ML20094G405

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Submits Changes to Be Implemented Prior to Util Resuming Remedial Soils Work.Draft List of Noncompliances & Deviations,Handwritten Notes & List of Events Since Jul 1981 Hearings Encl
ML20094G405
Person / Time
Site: Midland
Issue date: 09/20/1982
From: Warnick R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19258A087 List: ... further results
References
CON-BX15-010, CON-BX15-10, FOIA-84-96 NUDOCS 8408130301
Download: ML20094G405 (70)
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f 'e., . *))[?* g NilCLEAR REGUI.ATOltY COMMISSION h ~ o 2 e REGION til [ g M9 ROOSEVELT RoAo occm ct.tyn, Lusois soia? M;0!ORANDUM FOR: James G. Keppler, Regional Administrator FROM: R. F. Warnick, Acting Director, Office of Special Cases

SUBJECT:

REVIEW OF CONSUMERS POWER COMPANY COMMITMENTS As directed by you on September 7, 1982, the Midland Section has reviewed the licensee's draft commitments to improve the implementation of their Quality Program in the remedial soils area and in the remaining construction activities at the Midland sit'e. These commitments resulted from discussions you and D. G. Eisenhut had with J. D. Selby and J. W. Cook of CPCo on September 2, 1982. The licenssa's draft commitments are meant to confirm and/or improve the quality of the work performed at Midland and address some of the suggestions made by the Midland Section as described in my memo to you of August 18, 1982. However, che licensee's draft commitments fall short of what we believe -is needed to cura uus rivaca uvuno. We believe the changes described below must be made. Items 1 thru 4 should be implemented prior to allowing CPCo to resume the remedial soils work. Items 5, 6, and 7 pertain to the licensee's commitments for all other plant work. 1. The licensee's draft commitment letter describes how CPCo is under-taking a review of past correspondence to create a computer listing of all commitments not already reflected in the construction documents. We feel that Consumers Power Company must provide a master list of all commitments made regarding remedial soils work prior to starting work. To reduce any unnecessary delays that would impact on the project, we would accept a partial list that would identify all commitments made on specific work activities planned for 'he first 60 days of t work with a follow-up master list for all remaining remedial work to be issued within 60 days from the start of the work. g408130301 840/is POR FOIA PDR R ICEg4--96 c e-

l Jtmea'G. Kapplcr 21 d 2. The draf t letter states that CPCo will integrate the soils QA and QC functions under the direction of MPQAD. We believe that Consumers Power Company should remove all responsibility for Quality Control activities from Bechtel. This should include administrative functions such as hiring, firing, promotions, salary, etc. CPCo must also qualify and certify all QC personnel to CPCo standards. 3. CPCo's draft letter commits to "substantially upgraded training programs". We believe that the training program should be implemented for all personnel involved in remedial soil activities. The thrust of the program should be directed towards building " quality" into the work , and ensuring that everyone is knowledgeable of their responsibilities and authority. This training program should be accomplished before the start of soils work. 4. The draft letter indicates that a third party will be retained to independently appraise the initial phases of the construction of the a==414=ey building underpinning. He believe the special team that will evalaate Consumers Power Company performance should be in place prior to start of work on pier 12. The Midland Section strongly reconsnends that you do not issue blanket authorization for Consumers Power Company to proceed with the soils project. Rather, we recommend that work projects be authroized piece-meal by the Section as provided in our work authorization agreement with CPCo in order for our staff to evaluate the licensee's quality effort. When the work effort shows that the licensee is adequately implementing their program, additional work projects would be authorized. 5. We do not feel that an INPO type " horizontal" assessment will provide sufficient confidence that the current work in progress is being properly implemnted, particularly if the INPO report suffers from the same lack of detail that exists in the operations type INPO reports. It is also our understanding.that INPO has minimal assessment experience at construction sites. Even if INPO or a contractor has the necessary expertise, a two-week overview.of Consumers Power Company capability will' omty give us a snap-shot perspective. The licensee's draft commitment ' S g = e e ~ -.-y-,,,, -,,. - - - -,. - -, .e w y a

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,~ x s. 3. James"G. Keppler letter does not address an ongoing assessmenti team beyond the INPO i effort. We need a detailed and indepth inspection effort thist extends over a much longer period of time. We originally requested the use of five contract-type personnel, reporting directly to the NRC for a period of six to twelve months, in order for the Midland Section to assess' the licensee's current work effort. We believe we must have these additional people to inspect ongoing and completed work. Without them we do not know if we can restore confidence in the Midland Facility. We don't believe the INPO assessment will accomplish what we intended to accomplish by our original recommendation. 6. We do not feel that the proposed CPCo QA/QC organization will be effective as long as Bechtel supervisory personnel are still in place and the administrative functions are still being controlled by Bechtel. We believe it is necessary for Consumers Power Company to take total control of QC. This comibent is an extension of comment 2. 7. There is insufficient information contained in the draft letter to be able to tell much about the '.' vertical slice

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P. that. interrelationships between various safety systems have been adeguately addressed. e intend to work with CPCo and feel we will be able to accomplish some of our coassents and recommendations (1, 3, 4, and 7). We request your help in accomplishing items 2, 5, and 6. _ -The Midland Section has a difficult task to accomplish. In addition to following the remedial soils and other ongoing work, we must complete enough construction inspections to determine whether or not the plant is built as designed and to determine whether or not any of the types of problems identified at Zimmer exist at Midland. We must resolve the allegations regarding Zack HVAC work and the allegations in the affidavits supplied by GAP. We must also get CPCo to take the actions that will produce the results which in turn will allow the NRC staff to have confidence in CPCo management and Midland. We need more manpower on site to do the job. Should you have any questions regarding this memorandum, I shall be happy to discuss: them with;you2 R. F. Warnick, Acting Director Office of Special Cases

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QUALITY ASSURAt:CE - 190JECTS.13GINEERIIl0 & CONSTRUCTION J B. W. MarguP113. Dirsetzr J J. A. Chase. Secret ry / l / I I I I QUALITY ASSURANCE INSPECTION, EXAMINATION & QUALITY ASSURANCE INSPECTION, TXAMINATION & AUDIT & ENGINEERING-MIDLAND TEST VERIFICATION-MIDLAND FJMINrfftIf3G-0THER TFS? VERIFICATION-0THER ADMINISTRATION 'J W. R. Bird (R) M J. L. Corley (H) J F. M. Macri (H) + -J F. M. Macri (Acting H) + J D. A. Tar.p: art (R) 'J 1.. J. Bidol Secy. + M P. Po.,111e, secy, J I. J. Bidol, Secy. + J L. J. Bidol Secy. + J L. L. Bailey. Steno t J B. M. Iounds. Stene J,P J. M. Buechler C E. C. Adams J W. C. Carr C C. L. Roshy J C. M. Bell J S. BanerM - J P. D. Milano

  • J D. Jones CIVIL CIVIL J

Vacancy ('79)* CT J. L. Stivers e J P. E. Love M D. E. Horn (S) M

0. T. Black K.CN.W J. M. Decker J

J. N. Leech /3-16-75 M M. J. Damaso e J R. E. Field

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ELECTRICAL / ELECTRONICS ELEC11tICAL/ ELECTRONICS M P. R. Kyner (S) M M. J. Schaeffer (S) M W. H. Benkert J P. W. Jacobsen M E. L. Jones

  • M D. Nott
  • FLUIDS & MECHANICAL FLUIDS & MECHANICAL l

l J R. L. Southon (8) ( M R. E. Whitaker M D. R. Keating (8) [ f'* M W. F. Dickson M M. F. DeWitt 'g<* M L. R. Howell I A' 'h M H. L. Allen

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{ M D. K. Martin e NONDESTRUCTIVE EXAMINATION J J. L. Wood (S) (H) = Section Head .J H. S. Carcha NONDESTRUCTIVE (S) = Croup Supervisor EXAMINATI0tl J = Jackson location M = Midland location M Vacancy (S) C = Campbell location RELIABILITY & H N' b* ZI"""""* P = Palisades Location 4 M E' I{"". MAINTAll3 ABILITY D = Rig Rock Point location K = Karn, Wendock location j. J R. J. Sciamanda (8) W = Whiting location CB = Cobb Loc'ation CT.= Chattanoorn Tennessee j. DOCUNDITATION C0ffrHOL ,= Contract Personnel ,i + = Dual Capacity i a M R. C. Wollney (S) Date = Expected Report Date for New Hire ? Rev 2/6/79

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SUPPORTING DATA AND SUMMARIES-1. Noncompliance Data Facility Name: Midland Nuclear Power Plant UNIT: 2 DOCKET NO: 50_330 Inspections No.50-330/80-18 through No.50-330/80-38 No.50-330/81-04 through No.50-330/81-12 i ~ Noncomoliances and Deviations Severity Levels Categories unctional Areas I II III IV V VI Viol. Infr. Def. Dev. .' Soils & Foundations ( 2') (1)' (1) Containment & Other Safety Felae.a <tructures

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~Saferv_Delated Comnonents 2 ' V.- -' T lV '<. ~ - (151 r i) uvar syneam + -' Electrical Power Runniv/n4e.- (4)/ l' In"trumentation & Control Svs. Licensing Activities Ouelity Assurance (1)' flf Fire Protection ' Pra'tervice Inspection Denian and Desion Chances " R oortino Recuirements (11' o TOTALS 4 13 1 In 3 1

Numbers in parenthesis indicate noncompliances common to both units.

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GQ 'j #--!(- y] !!! rp, i s' LDL E L. V. SUPPORTING DATA AND SUMMARIES 1. Noncompliance Data Facility Name: Midland Nuclear Power Plant UNIT: 1 DOCKET NO:so_179 Inspections No.50-329/80-17 through No.50-329/80-37 No. 50-179 /A1 -n 4 through No.cn_ no /o, _, > Noncompliances and Deviations Severity Levels Categories Functional Areas I II III IV V VI Viol. Infr. Def. Dev. / / / 1.' Soils & Foundations (2) (1) (1)

2. - Containment & Other Safety Relae a 4t'uctures r

3.' Pinine System & Suenorts (1) (4) (1) 46 Saferv Related Comnonents f . / i t l- ./ / (1)/ 3 -).- (15) ( 3) 5.' uvac c;vse.. 6.- Electrical Power sunniv/nfe '5/ 7. Instrumentation & Control Sva. 8. Licensing Activities / /

9. ' ouality Assurance (1) (1) 10.

Fire Protection 11. Preservice Inspection 12. Desian and Desion Chances

13../ Reoortino Recuirements f1) 14.

15. i 16. 17. j 18. 19. 1 ,20. 21. TOTALS 4 12 17 3 1 If Numbers in parenthesis indicate noncompliances common to both units. l-((fac 1 E.M( $Pb f l* b) W f _.. e

__ $$Y h SUltnRY 0F ITEMS OF NONCOMPLIANCE L b 29 50-330 Area of Subject of-Unit 1 . Unit 2. I' 3 { ! Report No. Noncompliance Noncompliance Points Points [, 0-10 80-11 Criterion V ' Activities affecting quality were not accomplished in-t accordance with documented instructions and procedures i for fabrication. 10 10 Infraction.; Criterion V Welders identification was not recorded on travelers. 2 2 Deficiency l Criterion V Unapproved marking material, Eberhard Faber Marquette was l 3 i used to mark sheet steel stock and fabricated items instal-led in seismic Class 1 duct work without a change approved { by the contractor. 2 2 Deficiency ! Criterion XII Documentary evidence did not exist that material and equip- } ment conform to procurement requirements prior to instal-l 1ation or use. 10 10' Infraction i I ) Criterion VIIE Failure to assure the identification of safety related i i HVAC components throughout fabrication, erection and Installation. 10 10 Infraction 1 Criterion IX Established welding procedures were not used as specified or in the manner used to qualify the procedure. 10 10. Infraction ~ Criterion IX Procedures to control weld filler metal at the Midland 1 4, l i (pgisXa@Gm(2@OMfD G((R(D WIDGYD fiYI)R. kMdm Ob, - - -b---.-- O E ---

[ f ~ ?- I SUtenRY OF ITEMS OF NONCOMPLIANCE- ~ U C I I '329 50-330 Area of Subject of Unit 1 Unit 2-l i. < Report No. Noncompliance Noncompliance Points Points Type "i (cont)(cont) Welding was not performed in accordance with prequalified. f, 10-10 80-11 Criterion IX 1 j welding procedures. 10 10 Infraction. l c a /i Criterion IX Individual welds were not identified by welder ID numbers. 10 10 Infraction it l F 1 Criterion IX Two welders were assigned the same welder's ID stamp 10 10 Infraction i f l l i Criterion X Instructions and procedures for inspections were not pre-i ] scribed for activities affecting quality. 10 10 Infraction l i Criterion X The program for inspection was not adequate to assure com-pliance with applicable specifications. 2 2 Deficiency ~ i-I Criterion XV Measures which would prevent the inadvertent use or-instal-1ation of nonconfonning materials had not been established. 10 10 Infraction J ~ 4 1 Criterion XV Nonconfonnance tags had been applied to fire dampers without i l l explicitly identifying the item. 10 10 Infraction Criterion XVI None of the seven nonconformance reports generated by CPCo j during 5/23 - 10/2/79 had been promptly corrected. 10 ' 1'O Infraction I f I'

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SUMMARY

OF ITEMS OF NONCOMPLIANCE b329 50-330 Area of Subject of Unit 1 Unit 2 io f-Rep 7rt No. Noncompliance Noncompliance Points Points Type i

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3-10 80-11 Criterion XVI Measures were not adequate to assure that conditions adverse 1 to quality were promptly identified. 10 10 Infraction ;- I Criterion XVIl Sufficient records to furnish evidence of activities (, t affecting quality were not maintained. 10 10 Infraction

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I I ' SUM 1ARY CF ITEMS OF NONCOMPLIANCE 50-9 50-330 Arca e Subjsct of Unit 1 Unit 2 $+s(' .\\ IE Rtport No. No pliance Noncompliance Points Points ~ r s 80-20 80-21 Criterion IV Bechtel Purchase Order did not specify ,i SS 8'1 applicable des' [ 10 10 ED&L-60,000 - W 7efg i d.(.R e 80-21 80-22 Criterion XVIII Failure to perform audit of Photon 2% gg Testing, Inc. prior to welder training f gg/[.1 and qualification. 5 ~~ ' ! \\ - 10 10 a t-80-28 80-29 Criterion X Bypass of an inspection hold point. / 2 only). 10 t 80-31 80-32 erion II Delay in making l'0 CFR 50.55(e) report-j k gg ability detenninations and information l gbQL was not immediately disseminatqd to ' a t f Q 2.I h $5 - the client. 10 10 k'f N l i 80-32 80-33 Crf.terion XVI Failure to initiate preventive action 2_ ~2_. j-7 to preclude repetition of not identi-7270G i fying design documents. Reviewers were not reviewing the FSAR against references. 10 10 g

SUMMARY

OF ITEMS OF NONCOMPLIANCE r of Subject of Unit 1 Unit 2 Severity -32 5 -33 Area [aclTI Nopompliance Level S Report No. Noncompliance Points Points 0-32 80-33 Criterion III Three examples of failure to translate applicable regula-fi' h tory requirements and design criteria into design documents M f L7d b t a) Failure to maintain a coordination log of specifica- { tion change notices. !f b) Failure to correctly translate SCM-9004 as a require-i ment into Rev. 20 of specification C-208. l t c) Failure of EDPI 4.25.1, Rev. 8 to establish adequate t measures to waive design interface requirements. 10 10 IV { / s-s ) i 9 2 e

