ML20069J066

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Testimony of Ja Mooney Re Remedial Soils Work.Discusses Events Up to & Including Major Action Announced in Util ,Implementation of Commitments & Progress Rept on Completed Underpinning Work
ML20069J066
Person / Time
Site: Midland
Issue date: 04/11/1983
From: Mooney J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
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ML20069J056 List:
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ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304130280
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DOCMETED CWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'83 IM 11 P':53 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos. 50-329 OM

) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OL (Midland Plant, Units 1 & 2) ) 50-330 OL TESTIMONY OF JAMES A. MOONEY ON REMEDIAL SOILS WORK I. Introduction and Scope My name is James A. Mooney. I am Executive Manager -

Midland Project Office. I have responsibility for the remedial soils work now being undertaken by the Midland Project. My testimony describes the significant steps the Company is taking in order to successfully complete the remedial soils project. To place these steps in proper perspective, this testimony discusses the events in the soils area leading up to and including the major action announced by the Company in Mr. Cook's September 17, 1982, letter (Serial No. 18845) to Mr. Denton and Mr. Keppler. It further addresses the implemen-tation of the commitments in the September 17, 1982, letter and provides a progress report regarding underpinning work completed thus far.

My experience and background are described in detail in i the resume appended to my testimony (Appendix 1).- The following is a summary:

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I have been Executive Manager - Midland Project Office since August, 1981. Previously I was associated with Alabama Power Company for more than 21 years ard held posi-tions of major responsibility associated with providing generating facilities for that system. Prior to my current position, I was Project Manager for the Parley Nuclear Plant Units 1 and 2. In that position, I directed all activities to insure the successful completion of the facility. Previously, I was responsible for directing the overall system construc-tion services activities including: contracts, budgets, quality control, material services, geologic services, and concrete and soils.

I am a Registered Professional Engineer and a member of Phi Kappa Phi, Tau Beta Pi, and Eta Kappa Nu Honorary Societies.

I received my BEE from Auburn University in 1963 and MSEE from Auburn University in 1970.

II. Background The Consumers Power Ccmpany September 17, 1982, action plan was the result of concern both on the part of Consumers Power Company and on the part of the NRC Staff with the progess and performance of soils remedial work and quality assurance implementation. A number of events in calendar year 1982 brought these concerns to a focus in September, 1982.

In early March, the Company and NRC Staff had a technical difference relating to the appropriate quality requirements for the proposed underpinning work.- On March 30, i 1982, the Company accepted the Staff's position. However, O

certain Staff members felt they had been misled during an earlier phone call. After a formal investigation, the Region determined that no material false statement-had been made, but I believe the incident adversely affected Region III's confidence in the soils work. (Further testimony on this subject appears in the " Testimony of J. A. Mooney and R. M. Wheeler Concerning the Alleged Violation of the April 30 Order and March, 1982, Cable Pulling Incident.")

In April, 1982, the Company met w'ith representatives of NRC Region III to discuss a draft SALP Report critical of soils QA performance for the reported SALP period. The Region stated that soils QA as of the report date was only minimally acceptable.

Additionally, in the Spring of 1982, drilling and excavation problems resulted from inadequate procedures and controls. These specific problems were later resolved by the creation of an excavation permit system, but their occurrence suggested a need for more basic changes. The Board's April 30 Order, which resulted in part from these implementation problems, also indicated this need. In May, the Company, as a result, began a comprehensive review of the soils remedial work. This i

i included an evaluation of the resources committed to the soils project, the QA/QC effort on soils, and needs for improved overall implementation of soils work. The immediate result of this consideration was the July, 1982, decision to consolidate ,

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O soils QA and QC under MPQAD, as described more fully below.

Other steps were also under review.

In August, 1982, the Company stopped all ongoing soils work as a result of an accusation that it had violated the Board's April 30 Order. Although I do not believe the Order was violated, the incident further pointed out that some basic changes were necessary to bring the job up to both our and the Region's expectations. The Company, at that time, entered into a work authorization system with Region III to resolve the specific concern giving rise to the allegation that the Order had been violated.

In a meeting on September 2, 1982, the Company proposed a number of steps in addition to the consolidation of soils QA and QC, to assure the successful implementation of all aspects of the planned soils remedial construction. These measures amounted to a major change in the Compa: y's methodology for carrying out the job. The specific actions were detailed in Mr. Cook's September 17, 1982, letter (Serial No. 18845) to Mr. Denton and Mr. Keppler (Appendix 2) . These revisions and additions to the job implementation plan were the culmination of a number of discussions with the NRC Staff, in-house analysis and consideration of soils remedial work to date.

III. The September 17 Action Items The proposal by the Company and its Action Plan incorporated seven major items:

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(1) Retaining a third party to independently assess the implementation of the auxiliary building underpinning work, (2) Integrating the soils QA and QC functions under the direction of MPQAD, (3) Creating a " Soils" project organization with dedicated employees and single point accountability to accomplish all work covered by the ASLB Order, (4) Establishing new and upgraded training activities, including a special quality indoctrination program, specific training in underpinning activities, and the use of a mock-up test pit for underpinning construc-tion training, (5) Developing a quality improvement program (QIP),

specifically for soils remedial work, (6) Increasing Senior Management involvement in the soils remedial project through weekly, onsite management meetings wherein both work progress and quality activities are reviewed, and (7) Improving systems for tracking of and accounting for

, design commitments.

1 In the following testimony I will discuss the

, details of the seven items included in the September 17 action l

plan.

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1. Independent' Assessment Mr. Cook's September 17, 1982, letter states: "A third party will be retained to independently appraise the initial phases of the construction of the auxiliary building underpinning."

A. Selection of Independent Assessment Team After a review to determine the most acceptable and qualified contractors, the Company decided to retain the firms of Stone & Webster Engineering Corporation (S&W), a highly respected engineering and construction firm, and Parsons, Brinckerhoff, Quade & Douglas (Parsons), an engineering, design, planning and construction management firm-with recognized underpinning expertise, to carry out the assessment. Following the meeting with the NRC on September 2, 1982, in which the Company described its plans, the Company executed the necessary contractual documents, prepared and reviewed implementing plans and procedures, and arranged for the presence of S&W/ Parsons onsite by September 20, 1982.

The independent third-party assessment includes both a review of the scils design documents and construction plans and observation of the construction itself to assure that (1) the design intent is being implemented, (2) that construction is consistent with industry standards, (3) that the Quality Assurance program is being implemented satisfactorily and (4) that construction is being performed in accordance with construction documents.

On September 28, 1982, the Company and the S&W/ Parsons team met with the NRC Region III Staff to discuss communications among S&W/ Parsons, the Company, and NRC, as well as the process

l S&W/ Parsons would use to report assessment results and flndings.

Subsequently, on November 5, 1982, the NRC convened a public meeting to discuss the scope of the assessment, S&W's and Parsons' credentials, and S&W's and Parsons' independence. At this meeting, the Company presented qualifications of all S&W's and Parsons' personnel assigned to the assessment team. On November 15, 1982, the Company transmitted to the NRC information responding to certain questions raised in the November 5, 1982 meeting regarding S&W's independence (Attachment C to the February 24, 1983, Keppler to Cook letter (Appendix 3)) . The NRC made further requests for information on that subject and S&W i

- responded on February 14 and 15, 1983. (Attachments A and B to the February 24, 1983, Keppler to Cook letter (Appendix 3) ) .

B. The S&W/ Parsons Program P

a. Qualifications

, The S&W/ Parsons Team is highly qualified to carry out the independent assessment of the Midland underpinning effort. Stone & Webster is a large, highly experienced and well respected engineering and construction firm with considerable nuclear power plant design and construction experience. S&W has direct experience conducting independent assessments at the Summer and Diable Canyon Nuclear Stations. Parson, brings to the assessment team special experience in the field of soils construction, particularly underpinning. The Parsons firm has extensive experience in foundations, tunnelling, excavation and t

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support of underground caverns and underpinning much of which has been in conjunction with the San Francisco, Washington, Baltimore and Atlanta mass transit systems. The S&W/ Parsons team includes individuals with expertise in quality assurance, design and construction as well as members specifically skilled in underpinning techniques.

The partic'lar u individuals assigned to the S&W/ Parsons assessment team are all highly qualified personnel with impressive credentials and a number of years of soils experience.

The S&W and Parsons Project Managers are experienced in both design and field aspects of soils-related construction, and each has over 20 years experience in soils work and a number of years in management capacities within those fields. At the November 5, 1982, meeting both S&W and rarsons presented credentials of all individuals on the assessment team to the NRC and the public. By letter dated February 24, 1983, the NRC Staff informed Consumers Power that S&W/ Parsons satisfied its criteria for competence.

(See Appendix 3.)

b. Team Independence The assessment team meets the independence criteria established by Commissioner Palladino in his letter.of February 1, 1982 to Congressmen Ottinger and Dingell and implemented in the Company's Specification CC-100 issued September 20, 1982. S&W and Parsons have attested to their .

Corporate independence by information and affidavits supplied to '

the NRC and attached to Mr. Keppler's February 24, 1983, letter

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to Mr. Cook (Attachment A to February 24, 1983, Keppler to Cook  ;

l letter (Appendix 3)). Moreover, at the NRC's request, the members assigned to the assessment team have individually supplied affidavits pertaining to their own independence from Consumers Power company, Bechtel and the Mergentime Corporation.

(Attachment B to February 24, 1983, Keppler to Cook letter (Appendix 3)).

