ML20052A740
| ML20052A740 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/12/1982 |
| From: | Hood D Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20052A738 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8204290107 | |
| Download: ML20052A740 (8) | |
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In4R 12 807.
Docket Nos: 50-329 and 50-330 OM,0L APPLICANT: Consumers Power Company FACILITY:
Midland Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF MARCH 10, 1982 MEETING CONCERNING QUALITY ASSURANCE TO BE APPLIED TO REMEDIAL FOUNDATION WORK 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 related to underpinning of the electrical penetration areas of the Auxiliary Building and of the Service Water Pump Structure and to construction of the new Borated Water Storage Tank foundation ring was discussed. A list of meeting attendees is attached as Enclosure 1. is a compilation of the materials handed out and discussed at this meeting.
SUMMARY
A draft 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 items and activities to which the plan would not apply (i.e., "non-Q" activities). The meeting was held to allow the Applicant and his Architect-Engineer to discuss in detail the applicability of this plan.
The Applicant informed the Staff that the Quality Plan has recently been fina-lized as MPQP-1.
It was transmitted by Bechtel by CPCo (WRBird) letter dated March 3, 1982 (see Enclosure 2).
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 are acceptable.
Issuance of formal acceptance is awaiting the discussion of the extent of the program's applicability and specifically the items which it will not cover. Due to the nature of this work, the Staff's initial consideration is that essentially all construction activities related to the remedial work should fall under this program.
CPCo and Bechtel sought to limit full program applicability to those items which they considered safety-related. This term is defined in the accepted CPCo Quality Assurance Topical Report and in section 1.1.2.2.1 of the FSAR (see ).
From a technical design viewpoint, Bechtel proposed the following clarifications as the logical application of these definitions to the remedial work:
1.
Only permanent supports / structures need be Q listed.
2.
Temporary (i.e., construction) supports need not be Q.
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3.
Support of non-Q structures (e.g., turbine building) is inherently non-Q.
Procedures for manipulation of a s/afety structure (e.g., jacking) are Q 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 fuel 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 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.
7.
Given the above points, the conclusion must be drawn that installation of 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 support, is non-Q, however the evaluation of its effect on the structure is Q.
CPCo noted that the key point in the above items is that adverse impact on a 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 desirable considering the nature and extent of this work. CPCo therefore proposed a new designation of "QA".
Items and activities so designated would be treated by CPCo, Bechtel, and their construction contractors exactly as Q items except for reportability to the NRC. A portion of the Auxiliary Building construction sequence drawing designating those piers to be Q and thcse to be QA was discussed (see Enclosure 2).
There are certain activities related to the underpinning work which would fall
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in neither of these categori.s. An example discussed at some length was excava-tion of the drift (tunnel) under the turbine building (non-Q). Although final construction drawings, preparation of which would involve a 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 associated bracing could have an immediate effect on the Auxiliary Building.
The Applicant contended that the monitoring program for the Auxiliary Building, which is accorded Q status, would detect such an effect.
During the discussion, the Applicant expressed concern that a Q-listing automa -
tically required the imposition of numerous difficult requirements which might 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 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.
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Following a private caucus, the Staff responded to the applicant's proposals as follows:
The Staff did not accept the concept of the"QA" Classification. The Staff considers that all activit!es 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 must be obtained prior to conducting any work efforts completely outside the quality plan.
The Region will continue the level of involvement of the recent past.
Every drawing and specification does not require Region 111 concurrence before use, although they must be completed and available prior to commen-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-dering the flexibility inherent in 10CFR50 Appendix B.
The Staff rejects the philosophy of reliance on the monitoring program as 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.
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 submit 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 ).
The NRC will take specific action on this submittal prior to the start of phase 2 work.
ARL Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As Stated cc:
See Next Page
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o MIDLAND f
Mr. J. W. Cook Vice President Consumers Power Cogany i
1945 West Parnall Road Jackson, Michigan 49201 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 Company 212 West Michigan Avenue U.S. Nuclear Regulatory Conunission Jackson, Michigan 49201 Resident Inspectors Office Route 7 4
Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 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 Consuniers Power Cogany l
720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 1
Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen j
Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL) l Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richlpnd, Washington 99352 7910 Woodmont Avenue 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 Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Consnission, Cherry & Flynn Region III Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 l
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Mr. J. W. Cook cc:
Commander, Naval Surf ace Weapons Center ATTN:
P. C. Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Aage, Manager Facility Design Engineering Energy Technology Engineering Center o
P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Ralph S. Decker Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 t
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 1
l Geotechnical Engineers, Inc.
ATTN:
Dr. Steve J. Paulos i
1017 Main Street Winchester, Massachusetts 01890 l
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t 6-ENCLOSURE 1 I
LIST OF ATTENDEES March 10, 1982 NRC Meeting, QA REMEDIAL FOUNDATION WORK
~ 'NRC CPCo.
BECHTEL D. S. Hood J. A.-Mooney A. J. Boos E. G. Adensam R. H. Huston N.
Swanherg R. B; Landsman D. M. Budziki J.
Gilray W. R. Bird R. J. Cook J.
Brunner J. D. Kane
'R.'C.
Hirzel' F.
Rinaldi D. E. Horn 1
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Genere4 OfftAs: 212 West Miehteen Avenue, Jeoksen. Miehlpen 40201 * (017) 788 4800 March 3, 1982 Mr A J Boos Ltchtel Power Corporation PO Box 1000 Ann Arbor, MI h8106 MIDLAND PROJECT -
QUALITY PLAN FOR UNDERPINNING ACTIVITIES FILE:
0.h.9 20.6, 5.17 SERIAL:
1611h 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 now getting its formal release while avaiting the policy document for authorization for us to utilize quality plans on the Midland Project, that in fact the plan has been in effect since early January when the Project Team members agreed to the contents of the plan. This formal release of Revision 0 is changed from what was reviewed anc agreed upon in early Januar'/ as follows:
1.
Words were added to specifically define the MPQAD role in reviewing non-Q documents.
These specific words were reviewed with you on February 19, 1982.
2.
Reference to EDPI h.25.1 was revised to include the new procedure EDPI k.25 2.
3.
EDPI's 2.lk.8 and h.l.1 were added to the list of applicable procedures.
These were referenced in the body or the attachments to the plan.
h.
EDPI h.62.1 was eliminated from the list of applicable procedures as that specific EDPI has been canc.elled.
All elements of this quality plan must be in effect prior to Phase II of the underpinning activities.
L sic:"~TJ C2IGniAT; y
.d U R Bird Cortifici l'7 Manager of Quality Assurance Midland Project WRB/lr
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