ML20094M455

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Notifies of Intent to Continue Const of Plant Following Recent Notification from Dow Chemical Co of Decision to Terminate Agreement to Purchase Energy.Related Info Encl
ML20094M455
Person / Time
Site: Midland
Issue date: 07/15/1983
From: Fitzpatrick R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Strasma J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19258A087 List: ... further results
References
CON-BX21-019, CON-BX21-19, FOIA-84-96 NUDOCS 8408150652
Download: ML20094M455 (72)


Text

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JACKSCNe MICMlGAN 7-15-83 10:d2 AM THE FOLLCVING IS FOR YCVR INFORMATION.

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JACKSON, MICH, JULY 15, 1983--CONSLMERS P0nER COMPANY WILL CCNTINUE CONSTRUC1ICN OF ITS NUCLEAR PLANT IN HIOLAND, JAMES S FALAFEE, VICE CHAIRMAN CF CONSUMERS PO*ER,,ANNCUNCED TODAY.

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t "THIS IS THE ONLY PRUDENT STEP FCR US TO TAKE," FALAMEE SA10 "THE ELECTRICITY TbAT aILL BE ARCDUCEO BY THAT PLANT WILL BE NEECED BY

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  • ICHIGAN CUSTOMERS IN THE FUTURE."

THE WIOLAND PLANT, HE SAID,

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aILL 6E A VALUABLE ASSET TC THE STATE CF MICHIGAN.

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THE PLANT IS 81 PERCENT COPPLETE.

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Ot! T*URSCAY, CCNSUPERS PO*ER COMPANY

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CFEMICAL COPPANY THAT IT HAD TER*INATEC THE AGREEMENT TO PLRCHASE

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ENESGY FWOM THE MICLAND ALANT.

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FALAPEE 15 SLED A GENERAL DENIAL TO ALLEGATIONS FILEC EY Con

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Cwc"ICAL CCPPANY IN THE COLNTY CF PICLAND CIRCUIT CCURT CONCERN-ING CONSTkLCTICN PEORLEMS AT THE PLANT.

"N0h, TPOLGH, IS ACT THE

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TIPE TC MAME ALLEGATICt.S OR COUNTER ALLEGATICNS," FALAHEE SAID.

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4AlhEF, eb SAIC, CCNSUPERS ACaER aILL ASSESS THE ENTIRE SITLATION 1-ANC ?A4E CCFFENTS IN TrE FL,TLHL T H Ei O U G F LEGAL PRCCECLRES.

h "Tbt SUPPLY OF STEAM FCH DCh aAS JUST A PORTION CF CUR HIDLAN3 52 840718 ISE SIDE FOR WESTERN UNION'S TOLL - FREE PHONE NUd8Ek } 8 }$;h g8 s

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PROVIDE RELIAiLE, LOW-CCST ELECTRICITY FOR CLR 1.3 FILLICN CLS=

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WE INTEND TO CONTINLE FLLFILLING THAT MISSIGN.

MICLAND DILL FLAY A PAJOR HCLE IN THE ENERGY FLTURE CF THIS STATE,"

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July 29, 1983 if un? YlJc.. ;_,p$ h5 Docket Nos: 50-329 OM, OL 3pp and 50-330 OM, OL aq y p

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.LETON,h MEMORANDUM FOR: The Atomic Safety and Licensing Board for the Midland Plant, Units 1 and 2 FROM:

Thomas M. Nw ak, Assistant Director for Licensing, Division of Licensing

SUBJECT:

BOARD NOT7FICATION - NEW INFORMATION RELATING TO SOILS REMEDIAL WORK, lELDING AND THE DOW CONTRACT (BN 83-106)

This information is prwided in accordance with the present NRC procedures regard-ing Board Notification.

The following information :leals with new developments in various aspects of the Midland proje:t. Portions of the notification may be relevant to the Midland OM/0L proceedings in areas of soils remedial work, HVAC systems, Quality Assurance and the Dow Chemical legal proceedings.

Any additional information relevant to these issues will be prwided in a future Board Notification.

Inomas M. Nw ak, Assistant Director for Licensing Division of Licensing 8306270424 AUG 0 81983

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i DISTRIBUTION LIST FOR BOARD NOTIFICATION Midland Units 1&2, Docket Nos. 50-329/330 ACRS Members Charles Bechhoefer, Esq.

Dr. Robert C. Axtmann Ms. Lynne Bernabei Mr. Myer Bender James E. Brunner, Esq.

Dr. Mex W. Carbon Dr. John H. Buck Mr. Jesse C. Ebersole Myron M. Cherry, P.C.

Mr. Harold Etherington Dr. Frederick 3 Cowan Dr. William Kerr T. J. Creswell Dr. Harold W. Lewis Steve J. Galder, P.E.

Dr. J. Carson Mark Dr. Jerry Harbour Mr. William M. Mathis Mr. Wayne Hearn Dr. Dade W. Moeller Mre James R. kates Dr. Milton S. Plesset Frank J. Kelley, Esq.

Mr. Jeremiah J. Ray Christine N. Kohl, Esq.

Dr. David Okrent Mr. Wendell H. Marshall Dr. Paul C. Shewmon Michael I. Miller, Esq.

Dr. Chester P. Siess Thomas S. Moore, Esq.

Mr. David A. Ward Mr. Paul Rau Ms. Mary Sinclair Ms. Barbara Stamiris Frederick C. Williams, Esq.

Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Panel Docketing and Service Section Document Management Branch l

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' MIDLAND (ForBNs)

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Mr. J. W. Cook 1

Vice President Consiners Power Company 1945 West Parnall Road Jackson, Michigan 49201 cc: Stewart H. Freeman James G. Keppler, Regional Administrator Assistant Attorney General U.S. Nuclear Regulatory Commission, State of Michigan Enviornmental Region III Protection Division 799 Roosevelt Road 720 Law Building Glen Ellyn, Illinois 60137 Lansing, Michigan 48913 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way 124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909 Mr. R. B. Borsum Geotechnical Engineers, Inc.

Nuclear Power Generation Division ATTN: Dr. Steven J. Poulos Babcock & Wilcox 1017 Main Street 7910 Woodnont Avenue, Suite 220 Winchester, Massachusetts 01890 Bethesda, Maryland 20814 Billie Pirner Garde Mr. Don van Farrowe, Chief Director, Citizens Clinic Division of Radiological Health for Accountable Government i

Department of Public Health Government Accountability Project P.O. Box 33035 Institute for Policy Studies Lansing, Michigan 48909 1901 Que Street, N.W.

U.S. Nuclear Regulatory Commission Resident Inspectors Office Commander, Naval Surface Weapons Center Route 7 1 ATTN: P. C. Huang l

Midland, Michigan 48640 White Oak Silver Spring, Maryland 20910 Mr. Paul A. Perry, Secretary

. Consumers Power Company Mr. L. J. Auge, Manager 212 W. Michigan Avenue Facility Design Engineering Jackson, Michigan 49201 Energy Technology Engineering Center P.O. Box 1449 Me. Walt Apley Canoga Park, California' 91304 c/o Mr. Max Clausen Battalle Pacific North West Labs (PNWL)

Mr. Neil Gehring Battelle Blvd.

U.S. Corps of Engineers SIGMA IV Building NCEED - T Richland, Washington 99352 7th Floor 477 Michigan Avenue Mr. I. Charak, Manager Detroit, Michigan 48226 NRC Assistance Project Argonne National Laboratory 9700 South Cass Avenue Argonne, Illinois 60439 s

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D. G. Eisenhut, Director, Division of Licensing, NRR FRON:

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

SUBJECT:

RECOMMENDATION FOR NOTIFICITION OF LICENSING BOARD In accordance with present NRC procedures ragarding Board Notifications, the following information is being provided as constituting new infor-motion, some of which is relevant and mater!.a1 to the Midland OM/0L proceedings.

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'A.

This information deals with the licensce's July 11, 1983, decision to stop all Service Water Pump Structure (SWPS) related dewatering well drilling. The pertinent facts that relate to the stop work are at follows:

1.

(n July 9, 1983, Bechtel Construction stopped drilling on well #521 when an obstruction was encountered at approximate elevation 619.5 feet. The licenses thought that the obstruction was most likely bedding material for a non-Q prestressed concrete pipe connecting the service water system to the cooling tower.

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On July 9, 1983 Bechtel Construction stopped drilling on piezameter fLS-7 when an obstruction was encountered at approximate elevation 614.5 feet. The licenses thought that the obetruction was most likely the mud mat from an electrical duct-bank.

3.

On July 11.-1983, the NRC was informed of these two incidents by a conference call from the licenses. Midland Project Quality Assurance Department (MPQAD) decided to issue a formal stop work on all SWPS drilling after these discussions.

At the current time all drilling around the SWPS remains stopped pending the licensee's completion of their corrective action to preclude recurrence. The events and the licensee's corrective actions are described in the attached letter from Mooney to Harrison, dated July 15, 1983.

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-QQ Y 1 $33 B.

There appears to be a continuing lack of attention to detail in the implementation of the remedial soil / underpinning programs. '1his is illustrated by the latest Stone and Webster weekly report No. 41, which is attached. The report indicates problems such as untimely resolution of outstanding NCR's, not meeting the intent of design drawings by extending the slope layback under the electrical penetration area (EPA), and not keeping the number of attached changes to a design drawing within workable limits.

1 On July 13, 1983, the Region III staff performed an inspection of the matters described in paragraphs A. and B. above and questioned why soils work should continue. The licensee's response, dated July 15, 1983, to these questions is attached.

On July 20, 1983, subsequent to the licensee response, the NRC was informed that well #521 had indeed been drilled through the concrete pipe and not into the bedding material as originally thought.

C.

On June 29, 1983, following a review by the Senior Resident Inspector of welding procedures and observation of welding performance demonstra-tions, the NRC authorized the resumption of safety-related welding work on the Heating, Ventilation, and Air Conditioning systems. The work was initially stopped November 30, 1982, after a licensee audit determined that the quality assurance program for velder qualification and welding procedure qualifications was inadequate. A copy of our authorization letter is attached.

D.

Although this is not a safety concern, i:he following information is provided to keep the Board informed. The lead welding engineer for remedial soils work allegedly instructed a welding rod room attendant to change the rod return time on a number of vsid rod withdrawal slips j

to conform to site requirements. Bechtel, when learning of the alleged falsification, investigated, and fired the engineer on June 29, 1983.

i The inspectors determined there weis no safety significance to this incident.

1 The welding rods, even though outside the heating ovens for an extended period, were kept by workmen in===11 portable warminF vens. In addition, the rods were used in the welding of structu.

considered temporary.

E.

Consumers Power Compemy informed Begion III that Dow Chemical Company is attempting to terminate its contract with Consumers Power Company to supply procese steen to Dow's Midland facility from the Midland Nuclear Power Statice. On July 14. 1983, Dow announced it was filing suit ' seeking a court judgment that all Dow's obligations under the j

contract be cancelled "because of CPCo's misrepresentations and t

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3-D. G. Eisenhut non-disclosures... and CPCo's inability to complete the Midland Muclear Plant within any reasonable time and at a reasonable cost."

CPCo notified the region that they planned to formally notify the Board in the near future.

If you have any questions or desire further inforinatien regarding this matter please call me.

k NLktudu' R. F. Warnick, Director Office of Special Cases Attachments: As stated cc w/o attachments:

A. B. Davis J. J. haon R. N. Gardner R. B. Landsman R. J. Cook B. L. Burgess j

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October 18, 1979 MEMORANDUM FOR:

R. C. Knop R. Cook D. W. Hayes T. Vandet D. H. Danielson F. Jablonski K. Naidu E. Lee G. Maxwell G. Gallagher W. Hansen K. Ward P. Barrett I. Yin FROM:

G. Fiorelli, Chief, Reactor Construction and Engineering Support Branch

SUBJECT:

MIDL.hNDCONSTRUCTIONSTATUSREPORTASOF OCTOBER 1, 1979

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i The attached report was finalized based on your feedback requested in my memo of October 5,1979.

If you still feet adjustments are necessary please contact me.

If you consider the report characterizes your' current assessment of the Midland project, please con ~ cur and pass it L

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along promptly.

4 G. Fiorelli, Chief Reactor Construction and

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Enclosure:

As stated Engineering Support Branch ec:

J. G. Keppler i

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SUMMARY

REPORT UPDATE

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I Facility Data

' 329 and 50-330 Docket Number Construction Permits

- CPPR-81 and CPPR-82 Permits Issued

- December 14, 1972 Type Reactor

- PWR; Unit 1, 492 MWe*; Uni.t 2, 818 MWe NSSS

- Babcock and Wilcox Design / Constructor

- Bechtel Power Corporation

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Fuel Load Dates

- Unit 1, 4/82; Unit 2,11/81 Status of construction

- Unit 1, 54%; Unit 2, 61%; Engineering 82%

  • Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers.

Chronological Listing of Major Events July 1970 5 tart of construction under exemption 9/29-30 8 Site inspection, four items of noncompliance identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtet Ann Arbor offices, five items of noncompliance identified 31/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order 12/29/73 Licensee answers Show cause order commits to improvements on GA program and QA/QC staff 12/3/73 Show cause order issued suspending cadwelding operation 12/6-7/73 Special inspection conducted by RIII and HQ personnel 32/37/73 show cause Order modified to allow cadwelding based on inspection findings of 12/6-7/73

12/5/75 CF reported that rebar spacing out of specification 50 u

locations in Unit 2 containment 3/5 & 10/75 CP reported that 63 f6 rebar vere either missing or misplaced in Auxiliary Building N12/75 RIII held r.anagement meeting with CP 9

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8/21/75 CP reported that 42 sets of #6 tie bais were missing in Auxiliary Building 3/22/76 CP reported that 32 #8 rebar were omitted in Auxiliary Building. A stop-vork order was issued _by CP 3/26/76 RIII inspector requested CP to inform RIII when stop-vork order to be lifted and to investigate the cause and the extent of the problem.

Additional rebar problems identified during site inspection by NRC 3/31/76 CP lif ted the stop-vork order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 RIII manage =ent discussed inspection findings with site personnel 5/20/76 RIII management meeting with CP President, Vice President, and others.

6/7 & 8/76 RIII follow up meeting with CP managecent and discussed the.CP 21 correction coc=itments 6/1-7/1/76 Overall rebar omission reviewed by R. I. Shev=aker

'(7/28/76 CP stops concrete placement work when further rebar N

placement errors found by their overview program.

PK-III-76-52 issued by RIII 8/2/76 RIII recommends BQ notice of v' olation be issued d

g/9 - 9/9/76 Tive week full-time RIII inspection conducted

~/13/76 Notice issued 8

10/29/76 CP responded to BQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of contain=ent liner discovered by Licensee 4/19/77 Tendon sheath o=dssions of Unit I reported 4/29/77 IAL issued relative to tendon sheath placement errors 5/5/77 Management meeting at CP Corporate Office relative to IAL regarding tendon sheath problem

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5/24/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implementation at Midland site.

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6/75 - 7/77 Series of meetings and letters between cP and NRR on applicability of Regulatory Guides to Midland.

t Commitments by CP to the guides was responsive.

7/24/78 Construction resident inspection assigned.

1 8/21/78 Measurements by Bechtet indicate excessive settlement of Dieset Generator Building.

Officially reported to RIII on September 7,1978.

12/78 - 1/79 Special investigation / inspection conducted at Midland sites,Bechtel Ann Arbor Engineering offices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement problem.

2/7/79 Corporate meeting between RIII and CPC to discuss project status and future inspection activities.

CPC informed construction performance on track with exception of diesel /fitt problem.

2/23/79 Meeting held in RIII with Consumers Power to discuss i

diesel generator building and plant area fitt j

problems.

1 3/5/79 Meeting held with CPC to discuss diesel generator. building and plant area fitt problems.

3/21/79 10 CFR 50.54 request for information regarding plant i

fill sent to CPC by NRR.

I 5/5/79 Congressman Albosta and aides visited Midland site to discuss TMI effect on Midland.

i 5/8-11/79 Mid-QA inspection conducted.

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Significant Maior Events _

Past Problems I

1.

Cadweld Splicing Problem and Show Cause Order A routine inspection, conducted on November 6-8,1973, as a -

result of intervenor information, identified eleven examples i

of four noncompliance items relative to rebar Cadwelding operations. These items were summarized as:

(1) untrained Cadweld inspectors; (2) rejectable Cadwelds accepted by QC inspectors; (3) records inadequate to establish cadwelds met requirements; and (4) inadequate procedures.

As a result, the Licensee stopped work on cadweld operations on November 9,1973 which in turn stopped rebar installation and concrete placement work. The licensee agreed not to resume work until the NRC reviewed and accepted their corrective action.

However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations.

On December 6-7, 1973, RIII and HQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The Show Cause Order was modified on 3

December 17, 1973, allowing resumption of Cadwelding operations based on the inspection results.

i The Licensee answered the Show cause order on Dece?ber 29, 1973, i

committing to revise and improve the QA manuals and procedures l

and make QA/QC personnel changes.

Prehearing conferences were held on March 28 and May 30,1974, and the hearing began on July 16, 1974.

On September 25, 1974, '

l the Hearing Board found that the Licensee was implementing its l

QA program in compliance with regulations and that construction l

should not be stopped.

.i 2.

_Rebar Omission / Placements Errors Leadino to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection conducted on December 11-13, 1974.

The Licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to 652' - 9" of l

Unit 2 containment. This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of noncompt'iance in reports Nos. 50-329/74-11 and 50-330/74-11.

I Additional rebar deviations and omissions were identified in i

rarch and August 1975 and in April, May and June 1976.

Inspection i

report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.

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Licassee response dated June 18, 1976, listed 21 separate items

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(commitment s) for corrective action. A June 24,1976 Letter provided a plan of action schedule for implementing the 21 items.

The Licensee suspended concrete placement work until the items

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addressed in Licensee's June 24 letter were resolved or implemented.

This commitnent was documented in a RIII letter to the Licensee dated June 25 1976. Although not stamped as an IAL, in-house memos referred to it as such.

i Rebar installation and concrete placement activities were satisfactorily resumed in early July 1976, following completion of the items and verification by RIII.

Additional action taken is as follows:

a.

By the NRC (1)

Assignment of an inspector full-time onsite for five weeks to observe civil work in progress.

(2)

IE management meetings with the licensee at their corporate offices (3)

Inspection and evaluation by Headquarters personnel j

b.

By the Licensee-(1)

June 18, 1976 letter committing to 21 items of corrective action.

