ML20094M405

Ack Receipt of & Payment in Amount of $116,500 for Civil Penalty Imposed by 830829 Order

ML20094M405
Person / Time
Site:	Midland
Issue date:	10/04/1983
From:	Axelrad J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Selby J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML19258A087	List: IR 05000329/1978020 IR 05000329/1981012 IR 05000329/1982007 IR 05000329/1982009 IR 05000329/1982014 ML19258A086 ML19351C947 ML20093B251 ML20093B495 ML20093B616 ML20093B708 ML20093B747 ML20093B900 ML20093B940 ML20093C001 ML20093C006 ML20093C017 ML20093C025 ML20093C030 ML20093C035 ML20093C068 ML20093C073 ML20093C079 ML20093C082 ML20093C101 ML20093C104 ML20093C108 ML20093C116 ML20093C174 ML20093C189 ML20093C196 ML20093C226 ML20093C231 ML20093C262 ML20093C318 ML20093C324 ML20093C347 ML20093C354 ML20093C374 ML20093C377 ML20093C390 ML20093C394 ML20093C398 ML20093C405 ML20093C440 ML20093C444 ML20093C649 ML20093M884 ML20093M994 ML20093N005 ... further results
References
CON-BX21-016, CON-BX21-16, FOIA-84-96 EA-83-003, EA-83-3, NUDOCS 8408150640
Download: ML20094M405 (2)

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'o UNITED STATES E

NUCLEAR REGULATORY COMMISSION

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Docket No. 50-329 EA 83-03 Consumers Power Company ATTN: Mr. John D. Selby President 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

This will acknowledge receipt of your letter dated September 26, 1983 and

-your check for $116,500 in payment for the civil penalty imposed by Order dated August 29, 1983. We will continue to examine, during future inspec-tions, your corrective actions described in your letters dated March 10, and July 12, 1983.

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Jane A. Axelrad. Director of Enforcement Office of Inspection and Enforcement OCT 6 W3 8408150640 040718 PDR FOIA RICE 84-96 PDR

1 OCT 4 1983 Distribution List PDR LPDR ACRS SECY

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- R. DeYoung, IE J. Axelrad, IE J. Keppler, RIII J. Lieberman, ELD V. Stello, DED/ROGR Enforcemeny Coordintors RI, RII, RIII, RIV, RV F. Ingram, PA

~J. Cumings, DIA B. Hayes, OI H. Denton, NRR J. Crooks, AE00 G. Klingler, IE J. Taylor IE E. Jordan, IE C. Thayer, IE ES Files EA Files DCS v

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Mr J G Kepplei, t Regional Administrator, s

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,t MIDLAh3 PROJECTi ll RESPONSE TO DRAFT SALP REPORT FILE !O.6.1 SERIAL 25682

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Consumers Povet Company has received,and reviewed the NRC's Systematic. Assess- -

ment,of Licensen Performance (SALP Report) for the Midland Nuclear Plant.

Units,1 and 2, for the period July 1,'1981 through March 31, 1983 and acknow-ledges}the NRC's comments.

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l Co,nsumers Pwer Company recognizes the purpose of the SALP Report and is committed to* accomplish the improvements necessary to achieve the quality performance' level that both the NRC and the Ccap~any desire.

-The Company is particularly concerned about the SALP evaluation in the Remedial Soils work and will devote the management' attention necessary to establish improved overall performance in thic area. Efforts will be focused on addressing the NRC's concern regarding attention to' detail and implementa-tion of the Quality Assurance Program.

Our managmen't team is dedicated to 2

assuring that future Remedial Soils work will conform to the requirements of the Midland QA Program.

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The Company believes'that the elements of the CCP Program are sound and that it will result in'alvell controlled process by which to both verify the quality of past completed construction'and' ensure the quality of construction work yet to go.

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The CCP may need 'spe refinement as -wa gain experience with it, but'as a management team've are dedicated to give it the attention and support needed.

We will modify;1t, as changelis needed, to ensure that it works. The success-ful implementation'of this program will clearly support the Company's gJai of meeting the requirements of the Midland QA Program.

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In conclusion the Company has evaluated the contents of the SALP III Report and the management team vill take whatever steps are necessary to achieve the quality perfomance level that both the NRC and the Company desire.

CC DSHood, US :RC RJCook, Midland Resident Inspecter O

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'Mr yt a:.h J Kelley, Esq

' Attorney General of the Atcmic 5 fety & I,1cecsing Appeal Board State of Michigan V S Nuclear. Regulatory Co=ission

~Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General

? nvironmental Protee*. ion Division E

Mr C R Stephens (3) 720 Law Building Chief, Docketing & Services L nsing, MI 48913 R

U S Nuclear Regulatory Corrission Office of the Secretary f;.Mr Myron M Cherry, Esq Washington, DC 20555 A Suite 37000 Ms Mary Sinclair (Three Firsc' National Plaza 5711 Summerset Street Chicago, IL 60602-Midland, MI 48640 Mr dendell H Marshall' Mr William D Paton, Esq PID 10 f..

Counsel for the NRC Staff Midland, MI 48640 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & -Licensing Atomic Safety & Licensing

. Board Panel Board Panel U S 3nclear Regulatory Commission U S Nuclear Regulatory Commission Washington..DC 20555 Washington, DC 2.0555 Dr Federick P Cowan Ms Barbara Stamiris 6152 N Verde-Trail 5795 North River Road Apt,B-125 Rt 3 Boca,Raton, FL 33433 Freeland, MI 48623

Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602

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Mr D F Judd Mr John Demeester, 'Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg,'VA 24505 Midland, MI 48640 Mr S,teve Gadler, Isq Ms Lynne Bernebei 2120 Carter-Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 9/3/S3= -

mIU583-0429a100

2 COllSumCi5 L POWCT i Presid

= Projects. Enginemng and Construction General Offices: 1945 West Pernest Moed, Jock,on, Ma 49201 e (517) 788 0453 September 8, 1983 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERCY CENTER INSPECTION REPORT No 50-329/83-11(OSC) AND 50-330/83-11(OSC)

File:

0.4.2 UFI: 70*01 Serial: CSC-6869 0485.16 42*05*22*04

REFERENCE:

(1) R F Warnick letter to J W Cook, dated August 4, 1983 Inspection Report No 50-329/83-11(OSC) and 50-330/83-11 (OSC)

This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and requested our written response to the item of noncompliance therein.

JW6/ BHP /dmh Attachment cc: RFWarnick, NRC Region III JJHarrison, NRC Region III RNGardner, NRC Region III RBLandsman, NRC Region III I

RJCook, NRC Senior Resident Inspector, Midland Site RLBurgess, NRC Resident Inspector, Midland Site NOV0783-0001A-CN02 SEP 121983 u

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's Serial: CSC-6869 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT NO 50-329/83-11(OSC) & 50-330/83-11(OSC)

Appendix (Notice of Violation) to Inspection Report No. 50-329/83-11(OSC) and 50-330/83-11(OSC) provides one item of noncompliance to 10 CFR 50, Appendix B.

The NRC statement and our responses are given below:

NRC STATEMENT 10 CFR 50, Appendix B, Criterion V states', in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

CPC-1-A Policy 13, Handling, Storage, and Shipping; Section 3.3, RECEIPT AND STORAGE, states, in part, " Suppliers provide plans..., procedures and personnel to.... store,... items upon arrival at the site."

Bechtel Power Corporation field Procedure FPG 4.000, Revision 10, Storage -

Maintenance / Inspection of Equipment and Materials, states in part in Section 6.2.4 " Items shall be stored on dunnage or cribbing to allow for air cir-culation and to minimize the trapping of water."

Contrary to the above, structural items stored in various areas of the Poseyville Road laydown area were not stored on dunnage or cribbing to allow for air circulation and to minimize the trapping of water as required by Bechtel Field Procedure FPG 4.000, Revision 10.

This is a Severity Level V violation (Supplement II).

CONSUMERS POWER COMPANY RESPONSE In accordance with this Notice of Violation, an explanation of corrective action is as follows:

1.

Corrective Action Taken and the Results Achieved:

As clarification to the item of noncompliance the structural I-beam

., identified in your report was intended for usa as a pipe storage rack

,and was a spare setting alongside others being used as such.

~ Work ~ orders for placing on dunnage the stock steel and unistrut pieces welded to base plates were issued June 20, 1983, and June 7, 1983, respec-tively. The work was completed June 2.1., 1983, and verified by CPCo.

NOV0783-0001A-CN02

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2.

Corrective Action to be Taken to Avoid Further Noncompliance:

Dedicated crews of craftsmen were established July 20, 1983, to maintain the laydown area in accordance with the requirements of FPG 4.000.

