ML20107A888

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Submits Estimated Time Schedule for Hearing.Supporting Documentation Encl
ML20107A888
Person / Time
Site: 05000000, Midland
Issue date: 01/09/1980
From: Hood D
NRC
To: Rubenstein L
NRC
Shared Package
ML20099A237 List:
References
FOIA-84-96 NUDOCS 8502200136
Download: ML20107A888 (5)
v • d • e


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NUCLEAR REGULATORY COMMISSION UNITED STATES j

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November 19, 1979 Docket Nos. 50-329/330 MEMORANDUM FOR: Harold D. Thornburg, Director, Division of Reactor Construction Inspection IE

, FROM:

R. E. Shewmaker, Division of Reactor Construction Inspection. IE

SUBJECT:

FORTHCOMING MEETING TO DISCUSS MIDLAND, UNITS 1 AND 2 DATE & TIME:

Wednesday, November 28, 1979 at 9:00 AM LOCATION:

Room 319. East West Towers Building PURPOSE:

The staff will' consider the past history of problems that have occurred to date during the construction of the two units at the Midland site to detemine whether any specific action is required at this time.

PARTICIPANTS:

IE:RCI Thornburg, Reinmuth, Shewmaker IE:X005 Brockett RIII Keppler, Fiore111, Knop ELD Murray, Lieberman, Olmstead, Bachmann NRR Hood

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Division of Reactor Construction Inspection IE cc: -See Attached List e

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NUCLEAR REGULATORY COMMISSION 2

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November 5, 1979 Docket Nos. 50-329/330

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MEMORANDUM FOR: Harold D.'Thornburg,' Director, Division of r Construction Inspection, IE R. E. Shewmaker, Divisio\\

Reactor Co uction Inspection, IE FROM:

lVNITS 1 AND 2

SUBJECT:

FORTHCOMING MEETING ISCUSS MID h,

DATE & TIME:

Friday, November 979 at 9:0 LOCATION:

Hearing Room, Floor, Easpt s Towers Building PURPOSE:

The staff I consid tt[pa t history of problems that have oc rM to date d frg the construction of the two units a e Midland !

to determine whether any specific acti:

required at. h s time.

PARTICIPANTS:

IE:

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Brocket RIII Keppler, Fiorelli, Knop ELD Murray, Lieberman, Olmstead, Bachmann NRR Hood E,T 1

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O vision of Reactor.

Construction Inspection, IE cc: See Attached List 4

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UNITED STATES NUCLEAR REGULATORY COMMISSION y,

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  • k, November 2, 1979 Docket Nos. 50-329/330 MEMORANDUM FOR: Harold D. Thornburg, Director, Di isi f Reactor Constru n

Inspection, IE FROM:

R. E. Shewmaker, Division of Rea Construction In et

, IE

SUBJECT:

FORTHCOMING MEETING TO DIS S M IDLAND, UNITS 1 DATE & TIME:

a) Tuesday, November,\\79at9:00AM b) Tuesday,No mbe 6

979 at 3:30PM

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a) Hearing om, Floor East West Tw Building b) D. V ss o'

Office, Room 278, P ps Building PURPOSE:

The staf wi consider the past stbry of problems that hav o u d to date during t struction of the two unit t the Midland si o

ermine whether any specific j

action is required at t is i PARTICIPANT.

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Thornburg, Reinmuth, hewmaker IE:X005 Brockett L

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Ke ler, F lli, Knop 1.

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Murray, 1eberman, Olmstead l

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Vassallo, Varga, Ruberstein, Hood Knight, Haass, Jackson, Schauer

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o ert E. She xer f Division of Reactor Construction Inspection, IE cc:

See Attached List l

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MEETING NOTICE DISTRIBUTION

-Docket File NRC POR Local POR TIC LWR #4 File H. Denton, NRR E. Case, NRR R. Mattson, NRR D..Yissallo, NRR D. Skovholt, NRR S. Yargi, NRR L. Ruberstein, NRR W. Haass, NRR

-ACRS D. Hood, NRR

-J. Knight, NRR F. Schauer, NRR R. Jackson, NRR L. Hulman, NRR J. Murray, ELD W. Olmstead, ELD J. Keppler, RIII-G. Reinmuth, IE T. Brockett, IE G. Fiore111, RIII

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DETERMINE:

The Staff will consider the past history of problems that have occurred to date during the construction of the two units at the Midland site.

