ML20126L879

Testimony of Ej Gallagher Re Stamiris Contention 3. Managerial Attitude Is Consistent W/Qa Regulations Implementation on Soil Settlement Problems.Prof Qualifications Encl

ML20126L879
Person / Time
Site:	Midland
Issue date:	06/08/1981
From:	Gallagher E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20126L803	List: ML20126L799 ML20126L806 ML20126L819 ML20126L822 ML20126L828 ML20126L834 ML20126L838 ML20126L843 ML20126L848 ML20126L854 ML20126L859 ML20126L864 ML20126L873 ML20126L879 ML20126L885 ML20126L887
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8106090715
Download: ML20126L879 (7)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE. ATOMIC SA'FETY AND LICENSING BOARD In the Matter of

' CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & OL j 50-330 OM & OL '

(MidlandPlant, Units 1and2)

NRC STAFF TESTIMONY WITH RESPECT TO '

INTERVENOR STAMIRIS' CONTENTION NUMBER 3

-Q.1. Please state your-name and position with the NRC.

A. My name is Eugene J. Gallagher. I am a civil engineer with I the U.S. Nuclear Regulatory Commission.- Since February,1981, I have

.been assigned.to the Reactor Engineering Branch, Division of Resident and Regional Reactor Inspection, Office of Inspection and Enforcement. Prior

,} to February,1981, I was a reactor inspector assigned. to the Region. III, Reactor Construction and Engineering Support Branch, Office of Inspection ,

and Enforcement.- I was assigned to the Midland Plant (among others) from October,1978' until January,1981. . , [

Since October of 1978, I have spent approximately one year of effort l performing inspections, reviewing quality control records and procedures, observing work activities, reviewing Consumers Power Company (hereafter Consumers) . responses to 50.54(f) questions 1 and 23, attending meetings I and presentations by Consumers and Bechtel regarding the soil settlement matter at the Midland Plant.

Have you prepared a statement of professional qualifications?

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A. Yes, a copy of this statement is attachment No. 1.

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Q.3. Please stateithe. nature of the responsibilities that you had with. respect.to the Midland Plant, Units 1 and 2.'

. A. As a civil engineer. inspector for the Region III Office of Inspection 'and Enforcement I conducted five inspections prior to December 6,1979 in order to (1) ascertain whether adequate quality assurance plans, instructions and procedures had been established for the l construction of the foundation of safety related structures, (2) provide an independent evaluation of the performance, work in progress and

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completed work to ascertain whether activities relative to foundation

. construction were accomplished in accordance with NRC requirements, and 1

.(3) review the quality related records to ascertain whether. these records reflected work accomplished consistent with NRC requirements and license L O l commitments. -

L Q.4. What is the NRC Staff response to Intervenor Stamiris Contention 3?

A. Intervenor Stamiris Contention 3 reads as follows:

Consumers Power Company has not implemented its Quality

! Assurance Program regarding soil settlement issues according to 10 CFR Part 50, Appendix B regulations, and this represents a repeated pattern of quality-assurance deficiency reflecting a managerial attitude inconsistent with implementation of Quality Assurance Regulations with respect to soil settlement problems, since reasonable assurance was given in past cases (ALAB-100, ALAB-106 and LBP-74-71) that proper quality assurance would ensue and it has not.

The Quality Assurance deficiencies regarding soil settlement include:

L a) 10 CFR Part 50, Appendix B, Criteria III, V, X and XVI l O as set forth in the Order'of Modification; L

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- 3-V b) 10 CFR Part 50, Appendix B, additional criteria denoted by roman numerals below:

1. The Applicant has failed to assume responsibility for execution of the QA program through its failure to verify and review FSAR statements (pp. 6-8 and p. 21 Keppler Report) and through its reliance on final test results not in accordance with specified requirements (p.

16,KepplerReport);

II. The QA program was not carried out according to written policies, procedures and instructions, in that oral directions were relied upon and repeated deviations from policies occurred regarding compaction procedures (p.

9-14, Keppler Report);

VII. Control of purchases material has not been maintained, in that examination and testing of backfill materials did not occur in accordance with regulations (NCR QF29, NCR QF147);

IX. Control of non-destructive testing was not accomplished by qualified personnel using qualified l

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V procedures regarding a) moisture control (Keppler Report p.14-16; QA l

Request 5040, NCRQFSS2, 172, 174 and 199);

b) compaction procedures (Keppler Report, p. 9, NCR QFS 68, 120 and 130); and c) plant fi 1 work (pp. 24 and 25, Keppler Report);

, XI. Test programs did not incorporate requirements and i acceptance limits adequately in the areas referenced in a, I b and c above, and do not meet these requirements L regarding soil settlement remedial actiors; l

XIII. Measures were not adequately established to prevent damage or deterioration of material regarding frost effects on compacted fill (pp. 16 and 17, Keppler Report);

l XV. Measures were not taken to control non-conforming l

material in order to prevent the inadvertent use (NCR QF29 and QF127);

c) the settlement of the Administration Building in 1977 should have served as a quality indicator, preventir,g the same

[] inadequate procedures from occurring in the 1978 construct'an V

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I of the diesel generator building causing its eventual settlement.

Before responding to the main allegation of Intervenor Stamiris Contention 3 I will' address,the specific deficiencies she lists in support of the contention.

The Staff agrees with the allegation in paragraph 3(a) which merely relies on facts alleged originally by the Staff in Appendix A to the December 6,1979 Order and in Investigation Report 78-20 (attachment 2).

.With regard to Contention 3(b), the fac'.s set forth describe violations of Criteria III, V, X and XVI as set forth in Appendix = A to the Order. However, Ms. Stamiris using these same facts, has designated violations of other criteria. The Staff does not agree with these designations; supplied by Ms. Stamiris in her contention 3(b). The

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Staff's view is that: i tem 3(b) I and 3(b) XIII are examples of violations of criterion III; items 3(b) II and 3('o) IX (c) are examples of violations of criterion V; items 3(b) VII and 3(b) IX (a) and (b) and 3(b) XV are examples of violations of criterion XVI; and item 3(b) XI is an example of violations of criterion V and XVI.

l j As discussed on pages 21 through 23 of the attached NRC

-Investigation Report (attachment 2) the Staff agrees with the allegations inContention3(c).

Ms. Stamiris also references additional Q.A. deficiencies reported I in NRC I&E reports 80-32 and 81-01 and SALP assessment of 11-24-80, CPCo Report 18.4.3.6 and NCR 3401 without any other specification. I authorized I

NRC I&E Reports 80-32 (attachment 3) and 81-01 (attachment 4). My O

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observations of quality assurance implementation prior to December 6,1979 p y r-- -+, e-,-e-~-- -,e , v v- ,m-v y -

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r a i ' led me'to believe that managerial attitude was inconsistent with implementation of quality assurance regulation's with respect to soil settlement problems. .-

'My present op. inion is that managerial attitude is consistent with implementation of ' quality assurance regulations with respect to soil settlement problems. The basis of this opinion is set forth in the NRC Staff testimony assessing present' implementation of quality assurance at the Midland Plant..

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ATTACHMENT 1 D) l A

v EUGENE J. GALLAGHER OFFICE OF INSPECTION AND ENFORCEMENT '

U.S. NUCLEAR REGULATORY COMMISSION

-PROFiSSIONALQUALIFICATIONS I am a Civil Engineer in the Division of Resident and Regional Reactor i Inspection, Reactor Engineering Branch, Office of Inspection and Enforcement.

I received a Bachelor of Engineering Degree in Civil Engineering from Villanova University in 1973 and a Master of Science Degree in Civil / Structural Engineering from Polytechnical Institute of New York in 1974. I am a registered Professional Engineer in the States of

-Illinois (#37828)~, Florida (#29114) and Louisiana (#16376). I am a member of the American Society of Civil Engineers, American Concrete Institute and Tau Beta Pi National Engineering Honor Society.

In my present work at the NRC, I provide technical assistance in the area of civil engineering to Regional offices and resident inspectors with particular enphasis on the design and construction of reinforced and Q prestressed concrete structures, foundations, structural steel buildings and in structural testing and surveillance. In addition, I provide iL 'j technical input for the development' and interpretation of industry codes, standards and regulatory requirements relating to inspection activities.

From 1978 to 1981 I was a member of the NRC Region 3 inspection staff responsible for' the inspections of civil engineering aspects of plants under construction and in operation. This included the Inspection of laboratory and field testing'of concrete, steel and soils materials, earth embankments and dams, material sources, piping systems and reinforced and prestressed concrete structures. In addition, a review of management controls and quality assurance programs were performed at plants under construction. I participated in approximately 90 inspections of reactor facilities.

Prior to joining the NRC Staff I was employed by E8ASCO Services, Inc. in New York City from 1973 to 1978. I performed designs of reinforced concrete and steel structures, design of hydraulic and water supply t

systems and preparation of specifications for construction. From 1975 to j 1978, I was the civil resident engineer at the Waterford 3 Nuclear Plant site responsible for providing technical assistance to construction, t

! Ouring 1972 and 1973 I was employed by Valley Forge Laboratory in Devon, PA performing inspection and testing on concrete, steal and soil materials.

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( I ADDITIONAL NRC TRAINING I

Fundamentals -of Inspection, ilRC, February 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)-

8WR Fundamentals Course,ilRC, March 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)

' Concrete Technology. and Codes, Portland Cement Assoc. , May 1978(80

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Quality Assurance Course, flRC, August.1978 -(40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) flondestructive Examination and Codes, Rockwell Int'l., August 1978 (120 hou rs ) .. ..

PWR= Fundamentals Course,flRC, November 1973 (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)

~ Welding Metallurgy, Ohio State University, September 1980 (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />)

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- ATTACHMENT 2 Og a

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Docket No. *"9' Docket U . 50- Ju Consumers Power Company ATTN: Mr. Utophen H. Howell ,

Vice President 1945 tiest Parnall Road Jackson, MI 49201 Centlemen:

This refers to the investi;ation conducted by Messrs. C. A. Phillip, E. G. Gallagher and G. F. Faxwell of this office on December 11-13, 13-20, 197S, and Janusry 4-5, 9-11 and 22-25, 1979, of activities at the Midland Nuclear Plant, t.' nits _1 and 2, authert:ed by NRC Construc-tien Permits No. CPPR-31 and Fo. C?PR-82. The investigation related to the secclement of 'the diesel generator building at Midland and the g

adequacy of the plant area fill. The preliminary results of this i investigation were discussed with Consumers Power Company and Bechtel Corporation representatives in our office on February 23 and Parch 5, 1979. *he report on the catters discussed during those meetings were i included with =y letter to you dated " arch 15, 1979. That letter also set forth the principal eatters of our concern as a result of this investigation.

Enclosed is a copy of the report of this investigation. In accordance

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with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, l Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the TRC's Public Docu=ent Room, except as follows. If this report contains infor=ation that you or your contractors believe to be proprietary, you must apply in writing to this office within tveaty days of your receipt of this notice, to whhhold such infor:ation from public disclosure. The applicatien zust include a full statecent of the reasons for which the infor acion i; is considered proprietary, and should be prepared so that proprietary infor:stion idectified in the application is contained in an enclosure to the application.

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U.S. NUCI. EAR REGUI CORY C050!ISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 050-329/78-20; 050-330/78-20

Subject:

Consumers Power Company Midland Nuclear Power Plant, Units 1 and 2 4, Midland, Michigan Settlement of the Diesel Generator Building Period of Investigation: December 11-13, 18-20, 1978 and January 4-5, 9 .11, 22-25, February 23, March 5, 1979 Investigators:

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E. 0 Callaghgr, 3-U3-79 hc.'1),'l5 F. Ma:

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V4 5/--fr <jev f Reviewed By: D. h! Mayes,'Ch,ref 3 / / / 7 '/

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Engir ering Support Section 1

., ISksh Reactor Construction and .

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Engineering Support Eranch

.Q T n e 0,i y C. E7'Norelius 3 !/'7 !7 7 Assistant to the Direcccr bI Nf' .

htC OF 7905o2elve2.

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REASON FOR INVESTIGATION On September 7, 1978, the licensee notified Ragion III, by telephone, that the set:1ement of the Diesel Generator Building and foundations experienced consti:uted a matter repor:able under the requirements of 10 CFR 50.55(e). Wri: ten interim reports were subsecuently submitted by the licensee by letters dated September 29 and November 7,1978.

An investigation was initiated to obtain information concerning the circumstances of this occurrence to determine whether: a breakdown in the Ouality Assurance program had occurred; the occurrence had been procerly reported; and, whe:her the FSAR s:atements were consistent with the design and construction of the plant.

SCOPE This investigation was performed to obtain information relating to design and construction activi:1es affecting the Diesel Generator Building foundations and the ac:ivities involved in the identifica-tion and reporting of unusual settlement of the building. The investigation consisted of an examination of pertinent records and

/'~'s procedures and interviews with personnel at the Midland site, the Consumers Power Company of fices in Jackson, Michigan, and the Sechtel

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\- Power Corporation of fices in Ann Arbor, >dchigan.

SUMMARY

OF FACTS By letter dated September 29, 1975, the licensee submitted a report as required by 10 CFR 50.55(e) cencerning an unural degree of settle-ment of the Diesel Generator Su11 ding (DGB). This reper: confirmed la informa: ion'previded during earlier :elephone conversa: fens on or i

about August 22, 1979, with the NRC Resident Inspec:or and on Sep: ember 7, 1978, with the Region III office. This report was an interim repor: and was followed by periodic interim repor:s providing additional information concerning actions being taken to resolve the problem. Fur:her testing l and moni:ering programs and an evaluation of the resulting da a have l

l been under:aken by the licensee to determine the :ause of the settlemen:

and the adequacy of :he :orrective action being takan. The results of

hese efforts will be submi::ed in a final repor :o the NRC.

Infrr ation ob:ained during :his inves:iaation indi:a:es: (l) A lack of control and supervision of plan: fill ac:1vi:les c:ntributed :o :he inadequate ::mpac:ien of founda: ion ma:eri41; (2) corree:ive ac:ica

! regarding n:nconformances rela:ed :o plant fill was insufficien: or i

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V-inadequate as evidenced by the repeated deviations from specification requirements; (3) certain design bases and construction specifications related to foundation type, material properties and compaction require-ments were'not followed;-(4) there was a lack of clear direction and support between the contractors engineering office and construction site as well as within the contractors engineering office: and, (5) the FSAR contains inconsistent, incorrect and unsupported statements with respect to foundation type, soil properties and settlement values.

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DETAILS

-Persons Contacted .

.During this-investigation approximately 50 individuals were contacted.

Twelve.CPCo personnel which included corporate engineering and quality assurance personnel as well as site management, quality assurance and quality control personnel. Thirty-two Bechtel personnel were contacted.

These largely consisted of site engineering,.quali:y assurance, quality n ,.c .a_. control, survey and labor supervisors and personnel in project engineering, quality assurance and Geotech at the Ann Arbor, Michigan office. . Three.  ;

individuals employed by U.S. Testing Company were also interviewed.  !

4 Introduction On August 2d,1978, the licensee informed the NRC Resident Inspector at the Midland site that unusual set:lement of_the Diesel Generator suilding (DG3) had.been detected through.the established Foundation Data Survey program. b'hile~the licensee regarded the matter as seri:us it was no:-c'ensidered to be reportable under the provisions of 10 CTR 50.55(e) until further da:a was obtained.

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Following the acquisition of addi:icnal data from further surveys and

a. core boring program which was initiated on August 25, 1978, the t's- licensee concluded the mat:er.was reportable and so telephonically notified Region III on September 7, 1978. The notification was follcwed up by a series of interim reports the first of which was submit:ed :o Region III by letter dated September 29, 1978. Subse-quen: interim reports were transmitted by letters dated November 7, 1978 and January 5, 1979.

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An inspection was conducted by Region III during :he period Oc:ober 24-27, 1978, to review the data then available; to ebserve the curren: condition af the structure; and, to review current activi:1es. Informa: ion regarding the inspection is centained in yRC Inspection Repor: No. 50-329/73-12; 50-330/78-12.  ;

On December 3-4, 1978, a meeting with SRR and Regice III represents:ives was held at the Midland site :o reviev :he status of the problem, :o discuss open' items identified in the aforemen:1oned inspection repor:

l. .and possible correc:ive actions.

' Identification and Reportin2 of Oiesel Genera:or Ecildinz !at:lement f Sur;evs :o es:ablish a baseline eleva: ion for the 0G3 vers :cepleted ,

bv 3echtel On Shy 9, 1973. As a resul: of :hese surveys, :he Chief .I of Survey Par:ies noted what he considered :s be unusual se::lemen:. He l O

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indicated _that from his experience-he would have expected about 1/8" settle-ment. The July 22 data- showed a dif ferential settlement between various locations ranging'from'l/a" to a. maximum of 1 3/8". .He promptly instructed his survey personne11 toLresurvey to: determine whether the data was accurate.

The resurvey. confirmed the accuracy of the survey data. The Chief of Survey Parties reported the survey, results to the Bechtel lead civil field engineer.

The lead civil field engineer said that ~ 1n. July 1978 the settlement of a pedestal in the DGB was noted from surveys and about a week later a 1"l discrepancy.was noted shen scribes on the 0GB were being moved

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up. He said that at that time he was uncertain as :o'whether actual set:1ement had occurred, the survey was in error or the apparent z discrepancy was a construction' error. He instructed the Chief of Survey Parties to check his survey results and to perform ' surveys more

- f requently :han the 60-day intervals required by the survey program as-a means cf determiaing whether-actual secclement had occurred and

-whether settlement continued.

The . Field Project Engineer was also informed of the apparent settlemen:

and.cencurred with the lead. civil field engineer's ac: ions. He said he had :oured the building at : hat time and he saw no visible indica: ions of stress which could be expected when unusual settlement occurs.

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- The lead civil field engineer said the DGB was monitored for about a

month. He compared the amount of settlement being experienced with the

\s_ se: clement values reflected in Figure 2.5-48 of. the FS AR and did not

- consider it. reportable until those values were exceeded. When the sectiement did exceed those valuesLas indicated by survey data obtained on about August 18, 1978, he prepared a conconformance repor: with the assistance of QC personnel <

The July 22 survey data was :ransmi::ed by the si:e to the 3echtel Project Engineering office in Ann Arbor by a routine transmittal memo

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da:ed July 26, 1978. The data was received at Ann Arbor, processed through document centrol on August 9, 1973, and was routinely routed

. :o the Civil Enginearing Group Supervisor. He sta:ed he did not review the data but placed a rou:e slip on it indicating those members of his group who should review 1:.

The engineer in :he Civil Group, who had established :he survey program and who was responsible for assuring i; was being carried out, sca:ed he reviewed the data and did ne: regard it as unusual. Ter that ressen he did not bring the ma::er to anyone's at:en: ion bu: merely routed 1- to o:her personnel in the civil group. The engineer respcnsible for the OGB said he did not see the da:a before the se::lement problem was iden:ified by the field in a nonconformance report.

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\j With the issuance of the noncemformance report, No. 1482, on August 18, 1978, C?co was also informed of this condi: ion. Cn or about August 21, 1973, the NRC Resident Inspector was orally informed of the matter by C?Co. It was indicated at that time cha: al: hough CPCo regarded :he matter as serious, they'did not consider it to be reportable under 10 CFR 50.55(e).

Construction on the DGB was placed on hold an August 23, 1978 and a test boring program was initia ed on August 25, 1978. Af:er prelim-inary evaluation of soil boring data, a Management Correc:ive Action Report (MCAR), No. 24, was issued by Sech:el on Se.ptember 7,1978.

The MCAR stated that based on a preliminary evaluation of the data, the mat:er was reportable under 10 CFR $0.!5(e), 1, iii and Region III was so notified by telephone on that date.

The telephone notification was subsequen ly followed up by a letter dated September 29, 1978, from CPCo enclosing a copy of MCAR 2a and Interim Report 1 prepared by Bechtel.

On the basis of the above, it is concluded that ;n this instance the licensee co: plied with the reperting require:ents of 10 CFR 50.55(e).

Review of ?S AR/?SAR Commitments oc Coroacted 7111 Material e

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-! apparent inconsistency was identified between FSAR Table 2.5-14 (Summary of Foundations Supporting Seismic Categcry I and II Strue:ures),

Table 2.5-9 (Mini:um Compaction Cri:eria) and the site cens:ruction drawing C-15 (Class I Fill Material Areas) regarding the type of foun-dation material to be used for plan: area fill. Table 2.5-14 identifies the suppor:ing soil ma:erials for the Auxiliary Building D, E, F, and C, Radwaste Building, Oiesel Generator Building and Bora:ed %'ater Storage Tanks to be " controlled cc= pac:ed cohesive fill." Table 2.5-9 also indica:es :he soil type for " supper: of structures" :o be clay.

lon:rary :o these FSAR cc= 1: ents, drgving C-45 indicates 2cce 2 (randen fill) =aterial, defined in Table 2.5-10 as "anv =a:ertal free l

of humus, organic er c:her deleterious material," is to be used wi:h "no j

res:rie:icas en .2radatien." Bering samples subs:an:ia:ed that Z:ne 2 (randc: fill) ma:erial was in fac: used.