(2)

Establishment of an overview inspection program to provide 100% reinspection of embedments by the Licensee following acceptance by the contractor QC personnet.

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By the Contractor i

(1)

Personnel changes and retraining of personnel.

(2)

Prepared technical evaluation for acceptability of each identified construction deficiency.

(3)

Improvement in their QA/QC program coverage of civil work (this was imposed by the Licensee).

3.

Tendon Sheath Placement Errors and Resultino Immediate Action Letter (IAL)_

On April 19, 1977, the licensee reported, as a Part 50, Cection 50.55(e) item, the inadvertent omission of two hoop tendon sheaths 6-i

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from a Unit 1 containment concrete placement at elevation 703' - 7" due to having already poured concrete in an area where the tendons were to be directed under a steam Line.

The tendons were subsequently rerouted in the next higher con _ crete lift.

- An IAL was issued to the Licensee on April 29,'1977, which s,pelled out six Licensee commitments for correction which included:

i (1) repairs and cause corrective action; (2) expansion of the licensee's oc overview program; (3) revisions to procedures and training of construction and inspection personnel.

A special QA program inspection was conducted in early May 1977.

The inspection team was made up of" personnel from RI, RIII and HQ.

Although five items of noncompliance were identified, it was the concensus of the inspectors that the Licensee's program was an acceptable program.

The licensee issued it's final report on August 12,1977.

Final review onsite was conducted and documented in report No. 50-329/77-08.

Current Problems i

1.

The Licensee informed the RIII office on September 8,1978, per requirements of 10 CFR 50.55(e) that settlement of the dieset generator foundations and structures were greater than expected.

FILL material in this area was placed between 1975 and 1977, with j

construction starting on the diesel generator building in mid-1977.

Review of the results of the RIII investigation / inspection into i

the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 l

which should have alerted Bechtet and the licensee to the pending problem.

These events included nonconformance reports, audit findings, field memos to engineering and problems with the t

administration building fitt which caused modification and replacement of the already poured footing and replacement of the fill material with Lean concrete.

causes of the excessive settlement tactudas (1) inadequate. placement method unqu'alified compaction equipment and excessive lif t I

thickness; (2) inadequate testing of the soit mater.ial; (3) inadequate i

oc inspection procedures; (4) unqualified quality control inspectors and field engineers; (5) over reliance on inadequate test results.

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l The proposed remedial work and corrective action are as follows:

(1)

Diesel Generator Building - apply surcharge Load in and around building to preconsolidate the foundation material.

continue to monitor soit response to predict Long-term settlement.

(2) Service Water Pump Structure - Install piles to hard glacial titt to support that portion of the structure founded en plant fitt material.

(3) Tank Farm - FILL has been determined to be suitable for the support of Borated Water Storage Tanks.

Tanks are to be constructed and hydro tested while monitoring soit response to confirm support of structures.

(4)

Diesel Oil Tanks - No remedial measure; backfill is considered adequate.

(5) Underground Facilities - No remedial work is anticipated with regards to buried piping.

(6) Auxiliary Building and F. W. Isolation Valve Pits - Installed a number of caissons to glacial tiLL material and replace soil material with concrete material un' der valve pits.

(7)

Dewatering System - Installed site dewatering system to provide assurance against soit liquidification during a seismic even The above remedial measures were proposed to the NRC staff on July 18,1979. No endorsement of the proposed actions have been issued to the Licensee to date. The Licensee is proceeding with the above plans.

The NRC activities, to date, include:

Lead technical responsibility and program review was transferred a.

to NRR from IE by memo dated November 17, 1978.

b.

Site meeting on December 3-4, 1978, uetween NRR, IE, Consumers Power and Dechtel to discuss the plant fill problem and proposed corrective action related to the Diesel Generator Building settlement.

RIII conducted an investigation / inspection relative to the c.

plant fill and Diesel Generator Duilding settlement.

Findings are contained in Report 50-329/78-20; 330/78-20 dated March 1979.

d.

NRC/ Consumers Power Company /Dechtet meetings held in RIII office to discuss finding of investigation / inspection of site settlement (February 23, 1979 and March 5, 1979).

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e.

NRC issue of 10 CFR 50.54(f) regarding plant fitt dated March 21, 1979.

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Several inspections of Midland site settlement have been performed.

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i The Constructor / Designer activities include:

i a.

Issued -NCR-1482 (August 21,1978) b.

Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978)

P Prepared a proposed corrective action option regarding placement c.

of sand overburden surcharge to accelerate and achieve proper compaction of diesel generator building sub4 soils.

d.

Issued 10 CFR 50.55(e) interim report number 1 dated September 29, 1978.

e.

Issued interim report No. 2 dated November 7,1978.

a

.f.

Issued interim report No. 3 dated June 5,1979.

g.

Issued interim report No. 4 dated February 23, 1979 4

j h.

Issued interim report No. 5 dated April 30, 1979 4' '

i. Responded to NRC 10 CFR 50.54(f) request for information onsite settlement dated April 24, 1979. Subsequent revision 1 dated May 31,1979, revision 2 dated July 9,1979 and revision 3 dated September 13, 1979.
j. Meeting with NRC to discuss site settlement causes and proposed 4

resolution and corrective action taken dated July 18, 1979.

j Information discussed at this meeting is documented in letter i

from CPCo to NRC dated August 10, 1979.

I k.

Issued interim report No. 6 dated August 10, 1979

]i L.

Issued interim report No. 7 dated September 5,1979 l

2.

Review of Quality Documentation to Establish Acceptability of Equipment The adequacy of engineering evaluation of cuality documentation (test reports, etc.) to determine if the documentation establishes j

that the equipment meets specification and environmental requirements is of concern. The Licensee, on November 13, 1978, issued a

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construction deficiency report (10 CFR 50.55(e)) relative to this matter. An interim report dated November 18, 1978 was received 4

1

and stated Consumers Power was pursuing this matter not only for Bechtet procured equipment but also for NSS supplied equipment.

3.

Source Inspection to Confirm conformance to specifications The adequacy of equipment acceptance inspection by Bechtet shop inspectors has been the subject of severat noncompliance /nonconformance repor

-Consumers Power has put heavy reliance on the creditability of the Bechtet vendor ' inspection program to insure that only quality equipment has been sent to the site. However, the referenced nonconformance reports raise questions that the Bechtel vendor inspection program may not be effectively working in all disciplines for supplied equipment.

Some significant examples are as follows:

(1) Decay heat removat pump being received with inadequate radiography.

The pumps were returned to the vendor for re radiography and repair. The pumps were returned to the site with one pump assembled backwards.

This pump was again shipped to the vendor for reassembly.

CPCo witnessed a portion of this reassembly and noted in their audit that some questionable techniques for establishing reference geometry were employed by the vendor.

The pumps had been shop inspected by Bechtet.

/ (2) Containment eersonnet air Lock hatches were received and installed with vendor supplied structural weld geometry which does not agree with manufacturing drawings.

The personnet air Lock doors had been vendor inspected.

(3) Containment electrical penetrations were received and instatted with approximately 25% of the vendor installed terminations showing blatant signs of inadequate crimping. These penetrations were shop inspected by 3 or 4 Bechtet supplier quality representatives (vendor inspectors).

(4) 350 McM, 3 phase power cable was received and instatted in some safety related circuits with water being emitted from one phase.

(5) A primary coolant pump casing was received and instatted without all the threads in one casing stud hole being intact. The casings were vendor inspected by both Bechtet and B&W.

Additional IE inspections will be conducted to determine if CP has thoroughly completed an overview of the Bechtet shop ir.spector's function and that equipment already purchased has been reviewed to confirm it meets requirements.

4.

"e" List Equipment

, There have been instances wherein safety related construction cceponents and their instattation activities have not-been-4dentified on the "Q" list.

. /

This shortcoming could have affected the quality of work performed during fabrication due to the absence of quality controls -identified with "4" list items.

Examples of non "Q" list activities identified which should be "e" listed include:

Cable Trays Components of Heating and Ventilation System The licensee will be advised to review past as weLL as future construction activities to confirm that they were property defined as "e" list work or components.

5.

Management controls Throughout the construction period CPCo has identified some of a.

the problems that have occurred and reported them under the require-4' ments of 10 CFR 50.55(e).

by promptly identifying these problems. Management has demonstrated an ope However, CPCo has on repeated occasions not reviewed problems to the depth required for i

full and timely resolution.

Examples are:

(

Rebar omissions (1974)

Tendon sheath location error (1977)

Diesel generator building settlement (1978)

Containment personnel access hatches (1978) i In each of the cases listed above the NRC in it's investigation has determined that the problem was of greater significance than first 1'

reported or the problem was more generic than identified by CPCo.

This incomplete wringing out of problems identified has been discussed l

with CPCo on numerous occasions in connection with CPCo's management j

of the Midland project.

a b.

There have been many cases wherein nonconformances have been identified, reviewed and accepted "as is."

The extent of review given by the Licensee prior to resolving problems is currently in progress.

In one case dealing with the repair of airlock hatches, a determination was made that an incomplete engineering review was given the matter.

i Inspection History i

The construction inspection program for Midland Units 1 and 2 is 'approximately 60% complete.

This is consistent with status of construction of the two units.

(Unit 1 - 54%; Unit 2 - 61%).

The licensee's QA program has repeatedly been subject to in-depth review by IE inspectors.

The following highlight these inspections.

1.

July 23-26,and August 8-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06:

A detailed review was conducted relative to the i

implementation of the Co,sumers Power Company's QA manual and Bechtel corporation's OA program for design activities at the Bechtet Ann Arbor of fice.

The identified concerns were reported as discrepanties relative to the Part 50, Appendix B, criteria requirements.

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September 10-11, 1973 report Nos. 50-329/73-08 and 50-330/73-08:

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' detailed review of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving three separate Appendix B criteria with five different examples, were-identified..

i 3.

February 6-7, 1974, report Nos. 50-329/74-03 and 50-330/74-03: A followup inspection at the licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along with other followup.

4.

June 16-17,1975, report Nos. 50-329/75-05 and 50-330/75-05:

Special inspection conducted at the licensee's corporate office to review 4

the new corporate QA program manual.

4 5.

August 9 through September 9,1976, report Nos. 50-329/76-08 and 50-330/76-08:

special five week inspection regarding QA program implementation onsite primarily for rebar installation and other civit engineering work.

f 6.

May 24-27,1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE AND RI personnel to examine the QA program implementation onsite by Consumers Power Company and by Bechtel Corporation.

Although five examples of noncompliance to Appendix B, Criterion V, were identified, the consensus of the inspectors involved was that the program and i'ts innlementation for Midland was considered to be adequate.

7.

May 8-11,1979, a mid construction GA inspection covering purchase control and inspection of received materials design control and site auditing and surveillance activities was conducted by a team of i

inspectors. While some items wiLL require resolution, it was concluded i

j the program was adequate.

j The licensee's Quality Assurance program has undergone a number of revisions to strengthen it's provisions.

The company has expanded it's l

QA/QC auditing and surveillance coverage to provide extensive overview i

inspection coverage. This was done in 1975 with a commitment early in their experience with rebar installation problems and was further c'ommitted by the Licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.. This overview inspection activity by the Licensee has been a positive supplement to the constructor's i

own program, however, currently our inspectors perceive the overview activities cover a small percentage of the work in some disciplines.

I This has been brought to the Licensee's attention who has responded with i

a revised overview plan. RIII inspectors are reviewing the plan as well as determining it's effectiveness through observation of construction work.

A specific area brought to the attention of the licensee was the lack of overview in the instrumentation, installation area. The Licensee has responded to this matter with increased staff and this item is under i

review by RIII inspectors.

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The RIII of fice of inspection and enforcement instituted an augmented onsite inspection coverage program during 1974, this program has continued in effect until the installation of the resident inspector in July 1978.

Enforcement History a.

Noncompliance Statistics Number of Number of Inspector Hours Year Noncompliances Inspections Onsite 1976 14 9

646 1977 5

12 648 1978 18 23 1180

  • 1979 to date 7

18 429 A resident inspector was assigned to the Midland site in July 1978. The onsite inspection hours shown above does not include his inspection time.

  • Through August 1979 b.

An investigation of the current soils placement / diesel generator building s,ettlement problem has revealed the existence of a material false statement.

Issuance of a Civil Penalty is.. currently being contemplated.

~'

Summary and Conclusions since the start of construction Midland has experienced some significant problems resulting in enforcement action.

These actions are related (1) to improper placement, sampling and testing of concrete and failure of QA/ec to act on identified deficiencies in September 1970; (2) to drawing control and lack of or inad. equate procedures.for control of design and procurement activities at the Bechtel Engineering offices in September 1973; (3) to inadequate training, procedures and inspection of cadweld activities in November 1973; (4) to a series of RIII in-depth GA inspections and meetings which identified underlying causes of weakness in the Midland GA program implementation relative to embedments in April, May and June 1976.

(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, aLL primarily concerned with installation of reinforcement steet); (5) to tendon sheath omissions in April 1977; and (6) to plant soit foundations and excessive settlement of the Diesel Generator Building relative to inadequate compacted soil and inspection activities in August 1978 through 1971.

Following each of these problem periods, the Licensee has taken action to correct the problems and to upgrade his GA program and QA/0C staff.

The most prominent action has been'an overview program which has been steadly expanded to cover safety related activities.

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s Th'e evaluation both by the licensee and IE of the structures and eculp-7-.

ment af fect'ed by these problems (again except the last) has established

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.'that they dully meet design requirements.

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T Lecking at the underlying causes of these problems two common threads emerg2:.c (1) utilities historically have tended to over rely on A-E's

.r If (in 'thlS' case, Bechtel) and (3) insensitivity on the part of both Bes'tetGnd Consue.ers, Power,io recognize the significance of isolated

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n events or failure to tdequately evaluate possible generic application of these events eithei of which would have led to early identification and,av'aidance (the, problem.

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Admittedly.constructiop' ifeMciendle's' have occurred which should have

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been identifte4 carLier Nat the Licensee's GA program has ultimately identified and~ sulhee,uintiy, corrected or in process of correcting these deficicn y

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'The,RIII inspectors EeLieve that continuation of (1) resident site j.

neoverage, (2) the Li4ensee overview program, (3) the Licensee's attention

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.' and resolution of TJentified problems in this report, (4) ceasing to permit work to continue when es,tity related problems are identified with construction activities and (5) a continuing inspection program by regional inspectors will-provide adequate assurance that construction

, ': will be performed in accordance with requirements and that any significant

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errers and deficiencies will be identified and corrected.

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I MIDLAND SD0tARY REPORT Facility Data Docket Numbers 329 and 50-330 Construction Permits

- CPPR-81 and CPPR-82 Permits Issued

- December 14, 1972 Type Reactor

- PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS Supplier

- Babcox & Wilcox Design / Constructor

- Bechtel Power Corporation Fuel Load Dates

- Unit 1,11/81; Unit 2,11/80 Status of Construction - Unit 1, 52%, Unit 2, 562; Engineering 800

  • Approximately one-half the steam production for Unit 1 is dedicaced, by contract, to be supplied to Dow Chemical Corporation, ti scugh appropriate isolation heat exchangers. Capability exists to alternate to Unit 2,for the steam source upon demand.

Chronological Listing of Maior Events July 1970 start of Construction under exemption 9/29-30 &

Site inspection, four items of noncompliance identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 11/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order 12'/29/73 Licensee answers Show Cause Order commits to leprovements on QA progrkm and QA/QC ntaff 12/3/73 Show Cause order issued suspending cadwalding operation 12/6-7/73 Special inspection conducted by Rill & HQ personnel 12/17/73 Show cause order modified to allow cadwelding based on inspection findings of 12/6-7/73

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, sl12/5/75 CP reported that rebar spacing out of specification 50 locations in Unit 2 containment s

3/5 & 10/75 CP reported that 63 #6 rebar were either missing or Q

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misplaced in Auxiliary Building

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3/12/75 RIII held management meeting with CP 3

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8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building 3/22/76 CP reported that 32 #8 rebar were omitted in Auxiliary Building. A stop-work order was issued by CP 3/26/76 RIII inspector requested CP to inform.RIII when stop-work order to be lifted and to investigate the cause and the extent of the problem. Additional rebar problems identified during site inspection 3/31/76 CP lifted the stop-work order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 RIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CP President, Vice President, and others.

6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction connitments 6/1-7/1/76 Overall rebar omission reviewed by R. E. Shewmaker 7/28/76 CP stops concrete placement work when further rebar placement errors found by their overview program.

PN-III-76-52 issued by RIII 8/2/76 RIII recommends HQ notice of violation be issued 8/9 - 9/9/76 Five week full-time RIII inspection conducted 8/13/76 Notice issued 10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of containment liner discovered 4/19/77 Tendon sheath omissions of Unit i reported 4/29/77 IAL issued relative to tendon sheath placement errors 5/5/77 Management meeting at' CP Corporate Office relative to IAL regarding tendon sheath problem

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5/24-27/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implementation at Midland site 6/75 - 7/77 Series of meetings and letters between CP and NRR on applicability of Regulatory Guides to Midland.

Commitments by CP to the guides was responsive 7/24/78 Construction resident-inspection assigned 8/21/78 Measurements by Bechtel indicate excessive settlement of Diesel Generator Building.6fficially reported to RIII on September 7, 1978 12/78 - 1/79 Special investigation / inspection conducted at Midland sites Bechtel Ann Arbor Engineering cffices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement problem 1

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I Selected ^ Major Events Past Problems 1.

Cadweld Splicing Problem and Show Cause Order A routine inspection, conducted on November 6-8, 1973, as a result of intervenor information, identified eleven examples s

of four noncompliance items relative to rebar Cadwelding operations. These items were summarized as:

(1) untrained Cadweld inspectors;- (2) rejectable Chdwelds accepted by QC gf }"

inspectors; (3) records inadequate t) establish cadwelds met i

g requirements; and (4) inadequate procedures.

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-s As a result, the licensee stopped work on cadweld operations k(

on November 9, ~ 1973 which in turn stopped rebar installationc

  • The licensee agreed not to resume work until the NRC reviewed and accepted their corrective action. However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1973 RIII and HQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The show cause order was modified on December 17, 1973, allowing resumption of Cadwelding operations based on the inspection results.

The licensee answered the Show Cause Order on December 29, 1973, committing to revise and improve the QA manuals ~ and procedures and make QA/QC personnel changes.

Prehearing conferences vere held on March 28 and May' 30, 1974, and the hearing began on July 16, 1974. On September. 25, 1974, the Hearing Board found that the licensee was implementing its QA program in compliance with regulations and that construction should not be stopped.

