ML20094M554
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s Consumers r& i Power id - Projects, Engsneersng and Construction oeneral offices: 1945 West Perness Road, Jackson, MI 49201 * (517) 788 0453 May 17, 1982
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e Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III l-799 Roosevelt Road p
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i MIDLAND PROJECT RESPONSE TO DRAFT SALP REPORT FILE 0.6.1 SERIAL 17485 On April 26, 1982, Mr J G Keppler and members of the NRC Region III staff met with Consumers Power Company personnel in Jackson whs.re the NRC presented the observations and findings of the Midland SALP board for the period July 1,
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1980 to July 30, 1981. At the conclusion cf that meeting we were informed that we should make written comments to Ge Region III office within 20 days
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of that meeting date. This letter transeits Consumers Power Company's response to the draft SALP evaluation report and to other comments made by Mr Keppler at that meeting.
Our general reaction to the SALP evaluation can be summarized as follows: We support the SALP goals and objectives because we believe it is vital to have an active and continuing dialogue with those who have direct regulatory responsibility for the' Midland Nuclear Plant. We do believe, however, that the SALP process has not yet reached maturity and there are areas where the process can be made more effective. With regard to the specific contents of the draft SALP report, we are enneerned with what we believe is an_
u_anecessa rily netative characterization of_the inspection results for the period covered by the SALP report._ Because of this concern and our belief that T.he facts do not support the characterization presented by the authors of the draft SALP report, we have spert considerable time reviewing the detailed information on which the draft SAL 1 report was based, and this analysis forms the basis of our attached response. We believe a careful review of this material will enable Region III management to understand the basis for our concern and to gain an appreciation for our perspective in this matter.
In addition to the review of the draft SALP report, Mr Keppler made several comments at the April 26 meeting regarding his own participation in both the NRC team inspection of May 1981 and his subsequent testimony in the ASLB hearings on the soils matter.
In order to respond to those comments we have also included additional material and analyses that directly respond to Mr Keppler's comments.
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2 Our detailed response to the SALP report and Mr Keppler's comments has been divided into three attachments transmitted with this letter. A description of each of the attachments follows. is a detailed review of the entire draft SALP report and the inspection results upon which the SALP report was based. We conclude that the details of the SALP analysis support a more positive conclusion than was presented at the SALP meeting. The basis for this suggestion is that there appears to be considerable ov m tate A of the actual severity of the inspection findings, some factual errors and_ omissions within the draft SALP report itself, and further, there are some assignments to this dALP evaluation of events that occurred prior to the SALP evaluation period, all of which contribute to an unnecessarily harsh characterization of the Midland Project regulatory performance during this SALP evaluation period. Attachment 1 also contains our comments on the SALP process. to this letter is a comparison of Mr Keppler's testimony in the Midland soils hearing with the specifics of the draft SALP report. This detailed comparison concludes that even with the generally negative characterization of the Midland Project by the SALP board, there is still no contradiction of Mr Keppler's prior testimony by the draft SALP report nor any need, in our opinion, for him to modify that testimony.
The third attachment to this letter entitled " Analysis of Current and Future Quality Activities With Regard to Remedial Soils Work," addresses specific questions raised by Mr Keppler at the conclusion of the SALP meeting. This attachment points out that there appear to have been considerable regulatory difficulties experienced by the Midland Project during the past two months, mainly because of the inability of the NRC staff and the Company to-finalize the quality assurance program coverage requirements for the soils remedial work, particularly for the underpinning ac'tivities. Attachment 3 points out that this difficulty appears to have been generally resolved and that there are numerous reasons for confidence that with the regulatory requirements properly defined, the remaining soils work can be carried out in a fully satisfactory manner.
Consumers Power Company urges the Region III management and staff to carefully consider the information and reasoning contained in this response to the April 26, SALP meeting. We believe that there is ample basis for the Region Administrator to reaffirm his 1981 overall team inspection findings in his overall conclusion to the 1980/1981 SALP evaluation.
Finally, as noted previously, we were disappointed with the negative tone of tha uraft SALP report. We take very seriously the comments made by the Region j
III SALP board members and will do whatever we can from the applicant's point of view to engender productive working relationships with the staff and to be responsive to the staff's concerns. Nevertheless, we must disagree with some of the material in the draft SALP report, and we request the opportunity to meet with Mr Keppler and his staff to review the detailed contents of this response.
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Distribution: Keppler (3 copies)
CC: Atomic Safety & Licensing Appeal Board CBechhoefer, ASLB
- HMCherry,Esq FPCow,:n, ASLB RJCook, Midland Resident Inspector SGadler JHarbour, ASLB DSHood RBlandsman WHMarshall BStamiris MSinclair oc0582-2048a102
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Attichment I ge 1-1 CONSUMERS POWER COMPANY RESPONSE TO THE DRAFT SALP REPORT FOR THE MIDLAND NUCLEAR PLANT
Reference:
1.
NRC letter; J A Hind to J W Cook; dated April 20, 1982; with Enclosures 1 and 2.
This response is in three parts. The first part provides a general response to the SALP appraisal and SALP process as a whole. The second part provides our detailed response to Enclosure 1 of the reference, the Significant SALP Report Findings. The third part provides' a detailed response to Enclosure 2 of the reference, the Pre-liminary SALP Report, dated March, 1982, covering the assessment period of July 1, 1980 to June 30, 1981.
Part 1 - General Response i
'A. We are encouraged by the general statements to the.effect that the NRC sees pro-grass in Consumers Power Company's overall quality assurance program and in _its management. Undoubtedly, there has been improvement in our regulatory performance from the 79/80 assessment period to the 80/81 period and from the 80/81 period to the present. Literally, dozens of actions have been taken in order to achieve this improvement. These actions have been communicated to the NRC.
In May, 1981, Mr Keppler and members of his staff performed an extensive team inspection from which they concluded that "... the scope and depth of this NRC inspection was such that the identified noncompliances do not contravene our conclusion that Consumers Power Company has established an effective organization for the management of construction and implementation of quality assurance at the site."
B.
We are, however, disappointed by the overall negative tone of the draft SALP Report. Nonetheless, we continue to be dedicated to attaining two goals:
1.
First and foremost, to ultimately assure that the as-built configuration of the plant is in conformance with all regulatory and design requirements;
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2.
To continue to improve our regulatory performance.
C.
We welcome feedback relative to our regulatory performance--the sooner the better. We have encouraged such feedback in a number of ways, and we shall continue to do so.
A number of meetings with Region III management and staff have been at our initiative. On numerous occasions we have proposed the establishment of routine, periodic meetings to exchange information with Region III's home' office staff. Og_our own in_itiative, we submitted our Preoperational g r6 ht)m3, jah Our sp'ecilic invitationTy 'have loirit'fibuted to Mr'Kippler's' perso i
Testing Manual in order to'obtain Region III review and comments at an early
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j 0f I qf[f participation in the NRC team inspection conducted in May,1981. We have s
proposed that an NRC Inspector be on site as much of the time as possible to i
assess our remedial soils work. Of cotrse, at the completion of NRC inspec-tions, exit interviews with the Inspectors are a routine feedback mechanism. -
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3 D.
'In reviewing how to improve the Company's overall regulatory performance,
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becomes evident that the most timely regulatory feedback is that which is
. received before the accomplishment of the work in questrion. While both
' Consumers and the NRC attempt-to achieve this objective, we believe both our organizations have fallen short in this area.
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It is our recommendation that the NRC consider scheduling seminars for the f; various ongoing nuclear construction jobs as they approach each major phase.One pu 4
h and procedure for each major new activity at each job. This review would 3 [Yh gf verify that all programmatic requirements at the detailed level were in i
f.p prior to the work or could be upgraded before the fact to meet Region III f
f s, expectations. In addition, the NRC inspection specialists could review with the Y[@x
.b applicant's quality personnel typical detailed inspection plans used by the NRC
[ in their on-sice inspections. At the same time, discur.sions of actual
.9 experience from other earlier constructi5h iilles 'could siake the Licensees for
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ciarre~nt construction sites more aware of and responsive to potential problems in
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We in industry hsys tried to accomplish this objective with our various regional
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and industry groups, and by reviewing inspection Jteports from. other jobs.
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However, 3hese efforts suffer byJ ack of NRC input at detailed working levels.
We urge the NRC to coiisliteTthis type of an approach to supplement their other l
inspection programs.
-A specific benefit to Midland's future performance has.already occurred as a 4
result of this concept. It was mentioned at the SALP meeting that we had i
submitted our Test Program Manual to Region III some time ago in order to obtain feedback prior to the start.of detailed systems testing. Even though some testing has already taken place, we are delighted to report that follow-up from the April 26 meeting has resulted in the scheduling of a detailed NRC review of i
the Midland test program for later this month.
E.
We recognize that the SALP process is a relatively new one and that the NRC is attempting to develop an approach to the SALP reviews that will be timely, fair and based on the best available information. This second SALP Report is a major improvement over the first, National SALP Report which was issued in the fall of 1981. Nonetheless,_,oug zrir -' %SALP Report discloses _ additional
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_ improvements which can be achieved in meeting the objectives of the SALP f /jk ""
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Tirst, there appears to be no consistent format in characterizing the areas
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The current SALP Report has both categorizations which leads to an inevitable
[ gdk, double counting of deficiencies identified during a report'ing period. The report itself recognizes this problem, but discounts it.
We appreciate the need perceived by Region III for singling out certain specific activities, such as i
design control, for separ.2te treatment in the SALP Report..Howare d e_ overlap of_f3nction and activity categories detracts substantially from the systematic.
nature of_the app uisal. Certainly, there are mechan'ses available to I
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Region III to express its particular concern with a designsted aptivity ocl}er q
than the SALP Report. % tj r.a,. 6 Q d p _, Q //r j w, 4 M r-o m. #
p'pg' Second, the rankings do not appear to be consistent. For example, no items of p
noncompliance were identified with respect to the Fire Protection, Containment and other Safety-Related Structures, and Preservice Inspection areas. Yet Fire Q
Protection was rated a " Category 1" while Containment and other Safety-Related Structure and Preservice Inspection we p ted a " Category 2."
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)Webelievethatthemajorcriteriainevaluatinglicenseeperformanceshouldbe f the number and seriousness of items of nonco:apliance identified by NRC for a
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given unit of inspection time. We are not suggesting that there is no room for Tw subjective judgment in the appraisals of each area. What seems to occur, j
g however, is a lack of consiste e from area A a m _in_ applying.the factors which shape that judgment. Moreover, we note that most of the specific items Y
N discussed were the subject of testimony before the ASLB conducting the soils no reviet.
eems to have taken place.
yg Finally, the time period during which the Licensee's performance is being l
evaluated is unclear. Part V of the Preliminary SALP Report does indicate that 3
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the noncompliances and deviations in the HVAC area were reported also in the
$[g first SALP report. However, one item of noncompliance listed,in the Piping Systems and Support Performance Evaluation related to an apparent nonconformance
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p j that took place in Ncvember, 1973, but was identified duriQ NRC inspection
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M itud in th_ Preliminary SE P Report represented design deficencies which e
occurred long before the SALP period.
If those are the groundrules for the SALP process, they should be clearly stated. The Licensee and the public will then I
recognize that the evaluation rests not only on events,which occurred during the f
evaluation process, but also on events identified during the evaluation period, regardless of when they tock place.
What follows is a response to specific statements in the Preliminary SALP Report.
Those specific statements are either direct quotations from, or characterizations of, items which were included in various NRC inspection reports. We have responded in writing to each inspection report and refer you to those responses for the details of the Company's position regarding each item. However, some of the characterizations of the findings of the inspection reports in the Preliminary SALP Report are incomplete. For your convenience, we have summarized our responses to each of the inspection findings, as well as clarifying the content in which those findings arose, as appropriate.
Part 2 - Response to Enclosure 1, Significant SALP Report Findings A.
General Observations 1.
We are pleased that the Preliminary SALP Report noted the " improvements in the overall quality assurance program"; that we have " established an effective organization for the management of QA/QC activities"; and that "the numbers and qualifications of personnel in the QA/QC org,anization(s) oc0582-0039a167
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1-4 and the overview and audit functions performed were found to be above that normally found at other construction sites."
2.
Also, we are pleased that for the 5 2pport Systems (HVAC) area the Preliminary Report recognized our risolution of the problems which existed during the previous SALP period pr h r to July 1, 1980. This resolution was realized through considerable expenditures of resources. We believe this demonstrates our responsiveness to problems with concrete actions.
3.
The general observations relative to the less technical administrativa. areas are of concern to us.
We do not view our past responses as argumentative-merely because they provide additional facts or reasoning which may not have been available for presentation to the NRC Inspector at the time of the exit interview or because they provide infermation with which the NRC Inspector disagrees. The Staff, in at least twm instances in the soils hearing, testified that making legitimate appeals is entirely proper, and is part of e
the normal give and take between the NRC Staff and the licensee. It is disappointing that the Preliminary SALP Report does not embrace the essence of that testimony and also of our management conference on this subject. At that conference, we were told not to be raluctant to appeal on any i
legitimate issue, but to discuss our differences with Region III prior to submitting any written appeal in order to facilitate its resolution. This 4
suggestion has been adopted.
B.
Pipinz Systems and Supports 1.
We agree with the Preliminary SALP Report item relating tc the unavailability of Committed Preliminary Design Calculations (CPDCs) to support the drawings for small bore piping. This, in our opinion, was the major quality deficiency that occurred during this SALP period. Upon discovery of the unavailability of the CPDCs, we stopped the design work, began immediate corrective action, and did not resume the work until both we and the NRC Staff were assured that the process had been ec.rrected. Even with the design process deficiency identified, '.t is heartening to report that not a single pipe segment required rework as a result of this situation, t
2.
We also note with pleasure that the informal current reting in the Piping Systems and Supports area as of this time is " Category 2" based on Mr R 1
l Cook's statements made during the April 26 presentation of the Preliminary SALP Report. This improved rating is, we assume, based upon recognition of our positive and effective corrective actions in this area.
i C.
Electrical Power Supply and Distribution 1.
While we understand that any noncompliance is "less than desired" and also understand the Staff's particular interest in our ambitious cable pulling schedule, we do not understand the apparently negative observations in this a*;es. The implication ~given is that were it not for the NRC's advice, we e
would D ra'n7 nadequ' ate' number ~of QA/QC personnel available to support lh_ej able pulling,si.hedule. This is an erroneous implication. We believe
~ we have always supported the cable pulling activities with the appropriate
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In fact, the amount of cable pulling carried out by the Company could not have been completed without adequate QC personnel, because in process inspection is required to verify cable pulling tensions.
2.
We also believe that the seven items identified'during this period were not excessive and were of relatively low consequence. These items are discussed more fully in the third part of this Attachment.
D.
Soils and Foundations 1.
We view the finding in this area especially harsh because it is predicated
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on some relatively minor i.tems of noncompliance, and on misinformation in U&~{
the_ Prelimi_ nary SALP Report, as demonstrated in the third part of this Attachment.
2.
Reference is made to_" limited QA/QC coverage." At no time has the QA/QC staff been insufficient to cover the ongoing work. At one time the NRC-advised us of the need for additional personnel to cover future work. We were fully aware of and agreed with that need, and we have staffed and are staffing to meet it.
Also, in our opinion, there has never been any inadequacy in the qualifications of the QA/QC personnel assigned to the remedial soils work. The QA Engineers so assigned are all degre d civil engineers. M /,( g g dg gg g Part 3 - Response to Enclosure 2, Preliminary SALP Report Tv 3 A Lp gg,[g A.
Section I, Introduction Our comments on this section are found in our general comments provided in Part 1, above.
B.
Section II, C_riterir, 1.
Our. general comments relating to the manner in which evaluations are made are contained in Part 1, Paragraph E, above.
C.
Section III, Summar7 of Results 1.
Our comments on this section are found in our general comments provided in Part 1, Paragraphs A and B, above.
D.
Section IV.1, Performance Analysis of Quality Assurance 1.
It is gratifying, as noted earlier, that the NRC recognizes our above normal efforts with regard to the Quality Assurance organization and program, with regard to our overinspections and audits, and with regard to our aggressiveness in assuming the primary inspection responsibility for the HVAC installation.
2.
Seven of the eight items identified from the May,1981, inspection and referenced in this section of the Prelieinary Report are duplicated elsewhere in the report under the Soils, Piping and Supports, and Electrical oc0582-0039a167 l
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1-6 Sections. Therefore, we will address these noncompliances specifically in
-the other sections.
3.I The eighth item from the May, 1981 inspection dealt with the correction of adverse quality trends. Action was taken to provide a procedural change to cause the more timely closeout or verification that correction has been made in response to an adverse trend.
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Our trend analysis activity is among the most comprehensive anywhere, in
-terms of scope and sophistication. Such_gn_activi_ty is not specifically_
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required by NRC regulations or ANSI standards. Should not credit be given 7
for this?
o 4.
This section of the Preliminary Report also refers to another inspection
" indicating questionable QA managerial control (because) the licensee failed to fully evaluate the technical capability of the i
principal supplier of services for soil boring activities."
This is an unfair and incorrect summary of what occurred.
The original NRC Inspection Report states:
"The technical capabilities of Woodward-Clyde (principal supplier of services for soil boring activities) were not evaluated prior to comnencement of drilling operations on April 2, 1981."
'h Our original letter of response stated:
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"On March 31, 1981, Consumers Power Company approved Woodward-Clyde consultants as the principal supplier of services for the soils boring and sample program based upon meetings (between March 3 and 11, 1981) with Woodward-Clyde consul-
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tants.