Specifically, neither S&W/ Parsons, nor its personnel assigned to perform the work at-Midland, have had any direct previous involvement with the Midland activities being reviewed by S&W/ Parsons. S&W/ Parsons and its personnel assigned to perform the independent assessment have not been previously hired by Consumers Power Company to perform the design, construction, or quality work relative to the soils remedial program. The personnel assigned to this independent assessment have not been previously employed by Consumers Power Company within the last three years. Further, the S&W/ Parsons personnel assigned to the assessment project do not have household members employed by Consumers Power Company, do not have any relatives employed by 4

Consumers Power in a management capacity, and do not own or control significant amounts of Consumers Power Company stock. In the February 24, 1983, letter (Appendix 3), Mr. Keppler stated that S&W/ Parsons met the independence criteria,

c. Scope of Work j The scope of the assessment is defined in Consumers Power Company Specification CC-100 (Rev. 1) as follows:
a. Development of an assessment program and preparation of a Project Quality Plan.
b. Overview of the design and construction documents to gain familiarity with the work.
c. Evaluation of the adequacy of technical and related administrative construction and quality procedures.
d. Evaluation of the degree of compliance with technical l

and administrative construction and quality procedures.

e. Daily reviews with the Owner and his contractor to obtain any clarifying information and project documents that are needed to carry out this assessment. The owner and the consultant will establish a specific communication plan at the start of the assessment.

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i f. Submittal of any nonconformance reports to the NRC with i

j a copy to the owner.

l g. Submittal of brief weekly progress reports to the NRC a

l with a copy to the Owner.

j h. The final report shall be overviewed by a senior level Consultant management and technical team.

i. The Consultant and its subcontractors shall not be responsible for implementation of corrective action, however, their professional opinion m'ay be requested.
j. In the event the owner desires to expand the scope of work, a written description of said scope revision shall be submitted to the Consultant and shall become effective upon issuance thereof; however, the 1

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l Consultant may reject any such revision by mailing written notice of such rejection to the Owner within 10 l days after receipt of the scope revision.

In accordance with paragraph j of the foregoing, the scope was expanded in my letter of February'24, 1983 (Appendix 4) , to include the following:

(1) Provide a QA overview and assessment of the design work packages to ensure accuracy and adequacy. This overview is to insure conformance to procedural and programmatic requirements.

(2) Provide a QA overview and assessment of the QC inspector requalification and certification program.

(3) Provide a QA overview and assessment of the training conducted for all personnel in the soils remedial work

effort.

(4) Expand the work contract to include an assessment of all underpinning work on safety-related structures on which underpinning work is done while the contract with Stone & Webster Michigan, Inc. is in effect.

S&W/ Parsons independent assessment will cover at a minimum the first three months of the Auxiliary Building underpinning work which has been authorized by the Nuclear Regulatory Commission. The independent assessment program is to continue, however, until the independent assessment team concludes; (1) that the design intent of the remedial construc-tion program is being fully implemented and (2)~the remedial f

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I construction work is consistent with industry standards. The l I

independent assessment will also continue until the assessment i team has assured itself that the Quality Assurance program is j being implemented and the work is being done in accordance with the construction documents,

d. Activities to Date The S&W/ Parsons assessment team was on-site and began the assessment of the auxiliary building underpinning work

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on September 20, 1982. To support the independent assessment, Consumers Power Company has made available such information as design and construction drawings, specifications and procedures, building and pier monitoring data, and construction schedules.

Access to facilities needed by Stone & Webster and its approved i

subcontractors has been provided. By November 5, 1982, Stone &

Webster had reviewed the vertical access shaft, the material storage area, the test facility and off-site batch plant, and the Quality Assurance documents. This fact is summarized in the letter from the NRC dated November 22, 1982, which documented the November 5, 1982, meeting between Consumers Power Company,-the NRC and the public.

By February 11, 1983, Stone & Webster had observed the excavation, placing of reinforcement, and concreting of Pier W-12, and the excavation and placing of reinforcement'for Pier E-12. In addition, the assessment team had reviewed the drawings, procedures and other documents pertaining to the underpinning work and observed performance of the QA and QC organizations during the progress of such work. During this period, the assessment team was on the site and had daily meetings with construction, quality and engineering personnel to obtain information and discuss the assessment team's observations.

4 As of the date of this testimony, the S&W/ Parsons team has not completed their final report in accordance with para-graph h of the Scope of Work, as amended, set forth above.

C. Reporting and Communication The S&W/ Parsons team assigned to the Independent Assessment reports to the Company and to the NRC Staff in several ways. The team holds daily meetings with Company personnel and Bechtel personnel. The NRC Staff has been invited to these meetings. The daily meetings are summarized in the weekly reports which the team issues on the activities covered during that particular week. Each weekly report summarizes the activities which the team has observed, the meetings which they have attended, the quality documents and records which they have reviewed and the observations which they made concerning the work activities.

In addition, when the team observes an item of deviation, for example, between a specification or drawing and the written work procedures, between a specified code and the work procedures, between construction materials and specifica-tions for materials, or from good construction practice, it k

t writes a "Nonconformance Identification Report" (NIR). These NIRs are held open until the Company provides an acceptable i

resolution. '

At the conclusion of the first three months of the .

Auxiliary Building underpinning work, S&W/ Parsons is required to provide a report to the NRC with a copy to Consumers Power.

Prior to submission, senior S&W/ Parsons management are to review 3 t

the contents of the report with the team members for completeness and accuracy. The report will summarize all of the team's observations on the underpinning work and give an overall assessment of the quality of construction.

All documents issued by the team including weekly reports, letters, the final report and NIRs are sent to the NRC and copies are issued to the Company. The purpose of this procedure is to assure that the Company exerts no editorial influence over the contents of documents or oral reports to the NRC.

In addition to these written reports, the S&W/ Parsons team has met privately with the NRC Staff and reviewed the performance of this soils work.

2. Integrating Soils QA/QC Functions Mr Cook's September 17 letter states:

"The project has reorganized the Soils QA/QC effort, creating an integrated organization with sin.gle point quality accountability under the MPQAD. This new organization is expected to improve QC performance, increase CP Co involvement in the management of the -

quality control function and improve QA/QC interfaces."

A major aspect of the incorporation of the Quality i

i Control function within MPQAD is the recertification of Quality Control inspectors to Consumers Power Company procedures. This certification effort involves training and examination in three areas: (1) programmatic quality procedures, including programmatic quality plans, nonconformance procedures, and general quality procedures; (2) inspection plans, including i inspection requirements, inspection methodologies, testing methodologies, hold points, etc; and (3) on the job training, followed by a performance demonstration to assure proficiency, which requires the satisfactory performance of an inspection under the observation of a certified inspector.

The NRC Region III had some concerns with our initial efforts at recertifying QC inspectors, as described in NRC Inspection Report 82-21. After the NRC advised us of its concerns, all Quality Controls inspectors previously certified to evaluate soils work were decertified and have been recertified to MPQAD procedures. Approximately 55 Quality Control inspectors have now been certified in one or more inspection plans. This is adequate to support present construction activities.

3. Soils Project Organization Mr Cook's September 17, 1982, letter states:

"The project organization formed for the perform-ance of the soils remedial work incorporates single-point accountability, dedicated personnel to the extent practical, minimum interfaces - particularly at the working level, and a quality organization-integrating QA-and QC. The soils project organization is tailored to the task at hand. The entire organization, includ-ing quality assurance and quality control are staffed 15 -

i with well qualified, experienced personnel, augmented by design consultants and construction subcontractors nationally recognized in the underpinning field."

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The term single-point accountability refers to the fact that I am in charge of and~ responsible for the~ performance of the soils remedial work, other than MPQAD's work. Subgroups responsible for portions of the work are managed by individuals who report directly_to me. This approach towards responsibility provides uniform direction and direct accountability. Prior to this change, the soils project design, construction 'and various scheduling groups reported to different individuals either within CP Co or within Bechtel. For example, the engineering supervisor in charge of the design elements of the soils project reported through Bechtel's project engineering organization. Similarly, the construction supervisor responsible for soils work reported through Bechtel's construction organization. Under the present approach, both positions now report directly to a Bechtel Assistant Project Manager who in turn reports to me. The scheduling groups have been organized into an integrated group reporting directly to ne.

In addition to the above, the organization structure after Sep'tember 17, 1982 provided for improved and enhanced coordination between' engineering, construction and quality aspects of the underpinning work. The Engineering,. Construction and Quality groups participate in weekly project meetings wherein short-term schedules, objectives and goals are discussed. This e

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Finally, the new organization brings a higher level management presence directly to the Midland jobsite. Under the new organization, a field soils manager controls all construction activities of the Bechtel Field Soils Organization and the soils subcontractors, the Mergentime Corporation and SW&P1 Also onsite is an assistant resident' project engineer responsible for design interface with construction activities. Th? ' quality group is headed by a Soils Superintendent.

4. Training Activities The September 17, 1982 letter states:

" Extensive training programs.for the soils under-pinning work have been developed. This overall train-ing program, which includes the major Construction and Quality organizations involved in soils work, covers both general training in quality and specific training relative to the construction procedures.

The majority of the personnel associated with Remedial Soils work have attended a special Quality Assurance Indoctrination Session. The QA indoctrina-tion has been provided to Bechtel Remedial Soils Group, CP Co Construction, QC, QA, Mergentime and_ Spencer, White and Prentis (SW&P) personnel down to'the craft foreman level. This training consists of one three-hour session covering Federal Nuclear Regula-tions, the NRC, Quality Programs in general and the Remedial Soils Quality Plan in detail.

With regard to the work procedures, a requirement on both Mergentime and SW&P is that specific training on the procedures be provided prior I to initiating any quality related construction i activity. The identification of individuals to receive this training is spelled out in each procedure pertaining to a specific construction activity. )

Completion of the specific training requirements is a  ;

QA hold point which must be satisfied before' work can I proceed. l In further recognition of the importance of l training to the underpinning work, the Company is util- '

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l izing a mock-up test pit as part of its training pro-gram for underpinning construction. The purpose of this test pit is to provide specific training in the construction of a pier, bell and grillage assembly from initial issuance of design drawings through completion of construction. This allows super /isory and craft personnel to perform work under the conditions, requirements and restraints which will be encountered

'when the actual underpinning starts. It also allows the various quality organizations to inspect the work and insure that their concerns and requirements are properly reflected in the procedures."