Durin; :his investiga:ica a review of d:cumenta:1:n shewed :ha: :he co 21: en: :o use cohesive soils was also made in respense :: ?SAR ques:ica 5.1.11 and sub=1::ed in ?SAR Amend:en: 6, dated December 12, l 1969, which s:a:es,'" Sails above Ileva:ian 605 will be cohesive soils in an engineered t.ckfill." This respense also indica:ed :ha: cer:ain class ! cceponene s s u;h as , eeerzencv diesel :enera:: s, hera:ed va:er l

L s:erage tanks a".d , 3ec'.a:ed pipinz and elec:ri:al condui: w0uld be founded on T..ls ".: erit 1.

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CPCo cuality assurance issued a nonconformance report QF-66, dated October 10, 1975, which stated that contrary to the PSAR statement (quoted above) Specification C-211 being implemented at the site required cohesionless (sand) material to be used wi:hin 3 feet of the walls of the plant area ltructures. The corrective action taken was I i for Bechtel to issue S AR Change Notice No. 0097 which stated, "The FSAR will clarify the use of cohesive and cohesionless so:ls for support of Class 1 structures." As noted above, the FSAR tables 2.5-14 and 2.5-9 once again stated that cohesive (clay) material was used for support of structures while :he construction drawing continued to permit the use of random fill material.

This investigation included efforts to ascertain whether procedures were established and implemented for the prepara: ion, con:rol and review of the technical criteria set forth in the safety analysis report (S AR) .

This included the role of both Bechtel and CPCo in the review of the SAR. Bechtel had established control of the SAR in precedure MED 4.22 (Preparation and Control of Safe:y Analysis Pepor: Revision 1, dated ~ June 20, 1974). The SAR prepara: ion and review flow chart requires the Engineering Group Supervisor (EGS) to reviev the originator's draf:

fer technical accuracy and compliance with the standard format guide.

Records indicated that Section 2.5.4 was origina:ed by :he 3echtel Geotech group on January 3, 1977. It was reviewed and approved for technical

(- f '"'N accuracy by an engineer in the civil projec: group on April 29, 1977.

I I No technical inaccuracies were noted in the documentation. The Civil

\~ - ECS advised that he did not personally review section 2.5.4 The designated engineer stated that in his review of :he sec: ion he was primarily concerned with the Auxiliary Building not the Diesel Genera:or Building. He said the review of FSAR ma:erial was performed by members of a group set up for this purpose. Not all of the content was checked since they relied to seme extent on :he originator. The author of See: ion 2.5.4 said he was not aware that changes regarding fill material had occurred since :he preparation of :he PS AR. It was tscer:ained that Field Engineerin; did.not reviev :he TS AR prior to its submi::al.

A par:ial review of the FSAR revealed that although Figure 2.5-48 indicates anticipated set:lement of the Diesel Generator Building during the life of the plant to be on the order of 3 inches. Section 3.3.5.5 (5: rue: ural Accep:ance Criteria) contains the fol'owing sta:e-I ment: "See:lemen:s en shallcw spread f:ctings founded :n compacted fil*.s are es:imated to be on the order of L/2" or less."

.See:1:n 3.S was prepared by Project Engineering. Geo:ech, who prepared Section 2.5, said they were unaware of :he presence of :he s:a:ement regarding 1/2" settlemen: in See: ion 3.3. The origina:or of Sectica 3.?

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said that the above statement was taken from the Dames and Moore report submitted as part of the PSAR. Since the PSAR did not show any change.

in this regard, he assumed the statement was valid for inclusion in the FSAR. He said there was_no other basis to support- this statement.

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CPCo also has an established procedure for the review and final approval

' of the S AR by procedure >TPM-13 dated June 23, 1976. Section 5.6 states j chat "CPCo shall approve all final draf t sections of the FSAR prior to ~

l final printing." Discussion with the responsible licensee representa-l.

cives for review of Section 2.5.4 indicated that a limited amount of

- cross-reference verification of technical content of the FSAR is

. perf ormed by C?Co.

The CPCo Project Engineer in Jackson stated that the review of drawings and specifications was an owner's preference kind of thing. No attempt was made to review all drawings and specifications since they did not have the manpower or expertise for that type of review. The staff engineers of the various -disciolines were asked to . indicate the drawings and specifications they wanted to review.

Regarding the review of the FSAR, he said that he had prepared a memorandum to the staff engineers stating the procedure that would be

followed in performing the review.

An examination of this memo, dated

/' \ July 28, 1976, showed that prime reviewers would perform a technical

( review, resolve comments made by other reviewers and perform the CPCo licensing review to assure compliance with required FS AR format and content.

As portions of the FSAR were received from Bechtel, C?Co sent comments to Bechtel. Following this review, meetings between Bechtel and CPCo were held to clearup any unresolved matters before each section was '

released for printing. A review of the files at CPCo relating to Section 2.5 and 3.3 showed that no comments were made concerning the above inconsistent and incorrect content. The apparent inconsistent and incorrect s tatements were act iden-ified during the review of the FSAR prior to submittal and the review procedures did not provide any mechanism ts identifv apparent inconsistencies between sections of the FSAR.

Based en the above, measures did not assure that design basis included in design drawings and specifications were translated into the license application which resulted as an inconsistency between the desi;n drawings and the FSAR. This is considered an item of noncompliance with'10 CFR 50, Appendix Y Criteri:n II*. (329/73-20-01; 330/73-20-01) e c

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Effect of Ground Water in Plant Area Fill

The normal Final' plant' grade.will be established at elevation 631 ground water was assu=ed_to_be at ground surface prior :o construe:1on, approximately' elevation 603. The' surface of the water in the cooling water pond.will be at a maximum of approxi=ately elevation 627.

The Dames and Moore' report on Foundation Investigation submitted 'with PSAR Amendment No. 1, dated February 3, 1969, stated that,'"The ef f ect of raising :he water level to elevation 625 in the reservoirs will cause the normal ground water level in the general plant area to

' eventually rise to approxima:ely eleva: ion 625. However, a drainage sys:em will.be provided to maintain the ground. water level in the plant fill at elevation 603."

A suoplement to Dames and Moore report was ' submitted in ?S AR Amendment No . 3 ; d a t ed Augus t - 13, 1969. which changed :he above planning of a drainage system to control the ground water. The supplement states, "The underdrainage system' considered in the initial report has been elimina:ed; consequently 1:'is assumed that the greund wa:er level in the plant area'will. rise concurrently to approxima:ely elevation 625."

A 3ech:el soils consultant'theori:ed in a December 1, 1973, site eeeting

/ ) that if soils' beneath the diesel generater building had been ecmpacted

\s,,/ too dry of optimum, changes in moisture af ter placement :could cause the soils ~co settle.significan:1y. 'Therefore, the total effect of the 3round. water being permitted to saturate the plant fill material is undetermined at this ti=e. An evaluation of this condi: ion is'under review by the licensee. This i:em is considered' unresolved. (329/78-20-02; 330/78-20-02)

Review of Comcaction Requirements for Plant Area 7111

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During the investigation a review of the his:ory of the esmpaction requirements.vas performed in order to determine whe:her :he compaction of the plant fill was implemented in cempliance with the commitmen:s in

he PSAR and in si:e construction specifica: ions.

?$AR, Amendmen:~ 1, da:ed February 3,1969, presented :he Oames and Yeare repor: " Foundation Investigation and'?reliminary Exeloracica for 3orrow-Pa t e r ials . " The recommended minimum compac: ion criteria for suoport cf cri:1 cal s:ruc:ures is s:a:ed en page L5. I: indica:es 95% of maximum density for " cohesive soils" as de: ermined by ASO! 0-1357-66T and LOOP for " granular solls."

?SAR, Amendment 3, da:ed Augus: 13, 1969, included a supplemen: :o the James and Moore repor: enti: led, "7ounda:ica 'nves:iza:icn and Freliminary

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Exploration for Borrow Ma terials." Page 16 of this repor: lists :he recce ended minimum compaction cri:eria for sand stils and cohesive soils.

For the fill material for supporting s:ructures the minimum compaction is 85% relative density for sand and 100% of maximu density for clay as determined by ASTM D-69a_ odified :o require 20,000 f t-lbs. of compae:ive energy (equivalent to 95" of ASTM D-1557, Method D which provides 56,000 f:-lbs of compactive energy). Subsequent to the filing of Amend en: 3, no amendments were made to the ?SAR to indicate tha: the recommendations contained in the Dames and Moore report would not be followed or would be further =cdified.

^ ' ~ ' Bechtel Specificatien C-210, Secti:n 13.0 (?lant Area 3ackfill and Ber: 3ackfill) indicates the compa:: ion requirements for cohesive soil

( 13. 7.- 1) to'be "not less than 95* of max 1=um density as determined by ASTM D-1557, Method D" and for cohesionless soils -(sand) (13.7.2) :o be cc=pacted ":o not less :han 30* relative density as determined by ASTM D-2049. "

A 00=parison of the ?S AR. commitments to the specification requiremen:s shows that the Ocepac:ica conni::ents for cohesive soil (clay) were translated in:o the : ens:ructi:n specifica: ion i.e. 93*. of maxieue density using ASTM J-1557, Meth:d D (co pac:ive energy of 56,000 f:-lbs) .

However, :he ::=pactien ce==itten: in the ?SAR for cohesionless soil

,- s (sand) was to: the same as in the construction specifica:icn, i.e. 35*

f N rela:1ve density versus :he SC" rela:ive density, transla:ed in the

/ censtruction specification.

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The compaction requiremen:s actually implemented were as follevs:

a. Cchesive soil (clay): 951 of naximu density as determined by

he "34:htel Medified Tes:," a c:=pactive energy of 20,000 f:-lbs was used instead of 16,000 f:-lbs of e epa::ive energy as ::::1::ed to in the PS AR and tequired by the cens:ruction specification C-210,

-n- Se:: ion 13.7.1.

b. Cohesianless seil (sand): 30* Tel's:ive density as de: ermined by ASTM C-2019 was used ins:ead of 33" as ::: it:ed :: in the

?SAR. E:vever :his is c:nsis:en: with :Onstru::icn specifi-ca:.,:n v ..v. :e::.:n ;;.r...

The :: pa::i:n require:en:s implemen:ed durin; :enstru:-1:n :f the ;'an: .

! area fil; be:veen e'.eva:i:ns 6:3 and 62- wer e, :heref:re, *ess than .

he ::::i: en:s made in the ?5AR f:: ::hesive and ::hesien'ess fi.1 .

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less than :ha: re::tred by :he Ie:h:e'. 5:e:ift:a:i:n. (5recift:a:i:r

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' contract) beginning with Revision 2, dated. July 27, 1973, which was I issued for subcontract showed tha: i: contained conflicting sections relating to the plant area backfill compaction requirements.

LSection 13.7, Compaction Requirements, from revision 2 to the la:est revision of specification C-210. consistently- specified that the backfill

-in :he plant area shall be compacted to 95% of maximum-densi:y as deter-mined by ASTM 1557, Method D.

Section 13.4, . Testing Plant Area 3ackfill, of specifica:1:n C-210 con-

""" "## ained.:he_ statement : hat :es:s would be ' performed as set for:h in Sectien 12.4.5, Laboratory Paximum Densi:y and Optimum Mois:ure Centent, which in turn specified a lesser standard,--20,000 foot-pounds per cubic.

foot..which is commonly referred to as-the Bechtel Modified Proctor Density Test-(BMP). ' This is contrary-co the requirements of Section 13.7.

Section:12 of the specification' applies'to Oike and Railroad Embankment Construe:1on.

I:,vas also no:ed that this centrol inconsistency was reflected in the applicable Midland OA Inspec: ion Cri:eria, SC-1.10, Item 2.3(d) Compaction which sta:es "3ackfill material for the specified :enes has been compacted to' the required density as de: ermined by 3ech:el Modified Proctor Method" 2

f'^s and yet references C-210, Sec:fon 13.7 as the" inspection criteria.

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The inconsis tency in control is fur:her indicated in Specification C-208-which defined the testing contract requiremen:s of subgrade materials, See: ion 9.1 (Tes:ing) required compac:1:n tes:s to be in accerdance w1:5 ASTM 3-L557 and only when directed was the 5M? compaction criteria to be used. It was de: ermined contrary to - this U.S. Testing was only orally advised that the BM? was :he s:andard :o be applied to :he tes:s they performed of plant area fill.

~' ' Thr: ugh in:erviews and an examinati:n of in:ermal documen:s i: was

.ns:ertained :ha: because of these in::qsir:encies, the questi n cf

! :ne applicable c:mpa::icn s:andard for ::hesive ma:erials in :he plan area was a recurring One.

The f:11: wing is a su=marv ef the documen:a:icn re;srding :he confusi:n

! Of the : mpacti:n requiremen:s f:: p'an: area fill. p 1-I

- _c 1. '_e::er '220-C-210 ~~ da:ed "une 10, 197;, (subcen::a::s :: Field Engineerin;) sta:es ":here has been s:me :enfusi:n as ':: :he inter-pre:aion :f :he-f:'_ low _np i:em: 13.7 ::::se:i:n To:uiremen:: all ba:kfill in the plan area and berm shal. :e ::m:a :e: :: n:: less

han ?!' ef ma::imum f ensi:y as de: ermined by modified er::::: me:hed i

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f f (ASTM '1357, Method D), with the exceo: ion that .?ones 4, 4A, 5, 3A. )

and 6 Materials need no special comoactive effor: other than as described in See:1on 12.3.1 (emphasis included in specification).

Quality Control questioned whether.:he exception s:ated above I applies enly Jeo Zoies 4, 4A' 5, 5A, and 6 or did. construction

, have to abide by Section 12.8.1 for. Zones 1 and 2. Section 12.8.1 clearly. requires Zone,2 material to be placed with a 50 ton rubber tired roller with a minimum of four roller passes per lift'. QC's interpretation was that;the field needed "co obtain 957 of maximum density by the modified Proctor method (ASTM'1537, Method D), wi:h no restrictions as to the method used to ebcain these results."-

2. Letter 7220-C-210-23,.datedJJune 24, 1974, (field Engineering :o construe: ion) responded to Item 1 abovec It states, "We have reviewed your June 10,_1974, IOM concerning compactive ef fort required'on. Zones 1 and 2 in the plant and berm backfill areas.

We agree with your interpretation; i.e. a 95% of maximum density is the acceptance criteria, and the' number of roller passes listed in Paragraph 12.S.1 does not' apply to plant and berm backfill. We

- feel the specification'is now clear and no FCR is required."

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3. Let:er'3C3E-370, dated July 25, 1974, (field construction :o

. proj ect engineering) lists outstanding items requiring Project gr

v Engineering's action. This includes the question, "Is'the-95*

compaction required in.the plant area :o be 95% of Bechtel Modified or 95*. of ASTM-1557, Method D."

4. Letter BEBC-456, dated August 1, 1974, (Project Engineerin; :o Field Cons:ruction) states that Geotech is addressing the ques:ica

-posed in BC3E-370 (Item 3 above).

5. Memorandum from Geotech to Bechtel Field, dated September 18, 1974, responds to :he question raised in 3CSE-370 (Icem 3 above). It states- "It is our opinion :ha: all the compaction

- requiremen:s that are needed for Sone II material in the plant fill is as s:ated in 13.7 with the ex:ep: ion hat Tones 4, 4A, 5, 5A, and 6 ma:erials need no special compac:ive effort other than described in'Section 12.3.1." Geo:ech reitera:es the specifica: ion requiremen: of 95* of ASTM L557, Method D. This was confirmed wi:h the Geotech personnel.

6. Telecen da:ed Sep: ember 9,1974, .from R. Crete (Field Engineering)-

o Rinford (Proj ect Engineering) states, "I made an anal:gy (an exaggera: ion admi::edly but applicable) tha: if :he compac:icn could be acheived with a herd of mules walkin: over :he fill it would be accep:able as long as i: ;ot :he required 955 compac: ion.

Rixford agreed."

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7. Telecon Consumers to Bechtel Engineering dated September 19, 1974, expressed Consumers Power Company concern about wha: they felt was a lack of control of compac: ion in the plant area fill. CPCo addressed the added_ responsibility this lack of control places on the inspector. Bechtel :old CPCo : hat it "was the inspector's job to make sure we got proper placement, compaction, etc."

8. Telecen dated Septe=ber IS, 1974, by Bechtel Field Engineering to Sechtel Project Engineering discussed compaction requiremen:s for specification C-210. It sea:ed, " Compaction acceptance is based on meeting an 'end produe:' requirement, i.e. 95* of maximum density only. No method of achieving this 'end product' is specified or is required. Rixford fully agrees with the above."

9. Telecon-dated October 7,1977, f rom Bechtel Field Engineering to Bechtel Project Engineering states, "QA has asked for clarification o f subject specification (C-210), See: ion 13 for plant area and berm backfill. See:1on 13.4 for :esting of materials refers to Section

.!2.4 and therefore, requires the Pechtel Modified ?rce:or Density Test for Compac:fon of cohesive backfill. See: ion 13.7 for compac-tien of the same materials refers to :ssting in accordance with ASTM D-1557 Method 0 Proc:or, w1:hou: specific reference :o Sechtel Modification." Sech:el Engineering responded to this question aa

/N follows: "This apparent conflict is clarified by Specification

('- ') C-203, Section 9.1.a, direction to the :esting subcontractor, which calls for ASTM D 1557 test for these materials and also allows Bechtel Field (the contractor) to call for the 3echtel Modification of tha: test. Either =eched is :herefore acceptable to project engineering."

10. Telecon da:ed October 7,1977, f ree 3echtel QA to 3ech:el Proj ec:

Enzineering questions, "Is :he intent of Paragraph 13.7 of Speci-fication C-210 that :he :es: be run to the 'Sechtel' modified proctor :est as is indica:ed in the FSAR Paragraph 2.5.4.5.3 and in respense to ::CR 33 ' Eh;ineering's response was "ves."

Various interviews were held wi:h Bech:el cons: rue: ion field en2ineers, C. C. Tes:inz personnel and Sech:el Ann Arbor Geotech and ?roj e::

Engineering personnel to ascertain : heir understanding of the cenpac:icn requiremen:3. Tour predcminan: versi:ns of :he unders::cd compa:: ion requiremen:s were s: aced by vari:us individuals vi:hin :he 3e:h:e1 Or;ani:a:1:n. They are as icilews:

a. Specifica:ica C-2'.0 required :he :en:rac::: :: perf:::

compac:icn :o the AST:t !557, Me: hod D, however, :he :esting recuirerenta w:cid be perf:rmed to the less 3:rinzen: "Esch:el Modified Tes: ".e :ho d . "

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b. -The required compaction and testing was always understood to be based on the "Bechtel Modified Test Method."

c. The required compaction and testing was always understood to be based on the standard ASTM 1557, Method D requirements,

d. A tacit understanding had been. established to use the techtel Modified Method, but to exceed this requirement by enough to'also satisfy the requirement of ASTM 1557, Method D.

It is apparent from the above four distinctly different understandings w 3. n .

of the compaction requirements, that the apparent confusion was not resolved. A member of the 3echtel QA staf f in Ann Arbor who had previously been a QA Engineer at. the Midland site said that QA audits of QC inspection' criteria did not identify the above inconsistencies.

This failure to-accomplish activities affecting the quality of the plant area fill in accordance with procedures is considered an item of noncom-pliance with 10 CFR 50, Appendix 3, Criterien V. (329/73-20-03: 330/78-20-03';

Review of Moisture Control p.ecuirements for plant Area Fill 7"'N Specification C-210, Section 13.6 (Moisture Control) requires moisture t control of the plant ' area fill material to conform to Section L2.6.

N The moisture control requirement in Section 12 6. .1 states , in part,

" Zone 1,.lA and 2 =aterial which require moisture control, shall be moisture conditioned in the borrow areas," and that " water concent during compaction shall not be more than two percentage points below optimum moisture content and shall not be more than two percen-

. tage points above optimum moisture content."

Contrary to the. above, Sechtel QA identified in 50-40 dated July 22, "Lw"" 1977, that "the field does not take moisture control tests prior to and during placement of the backfill, but rather rely on the moisture results taken f rom the in-place soil density tes ts."