.. Woodward-Clyde consultants were considered Q
qualified as documented by letter serial 12134, dated 4g 1 April 8, 1981 N Ramanujam to File B.2.5.4 (Attachment 3).
s, Even though this letter is dated April 8, 1981, it documents
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steps taken prior to April 2,1981, in qualIT71ng Woodward-N Clyde. Woodward-Clyde consultants were approved by Oral.
QQ Communication _ Report serial 11883, R C Hirzel to R C 7auman, da~ted April 2,1981Mattactsiient 2).
Both of these documents (Serials 12134 and 11883) were presented to Dr Ross Landsman of the Nuclear Regulatory Commission on April 9, 1981."
'T Mh not " questionable QA managerial control." This is not " failure to fully evaluate the technical capability of the principal supplier." The documentation was _provided to the NRC Inspector.
The actual noncompliance was failure to provide our Procurement Department with the letter documenting the approval of Woodward-Clyde prior to the commencement of activities on April 2.
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5.
Also, this same paragraph of the Preliminary SALP Report states:
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"The NRC identified 15 deficiencies in the principal supplier's quality assurance program manual indicating that the licensee had not adequately reviewed and approved the procedures prior to preparation of drilling activities."
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We are concerned both about the substantive and procedural implications of this comment. ' The 15 items referred to were generated as a result of out
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quality assurance programmatic requirements. The NRC Insoector narticinated i
E th us in the initia_1 and_ timely review of Woodward & Clyde's quality e
assurance manual. We welcomed his participation and anticipate that it will N
Eontinue.at Ien t through the conclusion of the soils remedial work. g y) 4t is simply counterproductive and unnecessarily adversarial for the NRC Inspector t6'"take credit" for having identified these deficiencies.
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gg-Indeed, he did not do so.
In any event, the important point is these items 1g were uncovered in a routine review, in accordance with established quality assurance practices.
_Had__the_y mone undetected past the review stage, ysom might have h en to the level of "dericiencies_." Our tinely hanairng of these matters is inappropriately characterized as a deficiency in the Preliminary SALP Report, when in fact it represents the proper functioning of the Quality Assurance Program.
E.
Section IV.2, Performance Analysis of Soils and Foundations j
1.
The second paragraph of this section of the Preliminary SALP Report, states:
"Every inspection involving regional based inspectors and addressing soils settlement issues has resulted in at least l
one significant item of noncompliance."
The correctness of this statement depends upon how the term " inspection" is s
defined. It has been customary to define an inspection in terms of the l
duration of the inspection trip. For example, if an Inspector visits the l
\\k site for three days in the first week, leaves and does not return until the i
third week, at which time he visits the site for two days, the practice has j
been to view these as two separate inspections. Houever, the practice of j
the NRC Inspector in this srea has been to combine, into a single NRC p
Inspection Report, the results of two or more inspection trips.
If an NRC i
inspection is defir.ed as the inspection performed during a single trip, this statement in the Preliminary SALP Report is incorrect.
4 2.
The Preliminary SALP Report states:
"There was a failure to initiate audit corrective action concerning the rereview of the FSAR and references to determine if design documents had modified the FSAR and if so I
d that changes had been made to the FSAR."
i This itew is duplicated in the Preliminary SALP Report in the section f
dealing with Design Control. Read carefully, the item reflects a failure to initiate audit corrective action, not a failure to perform an adequate i
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rereview of the FSAR. The need for the corrective action was, in our view, of minor importance.
The FSAR rereview was an extensive, as well as intensive effort spanning 18 1
months and involving three companies--Consumers Power Company, Bechtel, Babcock & Wilcox. Bechtel,-alone, spent an excess of 10,000 manhours on this effort prf or to its completion in September,1980. This effort resulted in a clarification and upgrading of the content of the FSAR. Two audits were made by the Consumers Power Company Quality Assurance Department to assess the adequacy of the FSAR rereview effort. Both audit teams concurred that the rereview had been accomplished conscientiously and.
effectively, assuring that design -changes had not modified the FSAR or, if
.so, that such changes had been subsequently reflected in the FSAR.
The item given in the Preliminary SALP Report stems from our audit finding to the effect that all of the design de uments which were rereviewed were listed in block 8 of the rereview foce as required by the rareview not procedure. The instructions for block 8 indicated that the rereviewers were l
to list the design documents to be rareviewel, to indicate whether or not any conflicts existed between the design documents and the FSAR, and then to 1
indicate the necessary rssolution. The audit showed that some rareviewers had listed only the design documents which contained conflicts, and had indicated the required resolutions. In essence, therefore, these rereviewers did not understand the block 8 instructions to require a 4
complete listing of documents--those whica did not contain conflicts as well as those which did.
Nevertheless, the technical correctness of the rereview was validated, as follows: Rereview packages which did not provide a complete list of the reviewed documents were identified, and a large sample of them was selected.
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The packages selected were those which were most likely to contain design document conflicts. The packages were re-rereviewed. From this re-l rereview, it was ascertained that not a single package contained even a single unresolved conflict. At this point, the rereview process was approximately 80 percent complete (recall that it was an 18 month effort).
While there appeared to be soes misinterpretation of the block 8 procedural j
requirement, all the rereviewers appeared to understand the intent of the rereview effort and were adequately resolving any conflicts between the design documents and the FSAR. Based on this, it was decided not to rewrite the procedure for block 8 and not to redo the block 8 document listings. It was thought that such actions only would have confused the procers at this point in time. After an exchange of correspondence with the NRC on this ites, however, we agreed to change the procedure and to provide additional j
training to the reviewers.
At the completion of the FSAR rereview effort, another sample of packages i,
was re-rereviewed by the audit team with the same results, thus verifying the adequacy of the remaining 20 percent of the effort which had not been subject to the initial audit re-rereview. In essence, then, the two audit re-rereviews confirmed the adequacy of the entire effort.
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In testimony before the Soils Hearing Board, Dr Landsman indicated that the block 8 condition did not call into question the technical effectiveness of the rereview, which Dr' Landsman specifically found adequate (TR.p-4857, 4930).
3.
The Preliminary SAI.P Report notes:
l "Three examples of failure to translate applictble regulatory requirements and design criteria into design documents."
This item is also duplicated in the Design Control section of ~ the </
. Preliminary SALP Report, s.
The first example given is:
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" Failure tc maintain a coordination log of Specification Change Notices (SCNs)."
i In response, there are three separate coordination logs fa the civil discipline. These logs are maintained by three different people. The
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Drafting Supervisor maintains the coerdination log for drawings and drawing change notices. The remaining documents, including SCNs, are covered by two other coordination logs which are maintained by Discipline Aides.
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During the Region III inspection, the Company could not immediately i
document that all coordination had been included on an SCN log. The problem was made worse by the fact that the NRC Inspector was i
inadvertently shown the, wrong log. Also the NRC Inspector felt that pplicable procedures required all revisions of specifications, whether i
technical or clerical in nature, including those merely incorporating i
previously approved or coordinated SCNs, be reviewed by Geotech and so j
noted in the log. Although the Company disagreed with this interpretation, the procedure was modified, making it clear that j
clerical revisions merely incorporating previously reviewed changes need j
not be re-ccordinated or re-reviewed by Geotech. At the request of the
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Region III Inspector, the Company also committed to review current j
revisions of civil, Q specifications to insure appropriate coordination of changes was carried out.
j In any event, this is hardly something which can be properly 1
characterized as a " failure to translate applicable regulatory l_
requirements and design criteria into design documents."
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b.
The second exemple given is:
" Failure to correctly translate Specification Change Notice No SCN-9004 as a requirement into Revision 20 of Specification C-208."
l This ites arose as a result of a slight difference in wording between an SCN and the specification, after incorporation of the SCN into the oc0582-0039a167
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t 1-10 specification, relative to' the Geotechnical Engineer's responsibilities for establishing the laboratory compaction test frequency. The SCN was issued.to describe the responsibilities of the newly assigned on-site Geotechnical Engineer. The specification after incorporation of the
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SCN, used terms different from and more general than the SCN to describe l-the geotechnical engineer's responsibility for the establishment of the frequency for labcratory compaction testing.
In our vi the intent of both the SCN an_d he specification was the sami, although,the C 77 '
inspartor aid not agreiNHquentTyrany differehce in wording was t
eliminated.
Aga'in',~tTds~ situation appears to be very harshly l-characterized as a " failure to translate applicable regulatory requirements and design criteria into design documents."
The third example given in the Preliminary SALP Report is:
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" Failure of Engineering Department Project Instruction No EDPI
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4.25.1, Revision 8 to establish adequate measures fe. design
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interface requirements."
)
In response, the EDPI was revised to state that it is the responsibility of the originator of a design change to coordinste the change with all groups which are affected by, or involved with, the revised portion of the document, regardless of whether the change is technical or editorial. This procedural change was made to eliminate the previous option of the Group Supervisor to waive the need for the coordination or interface when, in his judgment, it was unnecessary. This coordination is now required even for editorial changes. Adequate coordination had
)
been accomplished prior to the EDP1 revision.
The need for this added conservatism introduced by the EDPI revision is a matter of opinion and Consumers Power Company has accommodated the NRC's concern in ?.his regard. However, there was never any " failure to translate applicable regulatory requirements and design criteria into design documents" and to characterize this item in that way is erroneous and unfair.
4.
The Preliminar
- ~ _ y SALP Report gives the following ites:
["Failuretoestablishtestproceduresforsoilswork)
(activities."
The NRC Inspector founc that US Testing did not previously determine the l
rhoostat setting which produced the maximum density. However, US Testing did previously determine the rhoostat sa: ting that produced the maximum amplitude required by ASTM D2049. Tests were reperformed to verify that the maximum rheostat setting yields the maximum amplitude given in the relative l
, density table used for the project. gResults were documented and supplied to the NRC. This is far differant from a " failure to establish test procedures" as stated in the Preliminary SALP Report. Again, the Report's comments are a gross generalization and a misrepresentation of the factual situation.
oc0582-0039a167
~
}.'
1-11 In this situation, the NRC Inspector did not accept an ASTM Standard procedure called out in the specification and imposed his own personal preference as to the technical requirement.
c g
5.
The Preliminary SALP Report also indicates a:
h
" Failure to supply a qualified on-site Geotechnical Engineer."
f As part of the original response to soils issues, a Geotechnical Engineer b
was assigned to be on site. The resumes of the assigned engineer ("the 1
%g ' g (
g*#
first engineer") and of another applicant to the position ("the second y
t' engineer") were reviewed by Mr E Gallagher, then the cognizant NRC N
g Inspector. Mr Gallagher expressed his opinion to our Mr Horn that the 4
N
[
second engineer w M referabEe'because of his many years of field (nE experience. We cannot say whether or not Mr Gallagher noticed that the Q
second engineer was not a degreed engineer (although Mr Gallagher reviewed M
the man's resume). On the basis of Mr Gallagher's opinion, the first engineer was removed and the second engineer was assigned. to the site.
i Subsequently, another NRC Inspector, Dr Landsman, became cognizant in this I
- Q)M area. Dr Landsman who was accompanied by Mr Gallagher during this inspection, was advised of the original coordination with Mr Gallagher, but Dr Landsman held an opinion different from Mr Gallagher because the second D
engineer did not have a civil engineering degree. Dr Landsman then cited
'N s
the Company with a _deviationlor failure to erm 4ria a aum14 t inci Gaetechnical D
sfgineer for the job. ImmediateTy~iiie~reafter, the first engineer was
%s b'
' reassigned to Ene on-site position. Dr Landsman concurred with this b-assignment.
Inviewofthesefacts,thecitationseemsbt us unf ir.
Qgkdcelufm.,.
- c ceoLa.rry Rc 6.
The Preliminary Report also states:
tu tc.s, w f g
___ g "It was noted in NRC Inspection Reports No. 50-329/81-12; 50-Lt!pvh 330/81-12 that a sufficient number of qualified personnel were not available for the complex nature of the remedial soils work. This had previously haen identified in NRC Inspection Reports No. 50-329/81-01; 50-330/81-01, referenced previously as a deviation to a commitment."
-f G
Inspection Reports No. 50-329/81-01; 50-330/81-01 deal with the deviation d
relative to the on-site Geotechnical Engineer. This was covered in g
Paragraph 5, immediately above. By the placement of this item in two
}
different parts of the Preliminary Report, the appearance is given of two different items when, in fact, there is only one.
NRC Inspection Reports'No. 50-329/81-12; 50-330/81-12 merely indicated the
'Q NRC's advice to the effect that additional QA/QC personnel would be needed to accommodate the forthcoming remedial soils work. We agreed with this NRC
~D observation. We were not cited for any noncompliance on that score in these
- ,7 I h --
' inspection reports.(d 27 QA/QC persons employed by both MPQAD and BechtelW
- 4=- h ersons 17
--\\
employed in MPQAD an Quality Control to cover remedial soils work--appropriate for the current g
workload, also taking into account the time necessary to assure their
, adequate training and certification. Five more persons are due on site by oc0582-0039a167
~
~
1-12 sid May. Additional personnel are being sought to fill the 2 remaining
' authorized positions..The Preliminary SALP Report gives the impression of an inadequacy with regard to the quantity of personnel when, in fact, quite the opposite situation g h
7.
Finally, another ites referenced in this section of the Report is duplicated
[
in the Quality Assurance Sect _on of the Report. Please refer to Part 3, Paragraph D.4, above.
1 8.
In summary, while we find this section of the Preliminary Report inaccurate Nh
-andoverstated,l~wefullyrecognizethespecialsensitivitiesinvolvedinthe N
remedials soils area, and we are especially dedicated to the implementation i
_y of the quality controls and assurances required by law and engineering prudence.
F.
Section IV.3, Ferformance Analysis of Containment and Other Safety-Related Structures 1.
The cracks in the BWST foundation are also referred to in the section of the Preliminary SALP Report dealing with Design Control.
G.
Section IV.4, Performance Analysis of Piping Systems and Supports 1.
Itse a(1) of this section of the Preliminary SALP Report states that:
"Bechtel Purchase Order did not specify applicable codes for purchase of 60,000 pounds of E-7018 electrode."
L
\\
The original statement of the ites, from NRC Inspection Reports No. 329/80-Q 20-01 & 330/80-21-01-was as follows:
4 [(*
"Bechtel Corporation Welding Standard WFMC-1, Revision 8,
(
dated January 4, 1971, ' Welding Filler Material Control
,q Procedure Specification,' Paragraph 2.1, states, in part, N
that'.
. welding filler material ordering information shall i
.e g
g q
include the appropriate requirements of the job engineering w
t specification, the applicable Code and this procedure
- N t'
specification.
~
y t
3 j g y
' Contrary to the above, on July 10, 1980, the (NRC) Inspector i
l s
established (that) Bechtel Purchase Order No. 7220-F-5780, t
dated November 2, 1973, for 60,000 pounds o'f E-7018 electrodes did not specify the applicable Code.'"
i 5
Qd First, note that the Preliminary SALP Report statement omits any reference T
to the November 2, 1973, date. The Bechtel Purchase Order for the E-7018
[
electrode was issued on November 2, 1973. We question whether we should bd j
cited in this assessment period for an event which occurred 7 years prior t the assessment period.
Second, at the time of the procurement, a revision of VFMC-1, dated May, 1973, was applicable, whereas the citation referenced the January 4,1971 oc0582-0039a167 i
=
Attachment.1 1-13 revision of WFMC-1. The procurement was made in accordance with the May, 1973 specification. The procurement documentation reflected complete compliance with the requirements. Although these facts were not available immediately during the period of July 8-10, 1980, when the NRC Inspector was making the inspection, these facts were provided in our original response to the citation on August 25, 1980.
In addition, Consumers Power Company has performed an audit of the procurement documentation for weld filler materials procured from 1973 through 1980. This, too, was reported to the NRC in the August 25, 1980 response.
2.
Item a(2) fa this section of the Preliminary Report indicates that an Authorized Nuclear Inspector's hold point was bypassed for the pressurizer
']
rurge piping.
)
b' ( i' This item was ostected by the NRC Inspector on September 24, 1980. By September 25, corrective action had been taken and verified by the NRC 1'
' Inspector.
p 3.
Items a(3) and (4)-indicate that large bore pipe restraints, supports and anchors were installed incorrectly and that QC Inspectors did not detect the
\\
e incorrect installations.
ic l
It is highly unusual to cite a licensee twice for what is essentially a g /f} v.
single QA defect (one citation for the construction defect and another for I,
not having detected the defect).
The NRC Inspector found 7 cases of apparent nonconformances to design requirements. He stated that he was using cursory inspection techniques.
Upon our further inspection, we agreed that 3 of the cases were defects, but with more refined in=nection_technigues our investigation indicated that 2 3
cases were within tolerance, I case was a result of obvious post-inspection-damage that woald.be checked for during walkdown inspection, and 1 case was i
for work yet to be inspected initially. The 3 real defects were of a relatively minor nature, and none of them impaired the function of the i
hangers even though they constitute a legitimate basis for the NRC's finding.
,j.
On the basis of these findings, we agreed to make an extensive sampling 1
reinspection of hanger installations which were made prior to 1981. The results of this reinspection have indicated the presence of additional minor defects and may necessitate further reinjection. The results have been made available to the NRC and now are being analyzed by both the NRC and Consumers Power Company.
1 4.
Item a(5) in this section of the Preliminary Report, dealing with the t
- availability of Committed Preliminary Design Calculations for small bore pipe and piping suspension systems, is duplicated in another section of the i.
draft SALP Report dealing with Design Cc.1 trol and Design Changes and is the major contributor to the Significant SALP Report Findings for Piping Systems l
i
-oc0582-0039a167 J
4 8
1-14 and Supports given in Enclosure 1 to the Reference. Correspondingly, our response to this item is covered in Part 2, Paragraph B of this attachment.