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SUMMARY

OF ITEMS OF HONCOMPLIANCE i Ad-33rt P Mcf 50 Are Subj:ct of . Unit 1 Unit 2 Severity L . Report No. Noncompliance Noncompliance Points Points Level 81-01 81-01 Criterion V Failure to establish test procedures for soils work i 2.1 91~7 6 3 activities. 10 10 V 2, een i i Criterion VI Failurdtpcontroltestresultsforms'fofskilsdork, 10 10 V S.? PAM3 ~ activiues. ~4 EN [ N i '{ p ifgMp an.d4 ) hp[thhee $o /O /O VI Cr on I] g-control the use of signature stamps. 81-04 81-04 Criterien V Failure to have an appropriate procedure for installation b Soo 6 h of vent valves. 10 V { g',s. CC/}f t, l.. < / ,c Criterion V Failure to follow access control and severity-level V, (p g_i,../ ll; ( s. a doo[d ie.,U/2coresupportassem(!ly vet $t ' alves without being j v @h--6 (. l t . s i. j, ( accounted for on equipment log. / 10 v r r .. f[ 81-08 81-08 Criterion XIII Failure to provide adequate storage conditions for 7 -e.2 A S'/ o 5 3

1) Control Rod Drive Primary AC Breakers Un f(d,' C/YNS

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2) New and spent fuel storage racks
3) Emergency bat.tery chargers 10 10 V

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SUMMARY

OF ITEMS OF NONCOMPLIANCE 2f 50 3i r:0 cf Subj ct of Unit 1 Unit 2 S,varity IE eport o. Noncomp iance Noncompliance Points Points . Categories f T r 81-09 81-09 Critarion V Failure to evalukts the technical b ggf capabilities of Woodward prior to Ed8 commencement of drilling operations. 10 10 V e I I 81-11 81-11 Criterion V Failure to establish procedures for j h temporary support of cable, cable 7 s / o G I-g r g FA g coils --- and for routing cables. 10 V Mw/ ,, u Y Criterion X Electrical contractors failed to Qu j e ..p+ gb Oh j y ,p[j po S/o 3 verify conformance to paragraph 3.1, g4g failure to perform adequate inspec-tion. 10 V i Criterion XV Failure to identify and control '1 gfg g nonconforming components. 10 10 V b4AK Criterion III Failure to translate design criteria g into drawin8s and specifications. 10 '/O V -g b>oCl s 7 ec45 e

SUMMARY

OF ITEMS OF NONCOMPLIANCE l[h{ Nl~ l 0I M 29 50-330 Ara cf Subj ct cf Unit 1 UniE'2 " S.vsrity sfeeh eyoncompilience IE Report No. Noncompliance Points Points Categorles g 81-12 81-12 Criterion XVI Routine analysis of report revealed that-j 21 ~ _!. f 2,,7 g b appropriate site managers have not rou-b tinely establishe,d_conprehensive correc-tive actions in response to the identi-fication of adverse quality trends. 10 10 IV i i Criterion X Failure to identify during inspection 7 thae, nonconforming condie1on ita gt&L.aWi4~ sto% s i -j{ g - g/% Q regard to minimum installed cable bend 7 d radius existed. / Q VI i Crite ion XVI Failure to take proper corrective action 7 S/Oh[ with regard to the lack of approved pro-cedures for the rework i ms. 10 10 V [ Criterion V Failure to install large bore pipe i / ,S~ ggg restraints, supports, and anchors in i DYbb r accordance with design drawings and specifications. 10 10 V O e a

i. lj , d.t l ll,f pj (' SUIMARY OF ITEMS OF NONCOMPLIANCE ff ( 50- 29 50- 30 Arm cf Subj ct of Unit 1 Unit 2 Saczzty No% IE Report No. dcompliance Noncanpliance Points Points Categories (crat) (cont) T 81'-12 81-12 Criterion X Failure of QC inspec' tor to reject large I 8 i ggg bore restraints, supports and anchors l that were not installed in accordance with design drawings and specifications. 10 10 V Criterion III Failure to prepare, review and approve I f &Od)g O small bore pipe and piping suspension FCP4 system designs performed onsite in i l accordance with design control procedures 10 10 IV j l Criterion VI Failure to adequately control documents f M Oc/ O used in site small bore piping design g pSS activities. 10 10 V i ~ Crite,rion XVIII Failure of audits to include a detailed 4

i review of system stress analysis and to I

follow up on previously identified i Sco9o g gg hanger calculation problems. 10 10 V 1 = s

ssxENT or LICENSEE PERTORMMICE 7 / '/N ' ,c >ss /; y b(- / gg AND NATURE OF ENTORCEMENT ITEMS - Plants under Construction ) Docket No. Unit I racility Name 6 Envestigation Noncompliances and Deviations . Functional Areas

s. Inspection Severity Levels cateoories Manhours I

II III IV V VI Pliol j Infr. Def. Dev j i quality Assurance y

2. Site Preparation and j

Foundations / O

3. Containment Structures

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4. Safety-Related Structures
5. Piping and Hangers 33

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6. Sutety-Related Ccmponents
7. Electrical

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8. Instrumentation
9. Fire Protection p3-
10. Preservice Inspection g
11. Corrective Action and Reporting
12. Procurement g
13. Design and Design Changes
14. Training O
15. Plant Operations Preparation
16. Fuel I.cading Prepara-tion (1
17. Maintenance
18. Security & Safequards g-
19. Surveillance and Pre.

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20. Emergency Planning
21. Audits, Reviews, and Committee activities O

'22. Modules Not included in L Any Functional Area / / 20 .3 1260 1 R 21 3 .roTA:s Che.ckS "+ c,p.jon h.

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l SSESSMENT Or 1,2CENSEE PERTORMANCE gg AND NATURE OF ENFORCEMENT ITEMS - Plants under Construction M / bb b __ Docket No. Unit k Facility Name investigation Noncompliances and Deviations r Functional Areas

5. Inspection Severity Levels Cateoories Manhours I

II III IV V VI Viol.l Infr. Def. Dev

1. Quality Assurance f
2. Site Preparation and fq Foundations f
3. Containment Structures 3~

4. Safety-Related Structures

5. Piping and Hangers j

6. Safety-Related g Components I/ 4 . s. 7. Electrical fg 8. Instrumentation

9. Fire Protection gg
10. Preservice Inspection g
11. Corrective Action and 4

Reporting f

12. Procurement
13. Design and Design Changes 1
14. Training O
15. Plant Operations Preparation g
16. Fuel Icading Prepara-tion C,
17. Maintenance
18. Security & Safeguards g
19. Surveillance and Pre Cfs9ATra7AL TESTtNE O
20. Emergency Planning O
21. Audits, Reviews, and Committee activities O
22. Modules Not included in g

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-s Number end NStura of N ncemolianca Items Noncompliance Category Unit 1 ' Points _ Unit 2. Points Violations Infractions

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II. NUMBER AND NATURE OF ENFORCEMENT ITEMS Midland Unit 1 Docket No. 50-329 Investigation S Inspection Noncompliances and Deviations Functional Area Fanhours Severity Level Classification

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I II III' IV tV VI. __Vio.__Infr dDe f. 1. Quality Assurance 73 4 i I I 2. Site Preparation & Foundations 18 t 3. Containment Structure: 26 4. Sa fety-Related Struc tures 2 f f 5. Piping & Hangers 33 1 4 1 6. Safety-related Com-i ponents 14 i 7. Electrical 107 3 I l 8. Instrumentation 9. Fire Protection 25 i 10. Preservice Inspection 32 1 I 11. Corrective Actions & i. i Reporting 1 i j l l 12. Procurement 0 i i i i 13. Design and Design l t Changes 2 l l I l 14. Training 0 i i i i i i ~ 15. Modules Not Included l j l ~ In Any Functional Area 927 l 1 1 I 20 3 l 2 12i 21 3 TOTALS 1260 ep.m -w e. ,,ew. - *... en er-. y.a, -ee.,e, e se,- e J..

.. r, II..; NUMBER AND NATURE OF ENFORCEMENT ITE.T . Midland Unit 2 - Docket No. 50-330 r tInvestigation E Inspection Noncompliances and Deviations Funct5.onal Area Hanhours _ Severity Level Classification

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I 'II III" IV V VI Vio. I Infr. I Def. i s 1. Quality Assurance 71 4 I 2. Site Preparation & i Foundations 17 3. Contairunent Structury 5 4. Safety-Related S tructures 2 l -5. Piping & Hangers 40 1 4 l 2 6. Safety-Related Compo-nents 17 2 7. Electrical l ~ 104 2 1 8. . Ins trumentation 0 9. Fire Protection 26 s l- -10. Preservice Inspectiori 34' I i 1 - 11. Corrective Actions & f-Reporting 1 h-l l I l 12. Procurement-O

13.. Design and Design l-Changes 2

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14. Training i

0 l - 15. Modules Not Included ? i In Anv Functional Are's 921 1 1 20 3 1l 2 13 TOTAIS _1240 20 5 L e v-4 wa+p.4prwwe i%y-a q.e4 y g - = .%y,, g.,,y,-,9v--

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    • -geep,*

ek w se 4 g e = wp w p ,y,,, g

i. -

e t. \\ tA 14 M*lt # t ' Numb r and Nature of Nonc_otnolianew Items 3 i Nocccxnpliance Category Unit 1 Points Unit 2. Points e Violations Infractions 21 21 Deficiencies 3 3 Severity Levels I O O II O O III O O IV 2 2 V 12 13 VI O 1 e 0 .w. m.,..+,. .w. by., w.. e 9 g a.,., m--i-.. e .. w w-y w e,-. m.,,- e. 3 m. , m 3.,y- ...m..www..

= II. NUMBER AND NATURE CF ENFORCEMENT ITEMS Midland Unit 1 Noncompliances and Deviations Functional Area Severity Level Classif_ication I II III IV V VI' Vie Inf' De f. Dev 1. Quality Assurance 1 1 2. Site Preparation and Foundations 2 2 1 1 3. Containment Structures 4. Safety-rela ted S truc tures 5. Piping & Hangers 1 4 1 6. Safe ty-related Components 7. Electrical 5 8. Instrumentation 9. Fire Protection LO. Preservice Inspection L1. Corrective Actions and Retsortinz 1 L2. Procurement L3. Design and Design Channes 14. Traininz

15. Modules Not Included In

/g Any Functional Area 278 1 3 TOTALS 517 4 13 1 16 3 1

= s II. NUMBER AND NATURE OF ENFORCEMENT ITEMS Midland Unit 2 l Noncompliances and Deviations Functional Area Severity Level ! Classif_ication I II III IV V VI Vie InfiDef Dev 1. Quality Assurance 1 1 2. Site Preparation and Foundations 2 2 1 1 3. Containment Structures 4. Safety-related Structures 5. Piping & Hangers 1 4 2 6. Safety-related Components 2 7. Electrical 5 1 8. Ins trumenta tion 9. Fire Protection LO. Preservice Inspection L1, Corrective Actions and Reportina 1 L2. Procurement L3. Design and Design Channes L4. Training L5. Modules Not Included In Any Functional Area 277 1 15 1 TOTALS 49h 4 15 ? 1R 1 1

  • T

' ~

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[.,-

I A SUNGLRY OF ITEMS OF NONCOMPLIANCE - h, b329 50-330 Area of Subject of Unit 1 Unit 2-Resort No. Noncompliance Noncompliance Points Points h1080-11 I Criterion V Activities affecting quality were not accomplished in accordance with documented instructions and procedures for fabrication. 10 10 Infraction l ' Criterion V Welders identification was not recorded on travelers. 2 2 Deficienc'y l ' l .$ Criterion V Unapproved marking material, Eberhard Faber Marquette was I ] used to mark sheet steel stock and fabricated items instal-l led in seismic Class 1 duct work without a. change approved l (, i by the contractor. 2 2 Deficiency.*,! l l e[ Criterion.TII Documentary evidence did not exist that material and equip-i I ment conform to procurement requirement:, prior to instal-I l lation or use. 10 10 Infraction l; h Criterion VII L Failure to assure the identification of safety related ( HVAC components throughout fabrication, erection and Installation. Infractionf{- 10 10 I; Criterion IX Established welding procedures were not used as specified i 1 ; i ! (/ - or in the manner used to qualify the procedure. 10 10 " Infraction ) l '. ') Criterion IX Procedures to control weld filler metal at the Midland i ....s. s -,+ r.s,. Am. 9@-.

y; i

SUMMARY

OF ITEMS OF NONCOMPLIANCE )-329 50-330 Area of Subject of Unit 1 Unit 2 o f }'

Reo rt No. Noncompliance Noncompliance Points Points Type If (cInt)(cont) 4 80-10 80-11 Criterion IX Welding was not performed in' accordance with prequ'alified

, k welding procedureE 10 10 Infraction l { ~ 'I Criterion IX Individual welds were' not identified by welder ID htanhbr5. 10 10 Infraction 1 + c v.r I f,f /P Criterion IX Two welders were assigned the same welder's ID stamp 10, 10 ', ' Infraction h ^ ? t t ji Criterion X Instructions and procedures for inspections were not pre- { scribed for activities affecting quality. 10 10 Infraction /I Criterion X The program for inspection was not adequate to assure com-pliance with applicable specifications.' 2 2 Deficiency i i e I Criterion XV Measures which would prevent the inadvertent use or instal-I lation of nonconforming materials had not been established. 10 10 Infraction 2 i l i Criterion XV Nonconformance tags had been applied to fire dampers without i j' explicitly identifying the item. 10 10 Infraction j !I / S Criterion XVI None of the seven nonconformance reports generated by CPCo t during 5/23 - 10/2/79 had been promptly corrected. 10 10 Infrac tion ! l 4 0 e e

1

SUMMARY

OF ITEMS OF NONCOMPLIANCE 1-329 50-330 Area of Subject of Unit 1 Unit 2 > Report No. Noncompliance Noncompliance Points Points Type cont) (cont: /5-(0-10 80-11 Criterion XVI Heasures were not adequate to assure that conditions adverse g to quality were promptly identified. 10 10 Infraction.' // i Criterion XVIl Sufficient records to furnish evidence of activities } h affecting quality were not maintained. 10 10 Infraction L I f I e i r 1 i I. e O 9 5 h

gsgs5 MENT OF LICENSEE PERTORMAd@$ . ~...... ' ~ agg i 1 N-{ ~ NUMBER AND NATURE OF ENFORCEMENT ITEMS - Plants under Construc, tion y, ) Docket No. Unit I Facility Name Noncompliances and Deviations [nvestigation Functional Areas

6. Inspection Severity Levels Cateoories Manhours I

II III IV V VI Violl Infr. Def. Dev I y

1. Quality Assurance
2. Site Preparation and j

v T Foundations / D i V 3. Containment Structures ]h

. f4. Safety-Related Structures
5. Piping and Hangers g

$3 -/ y ) y

6. Safety-Related y

[ Components s

7. Electrical

.g /(yf 3 y' 8. Instrumentation y 9. Fire Protection 2{ /

10. Preservice Inspection g
11. Corrective Action and Reporting K
12. Procurement g
13. Design and Design

[ $ V Changes s/ 14. Training

  • O
15. Plant Operations Preparation Q
16. Fuel Loading Prepara-tion Q
17. Maintenance g
18. Security & Safeguards g
19. Surveillance and Pre.