As initially envisioned, the training program did not require formal documentation of the training material or atten-dance rosters. In reviewing these activities, Region III raised concerns regarding the status of the training program and the I

lack of records documenting who had received the specific train- l ing programs. In response, the project developed a matrix 1 specifying which individuals would receive the various training, by subject, position in the organization and discipline or group. ,

1 On the basis of the matrix, a procedure was developed by MPQAD i

implementing the directions and defining record keeping requirements.

The original training program, and the one carried into the matrix, included instructions on the role of QA and QC, the function of the NRC, QA requirements and procedures (including specifically the QA plans, MPQP-1 and 2) , emergency procedures, and the excavation and work authorization procedures. The training program required that craft personnel attend training in OA and special processes relating to particular tasks. After a review of the training program, Region III requested that the training of craft personnel be expanded to provide a more general

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I l understanding of underpinning technique and awareness of problems which could be encountered. In compliance with Region III's l

l request, Mergentime was requested to implement these changes and responded on February 16, 1983, that the training program was being upgraded accordingly.

A unique element of the training program at Midland involved the use of a mock-up test pit, which was located in a non-Q area of the site. The test pit provided hands-on experi-ence in excavating, lagging, placement of reinforcing steel, and concrete placement. It also provided an opportunity for QA personnel to inspect and docunent the execution of underpinniny activities in advance of the actual work. During mock-up pit l

operations, the project discovered deficiencies in the construc-tion procedures, which were corrected, and also improved certain elements of the underpinning design.

5. Quality Improvement Program (QIP)

The September 17, 1982, letter states:

"The Company is establishing a separate Quality Improvement Program (QIP) for the soils project.

Although not part of the formal Quality Assurance program, the QIP is a management system that should be helpful in communicating and reinforcing project policies and expectations to all project participants.

To launch this effort, an indoctrination program will l be presented to all individuals, stressing the absolutes of Quality and the concept of 'Doing it right i the first time.' Measurements specific to soils will l

! be developed for those critical areas which are j indicative of a ' quality product.' Tracking these l activities will provide an indication of the effectiveness of the program. The QIP will provide I

mechanisms for indivdual ' feedback' from all individ-uals involved, including the craft personnel."

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The Quality Improvement Program Manual developed spec- '

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-l ifically for soils was issued September 24, 1982. Under this l program, supervisors are trained in the principles of the QIP, 1

and are responsible for training the' individuals who work for them. The QIP philosophy emphasizes feedback to improve quality performance. Specific measurements and indications of quality are reported through a mechanism, which is apart from the formal requirements of 10 CFR 50 Appendix B. The QIP approaches quality from the standpoint of individual and group performance. The program also includes provision for recognizing quality perform-ance on the part of individuals who are given awards on the basis of their contributions to improve quality.

6. Senior Management Involvement The September 17, 1982, letter states: "The soils remedial effort also include a high level of senior management involvement." I conduct weekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. Mr. Cook meets onsite with this group an average of once a month and I personally brief Mr. Cook on the progress of soils remedial work at least once a week. In addition, the reporting chains to the senior project personnel have been shortened. The Company's CEO is briefed on a regular basis-and schedules bi-monthly briefings on all aspects of the project including soils. During the bi-monthly briefings, the CEO normally tours the Midland site.
7. Desian Commitments i

To assure that commitments made to the NRC are properly '

accounted for in design documents, CP Co and Bechtel have re-viewed correspondence with the NRC and other documents generated in connection with the NRC's review of the design proposals. From this review, the Project created a computer listing of NRC commitments. This listing is~ updated on a periodic basis.

Copies of it are provided to the NRC.

IV. Status Report on Remedial Soils Work To Date Preparatory work for underpinning the auxiliary building has been completed. This included the installation of underground utility protection, installation and activation of the freeze wall, installation of necessary construction dewater-4 ing, installation of monitoring instrumentation, and installation 1

of east and west access shafts.

I On December 9, 1982, the NRC released the work activities for Piers E/W 12, which are located under the turbine building. Work commenced on Pier W 12 on December 13, 1982.

The soil excavation and lagging installation for the Pier W 12 access pit, a six foot by eight foot pit, commenced at el. 609 and extended down to approximately el. 600. A nine-foot long drift (tunnel) under the turbine building was then begun. A few inches into the drift the excavators encountered a vertical face of concrete. This was removed using a hydraulic rock splitter. When the drift was completed, excavation and lagging of the three foot by six foot pier began. In this process, probe

holes were. advanced to determine if there was evidence of ground water. By January, 22, 1983, the pit in which the pier would be placed had been excavated to its approximate final depth. The i

bottom of the hole was then widened to accommodate the footing of the pier. At that point, reinforcing steel was installed up to about elevation 604. Instrumentation was then installed and concrete was placed on February 11, 1983. The upper and lower leveling plates were then bolted to the turbine building mat and 4

the top of the pier, respectively. The-level bearing assemblies and jackstands were installed and the load transfer was initiated around noon on March 11, 1983. Within 2-1/2 hours, the proof '

test load of 1,375 Kips had been applied. Some two hours later, the proof test load settlement criteria was satisfied (less than

.01 inch for a continuous one hour period) and the load was reduced. On March 14, the acceptance criteria of .01 inch i deflection maximum in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was attained, the wedges between the pier and bottom of the structure were inserted and the pressure in the jacks released.

Installation of Pier E 12, commenced on December 20, 1982, and was carried out in the same sequence as Pier W 12, but lagging Pier W '21 by one week'. The one week lag time was to permit incorporation of " lessons learned". Remaining under-pinning piers will be installed using the same methods as those used for Piers 12.

The NRC authorized the excavation and installation of ,

, Piers E/W 11 and Piers E/W 9 on February 22 and 24, 1983, I 1

respectively. Piers E/W 11 and Piers E/W 9 are located under the turbine building. The drifts to Piers 9 pass under the FIVPs.

The work on Piers 9 has been completed. The work on Piers 11 is presently in progress.

Also during February, the temporary support system for the FIVPs were jacked to insure the total FIVP load was being supported by the system. The temporary support was necessary because the Pier 9 drifts pass beneath the FIVPs. _

During jacking,' a crack in excess of 10 mils developed on the western FIVP at a location where piping was supported. In accordance with procedures agreed upon with the NRC requiring that such cracks be evaluated, an engineering analysis was carried out by one of the Company's consultants, Construction Technology Laboratories. The analysis determined that the structural integrity of the FIVP was not threatened by the crack. A minor crack also developed at a similar location in the eastern FIVP.

This crack was also evaluated and determined not to be structurally significant.

All of this work has been closely monitored by the S&W/ Parsons independent soils assessment team and Region III, which identified no major problems.

As the Manager with direct responsibility for'the remedial soils work, I am pleased with the success of the under-pinning work thus far. I recognize that the complexity of this job will require a continuing forceful management presence to ensure its continued success. I am paying special attention to

- j feedback from the soils section of MPQAD on inspection findings. i To this end, I and other top managers within the soils / group review nonconformance reports issued by MPQAD, as well as the reports of the S&W/ Parsons assessment team. MPQAD has been reviewing nonconformance reports in an effort to. identify and correct potential generic problems. In carrying out this effort, MPQAD recently reported to me that several nonconforming

conditions indicated a problem with the welding for metal lagging to be used in underpinning excavations. With this information, the soils group was able to take prompt corrective action.

As a further measure to enhance communications between the soils project management organization and MPQAD, I have appointed an individual on my Staff to monitor quality indicators and maintain an inclusive list of nonconformances. This list is reviewed and the ten most critical items are brought specifically to management attention at weekly meetings. With these measures and the others described above, I am confident that project management is maintaining proper control over quality aspects of the job.

V. Conclusion 1

The Midland Project has taken a number of steps to improvc the implementation of design, construction and quality assurance requirements in the soils area. These steps have substantially enhanced the performance of the job. I am satis-fled that, with continued agressive implementation of these.

measures and the other programmatic requirements, the soil i -

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remedial work at Midland will be successfully completed and will present no undue risk to the public health and safety.

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RESUME l

JAMES A. MOONEY I

1 Consumers Power Company 1945 W. Parnall Road Jackson, Puchigan 49201 Phone: (517) 788-0774 PERSONAL DATA Date of Birth : March 24,1940- -

Place of Birth: Wilsonville, Alabama (Shelby County)

EDUCATION High School Diploma:

Holtville High School -

Deatsv111e, Alabama June, 1958 Bachelor of Electrical Engineering:

Auburn University ,

Auburn, Alabama June, 1963 i

Master of Science in Electrical Engineering:

Auburn University Auburn, Alabama March, 1971 .

REGISTRATIONS Ragistered Professional Engineer State of Alabama No. 7830 HONORS l-Member of the following Honorary Societies:

Eta Kappa Nu Tau Beta Pi . j Phi Kappa Phi 4

l EITA!1.ED STATEMZhT OF PROFESSIONAL EXPERIENCE l

August, 1981 to Present Executive Manager - Midland Project Of fice; Consumers Power Company; Jackson, Michigan Responsible for directly managing all of the soils related activities.

Relationship and authority for soils QA is limited to project coordina-tion as spec 3' ied by QA program requirements. Additionally, responsible for implementation and overview of the Midland- Project Quality Improvement Program.

January,1977 to August, 1981 Project Manager' - Farley Nuclear Plant; Alabama Power Company; Dothan, Alabama -

Responsible for all construction activities associated with completion and modification of Farley Nuclear Plant Unit, I which achieved initial criticality in August, 1977. Responsible for all functions necessary ,

to insure the successful completion of Farley Nuclear Plant Unit 2 and reported directly to the Project Review Board on all matters relating to scope , schedule, budget and procedures. These functions included but were not limited to; design, construction, quality assurance, licensing, procurement, .,expediting, project planning and cost engineering.