2.

Rebar Omission / Placements Errors Leading to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection conducted on December 11-13, 1974. The licensee informed.the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to 652' - 9" of Unit 2 containment. This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of noncompliance in report Nos. 50-329/74-11 and 50-330/74-11.

Additional rebar deviations and omissions were identified in ihrch and August 1975 and in April, thy and June 1976. Inspection report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.

ST-

Licensee response dated June 18, 1976, listed 21 separate items (commitments) for corrective action. A June 24,1976 letter provided a plan of action schedule for implementing the 21 items. The licensee committed not to resume concrete placement work until the items addressed in licensee's June 24 letter were resolved or implemented.

This commitment was documented in a RIII letter to the licensee dated June 25, 1976.

Although not stamped as an IAL, in-house memos referred to it as such.

Rebar installation and concrete placement activities,were resumed in early July 1976, following completion of the items and verification by RIII.

Additional action taken is as follows:

a.

By the NRC-s (1) Assignment of an inspector full-time on site for five weeks to observe civil work in progress (2) IE management meetings with the licensee at their corporate offices (3) Inspection and evaluation by Headquarter personnel -

b.

By the Licensee (1) June 18, 1976 letter committing to.21 items of

^

corrective action (2) Establishment of an overview inspection progra= to provide 100" reinspection of.embedments by the licensee following acceptance by the contractor QC personnel c.

By the Contractor (1) Personnel changes and retraining of personnel (2) Prepared technical evalaation for acceptability of each identified construction deficiency (3)

Improvement in their QA/QC ' program coverage of civil' work (this was imposed by the licensee)

.3.

Tendon Sheath Placement Errors and Resulting Immediate Action Letter (IAL)

On April 19, 1977, the' licensee reported, as a Part 50, Section 50.55(e) item, the inadvertent omission of two hoop tendon sheaths from a Unit 1 containment concrete placement at 6

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elevation 703' - 7".

The tendon sheaths were, for.the most part, located at an elevation in the next higher concrete placement lift, except that they were' diverted to the lower placement lift to pass under a steam line penetration and

~it was where they were omitted.

Failure to rely on the proper source documents by construction and inspection personnel, contributed to the omission.

An IAL was issued to the licensee on April 29, 1977, which spelled out six licensee commitments for correction which included:

(1) repairs and cause corrective acrion; (2) expansion of the licensee's QC over view program; (3) revisions to procedures and training of construction and inspection

  • personnel.

A special QA program inspection was conducted in early May 1977.

The inspection team was made up of personnel fron RI, RIII,. and HQ. Although five items of noncompliance were identified, it.

was the concensous of the inspectors that the licensce's program was an acceptable program and that the Midland construction activities were' comparable to most other.

construction projects.

The licensee issued its final report on August 12, 1977. Final review on site was conducted and documented in report :*o.

50-329/77-08.

Current Problems 1.

Plant Fill - Diesel Generator Building Settlement The licensee informed the RIII office on September 8, 1978, of per requirements of 10 CFR 50.55(e) that settlement of'the diesel generator foundations and structures were greater th?n expected.

Fill material in this area was placed between 1975 and 1977, with construction starting on diesel generator building in mid-1977. Filling of the cooling pond began in early 1978 with the spring run-of f water. Over the year the water level has increased approximately 21 feet and in turn increasing the site gound water level.

It is not known at this time what effect (if any) the higher site ground water level has

-had on the plan fill and excessive setticment of the Diesel Generator Building.

It is interesting to note however, that initially the PSAR indicated an underdrain system would be installed to maintain the ground water at its normal-(pre pond) level but that it later was deleted.

7

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The NRC.ctivities, to date, include:

Transfer of lead responsibility to NRR from IE by memo a.

dated November 17, 1978 b.

Site meeting on December 3-4, 1978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel Generator Building settlement c.

RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement The Constructor / Designer activities include:

i a.

Issued NCR-1482 (August 21, 1978) b.

Issued Management Corrective Action Report (MCAR) No. '24 (September 7,1978)

Prepared a proposed corrective action option regarding c.

placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel, generator buildin'g sub soils Preliminary review of the results of the RIII investigation /

inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit findings, field menos to engineering and problems with the administration building fill which caused modification and replacement of the already poured footing and replacement of the fill material with lean concrete.

2.

Inspection and Quality Documentation to Establish Acceptability of Equipment This problem consists of two parts and has just recently been l

identified by RIII inspectors relative to Midland. The scope and depth of the problem has not been determined.

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The first part concerns the adequacy of engineering evaluation l

of quality documentation (test reports, etc.) to determine if l

the documentation establishes that the equipment meets t

specification and environ = ental requirements. The licensee, i

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on November 13, 1978, issued a construction deficiency report

. (10 CFR 50.55(e)) relative to this matter. Whether the report _.

4 was triggered by RIII inspector inquiriester by IE Circular or Bulletin is not known.' Jkt interim report dated November 28, 1978.was received and stated Consumers Power was pursuing this matter not only for. Bechtel procured equipment but also for NSS supplied equipment.

The second part of the problem concerns the adequacy of equipment acceptance inspection by Bechtel shop inspectors.

Examples of this problem include:

(1) Decay Heat Removal Pumps released by the shop inspector and shipped to the site with one pump assembled backwards, (2) electrical penetrations inspected and released by the shop inspector for shipment to the site. Site inspections to date indicate about 25% of the vendor wire terminations were improperly crimped.

4 Inspection Historv The construction inspection program for Midland Units.1 and 2 is approximately 50% complete. This is consistent with status of construction of the two

(

n units.

. Unit 1 - 52%; Unit 2 - 56%)

In terms of required inspection procedures approximately 25 have been completed, 33 are'in progress l

and 36 have not been initiated.

The routine inspection program has not identified an unusual number of enforcement items. Of the selected major events described above, only one is directly attributable to RIII enforcement activity (Cadweld splicing). The other were identified by the licensee and reported through the deficiency report system (50.55(e)). The Midland data for i

1976 - 78 is tabulated below.

Number of Number of Inspector Hours Year Noncompliances Inspections On Site 1976 14 9

646 1977 5

12 648

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1978 11 18 706 A resident inspector was assigned to the Midland site in July 1978.

The on site inspection hours shown above does not include his inspection-time.

The licensee's QA program has repeatedly been subject to in-depth review by IE inspectors.

Included are:

r.

1.

July 23-26 and August 8-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the implementation of the Consumers Power Company's QA manual and Bechtel Corporation's QA program for design activities at the Bechtel Ann Arbor office. The identified concerns were reported as discrepancies relative.to the Part 50, Appendix B, criteria requirements.

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2.

September-10-11, 1973, report Nos. 50-329/73-08 and 50-330/73-08:

A detailed review of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving three separate Appendix B criteria with five different examples, were identified, 3.

February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A followup inspection at the licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along with other followup.

4.

June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the licensee's corporate' office to review the new corporate QA program manual.

5.

August 9 through September 9,1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA program implementation on site primarily for rebar installation and other civil engineering work.

6.

May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE and'RI personnel to examine the QA program implementation on site by Consumers Power Company and by Bechtel Corporation. Although five examples of noncompliance to Appendix B, Criterion V, were~ identified, the consensus of the inspectors involved was that the program and its implementation for Midland was considered to be adequate.

Although the licensee's Quality Assurance program has under gone a number of revisions to strengthen its provisions, no current concern exist regarding its adequacy. Their Topical QA Plan has been reviewed and accepted by NRR through revision 7.

Implementation of the program has been and continues to be subject to further review with the mid-construction program review presently scheduled for March or April 1979.

I Consumers Power Company expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This began in 1975 with a commitment early in their experience with rebar installation problems and was further committed by the licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.

This overview inspection accivity by the licensee has been very effective as a supplement to the constructor's own program. Currently, this program is functioning across all significant activities at the site.

Enforcement History Approximately 6 months aftar restart of construction activities (11 months after CP issuance) an inspection identified four noncompliance items

. regarding cadwelding activities. This resulted in a show cause order

- being issued on December 3, 1973. This enforcement action was aired publicly during hearings held by the Atomic Safety Licensing Board

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in May 1974. The hearing board issued its decision in September 1974 I

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h, that concluded that' construction could proceed with adequate assurance i

l of quality.

' Identification of reinforcing bar problems began in December of 1974 with the licensee reporting improper spacing of rebar in the Unit 2 containment L

wall. Further reinforcing'bar spacing and/or omission of rebar was identified.in August.1975 and again in May 1976 with the citations of 5 noncompliances in an inspection report. An IE:hl notice of violation was issued regarding the ' citations in addition to the licensee issuing -

a stop work; order. The licensee issued a response-letter dated June 18, 1976' committing to_21 items of corre:tive action.. A Bechtel prepared technical assessment for each instance of rebar deficiency _was submitted-F to and review by IE:HQ who concluded that the structures involved will satisfy the SAR criteria and that the function of these structures will be' maintained during all design conditions. The RIII office of NRC

. performed a special five week inspection to assess the corrective action implementation without further citation.

The licensee reported that two_ hoop tendon sheaths were omitted in concrete placements of Unit 2 containment wall in April.1977. An Immediate-Action Letter was issued to the licensee on April 29, 1977

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listing six items of licenses commitments to be completed. A special inspection was performed on May 24-27, 1977 with four NRC inspectors i

(1-HQ,'l-RI, and 2-RIII). Although five items of nonco'pliance were-m identified, it was the consensus of the inspectors that the QA/QC' program in effect was adequate. The constructors nonconformance report provided an alternate method of installation for the tendon sheaths that was accepted.

The RIII office of inspection and enforcement instituted an augmented on site inspection coverage program during 1974, this program has -

continued in effect ever since and is still in effect.

It is noted that the noncompliance history with this program is essentially the same as the history of other RIII facilities with a comparable status of j

constructien. Further on site inspection augmentations was accomplished i

with the assignment of a full time resident inspector in August, 1978.

The noncompliance history for the Midland Project is provided in the following table.

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ENFORCEMENT ACTIONS Noncompliances Criteria (10 CFR 50 Appendix B)

Year

  1. Total

( ) Number of Occurrances 1970 4

V, X, XI, XVI 1971-1972 0

Construction haulted pending CP 1973 9

II V(5) XIII, XV, XVII 1974 3

V(2) EVI 1975 0

1976 10 V(4)

X, XII, XV, XVI, XVII, XVIII 1977 5

V(5) 10 CFR 50.55(e) iten 1978 11' V(4) VI(2), VII, IX(3), XVI Criteria II QA Program V

Instructions Procedures Drawing Control Work VI Document Control VII Control of Purchased Material IX Control of Special Processes a

X Inspection XII Control Measuring - Test Equipment XIII Handling - Storage XV Nonconforming Parts XVI Corrective Actions XVII QA Records K7III Audits

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Summarv and Conclusions Since the start of construction Midland has experienced s'ome significant problems resulting in enforcement action.

In evaluating these problems they have occurred in clumps :

(1) in September 1970 relative to improper placement, sampling and testing of concrete and failure of QA/QC to act on identified deficiencies; (2) in September 1973 relative to drawing control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering offices; (3) in November 1973 relative to inadequate training, procedures and inspection of cadweld activities; (4) in April, May and June 1976 resulting from a series of RIII in-depth QA inspections and meetings to identify '

underlying causes of weakness in the Midland CA program implementation relative to embedments.

(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, all primarily concerned with installation of reinforcement steel); (5) in April 1977 relative to tendon sheath omissions; and (6) in August 1978 concerning plant soil foundations and excessive settlement of the Diesel Generator Building.

Following each of these problem periods (excluding the last which is still under investigation), the licensee has been responsive and has taken extensive action to evaluate and correct the problem and to up-grade his QA program and QA/QC staff. The most effective of these licensee actions has been an overview program which has been steadly expanded to cover almost all safety related activities.

The evaluation both by the licensee and IE of the structures and equipment affected by these problems (again except the last) has established that they fully meet design requirements.

Since 1974 these problems have either been identified by the licensee's quality program or provided direction to cur inspectors.

Looking at the underlying causes of these problems two commen threads emerge:

(1) Consumers Power historically has tended to over rely on Bechtel, and (2) insensitivity on the part of both Bechtel and Consumers Power to recognize the significance of isolated events or failure to adequately evaluate possible generic application of these events either of which would have led tn early identification and avoidance of the problem including the last on plant fill and diesel generator building settlement.

Notwithstanding the above, it is our conclusion that the problems experienced are not indicative of a broadbreakdown in the overall quality assurance program. Admittedly, deficiencies have occurred which should have been identified earlier by quality control personnel, but the licensee's program has been effective in the ultimate identification and subsequent correction of these deficiencies. While we cannot dismiss the possibility that problems may have gone undetected by the licensee's overall quality assurance program, our inspection program has not identified significant problems overlooked by the licensee --- and this inspection affort has utilized many different inspectors.

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The RIII project inspectors believe that continuation of:

(1) resident site coverage, (2) the licensee overview program including its recent expansion into engineering design / review activities, and (3) a continuing inspection program by regional inspectors will provide adequate assurance that construction will be performed in accordance with requirements and that any significant errors and deficiencies will be identified and corrected.

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consumem f

power James W Cook hf Vice President - Projects, Engsneenng and Construction oenered offices: 1945 West Pernell Road, Jackson, MI 49101 e (517) 78&o453

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September 20, 1982 g{f Mr.7 G Keppler US Nuclear Regulatory Commission Region III 799 Roosevelt Rd Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT DOCKET NOS 50-329 & 50-330 IE BULLETIN 82-01, REVISION 1, SUPPLEMENT NO 1 FILE 0505.12 SERIAL 18856 IE Bulletin 82-01, Rev 1, Supplement 1, " Alterations of Radiographs of Welds in Piping Subassemblies", action no I requires Consumers Power Company to conduct a 100% review of all radiography representing welds associated with pipe wall thicknesses less than 1/2 inch in shop fabricated Quality Classes 1 and 2 subassemblies provided by ITT Grinnell, Kernersville, NC.

The purpose of the review was to evaluate ASME Code penetraneter sensitivity to determinc if it was altered, discernible and that adequate weld quality was demonstrated.

In December 1981, CP Co completed a 100% review of all ITT Grinnell, Kernersville, NC, radiography provided to the Midland Nuclear Site. This review was not limited to material thicknesses less than 1/2 inch, but included al] pire well thicknesses. This review included approximately 24,0T radiographs representing approximately 5,000 weld:i. The results of this review are as follows:

1.

Four welds were found which had the 4T holes altered in radiographs.

These welds have already been reported to the NRC and are specifically addressed in Supplement No 1 of the subject bulletin. Three of the four welds were reradiographed, and the welds were determined to be acceptable without any need for rework or repair. The fourth veld was previously removed during a piping system modification and no longer exists.

2.

Three welds for pipe wall thicknesses less than 1/2 inch and two welds for pipe wall thicknesses 1/2 inch and greater were considered by CP Co not to have the required quality level visible.

_No alteration was involved, only that the required penetrameter hole was not considered visible. All five welds were reradiographed and found to be acceptable without need for cither rework or repair.

miO982-0059a168 f.- yj n b[

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3.

Two welds for pipe wall thicknesses less than 1/2 inch (completely separate from items (1) and (2) above) were considered by CP Co to contain questionable weld indications. Both welds wste repaired, reradiographed and are now acceptable.

Based on the results of the review outlined above, we consider the action required by this bulletin to be complete.

JWC/WJH/acr CC RJCook, Midland Resident Inspector RCDeYoung, h7C

'DSHood, h7C DBMiller (3), Midland NCMoseley, h7C l

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g CONSUMERS POWER COMPAhT MIDLAND NUCLEAR C0 GENERATION PLANT DOCKETS 50-329 & 50-330 RESPONSE TO IE BULLETIN NO 82-01, REV 1, SUPPLEMENT I, ACTION ITEM 1 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 our response to Action Item I of IE Bulletin 82-01, Rev 1, Supplement 1, August 18, 1982.

CONSUMERS POWER COMPAhT BY J W Cook, Vice President Pro' cts, Engineering and Construction Sworn and subscribed to before me this 27 day of __ sept -wer.

1982.

d_@f Notary Public Jackson County, Michigan My commission expires _fente-her 8. Ic8h miO982-0059bl68

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[ (. d [ h y MIDLAND UNITS 1 AND 2 1

Major Events Ladder December 5, 1974

- Rebar spacing nonconformance identified for Unit 2 containment by licensee March 5 & 10, 1975 - Rebar deficiencies in Auxiliary Building identified by licensee; RIII accepts justification.

April 9, 1975

- Bechtel engineering justification for rebar spacing in Unit 2 containment accepted by RIII.

(Report No.

75-03.)

April 16, 1975

- Meeting at Consumers Power Company Corporate office; Hunnicutt, Hayes, and LeDoux relative to rebar spacing in containment and missing rebar in Auxiliary Building.

April 28, 1975

- Unit 2 containment rebar spacing reanalysis accepted.

August 21, 1975

- RIII notified of rebar omitted in Auxiliary Building.

May 4, 1976

- Bechtel conclusion, that missing rebar in Auxiliary Building will not affect integrity, referred to Headquarters; Hayes to Seyfrit.

June 7 & 8, 1976

- Meeting, Consumers Power Company, Jackson; Keppler and others vs Selby and others relative to missing rebar in Auxiliary Building and QA deficiencies per Report No.

76-04.

June 18 &.24,1976 - Licensee letters of response committing to 21 items of corrective action in response to Report No. 76-04.

June 25, 1976

- Keppler to Consumers Power Company; Immediate Action

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Letter per Jordan to Keppler memo 8/26/76.

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. July 14, 1976

- IE concurred with the Bechtel conclusion regarding missing rebar in Auxiliary Building, Seyfrit to Hunnicutt.

July 28, 1976

- PN-III-76-52 issued on concrete work stoppage due to further rebar placement errors found as a result of Consumers' overview program instigated in late June 1976.

August 2, 1976

- Keppler letter to Headquarters recommending Headquarters' Notice of Violation be issued.

Notice sent 8/13/73; October 29, 1976

- Consumers Power Company responded to Headquarters' Notice of Violations.

November 30, 1976 - Hearings take place on environmental matters.

Completed in January 1977.

December 10, 1976 - Consumers Power L mpany's Midland QA Progra=

accepted by NRR.

J

  • Jely 1977

- Staff commenced responding on Consumers Power Company's Regulatory Guide use.

Tebruary 26, 1977 - Bulge o currence of Unit 2 containment liner disecvered - reported on February 28, 1977.

April 14, 1977

- Meeting, Ann Arbor, to review activities of bulged liner plate repair.

