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O Consumers Power James W Cook Vice PressJent - Projects. Lngunrenng and Consfrwetsom General offices; 1945 West Pernell Road Jackson. MI 49201 * (5173 788-0453 September 26, 1983 Mr Richard C DeYoung Director Office of Inspection and Enforcement US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS 50-239, 50-330 RESPONSE TO EA83-03 FILE:
0.4.2 SERIAL
25914 29, This letter responds to your letter to Consumers Power Company dated August 1983, reciting the conclusion of the Office of Inspection and Enforcement re-garding the imposition of a civil penalty for violations found during Inspec-tion 83-23.
The Company was notified of these violations in a letter dated February 8, 1983. The Company's response, dated March 10, 1983, admitted that a civil penalty was warranted but asked that the penalty be reduced because of the prompt, thorough corrective actions undertaken in response to the violations. While the Company is disappointed that the Commission has not granted our request for mitigation of the penalty, we nevertheless agree to pay in full the penalty as set forth in your August 29, 1983 letter. Accord-ingly, please find herewith a check in the amount of $116,500.
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OM/0L SERVICE LIST Mr Frank J Kelley, Esq Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, MI 48640 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Frederick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernabei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NV Washington, DC 20009 9/3/83 miO583-0429a100
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EMORANDUM FOR: The Atomic Safety and Licensing Board for the Midland Plant, Units 1 and 2 FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SCHEDULE FOR COMPLETION OF RE-REVIEW 0F THE MIDLAND DIESEL GENERATOR BUILDING (BN 83-142)
On July 27, 1983, Board Notification 83-109 transmitted the NRC staff plan to address the concerns of Dr. Ross Landsman of Region III regarding the structural adequacy of the Midland Diesel Generator Building (DGB).
Enclosures 1, 2 and 3 to that Notification provided respectively: (1) a discussion of the Region III and NRR activities in this regard; (2) Dr. Landsman's written statement of his concerns and; (3) a detailed NRR action plan, including the schedules for completion of the effort.
This Board Notification 83-142 further supplements the information regarding the DGB re-evaluation. As with the original Notification, this updated Information is provided in accordance with NRC procedures regarding Board Notifications and is deemed as information material and relevant to safety issues in the Midland OM/0L proceeding. Specifically, the re-evaluation effort is relevant to: (1) concerns expressed by Dr. Landsman in the OM - OL hearing and elsewhere regarding the adequacy of the Diesel Generator Building and; (2) testimony by members of the NRC staff and staff consultants during the December 10, 1982 hearing session regarding the Diesel Generator Building.
The enclosure contains a memorandum from D. G. Eisenhut to R. H. Vollmer accepting a delayed schedule for completion of the review of Dr. Landsman's concerns. Attachments to the Eisenhut memorandum include the Vollmer to Eisenhut memo noting the need for the delay in the schedule which was provided in BN 83-109. The Vollmer memo notes that issuance of the task force's findings will be delayed from September 28,1983 (i.e. 45 working days after receipt of Dr. Landsman's statement) to October 15, 1983. The Vollmer memo also includes a revised work plan. The events shown through September 13, 1983 have been completed as scheduled. The discussions with various individuals on September 8 and 13,1983 were in accordance with the 1
task force's role to interview concerned individuals. Although not shown, i
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. the individuals with whom the task force met on Septenber 8,1983 also included H. Singh of the U.S. Army Corps of Engineers. A second attachment to the Eisenhut memo is a letter from B. Gd; de of the Government Accountability Project expressing concerns related to the tatt force review.
bb Thomas M. Novak, Assistant irector for Licensing Division of Licensing
Enclosures:
As stated cc: Licensee / Boards Service List SECY OGC OPE 1
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DISTRIBUTION LIST'FOR BOARD NOTIFICATION (BN 83-142)
Midland Units 182, Docket Nos. 50-329/330 ACRS Members Charles Bechhoefer, Esq.
Dr. Robert C. Axtmann Ms. Lynne Bernabei Mr. Myer Bender Dr. Max W. Carbon James E. Brunner, Esq.
Mr. Jesse C. Ebersole Dr. John H. Buck Mr. Harold Etherington Myron M. Cherry, P.C.
Dr. William Kerr Dr. Frederick P. Cowan Dr. Harold W. Lewis T. J. Creswell Dr. J. Carson Mark Steve J. Galder, P.E.
Mr. William M. Mathis Dr. Jerry Harbour Dr. Dade W. Moeller Mr. Wayne Hearn Dr. Milton S. Plesset Mr. James R. Kates Mr. Jeremiah J. Ray Frank J. Kelley, Esq.
Dr. David Okrent C1ristine N. Kohl, Esq.
Dr. Paul C. Shewmon Mr. Howard A. Levin Dr. Chester P. Siess Mr. Wendell H. Marshall Mr. David A. Ward Michael I. Miller, Esq.
Thomas S. Moore Esq.
Mr. Paul Rau Ms. Mary Sinclair Ms. Barbara Stamiris Frederick C. Williams, Esq.
Atomic Safety and Licensing Board Panel f.tomic Safety and Licensing Appeal Panel Docketing and Service Section Document Management Branch D. Hood M. Miller E. Adensam 4
T. ilovak/M. O'Brien M. Duncan LB #4 Reading File S. Black
- 11. Williams D. Eisenhut R. Purple dime
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Mr. J. W. Cook Vice President Consimers Power Company 1945 West Parnall Road Jackson, Michigan 49201 l
cc: Stewart H. Freeman James G. Keppler, Regional Administrator Assistant Attorney General U.S. Nuclear Regulatory Commission, State of Michigan Enviornmental Region III Protection Division 799 Roosevelt Road 720 Law Building Glen Ellyn, Illinois 60137 Lansing, Michigan 48913 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way i
124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909 Mr. R. B. Borsum Geotechnical Engineers, Inc.
Nuclear Power Generation Division ATTN: Dr. Steven J. Poulos Babcock & Wilcox 1017 Main Street 7910 Woodmont Avenue, Suite 220 Winchester, Massachusetts 01890 Bethesda, Maryland 20814 Billie Pirner Garde Mr. Don van Farrowe, Chief Director, Citizens Clinic Division of Radiological Health for Accountable Government Department of Public Health Government Accountability Project P.O. Box 33035 Institute for Policy Studies Lansing, Michigan 48909 1901 Que Street, N.W.
Washington, D. C.
20009 U.S. Nuclear Regulatory Commission Resident Inspectors Office Commander, Naval Surface Weapons Center Route 7 ATTN: P. C. Huang Midland, Michigan 48640 White Oak Silver Spring, Maryland 20910 Mr. Paul A. Perry, Secretary Consumers Power Company Mr. L. J. Auge, Manager 212 W, Michigan Avenue Facility Design Engineering Jackson, Michigan 49201 Energy Technology Engineering Center P.O. Box 1449 Mr. Walt Apley Canoga Park, California 91304 c/o Mr. Max Clausen Battelle Pacific North West Labs (PNWL)
Mr. Neil Gehring Battelle Blvd.