5.
Item a(6) indicates:
" Failure to adequat=17 control documents used in site small 4
bore piping design activities."
(X Y The original item from NRC Inspection Report No 50-329/81-12 and 50-330/81-p.
12 stated that:
y a%
"An one) outdated specification was maintained at the small
.J 9 bUe(%ingdesigngroupworklocationandrevised g'~D calculations were not marked.' superseded' in accordance with the procedural requirements (our emphasis)."
k A
N After careful checking, this finding was determined to have been an isolated./
case.
Nevertheless, the calculations were checked and were found to be correct.
Training was conducted of all personnel in this group. An audit was made.
A procedure was changed to require that the specific revision number of the specification on which the calculation is based he documented in the 7
calculation package.
6.
Item a(7) indicates that Consumers Power Company audits did not:
y'
" Include a detailed review of system stress analysis and (did'
, [, '
not) follow up on previously identified hanger calculation inconsistencies."
In response, the above statement refers to the fact that we did not audit for the availability and correctness of the Committed Preliminary Design Calculations as discussed in Part 2, Paragraph B, and Part 3, Paragraph G.4, above. The audits that were made previously in this area concentrated on the completed calculations, rather than the preliminary calculations. The audit checklist for this area has since been adjusted to reflect a requirement relative to the preliminary calculations.
4 oc0582-0039a167 t
i
1-15 l
H.
Section IV.5, Performance Analysis of Safety-Related Components-1.
As a result of the two original items, from which the two items in this section of the Preliminary SALP Report are drawn, Consumers Power Company issued a formal Stop Work Order to Babcock & Wilcox and a letter to the NRC stating that the work stoppage would remain in effect until the corrective actions had been complated and reviewed by the NRC. Corrective actions were taken, as follows: The installation procedure for this activity was revised to clarify the method of installation and to specify the required dimensional checks. The indoctrination and training of the personnel performing the installation and of the personnel inspecting the work was strengthened. The Consumers Power Company overview inspection plan for this activity was revised. The NRC Resident Inspector verified these actions.
+
2.
Again, it is encouraging that today's rating in this araa, as stated by Mr R Cook during the April 26 meeting, is a stzong " Category 2," or even, perhaps, a " Category 1," based on the aggressiveness of our overview efforts. We recognize the particular importance of this area, and we intend l
to continue our agressive overview of this area.
I.
Section IV.6 Performance Analysis of Support Systems (KVAC) 1.
We appreciate the " Category.1" rating for the period in question and on an informal basis for the current period, as well, as stated by Mr R Cook
[
during the April 26 seating.
2.
It should be noted that the civil penalty was ' imposed for conditions which existed prior to the assessmens perisd in question,.
3.
The 17 items referred to were all identified as a result of investigations i
which were completed prior to_ June 30, 1980, and, therefore, prior to the 2
start of the assessment period in question. This may be observed by reviev of the individual items given in NRC Inspection Reports No. 50-329/80-10; j
50-330/80-11. Although these Inspection Reports are dated January 12, 1981, 1
they clearly provide findings that were available prior to June 30, 1980.
During management meetings held on March 24 and 28, 1980, these investigation findings were discussed extensively.
n e
\\<q l
J. 'Section IV.7 Performance Analysis of Electrical Power Supply and Distribution
.s' 1.
Item a(1) in this section of the Preliminary SALP Report indicates a failure
?.
v to establish procedures for temporary support of cable.
g (7 The four damaged cables were repaired. The procedure was revised to require i
that coiled cables be properly supported, protected from damage and prevented from violating the minimum bend radius.
2.
Item a(2) in this section of the Report indicates that electrical contractors did not verify conformance to Paragraph 3.1 of Project Quality Control Instruction E-5.0.
f 1
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1-16 n\\
\\g This item was an isolated incident of two wires violating separation j
standards inside a control panel. The cable routing was rearranged to 7 4 -
provide the required separation, and the separation was verified by inspection. Electrical crafts and inspection personnel were formally reinstructed with regard to the separation requirements. Installation and inspection aids were provided to these personnel.
3.
Item a(3) indicates a:
" Failure to identify and control nonconforming components."
Because of the general nature of this ites, we are not sure to what it i
refers. After a thorough review of the NRC Inspection Reports for this assessment' period, however, we believe that it refers to an item from NRC Inspection Reports No. 50-329/81-11; 50-330/81-11, as follows:
"On April 23, 1981, the (NRC) Inspectors identified 14 instances in which cable tray in the upper and lower cable spreading areas were not installed in ar.cordance with the separation requirements delineated in the Midland FSAR and j'
which had not been identified and controlled to prevent j
inadvertent use or installation...
1 I
Consumers Power Company documented the nonconforming condition for a few 1
cases on a Nonconformance Report issued in May, 1979, long before the NRC Inspectors' finding.
I, ate in 1979, it was determined that the existing Marinite barriers were not the most suitable separation device for our plant configuration. This resulted, in January, 1980, in the removal of the requirement for the Marinite barriers. In the spring of 1980, a study was i
conducted to determine which kind of barriers would be more suitable when 1
the required spatial separation is not possible. Two things resulted from this study--first, that barrier installation would be accomplished best after cable pulling was complete; and second, that there was no risk in j
reworking cable trays after cable pulling to instr.11 the barriers, if needed. In August, 1980, a new barrier was chosen and SAR and design I
changes were made in April and June, 1981, respectively to reflect these changes.
a l
This is a lengthy discourse, we realize, but in essence, the main points are as follows: we were wel_1 aware of__the condition. At the time, we made a conscious decision not to }rovide any more inspection to identify additional specific cases where separation was not, maintained. We were aware that the design was being changed, that the construction process was being changed, and that the final Bechtel Quality Control insFection for this condition would be carried out at the conclusion of the construction process. The Bechtel Project Quality Control Instruction E-3.0, " Final Electrical Area Completion Activities," was revised to reflect the inspection for separation and, as needed, for the installation of barriers at the completion of the cable pulling activities. Correspondingly, we were holding open our Nonconformance Report to assure that these changes were correctly i
implemented. There was no inadvertent " failure to identify and control."
It was a conscious and knowledgeable deci g oc0582-0039a167
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1-17 This information was previded to the NRC on July 16, 1981, in our response to the NRC Mnspection Report. ~Considering the explanation supplied to the Staff, we believe that there was no ites of noncompliance and that this item
. should not have been in this Preliminary SALP Report.
4.
Item a(4) indicates a:
" Failure to translate design criteria into drawings and specifications."
9Dris inspection finding related to whether or not the color coding of instrumentation process lines was required. Based on our reading of the applicable codes and standards, it was not, and we stated this position in our original response to the NRC. At least one other licensee has the same position and is maintaining it.
However, we have acceded to the NRC concern in this area by agreeing to identify the instrument process lines with a.two digit alpha designator, and the specification has been. changed to add this new requirement. We are also not clear whether this recuirement applis.s.
generally or only in Kezion III, since the Draft Romulatorv Guide on th_is, subject makes no mention of the requirement.
5.
Item a(5) indicates a:
'" Failure to identify during inspection that a nonconforming condition with regard to miniaum installed cable bend radius existed."
The condition re' erred to was discovered by a Consumers Power Company f
employee who was accompanying the NRC Inspector during his inspection. A Consumers Power Company Nonconformance Report was written to document the condition for the single cable in question. In addition to physically correcting the condition, the Bechtel Quality Control Inspector who y
originally inspected the cable was given an 8-hour training program in all phases of cable tercination.
6.
Item a(6) indicates:
" Failure to take prompt corrective action with regard to the lack of approval of procedures for the rework of electrical raceways."
i We agreed that this was an entirely appropriate finding and Bechtel Construction and Bechtel Quality Control developed and issued the necessary administrative guidelines and instructions. Recently NRC Inspectors have conducted a follow-up inspection and determined that the rework controls have been properly implemented and carried out.
7.' Item a(7) indicates:
1
" Failure to provide adequate storage conditions for (three
^;
items)."
l oc0582-0039a167 l
}~l jl
,l x-1-18 The storage conditions for each of the items was immediately corrected. The Bechtel Maintenance Engineers were given additional ~ training in accordance with the requirements of the field maintenance procedure. Consumers Power Company performed a comprehensive audit in this area to assure compliance g, fj with tbn field maintenance procedure.
\\.C h (i 8.
It should be noted that each of the foregoing items is a Severity Level.V or \\p\\ sf VI, relatively low severity levels.
f ('
.9' We are gratified that our informal current rating is " Category 2," as stated (\\'
by Mr R Cook during the April 26 meeting.
\\
9.
In two places in this section of the Preliminary SALP Report reference is made to the quantity of Bechtel Quality Control personnel being employed, with the implication that this quantity may be insufficient. To our knowledge it was not; nor is it now.
In addition, in response to NRC concerns we have demonstrated both the qualifications of these personnel and the process by which they are certified.
K.
Section IV.8, Performance Analysis of Instrumentation and Control Systems No comment.
L.
Section IV.9, Performance Analysis of Licensing Activities Comments pretaining to our responsiveness to Staff requests for information regarding the " Soils" issue should certainly be qualified by noting the novelty or uniqueness of this technical review and the evolutionary nature of the Staff's positions. It is useful to note that as this review draws to its conclusion, the Advisory Committee on Reactor Safeguards (ACRS) subcommittee on the Midland soils questions characterized the Staff review as exhaustive and possibly an example of overkill. In addition, the ACRS subcommittee questioned the Staff extensively ca whether portions of their review and requirements went beyond what was necessary to protect public health and safety. We are gratified that the Staff finds our more recent replies to be responsive and of high quality. We are striving to maintain this trend and improve communications with the Staff.
M.
Section IV.10, Performance Analysis of Firs Protection
.\\
Ve appreciate NRC's " Category 1" rating in this area and its recognition of our efforts.
N.
Section IV.11, Performance Analysis of Preservice Inspection In view of the extensive amount of preservice inspection which was performed during the period corresponding to this SALP Report and continuing into the cu' rent period, with no items of noncompliance, we fail to understand why this-r area is not rated as " Category 1" instead of " Category 2,".
oc0582-0039a167 e
l 1-19
-0.
Section IV.12. Performance Analysis of Design Control and Design Channes 1.
Items.a(1)(a) and (b) given in this section of the Preliminary SALP Report are duplicates of items given in Section IV.2.
As such, our specific response to these items is given in Part 3, Paragraphs E. 2 and 3, and will not be repeated here.
i 2.
Item a(2) in this section of the Report is a duplicate of an item covered in Section IV.4.
As such, our specific response is provided in Part-3, Paragraph G.4 and will~not be repeated here.
3.
Item a(3) in this section of the Report is a duplicate of an item given in Section IV.7. of the Report. As such, our specific response is given in'Part 3, Paragraph J.4 and will not be repeated here.
4 The five ICCFR50.55(e) items listed in this' section of the Preliminary Report relate te designs which were completed long before the start of the SALP period in question--in fact, years before. ~ Our identification of these items during this assessment period indicates continuing design reviews, 4
improved design. control and our rigid compliance with the reporting requirements of 10CFR50.55(e).
4 5.
We also call _your attention to five inspections of Bechtel Power Corporation, Ann Arbor Division, engineering firm for the Midlahd Plant, j
conducted between January, 1979 and September, 1981 by the Vendor Inspection Branch of Region IV. The inspection covered a* wide variety of design i
activities. For example, the October 7-10, 1980 inspection encompassed design verification, design interface, and design inspection activities.
The March 31-April 3, 1981 inspection covered computer program control, technical personnel background verification, design change control and design corrective action. The two specifically referenced inspections were conducted during the-SALP sppraisal period. In all five inspections, there were a total of 6 nonconforming items identified, all of a relatively minor 4
nature (nonconformances or deviations rather than violations). In two of the inspections no-items of nor. compliance were found. In our view, these j
inspections are indicative of a high degree of compliance within design segments of the Midland Project, and would clearly support m higher rating than the one given in this area.
{
(The five inspection reports are documented in letters dated April 16, 1981; October 14, 1981; November 5, 1980; June 15, 1979; and January 19, 1979, to the Bechtel Power Corporation, Ann Arbor Division, from Uldis Potapors; Chief Vendor Inspection Branch.)
I 6.
Considering the nature of Items a(1)(a) and (b) and a(3), and the unfairness of a citation for activities long before.the period in question, we are
, disappointed by a " Category 3" rating in this area.
We believe that design control is one of the most difficult and important aspects of nuclear power plant projects. Design control has been doubly difficult for the Midland Project mainly because of the duration of the i
project and the incorporation of a multitude of new regulatory requirements, i
,3 oc0582-0039a167 9
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1-20
~
Lato the design as it progressed. We do not dismiss for a som'ent our obligation to monitor and improve our own efforts in this area and we continue to institute our own internal programs to increase our confidence in the quality of the overall design effort. We raise this concern with the preliminary SALP evaluation because the only significant finding in the SALP period that indicates a design control problem was the small bore piping lack of design package cover sheet, which was concluded to be an. isolated event. On the other hand, we believe that ths Region IV inspection reports and the seven 50.55(e) reports referenced provide strong indications that the design control area is improving.
P;Section IV.13, Performance Appraisal of Reporting Requirements and Corrective Action 1.
In this section of the Report, it is stated that:
I "The licenroe failed to make a timely determination for the need to submit a 10CFR50.55(e) Report to the NRC based on a 10CFR Part 21 Report from TransAmerica,DeLaval, Inc."
i Consumers Power Company has always adopted a conservative attitude towards reporting under 10 CFR 50.55(e). We believe the industry, practice in this regard varies, depending upon the amount of analysis undertaken and discretion exercised in determining whether a deficiency could have an i
adverse impact on safety. In the past, Region III has stated that the Company does a " good job" reporting under 10 CFR 50.55(e).
I In this specific case, the DeLaval Part 21 Report was sent to Bechtel and was misrouted, such that Consumers Power Company and the appropriate Bechtel personnel were not aware of the Part 21 Report on a timely basis. In the final analysis, the condition was determined not to be 50.55(e) reportable.
Corrective actions were taken. They included issuing letters to suppliers to advise them of the person to whom Part 21 Reports should be submitted, conducting training sessions at the site for key personnel to assure that misdirected Part 21 Reports get correctly redirected, and issuing periodic menos reiterating the information offersd in the training session.
j -
2.
This section of the Preliminary SALP Report also states:
" Expeditious resolution of noncompliances is often delayed by inadequate licensee responses. The licensee has a tendency to spend too much time trying to justify why a finding is not a noncompliance rather than devoting the time to correcting the basic problem. Nine of 22 items of nencompliance were contested (excluding HVAC system nonompliances). Two of the contested noncompliances were retracted, but time and effort were lost in timely resolutions. Similar attitudes and responses have been observed regarding Company audit findings.
This attitude is reflective of the licensee corrective action l
system and becomes a detriment to quality."
l
(
oc0582-0039a167
l 1+21 t
In response, let's. deal with the statistics first. Two of the nine appeals (excluding HVAC) were granted,~ or 22 percent. -Five other HVAC items were
.4-appealed, and two of those appeals were granted, or 40 percent. Combined, 14 items were appealed, 4 appeals were granted, or 29 percent. Of those not granted, the merits of the appeal are well documented.
While there may be some unavoidable delay because of appeals, in no instance has an appeal precluded timely corrective action. In addition, the Staff has repeatedly testified in the Soils Hearing that the Applicar' should appeal when necessary or appropriate.
During a meeting on October 5, -1981, NRC's Region III management made -it clear that NRC's concern was with the administrative process by which appeals were made, not with the appeals.themselves. They stated that appeals should be made and dispositioned informally, if possible, prior to the issuance of NRC Inspection Reports or, at the latest, prior to our written response to the NRC. findings. We agreed with this suggestion an'd assured the NRC that such appeals, if any, would be made accordingly. It is disappointing that the substance of this management discussion was not
,i reported in the Preliminary SALP Report.
1 Q.
Section V. A. Noncompliance Data 1.
It is important to recognize that the noncompliances and deviations given in the table for Midland Unit 1 are identical to those given in the table for Midland Unit 2 in the large majority of cases. We recognize that this is so stated in the footnote to both tables in the Report.
2.
At this point, it is appropriate to r iterate from our response given in e
Part 3, Paragraph I.3, that the 17 items associated with the HVAC were all identified as a^ result of investigations which were completed prior to June 30, 1980 and, therefore, prior to the start of the assessment period in question. This can be seen by review of the individual items given in NRC i
Inspection Reports No. 50-329/80-10; 50-330/80-11. Although these l
Inspection Reports are dated January-12, 1981, they clearly provide findings that were available prior to June 30, 1980. During management meetings held on March 24 and 28, 1980, these investigation findings were extensively 1
discussed. In conversations with NRC Inspectors, we were advised that these items are included in this SALP Report because they were inadvertently excluded from the earlier Report, and that they have to be covered somewhere. We believe that the earlier SALP Report should be revised to reflect these items. The presence of these items in' tais SALP Report bears unfavorably and unfairly upon the overall impression offered by the Report for the period in question.
R.
Section V.B, Licensee Report Date 1." The twelve 50.55(e) Reports listed herein further demonstrate our cooperative approach with regard to the submittal of 50.55(e) Reports, as ststed earlier in our response given in Part 3, Paragraph 0. 4 and 5.
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Section V.C, Licensee Activities No comment.
T.
Section V.D. Inspection Activities 1.
The results of the May 18-22, 1981, NRC team inspection evoked the following conclusion, as given in NRC Inspection Reports No. 50-329/81-12; 50-330/81-12:
"This was an in-depth inspection to examine the implementation status and effectiveness of the current QA Program, to determine whether previoasly identified quality assuranca problems were sufficiently precluded from occurrence in other areas, and to ascertain whether management involvement in the QA Program was sufficient and effective.