August, 1975 to January, 1977 Manager - Construction Services; Alabama Power Company; Birmingham, Alabama ' .

Responsible for all construction service activities necessary to support the total major project construction effort of the Company which included two (2) nuclear units, five (5) fossil units and three (3) hydro units.

The~se services included the following groups: Contracts , Budgets, Quality Control, Material Services, Geologic Services, Concrete and Soils. Pkjor accomplishments included defining, developing and implementing the " labor Broker" cdncept of construction at a new four (4) unit fossil site.

Phrchi 1973 to August, 1975 Power Plant Material Superintendent; Alabama Power Company; Birmingham, Alabama Responsible for coordinating. delivery of all materials, equipment and drawings required in the construction of Company generating plant '

facilities. Major accomplishments included a redefinition of site-general i office responsibilities to insure a more effective and responsive site organization.

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. . Mar ch , 19 71 to Mar ch , 19 73 .

Assistant to Senior Vice-President; Alabama Power Cc=pany; Birmingham, Alabama )

Work as assigned by Sr. Vice-President, Engineering and Construction, with major responsibilities in connection with construction of Company's I first nuclear steam electric generating plant including participation in licensing procedures, development of construction and start-up r schedules, coordination of engineering, procurement and construction, and involvement in quality assurance activitie's. Also participated in i joint utili ty ef fort to develop a computerized construction management system and studied needs of' Company relative to that system. .

i March, 19 70 to March, 1971 l

Engineering Computer Ap'plications Coordinator; Alabama Power Company; Birmingham, Alabama i

Responsible for coordinating computer related engineering activities within Company and with the Service Company including identifying needs, l developing programs and confirming results. This assignment required participation in industry groups and professional societies.

September,1968 to March,1970 Graduate Assistant; Auburn University, Auburn, Alabank i

Obtained Masters Degree in Electrical Engineering under program sponsored ,

jointly by Alabama Power Company and Auburn University. This program

  • included teaching responsibilities in basic circuits, power system analysis and electrical machinery. Thesis was in area of digital load flow analysis I of power systems.

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February,1967. to September, 1968 ,

t Staff Assistant; Transmission and Distribution; /.labama Power Company; Birmingham, Alabama Conducted special projects as assigned by Vice-President, Transmission

and Distribution, including such items as feasibility study for adapting j Pert Technique for planning and scheduling engineering and construction projects of the Company, preparation and presentation of plant additions ,

and retirements budget for final Company approval and economical analysis '

to determine replacement agd of fleet cars.

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s April, 1966 to February, 1967..

Engine er-in-Char ge ; Livingston Sub-District; Alabama Power Company; Livingsten, Alabama ,

Responsible for all operations in sub-district including engineering and design of extensions and improvements to distribution system, supervision of line const "ction crews, selection and adaptation of distribution hard-ware, handl.ing customer inquiries and complaints, operation'of transmission lines and substations, etc.

October, 1964 to April, 1966 ,

Senior II Engineer; Clanton District; Alabama Power Company; Clanton, Alabama .

Responsible for engineering and designing distribution system extensions and improvements, for operation of system including proper restoration of service following a power outage, and for scheduling and following construc-tion progress of projects to assure that they met required in-service dates.

April,1964 to October,1964 Assistant Alabama to Division Chief Engineer; Alabama Power Company; Montgomery, Made voltage drop calcul/tions for existing distrib tion systems and recommended engineeridg solutions when problems were indicated. Phde flicker calculations for new motors of larger sizes to be added by .

customers and specified starting and running requirements. Instructed ,

operating personnel and construction crews in the proper installation and operation'of underground distribution systems.

June,.1963 to April, 1964 Junior Engineer; Montgomery Distric%; Alabama Power Comp ny; Montgomery, Alabama ,

Engineered and designed distribution systems to serve new and added electrical loads and prepared specifications and cost estimates for these extensions. In this capacity, it was necessary to coordinate

l. the engineering developers and and design other to meet the requirements of contractors, utilities.

, thrch, 1960 to June, 1963

  • Co-op Student; Alabama Power Company; Birmingham, Alabama Assigned to Rural Services Department.

Responsibilities included developing programs and mailing educational presentations to agricultural groups to pro =ote use of electricity on farms in service area.

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?. ug h Vice Pressdent - Projects, Enginerrung

\ %' . j and Construcsson oeneral offices: 1946 West Pernen Road, Jackson, MI 49201 * (5171 788 0453 September 17, 1982 Harold R Denton, Director ,

Office of Nuclear Reactor Regulation ,

t Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 ,

J G Keppler Administrator, Region III US Nuclear Regulatory Commission 799 Roosevelt Road '

Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT ,

MIDLAND DOCKET NOS 50-329, 50-330 QUALITY ASSURANCE PROGRAM IMPLEMENTATION FOR SOILS REMEDIAL WORK FILE: 0485.16 SERIAL: 18845 This letter summarizes recent discussions with NRC management regarding ,

implementation of soils remedial construction and presents the Company's

  • documentation of those discussions.

BACKGROUND The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co. Follow-up discussions with the NRR staff and Region III Inspectors led to the conclusion that the Quality Assurance Program and its definition was adequate; however, there was concern that certain aspects were not being or might not be satisfactorily implemented.

Consumers Power has performed an in-depth review of the implementation plans for the Midland soils work activities. This review included the areas'of design and construction requirements and plans, organization and personnel, project controls and management involvement. The results of this review and the proposed steps to assure the successful implementation of all aspects of the work were discussed with the NRC management in a meeting held in Chicago on September 2, 1982.

oc0982-0232a100-164

.OPETIZ '2

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STEPS TO IMPROVE IMPI.E S*TATION A number of new steps have or are being taken by Consumers Power Co to enhancG the implementation of the quality program with regard to the soils remedial work. These measures touch upon all aspects of the work, from design to postc c'onstruction verification and include,the following:

(1) Retaining a third party to independently assess the implementation of thc-auxiliary building underpinning work; (2) Integrating the soils QA and'QC functions under the direction of*MPQAD; (3) Creating a " Soils" project organization with dedicated employees and single point accountability to accomplish all work covered by the ASLB order; (4) Establishing new and upgraded training activities, including a special quality indoctrination program, specific training in underpinning activities, and the use of a mock-up test pit for underpinning construction training; (5) Developing a quality improvement program (QIP), specifically for soils remedial work; '

(6) Increasing senior management involvement in'the soils remedial project j

through weekly, on-site management meetings wherein both work progress and quality activities are reviewed; (7) Improving systems for tracking of and accounting for design commitments.

What follows is a description of the soils implementation plan, as it will be carried out using the new approaches outlined above, together with other specific aspects which we believe will be criticial to the successful performance of the job. The discussion is limited to the implementation features specific to soils, is divided into areas roughly describing the progression of the job from design to completion and ends with a description of organizations, management involvement and NRC overview.

DESIGN ADEQUACY AND IMPLEMENTATION -

The design for the required remedial activities is in 'an advanced state; design details and adequacy have been reviewed by numerous organizations. A l special ACRS Subcommittee reviewed the soils activities and commented favorably on the thoroughness and*' conservatism of the review and remedial approaches. Numerous submittals to the NRC have been presented to clarify the design intent. It is our understanding.that the Staff is completing its detailed review of all design aspects and is in the process of issuing an SSER. This advanced state of design has permitted the early development of'a thorough planning effort and _ assisted in the organization and development of a detailed training effort. .Following-up on design activities, the Project has assigned to the site a design team co= prised of experienced structural and geotechnical engineers under .the Resident Engineer. This team will monitor oc0982-0232a100-164

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e and review the field implementation as specified in design documents, resolve on a timely basis routine construction questions requiring engineering response and administer the specific contingency plans immediately if any problem should arise during the underpinning work. Additional engineering l resources for the soils work will continue to be located in Ann Arbor.

IMPLEMENTATION OF. DESIGN FEATURES AND COMMITMENTS All soils activities covered by the ASLB Order of April 30, 1982 are covered under soils-specific QA plans. These plans require that appropriate procedures are in place to accomp.lish the work in a quality manner and that -

detailed inspection plans be developed and utilized. Additionally, a Work Authorization Procedure and Work Permit System insure that the NRC and CP Co have specifically authorized and released the work. Under this system, the NRC reviews proposed work details, asks for additional information when necessary and authorizes construction activities in advance. CPCo then authorizes the work to proceed.

To further assure that commitments made to the NRC are properly accounted for ~

in design documents, Consumers Power and Bechtel review the written records of commitments and insure that they are being incorporated into design documents.

The Project is currently undertaking an additional review of past correspondence to create a computer listing of commitments. This computer list will be periodically reviewed to insure that consnitments are incorporated in design or construction documents in a timely fashion..

PERFORMANCE OF PROJECT CONSTRUCTION, QUALITY ASSURANCE AND QUALITY CONTROL ACTIVITIES ,.

To assure that project construction, quality assurance and quality control personnel correctly carry out their appointed tasks, a number of measures have been taken, including a reorganization of quality control, upgraded training programs, direct Company involvement in construction scheduling and control, and utilization of a contract format to minimize any cutting of corners by contractors. These elements of enhanced petrformance are described more specifically below.

First, the project has reorganized the Soils QA-QC effort, creating an integrated organization with single point quality accountability under the MPQAD. This new organization is expected to improve QC performance, increase CPCo involvement in the management of the quality control function and improve QA-QC interfaces.

Second, extensive training programs for the soils underpinning work have been developed. This overall training program, which includes the major Construction and Quality organizations involved in soils work, covers both general training in quality and specific training relative to the construction procedures.