U.S. Corps of Engineers SIGMA IV Building NCEED - T i
Richland, Washington 99352 7th Floor 477 Michigan Avenue Mr. I. Charak, Manager Detroit, Michigan 48226 NRC Assistance Project Argonne National Laboratory 9700 South Cass Avenue i
Argonne, Illinois 60439 1
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$EP 2 01983 MEMORANDUM FOR:
Thomas Novak, Assistant Director for Licensing FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
BOARD NOTIFICATION FOR MIDLAND I have determined that the attached correspondence concerning a new schedule for the review of the Landsman concerns should be transmitted to the Board and parties for Midland according to the procedure of Office Letter No.19.
Your transmittal should include both enclosures to my memorandum to Vollmer.
Issue this as Board Notification 83,142.
' Darrell G. Eisenhut, Director Division of Licensing
Enclosure:
As Stated cc: E. Adensam D. Hood L l!?-
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ENCLOSURE 1
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%.7 SEP 2 01983 MEMORANDUM FOR:
Richard H. Vollmer, Director Division of Engineering FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
EVALUATION OF THE LANDSMAN CONCERNS FOR MIDLAND Your letter of September 8,1983 (Enclosure 1) provided a revised schedule for the DE work plan regarding the Landsman concerns. While I find the proposed schedule acceptable I feel compelled to emphasize that we must i
ensure that no further slippage occurs.
I am also in receipt of a letter fmm Billie Garde (Enclosure 2) that indicates their understanding that several staff members had " strong feelsings about the approval by the DGB resolution." Please consider this letter in your ongoing review.
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i Darrell G. Eisenhut, Dire: tor Division of Licensing
Enclosures:
- 1. Vollmer memo to DGEisenhut 8/8/83
- 2. B. Garde to DGEisenhut 7/19/83
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SEP 8M MEMORANDUM FOR: Darrell G. Eisenhut Director Division of Licensing, ONRR FROM:
Richard H. Vollmer Director Division of Engineering, ONRR
SUBJECT:
EVALUATION OF LANDSMAN'S CONCERNS REGARDING DIESEL GENERATOR BUILDING AT MIDLAND
References:
1.
Memo, Eisenhut to Keppler, June 27, 1983 2.
Memo, Vollmer to Eisenhut, July 21, 1983 3.
Memo, Landsman to Warnick, July 19, 1983 Due to schedule conflicts between the Diablo Canyon Review and this effort on Midland which affects the personnel from Brookhaven National Laboratory (BNL),
CE must reschedule the completion of the Midland DGB review from September 28 to October 15, 1983. During the :nonth of September, the BNL personnel will I
partially be committed to Diablo Canyon reviewing ITR's, preparing testimony and taking depositions. If you do not concur with slipping this effort to accomodate the demands of Diablo Canyon, please advise accordingly.
Enclosed is a revised Work Plan for the completion of the DE evaluation of the Landsman's concerns. The ASLB (via OELD) should be advised of the revised schedule for completion.
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Richard H. Vollmer, Director Division of Engineering, ONRR
Enclosure:
As stated cc:
H. Denton l
J. Knight G. Lear P. Kuo N. Romney l
C. Tan E. Adensam D. Hood CONTACT:
N. Romney, SGEB 49-08987 hNiw6C[ '
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ENCLOSURE Midland NPP Diesel Generator Building Review Work Plan 4
August 24 - 25, 1983 Task Force - Site Visit - Completed September 8, 1983 Task Force meet with:
F. Rinaldi J. Kane J. Matra G. Harstead Septen.ber 13,1983 (AM)
Task Force meet with R. Landsman (AnnArbor, Michigan)
September 12 - 13, 1983 Task Force conduct audit of Midland DGB (AnnArbor, Michigan)
October 15, 1983 Issue Report of Findings e
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. GOVERNMENT ACCOUNTABluTY PROJECT Institute for Polior Studies (202)234 9382 1901 Que Street. N.W., Woshington. D.C. 20009 August 19, 1983 Mr. Darrell G. Eisenhut, Director.
Division of Licensing office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
On August 10, 1983 you responded to my Aug.
8, 1983 request for information regarding the review group formed to consider the concerns of Mr. Ross Landsman.
On Aug. 11, 1983 during a public meeting on the Construction Completion Plan (CCP) you indicated that a review of the NRR Engineering Division had indicated no support or agreement with Mr. Landsman.
Mrs. Barbara Stamiris, the Citizen Intervenor on the soils settlement ("0M") proceedings inquired specif:.cally about Mr. Joe Kane of your office and a consultant, Dr. Sing, of the U.S. Army Corps of Engineers.
You indicated that you were not aware of whether or not those individuals had been asked or not.
Please inform Mrs. Stamiris and myself of the answer to that question.
More specifically, it is our clear understanding that several members of the Engineering Staf f in both the Region and in headquarters had very strong feelings about the approval of the DGB resolution.
We expect your technical review to include the past concerns of both Regional and headquarters engineers.
Furthermore, since the concerns about this issue and its resolution are of interest to Congress, the local intervenors and GAP we respectfully request that your office issue an Interim report, allow time for review and comment by the public, and hold at least one open meeting prior to the issurance of the final report on this subject.
A final concern we wish to raise with your office deals with the background of the individuals you have nominated to complete the review of Dr. Landsman's concerns.
All of the people selected are structural engineers.
Dr. Landsman of course, is a geo-technical engineer.
Clearly, any review team should contain professional representation from Dr. Landsman's discipline, and suggest that you appoint an independent geo-technical consultant to review the work of your engineers.
Finally, we concur with Mr. Robert Warnicks suggestion contained in his July 21, 1983 memo to you that "all related correspondence and the resulting report (s) and documentation should be placed in the public document room and distribution list. "
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Thank you for your extraordinary promptness to my August 8, 1983 letter, it was a pleasant surprise.
I look forward to an equally pleasant substantive report on the DGB from your office.
Sincerely, Billie Pirner Garde Citizens Clinic Director W9W 4
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015TRIBUT10N:
i g Nos. 50-329/330 Auuust 10. 1983 Local PDR PRC Sy5 tem LB M r/f l
Socket Nos: % 37*
EAdensas and 40-?30 DHood DEisenhut P1111e Pirner Garde Director Movak Citizens Clinic for Accountable Gcvernment RYOII"'I Governrant Accountab11f ty Project Glear Institute for Policy Studies E ncan 1901 Ove Street, W.W.