Apr11 19, 1977

-TendonsheathomissionofUnitfreported.

April 29, 1977

- Immediate Action Letter issued relative to tendon sheath placement errors.

  • See backup information on Regulatory Guides.

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- May 5, 1977 Meeting, Consumers Power Company, Jackson; Keppler, Heishman, and Hayes relative to Immediate Action Letter discussion regarding tendon sheath problem.

May 24 - 27,1977 Special QA inspection to determine adequacy of QA program implementation at Midland.

June 30, 1977 Meeting, Ann Arbor; R. F. Heishman and R. E. Shewmaker; release to proceed for tendon sheath omission and for bulge repair.

August 1-S &L Site inspection to witness start of repairs for bulge 8 - 9, 1977 liner and review records of completion of tendon sheath.

August 12, 1977

- Final 50.55(e) report on tendon sheath.

August 15, 1977

- Final report on liner plate repair.

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ENFORCEMENT HISTORY - MIDLAND 1 M;D 2 Report Number of Report Number of

-Number Noncompliances Number Nencompliances 70-1 0

74-1 1

70-2 0

74-2 0

70-3 0

74-3 0

70-4 0

74-4 1

70-5 0

74-5 0

70-6 4

74-6 0

71 0 74-7 0

71-2 0

74-8 0

[

74-9 0

74-10 0

72-1 0

74, 3

}

73-1 0

73-2 0

75-3 0

73-3 0

75-2 0

73-4 0

75-3 0

73-5 0

75-6 0

73-6 0

75-7 0

73-7 0

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73-8 5

76-3 3

73-9 0

76-2 2

73-10 4

76-3 0

HQ's Notice of 73-11 0

76-4 5 = Violation 76-5 0

9 7b6 0

Show Cause Order Issued 12/3/73 10 77-1 0

77-2 1

77-3 0

Asof8/k4/76,ninestop-work 77-4 0

orders issued by CP.

77-5 0

1 (Total 27)

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MIDLAND 1 AND 2 CHRONOLOGICAL LISTING OF QA/QC EMBEDMENT PROBLD!S 9/29-30 &'

Site Inspection conducted. Four nonconformances regarding:

10/1/70:

(1) placement activities violated ACI Code, (2) lab not performing tests per PSAR, (3) sampling not par ASTM, and (4) QA/QC personnel did not act on deviations when identi-fied. This was considered during hearings.

1971:

In mothballs pending CP.

1972:

In mothballs pending CP.

12/14/72: CP issued.

(Calvert Cliffs impacted on CP issuance.)

9/73:

Five nonconformance of Bechtel Ann Arbor activities.

11/73:

Four separate criteria nonconformances with several examples of each, including cadweld splicing, storage of materials, identification of acceptance, and resulting records. Pre-cipitated the Show Cause Order.

12/5/74:

CP repotted to RIII per 50.55(4) that rebar spacing out of specification 50 locations in Unit 2 containment (RIII Reports 75-01, 75-02, and 75-03).

3/5 & 10/75:CP reported to Rill that approximately 63 #6 rabar were either missing or misplaced in Auxiliary Building.

(RIII Report 75-03.)

3/12/75:.

RIII held management meeting with CP (RIV letter to CP, dated April 16, 1975).

8/21/75:

CP reported to RIII that 42 sets of #6 tie bars were missing in Auxiliary Building (RIII Report 75-07).

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3/22/76:

CP reported to RIII that approximately 32 FB rebar were omitted in Auxiliary Building. A stop-work order was issued by CP (RIII Report 76-04).

3/26/76:

RIII inspector requested CP to inform RIII when stop-work order to be lifted and to investigate the cause and the extent of the problem. Additional rebar problems identi-fied during site inspection (RIII Report 76-04).

3/31/76:

CP lifted the stop-work order.

4/19 thru RIII performed in-derth QA inspection at N1dland (RIII 5/14/76:

Report 76-04).

5/14/76:

Discussed inspection findings with site. personnel (RIII Report 76-04).

5/20/76:

RIII management meeting with CP President, Vice President, and others.

6/7 & 8/76:

RIII follow-up meeting with CP management and discussed the CP 21 correction ccomitments.

6/1-7/1/76:

Overall rebar emission reviewed by R. E. Shewmaker (Report 76-05).

8/9 thru Five-week, full-time onsite inspectica conducted by RIII 9/9/76:

inspector (RIII Report 76-08).

2/28/77:

Unit 2 bulge of containment liner discovered.

4/19/77:

Tendon sheaths problem of Unit 1 was reported.

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REBAR OMISSION PROBLD!

Inspection Report File Information 12/5/74

- CP identified rebar spacing noncompliance for Unit 2 contain-ment wall. Issued QF-36 and atop-vork FSW-6 December 6, 1974.

Inspection conducted on December 11 - 13, 1974.

Inspection Report No. 74-11.

2/5-7/75

- Inspection Report No. 75-01 More information requested for stress analysis for the rebar spacing of December 5, 1974. Tentative submittal March 15, 1975. NRC refuted existing analytical work.

2/26/75

- Inspection Report No. 75-32 NRC reviewed stress analysis on-rebar spacing nonconformance.

NRC refuted (CP agreed with NRC) analysis. Another analysis i

report due March 28, 1975.

4/8-9/75

- Inspection Report No. 75-03 NRC accepts Bechtel engineering justification. Resolves rebar spacing of December 5,1974 for tebar in Unit 2 cortainment.

Auxiliazry Building rebar deviations - found by CP on March 5 and 10, 1975. NRC accepts the licensee computations.

10/23-24/75 -Inspection Repor N). 75-07 August 21, 1975, NRC notified of rebar not installed in Auxiliary Building. NRC accepts CP analysis.

4/19-21, 5/3, 6-7, 13-14, and 20, 6/7-8/76 - Inspection Report No. 76-04 Bechtel concluded missing rebar in Auxiliary Building will not affect integrity. Referred to Headquarters.

QA inspection: Licensee letter June 18, 1976; licensee letter June 24, 1976.

4 Inspection Report No. 76-05 states revised and new work

l Rebar omission Problem,

procedures for concrete placement acceptable. Covered under licensee letter of June 24, 1976, under " Activities to be Completed Prior to Resumption of Q-Listed Concrete Placement."

6/24, 25, 30 and 7/1/76 - Inspection Report No. 76-05 IE:HQ did not identify any deficiency with Auxiliary Building rebar omissions.

Bechtel trend analysis not accepted by NRC - found acceptable in 76-09 dated November 1976. November 16 - 19, 1976, Bechte1~

trend analysis accepted by NRC.

8/9 - 9/9 and 23/76 - Inspection Report No. 76-08 Completes same licensee commitments from 76-04.

11/16-19/76 -Inspection Report No. 76-09 Inspector review of "Bechtel Trend Analysis" was found to be acceptable and considered resolved.

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LETTER FILE 12/5/74

- CP quality arrurance coordination found rebar spacing out of specification on containment wall of unit 2.

12/6/74

- Stop-work order issued by CP.

12/11-13/74 - Site inspection.

6/10/75

- Meeting by Mr. Yin with Mr. Slager, CP staff. Meeting held in RIII offices to review unresolved and/or open items from RIII inspection reports from 1970 to present.

11/18/75

- Meeting at Headquarters between RIII, IE, and CP to discuss implementation of Regulatory Guides 1.20, 1.26, 1.29, 1.46, 1.48, 1.67, and 1.72.

2/4/76

- Meeting scheduled for 2/4/76 between RIII, IE, and CP.

Meeting to review noncompliance items and unresolved items identified during RIII inspection of 1/14-16/76.

Infractions:

1.

No assurance temperature limits ware exceeded on concrete pours.

2.

No measures to identify nonconforming aggregste.

3.

Nonconforming aggregate not id= posed of as required.

2/4/76

- Meeting at CP corporate offices between CP, Hunnicutt, and Hayes.

The meeting reviewed noncompliance and unresolved items from January 13 - 16,1976 (Inspection Report No. 76-01).

Meeting discussed effectiveness of QA/QC effectiveness.

Licensee responded with letter of March 5, 1976.

4/28/75

- Memo of Yin to file. Yin review of BAPC report claims that rebar spacing problem in Unit 2 containment is considered resolved.

March 5, 1975 s CP notifies NRC of missing rebar in g

March 10, 1975j/ Auxiliary Building.

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Letter April' 16, 1975, Keppler-CP. Refers to meeting at CP

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corporate office with Hunnicutt, Hayes, and LaDoux. Meeting o

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_ toditeus's}ebarspacinginUnit2containmentandmissing 9

' reCar in'JJ$iliary Building. CP committed to:

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,1., Complete s.ifety evaluation and engineering review for n

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-,rebir ' spacing discrepancy.

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Continue, review of safety implications and reportability considerations for missing rebar.

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3.- Complete formulation and implementation of corrective n,a a sure s..

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7/26/75

- - Inspection at BAPC, Ann Arbor. NRC refuted analysis.

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On April 28,1975 -(Yin memo) analysis accepted.

3/16-18, 24-26/76 - Inspection Report No. 76-02 Addresses continued rebar omission. Discussed with D. W.

,i Hayes on April 13, 1976.

Report letter dated April 20, 1976.,

Letter, March 5, 1976, CP-Keppler Responds to citations of inspection of January 13 - 16, 1976.

Citatien: Concrete terperature, aggregate control, and disposai of aggregate.

May 4, 1976, Memo, Hayes t'o Seyfrit Refers to Headquarters for review and evaluation of missing /

t misplaced reber for periods of 2/76, 3/76, 10/74, 7/74 ----

p May 20, 1976 - Scheduled meeting at Jackson CP corporate

~i-offices to discuN noncompliance of April 19-May 20,1976 inspiction (Rerpre NA.z 76-04).

}

4

Letter File '

6/8/76

- CP issued stop-work order for placua+ sit of safety-related concrete. Referenced in NRC letter (Keppler) to CP dated June 25, 1976.

6/18/76

- CP r2sponse letter to inspection findings of April-May 1976 (Inspection Report No. 76-04) 20 items.

6/24/76

- CP response letter relative to schedule for plan of action for items of June 18, 1976 CP letter.

6/25/76

- Letter, Keppler to CP.

States resumption of concrete place-ment for safety-related structure will not start until certain items addressed in CP letter of June 24, 1976 are resolved. Memo, Jordan to Keppler, dated 8/26/76 refers to this as Immediate Action Letter.

7/14//6

- Memo, Seyfrit to Hunnicutt. Response to Hayes's memo of May 4,1976, as a result of Yin-Shewmaker inspection of June 24 and 25, 1976. The strength considerations for missing / misplaced rebar is considered resolved.

7/27/76

- RIII informed by CP that:

Coucrate work stopped becaise of errors in placing rebar.

PN-III-76-52 filed on July 28, 1976, states work stopped also

.in June 1976 and on three1 earlier occasions.

Rebar placement error of July 1, 1976, was in Auxiliary Building.

8/2/76

- Keppler' letter to Thompson recommending Headquarters' Notice of Violation. Natice sent August 13, 1976.

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Letter Fle \\

i 6/7 & 8/76

'(an'd May 20, A N6) meeting at CP corporate offices. Meeting involved Selby and other and Keppler and others.

10/18/76

- Hearing date set for November 16, 1976. Rescheduled later (11/18/76 to 11/30/76). Environmental.

~8/13/76

- Notice of Violation issued to CP (Selby).

10/29/76

- CP response to Notice of Violation.

12/P/76

- Notice to resume Midland hearing on December 14, 1976.

12/16/76

- 50.55(e) on deformed (defective) component cooling water pump casings.

12/29/76 '- Notice of resuming Midland hearing on January 8, 1977, in Chicago, Illinois.

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REGULATORY GUIDES Backup File - 1975 2/12/75 - J. G. Davis letter CP: acknowledge receipt of Consumers' report on reinforcing bar spacing (50.55(e)). Control No. H00419F3.

5/19/75 - Letter: S. H. Howell to A. Giambusso. First quarter '75 Financial Report. Page 3: QC/QA activities remain unchanged-curtailment of construction activities.

6/13/75 - NRC Schedule.

7/3/75

- Letter, R. C. Bauman (CP) to A. Schwencer. References meeting-of June 24, 1975 between NRC and CP to discuss applicability of Regulatory Guides through Regulatory Guide 1.75 at Midland.

List of Regulatory Guides having some disparity sith Midland construction.

7/24/75 - Letter, Bauman to Giambusso. Refers to NRC-CP meeting of 7/22/75.

Implementation of QA Regulatory Guides at 'fidland.

10/2/75 - Letter, Bauman to Boyd (NRC). Refers to tentative meeting on Materials Engineering Regulatory Guide 1.31.

States Midland position.

10/14/75 - Letter, Cooke to Keppler, NRC Schedule.

11/14/75 - Letter, A. Schwencer to CP addressing additional loads on vessel support system. NRC investigating but indicate present design may be adequate.

11/7/75 - Letter, Bauman to NRR (Boyd). Midland position on Regulatory Guides 1.1, 1.4, 1.7, 1.13, 1.25, 1.42, 1.49, 1.52, 1.54, and 1.70.

11/14/75 - Letter, Cooke to Keppler. NRC Schedule.

11/19/75 - Letter, Schwencer to CP.

NRC staff position on Regulatory Guide implementation at Midland.

Refers CP letter of 9/11/75.

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-1 Backup File -

12/1/75 - Letter, Bauman to NRR (Boyd). Midland position and information to NRK on use of Regulatory Guides.

12/11/75 - Letter, Bauman to NRR (Boyd).

Refers Schwencer's letter of 11/14/75. Supplies additional supporting information to vessel support system.

12/17/75 - Letter, Bauman to NRR (Boyd). Supplies additional information in response to Schwencer's letter of 11/19/75 on Regulatory Guide implementation and procurement status of plant components'.

7/21/75 - Letter, Bauman to Schwencer (NRC).

CP position on Regulatory 4

Guide use. Refers to meeting of July 22, 1975.

8/8/75

- letter, Howell to Giambusso. Financial status. Ik QC/QC changes. Indicates tentative change of personnel: Keeley as Midland Project Manager replaces Kessler; F. Southworth named Director of QA Services. Both effective August 1, 1975.

10/10/75 - Letter, Bauman to NRR (Boyd). Information on Midland Regulatory I

Guide positions. Refers to tentative Regulatory Guide meeting of 11/13/75.

10/15/75 - Letter, Bauman to NRR (Boyd). CP position on Regulatory Guide use at Midland.

11/10/75 - Letter, Howell-to Giambusso. Financial report plus no change tc QC/QA. Indicates construction escalation on January 1976.

1/13/76 - Letter, Schwencer to CP.

Comments and request for information for use of Regulatory Guides at Midland. Refers letter, CP to NRR of 11/7/75.

i 1/13/76 - Letter, Schwencer to CP.

Request for information on Regulatory Guide use at Midland. Refers to letter CP to NRR dated 10/10/75.

. _.. ~,

i Backup File _

1/26/76 - Letter, Schwencer to CP.

NRC comments and request for information on use of Regulatory Guides 1.26, 1.20, and 1.94.

2/3/76

- Letter, Bauman to NRR (Boyd). Supplies information requested in Schwencer's letter dated 12/23/75 pertaining to Regulatory Guide'use - electrical engineering.

2/3/76

- Letter, Bauman to NRR (Boyd). Supplies information requested in Schwencer's letter dated 10/30/75 on use of Regulatory Guide 1.59.

2/3/76

- Letter, Bauman to NRR (Boyd). Responds to Schwencer's letter dated 1/13/76 and supplies additional inforamtion on use of Regulatory Guides.

2/5/76

- Letter, Bauman to NRR (Boyd). Responds to Schwencer's letter dated 1/26/76. requesting information on use of Regulatory Guides 1.26 and 1.29.

2/10/76 - Letter, Bauman to NRR (Boyd). Final response to Schwencer's letter dated 1/26/76 requesting information on use of Regulatory Guide 1.94.

3/23/76 - Letter, Kneil (NRC) to CP announcing meeting at RIII March 30, 1976, on Section V.B of Appendix I, 10 CFR 50.

Also, letter, Kneil to CP dated 4/23/76. Also, leteer, Kneil to CP dated 5/10/76. Also, letter, Howell to NRR dated 3/15/77.

3/2/76

- Letter, Howell to Rusche requesting relief from Quarterly Financial' Reports established in Giambusso letter of September 13, 1974.

5/3/76

- Letter, Boyd to CP.

Relieves CP of Quarterly Financial Report and conditions of Giambusso letter of September 13, 1974.

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6/14/76 - Letter, Kneil to CP.

Staff position on use of Regulatory Guides 1.10, 1.12, 1.15, 1.18, 1.19, 1.35, 1.60, 1.61, and 1.92.

(Regulatory Guides 1.27, 1.55, and 1.59 excluded.)

Refers to CP letters of 7/21/75, 8/19/75, 12/1/75, and 2/3/76.

7/14/76

- Letter, Vassallo (NRR) to CP.

Letter requires CP do a j

reevaluation of vessel support systems for LOCA conditions.

i 10/8/76

- Letter, Varga to CP.

Staff position on use of Regulatory Guides 1.28, 1.30, 1.37, 1.38, 1.39, 1.58, 1.64, 1.74, 1.88, and 1.94 covered in CP of October 15, 1975. Also, staff position on use of Regulatory Guides 1.54 and 1.55 covered in CP letters of November 7,1975 and August 19, 197'5.

10/8/76

- Letter, Varga to CP.

Staff position - partial response to CP letter of October 10, 1975, for use of Regulatory Guides 1.20, 1.26, 1.29, 1.46, 1.48, and 1.67.

10/15/76 - Letter, Varga to CP.

Staff position on use of Regulatory Guides 1.6, 1.9, 1.11, 1.22, 1.32, 1.40, 1.41, 1.45, 1.47, 1.53, 1.62, 1.63, 1.73, 1.75, and 1.81.

Regulatory Guide 1.12 addressed in NRC letter of June 8, 1976. Refers to CP letters of July 21, 1975 and February 3,1976.

10/12/76 - Letter, Varga to CP.

Staff position on use of Regulatory Guides 1.1. 1.4, 1.7, 1.13, 1.25, 1.27, 1.42, 1.49, 1.52, and 1.59.

(Excludes 1.54.)

Refers to CP letters of August 19, 1975, November 7,1975, and February 3,1976.

Staff position on Regulatory Guide 1.70 covered in NRC letter of June 2,1976.

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. Backup File 12/10/76 - Letter, Varga to CP accepts Midland Design and Construction QA Program (10 CFR 50, Appendix A).

