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W3 * *A7lm2 LQ?M'.%._ -^. ?e :.. r.~.. :., Ah -. Roy A WeNo 3 Eseautve Menever i Quency Assurance Deperrneena MMinnd Propes hacene % Po see 19s3. Momene. ne esseo e (SIM sal-esos March 29, 1984 Mr J J Harrison, Chief, Midland Section US Nuclear Regulatory Comunission 799 Roosevelt Road Region III Clen Ellyn, IL 60137 MIDLAND ENERCY CENTER PROJECT - MINUTES OF NRC 2/29/84 MEETINC FILE 0.4.3 & 0.6 SERIAL 28921 e Attached is r. summary of the meeting between NRC Region III personnel and MPQAD persornel. This is the summary presented for your review in draf t and which you found satisfactory. W FE/kw CC DEBeaudoin. Midland
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OF MEETING BETWEEN MPQAD AND NRC REGION III PERSONNEL HELD AT NRC REGION III 0FFICERS ON FERRUARY 29, 1984 On Februrary 29, 1984 MPQAD and NRC Region III personnel (attendance sheet attached) met from approximately 8:30 AM to 11:30 AM to discuss: 1. Pasults of NRC HVAC inspections and investigation of allegations; 2. E:tpansion of MPQAD training, qualification, and certification activities; 3. Audit MSA-83-25 concerning MPQAD training, qualification and certification activities; 4. MPQAD activities relating to failed racertification candidates; 5. Miscellaneous Items. A summary of these items follows: 1. IVAC Participants NRC MPQAD RGardner HPLeonard JJHarrison RAWells RLandsman RFWarnick WEeyes
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During this portion of the meeting NRC Region III personnel reviewed the results of inspections and investigation into allegations l relating to HVAC work.,It was stated that the inspections and investigation was conducted by five (5) Region III and three (3) NRK personnel and included a total of 1142 manhours. The results of the investigation were that the allegations will be closed out. The NRC will be issuing nine items of noncompliance all i at Severity Level 4 and 5. This portion of the meeting was concluded with Region III personnel stating they were satisfied with the HVAC work and that the QA Program was being effectively faplemented. The formal report will follow shortly. MIO384-0001A-QL05 3/20/84'
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..g - o l j \\ ,.w.wpu mews.,* ~~~mn,-+me.g.w:.mme 2 -l 2. Training, Qualifications and Certification Participants 1 i NRC MPQAD RGardner DEBeaudoin JJEarrison GFEwert ar..nh gyLeonard 'i RWarnick MNunes j' RAWells i i During this portion of the meeting ENunes and DEBeaudoin presented t expansions planned for the training, qualification, and certification processed within MFQAD. (A copy of the overheads }* used is attached to this summary as Attachment A). The presentation was introduced by RAWells who indicated that the i espansion is not contrary to the trainias, qualification, sad certification commitments outlined in the Construction Completion i Program. During the presentation questions were raised concerning training methods and====4=mtion methods. The responsee indicated that methods would be used as appropriate as outlined in MPQAD Procedures. Also, that' oral eaaminations would not be used by the Trainias Besack, but would contiane to be part on the on-the-job 4' trainias sad performance demonstration process. t ] This portion of the meeting was concluded with the understanding j that MFQAD would proceed, as long as the espansion met regulatory j requirements CCF coenitaasts and MFQAD Procedure. j 3. Audit MsA-83-25 Participants NRC MFQAD I RGardner GFEwert I JJEarrison NFLeonard RLandsman RAWells During this portion of the meeting the subject audit was reviewed i I with Ragion III personnel. GFEvert opened tha review by stating that the audit was full scope and gave the status of findings and unresolved items as follows: Findings Unresolved Items 18 Total 9 Total 13 Closed 6 Closed 5 Open 3 open t l \\ Each finding and unresolved item was reviewed. Region III personnel indicated they would review Finding OSF closure during a future site i visit. MFQAD indicated that the Bechtel Materials and Quality / 20/84 .M10384-0001A Qt.053
' %E-rsgemmA~rt.menw.calve r**wr2v &Syrrmwmr :.. m.m7$ + -~c g ) t 3 Services Procedure for NDE personnel certification would be reviewed to assure it does not have an oral waiver provision for qualification requirements. It was agreed to review the need for the DAD Manager to sign Level III Certifications as long as appropriate site personnel do this. This closed out the review with the NRC other than the above noted items. 4. Racertification Candidates Participants NRC MPQAD RGardner GFEwere JJHarrison HPLeonard RLandsman RAWells RAWells opened this portion of the meeting by stating that MPQAD was essentially complete with the racertification effort. GFEvert reviewed the status and provided status information as indicated on Attachment B. GFEwere provided copies of the latest Reinspection Tracking Log and MPQAD Procedure B-5M to Region III personnel. The definition of a Racertification Candidate in the procedure was reviewed as well as the provision for sampling inspection of the Racertification Candidates previous inspections. NRC noted that this information could be significant for review of inaccessible items and future consideration of a sampling program. It was agreed that the Racertification Candidata program as described in the procedure would remain in effect. Personnel who meet the definition of a Racertification Candidate will be tracked. This is approximately 144 personnel. This closed out this item with the NRC other than for continued implementation. 5. Miscellaneous Items Participants NRC MPQAD JJHarrison RAWells JJHarrision and RAWells reviewed items as follows: 1. NCR M01-9-2-172 is to be closed by the week of March 5. The NRC l will obtain a copy when on site that week. MIO384-0001A-qt05 3/20/84
.= _= .,_a 'ys*$ Mc^ v s, ~ au p ---- @ w c x:- W:,-tm.;%my%. :m;wm:m:- '-^^^;.. g --;..,._. a 3 4 2. Status of FCR/FCN SW and related NCRs was discussed. RAWells said all Sii0s except Soils Mechanical were fully released and that should be released soon. Also noted that only three or four NCRs impacted hardware and that they were minor and might be dispositioned use-as-is. Basis for discussions was SWO Matrix and NCE Summary approved by DAT. Ths meeting ended at approvi=ately 11:30 AM. e esp N ' = - t : ?. O
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l s ATTACHMENT A ,g MPQAD/NRC 2/29/84 l Meeting Sumstary ( r ~ CP.,Q .!? i I1 l MIDLAND ~1 m 21 ENERGY. CENTER y: CERTIFICATION PROGRAM i ! i EXPANSION L1 3l [-l o r: PRESENTED TO: U.S. NRC, REGION 111 - ! 'l ON: FEBRUARY 29,1984 i y; l BY: CP CO MPQAD 3 !i i 1 ,1 t' i s' G ll 'li t, t .{. ? l H u
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.i[ ATTACllMENT A HPQAD/NRC 2/29/84 j-, ~ Heeting Summary .i .4t CERTIFICATION PROCESS 6 4 d. I k KN WLEDG'E &l SKILLS = !i IDENTIFY CANDIDATE NEEDS ia / I4 i GROUP TASKS j_ DETERMINE /- .e METHODS / ~ A MEASURE- / MENT / ~ i \\ PD /- i y a ll CERT o i
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MPQA 2/29/84 . _ __n-CPCo 3 CERTIFICATION l 3 PROCESS h '? J.j l PURPOSE: DESCRIBE ENHANCEMENTS TO THE .[( CERTIFICATION PROCESS ij tl 1L 1. TRAIN AND EXAMINE BY KNOWLEDGE ,1 AND SKILL GROUPINGS (INITIAL & Q! j ~ CONTINUING) ly 11. TRAIN AND EXAMINE BY THE APPROPRIATE ~ l. f METHOD i ^
i ATTACHMENT A HPQAD/ CRC 2/29/84 i. Meeting Summary i i PRESENT FLOW i ') SINGLE CLOSED 1 l FORMAT OJT j BOOK TRAIN +- + + l TRAINING TEST ji 1 , ( } ll 3 j ) POCl i PD +'. OR 3 PROGRAM \\ I f l d 'i i j h l CERT SELECT CANDIDATE .r t i ip kN ] fl .i r: I wm 1-
i ENHANCED FLOW Q@l"e,,,, ) Meeting Suassary .'f - Ci KNOWLEDGE & Skills d' 3, _. _ _. _ _. _0)'E. 4 f Lt. H f @ l.Nj d ff []ktg.. _ _. _. _, g; 3 I KNOWLEDGE ~ SKili5 ll f SELECTISM SF g ,j TRES PNASES & I ELEMENTS d SRIENTATISM SENERAL Specific p j PD ., J l lPNASEIl IPNASE 2) IPNASE 3) BASEB SN I IE }.: l CANBISATE*S ' ij i j ll l NEEBS g.._._.___._._._.._.____._..____.________.j 1 l ,j l SA PASSRAM I I SRIENTATISN l lSPECiflCATISNS j ,l ] I 5 i 1 IJ CANel8 ATE *$ WELBillt . CERT I NEEBb EVALMATISN l ggGCTRINATISNl l SRAWINGS l j 1 t BEASBSEMElli .1 i I l 10 l l INSP. PLANS l! lSELF-STuer CSNCRETING I e[j CAMBISATE g SELECTISN ~ l PaACTICE lIl if 'l .f i-SASANIZATISN INialNS I ' !l BECISISN) ANelles aSLYS l 1 !i i;
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9 @%90f . mCHEE A N 4'[# ' [ e[f MPQAD/VRC 2/29/84 4 4' / [ Mactins Summary q q q q TASK WEL DING <cour o, { INSPECT WELD CONTOUR AND SURFACE g g g g i APPEARANCE BY MEASUREMENT INSPECT WELDS FOR ELECTRICAL, INSTRUMENTATION SUPPORTS AND EEUIPMENT 8 lNCLUDING ATTACH TO BUILDING STRUCTURE VISUALLY CHECK FOR WELDER IDENTIFICATION l SYMBOL h h g INSPECT SURFACE PREPARATION FOR NDE i VERIFY STATUS OF NON-DESTRUCTIVE IXAMINATION - g REVIEW THE WELDING / INSTALLATION RECORDS h 8 PROCESS NOE REQUEST $ h g NOTIFY THE LFWE AND SUPERINTENDENT g g g I 0F THE STATUS OF THE NOE VISUALLY INSPECT BASE METAL REPAIR h 8 YlSUALLY INSPECT WELD LOCATION h 8 i VISUALLY INSPECT C0ATING OF WELDS AND UNCOVERED METAL OF ELECTRICAL SUPPORTS THAT ARE LOCATED h h I i OUTSIDE OF THE CONTAINMENT j COMPLETE QCF-3 FORM h g MAINTAIN THE QCF-3 AS PAltT OF THE IR VERIFY FE ACCEPTANCE OF THOSE ITINS WHICH g g g l REQUIRE THEIR APPROVAL l INSPECT STUO BASE FOR CLEANLINESS h h 8 FIPE SUPPOR TINSPECTION DESCRIBE ANY INACCESSIBLE ITEMS g VERIFY HOT BEN 0 LNG OF CARBON STEEL f VERIFY CLEANLINESS OF FLUOR 000LD /LUBRITE PLATES $ O 8 VERIFY ORILLED HOLIS ON BASEPLATES h 8
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~- vi / / A / / 8 38 4 4 &4 e TASK PIPE SUPP0R T INSPECT /0N <cour n MEASURE SURFACI BEARING ON BASEPLATES 8 i VERIFY BASEPLATE SHIM INSTALLATION 8 VERIFY TORQUE REQUIREMENTS 8 VERIFY PROPEM INSTALLATION OF ANCHORS 8 VERIFY THE ORIENTATION, LOCATION AND g CONFIGURATION OF THE PlPE SUPPORT REVIEW INTERFACING IR*: 8 PIPE INSTAllAT/0NINSPECTION VERIFY QCE's CERTIFICATION X VERIFY MINIMUM WALL THICKNESS f VERIFY UNSPECIFIED WELOS HAVE NOT BEEN A00ED 8 VE.11FY TEMPORARY ATTACHMENTS HAVE BEEN REMOVED INSPECT PIPE FOR Ol3TORTION f REVIEW INACCESSIBLE ITEMS RECOROS FOR h X c i ACCEPTAllLITY l INSPECT FLANGED JolNTS FOR UNIFORM CONTACT f VERIFY THAT BOLTING MATERIAL IS CORRECTLY h I INSTALLED i VERIFY MATERIAL TRACEABILITY VERIFY CONFIOURATION, ORIENTATION ANO LOCATION f 10ENTIFY SUPPORTIVE OOCUMENTATION g 4 w,
ATTACHMENT A MPQAD/NRC 2/29/84 }- Meeting Suasury l MEASUREMENT e.; TECHNIQUE '; D ~ v s i I$ I? I: 2 -i f CLOSED BOOK h, N . I 4 OPEN BO.OK h[ k' f EXERCISES 0 fi y f OTHER l ,A i ? l0 I e - l t c - e=0D i
ATTACllHENT A ~2 MPQAD/NRC 2/29/84 Y, Meeting Summary .4 1 1 -1i i TRAINING METHODS
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.] ',4.Qe; mem. c,<...- - ; w..:..c- < : ~ w. ...~ ~ - a v x w sse v ATTACHMENT B MPQAD/NRC 2/29/84 Meeting Sommary MPQAD RECERTIFICATION CANDIDATE RECAP (AS OF FEBRUARY 8, 1984) 144 Total Bechtel QC Certified Inspe:cors During September 1982 -74 Terminated /Not Identified As Candidates For QC Certification MPQAD -45 Candidates Completed Assigned Requirements 25 Candidates With Outstanding Certification Requirements 1,176 Total PQCI Certifications Durin;g September 1982 -703 Terminated /Not Identified Candidate For QC Certification PQCI's -8 Cancelled PQCI's -35 Duplicate PQCI Certifications -218 PQCI's Not Identified For MPQAD QC Recertification L -165 MPQAD Racertified PQCI's 47 PQCI's Requiring MPQAD Racertification i
,t'.' l: !" - [ naua 'g^ p' 4 A UNITED STATES ,,a .? NUCLEAR REGULATORY COMMISSION g WASHINGTON, D. C. 20555 - Y,/ 7 9, a y March 27, 1978 DOCKET NOS: 50-329 50-330 LICENSEE: Consumers Power Company FACILITY: Midland Plant, Units 1 & 2
SUBJECT:
SUMMARY
OF MARCH 21-22, 1978 MEETING AND SITE VISIT On March 21-22, 1978, we met with representatives of the licensee at the Midland site to discuss the scheduling of construction and to observe the construction activities in progress. The meeting notice and agenda for the meeting are attached as Enclosure 1. A list of attendees and persons contacted during the meeting is included as Enclosure 2. As noted in the agenda, the purpose of the meeting and visit was to examine variations in estimated dates for completion of construction of the Midland Plant. We also used the meeting to discuss with the licensee his reasons for the revised earliest and latest construction completion dates provided in Amendment 33 to, his application (FSAR). We met with representatives of the Licensee at the construction site offices on the morning of March 21, toured the site during the afternoon of March 21, and had followup discussions on the detailed construction schedules during the day on March 22. The February 1978 issue of the Yellow Book shows Unit 2 at 39% complete and Unit 1 at 35% complete. Earliest and latest dates for completion of construction are shown as October 1,1980 and October 1,1981 for Unit 2 and October 1,1981 and October 1,1982 for Unit 1. Fuel load dates are shown as November 1980 for Unit 2 and November 1981 for Unit 1. A generically-based forecast recently compiled by MIPC shows estimated fuel load dates of May 1982 and May 1983 for Units 2 and 1 respectively. Inasmuch as the completion dates for the Midland units are significant with respect to the ongoing remand hearing, this meeting was designed to resolve the differences between the Licensee's dates as shown in the Yellow Book, and the forecast dates developed by MIPC. We discussed with the licensee the methodology used by MIPC to develop the tools for its forecast of fuel load dates. Basically, it consists l of an average curve of construction versus time, based on the construc-l tion history of 14 different nuclear plants. Using this curve and the j reported percentage completion of construction for a particular plant, l ?!D$ ^ 5'h ,w-N
.2 y ._m m_. e t 2-an. estimate can be made of the time remaining until completion of construction. The Licensee bases estimates of construction completion on manhours. The formula uses actual manhours expended in the numerator, while the denominator is the sum of four factors:
- 1) the estimated total man-hours to construct the plant, 2) an allowance to take care of support effort and productivity of labor, 3) a factor to take care of contin-gencies, and 4) a scope change factor. The first three factors are revised on a six-month interval basis to update to a then current estimate of total labor needed plus allowances and contingencies. The fourth factor is changed each month to take into account efforts estimated to be required to handle changes in project scope.