Attorney, OELD Washir.gton D. C.
Dear Ms. Garde:
ACRS (16)
Your letter of August 8,1983, noted that the Divisten of Engfpertog in the Office of 44eclear Reactor Regulettees has fossed a review group to review the concern Dr. Ross Landsmen regardtag the structors) 4densesy.ef the Diesel Generater Bu (DGR) at Midland Plent. Unite 14 f.,.The esagefas of Dr. Landsmen and the taple-mentation concept for the perfew task uere'40stfhed is.Desed Notifiestion 33-109 which was forsorded to you en July IFg 1988.$respealetter requests Wer nos fellewt additional inforsetfen. These ftene and eur.,
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teral and Geotechnical meering Bransh (SMS).,, hse toen sosters from the 2C structuel staff are essigned - Sr. C. A' Ten ~ end ler R. B.' Banney. The teen l
moders sesefend by ear technteel.eeefstesse opatreet with tremoven Rationa l
Laboraterfes (SE.1 are Sectors H. Retchy 8. Miller, C. Coastest$es. P. W and A. philippecepeales. Eaglesere 1 s,
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into the technical report.
consistent with "Open To the extent practical, the revlew will be conducted.3 Federal Register 28056 heeting and Statement of hRC Staff Policy" frem theThis Statement an June 28. 1978.
between the IstC techatcal staff and applicants for licasses to be open for interested members of the pelft, petitleners, interveners, or other parties Records of sfgelffsant tafernstion exchsages and to attend as observers.
correspondence will be asiatateed by the Pawlow group and summ their final report as appropriate.
The consultant's consultants as mell as the anC met ers of the rarteu group.
critique of Dr. Landsman's cancerns util be incorporated directly into the report. The report will be made pub 11civ available.
1 trust this reply is responstve to your requests.
Sincerely.
De roll G. f.1senhut. Director Dtvisten of Licensing Office of nuclear Reactor Regulation
Enclosures:
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4 e g GOVERNMENT ACCOUNTADILITY PROJECT Inv. tote for Poi.cy Studies
'202)2N 03L 1901 Que Strem N W. Washington D C 20009 August 8, 1983 Mr. Darrell G.
Eisenhut Direct Division of Licensing Regulatory Commission U.S.
sat Washington, D.C.
20555
Dear Mr. Eissahut:
It is my understanding that the Division of Nuclear Reactor Regulations (NRR) Divisies of Engineering has developed review group composed of f our technical meabers, a group leader, atwo team members f rom the structural review staf f and a structural consultant to review the concerns of Dr. Ross Landsman over the the structural adequacy of the Diesel Generator Duilding at Midised Nuclear Power Plant.
Flesse provide the f ollowing information to a's as soon as possible f
1.
The names, resumes, and monimation process for the members of the review taang 1_/
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The methodology by which the review ef f ort will be completed, and 3.
The plans for public participation or oversight, including the input of empert consultants, into the technical j
report.
f We look forward to your immediate responsa.
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In particolar we are interested in the selecties of the
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Consumers Power Company ATTlh Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 s
Gentlemen:
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) of the Midland Nuclear Plant, Units 1 and 2, and our meeting of August 12, 1983, to review 3he results of that assessment covering the period July 1,1981, througn March 31, 1983. A copy of the SALP 3 Report was provided for your review in advance of the meeting.
Enclosed is the final SALP 3 Report that in:orporates the SALP Board Chairman's letter to you and your letter of September 6, 1983.
Frommyperspective,your[ffortstoimplementyourQualityAssurance(QA) program at the Midland Nuclear Plant during the assessment period clearly were ineffective. This was exemplified by our rating the Soils ar P Toundations functional area as Category 3 and by our identification during the Diesel Generator Building inspection of numerous weaknesses in the implementation of your QA p ngram.
I am encouraged by your commitment to accomplish the improvements necessary to achieve the quality performance level that the NRC expects as addressed in yout letter of September 6, 1983.
However, until improved performance is demonstrated, the NRC will continue to require strong oversight through third party inspections as well as its own inspections. Furthermore, while it is my desire to move away from our role of literally approving day-to-day activities in the remedial soils work to impleinent the ASLB Board Order, I do not intend to seek relief from that Order until we have the needed confidence that work in that area will be carried out effectively.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the SALP Report will be placed in the NRC's Public Document Room.
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sEJ: 16.,e3 is No reply to this letter is required; however, should you have any q'uestions concerning these matters, we will be pleased to discuss them with you.
Sincerely, d'
W James G. Keppler Regional Administrator
Enclosure:
SALP 3 Report No. 50-329/83-09; 50-330/83-09 cc w/ encl:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
Howard Levin (TERA)
Billie P. Garde, Government Accountability Project Lynne Bernabei, Government Accountability Project J. M. Taylor, IE h
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Systematic Assessment of Licensee Performance
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Midland Nuclear Generating Station, Units 1 and 2 Docket Nos. 50-329; 50-330 i
Report Nos. 50-329/83-09; 50-330/S3-09 Assessment Period July 1, 1981 through March 31, 1983 1
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d' CONTENTS Page I.~ Introduction.......................................................
1 II.
Criteria..........................................................
3 I I I. S umma ry o f R e s u l t s................................................ 4 IV. Pe r fo rma n ce An a lys e s.............................................. 5 V.
Suppo rting Da ta and Summa ries....................................
13 VI.
Enclosures.......................................................
19 Letter to Licensee from SALP Board Chairman Licensee Comments 4
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INTRODUCTION The NRC has established a program for the Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon those observations. SALP is supplemental to normal regulatory processes used to insure compliance to the rules and regulations. SALP is intended, primarily from a his-torical point,to be sufficiently diagnostic to provide a rational basis for allocating future NRC resources and to provide meaningful guidance to the licensee's management to promote quality and cafety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on June 7, and July 11, 1983, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance. A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee safety performance at Midland Nuclear Station, Units 1 and 2, from July 1, 1981 through March 31, 1983.
Inspections were conducted in March and April 1982 to evaluate the significance of the quality control (QC) inspection deficiencies identified during the special team inspection of May 1981. These followup inspections indicated that QC inspections were not properly identifying deficiencies in the installation of equipment. As a result of these deficiencies and due to recurring problems in the licensee's remedial soils work activities, increased NRC inspection effort was initiated through the formation of a special Midland Section comprised of inspectors dedicated solely to the Midland plant. Additional inspection assistance was obtained through a special contract with a Department of Energy Laboratory.
To aid in the evaluation of the as-built condition of the plant, a special inspection of the Diesel Generator Building was conducted during the period of October 12 through November 25, 1982. This inspection identified significant violations which demonstrated a breakdown in the implementation of the licensee's Quality Assurance (QA) program.