The following is a summary of the documentation that followed the identification of the above deviation from specification C-210.

1. Letter 3C3E-l533R (dated August 15, 1977) field to pr: ject engineerin;

. states, "it was found that densities meetin; specification require-ments could be attained, irrespective of the use of moisture tests," and that " moisture tests were not used to :entrol backfill moisture." The field requested "that project engineering a7ree to acceptance of backfill materials installed in the past, alenz with the records'thereof, irrespective of the use of the meisture tests."

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2. Letter BEBC-1859 (dated Sep: ember 30, 1977) responsed :o :he fields request in 3C3E-1533R. Engineering states, "It should be noted that it is ideal to control the moisture of backfill material at the borrow areas by conditioning" and that ":he procedure used to take moisture conceit . tests af ter compaction would not have direct impact on the quali:y of work." Engineering then agreed with the field request that " backfill placed prior to modification of testing methods to be accepted as is."

3. Telecen October 10, 1977, (3echtel OA Site :o 3ech:el Engineering, Ann Arbor)' indica:ed that , "there are no moisture requirements at the cime of density testing, only density requirement. The moisture requirement is prior :o compaction."

4. Telecon October 13, 1977, (Bechtel Engineering to 3echtel CA Site) changed what was indicated in the telecon on Oc:ober- 10, 1977, (Item 3 above) . Engineering then stated, "The moisture require-ment (+ 20 of optimum) is mandatory and must be implemen:ed at the time of pla:ement and testing." This is con:rary to what war stated en October 10, 1977.

5. Le::er SCBE-1669R (dated Novencer 18, 1977) once again is a field reques: to Bechtel engineering reques:ing, " written clari-

/'~m's fication of the 2% tolerance on backfill moisture content during

5. compaction."

6. Letter BE3C-1993 (dated December 15, 1977) provides engineering's response to SC3E-1669R reques:ing clarification of the mois:ure requirement. Engineering stated, "The mois:ure con:ent of the soil should be within 2! of optimum during placemen: and compaction.

Hewever, this property of the soil is not necessarily a measure of its adequacy after compac: ion."

7. Le::er 0-1631 (da:ed December 21, 1977) closes OA Action Reques:

50-40 (da:ed July 22, 1977) which firs: iden:ified the mois:ure concrol deficiency.

S. Telecon (dated April 7, 1973) from Field Engineering and Ouali:y Con:rol :o Projec: Engineering once again reques:s them ":o clarify 3EBC-1993" (December 13, 1977), Item 6 abeve. Two situa: ions were presen;ed to engineering as follows: (a) The mois:ure sample

aken f res :he borrow area at the start of :he snif: is acceptable, however, the mois:ure tes: taken in conjunc: ion wi:" Jae denst:y tes: fails while compac:1on was a::ained; and ,01 The nois:ure sample taken ft:m :he borrow ar2a at the s: art of :he shif: fails and :he material is condi:i ned :o meet mots:ure con:en: required,

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v however, the moisture test later fails at the time the passing compaction est is taken. Engineering responded, "the above :wo situations are acceptable as is." This response is contrary to the direction previously given in :elecon dated Oc:ober L3, 1977 (see Item 4 above).'

9. Letter GLR-249 (April 16,1978) is a Sechtel Si:e OA request to Project Engineering to resolve the moisture content situation and "to provide clear direction for :he control of moisture concent." QA recommends "one possible solution would be to delete the requirement to con:rol :he moisture content and rely

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on the compaction requirement only for completion of soils work."

10. Letter 3E3C-2236 (June 1, 1978) was Project Engineering's response to GLR-249 (Item 9 above) . It states, " moisture content is not necessarily a measure of a soil's adequacy to act as a founda: ion or backfill material," and tha: " soil with the specified densi:y following compaction would no: be rejec:ed on the basis : hat its moisture content was not contr:lled in the borrow area."

Based on the reviews of documentation, mois:ure controi had no'. been implemen:cd as the specification required. In addi: ion, the cat:er had not been resolved for the period of time from the issuance of QA e' 's Action Request SD-10 on July 22, 1977, until June, 1973, during which (x,_ ) time soils saf ety-related work continued.

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According :o the licensee, although coisture centrol was not s:rie:ly followed in accordance with specifica:1on requirements, final densi:y tests were used as a basis for acceptance of soil placement.

As poin:ed ou: to the licensee, moisture control is a required cen:rol point to assure attainment of percent compac: ion specified in specifi-cation C-210.

This failure to assure that conditions adverse to quality are pr:mp:1y iden:ified and corrected to preclude repe:i: ion is censidered an item l of noncompliance with 10 CFR 50, Appendix 3, Criterion XVI. (3.9/73-l 20-01; 330/73-20-04) i Revies of Subtrade ?recara: ion for plant Area ill The Oates and ! bore repor: on fcunda: ion investiga: ion Aubmi :ed wi:h PSA?. Amendmen: 3, da:ed August 13, 1969, states, "the clay soils are susce:tible :o loss cf strenzth due :o frost action, disturbance and/:r the presence of wa:er. If :he c:ns: rue:1on schedule requires

ha: founda: ion ex:ava:1on be left open durin; the win:er, it is re::: ended tha: an:ava: ion opera: ions be performed such :ha; a: leas:

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3.1/2 feet of natural soil or similar cover remain in place over the final subgrade or overlying the med mat. This layer of protective material is necessary to prevent the softening and disturbance of subgrade soils due to frost action." The licensee indicated :ha:

' instructions for winter' protection of foundation excavations were trans-mitted-by sketch C-271.

The Dames and Moore report also s ated, "If filling and backfilling operations are discontinued during periods of cold weather, it is recommended that all frozeh soils be removed or recemoacted prior to the resumption of operations."

After review of the applicable sections of specification C-210 (i.e.

Sections 12.5.1, 12.10, 10.1 and 11) the inspector has determined that the Bechtel specification did not provide specific ins: ructions for removal or recompaction of frozen /: hawed soils upon resumption of work after the winter period to preclude :he' effects of frost action on the compacted subgrade materials.

This failure .to assure that regulatory commitments as specified in the license applicatten are translated into specification, drawings or instrue:1ons is considered an item of noncompliance with 10 CFR 50, Appendix 3, Criterion III. (329/78-20-05; 330/78-20-05) s

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i Reviou of Nenconformance Recor:s Identified for ?lant Area Fill

\s The following examples of nonconformance and audit repor:s regarding the plant area fill were reviewed relative to the cause of the noncon-

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formance and the engineering evaluation and corrective action: -

No. Nonconformin2 Condi ion Entineerin; Evaluation (1) CPCo Failure to perform inspec- "Use as is" based on QF-29 tion and testing of struc- samples taken frem stock (10/11/71) tural backfill (sand) pile.

delivered to jobst:e 29 of 30 day in Aug, and Sep:.

74 Sech:e1 OC not informed of deliveries.

l (2) C?co Mois:ure con:r:1 out of Ac:ep:ed in place ma:erial QF-32 :olerance of specift:a- wi:n low moisture.

(3/7/75)  : ion C-210, see:ica 13.6.

( 31 CPCo Compac: ion :es: had been Failinz :ests were cle'ared QF-63 calcula:cd using incor- by su'esee.uen: passing l (10/17/75) ree: maximum lab densi:7 :es:s.

Tes: recerded as passin; was ac:usily a failure.

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- n (4) , 'Bechtel Sheerial placed did not. Engineering stated'that f NCR 421 meet moisture require- this ramp area is temp- 1 (5/5/76) ments. orary and>would be removed. j This was removed based on

" note added to NCR 421'on 3/18/77.

Note: In the vicinity of this ramp a Geotech engineer deter-mined the material to be." soft" and directed a test pit to be dug for investigation in September 1973 af ter the D. G. 31dg.

' settlement was identified.  ;

(5) .C?Co Lift thickness exceeded Material was removed and ,

,QF-120 maximum of 4"_in areas recompacted.

(9/21/76) not' accessible.to roller equipment. Insufficient monitoring of , placing

. crews. -Laborer foremac  ;

not familiar with re-quirements. .

E -(6)' CPCo Inspescion plSn C-2!0-4, Corrected inspection plan QF-130 Rav;- 0,' permits 12" lift ' requirements.

jr' -(10/18/76) thickness for areas in-accessible to rollers i'  !

caused by "misinterpre-cation ~of specification requirements. Spec. per-mitted 4" lift thickness.

(7) CPCo Failure to perform inspec- Engineering accepted the

'0F-147 tion and testing of struc-. material in place "use tural backfill (sand) on (2/2/77) as is."

12/1/76, 12/14/76 and 1/11/77 (same as QF-29 dated 10/14/74) material lacked gradation test requirements.

(3)- CPCo .voisture control out-of- ' Engineering a::apted QF-172 tolerance and compacti:n materials.

(7/3/77) criteria not met.

(9) C?Co Gradation requirements Engineeria; ac:epted 0F-17. for Zone 1 materials not materials.

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( 7'/15/ 7 7) met.

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(10) CPCo Moisture content not te:; Issued Bechtel SCR's No.

Q F- 199 compaccion requirements 100L and 1005; No. 1004 (11/4/77) for cohesive and cohesion- still open; No. LOO 5 less soil not cet. Mater- " accepted as is."

tais had been accepted using incorrect tes:ing data.

'll) CPCo Gradation requirement not Ingineering "accep:ed QF-203 met yet materials accepted. as is."

(11/22/77)

(12) CPCo Moisture conten: require- 3echtel C.C :o inform Audit ments not met; cest fre- forecan directing soils F-77-21 quency not met. work of requirements.

(3/77 &

6/71)

(!3) CPCo Compaction requirement for Project Engineering to Audit both cohesive and cohesion- justif: the materials T-77-32 less ca:erials no: met; :hese failing :ests (10/3/77) moisture requirements not :cpresent. SCR 07-195 .

me:; tests had been accep - still cpen.

/N ed yet failed requi-e ents.

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(11) Sech:el Same deficiency as SCR 698. Accepted, "use as is."

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(13) Bechte Strue: ural backfill (sand) Insineering accepted "ese as is."

I l SCR 693 was delivered without l (2/9/77) ac:eptance tes:s on Oct.

26, 29, Sov. 12, 1976 and Jan. 11, 12, 1977.

(16) 3ech:el  ::cis:ure cen:en: require- "A::ep:ed as is" based en l

SCR 1003 men:3 n:: 24:. densi:y :es: enly.

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tive a::icn re firiins ten:Onf 0754nces fe'.a:ed : D :1400

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ien: cr inade;;a:e as eviden:ed b* :he repea:ed devia:i:n3 ft:- s;e:i-fics:ica requirements.

~his fai*.ure :: 23sure tha: he :ause :f ::ndi:irns adcerse :: quali:"

are i:en~ifiei and "hi Adequa~e :7re:"iVe 1 i n Ye ~3 ken *: *:e lu e 4

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repetition is considered an teem of noncompliance with 10 CFR 50, Appendix 3, Criterion XVI. (329/73-20-06; 330/76-20-06)

Review of Calculations of See:1ement for Plant Area A review of the settlement calculations for the structures in the plant area was performed during a visit to the 3echtel, Ann Arbor Engineering of fice. Soecific at:ention was given to structures

- founded on plant area " compacted fill." The following specific findings were made:

1. FS AR, Section 3.3.4.1.2. (Diesel Genera:or Building) indicates the foundation 'of the DGB to be continuous footings with inde-pendent pedestals for each of the Diesel Generators. Con:rary to the structural arrangement described in the FSAR, the settle-ment calculations for the DC3 were performed on the premise : hat the building and equipment loads would be uniformly distributed to the foundation matertal by a L34' x 70' foundation mat. The settlement calculations were performed between Augus: 1976 and Cetober 1976 by Sech:e1 Geo:cch Division.

Discussion wi:h the Geotech F.ngineer who performed the set:lemant calculations indicated that he had not been informed of the l

/',_s} design change of the foundatien un:11 late August 1978 when :he l excessive settlements of :he DGB and pedestal becare apparent.

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2. FSAR Figure 2.5-47 indicates the load intensity for the OG3 :o be 4 KSF (4000 lbs. per sq. f:.); however, the se:tle=en: calculations reviewed indicate a uniform load of 3 KSF (3000 PSF) . This appears to be a conflict between the FS AR and set:1emen: calculattens.

The se: lement calcula: ions for the borated wa:er storage t'nksa 3.

were performed assuming a 54' diameter circular founda:1on =at Instead, :he tanks wi:h an assumed uniform lead of 2500 PSF.

are supper:ed on a continuous circular spread foo:ing and compacted strue: ural backfill as de: ailed on the construe: ten drawings. The Geotech engineer was also no: made aware of :he revised fcunda:1:n detail.

FSAR Figure 2.5-13 (Is:ima:ed Citica:e Settlemen:si indica:es :he an:icipated ultima:e set:lemen: for Unit i and 2 plan: 3:::::ures. The values indica:ed for :he Olesel Genera::: 3cildin; and Scra:ed a:ar S:: age Tanks are the values develeped assuming uniferely dis:ribu:ed loads feunded en na: foundations as was indica:ed in :he se::le-ent

alcula: ions reviewed even : hough :he actual desi;n and cens: rue:icn u:ill:es scread'icotings. The FSAR does no: indi:::e :he f:unda:icn p

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. N_-) ..s type assumed in the se:tierent calculations and therefore the values in the FSAR figure appear :o represent :he sec:lemen:s es:ima:ed for the as-construe:ed spread footing foundation.

4 During a review of 'the settlemen: calculations, it was observed that the ec=pression index (Cc ) for the compacted fill between elevations 603 and 634 in the plant area was assumed to be 0.001 (esticate based on experience). FS AR S ee:1:n 2. 5. 4.10. 3. 3 (Soil Paraceters) indicates the soil compressibili:y parame:ers used in the set:lement calculation are presented in Table 2.5-16.

This table indica:es that for the plant fill eleva: ions 603 to 634, the compression index used was 0.003. Contrary : the FSAR value, 0.001 was used in the settlemen: calculations reviewed.

This value is direc:ly used :o deternine :he estimated ultirate settlement of structure supper:ed by plant fill caterial.

3ased on the above examples, teasures did not assure : hat s pec if ic design bases, included in design documen:s, were translated into the license application resulting in inconsistencies between design docu-ments and the FS AR. This is considered an itet of noncompliance vi:h 10 CFR 50, Appendix 3, Criterion III. (3:9/73-:0-0;; 330/75-;0-07) t r

/N Discussions with CFCo personnel responsible for the technical review I (N- '") and format indicated that a comparison be:veen the design docurer.ts and TSAR had not been performed. Likewise, 3echtel personnel inci-cated tha: a de: ailed c0=parison for the :echnical a::uracy of design

' documenes :: :he 75AR s:atements had net been perfotmed; instead l

reliance was placed en :he origina::r's input.

According to the Civil Engineering Group Superviser, a mat foundati:n was considered for :he OG3 only during :he conceptual s: age. All drawings genera:cd shev a spread f ::ing f:unda:icn. The super ~iser i

3:ated tha: :he Geotech engineer apparently based his calcula: ions on

he concep:ual s: age informa:icn. He ven: en :: say that an individual in Geo:ech was respensible for checking the calcu'a:icns end the firs:

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hing he is supposed :: do is determine :ha: the basis for the calcu-I la:icts is corree:. He said tha: apparen:1y this was not d:ne.

1 Review o f Se::le en: ci ?.drints:rati:n Buildin: :o:ints lurin: the invas: iga:icn, it was discl sed :ha: :he Adminis:ra:irn Bui'.cing a: :he 'didland Fi:e had e:::erien:ed a:::essive se::*.e en: Of l

he f und::icn foc:in;s. A1:heu;h the Adminis::::i:n Buildinz is a l n:n-safe:v-rela:ed structure, it is supp0r:ed by ;1cn: area !;.1 ma:erial c: pac:ed and tes:cd :o :Pe sar.e recairerents as a:erial l

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supporting safety-related structures and therefore per:inent to the, j current secclements being experienced by the Diesel Generator Tailding, i

.The following are the events rela:ing :o the set:lement of the Admini- l stra:icn Building footings.

During.the end of August, 1977, a Sechtel field engineer observed a gap between a slab and the grade beam of the Administration Building. On August 23, 1977, a survey was taken of the settlement. The results indicated that the footings supporting the grade beam had experienced settlement ranging f rom 1.32" (north side) to 3.43" -(smh. side) .

This set:lement took place between July lf77; and :he enc of August

"" 1977. The footings were supported by " random fill" (Zone 2 materfgl).

i The concrete footings on the order of 7' 6" by 7' 6" by l' A" deep were removed along with the grade beam. The random fill material was also removed, _According to C. S. Testing personnel, it was observed during excava:icn of the fill' material.that there were voids of 1/ 4" to 2" or 3" within the fill and these were associated wi:h large lumps of unbroken clay measuring up to 3 feet in diane:er.

The Civil Field Engineer assigned responsibility for plan: fill work said': hat, al: hough he was no soils expert, it was.his opinion that :he

" problem was caused by the presence ef.peckets of water due to drainage from nhe steam tunnel. The Lead Civil Field Engineer also indicated

'f a crainage problem caused the Administracien Building footings settle-

.-\ . ment. They were,-however, unclear'as :o how the wa:er pockets ware l . formed, i.e. whether they were formed as the fill was being placed or.-

l hov they could develop after the fill was compac ed.

The excavated fill was replaced wi:h concrete and the design of l- individual footings was changed :o a con:inuous spread foo:ing i design for suppor: of the building.

As a resul: of the set:lement of :he Administration Building footings q a :stal ei seven borings were taken of which !ive were in the Admini . 1 scre:ica Building area, one in :he Evapora::r Building area and one sou:h of the Diesel Generator Building, in the Admints:ra:ica Buildinz area the f oundation ma:erial was found to be "sof t" wi:h " spongy char-acteristics." The two o:her borings did no: indica:e unusual ma:erial proper:tes in :ha: the blow counts were reasonable. *hese borings were taken in September 1977. 1 The licensee indicated : hat repor s from Sechtel concluded : hat the primary cause of :he settlemen: in the Admin?s:ra:ica Suilding urea 4 was insuffician: compac: ion of :he fill. Seth el also c:ncluded tha:

" deviations from specific compa:: ton requirenents was :he result of l

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v repea:ed erroneous selection of compac:1on standard," 1.e. the incorrect optimum coisture-densi:y curve was used for :he soil material being compacted. ' In effect, the moiseure-densi:y curve was erroneously assumed to represent the soil be_ing used and therefore soil was compacted to less

han maximum density.

Bechtel personnel, including the Civil Group Supervisor, Project Engineering,' the Field Proj ec: Engineer, :he Lead Civil Field Engineer,

.cnd the Chief Civil CC Inspector, all sea:ed tha: the Administration Building focting se::lement was regarded as a locali:ed orchlen. The ques: ion as to the adequacy of the entire plant area fill did no: arise even : hough the following similarities existed between :he Administration Building area and rest of plan: fill; (a) same soil specifica icn applied, (2) saee caterial (random fill) was used and (3) same centrol procedures and selection of laboratory compactica scacdards was used. The Diesel Genera:or 3uilding area required even more fill than other safety-related stru::ures since its base is located a: a higher elevation than the ethers.

. Review of Interface 2e:veen Ciesel Genera::r Su11 din 2 Feundation and

_~1ec rical Cuct 3 a n ',*. s A review of the design interface between :he elec:rical and civil se :icts fN' of :he 3echtel eriani:a:icn was performed to determine whe:her the I design accounted for the in:eraccion of the electrical due: banks and

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spread footings on :he differential se::lement of the ner:hside of the 0G3. I: ves decernined :ha: :he electrical and civil groups cade a::ome datiens in the design :o persi: se::lemen: of the spread fcotinps ar:und :he ele:irical duct banks by including a s:yr:foa " bond breaker" around the du:: banks. 3c:h elec:rica'. and civil 3 ups reviewed and ap; roved cle::rical Orawing E ~02 uhich includes :he appropria:e de: ail.

". vever. 3ech:el Drawing C-13 which iden:ifies C' ass ! fill ra:erial l

areas per:1:s :he use Of "one 2 (rand:r fil*i .chich includes "any .

ra:erial free Of humus. : ;ani: cr c:her dele:eri:us a:erial." This, in effe::, dcas n:: ):e:lude :he use :f ::::re:e ar:und :he e'ec:ri:al

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ions for accivi:1es affeccing the:quali:y of safety-related s:ructures is considered an 1:e of noncom-

.pliance w1:S 10 CFR 50, Appendix 3, Cricerion V. (329/78-20-08; 330/73-20-08) -

Review of Soils Placement and Inscection Activities for ?lant Area ?'ill-A subcontractor, Canonis Cons:ruction Company, South Haven, Michigan, performed the major portion of the earthwork at the Midland site.