The majority of the personnel associated with Remedial Soils work have

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attended a special Quality Assurance Indoctrination Session. The QA indoctrination has been provided to Bechtel Remedial Soils Group, CPCo oc0982-0232a100-164

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Construction, QC, QA, Mergentime and Spencer, White and Prentis (SW&P) personnel down to the craf,t foreman level. This training consists of one

i three-hour session covering Federal Nuclear Regulations, the NRC, Quality l Programs in general and the Remedial Soils Quality Plan in detail. t With regard to the work procedures, a requirement on both Mergentime and SW&P is that specific training on the procedure's be provided prior to ' initiating i any quality related construction activity. The identification of individuals to receive this training is spelled out in each procedure pertaining to a

- specific construction activity. Completion of the specific training requirements is a QA hold point which must be satisfied before work can ~

proceed.

In further recognition of the importance of training to the underpinning work, the Company is utilizing a mock-up test pit as part of its training program for underpinning construction. The purpose of this test pit is to provide specific training in the construction of a pier, bell and grillage assembly from initial issuance of design drawings through complet- of construction.

' This allows supervisory and craft personnel to perform ws ; under the conditions, requirements and restraints which will be encountered when the actual underpinning star,ts. It also allows the various quality organizations to inspect the work and insure that their concerns and requirements are 4

properly reflected in the procedures. -

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Third, to further enhance the performance of key project or'ganizations, Consumers Power will maintain control over scheduling, both through the constructionand contractors authorization subcontractors. process and by frequent meetings with the involved ,

Each week, underpinning subcontractors will present proposed construction work to the Company. In addition, to assure the best quality work, the major subcontracts were entered into on a time-material basis. This should improve subcontractor attention to detail and acceptance of owner direction in the performance of specific construction activities.

l Last, for the thesoils Company is establishing a separate Quality Improvement Program (QIP) project. Although not part of the formal Quality Assurance program, the QIP is a management system that should be helpful in communicating participants. and reinforcing project policies and expectations to all project To launch this effort, an. indoctrination program will be presented to all individuals, stressing the absolutes of Quality and the concept of "Doing it right the first time." Measureme'ts n specific to soils will be product". developed for those critical areas which are indicative of a " quality Tracking these activities will provide an indication of the effectiveness of the program. The QIP will provide mechanisms for individual ~

" feedback" from all individuals involved, including the craft personnel.

INDEPENDENT ASSESSMENT 4

A third party will be retained to independently appraise the initial phases of the construction of the auxiliary building underpinning. This consultant will be mobilized as soon as possible and, after familiarizing itself with the

' design, will evaluate the aux.iliary building underpinning construction work at i

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the site. If significant problems or adverse trends are observed, the third party assessment program will be extended in both scope and duration until a satisfactory conclusion can be drawn. The initial evaluation will be carried out over a three-month period.

The independent assessment will be conducted by a team of nuclear plant construction and quality assurance experts This team will-be supplemented by the additon of an underpinning consultant who will review the soils design documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consistent with industry standards. The assessment will further assure that .

the QA Program is'being Onplemented satisfactorily and that the construction is being implemented in accordance with the construction documents.

Arrangements are being made with Stone and Webster Engineering Corp to assume the lead role in this appraisal. They will be assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc who will provide underpinning expertise.

The NRC will be' apprised of all findings of this independent assessment in a timely manner.

ORGANIZATION, MANAGEMENT INVOLVEMENT AND NRC OVERVIEW The project organizatiod formed for the performance of the soils remedial work incorporates single point accountability, dedicated personnel to the extent practical, minimum interfaces particularly at the working level, and a quality organization integrating QA and QC. The soils project organization is tailored to the task at hand. The entire organization, including quality assurance and quality control are staffed with well qualified, experienced personnel, augmented by design consultants and construction subcontractors -

nationally recognized in the underpinning field.

The soils remedial effort will also include a high level of senior management involvement. Project senior management will conduct veekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. In addition, the reporting chains to the senior project .

personnel have been shortened. The Company's CEO is briefed on a regular basis and schedules bi-monthly briefings on all aspects of the project including soils. During the bi-monthly briefings, the CEO normally tours the Midland . site.

Complementing the CPCo management role, NRC Region Management overview of the construction process will be enhanced by monthly meetings, agreed upon by the Region, to overview the results of the quality program and the progress. of the soils project.

These meetings will cover any or all aspects of the project of general or special interest to the NRC management.

CONCLUSION Based on the discussion outlined above, CP Co believes that the soils program has been thoroughly and critically evaluat'ed and that all prerequisites for successful implementat. ion have been or are being accomplished. The Company's program, with the initial overview from the independent implementation assessment, and the continuing overview by the NRC staff and management should 1

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provide adequate assurance that the remedial soils activities will be l successfully completed.

JWC/ JAM /bjw CC Atomic Safety and Licensing Appeal Board l

CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harstead Engineering DSHood, NRC (2)

DFJudd, B&W JDKane, NRC FJKelley, Esq -

RBLandsman, NRC Region III WHMarshall .- .

JPMatra, Naval Surface Weapons Center W0tto, Army Corps of Engineers WDPatton, Esq  :

SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers BStamiris i

9 oc0952-0:222100-;6e

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f s' CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 18845 Dated Septe=ber 17, 1982 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the, Commission's Rules and. Regulations. thereunder, Consumers Power Company submits

  • information regarding the implementation of the Consumers Power Company Quality Program for the Midland Plant Soils remedial work.

CONSUMERS POWER COMPANY By /s/ J V Cook J W Cook, Vice President Projects, Engineering .and Construction

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Sworn and subscribed before me this 17th day of Sett 1932 .

/s/ Patricia A Vuffer Notary Public .

Bay County, Michigan My Commission Expires 3 h-86 miC9EE-CC00b100-lea

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  • \* 8 8 :.?. UNITEo ST ATES / [ e. ' *

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NUCLEAR REGULATORY COM.'.'ISSION I ~. REGloN Ill 3 )

799 RCoSEvtLT me Ao

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FE3 2 4 ?J Docket No. 50-329 Docket No. 50-330 Consumers Power Company Am: Mr. James W. Cook Vice President Midland Project '

1945 West Parnali Road ~

Jackson, MI 49201 Gentlemen: '

We have reviewed your proposti to have the Stone and Webster Corporation (S&W) perform the third party independent assess =ent of the soils remedial work activities.

The staff has received sworn statements from the S&W Corporation and i

from the key S&W personnel (Attachments A and B respectively) attesting to corporate and individual, independence. ~

The staff has also reviewed a letter, J. E. Brunner to W. D. Paton, dated November 15,1982 (Attachment C) which describes'the ' contracts undertaken by S&W for the Consumers Power Company and indicates that S&W or its subsidiaries have no holdings of Consumers Power Company .

stocks. The attachments to this letter have been subsequently notarized. **

The staff has considered the qualifications of both the S&W organization and the individuals proposed as team members to conduct the independent review of Consumers Power Company's managenent of the Midland soil project.

Inputs to this. review included the information supplied in the above .

submittals, the staff's existing knowledge of S&W perfornance at other nuclear power plants and information as to S&W personnel competence.

Our evaluation of these documents , revealed that the competence and independence criteria have been met as set forth in Chairman. Palladino's letter to Congressmen Ottinge'r and Dingell of February 1,1982.

Based on our reviews we have determined that the S&W Corporation is an acceptable organhation to perform the third party assessment of ,

the soils remedial work; howevin, the scope of the S&W assessment should -

l be broadened to include the following: l l

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Censu=ers Powar Cc=peny Eii 2 4 7957 (1) Provide a QA overview and assessment of the design verk packaEes to ensure accuracy and adequacy.

I (2) Provide a QA overview and assessment of the QC inspector requalifi-J cation and certification program.

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(3) Provide a QA overvizw and assessment of the training conducted for all personnel in the soils remedial work effort.

(4) Expand the work contract to . include an assessment of all under=; inning

  • work on safety-related structures on which underpinning work is done while your contract with Stone and Webster is in effect.

In addition, the liidland Section has reviewed Consumers Power Company's perfornance regarding the installation of Piers W12 and E12 and has concluded that no major discrepancies were identified during this work (Memorandum, R. Landsman to R. F. Warnick, dated 2/15/83, Attachment D) .

1 Stone and Webster in their letter dated February 14, 1983 (Attachment E) i also indicated that no major performance problems have been identified.

I They have stated that in their opinion additional underpinning work could j be released for construction. .

1 Based on the inclusion of thp previously described contract changes, your perfornance record regarding Piers W12 and E12, and the acceptability.of the Stone and Webster Corporation as the third party independent reviewer, we conclude that underpinning activities of saf ety-related structures may .

proceed. Please submit documentation of the expansion of the third party assessment to include the four areas identified above. The work activities l

vill be authorized in accordance with the approved NILC/CPCo Work Authorization Procedure.

Should you hav'e any questions regarding this letter please contact .

Mr. R. F. Warnick of my staff.

Sincerely,

& {.*-h er W James G. Keppler

. Regional Administrator

Enclosures:

As stated ec w/ enc 1:

See attached distribution list l

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- Anstimars Povar Comprny . -

3.- It:: 24 Oc v/ encl:

O S / Document Control Desk (RIDS)

Resident Inspector, RIII

~he Honorable Charles Bechhoef er, ASL3 he Honorable Jerry Harbour, ASLB

~he Honorable Frederick P. Cowan, ASLB

~he Honorable , Ralph S. Decker, ASLB William Paton , , ELD -

l Michael Miller Ronald Callen, Michigan Public Service Commission .

j Myron M. Cherry -

4 Barbara Stamiris 1 Mary Sinclair Wendell Marshall '

Colonel Steve J. Gadler -(P. E.)

