building) contro14f'distritheirmWr~aa16a3hude5dhanges should go through Document Control, not Field Engineering.
i
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..___1_--
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Page 2
/&/1ff477%
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Followed up from Engineering - Construction = Good.
5.
Ross' items
--Hilti, y.-a.J...c..,;.. y o,g. g m.
_..mu...-
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(?) Loo a
- see DIN 1
Looking at procedure. Still open.
Retracted FCN's?
Check with Ross on who he was working with, o
M;?~Aysga.;rrpergg4f3g. engine for Diesel exhaust, 241HBD-485-H5-10 1 Drawing 632-1-510
{-
- a. % g-imp.y. jQC didn't inspect, hanger critical (B3.1.1)
\\
}
Does this violate 2 over 17 b.
FNE - inspected, but no records, c.
Mechanical Engineering - some records, but not on this.
d.
Tack weld. Painted over.C' Weld?not in accordance with print.
u [f This hanger @lded to a "Q" berahigshould have showed preheat.
m' i
e.
N j
- 6. b W e^ % Fer
--Rumor - Bechtel might have to1Qeople__not _to en1k tn EE J j;.
--Came up yesterday with an FE
--NRC has right to talk to anyone
--0K to say I don't know if he doesn't. Answer honestly. Not my area.
--Referred to some handwritten note. Sevo
--Acknowledged our matrix
--Read a memo from Curtis to Rutgers JWC and WRB aware of and refuted
{6iCneed'to~ correct:this.7
--Individual has right to ask his supervisor present.
--Ieo responded. Defended FE response.
E SJWC$0urMoll6E.wilihtS1GCie'ecisWAll'dissitzitionsliaTu,unoerstana y (cdirnunicalions.'p;Egliin)_.thi4Lto everMed
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--DBM - His procedure is coming up
--Discussion
--Verify that we have all-the right up 7
JWC invited NRC to cane to us with general cancerns - Before they become a sore point.
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. ~., i ~ ~ DATE:; '.. ~ November??W-@.e -&::%,+.-10,.1982:' '7 b. @ c
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SUBJECT:
',0MIDLANDJPJETECT GNO.7020 =B?4'! # -
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%"id.i This memorandum doctments the NRC Exit Meeting held"on November'10.1982."4fa i
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IN,UE "A list of atteridees is attal:hed. Mr.bCook opened thE meeting and acted 'as71 C'.
2 r 9. :,.,:: ys pg:.
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m He stated that over'.t.h..e._.la.s.t.'.,'f_our, weeks, th,._i~..--+m,,
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-...... '-.. '......the lead N.RC. spoke'sperson.
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n.
p spectors have been concentrating on the Diesel / Generator Building. This areaif
- ? y p:-: -
Mr.g,. Cook stated that the
~
was picked deliberately for an in-depth review.
NRC Inspectors had groupted their collective findings into several catagorie's.], _ '
These were then presented as follows:
1.
Material Traceability i.
/
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- A"'a d~
rh arc-Several Es - les
- dh AreadmiGiek M# # "
P4 essa with no identifyinc markines> %
r
r _ i; r t" ' ', Ar$b m
B.
NCR 3266 - Barrett a
Material from unapproved vendor was installed.
Pat Corcoran has some additional infomation.
4.,,
C.
HVAC Fan Supports - Landsman 1" plates do not meet ASIM specs.
D.
Spec C-233 - Allows purchase of Q and non-Q (Gardner)
GWR is researching this issue.
E.
Indications of wrong material used in Construction (Landsman)
Gusset plates and HVAC 2.
Plant not built according to Dwgs.
A.
HVAC fan supports - (Landsman)
B.
Electrical Hangers (Gardner) 3 cable tray supports not per Dwgs.
FCN's have been written.
~.,-:..,.-!
7
. /..
4
/.
C.
Conduit Pull Boxes (Gardner)
Several do not conform ~to E-42.
... m.
D.
Diesel / Gen.erator Enginer Control Panels (Gsrdner)
,7. p.=72$.yWriW$.i V.!..
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Diesel / Generator fan support
- " " C "
No cross reference from dwg to field sketch and vice-versa.
.n B.
Control of Redlines (Barrett)
...i.2liss.;.
Doc. Control is bypassed.
C.
Retiring of FCR's
--.:i:M Need to label dwgs, that this has been done.
Lost FCR D.
Rev. 6 of C-1004 - HVAC Fan Support Incomp FCN C-335, but not listed on block.
(New item)
(
5.
Field Inspections not adequate.
i 1
l
? Discussed Earlier 6.
Design Control not adequate.
l.
a.
Monorail in Diesel / Generator Building
.g Should have written an NCR.
b.
FSK's used for fan supports c.
Diesel / Generator Exhaust Pipe t
l System is Q (pipe), hanger is non-Q Di: cussion of "Q" - ness issue.
Should we have stopped work, or written an NCR?
Issue of preheat open issue d.
Time for SCN's to come to the site.
b-..-..
d.
- n..
/
/
j 7
Remedial Soils 6
Perimeter dike and baffle dike should be Q.
a.
Armour Stone installation proceeded..
a dpc w 's.~
a, -
5.
~l. "'~. A May 25,.1982'. letter.from NCR to us.said it.V
-4
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Service inspections Vendor QA program Inadequate Receipt Inspections 19 page NCR by MPQAD SCRE Written
. ~.
b.
CCW Pumps, 1 pump curve.
7.
- 11. Other a.
Cable Tray Segregation Program to have correct cables b.
Painting of Welds i.
c.
Chipping of Concrete in CB.
!.I; No one should touch plant unless design is there Training Program down to F level.
- 12. Items from Landsman f
a.
Weld Rod Control L
Closed - Coment b.
FE Daily Reports Non-Q I
i c.
Hole in AB Need look up an FCN 13.
IkIN's Control of nc7-confinning items.
TE's have to interpret IPIN's NRC wants to follow up with us on this.
a
[
- 14. Use of IPIN's/ Ability to Trend Deficencies IPIN's - Leaves open inspection records Management doesn't know about deficiencies An JPIN does _not;haitIfuEther:.htalliticinYuse.N.hs,$ww (k,.
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.t November 10, 1982 5
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Jim Cooley INPO (MAC) r
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BRKappel Bechtel - Resident QE GLRichardson Bechtel - Ass't to Proj. Manager l ':
Ed Jones CPCo-Elect. and I6C Group Supv.
j IE41V USNRC l'
RLandsman RCook H
RWarnick lJ WShafer i.
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7.e NOTES FROM MEETING WIE NRC ON 11/23/82
- We made a good presentation on individual items, however:
.t.
- Generic approach is a concem to NRC J
- Where do we go now
- Inspection Program is behind where it should be:
t
- Open IR's is over 12,000 j
- IPIN's concern - big issue
- D/G Building problems found over last several weeks.
q
- What about rest of plant?
1
- What do we do?
-- How long to find them? Status of the plant.
- Inspectors feel safety related work should be stopped.
- I
- Warnick not sure how much work he could allow to proceed.
- R.S. work should continue, also some other elements of work like HVAC, non-safety related work, B6W work.
- NRC has.not really had time to think this through, but they wanted to talk to us.
- Need many more details on open IR's, IPIN's open.
i
- Issue of recertification of all QC Inspectors:
' ~
- We say we will be done by April, 1983.
- Adequacy of Inspection Program, up-to-dateness and our grasp of the QC program.
This is the center of their concern.
- It is,hard for NRC to issue an order.
Time consuming process, including going to the Comissioners.
- They want us to recognize the problem, take the action and take the credit. They would follow up with a C.A.L.
- JWCook reviewed his plan:
- Go over inspection specifics
- Get a time readout and response
- Make a proposal to address NRC concerns, to include Statusing of inspections Systematic work suspensions - Certain areas
- Not ready today to go over details.
- We are at a point in Construction where we will have to inspect quality into the job.
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- Warnick:says they are not fixed in their position today. They need to put their thoughts together. -Strong feelings within his group on stopping all work. We should address the problem (Zimmer did this) in 2 areas:
- 1) What are we doing today to control work going fomard.
Inspectors identify things.
l
- 2) Look at past week, we have performed (backward look). Have problems been
.,c
. addressed?
We should review our plan and present it to them prior to a 12/7/82 meeting they have with NRR. His is their deadline.
- NRC will be trying to determine if these problems exist in other areas of the plant.
- What are we doing differently from now forward to build quality into the plant?
- NRC lacks confidence that we will address concerns on a generic basis. We do res-pond well to specifics. We handled the meeting today very well.
- Good turnaround on our efforts to cooperate. Good attitude lately. Since we started communicating with NRC better, things have been good.
- Show NRC how we can address their concerns. They do not want to drop the build-ing on us. We should be responsive.
- Our in process effort is the key to solving the problem.
- We did this before in HVAC - we should repeat the performance.
- We will do everything we can to prevent them from issuing an order to us'- JWC.
We will meet the NRC timetable to resolve this.
b
- NRC will put all of their thoughts together and get back to us before we make any presentations to them. Eis will be done in the next few days.
~
- IPIN's, design document changes (capricious ones), and material traceability are among Ron Cook's concerns. We didn't do much today to make these concerns go away.
- Attendees at this meeting:
CPCO: JWCook, ~RAWells, DBMiller, BHPeck, MLCurland, Consultant from MAC (Vince)
BPCO: KVassar, JRutgers NRC:
Shafer, Cook, Warnick, Burgess, Gardner
' BHP 11/24/82 1
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NRC INSPECTION STATUS TIMETABLE
- October 12, 1982 Entrance Meeting with Wayne Shafer and others.
- October 12, 1982
.Four (4) week inspection of Plant by up to nine (9)~
through NRC inspectors. Three (3) infonnational " exit" meet-November 5, 1982 ings held throughout this time.
- November 10, 1982 Exit Meeting with Wayne Shafer, Bob Warnick and others.
- November 10, 1982 Continued to work with NRC Inspectors by phone and.
through in person to provide additional information on find-November 22, 1982 ings.
November 23, 1982
" Final" Exit Meeting with NRC - held'at CPCo request.
~
I GENERIC ISSUES
-I.
Material Traceability Examples: NRC has generic concerns with our perimeter control system of stor--
age.-
Our ability to locate a bad heat number after receipt once it is installed.
Use of high strength field fabricated materials (A-36 issue).
Resolution of a Bechtel NCR where material was purchased from an unapproved vendor.
Status:
We have been unable to fully resolve all of the NRC concerns. They still feel our system has problems.
We feel we can resolve the Bechtel NCR issue, and plan to do so the week of 11/29/82.
II. The Plant is not built according to design drawings.
l 8mP e: - HVAC fan supports i.
- Cable Tray supports
- Electrical Conduit pull boxes
- Welded vs. bolted connections
, /'
- D/G Engine control panels - missing washers.
Status:
We have written NCR's, FCR's, etc. to track these items. Most of
,L them are valid findings.
Final QC inspection has not been done f
I in all cases.
III. QC Inspector Records Incorrect Examples:
- QCIR's have been closed, yet the item does not look like the drawing.
v_
- -.. _ -. _ _. _ - - ~.
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- IPIN's issue.
o
[
Status: H is is a major concern. Still open.
IV. Design Document Controls Inadequate D/G fan support references design drawing to FSK.
Example:
Control of redlines.
Labeling of retired.FCR's.
Statt$s: We have prepkred changes to our procedures to resolve all of these.
Nevertheless, they are valid findings.
4 V.
Field' Inspections Not-Adequate 2
I The NRC feels that the problems in II and III above d uld not exi,st if we had adequate field inspections.
IV. Design Controls Not Adequate
~ Examples:
"Q-ness" issue: monorail, hangers FSK's used to design structural connections.
- Length of time for SCN's to come to the site.
-- Preheat of welds.
Status: The issue of '.'Q-ness" is a big one. The other ones can/are being resolved.
3 VII. Receipt Inspections The panel in the D/G Building from DeLaval was found to have wiring defects not picked up by receipt inspection, or MPQAD overinspection. His is a major concern.
MISCELLANEOUS CONCERNS
. Painting of welds: resolved.
- Code question on D/G air start lines:
resolved with Region III - referrel to NRR.
-- Chipping of concrete: valid finding, being tracked now by an NCR.
- Cable tray segregation: valid find, procedural revisions being made.
BHPeck 11/29/82 4
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0 CCNsuMERS POWER C_._.,s To DBMiller, Midland Plant gE0EP!ED 1 9 1902-rao,4 BHPeck, Midland Plan CCT ggg one October 18, 1982 Site M5r.
Power susacer MIDLAND PROJECT GWO 7020 Midisd Proiect EU
~~
USNRC ENTRANCE MEETING File:
0485.16 UFI: 99*04 Serial: CSC-6377 con"Noocuce cc JWCook, P26-336B BWMarguglio,MPQAD MLCurland,MPQAD gwet. cl. cq l.
JKMeisenheimer, MPQAD Civil L
An NRC Entrance Meeting was held on October 12, 1982. The list of attendees is attached.
Mr. Shafer opened the meeting by stating that this was not a routine inspection, but rather a " hands on" inspection to look at areas of completed work, such as the Diesel-Generator Building and the Service Water Pump Structure. He stated that the inspectors planned to walk through areas, talk to people, ask questions and ask for documentation. The NRC may ask to have cabinets coened, handles turned, etc. Mr. Miller stated that extreme care should be taien.in all areas of.the plant since approximately 75 percent of the electrical systems are ener-gized, hydrostatic tests and flushes are in progress and steam blows will be occurring shortly.
It was agreed that Confined Space Training and New Employee Safety Indoctrination would be provided for NRC inspectors who have not already received this training.
Mr. Shafer stated that this inspection would last about one month, and he pro-vided the names of additional inspectors who would arrive next week. Mr. Ron Cook will coordinate the inspection activities which will cover civil, electri-cal, and mechanical areas. At the close of the meeting asked for the latest status of five nonconfomance reports, and gave us a copy of each. The writer will coordinate the response to this request with MPQAD (J. Meisenheimer).