In addition, it resulted in the licensee's decision to suspend some safety-related work activities (December 3, 1982) and to formulate a construction completion program to provide assurance I that safety-related structures and systems were constructed as designed.
Due to the significant viola. ans, the NRC imposed a civil penalty of
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7 $120,000.
In view of the suspension of portions of safety-related work activities and the licensee's proposed construction completion program, the Region III Regional Administrator determined that the SALP 3 appraisal for 1
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Midland would address only areas where work activities continued; namely Remedial Soils (Soils and Foundations), the Nuclear Steam Supply System (Safety-Related Components and Piping Systems and Supports), the Heating, Ventilating, and Air Conditioning System (Support Systems), and Licensing Activities.
The results of the SALP Board assessments in the selecte functional areas will be presented to the licensee at a meeting in the near future.
SALP Board for Midland Nuclear Station:
J. A. Hind, Chairman, Director, Division of Radiological and Materials Safety Programs C. E. Norelius, Director, Division of Project and Resident Programs R. L. Spessard, Director, Division of Engineering T. N. Tambling, Chief, Program Support Section R. F. Warnick, Director, Office of Special Cases E. G. Adensam, Chief, Licensing Branch 4, NRR
'J. J. Harrison, Chief, Midland Section R. N. Gardner, Project Inspector R. B. Landsman, Reactor Inspector R. J. Cook, Senior Resident Inspector, Midland B. L. Burgess, Resident Inspector, Midland R. W. Defayette, Reactor Engineer
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II. CRITERIA The licensee performance is assessed in selected functional areas
' depending upon whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history i
5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee man-agement attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Li-4 censee management attention and involvement are evident and are concerned I
with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational
- safety or construction is being achieved.
Category 3: Both NRC and licensee attention should be increased. Li-
- censee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resource,t appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
3
l t
i.,
III.
SUMMARY
OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Soils and Foundations X
2.
Containment and other Safety Related Structures NOT ADDRESSED IN THIS REPORT
- 3.
Piping Systems and Supports X
4.
Safety Related Components X
5.
Support Systems X
6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT
- 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT
- 8.
Licensing Activities X
9.
Quality Assurance NOT ADDRESSED IN THIS REPORT
- 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT *
- For Functional Areas "Not Addressed In This Report" see Section I, Introduction.
S T.
4
IV. Performance Analyses 1.
Soils and Foundations a.
Analysis During this SALP period the licensee finalized the Remedial Soils program and initiated steps to implement the Remedial Soils measures necessary to correct previously identified soils deficiencies. The NRC's review and approval of the design of the Remedial Soils measures is documented in Supple-ment No. 2 to the Midland Safety Evaluation Report issued in October 1982. The steps taken by the licensee to implement the Remedial Soils measures during the SALP period include the following:
The excavation of the access shafts to elevation 609 The installation of six temporary underpinning piers Preparatory work for the Service Water Pump Structure underpinning Initiation of temporary dewatering system for the Service Water Pump Structure Initiation of probing for buried utilities adjacent to the Service Water Pump Structure The installation of the permanent dewatering system wells The installation of the auxiliary building underpinning instrumentation system i
Thirteen inspections (or portions of inspections) were per-formed in this area. During this SALP period a total of nine noncompliances and two deviations with NRC requirements were identified as follows:
(1) Severity Level IV - examples of failure to follow pro-cedures and failure to develop adequate procedures (329/82-03; 330/82-03)
(a) Failure to revise design drawings according to site procedural requirements (b) Failure to develop an adequate excavation procedure
=
s (c) Failure to assure design verification acoording to site procedural requirements i
i 5
t (2) Severity Level IV - examples of failure to develop adequate procedures (329/82-05; 330/82-05)
(a) Access shaft work was initioted without having a reviewed and approved procefore (b) Failure to develop adequate procedures to control specification design changes (c) Failure to develop adequate specification for permanent dewatering wells (d) Failure to develop an adequate procedure to prepare or implement overinspection plans (3) Deviation - failure to provide a qualified civil QA staff (329/82-05; 330/82-05)
(4) Severity Level IV - failure to establish a QA program which provided controls over the underpinning monitoring system (329/82-06; 330/82-06). This finding resulted in the issuance of a Confirmatory Action Letter (CAL) on March 31, 1982 (5) Severity Level V - failure to install anchor bolts in accordance with site procedures (329/82-11; 330/82-11)
(6) Deviation - failure to use approved installation /coord-ination forms to document the installation of underpinning monitoring instrumentation (329/82-11; 330/82-11)
(7) Severity Level IV - failure of specifications to identify the location of well sampling points (329/82-18; 330/82-18)
(8) Severity Level IV - failure to assure that the slope layback at the Auxiliary Building access shaft was con-structed in accordance with design (329/82-18; 330/82-18)
(9) Severity Level IV - examples of failure to establish measures to control the issuance of documents (329/82-21; 330/82-21)
(a) failure to use a controlled copy of a Project Quality Control Instruction (PQCI) to prepare a QC recerti-fication examination. This finding resulted in the
(
issuance of a CAL on September 24, 1982 (b) Failure to control QC manuals
=
(10) Severity Level III - failure to translate applicable
~
regulatory requirements concerning the purchase of armor stone for a "Q" portion of the perimeter dike into approp-riate specifications and design documents (329/82-22; 330/82-22) 6
(11) Severity Level III - failure to maintain current remedial soils drawings (329/83-03; 330/83-03)
The noncompliances identified during this rating period are evidence of the licensee's continued lack of atten-tion to detail in assuring that the requirements of the Midland QA program were properly implemented. Further-more, these noncompliances indicate the lack of manage-ment attention to quality in this area.
As a result of noncompliance item (4) an investigation was performed by NRC to determine whether material false statements had been made by the licensee's staff in regard to the installation stttus of the auxiliary building under-pinning monitoring instrumentation. The investigation failed to provide conclusive evidence that a material false statement had been made.
An investigation by NRC was initiated during this evaluation period to determine whether the licensee violated the April 30, 1982, Atomic Safety and Licensing Board (ASLB) Order which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit NRC approval. This investigation, which is continuing, focuses on the licensee digging below the " deep Q duct bank" allegedly without NRC approval.
A management meeting was held at the site on August 11, 1982, to discuss the potential violation of the Board Order.
A CAL was issued on this matter on August 12, 1982.
Noncompliance items (10) and (11) are individual examples related to the soils area ttken from much broader items of noncompliance not associated with this functional area.
(Items 10 and 11 were part of two separate citations for failure to adequately implement a quality assurance program.)
The two individual examples taken by themselves would not l
have been rated as severity level III.