It is to be determined

1) whether the known problems constitute a breakdown in the QA program significant enough to warrant some escalated enforceme'nt action,
2) whether there is any lack of confidence by the staff to accept construction completed to date in all areas as if the issuance of an OL were in the innediate future and
3) whether there are unresolved problems known but not identified by individual staff members and
4) whether any actions are necessary by the staff to assure that all construction completed to date is acceptable and
5) what actions, if any, are necessary in the future to preclude future problems.

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UNITED STATES

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M.,', J October 18, 1979 i

,r /.- fj f MEMORANDUM FOR:

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

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

SUBJECT:

MIDLAND 40NSTRUCTION STATUS REPORT AS OF OCTOBER 1, 1979 The attached report was finalized based on your feedback requested in my memo of October 5,1979.

If you stiLL feet adjustments are necessary please contact me..If you consider the. report characterizes your l

current assessment of the Midland project, please concur and pass it

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along promptly.

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l G. Fioretti, Chief Reactor Construction and l

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Enclosure:

As Itated Engineering Support Branch cc:

J. G. Keppler l

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SUMMARY

REPORT UPDATE Facility Data Docket Number 329 and 50-330 Construction Permits

- CPPR-81 and CPPR-82

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Permits Issued

- December 14, 1972 Type Reactor

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

- Sabcock and Wilcox Design / Constructor

- Bechtel Power Corporation

- Unit 1, 4/82; Unit 2, 11/81 Fuel Load Dates Status of Construction

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

  • Approximately one-half the steam production for Uni't 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers.

Chronological Listing of Major Events

-July 1970 start of construction under exemption f

'9/29-30 &

Site inspection, four items of noncompliance identified, i

10/1/70 extensive review during CP hearings l-l 1971 - 1972 Plant in mothballs pending CP 12/14/72 CP issued l

9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 31/73 Inspection at-site,-four items of noncomoLiance identified (cadweld problem) precipitated the Show Cause Order L-Licensee answers.Show cause order commits to improvements 12/29/73 on QA program and QA/QC staff 12/3/73 Show Cause Order issued suspending cadwelding operation 12/6-7/73 Special inspection conducted by RIII and He personnel l

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32/37/73' Show cause order modified to allow cadwelding based on inspection findings of 12/6-7/73 b

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's 12/5/75 CP. reported that rebar spacing out of specification 5; locations.in Unit 2 containeen:

3/5 & 10/75 CP reported that 63 #6 rebar vere either missing or misplaced in Auxiliary Building 3/12/75 RIII held managenent meeting with CP O

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e CP reported that 42 sets of f 6 tie bars were missin; 8/21/75 in Auxiliary Building CP reported that 32 #8 rebar vere omitted in. Auxiliary 3/22/76 Building. A stop-vork order was issued by CP RIII inspector r'equested CP to inform RIII when stop-vork 3/26/76:

order to be lif ted and to investigate the cause and the extent of the problem. Additional rebar problems identified during site inspection by NRC CP lif ted the stop-vork order 3/31/76 RIII performed in-depth QA inspection at Midland 4/19 thru 5/14/76 RIII management discussed inspection findings with 5/14/76 site personnel RIII management meeting with CP President. Vice Preside.t.

5/20/76 and others.

RIII follow up meeting with CP management and discussed 6/7 &,8/76 the CP 21 correction co it=ents.

m Shevnak 6/1-7/1/76 Overall rebar omission reviewed by R.-_

CP stops concrete placement work when further rebar 7/28/76 placement errors found by their overview program.

PN-III-76-52 issued by RIII I

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RIII reconnends HQ notice of violation be issued f

8/2/76 Tive week full-time RIII inspection conducted l-4/9

.9/9/76

'8/13/76 Notice issued 10/29/76 CP responded to EQ Notice of Violations CP revised Midland QA program accepted by NRR 12/10/76 Unit 2 bulge of containment liner discovered by Licensee

.2/28/77 Tendon sheath omissions of Unic' I reported 4/19/77 l

IAL issued relative to tendon sheath placement errors

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4/29/77 Management meeting at CP Corporate Office relative to 5/5/77 I.AI, regarding tendon sheath problem I

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

series of meetings and Letters between CP and NRR on 6/75 - 7/77 applicability of Regulatory Guides to Midland.