1 Although eight items of noncompliance were identified during this inspection, it is our (NRC) judgment that the scope and depth of this NRC inspection was such that the identified noncompliances do not contravene our conclusion that Consumers Power Company has established an effective organization for the management of construction and implementation of quality assurance at the site."
U.
Section V.E, Investigations and Allegations Review No investigations or allegations were pursued during the assessment period corresponding to this SALP Report, including investigations and allegations for i
HVAC. This supports our earlier assertions that reference to the 17 HVAC items should be deleted entirely from this Report.
V.
Section V.T. Escalated Enforcement Actions-1.
The civil penalty was imposed for conditions which existed prior to the assessment period corresponding to this SALP Report.
2.
Under the heading of "Confirastory Action Letter" are two examples of inspection findings that appear to be characterized in an overly harsh manner. We have been told in prior conversations that letters of committment by the licensee with regard to inspection findings and which commit to actions desired by the NRC do not constitute an escalated enforcement action. Obviously, we misunderstood. Not only are these letters categorized under the escalated enforcement heading, but the text directly states that these were in fact the licensee equivalent of an immediate action letter. It was our understanding that Region III agreement
, to a licensee letter of commitment represented a Region III management decision that the item in question was downgraded in severity and did not represent an escalated enforcement action.
I i
oc0582-0039a167
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Section V.G, Management Conferences 1.
TVo of these management conferences were at Consumers Power Company's request.
2.
We strongly support the need for more management conferences with top and intermediate level NRC management participation, especially focused on attaining mutual understanding as to the standards that will be applicable to Midland inspections.
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2-1 COMPARISON OF TESTIM 0hY OF JAMES G KEPPLER BEFORE THE ASLB ON JULY _13-14, 1981 WITH FINDINGS IN THE DRAFT SALP REPORT Introduction On July 13-14, 1981, Mr James G Keppler, the Director of the Region III Office of Inspection and Enforcement, testified that the NRC has reasonable assurance that quality assurance and quality control programs at Midland,will be appropriately implemented with respect to future soils construction activity,
. including remedial actions.
In March 1982, Region III issued its Pre:iminary SALP Report on the Midland Plant. Nothing in the SALP Report-contravenes Mr Keppler's testinony regarding reasonable assurance.
All of the information contained in the SALP Report was known to Mr Keppler at the time he testified.
1.
Quality Assurance a.
SALP Analysis The report notes the creation of the MPQAD and Consumers Power's assumption of responsibility for onsite quality control and quality assurance functions for the installation of the HVAC systems.
It also lists the findings of NRC Inspection Report No SI-12.
The report concludes:
The licensee is rated Category 2 in his overall quality assurance capability. Notwithstanding weaknesses identified in specific areas, the licensee has been responsive in establishing an overall effective organization for the management of construction and implementation of quality assurance at the site.
b.
Prior Testimony Mr Keppleg7 testified extensively gygarding NRC Inspection No 81-12,II the MPQAD-and the Zack matters.-
Mr Keppler initiated NRC Inspec ion No 81-12 for the purpose of determining the efficacy of the MPQAD.g' Mr Keppler personally inspected the woyk of the NRC inspectors at the conclusion of the inspection,- participate drafting the inspection report, andsignedthefinalreport.EpinMr Keppler concurred in the report's conclusion that, although some problems were identified, the MPQAD atMidlandwereworkingquitewell.77ndthequalityassuranceprogram Mr Keppler also described the corrective actions Consumers Power had taken with regard to Zack, and concludedthattheZag)problemdidnotindicateabroaderbreakdown in quality assurance.
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Soils and Foundations J
a.
SALP Analysis ~
.The SALP. Reports lists the soils-related noncompliances and deviations 1 identified in NRC inspections of Midland during the SALP evaluation period (July 1,.1980 to June 30, 1981).
The report concludes that:
.The licensee'is rated Category 3 in this area.
The enforcement i
. history indicates that additional licensee attention is warranted.
l b.
Prior Testimony The evidence before the Licensing Board shows that Mr Keppler was L
thoroughly familiar with the 1980-81 enforcement history relating to soils issues when he made his judgment regarding reasonable assurance at Midland..Mr Keppler was Regional Director of Region 111 during this period an SALPanalysis.gjsigned allaof the NRC inspection reports listed in the He testified in de l
problems.identifed in these reports.-}gp1 about many of the soils He explained that all.of the I
soils problems' identified in 1980-81 were carefully reviewed and reassessed, and all pertinent records covering summer 1980, to May L
1981 were examined, in assurance in !1ay' 1981.39rriving at the conclusion-of reasonable
- Mr Keppler specifically noted'that the history of soils work at Midland did not contravene his judgment of l-reasonable assurance. The soils problems,-he testified, "can be largely' attributed to the failure to. fully recognize the importance of l
the application of quality assurance to soils work (but) the l
importance of quality assurance to soils work and to censequent remedial actions l.
ConsumersPower.gptheMidlandsiteisnowfullyrecognized"by l
3.
Containment and Other Safety-Related Structures.
l a.
SALP Analysis "The. licensee is rated Category 2 in this area.
The licensee's performance appears to be satisfactory; no significant strength nor weaknesses were' identified."
b.
Prior Testimony Mr Keppler did not testify on this subject.
u i
- 4. ' Piping Systems and Supports I
'SALP Analysis a.
The Report lists seven items of noncompliance identified by NRC Staff inspections during the evaluation period.
Eased on five of these
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items,.an Immediate Action Letter (IAL) was issued on May i-The report concludes:
_ 22, 1981.
The licensee is rated Category.3 in this area.
The enforcement history is indicative of weaknesses in the implementation of the quality assurance program.
"b. Prior Testimony Mr Keppler testified regarding the p{gyng problems identified during NRC' Inspection No 81-12 in May 1981.-- - He explained that problems with piping systems are an industry-w#ide concern that is' receiving censiderable Region III attention.12 Problems are inthisareaatalmosteverynuclear'siteinspected.ggyngidentified The NRC Staff inspector who identified the piping problems at Midland is at the forefront of knowledge in this area, anj6#did not consider the incidents at Midland to be significant.--
NRC Inspection No 81-12 confirmed that the methodology of the design, installation and qual controlinspectionofthepipingandsupportsystemwasacceptable.jyy It was the unanimous view of the inspection team that the problems identified were isolated, and not indicative of weaknesses in the implementation of the program jgy major programmatic S.
Safety-Related Components a.
SALP Analvsis The report lists the two items of noncompliance which culminated in Consumers Power's issuance of a letter of understanding on January 22, 1981. The report concludes:
The licensee is rated Category 2 in th's scea.
The above enforcement was aimed at an isolated inst.nce and may have been directly related to change in NSSS QC personnel changes.
The licensee had in the past and since this episode maintained adequate QA control for the assembly of NSSS equipment.
b.
Prior Testimony No testimony was given on this subject.
6.
Support Systems a.
SALP Analysis The report notes the quality assurance deficiencies and the Civil Penalty of the previous SALP evaluation period.
It commends Consumers Power's " aggressive action" in taking over complete responsibility for quality assurance and quality control in HVAC installations; this action resulted'in significant improvement in control over the installations and in correction of identified weaknesses.
The report concludes:
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The licensee is rated Category 1 in this area. Mana g; ment attention and involvement has been aggressive _in accepting full-QA/QC responsibility and supporting this organization with an adequate number of skilled personnel.
b.
' Prior Testimony
-Mr Keppler testified that the HVAC pr Jemsproblemdidnotindicatea broad breakdown in quality assurance 7.
Electrical Power Supply and Distribution.
a.
SALP Analysis l
The report listed seven noncompliances identified during the,
evaluation period and concluded:
The Licensee is rated Category 3 in this area.
The enforcement history. indicates a lack of management attention and involvement.
This is evident by apparent inadequate preplanning and assigreent of priorities as activities increased, a poor understanding of procedures for control of activities and minimal QC Staffing for the magnitude of the activities.
b.
Prior Testimony MrKepplertestifiedthatelectricalworkwasextens{g7yreviewed 1
durinc the May 1981 NRC Staff inspection of Midland.--
The inspection team reviewed five areas within electrical work: quality l
assurance records, quality assurance implementing procedures, q'uality l
control personnel, visual inspection of electrical work activities, andConsumersPower'sactionsgpjpreviously identified items.21/ Only four problems were identified.--
These problems were isolated and not indicative of any major prggyammatic weaknesses in the implementation of the program.--
The inspection report also
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j commended Consumers Power for several aspects of their electrical work program. First, the. program and its implementation regarding calibration of termination tools was. judged to be satisfactory.24
Second, Consumers Power had taken timely and cer.prehqnsive actions to correct areas addressed on previous NRC inspections.22' Finally, the quality gyurance(electrical)organizationwasfoundtobestrongand capable.
8.
Instrumentation and Control Systems a.
.SAIP Analysis "The Licensee is not rated in this area because a minimal amount of l
instrumentation installation and minimal inspection effort during this evaluation period."
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Prior...timony There was no testimony on this subject.
9.
Licensing Activities
- a. 'SALP Analysis "The Licensee is rated Category 2 in this area. 'Early responses during the evaluation period were lacking in respcnsiveness, hc-ever, the more recent responses tend to be substantive and'of acceptable quality."
b.
Prior Testimony Mr'Keppler did not testify on this subject 10.
Fire Protection a.
-SALP Analysis "The Licensee is rated Category 1 in this area. Management attention has resulted in a high level of performance in th'is area."
b.
Prior Testimony There was no testimony on this subject.
11.
Preservice Inspection a.
SALP Analysis The Licensee is rated Category 2 in this area.
The Licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified."
b.
Prior Testimony There was no testimony on this subject.
12.
Design Control and Design Changes a.
SALP Analysis The report notes four_ design control related noncompliances identified by NRC inspections and~five licensee-controllable Constr9etion
' Deficiency Reports indicating a lack of quality assurance i,n design control during the evaluation period.
The report concludes:
l The licensee is rated Category 3 in this area.
The amount of re-engineering that has transpired in electrical, civil and piping areas and the specific design control weaknesses discussed in rp0582-2030a173 i
Attachi.ent 2
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2-6 Soils and Foundatiens, Piping Systems and Supports and Electrical Power Supply and Distribution indicate significant weaknesses in
-overall design control.
b.
Prior Testimony Mr Keppler did not consider the prog}yms identified in the piping system to be a significant concern.--
He also testified that noncompliances identified by NRC inspections in the soils area, although o{gyoncern, did not contravene his judgment of reasonable assurance.--
Another NRC Staff witness, Mr Gilray, confirmed that the two soils noncompliances referenced here by the SALP Report were
-notsubstantiveanddidngg',bringtheadequacyofConsumersPowers precedures into question.2-The May 1961 KRC adequacyoftheelectricalprogrematMidland.3gpspectior.affirmedthe Mr Keppler did identify design control as a significant quality related problem.3??
13.
Reporting Recuirements and Corrective Action a.
SALP Analysis The report notes that Consumers Power contested several apparent items of noncompliance during the evaluation period, and concludes:
The Licensee is rated Category 3 in this area.
The licensee i
responses to enforcement items and internal audit findings are often delayed requiring repeated submittal to obtain acceptable resolutions.
b.
Prior Testimony Mr Keppler testified that Consumers Power had responded to all items l
of noncompliance identified in NRC inspection reports. He noted that Consumers Power agrees with some such items and disagrees with others.
Mr Keppler stated that the fact that Consumers Power does not agree with an-apparent item of noncompliance is not a sign of poor management attitude.
If the'e is a valid reason to disagree with the r
item, he added, then they should disagree with it.
This is a nor partofthegiveandtakebetweentheNRCStaffandthelicensee.ga) 1/
Keppler, Tr 1884-47, 1981-77, 1981-83, 1996-2002, 2004-09, 2076-84.
2/
Keppler, Tr 1973-76.
3/
. Keppler, Tr 1935-36, 1964-66, and prepared testimony at p 4, following Tr 1864.
4/
Keppler, prepared testimony at pp 4-7, following Tr 1864.
5/
Keppler, Tr 2078-79.
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NRC Staff Exhibit No 1; Keppler, Tr.
7/
Keppler, Tr 1973.
8/
Keppler, Tr 1935-36, 1964-66 and prepared testimony at p 4, following-Tr 1864.
9/
NRC Staff Exhibit No I (NRC Staff Inspection Report No 81-12); Staff Exhibit No 3 (NRC Inspection Report No 81-09), Gallagher, prepared l
testimony, Attachment No 3, (NRC Inspection Report No 80-32/80-33),
following Tr. 1754.
10/
Keppler, Tr. 1935-36, 1964, 66 1887, 1942, 2002-09, 2013-2017 and prepared testimony at pp 4-5, 7 9, following Tr 1864.
11/
Keppler, Tr 1913-14,-1977, 1982-83, 2083.
l 12/
Keppler, prepared testimony at p 8, following Tr 1864.
i 13/
Keppler, Tr 2004-09, 2017, 1942.
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Keppler, Tr 2006-09.
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Id-16/
Id.
17/
Id, prepared testimony, Attachment No 2, at p 5, following Tr 1864 18/
Id, prepared testimony at p 8, following Tr 1864.
19/
Id., at p 4.
20/
Keppler, Tr 2076-78, and prepared testimony at p 7, following Tr 1864.
21/
Id, prepared testimony, Attachment No 2, at p 21, following Tr 1864 22/
'Id, at p 11-12.
23/
Id, prepared testimony at p 8, following Tr 1864.
24/
Id, prepared testimony, Attachment No 2 at p 12, following Tr 1864.
25/
Id 26/
Id 27/
See discussion supra under " Piping Systems and Supports."
28/
See discussion supra under " Soils and youndations."
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Gilray, Tr 3742-43 (testifying regarding the soils noncompliances identified in NE Inspection Reports No 80-32 and 80-33) -
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30/
See discussion supra under " Electrical Power Supply and Distribution."
-:E/
Keppler, prepared testimony at p 4, following Tr 1864.
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Keppler, Tr 2083-84 i
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.o Attcchment 3 3-1 ANALYSIS OF CURRENT AND F171TRE QUALITY ACTIVITIES WITH REGARD TO REMEDIAL SOILS WORK At the April 26, 1982 SALP meeting Region Administrator, Mr J G Keppler, expressed concern that his staff had informally characterized the ongoing soils and foundation work as only minimally acceptable. Mr Keppler asked CP Co's management to comment on its impression of this characterization and to provide its suggestion as to how this assessment could be improved.
The following consists of a brief analysis of what Consumers Power perceives to be the basis for this informal characterization and a description of some of the current organizational and programmatic features of the soils activities that lead us to conclude that prospects are excellent for the satisfactory execution of the remaining soils and foundation work.
The soils-related activities at the Midland job site are curre'ntly at a relatively low level pending completion of the NRC staff's technical review and release, by the NRC, of the major portion of the remedial work still to be undertaken.
The work that has been done thus far in 1982 is concentrated in two areas. First, a significant number of wells have been drilled at the site, as part of the plant devatoring systems, as part of the freeze wall associated with the auxiliary building underpinning activity and to support the site drawdown tests.
Second, the major contractor for the auxiliary building underpinning work was mobilized; the initial work on the access shaft was completed; and, in parallel the detailed underpinning construction planning and continuing technical review with the NRC staff of subsequent work was carried out.
Very little work in the other remedial soils areas has been accomplished during this period.
In responding to Mr Keppler's comments at the SALP meeting, we believe that the basis for the staff's informal negative comments regarding the current soils quality assurance activities can be traced to one specific area of concern and one more broadly-based general concern. A discussion of each of these follows.
A specific area of work which may have been of concern to the staff, and one of immediate concern to Consumers, relates to the controls on the drilling and excavation activities that have been recently carried out.
Because the number of NCR's that had been written in this specific area and the severity of the most recent occurrence (drilling into an electrical duct bank), the Company concluded that even with the formal controls that were previously in place, additional controls were required. As a result on April 28, the Company issued a stop work on all drilling.
(This Consumers Power stop work direction preceded the ASLB Order of April 30, 1982.) As of May 12, the stop work order had not been removed, nor will it be until a new detailed drilling and excavation control procedure has been fully reviewed and accepted by Conrumers Power Company.
While there had been other corrective action taken prior to the CP Co stop work order, the Company is confident that the comprehensive revisions to the prior control procedures on drilling and excavation will preclude errors of the type recently experienced, and will assure that future rp0582-0091a100
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Attcche:nt 3 3-2 0
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j drilling and excavating work will be carried out in a satisfactory and controlled manner.
The general and considerably more significant area of inferred NRC concern can only be identified as the lack of timely agreement between the Ceepany and the NRC on the specific quality assurance coverage requirements to be imposed on e-the remedial soils work, particularly those to be imposed on the underpinning work.
The lack of timely resolution of this issue, the apparent 7
misunderstanding regarding the Company's commitments, and the contentious atmosphere at the March 10, 1982 seating on this subject and at the subsequent inspection undoubtedly contributed to the negative rating informally expressed by the staff.
When the auxiliary building underpinning work started with the first partial j
NRC release for construction of the vertical access shaft, CP Co presented a special quality assurance plan encompassing, in our opinion, appropriate portions of the underpinning work. This plan was initially presented to the.
staff at a meeting in Region III headquarters on January 12, 1982 and I
documented in a letter dated January 7, 1982. While the initial staff i
response to the plan appeared to be favorable, no official NRC conclusion was i
expressed. It became evident during the time between January and early March that at least one individual within the NRC staff believed that an extensive
?
