IR 05000329/1982013
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C L E N E LLYfL ILLINOIS 60137 s...
September 22, 1982 MEMORANDUM FOR: Stephen G. Burns, Office of the Executive Legal Director FROM:
A. Bert Davis, Deputy Regional Administrator, Region III
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SUBJECT:
CONSUMERS POWER COMPANY, MIDLAND hTCLEAR POWER PLANT, POSSIBLE MATERIAL FALSE STATEMENT
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During a telephone contact on September 21, 1982, Bill Schultz, Region III Enforcement Coordinator, discussed with you our concerns related to a possible material false statement made by a licensee representative during a meeting on March 10 and a telephone call on March 12, 1982. The statement concerned the installation of underpinning instrumentation at the Midland Nuclear Power Plant and dealt with the state of completion of the instrumen-tation. An investigation was conducted during the period April 6-June 17, 1982 and resulted in the enclosed investigation reports 50-329/82-13; 50-330/82-13; and 16 exhibits.
We request that you review the enclosures and give us an opinion as to whether we could support the is.uance of a civil penalty for a material false statement based solely on the information contained in the enclosure.
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A. Bert Davis Deputy Regional Administrator
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Enclosures: As stated
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R. F. Warnick, RIII
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R. B. Landsman, RIII
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c.iu s praw;eeds with this work beyond their own stopwork directives) these inci-d.>nts are torred miscornunications or misunderstandings caused by varying inter-
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pret ations of adrecrents.
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Two investigations have bee.n launche'd by Region III on the subject of Consucer's
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"possible misleading statd.nents;" and "possible violations of the Board's April i
30, 1982 Order" inv'olvink soils remedial work.25 i
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At some time we must at least consider *the possibility that all these events t,
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weren't really misundersta$ dings at all, but were conscious violations of agree-
ments and calculated risks undertaken because of pressure to push ahead and because s,
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J of an expectation that nothing would be done about it anyway.
If these possibilities are not even considered, or the results of the Region i
III or Office of Investigation probes are not considered by this Board before the underpinning excavations are premitted to begin, then they might as well be dis-i missed altogether. For once again, inaction or failure to interce'de would be inter-i preted by Consumer's as approval of the status quo and the soils reredial work
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will continue in the sane manner as it has thus far proceeded.
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The concerns of the Region III staff, Mr. Keppler, and this Board (in their
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April 30th Order) about Consumer's ability or willingness to carry out proper
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QA on their own initiative in the soils remedial work must be addressed now as
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it becomes increasingly apparant from the course of recent events that the " Staff consultation and approval" rethod of handling soils remedial work which the -Board set forth in their April 30th Order, is not succeeding in attaining the proper
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care and conservatism in the soils remedial work.,
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The canner in which the soils remedial events 27 took place and whether these avents do or do not constitute violations of Consuner's own, the NRC, or Board 254/15/82 Spessard memos 3/20/82 Landsman meno. -
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see attachnent A.
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j Docket No. 50-329
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Docket No. 50-330 Consumers Power Company
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ATTN:
Mr. James Vice President Midland Project 1945 West ParnaLL Road
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Jackson, MI 49201
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Gentlemen:
This refers to the investigation conducted by Mr. C. H. Weil of this office, during the period April 6 - June 17,1982, of activities at the Midland Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-81 and CPPR-82 and to the discussion of our findings with
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you on June 10, 1982.
The investigation was conducted to determine the facts concerning alleged
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misleading information provided to the NRC about the status of soils moniter-ing instrumentation installation. The enclosed copy of our investigation report identifies areas examined, records reviewed, observations made, and personnel interviewed.
The investi ion lead us to conclude that there was not a deliberate attempt to mislead the NRC; rather, that the statement made was interpre ed differently I
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8. P. 6 - substitute investigation for inspection
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As a result of the investigation, it is apparent that you and I have a
different opinion of our discussions in mid-March. Although the handling of problems in non-safety-related activities was discussed, no agreement wac
made. If you wish to discuss the handling of non-safety-related activities
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further, please contact h orelius, Region III Director of Engineer
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and Technical Programs.
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This investigation serves to emphasize the importance of unambiguous com-munications and the significance the NRC attaches to possible misleading or material f alse statements. We hope your employees understand our position in these matters.
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B.P. 8a (substitute investigation for inspection)
i We 'ill gladly discuss We appreciate your cooperation with our investigator.
w any questions you have concerning this inspection.
i Sin ce re ly, James G. Keppler, Regional Administrator
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. Enclosure: Investigation Report No.
50-329/82-13; 50-330.82-13
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Weil Warnick Norelius
. Spessard Davis Keppler
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. Report ha. 50-329/82-13 (EIS)
Report No. 50-330/82-13 (EIS)
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Docket No. 50-329; 50-330 License No. CPPR-81; CPPR-82 t
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Licensee: Consumers Power Company i
1945 West Parnall Road Jackson, MI 49201
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Facility Name:
Midland Nuclear Power' Plant, Units 1 and 2 Investigation Conducted: April 6 - June 17,1982
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Investigation at: Bethesda, MD, Glen Ellyn, IL, Jackson and Midland, MI
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Investigator:
Charles H. Weil Date Reviewed by:
Robert F. Warnick, Director Date i
l Er.forcement and Investigation Staff
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InvestigahnSummary i
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. Investigation on April 6-June 17,1982 (Report No. 50-329/82-13(EIS);
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50-330/82-13(EIS)
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Areas Investigated: Unannounced investigation of alleged misleading information provided to NRC Region III inspectors on March 10 and 12, 1982, concerning the installation of underpinning instrumentation at the Midland Nuclear Power Plant. This investigation involved 97 nours, both on and i
offsite, by one NRC fnvestigator.
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Results: NRC Region III inspectors were told " instrumentation is essentially l
weLL underway. Wiring has been pulled-raceway has been installed," which meant to the inspectors all wiring hfd been installed. Instrumentation hfrEl (o
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system was reviewed and 3 les had been pulled. Person making statement said, he had "no intent to mislead anyone. No reason to Lie."
Five NRR and nineteen Licensee representatives were interviewed, and felt the statement meant work had begun without giving a report on the status of
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completion.
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REASON FOR INVESTIGATION
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A This investigation was initiated to determine the f a:ts surrounding alleged
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misleading information provided on March 10 and 12, 1982, to NRC Region III (RIII) staff members by Alan J. Boos, the Bechtel Power Corporation Assistant-Project Manager at the Midland Nuclear Power Plant.
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SUMMARY OF FACTS )
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Investigation conducted into the circumstances surrounding alleged misleading i
information, concerning underpinning instrumentation, provided on March 10 and
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12, 1982, to RIII inspectors by Alan J. Boos. Region III personnel stated they were informed by Boos of the completion status of underpinning instru-
.i mentation on March 10 and 12. In a transcript of a telephone conversation
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on March 12th, Boos stated, "our instrumentation is essentially well underway.
Wiring has been outled - raceway has been installed." To the Region III inspectors, this meant aLL wiring had been installed. On March 17-18, 1982, i
the inspectors found anproximately 10% of the' wiring had been installed, and were informed the cable putting had not begun until arch 11, 982. The
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instrumentation system was reviewed and 32 of 159 cables had been pulledgsa h;h f1Agrdt \\
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'I Boos explained his statements as informing the Region III inspectors that
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underpinning instrumentation work had begun, but was not completed. Boos
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stated he had "no intent to mislead anyone. No reason to Lie."
Interviews of five NRR and nineteen-Licensee representatives in attendance on March 10 I
'and 12 did not disclose any inaccurate information in Boos' statements; and.
,those interviewed felt Boos was saying work had begun without giving a status l-
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.of completion report to the Regioil III inspectors.
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DETAILS
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Persons Contacted l
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_ Consumers Power Company
- J. W. Cook, Vice President - Midland Project W. R. Bird, Manager, Midland Project Quality Assurance Depart-ment (MPQAD)
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E. Brunner, Attorney D. M. Budzik, Head, Midland Project Licensing Section R. C. Hirzel, QA Engineer, PvQAD Remiedial Soils Group, j
D. E. Horn, MPQAD Civil Section Head
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R. W. Huston, Licensing Engineer E. L. Jones, MPQAD Electrical Group Supervisor
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B. W. Marguglio, Di rector, PPQAD D. W. Miller, Midland Site Manager J. A. Mooney, Midland Project Executive Manager G. L. Rogers Scheduler, D. F. Ronk, Midland Project Planning and Scheduling Section Head l
M. J. Schaeffer, MPQAD Electrical / Instrumentation and Centrols
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Section Head J. R. Schaub, Engineer D. E. Sibbald, Technical Section Engineer l'
R. M. Wheeler, Technical Section Supervisor
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t (* :senotes attendance at Exit Meeting on June 9, 1982)
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Isham, Lincoln & Beale, Counselors-at-Law
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P. P. Steptoe, III, Attorney F. C. Williams, Attorney
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Bechtel Power Corporation A. J. Boos, Assistant Project Manager
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R. T. Black, Field Engineer l
M. A. Dietrich, Project QA Engineer J. F. Fisher, Remedial Soils G.oup Manager R. E. Sevo, Civil / Soils QA Engineering Supervisor
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J. E. Simpson, Jr., Scheduling Engineer
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N. W. Swanberg, Assistant Project Engineer
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Wiss, Janney, Elstner and Associated, Inc.
G. M. Comer, Supervisor 1.5.
Merointine Corporation R. F. Obteitner, Project Manager i
K. A. VanderJagt, Scheduler 1.6.
Nuclear Regulatory Commission Reaion III i
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J. G. Keppler, Regional Administrator
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D. C. Boyd, Section Chief, Division of Project and Resident Programs
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I R. J. Cook, Senior Resident Inspector - Midland
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R. N. Gardner, Reactor Inspector j
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R. B. Landsman, Reactor Inspector j
j C. E. Norelius, Director, Division of Engineering and Technical i
Programs
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C. C. Williams, Section Chief, Division of Engineering and Technical Programs
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Nuclear Regulatory Commission Office of Nuclear Reactor Regulation
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I E. G. Adensam, Chief Licensing Branch 4 i
J. W. Si tray, Principal QA Engineer j
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D. S. Hood, Midland Project Licensing Manager J. D.- Kane, Principal Geotechnical Engineer
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F. P. Rinaldi, Structural Reviewer j
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Introduction
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i on December 15, 1972, the Atomic Energy Commission issued construction
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permits to the Consumers Power Company CPCO) to build the Midland Nuclear
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Power Plant, Units 1 and 2 at Midland, Michigan. CPC0 retained Bechtet
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i Power Corporation (BPC) as the architect-engineer and constructor of the
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plant. The f acilities utilizo Pressurized Water Reactors (PWR) supplied i
by the Babcock and Wilcox Company.
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From 1975 through 1977 approximately thirty feet of compacted fitt material i
j was placed overlying the natural soils on the site. During August 1977, j
some settlement was detected in an Administration Building foundation beam.
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(The Administration Building houses plant offices and is a non-nuclear-
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safety-related structure.) CPC0 conduct;ed an investigation into the
settling of the Administration Building during August and September 1977.
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CPC0 concluded the soil beneath the building had been adequately compacted,
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except for the soit directly beneath the one foundation beam.
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In October 1977 work began on the Diesel Generator Building foundation.
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'l During July 1978, the CPC0 monitoring program detected excessive settle-ment of the Diesel Generator Building. The building had settled 3.5 inches at the pont of greatest settlement. This is compared to the
design prediction of three inches for the expected plant operating Life
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of forty years. CPC0 took soil boiring samples from under the Diesel.
Generator Building and concluded the soil beneath the Diesel Generator l'.
Building and concluded the soil beneath the Diesel Generator Building had been inadequately compacted.-
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During 1979 CPC0 conducted soil borings throughout the plant site. The
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borings indicated soil was inadequately compacted beneath the electrical penetrations of the Auxiliary Building and a portion of the Service Water Pump Structure. CPC0 decided to underpin portions of the Auxiliary
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Building and the Service Water Pump Sturcture.
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i The NRC has conducted inspections and investigations of the soil settle-
j ment issues at the Midland Nuclear Power Plant. Numerous meetings,
'l telephone conversations and correspondence have ensued. On March 10, 1982 CPCO, BPC and the NRC met at NRC Headquarters, Bethesda, MD, to discuss
issues relating to the underpining of the structures. A telephone con-versation between the same parties was held on March 12, 1982, to clarify j
the issues of the March 10 meeting.
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Acoce
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s This investigation was conducted to determine the circumstances under I
which RIII personnel were provided with atleged misleading information concerning the installation status of instrumentation to monitor the underpinning activities at the Midland Plant. ALL facets of this inves-
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tigation, except those Listed in paragraphs 4, 7, 11.4, 11.5 and 11.6, were conducted in the presence of Mr. James E. Brunner, CPC0 attorney.
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Interview of RIII Personnet
4.1 Interview of RIII Civil Engineer a
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i During the period April 6-19,1982, Ross B. Landsman, Region III
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Reactor Inspector (Civi L Engineer), provided the following:
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On March 10, 1932, he attended a meeting with CPC0 and BPC at NRC Headquarters, Bethesda, MD, to discuss the application of f
quality assurance criteria to the remedial foundation work at the
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Midland site. The NRC and CPG 0 agreed remedial foundation work
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started before March 10, 1982, would not be included in the CPC0 quality assurance program, but work beginninC af ter that date would be within the quality assurance program. During the meeting Alan J. Boos (BPC Assistant ject Manager for the Midland site)
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instrumentation for the remedial soils monitoring progan had been
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completed. In view of Boos' statement the instrumentation was excluded from the quality assurance program.
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On March 12, 1982, Landsman, Boos, et -al participated in a con-i.
ference telephone call to identify the areas that were excluded from the quality assurance program. During this telephone call,
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Boos made the following statement," Gauges, backup gauges, have been procured as non-Q, but would be calibrated under.a Q program.
These are existing dial gauges. Our instrumentation is essentially weLL underway. Wiring has been pulled - raceway has been installed."
The telephone call had been recoreded by BPC. A copy of the trans-cript of the call is attached (Exhibit 1).
_ NOTE:
'Q' refers to work falling within the Quality Assurance
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program. 'Non-Q' refers to work outside of that program).
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On March 17, 1982, Landsman and Region III Electrical ' Inspector Ron Gardner arrived at the Midland plant to observe the remedial foundation work. During the course of their inspection, Gardner t
i reviewed the instrumentation for the underninning monitoring.
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Gardner Learned from CPCO employee Mike Schaeffer that the under-
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pinning instrumentation cable pulling had begun on March 11, 1982,
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and quality assurance criteria for the cable pulling had not been developed.
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Landsman provided a written statement (Exhibit II). A, copy of f
Landsman's inspection repert (No. 50-329/82-05 (DETP); 50-330/82-05
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CDETP)) is attached (Exhibit III).
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4.2 Interview of RIII Electrical Inspector
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On April 12, 1982, Ronald N. Gardner, Region III Reactor Inspector (Electrical) provided the following:
Region III Inspector Ross Landsman asked his (Gardner's) assist-ance in reviewing the instrumentaiton installations for the remedial soils monitoring program at the Midland Nuclear P er Plant. He accompanied Landsman to the Midland site, and on March 17, 1982, he reviewed the instrumentation.
He found quality assurance criteria had not been developed or
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implemented for the remedial soils instrumentation. Mark Schaeffer
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of CPC0 informed Gardner that cable pulling had not begun until March 11, 1982. Through observation on March 17, 1982, Gardner i
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found that 10% of the remedial soils monitoring instrumentatien cables had been pulled to the Data Acquisition Room.
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Gardner provided a written statemer.t (Exhibit IV). A copy of Gardner's inspection report (No. 50-329/82-06 (DETP; 50-330/82-06
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(DETP)) is attached (Exhibit V).
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4.3 Interview of Region III Senior Resident Inspector - Midland
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on April 8-9, 1982, Ronald J. Cookk Region III Senior Resident l
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Inspector at the Midland site, provided the following information:
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On March 10, 1982, he attended a meeting in Bethesds, MD, along with Landsman and representatives of CPC0 and BPC. The purpose of the meeting was to review the CPC0 quality assurance program under consideration for the remedial soils work at the Midland site.
During the meeting CPC0 and the NRC reached an agreement that aLL remedial soits work beginning after March 10,1982, wculd be
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don under the CPC0 quality Assurance program. Further, all work begun before March 10 would be excluded from the program. During i
the course of the meeting Boos stated the settlement monitoring i
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instrumentation was completed. Because of Boos' statements that
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the instrumentation was completed, it was agreed the instrumen-
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tation would be excluded from the quality assurance program.
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On March 12,1982, CPC0 requested Cook participate in a conference l
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telephone cal * to Ross Landsman and Dwane Boyd in the Region III l
office. BPC employees, including Boos, participated in the tele-
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phone call. BPC recorded the call and provided a transcript s
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(Exhibit I).
Boos stated during the March 12th telephone call,
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"our instrumentation is essentially weLL underway. Wiring has
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been pulled, raceway has been installed." Boos statements j-
meant to Cook that aLL instruments had been installed and wires had i.
been pulle expected aLL work to be completed, except for
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a few terminations and the calibration of the instruments.
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l On Maren 17, 1982, Region III Inspectors Ross Lanosman and Ron
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few cables had been pulled, but quality assurance criteria had
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not been developed for the instrumentation installation, including cable pulling. CPC0's Mike Schaeffer informed Gardner and Landsman
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that underpinning instrumentation had not begun until March 11,1982.
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On March 18, 1982, Schaeffer, Gardner, Landsman, CPC0's Ed Jones, and Cook visited the underpinning ic.strumentation Data Acquisition Room. We found about 10% (8 or 10 of 80 cables required for the
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instrumentation) of the cables had been pulled to the Data Acqui-
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sition Room.
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Subsequently, Landsman, Gardner and Cook tele,mhoned their super--
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visors (Dwane Boyd 'and CordeLL Williams) in the Region III office i
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to apprise them of the status of the underpinning instrumentation
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installation and the lack of quality assurance criteria for the
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underpinning instrumentation installation.
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i Cook provided a written statement (Exhibit VI).
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4.4
_ Interview of Region III Section Chiefs
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4.4.1 Interview of Region III Division of Project and Resident j
Programs Section Chief
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On April 30,1982, Dwane C. Boyd, Section Chief, Region III Division of Project and Resident Programs, provided the
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following information:
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Boyd recalled participating with Landsman in the tele-phone call from CPC0 and BPC. Prior to the telephone
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call, the NRC and CPC0 had agreed that any work begun on the underpinning activities before March 10, 1982 would not<<<
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on the underpinning activities before March 10, 1982
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't would not be included in the CPC0 quality assurance
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program.. ALL work begun af ter March 10th would be fully
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coveredbythequa[ityassuranceprogram.
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During the March 10th telephone call, Boos stated the
underpinning instrumentation installations were complete.