Commitments by CP to the guides was responsive.

construction resident inspection assigned.

7/24/78 Measurements by Bechtet indicate excessive settlement 8/21/78 of Diesel Generator Building. Officially reported to RIII on September 7,1978.

i Special investigation / inspection conducted at Midland.

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

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

project informed construction performance on track with exception of diesel / fill problem.

Meeting held in RIII with Consumers Power to discuss 2/23/79 diesel generator building and plant area fill problems.

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

10 CFR 50.54 reauest for information regarding plant 3/21/79 fill sent to CPC'by NRR.

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

Mid-QA inspection conducted.

5/8-11/79 W,

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- Sienificant Maior Events Past oroblems Cadwetc Solicino Problem and Show Cause Order 1.

6-8,1973, as a A routine inspection, conducted on November result of intervenor information, identified eleven examples of four noncompliance items relative to rebar Cadwelding (1) untrained operations.

These items were summarized as:

rejectable Cadwelds accepted by QC Cadweld inspectors; (2) inspectors; (3) records inadeouate to establish cadwelds met recuirements; and (4) inadequate procedures.-

As a result, the Licensee stooped work on cadweld operations on November 9,1973 which in turn stopped rebar installation and The Licensee agreed not to resume work concrete placement work.

until the NRC reviewed and accepted their corrective action.

However, Show Cause ' Order was issued on December 3,1973, On December 6-7,1973, RIII and l

suspending Cadwelding operations.

HQ personnel conducted a special inspective and determined that construction activity could be resumed in a m nner consiste'nt a

r The Show Cause Order was codified on with quality. criteria. allowing resumption of Cadwelding anerations December 17,1973,

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based on the inspection results.

29, 1973, The Licensee answered the Show Cause order on December l

committing to revise and improve the', QA' manuals and procedures l.

and make GA/DC Personnel changes.

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

Rebar Omission / Placements Errors leadine to IAL 2.-

Initial identification and report of rebar nonconformances1 13,1974.

. occurred during an NRC inspection conducted on December 1 -

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

reports Nos.

f' Additional rebar' deviations and omissions were identified in Inspection L

March and August 1975 and in Aorit, May and June 1976. _

50-329/76-04 and 50-330/76-04 identified five

' noncompliance _ items regarding reinforcement steel deficiericies.

report Nos.

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Licensee response dated June 18, 1976, Listed 21 separate items (commitments) for corrective action. A June 24, 1976 Letter provided a plan of action schedule for implementing the 21 items.

The Licensee suspended concrete placement work until the items addressed in Licensee's June 24 Letter were resolved or implemented.

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

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

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

Additional action taken is as folicws:

a.

By the NRC (1) Assignment of an inspector full-time onsite for five weeks to observe civil work in progress.

(2)

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

Inspection and evaluation by Headquarters personnel b.

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

(2)

Establishment of an overview inspection program to provide 100% reinspection of embedments by the Licensee following -

acceptance by the contractor GC personnet.

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By the Contractor (1)

Personnet changes and retraining of personnel.

(2)

Prepared technical evaluation for acceptability of

-each identified construction deficiency.

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

3.. Tendon Sheath Placement Errors and Resultina Immediate Action Letter CIAL) on Aprit 19,1977, the Licensee reported, as a Part 50, section 50.55(e) item,' the inadvertent omission of two hoco tendon sheaths e.

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from a Unit 1 containment concrete placement at elevation 703' - 7" due to having already coured concrete in an area where tne tendons were to be directed under a steam line. The tendons were subsequently rerouted in the next higher concrete lift.

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

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

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

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

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

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

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

Current Problems i

1.

The Licensee informed the RIII office on September 8, 1978, per requirements cf 10 CFR 50.55(e) that settlement of the diesel

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generator foundations and structures were-greater than expected.

FILL material in this area was placed between 1975 and 1977, with construction starting on the diesel generator building in mid-1977.

Review of the results of the RIII investigation / inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtet and the Licensee ;o the pending problem. These events included ncnconformance reports, audit findings, field memos to engineering and problems with the l

administration building fill which caused modification and replacement of'the already poured footing and r.eplacement of the fill material I

with Lean concrete.