Submitted to NRC by CP on 11/9/76.

1/5/77

- Letter, Howell to Vassa111o (NRR). Vessel support analysis due 4/77. References letters of NRR-CP, 7/14/76, and CP to NRR, 9/10/76.

3/15/77 - Letter, Howell to NRR (Boyd). Additional information on Appendix I.

Refers to backup information on 3/23/76.

4/29/77 - Letter, Howell to Vassallio. Vessel support analysis due 7/77.

Reference 1/5/77 and 6/8/77.

6/27/77 - Letter Howell to NRR (Boyd). Clarification of PSIR Amendment 32 dated 4/4/77. Electrical penetration information.

7/19/77 - Letter, Howell to NRR (Boyd). Addre,sses CP position on use of Regulatory Guides 1.10, 1.12, 1.15, 1.18, 1.19, 1.35, 1.57, 1.60, 1.61, 1.90, and 1.92.

Refers NRC letter of 6/8/76. GIVES

SUMMARY

STATUS OF REGULATORY GUIDE USE FOR STRUCTURAL ENGINEERINO.

7/19/77 - Letter, Howell to NRR (Boyd). Addresses CP position on use of Regulatory Guides 1.6, 1.9. 1.11, 1.22, 1.32, 1.40, 1.41, 1.45,

1. 47, 1. 53, 1. 62, 1. 63, 1. 73, 1. 75, and 1. 81.

Refers NRC letter of 9/29/76. GIVES SU}e'.ARY STATUS FOR REGULATORY GUIDE USE FOR STRUCTURAL (ELECTRICAL) ENGINEERING.

7/28/77 - Letter, Howell to NRR (Boyd). Proposed FSAR Section 13.2 on Plant Staff Training for Cold Operator Training.

UNIT 2 LINER PLATE BULGE 2/26/77 - Bulge occurrence discovered at 11:00 p.m. (Report No.

50-330/77-02).

2/28/77 - 50.55(e) prompt report to RIII at 2:15 p.m.

3/16/77 - NRC letter with report to licensee with noncompliance regarding failure to report timely.

4/5/77

- Response letter. Commitment made to provide procedure

" Reporting Deficiencies to NRC" No. 20-2, Revision No. 3, to prevent recurrence. Currently, Revision 3 still in review and modification sta60-3/23/77 - NRR representative visited site with inspector for damage briefing (50-330/77-04).

4/14/77 - Meeting at Ann Arbor to review actions of bulged plate removal and to-review activities relative to proposed repair; D. W. Hayes and R. E. Shewmaker (77-06).

5/4/77

- Site visit for inspection of existing conditions of liner bulge area.

D. W. Hayes and R. E. Shewmaker (50-330/77-07).

5/16/77 - Interim report issued per 50.55(e).

5/24-27/77-Special QA Program Inspection.

6/20/77 - Interim report issued per 50.55(e).

l 6/29-30/77-Site Inspection by R. E. Shewmaker (6/29/77) - (50-330/77-10).

Meeting, Ann Arbor (6/30/77) R. E. Shewmaker and R. F. Heishman.

Release for proceeding with repairs. Notify when start of repairs.

8/1-5 & - Site Inspection, T. E. Vandel. Witness start of repairs with

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- 9/77 first four-foot lift of liner plate installed and grouted.

Satisfactory.

(Report No. 50-330/77-11.)

8/15/77 - Final report issued per 50.55(e) in review by R. E. Shewmaker.

Further site inspection planned later.

UNIT 1 TENDON SHEATH PROBLEM 4/19/77 - 50.55(e) prompt notification report to RIII made. -

4/20/77 - PN-III-77-18 issued.

4/29/77 - Imtediate Action Letter issued to CP.

Six items of commitments:

1.

Notify RIII prior to repairs or modifications.

Complete (see Report No. 50-329/77-07).

2.

Complete investigation of cause and implement C.A.

Not complete, still in discussions with Bechtel regarding adequate performance.

3.

Expand overview program - arpanded program in process.

4.

Notify NRC of placement errors for all embedments starting May 9 and for next 120 days. - 120 days completes on September 9; during that time seven separate items have been ieported. See backup sheet A.

5.

Review and revice QC inspection procedures. All Bechtel i

QCI's have undergone review. Revision in progress.

6.

Training of QC engineers and field engineers expanded.

Training program and retraining is underway.

5/5/77

- Meeting in Jackson with Keppler. Heishman, and Hayes.

5/19/77 - Interim report issued per 50.55(e).

5/24-27/77-Special QA Program Inspection. Five noncompliance items.

1.

Bechtel: inadequate piping hanger support plate installation.

Currently still open.

2.

Bechtel: field engineers mark up installation drawings for hangers. Currently CA complete.

3.

Consumers: audit report remain unissued (4). Currently CA complete.

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4.

Consumers: trends analysis procedure unimplemented. Currently CA complete.

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Unit.1 Tendon ~ Sheath Problem _

5.

Champion (Batch Plant): defective batch scale not tagged per procedure. Currently CA complete.

Additional CA for items 3 and 4.

CP to reorganize and provide additional manpower.- Currently new organization in effect and i

most all personnel additions completed in August,to be reviewed further later.

(See organization chart backup sheet B.)

1 6/27/77 - Interim report issued per 50.55(e).

6/29-30/77-Site Inspection by R. E. Shewmaket (6/29/77) - (50-329/77-07).

Meeting in Ann Arbcr (6/30/77).

R. E. Shewmaker and R. F.

Heishman.

Release for proceeding with repairs.

8/1-5 & - fite Inspection. T. E. Vandel. Report No. 50-329/77-08.

i 8-9/77 Complete record review of repairs to tendon sheaths. No problem areas identified. Installation was accomplished as i

proposed.

8/12/77 - Final report issued per 50.55(e). Review is completed and thank i

you letter states that we have no further questions.

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BACKUP SHEET A ilta[.h errm cn 1.

Tendon Sheathing, 5/19/77 Vertical Sheaths - notified on 5/24/77 (NCR-803) C 2.

D. W. Hayes

- 6/22/77, 9 #11 bars missing (QF-169) 3.

I. T. Yin

- 7/15/77, 2 #11 bars missing (NCR-863) 4.

D. W. Hayes - 7/28/77, 2 bars missing (QF-175) C 5.

T. E. Vandel - 8/15/77, 8 #8 vall dowels missing (QF-176) C 6.

D. W. Hayes - 8/16/77, 4 cut bars not replaced (NCR-898) 7.

C. E. Jones - 8/17/77, pipe restraint controls omitted - reactor building (NCR-910)

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BACKUP SHEET B Other items Final report per 50.55(e) regarding the surveillance A.

May 27, 1977 specimen holder tubes (provided by B&W)

Follow-up agreements were outlined in our letter of thanks dated June 21, 1977.

Final report per 50.55(e) regarding. component B.

May 27, 1977 cooling water pump casings.

No comment by RIII, since casings have been rejected and will not be used for Midland.

PN-III-77-30, Industrial Accident - Death of Construction C.

May 24, 1977 Worker (no repercussions)

Meeting in RIII offices with B. W. Marguglio, CP D.

March 22, 1977 Director of Project Quality Assurance Services regarding contemplated independent inspection of NSSS installations.

E.

November 14, 1975 - Vessel support LOCA loading adequacy - question.

Analysis is due July 1977 to NRR.

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MIDLAND SUN 2tARY REPORT Facility Data Docket Numbers 50-329 and 50-330 Construction Permits

- CPPR-81 and CPPR-82 Permits Issued

- December 14, 1972 Type Reactor

- PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS Supplier

- Babcox & Wilcox Design / Constructor

- Bechtel Power Corporation Fuel Lead Dates

- Unit 1, 11/81; Unit 2, 11/80 Status of Cons:ruction - Unit 1, 52%, Unit 2, 560; Engineering 80%

  • Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Che=ical Corporation, through appropriate isolation heat exchangers.

Capability exists to alternate to Unit 2 for the steam source upon demand.

Chronological Listinc of Major Even'.s July 1970 Start of Construction under exemption 9/29-30 &

Site inspection, four items of noncorp11ance identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 11/73 Inspection at site, four items of noncompliance identified (cadweld problem) precipitated the Show Cause Order 12/29/73 Licensee answers Show Cause Order commits to improvements on QA program and QA/QC staff 12/3/73 Show Cause Order issued suspending caduciding operation 12/6-7/73 Special inspection conducted by RIII & HQ personnel 12/17/73 Show Cause order modified to allow cadwelding based on inspection findings of 12/6-7/73

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12/5/7f CP reported that rebar spacing out of specification 50 locations in Unit 2 containment 3/5 & 10/75

- CP reported that 63 f6 rebar were either missing or e.isplaced in Auxiliary Building 3/12/75 RIII held management meeting with CP

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8/21/75

.CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building 3/22/76

.CP reported that 32 #8 rebar were omitted in Auxiliary Building. A s' top-work order was issued by CP 3/26/76 RIII inspector requested CP to inform RIII when stop-wcrk order to be lifted and to investigate the cause and the

' extent of the problem. Additional rebar problems identified during site inspection 3/31/76 CP lifted the stop-work order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 RIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CP President, Vice President, and others.

6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction commitments 6/1-7/1/76 Overall rebar omission reviewed by R. E. Shew =aker 7/28/76 CP stops concrete placement work when further rebar placement errors found by their overview program.

PN-III-76-52 issued by RIII 8/2/76 RIII recommends HQ notice of violation be issued 8/,9 - 9/9/76 Tive week full-time RIII inspection conducted B/13/76 Notice issued 10/29/76 CP responded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR 2/28/77 Unit 2 bulge of containment liner discovered 4/19/77 Tendon sheath omissions of Unit I reported 4/29/77 IAL issued relative to tendon sheath placement errors 5/5/77 Management meeting at CP Corporate Office relative to IAL regarding tendon sheath problem 3

5

5/24-27/77 Special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implementation at Midland site 6/75 - 7/77 Series of meetings and letters between CP and NRR on applicability of Regulatory Guides to Midland.

Commitments by CP to the guides was responsive 7/24/78 Construction resident inspection assigned 8/21/78 Measurements by Bechtel indicate excessive settlement of Diesel Generator Building.Sfficially reported to RIII on September 7, 1978 12/78 - 1/79 Special investigation / inspection conducted at Midland site:

Bechtel Ann Arbor Engineering cffices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement problem I

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Sele'eted Major Events Past Problems

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1.

Cadweld Snlicing ' Problem and Show Cause Order i_

j A routine inspection, conducted on November 6-8,19 73, as a result of intervenor information, identified eleven examples q

of four noncompliance items relative to rebar Cadwelding

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operations. These items were summarized as : - (1) untrained '

pay {

Cadweld inspectors; (2) rejectable 3dwelds accepted by QC inspectors; (3) records inadequate as establish cadwelds met.

j j requirements; and (4)' inadequate procedures.

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As a result, the licensee stopped work on cadwald operations I (n' on November 9, 1973 which in turn stepped rebar installationc $

The licensee agreed not to resume work until the NRC reviewed and accepted their corrective action. However, Show Cause Order was issued on December 3, 1973, suspending Cadwelding operations. On December 6-7, 1973 RIII and HQ. personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with -quality criteria. The show cause order was modified on December 17, 1973, allowing resumption of Cadwelding operations. based on the inspection results.

The licensee answered the Show Cause Order on December 29, 1973, committing to revise and improve the QA manuals and procedures and make QA/QC personnel chat 3es.

Prehearing conferences were held on March 28 and May 30, 1974, and the hearing began on July 16, 1974. On September 25, 1974, the Hearing Board found that the licensee was implementing its QA program in compliance with regulations and that construction should not be stopped.

+

2.

Rebar Omission / Placements Errors Leading to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection cenducted on December 11-13, 1974.

The licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to 652' - 9" of Unit 2 containment. This item was subsequently reported per 10 CFR 50.55(e) and was identified as a item of noncompliance in report Nos. 50-329/74-11 and 50-330/74-11.

Additional rebar deviations and omissions were identified in March and August 1975 and in April, May and June 1976.

Inspection

, report Nos. 50-329/76-04 and 50-330/76-04 identified five

" noncompliance items regarding reinforcement steel deficiencies.

5

i e

t Licensee response dated June 18,'1976, listed 21 separate items (commitments) for corrective action. A June 24, 1976 letter provided a plan of action schedule for implementing the 21 items. The licensee committed not to resume concrete placement work-until the items addressed in licensee's June. 2' letter were resolved or implemented.- This commitment was f

documented in a RIII letter to the licensee dated June 25~, 1976.

Although not stamped as an IAL, in-house memos referred to it as such.

Rebar installation and concrete placement activities were 4

resumed in early July 1976, following completion of the items and-verification by RIII.

Additional' action taken is as follows:

a.

By the NRC (1) Assignment of an inspector-full-time on site for i

five weeks to observe civil work in progress (2)

IE management meetings with the licensee at their corporate offices j

(3) Inspection and evaluation by Headquarter personnel b.

By the Licensee I

(1) June 18, 1976 letter committing to 21 items of l

corrective action (2) Establishment of an overview inspection program to provide 100* reinspection of embedments by the licensee following acceptance by the contractor QC personnel c.

By the Contractor (1). Personnel changes and retraining of personnel (2) Prepared technical evaluation for acceptability of j

each identified construction deficiency i

(3)

Improvement in their QA/QC program coverage of civil i

work (this was imposed by the licensee) 3.

Tendon Sheath Placement Errors and Resulting Immediate Action Letter (IAL) 4 i

' 0n April 19, 1977, the licensee reported, as a Part 50, Section 50.55(e) item, the inadvertent omission of two hoop tendon sheaths from a Unit 1 containment concrete placement-at 4

i

m elevation 703' -

7".

The tendon sheaths were, for the cost part, located at an elevation in the next higher _co.ncrete placement lift, except that they were diverted to the lower placement lift to_ pass under a steam line penetration and it was where they were omitted. Failure to rely on the proper source documents by construction and inspection personnel, contributed to the omission.

5 An IAL was issued to the licensee on April 29, 1977, which spelled out six licensee commitments for correction which included:

(1) repairs and cause corrective action; (2) expansion of the licensee's QC over view program; (3) revisions to procedures and training of construction and inspection personnel.

A special QA program inspection was conducted in early "ay 1977.

t The inspection team was made up of personnel fron RI, RIII, and HQ. Although five items of noncompliance were identified, it was the concensous of the inspectors that the licensee's program was an acceptable program and that the Midland construction activities were comparable to most other construction projects.

The licensee issued its final report on August *12, 1977. Final review en site was conducted and documented in report No.

50-329/77-08.

4 Current Problems 1.

Plant Fill - Diesel Generator Building Settlement T*a licensee informed the RIII office on September 8, 1978, of per requirements of 10 CFR 50.55(e) that settlement of the diesel generator foundations and structures were greater than expected.

Fill material in this area was placed between 1975 and 1977, with construction starting on diesel generator building in mid-1977. Filling of the cooling pond began in early 1978 with the spring run-off water. Over the year the water level has increased approximately 21 feat and in turn increasing i

the site gound water level. It is not known at this time what effect (if any) the higher site ground water level has had on the plan fill and excessive settlement of the Diesel Generator Building. It is interesting to note howeww. that initially the PSAR indicated an underdrain system would be installed to maintain the ground water at its normal (pre pond) level but that it later was deleted.

l 7

The NRC activities, to date, include:

Transfer of lead responsibility to NRR from'TI by memo a.

dated November 17, 1978 b.

Site meeting on December 3-4, 1978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel Generator Building settlement RIII conducted an investigation / inspection relative to the c.

plant fill and Diesel Generator Building settlement The Constructor / Designer activities include:

a.

Issued NCR-1482 (August 21, 1978) b.

Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978)

Prepared a proposed corrective action option regarding c.

placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel generator building sub soils Preliminary review of the results of the RIII investigation /

inspection into the plant fill / Diesel Generator Building settlement problem indier.te many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit findings, field memos to engineering and problems with the administration building fill which caused modification and replacement of the already poured footing and replacement of the fill material with lean concrete.

2.

Inspection and Quality Documentation to Establish Acceptability of Equipment This problem consists of two parts and has just recently been identified by RIII inspectors relative to Midland. The scope and depth of the problem has not been determined.

The first part concerns the adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes that the equipment meets specification and environmental requirements. The licensee, YY 8

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on November 13, 1978, issued a construction deficiency report (10 CFR 50.55(e)). relative to this matter. 'Whether the report...

was triggered by RIII inspector inquiriesfer by 4E. Circular or Bulletin is not known. An interim report dated November 28, 1976 was received and stated Consumers Power was pursuing this i

matter not only for Bechtel procured equipment but also for NSS supplied equipment.

l The second part of the problem concerns the adequacy of equipment acceptance inspection by Bechtel shop inspectors.

Examples of this problem include:

(1) Decay Heat Removal i

Pumps released by the shop inspector and shipped to the l

site with one pump assembled backwards, (2) electrical penetrations inspected and released by the shop inspector for shipment to the site. Site inspections to date indicate about 251' of the vendor wire terminations were improperly crimped.

Inspection History The construction inspection program for Midland Units 1 and 2 is approximately 50% complete. This is consistent with status of construction of the twc units.

(Unit 1 - 52%; Unit 2 - 56%)

In terms of required inspection procedures approximately 25 have been completed, 33 are in progress and 36 have not been initiated.

The routine inspection program has not identified an unusual number j

of enforcement items. Of the selected major events described above, only one is directly attributable to RIII enforcement activity (Cadweld splicing). The other were identified by the licensee and reported t

through the deficiency report system (50.55(e)). The Midland data for 1976 - 78 is tabulated below.

Number of Number of Inspector Hours Year Noncompliances Inspections On Site 1976 14 9

646 1977 5

12 648 1978 11 18 706 A resident inspector was assigned to the Midland site in July 1978.

The on site inspection hours shown above does not include his inspection time.

The licensee's QA program has repeatedly been subject to in-depth review by IE inspectors. Included are:

1.

July 23-26 and August 8-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the impiamentation of the Consumers Power Company's QA manuti and Bechtel Corporation's QA program for design activities at the Bechtel Ann Arbor office. The identified concerns were reported as discrepancies relative to the Part 50, Appendix B, criteria requirements.

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September 10-11, 1973, report Nos. 50-329/73-08 and 50-330/73-08:

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A detailed review of the Bechtel Power Corporation QA program for Pudland was performed. Noncompliances involving thres separate Appendix B criteria with five different examples, were identified.

3.

February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A followup inspection at the licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along with other followup.

4.

