ML20091F435
| ML20091F435 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/13/1982 |
| From: | Tambling T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | NRC |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-07, CON-BOX-7, FOIA-84-96 NUDOCS 8406020170 | |
| Download: ML20091F435 (3) | |
Text
{{#Wiki_filter:_ _. t I UNITED STATE 8 8 NUCLEAR REGULATORY COMMISSION i nsaion m 790 nooseveLT noAo SLEN ELLYN,ILLif0006 00137 October 13, 1982 MEMORANDUM FOR: Those on Attached List FROM: T. N. Tambling, Chief, Operational Support Section
SUBJECT:
SALP III INPUT Input for Callaway. Fermi, Marble Hill, Perry, and Clinton Nuclear Plants for the SALP III evaluation period October 1,1581, through September 30, 1982, will be due October 30, 1982. Provide input in all areas you or your group has inspected. As in SALP II Resident Inspectors provide the largest single input and generally provide the primary inputs to the Supporting Data Sections. This should contina. Where several inputs are provided, they will be blended by the report preparer to develop a single evaluation. Functional area evaluations using inspection repcrts should include con-sideration of the ass.:iated " Inspector Evaluation" forms filled out per Region III Procedure 1206. Other information should be used as materials from PAS or INPO inspection reports, infomal observation, investigations, etc. For SALP III inputs, inspection report numbers applicable to a functional area evaluation should be identified and each noncompliance addressed should be related to its associated inspection report by number. Licensee Event Reports (LERs) used to support an evaluation should be identified by LER number. This infomation will. help the preparer of the integrated report. By natum of our looking for problems, our evaluations have frequently overlooked licensee strengths. An improved effort is needed to identify the licensees' strengths in the reports. Characterize both strengths and weaknesses, particularly noncompliances, using the criteria and guidance provided in NRC Manual Chapter 0516 to support whatever performance category is chosen. Remember that this is a performance evaluation for a year, not the last months of the period. Changes in perfomance over the period should be averaged. Note in the " Analysis" either particularly improved or degraded i performance trends observed either during the period or since the previous 1 one. Additional guidance is provided in the Attachment. t g70840517 C -96 PDR .)
i SALP.III Input October 13, 1982 Please be prompt with your input; send it to Tom Tambling, Chief, Operational Support Section, for distribution to the report preparers. Be ready to support the preparer in blending your input into the report format and to provide support during both the Board and licensee meetings. If residents have any questions on their submittals, contact your Section Chief. WYb^#l] b (*>T.N.Tambling, Chief Operational Support Section
Attachment:
Input Guidance l l 6 I I
Attachment - Memorandum dtd 10/13/82 Input Guidance I. Indicate the basis for the evaluation: a. Number of inspections b. Depth of inspections c. What was inspected d. Other observations, LER reviews, etc. e. Enforcement history II. Indicate findings: a. Noncompliances b. Strengths and weaknesses c. Pertinent LERs d. Enforcement actions, citations, etc. III. Indicate what the findings show or reflect in terms of licensee performance: a. Put finding in perspective such as: 1. Major problem, continuing for long term. 2. Minor problem, isolated case. 3. Major or minor safety significance, etc. b. Indicate trends if they~are evident. IV. Indicate actions taken and general licensee responsiveness to correct identified problems. (The resident inspectors can be particularly helpful in this area, particularly when problems are identified early in the inspection period and not subsequently addressed by formal inspection. The licensee responsiveness can have considerable impact on the performance category assigned.) l l i i i i [ ~ m
RRC \\ ~ ,r ege n= July 19, 1982 - Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATTN: Mr. James W. Cook Vice President Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen: This refers to the management meeting held by me and other NRC representa-tives with you and other representatives of Consumers Power Company in Jackson, Michigan, on April 26 and June 21, 1982, to review the results of the NRC's evaluation of the utility's regulatory performance at the Midland Nuclear Plant in connection with NRC Manual Chapter 0516 - Systemstic Assessment of Licensee / Performance (SALP) and covers the period July 1, 1980 through June 30, 1981. A preliminary copy of the SALP Report was provided to you in advance of our meeting. This report is enclosed, along with the written comments you provided on May 17, 1982. Your May 17, 1982, response to the SALP Report took issue with a number of findings and evaluations presented by the SALP Board. As discussed at the June 21 meeting, the NRC representatives were not pursuaded by the arguements presented and it is apparent that NRC and Consumers Power Company management have differing views as to the. facts surrounding several identified concerns. I intend to contact you'in the near future to arrange one or more " working" meetings between our staffs in_an attempt to clar_ify_thej isputed_ issues.. Following completion of that effort I will give you my overall observations and assessment of the utility's performance during the appraisal period along with comments I believe are appropriate relative to your May 17 letter. P b 4 A
Consumers Power Company 2 July 19, 1982 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the SALP Report will be placed in the NRC's Public Document Room. No reply to this letter is required; however, should you have any questions concerning these matters, we will be pleased to discuss them with you. Sincerely. Original signed by Jas:s Ge Keppler James G. Keppler Regional Administrator
Enclosure:
SALP Reports No. 50-329/82-14 and No. 50-330/82-14 cc w/ enc 1: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris ~ Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.) l P R I RI I RII 4' RIII R II RIIJ t [1 N, 1) h. T ling /sv Sg sard Norallus nd vis Ka'p1pr ll13l02 'h 'n h Q l/$ 1 l% WA-1 l A r --w
t - u SALP RIII U. S. NUCIIAR REGULATORY Cott!ISSION REGION III SYSTEMATIC ASSESSMENT OF LICENSEE PERTOMIANCE Consumers Power Company
- IIIDLAND NUCLEAR PLANT, UNITS 1 AND 2 Docket Nos.^50-329; 50-330 Reports No. 50-329/12-14; 30-330/82-14 L
Assessment Period [Jd!E1T'll N p~ t I March 1982 f-r f I f l' f.
~. CONTENTS Page 1. SALP Board Chairman Letter to Licensee.................... iii 2. Licensee Comments......................................... vii I. Introduction.............................................. 1 II. Criteria.................................................. 2 III. Summary of Results........................................ 3 t IV. Performance Analyses...................................... 4 t V. Supporting Data and Summaries............................. 18 A. Noncompliance Data................................... 18 B. Licensee Report Data................................. 20 C. Licensee Activities.................................. 21 D. Inspection Activities................................ 21 E. Investigations and Allegations Review................ 21 F. Escalated Enforcement Action......................... 21 G. Management Conferences............................... 22 m 4 f. 4 L l t I t 11. t 1 .I + k.
i Docket No. 50-329 Docket No. 50-330 Consumers Power Company ATIN: Mr. James W. Cook Vice President-. Midland Project 1945 West Parnall Road Jackson, MI 49201 Gentlemen: This is to confirm the conversation between Mr. D. J. Vande Walle and Mr. D. C. Boyd of the Region III staff scheduling April 26, 1982 at 1:00 p.m. as the date and time to discuss the Systematic Assessment of Licensee Performance (SALP) for the Midland Nuclear Plant, Units 1 and 2. This meeting is to be held at the Sheraton Hotel, One Jackson Square, in Jackson, Michigan. Mr. James G. Keppler, the Regional Administrator, and members of the NRC staff will present the observations and findings of the SALP Board. Since this meeting is intended to be a forum for the mutual understanding of the issues and findings, you are encouraged to have appropriate representation at the meeting. As a minimum we would suggest Mr. J. D. Selby, President, Mr. R. J. Reynolds, Executive Vice President, or Mr. J. W. Cook, Vice President Midland Project and managers for the verious functional areas where problems have been identified. The enclosed SALP Report which documents the findings of the SALP Board is for your review prior to the meeting. Subsequent to the meeting ~ the SALP Report will be issued by the Regional Administrator. to this letter summarizes ths more significant findings iden-i' tified in the SALP Board's evaluation of the Midland Nuclear Plant, Units 1 and 2 for the period of July 1, 1980 to Juno 30, 1981. Ifyoudesiretomakecommentsconenrningourevalut,tionofyourfhef-lity, they.should be' submitted to this office within twenty days of the meeting date; otherwise, it will be assumed that you have no comments. r i ~
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Consumers Power Company 2 l l In accordance with Section 2.790 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, a copy of this lettsr, the SALP Report, and your comments, if any, will be placed in the NRC's Public Document Room when the SALP Report is issued. Comments requested by this letter are not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-5111. If you have any questions concerning the SALP Report for the Consumers Power Company we will be happy to discuss them with you. l Sincerely, J. A. Hind, Director Division of Emergency Preparedness and Operational Support
Enclosures:
1. Significant Findings 2. Midland SALP Report (5 copies) cc w/encis: Resident Inspector, RIII 9 1 l v iv i t l
Significant SALP Report findings for the Midland Nuclear Generating Station. General Observations
- TheBoardnotipsistoyementsinthe__overallQualityAssurance_p_rogram_@ai r
,ihe Midland sitl. An indepth teggpection, performed in May't3e of 19 ~ [ndfEstif that Con (users YoMw=yny.,has_ establish'ed~ an effec org3Mi&YTon for the maWagement of AALQC, activities at the sity. M [ numb'ersssa~q'u'afifications of personnal in thii'Qi/QCyganization_and ty / ~ ~ ~ ~ove Rie F&Ed'Au~diflfuncEfons perfoimed'kere found t'o be_ab'ove that norma 1 To un d" WbThWco n s t ru ctT'o'EIl t'e}. During the July 1, 1980 to June 30, 1981, evaluation period the Licensee's performanceinresolvingtechnicalandqualityissuesinthe'installatip), of piping andjiping suspension s steep (particularly small bore piping in the,puDTng of'ilec~tr1calT sand in the handling of soils and foundaf ~ , tion problirip was 'TWr"Inii des t The licensee's QA/QC' capabilities were not fully anu effectively utilizecf as expected in these specific areas to insure adequate preplanning and timely review and control of quality activities. The 'licenie~e's performance in most oth'e~r~ area's~ ~h'as~besn_ sa'tisfidorf and a LsignificaiiFimproyes ~ hasbeenachieved'in'the11censee'sresolutf*ogofthe o ~ , heatingN4MITMY g..andai.r,conditioniMproblemsidentifiedintheprevious ~ evaluation ~ period ^(SALP 1). In the less technical, administrative areas, regarding corrective actions and reporting, the licensee has frequently demonstrated an,argumentativd attitude lintheirresponsestoNRCenforcementissues. This has resulte'd in management meetings with the licensee, subsequent to the SALP evaluation period, for further discussion and clarification of this area. Should the licensee offer strong responsible management conviction to resolving the reporting and corrective action issues, a turn-around in these areas can be expected. Functional Area Piping System and Suppory i During the evaluation period, ~ were identified in the -implainiiij 3Ation of'the gustityls' sift roar esign[Temediate'AEtEloii I,fTYEl was An
- Issued May' 22 P1981'," pertaining ~to'the'
~ientrol'and issuances" of c While in the process of reviewing {sialQrKjiipi,ig and support systems. drawings for the installation of and resolving these concerns, the licenses was found in noncompliance in another area. This resulted in issuance of a letter of understanding by the licensee for the control of modifications to small bore piping drawings which do not have committed Preliminary Design Calculatio: s. v 4 1 ___u.
,ElectricalPowerSupplyandDistributiop ~ The licensee had embarked on an ambitious " pulling schedule" commencing half way through the evaluation period. Prior to this, the NRC had verbally advised the licensee to have adequate number and quality of QA and QC personnel available when escalated electrical installation activities commenced. ! even~ items of noncomplianc identified during the evaluation S [ period indiistid a Isca or rigorqui. oyeragg. Subsequently,the,licensef has incre_as,edithe rigor,and frequency of overview inspectiongf performed a u detailed audit pe'rtaining to material storage and brought upper management's attention to the findings, and is presently inquiring into the adequacy of electrical QC coverage.,,Both NRC and 1_icenses attention should be increasgd. Soils ~and Toundationsj There had been considerable activity in the soils and foundations area during.the,past_three years. Theenforcementhistoryindicatesalackoqf
- attenti.on_to, detail by.the license,e,and a continuing inability on the part of the licensee to successfully implement proposed resolutions of the soils settlemant issues. This performance has resulted in several management meetings both in the NRC Headquarters offices and in the regional offices to discuss these matters and to delineate the NRC enforcement posture to the licensee.
These regulatory concerns primarily focusing on the limited QA/QC coverage provided have been expressed in the past during the taking of soil borings and installation of dewatering wells and simular concerns have been, expressed during the earlier, stages of.the remedial soils work. ? Both'NRC and licensegl Jttontion'should,be,increasadj O I l vi
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May 17, 1982 i Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Illyn, 3L 60137 MIDLAND PROJECT RESPONSE TO DRATT SALP REPORT TILE 0.6.1 SERIAL 17485 t on April 26, 1982, Mr J G Keppler and members of the NRC Region III staff met with Consumers Power Company personnel in Jackson where the NRC presented the observations and findings of the Midland SALP board for the period July 1, 1980 to July 30, 1981. At the conclusion of that meeting we were informed that we should make written comments to the Region III office within 20 days of that meeting date. This letter **ansmits Consumers Power Company's response to the draft SALP evaluation report and to other comments made by Mr Keppler at that meeting. Our general reaction to the SALP evaluation can be summarized as follows: We support the SALP goals and objectiv.es because we believe it is vital to have an active and continuing dialogue with those who have direct regulatory responsibility for the Midland Nuclear Plant. We do believe, however, that the SALP process has not yet reached maturity and there are areas where the process can be made more effective. With regard to the specific contents of j the draft SALP report, we are concerned with what.we believe is an unnecessarily negative characterization of the inspection results for the period covered by the SALP report. Because of this concern and our belief that the facts do r.at support the characterization presented by the authors of the draft SALP report, we have spent considerable time reviewing the detailed information on which the draft SALP report was based, and this analysis forms i the basis of our attached response. We believe a careful review of this l material will enable Region III management to understand the basis for our i concern and to gain an appreciation for our perspective in this matter. I l l In addition to the review of the draft SALP report, Mr Keppler made several j comments at the April 26 meeting regarding his own participation in both the NRC team inspection of May 1981 and his subsequent testimony in the ASLB l 1 hearings on the soils matter. In order to respond to those comments we have also included additional material and analyses that directly respond to Mr Keppler's comments. [ vit oc0582-2048a102 j _,,.~ ,*.:JC l l 4 --,r --*r y
2 Our detailed response to the SALP report and Mr Keppler's ecmments has been divided into three attachments transmitted with this letter. A description of each of the attachments follows. is a detailed review of the entire draft SALP report and the inspection results upon which the SALP report was based. We conclude that the details of the SALP analysis support a more positive conclusion than was presented at the SALP meeting. The basis fer this suggestion is that there appears to be considerable overstatement of the actual severity of the inspectica findings, some factual errors and omissions within the draft SALP report itself, and further, there are some assignments to this SALP evaluation of events that occurred prior to the SALP evaluation period, all of which contribute to an unnecessarily harsh characterization of the Midland Project regulatory performance during this SALP evaluation period. Attachment I also contains our comments on the SALP process. to this letter is a comparison of Mr Keppler's testimony in the Midland soils hearing with the specifics of the draft SALP report. This detailed comparison concludes that even with the generally negative characterization of the Midland Project by the SALP board, there is still no contradiction of Mr Keppler's prior testimony by the draft SALP report nor any need, in our opinion, for him to modify that testimony. The third attachment to this letter entitled " Analysis of Current and Future Quality Activities With Regard to Remedial Soils Work," addresses specific questions raised by Mr Keppler at the conclusion of the SALP meeting. This attachment points out that there appear to have been considerable regulatory . difficulties experienced by the Midland Project during the past two months, mainly because of the inability of the NRC staff and the Company to finalize the quality assurance program coverage requirements for the soils remedial work, particularly for the underpinning activities. Attachment 3 points out that this difficulty appears to have been generally resolved and that there are numerous reasons for confidence that with the regulatory requirements properly defined, the remaining soils work can be carried out in a fully satisfactory manner. Consumers Power Company urges the Region III management and staff to carefully consider the information and reasoning contained in this response to the April 26, SALP meeting. We believe that there is ample basis for the Region Administrator to reaffirm his 1981 overall team inspection findings in his i overall conclusion to the 1980/1981 SALP evaluation. Finally, as noted previously, we were disappointed with the negative tone of j the draft SALP report. We take very seriously the comments made by the Region i i III SALP board members and will do whatever we can from the applicant's point of view to engender productive working relationships with the staff and to be l responsive to the staff's concerns. Nevertheless, we must disagree with some of the material in the draft SALP report, and we request the opportunity to meet with Mr Keppler and his staff to review the detailed contents of this response. JWC/WRB/aat viii oc0582-2048a102 C. * ' M l 2
l \\ 3 Distribution: Keppler (3 copies) CC: Atomic Safety & Licensing Appeal Board CBechhoefer, ASLB MMCherry,Esq FPCowan, ASLB RJCook, Midland Resident Inspector SGadler JHarbour, ASLB DSHood RBlandsman MIMarshall BStamiris MSinclair i i l AK. oc0582-2048a102 .. \\
1-1 CONS"MERS POVER COMPANY RESPONSE TO THE DRAFT SALP REPORT FOR THE MIDLAND NUCLEAR PLANT Peference: 1. NRC letter; J A Hind to J W Cook; dated April 20, 1982; with Enclosures 1 and 2. This response is in three parts. The first part provides a general response to the l SALP appraisal and SALP process as a whole. The second part provides our detailed response to Enclosure 1 of the reference, the Significant SALP Report Findings. The third part provides a detailed response to Enclosure 2 of the reference, the Pre-liminary SALP Report, dated March,1982, covering the assessment period of July 1, 1980 to June 30, 1981. Part 1 ~ General Respense A. We are encouraged by the general statements to the effect that the NRC sees pro-gress in Consumers Power Company's overall quality assurance program and in its management. Undoubtedly, there has been improvement in our regulatory j performance from the 79/80 assessment period to the 80/81 period and from the 80/81 period to the present. Literally, dozens of actions have been taken in order to achieve this improvement. These actions have been communicated to the NRC. In May, 1981, Mr Keppler and members of his staff performed an extensive team inspection from which they concluded that "... the scope and depth of this NRC inspection was such that the identified noncompliances do not contravene our conclusion that Consumers Power Company has established an effective organization for the management of construction and implementation of quality assurance at the site." B. We are, however, disappointed by the overall negative tone of the draft SALP Report. Nonetheless, we continue to be dedicated to attaining two goals: ~ 1. First and foremost, to ultimately assure that the as-built configuration of the pisnt is in conformance with all regulatory and design requirements;
- and, 2.