A representative of CPC0 stated that since the instrumen-tation installation was complete, then the instrumentation
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installation would be excluded from the quality assurance l
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l program. Landsman and Boyd agreed the installed instrumen-tation would not have to be re-done, as long as the instru-mentation functional testing was conducted under the quality l
assurance program.
Sevsral days after the above telepho1e call, Landsman and Gardner went to the Midland site. They telephoned and in-formed Boyd only four of the instrumentation cables had been pulled and none of the instruments had been installed.
Boyd provided a written statement (Exhibit VI).
4.4.2 Interview of Region III Division of Engineering and Tech-nical Programs Section Chief -
Cordell C. Williams, Section Chief, Division of Engineering and Technical Programs, stated he could not recall any information surrounding the March 18, 1982, telephone con-l versation with Cook, Gardner and Landsman.
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5.
Review of Status of In alled Instrumentation Cables 5.1 Interview of CPC0 Electrical / Instrumentation and Control Section
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Head on May 26-27, 1982, Michael J. Schaeffer, Section Head, Electrical /
Instrumentation and Controls, Midland Project Quality Assurance
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Dagartment (MPQAD), provided the following:
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On March 17, 1982, Region III Inspector Ron Ga'rdner asked to review the procedures and drawings for the underpinning
monitoring instrumentation. Schaeffer informed Gardner f
that he (Schaeffer) was not aware this system was within the quality assurance program. On March 18, 1982, Schaeffer went to the field and observed that approximately 20% of f
the instrumentation system had been installed. Schaeffer
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recalled some conduits and cables had been installed.
(Schaeffer could not recall the amounts of cable or conduit).
'
No instrumentation was installed. Schaeffer could not recall the date either the conduit installation or cable pulling had begun. On March 19, 1932, work was stopped on the installation of the underpinning monitoring system until quality. assurance procedures were developed.
Schaeffer provided a written statement (Exhibit VIII).
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5.2 Interview of CPC0 Inspection Supervisor, Electrical / Instrumentation and C_onfigt Section-MPQAn
,
l on June 2,1982, Edgar L. Jones, Supervisor, Inspection, Exsitination l
and Test Verifiertion Group, PPQAD Electrical / Instrumentation and l
Control Section, provided the following:
!
On March 17, 1982, Region III Inspector Ron Gardner asked to see
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the drawings and procedures for the underpinning instrumentation
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installations. Jones believed the underpinning instrumentation was considered to be non-nuclear-safety-related; therefore, Jones was t
not aware of the status of the drawings and procedures. Jones l
accompanied Gardner, Landsman and others to the field. He t
i j
recalled seeing conduits, pull boxes, terminal block panels
.
and some instrumentation installed. He remembered about ten
+
j cables having been pulled to the Data Acquisition Room.
Jones provided a written statement (Exhibit IX).
5.3 Interview of BPC Project Quality Assurance Engineer
,
1.
On June 3,1982, Marion Dietrich, BPC Project Quality Assurance Engineer, advised he had not accompanied Jones, Schaeffer, Lands-man and Gardner to the field on March 18, 1982; rather, Dietrich made the arrangements for their inspection tour. Dietrich could not recall if any engineers accompanied the tour group on March 18th.
.
5.4 Interview of BPC Field Enaineer During the period May 27-June 3,1982, Richard T. Black, BPC-Field Engineer, provided the following:
He was the field engineer responsible for the installation of the
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underpinnir.g monitoring conduit and cable.
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His work assignment in February 1982 was to determine the locations
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of the instrumentation from the 'C' Series Project Drawings (civil
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drawings), the location of the Data Acquisition Room,"and decide on the quantitites of cable and conduit for the run. The conduits and cables were field routed, as this was consicered to me a temporary installation.
.
,
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During the third week of February 1982 the installation of the conduits began. From that point, until work was stopped on March 19, 1982, 2400' of conduit was installed. On May 27,1982, Black " walked-down" the conduit routes and found 2651' of conduit had been installed and thirty-two cables had been pulled to the Data Acquisition Room. Sixteen cables remained in the Data Acquisition Room and sixteen had been removed and scraped. No additional cables had been pulled since March 19, 1982.
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Black reviewed the current drawing for the underpinning instrumen-
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tation installation (BPC Drawing No. 7220-C198-11-1, Inst rument Cable Installation, approved March 30, 1982, and determined this
.
I drawing specified 213 cables would be installed in order to complete the system.
5.5 Interview of Assistant Project Enaineer
>
On June 9, 1982, Neal W. Swanberg, BPC Assistant Project Engineer-
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Midland, provided the following:
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As of March 17, 1982, the design of the underpinning instrumentation
.
system was not finalized as only preliminary drawings had been pro-duced. The drawings were:
f
Drawing No.
Drawing Title C-1490 Auxiliary Building Instrument Locations for Underpinning
,
C-1491 Auxiliary Building Instrument Locations for Underpinning l
i C-1492-1 Instrument Location at Underpinning Piers l
C-1493 Auxiliary Building and Feedwater Isolation Valve Pit Instrumentation System Monitoring Matrix From the review of these drawings, Swanberg concluded 159 cables were needed to complete the instrumentation on March 17, 1982. The drawings specified one cable for each gauge or instrument. The 159
cables were:
61 cables for Linear Variable Differential Transducers (LVDT) and Differential Movenent Devices (DPD).
I 50 cables for Carlsen stress meters for piers 48 cables for strain gauges on temporary steel columns 159 cables i
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5.6 Observation of Installed Instrumentation
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b On May 20 and 27, 1982, direct observation of the installed underpin-ning instrumentation disclosed the following:
'
i The Data Acquisition Room was visited with G. Matt Comer of Wiss, Janney, Elstner and Associates (the instrumentation subcontractor).
The monitor, data disc storage and printer were installed. The
,
i i
terminal board was avaiLable, but no terminations had been made.
i l
Eighteen cables entered the room.
}
Nine deepseated benchmarks (DSB) were examined with the assist-ance of Donald E. Sibbald of CPCO's Technical Section.- Only two DSBs (DSB-2E and DSB-2W) had conduit and instrument brackets installed. Cables had been pulleti to,DSB-2E and DSB-2W. Conduits, cables and brackets were not found at the remaining benchmarks (DSB-AN, DSB-3E, DSB-3W, DSB-AS1, DSB-AS2, DSB-1E and DSB-1W).
6.
Interview of BPC Assistant Project Manager On May 27-28, 1982, Alan J. Boos, BPC Assistant Project Manager-Midland, provided the following:
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He was in attendance at both the March 10, 1982, meeting in Bethesda, MD, with the NRC and CPC0 and at the March 12th converence telephone call to-l
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Region III.
l The March 10th meeting was to clarify the areas of the underpinning work
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to be "Q" listed (under the CPC0 Quality Assurance Program). Much
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discussion, confusion and disagreement ensued. At the conclusion of
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the meeting, NRC's Carl Hood stated that all work beginning with Phase 2
,
of the underpinning activities would be included in the quality assurance l
i program.
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The discussions of the components of the underpinning work, except wood Lagging and steel beams, were not discussed in detail, dealing only in i
the terms of the " general schedule" of work. Only wood Lagging and
'
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steel beams, as components of the underpinning work, received detailed
!
attention during the meeting.
i Boos stated he could not recall making any specific statements pertaining
,
to the status of completion of the instrumentation. Instrumentation was
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!
discussed in terms 'of CPC0's desire to have procurement and installation
,
of the instruments excluded from the quality assurance program, but to have calibration, check-out frequency of reading and data usage f alling -
within the quality assurance guidelines.
After the March 10th meeting, Boos discussed with CPC0's Jim Mooney the necessity to come to an immediate resolution of what was, and what i
was not, to be included in the underpinning quality assurance program.
,
r-For that reason Region III was telephoned on March 12th.
,
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l on March 12, 1982, Boos, along with representatives of CPC0 and BPC, L
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placed a conference telephone call to Landsman and Boyd in Region III.
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The _ purpose of the call was to outline the areas CPC0 and BPC considered I
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to be within the quality ass'urance program, "Q Listed", and those areas
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ex c luded, "non-Q".
A matrix was prepared by CPC0 and BPC and used during
'I the call. The matrix outlined the
"Q" and "non-Q" areas. Ecopyofthe
.
matrix was telefaxed (Exhibit X) to Landsman at the Region III office at the conclusion of the telephone call. BPC recorded the telephone
call of March 12th and provided a copy to Region III (Exhibit I).
Boos
,
reviewed the transcript during the interview.
l Boos stated the points he was trying to make during the telephone call i
were: Work on the instrumentation system had begun. The procurement of
'
t system components and the instattation of cable and conduit were being done "non-Q" The reasons for the statements were to inform Landsman not to be surprised during his next inspectin that work had begun.
'
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t From weekly status of meetings, Boos knew "some of the raceway had been i
installed," and he " felt raceway was pretty weLL underway." Boos knew the instrumentation was not installed, as it had not arrived onsite.
But based upon the information presented by his staff at their weekly (Friday) status meeting, he knew work was underway for the installation of the underpinning instrumentation. Boos could not give an exact
'
t percentage of completion, and be could not recatt which member of his
staff informed him that instrumentation work had begun.
i Boos stated he "was trying to say work was underway, but not complete."
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I Additionally, Boos stated he had "no intent to mislead anyone. No
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i reason to lie." Boos provided a written statement (Exhibit XI)
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7.
Interviews of NRC Employees in Attendance at Meeting and Telephone CALL
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7.1 Interviews of Region III Personnel The interviews of the Region III staff members attending the March 10, 1982, meeting in Bethesda, MD, and those present for the March 12, 1982, telephone call were reported in paragraph four and Exhibits
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II,,VI, and VII of this report.
I
i 7.2 Interviews of Office of Nuclear Reactor Regulation (NRR) Staff
Members
4 7.2.1 Interview of NRR Licensing Manager
,
i on April 14-16, 1982, Darl S. Hood, the NRR Licensing Manager for the Midland Project, provided the following:
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On March 10, 1982, Hood and other members of the NRR staff attended a meeting with CPC0 and BPC. The purpose of the meeting was to identify the areas of the Midland l
remedial soils program to be included, or escluded, from
.'
i the CPC0 Quality Assurance Program.
CPC0 with Boos' assistance made a presentation which
included a new quality assurance category. This new cate-gory, which CPC0 termed "0A", would incorporate the quality
,
assurance criteria for areas which were not nuclear-safety-
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realted and would be excluded from the NRC's regulatory
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purview. One such area was the wood tagging for the
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underpinning access shafts.
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After much debate a tuncheon recess was called. During
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the recess the NRC staff members caucussed on the CPC0 propos al. Afterwards Hood informed the reassembled meeting, "from this point forward" all underpinning activi-
_
i ties would be "Q listed" within the scope of the CPC0
,
j quality assurance program and the regulatory jurisdiction of the NRC. Af ter discussions with Boos and CPC0's i
Jim Mooney, Hood clarified this point as all work beginning i
j With Phase 2, unless CPC0 requested relief from the commit-ment for a specific problem.
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Hood recognized Phase 1 of the underpinning work had been accepted by the NRC as being non-nuclear-safety-related.
Phase 1 of the underpinning consisted of digging the vertical
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access shaft before commencing with the tunnel beneath i
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the Turbine Building (Phase 2).
Hood stated the under-
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l pinning instrumentation was Phase 2 work which had to be completed during Phase 1.
Hood continued, the instrumen-
tation had to be installed and operational prior to commencing the tunnel beneath the Turbine Building, and the instrumentation was always considered to be nuclear-
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safety-related since the purpose of the instrumentation was
to measure any movement of the structure while tunnelling.
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Hood did not recall any statements by Boos regarding the
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i status of instattation of instrumentation.
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Hood provided a written statement (Exhibit XII) and a copy
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i of a letter, dated March 22, 1982, which he had referenced in his statement (Exhibit XIII). Hood also provided the i
NRR report of the meeting of March 10, 1982 (Exhibit XIV).
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7.2.2 Interview of Geotechnical Engineer
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i on April 14, 1982, Joseph D. Kane, Principal Geotechnical Engineer, NRR,provided the following information
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He attended the March 10, 1982 with CPC0 and BPC concerning the quality assurance program to be applied to the under-pinning work at the Midland plant. During the course of j
the meeting, Alan Boos of BPC stated, "a lot of instrumen-
tation was installed."
l Kane advised that Boos statement came during the discussion of applying the quality assurance program to all under-pinning phases. Kane felt Boos was attempting tc point out that instrumentation installation had begun and the adverse impact upon the completion of the work if the quality assurance criteria were applied at the current
!
point of construction. Kane felt Boos was trying to add to the major discussion of "0 listing" and was not giving
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a report on the status of instrumentation installation.
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Kane provided a written statement (Exhibit XV).
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7.2.3 Interview of Principal Qu.ality__ Assurance Enaineer
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On April 16, 1982, John W. Gilray, Principal Quality Assurance Engineer, NRR, provided the following:
He attended the March 10, 1982, meeting with CPC0 and BPC in Bethesda, MD. The purpose of the meeting was to discuss the application of the CPC0 Quality Assurance Program to the underpirating work at the Midland site. During the meeting, Hood stated, "all work associated with the under-
<
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pinning would be under the quality assurance program, unless CPC0 specifically requested otherwise."
i
Gilray did not recall any discussions about instrumentation or instrumentation installation during the March 10 meeting.
7.2.4 Interview of Structural Reviewer
~
On April 14,1982, Frank P. Rinaldi, Structural Reviewer, NRR, provided the followingt*
He attended the March 10,1982, meeting with CPC0 and BPC
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where the application of quality assurance criteria to the t
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underpinning was discussed. During the meeting, someone
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from 8PC, possibly Boos, made a stateinent that instrumen-tation installation was underway. Rinaldi could not
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recall the specific statement or if Doos was actually the i
person making the statement. The meeting ended with NRR's Dart Hood stating, 'everything installA af ter neM0th would be under the quality assurance program."
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7.2.5 Interview of Licensing Branch chief
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I On April 14, 1982, Elinor G. Adensam, Chief, Licensing Branch 4, advised she only attended the morning session of the March 10, 1982 meeting with CPC0 and BPC. The meeting concerned the application of quality assurance requirements to the remedial soils program at the Midland Plant. She
,
did not attend the afternoon session of that meeting.
,
She did not recall anyone, including Boos, making any statements pertaining to the installation of underpinning instrumentation.
8.
Interview of CPC0 Representatives Present for Meeting and Tetophone Call I
8.1 Interview of_ Esecutive_ Manager of the Midland Project _
l On June 8,1982, James A. Mooney, Executive Manager of the Midland Project, provided the following
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He attended the March'10,1982 meeting in Bethesda, MD, with the
.
NRC staff and he participated in the March 12th telephone call to
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Landsman and Scyd at the Region !!! office.
I
!
The March.10th meeting was to discuss the application of quality assurance criteria to the underpinning work at the Midland plant.
The focus of the meeting was to consider what areas were to be I
{
"O Listed" and the areas that were esempt. At the March 10th meeting CPC0 introduced a new category, "0A".
The "GA" category l
included areas that CPC0 knew were non-nuclear-safety-related, but for CPC0's commercial interest should be of high quality and therefore covered by the quality assurance program. CPC0 pointed out that the "4A" category would be outside of the NRC',s regulatory
realm, as the area was not related to safeguarding the public health and safety since it did not have any effect upon the safe shut-down and maintaining safe shut-down of the reactor. The l
tunnel beneath the Turbine Building was considered to be non-nuclear-a safety related. The tunnel underneath the Turbine Building was
'
l considered to be in the "4A" category. In order to assure high
,
I quality work was done. The assurance of high quality work, by having quality assurance reviews was in the best financial interest of the company.
I i'
A statement was made th NAA's Darl Hood during the March 10th meeting that, " Henceforth everything is 4."
Which meant that i
everything dealing with the underpinning would be done under the quality assurance program. After much discussion of this statement,
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Hood restated the position as, "ALL work beginning with Phase 2
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l would be Q Listed."
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Mooney felt a clear understanding did not exist between CPC0 and the NRC as to the differences between Phase 1 and Phase 2.
The instrumentation was never defined as being a part of the Phase 1
.
work or a part of Phase 2.
Mooney believed the instrumentation
,
was clearly a part of the Phase 1 work since the instrumentation
I would have to be installed and functioning before beginning
~!
Phase 2.
Mooney did not consider the installation of conduit f
and cable pulling to be a "Q Listed" because any effect of the cable or conduit upon data collect U.e., erratic signarts) would be readily detected. However, Mooney considered the " check-out"
!
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of the system, including instrument calibration, and the collection of the data to be "Q Listed." Since he believed the instrumenta-
tion was subject to Hood's statement of March 10<u
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t tion installation including cable and ccnduit to be part of Phase 1 work; the installation of underpinning instrumentation was subject to Hood's statement of Mar'ch 10 exempting Phase 1 work'from the
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i quauty assurance program. '\\
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-:-y Mc6ney did not' recall'AL ' Boos, or anyone else, makinga statement
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.durkrig the March 10th meeting concerning' the installation status Q
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w of'the instrumentsfion?
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l v: ' 'CFC0 and BPC placed the telephone call to Landsmas'in.d Boyd on m
L-March 12, 1982 in order to clarify which items'were "Q Listed" f
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which were not. A matrix (Exhibit X) was prepared for use during l
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the telephone call. The matrix showed the status of items, in-
,
cluding instrumentation, and whether, or not, an item was "Q Listed".
,
On March 12th. He explained to Ron Cook, the NRC Resident Inspector
!
at Midland who was also participating in the telephone call, that
,
the matrix preparation was rushed and it was somewhat confusing.
Mooney also recalled informing Cook at the conclusion of the tele-phone call that a large amount of instrumentation work remained to be done.
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Mooney stated the information presented by CPC0 and BPC during the March 12, 1982, telephone call to Region III was accurate.
.
l l
8.2 Interview of MPQAD Civil Section Head
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l On June 3,1982, Donald E. Horn, MPQAD Civil Section, provided the
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following:
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He was present for both the March 10, 1982 meeting in Bethesda, MD, and for the March 12, conference telephone call to Region III.
!
At the March 10th meeting CPC0 outlined the underpinning areas to be included, or excluded, from the auality assurance program.
The NRC rebutted the CPC0 position with the statement that aLL of the underpinning activities would be included within' the quality l
assurance program, unless CPC0 made application for a specific l'
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exclusion. Horn did not recall any statements by Al Boos, or
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anyone else, concerning the installation scatus of the uaderpinning
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instrumentation.
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The March 12th telephone call concerned the specific areas which l
were either "Q Listed" or excluded from the "Q" listing. Most of
!
the discussion dea,t with specific areas and stating whether or not i
the procurement, installation and checkout were "Q Listed."
l Horn was shown a copy of the transcript of the March 12th telephone J
l
._ call (Exhibit I).
Horn stated the final check-out of the instrumentaiton was always meant to be "Q Listed." Horn believed Boos statements about instru-
!
mentation in the transcript were meant to inform Landsman that work
'
had started and Boos was not trying to say "what stage of completion."
i
.
l 9.