For example, the NRC requirements for fire protection required an additional quantity of manhours to be added to the estimate. In practice, then, use of this formula results in what is thought to be an adequately conservative measure of total manhours expended compared to the total manhours budgeted. The construction completion figures are based strictly on the manhours, which are directly correlatable to work _in place. That is, an electrician can pull so many feet of cable per hour or make so many splices per hour, or it takes so many manhours to place a yard of concrete, etc. No credit is taken by the Licensee for value 4 or quantity of materials in place. It should be noted that the Licensee maintains records and estimates percentage completion on a total project basis. The percentage comple-tion figures reported for the Yellow Book are a simplification of more accurate records maintained for the project as a whole. The Yellow Book figures are derived based on an apportionment of effort on common facilities between Units 1 and 2. Refinement of the reported percent completion values, if applied to the MIPC forecast model, could provide for better agreement with the Licensee's estimated completion dates. This would require considerable additional effort, howevers which we do not feel is warranted. The Licensee's procurement program appears to be in good shape, probably considerably better than would normally be the case for a plant at this stage of construction. The principal reason is that dur-ing the 1974-1975 period when construction effort was curtailed due to lack of funds, procurement kept moving, with the result that all major components (reactor vessels, steam generators, pressurizers, reactor coolant pumps and piping, main steam valves, turbine-generators, etc.) either are now on site or are stored off-site and available for place-ment when needed. Hence, procurement should not pose any big problems l to maintaining the current construction schedule. We did not examine the detailed status of the design effort as compared e. ~ w w ,-----w -v-7.. ---+----------,,.---,v-*.,---,-v,v. e-w-.,-+--.-w,.----,.-, w g-9. y -y-,,w-,,.y,,p.-- .,,,., - ~ tv--t'
-c a a . to the construction activity, but it appeared to be adequately far advanced so as to avoid costly and time-consuming rework of construc-tion. Of note is the fact that the licensee has maintained close contact with other plants, to take advantage of lessons learned else-where so as to avoid mistakes at Midland. The design drawings have been. translated into plastic, scale models of some plant areas which proved useful-to avoid interferences of equipment and components. One point of potential schedule impact is associated with union contracts. All craft union contracts except for the electrical workers are up for renegotiation this year. The Licensee does not now antici-pate any major problems in this regard, but it is possible that contract negotiations could cause work stoppages which are not specifi-cally provided for in the Midland schedule. The current. work force at the site consists of about 2900-3000 people, of which approximately 600 are on the second shift. The Licensee i reported using up to about 8% casual ovectime thus far, but it is anticipated that overtime will be increased to as much as 15% on an as-needed basis. A close watch is maintained on all productivity, including second shift and overtime efforts, to assure optimum use of workers. At the present time, the construction emphasis is changing from a basic structural-civil effort to a mechanical-electrical effort. As such, the relative mix of workers by trades is changing. Minimal problems are anticipated in attaining the correct mix of skills for the job. Specifically, welders have not been a problem and the Licensee runs an in-house welding school to assure an adequate supply of qualified welders. Work is just now getting underway on preparation of pre-operational test procedures. It appears that the time for procedure preparation may be a bit tight. However, efforts will be based on lessons learned at other plants (e.g. TMI-2) and the Licensee anticipates no delays from this cause. Approximately twenty test engineers are now on site and have begun work on the pre-op test procedures. A matter of some concern to the staff is the question of hangers and snubbers. These have held up construction at some plants. However, the Licensee is aware of the potential problem and is taking steps to avoid it for Midland. A special hanger fabrication facility has been set up and the Licensee is working with the snubber supplier (ITT Grinnell) to assure that snubbers will be available when needed. The present intent is to install all' hangers and snubbers prior to hot functional testing, although some could be left for later installation if necessary. l
..u_., 2...y. - _ a a :_. 2 2 u.s _ ..\\ . Overall, the site construction activities appear to be in good shape. The civil-structural effort generally is on-schedule to ahead-of-schedule. Installation of large pipe is ahead of schedule. Both reactor buildings are considerably ahead of schedule on interior concrete. The Licensee intends to start installing NSSS components in Unit 2 in April if the weather permits. The plans for Unit 2 containment should allow rapid installation of piping and cables following NSSS installation without long delays for concrete work. l Cable tray and electrical installation is slightly behind schedule at this point, but as noted earlier, the emphasis is just now changing to include greater electrical effort. The Licensee anticipates minimal problems in getting back on schedule in this area. -It is noteworthy that -the Licensee's plans call for completion and check-out of all connon facilities (e.g. auxiliary building, diesel-generator building, rad-waste facilities, cooling water ponds, grounds, etc.) in conjunction with completion of Unit 2. Thus, nearly 85% of the total effort now is tied to Unit 2 completion, even though much would not be needed until Unit 1 is completed. Overall, the Licensee's schedule calls for fuel load on Unit 2 to occur 31 months from now (November 1980). Included in this schedule is a three-month contingency, or about 10%, which appears adequate at this stage of construction. It would not be enough to take care of major delays such as could be caused by an extended strike or by other conceivable problems such as financial difficulties. However, it does i appear adequate for anything that might reasonably be anticipated. As noted earlier, we used the meeting for the ancillary purpose of addressing the Licensee's request to slip the construction completisn dates as provided in the construction permits for the Midland units. In response to our questions, the Licensee's representatives ex-1 plained that the construction schedules estimated at the time of construction permit issuance have been delayed for reasons beyond l i their control. These delays are included in the exiiting forecasts for completion of the units. Both units were delayed 24 months due to adverse financial conditions in 1974 and 1975.- Unit 2 was rescheduled to be completed one year ahead of Unit 1, resulting in a delay of 13 months to Unit 1 and an advance of 11 months to Unit 2. Both units were delayed 9 months due to re-evaluation of construction time because of changing project scope and industry experience. Some of the more significant examples of changing project scope which influenced schedules were identified to be: (1) A new building for waste processing equipment resulting from 10 CFR Part 50, Appendix 1. J
. (2) Changes to' provide two cable spreading rooms and other space reanirements for electrical separation resulting from revialons to IEEE Standard 279. (3) Plant arrangement changes to equipment and structures to provide improved access to Class 1 piping resulting from the inservice inspection requirements of Section XI of the ASME Code. (4) Redesign of the Auxiliary Building consistent with spent fuel cask drop guidance of Re'gulatory Guide 1.13. (5) Updating of piping and valves from ANSI B31.7 to ASME III. (6) Requirements for additional analyses and testing to verify seismic requirements. (7) Changes resulting from OSHA requirements. Our general conclusion as a result of the visit is that the Licensee has identified possible problem areas and has taken or is taking necessary action to work around these problems without a major schedule impact. The proposed construction schedule, based on the current project status, appears to be realistic and achievable, although it may be a bit on the optimistic side. Barring major, unfore-seen problems, any slip in the schedule should be relatively minor. We identified no problem areas that indicated that the current schedule could not be met. Accordingly, we conclude that the November 1980 fuel load date for Unit 2 is a good date for current planning purposes. Further, we are optimistic that the November 1981 date for Unit 1 fuel loading should be achievable, since our perception is that Unit 1 major facilities are significantly ahead of schedule. Ad l L. P. Crocker e Technical Assistant to the Director Division of Project Management
Enclosures:
l2. 1. Meeting Notice Attendance List ) I e G ,,_,.-.-,,,...,,m_._ --y.. m ,-.m..v
s _~ M%q* I I o UNITED STATES ",, / 7, NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 MAR 161978 Docket Nos.: 50-329/330 EMDRANDUM FOR: Steven A. Varga, Chief, Light Water Reactors Branch No. 4, Division of Project Management FROM: Darl Hood, Project Manager, Light Water Reactors Branch No. 4, Division of Project Management
SUBJECT:
FORTHCOMING MEETING TO REVIEW MIDLAND PLANT UNIT 2 CONSTRUCTION COMPLETION SCHEDULE Date & Time: March 21 & 22,1978 (Tuesday & Wednesday) 9:00 a.m. Location: Midland, Michigan
Purpose:
To evaluate the schedule for completion of construction and fuel load dates for Midland Unit 2.
Participants:
NRC - L. Crocker, DPM; D. Hood, DPM; W. Reinmuth, I&E; W. Lovelace, MIPC; T. Vandel, I&E; et al. Consumers Power Co. - G. Keeley; Others as may be requested during the review. nu fc fo Darl Hood, Project Manager Light Water Reactors Branch No. 4 Division of Project Management
Enclosure:
Agenda cc: See Next Page a 11 2 ! L.,,, Tf/f(p'f7 ~
..~ . -- - -.. -. -., - ~.. p_ s AGENDA The meeting is part of an evaluation being performed by the NRC to determine best estimate dates for completion of construction and fuel loading for Midland Unit 2, the earlier of two units being constructed. On Mar. 8, 1978, the NRC advised the Atomic Safety and Licensing Board of variations in estimates by the NRC's Caseload Forecasting Panel, previous estimates carried by the staff in its " Yellow Book", and estimates by Consumers Power Company in Amendment 33 to the application. Recognizing the variations of these estimates and the fact that these estimates potentially affect certain issues in the Midland hearing, the staff is perfoming a more detailed plant-specific analysis. The staff also views the evaluation to be relevant to the request by Consumers Power Company for extension of Construction Pemits CPPR-81 an.d CPPR-82 as requested by Amendment 33 to the aoplication. 4 e 9 P'
[. Consumers Power Company ces: i Michael I. Miller, Esq. 1 Isham, Lincoln & Beale l Suite 4200 e One First National Plaza . Chicago, Illinois 60670 Judd L. Bacon, Esq. Managing Attorney Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers. Power Company 212 W. Michigan Avenue Jackson, Michigan 49201 Howard J. Vogel, Esq. Knittle & Vogel 814 Flour Exchange Building Minneapolis, Minnesota 55415 Myron M. Cherry, Esq. One IBM Plaza Chicago, Illinois 60611 Honorable Curt Schneider Attorney General State of Kansas Tepeka, Kansas 66612 Irving Like, Esq. Reilly, Like and Schneider 200 West Main Street Babylon, New York 11702 James A. Kendell, Esc. Currie and Kendall 135 North Saginaw Road Midland, Michigan 48640 T.ouis W. Prib'ila, Esq. 1 Michigan Division Legal Department 47 Building Dow Chemical USA Midland, Michigan 48640 d .\\ r- ~ r 1 ~ ___,.__..,_.,,e
(,. l j. .I Consumers Power Company ces (continued) Lee Nute, Esq. Michigan Division 'Ihe Dow Chemical Comp'any i l 47 Building j Midland, Michigan 48640 e e i e 9 9 e D / e 1 ' t'. . f' mr- ,n, ,a --,,,,..p--,,., , - -,,+,, n. e--
[ \\ ATTENDANCE LIST March 21-22, 1978 Midland Site Meeting Licensee G. S. Keeley Consumers Power Company, Project Manager T. C. Cooke Consumers Power Company, Project Superintendant K. R. Kline Consumers Power Company, Project Control Supervisor C. D. Johnson Consumers Power Company, Construction Control Supervisor W. G. Jones Bechtel, Project Cost & Schedule Supervisor NRC W. H. Lovelace MIPC D. S. Hood NRR, Midland Project Manager L. P. Crocker NRR, Technical Assistant to DPM -T. E. Vandel R:III, Project Inspector R. J. Cook R:III, On-site Inspector (designee)
- E. W. K. Lee R:III, Inspector
- K. R. Naidu R:III, Inspector March 21 only
- Contacted, but did not participate in meeting F
g..,. -.+ ... ~ 7 To DLQuamme tS '! Facu ek, NIReic cl/GWRowe Consumers one February 15, 1984 E0WSI SusJccT MIDLAND ENERGY CENTER GWO 7020 USNRC EXIT MEETING File: 0485.15 UFI: 12*24*25 Serial: CSC-7331 caU""$,ccc 0485.21 42*03*03 cc JWCook, P26-336B HPLeonard, MPQAD RAWells, MPQAD JLWood, MPQAD Attendees - The following is a brief report of the exit meeting concerning cable sub-stitutions held on February 10, 1984. f O e I l
___ff x i ?(.' ;; * * s MEETING NOTES i In 1982, an allegation was made by a former electrician, that indiscriminate cable substitutions were being made. A subsequent overinspection of over 9000 class IE cables revealed six cables of incorrect size. Not only was cable size checked, but routing, color coding and mylar tag info rma, tion., Although the overinspection was completed in 1983.with a number of NCR's i being generated the NRC requested an exit meeting to further investigste the breakdown. ~~ An exit meeting was held on February 10, 1984, in the Orientation Room between Bechtel, ccasumers and NRC officials. Those in attendance were: CPCO BPCO NRC M. Schaeffer D. Scott J. Harrison ..D. Cochran M. McCully R. Gardner J. Rowe R. Beistand B. Burgess D. Newcome Mr. Cardner requested any additional information on why two different size wires could be cut from the same reel, why the reel number recorded wa's an invalid number and why the tags attached to the cable were incorrect l. (2 of 4 wrong). I Mr. McCully explained that, shortly after he arrived on site he found the manufacturer's serial number was being used (in some cases) for the i reel number. As to the other two concerns, Mr.. McCully nor could anyone else provide a plausible reason for the errors. A trip to the present " cut-shop" was made to look at the present set-up
- and.how reels are marked to see if a reason for the errors could be found.
Only suppositions could be given. The group then went to the Services Support Building to look at tags that identified cables (made out by " cut-shop"). The tags showed they l had been improperly filled out. Prior to leaving the Orientation Room, Mr. Cardner informed the group this item would be viewed as an "ites of non-compliance". l GWRowe 2/14/84 .-_.,,_..,.,,.m-.
y To DLQuacme, Midland Energy Center,q From BHPeck, Midland Energy Center ,/ CONSUMERS POWER Date April 9, 1984 COMPANY Subject MIDLAND ENERGY CENTER GWO 7020 Internal i USNRC EXIT MEETING Correspondence File: 0485.15 UFI: 99*04 Serial: CSC-7599 CC JWCook, P26-336B MLCurland, MPQAD RAWells, MPQAD Meeting Attendees An NRC Exit Meeting was held on April 6, 1984, to discuss recent visits to follow-up open items previously identified by the NRC. The meeting was held in TCValenzano's office with attendees as noted below: MEETING ATTENDEES CPCo Bechtel BWCC NRC FJYanik GAHierzer VNAsgaonkar CScheibelhut BHPeck PHiland REWhitaker JElsbersgas DJVokal BLBurgess REDruin RDDavis The following information was discussed: Item 82-22-04; In progress Inspection Issue; CPCo response to NRC is satisfac-tory. Considered open pending follow-up by NRC. Item 80-20-05/21-05; No code for purchase of welding wire. Considered open. Further action required by NRC. Item 83-12-01/13-01; Hanger deficiencies. Considered open pending re-work / veri-fication of hangers. Item 83-07-01/02; Kelly Building segregation. NRC considers closed. Item 83-01-01; Untagged Value Issue. NRC considers closed. Item 78-19-02; Nuts on Hangers - Safety wires on shackles not required by vendor. NRC considers closed. Item 81-20-01; Cable tray dividers. NRC requires additional information. Considered open. CIRCULARS 81-09; Effluent Monitor Bypass - Closed 81-12; Testing of Power Breakers - Closed 9 IC0484-0010A-CN02
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2 81-14; Main Steam Isolation Valves - Closed INFORMATION NOTICES 82-13 (Became 84-02 bulletin); Failure of GR relays - Closed 81-15; Inadvertant Isolation of Instrument Lines - Closed l I e i l IC0484-0010A-CN02 t-
.., _ -.n To DLQuamme. Midland Energy Center I ra o., BHPeck, Midland Energy Center 3 Consumers Duc April 16, 1984 POW 8r SueJcc7 MIDLAND ENERGY CENTER GWO 7020 MARCH, 1984 NRC RESIDENT INSPECTOR EXIT MEETING File: 0485.15 UFI: 12*24*25 Serial: CSC-7632 clNE*N,occc cc JWCook, P26-336B MLCurland, MPQAD RAWells, MPQAD Meeting Attendees A monthly exit meeting was held on April 9, 1984 with the NRC Resident Inspec-tor. j 4 MEETING ATTENDEES CPCo Bechtel NRC DLQuamme CAHierzer BBurgess RAWells PHiland DDJohnson Housekeeping goods however, the project needs to increase efforts as work in-creases. I Document Control - NRC investigation confirms CIO findings. Project to make presentation to NRC Wednesday, April 11, 1984, on resolution of document con-rol problems. Status Assessment / Quality Verification Program documents are okay. NCRs - Philosophy on timeliness of issuance. NCR in one case took a week. Procedure is being changed from 24 hours. i Schedule from Bechtel on CCP for NRC. They are getting the weekly status re-port. Pat Hiland to verify that this is adequate. i Allegation regarding mechanical snubbers closed. l Presentation on Zack audit prior to formal submittal. Extension to June 1 requested. DDJohnson/dmh i i ( wr-
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-.- e ~, - > ~ = - ~.- _.._ _ -; me PUBLIC MEETING 8/11/83 7:00PM Valley Plaza - Great Hall NRC ATTENDEES: Darl Hood Jim Partlow Jim Stone Ron Cook Tom Novak Jim Lieberman Darrell Eisenhut Jim Keppler Bob Warnick Elinor Adensam ' Jay Harrison Ron Gardner Russ Marabito Keppler - Opening statement - Thirty people signed up to make statements. Please limit yourself to three minutes and try to speak only on the CCP. Jay - History and description of CCP and S&W qualifications and duties, TERA qualifications and duties. Points raised by GAP and NRC response. Keppler - Reverification program requirement by CPCo, third party overview, and overview by NRC versus third party reverification and NRC overview. Point of controversy. Comments would be appreciated. R. Tomachek -Prepared statement - Industry needs the plant. If license denied, Michigan industry would be at a severe disadvantage. Industries would not build in an area where energy was not available. F. Bransnan - 300,000 people will benefit from completion of plant. Bay Area Exec. Dir. Chamber of Commerce endorses plant. Position has not changed. Bay Area Progress is never easy. Ch. Comm. G. Foster - No distrust in community. Saginaw and Bay County Labor Councils j Pres., Sag. endorse nuclear plant. Only Lone Tree Council wishes to discredit Labor Council plant. Pamphlets are misleading. Only individual marbers of groups AFL/CIO are against plant - not any unions that he kncws of. S. Long - Business person - Member of Midland Chamber of Conenerce. Midland plant needed. I S. Young - Supports completion of the plant. Putting together tri-county V.P. Sag Co. program to support completion of plant. Necessary to future growth Ch. of Comm. of tri-county area. Trust NRC to ensure safe construction of plant.
%- -. - w _ __ .m_ m z _ m e 4 8/11/83 - 7:00PM: L. Romo - All'need jobs and energy. Based on construction record of CPCo, plant cannot be built safely. Rates will
- go up at least 30-35%.
Businesses will not be attracted to area and homeowners cannot afford it. CCP leaves identification of problems to CPCo. 'Itird party should be identifying problems. J. Dumlar - Supportive of forum - Serious doubts about viability of plant.in comununity and state. Can justify licensing of plant for presumed benefit of public. Site too close to dense population and is there-l fore not safe. Evacuation - Construction problems - Silence from l licensing board. Divisive atmosphere in community. Adequate health and safety of public must be assured. Plant cost - Plant safety - - Citizens confidence. Darl Hood - Evacuation (Emergency Planning) calls for a drill of evacuation plan for area. Drills are at least one year away. Those factors are taken into consideration. Siting was considered during construc-tion permit stage. Plant was justified for this site and plant was approved. Eisenhut - Citizen confidence - Reason for. meetings - why we're here. Confidence serious question for us, too. G. Yobst - Midland Resident 4 1/2 years. Read letter from another pipefitter. Pipefitter First-class workmanship. Need plant. T. Miller - Integrity impugned by previous speaker. Don't have total community support, but our support is not marginal. Do not consider ourselves splinter group. We are an outreach group. What is behind all the problems? Kappler - Seems to be implementation of the programs. Third party overview will remain until we have confidence in CPCo. Management is ulti-mately responsible. Wm. Welch - No single issue more important to our conununity than the completion Exec. V.P. and licensing of the plant. Not experts on nuclear safety, but trust Midland NRC to see,that plant is built safely. Seems to be a great deal of Ch of Conan quibbling between NBC and CPCo of non-substantive issues. Impose reasonable standards on CPCo, but get it done. We all contributed j to the cost by. allowing the process to drag out for so long. Issues are talked about in irrational terms. Trust NRC to expedite comple-tion of the plant. A. LaBrose - Quality - can't insulate until all welds are checked. Have been insul-checked, re-checked and re-checked. ator G. Wilson - Plant wasn't needed. Will be too costly to afford. Plant badly Sag Auto built. Plant should be closed down. If it has to be built, build worker it safely. 5 i i ~
www .e - .. w :.w...= ~ l*e 8/11/83 - 7:00PM M. Corbett - Last man lied. Men know what'they're doing. Men take pride in their job and try to do their best. L. Hallberg -Jobs are important in area right now. Jobs have been lost because of impact of plant on Dow. NRC pointing finger at CPCo management. CPCo has not earned the confidence of the people. If CCP fails, CPCo can just come up with a new plant. Keppler - Our view is not whether it should or should not operate, but that it operate safely. Two years ago, I was extremely down on CPCo operating plants, particularly Palisades. They've turned that around. We're hoping they do the sc ne at Midland. B. Wilson - Don't represent anyone. Member of Lone Tree Council Have heard attacks here on people like Terry Miller. I think their concerns are genuine and they have no ax to grind. Am concerned over cost of nuclear plant. Safety will lose out against almighty buck. i Eisenhut - Program will not be ranuned through because of financial considera-tions. Has been going on for many months much to dismay of CPCo. R. McCauley -People who are eventually going to live in community are best quali- ~ plant fled to inspect the plant. worker Quality of wor 1r==nahip couldn't be better. Why depend on other coun-R. Young Electrician tries for fuel. Why not depend on ourselves. E. Ivey - Has interest in economic welfare of this community. Would be economic disaster for community if plant is not licensed. s B. Garde - Soil settlement, cadweld problems not Terry Miller's fault or anyone GAP elses. CCP is plan that a lot bf people have put effort into. Ms. Rosingard - CCP - Bear in mind that a system of checks and balances does not work very well when it is within one entity. Decision for third party overview a good decision, but may be too late. G. Carson - Commend NRC for effort to ensure safety. of plant. Need the power. Midland No acid rain from nuclear plant. Clean energy is needed for this Molecular area. No reason to expect why we cannot in time learn to use this Institute energy. D. Ellis Need to attract new business to Michigan. Completion of plant is U of M needed for development of Michigan economy. Some of cost increases Flint Camp. are due to hearings such as this. GAP is supported by IPS which is Econ Prof an organization of very far left. GAP may have a hidden agenda. Sister Platte-Assured us that there would be independent audit - open process.. Sag City Coun-Read now that after CPCo sights the problems, then there wouId be cil a solution to them. Pressure on us is enormous because there are l not enough women. Have to be committed to the little people of the community in order to restore credibility. Must assure us 3 that the waste can be disposed of safely.