Attachment 9
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ATTENDANCE LIST
~
4 3:
.NRC ENTRANCE - 10/12/82 G
1:30 P.M.
NAME ORGANIZATION Rleiheeler CPCo - Construction JKMeisenheimer CPCo Soils MPQAD MSSolanki Bechtel QA WDShafer USNRC RNGardner*
NRC - R III OfScheibelhut NRC.- R III JFFisher-Bechtel ESmith Bechtel
.r MBlendy Bechtel ETCviki Bechtel JDarby Bechtel Resident RBland==an NRC - R III RJCook NRC - Senior Resident i
BLBurgess NRC - Resident Inspector RBicCue CPCo - Tech. Supt.
BHPeck CPCO - Construction l
DBM111er CPCo - Site Manager MLCurland CPCo - Site QA Supt.
I e
9 L
4 r$ -
DBMiller COnSumBIS oATc October 25, 1982' power Company
.suescer MIDLAND PRNECT GNO 7020 USNRC EXIT MEETING
"" ~--
4,,,,,,,,
File:
0485.16 UFI: 99*04 Serial: CSC-6408 conacsromocace cc JWCook, P26-336B' RAWells, P14-113A i
~
BNMarguglio,MPQAD MLCurland,MPQAD Coff' s
JKMeisenheimer, MPQAD Civil h is memorandum documents an NRC Exit Meeting held on October 15, 1932. A list'of attendees is ' attached. A sumarv listing of action items is also at-tached.
I am currently developing a mechanism to keep' track of open items with the NRC, and plan to finalize something in the near future.
Mr. R. Cook began tlie meeting by s.tating that after the first four days of effoit,. the NRC had gotten into more areas than initially planned.' The.is-sues to be discussed are to be considered preliminary, and the comunication of status to us is the purpose of this meeting.
NRC Inspectors Cook and Landsman.have been lo' king at the Diesel Generator o
Building to'get "a story." After they have completed their review, they will o
see what it says.} ne concerns at this point are as follows:
a.
1C231 Diesel Generator Control Panel - Bolts not traceable per design.
h ere was no number or'a? proval signatures on the original FCR pre-L sented. Bechtel found bat the original was lost while being routed l
for coordinating signatures and caused a second copy of the original l.
to be " walked through." A signed copy of the FCR (M-149) was pro-vided to Mr. Gardner the same day.
b.
Terminations in Panel IC231 were also inspected.
Problems with in-
~
ternal wiring separation were identified. This problem was document-ed by MPQAD on NCR 075, in June,1982 The NRC will review the reso-lution of this NCR.
i c.
Foundation bolts for Panel IC111 - open item en material traceability. -
Some missing washers were also noted.
d.
Potential Item of Non-Compliance - An inspection of panel 1C112 re-1 vealed defective terminations on internal wiring done in the vendor shop.
Several broken strands of wire was dso noted. The NRC felt there was poor worknanship inside the panel. A QA overinspection com-pleted earlier, and it was not known at this tima if these items had been picked up. Mr. Ed Jones will follow up.
g e
i.
1*
i USNRC EXIT MEETING
' October 25, 1982 Page-2 W :.:
~
1 Mr. Paul Barret stated he had an open item on the in-process'QC inspection of -
hangers built to the ASME code. Mr. Barret needs to verify in-process Npae-tions for the correct welder, prhe and fit-up during fabrication., He also had unanswered questions in 'the following areas:
Rusty welds on hangers and grouted anchor ~ bolts in Bay I of Diesel L.
s.
Generator Building.
b.
Control of distribution of redline changes, Changes should go through
.t Doctament Control, not Field Engineering. -
Mr.t Barret also commented that the installation of wlds and piping looked He has reviewd the controlled process from Engineering to Construction, he felt it looked good.
Mr. Ron Cook reported on the following items which were reviewd by Dr. Landsman:
.a.
Hilti anchors bolt installation.in the' Diesel Generator Building looked. good.
'b.
The NRC is sti11'looking at an PCR procedure over the issue of retired i!
' FOl's.
,.r i V!
c.
A pipe hanger over.the Diesel Generator Engine (for Diesel exhaust)
~
was reviewd in detail.
1his item is still open, pending resolution of several questions on "Q" vs. "non-Q", weld painting, documentation, inspection and welding t.
to a beam.
e
' Mr. Wayne Shafer discussed communications between the NRC and w rsonnel on site
[
lt as it related to an incident that came up yesterday with a Becitel Field Engineer.
1he NRC has the right to talk to anyone, howver, an individual has a right to
(-
ask that his supervisor be present.. Mr. Shafer said it was pennissible for an individual to sa don't know if he doesn't, howver, all answers should be given j
honestly. He ac ledged the existence of our matrix of communications with l
Bechtel, but stated that we need to correct this. Mr. J. W. Cook stated that our' l
policy will be redefined 'and will meet the needs of the NRC. All organi ations will understand this policy of communications, and it will be explained to every-one. Mr. D. B. Miller pointed out.that he would be issuing an interface pro-cedure in the near future for communications with the NRC'.
i
'i.
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l BHP /dmw Attachment l
o J.
.-.-- - =
/
ATIE GANCE LIST l
NRC EXIT - OCIDBER 15, 1982 10:00 A.IL NAME ORGANIZATION BHPeck CPCo - Construction DBMiller t
I CPCo'- Site Manager l
REWhitaker MPQAD MJSchaeffer MoQAD VSSolanki Bechtel QA LEDavis Bechtel Site Manager ESmith Bechtel - PFQCE EJones
~
CPCo,MPQAD RJCook NRC Senior Resident WDShafer Chief, OCS JWCook CPCo - VP Projects, Eng. and Const,
.JMooney CPCo KRBird CPCo - MPQAD Manager CHScheihelimit NRC - ANL PGBarrett' NRC - Region III j -
h i
e
3 9
]
ITEM DESCRIPTION
- hac CONTACT
- ACTIGI, R220L%.
~
j
'.GWR #1 Generatcr Control Panel IC-231-Anchor Ron Gardner.
FCR-M-6655 written 9-21-82
- [
Bolts no,t installed a'ccording to vendor lost'.. FCR rewritten on 10-J drawing.
14-82.'to install nut to hold Yes J
Z channel to panel plus nut
?
and washer to adhere to con-
~
crete curb.
' GWR -82 CPCo NCR-075 internal wiring separation Ron Gardner Delaval te be on site for inadequate in panel IC-232.
inspection on GWR to follow-up with Delaval u
Q GWR -#3 Foundation bolts fSr panel 1C-111'have no Ron Gardner
- Mike. Verderosa has found 'that Closed per
!l traceability.. Anchor bolt washers missing.
drawing NRC has referenced Exit Meeting was internal drawing to De-Notes of 10-n 1aval. 'Ihere is no require-22-82 ment that these
'J' bolts K
have O ER.
jiGWR-84 Internal wiring in panel IC'111 has de-Ron Gardner Delaval to be on site
~
U fective shop terminations.
and should be able to pro-vide some resolution. GWR H
to follow up with Delaval.
a n
ji GWR -85 General concern on separation of wiring Ron Gardner QAC191 written 8/2/82re)-
l j!
throughout plant.
sponse was to revise E-47 F
and E-42 and modify PQCI E4.0. E-42 8/13/82 signed
};
off. E-47 9/15/82 signed.
H off. Still require method il of implementation. GWR
[
working /GWarner dr q
jt
~
UdR = G. W. Rcwe 10/25/8 2
'Page 1 oi'
,I l
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.g ITIN -
DESCRIPTION.
. '.hnC CONTACT g
ACTI(M.
Rc.20LL l
4 1
10/19/82 Questions'Concer'ning.Large Bore Hangers
, Land - n
~
. (JS.K).
in D/G Building.
~
\\<
1.
Why is this hanger Non Q 652-1-501?
l'.
Section 9.5.8.of NRC.
SER states that NRC in agree-ment with this design philos-ophy..
0 PEN-Parts of hanger n' t welded according 2.
Land - n 2.
Hanger Construction not 10/20/82 o
to Dwg. 652-1-501..
complete.
1
- 3.
Strut Support not welded according td Landsman 3
Hanger Constructioni not 10/20/82 Dwg. 652-10501.
completed.
4.
Item #1 Bill of Material not according Landsman 4.
Hanger Dwg. redlined'in 10/20/82 Dwg. "10 x 8" tube steel replaced by "10 x Standish Fab Shop due to lact 10" and not called out on work print 652-of material. Redline not 1-501.
included in work print.'
5.
No preheat done to structural steel i.andsman OPEN prior to welding of hanger member.
10/19/82 Questions Concerning Large Bore Hangers j
(JSK) in D/G Building.
6.
Field Welding Engineer does not keep Imad n
F.W.E. daily re mrts on non-10/20/82 records of what inspected or what to in Q Welds.for eac1 welder in spect.
his responsibility arqa.
Info:'is microfilmed and kept by CPCo.
3 j
1,0/2d/82 Questions concerning large bore hanger's in
'(JSK)
D/G Building.
1.
Where is weld rod t s
ified for ImnA n
Forn 84. civil as called out 10/20/82 l
stiffener plate Dwg. 65 5 1.
in weld spec. G-27.
,10/25/82 e
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~
' ' ~ ~ ^
.n ITB1 DESCRIFFION 4 hm,' CONTACT
. ACTION.
R M LVL L
t l
2.
Diesel Exhaust snubber 1-652-1-19 Landsman
. Assembly furnished by ITT
~10/20/82' i
No stanchion to plate welding symbol.
Grinnell, no welding requir'-
ed at point in question.
t 3.
Upper Hangers on Diesel Exhaust system.
Landsman No QC awaiting clarification 10/20/82 Have they been inspected by QC.
of Appendix M.of M326 before
[
inspection of hangers.
L 4.
Stiffener Plates Welded to structrual Landsman An obstruction would not al-10/20/82 above hanger in question welded on one side both sides. 'lhis is tech-low welding to be done to only, is this good.Eng'g practice.
nically acceptable. However:
both sides would be welded normally.
10/20/82 Questions concerning large bore hangers
- (JSK) in D/G Building.
5.
Is there a redline for snubber 1-652-Landsman OPEN 1-19 showing weld to imbed in bay. Simi-i, lar situation in Bay 1.
Y
~6.
Bay 2 left side beam attachment for Landsman Inspect wel'd for increass '
spring hanger, although welded there is in fillet size equal to gap a gap between two welded pieces is this not to exceed 3/16" acceptable redline to 1-652-1-501.,
OPEN 7.
Number on hanger FSK is not the same Landsman OPEN'.'
as number on ISO that references. detail
'no. (1-652-1-19) US. 2-652-1-19 j
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Procedure for time limit on.forwarIllng Landsman
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SPEC changes from Ann Arbor.
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.hd CONTACT ACTION RrAA l1 D/G Rusty welds on hangers and grouted anchor Paul Barret -
Hangers - After QC and FE ap-7 e
10/19.
bolts in Bay 2 of Diesel / Generator Build-proval', surface will be prp-4 (JSK) ing-Pared and painted Bechtel t
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Control of distribution of redline changes Paul Barret should go through D. C. not Field Engineer ~-
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R3 Questions on the IPIN's Program Ron Gardner Several meetings held during U
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. November 1, 1982 Company sussect MIDLAND PRCUECT GWO 7020 USNRC EXIT MEETING con.carouocuec m,,,.
File:
0485.16 UFI: 99*04 Serial: CSC-6412 j
I cc JWCook, P-26-336B RAWells,MPQAD MLCurland,MPQAD JKMeisenheimer, MPQAD Civil This memorandum documents the NRC Exit Meeting held on October 22, 1982. A list of attendees is attached. The listing of ~open items that I am maintaining has been updated through November 1,1982 and includes the contents of this memorandum.
I Mr. R. Cook opened the meeting and stated that the purpose of this exit was to provide status on where we are, and where we are headed, on the current NRC in-spection. A formal exit will be neld later with Mr. Keppler and Mr. Warnick at-tending. The four personnel from Argonne National Laboratory assisting the NRC will not be returning next week. Mr. Paul Barret will be here next weet to con-tinue his portions of the current inspection.
Dr. Ross Landsman. reviewed the areas he looked at during the week. With regard to remedial soils issues, he noted the following:
a) Drawing C Need to put a note on this drawing saying that the temp-orary underpinning tunnel is "Q".
b) Specification for rip-rap of Annour stone is needed.
(A copy of this document was provided to Dr. Landsman after the exit meeting.)
c) Drawing C Areas of dike (baffle 6 perimeter) adjacent to SWPS need to be shown.
d) CPCo needs to provide a letter to NRC that our review of C-45 for under-l ground piping was completed.
e) The issue of instrumentation readings for the Auxiliary Building Electrical Penetration rooms needs to be resolved. This is a prerequisite for Pier 12 work.
1 With regard to his continuing inspection of the Diesel-Generator Bui(ding, Dr.
~
In d = n had the following comments:
l
'Ihe issue of items installed as "non-Q" is still open. This is an open issue between the NRR and the NRC-Region III Inspection group assigned to Midland. Ex-amples of this concern include: The "non-Q" hangers that support the "Q" diesel engine exhr.ust piping, and the non-Q monorail system that is installed over the i
diesel-generators.
A concern with. the "non-Q" fieli welding engineers reporting methods was raised.
2-* -- - ---
~
IJSNRC EXIT MEETING
'i
- /.'
~ NOVEMBER 1, 1982 V
PAGE 2 i
The initial concem was with the availability of records of what the Bechtel Field Engineers had' inspected and their responsibilities with what to inspect.
He was'shown a daily report form that is kept on file for 6 months and then is mocrofilmed by.CPCo and stored. His concern seems to be now the accessibil-ity of the records. Dr. Tand = n had stated that this. item was closed prior to the exit.
Dr. Tand e n expressed concern with several hanger drawings in the diesel build-ing. Several hanger numbers on FSK (2-652-1-19) did not match nunbers on iso-metric drawing H652. Bere was a. change in the method for attachment of a hanger plate to a wal1. He change was not covered by a red line to the drawing.