Interviews of CPCO and BPC Representatives at March 10th Meetino l
!
9.1 Interdew of Midland Proiect Quality Assurance Mananer
,
On June 8,1982, Walter R. Bird, Manager, Midland Project Quality Assurance Department (MPQAD) provided the following:
He recalled being present at the meeting on March 10,1982,in Bethesda, MD, where CPC0 proposed a new Quality Assurance category, "QA" for the underpinning work at the Midland Plant.
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The new category covered items that were non-nuclear safety-
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l related, but were important to CPCO for various reasons to be
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included in the quality assurance program. The NRC objected to this
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proposition, stating it was too general and CPC0 should develop a
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more specific plan.
Part of the CPC0 proposal was underpinning instrumentation. The
installation would not be "Q Listed." However, the calibration,
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check-out and data taking would be included in the CPC0 quality assurance program. The principle was to insure the final product, the data, was as good as possible.
I e
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Bird did not recall Al Boos, or anyone else, making any state-ments pertaining to the installation status of the underpinning instrumentation.
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i Bird stated he had a perception the instrumentation installation was farther along than the actual condition. Bird was aware the underpinning instrumentation system was incomplete, as the t-l brackets had not been fabricated and the instruments had not arrived onsite. However, from the information he had been given during status meetings, he was surprised to learn the few number of cables
,
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pulled.
-.
Bird provided a written statement (Exhibit XVD.
9.2 Interview of Midland Project Licensing Section Head
$
On June 9,1982, Dennis M. Budzik, Licensing Section Head for the
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Midland Project, provided the follok sg:
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He attended the meeting in Bethesda, MD, on March 10,'1982. He
was present for the entire morning session, but missed most of the afternoon sesh 6n.
,
!
The purpose of the meeting was to come to an understanding with
'
the NRC on which portions of the remedial soils work at the
,
i Midland plant would be subjected to the quality assurance program.
l l
CPCO presented three positions. The first position was to have
'
none of the remedial soils work under the quality assurance program.
The second position was called "QA".
l i
The "QA" category would be applied to components of design and construction which were not related to nuclear safety, but com-ponents which CPC0 felt should be done under the quality assurance program in order to minimize CPCO's financial risk. An example
-!
was the piers underneath the Turbine Building. The Turbine Bui Ld-ing, being non-nuclear-safety-related, was not required to be inspected under the quality assurance criteria. However, the i
tunnelling beneath the building could cause significant damage to l
1.
l the structure and to minimize the risk CPC0 would apply the quality assurance program. CPC0 wanted the NRC to recognize the "QA" category as an area where the CPC0 Quality Assurance Program had l
!
been applied, but was outside of the NRC's regulatory jurisdiction.
j, CPC0 emphasized the items under the "QA" category were not related
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to nuclear safety and would not endanger the public health and safety.
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Linderpinning instrumentation was discussed in the context that
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monitoring and assuring the data was correct were safety related.
.
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This included calibration, recording, and using the information.
,
l However, the instruments and associated hardware (i.e., cable and conduit) would not be " safety grade." Rather, CPC0 would insure
-
!
l that high quality materials were used to assure a good product.
The underpinning instrunentation does not affect the public health
-
-
and safety, but shows the stress, or lack of stress, placed on a l
non-nuclear structure.
._
I
!
Budznik was aware on March 10, 1982, that some work had begun on
,
the underpinning inatrumentation and thought the system was less than 50% complete. Budzik did not recall any statements by Boos,
.
i
,
.
-
f or anyone else, at that meeting concerning the completion status of the underpinning instrumentation. Budzik recalled some discussion
!
of work underway, but did not recall if the underpinning instrumen-tation had been discussed.
!
'
The portions of the afternoon sesh ens of the March 10th meeting that Budzik attended were spend in clarifying NRR's position j_
on the CPC0 proposals. NRR's position, that aLL underpinning
'
,
work would be under the quality assurance program, started when
'
Phase 2 work began. On March 10,1982, Phase 2 of the underpinning had not begun.
(
9.3 Interview of BPC Assistant Project Engineer i
.
- .
.
)
' ' f r 9, 10", u 3t E ewanberg, SP4_ Assistant Project Engineer.m-.
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On June 9,1982, Neal W. Swanberg, BPC Assistant Project Engineer-
.
Midland, provided the following:
,
)
'
He was present for the meeting on March 10, 1982, at NRC Head-quarters in Bethesda, MD.
The purpose of the meeting was to
'
!
clairfy the extent of underpinning work at the Midland plant that would be included in the quality assurance program.
l CPC0 presented a plan of the underpinning areas to be included
-
'
-
in the quality assurance program. The NRC disagreet with CPCO's
!
~!
plan and stated that aLL underpinning activities would be included in the quality assurance program. Swanberg did not recall if a point-in-time was established to have aLL underpinning work
'
i included in the quality assurance program. Swanberg recalled the i
vertical access shaft and the dewatering wells were excluded from i
{
the quality assurance program, and thought the beginning of the j
Phase 2 work, the drif t beneath the Turbine Building, was the
,,
beginning point where aLL work would be governed by the quality assurance program.
Instrumentation was discussed at the March 10th meeting, and an
!
attempt was made to define the portions of the underpinning instru-mentation included in the quality assurance program. - The purpose
!-
!
of the instrumentation was to show the structures were not-harmed during the underpinning. Swanberg did not recall any statements by Al Boos, or anyone else, concerning the completion
_
j status of the underpinning instrumentation.
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Swanberg felt the NRC's mandate that aLL underpinning work was
-
i included in the quality assurance program was wide sweeping and l
ambigious. Since the mandate was so broad, Swanberg assumed the underpinning instrumentation was included. He made his
,
assumption based upon his knowledge that the instrumentation would have to be installed and operating prior to Phase 2.
Swanberg
,
did not recall any conversations as to which phase, Phase 1 or 2, included the instrumentation. From a technical standpoing Swanberg i
.j considered the instrumentation to be required for Phase 2 work, but
!
did not know if instrumentation was included in Phase 1 or the begin-ning of Phase 2.
l
-9.4
_ Interview of Licensing Engineer
,
i On June 8,1982, Roger W. Huston, CPC0 Licensing Engineer for the Midland Project, provided the following information:
1
'
a'
He attended the March 10,1982, meeting where CPC0 presented a plan for the application of quality assurance criteria to the
'
underpinning work at the Midland plant. The discussions surrounded'
the areas to be "Q Listed" and the areas excluded from the quality l
l assurance program. Instrumentaiton was discussed to the extent
,
.l
'
that a monitoring program would be used to detect settlement of the structures (the Auxiliary Building in relation to the Turbine
~ Building). He did not remember any discussion pertaining to the l7
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completion status of the instrumentation.
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l 9.5 Interview of Remedial SoiLd Quality Assurance Engineer l-l
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.
l On May 28, 1982, Rudolph C. Hirzel, a quality assurance engineer
,
under contract to CPCO MPQAD through Science Applications, Inc.,
provided the following:
'
He was at the March 10, 1982, meeting at NRC Headquarters where
.
CPCO presented a quality assurance program for underpinning at the Midland site. The NRC rejected the CPC0 program and a formal j
',
agreement between CPC0 and the NRC was never completed. The CPC0 and BPC representatives advised the NRC that they would have to discuss the position with their respective managements. On f
their return trip to Michigan, CPCO's Don Horn asked for a listing of areas to be excluded from the quality assurance plan. This was
'
to be included in a composite Listing of "non Q" items to be presented to the NRC at a later date.
,
.
Hirzel recalled bench.aarks were the only specific component of the instrumentation discussed during the March 10th meeting. He did not recall anyone, including Al Boos, discussing the completion
'
status of the instrumentation.
,
9.6'
Interview of CPC0 Attorneys i
9.6.1 Interview of Corporate Attorney l
l On May 26,1982, James,E. Brunner, Attorney in CPC0's
,
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Corporate Legal Department, provided the following:
-
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He attended the meeting in Bethesda, MD, on March 10, 1982.
He was in-and-out of the sessions and did not recall anyone, j
including Boos, discussing the completion status of the l
underpinning instrumentation.
.
9.6.2 Interview of Retained Attorney
!
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On June 10, 1982, Frederick C. Williams, an attorney with t
'
the firm of Isham, Lincoln and Beale under CPC0 retainer, was telephonically interviewed from Las Vegas,N'/. Williams i
'
!
provided the following:
i
.
'
He attended the meeting in Bethesda, MD, on March 10,1982, I
where CPCO presented a program describing the Midland underpinning work to be included and excluded from the quality assurance program. He described the meeting as difficult with vast differences between CPCO's position and that of the NRC.
~
CPCO's position was to have some, but not aLL, underpinning j
~
work included in the quality assurance program. For the most part the underpinning would be in a new category, "QA,"
i
..
in the quality assurance program. The "QA" category would i
-
be non-nuclear-safety-related areas covered by the quality -
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assurnace plan, but would be excluded from NRC review.
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The NRC rebutted the CPCO position by stating that all
.
underpinning work would be under the quality assurance
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program.
,
l The discussions, included the major categories of work (i.e.
i monitoring, tunnelling) to be "Q Listed." There was some discussien of sub-components being subjected to quality i
assurance review, but "not every turn of a bolt." The general consensus was aLL work underway would be excluded i
from the quality assurance program. The application of the
!*
quality assurance program to the entire underpinning pro -
gram would begin with Phase 2.
The NRC agreed that work underway was " grandfathered out of the program."
i
'.
t Williams recalled during the general discuss of instrumenta-i tion that Boos made a statement that instrumentation cable had been pulled. Boos' statement was made. during the i
discussion of the phases of the instrumentation to be included in the quality assurance program. Boos did not indicate an amount of cable pulled.
p-s
i 10. Interviews of CPC0 and BPC Personnel Present for Telephone CALL 10.1 Interview of BPC Remedial Soils Group Manager l
On May 27,1982, John F. Fisher, BPC Remedial Soils Group Manager, t
i i
provided the following:
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He was present for the-March 12, 1982, telephone call to Regicn III.
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The purpose of the call was to identify the areas of the under-i
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.
pinning work to be excluded from the quality assurance" program.
,
Al Boos did most of the talking during the call and was speaking
~
about the work ar-as that CPC0 and BPC considered to be "non-Q".
.
Boos' statements were not meant as a status of work report, but i
to show that work had begun and that the work had been done "non-Q".
l Fisher was aware the installation of instrumentation had begun,
'
I and was not complete. Fisher believed Boos' statement "our instru-mentation is essentially weLL underway. Wiring has been pulled.
Raceway has been installed," was accurate in that Fisher considered
-
'
l the instrumentation to be underway in preparation for the next
work phase. Fisher thought Boos intended to communicate to the i
Region III personnel that instrumentation wiring and conduit had
!
been installed "non k".
'
10.2 Interview of BPC Scheduling Engineer
'
,
On May 27, 1982, John E. Simpson, Jr., BPC Scheduling Engineer,.
provided the following:
He was present for the conference telephone call to Region III on
,
March 12,1982, where-_CPCO and BPC sought the concurrence of Region
.
III in the underpinning areas to be excluded from the quality l
- !
assurance program. The conversation dealt with the "non Q Listed" j
.
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areas and instrumentation was discussed in that context by Al Boos.
-
The procurement and installation of the instrumentation was to be
'
"non-Q", while the calibration and monitoring were "Q listed".
Prior to the conversation with Region III, Boos had requested
Simpson to determine the status of the underpinning instalation.
Simpson did not retain any notes, but recalled he had asked a field engineer to get the installation status for him. The engineer returned with the information that four deep-seated benchmarks were
completely installed. Other benchmark holes had been drilled, the
,
pipe casing had been grouted, and conduit had been installed for eight benchmarks. Simpson stated he did not understanql the technical significance of the field engineers information, as he was looking i
-
'
at the information from a scheduler's viewpoint. He knew eight benchmarks had to be installed before work could proceed and thought the installation work was about completed. The field engineer never gave him a specific percentage-of completed work. He informed
&
Boos the instrumentaiton was " essentially complete". Simpson never personally observed any portion of the instrumentation system.
To Simpson, aLL of the information that Boos provided to Region III during the telephone call on March 12th was accurate. Had Boos said something inaccurate during the telephone call, Simpson stated he would have interjected into the conversation and corrected l. -
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Boos.
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10.3 Interview of CPC0 Engineer j
.
On May 28, 1982, John R. Schaub, CPC0 Engineer, provided the following:
He was present for a conference telephone call on March 12, 1982, to Landsman and Boyd in the Region III office. The call was placed to explain the areas CPC0 and BPC wanted to remain "non-Q".
A matrix (Exhibit X) was used to explain the status of the "non-Q" items beginning with procurement. The call was meant to discuss
,
'
work that was underway and was not meant to be a status report.
i i
Schaub was aware that some benchmarks had arrived onsite, but none i
of the instruments. It seemed logical to Schaub that without all of the benchmarks and with none of the instruments, it would not
!
be possible to route the cable and conduit. Schaub thought Lands-man was aware that none of the instruments were onsite. It also
)
seemed to Schaub that Landsman was "not tracking" with the conver-sation, even though Boos had clarified his points.
Additionally, Schaub advised that all of Boos' comments during the telephone call on March 12th were accurate and had they not been
}
accurate he would have corrected Boos.
10.4 Interm dw of Planning and Scheduling Section Head on June 8, 1982, David F. Ronk, Planning and Scheduling Section Head for the Midland Project, provided the following:
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I The March 12,1982 telephone call started without him. After
-
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~j reveiweing the BPC transcript of the telephone call (Exhibit I),
,
-
i he recalled entering the room at the point in the discussion of wood Lagging.
-
!
!
The comments about instrumentation were to inform Region III that design and procurement of the instrumentation had been done "non-Q".
Further, some raceway had been installed and cables pulled as
"non-Q".
Also, that the instrument reading would be considered
"Q~.
,
I To the best of his knowledge none of Boos' comments during the l
telephone call were inaccurate.
I 10.5 Interview of MPQAD Civil Remedial Quality Assurance Engineer Super-visor
'
On May 28, 1982, Robert E. Sevo, BPC MPQAD Remedial Civil Quality Assurance Engineer Supervisor, provided the following:
.
He was present for the Marfh 12, 1982 conference telephone call to Region III. However, he did not participate in the conversa-tion and did not remember any of the details of the call.
Sevo was shown a copy of the BPC transcript of the telephone call (Cxhibit I).
Sevo stated that to the best of his knowledge aLL (
of the comments were accurate.
,
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10.6 Interview of Mergintine Corp. Employees
.
10.6.1 Interview of Mergintine Corp. Project Manager.
on May 27,1982, Raymond E. Oberleitner, Mergintine Corp.
Project Manager, was interviewed. Overleitner stated his firm was contracted to do the underpinning work at Midland.
Oberleitner advised he was present during the opening remarks of the telephone call to Region III on March 12,
,
i 1982, but left the.oom early in the conversation. He
'
recalled some discussion about underpinning work to be excluded f rom the quality assurance program, but did not
'
pay much attention as he was not directLy involved. He
did not remember any discussion of instrumentation.
i
.
!
Oberleitner was shown a copy of the transcript of the
I March 12th celephone conversation (Exhibit I).
He
stated he could not comment on the accuracy of the infor--
mation as it did not involve his company or work area.
l 10.6.2 Interview of Meraintine Scheduling. Consultant
.
On May 27, 1982, Kenneth A Vander Jagt, Mergintine Scheduling Consultant, was interviewed. Vander Jagt advised he attended only a small portion of the March 12,
!
1982 telephone call to Region III. He did not recall the discussion on instrumentation. VanderJegt was shown
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a copy of the telephone call transcript (Exhibit I) and
,
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advised he could not comment on the accuracy of the
information as it did not pertain to his company's OT a eivities.
!
h 10.7 Interview of CPCO Scheduler
,
.
On June 14, 1982, Gary L. Rogers, Planning and Scheduling Consultant to CPCO, was telephonically interviewed f rom Los Angeles,
- :
l CA, and provided the following:
'
.
He recalled being present for the telephone call to Region III
!
e on March 12, 1982, but did not contribute to the discussions.
!
He recalled the discussion surrounded potential changes to various phases of the underpinning work. There was a general
!
!
.'s discussion about instrumentation and what had been done in design i
~
i and status in the field. Various topics concerning instrumentation were discussed, including system design, conduit placement and -
J
,
benchmark installation. However, he could not recall any speci-
fics of the conversation. He did not recall hearing anything during
,
!
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!
the telephone call which was inaccurate.
1 10.8 Interview of Quality Assurance Department Director
'
,
i-l On June 8,1982, Benjamin W. MargugLio, Direetor of the Midland '
Quality Assurance Department, provided the following:
.
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i He was present for the' conference telephone call on March 12, 1982,
.
to the Region III office. The purpose of the call was to inform Region III of the underpinning activities that were "Q" or "non-Q" Listed, and not to report the status of installation.
l t
He was presnet for the conference telephone call on March 12
!
1982, to the Region III of fice. The purpose of the call was
,
I to inform Region III of the underpinning activities that were
"Q" or "non-Q" listed, and not to report the status of instalLatio.
_. t Al Boos did most of the talking during the call and had used
,
a matrix (Exhibit X) in his discussion. Boos went down the matrix as he spoke and provided the project's desination, "Q" or
"non-Q" for an area and the reason (s) the area was not considered J
]
to be within the quality assurance program.
I a
Marguglio was confused by the Matrix's format, as he had been
'
-
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asked to join the conference call "at the eleventh hour" and had
.
(The Head of not had the opportunity to consult with Don Horn.
.
the MPQAD Civil Section). He was "new to the discussion area" and had not attended the March 10th meeting in Bethesda, MD.
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Also, it was the project policy for project management, not
.
MPQAD, to determine the areas covered by the quality assurance program.
}
Marguglio.was shown a copy of the BPC transcript of the March 12th
!
telephone conversation (Exhibit I).
He advised his participation
$
in the conference call was limited to clarification of the matrix
,
as it was used for the instrumentation. Marguglio advised he injected into the conversation to clarify the instrumentation comments, as he did not have the background of the March 10th
<
- meeting to fully understand the instrumentation matrix. Marguglio stated he was focusing on the communication of the information in the matrix and not on what Boos was actuaLLy saying.
-
t i
At the time of the conversation the transcript (Exhibit I)
t l
was correct. In retrospect Marguglio felt " wiring has been pulled"
could be misconstrued as, "aLL wiring was pulled," when in fact
.
only some _ wiring had been pulled. Marguglio also felt that Boos'
statement, "our instrun.cntation is essentially weLL underway,"
referred to procurement of the instrumentation. Marguglio believed that Boos could have been more specific during his conversation I
l with Region III on March 12,1982.
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'
11.
Review of Additional Information 11.1. Interview of Region III Personnel
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During the interviews of the Region III staf f members (Ross 8.
.