Although Canonie was primarily engaged to construct the cooling pond

' dike, they also performed mos: of the plant area fill work. 3echtel, howeve'r, also performed plant fill work prior :o and.af:er Canonie lef:

the site in mid-October 1977. The las: Canonie' daily 0A/QC fill placemant report is dated October 16, 1977.

A'ccording to Canonie OA/QC records :he first fill in the DG3 area was placed in late October and early Move ber 1975. No fur:her fill was placed in :he area until July 1976. After cha: :tre, fill work in the

+ area'vas interspersed with-soils work in other areas.

Tihile it would be difficult to identify :he soil work performed by Sech:el versus. chat perfor ed by Canonie, records reviewed indicated that mest of the 3echtel work was done during the latter part of 1976 and continued through 19i7 and 1978. Although most of :he 3echtel work

( related :o placing sand around piping and ducts after : hey.were laid and placing sand adjacen: :o walls, some motori:ed work compacting clay fill was also done by Bechtel.

j' Regarding the plant fill work' performed by Bechtel, C?Co Audi: Report No. ?-77-21 dated' June 10, 1977, identified a number of deficiencies l-which reconcended the corrsetive action to be as follows: (1) "the foremen directing'the soils work should be instrue:ed as ;o the required mois:ure con:en: limi:s" and (2) "the foreman directing the soils work should be instruc:ed as to the correct tes: frequency requiremen:s." In:erviews wi:h two such Bechtel fore =en confirmed :he fac: :ha: : hey were direc tag soil opera:icns. They indi:ated they received : heir ins: rue: ton regarding 11!: :hicknesses and tes:ing requiremen:s verbally fro field engineering :hrough a general foreman.

3eshcel desi;n criteria C-301 (? age 3) and ?SAR Amendmen: No. 3 (Cares and Mcore ?eper:, Page 15).s:a:es : hat, " Filling opera: ions should be pe: forced under :he continuous technical supervision of .a qua'ified .

sotii engineer who would perf:en in-place densi:y :es:s in :he :orpac:ed fill :: verifv : hat all ma:crials are placed and compac:ed in ac:ordance wi:h :he recensended cri:eria."

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Based'en the above, the soils activities were not accomplished under the  ;

continuous technical supervision in accordance with Bech:el design cri-

aria.. This. failure to provide a qualified soils engineer Oc perfore 1

technical supervision for activities affecting quali:y as required by I specifications and :he PSAR'is considered an 1:a of~ noncompliance wi:5 10 CFR 50, Appendix 3, Criterion V. (329/78-20-09; 330/78-20-09)

The forenen indicated that Bechtel Field Engineers and QC inspectors were rarely in'the areas where soils activities were going on. The forecen )

decided when and where :ests were :aken. The locations of ests were l approximated by pacing or visually escitating dis:ances f ece columns or building walls. Lift thicknesses were determined visually, usually without the use of. grade stakes.

Soils, testing services are provided by C. S. Tes:ing Company based on the requirements of Specification C-208. The two C. S. Testing tech-nicians who said : hey performed an estimated 90% of the seil testing during the years 1975-77, indica:ed : hat they rarely saw a Sech:el field engineer or QC inspector _in-the areas where plan fill ac:ivities were going on. One :echnician said he could recall only one occasion when a QC. inspector was present when he cock an in-place density es:. The other technician estica:ed he,had con:ac: wi h a QC inspec:or in the field abou: ence a conth. A Sechtel QC inspe::or, however, was assigned to the testing laboratory on a full-time basis.

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E U.S.: Testing personne1'sta:ed that erroneous tes: locaticas were a f chronic proble: regarding the Bechtel placed fill, the loca: ion of a :est '.tas -usually given at the time of the tes: by a labor foreman L

or a labecer if :he foreman wasn't there. Semetimes, however, a foreman was not familiar vi:h the area in which he was'werking and the loca:1cn was not provided until so=ecime af:er the :est. It became necessarv en l occasien to wi:hhold':est resul:s as a means of ge::ing the test loca;ien.

Tes: 41eva: ices were approxt:a:ed' sequentially.

The technicians fur:her advised tha: rarely did a 3echte! QC inspe::or request a test. Normally, labor foremen requested : hem. On oc:asion a technician passing :hrough an area would be asked by a foreman if

. .a test should be'taken. Upon concle:icn of in-place ces:s, :he resul:s were usually coe=unicated :o :he foreman directing :he werk. Tes:

failures'were also reported by telephene to CC or Field En;ineerin;. A

• weekly reper: ef :es: was provided :o 2ech:el OC and Field Engineering who reviewed any res: failures and resolved : hem.

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'J. S. Tes: int pers:nnel advised :ha: : hey were raquested :: :ake :es:s o f c'.ay fill while 1: was raining and in 0: der :a de so, plas:ic was half over that':0 ;:::ec: : heir equipmen: while :he :es: was made.

e l-Even :heu;h 1: was rainin;, :he fill placemen: w:rk was no: s::pped en j v - 6 I

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some occasions. A 3echtel foreman confirmed that densi:y tes:s were on occasion taken wnile it was raining. While :his is no: contrary to the specification instructions, it is contrary to standard practice.

C. S. Testing personnelindica:ed that when moisture was added, :he procedure did not include blending the material which resul:ed in mushy seams. It is commonly accepted good parctice :o disc the fill after soraying it with water to add needed moisture. A 3echtel foreran stated that if moisture was needed they compacted 6" then sprinkled i:

and : hen added ano:her 6".

The field engineer who was assigned responsibility for plant fill work s:a:ed he did not spend full time on soils work since he aise had responsibill:y for two strue:ures, the steam tunnel and general yard work. He said he tried to ge: cut to the area where fill vork was being done once a day. Some :imes he did and sometimes he did no:,

He indicated it was his impression that :he CC Inspector responsible for :he soils work on :he day shift vist:ed those work areas ence or

wite a week. He confirmed that only oral instrue:1cas were furnished to the foremen whom he felt were conscientious. The main proble: he experienced with the foreman was maintaining pr:per lif: :hickness.

The QC inspecter who was primarily responsi'rle for the plan: fill verk

( p-'s is no longer employed by'3echtel. The QC inspec:or who was respensible f for :he plan: fill work on :he nigh: shift stated that he :ried :o devo:e A/

) about one hour a nigh: to the plant fill ac:ivities. He indica:ed : hat during 1976-1977 there was much emphasis being placed on cadwelding and f rebar work and it was necessary to spend the majcrity of his time on l  : hose activities. He maintained that he did have fairly frecuent contac:s with the technicians who performed the in-place density :ests, par:ic-ulc ty when :est failures occurred. He indica:ed it was nis irpression tha: the labor foremen were direc:ing fill pla:enent adequa:ely.

Eeview of !nspec: ion Procedures l

l The following pr:cedures whi h are relative :o backfill opera: tons at Midland ".'ni:s ! and 2 be: ween Augus: 1970 :hrough Decenter 1977 vere reviewed.

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a. 3ech:el Pas:er ?roject CC las:ruction for Compac:ed 3ackfill -

C-l.02 was issued for cans:ru:: ton October 13, 1979, and it is presen:ly :he curren; ins:ruccicn which is used Sv 3ech:el 0.C

/ shen Bech:al is :he inspectica a;ency, providing first level l

l inspections durin; ba:kfill Opera: ions 1. Tur:ner, :his inscruc-tion was used by Se:h:el 4C when meni:: ring the ac:ivi:ies of i

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1 other inspection agencies (Canonie) when such agencies were

performing the first level inspections of backfill opera

ions during the time periods of October 18, L976, until June 26, 1977.

b. Bechtel cuali:y Con' trol >bscer Inspection plan for Plan: Foundation Excavation and Cooling Pond Dikes (Plant Area Backfill and Berm Backfill) - Procedure No. C-2l0-4 was the instruction utili:ed by Bechtel QC when monitoring :he activities of other inspeccion agencies that were providing :he first level inspeccions of back-fill operations (:his instruction was utili:ed during time periods prior to Cc:ober 18, 1976).

c. Bechtel Quality Control >bs:er Inspectien Plan for Structural

' Backfill Placement - So. C-211-1 is an ins: rue:icn utilized by Bechtel QC when performing first level inspection of backfill activities prior :o October 13, 1976.

3echtel Precedure C-1.02, listed above, was wri: ten as a replacement for both Procedures C-210-4 and C-2ti-1. The inspection acrivities which were delineated in Procedures C-2!0-4 and C-211-1 were compared with those described in Procedure C-1.02. The following are some of those activitics which were compared:

Inspec: ion Code for--

f'~'s, C-210 C-2LI-l C-1.02 ig / Activities / Task Descriotion Backfilt Material

(*) 1. Free of brush, roots, sed, I S(V) snow, ice or frozen soil.

(*) 2. Material =oisture conditioned S I S(V)

o required moisture content.

3. Strue: ural backfill used . I with 3" of plant strue:ure, shall be cohesionless and free-draining.

1 S (b*)

(*)

a. Sb:erial not placed upon I l frozen surface.

Founda: ion approved price :o H H R'M 5.

backfill placement.

6. Prior to 3:ar: of work, area (V) free of debris, : cash and unsuitable material.

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Cc=caction Recuirements

1. Cohesionless material com- 5 S S(V) pacted not less than 80%

relative danilty.

(*) 2. Cohesive material compacted W S S(v) to not less than 95% max.

density.

(*) 3. Zone: 1, LA, 2 and 3 material W I S(v) in uncompac:ed lifts not ex-ceeding 12"; areas not access-ible to roller equipment the material placed in uncompacted lifts no exceeding 4".

1 Material Testing

1. Verify testing and test results are.as per engineering requirements.

a. >bterials S S 5(V)

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b. Moisture S S S(V)

c. Compaction S S S(V)

2. Review lab test report verifying:

Proper ec.st method. R R

a. R

b. Proper test frequency. R R R

' c. Technical adequacy. . R R R I - Inspecti:n poin:

M - Hold poin W - Wi: ness point S - Surveillance (V) - visual R - Review records Those ac:ivities identified by an (*) as:erisk indica:e inspec: ion require-men:s which have been relaxed from the cri:inal precedural require.r.en:s.

It is :ensidered tha: :he relaxation of ac: ions rela: tag :c :he c:cfir-ma:Lon that s:ils placement activi:ies were conducted ac: rding to n

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specifications contributed to inadequate coepaction of foundation and fill material and the increase incidence of deviations from specifications regarding lift thickness, moisture control and frequency of testing.

This failure to provide adequate inspection of activities affecting quality

'4' is cons ~1dered an item of noncompliance with 10 CFR 50, Appendix 3, Criterion X. (3;9/75-20-10; 330/70-20-10)

Exit Meetings Members of the MRC staff met with Consumers Power Company and 3echtel Corpora: ion at the NRC Region III of fice on February 23, 1979 to present the scope, purpose, and oreliminary findings of.the investigation. That meeting was subsequently followed by a second meeting held on March 5, 1979, during which Consumers Power Company responded to the preliminary investigation findings. The documents used during these meetings were transmitted to Consumers Power Company by MRC letter dated March 15, 1979.

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<I8 o NUCLEAR REGULATORY COMMISSION REGION lit I/

g7)[f 799 ROOSEVELT ROAD o L E N E L LYN, IL LINotS Go13, ATTACHMENT 3 V

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l I Docket No. 50-329 T,vcKet No. 50-330 i

Consumers Power Company ATTN: Mr. James W. Cook i

Vice President Hidland Project f i 1945 West Parnall Road i Jackson, MI 49201 Centlemen:

l This refers to a special announced inspection conducted by Messrs. E. J. Gallagher and R. B. Landsman of this office and Mr. J. W. Gilray of the Office of Nucicar Reactor Regulation, Quality l

Assurance Branch on December 8-11, 1980, of activities at the Midland l Nuclear Power Plant, Units 1 and 2, authorized by h7C Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with you

fD and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during

.the inspection. The inspection consisted of a review of the Consumers Power Company response and implementation of corrective actions regarding the 10 CFR 50.54(f), Question 1 of NRC letter dated March 21, 1979 and Question 23, request for additional information dated September 11, 1979.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as described in the enclosed Appendir A, l

and a written response is required.

In addition to the above, the unresolved items described in Paragraph 3(c) and 3(d) requires your attention. Please provide c written response to each individual part of the unresolved items for our review along with your i response to the identified items of noncompliance.

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, the enclosures, and your response to this letter will be placed in the NRC's Public Document l

Room, except as follows. If the enclosures contain information that you or l

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your contractors believe to be proprietary,-you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure. The application must include a full statement of the-reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, James G. Keppler Director

Enclosures:

1. Appendix A, Notice of Violation

2. IE Inspection Reports No. 50-329/80-32 and No. 50-330/80-33

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Central Files Reproduction Unit NRC.20b PDR Local PDR NSIC TIC l Ronald Callen, Michigan I

Public Service Commission Myron M. Cherry l

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3 gfendix A '

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NOTICE OF VIOLATION Consumers Power Co. Docket No. 50-329 Docket No. 50-330 As a result of the inspection conducted on December 8 - 11, 1980, and in accordance with the Interim Enforcement-Policy, 45 FR 66754 '

(October 7,1980),- the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion XVI states, in part, that " Measures shall be established to assure ,that conditions adverse to quality such as. . . deficiencies. . .a re promptly . . . corrected. The measures shall assure that the cause...is determined and corrective action taken to preclude repetition."

Consumers Power Co. QA Program, Policy No.16, corrective action states, '

in part, that " corrective action is that action taken to correct and pre-clude recurrence of significant recurrence of significant conditions adverse to the quality of items. . . Conditions or trends observed or identified which are adverse to quality are considered for corrective action..."

h Tle "FSAR Re-review Procedure" instructions for Block 8 requires that "t he engineering design documents against which the FSAR review package

is to be reviewed are listed by the primary review engineer."

CPCO Audit No. M-01-53-0 states, in part, "the following significant items were revealed by this audit...in many instances not all of the design documents were listed as required by the instructions for per-forming the re-review."

Contrary to the above, CPCO did not initiate preventive action to pre-clude repetition of not identifying design documents for the remaining re-review packages as evidenced by the inspectors review of other Fr.AR re-review packages which did not include all of the design documents.

In addition, interviews with some of the primary reviewers indicated that they were not reviewing the FSAR for technical accuracy against references at the end of the FSAR chapter as required by the procedure.

Based on the above, the adequacy of the FSAR re-review is in question.

This.is a Severity Level IV violation (Supplement II).

l 2. 10 CFR 50, Appendix B, Criteria III, states, in part, that " Measures shall be established to assure that... design bases ...are correctly translated into specifications. . .and for the identification and control i of design interfaces...these measures shall include the establishment i

O of procedures. ..for the review of documents involving design interfaces."

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Consumers Power Co. QA Program, Policy No. 3 states, in part that "Each group.. performing detailed design translates the applicable regulatory requirements... design criteria into design documents, such as specifica-tions... procedures. The design organization... establishes and controls the interface with other-design organizations.

a. Bechtel EDPI 4.25-1, Section 6.1, states, in part "Each originating design group shall maintain a log of all documents which are routed to personnel external to the design group. These logs shall be re-tained.. .providing visibility of the projects design interface control.

Contrary to the above, Bechtel Civil Project Engineering group did not maintain a coordination log of specification and specification

. change notices as evidenced by our review of soils related specifica-tions C-211 and C-210.

b. ANSI N45.2.11, Paragraph 4.1 requires that applicable design inputs are correctly translated into specifications drawings, procedures or

. Instructions. In addition, Paragraph 7.0 requires that documents including changes are reviewed for adequacy.

Consumers Power Co. 's 50.54(f) response, Page I-17, Paragraph 4(a) required that specification change notice (SCN)-9004 be issued to.

h) require a laboratory compaction test to be performed for each field density test. SCN-9004 was initiated on 4/13/79.

V Contrary to the above, Revision 16, dated 8/24/79, to the present Revision 20 of specification C-208 did not correctly translate l SCN-9004 as a requirement into the specification. Revision 16 permitted laboratory density tests to be performed at a frequency as determined by the geotechnical engineer rather than for each field density test performed.

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c. ANSI N45.2.11, Paragraph 8.2 requires that design changes be reviewed and approved by the same groups or organizations which reviewed and approved the original design documents.

Consumers Power Co. 50.54(f) response, Page 23-11 committed to revise existing design control measures and require design interfaces on s design changes. EDPI 4.25.1, Revision 7 added Section 4.2 which states, "It is the responsibility of the originator of a design change to effect -

coordination of the change with all groups which reviewed and/or used the original or subsequent revisions of that design document."

Contrary to the above, Revision 8 to EDPI 4.25.1 permits the group

! supervisor to waive the design interface requirement by adding to Section 4.2, "as determined by the group supervisor of the discipline which originated the document." Revision 8 does not establish adequate measures as required by ANSI N45.2.11 or as committed per 50.54(f)

/] response.

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This is a Severity Level IV violation (Supplement II).

Pursuant to the provisions'of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) correc-tive' action taken and the results achieved; (2) corrective action to be taken to' avoid further noncompliance; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.

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O U.S. NUCLEAR REGULATORY COMMISSION V 0FFICE OF INSPECTION AND ENFORCEMENT REGION III Reports No. 50-329/80-32; 50-330/80-33 _

Docket Nos. 50-329; 50-330 ' Licenses No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Inspection At: Bechtel Power Co., Ann Arbor, Michigan Inspection Conducted: December 8-11, 1980 t

Inspectors: E. . Gal g r, Region III

! OI 4 Landsman,RegionIII R. B b I'Il J. G1 y b Qua ity Assurance Branch /' 7' f /

Reviewed By: R. C. pnop, Chief & 7 P/

f Projects Section No. 1 Approved By: G.' Fiorelli, Chief l Reactor Construction and Engineering Support Branch Inspection Summary Inspection on December 8-11, 1980 (Reports No. 50-329/80-32; 50-330/80-33)

Areas Inspected: Consumers Power Company response and implementation of corrective actions regarding the 10 CFR 50.54(f) request of Question 1 of i

NRC letter dated March 21, 1979 and Question 23, request for additional

! information dated September 11, 1979. The inspection involved 106 inspector-bours at the Bechtel Ann Arbor office by three NRC staff. In addition, approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of review of the licensee response was performed prior to the inspection.

Results: Two items of noncompliance were identified in the above areas

! inspected - Severity Level IV, Inadequate Design Control with three examples; I Severity Level IV, Inadequate Corrective Action; and Unresolved Items identified l in Paragraph 3(c) and 3(d).

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Exit Meeting A 3tendees at Ann Arbor, Michigan, December 11, 1980 Nuclear Regulatory Commission E. J. Gallagher, Civil Engineer' Inspector, IE: Region III R. B. Landsman, Civil Engineer Inspector, IE: Region III J. W. Gilray, Quality Assurance Branch, NRR Consumers Power Company J. W. Cook, Vice President,~ Projects, Engineering and Construction B. W. Marguglio, Director, Environmental Services and Quality Assurance W. R. Bird, Quality Assurance Manager, Midland Project D. M. Turnbull, Site Quality Assurance Superintendent G. R. Eagle, Supervising Quality Assurance Engineer G. S. Keeley, Midland Project Manager G. E. Clyde, Licensing Engineer H, P. Leonard, Section Head, Quality Assurance Engineer D. E. Horn, Group Civil Supervisor, Quality Assurance Engineer Bechtel, Ann Arbor Office 1

i

,3 J. Rutgers, Midland Project Manager l

i [d i J. Milandin, Manager of Quality Assurance L. A. Dreisbach, Assistant Project Manager V. J. Manta, Project Quality Engineer N. Swanberg, Assistant Project Engineer G. L. Richardson, Quality Assurance Manager, Midland Project D. F. Lewis, Licensing Engineer R. E. Sevo, Quality Assurance Engineer A. E. Bico, Quality Assurance Engineer j R. L. Rixford, Quality Assurance Engineer l

J. R. McBride, Quality Engineer R. C. Hollar, Quality Engineer

1. Background Meetings were held on February 23, 1979 and March 5, 1979 at the NRC Region III office in Glen Ellyn, Illinois to discuss the circumstances associated with the settlement e,f the diesel generator building at the Midland facility. This discussion uas part of the investigation conducted by Region III as documented in NRC Invetsigation Report No. 50-329/78-20; 50-330/78-20, dated March 22, 19/9. Representatives i of the NRC staff from headquarters attended the meeting on March 5, L 1979. The staff stated that it's concern was not' limited to the

narrow scope of'the settlement of the diesel generator building, but

! extended'to various buildings, utilities and other structures located in and on the plar.t area fill. In addition, the staff exprer. sed p concern with the Consumers Power Company Quality. Assurance Program.