To continue to improve our regulatory performance. C. We welcome feedback relative to our regulatory performance--the sooner the better. We have encouraged such feedback in a number of ways, and we shall continue to do so. A number of meetings with Region III management and staff have been at our initiative. On numerous occasions we have proposed the establishment of routine, periodic meetings to exchange information with Region III's home office staff. On our own initiative, we submitted our Preoperational l' Testing Manual in order to obtain Region III review and comments at an early date. Our specific invitation may have contributed to Mr Keppler's personal participation in the NRC team inspection conducted in May, 1981. We have proposed that an NRC Inspector be on site as much of the time as possibla to asse.ss our remedial soils work. Of course, at the completion of NRC inspec-tions, axit interviews with the Inspectors are a routine feedback mechanism. x -oc0582-0039a167' a +- e C m
1-2 t D. In reviewing how to improve the Company's overall regulatory performance, it becomes evident that the most timely regulatory feedback is that which is received before the accomplishment of the work in question. While both Consumers and the NRC attempt to achieve this objective, we believe both our organizations have fallen short in this area. .c v It is our recommendation that the NRC consider scheduling seminars for the frA ', d various ongoing nuclear construction jobs as they approach each major phase. q~ 7 " / " One purpose of these seminars would be to review the detailed quality programs # ',,, 4. and procedure for each major new activity at each job. This review would verify that all programmatic requirements at the detailed level were in place prior to the work or could be upgraded before the fact to meet Region III expectations. In addition, the NRC inspection specialists could review with the applicant's quality personnel typical detailed inspection plans used by the NRC in their on-site inspections. At the same time, discussions of actual experience from other earlier construction sites could make the Licensees for current construction sites more aware of and responsive to potential problems in the work area about to begin. We in industry have tried to accomplish this objective with our various regional and industry groups, and by reviewing inspection reports from other jobs. However, these efforts suffer by lack of NRC input at detailed working levels. We urge the NRC to consider this type of an approach to supplement their other , inspection programs. A specific benefit to Midland's future performance has already occurred as a result of this concept. It was mentioned at the SALP meeting that we had submitted our Test Program Manual to Region III some time ago in order to obtain feedback prior to the start.cf detailed systems testing. Even though some testing has already taken place, we are delighted to report that follow-up from the April 26 meeting has resulted in the scheduling of a detailed NRC review of 9 ,the Midland test program for later this month. E. -We recognize that the SALP process is a re16tively new one and that the NRC is o f,'. - > attempting to develop an approach to the SALP reviews'that will be timely, fair F., and based on the best available information. This seccnd SALP Report is a major h{ < improvement over the first, National SALP Report which was issued in the fall of 4 .) ; U ci 1981. Nonetheless, our review of this SALP Report discloses additional dC 'rd' improvements which can be achieved in meeting the objectives of the SALP gj process. 'First, there appears to be no consistent format in characterizing the areas which arc being evaluated. The assessment can be made by functional engineering areas such as soils, containment, piping, etc; or it can be made on the basis of discrete engineering activities such as design, procurement, construction, etc. The current SALP Report has both categorizations which leads to an inevitable j l double counting of deficiencies identified during a reporting period. The report itself recognizes this problem, but discounts it. We appreciate the need perceived by Region III for singling out certain specific activities, such as fdesigncontrol,forseparatetreatmentintheSALPReport. However, the overlap of function and activity categories detracts substantially from the systematic ) nature of the appraisal. Certain!, there are mechanisms available to X J oc0582-0039a167 i ) 4 d y e s,-- -.----e-y-.+- y 9 -,m w. g
1-3 Region III to express its particular concern with a designated activity other than the SALP Rooert. ~l Second, the rankings do not appear to be consistent. For example, no items of O p: ' j,. s, noncompliance were identified with respect to the Fire Protection, Containment l' , and other Safety-Related Structures, and Preservice Inspection areas. Yet Fire ! Protection was rated a " Category 1" while Containment and other Safety-Related l Structure and Preservice Inspection were rated a " Category 2." ~~' We believe that the major criteria in evaluating licensee performance should be the number and seriousness of items of noncompliance identified by NRC for a given unit of inspection time. We are not suggesting that there is no room for subjective judgment in the appraisals of each area. What seems to occur, however, is a lack of consistency from area to area in applying the factors which shape that judgment. Moreover, we note that most of the specific items 3 discussed were the subject of testimony before the ASLB conducting the soils lhearings. Yet no review of that testimony seems to have taken place. ' Finally, the time period during which the Licensee's performance is being ~~~ evaluated is unclear. Part V of the Preliminary SALP Report does indicate that the noncompliances and deviations in the HVAC area were reported also in the first SALP report. However, one item of noncompliance listed in the Piping p Systems and Support Performance Evaluation related to an apparent nonconformance that took place in November, 1973, but was identified during an NRC inspection t ,. ^ during the SALP evaluation period. In addition, all of the 50.55(e) reports ' cited in the Preliminary SALP Report represented design deficencies which , occurred long before the SALP period. If those are the groundrules for the SALP process, they should be clearly stated. The Licensee and the public will than i recognize that the evaluation rests not only on events which occurred during the j evaluation process, but also on events identified during the evaluation period,'
- regardless of when they took place.
s; What follows is a response to specific statements in the Preliminary SALP Report. 'N Those specific statements are either direct quotations from, or characterizations of, items which were included in various NRC inspection reports. We have responded in writing to each inspection report and refer you to those responses for the details of the Company's position regarding each item. However, some of the characterizations of the findings of the inspection reports in the Preliminary SALP l Report are incomplete. For your convenience, we have summarized our responses to i each of the inspection findings, as well as clarifying the content in which those i findings arose, as appropriate. Part 2 - Response to Enclosure 1. Significant SALP Report Findinas .) A. General Observations 1. We are pleased that the Preliminary'SALP Report noted the " improvements in the overall quality assurance program"; that we have " established an effective organization for the management of QA/QC activities"; and that i "the numbers and qualifications of personnel in the QA/QC organization (s) xii oc0582-0039a167 i + - -~ ~
m 1-4 i and the overview and audit functions performed were found to be above that normally found at other construction sites." 2. Also, we are pleased that for the Support Systems (HVAC) area the Preliminary Report recognized our resolution of the problems which existed during the previous SALP period prior to July 1, 1980. This resolution was realized through considerable expenditures of resources. We believe this demonstrates our responsiveness to problems with concrete actions. 3. The general observations relative to the less technical administrative areas are of concern to us. We do not view our past responses as argumentative merely because they provide additional facts or reasoning which may not have been available for presentation to the NRC Inspector at the time of the exit interview or because they provide information with which the NRC Inspector disagrees. The Staft., in at least two instances in the soils hearing, testified that making legitimate appeals is entirely proper, and is part of the normal give and take between the NRC Staff and the licenses. It is disappointing that the Preliminary SALP Report does not embrace the essence of that testimony and also of our management conference on this subject. At that conference, we were told not to be reluctant to appeal on any legitimate issue, but to discuss our differences with Region III prior to submitting any written appeal in order to facilitate its resolution. This suggestion has been adopted. ~ B. Pipinz Systems and Supports j 1. We agree with the Preliminary SALP Report ites relating to ths unavailability of Committed Preliminary Design Calculations (CPDCs) to support the drawings for small bore piping. This, in our opinion, was the / major quality deficiency that occurred during this SALP period. Upon discovery of the unavailability of the CPDCs, we stopped the design work, began immediate corrective action, and did not resume the work until both we and the NRC Staff were assured that the process had been corrected. Even with the design process deficiency identified, it is heartening to report i that not a single pipe segment required rework as a result of this situation. 1- 'I 2. We also note with pleasure that the informal current rating in the Piping Systems and Supports area as of this time is " Category 2" based on Mr R 'MCook'sstatementsmadeduringtheApril26presentationofthePreliminary ,.n- %ALPReport. This improved rating is, we assume, based upon recognition of j 't .,,sp,e ,our positive and effective corrective actions in this area. 4 g/. P lj C. Electrical Power Supply and Distribution 1. While we understand that any' noncompliance is "less than desired" and also l understand the Staff's particular interest in our ambitious cable pulling 1 schedule, we do not understand the apparently negative observations in this l -area. The impa! cation given is that were it not for the NRC's advice, we would have had sa inadequate number of QA/QC personnel available to support 3 11 the cable pulling schedule. This is an erroneous implication. We believe we have always supported the cable pulling activities with the appropriate A~ xiii .oc0582-0039a167 7 .L l + p i s i ~
1-5 number of QA/QC personnel. In fact, the amount of.able pulling carried out by the Company could not have been completed without adequate QC personnel, because in process inspection is required to verify cable pulling tensions. 2. We also believe that the seven items identified during this period were not excessive and were of relatively low consequence. These items are discussed more fully in the third part of this Attachment. D. Soils and youndations
- 1..We view the finding in this area especially harsh because it_1.s_predic,ated on some relatively minor 1.tems of noncompliance, and on(misinformat,fon>in Ithe Preliminary SALP Report, as demonstrated in the thir Cpart of this jAttachment.
2. Reference is made to " limited QA/QC coverage." At no time has the QA/QC , staff been insufficient to cover the ongoing work. At one time the NRC i advised us of the need for additional personnel to cover future work. We were fully aware of and agreed with that need, and we have staffed and are staffing to meet it. Also, in our opinion, there has never been any inadequacy in the qualifica;. ions of the QA/QC pe_rsonnel assigned to th_e _ remedial _soi.1_s W The QA Engineers so assigned are al1~dsgreed~Eivil @T:sineers. '*rae ;vt /.I j7, 92 ~ )Vef frue h> . N.! ? Pe nM,. -.- Part 3 - Response to Enclosure 2. Preliminary SALP Report l A. Section I. Introduction Our comments on this section are found in our general comments provided in Part 1, above. B. Section II. Criteria 1. Our, general comments relating to the manner in which evaluations are made are contained in Part 1, Paragraph E, above. C. Section III. Summary of Results 1. Our comments on this section are found in our general comments provided in Part 1. Paragraphs A and B, above. D. Section IV.I. Performance Analysis of' Quality Assurance 1. It is gratifying, as noted earlier, that the NRC recognizes our above normal efforts with regard to the Quality Assurance organization and program, with regard to our overinspections and audits, and with regard to our aggressiveness in assuming the primary inspection responsibility for the HVAC installation. l ( l-
- 2. ;Seven of the eight ites identified from the May,1981, inspection and
!= referenced in this section of the Preliminary Report are duplicated elsewhere in the report under the Soils, Piping and Supports, and Electrical xiv oc0582-0039a167
4 1-6 Sections. Therefore, we will address these noncompliances specifically in the other sections. 3. The eighth item from the May, 1981 inspection dealt with the corr 3ction of adverse quality trends. Action was taken to provide a procedural change to cause the more timely closeout or verification that correction has been made in response to an adverse trend. rm 'Our trend analysis activity is among the most comprehensive anywhere, in f OI 'ltermsofscopeandsophistication. Such an activity is not specifically required by NRC regulations or ANSI standards. Should not credit be given for this? 4. This section of the Preliminary Report also refers to another inspection " indicating questionable QA managerial control (because) the ],, { licensee failed to fully evaluate the technical capability of the L ?. s. principal supplier of services for soil boring activities." gr-This is an unfair and incorrect summary of what occurred. The original NRC Inspection Report states: "The technical capabilities of Woodward-Clyde (principal supplier of services for soil boring activities) were not evaluated prior to commencement of drilling operations on April 2, 1981." Our original letter of response stated: 7 ( [I2C N Vi b Sfog'l Clyde consultants as the principal supplier of services "On March 31, 1981, Consumers Power Company approved Woodward-L vc bar n d > g 0 the soils boring and sample program based upon meetings jbetweenMarch3and11,1981) with Woodward-Clyde consul-y g -v:oc. A tants. .. Woodward-Clyde consultants were considered qualified as docuniented by letter serial.12134, dated 6h N c;c p e v'C h~.:.fApril 8,1981 N Ramanujam to File B.2.5.4 (Attachment 1), en9 * "'* W/I *q -Even though this letter is dated April 8, 1981, it documents M steps taken prior to April 2,1981, in qualifying Woodward-f,}) ge) *7 Clyde. Woodward-Clyde consultants were approved by Oral Communication Report serial 11883, R C Hirzel to R C Bauman, ,,'f_, 4 J ated April 2, 1981, (Attachment 2). Both of these documents NA "T (Serials 12134 and 11883) were presented to Dr Ross Landsman e ' #e ', " f M h,~
- of the Nuclear Regulatory Commission on April 9,1981." /
^ ~ ~ .... _ ~ sd,,d p t" ffThisisnot"questionableQAmanagerialcoit1",disisnot"failuret_o) Ifully~eviluate tne technical capability of the principal supplier.",The (documentarion"was provided'to the NRC Inspector. -1,- j l A-11 '{ 'Ihe actual noncmil. iras failure to provide our Procurement Department with the letter documenting the approval of Woodward-Clyde prior to the l commencement of activities on April 2. XV. ( oc0582-0039a167 1 ---.g -7,
l-7 5. Also, this same paragraph of the Preliminary SALP Report states: ' 'i %, "The NRC identified 15 deficiencies in the principal .f.f, # f supplier's quality assurance program manual indicating that l'T v. / ' / s / the licensee had not adequately reviewed and approved the 4 c [ ' ;l / procedures prior to preparation of drilling activities." ) J'. l .p / We are concerned both about the substantive and procedural implications of ii this comment. The 15 items referred to were nerated as a_r.aanit-of-our quality _assuranct RIQarAmmatic_re_quirement The NRC Inspector participated Tb. is.waY'with us in the initial and timely review of yoodward.s Clyde's quality _ ce,, e7~
- L assurance _ manuals We welcon.d his participation and anticipate sharis will
" ; g.,s., g, continue, at least through the conclusion of the soils remedial work. But ,J it is simply counterproductive and unnecessarily adversarial for the h7C Inspector to "take credit" for having identified these deficiencies. Indeed, he did not do so. In any event, the important point is these items were uncovered in a routine review, in accordance with established quality might have risen to the level of " deficiencies.gast the review stage, some assurance practices. Had they gone undetected Our timely handling of these matters is inappropriately characterized as a deficiency in the Preliminary SALP Report, when in fact it represents the proper functioning of the Quality Assurance Program. E. Section IV.2. Performance Analysis of Soils and Foundations 1. The second paragraph of this section of the Preliminary SALP Report, states: "Every inspection involving regional based inspectors and addressing soils settlement issues has resulted in at least one significant item of noncompliance." The correctness of this statement depends upon how the term " inspection" is define.1. It has been customary to define an inspection in terms of the i ~ v duration of the inspection trip. For exampic, if an Inspector visits the 4 site for three days in the first week, leaves and does not return until the third week, at which time he visits the site for two days, the practice has been to view these as two separate inspections. However, the practice of the NRC Inspector in this area has been to combine, into a single NRC Inspection Report, the results of two or more inspection trips. If an NRC inspection is defined as the inspection performed during a single trip, this statement in the Preliminary SALP Report is incorrect. 2. The Preliminary SALP Report states: M "There was a failure to initiate audit corrective action Q concerning the rereview of the FSAR and references to y f \\/ determine if design documents had modified the FSAR and if so 5 6 that changes had been made to the FSAR." d t p e k, d, # This ites is duplicated in the Preliminary SALP Report in the section t dealing with Design Control. Read carefully, the item reflects a failure to j initiate audit corrective action, not a failure to perform an adequate j xvi oc0582-0039a167 ~ l
1-8 rereview of the FSAR. The need for the corrective action was, in our view, of minor importance. The FSAR rareview was an extensive, as well as intensive effort spanning 18 months and involving three companies--Consumers Power Company, Bechtel, Babcock & Wilcox. Bechtel, alone, spent an excess of 10,000 manhours on this effort prior to its completion ir. September,1980. This effort i resulted in a clarification and upgrading of the content of the FSAR. Two audits were made by the Consumers Power Company Quality Assurance Department to assess-the adequacy of the FSAR rereview effort. Both audit teams concurred that the rereview had been accomplished conscientiously and. effectively, assuring that design changes had not modified the FSAR or, if so, that such changes had been subsequently reflected in the FSAR. ) The item given in the Preliminary SALP Report stems from our audit finding to the effect that all of the design documents which were rereviewed were not listed in block 8 of the rereview form as required by the rareview procedure. The instructions for block 8 indicated that the rereviewers were to list the design documents to be rereviewed, to indicate whether or not any conflicts existed between the design documents and the FSAR, and then to indicate the necessary resolution. The audit showed that some rereviewers had listed only the design documents which contained conflicts, and had indicated the required resolutions. In essence, therefore, these rareviewers did not understand the block 8 instructions to require a complete listing of documents--those which did not contain conflicts as well at those which did, i Nevertheless, the technical correctness of the rereview was validated, as follows: Rereview packages which did not provide a complete list of the reviewed documents were identified, and a large sample of them was selected. The packages selected were those which were most likely to contain design document confli:cs. The packages were re-rereviewed. From this re-rereview, it was ascertained that not a single package contained even a single unresolved conflict. At this point, the eereview process was approximately 80 percent complete (recall that it was an 18 month effort). While there appeared to be some misinterpretation of the block 8 procedural requirement, all the rereviewers appeared to understand the intent of the rereview effort and wars adequately resolving any conflicts.between the design documents and the FSAR. Based on this, it was decided not to rewrite the procedure for block 8 and not to redo the block 8 document listings. It was thought that such actions only would have confused the process at this point in time. After an exchange of correspondence with the NRC on this ites, however, we agreed to change the procedure and to provide additional 1-training to the reviewers. At the completion of the FSAR reroview effort, another sample of packages was re-rereviewed by the audit team with the same results, thus verifying the adequacy of the remaining 20 percent of the effort which had not been subject to the initial audit re-rereview. In essence, then, the two audit i re-rereviews confirmed the adequacy of the entire effort. l I i i xvii l-i oc0582-0039a167 h l i y ... - ~.,. -._ .~. --m 9
. ~ J 1-9 In testimony before the Soils Hearing Board, Dr Landsman indicated that the block 8 condition did not call into question the technical effectiveness of the r. review, which Dr Landsman specifically found adequate (TR.p-4857, 4930). [itoss 3. 'Ihe Preliminary SALP Report notes: ' ' ~ ~ 7 "Three examples of failure to translate applicable regulatory (g-4 k requirements and design critsria into design documents." i 11 e [ ; ( e. h* ' This item is also duplicated in the Design Control section of the J Preliminary SALP Report.