}
nodification of the program coverage under the QA plan, MPQp-1, should be L
required. This preference for expanded NRC requirements became an NRC staff j
working level position, formally expressed to the Company at the meeting on
[
i March 10, 1982. As a result of that meeting, the NRC Region III inspector apparently concluded that Consumers had committed to fully accepting the NRC Staff position that essentially all to go underpinning work should be Q-i listed, unless exceptions are agreed upon. The NRC's meeting minutes reflect i
no such commitment. In fact, no commitment was made. This sisunderstanding, and others arising out of tollow-up discussions with the staff, has apparently affected Region III's feelings toward our soils quality assurance program and I
personnel. It is, therefore, not surprising that the NRC Region III staff 1
considers the quality assurance activities in the soils and foundation area to i
}
be in need of improvement based on its recent experience.
(It should also be
}
noted that the NRC SALP Board held its second and final meeting on March 23, j
1982.) The Company also agrees that it is extremely difficult to avoid
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1 regulatory difficulties unless both parties have a common understanding and i
i agreement as to the scope of applicable requirements. The major issue with l
regard to QA program coverage was resolved at the management level meeting L
i held on March 30, 1942 in Glen Ellyn and documented by the April 5, 1982 1etter of J W Cook to J G Keppler, in which the Company agreed to "Q" list essentially all of the to go underpinning work. However, the staff has still f
j not formally acknowledged its concurrence with that letter. This concurrence
(
i would be of significant assistance in documenting the conclusion of the staff's review of progran requirements and permitting the redirection of i
resources from program definition to successful program execution.
l i
Resolution of the concerne noted above will make a significant contribution to l
the rossining soils work.
In addition, the following considerations should provide added confidence that eacellent results will be obtained in the j.
remaining soils construction activities.
1 f
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Attcche:nt 3 3-3 1
Dedication of a high quality professional staff to the underpinning and other soils work is of paramount importance to its successful completion. Because i
5 of the complexity and importance of the underpinning work as the dominant factor in the soils remedial program, a mini project of dedicated groups has been set up to focus attention on the soils activities, with particular emphasis on the underpinning. The technical qualifications of the individuals staffing these activities emphasize previous related experience. At the site, specific underpinning groups have been formed within Bechtel construction, Bechtel quality control and MPQAD, all staffed with individuals having significant applicable technical experience and academic credentials. Both l
i Bechtel resident engineering and Bechtel engineering in Ann Arbor have dedicated remedial soils groups. The onsite resident engineering office will have four geotechnical engineers and at least two structural engineers j
dedicat'ed to supporting the field activities. Consumers Power Company home-office soils' activities are currently staffed with two experienced geotechnical engineers and several experienced structural engineers who have j
been active in the design reviews and prior licensing evaluations and who will f
continue to follow the soils remedial work throughout the duration of the construction. The overall Consumers Power Company project management of soils i
is also organized as a mini project, and the senior Consumers Power Company-individual has had significant nuclear power plant experience at the project manager level.
h In addition to the on-staff individuals for Consumers Power Company, Bechtel and the major subcontractors, significant consulting resources are also integrated into the soils work. The design consulting fire for the auxiliary building underpinning has a staff een onsite to coordinate with his home.
]
office personnel. All the major consultants will be asked to periodically review the job progress as the underpinning work proceeds.
To assist some of the technical specialists in fully understanding all of the
~
t quality requirements on the job, some additions to the staff are also planned.
l 1
The Bechtel underpinning construction group leader, who oversees and interacts j
with the underpinning subcontractors, will have a quality consultant on his j
staff to assist his in any and all quality-related matters.
It is also anticipated that the underpinning quality control organization will be l
augmented to enhance its breadth of leadership.
i Ve believe that the NRC themselves can significantly assist in the successful completion of the underpinning and other soils remedial activities by i
expanding the presence of their lead inspector on the site as the work progresses. Specific steps to facilitate this NRC interaction were agreed upon, as documented in the April 5, 1982 letter referenced above, and
)
complemented by day-to-day working agreements.
i A second area which should significantly assist in the successful completion of the remedial soils work, particularly the underpinning activities, is the f
degre's of design completion prior to the work entering the major construction l
phase. Because of the extent and thoroughness of the NRC staff review, there
}
is a more complete design for the underpinning activities than is normally in place for other construction activities. Essential completion of the calculations for the underpinning work before the major construction phase j
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3-4 begins will minimize the kind of major design changes that can occur in nuclear plant structural design process because of calculation revisions.
There will, of course, be design changes as the work progresses, but the degree of calculation completeness reached prior to initial drawing release will significantly contribute to the stability and success of the construction process.
In addition to the degree of compi~eteness in the underpinning design activity, the interface review called for by the quality assurance plan for the underpinning activity, MPQP-1, is also substantial. These reviews will also contribute to both the validity of the design and the general understanding of design requirements and quality attributes by all persons participating in the underpinning activities.
In addition, MPQP-1 directly inserted quality assurance (and through quality assurance, quality control) comments into the design review cycle, a significant requirement above and beyond the quality assurance program for the balance of the plant.
The number of procedural controls that have been or are being instituted for this work should also engender confidence that the critical underpinning activities will be satisfactorily controlled. Judging from the work to date, there will be more than 50 specific work procedures developed for the underpinning work.
MPQP-1 calls for integration of inspection held points directly in these construction work procedures.
As a result o'f these steps, the procedural controls for the underpinning work will be more extensive than those for any other activities, with the possible exception of NSSS primary loop activities, covered by the QA program for the balance of the project. The extent of the construction procedures automatically increases the scope of the training activities and of the inspection plans which are developed based on the specific work procedures.
Finally, as a result of the extensive discussions with the NRC staff regarding the coverage of the "Q" program, MPQP-1 is being applied to essentially all of the underpinning work still to be done.
While this application may or may not be completely consistent with a strict definition of what is " safety-related,"
it should lend added assurance that the work in total, and the safety-related work in particular, will be carried out successfully.
In light of the foregoing, it is hoped that the Region III management can gain an appreciation of Consumers Power Company's perception of recent events and that both the Region III management and staff can develop added confidence that the to go soils work, particularly the extensive underpinning activities, i
can and will be carried out up to the expectations of both the applicant and the NRC.
rp0582-0091a100
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Vice Prestlant - Profacts. Engineenng and Constmstion oeneral Offices: 1945 West Pernais Road, Jocheon, MI 40201 * (517) 788 0453 PR I NC I P,'.L <;7_uc;-
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Mr J G Keppler, Regional Adrainistrator
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US Nuclear Regulatory Commission
.'!.~T~~.'J; 7".-l Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT REVISED RESPONSE TO DRAFT SALP REPORT FILE 0.6.1 SERIAL 17485 i
Attached is Consumers Power Company's revised response to the NRC's Preliminary SALP Report for the Midland Nuclear Plant for the period July 1, 1980 to June 30, 1981. To review the sequence of events related to this response: a Draft SALP Report was initially reviewed with the NRC during a meeting in Jackson, Michigan on April 26, 1982; the Company filed comments on the Draft Report on May 17, 1982; a meeting to discuss these comments was held in Jackson on June 21, 1982; and a meeting of our staffs took place on August 5,1982 to discuss and reconcile differences arising out of the Draft Report and the Company's May 17 comments.
During the August 5 meeting, Consumers Power indicated that it would revise Attschment 1 of its May 17, 1982 response. The attached revision, therefore, replaces Attachment 1 to our May 17 response. Attachments 2 and 3 (as corrected in our May 21, 1982 letter) to my May 17 letter are unchanged but are attached to this response for completeness.
In our revised response we have been able to take advantage of the June 21 and August 5 discussions with the Region regarding the Draft Report and our response, and additionally have had the opportunity to review again, in light of the meetings with the Region, the Report and our tesponse in much more detail with our own personnel. As a result of all of these efforts, I believe that our comments now reflect a more full consideration and better understanding of the points raised by NFC Staff members.
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oc0882-2422a112-100 /
(hhh SEP 2 31982
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Distribution: Keppler (3 copies)
CC: Atomic Safety & Licensing Appeal Board CBechhoefer, ASLB MfCherry,Esq FPCowan, ASLB RJCook, Midland Resident Inspector SGadler JHarbour, ASLB DSHood RBLandsman 14Diarshall BStamiris MSinclair l
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1 CONSUMERS POWER COMPANT RESPONSE TO THE DRAFT SALP REPORT FOR THE MIDLAND NUCLEAR PLANT
Reference:
1.
NRC letter; J A Hind to J W Cook; adated April 20, 1982; with Enclosures I snd 2.
2.
NRC letter: J G Keppler to J W Cook; dated July 19, 1982.
This attachment is in three parts. The first part provides general comments regarding the SALP appraisal and SALP process as a whole. The second part provides our detailed response to Enclosure 1 of the reference, the Significant SALP Report Findings. The third part provides a detailed response to Enclosure 2 of the reference, the Preliminary SALP Report, dated March, 1982, covering the assessment period of July 1,1980 to June 30, 1981.
Part 1 - General Comments The Company views the SALP process as a learning experience and believes that this SALP Report and the subsequent reviews and discussions held between the Company and the NRC Staff have enhanced communication between our organizations. The principal purposes of the Response to this SALP Report are as follows:
1.
Providing clarifications of fact 2.
Stating subsequent corrective actions regarding specific findings.
miO882-2420a141-100
3
- c 2
- +.
Part 2 - Response to Enclosure 1. Simnificant SALP Report Findinas,
Aa-(sENERAL OBSERVATIONS
-No Comment.
B.
Pipina Systems and Supports 1.
The Preliminary SALP Report item relating to the unavailability of Committed' Preliminary Design Calculations (CPDCs) to support the drawings' for small bore piping was, in our opinion, the most significant quality deficiency that occurred during this SALP period.
Upon discovery. of the unavailability of the CPDCs, we stopped the design work, began immediate corrective action, and did not resume the work until both the Company and the NRC Staff were assured that the process had been corrected. No pipe segments required rework as a result of this deficiency.
C.
Electrical Power Sudply and Distribution The Preliminary Report notes items of noncompliance and Region III's advice as to QA/QC staffing requirements. It also notes an increase in f
the rigor and' frequency of overview inspections in this area. The Report also recounts other steps (performance of a detailed audit and evaluations of the adequacy of QC coverage) taken to improve the QA/QC r
controls. While the Company agrees that items of noncompliance did
[
, occur, we believe that electrical QA/QC Staffing during the SALP period r
was adequate for the scope of work involved.
miO882-2420a141-100 O
+
3
-~
D.
Soils and Foundations As indicated in the cover letter to this Response, our detailed comments in this area (contained in Part 3, Paragraphs D & E below) now reflect a better understanding of the Inspectors' views as expressed in the Draft Salp Report. Attachment 3 to this response addresses an increased QA/QC scope and outlines certain steps taken to achieve an enhanced QA/QO program. For the SALP period, we believe the QA/QC staff was adequate for the scope of work.
t I
miO882-2420a141-100
g Part 3 - Response to Enclosure 2. Preliminary SALP Report A.
Section I, Introduction No Comment.
B.
Section II. Criteria No Comment.
C.
Section III, Summary of Results l
l 1.
The Company is concerned about the Category 3 ratings and although the functions receiving a rating in this category are " acceptable,"
i the Company is committed to achieve improvements.
j D.
Section IV.1, Performance Analysis of Quality Assurance V
l 1.
Seven of the eight itees identified frca the May 1981 inspection and' referenced in this section of the Preliminary Report are specifically noted elsewhere in the report under the Soils. Piping and Supports, l
l and Electrical Sections. Therefore, we will address these l
l noncompliances apecifically in the other sections.
l l
2.
The eighth item from the May 1981 inspection dealt with the correction of adverse quality trends. The procedure in question was revised to provide more timely identification of the " root cause" and closeout or verifications regarding quality trends.
3.
This section of the Preliminary SALP Report also refers to a finding of the NRC's Insp6ction Report 81-12, conducted May 18-22, 1981. The siO882-2420a141-100 e
5
~
Report states that "the licensee failed to fully evaluate the technical capability of the principal supplier of services for soil boring activities."
The Company's quality assurance procedures require a two-faceted evaluation of suppliers. Both the supplier's quality assurance ability and its technical ability to perform the job must be evaluated. Both of these evaluations must be documented before the contractor is allowed to begin work.
The evaluation of the supplier in question (Woodward Clyde, W/C) was carried out by MPQAD for quality assurance ability and by Design Production for technical ability. MPQAD dovimented W/C's quality assurance competence prior to the start of W/C's work. Before allowing W/C to proceed, MPQAD also phoned Design Production to ensure that W/C's competence from a technical standpoint was approved. Design Production documented, after the fact, the technical review that had taken place prior to start of drilling activities by W/C. W/C is a nationally-known soils testing firm.
The Company does not believe that W/C's technical credentials are in dispute.
The fact remains, however, that the Company failed to document in a timely fashion its technical (as opposed to QA) evaluation of W/C's ability to perform, as required by applicable procedures. The Company concedes this failure.
5.
Also, this same paragraph of the Preliminary SALP Report states:
miO882-2420a141-100
6 "The NRC identified 15 deficiencies in the principal supplier's quality assurance program manual indicating that the licensee had not adequately reviewed and approved the procedures prior to preparation of drilling activities."
i The reference ig the Preliminary SALP Report to the "15 deficiencies" does not reflect a citation for a condition of noncompliance - only a consent on a draft set of construction procedures to be used by the Company's drilling contractor. Nevertheless, it was important to correct the items before permitting W/C to begin work. This was done.
The itses of concern were discussed at a meeting between the Company and the NRC Inspector on March 26, 1981. At that time the l
construction procedures of W/C were still in the review cycle and had not yet been approved by the Company, a necessary step before the inception of work. W/C had recently revised its construciton procedures, and when the NRC was given a draf t copy of those procedures before the meeting on the 26th, HPQAD had not completed l
l its final review or incorporated its final comments.
The involved NRC Inspector stated that he went to the meeting on the i
26th with a list of items which then were called to the attention of MPQAD. The responsible MPQAD person indicates that a few, but not I
all, of the itees had already been observed by MPOAD and these items were intended to be corrected or clarified before approving the procedures.
c e10842 2420a141 100 I
l t.,m
7 E.
Section IV.2. Performance Analysis of Soils and Foundations 1.
The Preliminary SALP Report states:
"There was a failure to initiate audit corrective action concerning the rereview of the FSAR and references to determine if design documents had modified the FSAR and if so that changes had been made to the FSAR."
The Company's response to this item is extensively documented in the response to NRC Inspection Reports and in the Soils Hearing Record.
2.
The Preliminary SALP Report notes:
"Three examples of failure to translate applicable regulatory requirements and design criteria into design documents."
a.
The first example given is:
" Failure to maintain a coordination log of Sp6cification Change Notices (SCNs)."
There are and were three separate coordination logs in the civil discipline. These loss are maintained by three different people.
The Drafting Supervisor maintains the coordination log for drawings and drawing change notices. The remaining documents.
Including SCNs, are covered by two other coordination loss which are maintained by Discipline Aides.
miO882 2420a141 100
e 8
.T :
~The factual basis for this item of non compliance was extensively
~
litigated during the soils hearing. Certain corrective actions, including procedural' modifications and a review of civil Q specifications to insure appropriate design coordinations, should resolve NRC concerns in this area.
b.
The second example given is:
" Failure to correctly translate Specification Change Notice No SCN-9004 as a requirement into Revision 20 of.
Specification C-208."
This item arose as a result of a difference in wording between an i
SCN and the specification,'after incorporation of the SCN into the specification, relative to the Geotechnical Engineer's i
responsibilities for establishing the laboratory compaction test frequency. The SCN was issued to desc~ ribe the responsibilities
]
of the newly assigned on-site Geotechnical Engineer. The specification after incorporation of the SCN used words different from and more general than the SCN to describe the Geotechnical Engineer's responsibility for the establishment of the frequency for laboratory compaction testing.
In our view, the intent.of both the SCN and the specification was the same, although the language difference could reasonably have led to a different conclusion. The specification wording was subsequently changed to agree exactly with'the SCN.
L
~nse third example given in the Preliminary SALP Report is:
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9
" Failure of Engineering Department Project Instruction No I
EDPI 4.25.1, Revision 8 to establish adequate measures for design interface requirement."
The EDPI was revised after the inspection to state that it is the responsibility of the originator of a design change to coordinate the change with all groups which are affected by, or involved ~
with, the revised portion of the document, regardless of whether the change is technical or editorial. This procedural change was made to eliminate the previous option of the Group Supervisor to waive the need for the coordination or interface when, in his judgment, it was unnecessary.
In the Company's opinion, adequate interface review procedures existed prior to the procedural change although the change added an additional level of control.
3.
The Preliminary SALP Report references the following item:
" Failure to establish test procedures for soils work activities."
This item of noncompliance arose out of three conditions reported as noncomplying during NRC Inspection 81-01 (January 7-9, 1981). One of the three items dealt with the' absence of specific instructions indicating the depth at which field density samples should be taken.
A second item involved the lack of procedures specifying how samples should be taken for relative density measurements.
A third item dealt with the failure to establish procedures to correlate maximum miOB82-2420a141-100
I 10 1
amplitude settings on a soil testing device, a rheostat _ setting, and maximum density of the soil sample being tested.
At the time of the inspection, the civil specifiestions under which soils placement and compaction were being performed referenced sections of the ASTM testing standards. For example, a civil specification referenced ASTM D 2049, which establishes a step by
~
step procedure for determining relative density of cohesionless soils. According to the NRC Inspector, the statement in the SALP Report alleging a " failure to establish test procedures" referred to the lack of any procedures above and beyond the ASTM standard methods.