Additional supervision has been added at the Poseyville laydown area to direct the crews and implement access control for entrance into the laydown area.

3.

The Date When Full Compliance Will be Achieved:

Full compliance has been achieved.

All the items identified in the Notice of Violation were placed on dunnage June 21, 1983. The unistrut pieces were subsequently moved to the scrap area for' salvage on July 23, 1983.

The manning of the dedicated crews and additional supervision have been completed and are presently functioning.

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NOV0783-0001A-CN02

CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329/50-330 Letter Serial CSC-Dated September 8, 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 the response to R F Warnick letter to J W Cook dated August 4, 1983.

CONSUMERS POWER COMPANY

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By J C Cook, Vice President f

Projects Engineering and Construction

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Sworn and s'ubscribed before me this 1

day of _ dM,.7/<, 1983.

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Not'ary Public

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NOV0783-0001A-CN02

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+t OL/0M SERVICE LIST Mr Charles Bechhoefer, Esq Mr Frank J Kelley, Esq

. Administrative Judge Attorney General of the

- Atomic Safety & Licensing Board Panel State of Michigan US Nuclear Regulatory Commission Mr Stewart H Freeman, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Div 720 Law Building Lansing, MI 48913

. Dr Frederick P Cowan Mr Myron M Cherry, Esq Administrative Judge Cherry & Flynn 6152 N Verde Trail 3 First National Plaza Apt B-125 Suite 3700 Boca Raton, FL 33433 Chicago, IL 60602 Mr Michael Miller, Esq Mr Wendell H Marshall Isham, Lincoln & Beale RFD 10 3 First' National Plaza Midland, MI 48640 Suite 5200 Chicago, IL 60602-Mr D F Judd, Sr Project Manager.

Mr John Demeester The Babcock &'Wilcox Company Dow Chemical Building P O Box 1260 Michigan Division Lynchburg, Va.24505 Midland, MI 48640 Atomic Safety & Licensing board Panel Ms Mary Sinclair i

U S Nuclear Regulatory Commission 5711 Summerset Street r.

Washington, DC 20555 Midland, MI 40i40 i

Atomic Safety & Licensing Appeal Board Mr Steve Gadler U S Nuclear Regulatory Commission 2120 Carter Avenue Washington, DC 20555 St Paul, MN 55108 j

Mr William D Paton, Esq Mr Lee L Bishop

. 1 Counsel for NRC Staff Harmon & Weiss US Nuclear Regulatory Commission 1725 I Street, NW #506

. Washington. DC 20555 Washington, DC 20006 Ms. Barbara Stamiris Mr C R Stephens 579ji North River Road docketing and Service Station Rogte 3l Office of the Secretary Freeland, MI 48623 US Nuclear Regulatory.

e Washington, DC 20555 Dr Jerry Harbour Lynn Bernabei US Nuclear Regulatory Connaission Governmental Accountability Atomic Safety & Licensing Board Panel Project (CAP)

Washington, DC. 20555 1901 Q Street NW Washington, DC 20009 NOV0783-0001A-CN02 1

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SEP 0 8 1983 MEMORANDUM FOR: James G. Keppler, Regional Administrator FBQ4:

R. F. Warnick, Director, Office of Special Cases

SUBJECT:

MOtfrHLY STATUS REPORT FOR AUGUST,1983 Attached is the status report for the Midland Project for the period of August 1 - August 31, 1983.

Should you have any questions regarding this information, please contact J. J. Harrison of my staff.

"Grigir:sl sis..;d L/.R. F. b'.:rn ick" 1

R. F. Warnick, Director Office of Special Cases

Attachment:

As stated cc w/ attachment:

D. G. Eisenhut, 30tR J. M. Sniezek, IE A. B. Davis, XIII nMs/ Document Control Desk (RIns)

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790 ROOSEVELT ROAD 8

GLEN ELLYN, ILLINOIS 60137 September 7, 1983 MEMORANDUM FOR:

R. F. Warnic:c, Director, Office of Special Cases FROM:

R. J. Cook, Senior Resident Inspector, Midland Site

SUBJECT:

MONTHLY STATUS REPORT Attached is the status report for the Midland Nuclear Construction Site covering the period of August 1,1983, through August 31, 1983,

"'he status report contains the input from each member of the Midland Inspec-tion Site Team of the office of Special Cases.

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Cook Senior Resident Inspector Midland Site Resident Office cc/ attachments J. J. Harrison R. B. Landsman R. N.. Gardner B. L., Burgess

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SUMMARY

OF SIGNIFICANT MIDLAND ISSUES

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1 1.

Heating, Ventilation, and Air Conditioning (HVAC)

Investigation into allegations associated with HVAC equipment by Region III is continuing. A plan has been developed and approved by NRC Region III to determine adequacy of HVAC equipment. The plan involves a random sampling of various pieces of installed ducting and hangers and a sampling of items in storage. After marking, removal and packaging the HVAC pieces, they will be shipped to Argonne National Laboratory in Argonne, Illinois for chemical, physical and nondestructive examination (NDE). Argonne Labora-tory test results will be used to formulate a basis to address allegations

, associated with installation of HVAC equipment by the Zack Company.

2.

Remedial Soils Work Authorization During the report period, the following remedial soils work activities were authorized using the NRC appr.wed work authorization procedure:

a.

Exploratory probing for UAT (Eadt and West).

b.

Pregrout from UAT (East and West).

c.

Drift to excavate and install Piers 14 East and West.

d.

Excavate and install Piers 13 East and West.

e.

Install east and west side level C wales.

3.

Significant Meetings On August 11,1983, the Director, Division of Licensing; Regional Adminis-trator, Region III; Director, Office of Special Cases; and other members of their staffs met with the Midland ASLB Intervenors to discuss technical aspects of the Construction Completion Plan (CCP). A second meeting to discuss the CCP was held with the public later the same day to provide the public with an opportunity to comment.

On August 12, 1983, a meeting was held with Consumers Power Company and the public to discuss the Midland Systematic Appraisal of Licensee Performance (SALP).

On August 25, 1983, a working meeting with Stone and Webster, attended by the public, was held to -clarify the methodology used by Stone and Webster to perfom their overview of the CCP.

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Docket Nos. 50-329/330 y-$-f-j pC--

MEMORANDUM FOR:

G.E. Lear, Chief, Structural & Geotechnical 9E Engineering Branch, y

g, g.-p-j FROM:

Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing

SUBJECT:

CLARIFICATION OF NRR ASSISTANCE IN RESOLVING MIDLAND SOILS ISSUES J

Recent discussions with Region III have occurred to clarify R. F. Warnick's memorandum of March 16, 1983 (Enclosure 1) addressing NRR assistance in resolving Midland soils issues. The clarification focused on the statement that " Region III has assumed all responsibility for reviewing the remedial soils work at the Midland site" Region II: agrees that this statement does not 6pply to changes representing a significant departure from the Midland SER and its supplements or associated hearing testimony. Such changes are to be handled through the nomal licensing process (i.e., by formal request from CPCo to NRR and SER supplements).

Accordingly, in the execution of the Task Interface Agreement 83-40 (TAC #51341; accomplishment No. 141433) included in Enclosure 1 NRR should be alert to recognize early where changes requested by CPCo repre-sent a significant departure from our earlier evaluation, and to assure that such requests and reviews are accomplished in accordance with NRC regulations for licensing reviews and documentation requirements. Please assure that any such changes are identified promptly to the Licensing Project Manager, Darl Hood, in order that proper coordination and documentation be achieved.

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AN Elinor G. Adensam, Chief Licensing Branch No. 4 Division of Licensing

Enclosure:

As stated l

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J. C. Stone. II v D. Heed, 'GJ.

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SEP 1 4 1983' Docket No. 50-329

' Docket No. 50-330 Consumers Power Company

~ ATTN:

Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI ~49201 Gentlemen:

Thank you for your letter dated September 8,1983, informing us of the steps you have taken.to correct the noncompliance which we brought to your-attention in Inspection Report No. 50-329/83-11(OSC); 50-330/83-11(OSC) forwarded by our letter dated August 4, 1983. We will examine these matters

'during a subsequent inspection.

Your cooperation.with us-is appreciated.

Sincerely, NFulad R. F. Warnick, Director Office of Special Cases cc w/1tr dtd 09/08/83: See attached distribution list

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Consumers Power Company 2

BEE I 41083 cc w/1tr dtd 09/08/83:

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair

- Wendell Marshall Colonel Steve J. Gadler (P.E.)

Howard Levin (TERA)

Billie P. Garde, Government Accountability Project Lynne Bernabei, Government Accountability Project e.