\\ 8/11/83 - 7:00PM Keppler - Allegations have been, are being, or will be investigated by the NRC. We believe that the CCP should be a viable program. Platte - Think you need a more independent process for CCP. S. Black - Need necessary energy for welfare of Michigan. To put Michigan Conan. for To put Michigan citizens back on the job. Jobs G Energy D. Erskine - We need the safe nuclear power plant in Midland. farmer J. Tanner - Will employ those people until plant is completed. Atty General Lone Tree says there will be a 65% increase in rates. How will this affect Council jobs? Decrease after plant is built. Aug. 2 Wall Street Journal says " Nuclear power is twice as expensive as coal-fired plants and can't be operated efficiently". Will have 54% more energy than needed when plant is completed. Eisenhut - Avg. plant has 50% efficiency rate? Tanner - Yes - stated in article. Eisenhut - 54% too much energy? What were you referring to? Tanner - Mr. Miller says 83% is plant operates. Eisenhut - Must have enough to cover peak load, so if average is considered, of course, it would be in excess. Siebert - Can hear warning system very well in house with windows closed. plant work-Live seven miles from plant. er Cameron - Born and raised in Midland. Want plant completed, built and operated safely. M. Kearn - Plant has been constructed under a microscope. Have confidence in Pres., safety of plant. Asset to business growth. Get on with the task. Freeland Area Ch of Comm. (No name) Plant built by organized labor. No one would be fired for complaining Hemlock about shoddy work. V. Castellano - Ingersoll Township goes on record as being against the Midland plant until all safety issues are resolved. Mismanagement. Since Dow has terminated contract, they will continue with their H plume (thermal discharge). We will now have two thermal plumes in the Tittabawassee River. Higher toxicity on aquatic life. s
e I 8/11/83 - 7:00PM Keppler - Not prepared to respond to this. We will get back to you later. J. McFarland-Don't worry about cost. I work under tightest rules I've ever worked Plant under. Watched too close to get away with anything. I believe it's worker safe. J. Secord Am relieved to hear a more balanced viewpoint than in the past. There will always be someone who is unhappy. Can't wait to please everyone. 1 P. Sole - Regarding Sister Ardith Platte's conments regarding pregnant women pregnant being worried about plant. I'm not worried. I work with these people CPCo worker and know they're qualified. We need this plant. i Eisenhut - Two sides to every argument. Appreciate sincere comments made. Some things are beyond NRC control. A lot of questions inferring that CPCo management is the problem. Would like to ask Jim Cook to comment. l J. Cook - Difficult to give single response. Been a very changing business. Much more sophisticated. Impressed with resiliency of the people who are there. Proud of training center we have built. Same kind of dedicated people on construction site as there are in operations dept. Kappler - Have been receiving CCP since beginning of the year and have resolved a lot of problems. Would like to hear your articulation of what you believe the problems are at' Midland. J. Cook - Have not met our own expectations. The plant / hardware is as stout as anyone around, but not everyone can know all the ramification of workmanship not exactly matching drawings. Think that is our main problem now. Other problems over the years have been fully addressed and solved as they occurred. Eisenhut - Regarding comment about people feeling pressure of losing their jobs. Do you feel you have a system in place where the worker can feel comfortable coming forth to management without any reprisals? J. Cook - I believe we do. Don Miller and his staff have an excellent rela-4 tionship with the crafts people. Also have a formal system for investigating concerns. Also would like to offer my own telephone number to anyone who feels they are not getting a positive response. Will set up a system and post it around the site. Keppler - Thank you for coming tonight. Planning to hold working level meetings in the area monthly. 4 + l , -. - - - - ~. -,,, -.,. ~. - -., - _.... ~., - -.. -. -.
r ] i PUBLIC MEETING 8/11/83 2:00 PM Quality Inn Conf. Room NRC ATTENDEES: INT"RVENOR ATTENDEES: c Darl Hood B. Stamiris Jim Partlow Lucy Hallberge Jim Stone Leo Romo Ron Cock B. Garde Tom Novak Terry Miller Jim Lieberman Kathy ---- Darrell Eisenhut Joel Tanner Jim Keppler Bob Warnick Elinor Adensam Jay Harrison Ron Gardner Russ Marabito Keppler - Opening statement - Close to approving CCP. All comments today will be considered. Jay - Slide presentation Stamiris - Where are you in CCP approval? B. Garde - Will want more details on first phase Keppler - In Mgmt & Review Phase now? Jay - Yes. Eisenhut.- Schematic laid out by CPCo and added to by NRC? Jay - Yes. Eisenhut - These are things to be done to make the CCP acceptable. Jay - Have proposals which have not yet been made to CPCo and CPCo will have a chance to rebut. B. Garde - Want time for written comments. Keppler - If CPCo adopts suggestions, NRC will approve unless substantive comments. )
(- (. i l 8/11/83 - 2:00PM f Jay - NRC hold points requiredt Training /recertification of QC inspectors Prior to initiation of Phase I Prior to initiation of Phase II Hold points will be in place until were satisfied. B. Garde - What are you going to look at? Pipe hangers? Jay - Already started pipe hangers. Will be looking at --- hangers as well. B. Garde - Hanger reinspection for example - More scrutiny on first than on later? Jay - Not going to tell them what we're going to do. B. Garde - How is public going to know your inspection is adequate? If you only spot check? Jay - Don't know how much will be inspected. Won't know until we reach a confortable point. B. Garde - Management review or paperwork review? Jay - Did management review last week. Everything o.k. Found problems with procedures. Keppler - Will go into this with enough depth to have confidence in CPCo. Hold monthly meetings to give public confidence and be able to assess how things are going. B. Garde - Perfectly reasonable. Don't like announced inspections, but that's assuming S&W is looking closely at CPCo. Jay - When we're satisfied - we'll lift the hold points and CPCo will be able to continue. Do not want to have to approve every step such as we are doing in soils. B. Garde - That's what I would like. B. Garde - Describe second hold point. Jay - After completion of all these activities will start on Phase 2. B. Garde - Saying NRC will take team in on each system? Jay - No - not 100% inspection. Just want to know system is working. To do what you want would require one on one. Random checks. When confident - will lift hold point and go into normal inspection mode. Keppler - Will check heavily at first and then back off. Placing a lot of emphasis on third party and very thorough review before lifting hold points. b - --
.. y. p_m _ _. - m .~_ ~, . = mm--__.y 8/11/83 - 2:00PM B. Garde -- You trust CPCo. We don't. Don't feel Jay's explanation is adequate. Keppler - What do you want? B. Garde - Explained in 6/13 letter. Want to wait until Jay is done. Kappler - Don't want to argue. Want to hear your views. Maybe comunents by ~ S&W. S. Baranow - We believe it is an adequate progran:. B. Garde - Rev. 17 S. Baranow - Yes. Management Review meetings and training is our involvement now. S. Baranow - Intend 100% evaluation of inspection training. Adequate so far. How many on staff? S. Baranow - Nine. B. Stamiris -Same nine people who are reviewing soils? S. Baranow - No. Eisenhut - What will S&W's role be to verify that CPCo has done adequate job? S. Baranow - Have developed check lists which will be used in each room to physically verify that CPCo did an adequate job. Eisenhut - What kind of inspections. Give me a flavor. S. Baranow - Developed addressing all the important points of PQCI. Eisenhut - Make determination that CPCo has done an adequate job? S. Baranow - Yes. L. Hallbierg-Will have more than nine? How many. S. Baranow - As many as necessary. If fifty are needed, will get fifty. Jay - Next step will be to bring staff up to fif teen. Baer - No restrictions on budget or personnel. B. Stamiris - What assurance that HVAC as-built is adequate? ] Jay - NRC and TERA and S&W are looking at them. I
_ _ ~. 8/11/83 - 2:00PM Keppler - Concerns about Zack date back in time. Assigned group to look at Zack from CSC. Onsite inspection going on right now. Interviews with people who have concerns. B. Stamiris -Why did it not stop. Why exempted? Kappler - We found CPCo was controlling it. No basis to stop work on it.,_ warnick - Good reports from inspectors. No history of problems. Keppler - If we need to include it in CCP, we will. Jay - R. Cook very satisfied with welding procedure. B. Garde - How much has been ripped out since 1979/807 R. Cook - Work looked at by CPCo. Guess would be 1/3 torn out and a lot reworked since the 1980 period. CPCo doing QA/QC. Didn't work when Zack did their own. CPCo doing 100% inspection. B. Garde - How much has had to be redone. Will that be in Zack report?. Warnick - Yes B. Garde - Going to put procedures checklist in PDR7 Jay - Yes. Leo Remo - What will be verified under Phase I? Jay - Reinspection of work already inspected. L. Romo - S&W7 B. Garde - Does S&W methodology describe how much will look at? Baer - Not 1004 - Random sampling. B. Garde - Does detail how much to look at? Baer - No. S&W putting it's reputation on the line. B. Garde - Think S&W reputation already tarnished by work done at other sites. Will trust because work is adequate not because of reputation. Eisenhut - If sample not good enough - will increase sample. Difficult to instill confidence once lost. i e
= 1 v 4 8/11/83 - 2:00PM -5. B. Garde - Pleased with TERA's methodology. Have confidence in Jay and the team. I trust them. Public has lost confidence and wants to know what's out there. Working out problems on methodology will prevent having these meetings. Eisenhut - Will be heavy amount of overview but process will not work perfectly from the beginning. Kathy - We are confident in NRC, Midland. When will there be more? Kappler - Seven more people for Midland and Zimer working out of Illinois. Maybe one more resident at Midland. Kathy - Time frame? Keppler - No. B. Garde - Battered out over about 6 months the TERA program. Jay - Seven months on CCP already. B. Garde - Only three pages on S&W to look at. Jay - Will give sample procedures for you to look at with S&W approval. Jay - Correction - Something less than 100% of Zack reinspection by NRC. GAP 2.206 request (1) Don't feel modifying CP is needed at this time. (3) Do not intend to reject either (4) Will not require because would take NRC out of regulatory posture. (5) Will make increase in staff. (6) Issues have been reopened. Task force put together and issues will be reviewed. Jay - Conclusions B. Garde - Focus comments around issues raised in 2.206. Major problem with CCP as presented and your review goes back to quality verification of CCP Review. Feel confident of training, team training and statistical sampling plan. Not a lot of rrom for negotiations or presentation you have made. Original request for third party review still needed. Want to know methodology. Will do conscientious review. S&W not adequate. Teams spotcheck o.k. Keppler - S&W material will be put in PDR. Terry Miller - Want to thank NRC, etc. Oppcsed to plant. Unnecessary, costly. Endorsed by mayors of any City and Saginaw. This company should not be allowed to verify their own construction. We have no trust I in this company. Keppler - Could comment on overviews? Miller - Extremely impressed. Many things excellent. Third party shoundsuper-vise the continuing construction. Public is aware CPCo is under the
~ -. s,e, - z_. .. g _ m.m.. -- -_m ..m m.- ~.. 8/11/83 - 2:00PM gun as far as cost and scheduling. In paper daily. Tri-county cosmunity skeptical about program allowing utility to oversee their own construction. Kathy - Education campaign started in June. Brochures (Cost, Danger in Operation). People feel impotent:to fight. Tanner -~ - Soils settlement problem. Will NRC make'their data available to an outside consultant. Eisenhut - Is all CPCo data. B. Garde - What kind of input would that expert have if we could raise the . money to get him? Eisenhut - Provided resumes of.five individuals who are noted in their field, brought in by Brookhaven Labs., and two other specialists. Will look at all records and information available - go out to the site. Am sure they will be happy to meet'with your expert.- Cannot commit beyond that. Tanner - Will he have available to him, every bit of data he will need? Eisenhut - It's all in the PDR. B.~ Garde - Can let us know in a day or so the boundaries of his involvement?
- 8. Stamiris -Opinion on D. G. Bldg.
Eisenhut - Congressional hearings first time I heard views against D. G. Bldg. Asked everyone else if they disagreed and no one else did. Romo - People in Tri-cities have lost trust in CPCo. Outline shows why. What about that which is not accessible? How can that be reviewed and what is percentage? Jay - Can only look at records on some things. Program set up on how to administer. i B. Garde - Outline of CCP is not specific on what is and is not accessible. What plans have CPCo put forth to ---. Why do you think docu-mentation review is accepcable? Jay - Can't assume everything inaccessible is unacceptable. Will have to see what documents show us. I Kappler - If five of fifteen accessible welds are bad - something would have to be done. If all fifteen were good, assumption would be that inaccessible welds would be good as well. i e i
3 - - - ~.. . ~. .e 8/11/83 - 2:00PM B.' Garde - Have considered a CAT inspection? Keppler - No. Have other plants that need to be looked at. i Jay - Dedicated staff such as we have is much more effective. Reinforcing steel .many of the problems were way back when.- Can't assume whole plant is bad because of what happened in D. G. Bldg. Lucy -' Will we ever know what percentage of problems are inaccessible? Kappler - Oh sure. . Lucy - How does Zimmar QCP compare to CCP? i. Warnick - Both require backward look. Both require work to be done by the utility. Identified over 15.,000 nonconforming conditions. Stopping work not related to QCP Keppler - QCP working so well, it was almost a chaotic situation. Trying to fix things up before ---- Luch - Why not take away QA/QC from CPCo now. s 1Keppler - Must instill in utility a sense of responsibility to do the job. I Eisenhut - Hot in charter to overview or supervise. If it is completed, CPCo will have to operate it and you have to have confidence in them. Romo - What will happen if CPCo messes up again. Kappler - Things will come to a halt again. Eisenhut - Won't get a license if NRC doesn't have confidence. Stamiris - Isn't the close scrutiny by the NRC and the CCP itself a testimonial to your lack of confidence? Eisenhut - Not at all. ------No confidence without third party review. Stamiris - tbn't you feel that allowing CPCo to go in to identify problems that exist poses an inherent conflict due to their financial problems? 1 Eisenhut - (Couldn't get it) B. Garde - Summary comments - CPCo shoud not be trusted. Until public and you know what is on that site --- Not totally comfortable with S&W. Can't make committments to rest of program until we know ---. CPCo developing plan to meet your requirements not to deal with the problem that is out there. NRC hold points were not in first couple of versions of CCP. If plant operates one day, cost can be put in rate i base. . ~..
a- , ; n: l [' -1 l 8/11/83 - 2:00PM. Kappler.- Jim Cook, do you have anything to say? J. Cook - Team that is on site is eager to turn opinion around of NRC and public. - Will try to show all of you with our actions. O b
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cf .s***"'., UNITED STATES f, NUCL, EAR REGULATORY COMMISSION
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REGiord if1 %,;, g / J.,,e 7ss noosEvsLT noAo-
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/ January 6, 1983 NOTE TO: W. Schultz J. Keppler B. Davis S. Lewis wif. Shafer FROM: R. Warnick This is a polished draft of the proposed Midland escalated enforcement package. Bill Schultz is reviewing it to make sure it is in the proper format and that it is a good complete package. We will hold the enforcement conference with Jim Cook and others on January 18 in RIII at 10:00 a.m. If you have any comments or questions, please contact me or Schultz. R. F. Warnick 4 .r. l - I 6 e
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s., ,4.. 4 mu. e f e. OPENING REMARKS JM ES G. KEPPLER REVIEW OF INSPECTION FINDINGS WAYNE D. SHAFER RESPONSE IF DESIRED CONSUTRS POWER COPPANY WERE DO WE GO FROM HERE? J#ES G. KEPPLIR OTER l%TTERS J#ES G. KEPPLIR S i r y
.'k b f 1~ ITFM 1 CRITERION III: DESIGN CONTROL SIX EXAPRES OF NON00PPLIANCE. TE FOLLOWING ARE EX#RES: 1. EASURES WERE 10T ESTABLISED FOR TE SELECTION AND REVIEW FOR SUITABILITY OF APPLICATION OF MATERIALS ASSOCIATED WITH TE N DIESEL GEEATOR EXHAUST MFFLER. 2. TE FAILLEE TO ANALY2E TE F0lR DIESEL GEERAM BUILDING P0NORAILS L AS SEISMIC CATEGORY 1. gg 3. m uCENSEE DESIGNED AE QWRUCTED THIRTY-TW DIESEL GENERAM2C BUIGIE EXHAUST SYSHM HANGERS WHEUT MNSMTIE M MUCRE p g, q REEllATORY RERJIREPENTS INTO DESIGN DOCTENTS. FSA /l,4 M [^ 2). m& 9tr i ~__.__-.7 ,-_....,..--._,-.-,...-.------,4, . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - ' - - - - - - -
i 4 CRITERION V: INSTRUCTIONS, F90CEDURES, AND DRAWINGS SEETEEN EX#RES OF NONCOPPLIANCE. TE FOLLOWING ARE EXAIPLES: 1. FAILURE TO INSTALL DIESEL GEERATOR ENGIE CONTROL PAELS IN ACCDRDANCE WITH REQUIREPENTS AND DRAWINGS. 4 e 2. FAILIFE TO IDENTIFY BY YELLOW PAINTED ENDS #0/0R SEGREGATE 10N-Q STOCK STEEL. 3. FLAPE C11TTING OF DIESEL GEERATOR RFFLER StPPORT SLDTS IN VIOLATION OF TE VEP00R DRAWING. l 14. TE EIGHT BRACING TOP GUSSET PLATES FOR TE INAC FAN SLFPORT ERE NOT SIZED ACCORDING TO SPECIFICATIONS. l l 1.