Landsman, paragraph 4.1, Exhibit II; Ronald N. Gardner, paragraph 4.2,
'
Exhibit IV; and, Ronald J. Cook, paragraph 4.3, Exhibit VI), each advised Ben Marguglio had apprised them (Landsman, Gardner and
}
Cook) of an agreement between James W. Cook, CPCO Vice President-i
!
Midland Project and James G. Keppler, Region III Adminsitrator, that the NRC would treat Items of Noncompliance involving the Midland remedial soils program dif ferently f rom other noncompliances
]
with NRC requirements.
l
.
11.2 Interview of Quality Assurance Department Director The foLLh information was obtained f rom Benjamin W. Marguglio, I
Director, Midland Quality Assurance Department, during an interview on June 8,1982:
About the time of the March 10,1982 meeting, Marguglio was j
informed by James Cook of a conversation between Cook and Keppler about the remedial soils program. The conversation dealt with CPCO's position of including non-nuclear-safety-related areas of the underpinning work into the quality assurance progra informed Marguglio that Keppler had agreed that any problems g
arising in a n clear-safety-related underpinning activity,
^6
-
s incIuded by CPC0 in the quali y assurance program and agreed to by the NRC J
(
that the activity was not related to nuclear safety, would not be treated as noncompliance with NRC requirements.
Marguglio
informed Landsman, Ron Cook, and Gardner of the James Cook-r
.
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James Keppler conversation only to illustrate to the Region III
.
staff the installation of underpinning instrumentation was not related to nuclear safety; although the calibration of instrumen-tation and use of the information was.
11.3 pterview of CPCO Vice President
.
I i
on June 9,1982, James W. Cook, Vice President-Midland Project, provided the following:
Cook reviewed CPCO's position with Marguglio prior to the March 10,
1982 meeting at NRC Headquarter wanted a single quality
{
assurance program for the underpinning. He recognized if aLL j
underpinning work came within the scope of the quality assurance i
j program, then CPCO could be held in noncompliance with NRC l
requirements for areas not related to nuclear safety. He told Marguglio that he (Cook) would teleph'one Keppler to discuss this Concer telephoned Keppler after hearing the results of the March 10th
,
meetin was concerned the NRC had too broad a definition of the underpinning areas to be included in the Quality Assurance Progra '_' felt it was necessary to go to Region III management for resolution" of the problems, and telephoned Keppler.
.
He told Keppler, CPCO was willing to have a single quality' assurance program for the underpinning work, but felt CPCO should not be penalized for underpinning work not associated with nuclear safety.
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Keppler agreed CPC0 should not be held in noncompliance by the NRC
.
for non-nuclear-safety-related work. Keppler told Cook that before
,
l making a final decision he (Keppler) would discuss this matter with the Region III staff.
'
11.4 Interview of Region III Administrator On June 11,1982, James G. Keppler, Region III Administrator,
provided the following:
a i
,
He had several telephne calles with CPCO's James Cook during l
mid-March. The calls dealt with several areas, including the i
j application of 10 CFR 50 Appendix B, to the soils problems at the i
{
Midland plant.
-
i
Cook's question dealt with the NRC staff's poisition of applying 10 CFR 50 Appendix B to the soils problem was wilLing to have Region III inspect at t of the underpinning work at Midland, but felt it would be unfair to CPCO to have citations written against 10 CFR 50 Appendix B criteria for areas which were not related to nuclear safety. Rather, Cook felt the NRC could
_
inspect the non-nuclear-safety areas, and if deficiencies were found they could be written in the body of the Region III report without making a citation against 10 CFR 50 Appendix wanted the problems to be reviewed by the NRC. Keppler did not
.
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I reach any agreement with Cook, and referred Cook to Charles Norelius,
.
Region III Director of Engineering and Technical Programs.
11.5 Interview of Region III Division Director f
On June 16, 1982, Charles E. Norelius, Region III Director of l
Engineering and Technical Programs, provided the following:
During March 1982, numerous discussions were held by his staff, l
including Gardner and Landsman, concerning the underpinning instrumentation cable pulling at the Midland site. The discussions i
surrounded CPCO's pulling of underpinning instrumentation cable without it being included in the CPCO Quality Assurance Program.
?
Based upon the discussions it was decided to issue a Confirmation of Action letter to CPC0 and to involve CPCO in a meeting at I'
the Region III offices in late March. Norelius was certain he had spoken to Cook about the cable pulling and the meeting; however, he could not recall any details of the conversations.
Bill Little, Region III Engineering Inspection Branch Chief, was responsible for the details of the meeting and Little had spoken to Cook to arrange the meetin advised Little that CPCO had been doing some remedial soils work which had not been included in the quality assurance program, and Cook and Keppler had agreed
.j that non-nuclear-safety-related underpinning work would not be l
subject to NRC regulatory review.
.
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j Norelius spoke to Keppler about the conversation between Cook and
.
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Little. Keppler advised Norelius that Cook had telephone l
-
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had apprised Keppler that CPC0 wanted to have a single quality
,
assurance program for the underpinning work and the quality assur-ance program would include nuclear-safety-related and non-safety-l related work alike in the progra had said that CPC0 t
!
should not be held in noncompliance with NRC requirements for
.
.
the non-safety-related areas of the underpinning quality assurance program. Keppler acknowledge to Cook that this seemed reasonable,
'
but wanted to speak to his staff before making a final decision.
i 11.6 Interview of Region III Branch Chief
.
On June 17, 1982, William S. Little, Region III Engineering Inspec-
,
,
tion Branch Chief, provided the following:
b
'
' '
,
Du-ing March 1982, Region III Inspectors Ross Landsman and Ronald Gardner inspected the underpinning instrumentation cable
,
at the Midland project.' They learned that cables had been
-
pulled, but quality assurance criteria had not been developed for j
those cables pulled. CPC0 agreed to stop the underpinning instrumentation cable pulling until the necessary quality assurl ance procedures were developed. Region III decided to issue a Confirmation of Action Letter to CPC0 for stopping the cable pulls.
j~
Little and James Cook, CPCO Vice President, discussed the Confir-mation of Action Letter by telephone.. Cook told Little of an
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agreement between Cook and Keppler that the NRC would not take
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l regulatory action for non-nuclear-safety-related work included in
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the underpinning quality assurance progra said certain l
areas of the underpinning werk were not related to nuclear safety, but were included in the quality assurance program to insure high
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i quality workmanship. These areas were included in the program i
j for CPC0's benefit and were not related to nuclear safety; there-fore, the areas were not subject to the NRC's regulatory process.
I i:
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l Little informed Cook he did not know of any agreement between Cook
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l and Keppler. Little also told Cook that the underpinning instrumen-I tation was definitely safety related as' the instrumentation' would I
determine if any damage had been caused to safety related structures
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j during the tunnetting process.
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t Little advised Norelius of Cook's comments about an agreement with
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Keppler. Norelius spoke to Keppler and learned Cook had telephone had explained to Keppler the CPCO position to have non-nuclear
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f safety-related areas included in the underpinning quality
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assurance program and that these areas would be excluded from the
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NRC's regulatory review. Keppler told Norelius he never had q
L l
an' agreement with Cook.
12.
, Exit Meeting On J 0,~ 1982, the results of 'the investigation to date were discussed
}
with ames W.' Cook,'CPC0 Vice President-Midland Project, and James E. Brunner,
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CPC0 attorney.
.I, Ex'hibi ts :
I Transcript of March 12, 1982, telephone catt II Statement of Ross B. Landsman
III NRC Inspection Rpt. No. 50-329/82-0$sDETP); 50-330/82-05CDETP)
IV Statement of Ronald N. Gardner
'
V NRC Inspection Rpt. No. 50-329/82-06(DETP); 50-330/82-06(DETP)
l
I VI Statement of Ronald i VII Statement of Dwane C. Boyd
,
VIII Statement of Michael J. Schaef fer l
IX Statement of Edgar L. Jones f
X Telefax Copy of Matrix used in March 12th telephone call XI Statement of Alan J. Boos XII Statement of,Darl S. Hood
l XIII Ltr, March 22, 1982, Tedesco to J. i
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XIV NRR Summary Rpt of March 10, 1982 meeting
.
XV Statement of Joseph D. Kane XVI Statement of Walter R. Bird
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March 12, 1982 2:08 p.m.
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Conference telephone call between Bechtel/ Consumers and NRC.,
C,all initiated by Don Horn /Al Boos to Dr. Ross Landsman, NRC, Region 3.
in attendance:
BECHTEL/CPCo
.
NRC-Region III -Chicago f[.7)
Al Boos Ross Landsman J.
Fisher Mr.. Boyd
- (NRC - Site)
v D.
Horn
.
J. Schaub o
C Jim Moore f
Ben Marguglio
J. Simpson j
Q, b(j V
Bob Sevo
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' /)
Dave Ronk f
Gary Rogers V
') U
Ray Oberleitner (Mergentime)
. l Ken Vanderjack
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Boos:
Hello, Ross, this is Al Boos, with Don Horn.
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Who is there with you?
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Ross:
Lansdsman and.Boyd.
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Boos:
Who else?
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That is it.
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Were you able to get through to the NhR or not?
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Couldn't raise anybody - will handle withoutMfm.
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Boos:
(Brief introductory remark) With respect to remedial
soils work, it was the staff!s position that all items
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were Q unless applicant could demonstrate that certain i
activities should be non-Q data.
When I came back to
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l Michigan, we have a weekly coordination meeting and one of
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the first things we did this morning was to draw up a list of those items which either have been completed or in
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process or are proposed which we feel can, in fact, be treated as non-Q items.
Since we are working under the
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Ex*yze27Z
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business as usus1 concept.of.you making audits, we felt
it was prudent to review with you this list prior to
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making inspection so that we would have a very clear
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dialogue in terms of'those items remaining Q, primarily
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because in some respects we elect to bid it may not be
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physically possible to replace that item - like removing p---. -Y or drift.
Since we don't want to be cited,
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we are going to attempt to identify items we feel are
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non-Q.
We feel it is essentially a. complete list.
May be a need from time to time to offer other items. *We will
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j try to do it before we undertake the work.
I wi11 ask
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Don to take us through this.
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Boos:
Access shafts below 609 - drifts, the piers and instrumentation. l
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I (Ron Cook has a copy of it.
If necessary for interpretation,
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he can help me).
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Access shaf ts below 609 - Soldier Piles.
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It may help you if you have a clean sheet of paper to
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J put down four column,' headings.
I will try and summarise.
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j With respect to soldier piles, we have procured those piles
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and have installed'them as non-Q as you are aware.
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With respect to access shafts below 609.
In this case,
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in general, other than just access shafts at 609, we feel
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_that the purchase of tools and equipment like torque i
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wr'enches, jacks, gauges and threading machines should be
I non-Q.
Our rationale is that there is either provision for
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calibration or an end inspection of the fabrication, like the reinforcing steel that is threaded by the threading
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machine.
Again, tools and equipment is intended to be
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a generic comment.
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Ne'stion:
Is this construction equipment?.
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Answer:
Yes, tools and equipment.
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(This is being transcribed for purpose $ of preparing a telephone i-
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summary.
QA required it.)
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Access sha1Er below 609 Purchaseof steel and s
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wood L;ac. T, and I'believe we talked about that the other
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day in Bethesda.
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s sJ.0 Fisher:
To differentiate - steel shape whalers in wood h3Ih
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Ross:
When we talked h the Washington, de were talking about
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the no certs.
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That is what,makes it,a,..Q purchase.
We.would not be buying A1:
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this with mill certs because this steel doesn't stay nn
'g Standard 3,1n - it is temporary and non permanent.
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. manufactured item.
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, 'R[oss: ' We are just t lking about the mill cert?.
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.yA1:
We are'not talking about buying *1t Q.
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Cook:
The tons" of concrete that-you pour around here:- did you
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have mill.csits on the wood forms you used before?
Why
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on this particulay job?
Isn't wood M steel shapes?
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'A1:.
That is right No, didn 't think it ~ needs to be bought Q.
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Cook:
You didn't talk about this before.
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.A1:
Thia,fs a.Whole'new thing.
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hat,is the meaning,of all'this?
Cook:
NRC '-
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A1:
We were directed t$at everything was to be Q unless the m
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l-l applicant could demonstrate.that item could be classified.
b K
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as non-Q - we feel. that. it is imperative for us to check
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off:with yo even though you may say need not be-
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purchased Q.
.We want tileave a-trail that is crystal-
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Cook:
The point is that historically we never have approved l
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Our function is that you are obligated to assure the world.that-tou have done all things appropriate
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and have invoked QA.
Wd cannot either agree or disagree.
_
ili I am not asking for you
- I am making a statement of our
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policy in advance.
We wi11 know in an audit what our position is.
If he is not in agreement with that
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position it is in our mutual interests for us to know now from a cost, schedule quality and personnel safety j
i standpoint.
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Cook:
Go ahead and revert back to the fact that you poured tons of concrete.
Fisher:
We are doing this because of what you told'us the other day.
A1:
Last item under access shafts below 609 is purchase of
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rock bolts.
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Ross:
Which rock bolts?
A1:
Rock bolts Turbine Building and buttress access shaft.
hS *
/Jg Again, purchase A installa^ ion would be handled as Q.
In all of these cases, I have talked about you will note
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I have talked about only procurement of material with
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exception of soldier piles.
Tools and equipment, etc Installation would be Q.
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~Ross:
Continue..
,
1A1:-
New subject - drifts.
We are planning to procure the l
material for the steel sheets which are basically the
_0m.
box-shaped frames that accept Ladd5nhinthedriftasnon-Q.
Fabrication of those steel sheets would be Q and installation.
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of the wood 1-,ving(and
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The next item - the procurement
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N wood wedges for the drifts would also be non-Q.
Procurement.
Procurement of the back packing material for the drifts would be non-Q.
And as a 4th item, the procurement of
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the rock and earth anchors would be'non-Q.
Those are the
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.i sets of items.under the classification of drifts.
Under
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piers - - -
Don has asked me to again reiterate that fabrication and installation of the drifts classification items would be
Q.
Under classification of piers, Ross, you m be aware J
that there is Ethifoam to be put behind metal _1_,g -Q
as 3.uv.
back packing.
May be gluing Ethifoam to steel We will
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propose to procure that glue as a non-Q commodity.
Verification that is in place would be a Q-listed activity.
j
That is the only entry I have under piers.
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l Last item is instrumentation.
We are talking about the i
settlement monitoring instrumentation, pier monitoring i
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instrumentation, etc.
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Our position here is that the raceway, the wire and the
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brackets that'would accept the instrumentation would be
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procur'ed and installed as non-Q.
The checkout of the
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i system and the' ' 5 3 of the reading would be Q.
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Ross:. What would you say about the instrumentation _in that area?
A1:
Instrumentation has been purchasedLQ.
The instrumentation system 1s in a data room - it has been procured and installed with environmental controls
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as non-Q.
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l A1:
The last item which is essentially a repeat of that
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sauges backup gauges)
above under access shafts j
j ave been procured as non-Q but would be calibrated
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under a Q program.
These are existing dial gauges.
,
our instrumentation is essentially well under way.
Wiring has been pulled - raceway has been installed,
.
etc.
Those are the only comments I have.
!
Ross:
Okay.
Let us talk here a minute and we will get back G
with you in just a second.
pn aI 'non Q7 B. Marguglio:
Didn't those dotted lines
,
A1:
Yes, across the board.
BM:
Did that come acgoss in the conversation?
A1:
I will reiterate it.
It becomes Q at the checkout of the system.'
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do' k :
I am here.
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Ross:
Feel free to make your own comment.
Boyd:
We would like to digest this list and get back with your designated person on Monday.
We'd like to sit down and look it over and get back with you, but not to say that we approve or disapprove.
If we have any problems or i
= does not constitute approval - it means we don't have
'
any problems with what is here.
,
A1:
We recognize that you are not going to sign anything as
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co-approvers.
l l
l Boyd:
But we can look over and make judgments whether we have
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. any problems and identify anything that does give us
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i problems.- Who should we get back with on Monday?
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A1:
Don Horn.
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Boyd:
okay.
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Boyd:
Ren, do you have any problems with that?
l Cook:
I think that can be guite livable.
We might appear not
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to have any problems but later on we get into construction
cnd problem is created.
I don't want to have relinquished
.
our right to enforcement in that area.
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Ross:
That is exactly why we don't go in o approval process.
My judgment is there will be very that will happen j
that way but we want the door open.
Ross:
Okay.
i A1:
Very good.
The rest of us in the room will wait to hear i
!
from you and your results on Monda,y.
BM:
I have a question.
Will it be both of you gentlemen calling Don Horn Monday?
Boyd:
Ron Cook and Ross and myself will get together and talk -
i one of us will make the call.
We will get back with you i
on Monday with our findings.
.
A1:
To clarify one point, to make sure I didn't mislead the people in Chicago - with respect to the raceway materi:1 M
- the wire, the fabrication of brackets thaty s
.,t e
l instrumentation,and termination of wire that we are talking I
l about that, with respect to procurement through installation.
-)
Boyd:
Could you give Ron Cook a copy of that so he can fax it to us?
'
Cook:
I will try to fax it to you right away.
l
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Boyd:
I think that is important.
L i
j A1:
Thank you very much.
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'W-1 e wa
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Midland MPQAD
(LOCATION)
June 2, 1992 (DATE)
[
. i, nigar L. Jones hereby make the following
,
statement to ciarles H. Weil who has identified himself
,
to me as an Investigator of the United States Nuclear Regulatory Commission.
I make this statement freely with no threats or promises of reward having been made to me.
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am a self employed contractor with the Midland Project Quality As Irance Department (MPQAD). I have worked at Midland for MPQAD si
.978, aspervisor of the Inspection, Examination and Test Verification group / g,/f except for six months in 1980 and two months in 1981.
I e
up
,
Electrical and I&C (Inst.nunentation and Control) Section.
m or about March 17, 198
. Ron Gardner, Reactor Inspector Region III,
,
came into Mr. Mike Sch e 's office and asked what the status of dra qs
,
and procedures for the Wderpinning Instrtsnentation was at t[ i g4 th Mr. Schaeffer and I indicated to Mr. Gardner that we believe<
strumentation was Non Class lE and that we were not aware of the status of the drawings and procedures.
$
We did tour the Data Acquisition Room on top of the Auxiliary Building with
the following:
b Mr. Marion Dietrich w. Michael Schaeffer i
Mr. Ron Gardner
,
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Mr. Ross Landsenan
'
ho engineers B1 Jones I
I found conduits, pull box, terminal block panel and some instrumentation.
installed. There were approximately ten cables that had been pulled into the, Data Acquisition Room.
,
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i Approximately two weeks ago, I teured the same Data Acquisition Room. I do not
)
recall observing any changes to the installedgquipment betwean this visit
)
and the visit on or about March 17, 1982. Y $
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have read the foregoing statement consisting of I
pages.