A revision to specification M326 took from the September 27, 1982 sign-off date until October 15, 1982 when the revision was received from Docume'.t Control. He thought that this was an inordinate amount of time and he asked if the document a
control procedure addressed any time limits for document transmittal. His item will remain open until'his next visit.
Mr. Ron Gardner reviewed the areas he had looked at during the week:
a) Vendor wiring terminations in Panel 1C112 - MPQAD NCR 139 has been written on this item.
b) Foundation bolts for Panel 1C111 - The problem on material traceability has been resolved. MPQAD NCR 138 has been written for the missing nuts and washers.
c) Type B conduit supports in Bay 4 of the Diesel-Generator Building - Mr.
-l Gardner is waiting for more infomation on this item.
d) Cable Tray Supports - Mr. Gardner is reviewing FCR's 2369 and 5088 on this subject.
e) Bechtel Quality Control In-Process Inspection Notices (IPIN's) program-Mr. Gardner has several open items on this subject, which will be pur-sued on his next visit.
Mr. John Simon had several comments on Diesel-Generator Building intake piping:
a) A discrepant (undersize) weld was found on a filter housing.
b) Details to the welder for a. bracket weld were reviewed.
c) Drawing attachments (FCN's) seem excessive on one drawing (Mr. DBMiller responded that this item had been previously identified, andNorrective action was in progress.)
Finally, Mr. Ron Cook discussed the issue of vendor welds on structural steel. He acknowledged the writing of an NCR and a SCRE, and stated the item will remain open until the NRC reviews cur disposition. Mr. M. Dietrich will arrange a briefing for Mr. Cook on this subject.
2 m.
I 1.;
i NRC EXIT MEhTING l
J, 10/22/82 Name Capany 14 Wheeler
-Cbnstners Power Company
~ '
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DINiller, Jr.
' Consumers Power. Company RT&h=affer Constners' Power Company NDShafer NRC d
CHSchelbelhut NdC t
Ray Gustafson NRC f
Bruce Burgess NRC Resident Inspector Ron Gardner NRC 4
ALSather NRC i
RJCook NRC Senior Resident 5
Ross Landsman NRC i
E1 Jones CPCo i
- MADietrich Bechtel BRKappel Bechtel Resident Engineering QE Patrick Corcoran Bechtel Resident Engineering QE
(._
LEDavis Bechtel l
r' ESmith Bechtel l
JN4ooney Consuners Power Company JRSchaub Consumers Power Conpany BHPeck Consumers Power Company 4
John Simon NRC l
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To DBMiller, Midland Plant fao.e BHPeck, Midland Plant gggggggg power onc November 1, 1982 company suescer MIDLAND PROJECT GWO 7020 USNRC EXIT MEETING
,,ge,m File:
0485.16 UFI: 99*04 Serial: CSC-6415 connesconocuer
.i cc JNCook, P-26-336B i
RAWells,MPQAD MLCurland, MPQAD JKMeisenheimer, MPQAD Civil This memorandum documents the NRC Exit Meeting held on October 28,' 1982..A list of attendees is attached. The listing of open items that I am maintain-ing has been updated through November 1, 1982, and includes the contents of this memorandum.
Mr. W. Shafer opened the meeting by stating that the purpose of this exit was to provide additional. status on the current inspection. He stated that a for-mal exit was planned for November 10, 1982, at the plant, with Mr. Keppler and/
or Mr. Davis attending.
i Mr. P. Barrett reviewed the areas he looked at during the week:
- 1) Large Pipe Hanger Material Traceability - Bechtel NCR 3266 was writ-ten e.s a result of material purchased from an unapproved vendor. Mr.
Barret stated the corrective action taken was inadequate because the use of the material was disallowed for Class 1 applications, but not for classes 2 and 3.
This is an item of non-compliance.
l-Mr. P. Corcoran provided a copy of ANSI N101.4 and stated our position.
Mr. Barrett stated he still needed to do more checking, and listed this item as unresolved.
i l
- 3) Document Control of redline drawings - Mr. Barrett stated that Bechtel Field Engineer distribution of redline drawings was not in accordance with 10CFR50, Criterian 14 in that Document Control was bypassed. It was noted that the Bechtel Field Procedure was being followed as written.
Mr. Barrett agreed. This is an item of noncompliance.'
l
- 4) Control of Temporary Hangers - Mr. Barrett inquired about our system for performing this function, and asked that we get back to Mr. R.
Cook with some information. This is an open item.
- 5) Cable Tray Segregation - Mr. Barret had several questions about a cable l
tray he observed in the Containment Building Purge Room at elevation 674: cable was observed to be overlapping the barrier, and the adequacy of the barrier to prevent spurious signals was questioned. Mr. E. Smith l
- - - - - _, -. ~
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USNRC EXIT MEETING
/
NOVEMB2R 1, 1982 PAGE 2 i
provided a. copy of the QCI as'the control whnni== for inspecting for deficiencies of'this nature.
Mr.' Barrett stated.he would -review this '
infonnation and get back to us. This is'an open item.
6.
Hole chipped in Contniment Building Exterior Wall - Mr. Barrett noticed that a hole had been chipped in the exterior wall in-the Contaimeent Build-ing. Purge Room at elevation 674. Upon further review of the matur, it was noted that no drilling permit (as required by TIG-1.111) had been obtained
,j-for the work, which was done sometime in 1981.. A full response to this item was not possible due to shortness of time. We will follow up with any additional infonnation next week. 'Ihis is an item of noncompliance.
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USNRC EXIT' MEETING OCTOBER 28, 1982
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i NAME GtGANIZATICN
- 4 NfPeck CPCo Construction ESmith Bechtel - PFQCE E
JSKreple Construction REWhitaker MEQAD BRKappel Bechtel - Resident Engineer Patrick Corcoran Resident Prod. Engine.:r-Bechtel E
MLCurland CPCo-Site QA Supt.-
LRHowell CPCo - ffQAD I
FHSchulmeister Bechtel MPQAD 1
RLAkers MPQAD PABarrett NRC WDShafer NRC f
RJCook NRC MADietrich-Bechtel MPQAD
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JJGilmartin Bechtel PFE LEDavis Bechtel 1
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FnoM BHPeck, Midland Plan O
Consumers one November 29, 1982 Power susaccr MIDIAND PROJECT GWO 7020 USNRC EXIT MEETING co2c" File:
0485.21 UFI:
99*04 {Seriali CSCR64545_47 L
i cc JWCook; P26-336B REMcCue, Midland i
RAWells,MPQAD l
MLCuiland, MPQAD JKMeisenheimer, MPQAD Civil I,
This memorandun documents the NRC Exit Meeting held o+M %Muh
- A list of attendees is attached. These notes have been written in a general, narrative format. The detailed listing of specific items is being tracked in the NRC Open Items List that I am maintaining. Mr. R. Cook opened the meeting and acted as the; lead NRC spokesperson. He stated that over the last four weeks, the inspectors have 3een concentrating on the Diesel / Generator Building.
Mr. R. Cook stated that the NRC Inspectors had grouped their collective findings into several catagories. These were then presented as follows:
I g
1.
Material Traceabhity - Several examples were provided:
I A.
The NRC has observed steel plates in the laydown area with no identify-ing markings. They questioned what was actually A-36 material.
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B.
Bechtel NCR. 3266 was written to document material purchased from an tuik -
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.J approved vender which was installed in the plant.
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C'.
Certain HVAC fan support 1" plates do nc meet ASIM rolling steel toler-ances.
D.
Bechtel specification C-2s3 permits the purchase of Q and non-Q materials.
E.
Indications of wrong material used in construction were observed on HVAC fan support gusset plates.
2.
Plant not built according to design drawing - several examples were provided:
A.
Certain HVAC fan supports.
B.
Three cable tray supports are sot installed in accordance with design drawings. FCN's have been written to correct this problem.
C.
Several electrical conduit pull boxes do not conform to drawing E-42.
D.
Diesel / Generator Engine Control Panels - Missing foundation bolt washers.
E.
Supports for Diesel / Generator Silencers do' not look like the design drawings.
F.
In some cases, bolted connections are installed when welded connections are specified.
3 7...~
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'USNRC EXIT MEETING t,
NOVEMBER 29, 1982
(.
Page.2 3.
QC Inspector Records. Incorrect -
A.
Several QCIR's have been closed, stating that the item is installed.in
,accordance with design. drawings, when.in fact it is not.
B.
The NRC expressed concern with the Bechtel Inprocess Inspection Notices (IPIN*.;) program. They felt that it di,d not properly docu-ment rr r ormances or provide for timely inspections, and it did f
.not prevent further installation and use. Also, the JPIN is not properly addressed in the Trend Program.-
4..
Design Doctament Controls Inadequate - Several examples were provided:
A.
Diesel / Generator fan support No cross references from drawings that had'the design drawing to l-the field sketch (FSK), and vice-versa.
B.
Document-Control is bypassed in.the Bechtel field procedure for the
.centrol of mechanical redline drawings.
C.
Be~chtel: design drawings do not properly reflect applicable retired PCR's.
In addition, a file copy of an FCR was found to be lost.
D.
An' incomplete FCN was noted on drwing C-1004 for'an HVAC fan support.
5.
Field Inspections not adequate.
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, ".J.:-./h The examples given in item 2, above, are indications of inadequate field.7.- Q '
inspections.
"/.G. f4 6.
Design Controls are'not adequate - several examples were provided:
- a. 'A monorail in the Diesel / Generator Building was installed non-Q when it should have been Q.
An NCP. should have been written to document this.
b.
Field Sketches (FSK) were used for fan supports to design structural connections.'
c.
A Diesel / Generator Fxhaust pipe hanger was installed non-Q when it should have been Q.
i' -
j; The piping system is Q, however, the hanger is non-Q.
d.
The length of time for Specification Change Notices to come to the site, seemed to be excessive,' based upon an example noted.
The requirements for preheat 'of welding were questioned based upon our e.
example noted'in the. plant.
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-V USNRC EXIT MEETING NOVEMBER 29, 1982 Se 3 e ;;7 s.
- 7.
Receipt Inspections - endor wiring and termination deficiencies were found in Diesel / Generator control panels that been both receipt in.
_spected by Bechtel QC and overinspected by MPQAD.
In addition to the above items groupedf into generic categories, the NRC Inspectors
+
~
stated the~following, more specific, concerns:
1.
Dr. Landsman reviewed problems he had with Bechtel drawing C-45. 'Pottions of the baffle and perimeter dike should be Q, as should tie armour stone installation.
J. Mmney will.di=< >ss these items with Dr. Lancinnan for
-resolution.
r 2.
Mr. Barrett reviewed four items:
- Cable tray segregation procedures were reviewed based on example of a problem noted in the plant.
- Diesel / Generator air start lines inspection code requirements need to be traced back to the FSAR.
- Our requirements for the painting of welds outside the Cont =4==nt Build-ings need to be reviewed.
>h
- An area in the exterior wall of Containment. Building 1 was observed to have a small pocket of concrete removed by chipping.. Concern w pressed that the proper design and construction cont;rol were nas 'exf' ot in' place for tnis item.
C-J At the conclusion of the meeting, the Inspectors stated-that they needed addittrmal time T to assess the above findings in detail, and they had no coments on enforcement actid They also stated that many of the items were preliminary in nature. Mr. J. Cook stated that CPCo personnel would be. contacting the NRC Inspectors, prior to the finalization of their report, to provide additional information pertinent to the.
specific findings.
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NRC EXIT
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November 10, 1982 NAME ORGANIZATION
.B.H. Peck CPCo i Construc1; ion Supe.'
I R.M. Wheeler CPCo - Constructich ;
M.J.Schaeffer CPCo
.MPQAD.;s.
- m. -
Don S. Riat Bechtel - Reslilent Engineer..: /
Patrick Corcoran Bechtel*'ResidentErpject. Engineer L. H. Curtis Bechtel - Project Engineering. Manager E. H. Smith Bechtel Engineering Manager J. W. Cook CPCo - VP Projects, Eng. 4 Const.
D. B. Miller CPCo - Site Manager R. A. Wells
. Ex. Mgr. FPQAD M. A. Dietrich Bechtel QA/MPQAD E. C. Smith Bechtel PFQCE J. V. Gilmartin Bechtel PFE l
L. E. Davis Bechtel Site Manager T. C. Valenzano Bechtel Project Supt.
W. J. Friedrich INPO (MAC)
R. E. McCue
~
CPCo - TechMeni Supt.
Jim Copley INPO (MAC) l V. Solanki Bechtel QAE s
CPCO Construction
-/
G.:W. Rowe CPCo - QA - Nuclear Operations K. E. Marbaugh l
J. S. Kreple CPCo - Constnaction 1
l.
J. K. Meisenheimer CPCo - MPQAD Soils Supt.-
,V l
B._R. Kappel Bechtel - Resident QE G. L. Richardson Bechtel - Ass't to Proj. Manager.
E. L. Jones CPCo - Elect. and I6C Group Sup.-5IE8T l
L. R. Howell CPCo - MPQAD
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R. Landrnan R. Cook R. Warnick W. Shafer L'
R. Gardner P. Barrett B. Burgess MPQAD L. N. Howell c
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To DBMiller, Midland Plant m
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Consumers one November 29, 1982 power susscer MIDLAND PROJECT GWO 7020 USNRC EXIT MEETING
[o"Z%,ccc File: 0485.21 UFI:
99*04 Serial: CSC-6454 cc JWCook,- P26-336B REMcCue, Midland RAWells,MPQAD MLCurland,MPQAD JKMeisenheimer, MPQAD Civil This memorandum documents the NRC Exit Meeting held on November 10, 1982. A list of attendees is attached. These notes have been written in a general, narrative format. The detailed listing of specific items is being tracked in the NRC Open Items List that I am maintaining. Mr. R. Cook opened the meeting and acted as the lead NRC spokesperson. He stated that over the last four weeks, the inspectors have been concentrating on the Diesel / Generator Building.