4 Ofd.AT<@1 Testsaq Q

20. Emergency Planning O

~21. Audits, Reviews, and Committee activities OY f f h

22. Modules Not included (d Any Functional Area M l260 1 R 21 3

.ro m s che.cks ex+ c,mp.,and, '""'****-**W^ = s,eww ,,},

y m I NUMBER AND NATURE OF ENFORCEMENT ITEMS

  • Plants under Construction Unit' k y,

M / D LMN Docket No. Facility Name w Noncompliances and Deviations [nvestigation Cateoories Severity Levels Functional Areas

s. Inspection Manhours I

II ' III IV V VI Jiold Infr. Def. Dev f

1. Quality Assurance q
2. Site Preparation and f

f Foundations

3. Containment Structures 3
4. Safety-Related Structures
5. Piping and Hangers Q)

/ y Q ry

6. Saf ety-Related g

L / Components

7. Electrical

/g Q /

8. Instrumentation O
9. Fire Protection gg
10. Preservice Inspection g
11. Corrective Action and Reporting
12. Procurement
13. Design and Design K

Changes

14. Training O
15. Plant Operations Preparation g
16. Fuel Loading Prepara-tion C

i

17. Maintenance O
18. Security & Saf eguards g
19. Surveillance and Pre Ofi9ATtMAL TESTtNE O
20. Emergency Planning
21. Audits, Raylevs, and O

Committee activities

22. Modules Not included i 9

n Any Functional Area I240 2 $IF Zo 5 TOTus /3 / . ' ~ ^ ' ' *

    • en--we

-e ,m, ,),,

,3rsSMEtMf @J LWmf3S%Lb ULoa ve.Fwme - a 7 /).- / ~ NUMBER AND NATURE OF ENFORCEMENT ITEMS - Plants under Construction Mi DLQ ) Dociet No. 32f / y, unit Fccility Name. Noncompliances and Deviations [nvestigation Functional Areas

4. Inspection Severity Levels Catecories Manhours I

II III IV V VI Violl Infr. Def. Dev N

1. Quality Assurance j

Foundations ymM 1 I

2. Sita Preparation and
3. Containment Structures

%g J4. Safety-Related O Structures a ' 5. Piping and Hangers 93/7 / y /

6. 5stury-Related C

Components

7. Electrical

-/(;'74/lL [ 8. Instrumentation

9. Fire Protection 7 {g

^

10. Preservice Inspection g

/ ' 11. Corrective Action and y / R3portin9 T M ~

12. Procurement l 13. Design and Design O

f Changes I-14. Training

  • O
15. 'lant operations Preparation O
16. Fuel Loading Prepara-g

[ tion O 17.-Maintenance C

18. Sscurity & Safeguards Tw/NL O

..m - - f

19. Surveillance and Pre.

( OfelATsCv11 TssTnaq O

20. Emergency Planning
21. Audits, Reviews, and Committee activities p

/ 22. Modules Not included in f /y h ~ -s [' Any Functional Area 12605n M M i 2L 3 i -Aw O ~ Che.cIS e"f cap. pnd, I-.- --. _.. _ -,. _.... _... _ _ _ _ _.,,,,., _ _ _,,, _,, _ _, .,_..________.-_,--__.._....u:;..

Oi pstEsa u a w. ..s-...-- NUMBER.MD NATURE OF ENFORCEMENT ITEMS - Plants under Construction Uniti k y, M / b[MNO Docketf3. Facility Name w Noncompliances and Deviations Envestigation 1 Cateoories Severity Levels functional Areas E. Inspection .l II III IV V VI Violl Infr. Def.' Dev Manhours I 1.-Quality Assurance 7J l

2. Site Preparation and g

f A l = ~ Ecundations

3. Containment Structures yp 4 Safety-Related

~O Structitres

5. Piping and Hangers 3d ff

/ Q

6. Sutety-Related

@7 Components Q [

7. Electrical ig' gy
8. Instrumentation O
9. Fire Protection Gg
10. Preservice Inspection g

g

11. Corrective Action and

/ 10 Reporting

12. Procurement
13. Design and Design 0

Changes

14. Training g
15. Plant Operations Preparation g
16. Yuel Loading Prepara-tion G

l

17. Maintenance-O
18. Security & Safeguards g

f

19. Surveillance and Pre I

Ofl9ATIO7Al. TESTINE O

20. Emergency Planning i
21. Audits, Reviews, and O

Committee activities 3 a j

22. Modules Not included i

~wr O I a n cem t Any Functional Area .s .m ~ 4/ l /5 ..i.. ---.-w-.- ~,,-m.--..-,y--------.--_m ,.,,,,.--.--<-g y---

~.. 1980 REPORTS.. I T ~ I2._ ^ l 171'EC- , z 488 OPENEi> C1. .2 :e v o lJ: V -. TOPIC 329/80-13 Foster / 2/27 to 330/80-13 Tnata11ation P15 7 Erb 5/2 L l Identification of Problems P15 8 j N,_ f Consultant Review 'P15_ 9 / 4 N Management Meeting P15 10 + N ~ ~. 329/80-14 fa,5Src 1 ICeppler 330/80-'15 Meeeina eonducted in Glen E11vn to discums the & S em ff ~ 4 /? Midland RV holddown anchor bolt failures .329/80-17-01 9f}f-15 i 330/80-18-01 Licensee Action on IE Bulletin 80-08 P2 Ma,A A /19.11 An_g7/go /c - 7 9 sr O 10 '7 3nbL 329/8f-17 N - 73 " 5.5 - 330/80-18 Review of Revised PSI Procedure P3 2 ~ y j Material Certifications P4 3 (NDE) Personnel Certifications P4 4 i,l q Observation of Work and Work Activities P4 5 N 1 Review of Data Reports and Audits PS 6 l 3zy/ au-u-UZ i 330/80-10-02 Independent Inspection - Graver radiographs PS 7a Ref. 80-07, 80-27/28, 81-02, 81-06

f,p mi ou u-va 330/80-18-03 Bechtel Purchased Pipe from Grinnel P6 7c 80-27/28 i

t- .ere pr- +---ms-+we

  • +w-+--+-we.

,w-- e e4,,, * -, - ~.,. .w.. r-,-,--y, ,g-r-**w-*ema e-e,_

e--ww-e-,+e+-e-c.d+ec e eg e w++

w-- +

.i ~ 1980 REPORTS.- N~ ? TOPlc khd OPENED' CI,05Lb I ' f.l : rp JZ9/su-ZU 330/_80-21' Reactor Coolant Pressure Boundary Piping - Observa-Lee 7/8-10 tion of Work and Work Activities (Unit 2) P2 i ' ((,#h] J 1/ ~ "' / "~ Reactor Coolant Pressure Boundary Piping - Welding Material Control (Units 1 and 2) P3 2 i ',

\\\\

! I i Reactor Coolant Pressure Boundary Piping - Obser-k 'vation of Welding Activities (Units 1 and 2) P3 3 4 Reactor Coolane Pressure Boundavv Pinine - Waldar h Oualification (Unien 1 and 21 P/4 4 Raf. R0-01 329/80-20-01 330/80-21-01 Safety Related Pinine - Welaine Materist conerof (Units 1 and 2) P4 5 8, F. fro - 2 e,/29 ~ 389/80.-20 h 330/80-21 Safety Related Pipina - Observation of Weldine Activities (Unit 1) PS 6 L Safety Related Piping - Observation of NDE 1 Activities (Unit 1) PS 7 1 i J Z9 /.su-Zu-02 330/80-21-02 Safety Related Water Storage Tanks Fabricated by i Graver Company - Tank No.1T lack of fusion IN \\. may exise P6 8b M $ \\ ( 329/80-23

g 330/80-24 Construction Schadules P2 1 h enh f n A/10 99 3

g Part 21 Items P2 2

8

.y

S L.-,_. ra:: ~:::.:::::.L...-..

.:i:L.,:::2.-..--

~ $~ 1980 REPORTS TOPIC 1 V5K " orzuzu' Ctosti, N 'g i Jzy/so-za va11agner -:(i 330/80-26 contat=nant Prestressing System P3 1 Landsman 8/27-29 ? 13 - ~/ N i.5 e., ,fc ,d ~ Meeting on Soils Issue at CPCo Office FM 329/80-27 330/80-28 Licensee Action on IE Bulletin 80-08 P3 Ward 9/23-24 Ref. 80-17/18-01 'F--[ 5[)N e- . 3cif Procedure and Manual Review P3 2 Material and Equipment Certification P6 3

~!..

N 3 NDE Personnel Certifications P7 4 .Ni ) Observation,of Work and Work Activities P7 5 r Review of Data Reports and Audits P8 6 .) s-k N' Independent Inspection - Allegations - Allegation 1-I' I Radiographic location markers removed from piping .Q ( \\ systems for inservice insp. not. replaced accurately. P8 7 l l' Conclusion - Allegation substantiated P9 7 L 1 Independent Inspection - Allegations - Allegation 2-n l Radiographer used wrong source. P9 7 j f L A w-r m-. l r j f Conclusion - Allegation not substantiated P9 7 [ F, 9/-c 1, Y. N, ?,..-,, n,_. .l,,,.e._, .,.,,N

1980 REPORTS. . M ~" - IUS1'ECo L - ft l TOPIC 408 ll OPENED L C1.05L i. N 329/80-23 4 - 330/80-24 New CPCo OA Organization P3 3 iutphin 8/19-22 5 ,j N 3 Zack Company Status P3'4 .N .E ' 50.55(e) - Unit 2 contairunent rebar spacing P3 5 N i 50.55(e) - Unit 2 containment fire P3 5 ^ 50.55(e) Missing rebar P3 5 329/80 330/80-25 Ev==f nntion of the licensee 's ore-ooerational Greer 8/26 radiolonical and nonradiolonical environmental monitorine oroer===. construction ohnse envir'on; mental orotection oronram and their 4=nla=entation. P2 2 ) T i Environmental Program Management P2 3 4 . Radiological Environmental Monitoring Program P2 4 Ref. 79-07 i^ \\jy !j la Non-radiologican Environmental Monitoring Program ik - P3 5 t M a( i. Meteorological Monitoring Program P3 6 i ~ Environmental Protection P3 7 ,y ,.,.. ~, - ...v.,, ,,v.

1980 REPORTS b-W5 s 'EOP8C kht OPENED ' C1.0SLis 329/80-27 330/80-28 Indeoendent. Insnection - Allegations - Allenation 3 Ward 9/23-24 i 7 # # d _E Field radiographs do' not meet the required geomet- /C A 73 c. 5.5 ,N-ric unsharpness P9 7 d g. g.f e z '5 Is tW ) Conclusion - Allegation substantiated A'+ G. 9-/-c z D 'Indeoendent Inanection - Alleontinna - A11eemeinn 4 4 !.1 1 4 Y ~ Manmoement instructed radionranhar to trim film to 'N~ eliminats " bad" shoo weld. P10 7 4 C Tr-/-a2 Yk l-Conclusion - A11eention not subsenntiated Pio 7 4 1 L 9, 9-I-c '1-329/80-28 330/80-29 50.55(e) ITT Grinnall Feeduster Pinen C1nand Tan o/94 9 f5-2s2pr f-JSJ 73 )] P2 Re f. IE Renort No. 99900019/80-01 _ -[ 3,fsc s-3 i T _99< 5*/ Reactor Coolant Pressure Boundary Pioine - Weldine A Material Control (Units 1 and 2) P3 1 y s N Reactor Coolant Pressure Boundary Pinine - Obser-1, - [ vation of Weldina Activities (Unit 1) P3 2 i e 330/80-29-01 Reactor Coolant Pressure Boundary Pipina - Visual i Examination of Welds (Unit 2) P4 3

1 i

329/80-28 330/80-29 Reactor Coolant Pressure Boundary Pipina - Welder Qualification (Units 1 and 2) P4 4 Ref. 80-20/21 I I ] Relocation of Pressurizer Level Sensing Nozzles ^ I~ (thf e 2 P5 5 .y, _,,,,, p .,,m,

W*' 1980 REPORTS. kh OPENED ' CLOSLis l-TOPIC 1 f/ 329/80-28 -11n/B0-94 Ranctor Coolant Praaanre Boundarv Pinine - Observa-Lee 9/71-25 l' tion of NDE Activities (Unit 1) P5 6 1 Reactor Coolant Pressure Boundary Piping - Obser-vation of Work and Work Activities (Unit 2) P5 7 k ~k Safety Related Piping - Observation of Welding Activities (Units 1 and 2) P6 8 N i Safety Related Piping - Observation of NDE Activities (Unit 2) P6 9 (/g,% 1 J4W/5U-JU Naidu/ f 330/80-31 IE Bulletins Closed 03, 75-06, 76-02, 76-03,

Sutphin,
720-2.1 76-05, 77 01, 77-02, 77-05 & 05A, 78-05, 79-01, 7 - 5/ C 5'/

i 79-09, 79-11, 79-23 P6 Review of Licensee Action Taken on IE Bulletins Re-Identified For Action by NRC Division of Licen-sing, Sept. 4, 1980 - Reopened Bulletin 79-21 s , i. Reopened Bulletin 80-06 P7 N %N 'N Review of Licensee Action Taken on IE Circulars Open 02, 77-06, 79-02, 79-17, 79-20, 77-16, 1 78-08 Closed 77-09, 78-18, 79-23 P8 5 CPCo Quality Assurance Organization P10 la Construction Schedules P10 lb

s 1980 REPORTS. I YW h1 Nbb OPENED i CLOSLv e TOPIC 329/80-30 Naidu.' y 330/80-31 On-Site Desien Activity P10 1c Sutchin 9/23-25 l 50.55(e) Personnel Air Locks Pil 2 s 329/80-30 330/80-31-01 Observation of Installed Electrical Equipment Units 1 & 2 - Battery Rack Specification Revision P13 la Ref. 81-12 / 329/80-30-02 330/80-31-02 Observation of Installed Electrical Ecuipment s Units 1 & 2 - Reinspection of welds on Main Control 4 Board Panels P15 le Y 329/80-30-03 ~ -330/80-31-03 Review of QA Records - Battery Chareer Test Docti-s. mentation.P16 2e Ref. 81-12 329/80.-30 330/80~-31 Review of Nonconformance Reports P18 3 Review of Equipment Verification Activities P18 4 p 329/60-32 Landsman / T 330/80-33 Background - Soil Settlement P2 1 Gallagher 12/11 Gilray .d+ ? >l Purpose of Inspection - To verify implementation of the specific comitments and action items re-flected in CPC response to 10 CFR 50.34(f) Questions 4 e 1 and 23 P3 2 f,4 pj_,j 389/80-32-01 /~ ^~~' ~~" ' Z W-/2 130/80-33-01

r. ~ mi _.

c._ m.,n ~ ,s, r = = 2 w provide-a,.,u ne m a a - s = _ - b iz.t;;f;;= ;;.: c1 Ps 2= 3_ .. 7 7..