Further discussion during the August 5, 1982 meeting established that the NRC will accept references to high level standards, such as the ASTM, as meeting procedural requirements, providing a detailed review of the standard is carried out.
In this instance, the NRC Inspector indicated that the ASTM standards were not alone sufficient because of the three particular deficiencies recited above.
As corrective action, the Company complied with the NRC's request by establishing an additional particular procedure covering soils
. testing, including the first item in'the Inspection Report, and by revising the specification for the second item in the Report. The Company believes that the addition of these procedures has eliminated the concern in these two areas. Regarding the third item, the amplitude-density correlation, tests were carried out confirming the correlation. Therefore, in the Company's opinion, this issue could miO882-2420a141-100
11 be categorized largely as a difference of opinion between experts as to procedural details necessary to supplement the ASTM standard method being used by this soil testing consultant.
In the final analysis, the Company responded fully to the NRC concern.
4.
The Preliminary SALP Report also indicates a:
" Failure to supply a qualified on-site Geotechnical Engineer."
Meeting previous commitments, the Company assigned a Geotechnical Engineer to be on site during soil placement activities. The resumes of the assigned engineer ("the first engineer") and of cnother applicant to the position ("the second engineer") were reviewed by a cognizant NRC Inspector during an inspection held in December 1980.
According to the recollection of an involved Company employee, the NRC Inspector concurred in the Company's decision to replace the first engineer with the second, who had greater practical experience than the first but who lacked an engineering degree. At a later date, another NRC Inspector reviewed the engineers' credentials. He felt that because the second engineer lacked a degree, the Company had failed to mcet its commitment. The Company was cited with a deviation for failure to provide a degreed Geotechnical engineer for the job. Thereafter, the first engineer was reassigned to the on-site position. Region III concurred with this assignment.
From discussions during the August 5, 1982 review meeting it appears that disagreement regarding this issue arose out of a difference of recollection of the facts and possibly a misunderstanding by the miO882-2420a141-100 u
y
+7 7
-9
--w
. l 12 Company or the Inspectors..As noted, the Company immedi,ately took the necessary steps to resolve the problem by assigning a degreed engineer to the Midland site.
5.
The Preliminary Report also states:
"It was noted in NRC Inspection Reports No 50-329/81-12; 50-330/81-12 that a sufficient number of qualified personnel were not available for the complex nature of the remedial soils work. This had previously been identified in NRC Inspection Reports No 50-329/81-01; 50-330/81-01, referenced previously as a deviation to a commitment."
Inspection Reports No 50-329/81-01; 50-330/81-01 deal with the deviation relative to the on-site Geotechnical Engineer. This was covered in Paragraph 4, immediately above.
NRC Inspection Reports No 50-329/81-12; 50-?30/81-12 indicated the NRC's advice to the effect that additional QA/QC personnel would be needed to accommodate the forthcoming remedial soils work. The statement in the Inspection Report did not reflect a citation for noncompliance. Staff additions were in fact made to accommodate this future work in the next SALP period.
6.
Finally, another item (evaluation of supplier technical capability) referenced in this section of the Report is duplicated in the Quality Assurance Section of the Report. Please refer to Part 3, Paragraph D.3, above.
miO882-2420a141-100 g
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13 F..Section IV.3, Performance Analysis of Containment and Other Safety-Related Structures No Comment.
G.
Section IV.4, Performance Analysis of Piping Systems and Supports 1.
Item a(1) of this section of the Preliminary SALP Report states that:
"Bechtel Purchase Order did not specify applicable codes for purchase of 60,000 pounds of E-7018 electrode."
The original statement of the item, from NRC Inspection Reports No 329/80-20-01 & 330/80-21-01 was as follows:
'Bechtel Corporation Welding Standard VFMC-1, Revision 8, dated January 4,1971, ' Welding Filler Material Control Procedure Specification,' Paragraph 2.1, states, in part, that '.
. welding filler material ordering information shall include the appropriate requirements of the job engineering specification, the applicable Code and this procedure specification.
' Contrary to the above, on July 10, 1980, the (NRC)
Inspector established (that) Bechtel Purchase Order No 7220-F-5780, dated November 2, 1973, for 60,000 pounds of E-7018 electrodes did not specify the applicable Code.'"
l The Company has reviewed certified material test reports and determined that results of tests were in accord with the appropriate miO882-2420a141-100
.._.,7
14 (ASME) Code specification, even though a documentation def.iciency
)
failed to relate this specification to the purchase order.
Consumers Power Company has performed an audit of the procurement documentation for weld filler materials procured from 1973 through 1980.
(This was reported to the NRC in the August 25, 1980 response.)
2.
Item a(2) in this section of the Preliminary Report indicates that an Authorized Nuclear Inspector's hold point was bypassed for the pressurizer surge piping.
This item was detected by the NRC Inspector on September 24, 1980.
By September 25, corrective action had been taken by the Company and verified by the NRC Inspector.
3.
Items a(3) and (4) indicate that large bore pipe restraints, supports and anchors were installed incorrectly and that QC Inspectors did not detect the incorrect installations. Testimody on this subject was presented during the soils hearing.
On the basis of the NRC's findings, the Company agreed to make an extensive sampling reinspection of hangers which were installed prior to 1981. The results have been made available to the NRC.
4.
Item a(5) in this section of the Preliminary SALP Report, dealing with the availability of Committed Preliminary Design Calculations for small bore pipe and piping suspension systems, was previously noted in another section of the Preliminary SALP Report (Functional miC682-2420a141-100 c,.
t
)
~
15 1
i Area - Piping System and Supports). Correspondingly, our response to this item was covered in Part 2, Paragraph B of this attachment.
5.
Item a(6) indicates:
" Failure to adequately control documents used in site,small bore piping design activities."
The original itam from NRC Inspection Report No 50-329/81-12 and 50-330/81-12 stated that:
"An outdated specification was maintained at the small bore piping design group work location and revised calculations i
were not marked ' superseded' in accordance with the procedural requirements-(our emphasis)."
As process corrective action, Bechtel conducted an in-house review to assure any other outdated specifications were identified and removed.
Other instances of outdated specifications were found during this.
audit. An audit conducted by MPQAD after this corrective action was taken found no more outdated specifications.
In addition, the calculations involved in the noncompliance were checked and found to be correct. Training was_ conducted of all personnel in this group.
A procedure was changed to require that the revision number of the P
specification on which the calculation is based be documented in the calculation package.
6.
Item a(7) indicates that Consumers Power Company audits did not:
i miO882-2420a141-100
j!
16
" Include a detailed review of system stress analysis and (did not) follow up on previously identified hanger calculation inconsistencies."
The Company did not audit for the availability and correctness of the Committed Preliminary Design Calculations as discussed in Part 2, Paragraph B, above. The audits that were made previously in this area concentrated on the completed calculations, rather than the preliminary calculations. The applicable audit checklist has since been adjusted to reflect a requirement relative to preliminary calculations.
H.
Section IV.5, Performance Analysis of Safety-Related Components 1.
As a result of the two original items noted in. the Preliminary SALP Report, Consumers Power Company issued a formal Stop Work Order to Babcock & Wilcox and a letter to the NRC stating that the stop work would remain in effect until the corrective actions had been completed and reviewed by the NRC. Corrective actions were taken, as follows: The installation procedure for this activity was revised to clarify the method of installation and to specify the required dimensional checks.
Involved B&W personnel, including inspectors, received indoctrination and training to stregthen their knowledge in this area. The Consumers Power Company overview inspection plan for this activity was revised.
1 1
I.
Section IV.6, Performance Analysis of Support Systems (HVAC) 1 l
1 1
i miO882-2420a141-100 I
J J
17 1.
The civil penalty was imposed for conditions which existed. prior to the assessment period in question.
2.
Corrective actions in regard to these items were undertaken by the Company as documented in previous correspondence with NRC Staff.
J.
Section IV.7, Performance Analvsis of Electrical Power Supply and Distribution 1.
Item a(1) in this section of the Preliminary SALP Report indicates a failure to establish procedures for temporary support of cable.
The four damaged cables were repaired. The procedure was revised to require that coiled cables be properly supported and that the coil configuration does not exceed the minimum bend radius.
2.
Item a(2) in this section of the Report indicates that electrical contractors did not verify conformance to Paragraph 3.1 of Project
, Quality Control Instruction E-5.0.
The cable routing was rearranged to provide the required separation, whkchwasverifiedbyinspection. Electrical crafts and inspection personnel were formally reinstructed with regard to the separation requirements.
Installation and inspection aids were provided to craft personnel.
3.
Item a(3) indicates a:
" Failure to identify and control nonconforming components."
miO882-2420a141-100 1
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a.
3.<'
18-After a thorough review of the NRC Inspection Reports for this assessment period, we believe that this item refers to a condition noted in NRC Inspection Reports No 50-329/81-11; 50-330/81-11, as follows:
"On April 23, 1981, the (NRC) Inspectors identified 14 instances in which cable tray in the upper and lower cable spreading areas were not installed in accordance.with the separation requirements delineated in the Midland TSAR and which had not been-identified and controlled to prevent 1
inadvertent use or installation..."
e Because of a re-design of the cable spreading room late in 1979, the Company decided to change the design for cable separation devices.
Under the old design, barriers were required when cable otherwise-would not meet separation criteria. The new design would also use barriers, but made from different materials. Accordingly, provision for barriers under the old design was removed from cable drawings.
The designers also decided that the new barriers would be added to the design at a later date because the cable re-design had to be 1
completed before barrier design could begin.
In the meantime, cable-pulling and routing could continue. When the NRC conducted its T
inspection, the old barriers had been removed from the drawings, giving the appearance that the cables did not meet separation criteria and lacked necessary protective barriers.
In 1979, project quality t.ssurance issued an NCR documenting one instance of separation criteria not being met in the absence of j
miO882-2420a1412 00 1
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i 19 separation barriers. Subsequent project correspondence, issued in April 1980, documented the need for the addition of barriers in the design.
Recognizing that the old procedure could possibly lead to missed barriers, the Company upgraded Bechtel Quality Control Instruction QCI E-3.0 (following identification of the 14 nonconformances by the NRC) to require verification that barriers are properly installed after the relevant area is completed.
4.
Item a(4) indicates a:
" Failure to translate design criteria into drawings and specifications."
This inspection finding related to whether or' not the color coding of instrumentation process lines was required. Based on our reading of the applicable codes and standards, it was not.
However, we have responded to the NRC concern in this area by agreeing to identify the instrument process lines with a two digit alpha designator, and the specification has been changed accordingly.
5.
Item a(5) indicates a:
" Failure to identify during inspection that a nonconforming condition with regard to minimum installed cable bend radius existed."
The condition referred to was discovered during a walk through by Consumers Power Company and an NRC Inspector. A Consumers Power miO882-2420a141-100 r
20
^
Company Nonconformance Report was written to document the -condition for the single cable in question. In addition to physically correcting the condition, the Bechtel Quality Control Inspector who originally inspected the cable was given an 8-hour training program in all phaser of cable termination.
6.
Item a(6) indicates:
" Failure to take prompt corrective action with regard to the lack of approval of procedures for the rework of electrical raceways."
Bechtel Construction and Bechtel Quality Control developed and issued the necessary administrative guidelines and instructions.
7.
Item a(7) indicater:
" Failure to provide adequate storage conditions for (three iters)."
The atorage conditions for each of the items was immediately corrected. The Bechtel Maintenance Engineers were given additional training in accordance with the requirements of the field maintenance procedure. Consumers Power Company also performed a comprehensive audit to assure compliance with the fieId maintenance procedure.
8.
The Company believes that the quantity of electrical QC inspectors employed during the SALP period was sufficient for the scope of work.
K.
Section IV.8, Performance Analysis of Instrumentation and Control Systems miO882-2420a141-100 '
~
No' comment.
L.
Section IV.9, Performance Analysis of Licensing Activities No Comment.
M.
No Comment.
N.
Section IV.11. Performance Analysis of Preservice Inspection No Comment.
i 0.
Section IV.12, Performance Analysis of Design Control and De' ign Changes s
1.
Items a(1)(a) and (b) given in this section of the Preliminary SALP Report were previously noted in Section IV.2.
As such', our specific response to these items is given in Part 3, Paragraphs E.1 and E.2 i
and will not be repeated here.
4 2.
Item a(2) in this section of the Report was previously noted in Section IV.4.
As such, our specific response is provided in Part 2, Paragraph B and will not be repeated here.
3.
Item a(3) in this section of the Report was previously noted in Section IV.7 of the Report. As such, our specific response is given in Part 3, Paragraph J.4 and will not be repeated here.
4.
The five 10CFR50.55(e) items listed in this section of the t
Preliminary Report relate to designs which were completed before the start of the SALP period in question. Our identification of these miO882-2420a141-100
22 items during this assessment period indicates continuing design reviews.
'5.
We also note that there were five inspections of Bachtel Power Corporation, Ann Arbor Division, the principal engineering firm for the Midland Plant, conducted during the SALP period by the Vendor Inspection Branch of Region IV.
TVo of these occurred during the SALP period. The inspections covered a wide variety of design activities. For example, the October 7-10, 1980 inspection encompassed design verification, design interface, and design inspection activities. The March 31-April 3, 1981 inspection covered computer program control, technical personnel background verification, design change control and design correct'ive action.
The two specifically referenced inspections were conducted during the SALP appraisal period.
In all five inspections, there were a tetal of 6 nonconforming items identified, all of a relatively minor nature (nonconformances or deviations rather than violations).
In two of the inspections no items of noncompliance were found.
In our view, these inspections are indicative of a high degree of compliance within design segments of the Midland Project.
(The five inspection reports are documented in letters dated April 16, 1981; October 14, 1981; November 5, 1980; June 15, 1979; and January 19, 1979, to the Bechtel Power Corporation, Ann Arbor Division, from Uldis Potapors, Chief Vendor Inspection Branch.)
6.
We believe that design control, although difficult, is one of the most important aspects of nuclear power plant projects. Design miO882-2420a141-100 1
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- 23.
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Attachment'l i
i
.P control has:been complex for the Midland Project mainly be.cause of l
the duration of the project and the. incorporation of a multitude of new regulatory requirements into the design as it progressed. Ne recognize our obligation to monitor and improve our own efforts.in this area and we continue to institute our own internal programs to increase our confidence'in the quality of the overall design effort.
P.
~ Section IV.13 Performance Appraisal of Reporting Requirements and Corrective Action j
i 1.
In this'section of'the Report, it is stated that:
t i
i.
"The licensee failed to make a timely determination for the j
r need to submit a 10CFR50.55(e) Report to the NRC based on a
}
i t
j 10CFR Part 21 Report from TransAmerica LeLaval, Inc."
i
+
f In this specific case, the DeLaval Part 21-Report was sent to Bechtel
- t
- and was misrouted, such that Consumers Power Company and the i
j' appropriate Bechtel personnel were not aware of the Part 21 Report on I
- a timely basis.
In the final analysis, the condition was determined not to be 50.55(e) reportable, f
I Corrective actions were taken. They include issuing letters to suppliers to advise them of the person to whom Part 21 Reports should 4
be submitted, conducting training sessions at the site for key a
j personnel to assure that sisdirected Part 21 Reports get correctly.
redirected, and issuing periodic memos reiterating the information offered in the training session.
miO882-2420al41-100 5
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L 2.
This section of the Preliminary SALP Report also statast
" Expeditious resolution of noncompliances is often delayed by inadequate licensee responses. The licensee has a tendency to spend too much time trying to justify why a finding is not a noncompliance rather than devoting the time to correcting the basic problem. Nine of 22 items of noncompliance were contested (excluding HVAC system noncompliances). Two of the contested noncompliances were retracted, but time and effort were lost in timely resolutions. Similar attitudes and responses have been observed regarding Company audit findings. This attitude is
~
reflective of the licensee corrective action system and L
becomes a detriment to quality."
The NRC Staff has, on repeated occasions, endorsed the appeal process as a legitimate method for handling differences of opinion. It is our policy to obtain a complete, clear understanding of the basis for l
noncompliance and to appeal only on substantive issues upon which the Company firmly believes it has a good position on the merits.
Q.
Section V.A. Noncompliance Data No Comment.
R.
Section V.B. Licensee Report Date r
No comment.
miO882-2420al41-100
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25 S.
Section V.C, Licensee Activities No comment.
T.
Section V.D, Inspection Activities No Comment U.
Section V.E, Investigations and A11eastions Review No Comment.
V.
Section V.F, Escalated Enforcement Actions 1.
The civil penalty was imposeri for conditions which existed prior to the assessment period corresponding to this SALP Report although the investigation was completed during the SALP period.
W.
Section V.G, Management Conferences No Comment miO882-2420a141-100
i 2-1 COMPARISON OF TESTIMONY OF JAMES G KEPPLER BEFORE THE ASLB ON JULY 13-14, 1981 WITH FINDINGS IN THE DRAFT SALP REPORT Introduction On July 13-14, 1981, Mr James G Keppler, the Director of the Region III Office of Inspection and Enforcement, testified that the NRC has reasonable assurance that quality assurance:and quality control programs at Midland will be
-appropriately implemented with respect to future soils construction activity, including. remedial actions'.
In March 1982, Region III issued its Preliminary SALP. Report on_the. Midland Plant. Nothing in the SALP Report contravenes Mr Keppler's testimony regarding ' reasonable assurance. All of the information
-contained in the SALP Report was known to Mr Keppler at the time he testified.
1.
Quality Assurance a.
SALP Analysis The report notes.the creation of the MPQAD and Consumers Power's-assumption of responsibility'for onsite quality control and quality assurance functions for the installation of the HVAC systems.
