ML20126L834

Testimony of JW Gilray That Deficiencies Occurring in Soils Const Were Caused by Lack of QA Controls in Program Procedures,Design,Installation,Surveillance,Insp,Tests, Verifications & Audits.Prof Qualifications Encl

ML20126L834
Person / Time
Site:	Midland
Issue date:	06/08/1981
From:	Gilray J Office of Nuclear Reactor Regulation
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 8106090666
Download: ML20126L834 (6)

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't'} UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I

BEFORE~THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )

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

) 50-330 OM & OL (Mid'and Plant, Units 1 and 2) )

NRC STAFF TESTIMONY WITH RESPECT TO QUALITY ASSURANCE Q.1. Please state your name and position with the NRC.

A. My name is John William Gilray. I am a Principal Quality Assurance Engineer in the Quality Assurance Branch of the Office of l f- s Nuclear Reactor Regulation. I participate as a senior reviewer of s- quality assurance program descriptions in Safety Analysis Reports to l

determine their acceptability prior to issuing a construction pennit or l

operating license. I graduated with a B.S. in Mechanical Engineering in 1958. For the past 22 years, I have been an engineer in quality assurance and quality control activities for programs associated with Navy Nuclear, NASA aerospace, and government and co.nr.ercial nuclear projects.

Currently, my principal assignments deal with the quality assurance review for the re-start and operations phase of TMI-1 and special quality assurance review of the design and construction programs for South Texas, Parble Hill, and Midland relative to the corrective actions and l subsequent improvements to these quality assurance programs.

/'~T A copy of my professional qualifications is attached.

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(g Q.f. Please state the dates of prior approval of the quality assurance >l program at Midland. 1 A. The quality assurance program for the design and construction of

{l the Midland Plant was found acceptable by the Commission, and the results of this evaluation are described in the SER dated November 12,1970 and '

in the Supplement #2 to the SER dated July 1977. The docketed quality

• anurance program is still acceptable and meets the criteria of Appendix B to 10 CFR 50 and quality-related regulatory guides and ANSI Standards.

Ineffective implementation of the program, however, led to the issuance y of the December 6,1979 Order tiodifying Con,truction Pernits.

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Q.3. -What has been your involvement in the Midland Project? h p A. As a result of inspection findings by the Office of Inspection -

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and Enforcement relative to the soils work, I was assigned as i.he quality assurance reviewer to assist in the evaluation of CPC's responses to our )

10 CFR 50.54 (f) questions initiated on fiarch 21, 1979. I reviewed and I evaluated the soils problem at Midland to determine if CPC had given y l sufficient attention to detennining the root causes of the soils problem (

l and to identify adequate corrective actions to preclude recurrence. I l reviewed CPC's response to question I which was submitted on April 24, L, .

1979 (Attachment 9 to the testimony of Eugene J. Gallagher) and their response to question 23 which was submitted on November 13, 1979

( Attachment 14 to the testimony of Eugene J., Gallagher).

l Question 1 actually consists of 4 questions which read as folbws:

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- (1) Identify those quality assurance deficiencies that contributed

- Q,/ 3 - to this problem, the possibilities of these deficiencies .being

- of a generic nature and.affecting other areas of the facility,

- and describe.the corrective. actions you have'taken to preclude these' deficiencies from happening in the future;

~ (2)L lWhat assurance exists that the apparent areas of contradictions

- in.the PSAR and FSAR'as described by the Office of Inspection i and Enforcement during the meetings of February 23 and March 5,

- 1979, do not exist -in other- sections of the PSAR and FSAR i dealing with matters other than fill?

- (3) Investigate other activities not associated with the , fill, but important to safety for'other systems, components, and structures of the tiidland facility, to determine if quality.

assurance deficiencies exist in view of the apparent breakdown of'certain quality assurance corstrols. Identify .those items investigated and the results of your investigation;'and 4

(4).. Considering. the result's.of your investigation in item (3)

- above, describe your position as to the overall effectiveness of your quality assurance program for the design and construction of the flidland plant.

-W Question 23.became necessary because we did not n< eive a ,

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( satisfactory response from CPC to question ~ 1. To date we have not received a satisfactory response from CPC to question '23. Additional

acceptable improvements have' been discussed in the CP/IE Reg. III meeting of March 13,~1981 and in the CP letter of J. Cook to J. Keppler dated .