-tm.. G -s D ... 1980 REPORTS '.) TOPIC l b OPENED lCLOSLD t J4y/cu-J4-Uz {pg 330/_80-33-02 Failure to maintain design interface and coordi-( faI !12/11 1 R' 'nator control P5 3b' 4r 329/80-32-03 330/80-33-03 Failuva to nernr4 Am m Amann s-a Ammign (nea.#=a= 81-12 )) control' P6 3e(1) 9 J4W/ au-Jz-Ur+ 330/80-33-04 Specification C-208 Consments Ref. 81-12 P7 3c (2). (3), (4),(5) & (6) j 329/80-32-05 3 330/80-33-05. Specification C-211 Consnents P7 3d(1), ( 2), (3). ' M, ~ & (4) Ref. 81-12 l h 4 't( 329/80-32-06 330/80-33-06 Review of Question.1, Par.c (b) and Question 23.* Part (2). Failure to Provide Adequate Corrective Action with Regard to Identified Au'dit Results P7 4 J 4W/ 5U-J Z j .330/80-33 Review of Question 1, Part (c) and Question 23, Part (3) P9 5 3ai&&-33 330/80-34 Steam Generator and Presisurizar Modifications, Erb 12/1-4 l~ $de d> / Units 1 and 2 P2 1 e. ce r 6 3

g. S e c t.5

/- Sc 0 ') / /-3cccj L-fcs o ?.3 Observation of Guide Blocks on Lower Internals

  1. . Sed 75 g-Sc C JY Unit 2 P3 2

.> Wy 1P<11.Cd G & (c [. QA Documentation on Safety Related Components, Units 1 and 2 P3 3 .....,......~..-.....,...,..-.,.....L...---.. ... ~ ~........... - ...,. ~., - -.

\\l ^ }}.>? - / : L ~. /- 1980 REPQRTS liiSPECo +l f/ TOPIC' 40d OPENED C1.05 L ie 329/50-33-01 y,' 330/80-34-01 Embedded Bolts for Attachment of Primary Coolant Erb 12/1-4 I Snubbers to Concrete' Wall - Some bolts below the minimum specified hardness of 31 - 39 RC P4 4 1 329/80-35 Keppler 330/80-36 Management Meetine Held on 11/24/80 at the Holidav & Memff 11/9A Inn, Jackson - Evaluation of Activities Authorized N s by NRC Construction Permits No. CPPR-81 and No. CPPR-82 y H Maior Observations P2 3 Ref. 80-36/37 S + 9 e n.- ......,.....-..., ~.. ....n..nn.

' '~ ~ '~ ~ ^ '~ ' 1981 REPORTS ___e .'.1.

  • g0PIC AN h i OPENED 1 CLOSLa-k 329/51-01

"**&"sRa"Itl 330/81-01 CPCo Quality Assurance Ornanization P5 la Pnin 1/7-9 u ..j Construction Schedule P5 lb Onsite Design Activity PS ic 50.55(e) Personnel Air Laelen PS 2a 329/81-01-01 330/81-01-01 Review of Onsite Soils Works Activition - InmAm-ni 19 I quate laboratory and field test nrocedures for M the control of soil testina activities. P6 la 'h 329/81-01-02 M 330/81-01-05 Doctament Control For Soils Work 81-12 Mammuren have n Y not been established to control the iman=nem of doctaments which affect auslity activitian PB lb ' l\\ Ref. 81-06 A f, p/. o 3 i 329/81-01-02 - 330/81-01-03 Soils Test Race 's - Soil emme renorta are nae int. m1 19 g/ tialed or datec and there were no amenhlfahad canerale an cha use of a rubber sienature s e==. P8 lefli Ife F. S I-c3 - 329/51-01-04 l 330/81-01-04 Test results (when densities exceed certain values 1 A1.19 ' reviews do not meet the requirements. P9 1c(21 Y Review of Nonconformance Reports P9 Id J u/aA-ul-um 330/81-01-05 Qualifications of Onsite Geotechnical Engineer W-n.- Y, P10 le f v 4 e sp.. en-ee..+ ep+ee e# e e%.. ...e, w o e, e+=, e; ew., ee-w e-se a w .*w' -==.e eewow n+...w.

o. en ee..

e..-.em m e.

~ ,,,,..,, _.,,. ;.. f 1981 REPORT.S s - - - ~ ' bh l OPCW CWSUh

  • l;
  1. 7 TOPIC

-T(,/ Jzy/st-ul-au.ane) 1ahg/ '330/81-01 Borated Water Storage Tank Reanalysis P10 2 uEp n 1/7-9 329/81-02 ' I 330/81-02 Licensee

  • Action on IE Bulletin P2 Ward 1/9.20-21
n.. 72.s4

,e i.5 c i ( Procedure Review P3 lb At _y,p g4 v ..N i Material and Equipinent Certification P3 le I % NDE Personnel Certifications P3 Id* s. / Observation of Work Activities P4 le t a [ Review of Data Reports P4 If Independent Inspection 'P4 2 Ref. 80-27/28 Jzy/su 1/27-29 330/81-03 Ccessents on Woolney Submittal P4 Sutphin 4/14-16 .-} U i 50.55(e) Personnel Airlocks P4 Ref. 80-01-03/03 f +j.

  • I,,

Licensee Action on IE Bulletins Yi Closed 79-05A, 79-08, 79-13, 79-13 Rev. 2, 79-21, ,qy 79-26, 80-05' - Open 79-14 y f q } Reactor Internals Vent Valves - Status of Instal-n L. ' lation, Unit 2 P7 1 Ref. 81-04 ,) j.V 329/81-03-OL 330 /81-03-0 L Midland Plant Procedures For the Processing of .nA Tnfar,nneinn Notices .._.,_ - as m -, r' #,,,.. 1. t Z.., 7 ~1, _ 719 T!"."CZZ.~C1;7* *Zi"', !ll*;_,*.C.TZ,C*'*C,_*1*C "~J'- .l'T * ' " *' ~C C _.CC,*C,*Z:22 L_._ _

/:.,- / -.+...a. }; .] s. 1981 REPORTS s-o TOP 1C , 1;;si'EC 4 e. I Aun i OPENED ' C1.05Li s s PJ 329/81-05 Keppler 11n/al nc; M,. c i n e-in cien Ellyn en discuss the Midland Project & Staff 3/13 4% I N IV8 Reorganization and Q'uality Assurance Program Yf update and modifications. 329/81-06 330/81-06 General - Third of four allegations resolved P3 1 Ward 3/18 & 5/12 '( Ref. 80-27/28. 79-20/21. 80-03. 80-17/18. 81-02 /t - 7%3L -) sc -,1c S J /c-yJe.5.5 [ Preservice Inspection P3 2 5 ,s y Independent Inspection PS 2 329/81-09 3/25-27 )1 330/81-09 Purpose of Inspection - to verify the quality a su-

,andsman 4/7 0 I

( rance program for the soil -borings P3 2 / 2/80 $ / S

?

4 N Review of Drilling Procedures P3 3 [ 329/51-09-01 330/81-09-01 Review of Contract Documents - Apl roval of Woodward-Clyde as a principal supplier of services was not complete prior to commencing soil boring activities. PS 4 ) 329/81-11-01 Sealing of cable ends. '/ - S' / c 0'/ pardner / d 330/81-11-01 Observation of Electrical Work Activities P2 la Love 4/28-30 / - 3;cSi S t O I. t / 7 9/51-11-02 /- 5 20.5/ 7-5/CD) ? y-330/81-11-02 Failure to prescribe activities affecting quality by documented procedures P4 lb A 329/81-11-03 an adeaunea 4nanaceinn Pli l e ' ~,} ii i-i=11=== Failure en perform { Failure to identify and control nonconforming 329/81-11-04 jA JJ'''' " conditionc P7 Id

7..

7,<, y. 7,-- ~ t J 4 I' T E REPORTS 'I O '- TOPIC hh OPENED i CLO5L

  • 329/81-11-03 7 - 5 /c(.J Gardner/

330/81-11-04 /endor wiring in Class 1E Battery Charger 1D17 is iove 4/28-30 I terminated w'th spaded lugs. P7 le [ 329/81-11. i - f/ r o / -330/81-11-05 Iteview of QfL Implementing Procedures - Terminatioris - 1 Failure to prescribe activities affeccing quality by documented procedures P8 2 329/51-11-07 j-f.2c5 / j 330/81-11-06 Review of Instrumentation Installation - Specifica-tions and Procedures - Failure to assure requirements were correctly translated into specifications, drawings, procedures and instructions. P9 3a 4 329/81-12 Team 3 14n/ai-19 50.55(e) Under' sized Wire Installed in the Control Insoec. 5/18-22 r/.a I Room Makeoup. Filter Drain Heater Units - Closed P7 2a / ' ' #' O ' I 7-3/CL 3 Ref. 78-13 /- S'/e65 i y.. Sec 7c ib 50.55(e) Inadequate Crimping in Vendor Supplied k '+ Electrical Penetrations.- Open P7 2b Ref. 78-12 i 4 i 329/51-12-01 330/81-12-01 Problem Areas Identified - Need to be more specific N in the administration and organizations 1 relation-I [ ships of the Bechtel site construction management A and quality control organizations, in regard to the tv L coordination, interface and working relationships between the two organizations. P 9 2b 3 i Positive Consnents P10 3 ?- j i .l, 122.

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,,. v. 'n.~ r - t 1981 REPORTS Nk j Orct;El> CLOSLa TOPIC 329/81-12 Team 330/81-12 Obiectives of the Inspection - to verify that current Inso. 5/18-22 i' Quality Assurance Pronram description and i=.1===n-N tation met recuirements of 10 CFR Part 50. Annendix B ? and other licensee couanitments. Pil 1 i' General Areas Inspected P11 2 l 329/81-12-02 g6 '\\ 330/81-12-02 Review of NSSS Nonconformance Renorts (NCRs) h Verification of the as-built conditions after " Proof Testina" was not accomplished. P13 3a-329/81-12-03 g- '\\ 330/81-12-03 Core Sunoort Assembiv Guide Block Positionine and Welding - Engineerina data associated with motion' of the auide blocks. P13 3b .a i Review of Consumers Power Company Nonconformance i Repores (NCR's) P13 4 7 I/ #0I O iw j. Review of Bechtel Corporation Nonconformance ~ Reports (NCR's) P13 5 7 - 8/ e 4.5 ['" Selection of Sampling Periods P14 6 i, Q I. d Conclusions P15 7 .:rW& QA Staffine (Civil Area) P16 1 4 l i - JZW/ 51-1Z-U4 330/81-12-04 Trend Analysis and Evaluation - Cons'-rs h.. not '3,' ...by Procedure M-2 in that appropriate corrective action ..., =., .s. e...,...,......... cnumitments. wore nne earahlfahed hv.che annt .~ onriara... fad 4*4a.. 1._ . oi a. s _ . _ _, ~. _ _ _.

9lc 9 i. ~/ J w L -. 6 1981 REPORTS 0 TOPIC kh OPCliEl> j C1.0$Li' 329/81-12-04 Team 3 _330/81-12-04 Nonconformance Report Reviews - Failure to take Insp. 5/18-22 ). ' adequate corrective actiion regarding an identified 4 i adverse trend P20 3 \\ 329/81-12 P20 4 330/81-12 Design Control of Block Walls Overinspection Plans and Implementation P20 5 329/81-12-05 330/81-12-05 Pemanent Dewatering System P21 6 329/81-12-06 330/81-12-06 Procurement of Materials P22 7 l 329/81-12 330/81-12 Quality Assurance Audits P22 8 t L' Project Quality Control Instructions P22 9 Failure to pe f an ad te ins ection 7'8/C03 h Observation oh E$ctrica$b"$rk Act$vities - Temina-330/81-12-07 tions P24 la \\ 329/81-12-07 / - 5/ 0 (. 73 330/81-12-08 Observation of Elecerf ent Unrk Aceivief na - Tomi nn-tions - No insnection olan for the reterminnefnn nf all electrical nover and control cables P24 lb 329/81-12-08 D 330/81-12-09 Qualification of OC Inspectors - Electrical - \\ N< M*[, Qualification and Certification of Electrical OC & $ O [a ,~ E Inspectors Questionable P25 2 329/81-12-09 N 330/81-12-10 Review of Raceway Rework Controls - Licensee's g ~e er ~n ,n114n, ehn rounck nf 4 ema nreviousiv. inspected and accepted by QC. P28 3

' ~ ~ ~ "p,;,. /, ... r 1981 REPORTS TOPIC kW Ol' ENCL > ' C1.0$L '} 3 329/51-12 Team 330/81-12 Review of Quality Assurance Records - Quality Action Insp/ 5/18-22 Requests k Storane of Electric Cable - Cable Storane Yard P30 5 329/81-12 330/81-12 Review of Procedures and Specifications P31 1 t i f - JC C '7 0 'g Inspection of Large Bore Pipe Suspension System Component Installations P32 2 329/81-12-10 f. 5 c c. 9 e 330/81-12-11 Rigid Frame Restraint 18-1 HOB-2-Hie P3 2e 329/81-12-11 5-5 Co '7 C 330/81-12-12 Deficiency in the pipe hanger program. P34 2c-1 a, .d' 329/81-12-12 g 330/81-12-13 Failure of the QC inspectors to identify the installation deficiencies Per 2 329/81-12-13 5 - M r'*7 C ' 110/81-12-14 Raviav of Site Small Bara Pinino namien Aceivirtan Failure to doce===ne s trana emiculmeinna nefnr en issuance of drawinen for construction P35 3a 329/81-12-14 330/81-12-15 Document Control - Soecifications and calculatione not up to date. P36 ab 329/81-12-15 f-So e 70 330/81-12-16 Control of Installation Channes - Procedural orovi-sions to control the effects of design revisions on semil bore piping and piping suspension systems were questionable. P36 3c

"'^*o _ 1981 REPORTS 'l ol TOPIC kb Ol'EliED ' C 05L3 329/81-12-15 5- .3 c c. ' c Team 7 330/81-12-16 Audits of Site'Small Bore Pirina Design Activities - Inso. 5/18-22 I Inadequate audits and surve:.11ances of the site small bore pipe and hanger design activities. P37 4a&b IMMEDIATE ACTION LETTER issued 5/22/81 4p,y/_,y / 329/81-14 7/ 7 330/81-14 Followup on T-diate Action Letter. (IAL) Items Yin - 7 23-?& P2 1 / 329/81-14-01 FollowuponAllegation-Fieldchannepro/ 330/81-14-01 cedures '/ used at the site for smal'1 bore wioinz and einine N supports. PS 2 - Inadeaua e desion control involving the RE review of th edline drawi s\\P7 #,A U-a ./ \\ Manaaement'/ 329/81-14 N Exit Meetina - Small Pininn and Pine \\" 330/81-14 Hans/ \\ er Review Status Presented by CP Management P7 1 N / \\ s-Positions and General Comments Noted by the Region III Management P8 2 1 (

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D $ N 2 M [C / OIN1980 REPORTS /d 5, </#.i f ,6D ~ TOPIC HPT #' F 4EI) C1.0S .y .3 /p / 80-19 4 32' Investination - Unlicensed Radiocrachics P3(3) 80-20 6/1-30 2% / ',y 'r 13' Investination - Const on Activities-Pertaining to Installa- /- tion of HVAC Svstame P3(4) Ref. /11: 80-12/13: 80-16/17: 80-18/19: 80-22/23 / N Sc. 6 R< 3 SwS5 ),. 34 Per el Airlock Door P3 (5) Ref. 80-15/16: 78-04 / \\ 7-

5) c' J 80 31 1

35 UNRESOLVED ITEM - Class 1E ilectrical Conduit Clamo Installation 80 31 S/-/( P4(6) Ref. 80-18/19 80-21 36 Zack Quality Assurance Manual Review P4(1) 80-22 7/16-1 1 37 Consumars Power Cormany Overview Activity P4(2) Re f. 80-29/80 ~ l7 .I: 38 Zack Ornanization Review P5(3) 4

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39 Material Reassessment Review - Dron-in Anchor Bolts P5(4a) ] 40 Material Renamenemnnt Review - Weldine to 3 /4" and abnvn bane .( metal P6(4b) gj %g s p n{e eg 41 Material Reannessment Review - Haneer Reinenection P7(4c) l 42 Reinspection Overview - Bechtel Corooration OC P8(Sa) 43 Licensee Corrective Action P8(6) 7......,...