Mr. R. Cook stated that the NRC Inspectors had grouped their collective findings into several catagories. These were then presented as follows:
1.
Material Traceability - Several examples were provided:
A.
'Ihe NRC has observed steel plates in the laydown area with no identify-ing markings. They questioned what was actually A-36 material.
B.
-Bechtel NCR 3266 was written to document material purchased from an un-approved vendor which was installed in the plant.
C.
Certain HVAC fan support 1" plates do not meet ASIM rolling steel toler-anCes.
D.
Bechtel specification C-233 permits the purchase of Q and non-Q materials.
E.
Indications of wrong material used in constn= tion were observed on HVAC l
fan support gusset plates.
l 2.
Plant not built according to design drawing - several examples were provided:
it A.
Certain HVAC fan supports.
B.
Three cable tray supports are not installed in accordance with design drawings. FCN's have been written to correct this problem.
C.
Several electrical conduit pull boxes do not confann to drawing E-42.
D.
Diesel / Generator Engine Control Panels - Missing foundation bolt-washers.
E.
Supports for Diesel / Generator Silencers do not look like the dexign drawings.
~
F.
In some cases, bolted connections are installed when welded
.. ections are specified.
c:
USNRC EXIT MEETING NOVEMBER 29, 1982 Page 2 3.
QC Inspector Records. Incorrect -
A.
Several QCIR's have been closed, stating that the item is installed.in ecordance with design drawings, when in fact it is not.
B.
The NRC expressed concern with the Bechtel Inprocess Inspection Notices (IPIN's) program. They felt that it did not properly docu-ment nonconformances or provide for timely inspections, and ic did not prevent further installation and use. Also, the IPIN is not
' properly addressed in the Trend Program.-
4.
Design Document Controls Inadequate - Several examples were provided:
A.
Diesel / Generator fan support No cross references from drawings that had the design drawing to the field sketch (FSK), and vice-versa.
B.
Document Control is bypassed in the Bechtel field procedure for the control of mechanical redline drawings.
C.
Bechtel design drawings do not ' properly reflect applicable retired FCR's.
In addition, a file copy of an FCR was found to be lost.
D.
An incomplete FCN was noted on drawing C-1004 for an HVAC fan support.
5.
Field Inspections not adequate.
' The examples given in item 2, above, are indications of inadequate field inspections.
6.
Design Controls are not adequate - several examples were provided:
A monorail in the Diesel / Generator Building was installed non-Q when a.
it should have been Q.
An NCR should have been written to document this, b.
Field Sketches (FSK) were used for fan supports to design structural connections.
I A Diesel / Generator Exhaust pipe hanger was installed non-Q when it c.
should have been Q.
l The piping system is Q, however, the hanger is non-Q.
d.
The length cf time for Specification Change Notices to come to the site, seemed to be excessive, based upon an example noted.
The requirements for preheat of welding were questioned based upon our l
e.
?
example noted in the plant.
j i
5-
- -USNRC EXIT MEETLNG NOVEMBER 29, 1982 Page 3 7.
Receipt Inspections - Vendor wiring and termination deficiencies were fourid in Diesel / Generator control panels that been both receipt in-spected by Bechtel QC and overinspected by MPQAD.
In addition to the above items grouped into generic categories, the*NRC' Inspectors stated the following, more specific, concerns:
1.
Dr. Tand==n reviewed problems he had with Bechtel drawing C-45.
Portions of the baffle and perimeter dike should be Q, as should the amour stone installation.
J. Iton'ey will discuss these items with Dr. Land:: nan for resolution.
j 2.
Mr. Barrett reviewed four items:
. Cable tray segregation procedures were reviewed based on example of a problem noted in the plant.
- Diesel / Generator air start lines inspection code requirements need to be traced back to the FSAR.
- Our requirements for the painting of welds outside the Containment Build-ings need to be reviewed.
- An area in the exterior wall of Containment Building 1 was observed to have a small pocket of concrete removed by chipping.
Concern was ex-pressed that the proper design and construction control 'were not in place for this item.
At the conclusion of the meeting, the Inspectors stated that they needed additional time to assess the above findings in detail, and,they had no comments on enforcement action.
/
They also stated that many of the items were preliminary in nature. Mr. J. Cook
- stated that CPCo personnel would be contacting the NRC Inspectors, prior to the finalization of their report, to provide additional infonnation pertinent to the specific findings.
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NRC EXIT l'
November 10, 1982 NAME ORGANIZATION B.H. Peck CPCo -i Construction Supt.
R.M. Wheeler CPCo - Constructi6n..
M.J.Schaeffer CPCo
.MPQAD Don S. Riat Bechtel - Re5ident. Engineer Patrick Corcoran Bechtel ' Resident Project Engineer L. H. Curtis Bechtel - Project Engineering Manager E. H. Smith Bechtel Engineering Manager J. W. Cook CPCo - VP Projects, Eng. 4 Const.
D. B. Miller CPCo - Site Manager R. A.' Wells Ex. Mgri MPQAD M. A. Dietrich Bechtel QA/MPQAD E. C. Smith Bechtel PFQCE J. V. Gilmartin Bechtel PFE L..E. Davis Bechtel Site Manager T. C. Valenzano Bechtel Project Supt.
W. J. Friedrich INPO (MAC)
R. E. McCue CPCo - Technical Supt.
V. Solanki Bechtel QAE G.:W. Rowe CPCO Construction K. E. Marbaugh CPCo - QA - Nuclear Operations J. S. Kreple CPCo - Construction J. K. Meisenheimer CPCo - MPQAD Soils Supt.
B. R. Kappel Bechtel - Resident QE l
G. L. Richardson Bechtel - Ass't to Proj. Manager E. L. Jones CPCo - Elect. and I5C Group Sup. IE61V L. R. Howell CPCo - MPQAD l.
USNRC 1
l R. Landsman l
R. Cook l;
R. Warnick
- i W. Shafer l
R. Gardner I'
P. Barrett i
i B. Burgess l'
MPQAD l!'
L. N. Howell l
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- Actionee is responsible for ' proposing subject file and correspondence legging for this document. Once correspondence logging has been completed, please
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return a copy of the completed routing slip along vi*.h a copy of the cover sheet from the document to P-24-517.
Draft Besponse Due KRR c.
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, see UNITED sTATIs
!p NUCLEAR REGULATORY COMMISSION i eg, e t
wasMNGTON. D. C. 20S45
d,' 7 NOV 101982 Docket Nos: 50-329 OM, OL and 50-330 OM, OL Dr. Paul Shewnon, Chairman Advisory Comittee on Reactor Safeguards U.S. Nuclear Regulatory Comission 1
Washington, D. C.
20555~
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Dear Dr. Shewnon:
Subject:
Report on Midland Design and Construction Problemis, Their Dispcsition, and Overall Effectiveness of the Effort to Assure Appropriate Quality i
The ACRS Interim Report on Midland Plant, Units 1 and 2 dated June 8,1982, requested, in part, "a report which discusses design and construction problems, their disposition, and the overall effectiveness of the effort to assure appro-priate quality."
Supplement No.1 to the Midland Safety Evaluation Report (SSER 1) replied.that Region III would prepare such a report addressing construction problems for the period from the beginning of construction through June 30, 1982. The enclosed report responds to that reply. SSER 1 also indicates that a final report on -
(
overall quality of plant construction will be issued for the remaining period
.following completion of construction.
In addition, the staff is curren'tly reviewing the several progra's proposed by m
the applicant to independently verify design and construction of the Midland Plant. - The results of this review will be addressed in a future supplanent to the SER.
l-Sincerely,
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- W N b W w Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: See next page
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y MIDLAND
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Mr. J. W. Cook Vice President.
Lee L. Bishop Consuners Power Company Harmon & Weiss 1945 West Parnall Road 1725 I Street, K.W., Suite 506 Jackson, Michigan 49201.
Washington, D. C.
20006 cc: Michael I. Miller Esq.
Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.
Division of Racielogical Health i
Alan 5. Farnell, Esq.
Department of' Fublic Health i;
Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza.
Lansing, Michigan 48909-51st floor Chicago, Illinois 60602 Mr. Steve Gadler n
2120 Carter Awwme 3
James E. Brunner Esq.
St. Paul, Minnesota 55108 Consuners Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan. 49201 Resident Inspe ors Office Route 7 Ms. Mary Sinclair Midland, Michigami 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stauriris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Per?y, Secretary Protection 01 vision Consumers Power Company 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 1
Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific storth West Labs (PNWL)
Battelle Blvd Mr. Roger W. Huston SI9tA IV Buildtag l
Suite 220 Richland, Washteston 99352 p
7910 Woodmont Avenue l
Bethesda, Maryland 20814 Mr. I. Charak, teenager NRC Assistance Project p
Mr. R. 8. Borsun Argonne National Laboratory K
Nuclear Power Generation Division 9700 South Cass Avenue Eabcock & Wilcox Argonne,1111 asis 60439 1
7910 Woodmont Avenue, Suite 220 Sethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III.
Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn Illinois 60137 l
Chicago, Illinois 60602 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way 124 Mcdonald Street P.O. Box 30221 t
Midland, Michigan 48640 Lansing, Michigan 48909
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.r, J. W. Cook w cc: Comander, Naval Surface Weapons Center ATTN:
P. C. Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atcenic Safety & Licensing Board -
U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan i '
Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos f
1017 Main Street Winchester.. Massachusetts 0189'i f
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4 Midland Nuclear Power Plant. Units 1 and 2 Docket No. 50-329 Docket No. 50-330 i
1 4
i-REPORT ON DESIGN AND CONSTRUCTION PROBLEMS FOR PSICD FRCM START OF CONSTRUCTION THROUGH JUNE 30, 1982 I
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i Report Requested by Advisory Committee on Reactor Safeguards l*
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Introduction The following report prepared by the NRC, through its Region III office, discusses Hidland 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 to commitments made in Supplement No.1 of the Safety Evaluation Report.
The report covers the period starting with the beg *4 of construc-tion up to June 30, 1982. A final report will be issued on the above subjects for the period from July 1,1982 through the completion of i
construttion discussing the overall quality of plant canstruction.
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II. Sw::marv and Conclusions of Overall Effectiveness Since the start of construction Midland has experienned some signifi-cant problems resulting in enforcement action (enforcement sta-istics are summarized in Table 1). Following the ideatification of each of these problems, the licensee has taken action to correct the problems i
and to upgrade the QA program and QA/QC staff. The most prominent action has been an overview program which has been steadily expanded i'
to cover safety related activities. In spite of the corrective
- i actions taken, the licensee continues to experience ;
- roblems in the h'g implementation of quality in construction.
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- j-Significant construction problems identified to date include
- (1)
't rebarj'h;.,{,['
1973 - cadweld splicing deficiencies (P.aragraph C.2); (2) 1976 -
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omissions (Paragraph F.3); (3) 1977 tiulge _'_is'the t': nit 2 Containment.
(Para-f.g,N,C I,iner Plate (Paragraph G.3); (4) 1977 - tendon sheath Theation drors gk h..
(Paragraph G.4); (5) 1978 - Diesel Generator Building settlement graph N.10); (6) 1980 - allegations pertaining to Zack Company heating,
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(7) 1980 - reactor pressure vessel anchor stud failures (Paragraph J.8);
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ventilating..and air conditioning (NVAC) deficiencies (Paragraph J.7);
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(8) 1981 - piping suspension system installation deficiencies (Paragraph K.4); and (9) 1982 - electrical cable misf=stallations (Paragraph I. 2).
j-Consumers Power has on repeated occasions not reviet.ed pr:blens to the depth required for full and timely resolution. Imamples are:
(1) robar omissions (1976); (2) tendon sheath locatian errors (1977);
(3) Diesel Generator Building settlement (1978); and (4) Zack Company HVAC deficiencies (1980). In each of these cases the NRC, in its investigation, has determined that the problem was of greater significance than first reported or that the problem seas more generic
,i than identified by Consumers Power Company.
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The Region III inspection staff believes probless have kept recurring at 7,J.3 b -
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(1) Overreliance um the architect-i I'
engineer, (2) failure to recognize and correct root cansas, (3) failure g3 l ge 70 to recognize the significance of isolated events (4) failure to review isolated events for their generic application, and (3) lack of an ye d'g l :'
aggressive quality assurance attitude.
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A history of the Midland design and constructie= problems and their t '.
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disposition, as identified and described in NRC inspection reports, g:.
is contained in the fo11owing section (zzz). rhis at.=ory is for the period from the beginning of construction through aune 30, 1982.
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III. Design a.d C=nstrue:fon problems As Docume.ted in NTC hsoee: ion Rece-s A.
1970 Six inspection reports were issued in 1970. In July 1970, construction activities authorized by the Midla=d Construction Pernit E=esption commenced. A total of four ite==s of noncom-pliance were identified in 1970. Rose items are dese:1 bed below:
1
. Tour items of.nonconformance were identified in, Inspection Report Nes. 30-329/70-06 and 30-330/70-06 concer:ing.^._e installation 'of concrete. The nonconformances regarded:
(1) c== crete placement activities violated ACI Code; (2) labora =ry sc= perferning tests per PSAR; (3) sampling not per ASTM; and (') QL/QC personnel did il' not act on deviations when identified. I.icensee corrective actions included:
(1) Bechtel to provide a re, attesting to Mplf the Auxiliary Building base slah where lack of c=n:solidation was apparent; (2) a commitment to perform tests at fS equencies specified in the PSAR; and (3) a concitment to== sin workers and gT3K,.,(
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8 the inspection staff. This satser was discussed during the Construction Permit Hearings and is considered c2csed.
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1971-1972
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Three inspections were conducted during this pW. No items p,1.;. ' *l[$ ' j 1 -
of noncompliance were identified. Midland cons==uction activities 4
l were suspended pending the pre-const.uction pe---* hearings.
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On December 13, 1972, the Midland Construction furnit was issued.
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1973
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Eleven inspection reports' vere issued in 1973 af which two per-
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tained to special management meetings, two to vendo: inspections,*.?