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ATTACHMR;T A 4,

4 Y ~ .; . c r o ::- i STONE & WEBSTER MICHIGAN, INC. 4 ",s.:,(#[j l ,  ; /.. !  : e. . . 4*

j g P.O. Box 2325. Boston. MAssAcHuscTTs C2107 TE ," i i

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! 4 Mr. J. C. Keppler February 14, 1 983 Ad=inis trator, Re gion III U. S. Nuclear Regulatory Canaission J.O. No.14358 799 Roosevelt Road MPS-7 ,

Glen Ellyn, IL 60137 l

RE : DOCKET NO. 50-329-330 )

MIDIAND PIANI - UNITS 1 AND 2 i INEPENENT ASSESSMENI 0F AUXILIARY BUILDING IEERPINNING INDEPENENT OF ASSESSMENT TEAM Cons uners Power Company Spe cification CC-100 originally issued on September 20, 1982, s et s . f orth the criteria for independence for the Ass es s=ent Team. S tone & Webster Michigan, Inc., determined that the i Corporation and the individual members of the Team satisfy the requirements of j the Specification. We have also determined that our subcontrctor, Parsons Brinckerhoff Michigan Inc. seet thes e re quirement s as set forth in a letter signed by Thomas R. Kuessel, Senior Vice President of Parson Brinckerhoff *

! Michigan Inc., dated November 4,1981.

In particular both Corporations satisfy the following criteria:

e The Corporations or individuals assiped to this work do not have any direct previous involvement with Midland activities that they will be reviating.

e The Corporations or idividuals assiped to this work have not been previously hired by the Owner to perf orm design, construction, or quality work relative to the soils remedial program.

The idividuals assiped to this vork have not been previously e

anployed by the owner within the last 3 years.

I e The idividuals assiped to this work do not have present household members employed by the Owner.

l e The idividuals assiped to this work do not have any relatives l employed by the owner in a management capacity, e The Corporations and iMividuals assiped to this work do not con-trol a significant snount of Owner stock.

HM4356 -4 FEB1 5 883 l l

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JGK 2 February 14, 1953 Under separate cover we are sending signed affidavits f or each member of the Assessment T eam . If you have any questions , please contact Mr. A. St=~'ey Luc ka at (617) $89-2067.

P. A. Wild Vice President Sworn and subs cribed to bef ore me on this 14th day of February,1983.

. [
  • N XC. ull'd Notary Public '

1 Suff olk County Massachusetts My Commission Expires November 8,1985.

Catherine Trabucco NGTARY PUB'lC .

For the C:mmanwealtn of U.assachusetts f.:/ Coram;s:,i:n Ex;;tes N v. 8,1985 1

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\2.'\:.) . 1L.i' 1 Q STONE & 'NEBSTER MICHIGAN, INC. h .'.] l P.O. Box 2325. Boston. MAssACHusrTTs C2107 3 1 - .- J ~

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I Mr. J. G. Keppler Tebruary 15, 1983 Administrator, Region III J.O. NO.14358 U.S. Nuclear Regulatory Co-4 ssion YJS-9 799 Roosevelt Road Glen Ellyn, IL 60137 ,

RE: DOCKET NO. 50-329/330 MIDLAND PLANT - UNITS 1 AND 2

INDEPENDENT ASSESSMENT OF AUXILIARY BUILDING 1:NDERPIMENG ASSESSMENT OF WORK ON PIERS W12 AND E12 TEAM MEMBER AFTIDAVITS Enclosed with this letter are signed affidavits for the Stone & Webster and Parsons Brinckerhoff Assessment Team members. .

If you have any questions with respect to these affidavits please call me at (617) 589-2067.

l A.S. Lucks Project Manager ASL:PJC O

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FrP16 933 e

UNITED STATES OF AMIEICA i

NUCLEAR REGULAIORY COMMISSIch l l

l ATOMIC SAIETT AND LICENSO;G BOARD l

In the Matter of '

Docket No. 50-329 OM CONSUMERS Pok'ER COMPANT , 50-330 OM (Midland Plant, Units 1 and 2 Docket No. 50-329 OL 50-330 OL February 14, 1983 -

l AFFIDAVIT OF

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i My name is A.S. Lucks . I an employed by Stone & Webster Engineering l Corporation as Proieet Manseer .

i I am currently assigned to the team which is conducting an independent assessment of soils work at the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project, or.any job or task for or en behalf of Consumers Power l Co=pany, Bechtel, or the Mergentime Company relating to soils of underpinning.

I have never been employ,ed by Consumers Power Company,, Bechtel, or Mergentime Company. I do not own any shares of Consumers Power Company, Bechtel, or Mergentime stock. Mutual funds or other funds in which I may have a j

beneficial interest, but over which I have no control, may own shares of -

Consumers Power Company, Bechtel, or Mergentime stock, of which I am. unaware!

A list of such funds in which I have an interest are attached. I have no

  • relatives which are or have been employed by Consumers Power Company, Bechtel, l

or Mergentime Company.

Sworn and Subscribed Before Me This .14th Day of February 1983 4tR (

~ Al2 W Notary Public Suffolk County, Massachusetts My Comnission Expires November 8.1985 l

Catherine Trabucco .

  • NOTARY PUBLIC For the Commomysalth of Massachusetts My Commission Expres Nov. 8,1985 e

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UNITID STATIS OF A." RICA NUCLEAR REGULATORY C010CSSION AIOMIC SATITT AND LICINSING BOAc In the Matter of _

Docket No. 50-329 OM CONSUMERS POWER COMPAW . 50-330 OM (Midland Plant, Units 1 and 2 Docket No. 50-329 OL 50-330 OL Tebruary 14, 1983 ATTIDAVIT OF [ . E- W.

My name is W.E. 1tilker . I am employed by Stone T Webster Engineering Corporation as Proiect Engineer .

I am currently assigned to the team which is conducting an independen't assessment of soils work at the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project', or any job or task for or on behalf o,f Consumers Power Company, Bechtel, or the Mergentime Company relating to soils of underpinning.

I have never been employed by Consumers Power Co=pany, .Bechtel, or Mergentime Company. I do not own any shares of Consumers Power Company, Bechtel, or Margentime stock. Mutual funds or other funds in which I.may have a beneficial interest, but over which I have no control, may own shares of ,

Const mers Power Company, Bechtel, or Mergentime stock,' c:! which I am unaware.

A lic c of such funds in which I have an interest are attached. I have no relatives which are or have been employed by Consumers Power Company, Bechtel, or Mergentime Company.

Sworn and Subscribed Before Me This 14th Day of Febn.ary 1983

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Notary Public ,

Suffolk County, Massachusetts My Commission Irpires November 8,1985 Catherine TrabucCo NOTARY PUBLIC For the Commonwealth of Massachusetts My Commission bpires Nov. 8,1985 J

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i-UNITED STATES OT AMT.AICA.

NUCLEAR REGULATORY COMMISSION ATOMIC SAITTT AND LICENSING BOARD In the Matter of ,, Docket No 50-329 05 CONSL".ERS PokIR COMPANT f0-330 05 (Midland Plant, Units 1 and 2) Docket No 50-329 OL 50-330 QL February 11, 1983 AFFIDAVIT OT'

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My name is k vt f s/?ppW . I se employed by s7scr yturnsrrt 44,~ixn-s wCf '

as e fromMm. Mswea '

I am currently assigned to the team which is conducting an independent

~

assessment of soils work at' the Midland Nuclear Plant site. Prior to being given this assignment, I have never worken' on any job or task associated with

~

the Midland Project, or any ~ job or task for or on behalf of Consumers Power Company, Bechtel, or the Mergentime company relating to s, oils or underpinning.

I have never beer employed by Consumers Power Company, Bechtel, or Mergentine Company. I'do not own any shares of Consumers Power Company, Bechtel, or Mergentime stock. Manual fcnds er other funds in which I may have a -

beneficial interest, but ever whie.h I have no control, say.own shares of

  • Consuegra Power Company, Bechtel, or Mergentine stock, of. which I an unaware.

A list of such funds in which I have an interest are attached. 'I have no relatives which are or have been employed by Consumers Poker'Compay, Bechtel, or Mergentine Company. ,

Sworn and Subscribed Before Me Thia // Day'of 2

  1. 71 uL n 1J

( Notary Ps lic p# .

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n; County Michigan My Coemission Expires A -//-[b 4

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11NITED STATES OF A'. ERICA NUCLEAR REGULATORT COTf1SSION i

ATOMIC SATETT AND LICENSINO LCARD In the Matter of ~ Docket No 50-329 OM CONSt22RS PokTR COMPANT 50-330 QM (Midland Plant, Units 1 and 2) Docket No 50-329 OL 50-330 OL Tebruary 11, 1983 A.TTIDAVIT CT My name is a n. seert . I an employed by ste'r.e & k'ebster

~

as r-p .... .

I am currently assigned to the team which is conducting an independent

~ assessment of soils work at' the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project, or any job or task for or on behalf of Consumers Power Company, Bechtel, or the Mergentime Company relating to soils or underpinning.

I have never been employed by Consumern Power Company, 3sicsstlfer Mergentine Campany. I do not own any shares of Consunars Power Company, Bechtel, or Mergentine stock. Mutual funds or other funds in which I may have a beneficial interest, but over which I have no control, may own shares of

  • Consumers Power Company, Bechtel, or Mergentine stock, of which I an unaware.

A list of such funds in which I have an interest are attach 2d. I have no

' relatives which are or have been employed by Consumers Power Company, Bechtel, or Mergentime Company.

Sworn and Subscribed Before Me This / /4 hay ofd./

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nb /

Notary Public #f/

i J. . County, Michigan My Commission Expires R - 4/' [ /.e .