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Causes of the excessive settlement tactuds: (1) inadeouate. clacement method unqualified compaction equipment and excessive lift thickness; (2) inadeouate testing of the soit material; (3) inadecuate-QC inspection procedures; (4) uncualified quality control inspectors.

L and field engineers; (5) over reliance on inadecuate test results.

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The proposed remedial work and corrective action are as follows:

(1)

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

Continue to monitor soil response to predict long-term settlement.

(2)

Service Water Pump Structure - Install piles to hard glacial tiLL to support that portion of the structure L

founded on plant fill material.

i (3)- Tank Farm - FILL has been determined to be suitable for l

the -support of Borated Water Storage Tanks. Tanks are to be constructed and hydro tested while monitoring soit response to confirm support of structures.

(4)

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

(5)

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

(6)

Auxiliary Building and F. W._ Isolation Valve Pits - Installed a number of caissons to glacial.tiLL material and replace soit material with concrete material under valve pits.

(7)

Dewatering System - Installed site dewatering system to provide assurance against soit Liquidification during a seismic event.

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The above remedial measures were proposed to the NRC staff on July 18,1979.

No endorsement of t.he proposed actions have been issued to the Licensee to date. The Licensee is proceeding with the above plans.

The NRC activities, to date, inctude:

a.

Lead technical responsibility and program review was transferred to NRR f rom IE by' memo ' dated November 17, 1978.

b.

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

c.

RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement.

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

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

4:

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e NRC issue of 10 CFR 50.54(f) regarding plant fill dated March 2',

e.

1979.

Several inspections of Midland site settlement have been f.

performed.

The Constructor / Designer activities include:

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

b.

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

Prepared a proposed corrective action option regarding placement c.

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

d.

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

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

e.

f.

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

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

Issued interim report No. 5 dated April 30, 1979 l

h.

i. Responded to NRC 10 CFR 50.54(f) request for information ensite 24,1979. Subsequent revision 1 dated settlement dated April May 31,1979, revision 2 dated July 9,1979 and revision 3 dated September 13, 1979.

J.

Meeting with NRC to discuss site settlement causes and proposed l

resolution and corrective action taken dated July 18, 1979.

.Information discussed at this meeting is documented in Letter from CPCo to NRC dated August 10, 1979.

i l

k.

Issued interim report No. 6 dated August 10, 1979 1

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

Review of Quality Documentation to Establish Acceptability of Ecuipment 2.

The adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes that the eauipment meets specification and environmental' requirements The Licensee, on November 13, 1978, issued a is of concern.

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

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and stated Consumers Power was pursuing this matter not only fo*

Bechtel procured equipment but also for NSS supplied equipment.

3.

Source Inspection to Confirm Conformance to Specifications

-The adecuacy of equipment acceptance inspection by BechteL shop inspectors has been the subject of several noncompliance /nonconformance recorts.

Consumers Power has put heavy reliance on the creditability of the Bechtet vendor inspection program to insure that only quality equipment has been sent to the site. However, the referenced nonconformance reports raise questions that the Bechtet vendor inspection program may not be effectively working in aLL disciplines for supplied equipment. Some significant examples are as follows:

(1) Decay heat removal pump being received with inadecuate radiography.

The pumps were returned to the vendor for re-radiography and repair. The pumps were returned to the site with one pump 4

assembled backwards.

This pump was again shipped to the vendor for reassembly.

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

The pumps had been shop inspected by BechteL.

C2) Containment personnel air Lock hatches were received and installed

/

with vendor supplied structural weld geometry'which does not agree with manufacturing drawings. The personnel air Lock doors had been vendor inspected.

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

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

(5) A primary coolant pump casing was received and installed without aLL the threads in one casing stud hole being intact. The casings were vendor inspected by both Bechtet and B8W.

Additional IE inspections wiLL be conducted to determine if CP has thoroughly completed an overview of the Bechtet shop inspector's function and that equipment already purchased has been reviewed to -

confirm it meets requirements.

4.

"Q" List Eauipment There have been instances wherein safety related construction.comoonents and their installation activities have not-been-4dentified on the "4" List..