[f one to an audit of the architect engineer, and six to onsite 1
)]M inspections. A total of six items of noncomplia'*ee were M
identified during 1973. One significant construm= ion probles was identified involving deficiencies in cadweld splining of rebar
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(see Paragraph 2). These items / problems are described below:
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Noncompliances involving two separate Appeculix B criteria jf with five different examples were identified during a
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special audit of the architect engineer.'s Quality Assuranc WO i
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Program. The noncompliances were documented in Inspection jo J. c Tseport Nos. 30-329/73-08 and 50-330/73-08. The items of f[j*f, y
.t noncompliance regarded:
(1) inadequate requirements for j;
quality record retentipn; (2) inadequate drawing control; t.
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(3) inadequate procedures; and (4) stapproved specificaricas 9
used for vendor control. Licensee correc=ive actions 1sf '.
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included: '(1) revision of Bechtel Nuc. lear Quality As raF.se ps' f
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al; Manual; (2) revision of Midland in ernal Procedures j
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(3) personnel instructed to audit the status of :
v, h. ed 'g stick files weekly; (4) project administrator ass:g::ed the
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. responsibility for maintenancs of master stick file; and (5) project engineer and staff to perform r.csthly 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.he identified
-violations.
2.
One significant construction probles was identified during s1973. ' It involved cadwald splicing deficia::Les and resulted in the issuance of a Show Cause Order. De a.ils are as follows:
A routine sinspection, conducted on November 6-8, 1973, identified eleven examples of four noncompliance items relative to rebar caduelding operations. n e noncompliances 1 f-care documented in Inspection Report Nos. ' 50-32f/73-10 and 330/73-10, These items were summarized as:
(1) untrained cadweld inspectors; (2)f rejectable cadwelds accepted by QC inspectors; (3); records iaadequate to establish cadwalds met requirements; and (4) inadequate procedures.
9 As a' result, the licensee, stopped work on cads. eld operations on November 9f,1973, which in a stopped robar installation and concrete placeaant scark. The licensee agreed not to rssume work until the NRC reviewed and accepted their corrective action. A 51:os: Cause Order was issued'en December 3,1973, formally suspending cad-welding operaticas. On December 6-7, 1973, Region III and Headquarters personnel canducted a special' inspection and dete71ned that construe: ion activities cocid be resumed in a manner consistent with quality criteria. I.icensee corree-tive actions included: (1) the revision of the 3echtel '
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g,7 3'0-specification to reflect requalification requirements; (2) m de_velopment of instructions requiring that work specifications be reviewed prior to Class 1 work; (3) the estabitshment of gA p 8,9 provisions for Consumers Power QA raview of work procedures; is jo pf, and (4) the establishment of procedures for the audit of f
Class 1 work.
O The show Cause Order was modified on December 17, 1973 allowing resumption of cadwelding operatio=s based on inspection results. The licenses answered.he Show Cause
' Order on December 29. 1973 committing to. revise and improve the 'QA manuals and procedures and make QA/;C persensel changes.
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, On Se;>tember 25, 1974, the Hearing Board found that the licensee was imp.lementing 'its QA program in co=pliance with '
regulations and that construction should no: be stopped.
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1974 q
s ih Eleven inspection repotts were issued in 1974 of which one h
pertained to a vendor inspection, one to an inspec:fon at the L
licensee's corporate offices, and nine to onsite Anspectior s.
l 2:ee items of concompliance vers identified duri=g 1974 l
These items are described below:
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One noncompliance was identified in Inspec ica Report No. 50-329/74-01 and 50-330/74-01 concerni=g the use of
~ unapproved procedures during the preparation of containmen:
building liner plates.for erection. Licensee corrective l
actions included:
(1) intensive review of liner plate
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records for accuracy; (2) issuance of nonc=nformance repon; F
(3) requirami a imposed that unapproved copies of procedures l
transmitted to the site be marked " advance copy;" and (4) identification of procedure approval s.atus. The
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licensee's actions in regards to this matter were reviewed
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and the noncompliance closed by the NRC as documented in Inspection Report Nos. 50-329/74-01 and 50-330/74-01.
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2.
One noncompliance was identified in Inspec_ ion Report l
Nos. 50-329/74-04 and 50-330/74-04, concer d g the use of a weld method which was not part of the applinable veld pro-cadure. Licensee corrective actions included:
(1) issuance
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of a nonconformance report; (2) repair of subject welds; p
(3) reinstruction of welders; and (4) increased surveillance j ~,
of containment liner plate field fabrications. The licensee's actions in regards to this nat-e= were reviewed ll and the noncompliance closed by the NRC as documented in jl Inspectiot Report Nos.. 50-329/74-04 and 50-330/74-04 f
3.
One noncompliance was identified in Inspecadon Report l-Nos. 50-329/74-11 and 50-330/74-11 concer d g the failure of QC inspections to identify nonconforming rebar spacing.
l.
Thir violation is discussed further in the 1976 section of
.his report, Paragraph T.S.
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1975 l.
Seven inspection reports were issued in 1975 of which one l;
pertained to a meeting in Region III, one to an inspection.at l.
the licensee's corporate offices", and five to casite inspection.
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' No noncompliances were identified in 1975, however, the licensee in.! arch and August of 1975 identified additional rebar deviations and omissions. This matter is further discussed in the 1976 section of this report, Paragraph T.S.
.T.
1976 Nine ' inspection reports were issued in 1976 pe== mining to nine onsite inspections. A total of seventeen items of noncompliance were identified during 1976. One significant co=struction problem was identifisd involving rebar omissions / placement errors and the issuance of a Headquarters liotice 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 30-330/76-01. These items regarded:
(1) inadequate concrete oven ta=perature controls; (2) no oessures to control nonconforming aggre-gate; and (3) failure to dispose of nonconfor=ing aggregate as required. I.icensee corrective actions included:
i '
(1) implementing a requirement for the reverification of oven temperature controls every three months; (2) removal of nonconforming aggregate from the batch plant area; (3) modification of subcontractor's QA manual; and (4) training of subcontractor's personnel to the revised QA manual. The corrective actions i=pleme=:ed by the
.i licensee in regards to these noncompliances were subse-quently reviewed and the items closed by the NRC as e
documented in Inspection Report Nos. 50-329/7c-02 and 50-330/76-02.
2.
Two items of noncompliance were identified in Inspection 4
Report Nos. 50-329/76-02 and 50-330/76-02. These items regarded:
(1) the Vice President of Engineering Inspection did not audit test reporta as required; and (2) corrective actions required by audit findings had not been performed.
. Corrective actions taken by the licensee innluded revising the U.S. Testing QA manual. The licensee's corrective actions taken in regards to these matters sure subsequently-reviewed and the itens 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 i.
approval of field engineering procedures. and instructions; (2) inadequate documentation of concrete feza' work deficiencies; and (3) inadequate control of site storage of post tension embedsents. I.icensee corrective actions included:
(1) revision of the Bechtel Nuclear QA manual; j
(2) revision of Bechtel field procedure for " Initiating and Processing Field Procedures and Instrucnions;"
(3) initiation of Bechtel Discrepancy Repe=s; (4) training sessions for Eachtel 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.
f 4
Two itant, of' noncompliance were identified in Inspection Repor Nos. 50-329/76-09 and 30-330/76-09. These itaas regarded:
(1) noncompliance report not written to identify broken reinforcing steel; and (2) hold denen studs for the I?
reactor vessel skirt were no: protected. I.icensee corrective l-actions included:
(1) inspection of all rebar dowels; (2) it initiation of new field procedure; and (3) initiation of nov 6
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_ procedure for inspecting reactor vessel a=d steen generater anchor bolts. The licensee's c:rrective actions in regards to these itans were subsequsatly reviewed and the itens closed by the NRC as documented in Inspection Report s
Nos. 50-329/77-01 and 50-330/77-01.
5.
One significant construction problem was identified during 1976.
It involved reber omissions / placement errors and the
+
j issuance of a Headqt erters Notice of Violation. Details are
.1 as iollows:
m During an NRC inspection conducted in Deca =ber 1974 the licensee informed the inspector that an audit had ide'ntified robar spacing problems in the Unit 2 contaimment. The failurs of QC inspectcrs to identify the nocconforming rebar spacing was identified in the 1974 NRC inspection report as an item of noncompliance.
(See the 1974 section of this report, Paragraph D.3.)
This satter was subsequently reported by the licensee as required by 10 CTR 50.55(e).
- r Additional robar deviations and omissions more identified in March and August 1975 and in April, Mar and June 1976.
Five items of noncompliance regarding re -*-coment steel d
deficiencies were identified in Inspection Report '
1 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 devels; (2) na=conformance reports concerning reinforcement steel deficiencies were
!I not adequately evaluated; (3) inadequate i=spections of
- j.
reinforcement steel; (4)-inadequate evaluations of a i
nonconformance report probles relative to ID CTR 50.55(e) reportability requirements; and (5) results of reviews, interim inspections, and monitoring of rei=forcement steel li installations were not documented.
l..
The licensee's response, dated June 18, 1976, listed 21 i,
separate items (commitments) for correctiven actions. A June 24, 1976 letter from the licenses prourided a plan of action schedule for implementing the 22 Atems. The licenses suspended concrete placement work m:11 the items address nd in the licensee's June 2!. letter were resolved or implemented. This commitment was documented in a Reston III Immediate Action Letter (IAL) to the licensee, dated June 25,
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1976.
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Rebar installation and concrete placement activities were l;
resumed in early July,:1976 following satisfactory completion ll of the corrective actions and verification by Region III as p
documented 'in Inspection Repor Nos. 50-329/76-05 and 50-330/76-05.
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A subsequent inspection to followup on reinforcing steel placement problems identified two noncompliances. These noncompliances are documented in Inspection Repor:
Nos. 50-329/76-07 and 50-330/76-07. The ac=co=pliances regarded:
(1) failurs to follow procedures; and (2) in-adequate Bechtel inspections of robar installations. The
' inspection report documents licensee corree ive actions which included: (1) removal of cognizant field engineer and laad 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 1: ems were reviewed and the items closed by the b"dC 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 Neadquarters Notice of Violation was issued on August 13, 1976.
. Additional actions taken by the licensee in=1uded the es:ablishment of an overview inspection program to provide 100% reinspection of embedments by the lice =see following acceptance by the contractor Quality Control personnel.
Additional actions taken by the contractor included:
(1) per-sonnel changes and retraining of personnel; (2) preparation of l
a technical evaluation for the acceptability of each identified construction deficiency; and (3) improvement in the QA/QC program coverage of civil work.
G.
1977 Twelve inspections pertaining to Unit 1 and fifteen inspections pertaining-to Unit 2 were conducted in 1977. Tan items of non-compliance were identified during 1977. Two sig=ificant construction probless were identifed involving as bulgt in the l
Unit 2 containment liner plate (see Paragraph 3) and errors in
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the placement of tendon sheathings (see Paragraph 4).
These items / problems are described below:
l*
l 1.
Five examples of noncompliance with Criteri=u V of l !-
10 CTR 50, Appendix B, were identified in I=spection Report Nos. 50-329/77-05 and 50-330/77-08. The examples of noncompliance regarded:
(1) inadequate =learance 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 for trends; and i.
(5) inadequase tagging of defec ive measuring equipment.
Licensee corrective acticas included:
(1) :larification of 8
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design and acceptance criteria contained in partiass:
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- specifications; (2) modification rad review of Quality Control Ins::uctions; (3) issuance of two field procedures relative to field sodifications of piping hanger drawings; (4) staffing of additional QA personnel at the site; (5) closer managsment attention; and (6) additional training 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 0 7-11, 50-329/78-01, and 50-330/78-01.
ll 2.
Three items of noncompliance were' identified in Inspection
'l Report Nos. 50-329/77-09 and 50-330/77-12. The itens re-7j.
garded:
(1) failure to follow audit proced=res; (2) failure to qualify stud welding procedures; and (3) inadequate welding inspection criteria. Licenses cor:ective actions included:
(1) administrative instruction issued to require the audit manager to obtain a semi-mon:hly audit findings status report from the project manager; (2) administ:stive 14 instruction issued for the close out and fo21ovup of internal corrective action requests; (3) revision of Quality Control Instruction; (4) special i=spections and audit; and (5) prescribing specific accep a=ce criteria.
The licensee's actions in regard to these i.ames were sub-sequently reviewed and the items closed by ::he h'RC as documented in Inspection Report Nos. 50-32998-01, 5,0-330/78-01, 50-329/78-05, and 50-330/78-C5.
3.
A significant construction problem involvi=g a bulge in -
the Unit. 2 containment liner plate was ide==1fi-d in 1977.
Details of the liner plate bulge follow:
.\\
The initial identification by the licensee af a bulge in the Unit 2 liner plate occurred on February 26, 1977. The' J
liner plate bulge occurred between column Ihme azimuths 250 degrees and 270 degrees and between elews ions 593 and 700. Inspection Report No. 50-330/77-02 decuments a
~
special inspection concerning the liner pis== bulge. This report further identifies an item of noncompliance relative to the failure of the licensee to report the bulge deficiency E
pursuant to the requirements of 10 CTR 50.15(e). The licensee's corrective actions in regard to this itse were reviewed and the ites closed by the NRC, as documented in inspection Report No. 50-330/77-14
' The cause of the liner plate bulge was dete= mined to be due to a leaking 2 inch water line installed in the con-tainment concrete as a: construction convenience. It was theorized that the water line froze, started to leak, allowing water to seep behind the liner. The water line was' supplied by a construction water pump. hat was set to cycis between '100 ar.d 130 p51. This pressure was censidered.
to be sufficient to cause the liner plate bulge.
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A meeting was held on April 4, 1977 at the A=n Arbor, Michigan Office of Bechtel to review the original design and construction concept of the containmen: liner, the procedures and actions taken during the rs= oval of bulge af f ected zones, the investiga-ion activities and results, and to ascertain the concepts involved in -de 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 foct lift of replacemen: liner plate installed. The completion of repair and the repair records were subsequently reviewed as documented in inspection Report No. 50-330f79-25.
