ML20091M767
| ML20091M767 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/13/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-10, FOIA-84-96 OL, OM, NUDOCS 8406120099 | |
| Download: ML20091M767 (11) | |
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UNITED STATES OF A:4 ERICA NUCLEAR REGULATORY' COMMISSION BEFORE THE ATO 4IC SAFETY AND LICENSING BOARD a
In the Matter of C0iiSUMERS POWER COMPANY l
Docket Nos. 50-329 OM & OL (iiidland Plant Units 1 a'nd 2:
)h 50-330 OM & OL AFFIDAVIT OF JAMES G. KEPPLER IN SUPPORT OF NRC STAFF MOTION FOR
SUMMARY
DISPOSITION ON THE ISSUE OF QUALITY ASSURANCE PROGPA4 IMPLEMENTATION PRIOR TO DECEMBER _6.1979 Q. 1.
Please state your name end. position with the NRC.
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A.
My name is James G. Keppler.
I am Director of the U.S.
Naclear Regulatory Commission's Region III (Chicago) Office and have held that pocition since Septenber,1973. A statement of sqy professional experience is attachment 1.
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Q. 2.
Please surnarize your past ihvolvement.with Consumers Power Company's implenentation of quality assurance at the. iiifland site prior to December 6 1979..
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Inconnectipnwithouron-goingassessnentofquality i
i assurance imple mntation at Midland, qr staff developed a chronological listing of najor events aEd problems at the site:which includes quality 1
1 assurance deficiencies. These events and: problems are set forth in i
i attachment 2 (dated February 15,1979)?and attachment 3 (dated October 1
t 18,1979).
I was personally involved. in decidthg the regulatory actions taken for the more signif cant problems described in attachments 2 and 3.
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Q. 3.
When did you first learn of the apparent excessive settlement
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of the diesel ~ generator building?
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A.
I'm not certain as to the actualidate I personally became aware of the diesel generator building settlement problen; however, a written 10 CFR 50.55(e) notification was made to Region III by the licensee on Septenbar 25, 1970 concerning the problem.
I became personally involved with the problem following an NRC inspection on October 24-27, 1978 whi h was conducted as a followup to the Itcensee's report of the istter.
This inspection was conducted by Eugene J.
Gallagher of my staff and is documented in attachment 2 of his affidavit.
After being briefed on the inspection findings by fir. Gallagher. I f."
y directed my staff to conduct a comprehensive investigation into the
. natter to detemine whether the problem had been reported to the NRC in a timely manner, to verify the degree of conformance with commitments made by the licensee in the Final Safety Analysis Report, and to assess the root cause(s) of the problem.
I Q. 4.
Summarize the investigation findings and your role in the assessment of eese findings.
A.
The detailed investigation findings are discusted in Attachments 4 and 7 to the affidavit of Eugene'J. Gallagher.
Five Region
!!!:nanagement represent tives (including qself) were briefed initially by the investigation tea on February. 16. 1979.'. Based on those detailed b
investigation findings. It was our unanimous conclusion that the i
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implementation of the quality assurance / quality control progran for assuring the proper soil foundation for the site was ineffective.
In addition, several of the comitments. in the FSAR related to this work had not been adhered to. With respect to the reportabil'ity consideration, we agreed that the flRC had been informed of the problem in a timely manner once it had oeen identified. Based on this briefing. I instructed ry staff to set up a meeting with Consumers Power Company to infom them of our investigation findings. Two meetings. were held with the licensee relative to this investigation (February 23,1979: and fiarch 5,1979).
I participated in both meetings. A summary report of these meetings (Attachments 4 and 5 to the affidavit of Eugene J. Gallagher) was provided to the licensee in my letter dated !! arch 15, 1979.
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I Q. 5.
Sux.arize subsequent actions taken by you with respect to the soil settleoent problem.
A.
Following the NRC investigation and related neatings with the Itcensee, Region !!! manageeent reached the following conclusions:
(1) The technical issues associated with improperly conpacted soil needed review and evaluation by NRK.. This conclusion resulted in my I
l memorandum of March 12.19f9 to lir. Thornburg (attachment 5).
I (2) The deficiencies identified with respect to implementation of the quality assurance pkgran were lief tad to sofis work. Since the original soil placement act'ivities had been substantially completed, no t
attempt was made at this tihe to stop soil workJ*
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(3)' Several comitments in the.FSAR were incorrect and.
required review by NRR and ELD to determine whe.ther tney constituted naterial false statements.
This conc.lusion resulted in my mexrandum of April 3,1979 to Mr. Thornburg.
Q. 6.
What was the disposition of your recomendatio,s and how does that action relate to thm Order that was issued on December 6, 19797 A.
On March 21, 1979 the NRC's Office of Nuclear Reactor Regulation issued a 10 CFR 50.54(f) request to Consumers Power Company f,m requiring the licensee to provide additional in' formation regarding the adequacy of the plant fill and the root causes-and corrective actions to be taken regarding quality assurance deficiencies.
I participated in meetings at headquarters which led to the issuance I
of the December 5.1979 Order Modifying Construction Permits.
I supported issuance of that Order.
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James G; Keppler ~
subscribed and sworn to b'efore me i
this day of April, 1901..
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Notary Public
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1 My Consiission expires:
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t JAMESG.EkPPLER, RI0 GRAPHICAL I4 FORMAT 10N James G. Keppler has been Regional Director of the Nuclear Regulatory Commission's Region III Office of Inspection and Enfdrcament since 1973.
(The Nuclear Regulatory Cons:ission was formed in January 1975 to take over the retulatory functions of the old Atomic Energy Cossaission (AEC).
The research and development activities of the AEC were assuised by the Det artment of Energy.)
Tt : Regional Office in Glen Ellyn is responsible for inspection and er.forcement activities at NRC licensed f acilities in eight midwestern states. This encompasses 20 nuclear power plants now in operation, 2i plants licensed for construction or under licensing review, 12 operating te search reactors, four fuel facilities and approximately 3700 byproduct -
materials licenses - generally for medical, industrial, research or educational applications.
Mr. Xeppler joined the AIC 'in 1965 as a reactor inspector.
Prior to his present post as Regional Director, he was Chie'f of the Reactor Testin5 and Operations Branch in the AEC Headquarters in Rathesda, Maryland.
He is a 1936 graduate of LeMoyne College in New York Stata.
Mr. Rappler's experience in the nuclear field includes nine years with General Electric Ccapany, first in its Aircraft Nuclear Fropulsion Department and later in its Atenic Pouer Equipment Department.
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NUCLEAR REGULATORY CON 4ISSION
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BEFORE THE AT0 HIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COMPANY Docket Nos. 50-329 OM & OL
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50-330 OM & OL (Midland Plant, Units 1 and 2
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NRC STAFF TESTIMONY OF JAMES G. KEPPLER WITH RESPECT TO THE QUALITY ASSURANCE PROGRAM IMPLEMENTATION PRIOR TO DECEMBER 6, 1979 Q. 1.
Please state your name and position with the NRC.
A.
My nane is James G. Keppler.
I am Director of the U.S.
Nuclear Regulatory Commission's Region III (Chicago) Office and have held
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that position since September, 1973. A statement of my professional experience is attachment 1.
Q. 2.
Please summarize your past involvement with Consumers Power Coapany's implementation of quality assurance at the Midland site prior to December 6,1979.
l A.
In connection with our on-going assessnent of quality assurance implementation at Midland, ny staff developed a chronological listing of najor events and problems at the site which includes quality assurance deficiencies. These events and problems are set forth in attachment 2 (dated February 15,1979) and attachment 3 (dated October la,1979).
I was personally involved in deciding the regulatory actions l.
taken for the more significant problems described in attachments 2 and 3.
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Q. 3.
.When did you first learn of the apparent excessive settlement of the diese1' generator building?
A.
I!m not certain as to the actual date I personally became aware of the diesel generator building settlement problem; however, a written 10 CFR 50.55(e) notification was made to Region III by the licensee on September 25, 1973 concerning the problem.
I became personally involved with the problem following an NRC inspection on October 24-27, 1978 which was conducted as a followup to the licensee's report of the matter. This inspection was conducted by Eugene J.