In view of continuing deficiencies in the soils area, the ASLB issued an Order on April 30, 1982, suspending all remedial soils act s. ties on safety-related (Q) soils for which the licemice did not have prior NRC approval.
Subsequent to this order the licensee resumed remedial soils activities with NRC approval. During the follow-ing months numerous problems occurred due to miscommun-ciation/ misunderstanding between the licensee and the NRC. To resolve these issues a Work Authorization.
=
Procedure was developed. This procedure requires the licensee to request and obtain written NRC suthorizhtion prior to the initiation of each remedial stils work b
7
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- i activity.
In addition, the scope of the Work Excavation Permit System was expanded to include all remedial soils work including underpinning. Due to the NRC's concerns 4
with the licensee's ability to properly implement the quality program in the remedial soils area an indepehdent third party overview was established. All the preceding actions occurred at the direction of the NRC, and were not a result of the licensee's initiative.
b.
. Conclusions i
The licensee is rated Category 3 in this area. Although this is the same rating as the previous assessment period, the j
licensee's overall performance in this functional area has continued to decline. NRC findings during this assessment period indicate a_ continued lack of_ attention to detail by the i
licensee and the continuing inabiltCilp:a the part of tha 11-ceasee to implement property'Ene requif3hents of the Midland QA program. A rating of less tnan minissily acceptable (Not datea) was considered by the Board; however, a Category 3 rating was assigned because of the stringent controls insti-tuted to govern work in this area, i.e., the Work Authorization Procedure, the Work Excavation Permit System, the independent third party overview, and continued scrutiny by the NRC staff.
i c.
Board Recommendations The Board recommends that the licensee thoroughly review the
~
performance of construction, engineering, and Quality Assurance managers in the Remedial Soils a_rea.
Ane implemei.tation of measures to provide czoser attention to detail in remedial soils work activities and to provide assurance that future remedial soils work will conform to the requirements of the i
Midland QA program should be a continuing management goal.
L Based on information provided to the Board subsequent to the evaluation period, the Board notes that the licensee has con-tinued to have performance problems in this area.
3&4. Safety-Related Components and Piping Systems and Supports a.
Analysis l
Portions of ten inspections were performed in the Nuclear Steam l
Supply System area during the evaluation period. The inspec-l
- ~
tions involved the observation of large and small bore hanger installations (including snubbers and restraints), receipt and installation records, modification of the reactor pressure l
vessel supports, auxiliary feedwater internal header modifica-i tion, and containment structural steel welding. Within the scope of this effort one item of noncompliance was' identified as follows:
i 8
Severity Level V - Failure to-follow procedures regarding the tagging of a valve located in the welding fabrication area (329/83-01; 330/83-01).
The licensee's resources appear to be adequate. The management controls being utilized, the records, and the records control system met requirements. The overall effectiveness and attitudes of licensee personnel in complying with requirements were con-sidered acceptable.
b.
Conclusion The licensee is rated Category 2 in this area. This is the same rating as the previous assecsment period.
c.
Board Recommendations The Board notes that subsequent to this evaluation period the NRC has indications that quality problems exist with installed components, piping, and piping supports. These indicators include the Independent Design and Construction Verification Program (TERA's Monthly Status Report dated May 27, 1983) and the licensee audit conducted February 23, 1983 through March 10, 1983 (including the R. Sember memo to D. Miller dated March 13, I
1983).
NRC inspection activities should focus on assuring that in-stalled items meet the design and regulatory requirements.
l l
5.
Support Systems a.
Analysis Portions of four inspections were performed covering Heating.
Ventilation, and Air Conditioning (HVAC) welder certifications, velder procedure qualification, and material traceability.
No items of noncompliance or deviations were identified during these inspections.
j As a result of a licensee audit of Photon Testing, Inc., the l
licensee suspended welding of safety-related HVAC work.
Photon Testing, Inc. had previously been contracted by the 4
licensee to qualify welding procedures and certify welders for HVAC fabrication and installation. The cumulative audit findings made the credibility of some of the certifications of previously_ certified welders, as well as the adequacy of some of the welding procedures, indeterminate. Due,to the
=
audit findings, the NRC imposed a hold point for the restart of safety-related HVAC welding.
9
An initial attempt by the licensee to demonstrate to the NRC that affected HVAC welding procedures had been qualified and were ready for implementation demonstrated that the welding procedures were still inadequate. As a result, the NRC did not authorize the licensee to restart safety-related HVAt welding.
No other problems in the HVAC area were identified.
b.
Conclusion The licensee is rated Category 2 in this area. This is a lower rating than the previous assessment due to the licensee's failure to initially take adequate corrective action to resolve the deficiencies identified in the Photon Testing, Inc. audit and the licensee managements failure to identify the inadequate initial corrective action.
c.
Board Recommendations Licensee management involvement should be increased in the area i
of ensuring proper and timely followup to correcting identified j
deficiencies. The board notes that subsequent to this evalua-tion period the licensee successfully demonstrated the adequacy of welding procedures and welders to perform to.those procedures.
Based en the demonstration, the NRC authorized the resumption i
of HVAC welding.
8.
Licensing Activities i
a.
Analysis The assessment was based on our evaluation of the following licensing activities:
Soils and Structures Emergency Planning Equipment Qualification Quality Assurance Program Natural Gas Pipeline i
Auxiliary Feedwater System Instrumentation and Control Systems Review Seismic Spectra i
Fire Protection Implementation of NUREG-0737 Items 4
For the licensing activities evaluated, there appeared to 7
j be appropriate management attention with decision making i
taking place at adequate levels. During numerous audits i
conducted by NRR, including audits relating to the soils issue, emergency planning, instrumentation and control systems, fire protection and equipment qualification, the records maintained by the licensee were generally complete.
l l
10 l-
.. - -.~
well maintained and available.
In almost every area, the appropriate level.of management participated in meetings
)
I with the NRC on safety, technical, and licensing issues and demonstrated knowledge on the meeting's subject matter.
In the soils remedial areas, a reorganization provided an execu-tive manager fully dedicated to this area; however,.some diffi-culties occurred in the early phases of this reorganization.
~
Clear lines of responsibility were established in support of the staff's safety evaluation and subsequent issuance of the Safety Evaluation Report. Priorities established by the li-censee management were generally consistent with and supportive of those priorities established by the staff.
Commitments made to incorporate resolutions into FSAR revisions were kept ar.d were generally timely. The licensee also made an objective and extensive effort to track open issues related to the safety evaluation. One issue which involved implementation of a THI Action Plan Item (Item I.B.I.2) reached an apparent impasse between the staff and applicant. However, when the proper level of NRC and licensee management attention was focused on the issue, both sides were able to reach an acceptable resolution. On the other hand, licensee's management failed to recognize the safety significance of constructing a high pres-sure gas facility in close proximity to safety structures until after construction completion.