O CRITERION VI: D00MNT CONDOL OE EX#FLE OF 10NC&PUANCE: PEASUES WERE MR ESTABUSED TO ENSLEE THAT 19NGER ISOETRIC DRAWINGS ERE DISTRIHRED TO TE SITE DOCTENT C0lGROL CENTER. i 0 w., -n , - - - - + - - - - ,,w-
~ CRITERION VII: CONGOL OF PURCHASED MATERIAL, EQJIITENT AND SERVICES OE EWPLE OF NONCOIPLIANCE: TE FAIUJRE OF SOURCE INSPECTIONS AT TE SUPPLIER FACILITY AND RECEIPT INSPECTIONS AT TE MIDUWD SITE TO IDENTIFY NONGNORMANCES OF THE WIRING IN TE DIESEL. GEERATDR ENGIE CDm0L P#El.S. l l l w.-e m. -w,.--. .,.w--- ..p -.y., w-m
l CRITERION IX: C0KIROL OF SPECIAL PR) CESSES OE EX#FLE OF NONCOTLIANCE: TE FAILURE TO VERIFY PREEAT OF EXISTING STRUCREAL STEEL TO A TBTERATURE OF 70* F AS REQUIRED BY SITE SPECIFICATIONS AND TE AWS 1974 CODE. i I
CRITERION X: INSPELTION 1M) EX# MIS OF NONCTFLIANCE: 1. TE FAILURE TO ESTABLISH AN INSPECTION PROGRAM TO ENSURE SEGREGATION OF CONTIOL AIS INSTRLPENTATION CABLES. 2. TE FAILURE OF QC INSPECTIONS TO Ititd.i AND IDENTIFY NONCONFOR%NCES ASSOCIATED WITH TE INSTALLATION OF TE HVAC FAN SUPPORT STEEL. i l I i i
l CRITERION XIII: 1%NDLING, STORAGE AND SHIPPING OE EX#e.E OF NONCOMUANCE: FIVE DIESEL GENERATOR BEARING RFR.ER PLATES ERE NOT MAINTAINED SINCE TEIR INSTALLATION.
e t bh f Id CRITERION XV: NONCOWORMING MTERIAL, PARTS, OR C0FFONENTS TWO EXAPFLES OF NONCOPPUANCE: PEASURES WERE 10T ESTABLISHED TO ENSIRE TMT NON 1. WERE f0T UTILI2ED IN SEISilC CATEEORY I SYSTEPS. % /9. b 2. Th0 NONCDEORMING CONDITIONS IDENTIFIED BY TE NRC AND COWIRTD BY TE UCENSEE WERE FUT DOCUSTED ON A NONCOWORMANCE REPORT. M [4 N Yb"V l^k h @ 9-00 W y d tn - M ivy @ W ed- ,y- - - -n ,,,em.,,,
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s ITEM 2 CRITERION XV: NON00EORMING MATERIALS, PARTS, OR QMUENTS R' s, f' ( A-16 ONE EX#RE OF NONCTFLIANCE: TE FAILlRE OF QJALITY CONTROL INSPECTORS TO DOCLPENT ALL OF Tile DEFICIENCIES MIICH TEY OBSERVED DlRING TEIR INSPECTIONS, e 1 i e . _, _. -.. _., ~.,., -,, _.. ~,, ...,m.
d-O l l SPECIAL HARDWARE INSPECTION OF THE D!FRFI GENERATOR BUILDING OCT.12 - NOV, 25,1982 WE ARE CWSIDERING THE ISSUANCE OF TWO MMOR ITEMS OF NONCOPPLIANE: 1. THE FAILURE TO IIPLEFENT THE QUALITY ASSURANE PROGRAM AS REDVIRED BY CRITERION II. 2. THE FAILURE OF QC INSPECTORS TO D00MNT ALL GSERVED NONC0ff0RMANCES DURING INSPECTIONS. THIS PPACTIE WAS INITIATED AS A RESULT OF MANAGEPENT DIRECTION. 'a y, v.----- v. w-,-.. w-<er+ - + - - - --- - ' - - --a*= e-
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e. a Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATIN: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen: This refers to the special inspection conducted by th's Office of Special Cases, Midland Section, of this office on October 12 through November 25, 1982, of activities at the Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82. The results of the inspection were discussed with you on November 10 and 23, 1982, at the conclusion of the inspection and on January 18, 1983, during an enforcement conference in the Region III office between you and others of your staff and me and others of the NRC staff. The results of the inspection indicate a significant breakdown in the j implementation of your quality assurance program as evidenced by numerous t examples of noncompliance with nine of the eighteen different criteria as i { set forth in 10 CFR 50, Appe1 dix B. 'the breakdown was caused by personnel ~ who failed to follow procedures, drawings, and specification; by first line t 1: ---.,_n,-.
~ o Consumers Power Company 2 supervision and field engineers who failed to identify and correct unaccept-able work; by construction management who failed to call for quality control inspections in a timely manner, allowing a backlog of almost 16,000 inspec-tions to develop; and by quality assurance personnel who failed to identify the problems and ensure that corrective actions were taken. As a result, you failed to fulfill your primary responsibility as described in Criterion 1 of Appendix B to 10 CFR 50; "to assure the execution of a quality assurance program." We understand that as a result of our findings you have inspected other areas of the plant and found similar deficiencies. As a result of our findings and your own findings, Consumers Power Company halted certain safety-related work at the Midland siti, reduced the work force by approximately 1100 people, committed to building cleanup and system layup, committed to organizing teams of construction and engineering personnel responsible for the completion of one or more plant systems, and committed to re-inspect all safety-related systems. i, l In order to'. emphasize the need for CPCo management to ensure implementation i of an effective quality assurance program that identifies and corrects l construction deficiencies, we propose to impose
- civil penalties for the items set forth in the Notice of Violation that is enclosed with this letter.
The violation in the Notice has been categorized at the severity level I described in the General Statement of Policy and Procedure for Enforcement Actions, Appendix C of 10 CTR 50. The base value for the Severity Level II i 4 ' J ---,-----,,.nm,- -,,,-w-.,, +, - -,, ---.---,---,,--,-,---,.-.r.--m-- m- .-, - -, -- - - ~ -,,,, -, - - -
.-~
- Consumers Power Company 3
violation is $64,000. After consultation with the Director of the Office of Inspection and Enforcement, I have been authorized to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the cumu-lative amount of Sixty Four Thousand-Dollars. You are required to respond to this letter and should follow the instructions in the Notice when preparing your response. Your reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate. 1 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclo-sures will be placed in the NRC Public Document Room. The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Mana,gement and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. 3 t Sincerely, 4 i James G. Keppler Regional Administrator a
Consumers Power Company 4
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties cc w/ enc 1: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB i The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.) concurrences: RIII RIII RIII RIII RIII RIII RIII IE:HQ Landsman /jp Gardner Shafer Warnick Lewis Davis. Keppler Axelrad 1/5/83
G NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES l Consumers Power Company Docket Nos. 50-329; 50-330 Midland Nuclear Power Plant Permit Nos. CPPR-81; CPPR-82 Units 1 and 2 l l l i As a result of the inspection conducted at the Midland Nuclear Plant on October 12 - November 25, 1982, the violation listed below with multiple examples was identified. The numerous examples of the violation demonstrate your failure to exercise adequate oversight and control of your principal contractor, to whom you had delegated the work of executing the quality assurance program. Your failure manifested itself in a widespread breakdown in the implementation of your quality assurance program and at least in part caused Consumers Power Company to halt some safety related work and take other significant actions to provide assurance that safety-related structures and systems are constructed as designed. 4 e _________.__________-___m
Appendix 2 In order to emphasize the need for improvements in your management controls, as related to an adequate quality assurance program, we propose to impose civil penalties in the cumulative amount of Sixty-Four Thousand Dollars. In accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C) 47 FR 9987 (March 9,1982), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violation and the associated civil penalties are set forth in Section I below: 10 CFR 50, Appendix B, Criterion II requires holders of construction permits for nuclear power planrs to document, by written policies, procedures, or instructions, a quality assurance program which complies with the requirements of Appendix B for all activities affecting the quality of safety-related struc-tures, systems, and components and to implement that program in accordance with those documents. Coatrary to the above, Consumers Power Company and its contractor did not adequately implement a quality assurance program to comply with the require-ments of, Appendix B as evidenced by the following examples: 1. 10 CFR 50, Appendix B, Criterion V states, in part, " Activities affecting gaality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomp-lished in accordance with these instructions, procedures, or drawings." .~, - : ca -.:. w - .w '-_x w.w - av- " z a. m,w ^'~' "'
.. =___ O Appendi:: 3 Consumers Power Quality Assurance Program Policy No. 5, Revision 12, Paragraph 1.0 states, in part, " Instructions for controlling and per-forming activities affecting quality of equipment or activities such . construction, installation... are documented in instructions, as.. procedures... and other forms of documents." Contrary to the above, the following instances of failure to accomplish activities affecting quality in accordance with instructions, procedures, specifications, or drawing requirements were identified: 4 a. The licensee failed to ensure that the installation of diesel genera-7 tor engine control panels 1C111,1C112, 2C111, and 2C112 was in accordance with the requirements delineated on foundation Drawing 7220-M18-250 in that the foundation bolt washers required by the subject drawing were not installed. l b. The licenses failed to ensure that the unscheduled pull box associ-ated with conduits 2BN006, 2BN007, and 2BDA002 was sized in accord-ance with the requirements delineated on Sheet 42 of Drawing E-42 in that the 12" x 12" x 6" as-built dimensions of the subject pull box did not conform to the 13 1/2" x 12" x 6" dimension requirements delineated on Sheet 42 of Drawing E-42. G l l i l
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Appendix 4 o ,c. The licensee failed to ensure that the l' 10" wall to support Ps dimension required by raceway support Drawing E-796(Q), Sheet 2 of 2 Revision 5, for hanger No. 86 was correctly translated into the as-built installation of the subject hanger in that the as-built wall to support dimension was 2' 1-1/2" in lieu of the required l' 10". d. The licensee failed to ensure that the 6' 6" wall to support dimension required by raceway support Drawing E-796(Q) Sheet 1 of 2, Revision 11 for hanger No.14 was correctly translated into the as-built installation of the subject hanger in that the as-built wall to support dimension was 5' 5" in lieu of the required 6' 6". Field Instruction FIG-9.600, Revision 1, stated in Paragraph 5.1.2 e. for Non-ASME, "Q"-listed steel " Steels other than those listed in 5.1.1 must be marked with the material type and grade (e.g., A-516 Grade 55)." Paragraph 5.1.1 referred to A-36 plato shapes and bars or A-500 Tube Steel. The inspectors identified high strength steel plate (that was not i A-36 or A-500) placed in the laydown area which was not marked with the material type and grade. j i \\ o O . (IA [. geun 4r e r. a e a m Ib
4 Appendix 5 %f. Field Instruction FIG-9.600, Revision 1, stated in Paragraph 5.4.1 ) for Non "Q" steel, "The ends of all material shall be painted yellow with segregated storage provicaed. When Non "Q" material is with-drawn from storage a continuous yellow strip must be painted down one side." The inspectors identified various stock steel shapes in the "Q" area with yellow colored paint on the ends and various steel stock shapes in the non "Q" area without painted ends, g3 Bechtel Vendor Drawing M18-80-4 required the slots in the diesel generator muffler support plate be sized at 7/8" vide by 15/8" long to allow for thermal expansion of the muffler. Bechtel Vendor Drawing M18-425(5)-1 also required that the slots be machined. The slots in the muffler support plates were not machined but were determined to be irregular and flame cut, leaving rough slot edges not in conformance with design Drawing M18-425(5)-1. h. Drawing !!18-250-6 required jacking plates be installed and imbedded in concrete beneath the muffler support jacking screws. The jacking plates were not installed underneath the center support plates of Bay 1 diesel generator muffler. y..r?::
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o. 4 Appendix 6 1. Procedure FID-2.100, " Outstanding FCR/FCN Retirement," Revision 2 did not require for retired FCR/FCN's, that the design drawing remain annotated indicating that an FCR/FCN had been retired. This resulted in retired FCR C-2103 being lost and not tracable to the design drawing. J. Field Sketch CY-1035 was net annotated as "Q", nor was there a reference to the affected drawing on the sketch as required by Procedure FPD-5.000 " Preparation of Field Sketches." k'. Procedure FPD-5.000, " Preparation of Field Sketches," Revision 1 did not require the design drawing to be annotated with a reference to field sketches. (1. The eight bracing top gusset plates identified on Drawing C-1004, Revision 10, as 5/16" thick were measured by the inspectors to be 1/4" thick in all four diesel generator bays. The as-built gusset plate connections in Bay 1 were not built m. as identified on Detail 3 of Drawing C-1004. The angle braces were welded together as opposed to separate welds for each brace. { None of the sixteen 1/4" bracing angles identified on Drawing n. C-1004 were constructed utilizing 1/4" matarial. 1 a
o Appendix 7 Drawing C-1004, Detail 2, required the W10 beam to beam connection 'I o. to be velded. In Bay No. 3, a bolted connection was constructed in lieu of the required welded connection, p. The column cover plate identified on FCR-C4401 was not constructed ) in Bay No. 3 as required. The plate was slotted instead of solid. l q. A section (approximately 18 x 10 x 4 inches deep) of the primary containment wall in Containment Purge Room 702 was removed (by chipping) without implementing FIG-1-111, Revision 4, Concrete Drilling Permit. l ) 2. 10 CFR 50 Appendix B, Criterion III states, in part, "... applicable regulatory requirements and the design basis... are correctly trans-lated into specifications, drawings, procedures,'and instructions. Measures shall... be established for the selection and review for suitability of application of materials, parts equipment, and processes that are essential to the safety-related functions of the structures, systems, and components. Design changes, including field cheages, shall I be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed j l the original design unless the applicant designates another responsible organization."
.__m n c. Appendix 8 ~ Consumers Power Company Quality Assurance Program Policy No. 3, Revision 12, Paragraphs 3.3 and 3.5 states, in part, "Each group or organization performing detailed design translates the applicable regulatory require-ments, design bases, codes, standards, and design criteria into design documents, such as... drawings .. changes to the design require the same review and approval as the original design by the group or 2 4 organization delegated lead design responsibility." i Contrary to the above: ) Measures were not established for the selection and review for a. suitability of application of materials associated with the Diesel i Generator Exhaust Muffler in that design drawings and specifications did not indicate the material identity of the muffler saddle supports and 4ates. Subsequently, the saddle support and plate materials i were selected and installed with no design interface. 1 l b. Design drawi:.3 C-147 required bolted bracing connections for the Diesel Generator Building HVAC bracing ausset plates. Field sketch { CY-1035 was used to change the design to welded connections in lieu 'i ) of the specified bolted connections. i l i l I 5@ '.:.G, i J I 4 w v.w - 'Rw~ -c ? - S- ~ ,os ~, n m -U
j Appendix 9 Design Drawings ::-1004 and C-147 did not specify the sizes of the c. Dissel Generator Building HVAC fan gusset plates. A " combo" shop work order request was used to design the gusset plates without appropriate review and approval. d. The licensee failed to analyze the four Diesel Generator Building monorails as seismic Category 1 as required by Regulatory Guide 1.29, endorsed by Appendix 3A of the FSAR. The licensee designed and constructed thirty-two Diesel Generator a. Building exhaust system hangers without translating the applicable regulatory requirements into design documents. f. The licensee purchased armor stone for a "Q" portion of the perimeter dike without translating the applicable regulatory requirements into appropriate specificati9ns and design documents. 3. 10 CFR 50, Appendix B, Criterion VII states, in part, " Measures shall be established to assure that purchased... equipment . conform to the procurement documents. These measures shall include provisions, as appropriate, fer... inspection at the contractor or subcontractor source, and examination of products upon delivery." ,,-,--.---.-.-.-m- .,,--..-.,...,---._--._---.--------4-,-#
m-c. _ ,. m m _- _ - - - - - - -,... _ w ~. Appendix 10 Consumers Power Quality Assurance Program Policy No. 7, Revision 12, Paragraphs 1.0 and 3.4, states, in part, "The Midland Project Office and the Midland Project Quality Assurance Department verify that procurement requirements are met. This is accomplished through... source evaluation and inspection. . receipt inspections are made to verify that the items. conform to procurement requirements not verified by source surveillance or inspection. Contrary to the above, source inspections at the panel supplier facility and receipt inspections at the Midland site failed to ensure conformance of the internal wiring within diesel generator engine control panels 1C111, 1C112, 2C111, and 2C112 to Procurement Specification 7220-G-5, Revision 1. Paragraph 6.0 of Specification 7220-G-5 states, "All electrical wiring. within the board enclosure shall conform to the highest industrial standards of design and workman-ship. NRC inspection on October 15, 1982 identified the following examples of defective terminations of internal wiring within the subject panels. a. The output lead on the Relay Tech device had numerous broken conductors at the termination lug. b. The K1 lead on the Relay Tach device had two broken strands resulting in a potential short circuit between the K1 lead and an adjacent conductor. ..e _. m
_= mn _. _ _ m ) Appendix 11 c. The 1-lead on the CB-1 device did not have all strands inserted into the compression lug. 4. 10 CFR 50, Appendix B, Criterion X states, in part, "A program for inspection of activities affecting quality shall be established and executed... to verify conformance with the documented... drawings for accomplishing the activity." Consumers Power Company Quality Assurance Program Policy No. 10, Revision 12 Section 1.0 states, in part, " Inspection and surveillance are performed to assure that activities affecting quality comply with documented.. design documents. inspection and surveillance are performed according to written instructions." Contrary to the above: An inspection program was not established for inspection of cables s. installed in horizontal trays which used metal dividers to segregate 4 control and instrumentation cables per design requirements. b. Quality Control (QC) inspections failed to ensure that activities affecting quality conformed to design documents in that QC inspec-tions performed on July 1,1981 and documented on QCIR C210-172 failed to detect and identify nonconformances 1.(e) through (o) of
7 -.m ~ _ _ _ o D Appendix 12 this appendix. These nonconformances were associated with installa-tion of the Diesel Generator Building HVAC fan support steel. 5. 10 CFR 50, Appendix B, Criterion XIII states, in part, " Measures shall be established to control the... cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration. When necessary for particular products, special protective environments... shall be specified." Consumers Power Company Quality Assurance Program Policy No. 13, Revision 12, Paragraph 3.3, states, in part, " Suppliers provide plans... saintain and control items upon arrival at the site." Contrary to the above, five of sixteen installed diesel generator bearing suffler plates were sufficiently warped to allow the inclusion of dirt and dust and were not maintained since their installation. 6. 10 CTR 50 Appendix B, Criterion IX states, in part, " Measures shall be established to assure that special processes, including welding, heat-treating, and nondestructive testing, are controlled..." Consumers Power Company Quality Assurance Program Policy No. 9. Revision 12 Paragraph 1.0 states, in part, "Where the required level of quality cannot be measured by inspection only of the item... acco4plish these
,~ m. s, Appendix 13 processes under controlled conditions in accordance with applicable codes, standards and specifications using qualified procedures, equipment and personnel." Paragraph 3.3 states, in part, "... Personnel performing 4 special processes maintain records to verify that the required activities were acceeplished in accordance with qualified procedures by qualified f personnel." l Contrary to the above, during welding of the Diesel Generator Building exhaust piping hanger support steel, the licenses did not verify preheat of existing structural steel to a temperature of 70*F as required by site specifications and the AWS 1974 Code. 7. 10 CFR 50, Appendix B, Criterion I states, in part, that " Measures shall be established to control the issuance of documents,. in-l cluding changes. 1 J ] l The Consumers Power Company Quality Assurance Program Policy No. 6 I Revision 12, Paragraph 1.0 states, in part, " Measures are included,to assure that documents, including changes,... are distributed according to a controlled distribution to the user functions," contrary to the above, measures were not established to control the distribution of changes (red lines) to hanger isometric drawings in that changes to Drawing 1-632-2-25(Q) were not distributed to the-Site Document i i Control Center.