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Under the authority of Section 182 of the Atomic Energy Act of 1954,

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( ,j as amended, and Section 50.54(f) of 10 CFR Part 50, additional in-formation was requested regarding the adequacy of the fill and the quality assurance program for the Midland site in order for the Commission to determine whether enforcement action such as license modification, suspension or revocation should be taken. Question 1 of the 50.54(f) letter dated March 21, 1979 requested information regarding the quality assurance program. On April 24, 1979, Consumers Power Company submitted the initial response to the 50.54(f) request, Questions 1 through 22. As a result of the NRC staff review of Question 1, the NRC concluded that the information provided was not sufficient for a complete review. Subsequently, on September 11, 1979 the NRC issued a request.for additional quality assurance information (Question 23). On November 13, 1979, Consumers Power Company submitted revision 4 to the 50.54(f) responses which included response to Question

23. As a result of the Region III investigation report and CPC0 responses, the NRC issued an Order modifying construction Permits No. CPPR-81 and No. CPPR-82, dated December 6, 1979. The latest revision to Consumers Power Company response to the 50.54(f) request is revision 10, dated November 21,-1980.

2. Purpose of Inspection The inspection was conducted at the Bechtel Power Company Ann Arbor, Michigan offices on December 8-11, 1980 to verify implementation of the specific commitments and action items reflected in Consumers Power Company response to 10 CFR 50.54(f) Questions 1 and 23 with the exception

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of those areas where completion of commitments has not been satisfied as of this time.

The inspection was divided into the following areas:

a. A review of CPCo response to Question 1, Part (a) and Question 23, Part (1) regarding the identification of the specific quality assurance deficiencies that contributed to the soils problem, including the root cause of the deficiency, remedial action in the soils area, the programmatic and generic corrective actions as committed to in the response,

b. A review of CPCo response to Question 1, Part (b) and Question 23, Part (2) regarding the provisions to be implemented to preclude areas of contradictions between the PSAR, FSAR and design docu-ments.

c. A review of CPCo response to Question 1, Part (c) and Question 23, Part (3) regarding the programmatic and generic corrective actions to provide confidence that quality assurance deficiencies do not

-(or will not) exist in other areas.

The following sections of this report discuss the results of the review of the above areas of CPCo response to Questions 1 and 23.

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3. Review of Question 1, Part (a) and Question 23, Part (1)

The identification of quality assurance deficiencies that contributed to the soils problem was discussed in Question 1, Part (a) and Question 23, Part (1). Concumers Power Company identified the root cause of the deficiencies, the remedial measures in the soils area, and the programmatic and generic corrective action to preclude further recurrence of the deficiencies. CPCo complied a list of specific action items that would have to be accomplished in order to satisfy the commitments made in response to Questions 1 and 23 of the 50.54(f) request.

Attachment No. I provides an action item tracking system which includes the action item description and reference and the status and documenta-tion verified by the NRC during this inspection.

Those action items for which CPCo commitments have been accomplished are identified as being " closed"; items identified as "open" either have not been completed by CPCo or the action taken was considered insufficient.

Question 1 provided 26 action items of which the NRC verified 18 had been satisfactorily accomplished while 8 remain open. Question 23 provided 57 action items of which 34-were determined to be satisfac-torily accomplished while 23 remain open.

O The following are NRC findings regading the implementation of certain t, CPCo commitments.

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a. Action items 23-5 and 23-38 as identified in Attachment No. I provided commitments to examine current procedures and practices for the preparation and control of the FSAR in view of past experiences. CPCo committed to procedural changes to existing engineering department procedures.

Seven Bechtel procedures were examined and revised to clarify l design control procedures for the FSAR. Engineering Department Procedure Instruction (EDPI) 4.25.1, Design Interface Control, was revised by Revision 7 by including section 4.2 which states, "It is the responsibility of the originator of a design document change to effect coordination of the change with all groups which reviewed and/or used the original or subsequent revisions of that design document."

Subsequently, Revision 8 to EDPI 4.25.1, changes the above by adding to the end of the statement, "as determined by the group i supervisor of the discipline which originated the document." The originator of Revision 8 stated that the intent was that only technical changes have to be interfaced while editorial changes would not necessarily require this interface control. The pro-l cedural change, however, does not reflect the intent and permits l

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- lp the group supervisor to waive interface control for any changes Vl as evidenced by inspection finding in Paragraph 3(b) of this report. The engineering procedures EDPI 4.25.1 does not satisfy CPCo commitment made to the NRC in response to Question 23, subsection 3.3, page 11 and identified as action item 23-5 of Attachment No. 1.

This failure to provide adequate design interface control is considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation. (50-329/80-32-01; 50-330/

80-33-01).

b. Engineering Department Procedure Instruction, EDPI 4.25.1, Section 6.1 requires that, "each originating design group shall maintain a log of all documents which are routed to personnel external to the design group. These logs shall be retained . . .

providing visibility of the projects design interface control."

It was determined based on a review of specification C-208, Revision 20, Materials Testing Services, Section 9, Soils Testing and C-211, Revision 12, Technical Specification for Backfill, that the civil project engineering group is not maintaining a complete coordination log of specifications and specification change notices.

Interviews with cognizant Bechtel personnel indicated that it is up to the originator of the document to transmit the design docu-r ment to the coordinator clerk to log it in as being interfaced It was determined from reviewing the

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V with the appropriate groups.

interface log that the originator of the documents are act aware of this requirement and documents are not being interfaced with other design groups as required by the procedure. In addition, Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants and ANSI N.45.2.11-1974, Section 10 requires design interface records to be maintained.

l This failure to maintain design interface and coordinator control l is considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation. (50-329/80-32-02; 50-230/

80-33-02).

c. Specification C-208, Revision 10, Section 9 regarding soil testing requirements was reviewed for technical content. It was determined that the specification was not adequate as written. The following specific findings were identified.

l (1) CPCo was identified in Question 1, Appendix I, Page I-13, Paragraph A.4(a) that the subcontractors test procedures for soil testing service were inadequate; specifically, U. S. Testing procedures did not provide for developing and updating a family of proctor curves used to compare in-place l

field density tests to maximum laboratory standards. CPCo committed to the remedial action on Page I-17, Paragraph 4(a) i

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(/ a problem because each field density test will be accompanied by a separate laboratory standard compaction test which will provide a direct comparison." It was also stated that SCN-9004, dated April 13, 1979 was issued to require the above. I It was determined _ that SCN-9004 was issued as cossnitted; however, during Revision 16, dated August 24, 1979, of specification C-208, the civil project engineer failed to include the above requirement and instead revised Table 9-1 to permit the frequency of the laboratory test to be "as directed by the on-site geotechnical engineer" rather than for each field density test.

This does not comply with the commitment made in 50.54(f) response to Question 1. This occurred because adequate design interface controls had not been implemented as required by ANSI N 45.2.11.

There was no evidence that the geotechnical group had reviewed or approved the revision to the specification.

This failure to provide adequate design interface control is considered contrary to 10 CFR 50, Appendix B, Criterion III as described in the Notice of Violation. (50-329/80-32-03; 50-330/

80-33-03).

(2) Specification C-208, Section_9.1.1 should be reworded to (q) remove confusion which exists about the word " compaction".

U This section should read: Modified proctor tests on cohesive material shall be performed'in accordance with ASTM D 1557, Method D.

i (3) Section 9.1.3 (first paragraph) does not specifically indicate how ASTM D 1566 has been modified by t! SBR DES E-24.

In addition, why does the specification prohibit the use of

the nuclear density device for measuring in place field I density? This device is an industry accepted method with a standard ASTM designation.

(4) Section 9.1.3 (second paragraph) assumes a specific gravity of 2.75. The actual specific gravity should be known and used as is the industry practice.

(5) Section 9.1.3(c) should also include: if the results still plot to the right of the ZAV curve the test should be rejected and a new density test performed.

(6) Section 9.1.3(d) uses the phrase 101% compaction. This should read 101% of maximum proctor density. This section also permits the on-site geotechnical engineer "to evaluate" the results of tests that exceed 101% proctor density for cohesive material and O

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105% for cohesionless material. This section should include the ' qualitative acceptance criteria and/or instructions to be

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used for the basis of this evaluation.

The above' items 3(c) 2, 3, 4, 5 and 6 are considered unresolved items pending a review of CPCo response to each item. (50-329/

80-32-04; 50-330/80-33-04).

d. Specification C-211, Revision 12 regarding backfill work activities was reviewed for technical content. It was determined that the specification was not adequate as written. The following specific items were identified.

(1) Section 8.1 does not specify the type of material to be used

'beneath Category I, safety related structures. This should be included in this specification.

(2) Section 8.1.1 does not specify the type of material to be used around pipes and duct banks. The specification should specify or refer to appropriate instructions.

~(3) -Section'8.3.2.(third paragraph) states, "the uncompacted lift thickness of the backfill material shall be determined by the on-site'geotechnical soils engineer . . ." The on-site soils. engineer should not have to determine the lift p thickness when Attachment No. I to specification C-211 specifies the requirement for each type of equipment based

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on equipment qualification tests.

(4) Section 8.5.2 permits the use of rubber-tired rollers to compact structural backfill and sand. Attachment No. I to specification C-211 does not indicate rubber-tired rollers as having been qualified and rubber-tired rollers should not be used to compact structural backfill and sand.

The above items 3(d) 1, 2, 3 and 4 are considered unresolved items pending a review of CPCo response to each item. (50-329/80-32-05; 50-330/80-33-05).

4. Review of Question 1, Part (b) and Question 23, Part (2)

The provisions and the procedures to be implemented to preclude conflicts between PSAR, FSAR and design documents was discussed in response to Question 1, Part (b) and Question 23, Part (2). Consumers Power Company included in their response a procedure entitled, "FSAR Rereview Procedure" to be implemented to accomplish this commitment.

Action-items. 23-1, 23-44 and 23-44(a) as identified in Attachment No. 1 provided the commitments to be implemented to assure FSAR accuracy. The following are the NRC findings regarding the implementation of these Coumlitments .

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[ It.was determined that, in general, consultant reports were not attached Q to the FSAR. However, the complete. text of a consultant report prepared by Weston Geophysical Engineering Company was found as an attachment to the FSAR and included in the FSAR, as Appendix 2C. Therefore, the CPCo .

response which states, " Consultant reports were not attached to the FSAR, l but portions of consultant reports were extracted and incorporated into ,

the FSAR text itself" (re: Question 23, Page 23-7) is not correct. I CPCo also stated that the FSAR was rereviewed against design documents

-such as consultant reports for conflicts.

It was determined that -verification of portions of consultant reports incorporated into the FSAR have been adequately reflected in design  ;

documents has not been satisfactorily accomplished. FSAR Rereview Pro-cedure, Revision 1, dated March 13, 1980, Subsection 2.1.3 states that each FSAR section'should be carefully reviewed against design documents

. . . as a minimum, the following should be checked . . . references at i the end of the FSAR chapter. The procedure also requirec in Item 8 that engineering design documents against which the FSAR review package is to be reviewed are to be listed by the primary review engineer in .

Block 8 of the FSAR rereview form. A review of FSAR packages Nos. 9474, 9473, 9472, 9471, 9096, 9097 and 9098 indicates that no design documents other than a few drawings were identified and listed. Numerous reports were referenced throughout the FSAR text of these sections, however, they were not recorded as required in Block 8 as being reviewed for consistency with the FSAR text.

(,) An' interview with a Bechtel cognizant primary review engineer indi-cated that he physically checked the references to make sure that they agreed with.the FSAR text. Subsequently, after the NRC inspector found an apparent discrepancy between the FSAR text and one of the references, the Bechtel reviewer indicated'that he did not check the text of the references, but merely checked the reference for consistency of subject matter, i.e., title vs. sentence content not technical substance vs.

a FSAR statements. Another cognizant Bechtel primary review engineer indicated he could not check references in his section because he was not qualified to review the technical matter in this area. He indicated that he relied on the Bechtel Geotech group (the interface reviewer in Block 11) to verify the references. Discussions with a Geiotech reviewer indicated he did check reports for consistency with the FSAR, but did not list them in Block 8 as required.

After this was determined, the inspector was informed that a CPCo interim audit No. M-01-53-0, dated March 1980, identified the same problem concerning the lack of identifying design documents in Block 8 of the FSAR review form. At this time approximat'ely 600 of a total 'of 900 FSAR rereview packages had been completed. However, no corrective action was taken. CPCo final audit of this activity, audit No. M-03-202-0, dated November 1980, once again identified an

. unresolved item, URI-3, regarding this same problem. The FSAR rereview is now complete and the unresolved itesi was pending resolution as of the date of this inspection.

.g.

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1

/ Cognizant individuals indicated that.one of the reasons why documents 4 s were'not listed.in Block 8 was because there was not sufficient space.

An interview with the preparer of the FSAR rereview document indicated

'that the. intent of. Block.8,'and it's instructions,-was to list all of the design documents to which the FSAR section was, reviewed against in .

order to assure there were no'more conflicts between design documents  !

and the FSAR text. .._

Based on the-above, it was determined the CPCo failed to provide l

adequate corrective action with regard to the identified audit results.  !

This is considered contrary to 10 CFR 50, Appendix B, Criterion XVI, as described in the Notice of Violation. (50-329/80-32-06; 50-330/80-33-06).

Due to this finding, CPCo implementation of the specific commitment l as discussed in response to Question 23, Part (2) has not been accom- .l plished and the adequacy of the FSAR rereview which has been completed  !

is questionable. j J'

5. Review of Question'1, Part (c) and Question 23, Part (3)

CPCo and Bechtel'have performed a detailed re-review of specifications, installations, and construction inspection plans, procurement documents, inspection.and test procedures,: including the results of inspections and tests to determine the completeness and accuracy of documents and the acceptability of hardware. In this regard, the IE inspection activities involved ~a review and evaluation of activities associated

/'Y' with'the above re-review actions and included discussions with main participants in the re-review effort. The following is a summary of this inspection.

a. .CPCo and Bechtel were able to demonstrate that an extensive

- re-review of specification,--inspections and test procedures, and documents associated with procurements were conducted with mean-ingful results. The. documents were evaluated by CPCo and Bechtel l to assure that the necessary tolerance call outs and quality l requirements were specified; that the qualification requirements were adequately called out and met; that there were sufficient specificity provided in the documents; and that there were the necessary inspection requirements specified. In addition, the completed documentation was evaluated to determine that technical i and quality requirements were met in an acceptable manner.

Areas that were found deficient resulted in revision and improve-ment to procedural controls and specifications. Hardware suspected {

of not meeting quality requirements were re-evaluated by engineering

,{

l and quality assurance to determine their accept, repair, or reject

!= status. .

Throughout this particular IE inspection effort, specifications, procedures, and instructions were reviewed and a determination t made that revisions and improvements were accomplished.  !

U.

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1 l

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' V) b.

The improved trend analysis and corrective action program estab-lished by CPCo and Bechtel was evaluated and found acceptable.

. 1 It is expected that this program will prove effective in detecting major weaknesses in the early stages such that meaningful, prompt corrective actions can be initiated during the design and construction phase.

c. The " flag program," w'hich provides assurance that problems, similar to those experienced with reactor vessels holddown anchor bolts, do not exist in other similar procurement actions where in process source inspection activities are involved, was evaluated. Purchase orders and receiving documentation were reviewed by Bechtel to determine that critical design.and specification requirements were properly carried out and where questions were raised concerning product function, a " flag" was identified to the concern requiring further evaluation, discussions, and resolution by engineering and quality assurance. Evidence showed this activity to be productive and in accordance with documented instructions,

d. The 1978 and 1980 independent audit results performed by the Management Analysis Corporation on CPCo and Bechtel were evaluated

.and found in accordance with program requirements.

Overall, the personnel contacted conveyed their QA knowledge and their sincerity and dedication towards performing the activities l p\ described above. However, as a result of the findings identified

' i during this inspection, it is clear that more emphasis must be V placed on the attention to detail in the preparation and review of documents. In order to accompl'ish this, upper management must play a more active role in conveying this principle to the working staf f and observing attitudes and activities to assure QA principles and attention to detail are being properly carried out.

Unresolved Item Unresolved items disclosed during the inspection are discussed in Para-graph 3(c) and 3(d) of the report.

Exit Meeting l

The inspector met with licensee and contractor representatives at the conclusion of the inspection on December 11, 1980 and summarized the inspection scope and findings. The items of noncompliance identified during the inspection were discussed in detail. The licensee acknowl-edged the inspection results.

Attachment:

Attachment No. 1

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ATTACllMENT t 1

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ACTION ITEMS PROGRAMMATIC AND GENERIC CORRECTIVE ACTIONS COMMITTED TO IN Tile RESPONSE TO QUESTION 1, PART (a)

• AND IN Ti!E RESPONSE TO QUESTION 23, PARTS (1) AND.(2).

' Action Action Item Item Description . Actions Verified

~

Number and Reference (Status) buring NRC Inspection 23-1 Consultant reports other than Dames & Moore were considered in accordance with the guidelines provided in NRC Regulatory Guide -1. 70, Revision

2. Consultant reports were not attached to the FSAR, but portions of consultant reports were extracted and incorporated into the FSAR text i

itself. Those portions incorporated into the FSAR become commitments. Therefore, disposition

of recommendations in consulting reports has been adequately accounted for in the prepara-l tion of the FSAR.

Verification that those portions of consultant (open) Refer to Action Item 44 for Review of reports determined to be commitments and incor- FSAR Re-review porated into the PSAR have been adequately reflected in project design documents' is being

, accomplished via the FSAR rereview program .

described in the response to Question 23,

]

Part (2).

i -_________________________

23-1(a) The two Bechtel QA audit findings reported in (Closed) Reviewed quality assurance audit 4.0-and our April 24, 1979, response (Paragraph D.1, special 1, "SAR change control", & audit findings 1 - 11 Page I-8) have been closed out. The results A-34 & A-35. The audit was performed to assure of this audit are being utilized in the PSAR that there is a system to assure design changes

, . control system study committed to in Subsection are reflected in the FSAR. Audit findings ident-3.3 of this response to Part (1). ified cases where design changes were not reflected in the FSAR. Corrective action resulted in a

' (Question 1, Appendix I, Section D.1, Page I-8 review of all design requirement verification Question 23, Subsection 3.1, Page 7) checklists (DRVCL's) for groups identified with problems. This review is documented in QE i

monitoring report DRVC-8.

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Action Action Item ~

Item Description .

Number and Reference' . (Status) _

23- 2 On April 3, 1979, Midland Project Engineering (Closed) Reviewed & verified memos & letters Group Supervisors in all disciplines were instructing proj. engr. field eng, 6 QC of pro-reinstructed that the only procedurally cedure for implementing clarification or change correct methods of implementing ' specification to approved drawings or specifications:

changes are through the use of specification (1) Bechtel memo to QCE's, dtd 5/30/79.

l revisions or Specification Change Notices. This (2) Bechtel memo to Field Engr's, dtd 3/28/79.

' was followed by an interoffice memorandum from (3) CPCo letter to Bechtel, dtd 3/12/79.

q the Project Engineer to all. Engineering Croup (4) Bechtel memo to Proj. Engr, dtd 3/21/79.

Supervisors on April 12, 1979. (5) Bechtel memo to Group Suprv, dtd 3/12/79.

(6) Bechtel letter to CPCo, dtd 6/5/79.

(Question 23, Subsection 3.2, Page 8; and Subsection 3.9, Page 24 )

23-3 Engineering Department Project Instruction (Closed) Reviewed & verifi d EDPI 4.49.1, Rev. 4, and 4.49.1 was revised in Revision'2 to state, " specification change notice # to include require-1 - 12 "Under no circumstances will interoffice ment that ICM's, memo's, telex's, 1WS's, etc. can memoranda, memoranda, telexes, 'IWXs , etc not be used to change spec. requirements. A spec.

be used to change the requirements of a change notice must be issued in order to change

-specification." spec. requirements.

(Question 1,-Appendix I, Section 0.2.d, Page I-8

} Question 23, subsection 3.2, Page 9, and Subsection 3.9, Page 24) 1 i

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• I te.n Description Number and Heference (Status) 23-4 A review of interof fice memoranda, memoranda, telexes, "IvX s , and other correspondence relating to specifications for construction and selected .-

procurements of 0-listed items will be' initiated.