- e a.
The first example given is: "Tailure to maintain a coordination log of Specification y '. Change Notices (SCNs)." / In response, there are three separate coordination logs in the civil d discipline. These logs are maintained by three different people. The Drafting Supervisor maintains the coordination log for drawings and drawing change notices. The remaining documents, including SCNs, are covered by two other coordination loss which are maintained b;' Discipline Aides. During the Region III inspection, the Company could not immediately document that all coordination had been included on an SCN log. The problem was made worse by the fact that the NRC Inspector was inadvertently shown the. wrong log. Also the NRC Inspector felt that applicable procedures required all revisions of specifications, whether technical er clerical in nature, including those merely incorporating previously approved or coordinated SCNs, be reviewed by Geotech and so noted in tha log. Although the Company disagreed with this interpretation, the procedure was modified, making it clear that clerical revisions merely incorporating previously reviewed changes need not be re-coordinated or re-reviewed by Geotech. At the request of the Region III Inspector, the Company also committed to review current revisions of civil, Q specifications to insure appropriate coordination of changes was carried out. 1 In any event, this is hardly something which can be properly [ ]j'4 characterized as a " failure to translate applicable regulatory (requirements and design criteria irato design documents." V b. The second example given is: f j " Failure to correctly translate Specification Change Notice No l SCN-9004 as a requirement into Revision 20 of Specification C-t 208." i l-This item arose as a result of a slight difference in wording between an l-SCN and the specification, after incorporation of the SCN into the l xvii,i oc0582-0039a167 l-l t ^^ .)
._e - 1-10 specification, relative to the Geotechnical Engineer's responsibilities for establishing the laboratory compaction test frequency. The SCN was issued to describe the responsibilities of the newly assigned on-site Gaotechnit.a1 Engineer. The specification after incorporation of the SCN, used terms different from and more general than the SCN to describe the geotechnical engineer's responsibility for the establishment of the frequency for laboratory compaction testing. In our view, the intent of l both the SCN and the specification was the same, although the NRC Inspector did not agree. Subsequently, any difference in wording was eliminated. Again, this situation appears to be very harshly y],,3 ~ ',,c. $ characterized as a " failure to translate applicable regulatory 'j. ' / requirements and design criteria into design documents." 6 c. The third example given in the Preliminary SALP Report is: " failure of Engineering Department Project Instruction No EDPI 4.25.1, Revision 8 to establish adequate measures for design interface requirements." In response, the EDPI was revised to state that it is the responsibility of the originator of a design change to coordinate the change with all groups which are affected by, or involved with, the revised portion of the document, regardless of whether the change is technical or editorial. This procedural change was made to eliminate the previous option of the Group Supervisor to waive the need for the coordination or interface when, in his judgment, it was unnecessary. This coordination is now required even for editorial changes. Adequate coordinction had been accomplished prior to the EDPI revision. The need for this added conservatism introduced by the EDPI revision is a matter of opinion and Consumers Power Company has accommodated the rNRC's concern in this regard. However, there was never any " failure to M. - i translate applicable regulatory requirements and design criteria into ' jdesigndocuments"andtocharacterizethisiteminthatwayiserroneous (and unfair. y 4. The P eliminary SALP Report gives the following item: Qh [ " Failure to establish test procedures for soils work activities." e O., i g'J The NRC Inspector found that US Testing did not previously determine the f .c p 1 C., rheostat setting which produced the maximum density. However, US Testing ( did previously determine the rheostat setting that ' produced the maximum
- h amplitude required by ASTM D2049. Tests were reperformed to verify that the jI maximum rhoostat setting yields the maximum amplitude given in the relative g '(."
density table used for the project. Results were documented and supplied to i j the NRC. This is far different from a " failure to establish test procedures" as stated in the Preliminary SALP Report. Again, the Report's comments are a gross generalization and a misrepresentation of the factual situation. xix 4 oc0582-0039a167 l__
f 1-11 N b ds p.<!c, 5 '} ). f
- In this situation, the NRC Inspector did not accept an ASTM Standard
- d. 'c 1 :,is. procedure called out in the specification and imposed his own personal preference as to the technical requirement. Cma L ei c., jb y L.,.y
) u 1 ( w 5. The Preliminary SALP Report also indicates a: J [ " Failure to supply a qualified on-site Geotechnical Engineer." 'f[I As part of the original response to soils issues, a Geotechnical Engineer The resumes of the assigned engineer ("the \\ was assigned to be on site.first engineer") and of another applicant to the position ("the f,,, * .,^ p ', l engineer") were reviewed by Mr E Gallagher, then the cognizant NRC L Inspector. Mr Gallagher expressed his opinion to our Mr Horn that the second engineer was preferable because of his many years of field experience. We cannot say whether or not Mr Gallagher noticed that the second engineer was not a degreed engineer (although Mr Gallagher reviewed p !, I ' h> g the man's resume). On the basis of Mr Gallagher's opirion, the first i tj . engineer was removed and the second engineer was assigned to the site. \\,-),1,.) / Subsequently, another NRC Inspector, Dr Landsman, became cognizant in this ,d ( area. Dr Landsman who was accompanied by Mr Gallagher during this i inspection, was advised of the original coordination with Mr Gallagher, but i Dr Landsman held an opinion different from Mr Gallagher because the second i engineer did not have a civil engineering degree. Dr Landsman then cited the Company with a deviation for failure to provide a qualified Geotechnical i engineer for the job. Immediately thereafter, the first engineer was i reassigned to the on-site position. Dr Landsman concurred with this assignmerit. In view of these facts, the citation seems to us unfair. 1 6. The Preliminary Report also states: j/ "It was noted in NRC Inspection Reports No. 50-329/81-12; 50-I 'I / g> $ " N y
- 330/81-12 that a sufficient number of qualified personnel were not available for the complex nature of the remedial soils
\\/N'Y,f( work. This had previously been identified in NRC Inspection h[; '/T ST Reports No. 50-329/81-01; 50-330/81-01, referenced previously // as a deviation to a commitment." ,,I guli'p Inspection Reports No. 50-329/81-01; 50-330/81-01 deal with the deviation -et relative to the on-site Geotechnical Engineer. This was covered in - fh/ aragraph 5, immediately above. By the placement of this ites in two -) 7 different parts of the Preliminary Report, the appearance is given of twoPN CeM d different items when, in fact, there is only one. J NRC Inspection Reports No. 50-329/81-12; 50-330/81-12 merely indicated the NRC's advice to the effect that additional QA/QC personnel would be needed to accommodate the forthcoming remedial soils work. We agreed with this NRC { observation. We were not cited for any noncompliance on that score in these { inspection reports. We now have 8 full time and 2 part time QA/QC persons employed in MPQAD and 27 QA/QC persons employed by both MPQAD and Bechtel 4 Quality Control to cover remedial soils work--appropriate for the current workload, also taking into account the time necessary to assure their adequate training and certification. Five more persons are due on site by xx l oc0582-0039a167 f C'
1-12 mid May. Additional personnel are being sought to fill the 2 remaiu ng authorized positions. The Preliminary SALP Report gives the impression of an inadequacy with regard to the quantity of personnel when, in fe 4, quite the opposite situation exists. j Finsh.Ipff / l)stk w 20 SYD s f a 7/ ',7, . Anot item _raferenged in this section of the Report is duplicated 7. < M 's / }p, ind.he(tbTality Assurance Sectic'n of the Report. Please refer to Part 3, I,P((?yff Paragrapn U.4, above. 8. In summary,-while we find this section of the Preliminary Report inaccurate [' F '8M - andiverstated{wefullyrecognizethespecialsensitivitiesinvolvedinthe (Oc luve lh A yemedials soils area, and we are especially dedicated to the implementation of'the quality controls and assurances required by law and engineering vuom.'i C v ' e
- prudence.
fl, ?. F. Section IV.3 Performance Analysis of Containment and Other Safety-Related Structures 1. The cracks in the BWST foundation are also referred to in the section of the Preliminary SALP Report dealing with Design Control. G. Section IV.4, Performance Analysis of Piping Systems and Supports 1. Item a(1) of this section of the Preliminary SALP Report states that: "Bechtel Purchase Order did not specify applicable cocas for purchase of 60,000 pounds of E-7018 electrode." The original statement of the item, from NRC Inspection Reports No. 329/80-20-01 & 330/80-21-01 was as follows: "Bechtel Corporation Welding Star.dard WFMC-1, Revision 8, dated January 4, 1971, ' Welding Filler Material Control , Procedure Specification,' Paragraph 2.1, states, in part, that'. . welding filler material ordering information shall include the appropriate requirements of the job engineering specification, the applicable Code and this procedure specification....' ' Contrary to the above, on July 10, 1980, the (NRC) Inspector established (that) Bechtel Purchase Order No. 7220-F-5780, dated November 2, 1973, for 60,000 pounds of E-7018 electrodes did not specify the applicable Code.'" First, note that the Preliminary SALP Report statement omits any reference to the November 2, 1973, date. The Bechtel Purchase Order for the E-7018 electrode was issued on November 2, 1973. We question whether me should be 9 i cited in this assessment period for an event which occurred 7 years prior to 0e F the assessment period. J l Second, at the time of the procurement, a revision of WFMC-1, dated May, 1973, was applicable, whereas the citation referenced the January 4, 1971 xxi oc0582-0039a167 l s w
~ -m e 1-13 13p.O / . h g The procurement was made in accordance with the H ' /- ,~r f 5" ,/ ~ i revision of WFMC-1. pR, 1 (,, 1973 specification. The procurement documentation reflected complete g- .i. y ' . g compliance with the requirements. Although these facts were not available 'e immediately during the period of July 8-10, 1980, when the NRC Inspector was making the inspection, these facts were provided in our original response to a. s,/ the citation on August 25, 1980. e $' p'.I I In addition, Consumers Power Company has performed an audit of the ) procurement documentation for weld filler materials procured from 1973 through 1980. This, too, was reported to the NRC in the August 25, 1980 response. 2. Item a(2) in this section of the Preliminary Report indicates that an Authorized Nuclear Inspector's hold point was bypassed for the pressurizer surge piping. This item was detected by the NRC Inspector on September 24, 1980. By September 25, corrective action had been taken and verified by the NRC Inspector. 3. Items a(3) and (4) indicate that large bore pipe restraints, supports and anchors were installed incorrectly and that QC Inspectors did not detect the incorrect installations. Q / It is highly unusual to cite a licensee twice for what is essentially a k ,/ f_ single QA defect (one citation for the construction defect and another for / not having detected the defect). The NRC In pector found 7 cases of apparent nonconformances to design requirements. He steted that he was using cursory inspection techniques. Upon our further inspection, we agreed that 3 of the cases were defects, but with more refined inspection techniques our investigation indicated that 2 cases were within tolerance, I case was a result of obvious post-inspection damage that would be checked for during walkdown inspection, and I case was for work yet to be inspected initially. The 3 r,eal defects were of a l' e C relatively minor nature, and none of them impaired the function of the hangers even though they constitute a legitimate basis for the NRC's finding. On the basis of these findings, we agreed to make an extensive sampling %~ ' 1 reinspection of hanger installations which were made prior to 1981. The M,, results of this reinspection have indicated the presence of additional minor />**' Y ' c,. e c defects and may necessitate further reinjection. The results have been made
- i available to the NRC and now are being analyzed by both the NRC and Consumers Power Company.