I have made any necessary corrections, and I have initialed those corrections. This statement is the truth to the best of my knowledge and belief. I declare under the penalty f perj/
t** I r8 u
that the for jng o
,
is true and correct. Executed on L
at (Date)
' Time)
r=4
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'*"#')
Subscribed and sworn to pefore me
this JY day of _ /4ast gf
,
i 19 Jh at /2res e**, M
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(Address)
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UNITED STATES a
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NUCLhAR REGULATORY COMMISSION
,
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g qr WASHINGTON,0. C. 20556
\\h..b..%.
gg 2 21982 5'
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i Mr'.'J. '
Vice President
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Consumers Power Company 1945 West Parnall Road.
Jackson, Michigan 49201
'
Dear Mr. Cook:
'
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S2 ject: Compilation of Infomation Requested for Completion of Staff j
Review of Phase 2 Underpinning of Midland Auxiliary Building -
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I Pursuant to the request of Mr. J. Mooney of your Company on March 11,1982, Enclosure 1 is a compilation of the infomation needed for completion of phase 2" of the construction activities for underpinning the NRC's review of of the Midland Auxiliary Building. " Phase 2" is defined by the Construction
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Sequence Logic Diagram provided the staff during a January 18-19, 1982 audit meeting (Enclosure 1 of our meeting sumary dated March 10,1982), and generally provides for further deepening of the vertical access shaft, construction of limited drifts under the Feedwater Isolation Valve Pits (FIVPs) and Turbine Building, and installation of certain piers.'
-
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Your prompt attention to these matters should provide for staff concurrence
.
with minimal impact to your present construction schedule'.
.
The reporting and/or recordkeeping requirements contained in this affect
!
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fewer than ten respondents; therefore, OMB clearance is not required under j
P.L.96-511.
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Sincerely
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'tA42
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i Robert L. Tedesco, Assistant Director
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- for Licensing
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Division of Licensing l
Enclosure:
As stated
,
cc: See next page
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MIDLAND,.
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Mr. J. Vice President
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Consumers Power Conpany
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i 1945 West Parnall Road
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Jackson,' Michigan 49201
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cc: Michael I. Miller, Esq.
Mr. Don van Farrowe,' Chief
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Ronald G. Zamarin, Esq.
Division of Radiological Health,,
i Alan S. Farnell, Esq.
Department of Public Health
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Isham, Lincoln & Beale P.O. Box 33035
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Suite 4200 Lansing, Michigan 48909
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1 First National. Plaza
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Chicago, Illinois. 60603 William J. Scanlon, Esq.
2034 Pauline Boulevard
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James E. Brunner, Esq.
Ann Arbor, Michigan 48103 i
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Consumers Power Cocyany
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U.S. Nuclear Regulatory Comission
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212 West Michigan Avenue Jackson, Michigan 49201 Resident Inspectors Office
,
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Route 7 Midland, Mic8f'gan 48640
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Ms. Mary Sinclair 5711 Summerset Drive
,
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Midland, Michigan 48640 Ms. Barbara Stamiris
.
5795 N. River
!
Stewart H. Freeman Freeland, Michigan 48623 l
Assistant Attorney General
.
State of Michigan Environmental Mr. Paul A. Perry, Secretary l
l Protection Division Consumers Power Conpany 720 Law Building 212 W. Michigan Avenue
,
Lansing, Michigan 48913 Jackson, Michigan 49201
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Mr. Wendell Marshall Mr. Walt Apley
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Route 10 c/o Mr. Max Clausen BattellePacificNorthWestLabs(PNWL)
,
Midland, Michigan 48640 Battelle Blvd.
$1GMA IV Building
"
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Mr. Roger W. Huston l
Richland, Washington.99352
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Suite 220
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7910 Woodmont Avenue l
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Bethesda, Maryland 20814 Mr. I. Charak, Manager
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NRC Assistance Project
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Argonne National Laboratory Mr. R. 8. Borsum
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Nuclear Power Generation Division 9700 South Cass Avenue
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Argonne,1111'nois 60439
,
' Babcock & Wilcox i
7910 Woodmont Avenue, Suite 220 *
James G. Keppler, Regional Administrator
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Bethesda, Maryland 20814 U.S. Nuclear Regulatory Comissi,on,.
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Cherry & Flynn Region III
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I 799 Roosevelt Road
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Three First Nationai Plaza Glen Ellyn, Illinois 60137
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Chicago, Illinois 60602
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Mr. Steve Gadler
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2120 Carter Avenue
St. Paul, Minnesota 55106
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Mr. L. J. Auge, Manager Facility Design Engineering
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Mr. Neil Gehring
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7th Floor
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477 Michigan Avenue
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Charles Bechhoefer, Esq.
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Atomic Safety & Licensing Board U.S. Nucitar Regulatory Commission
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Washington, D. C.
20555 Mr. Ralph S. Decker
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Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission
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Washington, D. C.
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Dr. Frederick P. Cowan
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Apt. B-125
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Jerry Harbour, Esq.
l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commissic.n
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Geotechnical Engineers, Inc.
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1017 Main Street
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Winchester, Massachusetts 01890
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Underpinning Work Midland - Auxiliary Building
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T GEOTECHNICAL EN'GINEERING f
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Review Concern (
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Submitt'al of. Updated Construction Sequence Drawing
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in ;Feb. 3-5' Audit and Feb. 26.1982. Meeting)._,
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Lettir documenting ac'tual' work to be performed und t'.',
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(telephone record, March 8,19'82,' Par'. 3).
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comitment not to proceed with 2b until t f : :. :
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by HRC Staff.
Update drawing of " Monitoring Matrix", No. C-1493(Q Ff%M
include tolerance criteria -(Telephone record, Mar. 8,1982
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Par.4.b).
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3j, CPC coanitment to have 6 deep seated bench marks wi
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installed and operational before beginning Phase 2a work.
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Also (Telephone record, March 8,1982 Par. 4.B and Par. 5)
instruments DMD-1W, DMD-1E, DSB-1W DSB-1E are to
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and operational.
(Feb 3-5 Design Audit).
.
Submittal of strain gage installation details 9 El 659 with
-
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26, 1982 meeting * and
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limiting strain valves and basis (Feb.
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telephone record, Mar. 8,1982, Par 4.d).
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s Comitment to perform test load above design load (e.g.,1
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. times)*on installed pier to develop load-deflection curveIdenti
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for verification of hard clay soil modulus.
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(Feb. 3-5 Design Audit).
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Submittal of measures to be required during periods of.
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shutdown to support faces of drifts' and bottoms of pits
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7.
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(Feb. 3-5 Design Audit).
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Submittal of plans for dewatering loca
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adyance of pit construction (Feb. 3-5 Design Audit).
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il Phase 2a items are thost not impacted by analyses of th
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modulus values beneath the main, Auxiliary Building,
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No.
Review' Concern
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1.
Provide instrumentation details and horizontal movement tolerance,,
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criteria with basis, for 3 instruments to be insta11'ed at top of.
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EPA's and Control Tower (Telephone record, March 8,1982
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Par. 4.c and Par. 5).
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Submittal of.results from analysis that establishes induced stresses at El 659 assuming EPA is supported by first temporary
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support (Pier W8) and using Existing Soil Springs under EPA and
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Control Tower and Auxiliary Building (Feb. 3-5 Design Audit)
i 3.
Comitment by CPC to have installed and operational all of the
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remaining instrument.s identified on Drwg C-1493(Q).
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II. STRUCTURAL ENGINEERING (Phase 2a)
,. Strain gauges or equivalent shall be provided at critical locations,
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Elevation 659' slab i
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Control Tower shear wall c.
Slabs and' walls near post-tensioning cables at the Control
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Tower and Electrical Penetration Areas
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Steel beams shall have strain gauges.and not, deflection
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meters.
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Information shall be provided for these gauges regarding:
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'
1.
Location
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2.
Monitoring frequency
.
3.
Limits (initial and distress points)
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Evaluations of results (method and acceptance criteria)
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Commitment that instruments shall be in place and operational before beginning Phase 2a.
III. MECHANICAL ENGINEERING BRANCH (Prior to drifting beneath FIVP)
.
1.
. Allowable movements shall be based upon total settlements since
,
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the main feedwater piping was first installed in 1977.
.
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2.
A cornitment that the 2" steam generator drain lines shall first be shown not to be limiting for allowable structural movements in
.
the event a decision should be made to connect this piping prior
to completion of underpinning.
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IV. QUALITY ASSURANCE
-
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Applicant shall notify NRC that all underpinning construction
'
will be Q listed consistent with the NRC Staff's findings during
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the meeting of March 10, 1982.
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UNITED STATES
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Docket Nos: 50-329 and 50-330 DM.0L
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APPLICANT: Consumers Power Company
FACILITY:
Midland Plant. Units 1 and 2 l
SUBJECT:
SUMMARY OF MARCH 10, 1982 MEETING CONCERNING QUALITY
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ASSURANCE TO BE APPLIED TO REhEDIAL FOUNDATION WORK l
'
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On March 10, 1982, the NRC Staff met in Bethesda, Maryland with Consumers Power Company and Bechtel Power Corporation to discuss the application of quality
'
assurance to remedial foundation work. Specifically, applicability to work
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related to underpinning of the electrical penetration areas of the Auxiliary j
j Building and of the Service Water Pump Structure and to construction'of the new
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Borated Water Storage Tank foundation ring was discussed. A list of meeting A
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attendees is attached as Enclosure 1.
Enclosure 2 is a compilation of the i
i materials handed out and discussed at this meeting.
j SUMMARY l
A draf t of the Quality Plan'for Underpinning Activities was submitted for NRC
'
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i review by Consumers Power Company letter dated January 7,1982. During the
.
course of its review, the Staff had requested to be provided with a listing of
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'ite'as and activities to which the plan would not apply (i.e.. "non-Q" l
activities). The meeting was held to allow the Applicant and his
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Architect-Engineer to discuss in detail the applicability of.this plan.
l The Applicant informed the Staff that the Quality Plan has recently been fina-
lined as MPQP-1.* It was transmitted by Bechtel by CPCo (WRBird) letter dated l
March 3, 1982 (see Enclosure 2).
'
The Staff noted that the prograismatic aspects of the quality plan submitted j
January 7 appeared to be in full compliance with Appendix B of 10CFR50 and are l
,
acceptable. Issuance of formal acceptance is awaiting the discussion of the
,
l extent.of the program's applicability and specifically the itdes which it will
j not cover. Due to the nature of this work, the staff's initial consideration is
'
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that essentially all construction activities related to the remedial work should
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'
fall under this program.
,
CPCo and Bechtel sought to limit full progran applicability to those items which they considered safety-relatpd. This ters is defined in the accepted CPCo
'
Quality Assurance Topical Report and in section 1.1.2.2.1 of the FsAR (see
'
l-Enclosure 2)..From a technical design viewpoint. Bechtel proposed the following '
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clarifications as the logical application of these definitions to the remedial
-
work:
1.
Only permaisent supports / structures need be Q listed.
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2.- ' Temporary (i.e.._ construction) supports need not be Q'.
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Exhibit XIV
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Support of non-Q* structures (e.g., turbine building) is inherently non-Q..
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Procedures for manipu19 tion M a ecf*y nerneta s (e...,,acking) are Q j
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when the manipulations produce final input loads. For example, jacking
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i from a temporary support is non-Q not because it is not important but
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because it is not relied on for the safety of the structure following fuel
i load when the health and safety of the public could potentially be at risk.
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5.
'A monitoring program to determine the effect on safety-related structures f
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of all work, including temporary (i.e., non-Q) loads will be in place. The i
i monitoring program will be Q.
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i 6.
Non safety-related buildings and supports which can affect safety-related
i structure are non-Q. However, the evaluation of the effect of such struc-
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tures on safety structures is Q.
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7.
Given the above points, the conclusion must be drawn that installation of
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temporary underpinning where it will ultimately become a part of the
'
permanent underpinning'(i.e., under the control tower) is Q.
Temporary i
support of the electrical penetration areas, not to be a part of the final
,
l support, is non-Q however the evaluation of its effect on the structure is t
i Q.
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CpCo noted that the key point in the above items is that adverse impact on a i
structure from the temporary work has a potential impact on plant licensability,
'
j but not on health and safety. CPCo acknowledged, however, that quality control
'
j on some work which would not be defined as Q in accordance with the above is
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desirable considering the nature and extent of this work. CPCo therefore j
'
proposed a new designation of "QA".
Items and activities so designated would be
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treated by CpCo, Bechtel, and their construction contractors exactly as Q items
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l except for reportability to the NRC. A portion of the Auxiliary Building l
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construction sequence drawing designating those piers to be Q and those to'be,,QA" i.
was discussed (see Enclosure 2).
,
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There are certain activities related to the undarpinning work which would fall.
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in neither of these categories. An example discussed at some length was excava-g tion of the drift (tunnel)^under the turbine building (non-Q). Although finsi
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j construction drawings, ptoparation of which would. involve a final I
,
i classification, are not complete, the Applicant agreed this work would probably i
fall into neither category. The staff.noted that failure to properly install
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I tihe associated bracing could have an inasdiate effect on the Auxiliary Building..
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The Applicant contended that the monitoring program for the Auxiliary Building,
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j which is accorded Q status, would detect such an effect.
F
,
i During the discussion, the Applicant empressed concern that a Q-listing autons-j-
tically required the imposition of numerous difficult requirements which might i
L mot relate to the real soneern. The staff disagreed, noting that 10CFR50
' Appendin 3 provides that QA shall be implemented to the entent commensurate with
the impact on safetyg for esemple, while it does not matter what taplement is :
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used to remove soil when Jigging an access shaft, the location, sise, and depth j
of the shaft are important.
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ifleeting Sumary
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Following a private caucus, the Staff responded to the applicant's proposals as
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follows:
,
The Staff did not accept the concept of theQA" Classification. The Staff considers that all activities beginning with phase 2 work should be Q
.
!
listed except on very specific items whwich can be shown on a specific basis to justify non-Q treatment. NRR concurrence in this justification l
,
'
must be obtained prior to conducting any work efforts completely outside
'the quality plan.
I l
4 The Region will continue the level of involvement of the recent past.
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Every drawing and specification does not require Region III concurrence
,
i before use, although they must be completed and available prior to commen-cing the work they cover. In preparing and approving these documenta, i
j individual detailed activities which require or do not require specific QA
!
-
controls shall be specified in accordance with the quality plan and consi-I
dering the flexibility inherent in 10CFR50 Appendix B.
The Staff rejects the philosophy of reliance on the monitoring program as i
the sole Q protection for safety structures. The process controls which
!
preclude the attainment of undesirable effects which the monitoring program
'
would detect must be subjected to the full rigor of the MPQAD program.
l With respect to the items of design philosophy enumerated above, the Staff j
disagrees with number's 1, 2, 3 and 7.
The Staff disagrees with the limita-
!
tion cf number 4 to final input loads. The Staff agrees that the j
inonitoring program of number 5 aust be Q but rejects the concept of this as i
the sole Q protection for safety-related structures. The staff disagrees
!
-
with the aspects of number 6 which classify non safety-related buildings
-
and supports as non-Q but agrees the evaluation of effects must be Q as
,
l well as related construction and design work.
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.
It was. agreed at' the conclusion of the meeting that the applicant must suSait a
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1etter, prior to beginning phase 2 work, which provides the information agreed i
i to in the March 8, 1982 telephone call with Mr. J. D. Kane of the Staff (see j
Enclosure 2). The NRC will take specific action on this submittal prior to the
start of phase 2 work.
I'
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,
l Mu Hn 7h
.
,
Darl S. Hood, Fruject Manager
,
Licensing Branch No. 4
,
j Division of Licensing
,
l Enclosures:
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As Stated
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cc:
I See Next Fase
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MIDLAND
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Mr. J. ;
Vice President
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Consumers Power Cogany
1945 West Parnall Road
!
Jackson, Michigan 49201 I
cc: Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief
' Ronald G. Zamarin Esq.
Division of Radiological Health
Alan S. Farnell, Esq.
Department of Public Health Isham, Lincoln & Beale P.O. Box 33035
,
Suite 4200 Lansing, Michigan 48909
.
'
1 First National Plaza Chicago, Illinois 60603 William J. Scanlon, Esq.
2034 Pauline Boulevard
James E. Brunner. Esq.
Ann Arbor, Michigan 48103 Consumers Power Cogany
,
i 212 West Michigan Avenue U.S. Nuclear Regulatory Comission i
Jackson, Michigan 49201 Resident Inspectors Office
!
Route 7
-
.
I Ms. Mary Sinclair Midland, MicNigan 48640
'
5711 Summerset Drive i
Midland, Mir.higan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623
Assistant Attorney General
State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Co g any 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Walt Apley
'
Route 10 c/o Mr. Max Clausen
. Midland, Michigan 48640 Battelle Pacific horth West 1.sbs (PNWL)
,
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352
l 7910 Woodmont Avenue,
i l
Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory
.
Nuclear Power Generation Division 9700 South Cass Avenue
.
Babcock & Wilcox
' gonne, Illinois' 60439 7910 Woodmont Avenue, Suite 220
Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Comissi,on.
'
-
Cherry & Flynn Region III
-
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Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, 1111nois 60602
.
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I cc: Commander, Naval Surface Weapons Center ATTN:
P. C. Huang
.
White Oak
.
.
. Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center
,
P.O. Box 1449
'
Canoga Park, California 91304
.
,
Mr. Neil Gehring
+
U.S. Corps of Engineers j
NCEED - T
.
7th Floor
}
477 Michigan Avenue i
Detroit, Michigan 48226
,
Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission
,
.
Washington, D. C.
20555 i'
,
Mr. Ralph S. Decker
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission
.
.
Washington, D. C.
20555 t
Dr. Frederick P. Cowan
.
Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
,
Washington, D. C.
20555
-
,
deotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos
1017 Main Street
.
Winchester, Massachusetts 01890
,
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i ENCLOSURE 1
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l LIST OF ATTENDEES
!
March 10, 1982 NRC Meeting, QA REMEDIAL FOUNDATION WORK S
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'
NRC CPCo BECHTEL
.
.
,
D. S. Hood J. A. Mooney A. J. Boos
E. G. Adensas R. H. Huston N.
Swanberg R. B. Landsman D. M. Budzik
+
J.
Gilray W. R. Bird
R. J..
Brunner
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J. D. Kane R. C. Hirzel i
F.