J.. = n,z-m 5 Appendix 14 8.- 10 CFR 50, Appendix B, Criterion XV states, in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation." Consumers Power Quality Assurance Program Policy No. 15, Revision 12, Paragraph 1.0, states, in part, " Items, services or activities which are deficient in characteristic, documentation or procedure which j renders the quality unacceptable or indeterminate and which is con-sidered significant to safety are identified as nonconformances. Non-4 conforming items... are identified by marking, tagging, segregating or by documentation. Nonconforming items are controlled to prevent i their inadvertent installation or use. Nonconforming items and acti-4 [ vities are recorded and are considered for corrective action to prevent ] recurrence..." I j Contrary to the above: a, Quality Control inspectors were not identifying as nonconformances t all of the deficiencies which they observed during their inspections. Inprocess inspection notices (IPIN's) associated with suspended in-spections identified as nonconformances only a portion of the observed l deficiencies. Supervisory QC personnel stated that they directed t QC insper. tors to limit the number of nonconformances documented during i an inspection. This directive was verified by discussions with QC 4 i 1
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.w,w -- -~ --a w. -;a .2 w Appendix 15 inspectors. As a result, measures were not established.to prevent the continued installation and use of these nonconforming items. In addition, corrective actions.sess were not implemented to prevent recurrence of these nonconformances. b. Measures were not established or implemented to determine if materials ultimately restricted (per Nonconformance Report No. 3266) from in-stallation or use in ASME Class I systems were actually installed or used in Class I systems. NCR 3266 originally permitted unrestricted use of material that was subsequently restricted from Class I systems. c. As of November 10, 1982, two nonconforming conditions identified by the NRC on October 12, 1982, and ' confirmed by the licensee on October 19, and 25, respectively, had not been documented on a non-conformance report, a quality assurance report, or other appropriate report. The two nonconforming conditions were: (1) The diesel generator exhaust hangers were not classified, designed, or built as Q. (2) The design of diesel generator monorail was not analyzed using to Seisme Category I design requirements. This is a Severity Level II violation (Supplement II). t . _3 .-..a. .. s. /. w..._.. g, ...~. 7 p e r-.../O_7 I. g.}... } ,.,7.- -u. -. - _..___.,m.. _,u--_-.
Appendix-16 Pursuant to the provisions of 10 CFR 2.201, Consumers Power Company is hereby required to submit to the Director, Office of Inspection and i Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555 and a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137, { within 30 days of the date of this Notice a writtsn statement or explana-tion, including for each a'lleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation, if admitted; (3) the l l corrective steps which have been taken and the results achieved; (4) the t corrective steps which will be taken to avoid further violations; and (5) the i date when full compliance will be achieved. Consideration may be given to extending the response time for good cause shown. Under the authority of i Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under i oath or affirmation. l I Within the same time as provided for the respo'ase required above under 4 10 CFR 2.201, Consumers Power Company may pay the civil penalties in the cumulative, amount of $64,000 or may protest imposition of the civil penal-ties, in whole or in part, by a written answer. Should Consumers Power i Company fail to answer within the time specified, the Director, Office of 4 Inspection and Enforcement will issue an order imposing the civil penalties l proposed above. Should Consumers Power Company elect to file an answer in accordance with 10 CFR 2.205 protacting the civil penalties, such answer may j (1) deny the violations listed in this Notice, in whole or in part; (2) demon-t ,,--,.-r_,-- , _ _.... -,,, _ _. ~.. _ _.. _,_,_,.m., _-,_,.m .,~___m,.. .-___,_-._.c,_. ,,_m-
_ _.m. m_ e. Appendix 17 strate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalties should not be imposed. In addition to pro-testing the civil penalties, in whole or in part, such answer may request remission or sitigation of the penalties. In requesting mitigation of the proposed penalties, the five factors contained in Section IV(B) of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CTR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CTR 2.201, but may incorporate statements or explana-1 tions by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. Consumers Power Company's attention is directed to the other provisions of 10 CTR 2.205, rosarding the procedures for imposing a civil penalty. Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CTR 2.205, this mayyer may be referred to the Attorney General, and the peaalties, unless compromised, remitted, or nitigated, may be collected.by civil action pursuant to Section 234c of the Act. 42 U.S.C. 2282. FOR THE NUCLEAR REGULATORY COMMISSION l
n... - ~ ...- __ _ _ n.__ .o Appendix .18 James G. Keppler Regional Administrator Dated at Glen Ellyn, 1111acis this day of 1982 9 0 e
= ~. Appendix A Index Appendix Item Report Item No. Section 1.a 329/82-22-02A 3.a 330/82-22-02A 1.b 329/82-22-02B 4.a.(4) 330/82-22-02B 1.c 329/82-22-020 4.b 330/82-22-020 1.d 329/82-22-02D 4.c 330/82-22-02D 1.e 329/82-22-05A 6.a 330/82-22-05A 1.f 329/82-22-05B 6.b 330/82-22-05B 13 329/82-22-09A 7.b.(1) 330/82-22-09A l [
l e l 2 Appendix Item Report Item No. Section 1.h 329/82-22-09B 7.b.(2) 330/82-22-09B 1.1 329/82-22-18A 10.b 330/82-22-18A 1.j 329/82-22-18B 10.c.(2) 330/82-22-18B 1.k 329/82-22-18C 10.c.(3) 330/82-22-18C 1.1 329/82-22-16 10.a.(1) 330/82-22-16 1.m 329/82-22-16 10.a.(2) 330/82-22-16 1.n 329/82-22-16 10.a.(3) 330/82-22-16 1 1.o 3I1/82-22-16 10.a. (4) 330/82-22-16 ,-m, y -n-.-r 3 -w.+y
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'.a e a-S Appendix Item Report Item No. Section 8.c.(1) 329/82-22-12A 8.a 330/82-22-12A L 8.c.(2) 329/82-22-123 9 330/82-22-12B O e e
- e. -m-_,m_; ,.mam2 _s_% y. e a U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-329/82-22; 50-330/82-22 Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Plant, Units 1 and 2 Inspection At: Midland Site, Midland, MI Inspection Conducted: October 12 - November 25, 1982 Inspectors: P. A. Barrett B. L. Burgess ,_,,_.,m _,,__i_------.,.f,. m wr. ,,,_y_. _ - w-gw-,, y -,e-,-- 7
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y w. i R. J. Cook R. N. Gardntr R. B. Landsman Approved by: W. D. Shafer, Chief Section 2, Office of Special Cases Inspection Summary 1 Inspection on October 12 - November 25, 1982 (Report No. 50-329/82-22: 50-330/82-22) Areas Inspected: Licensee actions on previously identified items; special inspection involving electrical, mechanical and civil components of the Diesel Generator Building; control of concrete chipping; control of electrical cable segregation; review of Remedial Soils requalification activities; peri-meter dike armor stone activities; prestartup test; ultrasonic testing of hold down bolts. The inspection involved a total of 556 inspector-hours onsite by i five NRC inspectort including 72 inspector-hours onsite during off-shifts. Results: Of the areas inspected, no apparent items of no'ncompliance or devia- ~
aw- .s tions were identified in four areas. Noncompliances identified in the remain-ing areas were as follows: Noncompliance Report Section Criterion III - Failure to establish adequate 7.a. 8.a. 9, 10.c.(1), design control measures 10.c.(4), 25 Criterion V - Failure to develop adequate 3.a, 4.a(4), 4.b, 4.c. procedures and failure to 6.a 6.b, 7.b.(1), 7.b.(2), accomplish activities affecting 10.a, 10.b, 10.c.(2), quality in accordance with 10.c.(3), 17 instructions, procedures or drawings Criterion VI - Failure to establish measures to 12 control the issuance of documents, including changes Criterion VII - Failure to conduct adequate 2.b component source inspections and receipt inspections Criterion IX - Failure to establish measures to 8.b control special processes a 3
p._ m _ m_.- 4 Criterion X - Failure to establish an inspection 10.a. 18 -program and failure of QC inspections to identi'v aoncenformances Criterion XIII - Failure to establish measures 7.b.(3) to maintain and control the cleaning and preservation of equipment Criterion XV - Failure to establish measures to 5, 8.a, 9, 14.b control nonconforming materials, parts, or components i e e 4
DETAILS ~ Persons Contacted Consumers Power Company J. W. Cook, Vice President R. Welles, Executive Manager D. B. Miller, Site Manager M. L. Curland, QA Superintendent R. L. Akers, MPQAD J. G. Balazer, Construction Engineer E. M. Evans, Construction Engineer L. R. Howell, MPQAD - D. D. Johnson, Construction Engineer E. Jones, MPQAD G. B. Johnson, Construction Engineer J. S. Kreple, Construction Engineer G. M. Murray, Construction Engineer B. H. Peck, Construction Engineer D. W. Puhal*1a, Construction Engineer G. W. Rowe, Construction Engineer M. J. Schaeffer, MPQAD D. E. Sibbald, Construction Engineer T. A. Spelman, Construction Engineer 5
__-w~m ~ .,7m,. D. J. Vokal, Construction Engineer R. M. Wheeler, Construction Engineer. R,. H. Wieland, Construction Engineer J. T. Walton, Construction Engineer R. E. Whitaker, Construction Engineer l Bechtel Power Company H. Wahl, Vice President and General Manager K. Vassar, Manager, Division of Project Operations and Services J. Rutgers, Project Manager L. Davis, Site Manager M. A. Dietrich, MPQAD P. Corcoran, Resident Project Engineer J. J. Gilmartin, Field Engineer , B. R. Kappel, Resident Engineer F. H. Schulmeister, MPQAD E. Smith, PFQCE Other licensee and contractor personnel were routinely contacted during. the course of the inspection. 1. Licensee Actions on Previously Identified Items (Closed) Deviation (50-329/82-11-01; 50-330/82-11-01): The licensee I failed to use approved installation / coordination forms during the t i. 6 i
+ - a 1 I installation of affected underpinning instrumentation. As documented in Inspection Report No. 50-329/82-18; 50-330/82-18, the inspector verified that the licensee was properly documenting the installation of underpinning instrumentation on attached installation / coordination forms. During this inspection the inspector reviewed Bechtel Power Corporation Procedure FPU-1.000, Revision 0, which delineated procedures for the i preparation, approval, and use of the subject installation / coordination forms. The inspector determined that the Bechtel procedure was acceptable. Functional or Program Areas Inspected 2. Electrical Cable Terminations 1 An inspection of completed Class 1E cable terminations in Diesel Engine Control Panels 1C111, IC112, and in Diesel Generator Control Panel IC231 was conducted. During this inspection internal wiring terminations and field terminations were observed. The internal wiring terminations were accomplished by the panel supplier during the manufacture of the panels while the field terminations were accomplished by onsite Bechtel electriciana. t a. The following field terminations were observed: Cable Scheme Number Location of Termination 1AA0502M 1C231 1AA0502R 1C231 l t 7 _._..___._..,.____,-__...-_y,,
.u o - A _:. A_ -m. Cable Scheme Number Location of Termination 1AD1201A IC231 1AG1101B IC231 1AG1101C 1C231 1AG1101F IC231 1AG1102N IC231 1AG1105B IC231 1AG1105C 1C111 1AG1113C IC111 1AA0001L 1C111 1AA0502G IC111 1AB5311K IC111 1AD1115A 1C111 1AG1102G IC111 IAG1102K 1C111 1 1AG1102L 1C111 1AG1102M 1C111 1AG1102N 1C111 1AG1105C 1C111 1AG1108C 1C111 1AG1108F 1C111 1AG1109B IC111 1AG1109C 1C111 1AV099E IC111 1AV100E \\ 1C111 8
j The inspector verified that the above field terminations met the requirements of Bechtel Termination Procedure FPE-7.000 including the use of proper termination lugs and connection to the correct termination board locations. T F b. The irt.pector observed the termination of internal wiring in Diesel Engine Control Panel IC112. The inspection revealed numerous instances where the internal conductors within the panels were damaged or were not properly terminared. Examples included: (1) The output lead on the Relay Tach device had numerous broken conductors at the termination lug. ~ (2) The K1 lead on the Relay Tach device had two broken strands resulting in a potential short circuit between the K1 lead and an adjacent conductor. (3) The 1-lead on the CB-1 device did not have all strands inserted into the compression lug. The above conditions were contrary to the procurement requirements i delineated in Specification 7220-G-5, Revision 1, Paragraph 6.0 which stated, in part, "All electrical wiring. within the board enclosure shall conform to the highest industrial standards i of design and workmanship." This failure of source inspections at i the panel supplier facilities and receipt inspections at the Midland I w 9
1- -w._ w - =- e site to assure conformance of the internal wiring to procurement requirements was considered an item of noncompliance with 10 CFR 50 Appendix B, Criterion VII as described in Appendix A of the report transmittal letter. (50-329/82-22-01; 50-330/82-22-01) Subsequent to this finding the licensee initiated NCR No. M01-9-2-139 which contained 19 pages of identified internal wiring deficiencies associated with Diesel Engine Control Panels 1C111,1C112, 2C111 and 2C112. The licensee on December 3, 1982 identified the poor workman-ship within the subject panels as part of a potential 50.55(e) report on Vendor supplied electrical equipment. The inspector determined that the internal wiring within the Diesel c. Generator Control Panels was not instelled in accordance with the separation requirements delineated in the Midland FSAR. Nonclass IE wiring was routed within six inches of Class 1E wiring and the color coding of the internal wiring did not correctly identify the wiring as being Class 1E or Nonclass 1E. Subsequent to this finding the inspector reviewed Consumers Power Company (CPCo) NCR No. M-01-9-1-075 dated June' 19, 1981. This NCR was written by the li-conses to document the aforementioned internal wiring separation deficiencies. The NCR stated that the panel supplier was sending a representative to the Midland site on November 15, 1982. On November 18, 1982 the licensee informed the inspector that panel i i supplier representatives had arrived onsite on November-16, 1982 i i 10 -- --- - I
- ^ ~:s..., a _a ._- ~. _. ~ and that these representatives had determined that the panels would be modified to correct the internal wiring separation problems. The inspector had no further questions on this matter.. 3. Diesel Control Panel Installations The inspector observed the installation of the Diesel Generator Control Panel and the Diesel Engine Control Panel associated with each of the. four diesel generators. The installation requirements for these panels were delineated on Drawings 7220-M18-83 and 7220-M18-250. During this inspection the following was observed: 1 The Diesel Engine Control Panels were not installed in accordance a. with foundation Droring 7220-M18-250. This drawing required the installation of bevelled washers and flat washers on the foundation bolts. The flat washers were not installed on any of the four panels. In addition, there was no evidence that the bevelled washers were, installed before the panels were grouted. This failure to install i foundation washers as required by the pertinent foundation drawing was considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in Appendix A of the report transmittal 1 letter. (50-329/82-22-02A ; 50-330/82-22-02A) Subsequent to this finding the licensee initiated NCR No. M01-9-2-138 to document the missing washers, t I el 11
~* i b. The Diesel Generato,r Control Panel base to cab 2 net hardware installa-tion was not in accordance with Drawing 7220-M18-83. The drawing required that the cabinet be secured to the base utilizing 1/2" hex bolts with threads embedded 2" into concrete. The licensee had installed nuts on the 1/2" hex bolts which were not identified on the subject drawing. In addition, the concrete curb had not been poured at the time of this inspection. The inspector further observed that the drawing details did not clearly describe the base to cabinet hardware configuration. Discussions with the licensee revealed.that the incomplete cabinet foundation was documented on an In Process Inspection Notice (IPIN), dated June 14, 1982. On September 21, 1982, the licensee had initiated Field Change Request (FCR) M-6655 which proposed a change to the cabinet to foundation detail located on drawing 7220-M18-83. The inspector had no further questions on this matter. 4. Raceway Support Installations The inspector observed the as-built installation of the type 13 a. conduit support for conduits 2BN006, 2BN007 and 2BDA002 located in Bay 4 of the Diesel Generator Building. The as-built installa-tion of the support was compared with the requirements delineated on Drawing E-42. During the inspection of this support the follow-ing was determined: 1 12 - - - - - I
- x,_ =
(1) The lengths of the support members were determined to be within the tolerances identified on Dawing E-42. (2) The base plate dimensions were in accordance with the drawing requirements. (3) *Ihe support welds were acceptable. 1 (4) The size of the unscheduled pull box mounted on the conduit s support did not conform to Sheet 42 of Drawing E-42. The as-built dimensions of the box were determined to be 12" x 12" x 6". The dimensions required by Sheet 42 were 13 1/2" x 12" x 6". This failure to install the correct size unscheduled pull box was a further example of noncompliance as cited in paragraph 3.a above. (50-329/82-22-023; 50-330/82-22-02B) b. The inspector observed the as-built installation of tray support FSK-E-796, Sh 1-86 installed in Bay 4 of the Diesel Generator Building. The as-built configuration of the support and the as-built support dimensions were compared with the requirements identified on Drawing E-796(Q), Revision 5, Sheet 2 of 2. This inspection revealed that the as-built 2' 1 1/2" wall to support dimension did not conform to the l' 10" dimension required by the aforementioned drawing. The failure to install the subject support in accordance with the drawing requirements was a further example of noncompliance as cited in para-graph 3.a above. (50-329/82-22-02C; 50-330/82-22-02C) 13
~, __ - w An inspection of the as-built installation of tray support No. 14 c. installed in Bay 2Gil of the Diesel Generator Building was conducted. The as-built configuration of the support and the as-bui1t support i dimensions were compared with the requirements identified on Drawing i E-796(Q), Revision 11, Sheet 1 of 2. This inspection revealed that the as-built 5' 5" wall to support dimension did not conform to the 6' 6" dimension required by the aforementioned drawing. The failure to install the subject support in accordance with the drawing re-quirements was a further example of noncompliance as cited in para-graph 3.a above. (50-329/82-22-02D; 50-330/82-22-02D) d. The licensee was questioned as to the status of the seismic analysis performed to provide assurance that the plant conduit and tray supports, as installed, met the seismic requirements for the Midland plant. The licensee stated that the seismic analysis was being accomplished at this time and that the results of the analysis would be available when completed. This matter will remain open until the inspector has reviewed the data relating to the seismic analysis. (50-329/82-22-03; 50-330/82-22-03) 5. Review of Quality Control Activities t During the review of Bechtel Quality Control (QC) inspection activities the inspector determined that Bechtel QC inspectors were not identifying I as nonconformances all of the deficiencies which they observed during their inspections. The QC inspectors were instruct d to suspend an i 14
^ ~ ^ uw--.. + l l l l m inspection if an excessive number of deficiencies were observed. In Process Inspection Notices (IPINs) were QC documents utilized by QC inspectors to record nonconformances observed during in process in-spections and during inspections of completed items. IPINs associated with suspended inspections identified as nbnconformances only a portion of the observed deficiencies. No record was made of the remaining observed deficiencies. In addition, the IPINs did not document the fact that the inspection was suspended due to excessive deficiencies having been observed. Finally, the criteria to be used,by QC inspectors in determining whether observed deficiencies were excessive was not defined. As a result of the above, the following was determined: Trend analysis, as identified in Midland Project Quality Assurance a. Department Procedure M-2, was designed to serve as a management tool to detect changes in the rates of nonconformance..For deter-iorations in quality the procedure required the performance of an in-depth analysis to determine the root cause of nonconformance. The failure of QC inspectors to document all observed nonconform-ances resulted in the Trend Analysis Program, as it relates to IPINs, not addressing all nonconformances. Management's ability to determine the root cause of nonconformance so as to prevent re-currence had been accordingly diminished. i b. An additional function of the in-depth analysis required by Trend Analysis Procedure M-2 was the determination as to whether or not work affected by nonconformance should be stopped. The failure of 15
.:;u. =.n_-, l QC inspectors to document all observed nonconformances resulted in the continuation of nonconforming work activities wh.ich received no stop work considerations, thereby preventing management from performing an indepth analysis. The failure to establish measures to control materials, parts, or com-ponents which did not conform to requirements in order to prevent their inadvertent use or installation was considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion XV as described in Appendix A of the report transmittal letter. (50-329/82-22-04; 50-330/82-22-04) 6. Examination of Steel in Laydown Area During the inspection, the laydown area was examined by the a. inspectors. It was noted that there was stock steel with no markings which would identify the material to a given material heat number. Bechtel Field Instruction FIG-9.600, Color Coding of Field Purchased Pipe, Fittings, Bolting Material, Non-Q Hangers, Stock Steel, and' Component Parts, states that "No marking is re-quired for A-36 plate, shapes, and bars or A-500 Tube Steel for Non-ASME, Q-listed Steel." This same specification required that stock steel other than A-36 and A-500 Tube Steel be marked with the material type and grade. High strength steel plate was identified in the laydown area without markings of material type and grade. Failure to not mark high strength steel with the material type and grade was considered an item of noncompliance against 10 CFR 50 Appendix B, Criterion V. (50-329/82-22-05A; 50-330-82-22-05A) 16