Gallagher of my staff and is documented in attachment 2 of his t,estiniony._,
After being briefed on the inspection findings by Mr. Gallagher, I-directed my staff to conduct a comprehensive investigation into the matter to determine whether the problem had been reported to the NRC in a timely manner, to verify the degree of conformance with commitments made by the licensee in the Final Safety Analysis Report, and to assess the root cause(s) of the problem.
Q. 4.
Summarize the investigation findings and your role in the assessment of these findings.
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A.
The detailed investigation findings are discussed in Attachments 4 and 7 to the testimony of Eugene J. Gallagher.. Five Region III nanagement representatives (including myself) were briefed _ initially by the investigation team on February 16, 1979.
Based on those detailed i
investigation findings, it was our unanimous conclusion that the
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implementation of the quality assurance / quality control progran for assuring the proper soil foundation for the site was ineffective.
In addition, several of the commitments in the FSAR related to this work had not been adhered to. With respect to the reportability consideration, we agreed that the flRC had been informed of the problea in a timely manner once it had been identified. Based on this briefing, I instructed my staff to set up a meeting with Consumers Power Company to inform them of our investigation findings. Two meetings were held with the licensee relative to this investigation (February 23, 1979 and itarch 5, 1979).
I participated in both meetings. A summary report of these meetings (Attachments 4 and 5 to the testimony. of Eugene J. Gallagher) was provided to the licensee in my letter dated itarch 15, 1979.
Q. 5.
Surr.arize subsequent actions taken by you with respect to the soil settlement problem.
A.
Following the flRC investigation and related meetings with the licensee, Region III management reached the following conclusions:
(1) The technical issues associated with improperly conpacted i
soil needed review and evaluation by f1RR.
This conclusion resulted in my l
memorandum of liarch 12, 1979 to lir. Thornburg (attachment 5).
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(2) The deficiencies identified with respect to implementation l
of the quality assurance program were limited to soils work.
Since the original soil placement activities had been substantially completed, no attempt was made at this time to stop soil work.
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(3) Several commitments in the FSAR were incorrect and required review by NRR and ELD to determine whether they constituted naterial false statements.
This conclusion resulted in my memorandum of April 3, 1979 to Mr. Thorn' burg.
Q. 6.
What was the disposition of your recommendations and how does that action relate to the Order that was issued on Dececber 6, 19797 A.
On March 21, 1979 the NRC's Office of Nuclear Reactor Regulation issued a 10 CFR 50.54(f) request to Consumers Power Company requiring the licensee to provide additional information regarding the
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adequacy of the plant fill and the root causes and corrective actions to be taken regarding quality assurance deficiencies.
I participated in meetings at headquarters which led to the issuance of the December 6,1979 Order Modifying Construction Permits.
I supported issuance of that Order.
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,p JAMES G. KEPPLER - BIOGRAPHICAL INFORMATION James G. Kappler has been Regional Director of the Nuclear Regulatory Commission's Region III Office of Inspection and Enforcement since 1973.
(The Nuclear Regulatory Commission was formed in January 1975 to take over the regulatory functions of the old Atomic Energy Commission (AEC).
The research and development activities of the AEC were assumed by the i
Department of Energy.)
1 The Regional Office in Glen Ellyn is responsible for inspection and enforcement activities at NRC licensed facilities in eight midwestern states. This encompasses 20 nuclear power plants now in operation, 21 plants licensed for construction or under licensing review, 12 operating research reactors, four fuel facilities and approximately 3700 byproduct materials licenses -- generally for medical, industrial, research or educational applications.
Mr. Kappler joined the AEC in 1965 as a reactor inspector. Prior to i
his present post as Regional Director, he was Chief of the Reactor Testing and Operations Branch in the AEC Headquarters in Bethesda, Ma ryland.
He is a 1956 graduate of LeMoyne College in New York State.
Mr. Kappler's experience in the nuclear field includes nine years with General Electric Company, first in its Aircraf t Nuclear Propulsion Department and later in its Atomic Power Equipment Department.
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February 15, 1979 MEMORANDLH FOR:
H. D. Thornburg, Director, Division of Rasetor Construction Inspectica, II FROM:
James C. Esppler, Director
SUBJECT:
MIDLAND SLHMARY REFORT The attached report, which represents Region III's overall assessment of the Midland construction project to date from a regulatory standpoint, was discussed with you and representatives from your staff NRR, and OELD during our nee. ting at EQ's on February 6,1979. Durfag that nesting, it was concluded that this report should be prov.ded to OELD for transmittal to the I.icensing Board and the various parties to the Hea ring. As such, this information is being forwarded for your action.
We believe the meeting was quite useful in receiving feedback from the various NRC people involved relative to our position on the status of this facility.
Please contact as if you have any questions regarding this matter.
James G. Esppler Director
Attachment:
Midland Surasary Report l
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(R MIDLAND StT*ARY REPORT Facility Da:a
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Docket Nu=bers 329 and 50-330 Construction Permits
- CPPR-81 and CPPR-82 Per=its Issued
- December 14, 1972 Type Reactor
- Pk'R; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS Supplier
- Babcox & Wilcox Design / Constructor
- Bechtel Pcver Corporation Fuel Load Dates
- Unit 1,11/81; Unit 2,11/80 Status of construction - Unit 1, 52*, Unit 2, 56*; Engineering 80*
- Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Cher.ical Corporation, through appropriate isolation heat exchangers. Capability exists to alternate to Unit 2 for the steam source upon demand.
Chronolonical Listing of Major Events July 1970 start of Construction under exemption 9/29-30 &
Site inspection, four items of noncomplia'nce identified, 10/1/70 extensive review during CP hearings 1971 - 1972 Plant in acchballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 11/73 Inspection at site, four items of noncompliance identified (cadweld probles) precipitated the show Cause order r
12/29/73 Licensee answere show Cause order commits to improvements on QA program and QA/QC staff 12/3/73 Show cause Order issued suspending cadweldins operation 12/6-7/73, Special inspection conducted by A1II & EQ personnel 12/17/73 Show cause order modified to allow cadwelding based on inspection findings of 12/6-7/73 V
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12/5/75 CP reported that rebar spacing out of specification 50 locations in t' nit 2 containment 3/5 & 10/75 CF reported that 63 #6 rebar were either alijsing or
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misplaced in Auxiliary Building
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3/12/75 RIII held management meeting with CP I
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8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building 3/22/76 CPreportedthat32#6rebarwereoeittedikAuxiliary Building. A stop-vork order was issued by 2
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3/26/76 RIII inspector requested CP to inform RIII when stop-verk order to be lif ted and to investigate the cause and the extent of the problem. Additional rebar problems identified during site inspection 3/31/76 CP lif ted the stop-work order 4/19 thru RIII performed in-denth QA inspection at Midland 5/14/76 5/1'/76 RIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CF President, Vice President, and others.
6/7 & 8/76 RIII follow up meeting with CP management and discussed the CP 21 correction commitments 6/1-7/1/76 overall rebar omission reviewed by R. E. Shewmaker 7/28/76 CP stops concrete placement work when further rebar placement errors found by their overview program.
PN-III-76-52 issued by RIII 8/2/76 RIII recommends HQ notice of violation be issued 4/9 - 9/9/76 Pive week full-time RIII inspection conducted
'8/13/76 Notice issued 10/29/76 CP rssponded to HQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRA 2/28/77 Unit 2 bulge of containment liner discovered 4/19/77 Tendon sheath emissions of Unit I reported 4/29/77 IAL issued relative to tendon sheath placement errors 5/5/77 Management meeting at CP Corporate Office rilative to IAL regarding tendon sheath problem
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5/24-27/77 special inspection by RIII, RI and HQ personnel to determine adequacy of QA program implementation at Nddland site 7
6/75 - 7/77 Series of meetings and letters between CP add NRR on applicability of Regulatory Guides to Midland.
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Commitments by CP to the guides was responsive 7/24/78 Construction resident inspection assigned 8/21/78 Measurements by Bechtel indicate excessive settlement of Diesel Generator Building.8fficially reported to RIII on September 7, 1978 12/78 - 1/79 Special investigation / inspection conducted at Midland sites Bechtel Ann Arbor Engineering cffices and at CP corperate offices relative to Midland plant fill and Diesel Generator building settlement proble:
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j Selected Major Events Past Problees 1.