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Vice President - Projtess, Enginernng and Construction Generet officos: 1945 West Parnell Road, Jackson, Mt 49201 + (517) 788 0453 September 8, 1983

=Mr J G Keppler, Regional Administrator US Nuclear Regulatory Cocmission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

. MIDLAND ENERGY CENTER INSPECTION REPORT NO 50-329/83-11(OSC) AND 50-330/83-11(OSC)

File:

0.4.2 UFI:

70*01 Serial: CSC-6869 0485.16 42*05*22*04

REFERENCE:

(1) R F Warnick letter to J W Cook, dated August 4, 1983 Inspection Report No 50-329/83-11(OSC) and 50-330/83-11 (OSC)

This letter, including Attachment 1, provides our response to Reference 1, which transmitted the subject Inspection Report and requested our written response to the item of noncompliance therein, w N.

JWC/ BHP /dmh Attachment cc: RFWarnick, NRC Region III JJHarrison, NRC Region III RNGardner, NRC Region III RBLandsman, NRC Region III RJCook, NRC Senior Resident Inspector, Midland Site RLBurgess, NRC Resident Inspector, Midland Site SEP 121983 NOV0783-0001A-CN02 Y4 0

i Serial: CSC-6869 CONSUMERS POWER COMPANY'S RESPONSE TO US NUCLEAR REGULATORY COMMISSION, REGION III INSPECTION REPORT'NO 50-329/83-11(OSC) & 50-330/83-11(OSC)

Appendix (Notice of Violation) to Inspection Report No. 50-329/83-11(OSC) and 50-330/83-11(OSC) provides one item of noncompliance to 10 CFR 50, Appendix 3.

The NRC statement and our responses are given below:

NRC STATEMENT 10 CFR 50, Appendix B, Criterion V states, in part, " Activities aff cti g e

n quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

CPC-1-A Policy 13,~ dandling, Storage, and Shipping; Section 3.3, RECEIPT AND STORAGE, states, in part, " Suppliers provide plans,.

procedures and personnel to.

., store,.

items upon arrival at the site."

Bechtel Power Corporation field Procedure FPG 4.000, Revision 10, Storage -

Maintenan'ce/ Inspection of Equipment and Materials, states in part in Section 6.2.4 " Items shall be stored on dunnage or cribbing to allow for air cir-culation and to minimize the trapping of water."

Contrary to-the above, structural items stored in various areas of the Poseyville Road laydown area were not stored on dunnage or cribbing to allow for air' circulation and to minimize the trapping of water as required by Bechtel Field Procedure FPG 4.000, Revision 10.

This is a Severity Level V violation (Supplement II).

CONSUMERS POWER COMPANY RESPONSE In acccrdance with this Notice of Violation, an explanation of corrective

-action is as follows:

t 1.

Corrective Action Taken and the Results Achieved:

As clarification to the item of noncompliance the structural I-beam identified in your. report was intended for use as a pipe storage rack and was a spare setting alongside others being used as such.

Work orders for placing on dunnage the stock steel and unistrut pieces welded to base plates were issued June 20, 1983, and June 7, 1983, respec-tively. The work was completed June 21, 1983, and verified by CPCo.

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Corrective Action to be Taken to Avoid Further Noncompliance:

Dedicated crews of craftsmen were established July 20, 1983, to maintain the laydewn area in accordance with the requirements of FPG 4.000.

Additional supervision has been added at the Poseyville laydown crea to direct the crews and implement access control for entrance into the laydown area.

3.

The Date When Full Compliance Will be Achieved:

Full compliance has been achieved.

-All the items identified in the Notice of Violation were placed on dunnage June 21, 1983. The unistrut pieces were subsequently moved to the scrap area for salvage on July 23, 1983.

The manning of the dedicated crews and additional supervision have been completed and are presently functioning.

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- i CONSUMERS POWER COMPANY Midland Units I and 2 Docket No 50-329/50-330 Letter Serial CSC-Dated September 8, 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 the response to R F Warnick letter to J W Cook dated August 4, 1983.

CONSUMERS POWER COMPANY By

/L J W Cook, Vice President f

Projects, Engineering and Construction f

Sworn and subscribed before me this f

day of j / ~/ec, 1983.

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.o OL/0M SERVICE LIST-i Mr Charles Bechhoefer, Esq Mr Frank J Kelley, Esq Administrative Judge Attorney General of the Atomic Safety & Licensing Board Panel State of Michigan US Nuclear Regulatory Connaission Mr Stewart H Freeman, Esq Washington DC 20555 Assistant Attorney General Environmental Protection Div 720 Law Building Lansing MI 48913 Dr Frederick P Cowan Mr Myron M Cherry, Esq

' Administrative Judge Cherry & Flynn 6152 N Verde Trail 3 First National Plaza Apt B-125 Suite 3700 Boca Raton, FL 33433 Chicago, IL 60602 Mr Michael Miller, Esq Mr Wendell H Marshall Isham, Lincoln & Beale' RFD 10

-3 First National Plaza Midland, MI 48640 Suite 5200.

Chicago, IL 60602 Mr D F Judd, Sr Project Manager Mr John Demeester The Babcock & Wilcox Company Dow Chemical Building P O Box 1260 Michigan Division Lynchburg, Va 24503 Midland, MI 48640

--Atomic Safety & Licensing Board Panel Ms Mary Sinclair U S Nuclear Regulatory Commission

$711 Summerset Street Washington, DC 20555 Midland, MI 48640 Atomic Safety & Licensing Appeal Board Mr Steve Gadler U S Nuclear Regulatory Commission 2120 Carter Avenue Washington, DC 20555 St Paul, MN 55108 Mr William D Paton, Esq Mr Lee L Bishop Counsel for NRC Staff Hsrmon & Weiss US_ Nuclear Regulatory Com ission 172S I Street, NW #506 Washington, DC 20555 Washington, DC 20006 Ms Barbara Stamiris Mr C R Stephens 5795 North River Road Docketing and Service Station Route 3-Office of the Secret.ary Fyeeland..MI 48623

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US Nuclear Regulatory Washington, DC 20555 Dr Jo. ry Harbour Lynn Bernabei US Nud ear Regulatory Commission Governmental Accountability Atomic Safety & Licensing Board Panel Project (GAP)

Washington, DC 20555 1901 Q Street NW Washington, DC 20009 NOV0783-0001A-CN02

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L Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN:

Mr.' James W. Cook Vice President.

- Midland Project 1945 West Parnall Road Jacksca, MI 49201 Gentlemen:

This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) of the Midland Nuclear Plant, Units 1 and 2, and our meeting of

' August 12, 1983, to review the results of that assessment covering the period July 1, 1981, through March 31, 1983. A copy of the SALP 3 Report.

^

was provided for your. review in advance of the meeting. Enclosed is the

' final SALP 3 Report that incorporates the SALP Board Chairman's letter to you and your letter of September 6, 1983.

From my perspective, your efforts to implement your Quality Assurance (QA) program at the Midland Nuclear Plant during the assessment period clearly were ineffective. This was exemplified by our rating the Soils and Foundatioes functional area as Category 3 and by our identification during the Diesel Generator Building inspection of numerous weaknesses in the implementation of your QA program.

I an encouraged by your concitment to accomplish the improvements necessary to achieve the quality performance level that the NRC expects as addressad in your letter of September 6, 1983.

However, until. improved performance is demonstrated, the NRC will continue to require strong oversight through third party inspections as well as its own inspections. Furthermore, while it is my desire to move away from our role of literally approving day-to-day activities in the remedial soils work I~

to implement the ASLB Board Order, I do not intend to seek relief from that

' Order until we have the needed confidence that work in that area will be carried out effectively.

In accordance with Section 2.790 of the NRC's "Sules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the SALP Rgport will be placed in the NRC's Public Document Room.

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ENEF 1 6 _,d3 e

No reply to this letter is required; however, should you have any q'uestions concerning these matters, we will be pleased to discuss them with you.

Sincerely,

[Y c' James G. Keppler Regional Administrator

Enclosure:

SALP 3 Report No. 50-329/83-09; 50-330/83-09 cc w/ encl:

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan.

Public Service Commission Myron M. Cherry

-Barbara Stamiris Mary Sinclair Wendell Marshall

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Colonel Steve J. Gadler (P.E.)

.c Howard Levin (TERA)

Billie P. Garde, Government

. Accountability Project Lynne Bernabei, Government Accountability Project J. M._ Taylor, IE W

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SALP 3 W

U. S. Nuclear Regulatory Commission Region III Systematic Assessment of Licensee Performance Consumers Power Company Midland Nuclear Generating Station, Units 1 and 2 Docket Nos. 50-329; 50-330 Report Nos. 50-329/83-09; 50-330/83-09 Assessment Period July 1, 1981 through March 31, 1983 J

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CONTENTS

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4 I.~ Introduction.......................................................