I was employed by Bechtel Corporation from March 1951 to July 1968 and from June 1972 to September 1976. g ,

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! tNITID STATES OF AMERICA

NUCLEAR REGULATORY Co.TiISSION J

! ATOMIC SATITY AND LICINSING BOARD i

In the Matter of , Do.ket No 50-329 ON j CONSL'.ERS POWER COMPANT 50-330 Ott (Midland Plant, Units 1 and 2) Docket No 50-329 OL 50-330 QL 4

Februa:7 11, 1983 l

~

ATTIDAVIT OF M a w o > ((ch1.,

My name is tw...e. T. hu.n I an employed by Stone and Webster Enge:' Cere.

as s.-4-- n..$ 4 v n.......... Engineer.

I as currently assigned to the team which is conducting an independent assessment of soils work at the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project, or any. job or task for or on behalf of Consumers Power Company, Bechtel, or the Bergentime Company relaiting to soils or underp4=adas..

I have never been employed by Consumers Power Company, Berhtel, or Mergentime Company. ,I do not own any shares of Consumers Power company, Bechtel, or Mergentine stock. Mutual funds or other funds in which I may have a .

beneficial interest, but over which I have no control, may own shares of .

Consumers Power Company, Bechtel, or Bergentine stock, of which I an unaware.

A list of such funds in which I have an interest are attached. I have no

,' relatives whi6 are or have been employed by Consumers Power Company, Bechtel, or Mergentime Company.

Sworn and Subs ribed Before Me This // ayofh aLL0 Notary Public &v su 9---- County, Michigan My Commission Ezy s 2 - 4 / - [dp l

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7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-329 OM COMSUMERS POVER COMPANY 50-330 OM (Midland Plant, Units 1 and 2) Docket No. 50,329 OL 50-330 OL .

February 11, 1983 AFFIDAVIT OF kY My name is Barr . Helsinger.106m employed by Stone & Webster as 0.A Enginet'r .

l am currently assigned to the team which is conducting an independent assessment of soils work at the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project, or any job or task for or on behalf of Consumers Power Company, Bechtel, or the Mergentime Company relating to soils or underpinning.

I have never been employed by Consumers Power Company, Bechtel, or Mergentime Company. I do not own any shares of Consumers Power Company, Bechtel, or ,

Mergentime stock. Mutual funds or other funds in which I may have a beneficial interest, but over which I have no control, may own shares of Consumers Power Company, Bechtel, or Mergentime stock, of which I am unaware.

A list of such funds in which I have an interest are attached. I have no relatives which are or have been employed by Consumers Power Company, Bechtel, or Mergentime Company.

O f d Sworn and Subscribed Before Me This uNDay of hc , n s o, 1983 Xa9 <: <, 9, .' A_CG Notary Public NANCY S. NOSLI

,,,,,,, p . .ea=- v.* 3 w woscm n2nme i=. - ==* 88. Fli 4 My ConnissIon Explres =c

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UNITED ST.AIT.5 0F AERICA EUCI. EAR REGL"ECKI Cot %ISSION M

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j ATot1IC SATETT AND LICINSING BOARD i

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i In the Matter of . Dockat No 50-329 Cai gI 50-330 ott

-t cogs M1tM POWER Cat!PArr o (Midland Plant, Units 1 and 2) Dockat No 50-319 CL 50-330 QL Tabruary 11 ISt.3 a

I ATTIDAVIT or / ,

v My name is Thomas R. Kuesel . I an employed by Parsons Brinckerhoff Ouade &

as Senior nce Presicent . Douglas, Inc.

I as currently assigned to the team which is condmeti=g an independant arsessment of soils work at the Midland Nuclear Plaat sita. Prise ta be.ing l

given this assignment, I have never worked on any job or task associated with

- the Midland Project, or any job or task for or on behalf of Consumers Power

v =y, Rechtal, or the Bergentime CT y relating to soils or nadarpianing.:

- I have never been employed by consumers Power fv=y, Bechteli or Mergentime ,

'Capany. I do not own any shares of Consus.tes Power Em-y, Bechtal, or Bergentime stock. Mataal funds or other funds in which I may have a beneficial interest, but over which I have no control, may own shares of

, Consumers Power company, Bechtal.. or Herrentime stock, of which I am unaware, l

A list of such funds in which I have an interest are attached. I have na relativas which are or have been employed by Consumers Power fmy, Bechtel, or Mergentime Company. .

. J9FA l Swcru and subscribed Before Me This / 4 D)/ of /45 ptf he4

'0 . ia I t:oT;Jn r--

" *,:~f".'v, ammission Expires * ,

.; ",}'g CC W.4.J I' ' ' * * * '"'

  • From 1963 to 1967 I was employed by Parsons Brinckerhoff-Tudor-Bechtel, General Engineering Consultants for design and construction management of the San Francisco Bay Area Rapid Transit System, in the capacity of Assistant Manager of Engineering.

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! Hj MITID ST.ATES 07 AMER.ICA f

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NUCLEAR RT.GUIATORI C M SSION Is .

AToti1C EATETT AND LICESING BOARD l

N E ,.

In the Batter of Docket No 50-329 ott m .

50-330 02!

i 9' CONsmrM POWER CCRfPANY Dockat No 50-329 CL i [d (Eidland Plant, Units 1 and 2)

' 50-33,0 CL

~,ne r  : . .

1 February 11, 1983 ATTIDAVIT or  % 'W My name is Louis G. _Silano I an employed by Parsons Brinckerhoff Onade &

as Ta r 5, 4 - = 1 n i -. -- .

oc ug;.as , Inc.

i . Major Structures .

l I an entrently assigned to the taan which is condneting an independant assessment of soils work at'the Eidland Nuclear Plant sita. Prior ta being given this masignment I have never worked on any job or task associ.ited with -

. the Eidland Project, or any job or task for or on hah =tf of Consumers Power l W=_-y, Bechtel, or the Margentime em y relating e ta oeils or underpinning.

. I have never been employed by Censume.rs Power r__-_y, Bechtal, or Mergentime j Company. I do not own any shares of Consumars Power Campany, Bechtal, or i 5ersentime stock. !!staal funds or othar funds in which I may have a ,

l beneficial interest, but ever which I have no control, may own shares of 4 Consumers Power Company, Bechtal, or Herrentime stock, of.which I am uns==re, .

A list of inch funds in which I have as interest are attached. I have no i

l relatives which are or ksve been employed by Consume.rs Power Company, Rechtel,

or Bergentime Company. - .

19 f)

] Sworn and' Subscribed Before Me This A D&y of [*e Mar LA D Notasy Public 9-h er N-- r , "i1..

rF ?. O. c-'o "U .7."M.' ' ' S

!!y Commission Ezpires 8,h ; t..s. J e 3 8... .

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l WIIID STATES OT. AERICA NUCLEAR REGUIATOR? CO.?.ISSION l ATOMIC SAIITT AND LICENSING BOARD In the Matter of ,

Docket No 50-329 05 l CONSUMERS PofnTR COMPANT 50-330 oH I (Midland Plant, Units 1 and 2) Docket No 50-329 OL  !

50-330 QL  !

February 11, 1983' -

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i AFFIDAVIT OF // -

,m,

, _ f My name is W [ PA/2x/ . I an employed by fe.rons Sme./tde// Q.,,er/t '

S&

as Likso 4 a-w . ~'

l

- .- l I as currently assigned to the team which is conducting an independent i assessment of soils work at the Midland Nuclear Plant site. Prior to being l

~

given this assignment, I have never worked on any job or task associated with  !

the Midland Project, or any job or task for or an behalf of Consumers Power .  ;

Company, Bechtel, or the Mergentime Company relating to soils or underpinning.  ;

I have never been employed by Consumers Power Company, Rechtel, or Mergentime i Company. I do not own any shares of Consumers Power Company, Bechtel, or [

i Mergentine stock. Mutual funds or other funds in which I may have a , j beneficial interest, but over which I have no control, may own shares of .  !

Consumers Power Company, Bechtel, or Mergentine stock, of which I as unaware.  !

A list of such funds in which I have an interest are attached. I have no  ;

relatives which are or have been employed by Consumers Power Company, Bechtel, .

or Mergentime Company.

Sworn and Subscr ed Before Me This[/ Day a i

Notary.Public &v i 1 "::: County, Michigan  ;

My Commission s 8- @ [d ,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY Co.SISSION i

ATOMIC SATETT AND LICENSING BOARD In the Matter of. .

- Docket No 50-329 05 CONSUMERS P0hT.R COMPANT 50-330 OM (Midland Plant, Units 1 and 2) Docket No 50-329 OL 50-330 QL February 11, 1983 AITIDAVIT OF //

My name is Jerrold Ratner'.

/

I an employed by Parsens Brinckerhoff. Quade and Douglas as Famacer. Corstruction .

I am currently assigned to the team which is conducting an independent assessment of soils work at' the Midland Nuclear Plant site. Prior to being given this assignment, I have never worked on any job or task associated with the Midland Project, or any job or task for or on behalf of Consumers Power Company, Bechtel, or the Mergentime Company relating to. soils or underpinning.

I have never been employed by Consumers Power Company, Bechtel, or Mergentime Company. I do not own any shares of Consuadrs Power Company, Bechtal, or Mergentime stock. Mutual funds or other funds in which I may have a .

beneficial interest, but over which I have no control, may own shares of Consumers Power Company, Bechtel, or Mergentime stock, of which I an unaware.

A list of such funds in which I have an interest are attached. I have no relatives which are or have been employed by consumers Power company, Bechtel, or Mergentime Company.

Sworn and Subs ribed Before Me This /Mb-Day of d a.

Notary Public Em " "

h County, Michigan My Constission Empires Y 3 W-[0 .

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tNIIID KIAIES OF AMCA FOCII.AR REGUIAICKI CCt2CISSION

  • j ATotiIC SAITIT AND LICIESING BOARD t

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In the Eatter'of .

Dociet No 50-329 C21

  • i CcXs's PO4'ER Cot PAYI 50-330 oti j (Hidland Plant, Units 1 and 2) Docks: No 50-329 OL i

j .