4. Item a(5) in this section of the Prelininary Report, dealing with the l availability of Committed Preliminary Design Calculations for small bore pipe and piping suspension systems, is duplicated in another section of the j draft SAI.P Report dealing with Design Control and Design Changes and is the I major contributor to the Significant SAI.P Report Findings for Piping Systems I xxii oc0582-0039a167 i ( .A
. = - _ _ 1-14 and Supports given in Enclosure I to the Reference. Correspondingly, our response to this item is covered in Part 2, Paragraph B of this attachment. 5. Item a(6) indicates: " Failure to adequately control documents used in site small bore piping design activities." The original item from NRC Inspection Report No 50-329/81-12 and 50-330/81-12 stated that: "An (one) outdated specification was maintained at the small bore piping design group work location and revised calculations were not marked ' superseded' in accordance with the procedural requirements (our emphasis)." After careful checking, this finding was determined to have been an(isolate'd j
- case, i
Nevertheless, the calculations were checked and were found to be correct. Training was conducted of all personnel in this group. An audit was made. A procedure was changed to require that the specific revision number of ths specification on which the calculation is based be documented in the calculation package. 6. Item a(7) indicates that Consumers Power Company audits did not: I " Include a detailed review of system stress analysis and (did not) follow up on previously identified hanger calculation inconsis tencies." In response, the above statement refers to the fact that we did not audit for the availability and correctness of the Committed Preliminary Design j Calculations as discuss 2d in Part 2. Paragraph B, and Part 3, Paragraph G.4, above. The audits that were made previously in this area concentrated on the completed calculations, rather than the preliminary calculations. The audit checklist for this area has since been adjusted to reflect a requirement relative to the preliminary calculations. E i 8 .g l 1 xxili ~$ oc0582-0039a167 r
m. 4 l 1-15 H. Section IV.S. Performance Analysis of Safety-Related Components 1. As a result of the two original items, from which the two items in this i section of the Preliminary SALP Report are drawn, Consumers Power Company issued a formal Stop Work Order to Babcock & Wilcox and a letter to the NRC stating that the work stoppage would remain in effect until the corrective actions had been completed and reviewed by the NRC. Corrective actions were 4 taken, as follows: The installation procedure for this activity was revised to clarify the method of installation and to specify the required dimensional checks. The indoctrination ar.d training of the personnel performing the installation and of the personnel inspecting the work was strengthened. The Consumers Power Company overview inspection plan for this activity was revised. The NRC Resident Inspector verified these actions. 2. Again, it is encouraging that today's rating in this area, as stated by Mr R Cook during the April 26 meeting, is a strong " Category 2 " or even, perhaps, a " Category 1," based on the aggressiveness of our overview efforts. We recognize the particalar importance of this area, aad we intend to continue our agressive overview of this area. l. I. Section IV.6, Performance Analysis of Support Systems (HVAC) 1. Ve appreciate the " Category 1" rating for the period in question and on an informal basis for the current period, as well, as stated by Mr R Cook during the April 26 meeting. 2. It should be noted that the civil penalty was imposed for conditions which existed prior to the assessment period in question. 3. The 17 items referred to were all identified a t of investigations which were completed prior to(dune 30,1980[,and, therefore, prior to the i start of the assessment period.in que Con. This may be' observed by reviev of the individual items given in NRC Inspection Reports NA. 50-329/80-10; 50-330/80-11. Although these Inspection Reports are dated \\ January _12_1 1981, they clectly provide findings that were available prior to(June 30, 1980]\\ During management meetings held on March 24 and 28,1980, these investigation findings were discussed extensively. J. Section IV.7. Performance Analysis of Electrical Power Supply and Distribution 1. Item a(1) in this section of the Preliminary SALP Report indicates a failure to establish procedures for temporary support of cable. The four damaged cables were repaired. The procedure was revise 3 to require that coiled cables be properly supported, protected from damage and i 1 prevented from violating the minimum band radius. 1 I 2. Item a(2) in this section of the Report indicates that electrical contractors did not verify conformance to Paragraph 3.1 of Project Quality Control Instruction E-5.0. xxiy oc0582-0039a167 [ l-we s
1-16 \\ l This ites was an isolated incident of two wires violating separation standards inside a control panel. The cable routing was rearranged to provide the required separation, and the separation was verified by inspection. Electrical crafts and inspection personnel were formally reinstructed with regard to the separation requirements. Installation and inspection sids were provided to these personnel. 3. Ites a(3) indicates a: " Failure to identify and control nonconforming components." Because of the general nature of this item, we are not sure to what it refers. After a thorough review of the NRC Inspection Reports for this assessment period, however, we believe that it refers to an item from NRC Inspection Reports No. 50-329/81-11; 50-330/81-11, as follows: "On April 23, 1981, the (NRC) Inspectors identified 14 instances in which cable tray in the upper and lower cable spreading areas were not instalbd in accordance with the separation requirements delineated in the Midland FSAR and -which had not been identified and controlled to prevent )(.g ; p,d.gJD. inadvertent use or installation. . ~. -. _. _. _ of N,, %,,., Consumers Power Company documented the nonconforming condition for a few ^ cases on a Nonconformance Report issued in May, 1979, long before the NRC .tpen ywo e,yc. Inspectors' finclQig./ I. ate in 1979, it was determined that the existing ~j7"3 ' ' Marisite barriers were not the most suitable separation device for our plant configuration. This resulted, in January, 1980, in the removal of the 4 requirement for the Marinite barriers. In the spring of 1980, a study was conducted to determine which kind of barriers would be more suitable when i the required spatial separation is not possible. Two things resulted from this study--first, that barrier installation would be accomplished best after cable pulling was complete; an.1 second, that there was no risk in reworking cable trays after cable pulling to, install the barriers, if needed. In August, 1980, a new barrier was chosen and SAR and design changes were made in April and June, 1981, respectively to reflect these 1 changes. This is a lengthy discourse, we realise, but in essence, the usin points are as follows: we were well aware of the condition. At the time, we made a conscious decisioa not to provide any more inspection to identify additional specific cases where separation was not maintained. We were aware that the ,\\ design was being changed, that_the construction. process. was.,being, changed, , ij 3, , ' Y and th fathe riniiT Niintiil Quality Control inspection for this condition " ,.n
- h. g[ (Completion Activities,y' was revised to reflect th N-would be carried out.at the_sonclus, ion of the construction process."The i
' / SentiTProject Qualit Control Instruction E;3 07"F~ ins 1'Efeiitrical area / 1 I I ,s'.g,;. and, as needed, for the installation of barriers at the completion of th c (}, cable pulling activities. Correspondingly, we were holding open our s j ([: ] Nonconformance Report to assure that these changes were correctly ( p L{y. implemented. There was no inadvertent " failure to identify and control." t ,K, It was a. conscious and knowledgeable decision. xxy i oc0582-0039a167 i 1
1-17 / ,f This information was provided to the NRC on July 16, 1981, in our response to the NRC Inspection Report. Considering the explanation supplied to the >r [4 g Staff, we believe that there was no item of noncompliance and that this item / should not have been in this Preliminary SA12 Report. 1 4. Item a(4) indicates a: " Failure to translate design criteria into drawings and specifications." This inspection finding related to whether or not the color coding of instrumentation process Ifnes was required. Based on our reading of the applicable codes and standards, it was not, and we stated this position in our original response to the NRC. At least one other licensee has the same O[,l,9 position and is maintaining it. However, we have acceded to the NRC concern in this area by agreeing to identify the instrument process lines with a two / digit alpha designator, and the specification has been changed to add this I h* v new requirement. We are also not clear whether this requirement applies I I' generally or only in Region III, since the Draft Regulatory Guide on this lsubjectmakesnomentionoftherequirement. 5. Item a(5) indicates a: " Failure to identify during inspection that a nonconforming condition with regard to minimum installed cable bend radius existed." The condition re'farred to was discovered by a Consumers Power Company employee who wat accompanying the NRC Inspector during his inspection. A Consumers Power Company Nonconformance Report was written to document the condition for the single cable in question. In addition to physically correcting the condition, the Bechtel Quality Control Inspector who originally inspected the cable was given an 8-hour training program in all phases of cable termination. 6. Item a(6) indicates: " Failure to take prompt corrective action with regard to the lackofagprovalofproceduresforthereworkofelectrical raceways We agreed that this was an entirely appropriate finding and Bechtel t-l Cw.r.ruction and Bechtel Quality Control developed and issued the necessary aiministrative guidelines and instructions. Recently NRC Inspectors have c>nducted a follow-up inspection and determined that the rework controls t 'aave been properly implemented and carried out. 7. Item a(7) indicates: " Failure to provide adequate storage conditions for (three items)." xxvi l oc0582-0039a167 y ~m
1-18 The storage conditions for each of the items was immediately corrected. The Bechtel Maintenance Engineers were given additional training in accordance with the requirements of the field maintenance procedure. Consumers Power Company performed a comprehensive audit in this area to assure compliance with the field maintenance procedure. 8. It should be noted that each of the foregoing items is a Severity Level V or VI, relatively low severity levels. We are gratified that our informal current rating is "Cattgery 2," as stated by Mr R Cook during the April 26 meeting. 9. In two places in this siction of the Preliminary SALP Report reference is made to the quantity of Bechtel Quality Control personnel being employed, with the implication that this quantity may be insufficient. To our knowledge it was not; nor is it now. In addition, in response to NRC concerns we have demonstrated both the qualifications of these personnel and the process by which they are certified. K. Section IV.8. Performance Analysis of Instrumentation and Control Systems No comment. L. Section IV.9. Performance Analysis of Licensinz Activities Comments pretaining to our responsiveness to Staff requests for information regarding the " Soils" issue should certainly be qualified by noting the novelty or uniquaness of this technical review and the evolutionary nature of the Staff's positions. It is useful to note that as this review draws to its conclusion, the Advisory Committee on Reactor Safeguards (ACRS) subcommittee on the Midland soils questions characterized the Staff review as exhaustive and possibly an example of overkill.,In addition, the ACRS subcommittee questioned the Staff extensively on whether portions of their review and requirements want beyond what was necessary to protect public health and safety. We are gratified that the Staff finds our more recent replies to be responsive and of high quality. Ve are striving to maintain this trend and improve communications with the Staff. M. Section IV.10. Performance Analysis of Fire Protection We appreciate NRC's " Category 1" rating in this area and its recognition of our efforts. N. Section IV.11. Performance Analysis of Preservice Inspection In view of the extensive amount of preservice inspection which was performed k 7 during the period corresponding to this SALP Report and continuing into the ,W, current period, with no items of noncompliance, we fail to understand why this area is not rated as " Category 1" instead of " Category 2,". xxvii d' oc0582-0039a167 5 ,,n. l
1-19 j O. Section IV.12. Performance Analysis of Desian Control and Desian Change,s_ 1. Items a(1)(a) and (b) given in this section of the Preliminary SALP Report are duplicates of items given in Section IV.2. As such, our specific response to these items is given in Part 3 Paragraphs E. 2 and 3, and will not be repeated here. 2. Item a(2) in this secticn of the Report is a duplicate of an item covered in Section IV.4. As such, our specific response is provided in Part 3, Paragraph G.4 and will not be repeated here. 3. Item a(3) in this section of the Report is a duplicate of an item given in ] Section IV.7 af the Report. As such, our specific response is given in Part
- 3. Paragraph J.4 and will not be repeated here.
y wes c I,t c ?, .7 4. The five 10CTR50.55(e) items listed in this section of the Preliminary ' / Report relate to designs which were completed,long before the start of the SALP period in question--in fact,(fiTars beforD Our identification of these 1bJ 'M.Witems during this assessment period ~Iiidicates continuing design reviews, /*,," ,j improved design control and our rigid compliance with the reporting requirements of 10CTR50.55(e). 5. We also call your attention to five inspections of Bechtel Power Corporation, Ann Arbor Division, engineering firm for the Midland Plant, conducted between January, 1979 and September, 1981 by the Vendor Inspection Branch of Region IV. The inspection covered a* wide variety of design activities. For example, the October 7-10, 1980 inspection encompassed design verification, design interface, and design inspection activities. The March 31-April 3, 1981 inspection covered computer program control, technical persoanel background verification, design change control and design corrective action. The two specifically referenced inspections were conducted during the SALP appraisal period. In all five inspections, there l were a total of 6 nonconforming items identified, all of a relatively minor { nature (nonconformances or deviations rather,than violations). In two of the inspections no items of noncompliance were found. In our view, these i inspections are indicative of a high degree of compliance within design segments of the Midland Project, and would clearly support a higher rating i than the one given in this area. (n e five inspection reports are documented in letters dated April 16, 1981; October 14, 1981; November 5,1980; June 15,1979; and January 19, 1979, to i the Bechtel Power Corporation, Ann Arbor Division, from Uldis Potapors, Chief Vendor Inspection Branch.) 6. Considering the nature of Items a(1)(a) and (b) and a(3), and the unfairness 3 l of a citation for activities long before the period in question, we are [ disappointed by a " Category 3" rating in this area. I] We believe that design control is one of the most difficult and important aspects of nuclear power plant projects. Design control has been doubly difficult for the Midland Project mainly because of the duration of the _ l l project and the incorporation of a multitude of new regulatory requirements xxviii 1 oc0582-0039a167 i i-9y ---.,y.--.7-,.. ,y r
1-20 into the design as it progressed. We do not dismiss for a moment our obligation to monitor and improve our own efforts in this area and ws continue to institute our own internal programs to increase our confidence in the quality of the overall design effort. We raise this concern with the 1 preliminary SALP evaluation because the only significant finding in the SALP period that indicates a design control problem was the small bore piping lack of design package cover sheet, which was concluded to be an isolated 1 event. On the other hand, we believe that the Region IV inspection reports and the seven 50.55(e) reports referenced provide strong indications that the design control area is improving.
- Pi Section IV.13. Performance Appraisal of Reporting Requirements and Corrective Action 1.
In this section of the Report, it is stated that: "The licensee failed to make a timely determination for the need to submit a 10CTR50.55(e) Report to the NRC based on a 10CTR Part 21 Report from TransAmerica DeLaval, Inc." Consumers Power Company has always adopted a conservative attitude towards reporting under 10 CFR 50.55(e). We believe the industry practice in this regard varies, depending upon the amount of analysis undertaken and discretion exercised in determining whether a deficiency could have an adverse impact on safety. In the past, Region III has stated that the Company does a " good job" reporting under 10 CTR 50.55(e). In this specific case, the DeLaval Part 21 Report was sent to Bechtel and was misrouted, such that Consumers Power Company and the appropriate Bechtel personnel were not aware of the Part 21 Report on a timely basis. In the final analysis, the condition was determined not to be 50.55(e) reportable. Corrective actions were taken. They included issuing letters to suppliers to advise them of the person to whos Part 21. Reports should be submitted, i conducting training sessions at the site for key
- personnel to assure that misdirected Part 21 Reports get correctly redirected, and issuing periodic
} menos reiterating the information offered in the training session. 2. This section of the Preliminary SALP Report also states: } " Expeditious resolution of ncmcompliances is often delayed by 3 inadequate licensee responses'. 11e licensee has a tendency to i spend too much time trying to justify why a finding is not a '} noncompliance rather than ' devoting the time to correcting the i basic probles. Nine of 22 items of noncompliance were contested (excluding HVAC system noncompliances). TVo of the contested noncompliances were retracted, but time and effort -l were lost in timely resolutions. Similar attitudes and responses have been observed regarding Company audit findings. 1l This attitude is reflective of the licensee corrective action systes and becomes a detriment to quality." 4 xxix a oc0582-0039a167 i } j N y,, -,r 3
,n.