June 16-17, 1975, report Nee. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the licensee's corporata office to review the new corporate QA program manual.

5.

August 9 through September 9, 1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA program implementation on site primarily for rebar installation and other civil engineering work.

6.

May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE and RI personnel to examine the QA program implementation on site by Consumers Power Company and by Becht:1 Corporation. Although five examples of noncompliance to Appendix B Criterion V, were identified, the consensus of the inspectors involved was that the program and its implementation for Midland was considered to be adequate.

Although the licensee's Quality Assurance program has under gone a number of revisions to strengthen its provisions, no current concern exist regarding its adequacy. Their Topical QA Plan has been reviewed and accepted by NRR through revision 7.

Implementation of the program has been and continues to be subject to further review with the mid-f construction program review presently scheduled for March or April 1979.

C'ensumers Power Company expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This began in 1975 with a commitment early in their experience with rebar installation problems and was further committed by the licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.

This overview inspection activity by the licensee has been very effective as a supplement to the constructor's own program. Currently, this program is functioning across all significant activities at the site.

Enforcement History Approximately 6 months af ter restart of cot.struction activities (11 months af ter CP issuance) an inspection identified four noncompliance items regarding cadwelding activities. This resulted in a show cause order being issued on December 3,1973. This enforcement action was aired publicly <during hearings held by the Atomic Safety Licensing Board in May 1974. The hearing board issued its decision in September 1974

/0

r-that concluded that construction could proceed with adequate assurance of quality.

Identification of reinforcing bar problems began in December o'f 1974 with l

the licensee reporting improper spacing of rebar in the Unit 2 containnent l

wall. Further reinforcing har spacing and/or omission of rebar was identified in August 1975 and again in May 1976 with the citations of 5 noncompliances in an inspection report. An IE:HQ notice of violation was issued regarding the citations in addition to the licensee issuing l

a stop work order. The licensee issued a response letter dated June 18, 1976 committing to 21 items of corrective action. A Bechtel prepared technical assessment for each instance of rebar deficiency was submitted to and review by IE:HQ who concluded that the structures involved will satisfy the SAR criteria and that the function of these structures will be maintained during all design conditions. The RIII office of NRC performed a special five week inspecticn to assess the corrective action implementation without further citation.

The licensee reported that two hoop tendon sheaths were omitted in concrete placements of Unit 2 containment wall in April 1977. An Immediate Action Letter was issued to the licensee on April 29, 1977 t

listing six items of licensee commitments to be completed. A special inspection was performed on May 24-27, 1977 with four NRC inspectors (1-HQ,1-RI, and 2-RIII). Although five items of noncompliance were identified, it was the consensus of the inspectors that the QA/QC program in effect was adequate. The constructors nonconformance report provided an alternate method of installation for the tendon sheaths that was accepted.

The RIII office of inspection and enforcement instituted an augmented on site inspection coverage program during 1974, this program has continued in effect ever since and is still in effect.

It is noted that the noncompliance history with this program is essentially the same as the history of other RIII facilities with a comparable status of d6nstruction. Further on site inspection augmentations was accomplished with the assignment of a full time resident inspector in August, 1978.

The noncompliance history for the Midland Project is provided in the following table.

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l ENFORCEMD T ACTIONS Noncompliances Criteria (10 CFR 50 Appendix B)

Year

  1. Total

( ) Number of Occurrances 1970 4

V, X, XI, XVI 1971-1972 0

Construction haulted pending CP 1973 9

II V(5) XIII, XV, XVII 1974 3'

V(2) 3FI 1975 0

1976 10 V(4)

X, XII, XV, XVI, XVII, XVIII 1977 5

V(5) 10 CFR 50.55(e) item 1978 11 V(4) VI(2), VII, IX(3), XVI Crice'ria II QA Program V

Instructions Procedures Drawing Control Work VI Document Control VII Control of Purchased Material IX Control of Special Processes X

Inspection XII Control Measuring - Test Equipment XIII Handling - Storage XV Nonconforming Parts XVI Corrective Actior.s XVII QA Records XVIII

' Audits a

/ 2.

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a Summary and Conclusions A

Since:the start of construction Midland has experienced soot significant l _-

problems resulting in enforcement action. In evaluating these problems they have occurred in clumps:

(1) in September 1970 relative to improper i

placement, sampling and testing of concrete and failure of QA/QC to act

- on identified deficiencies; (2) in September 1973 relative to drawing control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering of fices ; (3) in November 1973 relative to inadequate training, procedures and inspecticn of cadweld activities; (4) in April, May and June 1976 resulting from a series of RIII in-depth QA inspections and meetings to identify underlying causes of weakness in the Midland QL program implementation relative to embedmonts.

(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, all primarily concerned with installation of reinforcement i

steel); (5) in April 1977 relative to tendon sheath omissions; and (6) i in August 1976 concerning plant soil foundations and excessive settlement of the Diesel Generator Building.

t.

j Following each of these problem periods (excluding the last which is 7

still under investigation). the licensee has been responsive and has taken extensive action to evaluate and correct the problem and to up-

);

grade his QA program and QA/QC staff. The most effective of these licensee actions has been an overview program which has been steadly j

expanded to cover almost all safety related activities.

1 i

The evaluation both by the licensee and IE of the structures and equipment affected by these problems (again except the last) has

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established that they fully meet design requirements.

4 Since 1974 these problems have either been identified by the licensee's l

quality program or provided direction to our inspectors.

I 1

Lgoking at the underlying causes of these problems _two common threads j

emerge:

(1) Consumers Power historically has tended to over rely on i

Bechtel, and (2) insensitivity on the part of both Bechtel and consumers i

Power to recognize the significance of isolated events or failure to adequately evaluate possible generic application of these events either of which would have led to early identification and avoidance of the i

problem including the last on plant fill and diesel generator building settlement.

I i

Notwithstanding the above, it is our conclusion that the problems experienced are not indicative of a broadbreakdown in the overall quality assurance program. Admittedly, deficiencies have e: curred which should have been identified earlier by quality control personnel, but the j

licensee's program has been effective in the ultimate identification and j

subsequent correction of these deficiencies. While we cannot dismiss the l

possibiltyy that problems any have gone undetected by the licensee's j

overall quality aneurance program, our inspection program has not identified i

significant problems overlooked by the licensee -- and this inspection j

effort has utilised many different inspectors.

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4 The RIII project inspectors believe that continuation, of:

(1) resident site coverage, (2) the licensee overview program including its recent expansion into engineering design / review activities, and ('3) a continuing inspection program by regional inspectors will provide adequate assurance that construction will be performed in accordance with requirements and that any significant errors and deficiencies will be identified and corrected.

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MIDLAND UNITS 1 AND 2 Major Events Ladder December 5, 1974

- Rebar spacing nonconformance identified for Unit 2 containment by licensee.

March 5 & 10, 1975 - Rebar deficiencies in Auxiliary Building identified by licensee; RIII accepts justification.

April 9, 1975

- Bechtel engineering justification for rebar spacing in Unit 2 containment accepted by RIII.

(Report No.

75-03.)

April 16, 1975

- Meeting at Consumers Power Company Corporate office; Hunnicutt, Hayes, and LeDoux relative to rebar spacing in containment and missing rebar in Auxiliary Building.

April 28, 1975

- Unit 2 containment rebar spacing reanalysis accepted.

August 21, 1975

- RIII notified of rebar omitted in Auxiliary Building.

May 4, 1976

- Bechtel conclusion, that missing rebar in Auxiliary Building will not affect integrity, referred to Headquarters; Hayes to Seyfrit.

June 7 & 8, 1976

- Meeting, Consumers Power Company, Jackson; Keppler and others vs Selby and others relative to missing rebar in Auxiliary Building and QA deficiencies per Report No.

76-04.

June 18 &.24, 1976 - Licensee letters of response committing to 21 items of corrective action in response to Report No. 76-04.

June 25, 1976

- Keppler to Consumers Pcwer Company; Immediate Action Letter per Jordan to Keppler memo 8/26/76.

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IE concurred with the Bechtel conclusion regarding July 14, 1976 -

missing rebar in Auxiliary Building, Seyfrit to

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Hunnicutt.

i PN-III-76-52 issued on concrete work stoppage due to July 28, 1976 further rebar placement errors found as a result of Consumers' overview program instigated in late June 1976.

Ktppler letter to Headquarters recommending August 2, 1976 Headquarters' Notice of Violation be issued.

Notice sent 8/13/7l$

Consumers Power Company responded to Headquarters' October 29, 1976 Notice of Violations.

November 30, 1976 Hearings take place on environmental matters.

Completed in January 1977.

Consumars Power Company's ?" "

December 10, 1976

't Program accepted by NRR.

  • July 1977 Staff commenced responding on Consumers Power Company's Regulatory Guide use.

February 26, 1977 Bulge occurrence of L' nit 2 containment liner discovered - repceted on February 28, 1977.

April 14, 1977 Meeting, Ann Arbor, to review activities of bulged

.11nor plate repair.

Tendon sheath omissica of Unit f reported.

April 19, 1977 April 29, 1977 Immeliate Action Lette*.nsued relative to tendon sheath placement arrors.

S'ee backup' information on Regulatory Guides.

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Meeting, Consumers Power Company, Jackson; Keppler, May 5, 1977 Heishman, and Hayes relative to Immediate Action Letter discussion regarding tendon sheath problem.

Special QA inspection to determine adequacy of QA:

May 24 - 27,1977 program implementation at Midland.

Meeting, Ann Arbor; R. F. Heishman and R. E. Shewmaker; June 30, 1977 release to proceed for tendon sheath omission and for bulge repair.

Site inspection to witness start of repairs for bulge August 1 - 5 & -

8 - 9, 1977 liner and review records of completion of tendon sheath.

Final 50.55(e) report on tendon sheath.

August 12, 1977 Final report on liner plate repair.

August 15, 1977

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i l$BAROMISSION' PROBLEM Inspecti n Report Fil'e I'nformation

~ 12/5/74 CP identified rebar spacing noncompliance"for Unit 2 contain-(

- ment wall. Issusi QF-36' and stop-work FSW-6 December 6,1974.

Inspection ~ conducted on December 11 - 13, 1974. Inspection s -

- Report No. 7'4-llN x' N s

j 2/5-7/75

-Inspection Report.No. 75-01 More information requisted for stress analysis for the rebar s

Tentative submittal March 15, spacing of December 5, 1974.

t 1975. NRC tofuted exis't1ng analytical' work'. '

2/26/75 Inspection Report" o. 75 <

- s.

' NRC reviewed stress analysis on rebar spacing nonconformance.

s NRC refited (CP agreed with NRC). analysis.; Another analysis reportdueMd'rch 28, 1975.

4/8-9/75 Inspection Report No. 75-03 NRC accepts 3echtel engineering justification. Resolves rebar i

spacing of December 5, 1974 for rebar in Unit 2 containment.'

Auxiliazry Building robar deviations - found by CP on March 5 and 10, 1975. NRC accepts the licensee computations.

10/23-24/75 -Inspection Report No. 75-07 4

Aug..at 21, 1975, NRC notified of rebar not installed in

- Auxiliary Building. NRC accepts CP analysis.

i 4/19-21, -5/3, 6-7,13-14, and 20, 6/7-8/76 - Inspection Report No. 76-04 i

j Bechtel concluded missing rebar in Ausiliary Building will not 1

affect integrity. Referred to Headquarters.

1 QA inspection: Licensee' letter June 18, 1976; licensee letter June 24, 1976.

1 Inspection Report No. 76-05 states revised and new work (5

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July 14, 1976

- lE concurred with the Bechtel conclusion regarding missing rebar in Auxiliary Building, Seyfrit to Hunnicutt.

July 28, 1976

- PN-III-76-52 issued on concrete work stoppage due to further rebar placement errors found as a result of Consumers' overview program instigated in late June 1976.

August 2, 1976

- Keppler letter to Headquarters recommending Headquarterc' Notice of Violation be issued.

Noticesent8/13/76 October 29, 1976

- Consumers Power Company responded to Headquarters' Notice of Violations.

November 30, 1976 - Hearings take place on environmental matters.

Completed in January 1977.

I December 10, 1976 - Consumers Power Company's PP"

" Program accepted by NRR.
  • July 1977

- Staff commenced responding on Consumers Power Company's Regulatory. Guide use.

February 26, 1977 - Bulge occurrence of " nit 2 containment liner discovered - reported on February 28, 1977.

April 14, 1977

- Meeting, Ann Arbor, to review activities of bulged liner plate repair.

April 19, 1977

- Tendon sheath omission of Unit f reported.

April 29, 1977

- Immediate Action Lette-issued relative to tendon sheath placement errors.

  • S'ee backup information on Regulatory Guides.

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UE Docket No. 50-346 V re bresadant

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License No. NPF-3 14191 Ph9 !.242 August 25, 1977 Serial No. 371 Mr. James G. Keppler Regional Director, Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Reportable Occurrence NP-33-77-34 Davis-Besse Nuclear Power Station Unit 1 Date'of Occurrence: July 31, 1977 Enclosed find three copies of Licensee Event Report NP-33-77-34 with u supplemen-tal info mation sheet, which is being submitted in accordance with Technical Specification 6.9 to provide 30 day written notification of the subject occur-rence.

Yours truly, y

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LER:ljk Enclosures cc:

Dr. Ernst Volgenau, Director Office of Inspeccion and Enforcement

. Encl: 30 copies Licensee Event Report 30 copics Supplemental Information Sheet Mr. William C. Mcdonald, Director Office of Management Information and Program Control Encl: 3 copies Licensee Event Report 3 copies Supplemental Information Sheet 4[/

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THE TOLEDO LUISON COMPANY CO! SON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 4365R-r

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May 5, 1977

- Meeting, Consumers Power Company, Jackson; Keppler, Heishman, and Hayes relative to Immediate Action Letter discussion regarding tendon sheath problem.

May 24 - 27,1977 - Special QA inspection to determine adequacy of QA program implementation at Midland.

June 30, 1977

- Meeting, Ann Arbor; R. F. Beishman and R. E. Shewmaker; release to proceed for tendon sheath omission and for bulge repair.

August 1 - 5 &

- Site inspection to witness start of repairs for bulge 8 - 9, 1977 liner and review records of completion of tendon sheath.

P August 12, 1977-

- Final 50.55(e) report on tendon sheath.

August 15, 1977

- Final report on liner plate repair.

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O TOLEDO EDISON COMPANY DAVIS-BESSE UNIT ONE NUCLEAR POWER STATION SUPPLEMENTAL INFORM / TION FOR LER NP-33-77-28 3

DATE OF EVENT: July 29,-1977

. FACILITY: ' Davis-Besse Unit 1 4

IDENTIFICATION OF OCCURRENCE:

Removed High Pressure Injection Line 1-2 from Service to perform hydrostatic test Conditions Prior to occurrence:

The plant was in Mode 3, with Power (MRT) = 0 and Load.(MWE) = 0.

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Description of Occurrenec:

In October, 1976, it was discovered that the welded stellite seat was cracked in one of the four High Pressure Injection (HPI)

Line Stop Check Valves, HP49.

The valve was replaced in February,1977, with a new stop check valve which required a complete reweld to install the new body.

Since welding had been performed on the piping, a hydrostatic test on that section of pipe had to be completed.

Since there are no isolatable boundaries between HP49 and the Reactor Coolant System (R.C.S.), the hydrostatic test had to be delayed until the Reactor Coolant System was pressurized.

At 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on July 29, 1977, with the R.C.S. pressurized to 2120 PSIG, HP49 was hydro tested. This required removing power from injection valve HP2D ren-dering one of the two flow paths for HPI Pump 1-1 inoperable.

At this tice the plant was in Mode 3'for which Technical Specification 3.5.2 required entry into an action statement if either HPI Pump is inoperable.

At 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> on July 29 1977, the hydro test was completed and power restored to HPI Valve HP2D.

This removed the Station from the action statement of Technical Specification 3.5.2.

Designation of Apparent Cause of Occurrence: The cause of this event was deliberately entering an action statement to perform the required hydrostatic test.

Analysis of Occurrence:

Since HPI Pump 1-2 was operable and only one of the two HPI Pump 1-1 Injection Valves was inoperable, H.P.I. would be supplied if needed under accident conditions; therefore, no threat occurred to the health and safety of the public or to Station personnel.

Corrective Action: The hydrostatic test was completed and power restored to the High Pressure injection Valve, HP2D, by 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br /> on July 29, 1977.

Failure Data:

No previous similar evente have occurred.

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-r-REBAR OMISSION PROBLEM Inspection Report File Information 12/5/74

- CP identified rebar spacing noncompliance for Unit 2 contain-ment wall.

Issued QF-36 and stop-work FSW-6 December 6, 1974.

' Inspection conducted on December 11 - 13, 1974.

Inspection Report No. 74-11.

2/5-7/75

- Inspection Report No. 75-01 More information requested for stress analysis for the rebar spacing of December 5,1974. Tentative submittal March 15, 1975. NRC refuted existing analytical work.

2/26/75

- Inspection Report No. 75-02 NRC reviewed stress analysis on rebar spacing nonconformance.

NRC refuted (CP agreed with NRC) analysis. Another analysis report due March 28, 1975.

4/8-9/75

- Inspection Report No. 75-03 NRC accepts Bechtel engineering justification. Resolves rebar i

spacing of December 5, 1974 for rebar in Unit 2 containment.

Auxiliazry Building rebar deviations - found.by CP on March 5 and 10, 1975. NRC accepts the licensee computations.

10/23-24/75 -Inspection Report No. 75-07 August 21, 1975, NRC notified of rebar not installed in Auxiliary Building. NRC accepts CP analysis.

4/19-21, 5/3, 6-7, 13-14, and 20, 6/7-8/76 - Inspection Report No. 76-04 Bechtel concluded missing rebar in Auxiliary Building will not i

j affect integrity. Referred to Headquarters.

QA inspection: Licensee letter June 18, 1976; licensee letter June 24, 1976.

Inspection Report No. 76-05 states revised and new work

Rebar Omission Problem _

procedures for concrete placement acceptable. Covered under licensee letter of June 24, 1976, under " Activities to be Completed Prior to Resumption of Q-Listed Concrete Placement."

6/24, 25, 30 and 7/1/76 - Inspection Report No. 76-05 IE:HQ did not identify any deficiency with Auxiliary Building rebar omissions.

Bechtel trend analysis not accepted by NRC - found acceptable in 76-09 dated November 1976. November 16 - 19, 1976, Bechtel trend analysis accepted by NRC.

8/9 - 9/9 and 23/76 - Inspection deport No. 76-08 Completes same licensee commitments from 76-04.