Cadvold splicina Preblem and Show Cause Order A routine inspection, conducted on November 6-3, 1973, as a result of intervenor information, identified eleven examples 4'
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of four noncompliance items relative to rebar Cadwelding h
[j operations. These items were suse.arised as (1) untrained Cadweld inspectore s (2) rejectable adwelds accepted by QC inspectors (3) records inadequate e establish cadwelds met
,4 requirements; and (4) inadequate procedures.
As a result, the licensee stopped work on cadweld operations on November 9,1973 which in turn stopped rebar installation $
The licensee agreed not to resume work until the NRC reviewed and accepted their corrective action. However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1973 RIII and NQ personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The show cause order was modified on December 17, 1973, allowiat resumption of Cadwelding operations based on
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the inspectica results.
The licensee answered the Show cause Order en December 29, 1973, committing to revise and improve the QA manuals and procedures and make QA/QC personnel changes.
prehearing conferences were held en March 28 and May 30 1974, 6
and the hearing began on July 16, 1974. On September 25, 1974, the Nearing Board found that the licensee was implementing its QA program in soap 11ance with regulations and that sonstruction should not be stepped.
2.
Rabar % sion/ placements Irrors Leadina to IAL Initial identification and report of rebar sencenternanses occurred during as NRC inspection eenducted on December 11-13, 1974. The liceasse inferned the inspeeter that an audit, had identified robar specias problems at elevations 642' - 7" to 632' - 9" of Unit 2 centstament. This item was subsequently reported per 10 CFR 50.SS(e) and wee identified as a item of t
seacompliance is report Nos. 50-329/74-11 and 30-330/74-11.
Additional'rebar deviations and estestens were identified in March and August 1975 and in April, May and June 1974. !aspection 1
, report Nos. 30-329/74-04 and 50-330/76-04 identified five l
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nessempliance items regarding reinfersement steel deficiencies.
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p Licensee response dated June 18. 1976 listed 21 separate items (commitments) for corrective action. A June 24,1976 letter provided a plan of action schedule for implementing the 21 itema. The licensee committed not to reense c' acrete p
pla:eeent work until the items addressed in licenbee's June 24 7
letter were resolved or implemented. This commitment was docueented in a RI!! letter to the licensee dated June 25, 1976.
Although not stamped as an IAL in-house memos referred to it as such.
l Rebar installation and concrete placerent activities were resu=ed in early July 1976, following completion of the itama and verification by RIII.
Additional action taken is as follows:
a.
By the NRC (1) Assignment of an inspector full-time on site for 4
five weeks to observe civil work in progress (2)
It management meetings with the licensee at their corporate of fices (3)
Inspection and evaluation by Headquarter personnel b.
Iv the Licensee (1) June 18.1976 letter censitting to 2.1 itees of corrective action (2) Establishment of an ov'erview inspection program to
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provide 100: reinspection of embedsents by the licensee following acceptance by the contractor QC personnel c.
By the Contractor (1) personnel changes and retraining of personnel (2) prepared technical evaluation for acceptability of each identified construction deficiency (3) taprovement in their QA/QC program coverage of civil work (this was imposed by the licensee) 3.
Tendon Sheath placement Errors and Resultian f---diate Act(gg Letter (IAL) t
" On April it.1977, the licensee reported, as a Part 30, Section 30.55(e) ites, the inadvertent emission of two heep tenden g,,,
sheaths free a Unit 1 sentainment concrete placement at 6
elevation 703' - 7".
The te'ndon sheaths were, for the most part. located at an elevation in the next higher 4encrete placement lift, except that they were diverted tgf the lower placesent lift to pass under a steam line penetr4 tion and it was where they vere emitted. Failure to rely %n the 1
proper source documents by construction and inspection personnel, contributed to the emission.
An IA! was issued to the licensee on April 29, 1977 which spelled out six licensee couritments for correction which included:
(1) repairs and cause corrective action (2) expansion of the licensee's QC over view proprses (3) revisions l
to procedures and training of construction and inspection r
l personnel.
A special QA program inspection was conducted in early Pay 1977.
The inspection test was made up of personnel fror. Rt. R111, and HQ. Although five items of noncompliance were identified. it was the concensous of the inspectors that the licensee's program was an acceptable program and that the Midland i
construction activities were comparable to most other construction projects.
The licensee issued its final report en August 12, 1977. Final i
review on site was conducted and documented in report No.
30-329/77-04.
i Current problems, 1.
plant Till - Diesel Generator Buildina lettlement The licensee informed the R111 of fice en September 8,197f.
et per requirements of 10 CFR 30.35(e) that sestlement of the i
diesel generater foundations and structures were greater than expected.
Fill asterial in this area was placed between 1975 and 1977, r
with cemetruction starting en diesel generator building in i
mid-1977. Filling of the seeling pond began la early 1978 with the spring run-off water. Over the year the water level has increased apprentaately 21 feet and in turn increasing the site sound water level.
It is not known at this time what effect (if any) the higher site ground water level has had on the plan fill and excessive settlement of the Diesel Generator Building.
It is interesting to note however, that initially the pSAR indicated se underdrain eyesen would be installed te maintain the ground water at its asemal (pre pend) level but that it later was deleted.
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The NRC activities, to date, include:
a.
Transfer of lead responsibility to NRR from 3E by me=o dated November 17, 1978 7
b.
Site meeting on December 3-4, 1978, between 10Ut, II, Consumers Power and Bechtel to discuss the plant fill problem and proposed corrective action relative to the Diesel Generator Building settlement c.
RIII conducted an investigation / inspection relative to the plant fill and Diesel Generator Building settlement The Constructor / Designer activities include:
a.
Issued NCR-1482 (August 21, 1978) b.
Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978) c.
Prepared a proposed corrective action option regarding placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel generater building sub soils Preliminary review of the results of the RIII investigation /
inspection into the plant fill / Diesel Generator Building settle =ent problem indicate many events occurred between late 1973 and early 1978 which should have alerted Bechtel and the licensee to the pending problem. These events included nonconformance reports, audit findings, field me=os to engiaeering and problema with the administr'ation building fill which caused modification and replacement of the already poured footing and replacement of the fill material with lean concrete.
i 2.
Inspection and Quality Documentation to Establish Acceptability of Equipment This problem consists of two parts and has just recently been identified by RIII inspectors relative to Midland. The scope and depth of the problem has not been determined.
i The first part concerns the adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes that the equipment meets specification and environmental requirements. The licensee, o
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d on Nove=ber 13, 1978, issued a construction deficiency report (10 CTR 50.55(e)) relative to this matter. Whether the raper 1_...
was triggered by RIII inspector inquiriesfor by I.E Circular or Bulletin is not known. An interim report date2 November 28, 1978 was received and stated Consumers Power was pursuing this 7
matter not only for Bechtel procured equipment but also for NSS supplied equipment.
The second part of the problem concerns the adequacy of equipment acceptance inspection by Bechtel shop inspectors.
Examples of this problem include:
(1) Decay Heat Removal Pumps released by the shop inspector and shipped to the site with one pump assenbled backwards, (2) electrical penetrations inspected and released by the shop inspector for ship =ent to the site. Site inspections to date indicate about 25* of the vender wire ter=inations were improperly cri= ped.
Inspection Historv The construction inspection program for Midland Units 1 and 2 is approximately 50* complete. This is consistent with status of construction of the two units.
(Unit 1 - 52%; Unit 2 - 56%) In terms of required inspection procedures approxi=ately 25 have been completed, 33 are in progress and 36 have not been initiated.
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The routine inspection program has not identified an unusual number of enforcement items. Of the selected major events described above, only one is directly attributable to RIII enforcement activity (Cadweld splicing). The other were identified by the licensee an.d reported through the deficiency report system (50.55(e)). The Midland data for 1976 - 78 is tabulated below.
Number of Nur.ber of Inspector Hours Year Noncompliances
_ Inspections On Site 1976 14 -
9 646 1977 5
12 648 1978 11 18 706 A resident inspector was assigned to the Midland site in July 1978.
The on site inspection hours shown above does not include his inspection i
time.