It also lists the findings of NRC Inspection Report No 81-12.
The report concludes:
The licensee is rated Category 2 in his overall quality assurance capab.lity. Notwithstanding weaknesses identified in specific areas, the licensee has been responsive in establishing an overall effective organization for the management of construction and implementation of quality assurance at the site, b.
Prior Testimony festifiedextensivelygygardingNRCInspectionNo81-12,1I Mr Kepple t
the MPQAD and the Zack matters.-
Mr Keppler initiated NRC Inspec MPQAD.gjon No 81-12 for the purpose of determining the efficacy of the Mr Keppler personally inspected the w inspectorsattheconclusionoftheinspection,gykoftheNRC participat draftingtheinspectionreport,andsignedthefinalreportgpinMr Keppler concurred in the report's conclusion that, although some problems were identified, the MPQAD atMidlandwereworkingquitewell.77ndthequalityassuranceprogram
' Mr Keppler also described the corrective actions Consumers Power had taken with regard to Zack, and c'oncludedthattheZagyproblemdidnotindicateabroaderbreakdown in quality assurance.-
rp0582-2030a173
'2-2 2.
Soils and Foundations a.
'SALP Analysis The SALP Reports lists the soils-related noncompliances and deviations identified in'NRC inspections of Midland during the SALP evaluation period (July 1 1980 to June 30, 1981). The report concludes that:
The licensee is rated Category 3 in this area. The enforcement history indicates that additional licensee attention is warranted, b.
Prior Testimony The evidence before the Licensing Board shows that Mr Keppler was thoroughly familiar with the 1980-81 enforcement history relating to soils issues when he made his judgment regarding reasonable. assurance at Midland. Mr Keppler was Regional Director of Region III during.
this period an signed all of the NRC inspection reports listed in the SALPanalysisgj problems identifed in these reports.ggpl about many of the soils He testified in de He explained that all of the soils problems identified in 1980-81 were~ carefully reviewed and reassessed, and all pertinent records covering summer.1980, to May 1981 were examined, in 1981.39rriving at the conclusion of reasonable assurance in May
- Mr Keppler specifically noted that the' history of soils work at Midland did not contravene his judgment of reasonable assurance. The' sails problems, he testified, "can be largely attributed to the failure to fully recognize the importance.of the application of quality assurance to soils work (but) the importance of quality assurance to soils work and to consequent remedial actions ytheMidlandsiteisnowfullyrecognized"by Consumers Power.
3.
Containment and Other Safety-Related Structures a.
SALP Analysis "The licensee is rated Category 2 in this area. The licensee's performance appears to be satisfactory; no significant strength nor weaknesses were identified."
b.
Prior Testimony Mr Keppler did not testify on this subject.
4.
Pipina Systems and Supports a.
SALP Analysis The Report lists seven items of noncompliance identified by NRC Staff inspections during the evaluation period. Based on five of these rp0582-2030a173
2-3 d
items, an Immediate Action Letter (IAL) was issued on May 22, 1981.
The report concludes:
The licensee is rated Category 3 in this area. The enforcement history is indicative of weaknesses in the implementation of the quality assurance program.
b.
Prior Testimony MrKepplertestifiedregardingthepjgyngproblemsidentifiedduring NRC Inspection No 81-12 in May 1981.--
He explained that problems withpipingsystemsareanindustrygyideconcernthatisreceiving considerable _ Region III attention.--
Problems are in this area at almost every nuclear site inspected.ggyng identified The NRC Staff inspector who identified the piping problems at Midland is at the incidentsatMidlandtobesignificant.j6pidnotconsiderthe forefront of knowledge in this area, an NRC Inspection No 81-12 confirmedthatthemethodologyofthedesign,installationandqualjjy control inspection of the piping and support system was acceptable.--
It was the unanimous view of the inspection team that the problems identified were isolated, and not indicative of weaknessesintheimplementationoftheprogram.gymajorprogrammatic 5.
Safety-Related Components a.
SALP Analysis The report lists the two items of noncompliance which culminated in Consumers Power's issuance of a letter of understanding on January 22, 1981. The report concludes:
The licensee is rated Category 2 in this area. The above enforcement was aimed at an isolated instance and may have been directly related to change in NSSS QC personnel changes. The licensee had in the past and since this episode maintained adequate QA control for the assembly of NSSS equipment.
b.
Prior Testimony No testimony was given on this subject.
6.
Support Systems a.
SALP Analysis The report notes the quality assurance deficiencies and the Civil
. Penalty of the previous SALP evaluation period.
It commends Consumers Power's " aggressive action" in taking over complete responsibility for quality assurance and quality control in HVAC installations; this action resulted in significant improvement in control over the installations and in correction of identified weaknesses. The report concludes:
rp0582-2030a173
'Atttchment 2 2-4
\\
The licensee is' rated Category 1 in this area. Management attention and involvement has been aggressive in accepting full
-QA/QC responsibility and supporting'this organization with an adequate number of skilled personnel.
b.
Prior Testimony -
Mr Keppler testified that the HVAC pr Jensproblemdidnotindicatea
' broad breakdown in quality assurance
- 7.
Electrical Power Supply and Distribution
- a. 'SALP Analysis The report listed seven noncompliances identified during the
' evaluation period and concluded:
4 The Licensee is rated Category 3 in-this area. The enforcement history indicates a lack of management attention and involvement.
This is evident by apparent inadequate preplanning and assignment of priorities as activities increased, a poor understanding of procedures for control of activities and minimal QC Staffing for the magnitude of the activities.
b.
Prior Testimony Mr Keppler te'stified that electrical work was extensjgyly reviewed during the May 1981 NRC Staff inspection of Midland.--
The inspection team reviewed five areas within electrical work: quality assurance records, quality assurance implementing procedures, quality control personnel, visual inspection of electrical work activities, and Consumers Power's actions ggjpreviously identified items.21/ Only four problems were identified.--
These problems were isolated and not indicative of any major prggyammatic weaknesses in the implementation of the program.--
The inspection report also commended Consumers Power for several aspects of their electrical work program. First, the program and its implementation regarding calibration of termination tools was judged to be satisfactory.24/
Second,ConsumersPowerhadtakentimelyandcomprehggyiveactionsto correct areas addressed on previous NRC inspections.--
Finally, the qualityggyurance(electrical)organizationwasfoundtobestrongand
~
capable.
8.
Instramentation and Control Systems
- a..SALP Analysis "The Licensee is not rated in this area because a minimal amount of instrumentation installation and minimal inspection effort during this evaluation period."
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b.
Prior Testimony There was no testimony on this subject.
9.
Licensing Activities a.
SALP Analysis "The Licensee is rated Category 2 in this area. Early responses during the evaluation period were lacking in responsiveness. However, the more recent responses tend to be substantive and of acceptable quality."
b.
Prior Testimony Mr Keppler did not testify on this subject 10.
Fire Protection a.
SALP Analysis "The Licensee is rated Category 1 in this area. Management attention has resulted in a high level of performance in this area."
b.
Prior Testimony There was no testimony on this subject.
11.
Preservice Inspection 3
a.
SALP Analysis The Licensee is rated Category 2 in this area. The Licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified."
b.
Prior Testimony There was no testimony on this subject.
12.
Design Control and Design Changes a.
SALP Analysis The report notes four design control related noncompliances identified by NRC inspections and five licensee-controllable Construction Deficiency Reports indicating a lack of quality assurance in design control during the evaluation period. The report concludes:
The licensee is rated Category 3 in this area. The amount of re-engineering that has transpired in electrical, civil and piping areas and the specific design control weaknesses discussed in rp0582-2030a173 l
Attechment 2 2-6 Soils and Foundations, Piping Systems and Supports and. Electrical Power Supply and Distribution indicate significant weaknesses in overall design control.
b.
Prior Testimony MrKepplerdidnotconsidertheprog}7msidentifiedinthepiping system to be a-significant concern.--
He also testified that noncompliances identified by NRC inspections in the soils area, although oj87 neern, did not contravene his judgment of reasonable assurance.--
Another NRC Staff witness, Mr Gilray, confirmed that the two soils noncompliances referenced here by the SALP Report were not substantive and did n bring the adequacy of Consumers Powers proceduresintoquestion.ggj The May 1981 NRC adequacy of the electrical program at Midland.3fySPection affirmed the Mr Keppler did identifydesigncontrolasasignificantqualityrelatedproblem.377' 13.
Reporting Requirements and Corrective Action a.
SALP Analysis The report notes that Consumers Power contested several apparent items of noncompliance during the evaluation period, and concludes:
The Licensee is rated Category 3 in this area. The licensee responses to enforcement items and internal audit findings are often delayed requiring repeated submittal to obtain acceptable resolutions.
b.
Prior Testimony Mr Keppler testified that Consumers Power had responded to all items of noncompliance identified in NRC inspection reports. He noted that Consumers Power agrees with some such items and disagrees with others.
Mr Keppler stated that the fact that Consumers Power does not agree with an apparent item of noncompliance is not a sign of poor management attitude.
If there is a valid reason to disagree with the item, he added, then they should disagree with it.
This is a nor partofthegiveandtakebetweentheNRCStaffandthelicensee.g3J 1/
Keppler, Tr 1884-47, 1981-77, 1981-83, 1998-2002, 2004-09, 2076-84.
2/
Keppler, Tr 1973-76.
3/
Keppler, Tr 1935-36, 1964-66, and preparad testimony at p 4, following Tr 1864.
4/
Keppler, prepared testimony at pp 4-7, following Tr 1864.
S/
Keppler, Tr 2078-79.
rp0582-2030a173
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Attechment 2 i
2-7 6/
NRC Staff Exhibit No 1; Keppler, Tr.
7/
Keppler, Tr 1973.
8/
Keppler, Tr 1935-36, 1964-66 and prepared testimony at p 4, following Tr 1864.
9/
NRC Staff Exhibit No 1 (NRC Staff Inspection Report No 81-12); Staff Exhibit No 3 (NRC Inspection Report No 81-09), Gallagher, prepared testimony,-Attachment No 3, (NRC Inspection Report No 80-32/80-33),
following Tr, 1754.
--10/
Keppler, Tr. 1935-36, 1964, 66 1887, 1942, 2002-09, 2013-2017 and prepared testimony at pp 4-5, 7 9, following Tr 1864.
11/.
Keppler, Tr 1913-14, 1977, 1982-83, 2083.
12/
Keppler, prepared testimony at p 8, following Tr 1864.
13/
Keppler, Tr 2004-09, 2017, 1942.
14/
Keppler, Tr 2006-09.
15/
Id.
16/
Id.
17/
Id,' prepared testimony, Attachment No 2, at p 5, following Tr 1864, 18/
Id, prepared testimony at p 8, following Tr 1864.
19/
Id., at p 4.
20/
_ Keppler, Tr 2076-78, and prepared testimony at p 7, following Tr 1864.
21/
Id, prepared testimony, Attachment No 2, at p 11, following Tr 1864 22/
Id, at p 11-12.
23/
Id, prepared testimony at p 8, following Tr 1864.
24/_
Id, prepared testimony, Attachment No 2 at p 12, following Tr 1864.
25/
Id 26/
Id 27/
See discussion supra under " Piping Systems and Supports."
3 28/
See discussion supra under " Soils and Foundations."
rp0582-2030a173 i
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Attscheent 2 2-8 29/
Gilray, Tr 3742-43 (testifying regarding the soils noncomp.11ances.
identified in NRC Inspection Reports No 80-32 and 80-33)
- }0/
See discussion supra under " Electrical Power Supply and Distribution."
31/
KePPler, prepared testimony at p 4, following Tr 1864.
32/
Keppler, Tr 2083-84 r
I I
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r rp0582-2030a173
Attechnent 3 3-1 ANALYSIS OF CURRENT AND FUTURE QUALITY ACTIVITIES.
WITH REGARD TO REMEDIAL SOILS WORK At the April 26, 1982 SALP meeting Region Administrator, Mr J G Keppler,
- empressed concern that his staff had informally characterized the ongoing soils and foundation work as only minimally acceptable. Mr Keppler asked CP Co's management to comment on.its impression of this characterization and to
. provide its suggestion as to how this assessment could be improved.
The following consists of a brief analysis of what Consumers Power perceives to be the basis for this idformal characterization and a description of some cf the current organizational and programmatic features of the soils activities that lead us to conclude that prospects are excellent for the satisfactory execution of the remaining soils and foundation work.
The soils-related activities at the Midland job site are currently at a relatively low level pending completion of the NRC staff's technical review and release, by the NRC, of the major portion of the remedial work still to be undertaken. The work that has been done thus far in 1982 is concentrated in two areas. First, a significant number of wells have been drilled at the site, as part of the plant dewatering systems, as part of the freeze wall associated with the auxiliary building underpinning activity and to support the site drawdown tests. Second, the major contractor for the auxiliary building underpinning work was mobilized; the initial work on the. access shaft was completed; and, in parallel the detailed underpinning construction planning and continuing technical review with the NRC staff of subsequent work was carried out. Very little work in the other remedial soils areas has been accomplished during this period.
In responding to Mr Keppler's comments at the SALP meeting, we believe that the basis for the staff's informal negative comments regarding the current soils quality assurance activities can be traced to one specific area of concern and one more broadly-based general concern. A discussion of each of these follows.
A specific area of work which may have been of concern to the staff, and one of immediate concern to Consumers, relates to the controls on the drilling and excavation activities that have been recently carried out.
Because the number of NCR's that had been written in this specific area and the severity of the most recent occurrence (drilling into an electrical duct bank), the Company concluded that even with the formal controls that were previously in place,
. additional controls were required. As a result on April 28, the Company issued a stop work on all drilling by Mergentine and its subcontractors.
(This Consumers Power.stop work direction preceded the ASLB Order of April 30, 1982,) As of May 12, the stop work order had not been removed, nor will it be until a new detailed drilling and excavation control procedure has been fully reviewed and accepted by Consumers Power Company. While there had been other corrective action taken prior to the CP Co stop work order, the Company is confident that the comprehensive revisions to the prior control procedures on drilling and excavation will preclude errors of the type recently rp0582-0091a100 e
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carried out in a satisfactory and controlled manner.
The general and considerably more significant area of inferred NRC concern can i
-only be identified as the lack of timely agreement between the Company and the NRC on the specific quality assurance coverage requirements to be imposed on the remedial soils work, particularly those to be imposed on the underpinning i
work. The lack.of timely resolution of this issue, the apparent misunderstanding regarding the Company's commitments, and the contentious atmosphere at the March 10, 1982 meeting on this subject and at the subsequent j
j inspection undoubtedly contributed to the negative rating informally expressed j
by the staff.
'~
When the auxiliary building underpinning work started with the first i,artial i
NRC release for construction of the vertical access shaft, CP Co presented a special quality assurance plan encompassing, in our opinion, appropriate portions of the underpinning work. This plan was initially presented to the staff at a meeting in Region III headquarters on January 12, 1982 and documented in a letter dated January 7, 1982. While the initial staff 1
}
response to the plan appeared to be favorable, no official NRC conclusion was j
expressed. It became evident during the time between January and early March that at least one individual within the NRC staff believed that an extensive modification of the program covera;,e under the QA plan, MPQP-1, should be i
required. This preference for expanded NRC requirements became an NRC staff working level position, formally expressed to the Company at the meeting on j
March 10, 1982. As a result of that meeting, the NRC Region III inspector t
i apparently concluded.that Consumers had committed to fully accepting the NRC Staff position that essentially all to go underpinning work should be Q-listed, unless exceptions are agreed upon. The NRC's meeting minutes reflect no such commitment.
In fact, no commitment was made. This misunderstanding, and others arising out of follow-up discussions with the staff, has apparently "i
j affected Region III's feelings toward our soils quality assurance program and l
1 personnel. It is, therefore, not surprising that the NRC Region III staff I
considers the quality assurance activities in the soils and foundation area to be in need of improvement based on its recent experience.
(It should also be noted that the NRC SALP Board held its second and final meeting on March 23, 1982.) The Company also agrees that it is extremely difficult to avoid i
regulatory difficulties unless both parties have a common understanding and j
agreement as to the scope of applicable requirements. The major issue with regard to QA program coverage was resolved at the management level meeting L
j held on March 30, 1982 in Glen Ellyn and documented by the April 5, 1982 l
letter of J W Cook to J G Keppler, in which the Company agreed to "Q" list essentially all of the to go underpinning work. However, the staff has still not formally acknowledged its concurrence with that letter. This concurrence would be of significant assistance in documenting the conclusion of the staff's review of program requirements and permitting the redirection of resources from program definition to successful program execution.
t l
l Resolution of the concerns noted above will make a significant contribution to i
the remaining soils work.
In addition, the following considerations should provide added confidence that excellent results will be obtained in the i
remaining soils construction activities, i
rp0582-0091a100 l
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Attachm:nt 3 3-3
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N Dedication of.a high quality professional staff to.the underpinning and other soils work is of paramount importance to its successful completi_on,. Because of the complexity and importance of the= underpinning work as the dominant factor in the soils remedial program, a mini project of dedicated groups has been set up to focus attention on the soils activities, with particular emphasis on the underpinning. The technical' qualifications of the individuals staffing these activities emphasize previous:related~ experience. At the site, specific underpinning groups have been formed within 3echcel construction, Bechtel quality control and MPQAD,7all staffed with individuals having significant applicable technical e'perience and academic eredentials. Both r
Bechtel resident engineering and Bechtel engineering in' Ann Arbor have dedicated remedial soils groups. The onsite r'esident engineering office will have four geotechnical engineers and At least_two structural engineers dedicated to supporting the field activities. -Consumers' Power Company home-office soils activities are currently. staffed with two experienced geotechnical engineers and several expdrienced structural engineers who have been active in the design reviews and prior licensing evaluations and who will continue to follow the soils remedial work throughout the duration of the construction. The overall Consumers Power Company' project management of soils is also organized as a mini-project, and the senior Consumers Power Company individual has had significant' nuclear power plant experience at the project manager level.
s In addition to the on-staff individuals for Consumers Power Company, Bechtel and the major subcontractors, significant consulting resources are also integrated into the soils work. The design consulting firm for the auxiliary building underpinning has a staff man onsite to coordinate with his home office personnel. All' thd major consultants will be asked to periodically review the job progress 1as the underpinning, work proceeds.