v-
~ l 1 1-21 In response, let's deal with the statistics first. TVo of the nine appeals (excluding NVAC) were granted, or 22 percent. Five other HVAC items were appealed, and two of those appeals were granted, or 40 percent. Combined, 14 items were appealed, 4 appeals were granted, or 29 percent. Of those not granted, the merits of the appeal are well documented. While there may be some unavoidable delay because of appeals, in no instance has an appeal precluded timely correctiva action. In addition, the Staff has repeatedly testified in the Soils Hearing that the Applicant should appeal when necessary or appropriate. During a meeting on October 5,1981, NRC's Region III management made it clear that NRC's concern was with the administrative process by which appeals were made, not with the appeals themselves. They stated that appeals should be made and dispositioned informally, if possible, prior to the issuance of NRC Inspection Reports or, at the latest, prior to our written response to the NRC findings. We agreed with this suggestion and assured the NRC that such appeals, if any, would be made accordingly. It is disappointing that the substance of this management discussion was not reported in the Preliminary SALP Report. Q. Section V.A. Noncompliance Data 1. It is important to recognize that the noncompliances and deviations given in the table for Midland Unit 1 are identical to those given in the table for Midland Unit 2 in the large majority of cases. We recognize that this is so stated in the footnote to both tables in the Report. 2. At this point, it is appropriate to reiterate from our response given in. Part 3, Paragraph I.3, that the 17 items associated with the HVAC were all identified as a result of investigations which were completed prior to June 30, 1980 and, therefore, prior.to the start of the assessment period in question. This can be seen by review of the individual items given in NRC i Inspection Reports No. 50-329/80-10; 50-330/80-11. Although these ~ Inspection Reports are dated January 12, 1981, they clearly provide findings that were available prior to June 30, 1980. During management meetings held on March 24 and 28, 1980, these investigation findings were extensively discussed..In conversations with NRC Inspectors, we were advised that these items are included in this SALP Report because they were inadvertently i excluded from the earlier Report, and that they have to be covered { somewhere. We believe that the earlier SALP Report should be revised to l reflect these items. The presence of these items in this SALP Report bears unfavorably and unfairly upon the overall impression offered by the Report l for the period in question. l R. Section V.B. Licensee Reoort Date l 1. The twelve 50.55(e) Reports listed herein further demonstrate our j cooperative approach with regard to the submittal of 50.55(e) Reports, as l stated earlier in our response given in Part 3. Paragraph 0. 4 and 5. I xxx i-oc0582-0039a167 i i. q -e
O 's 1-22 S. Section V.C. Licensee Activities No comment. T. Section V.D. Inspection Activi, ties f 1. The results of the Miy 18-22, 196,1, NRC team inspection evoked the following conclusion, as given in NRC Inspection Reports No. 50-329/hh12; 50-330/81-12: "This was an'in-depth ~ inspection to' examine the implementation / status and sffectiveness of the current QA Program, to dete:mine whether preriously identified quality, assurance probici2s w' re sufficiently precluded from occurrence in other e areas, eni to ascertain whether menagement involvement in the QA Program was sufficient and effective. 'i Although eight items of noncompliance were identified durini; this inspection, it is our (NRC) judgesnt that the scope and depth chthis NRC inspection was such that the identified noncompliences do not contravene our conclusion that Centlumers Power Company has established an effective' organization for the management of construction and implementation of quality assurance at the, site." ,s U. Section V.'E. Invertirations _snd A11eastions Review 4 / No investigations op' allegations were pursued during thesesstssment period corresponding to dir SALP Report, includinj investigations and allegations for HVAC. This supports our earlier assertions that rehren:o to the 17 HVAC items 4 should be deleted ~ entirely from this Report. T V. Section V.F. Escslated Enforcement Acticas 1. The civil penalty was imposed for conditions which existed prior to tne assessment period corresponding to,this SALP Report. 2. Under tlie/ heiading ot*
- C,nfirmatory Act on Lette ' are ttiose.xamples of inspection findings thit inoaar to be charactorind in an overly harsh manr.or. We-have been told in prior conversations that letters of committment by the licensee with sogard to inspection findings and which ceramit to actions desired by the NstC do not; constitute an ' escalated enforcemer:t action.' Obviously, we misunderstood. Not only are these s
.i letters c' a!tegorized under the escalsted enforcement heading, but the text. I ~ {- directly stites that these were in fact the licensee equivalent of an ~ -' insiediate action. letter. It 6-s our_ understanding that Region III agreement ' to a licensee ' letter of committent represented a Region III ' management i decision that the-item in question was downgraded la severity and did not reprs en C an escalated enforcement actlun. l ~ k 4; L qi (, , xxxi t i L a. .i
- t
\\ \\ - oc0582-0039a167 3 a 1-a
- 4..
N. \\ f / .f l }' y ' ^ ^ 3 1 ',.3 'Q. y'. a y '~ ~ wt s ~ 4,, ,,e, u c' * - A '*A ' ' ' ' ' ' ' " " ' * ~
i 1-23 W. Section V.G. Management Conferences 1. hro of these management conferences were at Consumers Power Company's request. 2. We strongly support the need for more management conferences with top and intermediate level NRC management participation, especially focused on attaining mutual understanding as to the standards that will be applicable to Midland inspections. 1 1 f i f t xxxit oc0582-0039a167 e ) __._m_.--_______m-__
l 2-1 COMPAMSON OF TESTIMONY OF JAMES G KEPPLER BEFORE THE ASLB ON JULY 13-14, 1981 WITM FINDINGS IN THE DRAFT SALP REPORT Introduction On July 13-14, 1981, Mr James G Keppler, the Director of the Region III Office of Inspection and Enforcement, testified that the NRC has reasonable assurance that quality assurance and quality control programs at Midland will be appropriately implemented with respect to future soils construction activity, . including remedial actions. In March 1982, Region III issued its Preliminary SALP Report on the Midland Plant. Nothing in the SALP Report contravenes Mr Keppler's testimony regarding reasonable assurance. All of the information contained in the SALP Report was known to Mr Keppler at the time he testified. 1. Quality Assurance a. SALP Analysis The report notes the creation of the MPQAD and Consumers Power's assumption of responsibility for onsite quality control and quality assurance functions for the installaticn of the HVAC systems. It also lists the findings of NRC Inspection Report No 81-12. The report concludes: The licensee is rated Category 2 in his overall quality assurance capability. Notwithstanding weaknesses identified in specific areas, the licensee has been responsive in establishing an overall effective organizstion for the management of construction and implementation of quality assurance at the site. b. Prior Testimony Mr Kepplegtestified extensively g garding NRC Inspection No 81-12,M the MPQAD-and the Zack matters.- Mr Keppler initiated NRC Inspec on No 81-12 for the purpose of determining the efficacy of the MPQAD. Mr Keppler personally inspected the w inspectorsattheconclusionoftheinspection,gkoftheNRC participat drafting the inspection report, and signed the final report.g inMr Keppler concurred in the report's conclusion that, although some problemswereidentified,theMPQADgndthequalityassuranceprogram at Midland were working quite well.- Mr Keppler also described the corrective actions Consumers Power had taken with regard to Zack, and concluded that the Za in quality assurance.g problem did not indicate a broader breakdown 4 xxxiii rp0582-2030a173
2-2 2. Soils and Foundations a. SALP Analysis The SALP Reports lists the soils-related noncompliances and deviations identified in NRC inspections of Midland during the SALP evaluation period (July 1,1980 to June 30, 1981). The report concludes that: The licensee is rated Category 3 in this area. The enforcement history indicates that additional licensee attention is warranted. b. Prior Testimony The evidence before the Licensing Board shows that Mr Keppler was thoroughly familiar with the 1980-81 enforcement history relating to soils issues when he made his judgment regarding reasonable assurance at Midland. Mr Keppler was Regional Director of Region III during this period an SALPanalys:sgjsigned all of the NRC inspection reports listed in the He testified in de problemsidentifedinthesereports.ggp1aboutmanyofthesoils He explained that all of the soils problems identified in 1980-81 were carefully reviewed and reassessed, and all pertinent records covering summer 1980, to May 1981 were examined, in assurance in May 1981.ggrriving at the conclusion of reasonable - Mr Keppler specifically noted that the history of soils work at Midland did not contravene his judgment of reasonable assurance. The soils problems, he testified, "can be largely attributed to the failure to fully recognize the importance of the application of quality assurance to soils work (but) the importance of quality assurance to soils work and to consequent remedial actions Consumers Power.3gy the Midland site is now fully recognized" by 3. Containment and Other Safety-Related Structures a. SALP Analysis "The licensee is rated Category 2 in this area. The licensee's performance appears to be satisfactory; no significant strength nor weaknesses were identified." b. Prior Testimony Mr Keppler did not testify on this subject. 4. Pipina Systems and Supports I a. SALP Analysis i The Report lists seven items of noncompliance identified by NRC Staff inspections during the evaluation period. Based on five of these xxxiv 4 rp0582-2030a173 s
2-3 items, an Immediate Action Letter (IAL) was issued on May 22, 1981. The report concludes: The licensee is rated Category 3 in this area. The enforcement history is indicative of weaknesses in the implementation of the quality assurance program. h. Prior Testimony MrKepplertestifiedregardingthepjgyngproblemsidentifiedduring NRC Inspection No 81-12 in May 1981.-- He explained that problems withpipingsystemsareanindustrygyideconcernthatisreceiving considerable Region III attention.-- Problems are in this ' area at almost every nuclear site inspected.ggfug identified The NRC Staff inspector who identified the piping problems at Midland is at the forefrontofknowledgeinthisarea,ang6pidnotconsiderthe incidents at Midland to be significant.-- NRC Inspection No 81-12 confirmed that the methodology of the design, installation and qua1 controlinspectionofthepipingandsupportsystemwasacceptable.-{3y It was the unanimous view of the inspection team that the problems identified were isolated, and not indicative of weaknesses in the implementation of the program.jgy major programmatic 5. Safety-Related Components a. SALP Analysis The report lists the two items of noncompliance which culminated in Consumers Power's issuance of a letter of understanding on January 22, 1981. The report concludes: The licensee is rated Category 2 in this area. The above enforcement was aimed at an isolated instance and may have been directly related to change in NSSS QC personnel changes. The licensee had in the past and since this episode maintained adequate QA control for the assembly of NSSS equipment. 'b. Prior Testimony } No testimony was given on this subject. { 6. Support Systems a. SALP Analysis l The report notes the quality assurance deficiencies and the Civil Penalty of the previous SALP evaluation period. It commends Consumers Power's " aggressive action"'in taking over complete responsibility for quality assurance and quality' control in HVAC installations; this j j action resulted in significant improvement in control over the installations and in correction of identified weaknesses. The report concludes: i l rp0582-2030a173 i 4 + w I
2-4 \\ The licensee is rated Category 1 in this area. Management attention and involvement has been aggressive in accepting full QA/QC responsibility and supporting this organization with an adequate number of skilled personnel. b. Prior Testimony Mr Keppler testified that the HVAC prgens problem did not indicate a broad breakdown in quality assurance.- 7. Electrical Power Supply and Distribution a. SALP Analysis The report listed seven noncompliances identified during the evaluation period and concluded: The Licensee is rated Category 3 in this area. The enforcement history indicates a lack of management attention and involvement. This is evident by apparent inadequate preplanning and assignment of priorities as activities increased, a poor understanding of procedures for control of activities and minimal QC Staffing for the magnitude of the activities. b. Prior Testimony MrKepplertestifiedthatelectricalworkwasextensglyreviewed during the May 1981 NRC Staff inspection of Midland.- The inspection team reviewed five areas within electrical work: quality assurance records, quality assurance implementing procedures, quality control personnel, visual inspection of electrical work activities, and Consuiners Power's actichs previously identified items. U / Only four problems were identified. j These problems were isolated and not indicative of any major prilf*""he inspectf on report also
- 'i' "'*k"'" ** 1" th' implementation of the 1 rogram.-
T conunenced Consumers Power for several aspects of their electrical work program. First, the program and its implementation regarding calibration of termination tools was judged to be satisfactory.Ej Second,ConsumersPowerhadtakentimelyandcomprehggyiveactionsto correct areas addressed on previous NRC inspections.- Finally, the qualityggyurance(electrical)organizationwasfoundtobestrongand capable.- 8. Instrumentation and Control Systems a. SALP Analysis i "The Licensee is not rated in this area because a minimal amount of instrumentation installation and minimal inspection effort during this evaluation period." i l xxxvi rp0582-2030al73 1 1 .i
j 2-5 b. Prior Testimony There was no testimony on this subject. 9. Licensina Activities a. SALP Analysis "The Licensee is rated Category 2 in this area. Early responses during the evaluation period were lacking in responsiveness. However, the more recent responses tend to be substantive and of acceptable quality." b. Prior Testimony Mr Keppler did not testify on this subject
- 10. Fire Protection a.
SALP Analysis "The Licensee is rated Category 1 in this area. Management attention has resulted in a high level of performance in this area." b. Prior Testimony There was no testimony on this subject. 11. Preservice Inspection a. SALP Analysis The Licensee is rated Category 2 in this area. The Licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified." b. Prior Testimony There was no testimony on this subject.
- 12. Desian Control and Design Changes a.