1 II.

Criteria..........................................................

3 I I I. S umma ry o f Re s ul t s................................................ 4 IV. Performance Analyses..............................................

5 V.

Supporting Data and Summaries....................................

13 VI. Enclosures.......................................................

19 Letter to Licensee from SALP Board Chairman Licensee Conments I

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INTRODUCTION The NRC has established a program for the Systematic Assessment of j

Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon those observations. SALP

, ' is supplemental to normal regulatory processes used to insure compliance to the rules and regulations. SALP is intended, primarily from a his-torical point,to be sufficiently diagnostic to provide a rational basis for allocating future NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of the staff members listed below, met on June 7, and July 11, 1983, to review.the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, Systematic Assessment of

' Licensee Performance. A summary of the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee safety

~

performance at Midland Nuclear Station, Units 1 and 2, from July 1, 1981 through March 31, 1983.

Inspections were conducted in March and April 1982 to evaluate the significance of the quality control (QC) inspection deficiencies

-identified during the special team inspection of May 1981. These followup inspections indicated that QC inspections were not properly identifying deficiencies in the installation of equipment. As a result of these deficiencies and due to recurring problems in the licensee's remedial soils work activities, increased NRC inspection effort was initiated through the formation of a special Midland Section comprised of inspectors dedicated solely to the Midland plant. Additional:

inspection assistance was obtained through a special contract with a.

Department of Energy Laboratory.

To aid in the evaluation of the as-built condition of the plant, a special inspection of the Diesel Generator Building was conducted during the period of October 12 through November 25, 1982. This inspection identified significant violations which demonstrated a i>reakdown in the implementation of the licensee's Quality Assurance (QA) program. -In addition, it resulted.in the licensee's decision to suspend some safety-related work activities (December 3, 1982) and

. to formulate a construction completion program to pr *ide assurance

- that safety-related structures and systems were constructed as' designed.

Due to the significant violations, the NRC imposed a civil penalty of

=

7 $120,000.

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In view of the suspension of portions of safety-related work activities j'

and the licensee's proposed construction completion program, the Region III Regional Administrator determined that the SALP 3 appraisal for

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g Midlan'd would address only areas where' work act vitici continued; namely q Remedial Soils (Soils and Foundations), the' Nuclear Steam Supply System

'(Safety-Related Components and Piping Systems.and Supports), the Heating, Ventilating, and Air Conditioning System (Support Systems), and Licensing Activities.

0 g

The results of the SALP Board assessments in th'e selected functional areas will be presented to the licensee at a meeting in the near future.

4 SALP Board for. Midland Nuclear Station:

J.A. Hind, Chairman, Director, Division (afRadiologicalandMaterials Safety Programs C. E. Norelius, Director, Division of Project and Resident Programs R. L. Spessard, Director, Division of Engineering T. N..Tambling, Chief, Program Support Section R. F. Warnick, Director, Office of Special Cases E. G.'Adensam, Chief, licensin's Branch 4, NRR J. J. Harrison, Chief, Midland Section R. N. Gardner, Proje:t Inspector R. B. Landsman, Reactor Inspector R. J. Cook, Senior Resident Inspector, Midland B. L. Burgess. Resident Inspector, Midland R. W. Defayette, Reactor Engineer

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-l II. CRITERIA The licensee performance is assessed in selected functional areas depending upon whether the facility is in a construction,' pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because L

of little or no licensee activities or lack of meaningful observations.

Special areas may be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess each functional area.

1.

Management involvement in assuring quality 2.

Approach to resolution of technical issues from safety standpoint 3.

Responsiveness to NRC initiatives 4.

Enforcement-histcry 5.

Reporting and analysis of reportable events 6.

Staffing (including management) 7.

Training effectiveness and qualificat.on i

~

However, the SALP Board is not limated to these criteria and others may have been used where appropriate.

Based upon the SALP Board assessme~nt, each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:

Category 1: Reduced NRC attention may be appropriate. Licensee man-asement attention and involvement are aggressive and oriented toward

- nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.

Category 2: NRC attention should be maintained at normal levels. Li-censee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational

- safety or construction is being achieved.

6 Category 3: Both NRC and licensee attention should be increa, sed. Li-

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censee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resource,t appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.

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III.-

SUMMARY

'0F RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.

Soils and Foundations X

2.

Containment and other Safety Related Structures NOT ADDRESSED IN THIS REPORT

• 3.

Piping Systems and Supports X

4.

Safety Related Components X

5.

Support Systems X

6.

Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT

• 7.

Instrumentation and control Systems NOT ADDRESSED IN THIS REPORT

• 8.

Licensing Activities X

9.

Quality Assurance NOT ADDRESSED IN THIS REPORT

• 10.

Preoperational Testing NOT ADDRESSED IN THIS REPORT *

• For Functional Areas "Not Addressed In This Report" see Section I,

Introduction.

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IV. Performance Analyses 1.

Soils and Foundations.

I a.

Analysis During this SALP period the licensee finalized the Remedial Soils program and initiated steps to implement the Remedial Soils measures necessary to correct previously identified soils deficiencies. The NRC's review and approval of the design of the Remedial Soils measures is documented in Supple-ment No. 2 to the Midland Safety Evaluation Report issued in October 1982. The steps taken by the licensee to implement the Remedial Soils measures during the SALP period include the following:

The excavation of the access shafts to elevation 609 The installation of six temporary underpinning piers Preparatory work for the Service Water Pump Structure underpinning Initiation of temporary dewatering system for the Service Water Pump Structure Initiation of probing for buried utilities adjacent to the Service Water Pump Structure The installation of the permanent dewatering system wells The installation of the auxiliary building underpinning instrumentation system Thirteen inspections (or portions of inspections) were per-formed in this area. During this SALP period a total of nine noncompliances and two deviatiens with NRC requirements were identified as follows:

(1) Severity Level IV - examples of failure to follow pro-cedures and failure to develop adequate procedures-(329/82-03; 330/82-03)

(a) Failure to revise design drawings according to site procedural requirements

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(b) Failure to-develop an adequate excavation. procedure g

(c) Failure to assure design verification acc-erding to site procedural requirements

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(2) Severity Level.IV - examples of failure to develop adequate procedures (329/82-05; 330/82-05)

(a) Access shaft work was initiated without having a reviewed and approved procedure (b) Failure to develop adequate procedures to control specification design changes

.(c) Failure to develop adequate specification for permanent dewatering wells (d) -Failure to develop an adequate procedure to prepare or implement overinspection_ plans (3) Deviation - failure to provide a qualified civil QA staff (329/82-05; 330/82-05)

(4) Severity Level IV - failure to estab'lish a QA program which provided controls over the underpinning monitoring system (329/82-06; 330/82-06). This finding resulted in the issuance of a Confirmatory Action Letter (CAL) on March 31, 1982 (5) Severity Level V - failure to install anchor bolts in tscordance with site procedures (329/82-11; 330/82-11)

(6) Deviation - failure to'use approved installation /coord-ination forms to document'the installation of underpinning monitoring instrumentation (329/82-11; 330/82-11)

(7) Severity Level IV - failure of specifications to identify the location of well sampling points (329/82-18; 330/82-18)

(8) ' Severity Level IV - failure to assure that the slope layback at the Auxiliary Building access shaft was con-

.structed in accordance with design (329/82-18; 330/82-18)

(9) Severity Level IV - examples of failure to establish measures to control the issuance of documents (329/82-21; 330/82-21)

L (a) failure to use a controlled copy of a Project Quality Control Instruction (PQCI) to prepare a QC recerti-

- fication examination. This finding resulted in the

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issuance of a CAL on September 24, 1982

- "f (b) Failure to control QC manuals (10) Severity Level III - failure to translate applicable regulatory requirements concerning the purchase of armor stone for a "Q" portion of the perimeter dike into approp-riate specifications and design documents (329/82-22; 330/82-22) 6 f

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-(11) Severity Level III - failure to maintain current remedial soils drawings (329/83-03; 330/83-03)

The noncompliances identified during this rating period i

are evidence of the licensee's continued lack of atten-tion to detail in assuring that the requirements of the

-Midland QA program were properly implemented. Further-

'more, these noncompliances indicate the lack of manage-ment attention to quality in this' area.

l As a result of noncompliance ites (4) an investigation was performed by NRC to determine whether material false

. statements had been made by the licensee's staff in regard to the installation status of the auxiliary building under-pinning' monitoring instrumentation. The investigation failed to provide conclusive evidence'that a material-false statement had been made.