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The licensee's QA program has repeatedly been subject to in-depth review
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by II inspectors. Included are:
1.
July 23-26 and August 8-10, 1973, inspection report No;e. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the impfementation of the Consumers Power Company's QA manual and Bechtel l
Corporation's QA program for design activities at the Bechtel Ann l
Arbor office. The identified concerns were reported as discrepancies-
! V relative to the Part 50, Appendix B, criteria requirements.
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Septenbar 10-11, 1973, report Nos. 50-329/73-08 and 50-330/73-08:
A detailed review of the Bechtel Power Corporation QA program for Midland was performed. Noncompliances involving thre( separate Appendix 5 criteria with five different examples, werd identified.
3 3.
February 6-7, 1974, reports No. 50-329/74-03 and 50-330/74-03: A followup inspection at the licensee's corporate office, relative to the items identified during the September 1973 inspection (above) along with other followup.
4.
. June 16-17, 1975, report Nos. 50-329/75-05 and 50-330/75-05: Special inspection conducted at the licensee's corporate office to review the new corporate QA program manual.
5.
August 9 through September 9,1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding QA program implementation on site primarily for robar installation and other civil engineering work.
6.
May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: Special inspection conducted at the site by RIII, IE and RI personnel to examine the QA program implementation on site by Consumers i
Power Company and by Bechtel Corporation. Although five examples of noncompliance to Appendix 3. Critation V, were identified, the consensus of the inspectors involved was thtt the program and its implementation for Midland was considered to be adequate.
/.1though the licensee's Quality Assurance program has under gone a nucher of revisions to strengthen its provisions, no current concern exist regarding its adequacy. Their Topical QA Plan has been ' reviewed and accepted by NRR through revision 7.
Implementation of the program has been and continues to be subject to further review with the mid-construction program review presently scheduled for March or April 1979.
Censumers Power Company expanded their QA/QC auditing and surveillance coverage to provide extensive overview inspection coverage. This began in 1975 with a commitment early in their experience with robar installation problems and was further committed by the licensee in his letter of June 18, 1976, responding to report Nos. 50-329/76-04 and 50-330/76-04.
t This overview inspection activity by the licensee has been very effective l
as a supplement to the constructor's own program. Currently, this program is functioning across all significant activities at the site.
Enforcement History l
l Approximately 6 months after restart of construction activities (11 months after CP issuance) an inspection identified four noncompliance items regarding cadwelding activities. This resulted in a show gause order being issued on December ),1973. This enforcement action was aired publicly"during hearings held by the Atomic Safety Licensing Board
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in May 1974. The hearing board issued its decision in September 1974 1
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that concluded that construction could proceed with adequate assurance of quality.
Identification of reinforcing bar problems began in December of 1974 with the licensee reporting improper spacing of rebar in the Unii 2 contain=ent
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wall. Further reinforcing bar spacing and/or omission of rebar was identified in August 1975 and again in May 1976 with the citations of 5 nonce =pliances in an inspection report. An IE:HQ notice of violation was issued regarding the citations in addition to the licensee issuing a stop work order. The licensee issued a response letter dated June 18, 1976 com=itting to 21 items of corrective action. A Bechtel prepared technical assessnent for each instance of rebar deficiency was submitted to and review by IE:HQ who concluded that the structures involved will satisfy the SAR criteria and that the function of these structures will be =aintained during all design conditions. The RIII office of NRC performed a special five week inspection to assess the corrective action implementation without further ettation.
The licensee reported that two hoop tendon sheaths were omitted in concrete place =ents of Unit 2 containment wall in April 1977. An I==ediate Action Letter was issued to the licensee on April 29, 1977 listing six items of licensee commitments to be completed. A special inspection was performed on May 24-27, 1977 with four NRC inspectors
,~x (1-HQ, 1-RI, and 2-RIII). Although five items of noncompliance were
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identified, it was the consensus of the inspectors that the QA/QC
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progra: in effect was adequate. The constructors nonconformance report provided an alternate method of installation for the tendon sheaths that was accepted.
The RIII office of inspection and enforcement instituted an augmented on site inspection coverage program during 1974, this prograc has.
continued in effect ever since and is still in effect. It is noted that the noncompliance history with this program is essentially the same as the history of other RIII facilities with a comparable status of
- construction. Further on site inspection augmentations was accomplished kith the assignment of a full time resident inspector in August,1978.
The noncompliance history for the Midland Project is provided in the i
following table.
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O ENTORCENINT ACTIONS Noncompliances Criteria (10CFR50AppejdixB)
Year
- Total
( ) Nunber of Occurtances 1970 4
V, X, XI, XVI 1971-1972 0
Construction haulted pending CP 1973 9
II V(5) XIII, XV, XVII 1974 3
V(2) X*I 1975 0
1976 10 V(4)
X, XII, XV, XVI, XVII, XVIII 1977 5
V(5) 10 CTR 50.55(e) item 1978 11 V(4) VI(2), VII, IX(3), XVI
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Criteria II QA Progran V
Instructions Procedures Drawing Control k'ork "
VI Document Control VII Control of Purchased Material IX Control of Special Processes X
Inspection XII Control Measuring - Test Equipment l
XIII Handling - Storage l
l XV Nonconforming Parts I
IVI Corrective Actions L
IVII QA Records XVIII
' Audits
.y 1
/2.
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Su=carv and Conclusiens Since the start of construction Midland has experienced somy significant problems resulting in enforcement action. In evaluating these problems they have occurred in clumps:
(1) in September 1970 relatiye to improper placement, sa=pling and testing of concrete and failure of DA/QC to act on identified deficiencias; (2) in September 1973 relative to drawing control and lack of or inadequate procedures for control of design and procure =ent activities at the Bechtel Engineering offices: (3) in Ncvember 1973 relative to inadequate training, procedures and inspection of cadweld activities; (4) in April, May and June 1976 resulting fro:
a series of RIII in-depth QA inspections and meetings to identify underlying causes of weakness in the Midland (A program implementation relative to embed =ents.
(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and docu=entation, all primarily concerned with installation of reinforcenent steel); (5) in April 1977 relative to tendon sheath omissions; and (6) in August 1976 concerning plant soil foundations and excessive settlecent of the Diesel Generator Building.
Fellowing each of these problee periods (excluding the last which is still under investigation), the licensee hastaen responsive and has
'taken extensive action to evaluate and correct the problem and to up-grade his QA program and QA/QC staff. The most effective of these licensee actions has been an overview program which has been steadly s
expanded to cover almost all safety related activities.
4 The evaluation both by the licensee and IE of the structures and equipment affected by these problems (again except the last) has established that they fully meet design requirements.
Since 1974 these problems have either been identified by the licensee's quality program or provided direction to our inspectors.
Looking at the underlying causes of these problems two commen threads emerge:
(1) Consumers Power historically has tended to over rely on Bechtel, and (2) insensitivity on the part of both Bechtel and Consumers Power to recognize the significance of isolated events or failure to adequately evaluate possible generic application of these events either of which would have led to early identification and avoidance of the l
problem including the last on plant fill and diesel generator building sectiement.
Notwithstanding the above, it is our conclusion that the problems experienced are not indicative of a broadbreakdown in the overall quality assurance program. Admittedly, deficiencies have occurred which should have been identified earlier by quality control personnel, but the licensee's program has been effective in the ultimate identification and subsequent correction of these deficiencies. While we candet dismiss the possibilicy that problems 'may have gone undetected by the licensee's -
overall quality assurance program, our inspection program has not identified significant problems overlooked by the licensee --- and this inspection (s_,-
effort has utilized many different inspectors.
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The RIII project inspectors believe that continuation of:
(1) resident site coverage, (2) the licensee overview program including,its recent expansion into engineering design / review activities, and (3) a continuing inspectionprogrambyregionalinspectorswillprovideadejusteassurance that construction will be performed in accordance with requirements and that l
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any significant errors and deficiencies will-be identified and corrected.