Rinaldi D. E. Horn
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ISHAM, LINCOLN & BEALE
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l MEETING SUMMARY DISTRIBUTION Docket File G. Lear ryg o.cc,k I I # 9 I E--
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NRC/PDR S. Pawlicki
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Local PDR V. Benaroya
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. TIC /NSIC/ TERA Z. Rosztoczy LB #4 r/f W. Haass
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H. Denton D. Muller
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E. Case R. Ballard
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D. Eisenhut W. Regan R. Purple R. Mattson
,
B. J. Youngblood P. Check A. Schwencer D. Parr
,
F. Miraglia F. Rosa t
J. Miller W. Butler G. Lainas W. Kreger i
R. Vollmer R. Houston J. P. Knight W. Gammill R. Bosnak L. Rubenstein F. Schauer T. Speis
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R. E. Jackson W. Johnston Attorney, OELD S. Hanauer
01E (3)
C. Berlinger
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F. Schroeder
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R. Tedesco D. Skovholt
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M. Ernst i
K. Kniel NRC Participants:
G. Knighton A. Thadani
,
D. Hood D. Tondi
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E. Adensam J. Kramer
R. Landsman D. Vassallo J. Gilray P. Collins D. Ziemann J. Kane F. Congel F. Rinaldi J. Stolz M. Srinivasan
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R. Baer
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bec: Applicant & Service List E. Adensam
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D. Hood I
Project Manager l
Licensing Assistant M. Duncan
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General Offlese 212 West Michigan Avenue. Joskeen. Miehleen 492e1 * (817) 7964880
March 3, 1982 i
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Mr A J Boos
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Bechtel Power Corporation PO Box 1000 Ann Arbor, MI h8106
MIDIana PROJECT -
QUALITY PLAN FOR UNDERPINNING ACIIVITIES FILE:
0.h.9 20.6, 5 17 SERIAL: 1611h
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Attached is MPQP-1, " Quality Plan for Underpinning Activities," with an effective date of March 2,1982.
It should be recognized that although this plan is just nov getting its for=al release while avaiting the policy document for authorization for us to utilize quality plans on the Midland
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Project, that in fact the plan has been in effect since early January when the Project Teas me=bers agreed to the centents of the plan. This formal i
release of Revision O is changed frem what was reviewed anc agreed upon in early January as follows:
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Words were added to specifically define the MPQAD role in reviewing d
non-Q documents. These specific words were reviewed with you on February 19', 1982.
I 2.
Reference to EDPI k.25.1 was revised to include the ney procedure EDPI h.25 2.
3.
EDPI's 2.1h.8 and h.1'.1 vere added to the list of appligable procedures.
These vere referenced in the body or the attachments to the plan.
k.
EDPI h.62.1 was eliminated from the list of applicable procedures as that specific EDPI has teen cancelled.
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All elements of this quality plan must be in effect prior to Phase II of the underpinning activities.
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l mBQ W R Bird
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Manager of Quality Assurance
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Midland Project
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npqp.1
REVISION 0
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'*i March 2, 1982
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Page 1
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t QUALITY PLAN FOR
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UNDERPINNING ACTIVITIES
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Effective Date March 2, 1982
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, Approved
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Manager MPQAD'
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Approved oo Fls 182,
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MPQP-1
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REVISION 0
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March 2,~1982
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Page 2 i
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES
GENERAI,
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All' activities for the remedial soils work will be covered by the existing-
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Consumers Power Company and Bechtel Power Corporation Topical Reports CPC-1-A and BQ-TOP-1, Revision 1A, respectively. This Quality Plan provides a more
_f detailed written description of the accomplishment of activities specific to
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the soils remedial work.
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The senior management co,sisting of J W Cook as Vice President of Projects,
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Engineering and Construction (Consumers Power Company) and J A Rutgers,
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f Midland Project Manager for Bechtel Power Corporation (CPCo's contractor for i
i the Midland Nuclear Plant), will review and approve major decisions and design concepts regarding remedial soils work. J A Mooney, CPCo Midland Project Office Executive Manager, and A J Boos, Bechtel Assistant Froject Manager,
will manage the remedial soils work. J F Fisher, Bechtel Construction '
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Remedial Soils Group Supervisor, will coordinate the Bechtel and Subcontractor
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field activities.
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W R Bird (Manager of MPQAD) and D E Horn (Civil Section Head).will manage the i
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remedial work with the overview of B W Marguglio (Director of Environmental and Quality Assurance).
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The specific Quality Plan and Q-list activities are defined in attachments to the Technical Specifications for Underpinning (7220-C-194 and 7220-C-195).
Organizations involved with the underpinning are defined in the Functiohal
,
f Matrix, Attachment 1 and as follows:
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miO332-4025a-66-27
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MPQP-1
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.3 REVISION 0 March 2, 1982 Page 3 i
QUALITY PLAN FOR UNDERPINNING ACTIVITIES
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CPCo Project Management - Sets policy, coordinates licensing review, and
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submittals to the NRC.
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,CPCo Safety and Licensing - Performa licensing reviews and coordinates FSAR revisions.
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'CPCo Design Production - Provides client design input and performs reviews of
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and comments on Bechtel Design Documents.
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CPCo Site Management - Monitors remedial activities with respect to commercial type items, construction activities such as equipment care, labor and production.
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Bechtel Project Management - Coordinates with client and sets polief for i
Bechtel organizations.
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Bechtel Project Engineering - Establishes design criteria and reviews input
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from non-Bechtel sources. Originates and
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controls design documents for construction.
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Becht'el Project Geotechnical Engineer - Functions as Project Engineering's
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Geotechnical representative on
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I project. Performs geotechnical
reviews related to design criteria and procedures. Interfaces with Geotech Services and Resident Geotechnical
.
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Engineer.
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miO342-4025a-66-27
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MPQP-1
i REVISION.0
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March 2,.1982
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Page 4
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QUAIITY PI.AN FOR UNDERPINNING ACTIVITIES i
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Bechtel Construction Remedial Soils Group - Performs the overall on-site i
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i management of all Remedial Soils
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Group remedial underpinning
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activities including construction
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coordination between Bechtel, NRC, i
CPCo and Subcontractor. Provides
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direction over Subcontractor
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J activities, and shall be the i
I single point of contact between l
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Subcontractor and Bechtel, NRC
,
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l CPCo and other agencias,
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l Geotech Services - Provides design and field geotechnical services as
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requested by Project Engineerias.
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Resident Geotechnical Engineer - Performs foundation inspection and
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geotechnical on-site monitoring of related
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l construction activities.
Interfaces with the Project Geotechnical Engineer.
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i Bechtel Quality Control (QC) - Performs first-line inspection verification of
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site Q-fist activities. Reviews safety-related
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construction Procedures.
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Midland Project Quality Assurance (MPQAD) - Provides the quality assurance for
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all remedial work including work
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REVIstoN o
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March 2, 1982 Page 5 ei
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i QUALITY PLAN FOR UNDERPINNING ACTIVITIES
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deae by Bechtel and Bechtoi l
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t Subcontractors. Develope quality i
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plass, reviews safety-related
design documents and construction
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procedures. Perfogas over-
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inspections and pre planned audits
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of Q-list activities as defined is a
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the quality plans.
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j subcontractor - Perform construction activities as contracted for. within the
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framework of the Midland Project Quality Program.
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consultaat - Provides advice to Bechtel Project Engineering er Bechgel
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S Construction (Remedial soils Group) os constructies methods,
destas, instrumentaties or gestech.
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j DESIGN CONTROL
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i Design Centrol for the remedial underpinatas of the Auxiliary Building
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(Electrical Penetrations and Centrol Structure) and Feedwe'ter Isolaties Valve
- Pit fill material replacement and Service Water Pump Structure will be
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provided by Project Kasiseering. Engineering Departeest Precedures (EDPs) and t
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Engineering Departamat Project Instructions (IDPIs) will provide the controls i
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for Engineering activities which are resPensive to the quality Progran requirements.
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miO342-4023e-44-27
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REVISION 0
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March 2,'1982
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Page 6
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l QUAI,ITY PI.AN FOR UNDERPINNING ACTIVITIES, t
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Desiga criteria will be developed from design input from consultants, the
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Midland Plant Safety Analysis Report, 50.54(f) responses submitted to the NRC
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staff, meetings with and submittals to the NRC staff, and testimony during the
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I ASI.B Soils hearing.
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Design documents, including specifications and drawings (as well as changes j
and revisions to these documents), will be reviewed and checked for compliance
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to design requirements by"Pechtel Project Engineering. Design documents will l
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be reviewed by Quality Control, MPQAD, Project Geotech and Construction'.
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The HPQAD review applies to design documents designated as either Q-listed l
j (safety related) or noa Q-listed. Por documents which are not safety related i
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i the MPQAD review will be limited to assuring the document in fact does not
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require safety related activities to protect Q-listed items, systems, or
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' structures. Subsequent revisions to documents concurred to be noa-Q-listed
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need not be submitted to NPQAD for review unless such a revision specifically i
adds a safety reisted activity.
, NPQAD will act as tha focal point for the assurance of the resolution of guality related consents.
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Technical specifications and revision,s thereof will be generated, reviewed, approved, and controlled by Bechtel Project Engineering is accordance with EDP 4.49.
Initial specifications will also be reviewed by CPCe Design Production and ceaments submitted to Bechtel Project Engineerias.
Specification Change Wetices (SCNs), used as interia change documents between
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siO382-4025a-66-27 l
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REVISION 0
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}farch 2, 1982 Page 7 QUALITY PLAN FOR UNDERPINNING ACTIVITIES il i
revisions of the specification, will receive the same level of review and
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approval-by Bechtel Project Engineering as the basic specifications, i
l Specification Change Notices shall be administered and controlled in
,
accordance with EDPI 4.49.1.
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Project Engineering will prepare, review, approve, issue and control design
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drawings in accordance with EDP 4.46.
Changes to engineering drawings will i
receive the'.same level of review and approval as the basic drawing and are
, administered in accordance with EDP 4.47 and EDPI 4.47.1.
Bechtel design calculations shall be originated, chec'ked, approved, controlled
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and documented by Project Engineering in accordance with EDP 4.37.
All design
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, calculations rubmitted by the consultant will be checked, reviewed,and
_ approved by Bechtel Project Enginearing, i
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C-BechtelConstruction.RemedialSodsGroupwillrequestfromornotifyProject
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Engineering of changes'to'dasign doct:senta by Field Change Requests (FCas) sud
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Field Chauge.N'otices Urdis), r=~4petively. The FCKs will be reviesad, j _
evaluated,dispositioned,contro1hedsadadministeredin,accordancewithEDP-
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4.62.
FCNs will allow Field CNasi.ructica to initiate field changes in design
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doctunents within the allowable gui. del,ines of Field Procedure FPD 2.000 as
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proyided by Project Engineering! FChs will be reviewed, evaluated, t
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,dispositioned, controlled and administered according to EDPI 4.62.1.
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REVISION.0
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March 2,.1982 l-Page 8 f
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES administered as illustrated in Attachment 2, Design Document Interface
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i Flowchart. Geotech design and calculation reviews will be accomplished per
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EDPI 4.25.2.
The Subc.ontractor will receive design documents from Field Document Control to be utilized for construction.
.
, Inspections will be performed by Bechtel QC to verify that construction is being performed to the latest. revisions of the design documents; audits and/or l
overinspections will be conducted by MPQAD. Field geotechnical activities, f
including subgrade acceptance, will be accomplished in accordance with
.
EDPI 2.14.8.
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PROCUREMENT AND RECEIVING
All procurement of Q-list items and services. for the remedial underpinning work will be done by Bechtel employing the technical and quality requirements
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established in the specifications and drawings. Q-material requisitions will
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be originated by Bechtel Construction Remedial Soils Group in accordance with I?G-8.000. Bechtel Construction Remedial Soils Group will be responsible for
, assuring that applicable regulatory. requirements, design bases, speci-fications, procedures and drawings are included and referenced in the
,
,
i procurement documents. The Field Procurement Department will initiate formal
,
i (
purchase orders and will be responsible for ensuring that the procurement l
package is complete and includes all of the information required by the supplier. MPQAD will review and approve procurement documents in accordance with MPQAD Frocedure M-5 to assure that necessary quality program requirements i-are included.
,
miO382-4025a-66-27
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REVISION 0
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March 2, 1982
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Page 9
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QUALITY PI.AN FOR UNDERPINNING ACTIVITIES
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Upon receipt of Q-material, inspections will be performed by Quality C
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l in.accordance with PSP G-5.1 to verify items comply with the procurement j
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Quality Package requirements and quality verifications packages are complete.
!
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. verification packages will be reviewed for availability, traceability and
,
f In legibility by Bechtel QC and audited by MPQAD (MPQAD Procedure F-1M f
h l QC for non-shop
.. addition, a technical review will be performed by Bec te
,
inspected items.
.
PREPARATION AND IMPLEMENTATION OF PROCEDURES / INSTRU
,I
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All Q-list activities performed by Bechtel or the Subcontractor to support
f construction will be controlled by approved procedures and/or instructions.
Written instructions to the Subcontractor will be in the form of engineering
,
,
specifications, drawings, and approved changes thereto.
i i
l The G-321D form (controlled by EDP 4.58) attached to the specifications
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,
,
identify the procedures to be submitted by the Subcontractor prior to the
,
These procedures will te logged, f:
. start of fabrication and construction.
controlled, and. distributed by the Field Document Control Center and w
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,
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reviewed by Prodect Engineering, Bechtel QC, Bechtel C*onstruction R
.
l Soils Group, HPQAD and Consultants as defined in Appendix A of the Q
.
Project
>
Plan and Q-listed activities for each technical specification.
Engineering will define the quality attributes of each procedure uti Q-listed activities called out in Section 4.3 of the Quality Plans review applies to procedures / instructions designated as either Q-listed F,or documents which are not safety related (safety related) or non Q-listed.
miO382-4025a-66-27
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REVISION 0 March 2, 1982
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Page 10 QUALITY PLAN FOR UNDERPINNING ACTIVITIES.
the MPQAD review will be limited to assuring the document in fact does not
,
j regsire safety related activities to protect Q-listed items, systems, or structures. Subsequent revisions to documents concurred to be non Q-listed
need not be submitted to MPQAD for review unless such a revision specifically
,
adds a safety related activity.
'
These procedures, when approved by Bechtel Project Engineering, Bechtel QC and
!
MPQAD, will provide authorization for fabrication / construction to proceed.
'
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INSPECTION, EXAMINATION, TEST AND CALIBRATION
I l
Quality verification, inspection and testing of all Bechtel and Subcontractor
'
Q-list activities will be performed by Bechtel Quality Control, independent of the Subcontractor and the Bechtel Construction Remedial Soils Group. Bechtel QC will prepare inspection plans (in accordance with PSP G-6.1 and G-1.1)
.
utilizing inputs from technical specifications, design drawings and Subcontractor procedures. Project Qtality Control Instruction (PQCIs) vill be prepared to cover all Bechtel and Sul. contractor Q-list activities. Existing
.PQCIs will be adapted for standard construction activities such as concrete
,
batching, placement and testing, and reinforcing steel installation.
Additional PQCIs will be developed as necessary to verify new underpinning
.
activities such as temporary support installation, load transfer and threaded reinforcing connectors. All PQCIs will be subject to MPQAD review according to MPQAD Procedure E-2M.- In addition, inspection and test activities will be monitored by'MPQAD through the use of overinspection plans ba'ed on an s
independent evaluation of design and procurement documents (MPQAD
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REVISION 0
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March 2, 1982 Page 11 I
l QUALITY PI.AN FOR UNDERPINNING ACTIVITIES
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j Procedure E-1M). The Subcontractor will be indoctrinated to Bechtel QC and MPQAD procedures and inspection planning to assure that hold and witness I
!
inspection points included as an integral part of the Subcontractor's
-
i procedures, will be adhered to.
-
l
-
Test will be performed to qualify, demonstrate or assure that the quality of
'
procured items or completed construction is as defined in applicable I
engineering drawings and procurement documents.
!
Calibration, maintenance and control of measuring and test equipment wil'1 be l
provided by an approved agency which will be pre qualified by MPQAD. This I
agency will provide for traceability to National Standards, the unique
.
l identification of each instrument or equipment requiring calibration, the
,
f
- establishment of calibration frequencies, and the identification of l
j calib'ation status. Calibration records will be maintained by the agency and r
i transmitted to Bechtel Construction Remedial Soils Group for review. At the
..
completion of the subcontract, these records will be turned over to Bechtel Quality Control. Performance and effectiveness of the agency will be verified by MPQAD audits and/or overinspections in accordance with MPQAD Procedures F-
.
1M and E-1M.
.
HANDLING AND STORAGE
.
~
_
All Q-list materials will be stored and handled in accordance with general Field Procedures FPG 4.000 and 5.000 and supplemented by the Subcontractor's procedure. Storage and handling of material,and equipment will be subject to I
.
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REVISION 0 I
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March 2,'1982 l
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Page 12 l
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j QUALITY PLAN FOR UNDERPINNING ACTIVITIES t
Bechtel QC inspection and verification according to PSP G-5.1 and MPQAD overinspections and/or audits.
(MPQAD Procedures E-1M and F-1M).
.
I DOCUMENT CONTROL AND QUALITY RECORDS i
Subcontractor documents which are to be submitted for review and comment by l
Bechtel Project Engineering, Bechtel QC and MPQAD will be controlled by the Field Document Control Center'(FDCC) in accordance with FPD 1.000.
Prior to the start of work, the Subcontractor will submit construction procedures as
'
required by the specifications, purchase orders and/or drawings to Bechtel Construction Remedial Soils Group. Bechtel' Construction Remedial Soils Group
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and the FDCC will distribute the procedures for review and approval as defined
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i in the Quality Plans for the underpinning activities. Bechtel Project Engineering will be responsible for resolving review comments.
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All quality records will be controlled by EDPs 5.16 and 5.24, Bechtel QC Procedure PSP G-7.1 and HPQAD Procedures F-11M and F-12M. *hese procedures will prescribe the requirement'for preparation, control, distribution and transmittal of all Q-relatd procedures, specifications, drawings and
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inspection records.
NONCONFORMING ITEMS AND CO2RECTIVE ACTION
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Nonconformances discovered during construction inspection activities will be documented and controlled by Bechtel QC in accordance with PSP G-3.2 and MPQAD.
in accordance with MPQAD Procedure F-2M.
These procedures provide for the
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i-identification'and documentation of the nonconforming ites, identify the i
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REVISION 0
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' March 2, 1982
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Page 13
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES authority for and disposition of the nonconforming condition, and provide for documenting the reinspection and closeout of the nonconformance.
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i Within the Midland Project Quality Program, the identification of significant i
and reportable items will be accomplished by Bechtel QC and MPQAD through the review of nonconformance reports, supplier surveillances and quality assurance
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audits. Ccerective action for significant quality problems will be controlled
,
by Bechtel PSP G-3.2 and MPQAD Procedure F-3M.
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J In the design phase, investigation of cause and action taken to preclude j
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recurrance of design deficiencies will be accomplished through EDP 4.65.
Design deficiencies include those items which are not identified in the course
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of design development and which ultimately require changes.
.
.
AUDITS
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Audits will'be performed by MPQAD to verify conformance of Q-list activities.
MPQAD Procedure F-1H includes provisions for the identification of deficiencies, the determination of entrective action, and the necessary-follow I-
!
.
up to verify that timely and effective action is taken. '
.
L TRAINING AND CERTIFICATION
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I All inspectors and quality auditors will be trained r.nd certified in accordance with PSP G-8.1 or MPQAD Procedures B-2M and/or B-3M.