An' investigation by NRC was initiated during this evabsation period to determine whether the licensee violated the April 30, 1982, Atomic Safety and Licensing

~ Board (ASLB) Order which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit NRC approval. This investigation, which is continuing, focuses on the licensee digging below the " deep Q duct bank" allegedly without NRC approval.

=A management meeting was held at the site on August 11, 1982, to discuss the potential violation of the Board Order.

A CAL was issued on this matter on August 12, 1982.

oncompliance items (10) and (11) are individual examples elated to the soils area taken from much broader items f noncompliance not associated with this fanctional area.

. items 10 and 11 were part of two separate citations'for failure to adequately implement a quality assurance program.)

The two individual examples taken by themselves would not have been rated as severity level III.

l-l

In view of continuing deficiencies in the soils area, the

.ASLB issued an Order on April 30, 1982, suspending a'll' remedial soils activities on safety-related (Q) soils for which the licensee did not have prior NRC' approval.

l Subsequent to this order the licensee resumed remedial soils activities with NRC approval. During the follow-

. ing months numerous problems occurred duef to miscommun-ciation/ misunderstanding between the licensee and the NRC. To resolve these issues a Work Authorization.

=

'T Procedure was developed. This procedure requires the licensee to request and obtain written NRC authorization prior to the initiation of each remedial soils work l

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l-activity.

In addition, the scope of the Work Excavation Permit System was-expanded-to include all remedial soils

. work including underpinning. Due to the NRC's concerns with the licensee's ability to properly implement the quality program in the remedial soils area an indepehdent third party overview was established. All the preceding actions occurred at the direction of the NRC, and were not a result of the licensee's initiative.

1 b.

Conclusions The licensee is rated Category 3 in this area. Although this c

-is the same rating as the previous assessment period, the licensee's overall performance in this functional area has continued to decline. NRC findings during this assessment period indicate a continued lack of attention to detail by the licensee and the continuing inability on the part of the li-censee to implement properly the requirements of the Midland.

'QA program. A rating of less than minimally acceptable (Not.-

Rated) was considered by the Board; however, a Category 3 rating was assigned because of the stringent controls insti-tuted to govern work in this area, i.e., the Work Authorization Procedure, the Work Excavation Permit System, the independent third party overview, and continued scrutiny by the NRC staff.

c.

Board Recommendations The Board recommends that the licensee thoroughly review the performance of construction, engineering, and Quality Assurance managers in the Remedial Soils area. The implementation of measures to provide closer attention to detail in remedial soils work activities and to provide assurance that future remedial soils work will conform to the requirements of-the Midland QA program should be a continuing management goal.

Based on information provided to the Board subsequent to the evaluation period, the Board notes that the licensee has con-tinued to have performance problems in this area.

3&4. Safety-Related Components and Piping Systems and Supports a.

Analysis Portions of ten inspections were performed in the Nuclear Steam Supply System area during the evaluation period. The inspec-

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tions involved the observation of large and small bore hanger installations (including snubbers and restraints), receipt and installation records, modification of the reactor pressure 7

vessel supports, auxiliary feedwater internal header modifica-

-tion, and containment structural steel welding. Within the scope of this effort one item of noncompliance was ' identified i.

as followsi 8

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. ~

Severity Level V - Failure to follow procedures regarding the tagging of a valve located in the welding fabrication area (329/83-01; 330/83-01).

The licensee's resources appear to be adequate. The management controls being utilized, the records, and the records control system met requirements. The overall effectiveness and attitudes of licensee personnel in complying with requirements were con-sidered acceptable.

• o.

Conclusion i

The licensee is rated Category 2 in this area. This is the same rating as the previous assessment period.

c.

Board Recommendations i

The Board notes that subsequent to this evaluation period the NRC has indications that quality problems exist with' installed components, piping, and piping supports. These indicators include the Independent Design and Construction Verification Program (TERA's Monthly Status Report dated May 27, 1983) and the licensee audit conducted February 23, 1983 through March 10,.

1983 (including the R. fember memo to D. Miller dated March 13, 1983)..

NRC inspection activities should focus on assuring that in-stalled items meet the design and regulatory requirements.

5.

- Support Systems a.

Analysis Portions of four inspections were performed covering Heating, Ventilation, and Air Conditioning (HVAC) welder 'cartifications, welder procedure qualification, and material traceability.

No items of noncompliance or deviations were identified during these inspections.

l As a result of a licensee audit of Photon Testing, Inc., the licensee suspended welding of safety-related HVAC work.

Photon Testing Inc. had previously been contracted by the licensee to qualify welding procedures and certify welders for HVAC fabrication and installation. The cumulative audit findings made the credibility of some of the certifications of previously certified welders, as well as the adequacy of l

some of the welding procedures, indeterminate. Due.to the l-7

- audit findings, the NRC imposed a hold point for the restart of safety-related HVAC welding.

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An initial attempt by the licensee to demonstrate to the NRC that affected HVAC welding procedures had been qualified and were ready for implementation demonstrated that the welding procedures were still inadequate. As a result, the NRC did not authorize the licensee to restart safety-related HVAt welding.

No other problems in the HVAC area were identified.

b' Conclusion

-The licensee is rated Category 2 in this' area. This is a lower rating than the previous assessment due to the licensee's failure to initially take adequate correct.ive action to resolve the deficiencies-identified in the Photon Testing, Inc. audit and the licensee managements failure to identify the inadequate

- initial corrective action.

c.

- Board Recommendations Licensee management involvement should be increased in the area of ensuring proper and timely followup to correcting identified deficiencies. The board notes that subsequent to this evalua-tion periad the licensee successfully demons :ated the adequacy of welding procedures and welders to perform o those procedures.

Based on the demonstration, the NRC authorized the resumption of HVAC welding.

8.

Licensing Activities a.

Analysis The assessment was based on our evaluation of the following

~

licensing activities:

Soils and Structures Emergency Planning Equipment Qualification Quality Assurance Program Natural Gas Pipeline Auxiliary Teedvater System Instrumentation and Control Systems Review Seismic Spectra Fire Protection.

Implementation of NUREG-0737 Items For the licensing activities evaluated, there appeared to

^2 be appropriate management attention with decision making taking place at adequate levels. During numerous endits conducted by 10Ut, including audits relating to the ' soils issue, emergency planning, instrumentation and control systems, fire protection and equipment qualification, the records maintained by the licensee were generally complete, 10 i

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.l' well maintained and available. In almost every area, the appropriate level of management participated in meetings with the NRC on' safety, technical, and licensing issues and demonstrated knowledge on the meeting's subject matter.

In the soils remedial areas, a reorganization provided an execu-tive manager fully dedicated to this area; however,.some diffi-culties occurred in the early phases of this reorganization.

Clear lines of responsibility were established in support of the staff's safety evaluation and subsequent issuance of the Safety Evaluation Report. Priorities established by the 11-censee management were generally consistent with and supportive of those priorities established by the staff. Commitments made to incorporate resolutions into FSAR revisions were kept and i

were generally timely. The licensee also made an objective j

and extensive effort to track open issues related to the safety

i evaluation. One issue which involved implementation of a TMI Action Plan Item (Item I.B.1.2) reached an apparent impasse tetween the staff and applicant. However, when the proper level of NRC and licensee management attention was focused on the issue, both sides were able to reach an acceptable resolution. On the other hand, licensee's management failed to recognize the safety significance of constructing a high pres-sure gas facility in close proximity to safety structures until after construction completion.

Generally, licensee personnel involve d in resolution of technical questions were knowledgeable and clearly understood the issues. During the appraisal period, the technical sub-mittals by the licensee to the NRC were usually complete and conservative. Resolution of two technical issues during the safety evaluation required elevation to the Division Director appeals level. In one of these issues, relief was given to

'the licensee. In the other, the licensee was required to commit to installation of a third auxiliary feedwater pump.

In both cases, however, the licensee prepared reasonable technical justification for their position. In addition, the licensee's response once the appeals decision on the auxiliary feedwater-pump had been made was excellent.

The licensing area of soils and structures needs improvement i

insofar as the approach to technical issues. There was reluctance by the licensee to terform certain soils remedial work utilizing accepted quality assurance procedures until required by the MRC.

In regard to the buried piping issue, 1

the licensee appeared to lack a thorough understanding of the safety issues involved resulting in the submission of additional t

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achieved. Improvement in the soils area over the appraisal period.has been evidenced by more specific and clearer sub-mittals to the NRC.