To assist some of the technical specialists in fully understanding all of the quality requirements on the job, some additions to the staff ate also planned.
The Bechtel underpinning construction grou'p leader, who oversees and interacts
~
with the underpinning subcontractors, will have a quality consultant on his staff to assist him in any and all quality-related matters.
It is also anticipated that the underpinning quality coritrol organization will be augmented to enhance its breadth of leadership.'
1 We believe that the NRC themselves can significantly assist in the successful completion of the underpinning and' other soils remedial, activities by expanding the presence of their lead inspector on the site as the. work progresses. Specific steps to facilitate this NRC interaction mete agreed upon, as documented in the April 5, 1962 letter referenced above, and complemented by day-to-day working agreen,ents.
A second area which should significantly assist in the su,ccessfdl completion of the remedial soils work, particularly the underpinning activit'ies, is the degree of design completion prior'to the work entering'the major construction phase. Because of the extent a'nd thoroughness of the'NRC stafffreview, there is a more complete design for the underpinning activities than is normally in place for other construction activities. Essential completion of the calculations for the underpinning work before the major construction phase 1
rp0582-0091a100
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3-4 begins will minimize the kind of major design changes that can occur in nuclear plant structural design process because of calculation revisions.
There will, of course, be design changes as the work progresses, but the degree of calculation completeness reached prior to initial drawing release will significantly contribute to the stability and success of the construction process.
In addition to the degree of completeness in the underpinning design activity, the interface review called for by the quality assurance plan for the underpinning activity, MPQP-1, is also substantial. These reviews will also contribute to both the validity of the design and the general understanding of design requirements and quality attributes by all persons participating in the underpinning activities. In addition, MPQP-1 directly inserted quality assurance (and through quality assurance, quality control) comments into the design review cycle, a significant requirement above and beyond the quality assurance program for the balance of the plant.
The number of procedural controls that have been or are being instituted for this work should also engender confidence that the critical underpinning activities will be satisfactorily controlled. Judging from the work to date, there will bk more than 50 specific work procedures developed for the underpinning work. MPQP-1 calls for integration of inspection hold points directly in these construction work procedures. As a result of these steps, the procedural controls for the underpinning work will be more' extensive than those for any other activities, with the possible exception of NSSS primary loop activities, covered by the QA program for the balance of the project. The extent of the construction procedures automatically increases the scope of the training activities and of the inspection plans which are developed based on the specific work procedures.
Finally, as a result of the extensive discussions with the NRC staff regarding
~
the coverage of the "Q" program, MPQP-1 is being applied to essentially all of the underpinning work still to be done. While this application may or may not be completely consistent with a strict definition of what is " safety-related,"
it should lend added assurance that the work in total, and the safety-related work in particular, will be carried out successfully.
In light of the foregoing, it is hoped that the Region III management can gain an appreciation of Consumers Power Company's perception of recent events and that both the Region III management and staff can develop added confidence that the to go soils work, particularly the extensive underpinning activities, can and will be carried out up to the expectations of both the applicant and the NRC.
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for the installation of the safety-related small bore piping and piping suspension systems.
4.
Confirmatory Action Letter Consumers Power Company issued a (a) On January 22, 1981, letter to the Director of Region III stating that their 16, 1981, to B&W for instal-Stop Work Order of January lation of Core Support Assembly Vent Valves would remain i
in effect until the procedures were revised, training of personnel was completed, and the overview inspection This action was taken in lieu of
~
plan was revised.
Region III, Office of Inspection and Enforcement issuing an Immediate Action Letter.
Consumers Power Company issued a letter On July 27, 1981, (b) to the Director, Region III delineating those actions to be taken to control modification to drawings which do not have the required Committed Preliminary Design Calcula-tions (CPDC) and'that the methodology for modifications to be fully documented and submitted to the Regional This action was taken in lieu of Office for review.
Region III Office of Inspection and Enforcement issuing an Immediate Action Letter.
G.
M_anagement Conferences Three meetings were held with Consumers Power Corporate Management during the appraisal period.
1980 and continued The first meeting was held on November 24, 1.
on December 2 and 17, 1980. The purpose of the meeting was to discuss the Systematic Assessment of Licensee Performance (SALP) and to be present for the licensee's presentation of (Inspection Reports the recently reorganized QA organization.
No. 50-329/80-35 and 50-330/80-37).
The second meetir.g was held March 13, 1981, to discuss the 2.
Midland Project Organization, Midland QA Program evaluation and the new external quality consultation.
(Inspection Reports No. 50-329/81-05 and 50-330/81-05).
The third meeting was held on May 22, 1981, to discuss the 3.
results of the team inspection of May 18 to 22, 1981.
(Inspection Reports No. 50-329/81-12 and 50-330/81-12).
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UNITED STATES
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F NUCLEAR REGULATORY ( OMMISSION k [k E ' o;[$
'M ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 1
g WAs!*lNGTON, D. C. 20555 PRIC IE.%,s_I G
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Honorable Nunzio J. Palladino I
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Chairman
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DEP W U. S. Nuclear Regulatory Commission Washington. D.C. 20555
Dear Dr. Palladino:
SUBJECT:
ACRS INTERIM REPORT ON MIDLAND PLANT, UNITS 1 AND 2 During its 266th meeting, June 3-5, 1982, the Advisory Committee on Reactor Safeguards reviewed the application of Consumers Power Company for a li-cense to operate the Midland Plant, Units 1 and 2.
This application was also considereo at Subcommittee meetings held on April 29, 1982 in Washing-ton, D. C., on May 21,1982 in Midiand, Michigan and on June 2,1982 tn Washington, D. C.
On May 20,1982 members of the Subcommittee toured the plant.
In the course of these meetings the Committee had the benefit of discussions with representatives and consultants of Consumers Power Company, Babcock and Wilcox Company, Bechtel Corporation, the Nuclear Regulatory Commission Staff, and members of the public.
The Committee also had the benefit of the documents listed below.
The ACRS reported on - June 18, 1970 regarding the construction permit ap-plicatio'n fer the Midland Plant; on September 23, 1970 regarding several amendments to the application; and on November 18, 1975 regarding applica-ble generic matters.
The Midland Plant site is located on the south bank of the Tittabawassee River adjacent to the southern city limits of Midland.
The main industrial complex of the Dow Chemical Company lies within the city limits directly across the river from the site.
There are about 2000 industrial workers within one mile of the site, and the estimated 1980 population was about 51,400 residents within five miles of the site.
This makes the Midland site one of the more densely populated sites at distances close to the Plant.
Each of the two Midland units employs a Babcock and Wilcox designed nuclear steam supply systen rated at 2468 MWt with a stretch power rating of 2552 MWt.
The Midland Plant is unique in that the heat generated will be used not only to produce electricity but also to produce process steam for the Dow Chemical Company plant via a tertiary system.
The Midland Plant has been the subject of several major problems related to quality assurance during plant construction.
One of these problems relates to the soil fill under several safety-related structures.
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JUN 161982
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Honorable Nunzio J. Palladino June 8, 1982 deficiencies relating to soil fill have - led to excessive settlement and some cracking of these structures, and have also introduced questions concerning the adequacy of protection against liquefaction of the granular portions of the fill in the event of strong vibratory motion accompanying an earthquake.
The Applicant has proposed and is implementing, under close surveillance by the NRC Staff, remedial measures with regard to the foundation deficiencies.
We are generally satisfied with the approach being taken, subject to confir-mation of the overall quality assurance program and the seismic design basis. Both of these items are discussed below.
With regard to quality control of design and construction, the report of the NRC Staff's Systematic Assessment of Licensee Performance (SALP) review for
~
theJ period July 1,1980 to June 30, 1981 revealed deficiencies in the instal-lation of piping and piping suspension systems, in the pulling of electrical cables, and in the handl.ing of problems relating to soils and foundation.
Deficiencies by the Applicant in the handling of soils-related matters have continued to occur, subsequent to issuance of the SALP report.
We believe that the NRC Staff is handling the corrective actions for specifically identified quality assurance deficiencies in an appropriate manner.
In view of the overall concern about Midland quality assurance the NRC should arrange for a broader assessment of Midland's design adequacy and construction quality with emphasis on installed electrical, contral, and j.
mechanical equipment as well as piping and foundations.
We wish to receive a report which discusses design and construction problems, their disposi-a
- tion, and the overall effectiveness of the effort to assure appropriate quality'.
n i
Our reservation concerning seismic design relates to the lack of adequate assurance that the Midland Plant will be capable of accomplishing shutdown j
heat removal fer low probability earthquakes more severe than the safe shutdown earthquake (SSE).
The Midland seismic design basis at the con-struction permit stage corresponded to a IEI VI, peak ground acceleration of 0.129, employing a modified Housner spectrum.
For the operating license l
review, the NRC Staff has reevaluated the original seismic design basis and the Applicant and the NRC Staff have agreed on the use of site-specific analyses which have led to increases in the design response spectra ' for frequencies above about 2 cycles /sec.
Historically, no earthquakes stronger than the newly proposed SSE have 4
occurred within 200 miles of the Plant.
However, expert opinion differs widely 'on the exceedance frequency of the proposed SSE and on the severity 4
i at the site of earthquakes whose likelihood is less than 1 in 10 or 1 in 5
i 10 per year.
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Honorable Nunzio J. Palladino June 8, 1982 The Applicant is currently reevaluating by selective audit the seismic capability of the plant, as originally designed, to withstand the revised SSE.
Measures taken to assure safe shutdown in the event of an earthquake include the use of dewatering to reduce the potential for soil liquefaction.
s We recommend that all systems and components important to decay heat removal be carefully evaluated for their ability to accorrplish necessary functions
'in the unlikely event of lower-probability, more severe earthquakes in order i
to provide the necessary degree of assurance.
This matter should be re-solved _ in.a manner satisfactory to the NRC Staff.
We wish to be kept informed about the resolution of this matter.
We believe that any recom-mendations for changes in the plant resulting from this evaluation should be implemented by the end of tl:e second refueling outage.
I The_ Applicant has agreed to provide core exit thermocouples, a hot-leg-level measurement system, and subcooled margin monitors as instrumentation l
to detect inadequate core cooling.
Consumers Power Company also plans to include a remotely operable vent on top of both inlet loops to the steam generators; however, Consumers has not committed to supply a high point vent on the reactor vessel head.
This matter should be resolved in a manner satisfactory to the NRC Staff.
The ACRS recommends that the Applicant review further the potential for providing indications of water content or 1
level within the reactor vessel.
The staff of the Applicant includes many personnel who have had nuclear power plant experience.
However, operating experience with this B&W type power reactor is limited, and the NRC Staff is requiring that at least one person having experience on a large commercial PWR be included on each shift for one year. We support the NRC Staff position.
The Applicant's experience with the operation of nuclear power plants should, in principle, place Consumers in a favorable position to provide continuing, careful oversight of the operations at the Midland Plant.
In view of some prior adverse operating experience at the Palisades. Plant i
however, we recommend that the NRC Staff institute an augmented audit of operations at Midland, at least during the early years of operation at power.
We have reviewed the evaluation made of the tertiary process steam system for use by Dow Chemical Company.
This system appears not to impose any i
unacceptable impacts either on the safe operation of the Midland Plant or on the people working at the Dow Chemical Company.
The Applicant has undertaken an effort to have a probabilistic risk assess-ment (PRA) performed for the Midland Plant and stated that the results will l
be available in the fall of 1982.
We believe it desirable to have plant-i specific PRAs performed for each commercial nuclear power plant and that 4
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'5 Honorable Nunzio-J. Palladino June 8, 1982 it is particularly appropriate for the Midland Plant because of its rela-tively high, close-in population density. We wish to have the opportunity to review the Midland PRA with assistance from the NRC Staff, and to offer comments or recommendations as appropriate.
We do not believe that this review need delay licensing of the Midland Plant for operation.
Recently, questions have come to light in connection with B&W plants con-cerning the availability of natural circulation in the presence of an interrupted or continuing small break loss-of-coolant accident.
We wish to see a proposed NRC Staff resolution of this issue.
. The Applicant described an extensive systems interactions study being undertaken for the Midland Plant.
We wish to be informed of the results of this study.
We believe that,.in view of the population density near this plant, addi-tional prudence is appropriate for the Midland Plant in the resolution of the ATWS issue and other Unresolved Safety Issues.
We endorse the participation of Dow Chemical Company plant personnel in emergency procedures developed on the basis of-an assumed failure at the Midland Plant.
Similarly, there should be active participation by Midland Plant personnel in emergency procedures developed on the basis of an assumed failure at the Dow Chemical plant. The Applicant and the NRC Staff l
should promote continued coordination of these types of relationships, as i.
well as those involving appropriate state and local groups to assure that the capability for an effective emergency response is developed and main-tained.
~
j With regard to the eleven items identified in the ACRS Supplemental Report on Midland Plant, Units 1 and 2 dated November 18, 1976, we have the follow-ing comments.
The issues related to vibration and loose-parts monitoring, potential for axial xenon oscillations, behavior of core-barrel check 1
valves during normal operation, fuel handling accidents, effects of blowdown forces on core internals, LOCA-related' fuel rod failures, and. improved i
quality assurance and in-service inspection for the primary system have all been resolved or are in a confirmatory stage of being resolved. Separation of protection and control equipment has been accomplished in an appropriate
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manner; however, the safety implications of control systems remains an Unresolved Safety Issue directly applicable to Midland.
Resolution awaits completion of the NRC Staff Task Action Plan A-47.
The effect of ECCS induced thermal shock on pressure vessel integrity has been resolved in part; however, the Unresolved Safety Issue on pressurized thermal shock will apply.
Environmental qualification of equipment remains a generic l
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Honorable Nunzio J. Palladino June 8, 1982 issue which is under review by the NRC Staff and whose resolution will apply to the Midland Plant.
Instrumentation to follow the course of an accident has~ been resolved in part by the development of revised Regulatory
. Guide 1.97.
We do not believe that licensing of the Midland Plant for operation need. await further resolution of any of the eleven issues dis-cussed above.
The various other matters identified by the NRC Staff as open or confirma-tory in the Safety Evaluation Report should be resolved in a manner satis-I factory to the NRC Staff. We wish to be kept advised concerning resolution of the turbine missile issue.
The ACRS believes that, subject to satisfactory completion of construction and. staffing and if due regard is given to the comments above, the Midland Plant, Units 1 and 2 can be operated at power levels up to 5 percent of full power with reasonable assurance that there is no undue risk to the health and safety of the public.
t i
We defer our recommendation regarding operation at full power until we have had the opportunity to review the plan for an audit of plant quality and
.the proposed resolution of the question regarding natural circulation in the presence of a small break LOCA.
Dr.. Kerr did not participate in the Comittee's review of this matter.
Sincerely, 9
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s.
P. Shewmon Chairman
References:
1.
Consumers Power Company, " Midland Plant Units 1 and 2 - Final Safety Analysis Report" including Anendments 1-43 2.
U.S. Nuclear Regulatory Commission, " Safety Evaluation Report Related to the Operation of Midland Plant, Units 1 and 2," NUREG-0793, dated May 1982 3.
U.S. Nuclear Regulatory Comission, "NRC Licensee Assessments,"
NUREG-0834, dated August 1981 4.
Letter from J. Cook, Consumers Power Company, to J. Keppler, NRC,
Subject:
Midland Project Response to Draft SALP Report, daced May 17,1982 5.
Letter from J. Cook, Consumers Power Company, to J. Keppler, NRC, l
Subject:
Midland Project Quality Assurance Program Update, dated j
April 30,1981 6
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Honorable Nunzio J. Palladino 6-June 8, 1982 6.
Letter from J. Hind, NRC, to J. Cook, Consumers Power Company,
Subject:
Systematic Assessment of Licensee Performance (SALP),
dated April 20, 1982 l
7.
Letter from J. Cook, Consumers Power Company, to H. Denton, NRC,
Subject:
Summary of Soils-Related Issues at the Midland Nuclear Plant, dated April 19, 1982 8.
Letter from K. Drehobl, Consumers Power Company, to D. Fischer, ACRS,
Subject:
Midland Project Soils Information, dated April 12, 1982 9.
Statement of Ms. M. Sinclair to ACRS, dated June 4,1982 10.
Letter from B. Stamiris to Dr. D. Okrent and ACRS Members,
Subject:
Midland OL Review, dated May 29, 1982
. 11. Letter from M. Sinclair to Dr. P. Shewmon, ACRS,
Subject:
Midland OL Review, dated May 28, 1982 12.
Statement by Dr. C. Anderson to ACRS Midland Plant Subcommittee dated May 20-21, 1982
- 13. Statement by Ms. M. Sinclair to ACRS Midland Plant Subcommittee dated May 20-21, 1982
- 14. Letter from B. Stamicis to D. Fischer and ACRS Members,
Subject:
Soil Settlement and QA Issues, dated May 20, 1982 15.
Letter from M. Sinclair to Dr. C. Siess, ACRS,
Subject:
Midland Soil Settlement, dated April 26, 1982 k
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