wy.. - p. m__ J -. =_. 4 b. Field Instruction FIG-9.600, referenced above, required that the ends of all Non-Q steel material be painted yellow with separate storage provided. During the examination of steel in the laydown area, it was noted that there were Q and non-Q storage areas. However, some steel stock in the Q area was painted on the ends with a paint color resembling faded yellow paint and some of the steel in the.non-Q area did not have the yellow paint marking. The licenses stated that the yellow-like color paint noted in the Q storage area had been placed on the material by the manufacturer. The licensee painted the ends of all the material in the non-Q area after this was identified by the inspectors. Failure to mark and/or segregate Q and non-Q material was considered an item of noncompli-ance with 10 CFR 50 Appendix B, Criterion V. (50-329/82-22-05B; 50-329/82-22-0$B) The references above to Field Instruction FIG-9.600 pertain to c. Revision 1 of this instruction, dated December 2,1981. Revision 1 superceded Revision 0 which was dated February 1979. Revision 0 referred only to field purchased pipe, fittings and bolting material and made no reference to stock steel identification. The inspectors identified (in the laydown area) a nominal 25 foot length of 12 x 12 WF beam that had no markings but was stored in an area that had ASTM-A-588 steel of similar description and surface color / texture appearance to the unmarked beam. The ability of the licenses to maintain material traceability and identification in accordance with the regulations was considered an unresolved item. (50-329/82-22-06; 50-330/82-22-06) 4 ' 17
+... aru.w a. - '+ ~ =- -. - ~ ~ l d. The inspector requested to see QA audits of material traceability. The only audits that could be located during the inspection were of receiving and fabrication of miscellaneous structural steel. No audits of material traceability could be located during this inspection. Subsequent communications with the licensee revealed that an audit had been conducted in September 1982 (M01-332-2). Pending review of this audit, this is an unresolved item. (50-329/82-22-07; 50-330/82-22-07) 7. Diesel Generator Muffler Inspection The inspectors conducted an inspection of the diesel generator muffler located in the Diesel Generator Building. The inspection included a review of the applicable drawings and documentation associated with installation and modification of the four diesel generator (DG) mufflers. The DG mufflers were constructed offsite by American Air Filter Co., Inc. (a subcontractor of Transamerica Delaval, the DG system supplier), and installed onsite by Bechtel Power Company (BPCo). After onsite receipt inspection and when construction permitted, the mufflers were installed ) in their respective rooms in the DG Building. During installation of the mufflers, it was noted that the saddle support baseplate holes and slots would net match anchor bolt locations. FCR M-2283 was written to modify the saddle support base plates to fit the anchor bolt locations. 5 18 .------,-,------c-c--
,..eaa m - m - ~ -- .u-u wa l l a. During the inspection the licensee was requested to review docu-l mentation of the base plates to determine if traceability was evident. 1 l 'The licensee's review of base plate documentation identified that l part numbers could be tracked to a Certificate of Conformance. The Certificate of Conformance was written for purchased "Q" material that was not manufactured to ASME code specifications. The Certifi-cate of Conformance, did not, however, specify the material used during the manufacture of the base plates. The inspector and the licensee reviewed the base plate and muffler saddle support drawings and specifications for identification of plate material. Muffler and saddle support material was not specified on the design drawings and specifications. FSAR Section 3.2 Table 3.2-1 identifies the Diesel Generator Com-bustion Air Intake and Exhaust System as Seismic Category 1. To qualify the muffler to Seismic Category 1 criteria, the saddle supports and base plate material requirements must be specified to ensure that the muffler would meet seismic criteria. E 10 CFR 50 Appendix B, Criterion III requires measures to be estab-lished for the selection and review for suitability of application of materials that are essential to the safety related functions of-i the structures, systems, and components. 1-The failure of design documents to specify requirements for the selection and review for suitability of application (in this case i l 19
om v -a g_ l Seismic Category 1) of materials associated with the DG muffler 1 was considered an item of noncompliance with 10 CFR 50, Appendix B, l Criterion III, as described in the Appendix to the report transmittal letter (50-329/82-22-08; 50-330/82-22-08). b. In addition to the above, the inspectors identified other noncom-pliances associated with the installation of the DG muffler as follows: (1) To allow for adequate thermal expansion of the DG mufflers, slots were specified by Drawing M18-80-4 to be sized at 7/8" by 1 5/8". In addition, Bechtel Vendor Drawing M18-425(5)-1 required that plate slots used for support plate modifications be machined. The inspectors determined that the slots were irregular and did not conform to design drawings. Slot surfaces appeared rough and discolored, indicating they were torch cut rather than machined as required by design drawings. e Failure to fabricate the slots in accordance with design drawings was considered an item of noncompliance with 10 CFR j 50, Appendix B, Criterion V, which requires that activities affecting quality be accomplished in accordance with drawings j as described in the Appendix to the transmittal letter to this report (50-329/82-22-09A; 50-330/82-09A).' ~ t 20 .., ~.. _ _ _ -., _.. _, _ _. _.,.. _. - - _ -. -. -,. _ _ _ _ - -.
, m.am-1. m _. aa_ I \\ 9 Subsequent to the inspection, the licensee generated NCR 4693 to disposition the slots of the support plates for the DG muffler. (2) Vendor Drawing M18-250-6 required that jacking plates be installed and imbedded in concrete beneath the muffler support jacking screws. The inspection of the Diesel Generator muffler in Bay No.1, revealed that the jacking plates had not been installed be-neath the center saddle support. The licensee identified that nine of tho 48 jacking plates were missing in the four bays. Failure to install the jacking plates was considered an item of noncompliance with 10 CFR Appendix B, Criterion V, which i requires that activities affecting quality be accomplished in accordance with drawings as described in the Appendix to the transmittal letter of this report (50-329/82-22-09B; 50-330/82-22-098). Subsequent to the inspection, the licensee wrote NCR 4694 i against the failure to install the jacking plates, t (3) Drawing M18-250-6 indicated two slide bearing elements welded to the bottee of the outer saddle support base plates for each I t' \\ ) 21
+
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--,x.---:.-- a -a DG muffler to allow for thermal expansion during muffler heatup. During the plate inspection, it was nored that some of the bearing plates were warped sufficiently to allow di,rt to pene-trate between the bearing plate surfaces which would restrict plate movement. A review of all bearing plates by the licensee revealed five of sixteen-that were sufficiently warped to allow the inclusion of dirt. Tailure of the licensee to protect the bearing sur-faces from dirt, dust, and other forms of contamination was considered an item of noncomplianca with 10 CFR 50, Appendix B, Criterion XIII requiring control of cleaning and preservation of material and equipment as described in the Appendix to the , transmittal letter of this report (50-329/82-22-10; 50-330/82-22-10). On Lecember 3, 1982, the licensee verbally committed to imple-menting a program to identify other material and equipment requiring protection from contamination and to include this identified equipment in a pis ?ative maintenance program. 8. Di sel Generator Exhaust Piping hjng.a ? a. The inspector selected the diese' generator exhaust piping for review. The latest revisions of applicable design drawings were , compared to the actual as-built configuration of the ha5gers. I ? 22
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)
w.-,= w nw _. -v n- ..c= From this review, it was determined that the actual configuration of the hangers did not match the design drawings for the following hangers: (1) 652-1-19; the west support plate was welded to the wall embed on the east side instead of two expansion anchors as illustrated on the redline drawing. The licensee subsequently documented this on FCR M6925 instead of an NCR as required by site procedures. (2) 652-1-510; the welds connecting the hanger base plates to the support tubes were not constructed as shown on the drawings. The licensee stated that welding on the hanger was not completed. The licensee's position was that the hangers in question were non "Q" and their failure would not affect any safety system. The inspector determined that the exhaust pipe was "Q", as documented in the FSAR, the SER and on Drawing M-652, Sh.1, Revision 8, Note No.19. There-fore, the hangers supporting the pipe were also required to be "Q". The exhaust pipe hangers were constructed without implementing the program requirements. The failure of the licensae to ensure that quality assurance requirements defined in the FSAR and the SER were translated into the design and construction of the exhaust system hangers was contrary to 10 CFR 50, Appendix B, Criterion III as described in the Appendix of the report transmittal letter (50-329/82-22-11; 50-330/82-22-11). 23
-. _ _ ~... my. -m .. mm- "On October 19, 1982, the license's informed the inspector that the exhaust system was indeed "Q" and administrative measures were under way to correct the problem; however, these measures were not identi-fled on any document. Site Procedure G3.2 required that an NCR be written for nonconforming conditions. The licensee, as of November 10, 1982, had failed to document this nonconforming condition through issuance of an NCR. The failure to control components which did not conform to requirements was contrary to 10 CFR 50, Appendix B, Criterion XV as described in the Appendix of the report transmittal letter (50-329/82-22-12A; 50-330/82-22-12A) b. During the review of the as-built hanger details, the inspector observed the welding of hanger stiffeners to existing "Q" structural steel. The stiffeners were being welded to a 36 inch "Q" beam with 1 1/8" flanges without any preheat. The room temperature at the time of the inspection approximated the outside temperature due to no available heating. The welders informed the inspector that there were no preheat requirements for these welds. The inspector determined that Specification FSW Structural-1 and the AWS 1974 Code require a minimum preheat temperature of 70 F. The licensee did not verify the temperature of the existing structural steel during welding. Further-more, site inspection procedures were inadequate in that they did not require verification of preheat temperatures until they reach 150'F. The failure to verify 70*F preheat temperature requirements was con-trary to 10 CFR 50, Appendix B, Criterion IX as described in the Appendix of the report transmittal letter (50-329/82-22*-13.; 50-330/82-22-13). 24
ewm-u = .x =mm-a e 9. Diesel Generator Building Monorail A review of the monorail installed above each diesel generator was per-formed in order to determine whether the monorail was designed and in-stalled in compliance with the requirements in the FSAR and construction specifications. The licenses took exception to Regulatory Guide 1.29, Position C.4, resulting in these monorails not being constructed "Q". The licensee's plant wide exception to position C-4 of RG 1.29 has been referred to NRR for review. This item is unresolved pending NRR's response (50-329/82-22-14; 50-330/82-22-14). Discussions with the licensee on the monorail indicated that not only was the monorail installed non "Q", but it also was not analyzed to Seismic Category I requirements as required by RG 1.29. The failure to analyze the monorails to Seismic Category I requirements was contrary to 10 CFR 50, Appendix B, Criterion III as described in the Appendix of the report transmittal letter (50-329/82-22-15A; 50-330/82-22-15A). Subsequent to the inspector's finding, the licensee reported the noncon-forming design on a " Proximity-Seismic Category II/I Interaction Identi-fication Sheet" instead of a Nonconformance Report. The identification l of this nonconforming item in this manner circumvented the licensee's nonconformance program. As a result, this concern had not been reviewed for generic applicability or for potential reportability as "of November 10, 25
- - - - - - - - e _=> amu. m 1982. The failure to identify and control this nonconforming condition was contrary to 10 CFR 50, Appendix B, Criterion XV as described in the Appendix of the report transmittal letter (50-329/82-22-12B; 50-330/82-22-12B). 10. Diesel Generator Building HVAC Fan Support Steel An inspection of the as-built structure was made using the latest a. revisions of applicable design drawings. From this review, the inspector determined the following discrepancies: (1) The eight bracing top gusset plates identified on Drawing C-1004, Revision 10, as 5/16" thick were measured by the ' inspectors to be 1/4" thick in all four DG bays. (2) The as-built gusset plate connections in Bay No. I were not built as identified on Detail 3 of Drawing C-1004. The braces were welded together as opposed to separate welds for each brace. (3) None of the sixteen 1/4" bracing angles identified on Drawing C-1004 were constructed utilizing 1/4" material. (4) Drawing C-1004, Detail No. 2 required the W10 beam to beam connection to be welded. In Bay No. 3, the inspector observed that a bolted connection was constructed in lieu of the re-quired welded connection. 26 - -. ~,
_ e,... : 2 i (5) The column cover plate identified on FCR-C4401 was not con-structed in Bay No. 3 as required. The plate was slotted t instead of solid as depicted on the FCR. The failure of the licenses to ensure that work was accomplished in accordance with the drawings was an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report transmittal letter (50-329/82-22-16; 50-330/82-22-16). The inspector further determined that QCIR C210-172, Revision 1, which documented the inspection of the fan supports, was closed on July 1, 1981 with no exceptions or nonconformances noted. The QC inspector closed the inspection with a determination that the structure was built in accordance with the drawing. The failure of QC to detect and identify these nonconformances was contrary to 10 CFR 50, Appendix B, Criterion X as described in the Appendix of the report transmittal letter (50-329/82-22-17; 50-330/82 22-17). b. The inspector determined that Procedure FID-2.100, " Outstanding FCR/FCN Retirement," Revision 2, was inadequate in~ that it did not require, for retired FCR/FCN's, that the design drawing remain annotated indicating that an FCR/FCN had been retired. As a result, 1 l the HVAC structural steel did not conform to identified design requirements. Additionally, as a result of not having adequate measures to control retired FCR/FCN's, the document control vault lost retired FCR C-2103. The failure of the licensee to establish i 27
L 2 . w' w.. .~~ measures to ider dfy the existence of retired FCR/FCNs on the appropriate design drawings was an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report transmittal letter (50-329/82-22-18A; 50-330/82-22-18A). The inspector questioned the licensee as to the method in which c. the bottom bracing connections were made since there were no bottom bracing gusset plate connection details (weld sizes, plate sizes and plate thicknesses) identified on Drawings C-1004 and C-147. There were also no instructions on site to indicate the method or standard practice to be used to design bracing gusset plates. The following concerns were identified: (1) Design Drawing C-147 required bolted bracing connections for the diesel generator building HVAC bracing gusset plates. Contrary to this design requirement, Field Sketch CY-1035 was used to design welded connections in lieu of the specified bolted connection. As a result, design changes were being implemented without the same review and approval as the original design. The implementation of changes in design in. the field without subsequent review and approval was considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion i III as desczibed in the Appendix of the report transmittal letter (50-329/82-22-15B; 50-330/82-22-15B). 28 -- - - - - - - - - - - ~ - ~ ~ ~ ~ - ~ ~ ' ~ * ~ ~ ' '
~ (2) Field Sketch Number CY-1035 which illustrated the bottom gusset plates was not annotated as "Q", nor was there a reference on the sketch to the affected design drawing. This is contrary to the requirements delineated in Procedure FPD-5.000, "Prepara-tion of Field Sketches," Revision 1. The failure to follow procedures was an item of noncompliance with 10 CFR 50, Appendix B, Criterion V as described in the Appendix of the report trans-mittal letter (50-329/82-22-18B; 50-330/82-22-18B). (3) The inspector further determined that the procedure did not require the drawing to be annotated with a reference to the field sketches. There was no procedural requirement or means to ensure that the existence of a field sketch was annotated on a drawing. The failure to develop procedures to adequately control field sketches was in noncompliance with 10 CFR, Appendix B, Criterion V, as described in the Appendix of the report transmittal letter (50-329/82-22-18C; 50-330/82-22-18C). (4) The inspector determined that the bottom gusset plate sizes i were only identified on a Combo Shop work order sketch. As a result, the bottom gusset plates were designed in the field without adequate review and approval. The failure to control the gusset plate design was in noncompliance with 10 CFR 50, Appendix B, Criterion III as identified in the Appendix of the i report transmittal letter (50-329/82-22-15C; 50-330/82-22-15C). t ~ 29 1 ~.. -
mq = d. The inspectors determined that the existing 1/4" gusset plates appeared to be out of ASTM Specification A6 requirements for rolling mill tolerances as identified in Table 1 of the ASTM Spe'cification. Due to the plates having been previously painted, the actual plate thicknesses had not been determined at the time of this inspection. This matter is unresolved (50-329/82-22-19; 50-330/82-22-19). 11. Pipe Installation Activities The inspector selected for inspection one of the two pipelines which connected an air start tank to Diesel IB11, and the four support hangers for both pipelines. Diesel IB11.was located in Bay 2. Pipeline 1-GCC-1-5-652-2 was specified on Bechtel Drawing No M-652, Sheet 2, (Q), Revision 3. The drawing specified the pipeline configuration and identified which welds (shop welds) were made at the vendor and which welds (field welds) were made by site craftsmen. The inspector observed the installed pipeline components and connecting welds for line 1-GCC-1-5-652-2. The pipeline configuration was as speci-fled on the drawing. There were no unacceptable visual deficiencies on any of the pipe welds. The pipe components supplied by the vendor were marked with heat number 32995. The pipe component (pup piece) supplied at the site was marked with heat number 738367. Certified Material Test Reports, CMTR's, were available on site for both of the above heat numbers. 30
.n A review of the weld inspection records for the shop welds revealed that the shop welds had passed radiographic and visual examination. The visual examination report included fitup, root, intermediate'and final ~ weld passes. A review of the records for two field welds (M-652-2-7 and H 652-2-11) indicated that only final visual examination had been performed. The licensee stated that no additional nondestructive examination, NDE, was required for those field welds because the pipe was only three inches in diameter. ASME Section III 1971 Code, Summer 1973 Addendum, Article ND-5220 states, "All pressure-retaining welds in piping, pumps and valves greater than four inches nominal pipe size shall be examined by either 4 the magnetic particle, liquid penetrant or radiographic method." This code revision did not specify any NDE requirements for piping diameters 4 of four inches and less. The pipe inspected was less than four inches in dismeter. A review of the Midland Final Safety Analysis Report, FSAR, Section 3.0, 1 revealed that the design code (ASME) for nuclear pipe over two inches in diameter, had not been specified. During a telephone conversation on November 18, 1982, the licensee concurred that the design code had not i been specified in the FSAR, but stated the design code was specified in site Specification No. M-324(Q), Revision 1. The RIII inspector confirmed the licensee's statement. This matter has been referred to NRR and is open pending further review (50-329/82-22-20; 50-330/82-22-20). 31
~ D 1 12. Hanger Design Control LAn inspection of four support hangers on Diesel 1G11 pipelines was conducted. The inspector requested the Bechtel Site Document Control Center to provide the latest isometric drawings for the four hangers that supported the two diesel air start pipelines. The control center provided the following drawings: (1) 1-652-2-25(Q), Revision 0 (2) 1-652-2-26(Q), Revision 1F1 (3) 1-652-2-27(Q), Revision 0 (4) 1-652-2-28(Q), Revision 1F1 Drawing 1-652-2-25(Q), Revision 0, was used to check the actual installa-tion of the respective hanger. The drawing and the actual installation were different. A review of the QC copy and the original work print revealed that the hangers appeared to be installed in accordance with the red line changes. Field Instruction FIP-1.112 Revision 5, " Field Marking of Prints for Pipe Supports," was used to control red line changes. The procedure essentially defined the method for which support changes that did not require a total redesign could be modified in the f eld. The procedure 32 i
required Resident Engineering approval for all support modification except minor revisions that did.not affect the basic design. The pro-cedure appeared to assign Field Engineering the responsibility of con-trolling (ensuring proper approvals and distribution) red line changes. The procedure also required Field Engineering to number and log the red line changes. Discussions with Field Engineering personnel responsible for the red line los revealed that the log was not controlled. The log appeared to be an ineffective control mechanism because the entries were made chronologically for changes to all drawings and could not readily be used to identify how many changes affected any specific drawing. The Bechtel Lead Mechanical Field Engineer stated that red line changes were initiated by Field Engineering, approved by Resident Engineering, end returned to Fiald Engineering for distribution. In addition, the inspector determined that distribution to the Document Control Center was being bypassed. Adequate measures were net established to control the issuance of these d document changes. This was contrary to 10 CFR 50, Appendix B, Criterion VI as described in the Appendix to the report transmittal letter (50-329/82-22-2I; 50-330/82-22-21). Bechtel Project Engineering Procedure, PEP, No. 4.46.9, Revision 0, established the controls for red line changes received by Resident Engineering. The procedure required the cogniaint discipline resident engineer to maintain a log of red lines received. The inspector verified c 33 m.