4.
A second significant construction problem involved tendon sheath placement errors and resulted in an Immediate Action Letter (IAL). Details are as follows:
r The licensee reported, on April 19, 1977 T.he discovery of o
an error in the 1.' nit 1 containment building which resulted in two tendon sheathings (H32-036 and H13-C36) being mis-placed, and two tendon sheathings (H32-037 and H13-037) being omitted. As shown on pertinent vendor drau:f.ngs, these four
- tendons were to be deflected downward to clear the two' main steam penetrations at center line elevation 707' 0".
Concrete had been placed to a constructicut joint at elevation 703' 7" approximately one week before these tendon deficiencies I
were discovered.
Corrective actions resulted in the rerouting of tendon sheathing 2
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.
i.
The tendon sheath placement errorsi and the past history of rebar,
l.
placement errors indicated the need for fder NRC evaluation of the licensee's QA/QC program. As a resu1=, an IAI, was issued to the licensee on April 29, 1977. Licensee commitnants addressed 3
L:
by this IAL included: -(1) NRC notificatim prior to repairs or l
modifications involving the placement of cancrete in the area of the misplaced and omitted tendon sheaths; (2) identification of l4 the cause of the tendon sheath deficiencies and implementation of required corrective action; (3) expansion of the licensee's
'QC overview program; -(4) NRC notification of all embedmen:
placement errors identified after QC acceptance; (5) review and revision of QC inspection procedures; and (6) training of construction and inspection personnel.
10
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A special QA program ' inspection was conducted in.May 1977 as
, documented in Inspection Report Nos. 30-329/77-05 and 50-330/77-08. The inspection team was nada p of personnel from Region I, Region III, and Headquarters.
It was the con-sensus of opinion of the inspectors that the 2icensee's program was acceptable.
The licensee issued the final 50.55(e) repce: on this matter on August 12, 1977. Final onsite review was condue:ed and documented in Inspection Report Nos. 50-329j77-08 and
,{
50-329/79-15.
N.
1978 Twenty-two inspections and one investigation we:m conducted during i
'I-1978. A total of fourteen items of noncompliance were identified in 1978. One significant construction problem was adantified involving excessive se::lement of the Diesel Generator B"" g f undation (see Paragraph 10). These itema/ problems are described below:
w 1.
Three items of noncompliance were identified in Inspection Report Nos. 50-329/78-03 and 50-330/78-03. Dese item's regarded:
(1) inadequate inspections of we2ds on cable tray j.
supports; (2) inadequate control of welding altage,and amperage as required by AWS; and (3) i=adeq=sse documentation
~
of repairs on purchased equipment. Licensee.cc.rective actions included:
(1) additional training given Qum2.1 y Control Engineers and craft welders; (2) revision of pertinent technical specifications and weld acceptance requirecuu::s; (3) revision of welding procedures; (4) revisions of vendor. QA manual; and
- 3 (5) reinspections and engineering evaluatic=s. The licensee actions in regard to these items were subsesi;sently reviewed and the items closed by the NRC as' documented in Inspection Report J
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,. mzd 30-330/79-22.
a 2.
TVo items of noncompliance were identified in Inspection p
Report Nos. 50-329/7b o5 and 50-330/78-05. Dese items regarded:
(1) inadequate control of welding filler material; i
p>
and (2)' inadequate protection of spool pieces. Licensee cc :ective actions included:
(1) additional instructions
. given to welding personnel; (2) generation of nonconf=rance report to require Rechte'l to perform a tho=wagh inspectio.1
(
of the f acility, correct and document discrepancies noted, and instrue: craft personnel. ' The licensee actions in i,
regard to these items were subsequently reviewed and the items closed by the NRC as documented in I=spection Report Nos. 50-329/78-05, 50-330/78-05, 50-329/79-22, and 50-330/79-22.
L
[L 3.
Two examples of noncompliance with cne 10 CTR 50 Appendix 3 criterion were identified in Inspection Repor Nos. 50-329/78-07 and 50-330/78-07. These exa. ples regarded:
(1) inadequate ~
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coEtrol of drawings; and (2) inadequate drawing control pro-cadures. Licenses corrective actions included:
(1) Zack and 3echtel revised drawing control procedures; and (2) extensive audits of d:aving controls. The licensee acticns in regard to these items vers subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 30-329/79-25 and 50-330/79-25.
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4 One ites of noncompliance was ~ identified in Inspection
- Report No. 50-330/78-09 concerning inadeques backing gas O
flow rate during velding operations. Licensee corrective l-ac: ions included:
(1) revision of Bechtel welding pro-cedure specifications; (2) revision of Bechtel Quality Control Instruction; and (3) additional trM-+g for all welding Quality Control Engineers. The licensee's actions i;
' in regard to this ites were subsequently reviewed and the
.i
~
ites closed by the NRC as documented in Inspection Repor:
No. 50-330/78-16.
5.
Two items of noncompliance were identified in Inrpection
!s Report Nos. 50-329/78-13 and 50-330/78-13. The items
+1 regarded:
(1) inadequate inspection of weld jci:ts; and (2) inadequate storage of Class 1E equipmen:. Licenses corrective actions included: (1) revision of welding
- specifications; (2) additional -instructions to Q2 in-spectors; (3) additional overinspections; (t.) upgrade of administrative procedures; nd (5) actions _s bring storage environment within controlled specifications. The j;
licensee's actions in regard to these isees ver,e reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/78-13 and 50-330/78-13.
6.
Two items of noncompliance were identified in' Inspection l'
Report Nos. 50-329/78-15 and 50-330/78-15. These items regarded:
(1) nonconforming welds on Main Steam Isolation Valve support structures; and (2) inadequate corrective action taken to repair nonconforming Nelson Stud weld attachments. Licenses cc rective actions inc2nded:
(1) respo.--ible welding Quality Control Engineer requirsd to attend training course; (2) defective velds reworked; l.
and. (3) engineering evaluation. The licensee's actions in regard tc these items were subsequently reviewed and the itees closed by the NRC as documented i= Inspection l
Report Nos. 50-329/79-22, 30-330/79-22. 50-329/79-25 and 30-330/79-25.
3 i
7.
One deviation was identified in Inspection Report l'
No. 50-330/78-16 concerning the failure to meet ASME code requirements for nuclear piping. Licensee corrective actions included the determina: ion that the impact :ss: values of the pipe sacerial in question met the code requireme::s, and the t;T thickness measurements made by ITT Grinnell were in error and 12 i
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e voided by measurements made by Bechtel. The licensee's actions
, in regard to this item were subsequen-ly reviewed and the iten closed by the NRC as documented in Inspectica Report No. 50-330/79-24.
8.
One item of noncompliance was identified in Inspection Report Nos. 50-329/78-17 and 50-330/78-17 rsgarding the failure to follow weld procedures pertaining to the repair I
welding of cracked welds on the personnel ad locks. The 4 ;
licensee's corrective actions included steps to revise
~
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' affected drawings and to update the stress analysis report U
for the. air locks. The corrective actions taken by the licensee will be reviewed during future NRC inspections.
9.
. One ites of non.:ompliance was identified in Inspection Report C
Nos. 50-329/78-22 and,50-330/78-22 concerning the failure to perform specified maintenance and inspection activities on Auxiliary Teed Pumps. I.icensee corrective actions included:
J,1.
(1) training of pertinent Quality Control engineers; (2) transition of personnel in QC department relative to storage and-asintenance activities; and (3) i=spections and 4
evaluations of omitted maintenance. The lizensee's actions in regard to this ites were subsequently reviewed and the item closed by the NRC as documented in Inspection R,eport Nos. 50-329/78-22 and 50-330/78-22.
~
7 'hI 10.
One significant construction problem was idamtified during I
a 1978. It involved excessive settlement of.he Diesel
,h' Generator Building foundation. Details are as follows:
()O 4.*. ;'
i The' licensee informed the Region III office on September 8. - h.,.Jf'.,
1978, per requirements of 10 CTK 50.55(e), that settlement
)'
- g.c, yM of the Diesel Generator foundations and st=nctures was greate than expected.
j'
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Till satorial in this area was placed between 1975 and 1hf 77,8 [
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with construction starting on the diesel generator building in N
J mid-1977. Reviou of the results of the Regian III investi8a-p/ (p, I
I tion / inspection into the plant fill / Diesel Generator building M
settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee 6 the pending probles. These events included non-conformance reports, audit findings, field menos to engineering, 1hj. and problems with the administration building fill which caused i:
[
modification and replacement of the already poured footing and
' p replacement of the fill natorial with lean concrete.
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7 Causes of the excessive settlement included:
(1) inadequate placement method - unqualified compaction equipment and t;
i
_0'@' ~" O vg, Xdxcessive li! thickness; (2) inadequa a testing of the soil t'
[,, ',.'i' material; (3) inadequate QC inspection pro unqualified Quality Control inspectors and field engineers; s
and (5) over:eliance on inadequate test results.
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Lead technical responsibility and program reciou for this issue
. was transferred to NRR f:om IE by memo, dated November 17, 1975.
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 licenses to provide an independent evaluation and provide recommendations concerning the soll conditions existing under the Diesel Generator building.
As previously stated, an investigation was initiated in December.1978 by the NRC to obtain informatdan relating to design and construction activities affecti=3 the Diesel Generator Building foundation and the activities involved in the identification and reporting of unusual settlement of the building. h results of the investigation and additional l
developments in regard to this matter are discussed in the l
1979 section of this report, Paragraph I.11.
l I.
1979 l;
Thirty inspection reports were issued in 1979 of which one pertained l
to an onsite management meeting, two to investign= dons, 'one to a vendor inspection, one to a meeting in Region III, and twenty-five to onsite inspections. A totsi of seventeen items of noncompliance l
were identified in 1979. These items are described below:
l l
1.
One ites of noncompliance was identified in Inspection Report Nos. 50-329/79-10 and 50-330/79-10 concerni=g inadequate sessures to assure that the design basis was included in drawings and specifications. Licensee corrective actions included:
(1) revision to Midland TSAR: and (2) revision to pertinent specification. The licensee's ac dans in regard to this ites were subsequently reviewed and the ites 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 j.
Report Nos. 50-329/79-12 and 50-330/79-12. The items were:
(1) inadequate corrective action in regard to drawing controls; (2) discrepancy in Zack Velding Procedure j
Specification; and (3) inadequate control.of purchased satorial. Licensee corrective actions included:
(1) audit of-drawing control prog:am; (2) revision to drawing control requirements; (3) revision of Zack Valding Procedure Speci,
fication: (a) review of other Zack procedures; (3) missing data added to documentation packages: and (6) audits of other i:
documentation packages, The actions taken by the licensee were subsequently reviewed and the items closed by tha NRC as documented in inspection Report Nos.30-329 /$1-01, 30-330/61-01, 30-329/80-15, 30-330/80-16, 50-329/79-22, a=d 50-330/79-22.
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- s 3.
One item of n=ncompliance was identified in 2nspection
. Repers No. 50-330/79-13 concerning the fail::re to inspect all joints and connections on the Incore Instrument Tank as prescribed in the hydrostatic tes: procedn=e. Licensee i
corrective actions included a supplemental test of the Incore Instrument Tank and the initiation of a supplemental 2
test report. The licensee's acticas in regards to this satser were subsequently reviwod and the items closed by the NRC as documented in Inspectica Report No. 50-330/80-38.
[
- 4.
One ites of noncompliance was identified in Inspection Report No. 50-330/79-14.concerning the use of a vad of paper in making a purge das during welding activities.
Licensee corrective actions included:
(1) revision of pertinent procedures; (2) revision of pertinent Quality 1
i Control inspection checklist; and (3) ::aining sessions for welders and Quality Control inspectors. The licensee's actions in regards to this matter were subsequently reviewed and the ites closed by the NRC as doen=ented da Inspectior.
Report No. 50-330/80-16.
5.
One ites of noncompliance was identified in Inspection Report Nos. 50-329/79-18 and 50-330/79-18 c=ncerning inadequate controls to protect sa:erials and equipment from velding activities, Licensee entracsim actions
+
included training sessions for cognizant Tia2d Insineers, Superintendants, General Teresen and Toremen. The licensee's actions *in regards to this matter were subsagnently reviewed and the ites closed by the NRC as documented in Inspection Report Nos. 30429/80-15 and 50-330/80-16.
6.
Two items of noncompliance were identified da Inspection Report Nos. 50-329/79-19 and 50-3,30/79-19. ":hese items i
regarded:
(1) failure to ensure that approp= tate 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 required. Licenses corrective actions included:
(1) revision of pertinent specification; (2) examination given to Level I and Level II inspector; and (3) reinspectica: cf selected tendons. The licensee's actions in regards o these items were subsequently reviewed and the items closed by the NRC j.
as documented in-Inspection Repen Ncs. 50-330/80-09 50-329/80-04 and 50-330/80-04 7.
One ites of noncompliance was identified in Inspection l
Report Nos. 50-329/79-20 and 50-330/79-20 concerning inadequate controls for welding activities pertaining to l
4.16 YN switchgear. Licensee corrective actions included:
(1) correction of relevant records; (2) additional training for Quality Cont:31 Insineers; and (3) additdonal training.
for the Quality Control Document Ccerdinator. The licensee's actions were subsequently reviewed e.d the ites closed by the NRC as documented in Inspection Reper: Ncs. 50-329/80-15 and 50-330/80-16.
15
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8.
One item of noncompliance was identified in inspection Report No. 50-330/79-22 concerning inadequa:e veld rod controls. Licensee corrective actions included a training session for cognizant velding personnel. The actions taken 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.
't J
l 9.
One item of noncompliance was identified in Inspection Report Nos. 50-329/79-26 and 50-330/79-26 concerning failure to follow procedures relative to the shipment of auxiliary i
feed water pu ps to the site with nonconfo+g oil coolers.
Licensee corrective actions included:
(1) reinstruction t
given to cognizant engineer; and (2) Supplied Deviation
' i Disposition Request (SDDR) generated by the vendor. The licensee's actions in regards to this matta= were reviewed and the ites closed by the NRC as documented da Inspection Report Nos. 50-329/79-26 and 50-330/79-26.