11/16-19/76 -Inspection Report No. 76-09 Inspector review of "Bechtel Trend Analysis" was found to be acceptable and considered resolved.

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-LOWELL E. ROE Docket No. 50-346 v

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License No. NPF-3 14193259S242 August 26, 1977 Serial No. 373 Mr. James G. Keppler Regional Director, Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear-Mr.-Keppler:

Reportable Occurrence NP-32-77-13

(

Davis-Besse Nuclear Power Station Unit 1 l

Date of Occurrence: August 15, 1977 1

Enclosed find three copies of Licensee Event Report NP-32-77-13 with a supplemen-tal information sheet, which is being submitted in accordance with Technical Specification 6.9 to provide 14 day written notification of the subject occur-rence.

Yours truly, LER:ljk I

Enclosures l

cc:

Dr. Ernst Volgenau, Director Office of Inspection and Enforcement Encl: 40 copies Licensee Event Report 40 copies Supplemental Information Sheet Mr. Williar. G. Mcdonald, Director l

l Office of Management Information and Program Control i

l

. Encl: 3 copies Licensee Event Report 3 copies Supplemental Information Sheet 2 copies Telecopied Report SEP I1977 THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO OHIO 43852 w

LETTER FILE 12/5/74

- CP quality assurance coordination found rebar spacing out of specification on containment wall of unit 2.

12/6/74

- Stop-work raar issued by CP.

12/11-13/74 - Site inspection.

6/10/75

- Meeting by Mr. Yin with Mr. Slager, CP staff. Meeting held in RIII offices to review unresolved and/or open items from RIII inspection reports from 1970 to present.

11/18/75

- Meeting at Headquarters between RIII, IE, and CP to discuss implementation of Regulatory Guides 1.20, 1.26, 1.29, 1.46, 1.48, 1.67, and 1.72.

2/4/76

- Meeting scheduled for 2/4/76 between RIII, IE, and CP.

Meeting to review noncompliance items and unresolved items identified during RIII inspection of 1/14-16/76.

Infractions:

1.

No assurance temperature limits were exceeded on concrete pours.

2.

No measures to identify nonconforming aggregate.

3.

Nonconforming aggregate not idsposed of as required.

2/4/76

- Nketing at CP corporate offices between CP, Hunnicutt, and Hayes. The meeting reviewed noncompliance and unresolved items from January 13 - 16,1976 (Inspection Report No. 76-01).

Meeting discussed effectiveness of QA/QC effectiveness.

Licensee responded with letter of March 5. 1976.

4/28/75

- Memo of Yin to file. Yin review of BAPC report claims that rebar spacing proolem in Unit 2 containment is considered resolved.

March 5, 1975 s CP notifies NRC of missing rebar in

/

March 10, 1975/

Auxiliary Building.

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TO) 1;DO F.DISON COMI'ANY 11 AVIS-lESSE 11MIT ONE Nt1Cl. EAR POWF.l STATION StIPPl.EMI.NTAI. IJ FORMAT ION FOR 1.1:l: Jil' -33;-7 7;-4 q DATE.0F livip?T,:

August 3, 1977 TACILITY,: Davis-Besse Unit 1 Il!EN I,lf l Ci T,10,N,,0f OC.Crji,19.NCE : Auxilia ry Feedwat er Pump 1-2 did not st art on a lena t

of f eedwater t rip on St eam Generat or *l-1.

Conditions Prior to Occurrence: The plant was in Mode 3 with Power (MWT) = 0 and Load (MWE) = 0.

Descriyt_ ion of Occurrence: At 2338 hours0.0271 days <br />0.649 hours <br />0.00387 weeks <br />8.89609e-4 months <br /> on August 3,1977, while running TP 600.11, (Auxiliary Feedwater System and Once Thru Steam Generator Level Control Test), a trip signal from the Steam Generator 1 loss of feedwater circuitry was received which should have started the 1-2 Auxiliary Fced Pump (AFP).

The 1-1 AFP was already run-ning but 1-2 AFP did not start.

AFP l-2 was, therefore, inoperable whidh placed the unit in the Action Statement of Technical Specification 3.7.1.2.

The investigation found that the governor valve had been stepped on and was completely closed. The steam supply valve upst.eam from the governor valve opened allowing steam to come down against the closed governor valve, but the completely closed valve would not allow the turbine to roll and provide its own oil pressure to cpen the valve.

At 0010 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> on August 4,1977, when Auxiliary Feed Pump Turbine 1-2 governor valve was manually opened, AFPT l-2 was returned to operability.

Desinnation of Apparent Cause of Occurrence: There were several groups working in the area of the AFPT l-2 governor valve and any one of the workers could have stepped on or leaned on the governor valve to close it.

Other workers had previously been observed standing on the governor valve and were instructed at that time to use care when working in this area.

Analysis of Occurrence: There was not a threat to the health and safety of the public cr to station staff. Auxiliary Feed Pump 1-1 was operable, initial criticality had not been reached, and no accident requiring the Auxiliary Feed Pumps occurred.

Corrective Action: The valve was manually opened and all personnel working in the roo-were instructed not to stand or lean on the AFPT governor valves.

The Control Roer.

Operator has been instructed to monitor the high speed stop light once per hour.

work in this room has been greatly reduced, this occurrence is not expected to re-oe.ur.

Failure Data:

On.Tul y 27, 1977, both Auxiliary Feedwater Systems were inoperable (NP-32-77.-11).

On July 29, 1977, Auxiliary Feed Pump Turbine 1-1 was inoperabic (NP-33-77-42).

On August 2, 1977, both Auxiliary reed Pumps were inoperabic (NP-33-77-39). The cause of these occurrences, however, was not relat eil t o the governor valve -losure.

i Letter File Letter April 16, 1975, Keppler-CP. Refers to meeting at CP corporate office with Hunnicutt, Hayes, and LeDoux. Meeting to discuss rebar spacing in Unit 2 containment and missing rebar in Auxiliary Building. CP committed to:

1.

Complete safety evaluation and engineering review for rebar spacing discrepancy.

2.

Continue review of safety implications and reportability considerations for missing rebar.

3.

Complete formulation and implementation of corrective measures.

2/26/75

- Inspection at BAPC, Ann Arbor. NRC refuted analysis.

On April 28, 1975 (Yin memo) analysis accepted.

3/16-18, 24-26/76 - Inspection Report No. 76-02 Addresses continued rebar omission. Discussed with D. W.

i Hayes on April 13, 1976. Report letter dated April 20, 1976.

Letter, March 5, 1976, CP-Keppler Responds to citations of inspection of January 13 - 16, 1976.

Citation: Concrete temperature, aggregate control, and disposal of aggregate.

i May 4, 1976, Memo Hayes to Seyfrit Refers to Headquarters for review and evaluation of missing /

1 misplaced rebar for periods of 2/76, 3/76, 10/74, 7/74 ----

May 20, 1976 - Scheduled meeting at Jackson CP corporate offices to discuss noncompliance of April 19 - May 20,1976 inspection (Report No. 76-04).

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6/8/76

- CP issued stop-work order for placement of safety-related concrete. Referenced in NRC letter (Keppler) to CP dated June 25, 1976.

6/18/76

- CP response letter to inspection findings of April-May 1976 (Inspection Report No. 76-04) 20 items.

6/24/76

- CP response letter relative to schedule for plan of action for items of June 18, 1976 CP letter.

6/25/76

- Letter, Keppler to CP.

States resumption of concrete place-ment for safety-related structure will not start until certain items addressed in CP letter of June 24, 1976 are resolved. Memo, Jordan to Keppler, dated 8/26/76 refers to this 'as Immediate Action Letter.

7/14/76

- Memo, Seyfrit to Hunnicutt. Response to Hayes's memo of May 4, 1976, as a result of Yin-Shewmaker inspection of June 24 and 25, 1976. The strength considerations for missing / misplaced rebar is considered resolved.

7/27/76

- RIII informed by CP that:

Concrete work stopped because of errors in placing rebar.

PN-III-76-52 filed on July 28, 1976, states work stopped also in June 1976 and on three earlier occasions.

Rebar placement error of July 1, 1976, was in Auxiliary Building.

8/2/76

- Keppler letter to Thomp son recommending Headquarters' Notice of Violation. Notice sent August 13, 1976.

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%xa puiSGN Docket No. 50-346 LOWELL E. roe License No. NPF-3

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E4191259 SPda August 29, 1977 Serial No. 377 Mr. James G. Keppler Regional Director, Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn Illinios 60137

Dear Mr. Keppler:

Reportable Occurrence NP-33-77-46 Davis-Besse Nuclear Power Station Unit 1 Date of Occurrence: August 3, 1977 Enclosed find three copies of Licensee Event Report NP-33-77-46 with a supplemen-tal information sheet, which is being submitted in accordance with Technical Speci-fication 6.9 to provide 30 day written notification of the subject occurrence.

Yours truly,

/*

9

~

LER:ljk Enclosures 1

cc:

Dr. Ernst Volgenau, Director Office of Inspection and Enforecment Encl:

30 copies Licensee Event Report 30 copies Supplemental Information Sheet Mr. William G. Mcdonald, Director Office of Management Information and Program Control Encl: 3 copies Licensee Event Report 3 copics Supplemental Information Sheet

()O

  1. IS77 THC TOLEDO EDISON COMPANY COCON PLAZA 300 MADISON AVENUE TOLLDO. OHIO 43GS2

^

Letter Fle,

6/7 & 8/76 - (and May 20, 1976) meeting at CP corporate offices. Meeting involved Selby and other and Keppler and others.

10/18/76

- Hearing date set for November 16, 1976. Rescheduled later (11/18/76 to 11/30/76). Environmental.

8/13/76

- Notice of Violation issued to CP.(Selby).

10/29/76

- CP response to Notice of Violation.

12/8/76

- Notice to resume Midland hearing on December 14, 1976.

12/16/76

- 50.55(e) on deformed (defective) component cooling water pump casings.

12/29/76

- Notice of resuming Midland hearing on January 8, 1977, in Chicago, Illinois.

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.' ANY DAVIS-BESSr. UNIT 0::E U POW 1dn STATICM SUPPLDIENTAL INFORMATIO.. La i.CR NP-33-77-42 DATE OF EVEMT: July 29, 1977 FACILITY: Davis-Besce Unit 1

~

l IDENTIFICATION OF OCCUREE"CE: Auxiliary Feed Pump Turbine (AFPT) 1-1 Main Stean Supply Line Check Valve (MS734) bonnet leak Conditions Prior to Occurrence: The plant was in Mode 3, with Power (:?.:T) = 0 and Load (Mh'E) = 0.

Description of Occurrence: 'At 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on July 29, 1977 while Operations persennel were running Surveillanca Test (ST 5071.01) " Auxiliary Feeduater Monthly Test", Main Steam Supply Line Check Valve MS734 was discovered to have steam leaking around the bonnet. The Maintenance Departcent was incediately notified and steam to AFPT l-1 was secured so Maintenance personnel could repair MS734. While repairs on MS734 were underway, Maintenance persennel als:

made some governor adjustments. AFPT l-1 was therefore inoperable which places the Station in the Action Statement of Technical Specification 3.7.1.'2.

At 1945 hours0.0225 days <br />0.54 hours <br />0.00322 weeks <br />7.400725e-4 months <br /> on July 29, 1977, the Surveillance Test (ST 5071.01) was completed and AFFT l-1 was declared operable.

Designation of Anparent Cause of Occurrence: Gasket on bonne't failed due to relaxation of bonnet bolts. Four out of the eight bolts were found to be only finger tight. The exact cause of this relaxation is not known.

Analysis of Occurrence: Since AFPT 1-2 was operable at the time and the React:r had not yet reached initial criticality, there was no danger to the health and safety of the public or Station personnel.

Corrective Action: The leaky valve bonnet was repnited by replacing the bonnet gasket with a new one and AFFT l-1 was returned to operable status at 1945 hours0.0225 days <br />0.54 hours <br />0.00322 weeks <br />7.400725e-4 months <br /> on July 29, 1977, removing the Station from the Action Statement of Technical Specification 3.7.1.2.

Fa i t e-c ":: r, : On July 27, 1977, both' Auxiliary Feedwater Systems were inoperable G J,. - i. - i i ).

-h

i REGULATORY GUIDES Backup File - 1975

2/12/75 - J. G. Davis letter CP: acknowledge receipt of Consumers' report on reinforcing bar spacing-(50.55(e)). Control No. H00419F3.

5/19/75 - Letter: S. H. Howell to A. Giambusso. First quarter '75 Financial Report. Page 3: QC/QA activities remain unchanged-curtailment of construction activities.

6/13/75 - NRC Schedule.

7/3/75

- Letter, R. C. Bauman (CP) to A. Schwencer. References meeting of June 24, 1975 between NRC and CP to discuss applicability of Regulatory Guides through Regulatory Guide 1.75 at Midland.

List of Regulatory Guides having some disparity with Midland construction.

7/24/75 - Letter, Bauman to Giambusso. Refers to NRC-CP meeting of 7/22/75.

Implementation of QA Regulatory Guides at Midland.

10/2/75 - Letter, Bauman to Boyd (NRC). Refers to tentative meeting on Materials Engineering Regulatory Guide 1.31.

States Midland position.

10/14/75 - Letter, Cooke to Keppler, NRC Schedule.

11/14/75 - Letter, A. Schwencer to CP addressing additional loads on vessel support system. NRC investigating but indicate present design may be adequate.

11/7/75 - Letter, Bauman to NRR (Boyd). Midland position on Regulatory Guides 1.1, 1.4, 1.7, 1.13, 1.25, 1.42, 1.49, 1.52, 1.54, and 1.70.

11/14/75 - Letter, Cooke to Keppler. NRC Schedule.

11/19/75 - Letter, Schwencer to CP.

NRC staff position on Regulatory Gu__c y

implementation at Midland.

Refers CP letter of 9/11/75.

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Backup' File 12/1/75 - Letter, Bauman to NRR_(Boyd). Midland position and information to NRR on use of Regulatory Guides.

12/11/75 - Letter, Bauman to NRR (Boyd).

Refers Schwencer's letter of 11/14/75.^ Supplies additional supporting information to vessel support system.

12/17/75 - Letter, Bauman to NRR (Boyd). Supplies additional information in response to Schwencer's letter of 11/19/75 on Regulatory Guide implementation and procurement status of plant components.

7/21/75 Letter, Bauman to Schwencer (NRC). CP position on Regulatory Guide use. Refers to meeting of July 22, 1975.

8/8/75

- Letter, Howell to Giambusso. Financial status.

N,o QC/QC changes. Indicates tentative change of personnel: Keeley as Midland Project Manager replaces Kessler; F. Southworth named Director of QA Services. Both effective August 1, 1975.

10/10/75 - Letter, Bauman to NRR (Boyd).

Information on Midland Regulatory Guide positions. Refers to tentative Regulatory Guide meeting l

of 11/13/75.

t 10/15/75 - Letter, Bauman to NRR (Boyd).

CP position on Regulatory Guide use at Midland.

11/10/75-- Letter, Howell to Giambusso. Financial report plus no change to QC/QA. Indicates construction escalation on January 1976.

1/13/76 - Letter, Schwencer to CP.

Comments and' request for information for use of Regulatory Guides at Midland.

Refers letter, CP to NRR of 11/7/75.

1/13/76 - Letter, Schwencer to CP.

Request for information on Regulatory Guide use at Midland. Refers to letter CP to NRR dated 10/10/75.

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% a:som LOWELL E. ROE Docket.No. 50-346 v<. em* i

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-License No. NPF-3 441m 209 S?d2 August 23, 1977 Serial No. 366 Mr. James G. Keppler Regional Director, Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Reportable Occurrence NP-33-77-42 Davis-Be'sse Nuclear Power Station Unit 1 Date of Occurrence: July 29, 1977 Enclosed find three copies of Licensee Event Report NP-33-77-42, with-a supple-mental information sheet, which is being submitted in accordance with Technical Specification 6.9 to provide 30 day written notification of the subject occur-rence.

Yours truly,

'h aae ; %)Ag LER:ljk Enclosures cc:

Dr. Ernst Volgenau, Director Office of Inspection and Enforcement Encl: 30 copies Licensee Event Report

.30 copies Supplemental Information Sheet Mr. William G. Mcdonald, Director Office of Management l

'Informatio:,and-Program Control Encl:

3 copics Licensee Event Report g08Sfg 3 copies Supplemental Information Sheet l

THE TOLLDO I DISON COMPANY EDISON PtAZA 300 MADISON AVLNUC TOLEDO. OHto 43tib2

Backup File '1/26/76 - Letter, Schwencer to CP.

NRC comments and request for information on use of Regulatory Guides 1.26, 1.20, and 1.94.

2/3/76

- Letter, Bauman to NRR (Boyd). Supplies information requested in Schwencer's letter dated 12/23/75 pertaining to Regulatory Guide use - electrical engineering.

2/3/76

- Letter, Bauman to NRR (Boyd). Supplies information requested in Schwencer's letter dated 10/30/75 on use of Regulatory Guide 1.59.

2/3/76

- Letter, Bauman to NRR (Boyd). Responds to Schwencer's letter dated 1/13/76 and supplies additional inforamtion on use of Regulatory Guides.

2/5/76

- Letter, Bauman to NRR (Boyd). Responds to Schwencer's letter dated 1/26/76 requesting information on use of Regulatory Guides 1.26 and 1.29.

2/10/76 - Letter, Bauman to NRR (Boyd). Final response to Schwencer's letter dated 1/26/76. requesting information on use of Regulatory Guide 1.94.

3/23/76 - Letter, Kneil (NRC) to CP announcing meeting at RIII March 30, 1976, on Section V.B of Appendix 1, 10 CFR 50.

Also, letter, Kneil to CP dated 4/23/76. Also, letter, Kne11 to CP dated 5/10/76. Also, letter, Howell to NRR dated 3/15/77.

3/2/76

- Letter, Howell to Rusche requesting relief from Quarterly

+

Financial Reports established ir. Giambusso letter of September 13, 1974.

[

5/3/76

- Letter, Boyd to CP.

Relieves CP of Quarterly Financial Report i

j and conditions of Giambusso letter of September 13, 1974.

L I

TOLEDO EDISU:: COMPAtIY DAVIS-BESSE UNIT OSE NUCLEAR POWER STATION SUPPLDIENTAL INF01C4ATION FOR LER NI'-33-77-44 DATE OF EVENT: July 29, 1977 FACILITY:- Davis-Ecsse Unit 1 IDENTIFICATION OF OCCURRENCE:

Indication variation on two Steam Generator levcl transmitters (LI-Si9A6 and LT-SP9A7) was greater than the allowed differentfal tolerance of 10 inches.