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- UNITED STATES NUCLEAR REGULATORY COMMISSION yb
- '. Q;,o f, j i
7se noostvtLT noAo RE GION ill
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stru attvu. LLimois sets 7 m
I October 18, 1979 Is 2 MEMORANDUM FOR:
R. C. Knop R. Cook E
D. W. Hayes T. Vandet C
D. H. Danielson F. Jablonski K. Naidu E. Lee G. Maxwell G. Gallagher W. Hansen K. Ward P. Barrett I. Yin FROM:
- 8. Fioretti, Chief, Reactor Construction and Engineering Support Branch
SUBJECT:
MIDLAND CONSTRUCTION STATUS REPORT AS OF OCTOBER 1, 1979 N,
The attached report was finalized based on your feedback requested in a
my memo of October 5,1979. If you still feel adjustments are necessary please contact me.
If you consider the report characterizes your 3
current assessment of the Midland project, please coricur and pass it along promptly.
E. Fiorelli, Chief Reactor Construction and
Enclosure:
As stated Engineering Support Branch cc:
J. E. Keppler
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-MIDLAND
SUMMARY
REPORT UPDATE i
l Facility Data Docket Number 329 and 50-330 j
Construction Permits
- CPPR-81 and CPPR-82 Permits Issued-
- December 14, 1972 Type Reactor
- PWR; Unit 1, 492 MWe*; Unit 2, 818 MWe NSSS
- Babcock and Wilcox Design / Constructor
- Bechtel Power Corporation Fuel Load Dates
- Unit 1, 4/82; Unit 2,11/81 4
Status of Construction
- Unit 1, 54%; Unit 2, 61%; Engineering 82%
- Approximately one-half the steam production for Unit 1 is dedicated, by contract, to be supplied to Dow Chemical Corporation, through appropriate isolation heat exchangers.
- - s Chronological Listing of Major Events
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July 1970 start of construction under exemption 9/29-30 &
Site inspection, four items of noncompliance identified, 10/1/70 extensive review during CP hearings 1971 - 1972
' Plant in mothballs pending CP 12/14/72 CP issued 9/73 Inspection at Bechtel Ann Arbor offices, five items of noncompliance identified 4
31/73 Inspection at site, four items of noncompliance identified (cadweld probles) precipitated the Show Cause Order 12/29/73 Licensee answers Show Cause Order consits to improvements on GA program and GA/QC staff 12/3/73 Show Cause order issued suspending cadwelding operation i
12/6-7/73 Special inspection conducted by RIII and:He personnet J2/37/73 Show cause order modified to allow cadwelding based on inspection findings of 12/6-7/73 v
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12/5/75 CP. reported that rebar spacing out of specification 50
{o locations in Unit 2 containment j
3/5 & 10/75 CP reported that 63 #6 rebar were either missing or misplaced in Auxiliary Building r
1 3/12/75 RIII held management meeting with CP :.
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8/21/75 CP reported that 42 sets of #6 tie bars were missing in Auxiliary Building
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i 3/22/76 CP reported that 32 #8 rebar were omitted in Auxiliary Building. A stop-vork order was issued by. CP E
3/26/76 RIII inspector requested CP to inform RIII when stop-vork order to be lifted and to investigate the 'cause and the extent of the problem. Additional rebar problems identified during site inspection by NRC 3/31/76 CP lifted the stop-vork order 4/19 thru RIII performed in-depth QA inspection at Midland 5/14/76 5/14/76 RIII management discussed inspection findings with site personnel 5/20/76 RIII management meeting with CF President, Vice President, and others.
l 6/7 r, 8/76 RIII follow up meeting with CP management and discussed l
the CP 21 correction cot =1tments 6/1-7/1/76 Overall rebar omission reviewed by R. E. Shevnaker m
q /28/76,
CP stops concrete placement work when further rebar 7
placement errors found by their overview program.
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FN-III-76-52 issued by RIII 8/2/76 RIII recomands BQ notice of violation be issued g/9 - 9/9/76 Tive week full-time RIII inspection conducted
~/13/76 Notice issued 8
10/29/76 CP responded to EQ Notice of Violations 12/10/76 CP revised Midland QA program accepted by NRR
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2/28/77 Unit 2 bulge of containment liner discovered by Licensee
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4/19/77 Tendon sheath omissions of Unit i reported 4/29'77 IAL issued relative to tendon sheath placement errors
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5/5/I.{
Management meeting at CP Corporate Office: relative to IAL regarding tendon sheath problem
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special inspection by RIII, RI and HQ personnel to 5/24/77 determine adequacy of SA program implementation at Midland site.
j 6/75 - 7/77 Series of meetings and Letters between CP and NRR on applicability of Regulatory Guides to Midland.
Commitments by CP to the guides was responsive.
7/24/78 Construction resident inspection assigned.
8/21/78 Measurements by BechteL indicate excessive settlement of Diesel Generator Building. Officially reported to RIII on September 7,1978.
12/78 - 1/79 special investigation / inspection conducted at Midland sites,Bechtel Ann Arbor Engineering offices and at CP corporate offices relative to Midland plant fill and Diesel Generator building settlement probles.
2/7/79 Corporate meeting between RIII and CPC to discuss project status and future inspection activities. CPC informed construction performance on track with exception of dieset/ fill problem.
i 2/23/79 Meeting held in RIII with ' Consumers Power to discuss diesel generator building and plant area fitt problems.
3/5/79 Meeting held with CPC to discuss diesel generator building and plant area fitt problems.
3/21 /79 10 CFR 50.54 request for information regarding plant i
t 5/5/79 Congressman Albosta and aides visited Midland site to discuss TMI effect on Midland.
5/8-11/79 Mid-eA inspection conducted.
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m' jl Significant Maior Events Past Problems 1.
Cadweld Solicino Problem and Show Cause Order _
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A routine inspection, conducted on November 6-8,1973, as a 7
result of intervenor information, identified eleven examples of four noncompliance items relative to rebar Cadwelding operations. These items were summarized as:
(1) untrained Cadweld inspectors; (2) rejectable Cadwelds accepted by GC inspectors; (3) records inadequate to establish cadwelds met requirements; and (4) inadequate procedures.
As a result, the licensee stopped work on cadweld operations on November 9,1973 which in turn stopped rebar installation and concrete placement work. The Licensee agreed not to resume work until the NRC reviewed and accepted their corrective action.
However, Show Cause Order was issued on December 3,1973, suspending Cadwelding operations. On December 6-7, 1 973, RIII and He personnel conducted a special inspection and determined that construction activity could be resumed in a manner consistent with quality criteria. The Show cause Order was modified on December 17, 1973, allowing resumption of Cadwelding operations
~s based on the inspection results.
The Licensee answered the Show cause order on Dece&ber 29, 1973, committing to revise and improve the GA manuals and procedures and make EA/QC personnel changes.
Prehearing conferences were held on March 28 and May 30, 1974, and the hearing began on July 16, 1974.
On September 25, 1974, the Hearing Board found that the Licensee was implementing its SA program in compliance with regulations and that construction should not be stopped.
1 2.
_Rebar omission / Placements Errors Leadina to IAL Initial identification and report of rebar nonconformances occurred during an NRC inspection conducted on December 11-13, 1974.
l The Licensee informed the inspector that an audit, had identified rebar spacing problems at elevations 642' - 7" to 652' - 9" of Unit I containment. This item was subsequently reported per 1
10 CFR 50.55(e) and was identified as a item of noncompliance in reports Nos. 50-329/74-11 and 50-330/74-11.
Additional rebar deviations and omissions were identified in March and August 1975 and in April, May and June T976.
Inspection report Nos. 50-329/76-04 and 50-330/76-04 identified five noncompliance items regarding reinforcement steel deficiencies.
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,,/~'N Licensee response dated June 18, 1976, Listed 21 separate items (commitment s) for corrective action. A June 24,1976 Letter
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provided a plan of action schedule for implementing the 21 items.
The Licensee suspended concrete placement work until the items addressed in Licensee's June 24 Letter were resolveO or implemented.
This commitment was documented in a RIII letter to ithe Licensee dated June 25,1976. Although not stamped as an Int, in-house menos referred to it as such.
Rebar ' installation and concrete placement activities were satisf actoriLy resumed in early July 1976, following completion of the items and verification by RIII.
Additional action taken is as follows:
a.
By the NRC (1) Assignment of an inspector full-time onsite for five weeks to observe civil work in progress.
(2)
IE management meetings with the Licensee at their corporate offices C3)
Inspection and evaluation by Headquarters personnel b.