- 10. One item of noncompliance was identified in Inspection Report Nos. 50-329/79-27 and 50-330/79-27 cancerning the violation of QC Hold Tags. Licensee correc=ive actions included:
(1) a training session for Const=sesion Super-visors and Field Engineers; and (2) a Field Instruction on Quality Control Hold Tags was issued. 'Ihe licensee's actions in regards to this satser were subsequently reviewed and the item closed by the NRO as documented in Inspection Report Nos. 50-329/81-04 and 50-330/81-04.
i
- 11. As a follovup to the significant construction probles identified in 1978 (see Paragraph H.10), an investigation was initiated in December,1978 to obtain information i
relating to design and construction activities affecting the Diesel Generator Building foundations and the activities
{
involved in the identification and eporting of unusual i
settlement of the building. The investigation findings were documented in Inspection Report Nos. 50-329/78-20 and 50-330/78-20, dated Marc.h 22, 1979. Information obtained during this investigation indicated:
(1) a lack of control j,
and supervision of plant fill activities emntributed to the 4
inadequate compaction of foundation material; (2) corrective ac-ion 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 specificatians related to 1
},
foundation type, satorial properties, and compaction requirements were not followed; (4) there was a lack of clear direction and support between the contractor's i
engineering office and construction site personnel; and (5) the TSAR contained inconsistent, incorrect and unsup-ported statsoents with respect to foundatica type, soil properties, and set-lemen' values. Nine examples of l.
noncompliance involving four different 10 CFR 50, Appendix 3 criteria were identified in the subject i=spection report.
16
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i, Meetings were held on Tehruary 23, 1979 and March 5,1979 at the NRC Region III office to discuss the circ.:.mstances associated with the settlement of the Diesel Generator Building at the Midland facility. The NRC s aff 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 and other stru=sures located in and on the plant area fill. In addition, the staff expressed
'l l ),
I concern with the Consumers Power Company Q=ality Assurance
? b.'
Program. Under the authority of Section 152 of the Atomic.
I' 'p' y Energy Act of 1954, as amended, and Section 30.54(f) of r) h 6-e
[
10 CTR Part 50, additional information was _equested s
e regarding the adequacy of the fill and the gnality assurance
,?
. V' 0 program for the Midland site in order for the Co= mission to g-determine whether. enforcement action such as license modifi-m'.* / /p
\\.,f A
cation, suspension er revocation should be aken. Question 1 s'*
I of the 50.54(f) letter dated March 21, 1979 requested
)
inforsation regarding the quality assurance program. On g ig /@
e April 24, 1979, Consumers Power Company suta=itted the initi 7
response to the 50.54(f) request, Questions 1 through 22.,
a result of the NRC staff review of Questian 2, the NRC h i
j6[d
~ concluded that the information provided was not sufficient f r )g 6 a complete review. Subsequently, on September 11, 1979, the
{
NRC issued a request for additional quality assurance info:ma-1. G gh' C
tion (Question 23). On November 13, 1979, consumers Power Company submitted Revision 4 to the 30.54(f) responses which,.,
e I
i included response to Question 23. As a result of the
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Region III investigation report and CPCo responses, the NRC/ g issued an Order modifying construction Perm 1=s No. CPPR-81, e i. re
. k ', 'Y, n
.s.
i, and No. CP'R-82, dated December 6, 1979. This order
(') * *,.
prohibited further soils related activities antil the
~
approval'of the Remedial Soils work with the provision that *[M
.P submission of an admendment to the application seeking
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.e 5
d the order would not become effective in the event that the Due to the licensee's decisionOt l"(.O i
1 licensee requested a hear'ing.
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to request a he'aring this order forms the basis for the i,..
.ngoing is a no.rtngs.
During 1979, the licensee continued soil baring operations in order to identify and develop the qual 1=y of material in the plant ar,ea fill and beneath safety relszed structures.
l.
The licensee completed a program regarding the appli ation of a surcharge of sand material i= and around the Diesel-4 l
5 accelerate any future settlement of the Diesel Generator d g g 4p.f(g,ddj Generator Building. This surcharge was an attempt to Building by consolidating the foundation material.
(.
If' Additional developments in this matter are discussed in the 1980 section o this report, Paragraph J.9.
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17 i4
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I J.,
1950 Thi::y-seven inspection reports were issued in 15!0 of which two pertained to meetings at the licensee's corpcrate office, one to
~
a meeting in Glen Ellyn, two to investigations, a=d thirty-two to onsite inspections. A total of twenty-one items of noncompliance r
were identified during 1980. Two significant co=struction problems
~
were identified involving quality assurance problems at the Zack Co=pany (see Paragesph 7) and deficient reactor vessel anchor studs
~I
-(see Paragraph 8). These items / problems are described below:
i 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 1: nit 2 Se:vice Water System valve; and (3) failure to implement a design
~
change or prepara a Field Change Request. I.icensee correc-Il tive actions in regards to the items of noncompliance included:
(1) testing and qualification of the subject welder; (2) reinstructica 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 i-and the items closed by the. NRC as documented in Inspection Report Nos. 50-329/80-20, 50-330/80-21, 50-329/82-04 and 50-3.'0/82-04
),
2.
One itas of noncompliance was identified in Inspection Report do. 50-329/80-09 concerning the failure to maintain i.
l' levelr.ess requirements during core support asseshly lifts.
l The licensee's corrective actions in response to the ites
!r 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 satter will be reviewed durd=3 subsequent NRO inspections.
3.
One ites of noncompliance was identified in Inspection Report Nos. 50-329/80-20 and 50-330/80-21 c=ncerning the failure of a Bechtel purchase order for E7C28 ve* ding rods to specify the applicable codes. I.icenses coensi.ments in l,
regards to corrective actions included an a=di of the ordering and receiving records of weld filler material.
The licensee's corrective actions in regards to this satser will be reviewed during subsequent NRC inspections.
4 One ites of noncompliance was identified in Inspection Report Nos. 50-329/80-21 and 50-330/80-22 concerning the f ailure to perform an audit of Photon Testing, Inc. for services to qualify Zack Cospany welders. *icenses correc-tive actions included an audit of Photon Testing, Inc. The licensee's actions in regards to this matter were subsequently l
reviewed and.:he item closed by the SRC as documented in Inspection Report Nos. 50-329/81-03 a=d ~0-330/81-03.
18
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One iten of noncompliance was ide. ified in-Inspection Report Nos. 50-329/80-28 and 50-330/50-29 c==cerning the
- bypassing of a hold point on a Preuure Surge System weld.
The inspection report, further identifies tha= action had been taken to correct the identified n=nc=cg11ance and to prevent recurrence. The item is closed.
6.
One item of noncompliance was identified in Inspection Report Nos. 50-329/80-31 and 50-330/80-32 cancerning-substantial delays by the licensee in maki=g 10 CIR li Part 21 reportability determinations. I.icansee corrective H
actions included training sessicas for key personnel in
-l recognizing 10 CFR 21 reporting obligations.. The licensee's actions in regards to this matter were subsequently reviewed i
and the item closed by the NRC as documented in Inspection Report Nos. 50-329/81-07 and 50-330/81-07.
,1
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7.
A significant construction problem involv1=g quality assurance j;
problems at the Zack Company, the heating, ventilating, and air
-i-condition contractor was identified in 1980. Details of the Zack problem foll.ow:
! F 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 (HVAC) subcontractor at the Midland constr=cedon site.
The allegations dealt with material ::acemh'31:y, violations of procedures, falsification of documents, and the training
,of quality control inspectors.
(l As the :ssult of the allegations, an inves iastion was initiated by the NRC. During the initial phases of the 2?
investigation, the NRC determined that Consmeers Power.
Company had issued a Management Correctiva Antion Request (MCAR), dated January 8,1980, pertaining ::: the Zack Company. The MCAR showed that Zack had failed to initiate corrective action in a timely manner on a 2arge number of nonconformance reports and audit findings and had failed l'
to address other requirements and commitmenza of the g(0ih quality program.
L d
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61 1i!
Consumers Power Company had issued seven nonconformance
(,,N l8 reports during the period of May 23 to Oc.ober 2,1979 all
.cI J t
!i of which recessended 100', reinspection of work as a corrective l}
action. The investigation determined than as of March 19 O
'{
1980, corrective action had not been completed on any of gpCpoj 'J j y
p the nonconformance reports.
g/M Based on preliminary findings during the investigation, g4-y %,.!
i i
g which revealed some instances of continued nonconformance l *,*
A,e W' J'-
in the implementation of Zack's Quality Aasurance Program, t
an Iznediate Action I,etter (IAI.) was issued to the licensee
('
on March 21, 1980. The 1AI stated the NRC's understanding tha. a Stop Work Orde: tad leen issued to he Zack Corpora-tion for all its safety related construction activities.
19
+ * * - -
______s 1
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s T
Seventeen examples of noncompliance. involving eight different 10 CyR 50, Appendix P, criteria were identified during the investigation. The investigation findings are documented in 4 -
Inspection Report Nos. 30-329/80-10 and 50-330/80-11. The licensee's actions in regards to the items of noncompliance were subsequently revieced and the items c1csed by the NRC as
'C documented in Inspection Report Nos. 50-329/S2-15 and 50-130/82-15.
i.
On June 30, 1980, the NRC received from the licenses a d
letter documenting a Program Plan for resumption of safety related work by the Zack Company. The licar.see identified that corrective actions required prior to lifting the Stop Work included:
(1) the review and approval of all Field lj Quality Control Procedures and specific Veld Procedure Specifications; (2) the review and approvg1 of the revised Zack QA Manual; (3) the training and certification of the l
- QC personnel; and (4) the training of site production personnel.
j,
.)
Subsequent to followup NRC inspections to determine the effectiveness of licensee corrective actior.s, it was determined by the NRC, on August 14, 1980 ths: MVAC safety i
related work could resume.
l The Bechtel Power Corporation released the Zack Company from the Stop Work Order by letter dated August 14, 1980.
i As a result of the aforementioned investigation findings, the NRC imposed a Civil Penalty, on January 7,1981, on Consumers Power Company for the amount of $38,000.
8.
The second significant construction problem involved reactor pressure vessel anchor stud failures. Details are as follows:
F On Septes'er 14, 1979, consumers Power Company personnel o
notified the NRC of the discovery of a broken reactor ves' el anchor stud on the Midland Unit 1. reactor vessel.
E s
On October 12, 1979, this condition was reported under the requirements of 10 CTR 50.55(e). Two other studs were sub-li sequently found to be broken. As this condition reflected l,
a significant deficiency, an NRC investigation was initiated in February 1980 to review the materials, manufacturer, h
and installation of the studs.
The investigation findings, as-documented in Inspec-ion Repo'rt 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; (1-) failure to respond to indications that the studs were deficient;
- [
(5) failure to review mat,erials previously purchased when the purchase snecification was revised; and (6) miscalculation of 20
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i-w the stud stress area resulting in a slight over-specificatica stressing of the studs (this ite= vas iden:Afied by the licensee).
"hree items of noncompliance were identified in the inspec-e tion report. These items regarded:
(1)' failure to identify Subsection 57 of the ASE Code as the applicable requircent for the reactor vessel anchor bolts; (2) failure to establish seasures to assure that purchased satorisi conforms to the procurement documents; and (3) failure to establish sessures i
to assere th'at heat treating and nondestructive tests were controlled in accordance wi.h applicable codes and specifi-4 cations. Licensee commitments i= regards to corrective actions included:
(1) a commitment to co= duct 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 greater in diameter, have been 1
procured in accordance with proper codes and standards; -,
(2) a consitaent to obtain h1R approval of the acceptability i
of the Unit 2 reactor vessel anchor bolts and (3) a commis-ment that actual plant modifications to compensate for the defective bolts would not be started on th:1z 1 until approval of the design concept was received fres NIR.
The stud failure mechanism was identified as stress' corrosion c
cracking which propagated to the point than the studs failed by cleavage fracture. Tests indicated tha some studs utilized in t!ait 2, although of different asterial and heat treatment, have above specification surface hardness readings.
I The final report per 50.35(e) requirements eras submitted by
.he licensee on December 1,1981.-
)
h1R has the lead responsibility 'for evalum= ton and approval '
of the licensee's proposals for resolutiosa of this satser.
9.
A special inspection was conducted in December,1980 at the Bechtel Power Company Ann Arbor. 4ichigan affices to verify implementation of the specific commitments and action items
+
reflected in Consumers Power Company respanse to 10 CFR 50.5/.(f) questions (regarding excessive settlement of
.he Diesel Generator Building foundations). The results of this inspection were documented in *nspection Report Nos. 50-329/80-32 and 50-330/80-33. Tso items of noncompli.
ance were identified regarding: (1) failure to provide adequate corrective actions with regard to identified audit, resul s; and (2) inadequate design control, Licensee corrective ac'. ions included (1) revision of procedures;
+
(2) revision of specification; and (3) audit of TSAR sections.
"he licensee actions were subsequently revdeved and the itens closed by the NRC as documented in :sspection Report Nos. 50-329/,81-12. 50 330/81-12, 50-329/41-19 and 50-330/81-19.
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4-Additional information regarding this easter is discussed in the 1981 section of this report, Paragraph K.6.
K.
1981 Twenty-three inspection reports were issued in 1981 of which one pertained to a sanagement meeting and twenty-two to onsite inspections. A total of twenty-oca items of noncompliance were identified during 1981. One 'significant construccion probles was identified involving deficiencies in piping suspension systen in-stallations (see Paragraph 4).
These items / prob 2ams are described I
below:
1.