Subcontractor field supervisory and engineering personnel will be indoctrinated to the l
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REVISION 0
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March 2, 1982
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QUALITY PI.AN FOR UNDERPINNING ACTIVITIES quality system, inspection techniques, nonconformance control, NRC activities,
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field and engineering design changes and site organizations and interfaces The indoctrination will be ccepleted prior to any work proceeding. The
,
Subcontractor will be required to implement training for the procedures covering the Subcontractors Q-listed activities.
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REVISION O
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March'2, 1982
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Page 15
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LIST OF
APPLICABLE
PROCEDURES
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REVISION 0
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March 2, 1982
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Liat of Applicable Procedures
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Page 16
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f MIDI.AND PROJECT QUALITY ASSURANCE DEPARTMENT PROCEDURES,
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B-2M Personnel Training B,3M Qualification and Certification of Inspection and
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i Test Personnel
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E-1M Site Inspection Planning and Site Inspection
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E-2M Review of Site Inspection Planning Prepared by others than MPQA
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F-1M Audit l
F-2M Nonconformance Reporting, Corrective Action and i
S,tatusing
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, F-3M Resolution of Significant Quality Problems
.
F-11M Documentation Control
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F-12M Quality Records
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M-5 QA Review of Bechtel Field-originated Procurement
Documents
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ENGINEERING DEPARTMENT PROCEDURES
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l EDP - 4.37 Design Calculations
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CP - 4.46 Project Drawings i
EDP - 4.47 Drawing Change Notice EDP - 4.49 Project Specifications
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EDP - 4.58 Specifying and Reviewing Supplier Engineering and Quality Verification Documentation l
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l EDP - 4.62 FCR/FCN
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EDP - 4.65 Design Deficiency EDP - 5.16 Supplier Document Control i
EDP - 5.24 Document Distribution control Center
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REVISION 0
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.I.ist of Applicable Procedures March 2, 1982
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Page 17 FIELD PROCEDURES FPG-8.000 FMRs FPD-2.000 Field Change Request / Field Change Notice FPC-4.000 Storage Maintenance / Inspection of Equipment and Materials
.IPG-5.000 Maintenance / Inspection of Material and Equipment Released for Construction
,
FPD-1.000 Field Documentation of Correspondence Control
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l PROJECT SPECIAL PROVISIONS
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I PSP G-1.1 Assignment of Responsibilities, Manual Application
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i and Control PSP G-3.2 Control of Nonconforming Items
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PSP G-5.1 Material Receiving and Storage Control PSP G-6.1 Inspection Planning
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PSP G-7.1 Document, Records and Correspondence Control
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PSP G-8.1 Qualification, Evaluation, Examination Training and
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Certification of Construction Quality Control
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Personnel -
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ENGINEERING DEPARTMENT PROJECT INSTRUCTIONS
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EDPI - 2.14.8 Resident Geotechnical Engineer fo'r M'idland Remedial Underpinning Operation.
EDPI - 4.1.1 Preparation of Design Requirements Verification Checklist.
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EDPI - 4.25.2 Interface Control Design Documents for Remedial Soils
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Underpinning Operation.
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EDPI - 4.47.1 Interim Drawing Change Notice for the Midland Project 7220 EDPI - 4.49.1 Specification Change Notification
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REVISION O
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DESIGN DOCUMENT INTERFACE FLOWCHART
ATTACHMENT 2 TECHNICAL PAOJECT ENGINEEAUIS
!NTEAFACINO
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CONSULTANTS PA0 JECT ADIIIIIISTRATION CWIUSOII.S GAOUP OIIOUPS*
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CALCULATIOBIS
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i QUALITY ASSURANCE PROGRAM POLICY Page z
Revision 11 q
Date 11/18/81
)
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i LIST OF DEFINITIONS
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f Cbd3ERRE PgWK i
Safety-Related - The term applied to:
Structures, systems, components, materials, services or Operational Safety Actions or Activities named on the-Q-List as necessary to assure:
,
The integrity of the reactor coolant pressure boundary.
I
1.
The capability to shut down the reactor and maintain it in a safe condition.
2.
The capability to prevent or mitigate the consequences of an accident which
'
3.
could result in potential off-sita exposures to individuals in excess of exposures specified in 10 CTR 100.
,
The operation of the facility within Technical Specifications limits and Nuclear i
4.
Regulatory Requirements.
Secondary Standard - An item of measuring and test equipment (M&TE) used to cali-They are periodically calibrated using Reference Standards and brate other M&TE.
reserved for use in the calibration of working plant or field M&TE.
l N
Section_ - A subdivision of a department, usually made along lines of a technical specialty; eg, Nuclear Licensing, Health Physics, Nuclear Fuel, etc.
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Serrices - k'ork performed by an organization or department having no deliverabit hardwars type and item other than the results of construction, modifiestions, repairs,
.
inspections, audits, reviews, etc.
,
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Source Tnsnection - Inspection of an ites at a Scpp11er's facility during its
.
manufacture, or at completion of manufactura, to verify implementation of the procure-nant requirements.
Spare Part - An item ave 41mble for replacer,nc for an item in use.
Sbecial Nuclear Material (SNM) -
Plutonium, Uranium 233; uranium enriched in the Isotope 233 or in the Isotope 235; ud any other material which the NRC, pursuant to the provisions of 1.
Section 51 of the Atomic Energy Act of 1954 as amanded, determines to be
-
special nuclear material, but does not include source material; or Any material artificially enriched by any of the foregoing, but does not in-2.
clude source material.
Special Process - Those metallurgical, chemical, or other processes where assurance of the process activity is dependent on the use of qualified procedures, personnel, or equip:nent; and where assurance of quality cannot be by direct inspectio
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in-process activity or final product.
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heat-treating, NDE and environnental testing of the work process.
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MIDLAND 162-FSAR
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regulations, guidelines, or.other factors separate and distinct from the components of the system itself.
The system is
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considered as a unit,.with boundaries as defined by Regulatory
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Guide.1.70 and must meet specific requirements.
The design bases describe all essential characteristics of the system with
sufficient clarity so that an experienced engineer, using these
'
design bases and material referenced in the design bases, can
. understand the functions of the system with respect to the rest of the plant.
Items implicit to contemporary design (e.g., use
,
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of'the English system of weights and measures or the exercise of
good engineering practice) are not specified.
,
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'1.1.2.2.1 safety Design Bases i
'
safety design bases directly establish or l'ncrease nuclear
safety, safety design bases provide for or assure the following:
,
The integrity of the reacter ccolant pressure boundary a.
b.
The capability to shut down the reactor and saintain it in a safe shutdown conditicn '
,
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c.
The capability to prevent or mitigate the consequences l
j of accidents that could result in potential offsite
exposures comparable to the guideline exposures of
,
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d.
The accomplishment of specific structure, system, or (_
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component requirements which are important to safety
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The control room operator action is considered as one of the
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fundamental means of achieving these criteria.
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I safety-related structures, systems, and components important"to
'
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safety are the portions of systems which are indispensable to
nuclear safety.
Items which are associated with safety-related
,
equipment but which do not perform a nuclear safety functicn are
'
not safety-related.
Redundancy requirements and system performance cQnditions are
,
considered a feature of the equipment's capability to shut down
,
!
the reactor safely or to prevent or mitigate accidents.
I n
'
1.1.2.2.2 Power Generation Design Bases l
Power generation design bases are those design bases which are not related to nuclear plant safety.
They need not relate
-
directly to the generation of power; however, they relate at
>
least indirectly to power generaticn in the sense that all
station requirements which are not imposed for safety reasons
-
l support the major function of the station as a whole; i.e.,
the
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RECORD OF TELEPHONE CONVERSATION l
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DATE: _ March 8, 1982, 3:30 pm PROJECT: Midland
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RECORDED BY: Joseph D. Kane CLIENT:
TALKED WITH: Bechtel CPC GEI NRC
,
J. Anderson
'T. Thruvengadam S. Poulos J. Kane M. Das Gu'ta K. Razdan '
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.
i ROUTE TO:
INFORMATION
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G. Lear l
L. Heller vD. Hood
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F. Rinaldi S. Poulos H. Singh R. Landsman
J. Kane
!
MAIN SUBJECT OF CALL: AD0PTED SOIL SPRING STIFFNESSES USED IN DESIGN OF
!
AUXILIARY BUILDING UNDERPINNING AND START OF PHASE 2 l
CONSTRUCTION
'
'
ITEMS DISCUSSED:
l.
Attachments 1 and 2 to this telephone record provide the design cases and
'
!
soil spring stiffnesses adopted by Bechtel as soils input in their structural analysis of the Auxiliary Building. The values of stiffness
,
(
also on Attachment 2 under the column labeled NRC are the results of
'
extensive discussions between NRC Consultants S. Poulos, GEI, H. Singh, COE and J. Kane, NRC and represent the staff and its Consultants.
determination of the range of reasonable stiffness values which should be
,
'
considered in design. The NRC values had taen provided to Bechtel via telephone on March 5,1982 as committed to by the Staff in the meeting of. February 26, 1982 in Bethesda.
'
'
l The NRC recommended value of 70 KCF for the Main Auxiliary Building versus the Applicant's adopted 30 KCF for Case 2 is important because
,
l this difference has the potential to affect settlements which are to be
-
l tolerated during underpinning. Allowable settlements using the l
stiffness of 30 KCF had been provided on February 26, 1982 by l
M. DasGupta of Bechtel Corp.
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Following considerable discussion on NRC recommended stiffness values
(in both March 5 and March 8 telephone calls), Consumers expressed a
willingness to use these values in their structural analysis but indicated the time needed to complete the required computer runs would
'
impact their Phase 2 construction plans. As an alternative, J. Kane
.
.
suggested that Phase 2 work be subdivided into two parts, the initial
.
one beginniag with work which would not affect the EPA and Control Tower area and the second part beginning after the analysis using the NRC recommended stiffness values had been completed by CPC and the results evaluated by the NRC staff. An acceptable line of demarcation
between these two portions of Phase 2 work was tentatively identified as
'
column lines 2.5 and 10.5 on the Construction Sequence drawing provided i
for the underpinning work at the February 3-5 design audit. These lines,
respectively, are sufficiently west and east of the EPA and Control
,
Tower to conclude that these structures would be unaffected by underpinnir
,
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operations permitted by this initial portion of Phase 2 work.
'
f 3.
Consumers agreed to provide a letter to NRC giving details which would
.
pennit the Staff.to fully understand what work would be performed under
,
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.
this initial portion of Phase 2 work.
-
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I 4.
The following coments were given to. Consumers concerning the monitoring
!
plans during underpinning of the Auxi}iary Building.
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Drawing C-1493(Q), " Monitoring Matrix," should be updated and values a.
provided in the tolerance criteria column for staff concurrence befor any portion of Phase 2 work is started.
,
!
b.
Ihtet 8 of H. DasGupta's presentation on February 26, 1982 dees not
,
.i agree with previous drawings provided (Drwgs. C-14:0 (Q) and C-1491 (Q)). Corrections in proper labeling of the deep seated hench mark
'
.
locations on Sheet 8 and on Sheet 10 are r.eeded and should be
.
'
provided to the NRC.
.
.
c.
t:RC expressed h Concerti for measurement Of horizontal' movement betwet n
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the EPA and the Turbine Building and between the Control Tower and ti
Turbine Building during underpinning operations and suggested three monitori7g devices be installed. One device at the top of each wing the EPA's and one at the top of the Control Tower was recomended.
Consumers responded that they were now planning to place instruments at those locations in response to questions raised by ASLB but had nc yet updated the monitoring locations on Drawings C-1490(Q), C-1491(Q:
andC-1493(Q). The Staff indicated that criteria on tolerable relat-horizontal movement for these instruments should be established and -
,
'
furnished on the Monitoring Matrix-drawing along with the ~ basis for
'
these limits.
d.
As previously discussed at the February 26, 1982 meeting in Bethesda the Staff anticipates a submittal by Consumers identifying the
-
acceptance criteria for the strain gages to be placed at E1.659 on
'
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the Auxiliary Building.
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Consumers indicated that the six deep seated bench mark instruments
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located on Sheet 8 of M. DasGupta's presentation will be in operation
-
l before beginning Phase 2 work.
Installation of the additional
.
instruments at top of the EPA's and Control Tower and the strain gages at El 659 and the results of t e structural analysis using NRC h
recommended stiffness valves are to be completed before the second portion of Phase 2 work is started.
-
l 6.
J. Kane indicated that subdivision of Phase 2 underpinning work into two portions is subject to the approval of NRC Project Management
.
l and Structural Engineering Branch.
It was also indicated that other conditions which could affect the start of Phase' 2 work may be identified
'
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by the Staff. The original intent of this telephone conference call was to discuss soil spring stiffnesses but was not intended to address the
-
start of Phase 2 work.
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QUALITY PLAN AND
'
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Q-LISTED ACTIVITIES FOR SPECIFICATION C.194
.
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{
QUALITY PLAN AND Q-LISTED ACTIVITIES 1.0 PURPOSE AND SCOPE
.
.
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The purpose of this QA Plan is to provide the means by which to gain
I
..
_
l adequate confidence that the Service Water Pump Structuca underpinning
system is constructed according to design documents. This Plan describes
~ ~ ' '
the minimum procedural interfacing between the sub-contractor, i
contractor, consultant (s) and the Midland Project Quality Assurance l
'
Department. (MPQAD)
,
2.0 SUBMITTAL, REVIEW AND APPROVAL FOR Q-LISTED PROCEDURES
!
2.1 The procedures listed in Exhibit A will be submitted as a minimum i
by the subcontractor a's specified in the contract documents.
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2.2 The procedures will be routed for review, comment and approval t
i according to the flow diagram in Exhibit B.
+
.
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-
2.3 The groups responsible for review, comment and approval cf
.
procedures.will be sa specified in Exhibit A.
,
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.
3.0 CALIBRATION OF SUBCONTRACT 0R FURNISHED EQUIPMENT
,
-
t 3.1 All subcontractor-furnished jacks, sages, and construction
...,,
equipment requiring calibration will be calibrated by an agency approved and audited by MPQAD.'
..
4.0 QUALITY ACTIVITIES 4.1 ' Section 4.3 provides the Q-List. All Q-Listed hardware and' '
-
l installation will be performed in accordance with the Midland i
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.
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ENCLOSURE 2
QUALIT" PLAN AND
..
,
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Q-LISTEu ACTIVITIES FOR
,
SPECIFICATION C-194
.
!
Project Quality Assurance Program, and will be inspected by the Contractor's Quality Control organization and overinspected by the
'
-
MPQAD. All other Q-Listed activities will also be performed in j
accordance with the Program and will be controlled by the
!
Contractor's QC organization and the MPQAD.
l
.
f l-4.2 Within thirty days prior to the schedoled start of but not limited
!
to the following activities, meetings will be held between responsible personnel of Bechtel Construction Remedial Soils Group,
,
MPQAD, Contractor QC and the Subcontractor. The adequacy and I
availability of technical criteria; Quality Control inspection
plans; Subcontractor's procedures; schedule of Construction i
'
activites; the sequence and clarity of Q-List activities will be
'
i discussed.
.
'
1.
Start excavation below 620'.
.
2.
Start of final load transfer and lockoff.
.
l 4.3 For any work relating to the service water pump structure i
underpinning, the following activities will be Q-Listed. This is
'
.
intended to be a complete Q-List for all activites unique to
'
j underpinning other than design activities. Not all of these
{*
activities, however, will be within the Subcontractor's scope of l
work.
.
I i
l 1.
Document submittal, interface and control.
-
2.,
Procuring Q-Listed itema and materials.
I i
.
.
.
l
.
l 3.
Storage, handling and control of Q-Listed materials.
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ENCI.OSURE 2'.
'*
,
,
s-QUAI,ITY PLAN AND
-.
.
Q-LISTED ACTIVITIES FOR SPECIFICATION C-194
,
4.
Furnishing and installation of lagging and bracing under "Q" structures.
)
.
.
-
5.
Excavation limits, control and sequence under "Q" structures.
I 6.
Crack mapping and evaluation.
,
7.
Calibration, maintenance, control and installation of gages and settlement monitorfag instrumentation.
i
-
8.
Monitoring cf building movement instrumentation and pier
pressure sages.
.
t
.
9.
Fines monitoring of dewatering wells in "Q" areas.
,
10.
Location and protection "Q" utilities.
l 11.
Geotechnical aceptance of rubgrade.
!
l 12.
Fabrication and installation of reinforcing steel.
-
13.
Certification of personnel performing splices.
.
I l
14.
Tareadtrc of, reinforcing steel and installation of mechanical I
~
splices.
15.
Drilling in 'Q" structures for the installation of anchor bolts, rock anchsts and dewatering wells.
16.
Installation and inspection of anchor bolts and rock anchors.
.
- 17.
Compressible material configuration and installation.
.
13.
Testing of reinforcing steel and mechanical,sp' ices.
I
.
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ENCLOSURE 2
'
QUALITY PLAN AND
-
..
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'
Q-LISTED ACTIVITIES FOR SPECIFICATION C-194 I
i 19.
Installation, inspection and testing of structural concrete, i
j lean concrete, grout and drypack.
i
.
,
20.
Repair of concrete in "Q" structures.
I i
21.
Calibrating, maintaining, installing and controlling of I
j hydraulic jacks and pressure sages.
,
,
22.
Load transfer activites.
23.
Backfilling and acceptance testing for access shafts and tunnels in "Q" areas.
.
.
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Procedures To Be Submitted By The Subcontractor Organization Responsible For Proce' dure Review & Approval
-
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Procedure for general underpinning - This procedure
.X
0 X
X
shall include the overall concept of the work
-
involved, including the interface of.all the operations listed below.
Procedure for load transfer.
X
0 X
X
,
Procedure for placement of lean concrete backfill in X
X X
shafts and tunnel.
.
Procedure for installation of (including mixing) and X
X X
'
pressure grouting.
.
I
'
Procedure for placement of pier concrete.
X
X X
,
.
Procedure for acquiring and m.intaining calibration X
X X
of Jacks and gages.
!
'
Procedure for mechanical splicing of reinforcement.
X
X X
Procedure for threading of reinforcing steel.
X
X X
'
Procedure for installation of anchor bolta and rock X
X X
,
anchors.
LEGEND
.
l Procedure for installation of compressible material.
X
X X
REVIEW & APPROVAL - X l
!
'
Procedure for placing reinforcement includ'ng X
X X
REVIEW & CONNENT - 0 i
bending steel reinforcement O.ot and cold),
as applicable l
l
Procedure for core drillfug.
X
X X
-
t
,
.,
ENCLOSURE 2
[
?
'
EXHIBIT A
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-
PAGE 1 OF 2
?
'
.
.
,
_ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _.. _.
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.
.
Procedures To Be submitted By'The Subcontractor Organization Responsible.For Procedure Review & Appr' oval'
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recedure for concrete repairs.
X
X X
_
.
Procedure for excavation "0" structures and the X
0 X
X
,
!..
Installation of lagging.
,
.
'.,
.
.
,
'
Procedure for protection of underground utilities X
X X
,
,.