4 Generally, licensee personnel involved in resolution of technical questions were knowledgeable and clearly understood the issues. During the appraisal period, the technical sub-4 mittals by the licensee to the NRC were usually complete and conservative. Resolution of two technical issues during the i
safety evaluation required elevation to the Division Director appeals level.
In one of these issues, relief was given to the licensee.
In the other, the licensee was required to i
commit to installation of a third auxiliary feedwater pump.
In both cases, however, the licensee prepared reasonable technical justification for their position.
In addition, the licensee's response once the appeals decision on the auxiliary feedwater pump had been made was excellent.
The licensing area of soils and structures needs improvement insofar as the approach to technical issues. There was l
reluctance by the licensee to perform certain soils remedial I
work utilizing accepted quality assurance procedures until l
required by the NRC. In regard to the buried piping issue, the licensee appeared to lack a thorough understanding of the safety issues involved resulting in the submission of additional
=
i information several times before acceptable resolution was E
t I
11
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4 achieved. Improvement in the soils area over the appraisal period has been evidenced by more specific and clearer sub-j mittals to the NRC.
Responses to the NRC were generally timely and thorohgh. The licensee was particularly responsive in the area of instrumenta-tion and control systems. Additionally, in questions concerning the natural gas pipeline, the licensee demonstrated a willing-ness to address NRC concerns effectively and responsiveness increased accordingly. Responsiveness was rated poorly for those~ licensing issues which remained unresolved for a long period of time such as resolution of the buried piping problem.
With respect to licensing staff, positions appear to be well defined and responsibilities identified. Staff is adequate and at levels consistent with the activity for the licensing activities evaluated. The licensee effected reorganizations and personnel replacements within a reasonable time insofar as key positions are concerned.
In some cases, however, the staff considers that too much reliance was placed upon repre-sentation by consultants and by the architect / engineer.
b.
Conclusion The licensee is rated Category 2 in this area.
Generally, in licensing activities, the licensee expressed a willingness to respond to NRC initiatives. Submittals were usually timely and thorough. Especially notable is the degree of management attention directed toward licensing activities as evidenced by meeting participation and the a
level at which decisions occur. Areas of above average performance in all criteria include instrumentation and control systems reviews.
Conversely, although improvement in the soils area has been seen during this appraisal period, it is imperative for the licensee to continue to focus a high level of management attention in the soils area in order to maintain an acceptable level of performance insofar as licensing activities are concerned.
c.
Board Recommendations A high level of licensee management attention should be con-tinued in resolving the adequacy of responses to technical issues and improvement of management controls in the area of remedial soils and underpinning activities.
7 i
12
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V.
Supporting Data and Summaries A.
Noncompliance Data Facility Name: Midland, Units I and 2 Docket Nos. '50-329
.50-330 Inspections: No. 81-14 through 83-05 Noncompliance and Deviation Severity Levels Functional Area Assessment I
II III IV V
Dev 1.
Soils and Foundations 2
6 1
2 2.
Containment and Other Safety-Related Structures NOT ADDRESSED IN THIS REPORT 3.
Piping Systems and Supports 4.
Safety-Related Components 1
5.
Support Systems 6.
Electrical Power Supply and Distribution NOT ADDRESSED IN THIS REPORT 7.
Instrumentation and Control Systems NOT ADDRESSED IN THIS REPORT 8.
Licensing Activities 9.
Quality Assurance NOT ADDRESSED IN THIS REPORT 10.
Preoperational Testing NOT ADDRESSED IN THIS REPORT TOTALS 0
0 2
6 2
2 i
N O
5 13
.$3 l
- l. '
B.
Report Data l
1.
Construction Deficiency Reports (CDR)
During this SALP period, 19 CDR's were submitted by the licensee under the requirements of 10 CFR 50.55(e).
a.
Operating procedures must be modified to require at least one reactor cavity cooling fan in service during normal plant operation.
i b.
For certain control circuits, a voltage below the limits t
for proper operation of the motor control center starter coils was calculated. This line voltage drop is a direct result of currents passing through long control cables.
c.
The design of electrical components associated with the i
main steam isolation valves does not conform to the channel separation criteria in Reg. Guide 1.75; also, satisfactory seismic qualification reports have not been submitted.
i d.
Rodent damage has occurred in electrical penetration wiring and cables.
{
e.
The auxiliary feedwater level control valves are fed from Class IE instrument control power instead of Class IE preferred power supplies as specified in the FSAR.
i f.
The existing design of the auxiliary feedwater system pump turbine driver steam admission valve interlock system would i
block steam entry and prevent proper operation.
g.
It has been determined that instrument string error in the steam generator level circuits, under accident conditions, exceeds that allowed to establish steam generator ECCS control setpoints.
h.
Recent inspections at three operating B&W plants indicated damage to the internal auxiliary feedwater header assemb-lies. New external headers will provide all functional requirements.
i.
During an engineering review it was discovered that some Q-related equipment is located in the auxiliary building that is cooled by a non-safety grade HVAC system. During an accident, this could result in some Q-equipment being
=
lost.
l 7
j.
B&W supplied non-seismically qualified transnister mount-ing brackets for transmitters forming part of the reactor coolant pressure boundary.
i J
14
k.
Approximately 80% of the radiation monitoring modules, manufactured by Victoreen, Inc. were found to be noncon-forming. This was due to a significant QA breakdown at the supplier.
1.
During field modifications of 460V Class IE motor control centers supplied by ITE-Gould it was discovered that some of the control power transformers were undersized.
m.
The incorrect size class IE power cables were pulled and 4
installed.
.n.
ACI 349, Appendix B, issued August 1979 specifies that i
shear lugs in embedment designs shall be considered effec-tive only in compression zones. Some Midland embedment designs, which were completed and installed prior to this date, do not meet this new criterion.
o.
No specific features to mitigate frazil ice formation on the service water intake structure are contained in the design of the service water intake structure.
p.
The design of the suction piping for the auxiliary feed-l water system did not include overpressurization protection.
i q.
Unacceptable workmanship conditions have been identified on electrical control panels and cabinets supplied by various suppliers, r.
Bailey Controls Company NI/RPS and ECCAS cabinets have i
terminal blocks which are fastened to the termination panels by Tinnerman Nuts. These nuts could become loose.
s.
Class 1E electrical control cabinets appear to have in-sufficient clearances from adjacent equipment or walls.
The licensee's threshold for reporting is considered to be i
appropriate and the total number of items reported is not con-j sidered to be excessive.
2.