This shortcoming could have affected the cuality of work eerformet during fabrication due to the absence of cuality controls identified Examples of non "0" List ac:ivities identifiec with "Q" list items.

which should be "Q" Listed include:

Cable Trays Components of Heating and Ventilation System The Licensee wiLL be advised to review past as weLL as future construction activities to confirm that they were properly defined as "Q" list work or components.

5.

Management controts Throughout the construction period.CPCo has identified some of the problems that have occurred and reported them under the recuire-a.

ments of 10 CFR 50.55(e). Management has demonstrated an openness However, CPCo has on by promptly identifying these problems.

repeated occasions not reviewed problems to the depth required for full and timely resolution.

Examples are:

Rebar omissions (197*)

Tendon sheath location error (1977)

Diesel generator building settlement (1978)

Containment personnel access hatches (1978)

In each of the cases Listed above the NRC in it's investigation has i

determined that the problem was of greater significance than first reported or the problem was more generic than identified by CPCo.

This incomplete wringing out of problems identified has been discussed l

with CPCo on numerous occasions in connection with CPCo's management l-of the Midland project.

There have been many cases wherein nonconformances have been identified, l

'b.

reviewed and accepted "as is."

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

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

l Inspection History The construction inspection program for Midland Units 1 and 2 is approximately This is consistent with status of construction of the two L

60% complete.

units...(Unit 1 - 54%; Unit 2 - 61%). The Licensee's QA program has The following l

l repeatedly been subject to in-depth review by IE inspectors.

highlight these inspections.

8-10, 1973, inspection report Nos. 50-329/73 s6 1.

July 23-26,and Augusta detailed review was conducted relative to the and 50-330/73-06:

implementation of the Consumers Power Company's GA manual and Bechtel Corporation's QA program for design activities at the 8echtel Ann The identified concerns were reported as discrepancies Arbor office.

relative to the Part 50, Appendix 8, criteria requirements.

l'

- 11

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2.

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

A j

detailed review of the 8echtel Power Corporation QA program for Midland was performed. Noncompliances involving three separate Appendix 8 criteria with five different examples, were identified.

3.

February 6-7, 1974, report Nos. 50-329/74-03 and 50-330/74-03: A followup inspection at the Licensee's corporate office, relative to l

the items identified during the september 1973 inspection (above) along with other followup.

l 4.

June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: special inspection conducted at the Licensee's corporate office to review j

the new corporate QA program manual.

I 5.

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

Special five week inspection regarding QA program l

implementation onsite primarily for rebar installation and other civil engineering work.

6.

May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: special inspection conducted at the site by RIII, IE AND RI personnel to examine the GA program implementation onsite by Consumers Power Company and by Bechtel Corporation. A.Lthough five examples of i

noncompliance to Appendix 8, Criterion V, were identified, the consensus of the inspectors involved was that the program and its implementation e

for Midland was considered to be adequate.

7.

May 8-11,1979, a mid-construction GA inspection covering purchase control and inspection of received materials design control and site auditing and surveillance activities was conducted by a team of inspectors. While some items wiLL require resolution, it was concluded the program was adequate.

The Licensee's Quality Assurance program has undergone a number of revisions to strengthen it's provisions. The company has expanded it's GA/ec auditing and surveillance coverage to provide extensive overview inspection co.verage.

This was done in 1975 with a commitment early in their experience-with rebar installation problems and was further committed by the Licensee in his -Letter of June 18,1976, responding to report Nos. 329/76-04 and 50-330/76-04. This overview inspection activity by the Licensee has been a positive supplement to the constructor's own program, however, currently our inspectors perceive the overview activities cover a smaLL percentage of the work in some disciplines.

. This has been brought to the Licensee's attention who has responded with a revised overview plan.

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

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

review by RIII inspectors.

4 I

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f The RIII of fice of inspection and enforcement instituted an aucmented onsite inspection coverage program during 1974, this program has continuec in ef fect until the installation of the resident inspector in July 1975.

Enforcement History a.

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

646 1977 5

12 648 1978 18 23 1180

  • 1979 to date 7

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

  • Through August 1979 b.

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

Issuance of a Civil' Penalty is currently being contemplated.