The purpose of the review will be to identify' any clarifications which might reasonably.have been interpreted as modifying a specification ,

requirement and for which the~ specification itself was not formally changed. An. evaluation will be made to determine the effect on the technical acceptability, safety implications ,

of the-potential specification modification, and any work that has been or may be affected.

If it is determined that the interpretation may have af fected any completed work or future work, a formal change will be issued and remedial action necessary for product quality will be taken in accordance with approved procedures.

The foregoing procedure will be folldwed for all (closed) Verified Bechtel memo dated 12/20/79 specifications applying to construction of (File 0455) which.provides the procedure for 0-Listed items.

review of all (100%) Q-listed construction type spec's. and sampling plan procedure for procurement For specifications concerning the procurement type spec's.

of 0-Listed items, the foregoing procedure will be implemented on a random sampling basis.

The sample size has been established and the specification selection has been made.

(21) Review and acceptance criteria for the specifi- (Open) ca tions have been def ined. Review criteria has been established-(see above action item 4); acceptance criteria was not (47) The review of construction and selected defined. Audit report H01-200-0 also Identified procurement specifications is scheduled to be this as an unresolved item.

completed by April 1, 1981. (Open)

File had no review data for construction type or procurement type spec's.

. - - - - - - - . - - - . . - - -a----n. - - - - - - - - - . - - - -- -- - -- - - - - . . . - - - - - - - - . . . . - - - - . - - . -

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( ^'ht 4 of.21' Action Item

(

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Action Item Description

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( /g1 Number and Reference (Status)

(47) If the acceptance criteria are not me t, the (0 pen) Preliminary indication per Bechtel (cont'd) review will be expanded to include other Representative indicated that the review will specifica tions for Q-listed items. At that be required to be expanded to include other time, a revised completion date will be spec's than sampling plan identified.

established.

(Question 23, subsection 3.2, Page 9, and Subsection 3.9, Page 25) 23-5 A study was completed which examined current (23-33) procedures and practices for the preparation and control of the FSAR in view of these experiences. Procedural changes have been initiated by the revision of or addition to the Engineering Department Procedures. i

. (Question 23, subsection 3.3, Page 11)

+

23 4 An interoffice memorandum dated April 12, 1979, (Closed) Reviewed & verified inter-office memo was issued by Geotechnical Services to alert from S. Blue to Geotech personnel, dated 4/12/79 personnel of the need to revise or annotate which requires that changes in design be reflected calculations to reflect current design Status. in the original calculations & to reflect proper interdepartmental coordination has been achieved.

(Question 23, Subsection 3.4, Page 13) s 23-7 Pield Instruction FIC 1.100, "0-Listed Soils (Closed) Reviewed'& verified, field instruction Placement Job Responsibilities Matrix ," has been FIC1.100, Rev. 3, dated 8/15/80 to include daily prepared and establishes responsibilities for job responsibilities of the onsite geotechnical performing soils placement and compaction. engineer.

(Ouestion 23, Subsection 3.6, Page 18; Subsection 3.7, Page 20; and subsection 3.11, Page 30) 4

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' Action-Q . Action Item 3 1/5sj ,

i. Item Description ,

?-

. Number and Reference ~ (Status) e

~

. 23-7A- Review Field Procedure FPG-3.000 to. ensure (Closed)' Verified that FPC-3,000, Rev. O, Job j and clarity and completeness responsibilities for field engineers'was reviewed j 1 - 17

~

as a result of this review FIC 1.100," Job responsi--

1 (Question 1, Appendix'I, Section 0. 2, ~ Page I-ll) bilities for the onsite geotechnical engineer"was j established. ,, ,

[ 23-8 and Construction specifications,-instructions, and procedures were reviewed to identify any other (Open) CPCo commitment not completed.

j

1 - 16 equipment requiring qualification which had not

-yet been qualified. No such equipment was. .

j identified.

s I (Question 1, Appendix I,_Section D.1, Page I-ll-j Ouestion 23, Subsection 3.6, Page 18) 1 .

i l

23-9 A dimensional tolerance study was completed (closed) Verified that dimensional tolerance j using the reactor building spray _ pump.and study was performed on the reactor building spray

pump system.

ancillary system as the study mechanism.

] (Question 1, Appendix I, Section'D.2.b, Page I-8) j .

5 23-1 0 . Engineering reviewed specifications _not previously (Cinsed) verified that a review of spec's A-17 j and reviewed for the specificity'or tolerance studies. C-67, M-342, C-208, C-231 & A-41 was performed i 1-5 for specificity & tolerances. Revisions were

! (Question 1, Appendix I, Section D.2.c, Page I-8 ) made to spec. as needed.

23-11 A specific review of the FSAR and specification (Closed) Verified a review of FSAR & Spec 1 requirements for the qualification of electrical requirements for qualification of electrical l

! and mechanical components has been made as part and mechanical components has been performed 1

of the corrective action relating to CPCo's & documented in CPCO letter to NRC, Region III 50.55(e) report on component qualification. g dated December 5, 1980, as required by 50.55(e) reporting requirements.

{ _(Ouestion 1, Appendix I, Section D.2.e, Page I-8) 1 1 23-12 Ouality Assurance will schedule yearly audits of (Open) CPCo commitment not completed.

, the design calculational process for techniques

and actual analysis in each of the design disci-

! plines.

l (Ouestion '

, Appendix I, Section D.4, Page I-8) t i

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1/5/81 (

Action Action Item .

Item Description ,

Number and Reference (Status)-

• 23-13 Audits of ITT Grinnell hanger design and CPCo (Closed) Verified that audit OT-ITT Crinnel relay setting calculation have been conducted. (April 5, 1979) and audit of electrical and I6C a

(Question 1, Appendix I, Section D.4, Page I-8) 23- 14 Bechtel Project Engineering will review design (Closed) Reviewed file No. 54601-54618 i and drawings for cases where ducts penetrate (calc #41-1) dated 9/5/78 which identifies each 1 - 10 vertically through foundations. The possibility duct bank in the plant and interface with any of the duct being enlarged over the design buildings. Results of study were documented in a

recuirements and the effect this enlargement memo from L. Curtis to R. Rixford dated 5/27/80 may have upon the structure's behavior will be which indicates no other safety-related structure evaluated by June 1, 1979. Proper remedial except D. C. Bldg was ef fected by an interface 4

measures will be taken if the investigation with duct banks. Provisions were made to allow shows. potential problems. independent vertical movement between the diesel generator bldg and duct banks.

(Question 1, Appendix I, Section C.5.b, Page I-7) 23-1 5 An in-depth audit of U.S. Testing operations, (Closed) Reviewed and verified audit 25-2-7 of and covering testing and implementation of their U.S. Testing Company was performed on April 25-26,

+

1 - 20 OA program will be conducted in late April or 1979.

carly May 1979, by Bechtel Project QA and

. Engineering. ,,

(Ouestion 1, Appendix I, Section C.4.b, Page I-18; Section D.3.c, Page I-18) 23-1 6 An in-depth training session will be given to (open) See review of Action Item 23-17 l and tiidland OA Engineers covering the settlement 1 - 25 problem and methods to identify similar

,! conditions in the future.

(Ouestion 1, Appendix I, Section D.l.b, Page I-22) 4 i

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i Action Action Item

• Item Description ' *'

l . Number and Reference (Status) 23-17 An in-depth training' session will be given to ' (0 pen) '. Reviewed IOM dated July'27, 1979 and l and - all CPCo and Bechtel OA Engineers and Auditors June 4, 1979-documenting training to CPCo and 1 - 25 to increase-- their awareness of the settlement Bechtel QA personnel on Midland plant fill) problem and to discuss auditing and monitoring experiences. The file -does not contain docu .

] techniques to increase audit effectiveness. mentation of the contents or detail of the

training nor any material handed out to parti- ,

(Question 1, Appendix 1, Section D.2, Page I-22) cipants for)their future reference.

4 18 An in-depth review of the Bechtel trend (Open) CPCo commitment not completed.

and program data will be Unha. token by Bechtel OA l

1 - 24 management to ensure the identification of j any other similar areas that were not analyzed in sufficient depth,in the past reviews. i i

i (Question 1,-Appendix I, Section D.l.a, Page I-22)

}

l 23-19 Ouality Control Instructions have been evaluated and (Closed) verified the QCI's were reviewed and

' to ensure that the documentation characteristics items requiring further action and resolution 1 - 21 which are to be inspected (i.e., surveillance and identified (See Action Item 23-19A).

I 1 - 22 review callouts) are clearly specified.

i l 23-19 A and (This action modified to include necessary revi- -(Open) Completion of required changes to QCI's

sion to OCIs resulting from evaluation of surveil- ~

per Action Item 23-19 have not been completed.

1 1 - 21A lance and review callouts.)

(Oues tion 1, Appendix I, Section D.3.a, Page I-18 j and Section D.1, Page I-18) ~

23-20 Field Instruction 1.100 has been supplemented (Open) CPCo cc.amitment- not completed. Records

by establishing requirements for demonstrating identifying equip. capability not documented in

equipment capability, including responsibility Action Item file.

for equipment approval, and providing records

{ identifying this capability.

l (Question 23, Subsection 3.6, Page 18)

! 23-21 See Action Item Number 4 (21) (open) Acceptance criteria not defined (See

. Action Item 4 for review).

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Action ,

Item Description _

Number and Reference (Status) -

23-2 2 Guidelines for surveillance of- testing operations (Closed) Responsibilities for on-site have been developed and included in Field In- Geotechnical Engineer have been established per structions for -the onsite Soils Engineer. FIC 1.100, Rev. 3 which include requirements.

Engineering /Geotechnical Services has developed the guidelines. ,,

(Question 23, subsection 3.10, Page 27) 23-23 Engineering has revised Engineering Depart- (Closed) Verified EDP 4.22 has been revised by and ment Procedure 4.22 to clarify that Engineering issuance of MED 4.22, Rev. 6 to include Regulatory 1-3 personnel preparing the PSAR will follow the Guide 1.70 which renuires consultant' reports to requirements of Regulatory Guide 1.70, Revision 2, be referred with specific commitments included in

" Standard Format and Content of Safety Analysis text of the FSAR.

Reports for Nuclear Power Plants" (September '1975) .

Specifically, Regulatory Guide 1.70 (Pages iv and v of the Introduction) requires that such consul-tant reports only be referenced with the applicable commitments and supporting informa-i tion included in the test (third paragraph, Page v). Such a requirement precludes repetition i of this circumstance. -

+ .

(Ouestion 23, Subsection 3.1,'Page 7 and Subsection 3.3d, Page 46) i tt 23-24 To preclude any future inconsistencies between (closed) Verified EDP 4.1.1, Rev. 2, Preparation the PSAR and specifications, Engineering Depart- of the design requirement verification checklist','

ment Project Instruction 4.1.1 has been revised Para. 3.1 requires the discipline engineer who i to state that all specification changes, rather originates a design change document to fill out than just " major changes," will be reviewed for a DRVC as the change is developed. The DRVC consistency with the FSAR. include verification of consistency with the FSAR for design changes.

(Ouestion 23, Subsection 3.3, Page 11)

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Action Action 1 tem

• Item Description Number and Reference (Status) 23-25 Ouality Assurance has issued a Nuclear Quali ty (closed) Quality Assurance policy.Section II, Assurance-Manual amendment to clarify.the No. 2." design control procedures 7 Para. 3.1.4, requirement that procedures include measures for Rev. 2B states, engin*e'ering department procedure qualifying equipment under specified conditions. shall include criteria for specifying equip.

qualification requirements. Also construction (Ouestion 23, subsection 3.6, .Page 18) quality program,Section IV, No. 1 Rev. 2B 23-26 Para. 3.2.3(P) requires instructions for quali-'

In view of Action Item 6, Geotechnical Services fications of equip.

has revised Procedure FP-6437 to require that *

calculations be annotated tu reflect current .

(closed) Reviewed and verified procedure design status.

FP-6437-A2 was issued (See ref. letter from (Ouestion 23, S*1bsection 3.4; Page 13) S. Blue to R. Rixford dated 4/10/80).

23-27 Engineering Department Procedure 4.37 has also (closed) Verified procedure MED 4.37,'Rev. 11, 1 been revised to require that calculations be annotated to reflect current design status.

" Design Calculation"and EDPI 4.25.1, Rev. 7

" Design Interf ace Controlwas issued to require the f

originator of a design change to notify all groups (Question 23, Subsection 3.4, Page 13) which used the original design document and to 23-28 Civil / Structural Design Criteria 72202C-501 check the latest design. info prior to revising has been modified to contain the requirements calculations.

that a duct bank penetration shall be designed to eliminate the possibility of the nonspecif1 (Closed) Verified civil design criteria C-501, size duct interacting with the structures. Rev. II, Para. 6.6 has been added which states,

,,All interfaces between bldg's or foundations and (Ouestion 23, Subsection 3.5, Page 15) duct banks designed after Jan. 1, 1980 shall be included on civil design drawings and shall indi-i 23-29 The civil standa rd de tail drawings have been cate clearances or const. restrictions as required f

t revised to include a detail showing horizontal to account for differential settlement, seismic and vertical clearance requirements for duct m vement, etc.

bank penetrations. The detail addresses any mud mal restrictions. (Closed) Verified civil standards and misc.

concrete details, sheet 2, dwg C-141, Rev. 6 (Ouestion 23, subsection 3.5, Page 15) detail 12 provides duct bank clearance criteria.

T

. Sheet

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Action Action Item Item Description i Number and Reference (Status) --

23-30 Engineering clarified specifications and (closed) Verified spec C-211, Rev. 12 (39) Construction prepared' procedures (governing _

Para. 8.5.1 (compaction equipment) now requires the soils compaction equipment) to-implement proposed compaction equipment.to be qualified to the requirements of the Nuclear Quality Assurance demonstrate compaction can be achieved at'a Manual as stated in Action Item 25.

i specified lift thickness, number of' passes, speed (Question 23, Subsection 3.6, Page 18) of equipment and~f Nguency of vibration for vibrating equip.

23-31 Design documents, instructions, and procedures i for those activities requiring inprocess controls (Open) CPCo commitment not completed.

have been reviewed to assess the adequacy of existing i procedural controls and technical direction.

Engineering review has been completed.

4 (Question 1, Appendix I, Section D.2, Page I-ll; and Question 23, Subsection 3.7, Page 20- and Subsection 3.11, Page 30)

23-32 Guidelines for surveillance of testing operations i have been developed and included in (closed) See Action Item 23-22.

! tions for the onsite Soils Engineer. field Instruc-/

Engineering

}

Geotechnical Services has developed the guidelines and Field Engineering has prepared the instructions.

j (Ouestion 23, Subsection 3.10, Page 27) i 23-33 The Quality Assurance audit and monitoring program will be revised to emphasize and increase attention (Open) CPCo commitment not completed.

i to the need for evaluating policy and . procedural adequacy and assessment of product quality. A specialized audi t training program will be developed and implemented to ensure guidance for this revised approach.

(Question 23, Subsection 3.13, Page 35) i I

~ ~ * - * -

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D Action Action Iteu Item Description Number and Reference (Statu )

23-34 Control Document SP/ PSP G-6.1 has been revised (Closed) Verified Procedure'C-6.1, Rev. 5 has and to provide requirements for inspection planning been revised to inclu,de requirements for planning, 1 - 23 specifici ty and for the utilization of scientific specificity (Para. 3.3.2) and utilization of

. sampling rather than percentage sampling. scientific sampling (Para. 3.3.3.a.8). This deleted surveillance type inspection and now (Ouestion 1, Appendix I, Section D.S.f, Page I-20: andequires inspection by witness or test.

~

Ques tion 23, Subsection 3.8, Page 22; Subsection 3.9, Page 24; Subsection 4.2.2, Page 59) a 23-35 Control Documents SP/ PSP G-3.2, " Control of (closed) Verified C-3.2, Rev. 6, Control of Nonconforming Items," and Nonconforming Item [ dnd QA'PP C-101"QA Trend 23-36 OADP C-101, " Project Ouality Assurance Trend Analysis"have been modified to provide for and Analysis" have been revised to provide an identifying repetitive nonconforming conditions.

1 - 24 improved definition of implementing require- Interviewed Mr. T. K. Subramanian.

1 - 25 ments for identifying repetitive nonconforming conditions.

(Question 23, Subsection 3.12, Page 33) 23-37 Consistent with the intent of Action item Numbers (0 pen) CPCo commitment not completed.

35 and 36, Quality Assurance will review noncon-formance reports which we re open as of November 13, 1979, or became open prior to implementation of the improved Project Ouality Assurance Trend Analysis program as stated in Action Item 36.

This review will be to identify any repetitive nonconfotning conditions pertaining to product type or activi ty, or pertaining to nonconformance cause.

(Ouestion 23, Subsection 3.12, Page 33) ,

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Action Action Item

• Item Description Number and Reference .( Status) 23-38 A study'was completed which examined current (Open) See Action Item 23-5

, (23-5) procedures and practices for the preparation and control of the FSAR in view of these experiences.

Procedural changes have been initiated by the revision of or addition to the Engineering Department Procedures.-

(Question 23, Subsection 3.3, Page 11) 4 l' 23-39 Engineering clarified specifications and (Closed) Verified FIC 1.100, Rev. 3 requires

(30) Construction prepared procedures (governing the soils compar

tion equipment) to implement on-site geotechnical engineer to ensure compaction the requirements of the Nuclear Quality Assurance equipment is qualified andilisted in the spec and Manual as stated in Action Item 25. can deliver required degree of compaction.

4 i

(Question 23, Subsection 3.6, Page 18) 23-40 Design documents, instructions, and procedures

' for those activities requiring inprocess controls (Open) CPCo commitment not completed.

will be reviewed to assess the adequacy of existing procedural cont'rols and technical i

(31) direction. Engineering review has been com-oleted, and Field Engineering and quality i control review is scheduled for completion .;

by February 27, 1981.

(Question 1, Appendix I, Section D.2, Page I-ll; Oues tion 23, Subsection 3.7, Page 20, and a

Subsection 3.11, Page 30) e 4

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-e Action Action Item

. Item Description Number and Reference (Status) 23-41 OCIs in use will be reviewed to ascertain that 4

(open) CPCo crmmitment not completed.

provisions have been included consistent with -:

J.

the revised control document, SP/ PSP G-6.1, ,,

j "Ouality Control Inspection Plans."

, (Ouestion 1, Appendix I, Section D.1, Page I-18;

. Ouestion 23, Subsection 3.8, Page 22;.and l Subsection 3.9, Page 24) 23-4 2 Design documents, instructions, and procedures (Open)' CPCo commitment not completed.

i for those activities requiring inprocess controls will be reviewed to assess the adequacy of i existing procedural controls.and technical

! (31) direction. -Engineering review has been completed,

{ (40) and Field Engineering and quality control review is scheduled for completion by f February 27, 1981. Any revisions required will j be completed by April 17, 1981.

l

(Ouestion 1, Appendix I, Section D.2, Page I-ll; '

j Ouestion 23, Subsection 3.7, Page 20; and i

' Subsection 3.11, Page 30) 23-43 The impact of Action I 11 on completed work (Open) CPCo commitment'not completed.

will be evaluated, and oppropriate actions will

{

1 be taken as necessary.

(Oues tion 23, Subsection ' 3.8, Page 22; and Subsection 3.9, Page 25) 23-44 FSAR sections have been rereviewed as discussed (Open) 9 re-review packages were reviewed

in the Response to Question 23, Part (2). by the NRC.

l Not all of the design documents were (Ouestion 23, subsection 3.1, Page 7: listed in Block 8 of required form per procedure i

subsection 3.3, Page.11; for performing review issued .3/13/80. This was

! Subsection 3.2, Page 41; and identified as an item of noncompliance as dis-

?

Section 4.0, Page 47) cussed in Paragra'ph'4 of this report.

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Item Description 4 Numbe r and Reference 4 23 44A The audit committed to in cor response to (0 pen) (1) CPCo Audit not completed & (2) i Question 1, Part b, and described in Part (2), Existing Audit findings (M01-53-0) not satis-r Section 5.0 was conducted once-during the factorily resolve; .i.e.,' inadequate corrective

] course of the PSAR tereview (commencing March 17, action. This item has been identified as an

1980) and again af ter completion of the rereview item of noncompliance as discussed in para-(commencing November = 3, 1980). graph 4 of this report.

j (Question 23, Part (2), Section 5.0, Page 48) 1 1

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h l' 1/5/(J O- 7'- G Action Action Item Item Description Nenber -

and Reference 23- 45 .U.S. Testing was required to demonstrate to (open) 'CPCo commitment not completed.

cognizant Engineering Representatives that ,,

testing procedures, equipment, and personnel used for quality verification testing (for other than NDE and soils) were capable of providing accurate test results in accordance with the requirements of applicable design documents.