By the Licensee (1)
June 18,1976 letter committing to 21 items of corrective action.
(2)
Establishment of an overview inspection' program to provide 100% reinspection of embedments by the Licensee following acceptance by the contractor GC personnel.
c.
By the Contractor (1) Personnel changes and retraining of personnel.
(2) Prepared technical evaluation for acceptability of each identified construction deficiency.
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C3)
Improvement in their aA/QC program coverage of civil work-l (this was imposed by the Licensee).
l 3.
Tendon Sheath Placement E:.ars and Resultino Immediate Action Letter (IAL) on April 19, 1977, the licensee reported, as a Part 50, Section 50.55(e) ites, the. inadvertent omission of two hoop tendon sheaths
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1-from a Unit 1 containment concrete placement at elevation
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h 703' - 7" due to having already poured concrete in an area where the tendons were to be directed under a steam Line. The tendons were subsequently rerouted in the next higher conc 6ete lift.
An IAL was issued to the Licensee on April 29,197, which spelled out six Licensee commitments for correction which included:
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(1) repairs and cause corrective action; (2) expansion of the Licensee's GC overview program; (3) revisions to procedures and training of construction and inspection personnel.
A special GA program inspection was conducted in early May 1977.
The inspection team was made up of personnel from RI, RIII and HQ.
Although five items of noncompliance were identified, it was the concensus of the inspectors that the Licensee's program was an acceptable program.
The Licensee issued it's final report on August 12, 1977.
Final review onsite uas conducted and documented in report No. 50-329/77-08.
j Current Problems i
1.
The Licensee informed the RIII office on September 8,1978, l
per requirements of 10 CFR 50.55(e) that settlement of the diesel generator foundations and structures were greater than expected.
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FILL material in this area was placed between 1975 and 1977, with construction starting on the diesel generator building in mid-1977.
Review of the results of the RIII investigation / inspection into the plant fill / Diesel Generator Building settlement problem indicate many events occurred between Late 1973 and early 1978 which should have alerted Bechtet and the Licensee to the pending problem. These events included nonconformance reports, audit findings, field menos to engineering and problems with the administration building fitt which caused modification and replacement of the already poured footing and replacement of the fill material with Lean concrete.
Causes of-the macassive settlement taciudas (1) inadeounte. placement method unou'alified compaction equipment and excessive lift thickness; (2) inadequate testing of the seit material; C3) inadequate et inspection procedures; (4) unoualified quality control inspectors.
and field engineers; (5) over reliance on inadequate test results.
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' 'g The proposed remedial work and corrective action are as follows:
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(1)
Diesel Generator Building apply surcharge load in and around building to preconsolidate the foundati6n material.
Continue to monitor soit response to predict Lbng-tera settlement.
I (2) Service Water Pump Structure - Install piles to hard glacial tiLL to support that portion of the structure i
fdunded on plant fill material.
C3) Tank Farm - FILL has been determined to be suitable for the support of Borated Water Storage Tanks. Tanks are to be constructed and hydro tested while monitoring soit response to confirm support of structures.
(4) Diesel oil Tanks - No remedial measure; backfill is considered adequate.
(5) Underground Facilities - No remedial work is anticipated with regards to buried piping.
(6) Auxiliary Building and F. W. Isolation Valve Pits - Installed a number of caissons to glacial tiLL material and replace soit material with concrete material under valve pits.
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(7)
Dewatering System - Installed site dewatering system to provide assurance against soit liquidification during a seismic event The above remedial measures were proposed to the NRC staff on July 18,1979. No endorsement of the proposed actions have been issued to the Licensee to date. The Licensee is proceeding with the above plans.
The NRC activities, to date, include:
a.
Lead technical responsibility and program review was transferred to NRR from IE by meno dated November 17, 1978.
l b.
Site meeting on December 3-4, 1 978, between NRR, IE, Consumers Power and Bechtel to discuss the plant fill problem'and proposed corrective action related to the Diesel Generator Building settlement.
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c.
RIII conducted an investigation / inspection relative to the
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plant fill and Diesel Generator Building settlement.
Findings are contained in Report 50-329/78-20; 330/78-20 dated March 1979.
d.
NRC/ Consumers Power Company /Sechtel meetings held in RIII office to discuss finding of investigation / inspection of site settlement (February 23,1979 'and March 5,1979).
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NRC issue cf 10 CFR SD.54(f) regarding plant fill dated March 21, 1979.
f.
Several inspections of Midland site settlement have been performed.
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The Constructor / Designer activities include:
a.
Issued NCR-1482 (August 21, 1978)
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b.
Issued Management Corrective Action Report (MCAR) No. 24 (September 7,1978) c.
Prepared a proposed corrective action option regarding placement of sand overburden surcharge to accelerate and achieve proper compaction of diesel generator building sub soils.
d.
Issued 10 CFR 50.55(e) interim report number 1 dated September 29, 1978.
i e.
Issued interim report No. 2 dated November 7,1978.
f.
Issued interim report No. 3 dated June 5,1979.
g.
Issued interim report No. 4 dated Fetruary 23, 1979 h.
Issued interim report No. 5 dated April 30, 1979 1.
Responded to NRC 10 CFR 50.54Cf) request for information onsite settlement dated April 24, 1979. Subsequent revision 1 dated May 31,1979, revision 2 dated July 9,1979 and revision 3 dated September 13, 1979.
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- j. Meeting with NRC to discuss site settlement causes and proposed resolution and corrective action taken dated July 18,1979.
Information discussed at this meeting is documented in Letter from CPCo to NRC dated August 10, 1979.
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Issued interim report No. 6 dated August 10, 1979 L.
Issued interie report No. 7 dated September 5,1979
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Review of Guality Documentation to Establish Acceptability of Equipment The adequacy of engineering evaluation of quality documentation (test reports, etc.) to determine if the documentation establishes l
that the equipment meets specification and environmental: requirements is of concern. The Licensee, on November 13, 1978, issued a construction deficiency report (10 CFR 50.55(e)) relative to this matter. An interim report dated November 18, 1978 was received
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l-and stated Consumers Power was pursuing this matter not only for
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Bechtel procured equipment but also for NSS supplied equipment.
3.
Source Inspection to Confira Conformance to Specifications
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The adequacy of equipment acceptance inspection by Bech el shop inspectors has been the subject of several noncomplianceh.anconformance report Consumers Power has put heavy reliance on the creditability of the Bechtet vendor inspection program to insure that only quality equipment ha.s been sent to the site. However, the referenced nonconformance reports raise questions that the Bechtet vendor i
inspection program may not be effectively working in aLL disciplines for supplied equipment.
Some significant examples are as follows:
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(1) Decay heat removat pump being received with inadequate radiography.
. The pumps were returned to the vendor for re radiography and repair. The pumps were returned to the site with one pump assembled backwatds. This pump was again shipped to the vendor for reassembly.
CPCo witnessed a portion of this reassembly and noted in their audit that some questionable techniques for establishing reference geometry were employed by the vendor.
The pumps had been shop inspected by BechteL.
/ C2) Containment personnel air Lock hatches were received and installed i
with vendor supplied structural weld geometry which does not agree with manufacturing drawings. The personnel air Lock doors
,f had been vendor inspected.
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s (3) Containment electrical penetrations were received and installed with approximately 25% of the vendor installed terminations showing blatant signs of inadequate crimping. These penetrations were shop inspected by 3 or 4 Bechtet supplier quality representatives (vendor inspectors).
(4) 350 MCM, 3 phase power cable was received and installed in some safety related circuits with water being esitted from one phase.
l (5) A primary coolant pump casing was received and installed without aLL the threads in one casing stud hole being intact. The casings were vendor inspected by both BechteL and 88W.
Additional IE inspections wiLL be conducted to determine if CP has thoroughly completed an overview of the Bechtet shop inspector's function and that equipment already purchased has been reviewed to confirm it meets requirements.
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"e" L.ist Equipment l
, There have been instances wherein safety related construction components and their installation activities have not-t:= 'dentified on the "G" List.
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This shortcoming could have affected the quality of work performed i
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during fabrication due to the absence of ouality controls identified i
with "4" list items.