Responses to the NRC were generally timely and thorohgh. The licensee was particularly responsive in the area of instrumenta-

-tion and control systems. Additionally, in questions concerning the natural gas pipeline, the licensee demonstrated a willing-ness to address NRC concerns effectively and responsiveness increased accordingly. Responsiveness was rated poorly for those licensing issues which remained unresolved for a long period of time such as resolution of the buried piping problem.

.With respect to' licensing staff, positions appear to be well defined and responsibilities identified. Staff is adequate and at levels consistent with the activity for the licensing activities evaluated. The licensee effected reorganizations and personnel replacements within a reasonable time insofar as_ key positions are concerned. In some cases, however, the staff considers that too much reliance was placed upon repre-sentation by consultants and by the architect / engineer.

b.

Conclusion The licensee is rated Category 2 in this area.

Generally, in licensing activities, the licensee expressed a willingness to respond to NRC initiatives. Submittals were usually timely and thorough. Especially notable is the degree of management attention directed toward licensing activities as evidenced by meeting participation and the level at which decisions occur. Areas of above average performance in all criteria include instrumentation and control systems reviews. Conversely, although improvement in the soils area has been seen-during this appraisal period, it is imperative'for the licensee to continue to focus a high level of management attention in the soils area in order to maintain an acceptable level of performance insofar as licensing activities are concerned.

c.

Board Recommendations A high' level of licensee management attention should be con-tinued in resolving the adequacy of responses to technical issues and improvement of management controls in the area of remedial soils and underpinning activities.

5 12

V.

Supporting Data and Summaries A.

Noncompliance Data Facility Name: Midland, Units 1 and 2 Docket Nos. '50-329

.-50-330 Inspections:

No. 81-14 through 83-05 Noncompliance and Deviation Severity Levels Functional Area Assessment I

II III IV V

Dev 1.

Soils and Foundations 2

6 1

2 2.

Containment and Other Safety-Related Structures NOT ADDRESSED IN THIS REPORT 3.

Piping Systems and Supports 4.

Safety-Related Components 1

5.

Support Systems 6.

Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT 7.

Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT 8.

Licensing Activitias 9.

Quality Assurance NOT ADDRESSED IN THIS REPORT

10. Preoperational Testing NOT ADDRESSED IN THIS REPORT TOTALS 0

0 2

6 2

2 S

13

I.

6 B.

Repcrc Data 1.

Construction Deficiency Reports (CDR)

During this SALP period,19 CDR's were submitted by the licensee under.the requirements of 10 CFR 50.55(e).

Operating procedures must be modified to require at least a.

one reactor cavity cooling fan in service during normal plant operation.

b.

For certain control circuits, a voltage below the limits for proper operation of the motor control center starter coils was calculated. This line voltage drop is a direct result of currents passing through long control cables.

c.

The design of electrical components associated with the main steam isolation valves does not conform to the channel separation criteria in Reg. Cuide 1.75; also, satisfactory seismic qualification reports have not been submitted.

d.

Rodent damage has occurred in electrical penetration wiring and cables.

e.

The auxiliary feedwater level control valves are fed from Class lE instrument control power instead of Class lE preferred power supplies as specified in the FSAR.

f.

' The existing design of the auxiliary feedwater system pump turbine driver stesa admission valve interlock system would block steam entry and prevent proper operation.

g.

It has been determined that instrument string error in the steam generator level circuits, under accident conditions, exceeds that allowed to establish steam generator ECCS control setpoints.

h.

Recent inspections at three operating B&W plants indicated damage to the internal auxiliary feedwater header assemb-lies. New external headers will provide all functional requirements.

i.

During an engineering review it was discovered that some Q-related equipment'is located in the auxiliary building that is cocled by a non-safety grade HVAC system. During an accident, this could result in some Q-equipment being

= -

lost.

J.

B&W supplied non-seismically qualified transmiAter mount-ing brackets for transmitters forming part of the reactor coolant pressure boundary.

14

F r

k.

Approximately 80% of.the radiation monitoring modules, manufactured by Victoreen, Inc. were found to be noncon-

. forming. This was due to a significant QA breakdown at the supplier.

1.

During field modifications of 460V Class IE motor control centers supplied by ITE-Gould it was discovered that some of the control power transformers were undersized.

m.

The incorrect size class IE power cables were pulled and installed.

4 En.

ACI 349, Appendix B, issued August 1979 specifies that shear lugs in embedment designs shall be considered effec-tive only in compression zones. Some Midland embedment designs, which were completed and. installed prior to this date, do not meet this new criterion.

o.

No specific features to mitigate frazil ice formation on the service water intake structure are contained in the design of the service water intake structure.

p.

The design of the suction piping for the auxiliary feed-water system did not include overpressurization protection.

q.

Unacceptable worbaanship coeditions have been identified on electrical control panel sad cabinets supplied by various suppliers.

r.

Bailey Controls Company NI/RPS and ECCAS cabinets have terminal blocks which are fastened to the termination-panels by Tinnerman Nuts..These nuts could become loose.

s.

Class IE electrical control cabinets appear to have in-sufficient clearances from adjacent equipment or walls.

The licensee's threshold for reportius is considered to be appropriate and the total number of items reported is not con-sidered to be excessive.

2.

Part 21 Reports

(-

The licensee issued no Part 21 reports during the reporting period.

C. ; Licensee Activities The main construction areas during the evaluation period were.NSSS work, electrical equipment, conduits, cable trays, cables, HVAC, remedial soils work, small and large bore piping, pipe hangers and snubberst As a result of the diesel generator building inspection, the licensee halted on December 3, 1982, safety-related work with the exception of the following: system layup, hanger and cable reinspections, post system 15 J

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e turnover work, HVAC work, NSSS work, remedial soils work, and design engineering. -Preoperational testing was conducted on the Component Cooling Water System, the Decay Heat Removal System,and the Fuel Transfer System.

Units 1 and 2 were reported by the licensee to be 79% complete per the licensee's. letter to.Hatfield (NRC) dated May 6, 1983. Fuel load dates are < timated by the licensee to be February 1985 and October 1984, resp tively.

.D.

Inspection Activities The routine inspection effort by the NRC consisted of 39 inspections during

.the evaluation period.

In addition; a special team inspection (329/82-22; 330/82-22) was conducted to assess the adequacy.of implementation of the quality a surance program.

This assessment was done for the most part in the diesel generator build-

ing where the majority of work was performed subsequent to 1980. This inspection resulted in the licensee suspending some safety-related work on December 3, 1982.

I E..

Investiaations and Allegations Review 1.

An investigation was conducted to determine whether material false statements had been made by the licensee's staff in regards to the installation status of the auxiliary building monitoring instrumenta-tion. The investigation report (329/82-13; 330/82-13) failed to provide conclusive evidence that a material false statement had been i

made.

2.

An investigation was being conducted during this SALP period to deter-eine whether the licensee violated the April 30,'1982, ASLB order which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit NRC approval. The report 4

was not issued during this SALP period.

3.

A number of allegations were received during this SALP period regard-ing MVAC work by Zack, welding, electrical work, and deficiencies in the implementation of the CPCo QA/QC program.

Investigations or i

special inspections to resolve some of the issues identified within these allegations were initiated during this SALP period.

F.

Escalated Enforcement Action 1.

Civil Penalties

=

A Civil Penalty for $120,000 was issued during this evaluation period in regard to the adverse findings identified during the. diesel gener-ator building inspection (329/82-22; 330/82-22). The licensee's request for mitigation of the amount is under review by the NRC staff.

I I

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2.

Orders The ASLB issued an order on April 30, 1982, which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit,NRC approval. The ASLB issued a hubsequent clarifying order on May 7, 1982.

G.

Administrative Actions 1.

Corrective Action Letters A letter of understanding was issued by the licensee en a.

March 31, 1982, in response to deficiencies observed during the inspection of the auxiliary building monitoring instru-mentation.

(329/82-06; 330/82-06). This matter is also discussed in Section-V.E.1. of this report.

b.

-A Confirmatory Action Letter (CAL) was issued on August 12, 1982, in response to a potential ASLB order violation (329/82-18; 330/82-18). This matter is also discussed in Sections IV.1.a and V.E.2 of this report. Resolution of these concerns was still under investigation at the end of the SALP period.

c.

A CAL was issued on September 24, 1982, in response to deficiencies observed during the inspection 'of remedial soils 2

QC inspectors recertifications (329/82-21; 330/82-21).

.d.

A Jetter of understanding was issued on December 30, 1982, in response to deficiencies observed during the diesel

' generator building inspection (329/82-22; 330/82-22). This matter is also discussed in Sections V.C and V.F.1 of this report.