Part 21 Reports 1
5 The licensee issued no Part 21 reports during the reporting period.
1 C.!. Licensee Activities l
l
.". The main construction areas during the evaluation period were NSSS work, electrical equipment, conduits, cable trays, cables, NVAC, remedial coils work, small and large bore piping, pipe hangers and snubbers:- As a l
result of the diesel generator building inspection, the licen'see halted on December 3, 1982, safety-related work with the exception of the following:
system layup, hanger and cable reinspections, post system i
i
)
15 al
l-turnover work, HVAC work, NSSS work, remedial soils work, and design engineering. Preoperational testing was conducted on the Component Cooling Water System, the Decay Heat Removal System,and the Fuel Transfer System.
Units 1 and 2 were reported by the licensee to be 79% complete per the licensee's letter to Hatfield (NRC) dated May 6, 1983. Fuel load dates are estimated by the licensee to be February 1985 and October 1984, respectively.
D.
Inspection Activities The routine inspection effort by the NRC consisted of 39 inspections during the evaluation period.
In addition, a special team inspection (329/82-22; 330/82-22) was conducted to assess the adequacy of implementation of the quality assurance program.
This assessment was done for the most part in the diesel generator build-
'ing where the majority of work was performed subsequent to 1980. This inspection resulted in the licensee suspending some safety-related work on December 3, 1982.
E.
Investigations and Allegations Review 1.
An investigation was conducted to determine whether material false statements had been made by the licensee's staff in regards to the i
installation status of the auxiliary building monitoring instrumenta-l tion. The investigation report (329/82-13; 330/82-13) failed to provide conclusive evidence that a material false statement had been made.
I 2.
An investigation was being conducted during this SALP period to deter-i mine whether the licensee violated the April 30, 1982, ASLB order j
which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit NRC approval. The report was not issued during this SALP period.
.I 1
3.
A number of allegations were received during this SALP period regard-i ing HVAC work by Zack, welding, electrical work, and deficiencies in i
the implementation of the CPCo QA/QC program.
Investigations or special inspections to resolve some of the issues identified within these allegations were initiated during this SALP period.
F.
Escalated Enforcement Action k
1.
Civil Penalties I
A Civil Penalty for $120,000 was issued during this eval"uation period d
in regard to the adverse findings identified during the. diesel gener-ator building inspection (329/82-22; 330/82-22). The licensee's request for mitigation of the amount is under review by the NRC staff.
i 4
16 i
2.
Orders The ASLB issued an order on April 30, 1982, which suspended all remedial soils activities on "Q" soils for which the licensee did not have prior explicit NRC approval. The ASLB issued a hubsequent clarifying order on May 7, 1982.
G..
Administrative Actions
~
1 1.
Corrective Action Letters A letter of understanding was issued by the licensee on a.
March 31, 1982, in response to deficiencies observed during the inspection of the auxiliary building monitoring instru-mentation.
(329/82-06; 330/82-06). This matter is also discussed in Section V.E.1. of this report.
a b.
A Confirmatory Action Letter (CAL) was issued on August 12, 1982, in response to a potential ASLB order violation (329/82-18; 330/82-18). This matter is also discussed in Sections IV.I.a and V.E.2 of this report. Resolution of these concerns was still under investigation at the end of I
the SALP period.
c.
A CAL was issued on September 24, 1982, in respo'nse to deficiencies observed during the inspection of remedial soils QC inspectors recertifications (329/82-21; 330/82-21).
d.
A letter of understanding was issued on December 30, 1982, in response to deficiencies observed during the diesel i
generator building inspection (329/82-22; 330/82-22). This matter is also discussed in Sections V.C and V.F.1 of this 4
report.
i 2.
Management Conferences During this SALP period eighteen conferences were held between NRC and licensee management:
a.
On July 24, 1981, a management meeting was held to discuss inspection findings pertaining to irregularities in control and review of small bore piping system design packages.
b.
On January 12, 1982, a management meeting was held to review and discuss recent changes to the Midland QA organization and the QA program for the remedial soils work.
?
7 c.
On March 30, 1982, a management meeting was held to discuss NRC findings in the installation of underpinning monitoring instrumentation.
~
d.
On April 26, 1982, a meeting was held to present to CPCo management the SALP 2 findings.
l 17
e.
On May 14, 1982, a meeting was held during which the licensee presented a preliminary report of the results of the electrical cable reinspections.
(
f.
On June 21, 1982, a meeting was held to discuss CPCo's response to SALP 2.
3 On August 5, 1982, a meeting was held to further discuss CPCo's l-responses to SALP 2.
l-h.
On August 11, 1982, a management meeting was held to discuss a potential violation of the ASLB order of April 30, 1982, i.
On August 26, 1982, a management meeting was held to discuss Midland QA problems.
j.
On September 2, 1982, a management meeting was held to discuss the Quality Improvement Plan.
k.
On September 29, 1982, a management meeting was held to discuss the integration of QC activities into Midland Project Quality Assurance Department (MPQAD).
1.
On October 5,1982, a meeting was held to discuss the CPCo-TERA proposal concerning the Independent Design Verification Program (IDVP).
m.
On October 29, 1982, a meeting was held to discuss Bechtel performance / problems.
On Nover er 5,1982, a meeting was held to discuss Stone and s
n.
Webster (S&W) qualifications for performance of remedial soils third party overview.
o.
On January 18, 1983, an enforcement conference was held to dise m the diesel generator building findings.
p.
On February 8, 1983, a management meeting was held to discuss the CCP and the IDCVP as well as CPCo and Bechtel performance and desire to take proper' corrective action.
In addition, the NRC announced the imposition of a $120,000 fine due to diesel generator building findings.
q.
On March 7, 1983, a meeting was held to further discuss the CCP.
J r.
On March 15, 1983, a meeting was held to discuss the INPO Self Imposed Evaluation results.
3.
Construction Permit Amendment k
On May 26, 1982, the NRC amended the Construction Permits, CPPR-81 and CPPR-82, to implement the ASLB Ap ril 30, 1982, Order suspending all remedial soils activities on "Q" soils without prior explicit NRC approval.
18
I
\\
VI.
ENCLOSURES e
4 e
e M
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19
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-- i r.ucte Ar. atCu tTosv c:
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fi se c or. ni 1 5,,),** 4(f f m soa m a noto K.*.v. g ctts Ettvu. LL Nois som
'JUL 21 sg3 Docket Ne. 50-329 Do.eket No. 50-330 Consumers Power Company ATTN:
Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Centlemen:
This'referstotheNRC'sSystematickssessmentofLicenseePerformance (SALP) for the Midland Nuclear Plant, Units 1 and 2 for the period July 1, 1981 through March 31, 1983.
A meeting will be scheduled with you in the near future in which Mr. James C. Keppler and members of the NRC staff will present the obstr-vations and findings of the SALP Board. The more significant sal? Board findings are sucr.arized in Enclosure 1.