SALP Analysis t The report notes four design control related noncompliances identified by NRC inspections and five licensee-controllable Construction Deficiency Reports indicating a lack of quality assurance in design control during the evaluation period. The report concludes: The licensee is rated Category 3 in this area. The amount of re-engineering that has transpired in electrical, civil and piping l areas and the specific design contiol weaknesses discussed in xxxvii rp0582-2030al73 m
~ 2-6 Soils and Foundations, Piping Systems and Supports and Electrical i Power Supply and Distribution indicate significant weaknesses in overall design control. b. Prior Testimony Mr Keppler did not consider the prog}yes identified in the piping system to be a significant concern.-- He also testified that noncompliances identified by NRC inspections in the soils area, although o assurance.f87 neern, did not contravene his judgment of reasonable Another NRC Staff witness, Mr Gilray, confirmed that the two soils noncompliances referenced here by the SALP Report were not substantive and did a proceduresintoquestion.ggjbring the adequacy of Consumers Powers The May 1981 NRC adequacy of the electrical program at Midland.3fyspection affirmed the Mr Keppler did identifydesigncontrolasasignificantqualityrelatedproblem.397t
- 13. Reporting Requirements and Corrective Action i
a. SALP Analysis The report notes that Consumers Power contested several apparent items of noncompliance during the evaluation period, and concludes: 4t The Licensee is rated Category 3 in this area. The licensee responses to enforcement items and internal audit findings are often delayed requiring repeated submittal to obtain acceptable resolutions. b. Prior Testimony ) Mr Keppler testified that Consumers Power had responded to all items i I of noncompliance identified in NRC inspection reports. He noted that Consumers Power agrees with some such items and disagrees with others. Mr Keppler stated that the fact that Consumers Power does not agree with an apparent item of noncompliance is not a sign of poor i management attitude. If there is a valid reason to disagree with the ites, he adled, then they should disagree with it. This is a nor partofthegiveandtakebetweentheNRCStaffandthelicensee.gg) 1 -l i i f ]. 1/ Keppler, Tr 1884-47, 1981-77, 1981-83, 1998-2002, 2004-09, 2076-84. 2/ Keppler, Tr 1973-76. }/ Keppler, Tr 1935-36, 1964-66, and prepared testimony at p 4, following i Tr 1864. -t 4/ Keppler, prepared testimony at pp 4-7, following Tr 1864. 5/ Keppler Tr 2078-79. xxxviit t' j rp0582-2030a173 -] ? m e ---r r s.-,-m. - -,,,, wr
2-7 6/ NRC Staff Exhibit No 1; Keppler, Tr. 7/ Keppler, Tr 1973. 8/ Keppler, Tr 1935-36, 1964-66 and prepared testimony at p 4, following Tr 1864. i 9/ NRC Staff Exhibit No 1 (NRC Staff Inspection Report No 81-12); Staff Exhibit No 3 (NRC Inspection Report No 81-09), Gallagher, prepared testimony, Attachment No 3, (NRC Inspection Report No 80-32/80-33), following Tr, 1754. 1 10/ Keppler, Tr. 1935-36, 1964, 66 1887, 1942, 2002-09, 2013-2017 and } prepared testimony at pp 4-5, 7 9, following Tr 1864. 4 11/ Keppler, Tr 1913-14, 1977, 1982-83, 2083. 12/ Keppler, prepared testimony at p 8, following Tr 1864. 13/ Keppler, Tr 2004-09, 2017, 1942. 14/ Keppler, Tr 2006-09. ) 15/ Id. i H/ E-17/ Id, prepared testimony, Attachment No 2, at p 5, following Tr 1864. 18/ Id, prepared testimony at p 8, following Tr 186A. 19/ Id., at p 4. ~ 10/ Keppler, Tr 2076-78, and prepared testimony at p 7, following Tr 1864. 21/ Id, prepared testimony, Attachment No 2, at p 11, following Tr 1864. 22/ Id, at p 11-12. 23/ Id, prepared testimony at p 8, following Tr 1864. 24/ Id, prepared testimony, Attachment No 2 at p 12, following Tr 1864. 31/ H I; t 36/ H \\ 27/ See discussion supra under " Piping Systems and Supports." t 18/ See discussion supra under " Soils and Foundations." J d
- {:
.rp0582-2030a173 i jj. w y. w - ^ - - a J w---- m .,r, w-w
~ 2-8 l g/ Gilray, Tr 3742-43 (t.estifying regarding the soils noncompliances identified in NRC Inspection Reports No 80-32 and 80-33) 30/ See discussion supra under " Electrical Power Supply and Distribution." 0 3.1/ Keppler, prepared testimony at p 4, followir.g Tr 1864. 32/ Keppler, Tr 2083-84 i ~ x1 rp0582-2030a173
3-1 ANALYSIS OF CURRENT AND FWURE QUALITY ACTIVITIES WITH REGARD TO REMEDIAL SOILS WORK t,t the April 26, 1982 SALP meeting Region Administrator, Mr J G Keppler, expressed concern that his staff had informally chsracterized the ongoing soils and foundation work as only minimally acceptable. Mr Keppler asked CP Co's management to comment on its impression of this characterization and to provide its suggestion as to how this assessment could be improved. The following consists of a brief analysis of what Consumers Powar perceives to be the basis for this informal characterization and a description of some of the current organizational and programmatic features of the soils activities that lead us to conclude that prospects are excellent for the satisfactory execution of the remaining soils and foundation work. 4 The soils-related activities at the Midland job site are currently at a relatively low level pending completion of the NRC s,taff's technical review and release, by the NRC, of the major portion of the remedial work still to be undertaken. The work thet has been done thus far in 1982 is concentrated in two areas. First, a significant number of wells have been drilled at the site, as part of the plant dewatering systems, as part of the freeze wall i associated with the auxiliary building underpinning activity and to support the site drawdown tests. Second, the major contractor for the auxiliary building underpinning work was mobilized; the initial work on the access shaft j was completed; and, in parallel the detailed underpinning construction 1 planning and continuing technical review with the NRC staff of subsequent work was carried out. Very little work in the other remedial soils areas has been l accomplished during this period. In responding to Mr Keppler's comments at the SALP meeting, we believe that I the basis for the staff's informal negative comments regarding the current soils quality assurance activities can be traced to one specific area of concern and one more broadly-based general concern. A discussion of each of these follows. A specific area of work which may have been of concern to the staff, and one of immediate concern to Consumers, relates to the controls on the drilling and 3 } excavation activities that have been recently carried out. Because the number of NCR's that had been written in this specific area and the severity of the 6 most recent occurrence (drilling into an electrical duct bank), the Company concluded that even with the formal controls that were previously in place, additional controls were required. issued a stop work on all drilling. As a result on April 28, the Company (This Consumers Power stop work direction i preceded the ASL3 Order of April 30, 1982.) As of May 12, the stop work order had not been removed, nor will it be until a new detailed drilling and i excavation control procedure has been fully reviewed and accepted by Consumers Power Company. While there had been other corrective action taken prior to the CP Co stop work order, the Company is confident that the comprehensive revisions to the prior control procedures on drilling and excavation will preclude errors of the type recently experienced, and will assure that future xli rp0582-0091a100 I ~i i l' ~ m-- -e-p.-% y.y-e -..------y,y-w---, v 4 --M.......n- + r-4
o o 3-2 1 1 d-illing and excavating work will be carried out in a satisfactory and centro 11ed manner. The general and considerably more significant area of inferred NRC concern can only be identified as the lack of timely agreement between the Company and the NRC on the specific quality assurance coverage requirements to be imposed on the remedial soils work, particularly those to be imposed on the underpinning work. The lack of timely resolution of this issue, the apparent misunderstanding regarding the Company's commitments, and the contentious 1 atmosphere at the March 10, 1982 meeting on this subject and at the subsequent inspection undoubtedly contributed to the negative rating informally expretsed by the staff. When the auxiliary building underpinning work started with the first partial NRC release for construction of the vertical access shaft, CP Co presented a special quality assurance plan encompassing, in our opinion, appropriate portions of the underpinning work. This plan was initially presented to the staff at a meeting in Region III headquarters on January 12, 1982 and documented in a letter dated January 7, 1982. While the initial staff t response to the plan appeared to be favorable, no official NRC conclusion was expressed. It became evident during the time between January and early March that at least one individual within the NRC staff believed that an extensive modification of the program coverage under the QA plan, MPQP-1, should be required. This preference for expanded NRC requirements became an NFr staff working level position, formally expressed to the Company at the meeting on March 10, 1982. As a result of that meeting, the NRC Region III inspector apparently concluded that Consumers had committed to fully accepting the NRC Staff position that essentially all to-go underpinning work should be Q-listed, unless exceptions are agreed upon. The NRC's meeting minutes reflect no such commitment. In fact, no commitment was made. This misunderstanding, l and others arising out of follow-up discussions with the staff, has apparently 1 affected Region III's feelings toward our soils quality assurance program and personnel. It is, therefore, not surprising that the NRC Region III staff considirs the quality assurance activities in the soils and foundation area to 3 j be in need of improvement based on its recent experience. (It should also be noted that the NRC SALP Board held its second and final meeting on March 23, 1982.) The Company also agrees that it is extremely difficult to avoid regulatory difficulties unless both parties have a common understanding and agreement as to the scope of applicable requirements. The major issue with regard to QA program coverage was resolved at the management level meeting held on March 30, 1982 in Glen Ellyn and documented by the April 5, 1982 letter of J V Cook to J G Keppler, in which the Company agreed to "Q" list // essentially all of the to go underpinning work. However, the staff has still Haot formally acknowledged its concurrence with that letter. This concurrence 1 i would be of significant assistance in documenting the conclusion of the staff's review of program requirements and permitting the redirection of resources from program definition to successful program execution. I Resolution of the concerns noted above will make a significant contribution to i j the remaining soils work. In addition, the following considerations should provide added confidence that excellent results will be obtained in the i j remaining soils construction activities. xlii rp0582-0091a100 1 k = --
3-3 Dedication of a high quality professional staff to the underpinning and other soils work is of paramount importance to its successful completion. Because t of the complexity and importance of the underpinning work as the dominant factor in the soils remedial program, a mini project of dedicated groups has been set up to focus attention on the soils activities, with particular 1' emphasis on the underpinning. The technical qualifications of the individuals staffing these activities emphasize previous related experience. At the site, specific underpinning groups have been formed within Bechtel construction, Bechtel quality control and MPQAD, all staffed with individuals having significant applicable technical experience and academic credentials. Both Bechtel residert engineering and Bechtel engineering in Ann Arbor have dedicated remedial soils groups. The onsite resident engineering office will have four geotechnical engineers and at least two structural engineers dedicated to supporting the field activities. Consumers Power Company home-office soils ectivities are currently staffed with two experienced geotechnical engineers and several experienced structural engineers who have been active in the design reviews and prior licensing evaluations and who will i continue to follow the soils remedial work throughout the duration of the i construction. The overall Consumers Power Company project management of soils is also organized as a mini project, and the senior Consumers Power Company individual has had significant nuclear power plant experience at the project manager level. In addition to the on-staff individuals for Consumer s Power Company, Bechtel and the major subcontractors, significant consulting resources are also integrated into the soils work. The design consulting firm for the auxiliary building underpinning has a staff man onsite to coordinate with his home office personnel. All the major consultants will be asked to periodically review the job progress as the underpinning work proceeds. e l To assist some of the technical specialists in fully understanding all of the quality requirements on the job, some additions to the staff are also planned. 1 The Bechtel underpinning construction group leader, who oversees and interacts with the underpinning subcontractors, will have a quality consultant on his staff to assist him in any and all quality-related matters. It is also { anticipated that the underpinning quality control organization will be i augmented to enhance its breadth of leadership. i I' We believe that the NRC themselves can significantly assist in the successful completion of the underpinning and other soils remedial activities by expanding the presence of their lead inspector on the site as the work i progresses. Specific steps to facilitate th(r referenced above NRC interaction were agreed I upon, as documented in the(Apri K 19a2 tatte _ and )complementedbyday-to-dayworkingagreements. j A second area which should significantly assist in the successful completion j of the remedial soils work, particularly the underpinning activities, is the degree of design completion prior to the work entering the major construction i phase. Because of the extent and thoroughness of the NRC staff review, there is a more complete design for the underpinning activities than is normally in place for other construction activities. Essential completion of the I calculations for the underpinning work before the major construction phase xliii L j rp0582-0091a100 i i I ~ ,.ei. ,c-g. a s-wr -g- ---re---. ..---*g-y ---w- +r g.~.---- y---- +w w.-*-m---w--w-e.wy vv--=
.- - _ _ _ _ - = l { 3-4 begins will minimize the kind of major design changes that can occur in nuclear plant structural design process because of calculation revisions. i There will, of course, be design changes as the work progresses, but the degree of calculation completeness reached prior to initial drawing ielease will significantly contribute to the stability and success of the construction process. In addition to the degree of completeness in the underpinning design activity, the interface review called for by the quality assurance plan for the underpinning activity, MPQP-1, is also substantial. These reviews will also contribute to both the validity of the design and the general understanding of design requirements and quality attributes by all persons participating in the 1 underpinning activities. In addition, MPQP-1 directly inserted quality assurance (and through quality assurance, quality control) comments into the design review cycle, a significant requirement above and beyond the quality assurance program for the balance of the plant. The number of procedural controls that have been or are being instituted for this work should also engender confidence that the critical underpinning activities will be satisfactorily controlled. Judging from the work to date, {. there will be more than 50 specific work procedures developed for the underpinning work. MPQP-1 calls for integration of inspection hold points directly in these construction work procedures. As a result of these steps, the procedural controls for the underpinning work will be more extensive than those for any other activities, with the possible exception of NSSS primary loop activities, covered by the QA program for the balance of the project. The extent of the construction procedures automatically increases the scope of the ] training activities and of the inspection plans which are developed based on the specific work procedures. J Finally, as a result of the extensive discussions with the NRC staff regarding the coverage of the "Q" program, MPQP-1 is being applied to essentially all of j the underpinning work still to be done. While this application may or may not be completely consistent with a strict definition-of what is " safety-related," it should lend added assurance that the work in total, and the safety-related work in particular, will be carried out successfully. In light of the foregoing, it is hoped that the Region III management can gain i en appreciation cf Consumers Power Cospany's perception of recent events and that both the Region III management and' staff can develop added confidence that the to go soils work, particularly the extensive underpinning activities, g can and will be carried out up to the expectations of both the applicant and l the NRC. l l ^l l i l xliv rp0532-0091a100 i. V, l ~.-~ ~,
CORSumCf5 Power mm C0mp2Hy wa *>s - - ~ m s r - e c n=<sie. o ,e own.: Seas w.m r.rama n
- s. Jan=a. nu assai. tsin 7ssessa May 21, 1982 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND PROJECT RESPONSE TO DRAIT SALP REPORT I
FILE:
0.6.1 SERIAL
17249 At Page 3-1 of Attachment 3 to Consumers Power Company's " Response to Draft SALP Report", dated May 17, 1982, Paragraph 5, the sentence,"As a result on April 28, the Company issued a stop work order on all drilling" should have stated, "As a result on April 28, the Company issued a stop work order on all drilling conducted by Mergentine and its subcontractors." As was previously indicated in the Company's May 10, 1982 letter to H R Denton, which was reviewed with NRR prior to submission, installation of the permanent site dewatering system was being continued (under previously given NRC Staff approval). Region III was also advised, both by a copy of the May 10 letter and by telephone, that work on the permanent site dewatering system was continuing. We regret this inadvertent editorial error. j .i j JWC/JEB/dsb f j s CC Atomic Safety and Licensing Appeal Boged CBechhoefer, ASLB i HMCherry, Esq FPCowan, ASLB -RJCook, Midland Resident Inspector SGadler l JHarbour, ASLB 1 DSHood, USNRC t RBlandsman, USNRC, Region III l WHMarshall BStamiris MSinclair xlv oc0582-0025al64 MAY 2 51982 e e se o y- .-m
BCC WRBird, P-14-418A AJBoos, Bechtel JEBrunner, M-1079 DMBudzik, P-24-517A MLCurland, Midland LHCurtis, Bechtel MADietrich, Bechtel-Midland WDGreenwell, Bechtel GSKeeley, P-14-1138 BWMarguglio, JSC-220A DBMiller, Midland MIMiller, IL&B JAMooney, P-14-115A JARutgers, Bechtel TJSullivan, P-24-624A DMTurnbull, Midland RAWells, P-14-113A NRC Correspondence File 4 i xlvi oc0582-0025a168 i ,4 ,,, ~,,, <
l I. INTRODUCTION The NRC has established a program for Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon these observa-tions. SALP is supplemental to normal regulatory processes used to insure compliance to the rules and regulations. SALP is intended from a historical point to be sufficiently diagnostic to provide a rational basis: (1) for allocating future NRC regulatory resources, and (2) to provide meaningful guidance to licensee management to promote quality and safety of plant construction and operation. A NRC SALP Board composed of managers and inspectors who are know-ledgeable of the licensee activities, met on October 23, 1981 and March 23, 1982, to review the collection of performance observations and data to assess the licensee performance in selected functional areas. This SALP Report is the Board's assessment of the licensee safety performance at Consumers Power Company's Midland Nuclear Power Plant, for the peri _od ] { 111980toJune,30,l198g. The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held April 26, 1982. 8 t i i i 1
j e II. CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not ba assessed because of little or no licensee activities or lack of meaningful observations. Special areas may be added to highlight significant observation. One or more of the following evaluation criteria were used to assess each functional area. 1. Management-involvement in assuring quality. 2. Approach to resolution of technical issues from safety standpoint. 3. Responsiveness to NRC initiatives. 4. Enforcement history. 5. Reporting and analysis of reportable events. 6. Staffing (including management). 7. Training effectiveness and qualification. However, the SALP Board is not limited to these criteria and others may have been used where appropriate. Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is: Catezory 1. Reduced NRC attention may be appropriate. Licensee man-asement attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample'and wffectively used such that a high level of performance with respect to operational safety or construction is being achieved. Catezory 2. NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear safety; Ifcensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or constructio.1 is being achieved. Catezory 3. Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minime11y satisfactory performance with respect to operational safety or construction is being I achieved. l 2 v
e 1 i l III. SUP!!!ARY OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1. Quality Assurance X 2.T SdiiTC~isd Foundationg ]~/ 3. Containment and other Safety-Related Structures X 4.JMJji@{antsupportj J 5. Safety-Related Components X 6. Support Systems M
- 7. 6 y pply g j 8.