Summary and Conclusions Since the start of construction Midland has experienced some significant problems resulting in enforcement action. These actions 'are related (1) to improper placement, samoting and testing of concrete and failure of GA/QC to act on identified deficiencies in September 1970; (2) to drawing control and lack of or inadeouate procedures for control of design and procurement activities at the Bechtel Engineering offices in September 1973; (3) to inadeouste training, procedures and inspection of cadweld activities in November 1973; (4) to a series of RIII in-depth QA

\\

inspections and meetings which identified underlying causes of weakness in the Midland GA program isolementation relative to embedments in April, May and June 1976.

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

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

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

g c-The evaluation both by the licensee and IE of the structures and equip-cent af fected by these problems (again except the last) has established that they fully meet design requirecents.

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

(1) utilities historically have tended-to over rely on A-E's (in this case,.Gechtet) and (2) insensitivity on the part of both.

Sechtet and Consumers Power to recognize the significance of isolated events or f ailure to adecuately evaluate possible generic application of these events either of which would have led to early identificatien and avoidance of the problem.

Admittedly construction deficiencies have occurred which should have been identified earlier but the licensee's QA program has ultimately identified and subsequently, corrected or in process of correcting these deficiencie The RIII inspectors believe that continuation of (1) resident site coverage, (2) the licensee overview program, (3) the Licensee's attention and resolution of identified problems in this report, (4) ceasing to permit work to continue when quality related problems are identified with construction activities and (5) a continuing -inspection program by regional inspectors will provide adequate assurance that construction wiLL be perforced in accordance with requirements and that any significant errors and deficiencies will be identified and corrected.

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UNITED STATES

[(*.0 NUCLEAR REGULATORY COMMISSION CY%.... /

[

WASHINGTO V. D. C.20555 SEP z 71979 Docket No. 50-329/330

  • MEMORANDUM FOR: George C. Gode'r, Acting Executive Officer for Operations Support, IE FROM:

Harold D. Thornburg, Director, Division of Reactor Construction Inspection, IE

SUBJECT:

COMMENTS ON NEEDED ACTION ON MIDLAND ENFORCEMENT PACKA RIII tranunitted an enforcement package to me dated April 3,1979 and that package wa. sent to X005 as directed by J. Davis's memorandum of March 21, 1979.

RCI provid..d con:nents on the enforcement package in a memorandum dated June 13, l'j79 (see Enclosure 1) to X005 for coordination. We have not seen Since that date there have, 9

any p siti' ins in writing from NRR on the package.been several meetings (8/1,

,the questicos centering arcund further action on the enforcement package.

The meetin.rs were attended by personnel from NRR, El.D and IE. The various eegm ni cessary to make a finding on a material false statement were t

a.

Is the statement false?

b.

Is the statement material?

Under what circu:nstances or in what frame of mind was the statement made c.

(willful, deceitful, careless disregard)?

As a result. of these meetings and the subsequent discussions by telephone'with NRR represi.ntatives, we are of the opinion that the enforcement action should-be taken on Item 1 of the package as a material false statement in that the fill used at the site was not the type stated in the FSAR as having been used (random vs engineered. structural fill). The NRR conclusiens on the other four items were that the statements were not material and indicated " poor QA perfonnanci'" on the part of the licensee.

CONTACT:

11. E. Shewmaker IE fj,gh

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SEP 271973 2-G. C. Gower O

0 Further, it is our opinion that the f act that tnere ar improper internal coonfination and failure on the part of the licensee to These constitute -

assure that accurate infonnation was being provided in the FSAR.

sufficient facts to make a finding that the material false statement was m This wculd make the material false in careless disregani of the facts.

statement subject to a civil penalty vs actions allowed under the Adsin Procedures Act for the "seemd chance."

k

...We strongly recocrnend that X005 advise RIII to prepare the enforcement p

'in this manner and that we proceed quickly on this matter.

there is a reluctance by some'in the NRC against finalizing an action on material false statements while the bigger questions of the QA progran a

- work being done at the site as corrective actions which are not yet ap In our opinion, the two matters by the NRC are being considered for action.are distinct and on the false statenent.