Examples of non "Q" List activities identified which should be "Q" Listed include:
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Cable Trays Components of Heating and Ventilation System The Licensee wiLL be advised to review past as weLL as future constructi.on activities to confirm that they were property defined as "Q" List work or components.
i 5.
Management controts Throughout the construction period CPCo has identified some of a.
the problems that have occurred and reported them under the require-ments of 10 CFR 50.55(e).
Management has demonstrated an openness i
by promptly identifying these problems. However, CPCo has on repeated occasions not reviewed problems to the depth required for full and timely r esolution.
Examples are:
Rebar omissions (1974)
Tendon sheath location error (1977)
Diesel generator building settlement (1978)
Containment personnet access hatches (1978)
In each of the cases listed above the NRC in it's investigation has
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determined that the problem was of greater significance than first reported or the problem was more generic than identified by CPCo.
This incomplete wringing out of problems identified has been discussed with CPCo on numerous occasions in connection with CPCo's management of the Midland project.
There have been many cases wherein nonconformances have been identified, b.
reviewed and accepted "as is."
The extent of review given by the Licensee prior to resolving problems is currently in progress.
In one case dealing with the repair of airlock hatches, a determination was made that an incomplete engineering review was given the matter.
Inspection History
. The construction inspection program for Midland Units 1 and 2 is approximately
" 60% complete.
This is consistent with status of construction of the tuo units.
(Unit 1 - 54%; unit 2 - 61%).
The Licensee's GA program has repentedly been subject to in-depth review by IE inspectors.
The following highlight these inspections.
1.
July 23-26,and August 8,-10, 1973, inspection report Nos. 50-329/73-06 and 50-330/73-06: A detailed review was conducted relative to the implementation of the Consumers Power Company's GA manual and Bechtel
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Corporation's EA program for design activities at the Bechtel Ann V
Arbor office.
The identified concerns were reported as discrepancies i
relative to the Part 50, Appendix 3, criteria requirements.
O 2.
September 10-11,1973 report Nos. 50-329/73-08 and 50-330/73-08:
A detailed review of the Bechtel Power Corporation GA program for Midland was performed.
Noncompliances involving three separate Appendix B criteria with five different examples, were fdentified.
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. 3.
February 6-7, 1974, report Nos. 50-329/74-03 and 50-33044-03: A fotLowup inspection at the Licensee's corporate office, relative to i
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the items identified during the September 1973 inspection (above) along with other followup.
4.
June 16-17,1975, report Nos. 50-329/75-05 and 50-330/75-05:
special inspection conducted at the Licensee's corporate office to review the new corporate GA program manual.
5.
August 9 through September 9,1976, report Nos. 50-329/76-08 and 50-330/76-08: Special five-week inspection regarding RA program implementation onsite primarily for rebar installation and other j
civit engineering work.
6.
May 24-27, 1977, report Nos. 50-329/77-05 and 50-330/77-08: special inspection conducted at the site by RIII, IE AND RI personnel to examine the SA program implementation onsite by Consumers Power Company and by Bechtel Corporation. Although five examples of noncompliance to Appendix 8, Criterion V, were identified, the consensus
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of the inspectors involved was that the program and its implementation for Midland was considered to be adequate.
7.
May 8-11,1979, a mid construction GA inspection covering purchase control and inspection of received materials design control and site auditing and surveillance activities was conducted by a team of l
inspectors. While some items wiLL require resolution, it was concluded the program was adequate.
The Licensee's Quality Assurance program has undergone a number of revisions to strengthen it's provisions. The company has expanded it's RA/GC auditing and surveillance coverage to provide extensive overview inspection coverage. This was done in 1975 with a commitment early in their experience with rebar installation problems and was further c'ommitted by the Licensee in his Letter of June 18, 1976, responding to report Nos. 50-329/ 76-04 and 50-330/76-04.. This overview inspection activity by the Licensee has been a positive supplement to the constructor's own program, however, currently our inspectors perceive the overview
. activities cover a smaLL percentage of the work in some disciplines.
'This has been brought to the licensee's attention who has responded with a revised overview plan. RIII inspectors are reviewing the plan as weLL as determining it's effectiveness through observation of construction work.
A specific area brought to the attention of the Licensee was the Lack of overview in the instrumentation. installation area. The Licensee has responded to this matter with increased staff and this item is under i
"'N review by RIII inspectors.
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- O The RIII office of inspection and enforcement instituted an augmented
- k j onsite inspection coverage program during 1974, this program has continued 1
in effect until the installation of the resident inspector ip July 1978.
Enforcement History I
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- a.
Noncompliance Statistics Number of Number of Inspector Hours Year Noncompliances Inspections Onsite 1976 14 9
646 1977 5
12 648 1978 18 23 1180
- 1979 to date 7
18 429 l
A resident inspector was assigned to the Midland site in July 1978. The onsite inspection hours shown above does not include his inspection time.
- Through August 1979 b.
An investigation of the current soils placement / diesel generator building s,ettlement problem has revealed the existence of a material false statement. Issuance of a Civil Penalty is. currently being
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contemplated.
Summary and Conclusions Since the start of construction Midland has experienced some significant problems resulting in enforcement action. These actions are related (1) to improper placement, sampling and testing of concrete and failure of SA/ec to act on identified deficiencies in September 1970; (2) to drawing control and lack of or inadequate procedures for control of design and procurement activities at the Bechtel Engineering offices in September 1973; (3) to inadequate training, procedures and inspection of cadweld activities in November 1973; (4) to a series of RIII in-depth SA inspections and meetings which identified underlying causes of weakness j
in the Midland GA program implementation relative to embedments in April, May and June 1976.
(The noncompliance items identified involved inadequate quality inspection, corrective action, procedures and documentation, aLL primarily concerned with installation of reinforcement steet); (5)
.to tendon sheath omissions in April 1977; and (6) to plant soil foundations
,and excessive settlement of the Diesel Generator Suilding relative to inadequate conoscted soit and inspection activities in August 1978 through 1979 I
Following each of these-problem periods, the Licensee has taken action to correct the problems and to upgrade his GA program and GA/GC staff.
The most prominent action has been an overview program which has been
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steadly expanded to cover safety related activities.
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The evaluation both by the Licensee and IE of the structures and equio-ment affected by these problems (again except the Last) has established that they fully meet design requirements.
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. Looking at the underlying causes of these problees two commen threads i
r emerge:
(1) utilities historically have tended to over rely on A-E's
- (in this case, Bechtet) and (2) insensitivity on the part of both
' sechtet and Consumers Power to recognize the significance of isolated events or failure to adequately evaluate possible generic application l
of these events either of which would have led to early identification and avoidance of the problem.
1 Admittedly construction deficiencies have occurred which should have i
been identified earlier but the Licensee's SA program has ultimately identified and subsequently, corrected or in process of correcting these deficiene The RIII inspectors believe that continuation of (1) resident site 4
coverage, (2) the Licensee overview program, (3) the Licensee's attention and resolution of identified problems in this report, (4) ceasing to permit work to continue when quality related problems are identified with construction activities and (5) a continuing inspection program by regional inspectors wiLL provide adequate assurance that construction wiLL be performed in accordance with requirements and that any significant errors and deficiencies w1LL be identified and corrected.
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e Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN:
Mr. Stephen H. Howell Vice President 1945 West Parnall Road Jackson, MI 49201 Gentleman:
This refers to the meetings conducted on February 23, 1979, l
and March 5, 1979, between Consumers Power Company, Bechtel
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Corporation and NRC representatives held at the Region III office. Listing of attendees to the meetings are enclosed as Attachment No. 4.
The meetings, conducted in connection with the investigation of the settlement of the Midland diesel
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generator building and plant area fill, represent a continu-ation of that effort.
A separate report of the investigation conducted during I
Dece=ber 11-13, 18-20, 1978, and January 4-5, 9-11,' 22-25, 1979, by Messrs. E. J. Gallagher, G. A. Phillip and G. F. Maxwell of this office vill be issued in the near fu:ure.
During the meeting of February 23, 1979, the NRC summarized their preliminary investigation findings. These sunznary findings are provided in Attachment No. 1.
That meeting was subsequently followed by a second meeting held on March 5, 1979, during which Consumers Power Company repre-sentatives responded to the preliminary investigation findings identified in Attachment No. 1.