2.

Manasement Conferences During this SALP period eighteen conferences were belo between NRC and licensee manag= cent:

a.

On July 24, 1981, a management meeting was held to discuss inspection findings pertaining to irregularities in control and review of small bore piping system design packages.

i b.

On January 12, 1982, a management' meeting was held to review and discuss recent changes to the Midland QA organization and the QA program for the remedial soils work.

=

c.

On March 30, 1982, a management meeting was held to discuss NRC findings in the installation of underpinning monitoring i

instrumentation.

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d.

On April 26, 1982, a meeting was held to present to CPCo management the SALP 2 findings.

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On May 14, 1982, a meeting was held during which the licensee

. presented a preliminary report of the results of the electrical cable reinspections.

f.

On June 21, 1982, a meeting was held to discuss CPCo's response to SALP 2.

3 On August 5, 1982, a meeting was held to further discuss CPCo's responses to SALP 2.

h.

On August'11, 1982, a management meeting was held to discuss a potential violation of the ASLB order of April 30, 1982.

i.

On August 26, 1982, a management meeting was held to discuss Midland QA problems.

J.

On. September 2, 1982, a management meeting was held to discuss the Quality Improvement Plan.

k.

On September 29, 1982, a management meeting was held to discuss the integration of QC activities into Midland Project Quality Assurance Department (MPQAD).

1.

On October 5, 1982, a meeting was held to discuss the CPCo-TERA proposal concerning the Independent Design Verification Program (IDVP).

m.

On October 29, 1982, a meeting was held to discuss Bechtel performance / problems.

n.

On November 5, 1982, a meeting was held to discuss Stone and Webster (S&W) qualifications for performance of remedial soils third party overview.

o.

On January 18, 1983, an enforcement conference was held to discuss the diesel generator building findings.

p.

Cha February 8,1983, a management meeting was held to discuss the CCP and the IDLVP as well as CPCo and Bechtel performance

)

and desire to take proper corrective action. In addition, the NRC announced the imposition of a $120,000 fine due to diesel generator building findings.

q.

-On March 7, 1983, a meeting was held to further discuss the CCP.

r.

On March 15, 1983, a meeting was held to discuss the INPO Self Imposed Evaluation results.

I 3

Construction Permit Amendment C

On May 26, 1982, the NRC amended the Construction Permits, CPPR-81 and CPPR-82, to implement the ASLB April 30, 1982, Order suspending all remedial soils activities on "Q" soils without prior explicit NRC approval.

18

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t VI.

ENCLOSURES O

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'JUL 2 1 ss3 Docket Ne. 50-329 Docket No. 50-330 Consumers Power Company ATTN: Mr. James W. Cook i

Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Centlemen:

This refers to the NRC's Systematic kssessment of Licensee Performance

($ ALP) for the Midland Nuclear Plant, Units I and 2. for the period July 1, 1981 through March 31, 1983.

A seering vill be scheduled with you in the near future in w::1ch Mr. James G. Keppler and members of the NRC staff will present the obser-vations and findings of the SALP Board. The more significant'SALP Board

'indings are su=carized in Enclosure 1.

The enclosed SALP Report which documents the analyses, conclusions and recommendations of the SALP Board i

is for your review prior to the meeting.

Since this meeting is intended to be a forum for the mutual understanding of the-issues and findings, you are encouraged to have appropriate repre-sentation at the meeting. As a minimum we would suggest you, the Site

-Manager, $1te QA Manager, and managers for the various functional areas where probler.s have been identified attend the meeting. Any comments you may have regarding the SALP Report, as well as the SALP process, may be discussed at the meeting. Additionally, you may provide written comments

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within 20 days after the meeting.

I 1

Following our meeting and receipt of your written response, if any, the enclosed zeport vill be issued. The letter issuing the report will provide you a characterization of your overall safety performance along with any appropriate supplemental information regarding the report.

i in accordance with Section 2.790 of the NRC's " Rules of Practice" Part 2 l

Title 10, Code of Federal Regulations, a copy of this letter, the SALP Report, and your con =ents, if any, will be placed in the NRC's Public Doevaent Room when the SALP Report is issued.

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~JUL 2 I si3 If you have any questions concerning the SALP Report we vill be happy to discuss ther with you.

Sincere 19.

Ali

. Hind, Chairman Region III SALP Board Director, Division of Radiological and Materials Safety Program

Enclosures:

1.

Summary of Significant Findings (5 cys) 2.

Preliminary SALP Report (5 cys) cc w/encls:

Director, OIE Resident Inspector, RIII Project Manager, NRR PAO, Regien III m

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Sinnificant SALP Report Findings for the Midland Nuclear Generating Station Units 1 and 2 General Observations Inspections were conducted in March and April 1982 to evaluate the significance of the quality control (QC) inspection deficiencies identified during the special team inspection of May 1981. These followup inspections indicated that QC inspections were not properly identifying deficiencies in the install-ation of equipment. As a result of these deficiencies and due to recurring probless'in the licensee's remedial soils work activities, increased NRC inspection effort was initiated through the formation of a special Midland Section comprised of inspectors dedicated solely to the Midland plant.

Additional inspection assistance was obtained through a special contract with a Department of Energy Laboratory.

To aid in the evaluation of the as-built condition of the plant, a special

~

inspection of the Diesel Generator Building was conducted during the period of October 12 through November 25, 19.82. This inspection identified signifi-cant violations which demonstrated a breakdown in the implementation of the licensee's Quality Assurance (QA) program.

In addition, at resulted in the licensee's decision to suspend some safety-related work activities (December 3, 1982) and to formulate a construction completion program to provide assurance that safety-related atructures and systems were constructed

. as designed. Due to the significant violations, the NRC imposed a civil penalty of $120,000.

In view of the suspension of portions of safety-related work activities and-the licensee's proposed construction completion program, the Region III Regional Administrator determined that the SALP 3 appraisal for Midland would address only areas where work activities continued; namely, remedial soils (Scils and Foundations), the Nuclear Steam Supply System (Safety-Related Components and Piping Systems and Supports), the Heating, Ventilating, and Air Conditiocing System (Support Systems), and licensing activities.

4 Functional Areas 1.

Soils and Foundations Overall performance in this functional area has continued to indicate a declining trend and remains an area of concern. The decline was due

to the continued lack of attention to detail and the continuing inability on the part of the licensee to implement properly the requirements of

[ the Midland QA program.

3.&4, Safety-Related Components and Piping Systems and Supports q Performance in this functional area remains adequate. However, the NRC plans to cond' set a special inspection to evaluate this area in the near future.

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Support Systems Perforzance in this ' functional area has declined from category 1 to category 2.

The decifne was due to the lack of management attention to identified problems and the lack of timely corrective action to resolve these problems.

8J Licensing Activities Performance in this functional area remains adequate. Generally, responses are timely and technically correct. However, while the 4

licensing aspect of the soils issue has shown improvement over the appraisal period, the licensee should continue to focus a high level of management attention on this area.

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Consumers Power

- r James W Cook C0mp0Ry v <, r,,,is,., - r j,,,

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Generet offices: 1945 West Pwnael Road, Jeckson. MI 48201 e (517) 7stro453 September 6, 1983 V }

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y Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT RESPONSE TO DRAFT SALP REPORT FILE 0.6.1 SERIAL 25682 Consumers Power Company has received and reviewed the NRC's Systematic Assess-ment of Licensee Performance (SALP Report) for the Midland Nuclear Plant, Units 1 and 2, for the period July 1, 1981 through March 31, 1983 and acknow-ledges the NRC's comments.

Consumers Power Company recognizes the purpose of the SALP Report and is committed to accomplish the improvements necessary to achieve the quality performance level that both the NRC and the Company desire.

The Company is particularly concerned about the SALP svaluation in the Remedial Soils work and will devote the management attention necessary to establish improved overall performance in this area. Efforts will be focused on addressing the NRC's concern regarding attention to detail and implementa-tion of the Quality Assurance Program. Our managment team is dedicated to assuring that future Remedial Soils work will conform to the requirements of the Midland QA Program.

The Company believes that the elements of the CCP Program are sound and that l

it will result in a well controlled process by which to both verify the quility of past completed construction and ensure the quality of construction work yet to go.

Th'e CCP may need some refinement as we gain experience with it, but as a managemen*: team we are dedicated to give it the attention and suppert needed.

We vill modify it, as, change is needed, to ensure that it works. The success-ful implementation of this program vill clearly support the Company's goal of meeting the requirements of the Midland QA Program.