The enclosed SALP Report which documents the analyses, conclusions and recommendations of the S/IP Board is for your review prior to the meeting.
Since this meeting is intended to be a forum for the mutual understanding of the issues and findings, you are encouraged to have appropriate repre-sentation at the meeting. As a minimum we would suggest you, the Site Manager, $ste QA Manager, and managers for the various functional areas where problets have been identified attend the meeting. Any comments you may have regarding the SALP Report, as well as the SALP process, may be i
discussed at the meeting. Additionally, you may provide written comments within 20 days after the meeting.
t 1
Following our meeting and receipt of your written response, if any, the enclosed report will be issued. The letter issuing the report will provide you a characterization of your overall safety performance along with any appropriate supplemental information regarding the report.
In accordance with Section 2.790 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Pederal Regulations, a copy of this letter, the SALP Repert, and your comments, if any, will be placed in the NRC's Public Doeyment Room when the SALP Report is issued.
T.
k
. J-
) W/5C Q
C:.r.+ :.ra Io.er (c pany 2
' DOL 2 1 Gi3 i
If you have any questions concerning the SALP Report we vill be happy to discuss them with you.
Sincere 1f, o
44{
. Hind, Chairman Region III SALP Board Director, Division of Radiological and Materials Safety Program
Enclosures:
1.
Sumcary of Significant Findings (5 cys) 2.
Preliminary SALP Report (5 cys) cc w/encls:
Director, OIE Resident Inspector, RIII Proj ec t Manager, NRR PAO, Region III T.
r n-,
=.
.Significant SALP Report Findings for the Midland Nuclear Generating Station Units 1 and 2 General Observations
.Isspections were conducted in March and April 1982 to evaluate the significance 1
of the quality control (QC) inspection deficiencies identified during the special team inspection of May 1981. These followup inspections indicated that QC inspections were not properly identifying deficiencies in the' install-ation of equipment. As a result of these deficiencies and due to recurring problems in the licensee's remedial soils work activities, increased NRC i
]
inspection effort was initiated through the formation of a special Midland Section comprised of inspectors dedicated solely to the Midland plant.
Additional inspection assistance was obtained through a special contract with a Department of Energy Laboratory.
To aid in the evaluation of the as-built condition of the plant, a special i
inspection of the Diesel Generator Building was conducted during the period of October 12 through November 25, 1982. This inspection identified signifi-cant violations which demonstrated a breakdown in the implementation of the licensee's Quality Assurance (QA) program.
In addition, it resulted in the licensee's decision to suspend some safety-related work activities (December 3, 1982) and to formulate a construction completion program to provide assurance that safety-related structures and systems were constructed l
as designed. Due to the significant violations, the NRC imposed a civil penalty of $120,000.
In view of the suspension of portions of safety-related work activities and the licensee's proposed construction completion program, the Region III i
Regional Administrator determined that the SALP 3 appraisal for Midland 1
would address only areas where work activities continued; namely, remedial soils (Soils and Foundations), the Nuclear Steam Supply System (Safety-Related Components and Piping Systems and Supports), the Heating, Ventilating, and Air j
Conditioning System (Support Systems), and licensing activities.
Functional Areas 1
1.
Soils and Foundations Overall performance in this functional area has continued to indicate 4
a declining trend and remains an area of concern. The decline was due to the continued lack of attention to detail and the continuing inability on the part of the licensee to implement properly the requirements of
,", the Midland QA program.
3.&4. Safety-Related Components and Pipina Systems and Supports 7.'
Performance in this functional area remains adequate. However, the NRC plans to conduct a special inspection to evaluate this area in the near future.
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Support Systems Performance in this functional area has declined from category 1 to category 2.
The decline was due to the lack of management attention to identified problems and the lack of timely corrective action to resolve these problems.
8 Licensina Activities Performance in this functional area remains adequate. Generally, responses are timely and technically correct. However, while the licensing aspect of the scils issue has shown improvement over the appraisal period, the licensee should continue to focus a high level of management attention on this area.
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e CORSumEiS l
r power James W Cook C0mp8 tty via m,ua.,- rr.i.. s.ai..,,,
a.d Cons,ructie.
Generet offices: 1945 West Pernett flood, Jackson, MI 49201 * (517) 78& o453 September 6. 1983 Mr J G Keppler. Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT RESPONSE TO DRAFT SALP REPORT FILE 0.6.1 SERIAL 25682 Consumers Power Company has received and reviewed the NRC's Systematic Assess-ment of Licensee Performance (SALP Report) for the Midland Nuclear Plant, Units 1 and 2, for the period July 1, 1981 through March 31, 1983 and acknow-ledges the NRC's comments.
Consumers Power Company recognizes the purpose of the SALP Report and is committed to accomplish the improvements necessary to achieve the quality performance level that both the NRC and the Company desire.
The Company is particularly concerned about the SALP evaluation in the Remedial Soils work and will devote the management attention necessary to establish improved overall performance in this area. Efforts will be focused on addressing the NRC's concern regarding attention to detail and implementa-tion of the Quality Assurance Program. Our managment team is dedicated to assuring that future Remedial Soils work will conform to the requirements of the Midland QA Program.
The Company believes that the elements of the CCP Program are sound and that it will result in a well controlled process by which to both verify the quility of past completed construction and ensure the quality of construction work yet to go.
Th'e' CCP may need some refinement as we gain experience with it, but as a management team we are dedicated to give it the attention and suppert needed.
We will modify it, as change is needed, to ensure that it works. The success-ful implementation of this program will clearly support the Company's goal of meeting the requirements of the Midland QA Program.
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In conclusion the Comparr has evaluated the contents of the SALP III Report and the management teatr.sil1 take whatever steps are necessary to achieve the quality performance le el that both the NRC and the Company desire. -
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CC DSHood, US NRC RJCook, Midland Resident Inapector s
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l<s.4 OM/0L SERVICE LIST Mr Frank J Kelley, Esq Atomic Safety & Licensing
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Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Hs Carole Steinberg, Esq Washington, DC 20555 l
Assistant Attorney General l
' Environmental Protection Division Mr C R Stephens (3) l.
720 Law Building Chief, Docketing & Services Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq Suite 3700 Ms Mary Sinclair Three First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640 Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff Midland, MI 48640 V S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U S Nuclear Regulatory Commission U S Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr Federick P Cowan Hs Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca.Raton, FL 33433 Freeland, MI 48623 Mr Fred Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Avenue, NW, Suite 325 Board Panel Washington, DC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Hiller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, Il 60602 Mr D F Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lunchburg, VA 24505 Midland, MI 48640 Mr Steve Gadler, Esq Hs Lynne Bernebei 2120 Carter Avenue Government Accountab'111ty Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 i
9/3/83','
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