(Ques tion 1, Appendix I, Section D.3.b, Page.I-18;_

- Question 23, Subsection 3.10, Page 27; and r Subsection 3.11, Page 31) 23,46 - A sampling of U.S. Testing's test reports ( for (open) CPCo commitment not completed.

other than NDE and soils)~were reviewed by coonizant Engineering Representatives to ascertain that results evidence conformance' to testing requirements and design document limits.

(Ouestion 23, subsection 3.10, Page 28.; and Subsection 3.11, Page 31) 23-47 See Action Item Number 4 (47) (Open) ' CPCo conunitment not completed.

23-48 CPC' performs overinspection for soils (closed) Verified CPCo overinspection plan.

placement, utilizing a specific overinspection 01-C-3A, Rev. I for soil placement and reviewed P l an. completed overinspection results performed on weekly basis.This overinspection program is an (Ouestion 1, Appendix I, Section C.2.b, Page I-ll; ongoing activity by Midland QA group.

Section C.l.c, Page I-16) 23-49 CPCo performs overinspection of the U.S. (Closed) Verified CPCo overinspection plan Testing soils testing activities and reports, 01-C-4A, Revision 3, for soil testing and utilizing a specific overinspection plan. review completed overinspections performed on U. S. Testing.

(Oues tion 1, Appendix I, Section C.3.c, Page I-17)

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Sheet 16 of 'j 1/5/81 4 e' i Action Action Item 4 Item Description Number and Reference 23-50 CPCo Project Management and QA review field (Closed) Verified CPCo reviews of field pro-

. procedures (new and revised) and CPCo OA reviews cedures and quality control instruction in -

QCIs (new and revised) in line with Bechtel before addition to Bechtel prior to release.

release.

(Question 1, Appendix I, Section D.S.b, Page I-19) 23-51 In 1978, CPCo implemented an overinspection plan (Closed) Verified CPCo has overinspection plans struction and the Bechtel inspection process, in the civil, electrical,~ mechanical, and with the exception of civil activities. Re- welding /NDE work activities.

^;

inforcing steel and embeds were covered in the 4 overinspection. i (Question 1, Appendix I, Section D.S.c, Page I-19) l 23-52 CPCo reviews onsite subcontractor QA manuals (Closed) Verified CPCo reviews subcontractor and covers their work in the audit process. QA manuals and audits subcontractor work.

!. (Question 1, Appendix I, Section D.S.d, Page I-19) 23 53 An ongoing ef fort is improving the " surveillance" (closed) Verified that SF/ PSP G-6.1, Rev. 5 j mode called for in the OCIs by causing more " procedure for Quality control inspection plans' specific accountability as to what character- have deleted surveillance method and new require-j istics are inspected on what specific hardware ments direct inspection'by witness or test to i and in some cases changing " surveillance" to be performed by Quality Control surveillance j " inspection.= method has been deleted in para 3.3.3.a.3 of i C-6.1, Rev. 5.

(Question 1, Appendix I, Section D.S.e, Page I-19) 4 k

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! Action Action Item

_ Item ' Description Number and Reference '(Status)

~

1-1 Perform a final review & update of PSAR commitment list. (Open) Action item not reviewed by NRC during-i the inspection.

4 1-2 Review sections of_FSAR determined to be inactive. (0 pen)'. See Action Item 23-44 for NRC review &

results.

j 1-3 Review EDP 4.22. (closed)' See Action Item 23-23 for NRC review.

1-4 Audit Action Items 1-3 (Open) See / Item 23-44A for NRC review &

results.

1-5 Review specifications not included in specificity (Closed) See A'c tion Item 23-10 for NRC review study initially. and results. i

, 1-6 Dames and Moore Report was reviewed and recommendations (Open) File indice.ted review was complete,

identified and dispositioned. however, no detaisa of the recommendations identified or the dispositions uere available.

1

} (Question 23, subsection 3.1, Page 23-6) i

! (Question 1, Apx, I, Page I-6, Para C.1.(b) l 1-7 Complete review of pertinent portions of FSAR sections (Closed) Verified FSAR, Revision 18 to have i 2.5 and 3.8. corrected: (1) inconsistency between FSAR 3.8.5.5 and 2.5.4, Figure 2.5-48, settlement values, (2) i Inconsistencies between FSAR subection 2.5.4. and Table 2.5-9 and Table 2.5-14 regarding soil type 4

3.8.5 have been corrected via FSAR Amendment 18 supporting structures from clay to (Zone 2) ,

j (Feb 28,1979) the same revision also corrected ramdom fill, (3) Table 2.5-16, index of compressi-i inconsistency between 2.5.4 and drawing C-45. bility factors to be determined from fill studies.

4 (4) Table 2.5-21 compaction requirements.

! (Question 23, subsection 3.3, Page 23-11)

! Reviews of Section 2.5.4. are on " Hold" until

! (Question 1, Apx I, Page I-6, Para 3) resolut*on of soils issue.NRC office of NRR l

Geotechnical Branch will review FSAR section

. when final.

1 4

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\s_,) Sheet 18 b _ f Action Action Item  !!' ,

. Item Description Number and Reference 1-8 Correct Settlement Calculations (Closed) Verified settlement calculations have been made subsequent to surcharge operations (RE:

Settlement calculations will be revised after calculation No. S-105 File 8230, dated February 14, completion of diesel generator building sur- 1980), results of these calculations have been charge operations. Included in response to question 27 of 50.54(f) requests. Review of this response and results (Question 23 Subsection 3.4, Para 23-13) of calculations are being made by NRC office of NRR Ceotechnical Branch.

(Question 1 Apx I, Page I-6, Para C.4.a) n-9 -Schedule audits of the Geotechnical Section on a six (Closed) Review audits of Bechtel Geotechnical month basis. da ted. February 26-28, 1979, and August 29-31, 1979, and February 26-28, 1980. f A recent Bechtel QA audit of Bechtel Geotech Section 4

wan cosulucted in February 1979. Additional audits will Audits are scheduled for every six months.

be perturmed in this area on a six month cycle until complet ton of soil work.

(Question 1 Apx I, Page I-7, Para C.4.c) 1 - 10 Review drawings for possible effect of vertical duct 4 *

(Closed) See Action Item 23-14 for NRC review.

hank restrictions.

1- 11 Complete actions in response to DRUCL audit. (Closed) See Action Item 23-1 for NRC review.

4 I - 12 Revise EDP 4-49 to incorporate clarifications and (Closed) See Action Item 23-3 for NRC review.

Instructors for use of specification change notices.

I 1 - 13 Schedule audits of each design discipline calculations (open) CPCo commitment not completed.

on a yearly basis.

1- 14 Re-evaluate construction equipment used for compaction. (Closed) Verified 50.54(f) submittal, " Report on Test Fill Program" which provides documentation for i

Compaction equipment currently in use has been qualified qualification of compaction equipment currently in and construction notified of parameters governing use of use, Spec. C-211, attachment 1, provides a list of equipment.

equipment to be used and compaction requirements.

(Question 23 Subsection 3.6., Page 23-18)

(Question 1. Apx I, Page 1-11, Para C.1) .

Sheet 19 of 2Gj ,

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Action Action Item -

3 j Item Description

j. Number and Reference

] 1 - 15 Assign Field Soils Engineer and Soils Engineer-from (Closed) : Verified Spec. C-211 Para 8.3.5. requires

! design section. ' soil work to be performed under direction'of

. qualified onsite. soils engineer.

One full time and one part time onsite Geotechnical Soils Engineer has been assigned.

l (Question 23 Subsection 3.7., Page 23-20) i ~

(Question 1. Apx I, Page I-ll, Para C.2.a) 1 - 16 Review construction specifications and procedures to (Open)- See Action Item 23-8 . CPCo Commitment

• identify equipment requiring qualifications. .not completed.

3 1

1 1 - 17 Review field procedure FPC-3.00 to ensure clarify and (Closed) See Action item 23-/a for NRC review.

completeness.

i 1 - 18 PQCI 1.02 has been revised to incorporate the specific (Closed) Verified PQCI 1.02 (Rev. 5) has been characteristics to be verified by Quality Control. revised to include specific characteristics to be.

' inspected.

i (Question 23, Subsection 3.8, Page 23-22)

(Question 1, Apx I, Page I-16, Para C.l.a) .

Project Quality Control Instructions C-1.02 was revised (Closed) Verified C-1.02, Rev. 5 requires compaction

?.

to include verification of use of qualified equipment & equipment to be qualified and will adequately com- ,

p compliance with qualified procedures. pact the material being placed and provides for a-daily soil placement report.

, (Question 23, Subsection 3.6, Page 23-18)

(Question 1 Apx I, Page I-16 Para C.I.a) _

(Question 1, Apx I, Page I-17, Para C.4.a) f 4

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Action Action Item Item Description Number ,,

and Reference 1 - 18 PQCI 1.02 was revised to provide specific inspection. -(Closed) Verified PQCI 1.02 (Rev.-5) Para 2.3 Cont' requirements for verifying soil moisture contents, has been revised to provide inspection of moisture.

,rather_than surveillance. testing.

(Question 23, Subsection 3.9, Para 23-24) 1 - 19 . Complete in depth review of_ soil. test results (Close'd) Reviewed and verified report entitled, Geotechnical Services has completed an investigation- " Review of U. S. Testing-Field and Laboratory which includes an in depth review of testing performed Construction Test-Data on Soil Uses as Fill",

by U. S. Testing and reported test results, dated July, 1979 was performed.

(Question 23, Subsection 3.10, Page 23-27) 'i (Question 1 Apx I, Page I-17, Para C.3.a).

An in depth soils investigation program provides verifi- (Closed) Verified that bcrings test pits, cation of the acceptability of the soils or identified laboratory tests.. analysis of past test results any nonconformances requiring further remedial action. and plots of all resushave been performed as part of the investigation of the subsurface materials.

(Question 23, Subsection 3.8, Page 23-23) This information has been submitted to the NRC and is' currently under review by NRC office of NRR, ,

(Question 1.-Apx I, Page-I-17, Para 3.a) Geotechnical Branch.

• 1 - 20 Perform in depth audits of U. S. Testing. (Closed) See Action Item 23-15 for NRC review.

1 - 21 Review of QCI's for surveillance call outs. (Closed) See Action Item 23-19 for NRC review.

1 - 21A Modify QCI's Based on Item 1-21. (open) CPCo commitment not completed. j 1 - 22 Evaluate documentation call outs on QCI's (Closed) See Action Item 23-19 for NRC review. i e

1 - 23 Incorporate scientific sampling plans for inspection.

(Closed [ See Action Item 23-34 for NRC review.

1 - 24 Complete in depth review of Bechtel trend program. (Closed) See Action Items 23-35 and 23-36 for >

.NRC review.

r 6___ _ _ _ _ _ - - - - - - - - - - _ - _ _ _ . _ - .- _ _ _ _ _ _ _ - - -- ._

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Action Action Item .

Item Description

Numlier and Reference 1 - 25 Conduct QA Training. (Open) See Action Items 23-16 and 23-17 for NRC' review.

l ' (Unnus.bered) Selection of protor ' curves will no longer be a problem (Open) A review of this commitment resulted in because each field density test will be accompanied by an item of noncompliance as discussed in paragraph q

a separate laboratory standard which will provide'a 3.(c) of this report.

direct comparison. This was directed by a letter to U. S. Testing and reflected in specification change notice

(

C-208-9004, dated April 13, 1979.

(Question 23, Subsection 3.10, Page 23-27)

(Question 1, Apx I, Page I-17, Para C.4a) ,

Specifications wer- revised to provide more definition (Closed) Verified spec. C-211, Rev. 12,~ Para 8.4-(Unnumbered) (moisture control) has been revised to provide

requirement for soil moisture testing.

4 specific requirements for moisture testing.

! (Question 1. Apx I, Page I-16 Para C.2.a.).

i Spec. C-210 and 211 were revised to incorporate inter- (0 pen) Interpretations had not been identified or l (Unaumbered) pretations that affected specification requirements. evidence of being incorporated into specifications.

l (Question 23, Subsection 3.2., Page 23-8) i (Question 1, Apx I, Page I-6, Page C l.a)

(Unnumbered) The requirements for the control of testing were (Closed) Reviewed'and verified Spec. C-208, Rev. 20 adjusted, requiring the testing subcontractor to .20, Para 9.1.3. to require all field devsity tests i

check all field density tests for cohesive material to be checked to the zero-air voids curve.

l against the zero-air-voids curve.

(Question 23, Subsection 3 10, Page 23-27)

PQCI SC-1.05'was revised to add more stringent require- (Closed) Verified PQCI 1.05, Rev. 11 was revised

! (Unnumbered) to include requirements for inspecting in process ments for in process inspections of U. S. Testing.

testing activities.

i (Question 23, Subsection 3.10, Page 23-27) i i

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'b- CLEN ELLYN,ILLifiets 60137 ATTACHMENT 4 i V .... . 1 I

FEB 21981 Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN: Mr. James W. Cook-Vice President, Midland Project 1945 West Parnall Road Jackson,.MI 49201 Gentlemen: .

This refers to the routine inspection conducted by Messrs. E. J. Gallagher, R. B. Landsman, and R. Sutphin of this office on January 7-9, 1981 of activities at the Midland Nuclear Power Plant, Units 1 and 2 authorized by NRC Construction Permits No. CPPR-81 and No. CPPR-82 and to the discussion of our findings with Mr. W. R. Bird at the conclusion of the inspection.

The enclosed copy of our inspection report. identifies areas examined during n the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with h7C requirements, as described in the enclosed Appendix A, and a written response is required.

Certain other activities, set forth in Appendix B to this letter, appear to be a deviation from cocenitments which you have made in previous correspondence with the Commission. Please advise us in writing within twenty-five days of the date of this letter of the corrective action you have taken or plan to take, showing the estimated date of completion with regard to this deviation.

I In accordance with Section 2.790 of.the NRC's " Rules of Practice," Part 2, j Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, l and your response to this letter will be placed in the NRC's Public Document l Room, except as follows. If the enclosures contain information that you or 1 your centractors believe to be proprietary, you ::.ust apply in writing to this of fice, within twenty-five days of the date of this 1< tter, to withhold l

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, )vPE F Flos(1olSt

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Consumers Power Company- -

2- FEB  !

13 21961 -

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such information from public disclosure. The application must include a full statement. of the reasons for _which the information is considered proprietary, and should'be prepared.so that proprietary information identified in the application is contained.in an enclosure to the application. j i

k'e will gladly. discuss any questions you have concerning this' inspection. ,

Sincerely, James G. Keppler .

Director

Enclosures:

1. Appendix A, Notice of

' Violation.

2. Appendix B, Notice'of

. peviation

3. 'IE Inspection Reports

, No. 50-329/81-01 and No. 50-330/81-01 V

cc w/encls:

Central files Reproduction Unit NRC 20b ,

PDR Local.PDR -

NSIC-

, TIC Ronald Callen, Michigan Public Service Commission Myron M. Cherry, Chicago L

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l Appendix A )

.[ 1- )

V NOTICE OF VIOLATION ,

l l

Consumers Power Company Docket No. 50-329 Docket No. 50-330 As a result of the inspection conducted on January 7-9, 1981, and in.accordance with the Interim Enforcement Policy, 45'FR 66754 (October 7, 1980), the following violations were identified.

1. .10 CFR 50,-Appendix B, Criterion V,. requires in part " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings". ,

~

CP QA Program Policy No. 5 states in part, " Prior to performing... inspection on a safety related item, suppliers are required to develop written procedu.res for . . . performing required inspection and tests. These procedures reference applicable drawings, specific'ations', codes and standards. CPCo QA Departments review field... inspection procedures prior to implementation".

- Contrary to the above, the inspector determined that U. S. Testing Company ha's not established test procedures for soils work activities. The specifi .

cation for ' testing, C-208, references ASTM standards for performing specific

) tests, but does not include procedural controls or instructions for implement-ing the tests.

This is Severity Level V violation.

~

2. 10 CFR 50, Appendix B, Criterion VI requires in part', " Measures "

shall be established to control the issuance of documents . ..

CP QA Program Policy No. 6 states in part, " Documents which prescribe

. activities affecting quality . . . are. . . controlled according to written procedures. . . The document control system provedures for: Identifying the proper documents to be used in performing a quality related. . . activity;

- establishing curient and updated distribution lists".

Contrary to the above, the inspector determined that U. S. Testing Company test result forms are not controlled. The proper documents to be used for a specific' test are not defined. There is no distribution list for the forms.

The latest revision of the forms are not controlled.

This'is a Severity Level V violatien.

3. 10 CPR 50, Appendix B, Criterion XVII, requires in part, " Sufficient reccrds shall be maintained to furnish evidence of activities affecting quality".

ASSI N45.2.9, Section 3.2.1. requires in part, " Quality arrurar.ee records

.\  :!.211 be considered valid caly if stsr. ped initialed, si;;ned, er other.eise 3 0 0 e n t f e a t e d a n d d a t e d b y a u th o r i .~.e d p <: r n r.<.tl" .

M TID 3IFo203

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CP QA Program Policy No.17 states in part, " Compile' records as specified in applicable procedures, codes'. .. " -

N

'Bechtel. Field Instruction FIC-1.100, Appendix A uader Daily FER,. paragraph No. 18 states in part, " Review and initial all acceptabic test report sheets from U.S. Testing . - ." .

Contrary to the above,-the inspector observed that numerous U.S. Testing report sheets were rubber stamped with the name of the onsite geotech '

engineer and not initialed and dated as required. .In addition, there were no procedural controls for the use of the signature stamp.

This is'a Severtiy level VI-violation.

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of.this Notice a written statement or

- explanation in reply, including for each item of noncompliance: (1.) corrective  !

action taken and the results achieved; (2) corrective action to be taken to avo.id further noncompliance;'and (3) the date when full compliance will be achieved.

Under.the authority of Section 182 of the Atomic Energy Act of 1954, as amended,.

this response shall be submitted under oath or affirmation.

ated Ak.~ Oo I%) '

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Appendix B NOTICE OF DEVIATION Consumers Power Company Docket No. 50-329 Docket 1o. 50-330 As a. result of the inspection conducted on January 7-9, 1981, the following was cited as a deviation.

10 CFR'50, Section 50.54(f) response from CPCo to Question 23, Subsection 3.7 states in part, "One full time and one part time onsite geotechnical engineer have been assigned. These engineers provide technical direction and monitoring of the process."

Contrary to the above it.was determined that the assigned engineering technician does not satisfy the com:nitment made in 10 CFR 50.54(f) submitted to provide an onsite geotechnical engineer and to implement the duties and responsibilities of FIC 1.100,-Appendix A, " Duties & Responsibilities of the Onsite Geotechnical Engineer"..

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.4 U. S. NUCLEAR PJ.GULAT0hY CO.T:ISSION

/,) 0FFICE OF INSPECTION AND ENFORCE.'ENT REGION III Report No. 50-329/S1-01; 50-330/81-01 Docket No. 50-329; 50-330- License No. CPPR-S1; CPPR-82 Licensee: . Consumers Power Company 1945 Pa:nall Road Jackson, MI 49201:

Facility Name: ' Midland Nuclear Power Plant, Units 1 and 2 Inspection At: hidland Site Inspection Conducted: January 7-9, 1981 Inspectors: E. J. Gallagher O /'2d'd/

R. B. Landsman /-2.5 - T /

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i R. N. Sutphin, Jr. ,

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Reviewed By: R. C. Knop, Chief,

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Projection Section Approved By: . ell lef, /!,l[

Reactor Construction and I /

Engineering Support Branch Inspection Summary I

l Inspection on January 7-9, 1981 (Report No. 50-329/81-01; 50-330/81-01) l Areas Inspected: Consumers Power Company response and implementatice of l corrective actions regarding the 10 CFR 50.54(f) request of question 1 of NRC i- letter dated March 21, 1979 and question 23, request for additional information dated September 11, 1979; procedures, quality records and observation of work related soils work activity; quality assurance organization status, cor.:.tructier schedule; and status of personnel air locks. The inspection involved a total cf r 60 inspe: tor-hours on site by three NRC inspectors.

O buee or '

15ID5fFC416

l Results: Three items of nonect.pliance and one deviation were identified in the t.bove inspected areas - Severity Level IV, Inadequate Procedures; Severity Level IV - Inadequate document control; Severity VI - Inadequate Quality Assurance O(

Records; Deviation from commitraent to provide Geotechnical Engineer.