__-a ...= .~ o that two red lines identified on isometric drawing 1-652-2-25(Q) were properly controlled by the log. 1 13. Manger Installation Activities The inspector checked the installation of four support hangers against the respective isometric drawings (including changes) and the installation criteria. The four hanger configurations appeared to be as specified on the latest revisions to the isometric drawings. The welders identification mark was stamped adjacent to all hanger welds. All (approximately ten) of the field welds on the two large hangers specified on Drawings 1-652-2-26(Q), Revision 1/F1, and 1-652-2-28(Q), Revision 1/F1, were covered with surface rust. Specification 7220-M-326(Q), Revision 8, paragraph 5.15.1 stated, in part. "All component pipe supports shall have surface preparation and primer applied in accordance with Specification 7220-A-41, Technical Speci-fication for Field PrLeing and/or Top Coating Steel Surface. Specification 7220-A-41, Revision 9, paragraph 4.2 stated that all protective coating of steel for outside the containment shall be non "Q". The licensee stated that non "Q" meant non-safety related and therefore, was not required to maintain the safe operation of the plant. 34
1_____ w- = On November 9, 1982, the Bechtel Resident Engineer stated the cognizant corporate (Ann Arbor, Michigan) engineer's evaluation of the steel surfaces '(welds) outside containment concluded that the surface rust would not exceed 20 mils (0.02 inches) deep; that no pitting would result; and that even with the smallest weld (1/8 inch) there would only be a 16 percent reduction of weld size, which would still leave a 2.8 safety margin with maximum corrosion over a 40 year period. Additionally, the site construction personnel provided an established schedule which should assure that the welds were painted before the plant operates. No items of noncompliance or deviations were identi-fled. 14. Hanner Material Traceability 4 .a. Manger parts, specified on Drawings 1-632-2-26(Q) Revision 1F1 and 1-652-2-28(Q), Revision 1F1, included 1/2" x 6" x 6" and 1/2" ?. x 4" x 4" tube steel'(ASTM A-500, Grade B). The installed tube l steel was not marked with heat numbers. The inspection recorda did not identify the heat numbers traceable to the installed tube s, teel. The installed tube steel had the letter "Q" stamped on the individual sections. The licensee stated that the letter "Q" indicated that the tube steel heat numbers were controlled by pro-cedure up to the time the hangers were fabricated. The licensee also stated that the site procedures did not require any additional j. traceability controls after fabrication. 4 9 35
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The FSAR, Table 3.2-4 states that the design and fabrication code for hangers and supports for nuclear piping is ASME Section III, Subsection NF, 1974 (no addendum). Subsection NT-4122 states that material for component supports shall carry identification markings which will remain distinguishable until the component support is fabricated or installed. Therefore, the site controls for material identification for hangers (component supports) appeared to comply with the ASME code requirements. b. The inspector reviewed the Hanger Material Log for structural tubing. The log identified the quantity (in feet), size, material type (grade), ASME class, heat number, material receipt number, purchase order number, and relative remarks for the various shipments of tube steel. The los revealed that only type ASTM A-500 Grade B material had been received. The los also revealed that at least 3600 feet of various sizes and lengths of tube steel had been addressed on Bechtel Nonconformance Report, NCR 3266, January 23, 1981. The NCR stated that the " material was procured from subvendors who were not ASME or Bechtel qualified for an NA 3700 quality ptogram at the time of purchase." The NCR stated that no hold tags were applied. The.NCR listed 122 steel items (including various qualities, sizes and lengths of tube steel, angle iron, plate, etc.) which had been purchased from 16 different material suppliers / manufacturers. Page 8 of.the NCR stated "A conditional release is granted for use of the subject material. The material is traceable to a heat number and corrections or removal can be accomplished without causing damage 36
a . ___ m a.. s ps.x, o. I or contamination to associated plant equipment or structure." The conditional release was dated February 5, 1981. The conditional release was revised (added page 9 to the NCR) on March,25, 1981 to restrict 37 of the 122 items from use in ASME Section III Class 1 pipe supports. The restricted material was permitted for use in Class 2 and Class 3 hangers. On June 16, 1981, the NCR was revised to apparently reject the above 37 items for Class I use again. On July 1, 1981, the NCR was revised to reject 15 other items from in-sta11ation in Class 1 systems. On July 17, 1981 (amended July 27, 1981) the NCR was revised to accept 42 of the remaining items based on approval of two of the 16 material suppliers, and revised to reject seven additional items from Class I use. On October 28, 1981, the NCR was revised to reject one additional item from Class 1 use. Thus, from the date (January 23, 1981) that NCR 3266 was written, the NCR was revised four times to add restrictions on the use in Class 1 systems of numerous materials. The Bechtel QC acceptance (page 15) of NCR 3266 stated the resolu-tions of the 122 items, along with a brief basis for the resolutions. The resolutions were addressed in three categories according to the bases. The bases for the three categories was as follows: l (1) Certified Material Test Reports, CNTR's, were on file for 19 items and the requirements of ASME Subsection NF-2610(c) had been set, therefore, the respective materials 'could be used in Class 1 systems. l 37 - --~_ _..,,. - ~. -, ~ _ _ _ _ m.m.__._- _m._
(2) CMTR's were on file for 42 items and the requirements of ASME Subsection NA-3700 had been met, therefore, the respective materials could be used in Class 1 systems. (3) CMTR's were on file for 61 items and the requirements of ASME Subsection NF-2610(b) had been met; therefore, the respective materials could be used in Class 2 and Class 3 systems. The NCR noted that measures had been taken (heat log changed) to prevent the 61 items from being used in Class 1 systems on July 28, 1982. I Paragraphs (a), (b), and (c) of the ASME Code Section III, Subsection NF-2610 1974 Edition, Summer Addenda 1976 states: (a) Except as provided in (b) below, Material Manufacturers and Material Suppliers shall have a Quality System Program or an Identification and Verification Program, as applicable, which meets the requirements of NA-3700. (b) The requirements of NA-3767.4 shall be met as required by-NF-2130. The other requirements of NA-3700 need not be used by Material Manufacturers or Material Suppliers for small products, as defined in (c) below, and for material which is allowed by this Section to be furnished with a certificate of Compliance. For [ these products, the Manufacturer's or Insta11er's Quality Assurance Program (NA 4000) shall include measures to provide assurance that i 38
q w the material is furnished in accordance with the material specifi-cation, and the special requirements of this Section. (c) For the purpose of this paragraph, small products are defined as given in (1) through (3) below: (1) pipe, tube, pipe fittings, and flanges of 2 inch nominal size and less (2) bolting material l'ncluding studs, nuts, and bolts of 2 inch nominal diameter and less (3) structural material with a nominal cross-sectional area of 2 sq. inches and less. 'l Subsection NF-2130 states: (a) All materials used in the construction of component supports shall be certified. Certified Material Test Reports in accordance ) with NA-3767.4 shall be provided for material in Class 1 plate and l shell supports, Class 1 linear supports, and for materials for other types and classes of component supports when impact testing is re-quired (NF-2311). i (b) Certificates of Compliance with the material specification, grade, class, and heat-treated condition, as applicable, may be l l 39
-_s-w- --:w ~ ~ provided in lieu of Certified Material Test Reports for materials for all other component supports. (c) Copies of all Certified Test Reports and Certificates of Compliance applicable to each material used in the component support shall be furnished with the material." The Bechtel QA Manual (ASME III), Revision 2, dated July 1980, paragraph 4322 states, in part " Quality program demonstration is established through possession of a valid current, ASME Quality System Certificate (Material) or survey of the manufacturer or supplier by other (Bechtel) Procurement Supplier Quality Department." I Based on the ASME Subsection NT-2610(b), the first and third resolution categories to NCR 3266 appeared to be inadequate in that the NCR did not indicate that measures had been taken at the respective suppliers and/or j manufacturer, or the installer (Bechtel) to provide assurance that the 4 material was furnished in accordance with the material specification. The measures were required to verify the validity of the suppliers' certificates and the effectiveness of the certification system. Note: Subsection NF-2610(c) which was addressed in the first resolution cate-gory, defines small products and does not delete the requirements of Su..ection NF-2610(b). During a telephone conversation on November 29, 1982, the licensee stated ~ that two (i.e., Mills Alloy Steel Company and Carbon Steel Products 40
n Corporation) of sixteen of the material suppliers / manufacturers were -actually suppliers. The other fourteen were manufacturers contracted by the two suppliers. The licensee also stated that Bechtel had in fact approved the two suppliers QA programs prior to issuing contracts and that Bechtel had verified that at least one of the two suppliers had sufficient controls to ensure that their subcontractors (i.e., the fourteen manufacturers) had acceptable QA programs. On December 7, 1982, the inspector received from the licensee copies of a Bechtel Supplier Survey of Mills Alloy Steel Company dated June 10, 1981; copies of two ASME Quality System Certificate (Materials) for Mills Alloy Steel Company; copies of two Bechtel Reports of Audit of Carbon Steel Products Corporation dated June 19-20, 1979 and June 3, 1980 respectively; and one copy of a Bechtel Corrective Action Report (Re-audit) of Carbon Steel Products dated July 30, 1979. The above documents indi-cated that Mills Alloy Steel Company was an approved material supplier and adequately capable of qualifying their material manufacturers during the effective period of the respective purchase contracts which were addressed on NCR 3266. The above documents indicated that Carbon Steel Products Corporation was an approved material supplier during the effective period of the respective purchase contracts which were addressed on NCR 3266. No documentation was received which indicated that the material manu-facturers, contracted by Carbon Steel Products Corporation, pos'essed an ASME Quality System Certificate (Materials) or were surveyed by the Bechtel Procurement Supplier Quality Department. The Certificate or survey was required by the Bechtel QA Manual (ASME III), revision 2, 41
,,~_as- - a. = paragraph 4322, to demonstrate that the manufacturers had an adequate quality program. The licensee was notified of this inadequacy during 's telephone conversation on December 9, 1982. This matter is unresolved pending review of additional documentation which may be supplied by the licensee (50-329/82-22-22; 50-330/82-22-22). The measures taken in the third category to prevent the items restricted to Class 2 and Class 3 systems from being used in Class 1 systems was U inadequate. These measures only controlled the restricted items after July 28, 1982. Nothing was done to verify whether or not restricted items had been used in Class 1 systems prior to July 28, 1982. This verifica-tion was necessary, especially since the NCR permitted unrestricted uses a based on the conditional releases specified prior to July 28, 1982. The basis for the conditional releases stated that, " corrections or removal (of nonconforming material) can be accomplished. ." Measures were not established or implemented to determine if Class 2 and Class 3 mater-lals were used in Class 1 systems. Failure to establish measures to control materials which did not conform to requirements and to prevent l their inadvertent use or installation in Class 1 systems was contrary to 10 CFR 50, Appendix B, Criterion XV as described in Appendix A to the j report transmittal letter (50-329/82-22-23; 50-330/82-22-23). The second resolution category to NCR 3266 appeared to be adequate in that the applicable code requirements were indicated as being fulfilled. l i 1 42
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- 15. Manger Weld Inspections QCIR No. 7220/P-2.10, Revision 9, the hanger inspection record, did not indicate whether or not any in-process weld inspections had been performed during the installation of hangers (pipe supports). The licensee provided Bechtel Quality Control Instruction No. 7220/W-1.60, Revision 2.
The scope of the instruction stated that the instruction provided the quality control verification of in process inspection activities that were necessary to ensure that specified welding process requirements were being achieved. The instruction distinguished between the civil, electrical, component support, and piping (ASME) weld activites. The instruction and/or the instruction supplement required the following in process inspection of weld activities: a. Fitup b. Tack welds c. Surface Preparation d. Preheat e. Welding Technique f. Interpass Temperatures and Cleaning 43
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l g. Welder Qualification i !~ .h. Weld Procedure (addressed in W-1.60 supplements) i i. Established the frequency and number of weld activities required to be observed. f With the exception of preheat verification, the instruction appeared to establish suitable controls for the above in process weld activities, i Most of the controls for preheat verification were defined in instruc-a tions PQCI CV-1.00, Revision 2, E-2.10, Revision 6, E-1.0, Revision 11 P-2.10, Revision 10, and PW-1.00, Revision 4 for the respective discipline i activities (i.e., civil, electrical, component supports, and pipe welding). t Inclusively, the PQCI's required verification of preheat requirements in J j excess of 70*F for all weld activities and verification on a defined sample basis for preheat requirements of 70*F and'less. As discussed in { Section 8.b of this report, an inadequacy was identified with the preheat 4 controls for civil (structural) welding. I
- 16. Anchorina of Hanaers The hangers identified on Isometric Drawings 1-652-2-26(Q), Revision 1/F1 1
{ and 1-65"-2-28(Q), Revision 1/F1 were attached to the concrete super-structure with grouted anchor bolts. The nuts on the bolts were not l secured. The inspector requested the design requirements for securing j anchor bolts. The licenses provided Specification 7220-C-306(Q), t e., r.....- ,-,wn-m=-g mor-- e, m - 4v vv.cw.w .3-.m,- y--,--3,*%-,,-%,---,,-cr-,mwv,,--.,y,<-wo-..,------e-
r ws,# _m_ ,y Revision 8, Paragraph 5.8. Paragraph 5.8 appeared to establish adequate methods for securing threaded connections. PQCI No. P-2.00,, Revision 6 appeared to establish sufficient controls during inspections -to assure that the anchor bolts would be secured. The type (grade) of bolting materials (including alternatives), was specified in Specification 7220-C-306(Q), Revision 8,' Paragraph 5.0. The diameter of the anchor bolts was specified on the isometric drawings. Based on the anchor diameter, the bolt embedment could be determined from Specification 7220-C-306(Q), Revision 8, Appendix B, Table B-2. Since the bolts had already been grouted into place, the inspector re-viewed the records (QCIRs) for inspection of grouting and dry packing. The records indicated that the bolting type and size had been properly verified. 1 The inspector reviewed and discussed with the site Resident Engineering Group, the design calculations for the anchor bolt diameters specified j on Isometric Drawing 1-652-2-26(Q), Revision 1/F1. The caluelations indicated that the combined stresses for shear and tensile for the specific hanger required a bolt diameter of 7/8 inch when using ASTM Grade A-36 l steel. The Resident Engineering group stated that the calculation sheet j concluded by specifying a diameter of 3/4 inch. The Resident Engineer i stated that this error would be corrected. The ultimate result was that the correct size bolt (7/8 inch) was actually specified on the I drawing. 4 45 I J
y ; _= n. n- - -~ r, w- ~ a 6 17. Concrete Chipping The inspector observed a section of concrete wall which had been chipped sway. The chipped section was located on a wall in Containment Purge Room 702, elevation 674' 6". The volume of chipped concrete was non-uniform and approximately 18 inches high,10 inches wide and 4 inches deep (in some places). There were no markings or tags in the area which would have indicated that the chipped section was controlled. I Bechtel Field Engineer was responsible for that area of the plant and was aware of the chipped section. The engineer also stated that he planned to put this concern on a punchlist for regrouting. The licenses stated that the concrete was chipped away in late 1981 to locate drain tubes for tendon sheaths which were inadvertently embedded in the wall. The inspector observed two drains located just above the chipped area. The inspector asked if measures had been established to control the chipped area since the wall was now in a nonconforming condition. The licensee provided Bechtel Field Instruction No. FIG-1.111, Revision 4 Concrete Drilling Permit. Section 2.0 of this instruction stated, "This instruction discusses the method of initiating, identifying, approving, and controlling concrete drill permits. ." Section 5.0 stated, "This instruction applies to all concrete drill permits issued by any discipline for core drilling, chipping of concrete, or drilling for i 46
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- a installation of concrete anchors." The instruction defined the adminis-trative process for cempleting concrete drilling permits. The instruction appeared to address a method of control which could be used for concrete chipping activities, such as the one in the containment purge room.