April 30, 1981. Upon incorporating these improvements with the Midland docketed. response to question 23,.the overall response to questions 1 &

- 23 should be found acceptable to the NRC staff. Based on my evaluation o'f responses to questions 1 and 23 provided by'CPC, I have concluded that j L

prior to December 6,1979, quality assurance with respect to soils work at the site was not implemented in accordance with the docketed quality assurance program description previously approved by the AEC and the NRC.

Q.4. ' State your opinion as to the effectiveness of the implementation of the quality assurance program and the basis for your opinion, t

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( \ A. Persistant. problems during the design and construction of the

- -O Midland Plant since 1970 have raised serious questions regarding the I

effectiveness of the quality assurance program. Ineffective implementa-tion of the quality assurance program and a lack of quality assurance organization involvement in the day-to-day activities associated with safety-related activities in the soils area are clearly identified in

'the Office of Inspection and Enforcement inspection reports #78-12 and

1. 78-20_(Attachments 2 and 7 respectively to the testimony of Eugene J.

Gallagher) and in CPC's response to 10 CFR 50.54 (f) questions 1 and 23 (Attachments 9 and 14 respectively to the testimony of Eugene J.

Gallagher). They include:

(1) Inconsistencies between construction specifications and consultant reports.

b d (2) Lack of fonnal revisions of specifications to reflect clarification of specification requirements and improper use of memos as design control.

(3) Inconsistency of design basis within the FSAR relating to diesel generator building fill material end settlement values.

(4) Inconsistencies between the settlement calculations and the i

original design basis of the diesel generator building.

(5) Inadequate design coordination in the design of the duct bank. t (6) Insufficient compactive effort used in backfill operation.

_( 7) Insufficient technical direction in' the field.

(8) Inadequate quality control inspection of placement of fill.

(9) Inadequate soil moisture testing, y (10) Incorrect soil test results.

(11) Inadequate subcontractor test procedure. I l

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k (12) Inadequate corrective action for repetitive nonfonning conditions.

(13) Inadequate quality assurance auditing and monitoring of the plant fill work activities. l Summarizing, these deficiencies, which have occurred from the start of soils construction were caused by the lack of quality assurance controls  ;

in program procedures, design, installation, surveillance, inspection, tests, verifications, and audits. Based on the above, I conclude that ,i the docketed quality assurance program description was not adequately inplemented for the. soils work prior to December 6,1979.

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OUALIFIC6T10NS AND EXPERIENCE OF JOHh WILLIAM GILRA) esent Position

Title:

Principal Quality Assurance Enpineer (Nuclear)

Responsibilities: Participates as a senior member of the Office of Nuclear Reactor Regulation - Quality Assurance Branch staff whose function is primarily one of evaluating, from a safety standpoint, reactor construction and operating proposals with response to quality assurance and/or technical specifications. Serves l as Senior Nuclear Engineering Specialist for group evaluation of power reactor license applications.

6/63 - 6/72-

Title:

Quality Control Engineer for the AEC Space Nuclear Propulsion Office. t As the SNPO-C on-site Quality Control Engineer in f; Resp' nsibilities:

the prime contractor's plant, is responsible for (

monitoring the contractor's quality control program and providing technical direction relative to the testing, inspection and adherence to aerospace-rated quality control procedures for the development of the 1 nuclear rocket engine (NERVA). Directs inspection {

personnel of the Air Force Plant Representative's

,m office assigned to NERVA program relative to day-to-day inspections and quality surveys. -

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l l 8/62 - 6/63

Title:

Quality Control Engineer for Bourn's Inc. (Electronic Component Co.)

Responsibilities: Responsible for the Quality Control and Reliability policies and activities in the manufacturing and inspection of potentiometers and relays used in the Aerospace industry. Evaluates the design and in-l spection processes for adequate quality and reliability requirements.

l 1/59 - 8/62 Ti tle: Quality Control Engineer at Alco Prode:.ts, Inc.

(Fabricator of Nuclear Components) l Responsibilities: Responsible for establishing and assuring proper implementation of Quality Control and Quality Assurance requirements for nuclear components from the design purchasing and manufacturing phases thru the shipasnt of the ' components of the Navy Nuclear Shipyards.

l Schooling: Graduate in B5ME 1958 Courses: Optical Tooling Engineering Radiography and Film Reading eties: Society of Non-Destructive Testing American Society of Quality Control l PE: Registered Professional Quality Engineer l

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