Two items of noncompliance were identified in Inspection Report Nos. 50-329/81-04 and 50-330/81-04
~hese items i
regarded:. (1) failure to account for all mols and materials used in a controlled. clean room a=ma; and (2) inadequate procedure for the installation of the Unit 2 vent valves in the core support assembly. Licensee co: ec-tive actions included: (1) the upgrading of personnel and 1
equipment logs; (2) tne addition of new logs; (3) issuance
~
- i
- of a formal Stop Vork Order. for further vo=k on the instal-lation of vent valves; (4) the revision of issst11ation
- procedures; (6) training and indoctrination of personnel performing vent valve installations; and (5) the revis:on cf the overview inspection plan. The lice =see's actions in regards to these items were reviewed and it was determined that action had been taken to correct the identified non-compliances and to prevent recurrence. 'Itds determination is documented in Inspection Report Nos. 50-329/81-04 and j;
50-330/81-04 2.
One ites of noncompliance was identified in Inspection Report Nos; 50-329/81-08 and 50-330/81-08 regarding the failure to provide adequate storage condizians for Class 1E equipment. Licensee corrective actions incanded: (1) addi-lz tional training for Bechtel maintenance engineers; (2) an p
audit of maintenance activities; and (3) rosaspections of li affected equipment. The licensee's actions is regards to this natter were subsequently reviewed and the ites closed by the NRC. as documented in Inspection Report Kos. 50-329/81-23 and 50-330/81-23.
3.
Tour items of noncompliance were identified in Inspection Report Nos. 50-3:9/81-11 and 50-330/81-11. These items regarded:
(1) inadequate procedures for the sosperary-support of cables and for the routing of cables into equip-sent; (2) failure of QC inspectors to iden ify inadequate cable separation; (3) inadequate control of noncenforming raceway installations; and (4) failure to translate the TSAR requirements into instrumentation specifications.
Licensee corrective actions in regards to (1) and (2) above, included:
(1) the revision of cable nulli=g procedures; 22 r
J :X*L:l**'~2rr.T ~ r rrrrm m2rman
(2) the repair of damaged cables; (3) trai=i=3 given to the termination perscanal and the involved QC i=spector; and (4) the revision of the cable termination procedure. The licensee's actions in regards to these ite=s were subsequently reviewed and the items closed by the NRC as documented in Inspection Report Nos. 50-329/81-20, 50-33C/81-20, 30-329/82-03 and 50-330/82-03. I,1censee co=mit=ents in regards to corrective actions pertaini=g to items (3) and (a), above, included:
(1) the addition of =equired barriers on pertinent raceway drawings; (2) the rhvision of Project Quality Control Instruction; (3) and the revision of the instrumentation specification. The licensee's actions in regards to these items will be reviewed dn==sg subsequent NRC inspections.
4.
Eight items of noncompliance were identifici during a special indepth team inspection to examine he i..plementa-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.
Three of the items of noncompliance regardad:
(1) failure to take adequate ccrrective action conce: ming the trend MO analysis procedure; (2) failure of QC inspections to qg i
to take adequate corrective action in regn=ds to the lack 9g ',#
identify a nonconforming cable band radius; and (3) failure of rework procedures. I,icensee corrective ' actions in h ljA regards to items (1) and (2) above, includad:
(1) the r-s.
issuance of a new procedure for trending; (2) the revision, ;f' '.,,
l-v of cable tersiustion procedures; and (3) additional train-ing given to the responsible QC inspector. The licensee's g* g $ l li actions in regards to these items were subsequently
<t.c l-reviewed and the items closed by the NRC as documented in
[4,T, g -
. Inspection Report Nos. 50-329/82-02, 50-33C/82-02, g,, -
50-329/82-03 and 50-330/82-03. The licensen's commitments 1-in regards to corrective actions pertaining to ites (3) abovei /
I l.-
included:
(1) the development of Adminiss=azive Guidelines and Instructions for rework; and (2) the revision of field gli Ob ' '
i prc.cedures. The licensee's actions in ress=ds to this ites P 1
k will be reviewed during subsequent NRC ia---etions.
g Ts (
F l
The remaining five items of noncompliance identified in l!.
Inspection Report Nos. 50-329/81-12 and 50-330/81-12 are considered to be a significant construction probles.
Safety related pipe support and restraint installations and QC inspection deficiencies in regard to those instal-il lations were identified. The five items of noncompliance 3
pertaining to this issue regarded:
(1) failure to install large bore pipe restraints, supports and anchors in accordance l'
with design drawings and specifications; (2) failure of QC inspectors.to reject large bore pipe restraints, supports and anchors that were not installed in accordance with design drawings and specificatiets; (3) failure to prepare, i
l i
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i review and approve small bore pipe and pipi=g suspension
, systes designs performed onsite in accordance with design erntrol 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 pipi=g calculations
++
(2) audits of small bore piping activities; (3) revision of Engineering Directive; (4) additional trai=ing in QA pro-
- cedures; and (5) audits of document erntrol. 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. 30-329/82-07 and 50-330/82-07.
As a result of the adverse findings, an Immediata. Action Letter (IAL) was issued by the NRO on.May 22, 1981 acknow-lodging the NRC's understanding that the licenses would not issue fabrication and construction drawings for the i;
installation of the safet) related small bore pipe and piping suspension systems until requirements idectified in the IAL had been completed and audited.
The IAL requirements were subsequently reviewed and determined to have been satisfactorily add:sssed. This is documented in Inspection Report Nos. 50-229/81-14 and 50-330/81-14
+
l
. The licensee's actions in regards to noncompliante items l
(1) and (2) above, are discussed in Paragraph 1 of the following report section for 1982(L).
5.
One ites of noncompliance was identified in Inspection Report Nos. 50 329/81-14 and 50-330/81-14 concerning inadequate design controls involving the Rechsel Resident Engineer's review of the field engineers redline drawings for small bore piping. Licensee corrective actions included:
(1) a 100% review of all questionable systems; and (2) the revision of a Project Instruction. The licensee's actions in regards to this satser were suhsequently reviewed and the item closed by the NRC as documented in Inspection Report Nos. 50-329/82-07 and 50-330/82-07.
6.
In January,1981 an inspection,vas conducted by the NRC to,
verify whether adequate corrective actions had been imple-mented as described in the Consumers Power :ompany response to Questions 1 and 23 of 10 CTR 50.54(f) suhaittals (regarding excessive settlement of the Diesel Generator 3:ilding foundation). The findings during this inspection, which include three items of noncompliance and'ose deviation, are doca.unented in Inspection Report Sos. SC-329/!1-01 and l
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50-330/81-01. The itens of nonco=pliance a=d the deviatien 5
regarded:
(1) failure to develop tes: procedures for soils
}*,,
work activities; (2) f ailure to have soils 2aboratory records under complete document c:strol; (3) failure to hag [i.,
cl-
. explicit instructions for the onsite Geotechnical-Engineer s
- review of test results; and (4) failure to have's qualified
~
Geotechnical Engineer onsite. Licenses corrective actions-s
- i'.
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~
included:
(1) revision of Quality Control Procedurer'and Specification; (2) development of new Quality Control Procedures; and (3) the addition of a qualified Geotechnical~ f. ;
I Engineer. The licensee's actions in regards to these items,'
./'
were subsequen':17 res-deved and the itens c2nsed by the NRC as documented in Inspection Report Nos. 50-329/S1-12 and t,
\\
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50-330/81-12.
7.
In March 1981, an inspection was. initiated by the NRC to
. verify the licensee's Quality Assurance Program for the k0 0(
ongoing soil borings. The soil hori=gs were performed v
by the licensee in response to a request from the Corps of Engineers for additional soil information for their Lp M.T review of the licensee's 10 CTR 50.54(f) a= sue:s. The i
~ findings ~ of this inspection, which includes one ites of
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noncompliance, are documented in Inspection Report Nos. 50-329/81-09 and 50-330/81-09. The nonzoopliance,
4, f 1
regards the lack of evaluation of Voodward-Clyde technical capabilities prior to the coemencement of drilling opera-tions. Licenses commitments in regards to corrective J-actions included: (1) the review, for comp 2 dance, of "i
L Midland Project major procurements and con =racts; and p.-
(2) the review and revision of pertinent procedures. The M [ '*
licensee's corrective actions in regards to these items will f
be reviewed during subsequent NRC inspectimas..
. ',,j L.
1942 1,
Tourteen inspection reports have been issued darir.3 1982 covering the period through June 30, 1982 of which two pertain to manage-ment meetings, one to an investigation, one to the SALP seating.
and ten to onsite inspections. During this pe=ind of time seven items of noncompliance were identified. One significant
- construction probles was identified involving elec::ical cable misinsta11ations (see Paragraph 2). These items / problems are discussed below:
l.
1.
The licenses conducted reinspections to da: ermine the seriousness of the safety related support and rest:sint installation and QC inspection deficiencias identified in Inspection Report Nos.r50 329/81-12 and 50-330/81-12. The results of the reinspections are documented in Inspection Repor: Nos'. 50-329/82-07 and 50-330/82-07. 7:oo a sample size of 123 safety related supports and restraints installed and inspected by Quality Control, approx 1=stely 45'. were identified by the licensee as rejectable.
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On August 30, 1982, the licensee was informed of the NRC's pesi-ion that the licenses shall reinspect all the supperts and restraints installed pris to 1981 and perform sample reinspections of the components installed after 1981. The licenses has agreed to perform the reinspections.
2.
One significant construction problem was identified during 1982. It involved electrical cable misinstallations.
Details are as follows:
k During the special taas inspection conducted in May 1981, the NRC identified concerns in regards to the adequacy of b:
inspections performed by electrical Quality Con :o1 inspec-tors. These concerns were the result of the NRC's review l,
of numerous Nonconformance Reports (NCR) issued by Midland Project Quality Assurance Department (MPQAD) personnel during reinspections of items previously inspected and accepted by Bechtel QC inspectors. The h1tc required the licensee to perform reinspections of the items previously inspected by the QC inspectors associated arish the MPQAD
'~
NCRs. The licensee, in reports subsisted to the.9tc in May and June 1982, reported that of the 1084 electrical cables reinspected, 55 had been determined to be min outed in one or more vias. This concern was upgraded to an item of non-compliance and is documented in Inspection Report Nos. 50-329/82-06 and 30-330/82-06..
On September 2,1982, the licensee was informed by the NRC l
that a 100*. reinspection of class 1E cables installed or l
partially installed before March 15, 1982 ares required.
II In addition, the licensee was required to develop a sample reinspection program for those cables insta22ed after.
March 15 -1982. The licensee has agreed to perform the reinspections..
3.
Three examples of noncompliance to one 10 CFR 50 Appendix 3 Criterion were identified in Inspection Report Nos. 50-329/82-03 and 50-330/82-03. These examples regarded:
(1) failure to follow procedures concerning drawing changes; (2) inadequate specification resulting in the undermining of BVST No. 2 valve pit; and (3) inadequate control of changes to procedures. The licensee'~s response to the identified ites of noncompliance is presently under review. Corrective actions taken by the Ideensee in regards' to this ites will be reviewed during future inspections.
4 your examples of noncompliance to one 10 CFR 50 Appendix 3 l'
Criterion and a deviation were identified in Inspection Report Nos. 30-329/82-05 and 50-330/82-05. The examples of noncompliance and the deviation re8erded:
(1) failure l-to review and approve a Me:8entine (the soils cettractor) field procedure prior to initiation of work; (2) inadequate l
control of specification changes; (3) inade:;us e acceptance l
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- iteria for dewatering specification; (!-) i= adequate j
ins :uction to prepare or implemen: reinspen ica plans; and (5) inadequately. qualified re=edial soils sr.zf f.
The ::::e:-
3' tive actions taken by the licensee in regards to this ites will be reviewed during future inspections.
5.
One item of noncoopliance was identified in Inspection Repc::
Nos. 50-329/82-06 and 50-330/82-06 concerni=g the licensee's
~. ',
failure to establish a QA program to provide controls over the installa:ica of remedial soils instrumentati=m. This item resulted in the issuance of a letter by the licensee on March 31, 1982 confi =ing the licensee's suspensica of all unde:pi=ning instrumentation installation activities until: (1) approved, a
centro 11ed drawings and procedures or inst:== icas we:s developed to prescribe underpinning instrumentation i=sta11ation activities; (2) plans were established to inspect and a:dit instrumentation installation activities; and (3) Region III had concurred that (1) and (2), above, were acceptable, if A follovup inspection by Region III in April 1982 identified that the licensee had developed acceptable drawings, procedures, and instructions for underpinning instrumaion installations such that instru'nantation installation acti::izies could be resumed. An additional follevup inspectica =m August 23, 1982
+
determined that the installation of undarp'%g instrumentation for the Auxiliary Building was complete ant. meceptable. This item will remain open pending the licensee's development of l
drawings, procedures, and instructions for =he future installation l
of underpinning instrumentation for the Service 'n'ater Building.
(s l;
6.
One item of noncompliance and a deviation se=e identified in Inspection Report Nos. 50-329/82-11 and 50-35D/82-11. The items l
regarded:
(1) inadequate anchor bolt insta22ation; and -(2) the i!
. use of unapproved installation / coordination feras during remedial li soils ins::usentation installations. The licensee's responses :o the identified items of noncompliance are presently under review.
Corrective actions taken by the licensee i= regards to these itesa vill be reviewed during future inspec= ions.
The ASI3 issued an order modifying Construction Pa==its No. CPPR-81 and No. CPPR-82, dated April 30, 1982. This order suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit approval. The ASI3 issued another order, j.
dated May 7,1982 clarifying the April 30,1982 crder. This c: der only includes those activities bounded by the 1 miss identified on Drawing C-45.
As a result of past Region I.II findings, the Region III Administrator created a special Midland Section staffed with d-
'ividuals assigned sclely to the Midland project. Since the formation of the Midland See: ion a work authorization procedure has been :ieveloped by Regica III and the licensee to centrol verk and e.sure co=pliance to the ASI3 Order.
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i.ecive:
(1) the drilling of a number of wells which f=ction as par:
lj ef the temporary and permanent devatoring systems; (2', the installation.
of the freeze vall associated with the Auxiliary Building Underpi=ing activity; (3) the completion of the initial work on the access shaf:;
and (4) the completion of the Auxiliary Building inst:mestation for renadial soils activities.
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