However, the instruction did not establish requirements which stated when or for what activities a drilling permit must be used. A drilling permit was not used to control the chipped concrete in the containment purge room. Therefore, measures were not established to provide controls over concrete chipping activities which affected the quality of structures. The Bechtel construction personnel stated that there were several other areas in the plant in which the concrete had been chipped and was not controlled. Failure of the licensee to provide controls over activities such as concrete chipping which affects the quality of structures was contrary to 10 CTR 50, Appendix B, Criterion V as described in Appendix A of the report transmittal letter (50-329/82-22-24; 50-330/82-22-24). As a result of this finding, the licensee wrote NCR No. M01-9-2-154 November 14, 1982.
- 18. Cable Saarenation In Containment Purge Roos 702, the inspector observed cable tray sections l
which contained metal dividers that extended approximately 20 feet alons the trays. The dividers were approximately the height of the tray sides. } The tray sections were identified with green alpha-numeric markings (i.e., IBTF01, IBTT02 and 1BTF03; 1BJS01, IBJQ02, and 1BJQ03). The*RIII inspector I ) 1 47 l
m-- q i noted that many of the included cables crossed over the dividers or in some cases.were stacked higher than the dividers. The purpose of the dividers wastoprovideabarrierbetweenlowvoltagecontrolcableskndinstrument cables. The barrier / divider was designed to eliminate the possibility of the electromotive forces of the control cables from inducing noise signals into instrument cables. Since the cables crossed over the divider / barrier and were stacked higher than the divider, the cables were therefore misrouted and rendered the barrier ineffective. PQCI No. E-3.0, Revision 5, Final Area Completion Activities of Electrical Installation, addressed verification of certain cable training.(i.e..- bundling and redundant channel separation), but did not address verifi-cation of cable segregation in horizontal tray runs. Failure to establish a program for inspection of cables installed in horizontal trays which use metal dividers, to ensure conformance with design requirements for cable segregation was contrary to 10 CFR 50, Appendix B, Criterion X as described in Appendix A to the report transmittal letter (50-329/82-22-25; 50-330/82-22-25). As a result of chis finding, the licenses wrote NCR No. M01-9-2-151 dated November 1, 1982 to correct the specific cable tray installations addressed above. 48 I
m 19. Nonconforming Velds in Structural Steel During the reporting period, the Resident Inspector uas aware,that the licensee had overinspected 78 structural beams and that 41 of those beams had nonconforming welds. More definitively stated, 66 weld joints of 146 cverinspected were nonconforming. As a result of this overin-spection and subsequent findings, Nonconformance Report (NCR) No. M01-9-2-074 was generated. Weld defects noted were undersized welds and undercut welds ranging from 1/16 to 1/8 inch. Because of the indeterminant state of a large number of be&ms (nominally 2400 beams), the licensee has generated a Safety Concern and Reportability Evaluation Request to determine the reportability and ultimate safety significance of their findings. This evaluation was intended to be com-plated by mid-December.1982. The Resident Inspsetor examined some of the nonconforming welds identified in the NCR and concurred with the fint.igs. This concern was being reviewed and controlled by the licensee's programs. 20. Ultrasonic Testing (UT) of Holddown Bolts During the reporting period, the Resident Inspectors and a Regional based NDE Inspector measured anchor bolts in the four battery charger rooms, the Diesel Generatcr Building and the Service Water Building. Additional measurements using other transducers are proposed in the future to accomo-date more evaluation. These evaluations will be documented in other NRC Inspection R4 ports. 49
u- ~- _ ~. n_ 21. Prestartuo Test i The inspector observed the initial pump run of Component Coo, ling Water Pump 2P-73B on 10/21/82. The observations included a review of the test procedure OSP-CCW.01, observation of portions of the actual pump test, and a review of test data to ensure that test objectives had been met. Prior to the beginning of the test, the inspector walked down portions of the system and held discussions with members of the various test groups required to assimilate test data. The following concerns were noted: The Vibration Testing Group initially set up on the wrong pump and. a. had to be told the proper phap locations. b. Personnel monitoring bearing and oil temperatures were not aware of the maximum temperature limits on the pump being monitored. Minor discrepancies such as broken valve indicators and small leaks c. were not documented either on the test summary' or on a maintenance form. d. Pump performance curve supplied by the manufacturer referenced only one of the four component cooling water pump serial numbers. O O 50
g_= - m _ _.. _-= t 6 An interim exit interview was held on October 26, 1982, with the Technical Superintendent and his staff to discuss the inspector's testing concerns. The Technical Superintendent acknowledged the inspector's findings and stated the concerns would be addressed. The inspector observed portions of the initial pump run of Decay Heat Removal Pump 2P-60A. The concerns described in the previous paragraph (except for item d which was not applicable for this test) had been satisfactorily resolved for this test. The test was stopped after 90 minutes of pump run time due to high suction differential pressure (DP) indicating a clogged suction strainer. Oil and bearing temperatures had not stabilized adequately to satisfy test acceptance criteria. The l strainers were cleaned and replaced and the test restarted. The test I was completed satisfactorily on November 13, 1982. 22. Drawing C-45 The following concerns were discussed with the licensee regarding the staff's review of drawing C-45: l l The perimeter and baffle dikes adjacent to the emergency cooling a.. water reservior (ECWR) were not included as "Q" on the drawing. The licensee subsequently agreed to define these two areas as Q. e 51
n-= m_ - - b. The licensee was requested to confirm in writing that no seismic Category I underground utilities extend beyond the "Q" bounds of drawing C-45. The licensee was also requested to put a note on drawing C-45 c. indicating that the tunnel under the turbine building was "Q". The above concerns will be reviewed during subsequent inspections. 23. Auxiliary Building Instruments l l ilhile reviewing the baseline readings on the auxiliary building instru-mentation, the inspectors observed that the Electrical Penetration Area (EPA) outboard wings appeared to be moving upwards while the remaining deep seated absolute vertical readings were downward. The licensee was requested to provide an explanation of the significance of the Auxiliary Building movements. Two meetings on the subject have already been held on site and future discussions are planned. The upward movement of the EPA outboard wings appeared to be caused by a decrease in the ambient temperature. The licensee was requested to i define the correlation between temperature and upward movement and deter-aine if a correction factor should be incorporated into future EPA in-strumentation data. 52
f 4-4 24. Review of Remedial Soils Recualification Activities Lorf,g this inspection the inspector reviewed the results of,the written examinations administered to 19 QC inspectors. These written examinations, which tested the inspectors on QC programmatic requirements, were adminis-tered as part of the requalification program initiated by the licensee in integrating all QC functions under Consumers Power Company control. Of the 19 inspectors who were administered the examination, two inspectors failed the examination. The inspector informed the licensee that all pre-vious inspections performed by these two inspectors were rcquired to be reinspected. The licenses agreed to perform the reinspection. No items of noncompliance or deviations were identified. 25. Perimeter Dike Armor Stone During a plant tour the inspectors noted that the licensee was replacing riprap protection for the eastern periceter dike. The inspectors deter-mined that the new armor stone appeared to have weak clay-shale seams in most o( the pieces. This was confirmed by dropping a few pieces and observing them break apart. The licensee was informed of the inspector's concerns. Subsequently, the inspector was informed by the licensee that the rock did not meet the freeze-thaw and gradation requirements of Specification \\ C-209. The inspector was informed that the nonconforming armor stone ) would be removed from the site. I 53
.m --m _m m. The requirement that the perimeter and baffle dikes adjacent to the ultimate heat sink be covered by.the QA plan is delineated in the May 25, 1982, NRC to licensee letter and in Section 2.5.6.1 of the SER. The inspectors determined that the licensee had purchased the armor stone without establishing controls over the procurement and installation. The failure to translate applicable regulatory requirements into design documents was considered to be in noncompliance with 10 CFR 50, Appendix B, Criterion III as described in the Appendix of the report transmittal letter (50-329/82-22-25; 50-330/82/22/26). Subsequent to the inspectors' identification of the matter, the licensee agreed to have all necessary "Q" controls in place before proceeding with additional armor stone. placement. 26. Site Tours At periodic intervals during the report period, tours of essentially all site areas were performed. These tours were intended to assess the cleanliness of the site; storage conditions of equipment and piping being used in site construction; the potential for fire or other hazards ;which might have a deleterious effect on personnel and equipment; and to witness construction activities in progress. A system walkdown was performed of portions of the Diesel Generator and Primary Makeup System. l 54
s w e e' 27. Independent Assessment of Auxiliary Building Underpinning The inspectors reviewed the weekly reports (attached) submitted by Stone and Webster Engineering Corporation to document the results of the independent assessment of Auxiliary Building underpinning activities. No significant concerns were identified in these reports. 28. Open-Items d' pen items are matters not otherwise categorized in the report that require followup during future inspections. Open items disclosed during this inspection are discussed in Section 4.d and 11. 29. Unresolved Items ~ Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of non-cocpliance.. Unresolved items disclosed during this inspection are dis-cussed in Sections 6.b, 6.c, 9,10.d and 14.b. '). Exit Interview The inspectors met with licensee representatives (denoted under Persons Contacted) on October 15, 22, 26, 28, November 10 and 23, 1982. The inspectors summarized the scope and findings of the inspection. The licensee acknowledged the information. 55
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u.;...% ~.. e S ~ .u>y) - [. e f/ NCfrES FROM MEETING WIni NRC ON 11/23/82 - We made a good presentation on individual items, however: - Generic approach is a concern to NRC - Where do we go now - Inspection Program is behind.where it should be: - Open IR's is over 12,000 - IPIN's concern - big issue - D/G Building problems found over last several weeks. - What about rest of plant?, - What do we do? - How long to find them? Status of the plant. - Inspectors feel safety related work should be stopped. - Warnick not sure how much work he could allow to proceed. - R.S. work should continue, also some other elements of work like HVAC, non-safety related work, B6W work. - NRC has not really had time to think this through, but they wanted to talk to us. - Need many more details on open IR's, IPI.N's open. - Issue of recertification of all QC Inspectors: - We say we will be done by April, 19S3. - Adequacy of Inspection Program, up-to-dateness and our grasp of the QC program. This is the center of their concern. - It is hard for NRC to issue an order. o Time constaning process, including going to the Consnissioners. - They want us to recognize the problem, take the action and take the credit. They would follow up with a C.A.L. - JWCook reviewed his plan: - Go over inspection specifics - Get a time readout and response - Make a proposal to address NRC concems, to include Statusing of inspections Systematic work suspensions - Certain areas - Not ready today to go over details. - We are at a point in Construction where we will have to inspect quality into the job..
'/ , }~ - Warnick says they are not fixed in their position today. They need to put theis thoughts together. Strong feelings within his group on stopping all work. We should address the problem (Zinner did this) in 2 areas:
- 1) hhat are we doing today to control work going forward.
Inspectors identify things.
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- 2) Look at past week, we have performed (backward look). Have problems been
.,t:_j. addressed? ,. Q ..=r. - We should review our plan and present it to them prior to a 12/7/82 meeting 7 they have with NRR. This is their-deadline. q.y - NRC will be trying to determine if these problems exist in other areas of the plant. - hhat are we doing differently from now forward to build quality into the plant? - NRC lacks confidence that we will address concerns on a generic basis. We do res-pond well to specifics. We handled the meeting today very well. - Good turnaround on our efforts to cooperate. Good attitude lately. Since we started commmicating with NRC better, things have been good. - Show NRC how we can address their concems. They do not want to drop the build-ing on us. We should be responsive. - Our in process effort is the key to solving the problem. - We did this before in HVAC - we should repeat the performance. - We will do evervthing we can to prevent them from i> suing an order to us - Jh'C. We will meet the NRC timetable to resolve this. - NRC will put all of their thoughts together and get back to us before we make any presentations to them. This will be done in the next few days. - IPIN's, design document changes (capricious ones), and material traceability are among Ron Cook's concerns. We didn't do noch today to make these concerns go away. - Attendees at this meeting: CPCO: JWCook, RAWells, DBM111er, BHPeck, MLCurland, Consultant from MAC (Vince) BPCO: KVassar, JRutgers NRC: Shafer, Cook, Warnick, Burgess, Gardner BHP 11/24/82 .~...37.... e, .+...-.
= - rk h f 1 STONE & WEBSTER MICHIGAN, INC. l 1 P.O. Box 2325. Boston. massachusetts O2107 Mr. J. G. Keppler, Administrator, Region III June 3, 1983 Nuclear Regulatory Conssission J.O. No. 14509 ) 799 Roosevelt Road NRC Filef83-05-01 Glen Ellyn, IL 60137 RE: DOCKET NO. 50-329/330 MIDLAND PLANT - UNITS 1 AND 2 OVERVIEW OF THE CONSTRUCTION COMPLETION PROGRAM REPORT NO. 1 Attached is a chronology of Stone & Webster Engineering Corporation (SWEC) participation in Consumers Power Company, (CPCo) Construction Completion Pro-gram. In addition to addressing various meetings attended by SWEC, a status of the development of various phases of the Construction Implementation Over-view Program (CIO) is provided. We will advise your office on a weekly basis as to meetings attended and will report on our program development.- Current-ly six members of the CIO Team are on-site and are supported by two writers, from Boston, in the preparation of evaluation and ' erification checklists. v t If you have any-questions with respect to this report, please contact me at extension 665 (Bechtel), 517-631-4286. Very truly yours, /4lh __ g Stanle W. Baranow Program Manager Enclosure SWB/dah RCook, NRC Midland ! cc: i JJHarrison, NRC Glen Ellyn* DBMiller, Midland RBKelly, S&W APAmaruso. S&W =73cGi303&
w -. ~.... The initial visit to the site by the undersigned, was made on April 28, 1983 for 4 an introductory meeting with CPCo management personnel. Throughout this period numerous meetings were attended by CIO personnel, listed by dates shown:
- 1) April 29, 1983 - Management Review of the Construction Completion Program.
- 2) May 5,1983 A.M. - Introductory meeting with key members of the Management Review Committee; CPCo, Bechtel and SWEC.
- 3) May 5, 1983 P.M. - Meeting with R. Wells, B. Palmer, MPQAD.
Discussions on Training and CCP, received handouts of electrical NCRs, NRC correspondance, Inspectors Training Program and a copy of the CPCo Nonconformance procedure.
- 4) May 11, 1983 - Introductory meeting with Mr. R. Cook, NRC site Senior Inspec-tor; briefly discussed the philosophy and implementation of the CIO program.
The subject of weekly progress reports and meetings with NRC and CPCo was raised. Mr. Cook advised that weekly reports and meetings would not be re-quired during SWECs development of the' overview program, but would commence with the implementation of the CCP.
- 5) May 12, 1983 - Meeting with the NRC, CPCo, Bechtel and SWEC for discussion of the Construction Training Program FPG-2.000 Rev. 1 Program requires re-vision to address how " Trainers are trained."
- 6) May 17, 1983 - Meeting with NRC regional and site representatives.
The Quality Verification Program Document was reviewed in its entirety. Numer-ous areas were judged by the NRC to be unsatisfactory, particularly, the ( 95/95% acceptability plan. Also addressed were NRC concerns to responses by CPCo in letters dated April 6 and April 22, 1983 which were judged to be inadequate. NRC requested that the CIO perform an overview evaluation of the Interaction System walkdown of Safety Related equipment. l
- 7) May 18, 1983 - Management Review for Preparation and Statusing of Bulk Han-gers organization and training of supervision and craft personnel.
In at-I tendance were representatives of CPCo, Bechtel and SWEC.
- 8) May 23,.1983 - Meeting with R. Wells, Executive Director, MPQAD and the l
undersigned to discuss documentation required by CIO;PQCIs, status of PQCI development, INPO audit findings and responses, training matrix, CPCo commitments to the NRC. Also, discussed was the vehicle to be used to identify CIO concerns noted during reviews of PQCIs where attributes appear to be ambiguous and/or not in compliance eith Code requirements. Method of Communication / Notification is under consideration.
- 9) May 23, 1983 P.M. - Meeting with Roy Wells, Executive Director, to discuss getting on copy for various documents i.e. PQCIs, Inpo Audit findings and status, training matrix, status of PQCI development.
i
- 10) May 27, 1983 - Meeting with Bruce Peck, CPCo Construction Superintendent and l
Bechtel Representatives to discuss Construction Completion Team orgsnization. !~ Topics included background and Philosophy, Bechtel Construction Organization, CCP Organization. Team Organization, communications between Bechtel, CPCo l EC10 CIO Team Organization, Objectives and Philosophy. l i STATUS OF PROGRAM DEVELOPMENT l A. CIO Plan transmitted to the site NRC Inspector and CPCo on Thursday, May 19, 1983. r ~ .,.c,-.
a B.- Evaluation Plan (software assessment), in rough draft-awaiting comments. P C. Checklicts under development:-
- QC and Construction Training - Evaluation
- Management CCP responsibilities - Evaluation
- Bulk Hanger Organization - Evaluation
- "N" series procedures - Evaluation
- Reinspection of Pipe Component Supports P119/P129 walkdown - Evaluation and Verification 4
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