1980 REPORTS d'* i f /- e r P ~ TOPIC MPT # OPENE D CLO! 80-21 44 Classification of Fire Dampers and Other Components as 80-22 7/16-1 5 [ ~ ( M s:~/ -- #9 y2as / Equipment P9(7) ,3o 70 3 N70(. L5 [ TEM OF NONCOMPLIANCE - Qualification of Zack Co. Welders 80-21/22-01 r/-e-P10(8) Region letter requested response - Report Details section indicated no response needed. p# 46 Material Certification P10(9) > g[ 47 Welding Parameter Verification P11(10) [ 48 Exit Interview - Pertained to Zack Co. Items Requiring Resolution before Stop Work Order could be lif ted. Also referred to telecom between CPCo, RIII, Resident Inspector & Bechtel lif ting Stop Work Order on Zack P12 80-22 7 49 Detensioning of Reartor Vessel Holddown Bolts P2(2) Ref. 80-26/2 7 80-23 7/1-31 i 80-12/13 80-16/17; 80-18/19 n' 50 Follow-up Review of Corrective Measures for Installation of q HVAC Systems P3(3) Ref, 80-21/22: 80-26/27 l / 80-22 y 51 Investination - Construction Activities Pertaining to Installation 80-23 of HVAC Systems P3(4) Ref. 80-10/11. 12/13. 16/17. 18/19. 19/20 52 Caseload Forecast Panel P3(5) i ~... _. _.

-i, ;.,*# TOPIC Hi"r # Ol'I'NI;lj,1 '!.' 80-26 Detensioalae of *-=ctor Vessel'Holddown Bolts P2(2) Ref. 80-22/23 80-27 M/1-31 53 N ' 80 12/13; 80-16/17: 80-18/19 n i 54 Follow-up Review of Corrective Measures for Installation of MVAC Systems P3(3) Ref. 80-21/22'; 80-22/23 p a 50-29 55 Meeting With Soils Hearing Petitioners P3(2) 80-30 9/1-30 i 80-29-C 1 H%kk 56 -e to Diesel Geamrator Electrical Rotor P3(3) Raf. 80-31/32 80 10-f 1 dy-f/ C O l 57 Weldina Procedure chma-am for Installation of HVAC Syst 2 4 9 Ref. 80-21/22 i j, 7 )/ L. 54 Timeliness of QC Inssections for Installation of HVAC Syst-- f [ 74(5) Ref. 80-21/22 L i B0-31 9 59 Quality Control Classification of Diesel Fuel Oil P3(2) W-32 10/1-31 60 Alignment of Unit 1 Reactor Coolant Pumps P3(3) TOOD t V 61 HVAC System Fire Despers P3(4) Ref. 80-34/35 l 3p-- f f 62 Mydrostatic Test of Borsted Water Storage Tanks P4(5) k eem (; Installation of Level Sensing Nossles for Unit 2"B" Steau i 63 i le h ~ Generator P4(6) ON ( 4 I' s ( i .. ~.. _. _ __, _... _._ _ _. _. _.. _.... _.,

_ 4 - t "W ' i 1980 REPORTS ,' t 1OPIC H Pr # OPEEI). fi 80-31 64 Installation of Level Sensing Nozzles in the Unie 2 Pressurizer 80-32 10/1-11 P4(7) .f 65 Channes hSite Management)P5(8) - 80-31-O L 66 ITEM OF NONCOMPLIANCE - Transamerica Delaval, Inc.,10 CFR 50 80-32-0 L

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1 art 21 Notification P5(9) P 67 (0 pen) UNRESOLV$D ITEM 80-29/30-01 80-34 68 Transamerica Delaval, Inc.,' 10 CFR Part 21 Notification - Link Rod 80-35 11/1-30 Defect P2(1) 80-34-01 69 HVAC System Fire Dampers P2(2) Ref. 80-31/32 80-35-0 1 70 Systematic Assessment of Licensee Performance (SALP) Meetings P3(3) 71 Mounting of Safety Related Power Station Transferiners P3(4) ? 72 Changes in Site Management P4(5) 50-37 i 73 Closed Noncompliance (50-330/79-13-01) Hydrostatic Test of 80-38 12/1-3 L i Unie ? fnenem T nn ersona n e Tante 7T-A7 P7 74 Consi-rs Power Audits of the Zack Co. P3(14 fc/A, C,# 12wk I A c. 91. c */ . ~...

1981 REP 6RTS [..5, c/. A TOPIC HPT # OPENEl) CLOSL 1/1-31 1 CPCO Audies af the 7mah ca-71(2) Im F. no-17/1A 31 na g/1.1A 2 Peasanem'af Flu 44 in 150 McM-1/c R-11 P - e P= kin D1(1) H H J R f. 79-11. 70-1s. 70 27 an na. *_ 3 so.ssta) Ye.- - U ' eene d T..-4a.1 see4.. on t.4-4e= =. v.1 n n

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Oserators M(4) Respons n [uir:d 4 Tantallatiaa of Core Smart An-- 'iv Vane Valvan M(5) E9dko1 n (Failttre to e - 1w with nroviniaaa of ="" Quatiev caneral Pr-a A -a Ma. 9-c7-101) /C A 9/.o3 ITsu or NONCOMPLIANCR 330/ s r.it. -. en h a an --,-i.e. me-A 4----4h4 -

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4--e t. al nt-a a-1meda= of *ha wa=* waivaa. Pd /.E Dr.e 4 2/ 13 -2 6 C1---d "--- -14==== 80-31 01. 80-32-01 P2(2) R1 07 1/1 11 7 ties canen - It=== noted *kn e a-af ek. A -=== n=A afa. H 'H menem== in a lava==n aram en eka an=e af Unie 1 ennem4 - me uma daearinemetam. Pall.) 8 fra- - rien Delaval. Tam 10 CFR Part 21 Natif4amelan - Turba. e. \\ ahnener Thrust Bear 4== Arientian F3(3e) 9 Transamarios Delaval. Inc.,10 CFR Part 21 Notification - Link Rod'Defoot P3(3b) wk. . attsas in = - .Ef r e We= se. 4 d $.,ge-eevesp e-De e ma ge rn e es. .e eg 4seesun ere ses, e ge heyee q u e,m e +4m a.cowe < an emed aw e e +$.pesee-emeree *eeep -go o w m gr 'eser = e.

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I e,,/ d.6 P 1981 REPORTS TOPIC HPT # OPENE D CLOF 2/15-2E 11 Soil Borinses P4(3e) A-f.9/./c.. 5 / /3 81-07 3/1-31 s //YJ-fepr t # 9/-csr' &7 ef S801r skic s:- b,eiz,-C1) Af75R n.vj->r S') c 2 4//-50 12 (Closed) Unresolved Item 50-329/80-19-01: 50-330/80-20-01 P2(2) 81-10 4/1-30 6 2 e c ~i n r % t. Ccev o w' t T (WM r .~ '13 Site Tours - Mr. D. Hood, NRR Project Manager & Ms. E. Brown, Office of the Executive Legal Director accompanied the inspector on'one of his tours while those areas being discussed as part of the soil settlement issues were examined. P3(3a) 14 l Examination of Lavdown Area P3(3b) 15 Ouality Control Classification of Diesel Fuel Oil P3(3c) 16 Soil Borines P4(3d1 [e f. F/ -/ 'T, 9-/-c 7 h 17 50.53(e) Item - Potentini Failure nf Service Waear 91,,f e n Gnene \\ to Open Pillai Nn Innger enneidered vannrenhto 1R SO.55(eT Team - Adentincy nf Mers,emirn1 Rafnfnvromane ne w 4ne Cnneninmane Pr.reerneinna P4 (1 FT p l j g 19 Invescionefon - Cnnstructinn Aceivirfoe Parenining en Tneen11n-of HVAC Systema P5(3g) Ref. Rpe. Nn. RO-10 /11 CPCn leerer ~ dated 1/30/81 20 Construction Assessment Team Insoection P2(2biRef. 81-12 R1-13 5/1-11 4....-n...._.... . - -.. -...... _.. ~. - - -...

1981 REPORTS / fa s, c' - -s P ~p TOPIC 1(l'T # Ol'l;NillJ Jjllj 21 Brine Well Samples - Velsicol Chemical Comoany P3(2c) B1-13 5/1-11 22 Soil Borings P3(2d) L F, 9/- /0 23 Site Tours - Storage Conditions were not Adequate for some Eculo. 81-08 6/1-10 P2(a)' 24 Change of QA/QC Respcnsibilities for Installation of HVAC Systems P3(b) 25 Investigation - Construction Activities Partaining to Installation of HVAC Systems P3(c) 26 Allegations - Smal1 Bore Pipe Installation P3(d) VIDIATION 27 On Site Storare of Material and Eautoment P3 (M (1) ~ Storage of Control Rod Drive (CRD) Primary AC Breakers P4 l\\ f (2) New and Spent Fuel Storage Racks P4 (3) Battery Chargers P4 f 2 '7I.. 98 A11erations - Small Bore Pine Tns en11ntinna P2 2b Raf 81 -14 R1 -11 r. 29 Management Meeting P3'2e l ~. ~.. r r 30 Meeting With Soils Settlement Hearing Intervehor P3 2d w I 31 Hearings - Soil Settlement Issues P3 2e l \\ t v l l ~ l _..._.7_.. ,-.,-a n-,,. -,-e-e.., -. -

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Cg.-s g a ,#~cx[-. t o8.3-%'c/;/ 1 'c4.g &j - ) W.',,; p/3u, ge-w'ug, M.ugn~T / / B-st b Ws-1.c lb f/ }OQ-l' l j i g/- os S///-It// /. s ,7-/-/L <r-gg%v - j 9 p a ~ <- [ < ~ u 9, y lbNfY596 %,fd( w D A, M 9 M p a..; b li 4 Q Ik. L I e k e ..._.._.._,.,......._..-.._.r..

s L A s 7)t M Consumers Power Cempany a w c.k m,,s.a, o.a.c.: ome : ma cearr.<ese.,.i e.,i i., January 10, 1983te4s w.m r.m.n no.a. J.em n m 4 enc i. tom taso4sa t .,.},-- Nuclear Regulatory CommissionMr J G Keppler, Adminis 3 , Region III 799 Roosevelt Road l Glen Ellyn, IL 60137

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MIDLAND DOCKET NOSMIDLAND NUCLEAR C0 GENE CONSTRUCTION COMPLETION PROGRAM 50-329, 50-330 \\ FILE 0655 SERIAL 20428 ~ REFERENCE REGARDING CONSTRUCTION COMPLETION , 1982, FROM NRC REGION III On December 2 GRAM members of you,r staff to discuss th1982, Consumers Power Comp Construction Completion Program e e general concept of our proposedwith Mr W detail the Construction Completi The enclo your follow up letter (Reference)n Program,sure to this letter documents in o as reouested at the meeting and in ( Since our meeting, the program h evolution. implementing methods have beenDetails have been supplied and moa 1 developed. re specific objectives and n and to be a workable and sufficiWhile the Company expects the P established. rogram, as presently constituted necessary as future needs and expe i ent framework for future action r ence dictate. cdvancement of Project goals.The Construction Completion revisions may be i It represents the best efforts of Pm is a p canagement produce an, improvement in Project insupport and quality assurance p roject ccastruction and QA implementation nel. We believe it will stallation and inspection status provide increased confidence of the NRC The quality verification effort sh built. Other aspects of the Program systems that the plant has been properly inspect Prograa, ions and scheduling interfaces, should contribut ould together with recent Consumer, including the measure to improve quality assurance and remedial soils e to that result. s Power Company commitments regardi relations between the Company and th This work, can establish c basis for im Midland. rrponsiveness to both NRC concerns a dThe Construction Co ng e NRC Region group assigned to inspect proved It is our expectation that the Program demonstrates the Company's n the particular.needs of this Proj ram, created out of a desire to enhance th ect. oc0183-0308a100 e Q Qj^,zj(> M N ,M e"-" m e. w m e 7 g .,.-.7 9 y p-- .r _,-.y,,w7 ,y w --i -

2 orderliness and quality of construction, will achieve its intended purpose and lead to the successful " completion of construction" of the Midland Plant in accordance with regulatory requirements. We hope that this submittal fulfills your request for written information regarding the Construction Completion Program. Consumers Power Company is prepared to support the public meeting proposed for January 26, 1983 in Midland, Michigan. m td JVC/DMB/c1 CC Atomic Safety and Licensing Appeal Board CBechhoefer FPCowan, ASLB JHarbour, ASLB DSHood, NRC MMCherry RWHernan, NRC RJCook, Midland Resident Inspector FSKelley HRDenton, NRC WHMarshall WDPaton, NRC WDShafer, NRC RFWa rnick, h?.C BStamiris MSinclair LLBishop l I I L ~ l l 1 oc0183-0308a100

=. CONSUMERS POWER CC.IPANY s Midland Units 1 and 2 ~ Docket No 50-329, 50-330 I. Eetter Serial 20428 Dated January 10, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits its Construction Completion Program. CONSUMERS POWER COMPAhT By / j J Cook, Vice 7 resident Proj ts, Engineering and Construction Sworn and subscribed before me this L day of +,,f uAf/ 19f3 [' aztaa 0 kuRw Notary Publitt Bay County, Michigan My Commission Expires 8 - t/- f 6 oc0183-0308a100

-~ ? 4 t; Construction Completion Proaram s I Executive Summary t TieConstructionCompletionProgramhasbeenformulatedtoprovid guidance in i tVe planning and management of r.he design and quality activities necessary for completion of the construction of the Midland Nuclear Cogeneration Plant. Construction completion is defined in this Plan ~as carrying all systems to the point they are turned over to Consumers Power Company for component checkout and preoperational testing. The Construction Completion Program does not include the Remedial Soils Program which is treated in separate interactions-between Consumers Power Company and the Nuclear Regulatory Commission. Backaround i The Construction Completion Program was developed in response to a number of management concerns that have been identified during the period preceding the i initiation of the Program. The Midland Project had been proceeding at a high level of activity as it approached completion. The final transition from area construction to system completion, using punch lists, has been difficult for most nuclear projects. The Midland Project has not escaped these difficulties 4; which have been compounded due to the congested space and the continuing numerous design changes, both generally attributable to the age of the Project. These factors lead to the need for improved definition of work status, increased emphasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of systems for short-term milestones and increased effort to complete engineering ahead of field installation. I The Midland Project has been criticized by the NRC regional office as not having met their expectations for implementation of the Project's Quality i Assurance Program. The result has been that the Project management has too I often, during the past few months, been in a reactive rather than proactive posture with regard to quality assurance matters. In recognition of these conditions, management has concluded that a change in approach was needed to effectively complete the Project while maintaining high quality standards. \\: l Objectives l. The development of the Program has considered the Project's current status and p recent history and attempts to address the underlying or root causes of the L -problems currently being experienced. In order to develop the Program the i following overall objectives were established under three general headings. i. The Program must: I Improve Project Information Status By: Preparing an accurate list of to-go work against a defined baseline. ? mil 282-3489b200 ...-.i.. =, -. -=:...:==---.=..-.:

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2 i Bringinginspectionsup-to-dateandverifyingthatpastqdhlityissues have been or are being brought to resolution. T Maintaining a current status of work and quality inspections as the Project proceeds. Improve Implementation of the QA Program By: Expanding and consolidating Consumers Power Company control of the quality function. Improving the primary inspection process. Providing a uniform understanding of the quality requirements among all parties. Assure Efficient and Orderly Conduct of the Project By: Establishing an organizational structure consistent with the remaining work. Providing sufficient numbers of qualified personnel to carry out the program. Maintaining flexibility to modify the Plan as experience dictates. Description The Construction-Completion Program entails a number of major changes in the conduct of the final stages of the construction process and can be described in summary as a two phase process. First, after certain necessary preparations, the safety-related systems and [ areas of the plant will be systematically reviewed. This first phase will be carried out on an area-by-area basis, but will be accomplished mainly by teams organized with systems responsibility and a separate effort to verify the completed work. The product from this phase of the program will be a clear status of remaining installation work and a current inspection status which provides' quality verification of the existing work. The teams organized to carry out this first phase will continue to function in the second phase as the responsible organizational units to the complete the work. In order to achieve its complete set of objectives, the Program contains a number of activities and elements that support and are linked to the two major phases described above. The major components of the Plan, which are discussed in more detail in the balance of this report, can be described as follows: A significant reduction in the construction activity in the safety-related portion of the plant, material removal and a general cleanup will be carried out in preparation for installation and inspection status assessment and quality verification activities. mil 282-3489b100 i + y--- ..n.