Those responses, which include a revised " Consumers Power Company Discussion of NRC Inspection Facts" report, are provided.in Attachments No. 2 and No. 3.
1 Based on our investigation, review of your responses, as well as discussions during the March 5, 1979, meeting, our findings are as follows:
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EAR 15 T3 Consu=ers Power '
Co=pany a.
The quality assurance progra= for obtaining proper soil compaction of the Midland Site was deficient in a number of areas.
e b.
Soil of the type used in the foundation of the diesel generator building is also located, to varying degrees, under other Class I structures and plant area piping.
c.
Several inaccurate statements are contained in the TSAR with respect to the soil foundations.
In addition to the above findings, we continue to be. concerned with the following matters:
t a.
Although you have stated that inadequate soil compaction ~
contributed to the settlement of the D/G building, you have not determined what other factors contributed to the settlement.
b.
Because similar foundation materials were placed under other Class I structures, identified on page 3 of Attach-7 --s
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ment No. 3, we have concerns regarding the ability of the structures and components to fulfill their intended design functions under all required design bases for the life of the plant.
c.
We are concerned whether ycur current course of action on the settlement, which consists of preloading and consolidating the underlying supporting materials, will resolve the problem on a long term basis.
l As you are aware, tha March 5, 1979, meeting was concluded with your informing us that within two weeks you would provide additional soils exploratory information that might account for the differences between the fill supporting the diesel generator building and that of the other Class I structures. You also stated that in the event the available information is insuffi-cient to demonstrate resolution of the settiament problem, a further course of action would be providad.
In that this' matter is related to plant design, we are forwarding it to our NRC Headquarters staff for further review and evaluation. We will keep you informed of their action in this matter.
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- EAR 15 073
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Consumers Power !
Company Based on a March 9,1979, telephone conversation with a member of your staff who informed us that the report contains no proprietary infor=ation, this report vill be placed in the NRC's Public Docu=ent Room.
Sincerely, 4
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(fJamesG.Keppfer Director Attachments:
1.
NRC Presentation of Investigation Findings of the settlement of the Diesel Generator Building and Plant Area Fill dtd 2/23/79 2.
Consumers Power Company Discussion of NRC Inspection Facts Resulting from the NRC Investigation of the Diesel Generator Building Sattlement (revised 3/9/79) 3.
Consumers Power Company Response to NRC Question on the Condition of Soils Under
'1 All Other Plant Areas dtd 3/5/79
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4.
Attendence List at 2/23/79 and 3/5/79 Meetings cc w/ attachments:
J Central Files i
Reproduction Unit NRC 20b j
TIC Ronald Callen, Michigan Public Service Commission Dr. Wayne E. North Myron M. Cherry, Chicago O
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March 12, 1979 e
MEMORANDUM FOR:
H. D. Thornburg, Director, Division of Reacter l
Construction Inspection Office of Inspection and Enforcement FROM:
James G. Keppler, Director SU5 JECT:
MIDLAND DIESEL GENERATOR BUILDING AND PLAhT ARIA FILL Meetings on this subject were held on February 23, 1979 and i
March 5, 1979, between Consumers Power Company, Bechtel Corporation and NRC. These meetings were a continuation of the investigation conducted by our inspectors during December 11-13, 18-20, 1978 and January 4-5, 9-11, 22-25, 1979.
During the February 23, 1979 meeting we presented to Consumers Power Company our preliminary investigation findings, a copy of which was previously forwarded to you.
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During the March 5,1979 meeting Consumers Power Company provided their responses to those findings, copies of which are enclosed.
Our summary findings with regard to this matter are ss follows:
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1.
The quality assurance program for obtaining proper soil compaction of the Midland site was deficient in a number of areas, i
2.
Soil of the type used in the foundation of the diesel generator building is also located, to varying degrees, under other Class I structures. Whereas excessive settlement has been observed with the diesel generator building, the settlement of other Class I structures has not exceeded predicted values.
f 3.
Several incorrect statements are contained in the FSAR with respect to the soil foundation.
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In addition to these findings, we have compiled a list of technical questions which bear on the resolution of this problem. These are enclosed for your use in working with NRR.
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H. D. Thornburg March 12, 1979 As previously discussed with you, one of our concerns is related to why construction activities at the Midland site, which could be i
aMected by a Class I structure settlement should be continued while the total cause of the diesel generator settlement has not yet been 4
determined. During the meeting on Mare) 5,1979, this question i
was posed to the licensee. Their response was that continuing
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scheduled construction work would not compromise the committed evaluations or remedial actions nor aske irrevocable any conditions which do not fully satisfy FSAR or licensing requirements. Based j
on this, they are willing to accept the risk of continued construction.
In that we have questioned the licensee's intent to continue 4
i construction, we consider that the matter also warrants examination j
by HQ. This examination we feel also involves NRR f or the following l
reasons:
I 1.
If one assumes the foundation settlement placement was in accordance with design, then the matter of design adequacy i
becomes questionable.
2.
If one assumes foundation placement di/. not meet design specification, one must question acceptability of the soils condition under the l
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affected structures. It should be pointed out again, that the j
type of soils placed under the diesel generator building were also i
i the type placed under other Class I structures and associated pipes i
and utility lines.
l 3.
In light of items a and b above, the matter of seismic design also becomes one of concern.
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4.
Because of the licensee's total evaluation of the specific cause for the diesel generator and plant area fill settlement is not i
yet complete, the question of FSAR design review and its acceptability any warrant further attention by NRR.
As an alternate approach to the issue, consideration should be given l
to an NRC Directive or Show Cause Order which could expedite the 1
licensee's confirmation to the NRC that continued construction will not compromise the design function of the involved structures for
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the life-time of the plant. It may also expedite the licensee's investigation into the basic cause of the diesel generator settlement j
and its relationship (or absence) to 'other Class I structures.
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- 11. D. Thornburg March 12. 1979 We vill continue to followup on this matter and keep you informed of i
new information.
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Director i
Ecclosures:
As stated A
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MIDI.AND QUESTIONS 1._ The licensee has stated that the fill has settled under its own weight. What assurance is provided that the fill has not settled locally under:
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a.
Structures with rigid mat foundations as portions of the auxiliary building or service water pucp structure.
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Class' I piping in the fill resulting in lack of continuous x
N support causing additional stress not accounted for in N
design.
2.
How has the lack of compaction and the increase in soil s
3.
compressibility affected the seismic response spectra used 4
in. design'aad therefore, the soil-structure interaction during c seismic, loading?
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,,. k "Af ter ehreat preloading material is removed vill additional borings be caken to ascertain that the material has been
,s compacted'to the original requirements set forth in the PSAR 4
'and constrGetion license application?
4.
Sines the\\ foundation material is variable as described in 50.55(e)
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. interin report number 4, how can long term differential settlement
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- be piedicted to assure reliable startup of the D/G in the event -
of-esorgency? '
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What tolerance does the D/G manufacturer require on the alignment
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oftheD/Gjfo reliable operation and startup? -
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Preliminary information indicates that the piping in fill under and in the vicinity of the D/G building have gross deformations s
1 induced either prior to or during the preload program. What is
.the extent of thi deformation.
Is this deformation beyond predicted?
s If ro, what plans are being taken to correct the condition?
7.
The borated water storage tanks and diesel fuel oil tanks have
- ,s not yet' been constructed and are to be located in questionable p3 ant fill ot' varying quality. Why should those Class I structures be'tenstructed prior to assuring the foundation material is
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capable of vupporting such structures for the plant life?
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MIDI.A.ND QUESTIONS 8.
FSAR Figure 2.5-48 shows estimated ultimate settlements which
- indicate a differential settlement across individual mat foundation and within individual structures. Was this dif ferential accounted for in the o;iginal design of the mat foundation and in the design of structural member within the structure.
If not, what if fect does this differential settlement have on additional stresses induced in the mat or in structure me=bers such as slab-beam-column connections?
9.
Based on the information provided in CPCo interim report number 4, it appears that the tests performed on the exploratory borings indicate soil properties that do not meet the original compaction criteria set forth in the PSAR and specification for soils work.
What assurance is there that the soil under other Class I structures not accessible to exploratory boring meet the control compaction requirements?
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