Instrumentation and Control NOT RATED Eystems 9. Licensing Activities X
- 10. Fire Protection
- 11. Preservice Inspection X
- 12. 5 = i b "- -J'"^ *
(Desh.Chanask ,Xl / ~ 13.' Rep 6rtu~Yiiufr~Eisand)-- [X[/ 4 . Lor,rective,, Actio]n t, e i I 3 I .1
= 4 IV. PERFORMANCE ANALYSES 1. Quality Assurance a. Analysis Effective August 15, 1980, Consumers Power Company reorgan-ized the site QA functions by creating the Midland Plant Quality Assurance Departrent (MPQAD) which was composed of both Consumers Power Company and Bechtel Power Corporation personnel. This reorganization was instituted in the interest of more comprehensive coverage of QA and more timely resolution of noted discrepancies. Consumers Power Company retains the lead responsibility for QA. Also during the evaluation period, Consumers Power Company assumed responsibility for all onsite QA and QC functions for installation of HVAC systems. These functions and controls were previously handled by The Zack Company. The changes in responsibility were implemented to " establish more effective QA/QC interface; provide increased technical support; and provide a mechanism to improve inspection performance." An indepth team inspection was performed May 1981, to evaluate the impact of the changes on the overall QA Program implementation and effectiveness. Although eight items of noncompliance were identified, the Jower Company had established'an effective organizatfo's~fo/l scope and depth,of_the_ inspections indicated that Consumers sanagement of QA/QC activities at tWHQ. ~The inspection 'Feveal~'d' tlUiii the overal1Tiumber and kualification of e personnel in the licensee's QA organization were above that normally found at other construction sites. The QA programs and overview inspections and audit functions were also above the norm. Adverse findings in piping systems and supports and electrical power supply indicated a need for additional licensee attention in these areas. Seven of the eight nou-compliances (Severity Levels V and VI) were addressed in these functional areas. The eighth noncompliance (Severity Level IV) was generic to several functional areas; a failure of appropriate managers to take prompt comprehensive corrective action to correct i identified adverse Quality trends. This item of noncom-l
- cause,for,i @ncreaslag numbers of reported deficiencies.Kive of pliance was Thj i
L' - weaknesswasegen(surin[t,h_ep,rev_lousBALPyriof. 5 O e 4
In another inspection a Severity Level V noncompliance was identified indicating questionable QA managerial.contr.ol_. D, The licensee fait ~ef to fdlly evaluate the technical cap ' ability of the principal supplier of services for soil,- ^ ~ xboring _ activities J The NRC ~idirit111'ed'1fdeffeiencies in~ the principal supplier's Quality Assurance Procedure Manual indicating that tha licensee had not adequately reviewed ang 'activiti~es'."procedu*RT4Yfb7To preparatibit"bf"dFITTing --- ~ approved the ' ' ~ ^ b. Conclusion The licensee is rated M in his overall quality assurance capability. Notwithstanding weaknesses identified in specific areas, the licensee has been responsive in establishing an overall effective organization for the management of construction and implementation of quality assurance at the site, c. Board Recommendations ~' _The Eird notes theB1mn,1 fica ~nt improvements in the overalf f Quality Assurance Fr' gram;ghowever, it"'is ' recommended that o both'the NRC and the licensee give additional attention to ~ the specific problem areas. 2. Soils and Foundetions a. Analysis During the evaluation period, inspections have been per-formed to examine the licensee's implementation of corrective actions regarding the 10 CFR 50.54(f) request for additional information pertaining to soils settlement; observation of soils work activities and to witness taking of soil borings requested by NRC reviewers and consultants. Since 1978, the soils settlement issues have been paramount in the amount of attention by the NRC to this licensee. This activity resulted in an order issued December 1979, which is i the basis for a ongoing hearing on the soils settlement issues. s A multitude of effort by the NRC and licensee has gone into soil testing and major review of the FSAR and design control. In spite of this attention, evify lkspict'lon'involvin'z'l i [ regional basefinspectors fina addressing so11s ;settTes% resulted in at jeast.one significant item p ssmuss n== l Ynon ,aaanH]^The'iriforcement his't'ciry for 'this' fun ~ctional l ' area'during this SALP period is as follows: Two Level IV noncompliances were identified in NRC Inspection Reports No. 50-329/80-32; 50-330/80-33. I. 5
l i I (1) Failure to initiate audit corrective action concerning the rereview of the FSAR and references to determine if design documents had modified the FSAR and if so that changes had been made to the FSAR. (2) Three examples of failure to translate applicable ~ regulatory requirements and design criteria into design documents. (a) Failure to maintain a coordination log of Specification Change Notices (SCN). (b) Failure to correctly translate Specification Change Notice No. SCN-9004 as a requirement into Revision 20 of Specification C-208. (c) Failure of Engineering Department Project Instruction No. EDPI 4.25.1, Revision 8 to establish adequate measures for design interface requirements. One Level V noncompliance and a deviation were identified in NRC Inspection Reports No. 50-329/81-01; 50-330/81-01. ) f(1) Failure to establish test procedures for soils work ,p activitiea. , ' (2 Failure to supkly M ualified onsi E g~e~o' technical en7 n 2 ; ~ , [/ g / ,- ~..... ,n l OnT level V noncompliance was identified in NRC Inspection ' Reports No. 50-329/81-09; 50-330/81-09,which is discussed \\ ._under the Quality Assurance Section. However, the finding of lack of QA was a result of' attempting to review the QA associated with procuring soil boring samples. Failure to evaluate the technical capabilities of Woodward-Clyde (principal supplier *of services for soil boring activities) prior to procurement of a drilling contractor. p as noted in NRC Inspection Reports No. 50-329/81-12; / l 50-330/81-12 that a sufficient number of qualified personnel 1 ~3 were not available for the complex nature of the remedial p d, / soils work. This had previously been identified in NRC Inspection Reports No. 50-329/81-01; 50-330/81-01, referenced ,( previously as a deviation to a commitment. b. Conclusion The licensee is rated @ H Eg~ @ ]in this area. The enforce-sent history indicates that additional licensee attention is warranted. ( 6 1 k
e c. Board Recommendations _TheBoardrecommendedcontinydNR ieach major _ evolution in the_reEETu_C inspection activity forj tion _of soils settlemeny .issuesJ. n__ The issues identified during this evaluation period were addressed with the licensee and were thought to be resolved. However, following this evaluation period there was a period when very little physical work in the solis settlement and underpinning area was initiated onsite. When actual physical work was resumed it was found that adequate QA/QC attention was not given to these work activities. These areas have again been addressed and are believed to be resolved. Continued attention is required by both the NRC and the licensee. 3. Containment and Other Safety-Related Structures a. Analysis During the evaluation period, containment prestressing system procedures were reviewed; selected work activities associated with tendon insertion and buttonheading for Unit 1 were observed and prestressing system material' records for Unit 1 and quality records for Units 1 and 2 were reviewed. During the previous evaluation period the licensee experienced difficulty in installation of prestressing tendons. However, these difficulties did not exist during this evaluation period. The Senior Resident Inspector witnessed portions of the atmospheric hydrostatic test placed on the borated water storage tanks (BWST) including an examination by Quality Control and the Authorized Nuclear Insp6ctor. The hydro-static test was done in an acceptable manner. Although the hydrostatic test was completed without complications, loading of the BWST with water resulted in cracks developing in the valve pit area associated with these tanks. b. Conclusion Thelicenseeisrated[dateibyy'yinthisarea. The licensee's performance appears to be satisfactory, no significant strength nor weaknesses were identified. c. Board Recommendations None. 7 h i
The Board notes that subsequent to the evaluation period it was determined that the cracking in the valve pit support walls was related to soils issues. 4. Piping Systems and Supports a., Analysis During the evaluation period, installation of large and small bore piping and pipe hanger systems (including storage of piping components) was examined and noted in seven different inspection reports of regularly scheduled inspection activities. Three of these inspections, including a team inspection, resulted in' items of noncompliance and an isolated instance o' na equate dunnage in a temporary storage area. The following items of non-compliance indicate weakness in the implementation of the QA program. (1) Bechtel Purchase Order did not specify applicable codes for purchase of 60,000 pounds of E7018 electrode (In-fraction). (2) Bypass of an inspection hold point for. pressurizer surge piping (Infraction, Unit 2 only). (3) Failure to install large bore pipe restraints, supports, and anchors in accordance '<ith design drawings and specifications (Severity Level V). (4) failure of QC inspector to reject large bore restraints, supports and anchors that were not installed in accordance with design drawings and specifications (Severity Level V). ~ (5) Failure to prepare, review and approve small bore pipe and piping suspension system designs performed onsite in accordance with design control procedures (Severity Level IV). i -s (6) Failure to adequately control documents used in site small bore piping design activities (Severity Level V). .s (7) Failure of audits to include a detailed review of system stress analysis and to follow up on previously identified hanger calculation inconsistencies (Severity Level V). Based upon the last five items of noncompliance, an Immediate Action _ Letter. was issued on May 22, 1981, pertaining to j theggibygt [forthe"1nstalla-i tion of [aWsfipF6ft79 stems. 4 + 8 4
e-b. Conclusion The licensee is rated }ateg d j in this area. The enforcement history is Indicative of weaknesses in the implementation of the quality assurance program. c. Board Recommendations The Board notes that subsequent to the evaluation period an inspection on July 16-17 and 23-24, 1981, verified that the licensee had satisfactorily addressed the provisions of the May 22, 1981, IAL. Also on July 27, 1981, the licenses submitted a letter of understanding to the NRC stating the actions to be taken to control modification to small bore piping drawings which do not have Committed Preliminary Design Calculations. The Board recommends increased licensee and NRC attention. 5. Safety-Related Components s. Analysis During the evaluation period, NRC Inspectors observed alignment of reactor coolant pumps; installation of lower core support assembly vent valves and associated portions of quality documentation. The enforcement history consisted of two_ items of noncompliance and LConfiziInstody'Etfo} h@ All were issued as a result of NRd71ndings~during I ~ the installation of the core support assembly vent valves. The following is a summary of the items of noncompliance which culminated in a letter of understanding issued by the l licensee on January 22, 1981. l (1) Failure to have an appropriate procedure for installation of vent valves (Severity Level V): (2) Failure to follow access control procedures and account for items used in the assembly of the Unit 2 core support assembly vent valves on the equipment entry log (Severity Level V). The licensee's letter of understanding stated that the Stop Work Order on assembly of core support assembly vent valves would remain in effect until procedures, personnel training and QA overview inspection plans are upgraded. b. Conclusion The licensee is ratedkee~pyjtjin this area. 'Ihe abeve enforcement was aimed at an 1solated instance and may have 9 't. .~~
-~ _-.. - - - 2 G been directly related to changes in NSSS QC personnel changes. i The licensee had in the past and since this episode maintained adequate QA control for assembly of NSSS equipment (particularly reactor internals), c. Board Recommendations None. 6. Support Systems a. Analysis On January 7,1981, a $38,000 civil Penalty was levied against the licensee for QA deficiencies in the installation of heating, ventilating, and air conditioning (MVAC) systems which were noted during an investigation during the period of March 6, 1980 to July 31, 1980. Seventeen items of non-1 compliance were identified during this investigation and one additional item was identified in a later report (NRC Inspection Report No. 50-329/80C22). The later ites was not { considered in the Civil Penalty.4 /T j _ Theaboveenforcementhistorywasreflected1)theprevious SALP evaluation.. The licensee has made significant improve-ment in correcting programmatic weaknesses identified in the Civil Penalty. Since the investigation, the licensee has accepted complete responsibility for NVAC System QA/QC functions. This aggressive action of taking over the QA/QC function from the subcontractor has resulted in marked j improvement in the control of the HVAC installations. i: 1 b. Conclusion 3 The licensee is rated',Catgangfhin this area. Management attention and involvement has been. aggressive in accepting full QA/QC responsibility and supportin's this organization with an adequate number of skilled personnel. f c. Board Recommendations -The licensee should continue his attention in this area to assure a continued high level of performance. The NRC should continue inspection efforts in this area to assure the licensee commitments are being met. 7. Electrical Power Supply and Distribution a. Analysis During the evaluation period, two routine inspecticas and i part of a team inspection were performed in the electrical 10 o aw - e
o t area. Portion of five other inspections addrensed specific electrical items with one of these inspections addressing the in place storage condition of clectrical equipments. As a result,of the inspection effort dedicated to the electrical ' area, six Atems' of noncompliance were identified. The ~ inspection effort into the equipment storage conditions 3 resulted in a~ single item of noncompliance with three examples two of these examples were for electrical equipment. The re was essentially no electrical installation work per-formed for more than six months into the evaluation period 'because of the need to perform re-engineering to permit routing of the cables without thermal and/or physical overload of the raceways. When electrical work was resumed, it was dare or a very ambitious schedule. Prior to this resumption,sf work the NRC had verbally advised the licensee on the 'tead. for adoquate QA/QC coverage. However, it appears that noty nough qtialified QC personnel, rigorous QA audits and established procedural controls were invoked to avoid bhefolhiaslistnfenforcementitems. s w (1) Failure to er:ablish procedures for temporary support of cable,,' cable cuils---and for routing cablas ',, (Severity Level V) s'- .s. ' (2).'.?.lectrMal. contractors failed to verify conformance ~to Paraguph 3.J of Project Quality Control Instruction E-5.0, fa'ilurelto[ perform adequata' inspection (Severity Level,V) ~ (3) Failur's.to identify and control nonconforming components (S verity Level V) ? (4) Failure _ts ranslate dasisn criteria into drawings and specifications (Severity Level N)^ ^ (5). Failure to identify during inspection that a non-4 conforti.ng' condition with regard tu minimum installed a cable' bind radius existed (Saverity Level VI) T \\(6) Failure to take' proper corrective action with regard f s ^ L to the lack of approved procedures for the rework of N' electrical raceways (Se' verity Level V) s U)' Failure to provide adequat e sterage conditions for ~~ s " (Sevpity Level V), e-4 i (a). Control Rod Driv 3 Frimary AC Breakoes ? (b) New7nd spent fuel afioraga racks. j ,[ (c) Emergency battery char.gers s s 'b~ 1. g (1 s e,, s ~ x + F s .g 1 11 y f ~ / + 5\\ L _)" g e ' '" x ' ( , s, i j' iv A x' >v N, r
i 4 i b. Cor.clusion Category.J- )in this ares. The [iinforcement historyl(indicates a lack,of, manageme$ The licensee is rate ~ [- attentzoE'and lavolvemeJn. This is evident by apparent "Gadiliquare~ preplanning and assignment of priorities as a activities increased, a poor understanding of procedures for control activities and minimal QC staffing for the magnitude of the activities. ] c. Board Recommendations The Board recommends increased attention by both the licensee and NRC. Inspection effort should place particular emphasis on those' areas of heaviest activity for the month proceeding the inspection with particular emphasis on the number and qualification of QC personnel. The Board notes that the licensee performed an internal audit of the area and initiated corrective action sub-sequent to the evaluation period. This audit was limited and the licensee has indicated that it did not address all NRC concerns. The results of this audit have not been evaluated by the NRC. [ t 8. Instrumentation and Control Systems a. Analysis I 4 The licensee is not rated in this area because a minimal amount of instrumentation installation and minimal inspection effort during this evaluation period, b. Conclusion None. c. Board Recommendations Based upon the findings in electrical power supply and distribution, the Board recommends increased licensee and .f NRC attention commencing with increased installation ac-tivities. Particular emphasis should be placed on design _j control and QC coverage. This increased inspection effort ,l could be done coincident with. electrical inspections.- 'i 9. Licensina Activities i H a. Analysis Responses and submittals during this review period have principally regarded the soils settlement issue, including, seismic input and responses to Post-11t! requirements 12 . 'i 4 .L_ 3 ^
y ~ (NUREG-0737). During the earlier part of this review period, replies to staff's request waru not substantive end tended to argue the staff's need for that information; once a staff position was taken, the replies tended to become responsive. '~ener,,the quality o( the response tends to be acceptable once the need is firmly established. Because of the time expended 1 in establishinE t need..more thari the normal amot:at of time and effort are required to obtain acceptable and substantive responses. Recent responses establishing new seismic design criteria for the site have been of high quality once the staff's position letter established the need. The ficensee is considered to be technically competent and is_an e.nperienced utility with two operating nuclear plants. Timely close out or 2ong-standing open items is reasonable .when considering ths many open items on this plant, the early plant design and /nterrupted staff review following the TMI-2 eccident. 2 b. Conclusion ThelicenseeisratadjahirQinthisarea. Setly responses during the evaluation period were lacking in reaponsiveness. However, the more recent responses tend to be substantive and ~.,f acceptable qualify. c
- c. - b_o,ari Reconnenda_tions None.
~
- 10. Fire Proteetly a.