3 f. A review will be made of equipment status to assure that the prcper lay-up precautions have been implemented to protect the egttipment until the installation work is completed. = The integration of-the Bechtel QC function into the Midland Project Quality Assurance Department (MPQAD) under Consumers Power Company management will be completed. The Consumers Power Company is carrying out recertification program of Bechtel QC inspectors, and a review of the inspection procedures to be - utilized. 1 -The system completion teams will be organized, staffed and trained according to procedures developed to define the team's work process. The systems completion teams will 1) accomplish installation and inspection status assessment, 2) perform systems construction completion and construction quality performance and 3) determine that all requirements have been met prior to functional turnover for test and operation. Quality verification of completed work will be carried out in parallel \\ I with installation and inspection status activities of the system completion teams. A series of management reviews will be carried out to carefully monitor the conduct of the Program and to revise the plan as appropriate. Review and resolution will proceed on outstanding issues related either to QA program or QA program implementation as raised by the NRC or third party overviews of the Project. ~ Third party reviews will be undertaken to monitor Project performance l and to carry out the NRC's. requirements for independent design } (, verification. Schedule Status The Program was initiated on December 2, 1982 by limiting certain ongoing safety-related work and starting preparations for the phase-one work of status assessment and quality verification activities. Since the Program also has incorporated a number of commitments made to the NRC during the past few months, activities in support of these commitments such as QC integration into MPQAD and the recertification of QC inspectors, had been initiated prior to December. Status and schedules for each element of the Plan are enumerated in the text. In general, preparation for the Phase I activities are underway and will continue through January. A pilot team to develop the procedures and training req.irements will be initiated during January. It is expected that the first mil 282-3489b100 muni sy am_ m- -e* %o-M=49 d==4P+e- = m O'--

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p x = x s areas to undergo Phase 1 status assessment will be defined and teams mobilized during March. t Quality verification of completed work will start in late January br early February. q. The Program provides for the Phase 1 results on a system or partial system to be reviewed and evaluated prior to initiating Phase 2 system completion work on that system or partial system. Management will monitor both process readiness and Phase 1 evaluation results. The major areas of continuing safety-related work are NSSS construction as performed by B&W Construction Co, HVAC work under the Zack subcontract, the Remedial Soils Program and post-turnover punch list work released to Bechtel construction by Consumers Power Company. The Zack work is currently limited until a recently identified question on welder certification is resolved. During the implementation of the Program in 1983, the JiRC Resident Inspectors can use the Plan to monitor safety-related construction activities at the site. Since a substantial prtion of the Plan directly relates to commitments made to NRC management, Consumers Power Company intends to schedule periodic reviews of Program status and progress with the h7C. 9 l l l mil 282-3489b100 8' @~* NO

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l N l s x. F TABLE OF CONTENTS 1 t S'ection Title Pm 1.0 Introduction 1 l 2.0 Preparation of The Plant 5 [ 3.0 QA/QC Orgaaization Changes 6 4.0 Program Planning 8 5.0 Program Implementation 13 o 6.0 Quality Program Review 15 7.0 Third Party Reviews 16 8.0 System Layup 19 9.0 Continuing Work Activities 20 d 4 i mil 282-3489b100 ,qy g, g y ,= g - e D "WE

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1.0 INTRODUCTION

i I The Construction Completion Program has been formulated to providi guidance in the planning and quality activities necessary for completion of the construction of the Midland Nuclear Coseneration Plant. Construction c6mpletion is defined in this Plan as carrying all systems to the point thef are turned over to Consumers Power Company for component checkout and preoperational testing. The Construction Completion Program does not include the Remedial Soils Program which is treated in separate interactions between Consumers Power Company and the Nuclear Regulatory Commission. The Construction Completion Program will be referred to as the Program in this document which contains the Plan for Program development and implementation. Backaround The Construction Completion Program is being developed in response to a number of management concerns that have been identified during the period preceding the initiation of the Program. The Midland Project had been proceeding at a . high level of activity as it approached completion. The final transition from area construction to system completion,.using punch lists, has been difficult for most nuclear projects. The Midland Project has not escaped these diffic'ulties.which have been compounded due to the congested space and the continuing numerous design changes, both generally attributable to the age of the Project. These factors lead to the need for improved definition of work status, increased. emphasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of systems for short-term milestones and increased effort to complete engineering ahead of field installation. i The Midland Project has been criticized by the Nuclear Regulatory Commission regional office as not having met their expectations for imp,lementation of the Project's Quality Assurance Program. The result has been that the Project management has too often, during the past few months, been in a reactive rather than proactive posture with regar'd to quality assurance matters. In recognition of these conditions, Consumers Power Company has concluded that a change in approach is needed to effectively complete the Project while maintaining high quality standards. j Objectives The development of the Program has considered the Project's current status and I recent history and attempts to address the underlying or root causes of the problems currently being experienced. In order to develop the Program, the following overall objectives were established under three general headings. The Program must: 1 L Improve Project Information Status By: l Preparing an accurate list cf to-go work against a defined baseline. mil 282-4106a-66-102 t l l. ' L.. _.. ,~_..1. -_- _-..--_~ ---, u. ~

...7. {' N 2 \\ Bringing inspections up-to-date and verifying that past quatlity issues have been or are being brought to resolution. T Maintaining a current status of work and quality inspection's as the Project proceeds. e-Improve Implementation of the QA Proaram By: Expanding and consolidating Consumers Power Company control of the quality function. Improving the primary inspection process. Providing a uniform understanding of the quality requirements among all parties. Assure Efficient and Orderly Conduct of the Project By: Establishing an organizational structure consistent with the remaining work. Previding sufficient numbers of qualified personnel to carry out the P.ogram. ( Maintaining flexibility to modify the Plan as experience dictates. PLAN CONTENTS 4 The Program was initiated on December 2, 1982 by limiting on going work on Q-systems to pre-defined tasks and preparing the major structures housing Q-systems for an installation and inspection status assessment and verification of completed work. The relationship of the major elements of i i the Plan is shown in Figure 1-1. The sections of the Plan address the following major activity areas: l. PREPARATION OF THE PLANT (Section 2.0) The buildings are being prepared for a status assessment and verification of completed work. QA/QC ORGANIZATION CHANGES (Section 3.0) L A new QA organization that integrates the QA and QC functions under a Consumers Power Company direct reporting relationship is being i. established. As a part of this transition, the Bechtel QC inspectors l are being recertified to increase confidence in the quality inspection performance. mil 282-4106a-66-102 .G .a-.,. m-4 a*e- - * ~ ' " "'"

l v.. 3 i l i l PROGRAM PLANNING (Section 4.0) 1 ,r The overall Plan for the Program is.being developed in two major phases. The first phase includes: A team organization assigned on the basis of systems is being developed to determine present installat. ion and inspection' status. The inspection status assessment includes performing inspections on completed work to bring them up to date. A closely coordinated effort involving the construction contractor and Consumers Power Company (QA/QC, testing and construction) will improve quality perfo rmance. The quality verification of completed work will be based, in part, son' a sampling technique using re-certified inspectors as described in Section 3.0. i The second phase includes: Following. installation and inspection status assessment the team organization will retain responsibility for systems completion work. f - The QC inspection process of new work will be integrated with the i systems completion work to ensure adequate quality performance. i l k PROGRAM IMPIIMENTATION (Section 5.0) The first phase implementation of the Program will be initiated with a review of the process, procedures and team assignments that will be used. The pl y for verification of completed work will be reviewed separately;. N e teams will~ conduct the installation and inspection status as4nsment; verification of completed and inspected ork will proceed, as planned, in coordination with the team effort Following phase 1 completion of the first work segment, a management review of the plan effectiveness will be made. In-second phase. Program implementation, the assigned team will plan and schedule the remaining work needed for completion including QC inspections. QUALITY PROGRAM REVIEW (Section 6.0) The adequacy and completeness of the quality program will be reviewed on an ongoing basis, taking into consideration questions raised by NRC inspections and findings by third party reviewers. The results of these reviews will be considered as part of the management review that are -a part of the Program implementation (Section 5). mil 282-4106a-66-102 y 7_ 9p,,s,,

e l 4 THIRD PARTY REVIEWS (Section 7.0) IndependentassessmentsoftheMidlandProjectwillprovidemanagement and NRC with evaluations of Project performance. SYSTEM LAY-UP (Section 8.0) The on-going work to protect plant equipment and systems will be augmented as necessary to provide adequate protection during implementation of this Plan. ybl* CONTINUING WORK ACTIVITIES (Section 9.0) jj Work on Q-Systems has been limited. specific activities. This limitation permitsftmo6+t=nt work o proceed while allowing building, preparation for status assessment and verification activities.

SUMMARY

Each section of this Plan presents detailed objectives, a description of the activity involved, and a schedule for achieving major milestones. The Program, however, is still in an evolutionary state and revisions to the Plan may be necessary as Consumers Power Company gains experience'in the implementation of Program elements. k mil 282-4106a-66-102 vv m- ~ - - - - - ' ' ' * " ' ' ' ' ^ ' ' ~ ' ~ ' ' " ' ~ ' " " " ' '

I i ~ FIGURE 1-1 i. .I ~ CONSTRUCTION COMPLETION PROGRAM SCHEMATIC t j PHASE 1 PHA5fE2 i a iCECTIOM PLANNING IMPLEMENTATION PLANN'ING IMPLEMENTATION j r a PREPAR ATION. c i 2 L! OF THE PLANT \\ QA/OC 3 i REORGANIZATION j-l PHASE 1 4 PHASE 2 PLANNING PLANNING j VERIFICATION j MANAGEMENT op REVIEW COMPLETED IN8PECTIONS EVALUATION SYSTEMS. 5 AND COMPLETION INSTALLATION REVIEW WORK MANAGEMENT AND REVIEW INSPECTION ) STATUS JL d j 4..,- i l 6 QUALITY PROGRAM REVIEW ]i 7 THIRD PARTY REVIEWS i-, jj O SYSTEM LAY UP 9 CONTINUING WORK ACTIVITIES 4

5 2.0 PREPARATION'0F THE PLANT 2.1 Introduction The preparation of the Plant will clear the auxiliary, diesel generator and containment buildings and the service water pump structure of materials, construction tools and equipment and temporary construction facilities. 2.2 Objective To allow improved access to systems and areas for the Program s activities. 2.3 Description The preparation activities minimize obstacles and interferences for the Program activities. This is being accomplished through the following steps. 1. Limitation of Q-work to activities and areas defined in Section 9 resulting in substantial work force reduction. 2. Removal and storage of construction tools and equipment, and temporary construction facilities (scaffolding, etc) from the buildings identified in Section 2.1. 3. Removal, control and storage of uninstalled materials from the buildings identified in Section 2.1. 4. Appropriate housekeeping of all areas following material and equipment removal. The preparation for each area will be complete before initiating further Program activity. The on going work described in Section 9 will continue as scheduled during the preparation. 2.4 ' Schedule Status 'The preparation of the Plant began on December 2, 1982. It will be complete by January 31, 1983. u sil282-4106b-66-102 w-e-,.- 7 r-., -,

?. nd 6 Wpm,% i 3.0 QA/QC ORGANIZATION CHANGES t 3.1 " Introduction r The Consumer Power Company's Midland Project Quality Assurance Department (MPQAD) is being expanded to assume direct control of Bechtel QC activities. The new organization and the plan for the transition are described below. The transferred QC Inspectors will be recertified as part of this transition. 3.2 Objectives Establish New QA/QC Organization Establish an integrated organization which includes the transition s-of Bechtel QC to MPQAD while accomplishing the following objectives: 1. Establish direct Consumers Power Company control over the QC inspection process. 2. Establish the responsibilities and roles of the QA and QC Departments in the integrated orgsaization. Use jualified 'ersonnel from existint QA and QC departments and 3. p contractors to staff key positions throughout the integrated organization. Recertify QC Inspectors Ensure that those Quality Control inspection personnel transferring to MPQAD from Bechtel will be trained and recertified in accordance with MPQAD Procedure B-3M-1. obu $ 3.3 Description @M d 8 Establish New QA/QC Organization f .. i A new organization will be implemented under Consumers Pow ( Comp y b_ and will be. described in appropriate Topical Reports (CPC-1A and BQ-TOP-1) and quality program manuals (Volume II, BQAM and NQAM). hanges to these documents will be submitted to NR Features of the new organization include: 1. I.ead QC Supervisors report directly to a QC Superintendent who g reports to the MPQAD Executive Manager. Any required support L from Bechtel Corporate QC and QA functions (except ASME N-Stamp activities) is provided at the level of the MPQAD Executive L Manager. The MPQAD Executive Manager will review the performance of lead lA personr.el in his department. a mi1282-4106c-66-102 Ihr 9\\- + 5 -m + *, ap awDuS. -*eims na .___...,,___,ee ai ee. y.,nei yp-p. .__._,.__=-93-_ _ = _. - _ - -, _ _.. e p-e + = pese e + -. _ _. +, - e_m. y eem , e er M.*- ein-e w.e . m

~ 7 4 3. QA will develop an'd issue Quality Control inspection plans and i be responsible for the technical. content and requiriaents of / such plans. QC will be responsible to implement these plans. s r 4. QA will continue to monitor the Quality Control inspection

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process to insure that program requirements are satisfactorily implemented. [ 5. MPQAD will continue to use Bechtel's Quality Control Notices 1 Manual (QCNM) and Quality Assurance Manual (BQAM) as approved for use on the Midland Project. 6. ASME requirements imposed upon a epatractor as N-Stamp holder will remain with that contractor.( QA will monitor the implementation of ASME requirements. An organization chart (Fig 3-1) showing reporting relationships in the new organization is attached. } Reeertify QC Inspectors I-The training and recertification process for QC inspectors has been revised to include commitments made during the September 29, 1982 public meeting with the NRC. Those inspectors transferred from ..Bechtel to MPQAD will be trained and examined in accordance with i MPQAD Procedure ~B-3M-1. Upon satisfactory completion of the training and examination requirements, inspection personnel will be certified for the Project Quality Control Instruction (s) (PQCI(s)) they are to implement. Inspection personnel will be certified on a schedule which supports ongoing work and system completion team t activities. 3.4 Schedule Status f Establish New Ormanization i Advise NRC of the structure of the integrated organization. 12/15/82 L Transfer the Bechtel QC Organization to MPQAD. 1/17/83 Submit changes to Topical Reports and quality program manuals to i NRC. 2/17/83 i 'Recertify QC Inspectors f Specify the revised training and examination 1.0/25/82 requirements for certification (B-3M-1). Complete recertification 4/01/83 i i. mi1282-4106c-66-102 4 j, ,2,,,, i .3 . 4e, e .---.,-...,_-.--~,',,,',-..,-.....-_,_._,r-,c.m.. _-.,_.,-.,.-.,-_x

.;i a FIGURE 3-1 MPOAD ORGANIZATION BECHTEL MIDLAND PROJECT OC PROGRAMMATIC OUALITY ASSURANCE DEPT SUPPORT i. EXECUTIVE MANAGER ASME h1 l i A, l i; QUALITY ASSURANCE I; MANAGER l l (OFFSITE) l l I l I SITE SITE ij ADMINISTRATIOA HVAC OA/OF SOILS OA/OC & TRAINING SUPERINTENDENT SUPERINTENDENT SUPERI TENDENT UPERINTENDENT I I i l l I NOTE THIS CHART IS INTENDED TO INDICATE h ONLY THE INTEGRATION OF THE CIVIL ELECTRICAL PIPE / MECH / WELD j BECHTEL QC FUNCTION. OC OC (ASME) OC i l# l.'