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4: P DETAILS

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Persons Contacted Constmers Power Company D. Miller, Site Manager.

• W.. Bird, Quality Assurance Maiager

• T. Cooke,' Project Superintendent

• R. Davis,-Quality Engineer

'*R. L' heeler, Staff Engineer '

'*D. Horn, Civil Group Superiisor ,

• H. Leonard, Section Head, Qua}ity Engineering

• D..Turnbull, Site Quality Assurance Superintendent D. Keating,'Section Head IE and TV Bechtel Power-Company  !

• J. Russel, Assistant Project Field Quality Control Engineer

• E. Smith, Project Field Quality Control Engineer

• P. Corcoran, Resident Assistant Project Engineer

• P. Goguen, Lead Civil Field Engineer

• J. Betts, Assistant Field Project Engineer

• M.' Deitrich, Project Quality Assurance Engineer j .

• L. Snyder, Resident Quality Engineer l '

~~N .

s J U. S. Testing Company J. Speltz, Lab. Manager The inspectors also contacted other licensee ahd contractor personnel during the course of.the inspection.

• Denotes those in attendante at the exit meeting on January 9,1981. t l

L'icensee Action en Previously Identified Items (Closed) CPCo Action Item: S100D, NRC Inspector E. W. K. Lees concern regarding

" unreadable documents" in one of the document-packages for a shop weld, as ex-pressed by the inspector during his October 9-10, 1979 inspection, and item "D" of J. L. Corley October 12, 1979, Midland Memo No. . 344PQA79. CPCo determined that documents of concern' applied to spool piece 2CCA-61-5611-2-6 wherein parts of two radiograph reports were not legible due.to copy machine problems. Legible copies were secured for this file. In addition Ecchtel QC reviewed 20 other M-104-A data packages and'found 9 out of 298 pages in similar condition. Legible copies were

-:de of all discrepant pages and filed, as recceded in L. A. Dreisbach Meno LAE16SS of August 8, 1980, to J. L. Corley. This item of NRC concern is closed.

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(Closed) 329/79-12-01; 330/79-12-01 " Work Prints in use were not current revision",

CPCo Action Item S500. CPCo advised inspector that incorrect' issue (Rev. 11) of .

print was removed' and correct issue (Rev.12) provided to the work area at the time of the original inspection. Current-issue of the drawing is Revision 14, issued September 14, 1979, title of the drawing in Question is " Decay Heat Removal,

. Core ~ Flooding System Unit 2 Hangers, Location and Identification". Three audits  ;

have been performed.since the original inspection. One was reported in May 1979,- l one reported September 9, 1980, and-another reported on November 24, 1980, the l

'results of which indicate a significant improvecent in the revision control of I work prints. Based on this corrective action and commitments by CPCo to maintain a continuing program of audits in this area of activity, the referenced item of noncompliance is closed.

(Closed) Unresolved Item 329/80-11-03; 330/80-12.-03, "Soubber Missing Required Spacer". Two snubbers were found to have one missing spacer washer each, however, they had not gone through the regular inspection and acceptance by Quality Control at the time 24 pipe supports in various stages of inspection and installation were J observed by the NRC inspector. As a result of the express concern of the NRC inspector training was planned and conducted on June 10, 1980, construction corrected the condition of the two snubbers, and documented the. inspection on a QC-Gi-1 form, and activity 3.1.c in the P-2.10 PQCI has been added to' verify future configurations and orientations are correct, per M. A. Dietrich Memo No. LAD 1754 of November 12, 1980. ' Based on this documented corrective action, this unresolved item is con-sidered closed.

(Closed) CPCo Action Item: 5479, KRC inspector R. N. Sutphins concern regarding lack of update of EDPIS per comments in NRC reports No. 50-329/80-30; 50-330/80-31, Page 11. The inspector checked the two items in the Bechtel Power Corporation-Engineering Department procedures manual and found them to be in proper order.

This concern is closed. However, additional technical review of the Engineering Department procedures manual will be conducted at subsequent inspections.

9 4

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.c c .-

9 Section'I Prepared by' R. N.'Sutphin-Reviewed by R. C. Knop, Chief Projects Section 1

--l. Functional or Program Arsas: Inspected '

a. CP'Co-Quality Assurance Organization

- -The inspector reviewed the organization chart of the combined CPCo -

- Bechtel Quality Assurance. Organization, issue date January 1, 1981.

Mr. M. A. Dietrich is (Acting) PQAE replacing Mr. L. A. Dreisbach who has'been reassigned. . Mr. D. M. Turnbull had reported to:the site in the position of Site Project QA-Superintendent. The combined Midland project Quality Assurance organization now.has 40 persons assigned co= pared to'.36.as of mid October 1980. The supervisor of the adminis-

- tration Groupfreporting to the site project. Quality Assurance Superin- ,

.tendent' vill be announced in January 1981.. Additional information was .

requested on the person who has been selected to fill an open position. '

as Civil Quality control Engineer in the Bechtel Quality Control Organi-

^ zation.

' b. Construction Schedule v) g The inspector checked the. status of construction and construction schedules. for the overall project, and received a copy of the January 8, <

1981 CPCo report memo to NRC on the current yellow book schedule,

c. - Onsite Design Activity

• The' inspector checked the status of.the ongoing onsite design activity and continued his review of the engineering department procedures manual.

- The inspector toured the site to observe the status of the work.

No items of noncompliance or deviations were identified.

. 2. Other Inspection kreas

a. 50.55(e) Personnel Air Locks The inspector checked on the status of the activity to resolve the remaining open questions on the personnel air locks. The manufacturer is .vorking-on the completion of the as-built record, revised drawings, and updated stress report. Mc.tel vill reviev'these ite: when they are completed. The canufacturer will advise if any further repair or

. reverk is.recer. end. This itc

vill re:.ain c;>cn a .d aditional review vill be conducted at subsequent inspectiers.

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Section II I \

( / Prepared by E. J. Gallagher R. B. Landsman Reviewed by R. C. Knop, Chief Projects Section 1

1. Review of Onsite Soils Works Activities ,

As a followup to NRC Inspection Report No. 50-329/80-32; No. 50-330/80-33 the region III inspectors performed an inspection of the current onsite soils work activities to verify whether adequate corrective actions have been implemented as described in Consumers Power Company response to questions 1 and 23 of 10 CFR 50.54(f) submittals. The following are the specific findings.

a. Procedural Controls for Soils Work It was determined that U. S. Testing Company' (UST) have not established written procedures for implementing the requirements of Testing Specification C-208. This specification references numerous ASTM standards for performing specific tests but does not include procedural

. control or instructions for the implementation of such tests.

(1) While observing a laboratory relative density test (ASTM 2049) if)s. it was observed that the variable theostat on the testing

\' apparatus was set at maximum setting. The lab technician stated that ASTM D2049 requires the setting of the machine at maximum amplitude. It was determined that UST did not previously determine the rheostat setting that produced the maximum density for the material being used onsite. It was assumed by UST that maximum setting produced maximum density. Relative density tests are used to assure that the inplace field density meets the specification requirements.

f l Corps of Engineers Manual EM 1110-2-1906 dated E vember 30, 1970, l Appendix XII, Page XII-8 states the following:

I "It has been determined that for a particular vibrating table, L

mold, and surcharge assecbly, the maximum dry density of a speci-l men may be obtained at a displacement amplitude (rheostat settics) less than the maximum amplitude of which the apparatus is capable; l i.e. dry density may increase with increase in rheostat setting to a setting, beyond which the dry density decreases, therefore each 1sboratory should determine for it's apparatus the r!.ecstat setth.g

! at which maximum density is produced and use this setting for sub-sequent maximum decsity testing."

I Tootnote on Page XII-S states:

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y "It may be desirable to redetermine the optimum rheostat setting at the inception of testing for each major project."

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U. S. Testing had not determined this setting nor did a procedural

- control exist 'for the ' determination of the rheostat setting.

(2) Wile observing limited field soils work being perforned at .the metering pits south of the essential service water intake structu're at' elevation 630it was determined that samples used to perform

. relative density. tests have.been taken after.the material has been compacted. These samples should be taken prior to compaction since grain size and gradations can be. altered during compaction. The relative density test should be performed on as received caterial used prior toicompaction. . Grain. size is:ene of the important' char-acteristics of how soil behaves.- The inspector determined from a review of the available grain size analysis that there appears to be: a ' gradation change of the material comparing before and after compaction. ,

A procedural control specifying where and when to taken soil samples ,

Jshould have been established. UST.does not have procedural instruc-tions specifying the field technique where and when to take samples foi t

density tests.

(3) It was determined from discussions with the cognizant UST personnel

~

that they have been performing in place density tests "at the directiot Lj] of the onsite geotechnical engineer." However, there are no pro-cedural instructions as.to what depth below the lift being compacted Q the test should be performed. A review of the density test reports  ;

indicate that they are not correlating the density test depth to the lift being compacted.

Eased on the above, it has been determined that CPCo is in noncompliance with 10 CFR 50, Criterion V (Procedures) in that adequate laboratory and field test procedures have not been. established for the control of soil testing activities. (50-325/81-01-01; 50-330/81-01-01).

CPCo response to 50.54(f) question 23, subsection 3.11, page 23-31 states .that "U. S. Testing was required to demons't rate to cognizant ,

l

- engineering iepresentatives that testing procedures, equipment, and

- personnel used for quality verification testing were capable of pro-viding accurate test results. . ." This commitment has not been satisfied based on the above findings.

I Subsequent.to the inspection CPCo informed the RIII offices on January 16, 1981, by telephene that U. S. Testing Corporation veuld develop and issue impleentir.g recedures for soil cork activities.

These procedures will be reviewed during rubsequent inspections.

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b. Document Control For Soils ork p).

I

(, It was determined that U. S. Testing was using uncontrolled forms to record quality control test results. A binder was observed in the U.S.

Testing lab which contained QC forms used to record test results. On the inside cover it stated that the index does not reflect the latest

. revision of each form. The cognizant lab personnel were not able to

. demonstrate that the latest revision of QC test for=s were being used since there were no-document control provisions established to control

- these forms. An undated U.S. Testing inter-office memo was presented to the NRC inspector as the procedure to follow when receiving revised forms. It states in part, " log into controlled forms index". The  ;

inspector requested such a form index but did not receive it. There was no documentation onsite as to what forms are to be used~for what test as well'as what are the latest revisions of the forms.

Based on the above, it was determined that CPCo is in noncompliance with 10 CFR 50, Appendix B, . Criterion VI, (Document Centrol) in that measures have.not been established to control the issuance of documents which affect quality activities. (50-329/81-01-02; 50-330/81-01-02)

Subsequent to the inspection CPCo informed the RIII office that quality contro1' verification forms would be controlled by the implementing pro-cedures. This will be verified during subsequent NRC inspections.

c. Soils Test Records

. fm

) (1) Quality assurance records for backfill work activities were reviewed

( for completeness and compliance with licensee specifications, pro-eedures, and commitments.

Bechtel field instruction FIC.1.100, Appendix A, duties and.respons-ibilities of the onsite geotechnical engineer, Paragraph 18, requires that the onsite geotechnical engineer review and initial all accept-sble UST test report forms.

ANSI N45.2.9 (Quality Assurance Records), Section 3.2.1, requires that " quality assurance records shall be considered valid only if stamped, initialed, signed, or otherwise authenticated and dated

. by auth'orized personnel".

Numerous UST density test reports were rubber stamped by the geotechnical engineer, however, none were dated. In addition no procedural controls were established for the use or control of the rubber signature stamp of the geotechnical engineer.

w Based on the above it ras determined that CPCo is in nonccrpliance with 10 CFR 50, Appendix 3, Critorien XV11 (Quality Assurance Reccrds) in that the soil test rep:rts are not ir.itialed or dated and t!4.-e vere no established controls on the use of a ruiber signature s r p.

(50-329/81-01-03; 50-320/S1-01-03) e e s

Subsequent to the inspection CPCo informed the RIII office that

[] soil test reports would be initialed and dated as required. This .

(j will be verified during subsequent inspections.

(2) Specification C-208, Section 9.1.3(d) requires the geotechnical .

engineer to review and evaluate test results when densities exceed certain values. From discussions with the previous geotechnical.  ;

engineer, it was dete,rmined that the evaluation consisted only of l a check of the numerical calculations for numerical errors. If the calculations were correct the disposition was "use as is", this.

review does not meet the requirement to evaluate test results.

Subsequent to the inspection CPCo informed the RIII office that documented evaluations of the above would be performed. This is an unresolved item pending review of the evaluation (50-329/

81-01-04; 50-330/81-01-04).

-d. Review of Nonconformance Reports The NRC inspector requested all conconformance reports regarding soil work activities since March of 1979. The f'o11owing reports were made available.

Bechtel NRC No. Date Description of Rh Status 2294 6/23/79 Failing density tests Closed Closed pg 2307 2350 6/25/79 7/16/79 Failing density tests Tailing gradation test Closed (V) 2492 8/30/79 Qual, of ccmpaction equip. Closed re-Opened 3041 6/25/80 Tailing density tests 3159 10/07/80 Failing gradation test Closed 3165 10/09/80 Lift 4.hickness exceeded Closed CPCo M No. Date DescriptionofkRh Status M-01-4-0-005 1/18/80 No spec. requirement for backfil around piping Open M-01-2-9-060 7/19/80 Spec & purchase order for

' sand gradation not the same. Closed M-01-9-0-038 5/15/80 Final report on qualifica-tien of compaction equip-ment. Open i The above closed SCR's were determined to be adequetely resolved, those open or reopened will be reviewed during subsequent inspections.

D V

9

.. . + ,

e. Qualifications of Onsite Geotechnical Engineer 7- x CPCo response to 50.54(f) question.23, subsection 3.7, page 23-20, states _

( .that, "one full time and one part time onsite geotechnical soils engineer have been assigned." The inspector requested the qualifications of the onsite geotechnical engineer. A resume was presented to the inspector as representing the assigned individual to implement the conmitment in order to preclude future soils problems. This engineer is to provide the technical direction and monitoring of the entire earthwork process.

The resume that was presented was of an " Engineering Technician" with no previous formal education in engineering or geotechnical engineering.

-The engineering technician.had nominally 15 years of field and laboratory testing of soils.

This information was discussed with representatives of the KRC geotech-nical branch. It was determined that CPCo committed to provide techn-

~ ical-direction from a geotechnical engineer capable of being recognized and licensed by a state board of registration of professional engineering or equivalent.

In view of the fact that adequate technical direction had not been pro-vided per the commitment by CPCo in the 50.54(f) response it has been determined that CPCO is in deviation from a NRC commitment as described

. 'in Appendix B of the transmittal letter of this report. (50-329/81-01-05; 50-330/81-01-05)

/

Subsequent to the inspection, CPCo informed the RIII office that a (x~' geotechnical engineer would be ensite beginning January 19, 1981 and that job descriptions and qualifications for the geotechnical engineer for the speciality remedial work to follow would be developed. This

action will be verified during subsequent inspection.

l 2. Eorated Vater Storage Tank Reanalysis .

H During the inspection, the licensee informed the inspector that the prelimin-ary structural reanalysis of the borated water storage tank ring foundation yielded-results that indicated the foundation to be overstressed. The in-spector inquired to the quality assurance group if this condition had been

. considered for reportability. Af ter this inquiry, the Manager of Quality Assurance produced the CPCo form entitled, " Safety concern and reportability evaluation" for the IWST ring foundation.

' This d cument indicates. that a. finite element analysis results in' forces ind. :. :ents in excess of TSAR allowables. The reportability evaluation indiceted the' event was "not reportable" with further evaluation necessary.

T'.e p2anned actions included retaining a c:nsulttnt to review the results

lisined by.the' analysis and/or perf:rm an independent check and excavate

.3 i :;c:t the f:undati:n for si;ns of : .'e rs trerring (i.e. , cracking).

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,s On January 23, 19S1, CEPo infor ed the RIII office.the excavation around the.

( Unit I tank was complete and that cracks were observed in the areas of over-

\s,-} , stress. CPCo identified this item as a 50.55(e), significant construction deficiency. This item is under review by the KRC staff.

The inspector informed the Region III office and NRR project canager on Janua ry 9,1981. The licensce's evaluations of the matter are included as Attachment No. 1 of this report.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance or deviations.

Unresolved items disclosed during this inspection are discussed in Section II, Paragraph 1.c.(2).

Exit Meeting The inspectors met with licensee and contractor representatives at the conclusion of the inspection on January 9,1981 and summarized the inspection scope and findings. The licensee acknowledged the inspection findings. Subsequent to the exit meeting the inspectors and RIII management telephoned on January 14, 1981 the Quality Assurance Manager in order to verify what corrective action would

.be taken based on the inspection findings. On January 16, 1981, CPCo' informed i the RIII office of the actions te be taken which are contained in the report l , s Section II, Paragraph la, Ib, Ic, and le.

I

\ AttacFaent:

Attachment No. 1 I

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" SAFETY CONCERN AND

"%'E'#5E C'!/.t.l f Y /.*.4 '.7.h t E -*'

.g'I REPORTABlLITY EVALUATION uCE 1

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e CzCE:e wENTmEo to\

• s rc: ult of the 50.54(f } MEN, mEnE2 co :nitments to do a TO MANAGERWI

)

( 3,' 1. ??OM: R L Rixford hructuralreanalysisofCategoryIStructures(SocItecs 7 and 48-2), the BWST ring found'ation was reanalyzeds ORGMNE WD -

nd values were obtained which were inconsistent with ,SCF2 NO: 5 previous values, and inconsistent with TSAR require =ents. jFILENO: 15.1 The results of the analysis were obtained 1-4-51 and dis-  ;

'-DATE RECEIVID:

4:ussed in a 1-5-81 CPCo/Bechtel meeting. The Project - = - =-

tianager attended this meeting and subsequently briefed 2. IS CO:!CER. AgRT ly the Manager of Quality Assurance. 'r.HD{ t N/A

/ 3Y WOM? N/A f 3. IS KRC A'.:ATG OF THIS?

O TES em WEN? N/A (CONTINt!E ON NEXT PACE) 3Y WOM? N/A 5 BRIEF DESCRIPTION OF CONCERN - SYSTEM, CC!GON:3T, ACTIVITY, POSSI3LE SAFETY II.:?ACT - '

( ATTACH SUFFCRTINO DOCUIENTS).

The BWST ring foundation was analy::ed for several loading cochinations including the.

load plus live load which was de'termined to be the most severe. The analysis was. fir perforced using the cethods of BC-TOF-4A, Rev. 3 (this =ethod uses springs for soil /

structure interaction during a scis=ic event), but gave displacement values inconsist with anticipated and measured values. The analysis was then done using a finite elen technique which gave co.sistent displacement values but forces and cocents in excess FSAR allevables. The values obtained f rom the reanalyses which have been done indica an overstressing and, hence, a potential for failure of the foundation of the Categer E'.!S T .

(C0!!TI!'UE CH NEXT T A03

6. It.*EDIATE REPO?.TABILITY EVA111ATION: 7. OBOANIZATIO:1 TGPOUSIBLE F0? FU?.THER e., REFC3?A2LE - GO TO 13 EVAL'JATIC":

b. O POTINTIALLY PI?o3TA3'E - G0 TO 13 Bechtel Engineering - Civil e.G liOT MI?ORIJ3LE, FURTHER EVALUATION 8 '. FIU/J. RE?0RTA3!LITY EVALUATION d.O NOT REF0F:N3LE . (IF 6. c. CHEC:GD):

a. O p.PO? TABLE b, C nog gypogTA3LI 9 QA AFFR0'lAL OF I'!ALUA'IION '

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OF BLOCV.S 1 TO 7:

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l1ANACER - ??Q.A kN DATE

10. JUSTIFICATICN OF EVALUATION - ( ATTACH SUFFCpTI!io DOC U:G::TS)

The first reanalysis give displaccecnt values which were inconsistent with mecsured sett1ccent and anticipated; values.. This cast doubt upon the spring values used in th annlysis. The subsequ :nt 't'inite element analysis gase displacceent values which .:ere sistent with the.other values available for comparison, but gave forces.and moments v l cxecoded the FSAR allo tables by an amount sufficient to warrant an additional check o Il' thc0c values also.

T.'o ceticas planned to check these values are:

1.  %:cin a conrul,: cat to review the results cbtained by analyscs dene, .r.d/cr do an independent check.

2 '.

l C: cove te and inspect the fcunde.:irn for signs of everstrcesing (i.e., crecM . ,

l It- c ceri?cred pro .ature to jud;;c :. hic a reportabic ccnditica prior to confi r..c,*.12 the values cbtaine(by the finite c1cient cnalycis.

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