' Analys is j ~ During the.evaluatier. period, the Senior Resident Inspector toured'selectml areas of the site'eac.h month to assess the cleanliness of the site: and deterndne the: potential for fire cr cther bcr.irds'which might have a deleterious effect en. pSrsonnel and Aquipment. The site has malotained an adequate t I safety record during this SAIF period. A substantial portion cf the site safety program is devoted to fi:*e protection. The licensee conducts weekly training and drills'for'the on site fire brigade.. The fire brigade has consistantly passed the quarterly fire drills imposed by the licenseei's insurance agency. Volatile chsmicals are controlled and Issued in small.quantitie.1 in metal containots; Volatile chemicals, of'.s,' combustibles and tr' ash are not tolerated in an unclean .l ami uncontrolled state. l11a ~ hazards were minimized during ~ ~ )e evaluat' ion periodymd the licensee has accrued a multi-t q } m;'.lfon-hour safety record / 3 m: t i k c ~ j 13 u t i ' c ' l}o ( g. m } N-s .~ . - +.. yjg. -g z,. 3., .. -,... ~... - ....~ s '\\ W ~ ~ s j ' fj i
a b. Conclusion The licensee is rated 3a(hy] in this area. Management attention has resulted in a high level of performance in this area, c. Board Recommendations None. 11. Preservice Inspection a. Analysis During the evaluation period, three routine inspections were performed to evaluate the Ultrasonic Testing (UT) of the reactor pressure vessels by South West Research Institute (SVRI) and the preservice inspection being performed by Babcock & Wilcox (B&W). The inspection effort revealed that adequate management controls existed for the inservice inspection program, procedures, and material and equipment. The licensee responses to IE Bulletins was determined to be complete in this area. The data reports demonstrated that QA/QC audits and requirements are met. The qualifications and training of SWRI and B&W personnel was in accordance with SNT-TC-1A,1975. b. Conclusion Thelicenseeisratedjetlegoryjinthisarea. The licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified. c. Board Recommendations-
- None, t
12. Design Control and Design Channes f a. Analysis } During the evaluation period, three items of noncompliance were identified sgainst 10 CFR 50, Appendix B, Criterion III, Design Control and one item against Criteria XVI, Corrective Action which was closely related to deficiencies in design control. These items of noncompliance have been addressed in other sections of this SALP Report. However, the common l bond between these items of noncompliance is that each- ~ ] addresses inadequate design control. The following is a reference list of these items of j noncompliance: 14 ~ 1 =
(1) Section 1, Soils and Foundations (a) Failure to initiate preventive action to preclude { repetition of not identifying design documents. (b) Three examples of failure to translate applicable regulatory requirements and design criteria into design documents. (2) Section 3, Piping Systems and Supports Failure to prepare, review and approve small bore pipe and piping suspension system designs performed onsite in accordance with design control procedures. (3) Section 6. Electrical Power Supply and Distribution Failure to translate design criteria into drawings .and specifications. In addition to the enforceme t items listed above, an j Immediate Action Letter was issued by the NRC pertaining to design control and issuance of drawings for the installation of small bore piping. This ites was previously iterated in Section 5, Piping Systems and Supports. j Also, the following five 10 CFR 50.55(e) summaries, which i were among the twelve Construction Deficiency Reports sub-mitted demonstrates there was lack of QA in design control and these instances should have been licensee controllable. (a) High Energy Line Break Analysis (HELBA), steady state thrust forces rather than transient peak thrust forces we.~e used in the energy balance techniques for the design of HELBA pipe whip restrain,ts. (b) Component Cooling Water (CCW) Design, CCW system _j susceptibility to Loss of Coolant Accident (LOCA) induced failures. 'l ' ~] (c). Seismic model of Auxiliary Building has incorrect i assumption that control tower and main portion of i Auxiliary. Building are an integral unit between elevation 614 and 659. 1 -] . (d) Borated Water Storage Tank Foundation stress cracks. ^ (e) Shear reinforcement at major containment penetrations. i 1 t ig 15
- +3!
~ b. e
e 1 .i The fact that the licensee is able to identify design deficiencies through their audit programs and take appro-priate action is commendable. However, these design deficiencies would not occur if there were more stringent control at the source of these design errors and deficiencies. b. Conclusion The licensee is rated Estemory] in this area. The amount of re-engineering that has transpired in electrical, civil and ~ piping areas and the specific design control weaknesses dis-cussed in Soils and Foundations, Piping Systems and Supports and Electrical Power Supply and Distribution indicate 'signiffTaWseaEss~eriff overa!!"dislign' controg c. Board Recommendations i The Board recommends increased licensee and NRC attention to design control in all functional areas. Although design con-trol weaknesses were evident and considered in the ratings of Wolls and Foundations, Piping Systems and Supports, and Electrical Power Supply and Distribution, the Board considered it appropriate to provide a separate rating to direct special attention to design control and provide meaningful guidance to licensee management. The use of the separate rating was intended to highlight the fact that design control weaknesses were evident in several areas. This should not be interpreted as using the same observations twice to downgrade several areas. The Board felt that the Soils, Electrical and Piping areas would have been rated the same had design control aspects been found to be adequate.
- 13. -Reportina Requirements and Corrective Action f
a. Analysis 4 i During the evaluation period, the licensee submitted twelve Construction Deficiency Reports to the NRC. These reports ] provided an adequate although sometimes minimal description i of the circumstances warranting the issuance of the report. One item of noncompliance (Infraction) was identified when the llcensee failed to make a timely determination for the need to submit a 10 CFR 50.55(e) report to the b'RC based on t a 10 CFR Part 21 report from Transamerica DeLaval,.Inc. The i . Part 21 report pertained to diesel engine link rod clearances. The licensee has taken positive actions to ensure that any safety-related information received pertinent to the Midland j Site is evaluated with respect to the impact on overall safety. d [ Expeditious resolution of noncompliances is often delayed by inadequate licensee responses. The licensee has a j tendency to spend too such time trying to justify why a l l finding is not.a noncompliance rather than devoting the l I ct
- 1 -
16 ! Ej ' + ; \\' ' ~i r t b s e 4 w, p-,o e---, e, -,
4 time correcting the basic problem. Nine of 22 items of noncompliance were contested (excluding HVAC System non-compliances). Two of the contested noncompliances were retracted, but time and effort were lost in timely resolutions. Similar attitudes and responses have been observed regarding company audit findings. This attitude is reflective of the licensee corrective actions system and becomes a cetriment to quality. b. Conclusion The licensee is rated [ Category 3ld internal audit findings in this area. The licensee ~ responses to enforcement items an are often delayed requiring repeated submittal to obtain acceptable resolutions. c. Board Recommendations None. The Board notes that subsequent to the evaluation period, the licensee management was invited to a meeting in the Regional Offices
- .o discuss what constitutes an adequate response to noncompliances.
n i 1 1 27
e V. SUPPORTING DATA AND SUP!!! ARIES A. Noncompliance Data ) Facility Name: Midland, Unit 1 Docket No. 50-329 Inspections No. 80-10, 80-17, 80-20 through No. 80-37 81-01 through No. 81-13 Noncompliances and Deviations
- Severity Levels Categories Functional Areas I II III IV V VI :Y!oI3 '_ %. [ Del. [ Del 1.
Quality Assurance (1) (1) 2. Soils and Foundations (2) (1) (1) 3. Containment and other Safety-Related Structures 4. Piping Systems and Supports (1) (4) (1) 5. Safety-Related Components 6. Support Systems * (15) (3) 7. Electrical Power Supply and Distribution 1+(5) 8. Instrumentation and Control Systems 9. Licensing Activities -
- 10. Fire Protection
- 11. Preservice Inspection
- 12. Design Control and Design Changes l
- 13. Reporting Requirements (1) and Corrective Action TOTALS Q@@%
4 12 8 Numbers in parenthesis indicate noncompliances common to both units. 2 The total includes.17 items of noncompliance associated with HVAC problems addressed in the previous SALP evaluation. They are in-cluded here because of an overlap in the two SALP periods. 18
e Facility Name: Midland, Unit 2 Docket No. 50-330 Inspections No. 80-11, 80-18, 80-21 through No. 80-38 81-01 through No. 80-13 Noncompliances and Deviations
- Severity Levels Categories Functional Areas I II III IV V VI Viol. Infr. Def. Dev 1.
Quality Assurance (1) (1) 2. Soils and Foundations (2) (1) (1) 3. Containment and other Safety-Related Structures 4. Piping Systems and Supports (1) (4) 1+(1) 5. Safety-Related Components (2) 8 6. Support Systems (15) (3) 7. Electrical Power Supply and Distribution (5) 1 8. Instrumentation and Control Systems 9. Licensing Activities
- 10. Fire Protection
- 11. Preservice Inspection _
- 12. Design Control and Design Changes
- 13. Reporting Requirements (1) and Corrective Action TOTALS
[ 4 13 1 18 3 1 l 1 Numbers in parenthesis indicate noncompliances common to both units. 8 The total includes 17 items of noncompliance associated with NVAC problems addressed in the previous SALP evaluation. They are in-i cluded here because of an overlap in the two SALP periods. d .g .1 19
- l
-t ~ e-e B. Licensee Report Data 1. Construction Deficiency Reports (CDR's) TVelve (12) Construction Deficiency Reports (CDR's) reported pursuant to 10 CFR 50.55(e), were received by the regional office during the period of July 1, 1980 and June 30, 1981. The following list is a summary of each reportable item:
- a.
High Energy Line Break Analysis (RELBA), steady state thrust forces rather than transient peak thrust forces were used in the energy balance techniques for the design of HELBA pipe whip restraints b. Sway Strut Rod Ends Deficiency, ITT Grinnell supplies sway struts, snubbers and shock suppressors have loose or totally disengaged rod end bushings
- c.
Component Cooling Water (CCW) Design, CCW system susceptibility to Loss of Coolant Accident (LOCA) induced failures d. Nuclear Steam Supply System (NSSS) analysis, anomalies identified in the NSSS seismic and Loss of Coolant (LOCA) analysis of the primary system e. Emergency Core Cooling Actuation System (ECCAS) vendor wiring in the ECCAS cabinets 1C45 and 2C45 was incon-sistent with redundant subsystem modules in the cabinets f. Low alloy quenched and tempered bolting 1 1/2 ine.hes and greater in support of safety-related systems g. Underrated Terminal Strips on Limitorque Operators t 't
- h.
Seismic model of Auxiliary Building has incorrect assumption that control tower'and main portion of Auxiliary Building are an integral unit between elevation 614 and 659
- i. Borated Water Storage Tank Foundation stress cracks
- j. ITE Gould Class 1E equipment, unqualified cable used
{ to wire equipment and/or controls
- k.
Shear reinforcement at major containment penetrations 1. Operation of reactor cavity cooling system. 'I
- Indicates may have been licensee controllable and are indicative of lack of QA in design control.
-I i 4 1 j 20 . I l 4 A w e s w 1 --s e
e 4 r. t e 2. Part 21 Reports No Part 21 reports were initiated by the licensee during the reporting period. C. Licensee Activities The licensee continued to construct both units at the same rate and achieved approximately 70*. completion during the reporting period. Safety-related electrical installation was recommenced with vigor after a period of reduced activity while additional engineering was performed. Assembly of vessel internals, closure head and reactor coolant pumps aggressively continued during the period. As a portion of the resolution for soils settlement issues, extensive soil samples and borings were taken and work commenced on dewatering wells. D. Inspection Activities A major " team" inspection was accomplished on May 18-22, 1981, which resulted in an issue of an Immediate Action Letter (IAL) pertaining to installation of small bore piping. Heavy inspection effort was expended to follow the resolution of soils settlement issues and taking of soil samples. Inspec-tions in the electrical area have increased to be commensurate with the increase in licensee efforts in this area. E. Investigations and Allegations Review None were pursued during the evaluation period. F. ' h M Yaforcement Ace *== l 1. On January 7,1981, aM'"^ wpm was issued by the NRC as a result of an investigation pertaining to the installation of heating, ventilating and air conditioning equipment and systems. Nineteen items of noncompliance were identified in 10 of the 18 Appendix B criteria (10 CFR 50, Appendix B). The investigation was completed in July 1980. Two of the noncompliances were later retracted. 2. Orders None. 3. Immediate Action Letters On- , an Immediate Action Letter (IAL) was issued by the Region III Office of Inspection and Enforcement con-cerning the issuance of fabrication and construction drawings 21 .l 4 '-'s
4e for the installation of the safety-related small bore piping and piping suspension systems. 4. 'Confirss Wii'Acti W iAtiAd 6_ (a) Ondania3'ry727,~1984 Consumers Power Company issued a letteTtTi"tWe'DIi ed'cor of Region III stating that their Stop Work Order of January 16, 1981, to B&W for instal-lation of Core Support Assembly Vent Valves would remain in effect until the procedures were revised, training of personnel was completed, and the overview inspection plan was revised. This action was taken in lieu of Region III, Office of Inspection and Enforcement issuing an Immediate Action Letter. (b) O(Ju{y'27,'*198GponsumersPowerCompanyissuedaletter to the Director, Region III delineating those actions to be taken to control modification to drawings which do not have the required Committed Preliminary Design Calcula-tions (CPDC) and that the methodology for modifications to be fully documented and submitted to the Regional Office for review. This action was taken in lieu of Region III Office of Inspection and Enforcement issuing an Immediate Action Letter. G. Management Conferences Three meetings were held with Consumers Power Corporate Management during the appraisal period. 1. The first meeting was held on ){ovember,,24D986/and continued on Deccaber 2 and 17, 1980. The purpose of the meeting was to discuss the Systematic Assessment of Licensee Performance (SALP) and to be present for the licensee's presentation of = the recently reorganized QA organization. (Inspection Reports No. 50-329/80-36 and 50-330/80-37). 2. The second meeting was heldpirM3fl981g to discuss the Midland Project Organization, Midland QA Program evaluation and the new external quality consultation. (Inspection Reports j No. 50-329/81-05 and 50-330/81-05). 3. The third meeting was held onf E ff f 9 M to discuss the results of the team inspection of May 18 to 22, 1981. (Inspection Reports No. 50-329/81-12 and 50-330/81-12). i i I l l i 4 .t 22 E
.G .---}. O Addressees - Memorandum dtd 10/13/82 Keppler Davis Hind Spessard Norelius Neisler Little Harrison Gildner Livermore Streeter Knop Jackiw Hawkins Creed Greger Axelson Schumacher Little P periello 3 Marnick Konklin Hayes G. Edison, NRR Project Manager L. Kintner, NRR Project Manager E. Doolittle, NRR Project Manager J. Stefano, NRR Project Manager H. Williams, NRR Project Manager - l l
l e .e [, _ " "'Dy[g idb UNITED STATES + NUCLEAR REGULATORY COMMISSION / M i _ 7, REGloN 111 .e ne nooseveLT mo4o aLEN ELLYN, ILLINol5 80137 dVL 261983 t Docket No. 50-329 Docket No. 50-330 Ms. Billie P. Garde, Director Citizens for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street Washington, DC 20009
Dear Ms. Garde:
In the interest of providing a fresh and independent assessment of the adequacy of the Zack Company's constructica activities at Midland, the Region III Administrator directed the Region's Division of Engineering to conduct a thorough inspection of site HVAC construction activities including the concerns brought to our attention by former employees. Accordingly, we have begun the onsite inspection of Zack's activities and the detailed review of the pertinent affidavits which were provided to us by GAP so that an onsite inspection of these concerns can be con-ducted where appropriate. ( One of the affidavits we are reviewing is a response to an investigation conducted by Region III personnel which is documented in Report No. 50-329/00-10; 50-330/80-11. The affidavit was filed with us prior to the issuance of Report No. 50-329/82-15; 50-330/82-15. This report documents the results of the follow-up of open items from Report No. 50-329/80-10; 50-330/80-11. We believe that Report No. 50-329/82-15; 50-330/82-15 i addresses the substantive technical issues expressed by the affiant, and are enclosing a copy of this inspection report with the request that you make it available to him for review. If after reviewing this report the affiant still has unresolved issues, then we would like to meet with him to discuss his specific concerns. l 1 l 5 .O rp=- .+ w g
.t Ms. Billie P. Carde - Please advise Mr. Duane Danielson of this office at (312)932-2610 if you are unable to contact the affiant or if you have any questions regarding this letter. We appreciate your cooperation ia this matter. . Sincerely,. "Qricinct signed by R. L. Spessard" .R. L. Spessard, Director Division of Engineering Enclosuret Report Nos. 50-329/82-15; 50.-330/82-15 ec w/o anc1: Consumers Power Company A2TN: Mr. James W. Cook IIMB/ Document Control Desk (RIDS) Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Barbour, ASLB The Honorable Erederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Patony ELD Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Cedler (P.E.) Howard Levin (TERA) Lynne Bernabei, Covernment Accountability Project i i I i ? I ,t i I I a. I ..(...... 3 II i R g. '/. R l III 1 y,ap..R III 5 ~ Ic D nielscn,: Harr i snauwkl Hawkin on Little ' Wa iS essard a on> 7/26/83 /.......g. <,.....i...I ......k..[...".....,;...hb 7 8 . 4...... r ~ Ncac sonu ais no so uncu c24o. i.. _ _ _OFFICI A L RE: CORD. COPY. -}}