8 4.0 PROGRAM PLANNING 4.1 Introduction 3 The detailed planning for the major portion of the Construction Completion Program is described in this section. Planning in support of Phase I consists of the activities to set up dh"f[$1h ~ a team organization to assess the installation and inspection status foi;g-systems within major structures (Section 4.2) and to verify the adequacy of completed inspection effort (Section 4.3). The Phase 2 planning effort covers the process and procedures that will be used by the team organization for systems completion work (Section 4.4). The procedures to integrate the quality program requirements with continuing systems completion work will be developed (Section 4.5). ,p 4.2 Team Organization (Phase 1) "2 f py) 4.2.1 Introduction Organize and train teams and prepare procedures for an installation and inspection status assessment. 4.2.2 Objective 1. Establish and implement a team organization ready to inspect and assess systems for installation and inspection status. 2. Develop the organizational processes and procedures necessary to implement the team approach for status assessment. 3. Provide t. raining to ensure required inspection and installation status assessment activities are satisfactorily performed. 4.2.3 Description 1. The team organization structure will vary depending upon the assigned scope of work. The organization will consist of a team supervisor and personnel as appropriate i from field engineering, planning, craf t supervision, project engineering, MPQAD and Consumers Power Company Site Management Office. The team may be augmented by = procurement personnel, subcontract coordinators and turnover coordinators. Teams will be assigned a specific scope of work and held . accountable for status assessment and overal} completion within this scope. The scope includes the requirements mil 282-4106d-66-102 1 i s, .a- .-umge..

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x s 9 r to develop a viable working schedule and insure early identification and resolution of problem areas. Proj ect processes and procedures will be reviewed and modified to' incorporate the team organization. The teandfPQAD representative is responsible for providing the QA/QC support for the team. e receives scheduling ~ direction from th Team Superv'sor and technical direction from MPQAD. or his team's work, he analyzes thp n"a4tv _ o requir ments and plans the QC activities to S tenrate L, them with the team ritort. He assures the necessary PYLA s and certified inspection personnel are available for performing the inspections. He maintains cognizance of the quality status of the verification activities. The Washington Nuclear Plant #2 (WNP-2) team organization will be used as a starting point for a Midland specific approach. A pilot team or teams will be utilized to develop and test processes and procedures during the development stage to assure that Program objectives can be met. This i will also provide practical field input to assure that efficient and workable methods are used. Team members will be physically located together to the 3 [ extent practicable to improve. communication, status assessment, problem identification and problem resolution. 2. Training for inspection and installation status l assesscent wul oe provided to team members. It will l . include responsibilities, reporting functions, indoctrination of project processes and procedures and L f a=iliarization with the project quality progra= to g,k l ensure effective implementation. 3. A separate organization of design engineers (presently existing) will coordinate spatial interaction, review and I examination with the activities of these teams. 4.2.4 Schedule Status Designate pilot team. 1/21/83 Complete grouping of systems for assignment 2/28/83 to teams. Complete assignment of team supervisors and 3/31/83 members to designated systems. mil 282-4106d-66-102 ~..

s s 10 g(,,, g r kM 4.3 Quality Verification (Phase 1) hF 4.3.1 Introduction 3 V The d esti_on progr istheactivityunderta)[nt e o determine, using v.11ety of methods, that the i~nspections performed on completed work were done correctly. t* 4.3.2 Objectives The objectives of the verification program are to: deviewexistingPQC1'sandreviseasnecessarytoassure that: Attributes important to the safety and reliability of e. specific components, systems, and structures are identified for verification. b. Accept / reject criteria are clearly identified. c. Appropriate controls, methods, inspection and/or testing equipment are specified. d. Requisite skill levels are required per ANSI N45.2.6 or SNT-TC-1A. Develop and implement verification inspection plar. for completed work which considers: a. Re-inspection of accessible items, b. Review of documentation for attributes determined to be inaccessible for re-inspection. c. Sampling techniques using national standards. 4.3.3 Description PQCI's will be revised as necessary to meet the objectives in Section 4.3.2. Verification of the quality of accessible completed contruction, which has been previously inspected will be performed bv use of sampline nlans ba ed n HIL-S-105D (1963)her acceptable methodih Attributes % determined to be inaccessible Ior direc6 re-inspection due to embedment or the status of completed construction or installation (eg, veld preparation of completed welds, ,t_inforcement in_pl1_ced concrete, installed anchor bolts, e {* etc) will'be verified 7 s appropriate,/ by examination of [recordsg k fyI( 1 mi1282-4106d-66-102 -s ,.m. ,s- ,g.,w..,

j 11 o 1 4.3.4 Schedule Status Complete review and revision of PQCI's. (Dage to be determined.) = T Establish erificationinspectionplal)forco*mpleted work. (Da M er. ermined.) t* 4.4 System Completion Plannina (Phase 2) 4.4.1 Introduction ' Establish the processes for system completion, prepare procedures and expand training to cover systems completion work. 4.4.2 Objective The objectives of Ibe systems completion planning are as follows: / Establish processes and interfaces for system completion. i Prepare procedures defining tasks of each system completion team. Train team eembers by expanding upon training received previously for inspection and status assessment. 4 Establish scheduling methods to be used during system completion activities. f 4.4.3 Description The team organization (developed in Section 4.2) and the processes and procedures will be estended to accomplish the systems coupletion work. I . Training will be conducted to assure that supervisors understand the team objectives and their role. Emphasis will be placed on completion of all work in accordance jg* with the design requirements, the change control process g, used when the design must be modified, and changes to the established team processes and procedures. 4.4.4 Schedule Status 4 Complete team preparation for systems completion work. (Date to be determined.) J l i 2 1 r mil 282-61064-66-102. ....e. ~.. r .p s .. + .....,s

\\ s- \\ 12 4.5 QA/QC Systems Completion Plannina (Phase 2) 1 4.5.1 Introduction { The QA/QC systems completion activity covers the planning to support of system completion work. 4.5.2 Objectives Establish in-process inspection program and complete review and modification of PQCIs. 4.5.3 Description The QC in-process inspection program will be directly coordinated with future installation schedules to insure that inspection points, identified by MPQAD QA in the PQCI's, are integrated with the installation schedule. The identifi-cation of applicable PQCI's and required inspection points will be used by system completion teams to insure that QC -inspections are adequately scheduled into the process. The system completion team quality representative will be responsible for providing the link between the system completion team and MPQAD to insure that quality requirements are satisfied. PQCI's will be reviewed, and modified as necessary, to insure that proper attributes are being inspected, that inspection plans are clear and concise, that inspection points are specifically scheduled with installation activitics and that inspection results are properly documented. MPQAD QA will be responsible for the PQCI review activity and will obtain assistance, as required, from other project functions, such as Project Engineering and Quality Control. Revised PQCI's will be used to conduct inspection of future installation activities. 4.5.4 Schedule Status Issue procedure for integrating inspection points into the construction schedule. 2/22/83 l

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f. l 1 I FIGURE 4-1 CONCEPTUAL TEAM ORGANIZATION 1 a. s l} SYS. TEAM SUPV. PROJECT 02 { ENGR. N i o n . - - - - - -l b] l lT I ' LEAD SYS. TEAM LEAD SYS. MECHJi & C . ELECT. SYS. TEAM LD.SYS.TM. maressUgt TEAM F.E. SUPT.- SUPT. PLANNER PROJ. ENGR. l-I! rATMfE I L I i 8 SUPPORT GROUPS 8 l I i' l roc - -., - - g 8 g' 8 8 Q 8 8 l i! f PROCUREMENT .a. g i 9'x ~ !"d""l }! CPCO TEST l i 8. j susCoNTRAct p l ., u.o-1 1 1 j I i i

13 ~ 5.0 ' PROGRAM IMPLEMENTATION 5.1 Introduction 3 I TheimplementationofthePhase1ConstructionCompletihnProgram activities will be initiated after a management review of the overall process insures that Project performance and quality objectives have been addressed. The Phase 1 work will then be o carried out by the various teams in accordance with the procedures described _in the preceding sections. The installation and inspection status assessment of a system or partial system will be followed by a review of results by MPQAD and a second management review before initiating the Phase 2 systems completion work. -The . Phase 2 work will then be initiated on that system or partial system. 5.2 Objectives The objectives to be met are: Establish the present installation completion and quality status. Integrate the construction and quality activities for all remaining work. Improve performance in demonstrated conformance to quality goals in-all system completion work. 5.3 Description Management Reviews Project management will conduct formal review of the plans for implementation activities prior to initiation of team activities for the Phase I work. These reviews will ensure that identified project management and quality issues have been adequately addressed by L specific actions and that Program objectives are met. The reviews b will cover the process for both 1) the verification of completed [ inspection activity and 2) the installation and inspection status l activity. The installation and inspection status assessment will be performed l on a system and/or area basis. Phase 2 is initiated after a formal Project management review of the first status assessment results to evaluate f.mplementation effectiveness. After completion of this review, a work segment will be released for systems completion. Subsequent status assessment results will be reviewed by site I manageme prior to initiation of additional systems completion segments. eports will be made to Project management at regu arly a meetings. l f . mil 282-4106e-66-102 l . + Q -[, 9 v-r e-.--- w wy ev.--e-- ,,w wy ,..--+--.ee---= .---e. .-w -e .---e..--+,--.--ww= +.-- ,---w m-es. ww -- t--,-.--e=- e-,-v,

~ 14 Phase 1 Implementation The existing installation and inspection status will be established in accordance with the plan presented in Section 4. f Evaluate Phase 1 Results MPQAD will review the status assessment results to determine if any ,~. programmatic or implementation changes must be made. Verification scope will be adjusted, as necessary, based on evaluation results. Also, the evaluation will check for reportability to the NRC (as required by 10 CFR 50.55(e)) and Part 21. Phase 2 Implementation This activity starts systems completion for turnover. Work will be scheduled as installation nd inspection status assessments are completed and reviewed. Correction of identified problems will be . given priority over in tration of new work, as;anoronritts, and the system comple on teams will schedule their work based di these priorities. y 5.4 Schedule Statas Complete Management review and initiate implementation of plan for verification of completed inspections. (Date to be determined.) Complete Management review and initiate implementation of plan for status assessment. (Date to be determined.) Complete Management review of initial installation and inspection status results and initiate systems completion work. (Date to be determined.) mil 282-4106e-66-102 ~ -7. - . g :.-_ _...._

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15 6.0 QUALITY PROGRAM REVIEW !r 6.1 Introduction I-The adequacy and completeness of the quality program is reviewed as part of the ongoing Project management attention to quality. These reviews consider any questions raised by NRC inspections or findings raised by third party evaluations. 6.2 Objective Address issues raised by internal audits, NRC inspections and third party assessments. Program changes, if needed, will be evaluated and, as findings are processed, will be factored into the Project e work. (',' 6.3 Description

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(' / y p 7-e- Consumers Power Company believes Midland QA program is sound. From I time to time, questions arise on detailed' asp'ects of the program or program implementation. The normal process of addressing these issues ensures that all necessary information is provided to NRC and that internal confidence in the program is maintained. The recent inspection of the diesel generator building has raised several issues of gragrammatic concern. These are in the areas cf matnia_1,,t_r_assability, designJont.rol pro _ cess, Q-system related requirements, document control and receipt inspection. Pf5 Ject management has directed that MPQAD provide an expeditious evaluation of these issues to be considered as part of the management review rio to initiation of Phase 2. Once the NRC inspection report is received and specified items are identified, these items will be addressed and resolved through the normal process of closing the inspection findings. Any corrective action or program changes will be implemented as appropriate in Project work on a schedule provided -in the inspection report response. The Project will also receive, from time to time,' findings from third party assessments (Section 7). These findings or recommendations may also result in program modification or adiustments. Corrective action *.aken by the Project will.be implemented on a sched,ule stated in the response to these findings. L mil 282-4106f-66-102 i ~, _ _ _. -. . ~. m

16 7.0 THIRD PARTY REVIEWS ~ 7.1 Introduction .r This section describes third party evaluations and revie*ws that have been performed and are planned to asser,s the effectiveness of design and construction activity implementation. Third party reviews being e. conducted as part of the Remedial Soils Program are not included in this activity. 7.2 Objectives To assist in improving Project implementation and assessment of Midland design and construction adequacy, consultants will be utilized in order to: Achieve a broad snapshot of current Project practices and performance in relation to a national program. Provide continuous monitoring and feedback to Management of Project performance. Identify any activities or organizational elements needing improvement. Improve confidence (int 1uding the NRC's and the public's) in overall Project adequacy. 7.3 Description The use of consultants to overview Project design and construction activities with particular emphasis on construction is part of the effort to improve the Project's implementation of the quality program. Specifically, the plan overview employs the use of consultants for three separate functions: (1) To carry out a self-initiated evaluation (SIE) of the entire Project under the INPO Phase I program, (2) to utilize a third party overview of ongoing site construction activities to provide monitoring of the degree of implementation success achieved under the new program and (3) to conduct a third party Independent Design Verification (IDV) Prog {am. 1. The INPO self-initiated evaluation was planned as part of an industry commitment to the NRC in response to concerns over nuclear plant construction quality assurance. For the Midland SIE, the evaluation was contracted to be carried out entirely by third party, experienced personnel from the Management Analysis Company. 4 The evaluation was performed by a team of 17 consultants familiar with the INPO criteria and evaluation methodology. Over a period of a month they interviewed Project personnel at various locations and observed work in progress. The initial results of their evaluation have been presented to the Company mil 282-4106i-66-102 w e p-9 ,=4 + - * * - - m.,.- .w ww,em =m-e ,h