Conditions-Prior to Occurrence:

The plant was in Mode 3, with Power (MUT) = 0 and Load (MWE) = 0.

Descrintion of Occurrenec: At 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br /> on July 29, 1977, Instrument and Contrei personnel vere cali' rating and repairing tubing leaks on one Stess Generator level o

tranctitter at a time (LT-SP9A6, 9A7 and 9E9T. Each' transmitter uns restorcd to service uithin 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. At 1045 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.976225e-4 months <br /> while performing ST 5099.01, Miscellaneeus Instrument Shift Checks, 2 Stean Generator level transmitter indications on

- LT-SP9A6 and LT-SP9A7 were greater than the allowed differential tolerance of 10 inches. This placed the unit in the Action Statement of Technical Specificatien 3.3.2.2.(b).

Desinnation of Apparent Cause of Occurrence: After a Maintenance Work Ordar was issued, it was discovered that the vent valves on the transmitter body were 1saking causing a loss of level. indication in the Control Room.

The vent valves were nevar properly tightened during the calibrction.

Analysis of Occurrence:

Since the indications never went out of the tolerance that would require a manual trip of the Stcan and Feedwater Rupture Control Syste:

Channel, the Channel re=ained operable and there was no threat to the health and safety of the public or Station personnel.

Corrective Action: SFRCS level indicators were monitored closely to determine if any of the channels cust be tripped as per Action Statement #13 of Table 3.3-11.

The vent valves were tightened to stop the leaks and Steam Cencrator level indica-tion was returned to normal.

Investigation of this problem is continuine with the vendor (Rosemont).

Failure Data:

Stean Cencrator level was inoperable on'one prior event (NP-33-77-2'T.

but the cause ci ti.e reent was n.Ri;eient design in the power supplics.

e

---n

4

  • 1 Backup File
  • 6/14/76 - Letter, Kneil to CP.

Staff position on use of Regulatory Guides 1.10, 1.12, 1.15, 1.18, 1.19, 1.35, 1.60, 1.61, and.

1.92.

(Regulatory Guides 1.27, 1.55, and 1.59 excluded.)

Refers to CP letters of 7/21/75, 8/19/75, 12/1/75, and 2/3/76.

7/14/76

- Letter, Vassallo (NRR) to CP.

Letter requires CP do a reevaluation of vessel support systems for LOCA conditions.

10/8/76

- Letter, Varga to CP.

Staff position on use of Regulatory Guides 1.28, 1.30, 1.37, 1.38, 1.39, 1.58, 1.64, 1.74, 1.88, and 1.94 covered in CP of October 15, 1975. Also, staff position on use of Regulatory Guides 1.54 and 1.55' covered in CP letters of November 7,1975 and August 19, 1971.

10/8/76

- Letter, Varga to CP.

Staff position - partial response to CP 1etter of October 10, 1975, for use of Regulatory Guides 1.20, 1.26, 1.29, 1.46, 1.48, and 1.67.

10/15/76 - Letter, Varga to CP.

Staff position on use of Regulatory Guides 1.6, 1.9, 1.11, 1.22, 1.32, 1.40, 1.41, 1.45, 1.47, 1.53, 1.62, 1.63, 1.73, 1.75, and 1.81.

Regulatory Guide 1.12 addressed in NRC letter of June 8, 1976. Refers to CP letters of July 21, 1975 and February 3, 1976.

10/12/76 - Letter, Varga to CP.

Staff position on use of Regulatory Guides i

1.1. 1.4, 1.7, 1.13, 1.25, 1.27, 1.42, 1.49, 1.52, and 1.59.

(Excludes 1.54.)

Refers to CP letters of August 19, 1975, November 7,1975, and February 3,1976.

5ccff position on Regulatory Guide 1.70 covered in NRC letter of June 2, 1976.

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12/10/76 - Letter, Varga to CP accepts Midland Design and Construction 1QA Program (10 CFR 50, Appendix A).

Submitted to NRC by CP on 11/9/76.

Letter, Howell to VassalIio (NRR). Vessel support analysis 1/5/77.

due 4/77. Reference's letiters of NRR-CP, 7/14/76, and CP to NRR, 9/10/76.

3/15/77 - Letter, Howell to NRR (Boyd). Additional information on Appendix I.

. Refers to backup information on 3/23/76.

4/29/77 - Letter, Howell to Vassallio. Vessel support analysis due 7/77.

Reference 1/5/77.end 6/8/77.

6/27/77 - Letter Howell to NRR (Boyd).

Clarification of PSAR Amendment 32 dated 4/4/77. Electrical penetration information.

7/19/77 Letter, Howell to NRR (Boyd). Addresses CP position on use of Regulatory Guides 1.10, 1.12, 1.15, 1.18, 1.19, 1.35, 1.57, 1.60, 1.61, 1.90, and 1.92.

Refers NRC letter of 6/8/76. GIVES

SUMMARY

STATUS OF REGULATORY GUIDE USE FOR STRUCTURAL ENGINEERING.

7/19/77 - Letter, Howell to'NRR (Boyd). Addresses CP position on use of s

-legulatory Guides 1.6, 1.9, 1.11, 1.22, 1.32, 1.40, 1.41, 1.45, 1.47, 1.53, 1.62, 1.63, 1.73, 1.75, and 1.81.

Refers NRC letter

( of 9/29/76. GIVES

SUMMARY

STATUS FOR REGULATORY GUIDE USE FOR

\\

STRUCIURAL.(ELECTRICAL) ENGINEERING.

7/28/77 '- Letter,qowell to NRR (Boyd). Proposed FSAR Section 13.2 on 1

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e_ Totrno,Ord t:Dio Docket No. 50-346 LOWELL E.-ROE License No. NPF-3

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1419A 259-5247 August 23, 1977-Serial'No. 367 Mr. James G. Keppler Ragional Director, Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn,. Illinois 60137

Dear Mr. Keppler:

Reportable Occurrence NP-33-77-44 Davis-Besse Nuclear Power Station Unit 1 Date of Occurrence: July 29, 1977 Enclosed find three copies of Licensec Event Report NP-33-77-44 with a supple-mental information sheet, which is being submitted in accordanc'e with Technical Specification 6.9 to provide 30 day written notification of the subject occur-rence.

Yours truly, ed6[! J a6 t

t-

/

LER:ljk Enclosures cc:

Dr. Ernst Volgenau, Director Office of Inspection and Enforcement Encl:

30 copies Licensee Event Report 30 copies Suppleraental Information Sheet

.Mr. William C. Mcdonald, Director Officc of Management Information and Program Control Encl:

3 copics Licensee Event Report l

3 copies Supplemental Information Shoot 40cp9 1977 THC TOLEOO CDICON COMPANY

[DISON PLAZA 300 MAO! SON AVENUC T OLEDO. 01110 43G52 ne-.

y-T UNIT 2 LINER PLATE BULGE 2/26/77 - Bulge occurrence discovered at 11:00 p.m.

(Report No 50-330/77-02).

2/28/77 '- 50.55(e). prompt report to RIII at 2:15 p.m.

3/16/77 - NRC letter 'with report to licensee with noncompliance regarding failure to report timely.

4/5/77

- Response letter. Commitment made to provide procedure

" Reporting Deficiencies to NRC" No. 20-2, Revision No. 3, to s

prevent recurrence. Currently, Revision 3 still in review and modificatio: stage.

3/2$/77t ' - NRR ' representative visited site with inspector for damage briefing (50-}30/77-04).

.. i 4/14/77 - Meeting at Ann Arbor to review actions of bulged' plate removal s

and to review activities relative to proposed repair; D. W. Hayes T

and R. E. Shewmaker (77-06).

5/4/77-

- Site visit for inspection of existing conditions of liner bulge

's area.

D. W. Hayes and R. E. Shewt:aker (50-330/77-07).

5/16/77 - Interim report issued per 50.55(e).

S/24-27/?i-Special QA Program Inspeaction.

4 6/20/77 - IIsterim report issued p'er.50.55(e).

s s 6/29-30/77-Site Inspection by R. E. Shewms) e-6fl9/77) - (50-330/77-10).

3 Meeting, Ann Arbor (6/30/~ > ' ;, P. 3hewmaker and R. F. Heishman.

s Release for proceeding with repairs, Notify when start of

\\

repairs.

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8/I-5 & - Site Inspection, T. E.'Vandel Witness start of repairs with

.y 8-9/77 first.four-foot lift of liner plate installed and geputed.

Satisfactory.

(Report No. 50-330/77-11.)

l-8/15/77 - Final report issued per 50.55(e) in review by R. E. Shewmaker.

Further sit inspection planned later.

2

TOL::D0 ED1SO:: CO::PAMY g

DAVIS-P.ESSC UNIT ONE NUCl. EAR POUER STATION SUPPLDIENTAL'INFORMATION FOR LER NP-33-77-48 PAGE 2 evidence of burns or insulation integrity deterioration was found7 It was deter-

. mined that the construction equipment shorted one of the wires to ground in an area that is now surrounded by the blockout siliconc foam scalant which has effectively insulated uhatever insulation was violated. The centainment lightin; circuit from BE 1167 was re-energized after some preliminary checks and the fault has not re-occurred.

Ampcrage checks of'the circuits show no prob 1 cms.

A mogger check of the cable, AP BE1167, also shows that the cable is good.

Since non-0 AP BE 1167 (Containment Lighting) was the only circuit running through the ef fectcd conduit and all electrical checks indicate a good cabic, removal of the cable fro:

the penetration for further visual inspection will be performed at the first re-

. fueling outage.

BE 1101 trip is not unusual under a short circuit situation, as selective breaker tripping is only for overload conditions.

Analysis of Occurrence:

Since the reactor had not reached initial criticality, the loss of the Containment Spray Pump 1-1 Discharge Valve and 50% of the Centain-ment Vacuum Relief Isolation Valves for 35 minutes posed no threat to the health and safety of the public or to station personnel.

Containment Spray Pump 1-1 was operable, also.

J Corrective Action: Power was restored to both MCC EllC and EllE after thev were inspected for faults. No future failures with the same cause are expected in the future.

Failure Data: No previous similar events have occurred.

l

^\\

. UNIT 1 TENDON SHEATH PROBLEM 4/19/77 - 50.55(e) prompt notification report to RIII made.

4/20/77 - PN-III-77-18 issued.

4/29/77 - Immediate Action Letter issued to CP.

Six items of commitments:

1.

Notify RIII prior to repairs or modifications. Complete (see Report No. 50-329/77-07).

2.

Complete investigation of cause and implement C.A.

Not complete, still in discussions with Bechtel regarding adequate performance.

3.

Expand overvies program - expanded program in process.

4.

Notify NRC of placement errors for all embedments' starting May 9 and for next 120 days. - 120 days completes on September 9; during that time seven separate it' ems have been reported. See backup sheet A.

5.

Review and revice QC inspection procedures. All Bechtel QCI's have undergone review. Revision in progress.

6.

Training of QC engineers and field engineers expanded.

Training program and retraining is underway.

5/5/77

- Meeting in Jackson with Keppler, Heishman, and Hayes.

5/19/77 - Interim report issued per 50.55(e).

5/24-27/77-Special QA Program Inspection. Five noncompliance items.

1.

Bechtel: inadequate piping hanger support plate installation.

Currently still open.

2.

Bechtel: field engineers mark up installation drawings for hangers. Currently CA complete.

3.

Consumera: audit report remain unissued (4). Currently CA complete.

4.

Consumers: trends analysis procedure unimplemented. Currently CA complete.

I" g

-TOLEDO EDISON COMPAtlY DAVIS-BESSE UNIl ONE NUCLEAR Pth'ER STATION SUPPLEMENTAL INFOPJ1AT10N FOR LER NP-33-77-48

-DATE OF EVE q: July 27, 1977 FACILITl:

Davis-Bosse Unit 1 IDENTIFICATION OF OCCURRENCE: Loss of power to Containment Spray Pump 1-1 Discharge Valve and to Containment Vacuum Relief Isolation Valves.

Conditions Prior to Occurrence: The plant was in Mode 3, with Power (MWT) = 0 and

- Load (MWE) = 0.

Description of Occurrence: At 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br /> on July 27, 1977,'the feed breaker (BE1101) for Motor Control Center EllC tripped, which resulted in a de-energization of MCC EllC and MCC EllE.

MCC EllE is fed from MCC EllC.

When MCC EllC tripped, power was lost to the Containment Spray Pump 1-1 Discharge Valve CS 1530, whose feed breaker is BE1156.

Since power was lost to CS1530, Containment Spray Pump 1-1 was declared inoperable.

The station entered the Action Statement for Technical Specification 3.6.2.1 which requires two independent Containment Spray Systems to be operable.

Also, when MCC E11C was de-energized, power was lost to five of,the Containment Vacuum Relief Isolation Valves.

These valves and their breakers are:

VATNE BREAKER CV 5070 BE 1137 CV 5071 BE 1138 CV 5072 BE 1139 CV 5073 BE 1140

~

CV 5074 BE 1141 Since power was lost to these valves, they would not close on a Safety Features Actuation System signal to maintain Containment integrity. The station entered the Action Statement for Technical Specification 3.6..l.1 which requires Containment inta-grity to be maintained.

Also, as a result of this trip of MCC EllC, both Auxiliary Fecdwater Systems were declared inoperable.

This was covered in Licensee Event Report NP-32-77-11.

It was found that af ter investigation no faults existed on MCC E11C or MCC EllE, and they were re-energized successfully at 1220 hours0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.6421e-4 months <br /> on July 27, 1977. This re-turned the above valves back to operability, and the station was removed from Action Statements for Technical Specifications 3.6.2.1 and 3.6.1.1.

Desir.nNtion of Annarent Can w of 0 currence: The caune of the trip of BE 1101 have been caused by const ruc tion pert.innel (feeder.for E11C) h.5.. ii.o Jet.

1.it

.o (Bi.sco) working on p< net ration Pal.'vX in conduit #38357A, which is AP-ilEll67.

The

[

worker not iced a flach as he was manipulatine, his equipment around noon on Wednesday July 27, whic,h correspeids to the time HEl167 (Containment Lighting Disconnect Switch BSUX79113) feeder' breakbr t ripped.

  • This penetrat:on was inspected and no t

+

km

=

Unit 1 Tendon Sheath Problem _

5.

Champion (Batch Plant): defective batch scale not tagged per procedure. Currently CA complete.

Additional CA for items 3 and 4.

CP to reorganize and provide additional manpower.. Currently new organization in effect and most all personnel _ additions completed in August to be reviewed further later.

(See organization chart backup sheet B.)

6/27/77 - Interim report issued per 50.55(e).

6/29-30/77-Site Inspection by R. E. Shewmaker (6/29/77) - (50-329/77-07).

Meeting in Ann Arbor (6/30/77).

R. E. Shewmaker and R. F.

Heishman. Release ~for proceeding with repairs.

8/1-5 & - Site Inspection, T. E. Vandel. Report No. 50-329/77-08.

8-9/77 Complete' record review of repairs to tendon sheaths. No problem areas identified. Installation was accomplished as proposed.

8/12/77 - Final report issued per 50.55(e). Review is completed and thank you letter states that we have no further questions.

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Breakers were re-energized within 35 minute.s.

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l BACKUP SHEET'A

. 1.

Tendon Sheathing 5/19/77 elen //[r ) t < < ', -

en Vertical Sheaths - notified on 5/24/77 (NCR-803) C 2.

D. W. Hayes

- 6/22/77, 9 #11 bars missing (QF-169) 3.

I. T. Yin

- 7/15/77, 2 #11 bars missing (NCR-863) 4.

.D. W. Hayes - 7/28/77, 2 bars missing (QF-175) C 5.

T. E. Vandel - 8/15/77, 8 #8 wall dowels missing (QF-176) C I

6.

D. W. Hayes - 8/16/77, 4 cut bars not replaced (NCR-898)

7.. C. E. Jones - 8/17/77, pipe restraint controls omitted - reactor building (NCR-910) fc,. 7 l+ be.

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The_ drain valve was op_e_ned and lqvel was j

u ev p!!_). restored below the lim.it uithin 17 minutes. (NP-33-77-30) l

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{i}ilLrersonnel _ error caused the level to exceed the limit. while attest,tirg; I

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,e BACKUP SHEET B Other Items

^

A.

May 27, 1977

- Final report per 50.55(e) regarding the surveillance specimen holder tubes (provided by B&W)

Follow-up agreements were outlined in our letter of thanks dated J'une 21, 1977.

B.

May 27, 1977

- Final report per 50.55(e) regarding component cooling water pump casings.

No comment by RIII, since casings have been rejected and will not be used for Midland.

C.

May 24, 1977

- PN-III-77-30, Industrial Accident - Death of Construction Worker (no repercussions)

D.

March 22, 1977

- Meeting in RIII offices with B. W. Marguglio, CP Director of Project Quality Assurance Services regarding contemplated independent inspection of NSSS installations.

E.

November 14, 1975 - Vessel support LOCA loading adequacy - question.

Analysis is due July 1977 to NRR.

.M -e; 4

3:sp M [ Tot.Eun% 5N2ID LOW 5u.E. Rot Docket No. 50-346' lgly',,

u,,,, y, 3 ;,..-

. License No. NPF-3 August 24,'1977-Serial No. 369 Mr ' James G. Keppler Regional Director,~ Region Ill Office of' Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Roa1 Glen Ellyn, Ill nois 60137

Dear Mr. Keppler:

Reportable Occurrence NP-33-77-30' Davis-Besse-Nuclear. Power Station Unit 1 Date of Occurrence: July 30, 1977 Enclosed find three copics of Licensee Eient Report NP-33-77-30 with a supple-mental information sheet, which is being submitted in accordance with Technical Specification 6.9 to provide 30 day written notification of the subject occur-rence.

Yours truly,

~

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y[p r O,ctL',e AMg(

[

7*j LER:ljk Enclosures.

cc:

Dr. Ernst Volgenau. Director Office of Inapection and Enforcement Enc 1: 30 copies Licensee Event tieport 30 copics Supplemental Information Sheet Mr. William G. Mcdonald, Dtrcetor Office of M:ina;;ement

'Information and Program Control Enc 1: 3 copics Licertsce Eu.. Report O ' G " o @

.3 coplec Supplemental Information Sheet 1HF 10LLD0 FDiSON CCMI'ANY f.D150N PL A7A 300 MADISON AVCrJUC TULC DU, 011:0 43n52

- -