Procedure for preparing, submitting, and gevising X
X X
_
Q procedures.
'
-
,
{ f'
- ' ' '
Procedure for handling, storing, and controlling X
X X
'
'
Contractor-fernished materials.
.
.
-
Procedure for design document control.
X
0 X
'
-
.,
Procedures for interface and coordinatica X
0
X
'between the Subcontractor and the Contractor
.p
for activities covered by the QA Program.
.
. Procedure for certifying Subcontractor Personnel X
X X
~
specifically for AWS welding and mechanical. splices.
LEGEND
+
Procedure for Training Program of Subcontractor X
X X
t
Personnel for the Q-Prc.cedures covering the REVIEW & APPROVAL - X
~
Subcontractors scope of work REVIEW & COtMENT - 0
-
'
as applicalbe
.
.
.
.
ENCLOSURE 2 EXHIBIT A
-
PAGE 2 OF 2 E I
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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PROCEDUBE REVIEWl APPROVAL FLOWCHART
.
EHCIASURE 2
'.
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- *
EXN48tr 5
.
.
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.
+
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PROJECT INTERFACING FIELD PROJECT ENG8MEEneNG*
GROUPS *
SECHTEL
.
DOCUMENT ADessNISTRATION EDPl 4.25.1 CONSTRUC1cO4 CONIROL EDPEm EDP km
'
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SUSCOIITRACTM AEMEceAL SOILJ FAO 1988 GAOUP REVIEW ANO REVIEW AND
"" *
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COOADeNATION COedesENT(34704 I
LOGS INISTA48 PSI LOGS t.415TAesPSI DISThieUTES AS
,and OC appru e4
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d HECEIVES 04SThesuTES AS SPECIFIED-e
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DitAIINIOSS SPEC 8Fdo j
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INCOAPORATE COefeAENTS
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ASSIGN APPROWAL STATUS
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ENCLOSURE 3 e
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QUALITY PLAN AND
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Q-LISTED ACTIVITES FOR
'
- "
'
.
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SPECIFICATION C-195
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QUALITY PLAN AND Q-LISTED ACTIVITIES
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1.0 PURPOSE AND SCOPE'
,
.
-
,
.
-
.
t
,
l The purpose of. this QA Plan is co provide the means by which to gain adequateconfiNentthattheAuxiliaryBuilding(ElectricalPenetration
.-
,
s.m
,
and control structure) underpinning system and Feedwater Isolation Valve
{
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-
'
,
.yPit fill material replacement is constructed according to design
,
i l
documents. This Plan describes the minimum procedural interfacing
!
between the sub-contractor, contractor, consultant (s) and the Midland s
s
.. - -
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'
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Project Quality Assurance Department.
(MPQAD)
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,
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-
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l 2.0 SUhdITTAL. REVII'W AND APPROVAL FOR Q-LISTED PROCEDURES
,
.;
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t
-
j 2.1 The procedur4s listed in Exhibit A will be submitted as a minimum,
.
~
by the subcontractor as specified in the contract documents.
,
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2.2 ?The procedures will be routed for review, co' ament and approval j
l
-
.
_
i aci:ording tb the flow diagram in Exhibit B.
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2.3 The groups responsible for review comment and approval of r
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-
procedures will be as specified in Exhibit A.
.
.
.
3.0 CALIBRATION OF SUBCONTRACTOR FURNISHED EQUIPMENT 3.1 All subcontractor-furnished-jacks, gages, and construction
'
-
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equipment requiring cal,ibration will be calibrated by an agency
.
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,
.
appesved and: audited.by MPQAD.
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ENCLOSURE 3
,
,
,
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' ' '
QUALITY PLAN AND
-
Q-LISTED ACTIVITES FOR SPECIFICATION C-195
'
4.0 QUALITY ACTIVITIES 4.1 Section 4.3 provides the Q-List. All Q-Listed hardware and
'
,
installation will be performed in accordance with the Midland
,
!
Project Quality Assurance Program, and will be inspected by the Contractor's Quality Control organization and overinspected by the
!
MPQAD. All other Q-Listed activities will also be performed in l
.
i accordance with the Program and will be controlled by the
'
I Contractor's QC organization and the MPQAD.
4.2 Within thirty days prior to the scheduled start of but not limited
to the following activities, meetings will be held between
.
l responsible personnel of Bechtel Construction Remedial Soils Group,
.
MPQAD, Contractor QC and the Subcontractor. The adequacy and
availability of technical criteria; Quality Control inspection plans; Subcontractor's procedures; schedule of construction
!'
activities; the sequence and clarity of Q-List activities will be
,
discussed.
t I
1.
Start construction of temporary underpinning.
2.
Start construction of permanent underpinning wall.
-
3.
Start of final load transfer and lockoff.
l-
.
4.3 Yor any work relating to the auxiliary building underpinning, the i
following activities will be Q-Listed. This is intended to be a
'
i complete Q-List for all activites' unique to underpinning other.than o
' design activities. Not all of these activities, however, will be
,
f within the Subcontractor's scope of work.
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ENCLOSURE 3
,
,
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- ' *
,-
QUALITY PLAN AND
Q-LISTED ACTIVITES FOR i
SPECIFICATION C-195
1.
Document submittal, interface and control.
.
2.
Procuring Q-Listed items and materials.
.
.
3.
Storage, handling and control of Q-Listed materials.
4.
Furnishing and installation of lagging and bracing under "Q"
.
,
structures.
-
.
-
5.
Excavation limits, control and sequence under "Q" structures.
l 6.
Crack mapping and evaluation.
i
.
7.
Calibration, maintenance, control and installation of gages and I
!
.
settlement monitoring instrumentation.
.
.8.
Monitoring of building movement instrumentation and pier
!
-
j pressure gages.
- 9.
Fines monitoring of dewatering wells in "Q" areas.
t
-
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10.
Location and protection "Q" utilities.
t
-
.
11.
Geotechnical acceptance of subgrade.
'
.
,
12.
Fabrication of steel grillage for temporary supports for "Q" l
f structures.
,
i 13.
Fabrications and installation of temporary supports for "Q"
structures.
l I:
l l
,14.
Welding of temporary and permanent supports for,"Q" structures. -
.
I
_
.
.
.
.
,
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15. Fabrication and installation of reinforcing steel.'
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ENCLOSURE 3-
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,
QUALITY PLAN AND
.
l Q-LISTED ACTIVITES FOR SPECIFICATION C-195 i
i 16.
Certification of personnel performing splices.
'
.
17.
Threading of reinforcing steel and installation of mechanical i
.
splices.
-
i 18.
Drilling in "Q" structures for the installation of anchor
!
'
bolts, rock anchors and dewatering wells.
'
19.
Installation and inspection of anchor bolts and rock anchors, i
'
20.
Compressible material configuration and installation.
I
'21 Testing of reinforcing steel and mechanical splices.
.
,
I i
22.
Installation, inspection and testing of structural concrete, lean concrete, grout and drypack.
I 23.
Repair of concrete in "Q" structures.
24.
Calibrating, maintaining, installing and controlling of
-
I
'
hydraulic jacks and pressure sages.
-1 25.
Load transfer activities.
.
26.
Backfilling and acceptance testing for access shafts and tunnels in "Q" areas.
.
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Procedures To Be Subnitted By The Subcontractor
. Organization Responsible For Procedure Review & Approval
.
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Procedure for general underpinning - This procedure X
0 X
X
shall include the overall concept of the work involved, including the' interface of all the operations listed below.-
,'
- j.,
Procedure for load transfer.
X
0 X
X
f~
Procedure for placement of lean concrete backfill in X
X X
.-
shafts and tunnel.
.
,
Procedure for installation o'f' (including mixing)
X
X X
,
j and pressure grouting.
,
i
'
Procedure for placement of pier concrete.
X
X X
4 Procedure for acquiring and maintaining calibration X
X X
-
'
of Jacks and gages.
Procedure for mechanical splicing of reinforcement-X
X X
i
'
Procedure for threading of reinforcing steel.
X
X X
.
'
Procedure'for installation o~f anchor bolts and rock X
X X
,
anchors.
LEGEND
..
,
~!
.
Procedure for installation of compressible meterial.
X
X X
REVIEW &' APPROVAL - X
'.
,
I
.
Procedure for placing reinforcement includisig X
X X
REVIEW & COMMENT - O
bending steel reinforcement (hot and cold)..
as applicable
,
'
Procedure for core drilling.
X
X X
- . -
'
ENCLOSURE 3
'
EXHIBIT A Page 1 0F 2
.
.
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Procedures To Be Submitted B'y The Subcontractor Organization Responsible For Proced'ure Review & Anproval
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A3 Au2A Aa Procedure for concrete repairs.
X
X X
Procedure for excavation "Q" structures and the X
0 X
X
'
installation of lagging.
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Procedure for protection of underground utilities X
,0 X
X f
Procedure. for preparing, submitting, and. revising X
0-X X
Q proceeures.
i Procedure for handling, storing, and controlling X
X X
'
- Contractor-furnished materials.
.
!
Procedure for design document control.
X
0 X
.
Procedures for interface and' coordination X
0
X between the Subcontractor and the Contractor for activities covered by the QA Program.
Procedure for construction of temporary supports
.
-including grillage.
X
X X
Procedure for welding.
-
X
X X
I.ECEND
~
Procedure for ceritifying subcontractor personnel X
X X
REVIEW & APPROVAL - X specifically for Ah": welding and mechanical splices.
REVIEW & COMMENT - 0
,
Procedure for Training Program of subcontractor X
X X
as applicable
"
personnel for the Q-Procedures covering the subcontractor scope of work.
-
ENCLOSURE 3
!
EXHIBIT A l
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Page 2 OF 2 L
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' 2
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PROCEDURE REVIEWlAPPROVAL FLOWCHART
.
ENCIASURE 3
- .
EXNIS8T S'
' ;
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SECNTEL FIELD PROJECT CONSTRUCTION DOCUMENT PROJECT ENGINEERaNQ'
INTERFACING M TRACTOR
.
REMEDIAL SOILS CONTROL ADMINISTflATION EDPI 4.28.1 GROUPS *
GROUP FiO tiet EDP 8.18 EDP S.18
% RECEIVES h
ORIGINATElSUSAAIT
.e LOOS INASTAMPSI LOOS INf9TAMPSI REVIEW AND REVIEW AND
==
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Ofunifl00GS OtSTR45UTES AS
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-4 DISTRISUTES AS COOR0lNATION COMMENT (MPOA PROCEDURES SPECIFIES SPECIFIED sad OC approva4 i
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.
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RESOLVEl'
INCORPORATE
.
COMatENTS
.
,
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ASSIGN APPROWAL
-
STATUS
,
.
.
.
5 IIEVISE Att0 NOTIFY SIC TO
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I-NO H LOG OUT
%M LOG OUT STATUS
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'
t IIESuttelf REVISE AND 1. 2. 3
.
RESUSANT SEFORE
-
.i USE
'
.
,
.
.
-
YES
.
.
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STATUS alWORK MAY
!
CONSTRUCTION PROCEEIA REVISE Q LOG OUT hy LOG OUT
L b-AS INDICATED
.
ACTIVITY Pens-ssna e-
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.
.
STATUS 21 WORK MAY
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PROCEED. SUB8NT e
.
FINAL DOCUMENY
.
COSISTIIUCTION
'
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ACTIVITY PROCEEDS
.
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STATLis llWORK MAY **"
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PROCEED awon
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ifWt 12 FER
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i Docket Nos: 50-329 and 50-330 OM,0L i
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APPLICANT: Consumers Power Company
~
FACILITY:
Midland Plant Units 1 and 2
t
>
SUBJECT:
SUMMARY OF MARCH 10, 1982 MEETING CONCERNING QUALITY
'
ASSURANCE TO BE APPLIED TO REMEDIAL FOUNDATION WORK I
l l
On March 10, 1982, the NRC Staff met in Bethesda, Maryland with Consumers Powe-i Company and Bechtel Power Corporation to discuss the application of quality
'
j assurance to remedial foundation work. Specifically, applicability to work related to underpinning of the electrical penetration areas of the Auxiliary j
i Building and of the Service Water Pump Structure and to construction of the ne
Borated Water Storage Tank foundation ring was discussed. A list of meeting attendees is attached as Enclosure 1.
Enclosure 2 is a compila, tion of the
materials handed out and discussed at this meeting.
,
'
SUMMARY
.
f A draf t of the Quality Plan for Underpinning Activities was submitted for NRC review by Consumers Power * Company letter dated January 7, 1982. During the
. course of its review, the Staff had requested to be provided with a listing of i
items'and activities to which the plan would not apply (i.e., "non-Q"~
,
,
j
activities). The meeting was held to allow the Applicant and his l
Architect-Engineer to discuss in detail the applicability of this plan.
i The Applicant informed the Staff that the, Quality Plan has rec'ently been fina-
lized as MPQP-1. It was transmitted by Bechtel by CPCo (WRBird) letter dated
i March 3, 1982 (see Enclosure 2).
i
!
The Staff noted that the programmatic aspects of the quality plan submitted
.
January 7 appeared to be in full compliance with~ Appendix B of 10CFR50 and ar i~
Issuance of formal acceptance.is awaiting the' discussion of the
.
acceptable.
extent of the program's applicability and specifically the items which it wil not cover. Due to the nature of this work, the Staff's initial consideratioc
,
,
(.
that essentially all construction activities rel'ated to the remedial work she d
j.
fall under this program.
!
CPCo and Bechtel sought to limit full program applicability to those it'eus wt
' '
they considered safety-relat'ed. This term is defined in the accepted CPCo Quality Assurance Topical Report and in section 1.1.2.2.1 of the FSAR (see Enclosure 2).
From a technical design viewpoint, Bechtel proposed the follos
clarifications as the logical application of~these definitions to the remedis
.
'
work:
.
l-1.
. Only. permanent supports / structures. need be Q listed.
l F
!:
,.
2.-
Temporary (i.e.,' construction) supports need not be Q.
.
.
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c* yeeting Sumuqpry
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.u,,,,I *, Midland Plant
.
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i 3.
Support of non-Q structures (e.g., turbine building) is inherently non-Q.
,
. Procedures for man'ipulation of a s/afety structure (e.g., jacking) are Q i
i 4.
when the manipulations produce final input loads. For. example, jacking
,
from a temporary support is non-Q, not because it is not important but because it is not relied on for the safety of the structure following f:.41 load when the health and safety of the public could potentially be at risk.
.
.
.
!
5.
A monitoring program to determine the effect on safety-related structures -
'
i of all work, including temporary (i.e., non-Q) loads will be in place. The
!
monitoring program will be Q.
}'
'
6.
'Non safety-related buildings and supports which can affect safety-related structure are non-Q. However, the evaluation of the effect of such struc-
.
tures on safety structures is Q.
- l
+
}
l
-
7.
Given the above points., the conclusion must be drawn that installation of j.
l temporary underpinning where it will ultimately become a part of the
permanent underpinning (i.e., under.the control tower) is Q.
Temporary
'
support of the electrical penetration areas, not to be a 'part of the final l
support, is non-Q however the evaluation of its effect on the structure is
,
l Q.
i i
j
'CPCo noted that the key point in the above items is.that adverse impact on a I
l t
structure from the temporary work has a potential impact on plant licensability, but not on health and safety. CPCo acknowledged, however, that quality control
,
- on some work which would not be defined as Q in accordance with the above is j
-
desirable considering the nature and extent of this work. CPCo therefore
i proposed a new designation of "QA".
Items and activities so designated would be i
treated by CPCo Bechtel, and their construction contractors exactly as Q items
'
,
i except for reportability to the NRC. A portion of the Auxiliary Building
!
construction sequence drawing designating those piers to be Q and those to be,,QA,,
l was discussed (see Enclosure 2).
.
.
There are'certain activities related to the underpinning work which would fall
'
'
in neither of these c'ategories. An example discussed at some length was excava-
.
tion of the drif t (tunnel) under the turbine building (non-Q). Although final-
,
construction drawings, preparation of which would involve final
'
'
classification, are not complete, the Applicant agreed this work would probably fall into neither category. The Staff noted that failure to properly install
.
the ass,ociated bracing could have an immediate effect on the Auxiliary Building.
The Applicant. contended that the monitoring program for the Auxiliary Building.
.
l.
which is accorded Q status, would detect such an effect.
.
L During the discussion, the Applicant expressed concern that a Q-listing automa-
,
tically required the imposition of numerous difficult requirements which might i.
not relate to the real concern. The Staff disagreed, noting that 10CFR50 Appendix B provides that QA shall be implemented to the extent commensurate with
,
,
I the impact on safety; for example, while it does not matter what implement is
,-
used to remove soil when digging an access shaft, the location, size, and depth-of the shaft are important.
.
.
.
.
.
'"'* 4
.... '.................
........................................
..........................................
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OFFICIAL RECORD COP.Y
-
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.
Following a private caucus, the Staff responded to the applicant's proposals as l
follows:
,
i
~
.j The Staff did not accept the concept of theQA Classification. The Staff considers that all activittes beginning with phase 2 work should be Q
,
,
listed except on very specific items whwich can be shown on a specific
. basis to justify non-Q treatment. NRR concurrence in this justification i
,
.must be obtained prior to conducting any work efforts completely outside i
the quality plan.
~
>
.
j.
The Region will continue the level of involvement of the recent past.
i Every drawing and specification does not require Region III concurrence before use, although they must be completed and available prior to commen-
,
l t
cing the work they cover.
In preparing and approving these documents, individual detailed activities which require or do not require specific QA controls shall be specified in accordance with the quality plan and consi-l dering the flexibility inherent in 10CFR50 Appendix B.
g The. Staff rejects the philosophy of reliance on the' monitoring program as the sole Q protection for safety structures. The process controls which
,
l
'
preclude the attainment of undesirable effects which the monitoring program i
would detect must be subjected to the full rigor of the MPQAD program.
With respect to the items of design philosophy enumerated above, the Staff
disagrees with numbers 1, 2, 3 and 7.
The Staff disagrees with the limita-
!
tion of number 4 to final input loads. The Staff agrees that the
'
!
monitoring program of number 5 must be Q but rejects the concept of this as the sole Q protection for safety-related structures. The Staff disagrees with the aspects of number 6 which classify non safety-related buildings and supports as non-Q but agrees the evaluation of effects must be Q as
'
well as related construction and design work.
It was agreed at the conclusion of the meeting that the applicant must ubmit-a
'
~
letter, prior to beginning phase 2 work, which provides the information agreed
.
to in the March 8, 1982 telephone call with Mr. J. D. Kane of the Staff (see
!
Enclosure 2). The NRC will take specific action on this submittal prior to the
start of phase 2 work.
i i
!
-
L t
Darl S. Hood, Project Manager i
!
Licensing Branch No. 4 Division of Licensing
'
i
.
..
Enclosures:
As Stated I
1.
'
cc:
i.
See Next Page
.
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! adcy 3/ 1 2. /82 3/
..... l E../82 3/
/82,
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