3 DR0883-0001A-QLO7

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In conclusion the Company has evaluated the contents of the SALP III Report and the management team will take whatever steps are necessary to achieve the quality performance level that both the NRC and the Company desire. -

CC DSHood, US NBC RJCock, Midland Resident Inspector e

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OM/0L SERVICE LIST Mr Frank J Kelley, Esq Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General

' Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief, Do::keting & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr My'ron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, MI 48640 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Federick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca.Raton, FL 33433 Freeland, MI 48623 Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr."*mes E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lp chburg, VA 24505 Midland, MI 48640 Mr' Steve Gadler, Esq Ms Lynne Bernebei 2120 Carter Avenue Government AccountaEllity Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 9/3/83.-

m3 0583-0429a l,00

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[p eere UNITED STATES E

NUCLEAR REGULATORY COMMISSION.

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799 ROOSEVELT ROAD GLEN ELLYN, ILLINOIS 40137 September 16, 1983

' MEMORANDUM FOR:

D. H. Danielson, Chief, Materials and Processing Section THRU:

R. J. Cook, Senior Resident Inspector, Midland Site FROM:

R. C. Janke, Assistant Inspector (Co-op), Midland Site

SUBJECT:

SAMPLING OF THE ZACK COMPANY HVAC MATERIAL This. memo' refers to the cutting of samples by the Zack Company for NRC destructive examination inspection. On August 31 and September 1, 1983, Messrs.

D. H. Danielson and Wm. J. Key selected samples of HVAC structural material from various locations in the Midland Plant. Zack Company and Consumers Power MPQAD personnel witnessed the sample selection to insure an accurate listing would be made. By Tuesday, September 6,1983, the necessary ' travelers were prepared by Zack Company and cutting of the samples commenced on Wednesday, September 7, 1983. The sixty eight samples had been removed and cataloged by September 12, 1983. The attached list is a revised addition including drawing numbers and sample descriptions. As per your request, I personally observed the cutting and inscription of information on each piece of material.

It is anticipated that shipment to the Region of these samples will occur on September 21, 1983.

'If there are any questions, please contact me.

[

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As R. C.tJa e Assistant Inspector (Co-op)

Midland Site cc/w attachment J. J. Harrison

>R. F. Gardner W. J. Key J

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' Sample

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No.

'ID No.

Traveler.

V Drawing

. Sample Description Welds 1.-

Duct 209A-P4582 25 sh 3 Long. seam weld

.Yes 2.

Hgr. 75A-F17525 25 sh 3' 3/6~x 3i x 3} angle No

-(structural) 3 Duet 231

'F3730.

25 sh-3 Long.' seam weld Yes

4.

Duct 33C.

F21555 25 sh 3 Sheet sample.

No 5.

,Hgr. 88B F9835

. 25 sh 3 31.x.33 x 1" angle no

'6.

Hgr. 21' F720 25 sh 3 3i x 3! x i angle No

-7.

Duet-61 F788 25 sh 3 Sheet sample No 8.

Duct 44A

~F19839 25 sh 3 3/8" bolt No End_ Cap 9.

Duet 44A F19839 25 sh'3' 3/8"-bolt No

^End Cap.

10.

Duct 251 F17595 25 sh 3 Sheet sample No II..Diese) Generator Bldg.

A.

Say 4 11._

. Duct 29 F11601 85 Leni;. seam weld Yes 7

12.

Duet 63 F13735 85 Sheet sample No E.

Eay 3 13

, Duct 115 F11075 85 Sheet sample No

.14.-

15. - >.

'Hgr. 102 F11230 85 3 - structurals Yes Intersection of Vert.,

-16.-

Hor:. & Transverse members e

- *.. e

. g. _.

e

,s

- 111. : Service: Water Bldg.

~

Sample No.

ID No.

Traveler V Drawine Samp}e Description.

Welds

17. -

'Hgr. 4A' F2213 S3 3 x 3 x ! angle No 18.

.Hgr. 1.5

'F16702 S3 2 x-2 x i tube steel No i

19.

Duct.93 F10349 83 Longitudinal. corner weld -Yes 20.

. Duet 86.5 P553 83-Sheet sample No 21.

Hgr. 18B F14377 83 3 x 3 x i angle No

.22.

Hgr. 39A F9991 83 3i x 3i x i angle Yes l:

23 24.

Hgr. 36A F14376 83 3x3xi angle

'Yes with 1" Shis Plate l

25 '.

Duct 77A F12145 83

}" 6 Bolt No-26.

Duct 76A F12143 E3 j" 6 Bolt-

'No i

l l

[

. IV.

Eattery Room A.

Roo: 357 27.

hgr. 12A F14911 22 sh 2 2x 2 x 1" angle No 28.

Duct 11 F7245 22 sh 2 Sheet sa:ple No i

l E.

Roac 355 i

29.

Duct 39 F7331 22 sh 2 Sheet sample No 30.

Hgr. 20A F9530 22 sh 1 2 x 2-x i angle &

Yes 5/16" plate C.

Roo: 356 31.

Duct 3A PS25G 22 sh 1 Snect sa=ple No i

l.

32.

'Hgr. 8 F14196 22 sh 1 2 x 2 x 1" angle NC e

8 n

---u.-

---

.--,,--_~------___-----_----__---__w_-----_---

- -aw

's

~

a f

E*

Y, Auxiliary Eldh.~

~'

Sample.

- No.

'1D Nc.

Traveler Y Drawing Samolc Descr10 tion

' Melds

'A.

Cable Chase ES.6

-33 Hgr. 4

'F2507 22 sh 1B ll x 13 x 2 angle No

'34.

Duct-9A P4644 22 sh 1E Sheet sample No E.

C1ble Chase V7.8

^ 35.

Hgr.-25 F3755 22 sh 2B

.2 x 2 x i angle Yes i-

'VI.-

Containment - Unit 2 36.

Hgr. 4 F15721 34 sh 1 4 x 4 x i ang e No 37.

Hgr. 19 F7565 32 sh 2 3 x 3 x 2 angle No 35.

Hgr. 10 F6130 12 sh 2 4 x 4 x 3/8" angle No 39.

Hgr. 22 F17084 13 sh 1 3 x 3 x ! angle No VII.

Auxiliary B1dg. (Filter System) 40.

Hgr. 22

?19959 9 sh 2 4x4xi tube steel No

!III.

Material Issue Room - Job Site Stock

~

~

41.-

2 - Bolts 3/8 6 x 2 1/2" 4 2..-

43.-

- ' 2 - Bolts 1/2" d x 3 1/2 - Non 0 Ites - seistic Class II

~

44.-

45.-

-- ' 2' - Bolts 5/8" d x 2 1/2" i

46..

I e ~

S

(

(

=v

.~,s:-

, f:

SIX. - ' Fabri cat' ion Shop Job' Site Stock Sample MCN tha.

No.

Descriotion of Material

.47.

855-8 C Channel-

-C6 x.13#

j e48,

1935-5 C Channel C5 x 9# ~

449.-

1163 C Channel-C4 x 5.40 50..

101E-1 Tube Steel 6 x 4 x A"-

51.

1937-1 Tube Steel 1x 1 x la

^ '

52.

C2410-5 WF 8" I Beam 53 1462 -2 Plate 3/4" x 4" 5 4. --

C1064 WF I Beam 55.

1687-3 Plate 5/8" x 2" 56.

-C2560-5~

1 Plate 1" Plate x 34j"

_X.

Fabrication Shoo Weld Coupons Sample No. of Coll.

No.

Pieces No.

Description 57.

2

. 720 18 gauge 58.

- :7 -

711 22 gauge 59 2

C2547-5 10 gauge 60.

2 C2619-1 12 gauge XI.

Poseyville Laydown Area Sample tha.

ID No.

Traveler V Drawing Sample Description Welds 61.

Duct 37 P3642 25 sh 1 Sheet Sample

-No 62.

Duct 66 F14202 25 sh 1 Sheet sample No J

a,

'XII hectt<;td'Msterial Sample-Nc.

ID No.

Traveler V Drawing Sacole Description

'n'e l d s 63 Duct 109 R8792 27 sh 3 Stitch welds Yes

' 64.

Duct 152 F13738 -

65 Seam weld gored elbow Yes 65.

Duct 250,

F13749 65 Sea weld-sored elbow Yes 66.

Duct 40 F4613 11 sh 2 corner weld, fire da=per Yes sleeve 67.

Duct.20 F5863 27,sh 4 Seas weld; sq. to.round Yes (Non Q Material)

XIII.

Fabrication Shoc - Job Site Stock

'68.

MCN c 812-5 C channel.

3 x 5.4e Y$

as S

+

6 9

8 9 @

G P

l

- +

~ ~..,. _

-+