If you have any questions, please etntact us.

l Harold D. Thornburg Director Division of Reactor Constnaction Inspection IE C

i

'G. W. Rein,suth, IE cci J. G. Keppler, RIII/

T. W. Brockett, IE l

D. Hood, NRR C. E. Norelius, RIII e

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AUG 24197g MEMO TO FILE FROM:

D. Hood, Project-Manager, Light Water Reactors Branch No. 4. DPM

SUBJECT:

INTERNAL MEETING ON STATUS OF MIDLAND SOILS SETTLEMENT On August 16, 1979, me[nbers of NRR, I&E Headquarters and OELD met to discuss the status of the staff's review of the soils settlement matter at the Midland si te. The purpose was to determine the status of the staff's decision pursuant to 10 CFR 50.54f (which is applicable to construction permits by 10 CFR 50.55(c).)

The principal background documents to date are listed in Enclosure 1.

Meeting attendees are listed in Enclosure 2.

~

- Mr. Knight reported that the principal technical solutions proposed.by the applicant for the major structures appears to be basically sound such that, properly implemented, they can be expected to provide for adequate structural foundation support. He noted, however, that certain details of the applicant's reply were not sufficient and further infomation will be' required from the applicant.

For' example, the details of the applicant's load combination calculations and stress limits applicable to differential settlement, NRR's need for a more l

^

quantitative assessment to detemine that nozzle loads transmitted from settled pipes to the attached valves, pumps, tanks, etc will-remain within ASME Code allowables, and a more thorough monitoring program to follow actual performance dur,in'g operation. These findings and further requests are being documented and will be completed in late August.

Messrs Haass and.Gilray of QAB noted that some instances of poor performance in QA areas revealed in the I&E investigation report indicates that additional QA me'asures beyond those typically imposed by the NRC may be warranted. QAB's review is in its final _ stages of documentation and should be completed before the end of August.

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.. AUG 241979

.Mr.Thornburg noted I&E is continuing its review of the performance aspects of the_QA program and considering the soils settlement matter in relation to the Mr. Tnornburg anticipates that I&E

' reports of QA deficiencies in other areas.

- will reach its conclusions by mid-September 1979.

m OELD referenced a Memorandum and Order from ASLB dated August 2,1979 which ashs for clarification of the staff's position regarding consideration of the The board cannot determine from diesel generator building settlement issue.

' the staff's response whether the staff simply prefers not to issue a partial SER or whether there are other considerations making early consideration of this issue impossible or impractical. Mr. Odstead will prepare a reply clarifying the staff's DES schedule and. explaining why isolation of the DG building issue is not practical.

Mr..Rubenstein described the approach which DPM will take in arriving at an NRC position on.the technical qualification findings for the SER. 'The approach is that defined in a W. Haass memo dated 12/15/78, which calls for inputs from QAB, I&E, DOR and DPM.

l-Mr. Vassallo emphasized the need for timely decisions to be reached by'the staff-i

.and for similar status meetings in the near future.

7.,HoodeMA D

I'

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ENCLOSURE 1 BACKGROUND DOCUMENTATION Backgro,und Documentation relevant to NRR's 10 CFR 50.54(f) requests dated March 21, 1979 include the following: The applicant's reply dated April 24, 31,1979 (revision 1), and July 9,1979 (revision 2).

1979, was revised May Further infomation was supplied by the applicant during meetings attended by both I&E and NRR on March 5 and July 18, 1979.

In addition, certain infor-mation was requested by NRR technical branches as part of the FSAR review prior to issuance of the 10 CFR 50.54(f) requests and are replied to through Site visits by NRR staff to observe settlement were made FSAR amendments.

March 6 and June 7,1979, and December 3,1978. NRR participation with I&E results from a Transfer of Lead Responsibility which was distri'buted to b

technical review branches as part of a technical assistance request dated l

November 27, 1978.

Background documentation directed to I&E includes a 50.55(e) notification by the applicant dated _ September 29, 1978, for which six interim reports have been issued to date (November 7, 197B; December 21, 1978; January 5,1979; February 23,1979; April 30, l979; and June 25, 1979).

I&E has conducted a f

preliminary investigation and has documented its sumary findings, along with the applicant's discussion of these findings, in a letter to the applicant Enforcement actions due to potential material-false dated March 15, 1979.

statements in the FSAR as may be applicable to some of these I&E findings are presently under internal review, assisted by NRR staff as appropriate.

.

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