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17 .+ and a Project response to each finding will be prepared and . included as part of the evaluation report to be submitted first t) INPO and then to the NRC Region III Administrat(r, together with the INPO overview. t ~ 2. A third-party installation implementation overview is being J undertaken using, as a model, the program developed specifically for the underpinning portion of the soils remedial work. The overview will be initiated by retaining an independent firm, having considerable experience and depth of personnel in the nuclear construction field. The consultant's overview team will be located at the Midland Plant site and will observe the work l activities being conducted in accordance with this Plan on safety-related systems. The overview will continue for a period of six months, after which the Project's cumulative performance will be evaluated. Based on the overview team's findings, a determination will be made by the Company's top management on what modification, if any, should be made to the consultant's l scope of work. Findings identified by the installation overvie team will be made available to the NRC in accordance with the procedures established for the conduct of independent j verification programs. 3. An Independent Design Verification (IDV) is being conducted by Tera Corporation. The IDV is directed at verifying the quality of design and construction for the Midland Plant. The approach selected is a review and evaluation of a detailed " vertical slice" of the Project design and construction. The design and as-built configuration of two selected safety systems will be reviewed to assure their adequacy to function in accordance with their safety design bases and to assure applicable licensing [ commitments have been properly implemented. The field work done in support of this activity will not take place until after Phase I implementation (Section 5) has been completed on the L systems being reviewed. l l The Unit 2 Auxiliary Feedwater System (AFW) plus another system j to be selected with NRC concurrence, will be reviewed to fulfill the requirements of the IDV. l l l l mil 282-41061-66-102 e* 9 .m n 0 lm-p- e e >9 <v, ,n a,r--.m,--.-,.w----.- w-,,n., -,,.,--,.--,,,,yn_

l-- IB s 7.4 Status / Schedule 1

1. 'INPO Construction Project Evaluation

= t Select consultant and conduct Complete evaluation Submit report to INPO Jan 20, 1983 2. Independent Construction Overview Define scope Dec 30,-1982 Select consultant Jan 31, 1983 Mobilize assessment team (Date to be determined)- E . Receive assessment team (Date to be determined) report 3. IDV r Select 2 Systems .AFW System Complete .0btain NRC concurrence (Date to de determined) for second system. Complete Evaluation (Date to be determined) s I i mil 282-41061-66-102 4,-._ e. .,,.,_,,,,-.___.m-..%.,_.,y--_--,_,- .,, - - - - ~ -

19

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8.0 SYSTEM LAYUP 8.1 Introduction 3 Perform system lay-up activities to protect plant equip ent. 8.2 Objectives t-Expand th'e protection of completed and partially completed plant systems and components until plant start-up, to take into account any special considerations during the status assessment. 8.3 Description Procedures and instructions are provided in the Testing Program Manual to protect equipment during the on-going installation and test work. These will be extended to cover special considerations associated with the Program implementation. Both the pre-and post-turnover periods are covered. System and component integrity is ensured through existing programs and implementation of control and verification procedures. In summary, these procedures and instructions require: Test Engineers to complete walkdowns of Q-Systems (in the auxiliary, diesel generator and containment buildings and the service water pump structure), paying particular attention to systems / components that are open to the atmosphere (eg open ended pipes, open tanks, missing spools, disconnected instrument lines, etc). Systems that have been hydrotested but are not currently in controlled layup require action to place the system in layup. Layup will vary from system to system but in general will consist of air blowing to re-.vc coisture and closing the system from the atmosphere. 8.4 Schedule / Status Start extended layup activities 1/15/83 Issue walk down schedules 1/15/83 Complete the layup preparation walkdown 2/28/83 mil 282-4106 12 3 gg g an e w ' M &-M W. $9 94 h

~ j 21 x s Plant as nd the Midla ue for ctivites. effort, may .'O / tin ct a which will conher proje of the co pletion itiated ly completionthat are in support of ot systems m ering work will j]. be cuginering the eill cugin related to s pport ordercategory aign ee c to this completioninitiation. El u s ctivitieappropriate,ctivities insyste r befo ms re ol a s for cto Iticc initicted, a Any a area Inspe dependent ct. Proje of anResident rc11 ele the NRC that are in ase a r with s hedules to tier w d with c vie 2 c Schedule eding ce St-tus re pro a ctivities c Three n of this Pla. 4 l i l l l l t i I I i . s01

o MIDLAND - CHRONOLOGY OF EVENTS SINCE JULY 1981 HEARINGS 07/07/81 Soil Hearing ccmmenced 10/05/81 CPCo met with NRC to discuss organizational improvements 10/14/81 Hearing reconvened to deal with Geo-Technical Issues 01/12/82 CPCo met with NRC to discuss changes to the Midland QA organization 02/02/82 Testified at Midland soils hearing re: recent QA reorganization 03/30/82 CPCo/NRC Meeting (Norelius; Adensam) 04/13/82 NRC Public Meeting in Midland on Underpinning activities 04/26/82 Midland SALP-2 Meeting 04/28/82 Stop Work Order issued by CPCo against Mergentine (dug into 4160 volt power supply) 05/14/82 CPCo/NRC Meeting to discuss overview of electrical inspections 05/20/82 ACRS Subcommittee briefed re: Midland QA for construction 05/26/82 Construction Permit Amendment 3 issued 06/03/82 Full ACRS briefed re: Midland QA for construction 06/08/82 ACRS Report requested a Broader Assessment of design adequacy and construction quality 06/21/82 Spessard/Norelius recommendations provided 06/21/82 SALP-2 Meeting to discuss CPCo Response in Jackson, MI, Public Meeting 06/22/82 Meeting to Review Response to SALP Report 06/28/82 GAP News Conference requesting NRC halt construction 07/82 Office of Special Cases formed in Region III, includes Midland Section 07/07/82 ASLB issues memo / Order on reopening record on QA matters 07/09/82 NRC Requested IDV by CPCo 07/23/82 Cook memo issued containing Midland problems 07/26/82 RIII meeting with NRR to discuss Hidland QA problems (meeting minutes written 8/18/82, Warnick memo) 08/05/82 Public Meeting to discuss SALP-2 differences with CPCo 08/05/82 Salp-2 Meeting to further discuss CPCo response, in Jackson, MI, Public Meeting

.c N s a 08/09/82 Soils Stop Work Order issued by CPCo, potential violation of Board Order 08/10/82 Enforcement Conference re: unapproved excavations'(alleged violation of Board Order) 08/.10/82 CPCo stopped soils work at our request pending resolution of authority to dig holes 08/12/82 Issued Work Authorization Procedure for Soils (NRC/CPCo) 08/26/82 NRC management meeting with CPCo management re: QA problems 09/02/82 NRC followup meeting with CPCo management re: Quality Improvement Plan (JGK/Selby) 09/03/82 Briefing of Jack Roe and J. Austin of Commissioner's Staff at Midland 09/09/82 MPQAD Reorganization - Bechtel QC into CICo QA Organization 09/09/82 MeetingwithNRRtoreviewMiIdlandsoilsissue 09/10/82 Region III initial approval of MPQP 1 and 2 09/15/82 NRC Meeting with CPCo attorneys re: GAP allegations 09/17/82 CPCo notified NRC of integrated QA/QC 09/17/82 CPCo proposed Stone and Webster for soils third party overview 09/17/82 CPCo proposes IDV and other corrective actions 09/20/82 S&W began overview work on soils at the Midland site 09/22/82 Meeting with Mooney, Schaub, and Ronk on Midland QA commitments. They will give us a list. Also talked about taking QC from Bechtel and putting it under MPQAD - Problem with N stamp. 09/24/82 Soils Stop Work Order issued by CPCo following NRC inspection (CAL issued). QC training, requalification soils area 09/28/82 RIII initial meeting on site with S&W, proposed third party for soils activities 09/29/82 Public management meeting with CPCo re: QA/QC organization, CAL [ third party review 10/82 Safety Evaluation Report Supplement 2, issued approving soils design 10/01/82 JGK and ABD gave approval for Midland team inspection y y p e a. +.e w -e.w-==-.

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\\< 10/05/82 CPCo proposes TERA for IDV at meeting with KRR, RIII, GAP and proposed auxiliary feedwater system be included 10/07/82 Meeting in RIII with ELD to' discuss testimony for next round of hearings 10/12/82 Diesel generator building inspection commenced 10I13/82 Detroit Free Press had series on Midland. Kent and anonymous electrician were quoted. 10/15/82 DGB Inspection mini-exits with CPCo g 10/28/82 s 10/25/82 Revised Testimony issued by NRC 10/25/82 Meeting with NRR to discuss Midland third party IDVP proposal 10/26 - ] 11/05/82) ASLB Hearings in Session 10/29/82 Meeting with Bechtel to discuss performance / problems 11/05/82 Meeting with NRR to discuss Stone and Webster (S&W) Qualification for soils third party overview; NRR, RIII, CPCo, S&W, Persons, IE, GAP 11/07/82 TERA began auxiliary feedwater system review for IDVP at CPCo risk 11/10/82 DGB inspection team exit with CPCo site personnel (10-12 concerns with multiple examples and problems) 11/22/82 DGB inspection findings discussed with JGK by RFW 11/23/82 DGB inspection exit with CPCo manage:nent 11/30/82 CPCo notified Region III verbally of proposed Stop-Work 11/30/82 CPCo stopped all HVAC welding; problems with Photon ", testing, qualification of welding procedures - 12/01/82 CPCo announces Zack problem may lead to a large lay-off 12/02/82 Meeting RFW and Shafer and team with CPCo and Bechtel to discuss CCP. RIII informed. Also HQ and Connaission's assistants 12/03/82 CPCo stopped majority of safety related work at site. Issued PN and news release. Briefed JGK, ABD, SL ,I I 12/03/82 CPCo proposes to increase TERA scope to include three additional systems; Emergency Power (DG System), Safeguards Chill Water, and Containment Insulation Systems e p W = w eer 9 y-a =+4 ---p m .p.. .w,, ,,,.,p

a s ~ 12/07/82 NRC meeting to brief NRR/IE management on DGB inspection problems and QA/QC history and problems, CCP and the licensee "Get Well Program" 12/09/82 NRC approved CPCo to begin work on Piers 12E and 12W under turbine building 12/13/82 RIII meeting with ELL to discuss plans for supplemental testimony '12/30/82 NRC letter issued confirming Stop Work on Safety Related areas with certain exceptions 01/10/83 CPCo submitted proposed CCP with third party overview included in the proposal 01/18/83 Enforcement Conference with CPCo management re: diesel generator building inspectica 01/21/83 Final exit on diesel generator building inspection, concluding continued misuse of IPIN's and improper use of Attacheent 10 firms l 02/02/83 NRC/CPCo meeting to discuss CCP (collect info) 02/08/83 Proposed Civil Penalty issued; $120,000 02/08/83 Public Meeting re: CCP and IDCVP 02/08/83 Meeting with CPCo and Bechtel management to discuss desire to turn things around 02/09/83 TERA's Engineering Program Plan submitted; auxiliary feedwater only 02/14 - 18/83 ASLB Hearings in session 02/14/83 Stone and Webster supplies assessment of piers 12 East / West 02/15/83 CPCo sumits S&W independent qualification statements for soils 02/24/83 CPCo expands S&W contract to include QA overview / review work packages QC inspector requalification, all soils training, and on an assessment of all underpinning work 02/24/83 NRC approves Stone & Webster for soil third party overview 03/07/83 NRC Meeting with NRR/ GAP to discuss the CCP 03/08/83 Meeting in RIII with ELD to discuss supplemental hearing testimony 03/10/83 CPCo responded to Notice of Violation and proposed Civil Penalties

's N I 1 03/15/83 Meeting with CPCo to obtain INPO Self Imposed Evaluation results 03/22/83 NRC selects additional systems systems for the IDCVP; Emergency Electric Power System, and Control Room HVAC 03/28/83 RIII, letter issued requesting additional details re: CCP; included in this request was a proposed third party candidate and the protocol to be utilized for the IDCVP 04/04/83 darrison replaced Shafer 04/06/83 CPCo proposes Stone and Webster to perform third party overview for the CCP gS&W's program is titled Construction Implementation Overview (CIO) 04/13/83 Meeting in Headquarters to discuss TERA proposal on IDCVP; IE, RIII, NRR, and GAP participated 04/15/83 Stone and Webster issued a 90 Day Report on Assessment of Remedial Soils Underpinning Activities 04/19 - 7 21/83 J Caseload Forecast Panel at Midland; Public Meeting 4/19 and 4/21/83 04/21/83 Stone and Webster CIO personnel onsite 04/22/83 CPCo response to NRC letter of 3/28/83, re: CCP Additional Informa-tion 04/27 - 05/06/83 ASLB Hearing in session - NRC testifies 05/03/83 NRC approval of TERA for IDCVP for Auxiliary Feedwater only 05/17/83 Meeting with CPCo to discuss CCP/CIO; response 4/22/83 to NRC 3/28/83 letter re: Additional Information 05/18/83 TERA submitted modification to the Engineering Program Plan (EPP) to include the two additional system;s Emergency Power and Control Room HVAC se. ee +e e 4 ma e neeo *

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F._ _ .. s. I, Q. Bechtel Power Corporation ~ ...-,/ / w 131903 ,e f. Slie N g r, Post Office Box 2167 Midland. Michigan 48640 1 Mid!nnd Ptois:1 ,,y.U',/ December 16, 1980

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\\/ L Cc..sumers Power Company P. O. Box 1963 Midland, MI 48640 Attention: D. B' Miller Site Manager Job 7220 Midland Project Agency Response BCCC-5243

Dear !!r. Miller:

For your infernation and to expedite integral responses, the attached = atrix identifies individuals who are to respond to questions posed by CPCo, the h*RC, or other outside agencies during their routine visits, inspections, and audits at the jobsite. The purpose of this authorization it to mini =ize the opportunity for in-adequate or incorrect respenses to specific questions. The identification of individuals will also allow for nore rapid, factual responses. The Bechtel individuals not identified on the attached estrix should contact their supervisor when questioned by CPCo, the b~rC, or other f' outside/non-project agencies. i Very truly yours, . kOsbA I i s F oa. T = a E. Davis Site Manager JMB - wes_ q LED /ch N -l M i TWs_ Attachnent - Agency Response Matrix t I ODJ _ ~ . RF/ __ T RE.'A - s:s _ e e g

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5 L To Distribution MAR 2 81983 c ~ ' ' ' rnow DJones, JSC-206B Consumers Date March 23, 1983 Power ~ company sussecy 1982 BI'ENNIAL QUALITY ASSURANCE AUDIT MIDLAND PROJECT comacseomocuct DJ-58-83 cc GMouradian/ File: AMS-83-9 Attached for your information is the report of the 1982 Biennial Quality Assurance Audit of the Midland Project recently completed by Management Analysis Company. I -As, discussed at the exit meeting, each Audit Finding Report, Unresolved Item and Observation will be issued to the organization responsible for action. Should you have any questions, please do not hesitate to contact me. DJ/11b O S 9 m 1 l 2 - _. n : _,_. _..}}

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