50-330 OL .

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  • February 11, 1983 1

ArrIwIt or F e.JMtah .

.. k I

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.j gy ga (Fincent J. Madi).lI as employed by Parson.s Brinckerhoff Cuade (,  !

' 4 as Sea 4 m- t'* g4 m m . , . uGu94a5a ADC.

3 I an encrently assigned to the team which is conducting an indep- d--t i
  • assessment of soils work at* the Midland Nuclear Plant site. Prior to being

} rive this assignment, I have never worked on any job or task associated with j -

the Eid. Land Project, or any job or task for or en behalf of Consumers Power

  • WW, Bechtel, or the Bergentime C7 y relating to soils or underpia=ing.

I have never been employed by consumers Powe.r Company, Rechtel, or Bergentime

$

  • Company. I do not own any shares of Consumars Power Compa=r, Bechtel, or ~

i- Mergentime stock. Mn.tnal funds or other funds in which I may have a '

'{ .I

  • beneficial interest, but ever which I have no control, may own shares of consumers Power cm=7, Bechtel.. or Mergenti,me. stock, .of.which I am. unaware, . .. . . .

(- A list of such funds in which I have an interest are a:tached. I have no j relatives which are or have been employed by Consumers Power Ovy, Bechtel, -

j or Bergentime Company. . .

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Suorn and subscribed Befort He This /4 Dly of /*4 .19tr'

/ Notary' Public

{ h&-- t 4, Ms g My Qgr.ission Expires . r - r -- o -

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ATTACE. INT C

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ss oan 3- 4ma mBe D o.6e General omses. 212 West Mien 6emse As it.e. Jesseen. hel 482c1 e (517) 788. oslo '*=*""**

November 15. 1982 2."b"'"

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William D Paton f. .) ..b' -

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Counsel for the NRC Staff ly. .

a 1 U S Nuclear Regulatory Commission Washington, DC 20555 Mp-

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t~l 1 Eg i i i MIDI.AND NUCLEAR COGENIRATION PI. ANT

] f ,; ; h p q MIDI.AND DOCL*2.'.T NOS 50-329, 50-330 STONE & WEBSTER (S&W)

Recently, questions have been raised concerning the use of the Stone and Webster Company (S&W) to conduct an appraisal of underpinning of the Midland auxiliary building. A public meeting regarding these, issues, among others,

,was conducted in Washingtet on , November 5,1982.

During that neeting, representatives of the NRC Staff asked certain questions ,

touching upon the independence of the Stone and Webster Company. To respond 6 more fully to these questions, Consumers asked Stone & Webster to describe jobs undertaken by S&W on behalf of Consumers Power Company and to determine S&W's holdings of Consumers' securities. The attached letter is S&W's response to those questions.

According tu the attached letter, Stone & Webster has carried out, and is

  • carrying out, no work for Consumers Pov,er Company in relation to the soils  !

remedial project, other than the present audit. S&W has undertaken two i relatively limited assignments not related .to soils on behalf of the Midland  :

Proj ect. The letter =1se indicated. that Stsna & Webster's, or its s.absidiaries have no holdings of Consumers Power Company stocks. ]

, j

' 7"*4 ames E Brunner O i

CC DSHood, NRC l Billie Gardie  !

CM/C* Service I.ist I

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FDR ADOCK C5000329 A PDR .. . .

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?:-s=c J N ' 4, Isq A= c=e7 Ge=esi cf the-At=ie Safe:7 & **:- d r -

Appeal Pssel l

Sta=a:cf Mi % s=. O S Ju=le e Reg:'.z:_ s C==

i Carele St**-'eg, Esq, 7= 'd 5 D C 20535 Assista=. At ==e7 Ge=ersi .

? u - .a1 ?:: ecti:n Div . Mr C 1 Stephe=s 720 Iair 3*d r, -

Chief, -hi=g k se Tices.

Ic.si=g., MI kO913 7 5 3uclear Regula: .r C==n.

C*_.'.=e cf the Sec=sta:7

.h X Char:7, Esq, ' 7==*d 5:=r, D C 20555 Q:e 3 T a== . '

Suita k!C: Ms Mary "-*' d-Nd age, O 6C611.

57"1 Swaes. Street

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  • g ger.w.** y' e' =* ; E kafac Z?D.10 Pd'had,.Mr.h&6ho . 7'"' -- D Ps:ca, Esq .

. C=u=sel' f=r the 32C Staff Charles. 3e "aefer,. Esq

  • U S I= clear Regr.'a =ry C==n.

7= 'd--tc= ,D C 20555

,t==1= Safety & Lic- d r 3ca=1 Pa=m1 ,

A:2 Saf ecy & * * --*d r IT S Ive'em- Seg=Ia=c=7 Cast 7=-*d 9 c=,.D C 20555 -

3 carl Ps=e1

- ~t S 2ncies: 2es 1s:c=7 C==

7= S c=, D C'20555 Dr Frederich. ? Cavu=. .. - -

, 6152. I 7erde. 2:s'.1 , .

3arbars..Sta=1ris '

A:; 3-127 3cca: Esrc=,. ?L 33h33 m3 Ic=th 31rur 3 cad. .

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?reela=&, E kS623 .

Jerry Zarbeur At- d- Safety & lice =si=.g Carre;l'I Mahaser 3c' erd Pa=e1

' U S' 3uclear P.eg=1a=..s C=mm 3abeoek & 711ec= -

70 3az 1260 7= - :ce: D C 20575 L7-*s g,r Y'.rgd=is 24505 .

Lee L 31shcp

  • James Z 1 m.er,.Esq Ea==z=r & Weiss C;s.-. Pcver ? .,

1"25 7 Street,37 #5C6 7--*' Sc=, DC 20006 2"2 West Mir' d na Avuus Jacksc=, E h92C1 M ! Millar, Esq

, *shan, L1==cl= & 3eale Mr D 7 Judd .

3abecek.& Wilecz.

  • rte.Dette=si ?la:a PC 3ez 1260 52=d Floce tr '$arg, 7A 2ksof Chicago, = 606c3 Steve Gadler, Esq. Jeh= Demeester, Isq Ocv Che=1:s1 311g 2*20 Ca .c Ave =ue- Michign= 01:is1==

St Paul, .'Ci 55;CS M'.ilt.=d, X" EsfaC l

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  • E *:E'en: 9-11-62: 3:29pm  ; - g;mh-- .:;o 2 1
  • I STONE & WEBSTER MICHIG AN. INC.

P.c. nex 2325. sestoev. MassaouscT s 02t c7 l

l i

Nove_ber 9, 1882 Mr. John R Schaub .

Project Xanager Censumers Fower Cc=pany' 194$ W. Parnall Road b ek=aa. Michigan 49201

Dear Mr. Schaub:

Per your requcit to Mr. Carl 7. Sundstrom I a= teclosiis a list and description of john that Stone & Vebster .*ichigan Inc.,has undertakes

.for Consumers Power C = pan!r (CPCo).. I an also prtwiding' the 'results of my investigation of our holding 1r-in C7Co securf fiss.

If ve can be of further anaistanca. pisane call Mr. Carl T. .

Sundstros at (617) 389-2780.

  • Very truly yours.

N '.

/

P. A. Vild

. Tica'PrenJdant e

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j j Sesrt Date t-d Sate hvic! 3es.rtveien 'n e ?'ra n.

1 l 3/78 12/81 Reviev .=.idland Plant lint of c:;uf:=ent sei R0evitt i recoormand spara parts. RMontross

! CSleigh

~

,i

! 6/78 6/80 Frepare an outat,a critique report on the KSpencer 1 Palisadma Station second out:ge and provide I planninC suPPor: f or the Septcher,1979 re- '

l fueling outage.

i -

I 11/78 6/20 Precure a =ob!2a security access module to K5 peter be used for outage vari forces at Palisades.

t 3/82 7/82 Ivaluate and enke recr=endat hm for tisin- RDoene i

ing and :=picentation of the Midland Site SRovall,

.; Imergency Plan.

  • k'Beckman

~

l 9/82 -

Peric= an independent asses == t of con- JCook struction activities reisted .to the auxj21- * .oeney ary building and feedvater bolation valve JSchaub Pit r eedial.scrk at the.4td2and Site.

! 10/82 -

Previde eerscry plan:ing eunnulting as.rvi:es RSinde=enn .

for the lia Rock Site. kHille .,

}

1 J 10/82 - Ferder. . vibratien analysis on the boiler f acd JIord l pt.7 at the J.11. Ca=pbell Unit 3 and reco=- TMehl i nend and f_pl eent corrective actions. GKeller j -

10/82 -

Provide ar vices and =arerials to coordinate TIlvood the 1983/84 Palisades refueling outage. - .:Schneider 1

1 5

1 I

J 0 Note - S&*=* did the review but hT:E who van already working in Michigan for 1)etroit ,

Edison at the Termi Station is doing the detailed planninC. 1 e

eue

-, - --- m+ - ,, ,e,. ,,,,,--,,n , , , - , ------~e---.--,- , , - - - - - - , ,

.""x 7 E0"* :E.". .:95; 9-11-32; 3: at*. M  ; e_ .-e -

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MC1.*:1:;CE CT CF:- Or/x7 !!F 1

Stone & Vebster, fr.e.. the parant ec:tany of Sinne & Vebster

'-='4neering Corporation and its subsidiarJ a. {1r.cluding SVIC) have ne holdings of'CPCo securities. The L.ployee Savings Plan of S:ene' & Webster.

Incorporated and participating subsidiarisx is administered by the Chane Manhattan lank. N.A. as trustse. Tunds ray be invested in the Employaa Bene. fit Invest:= ant Tunds, Equity Fund of the Chase Manhattan 3ank which is a ecu=ingled fund. Stone & V,bstar axercises no direct control ovet the ,

i.= vest =ent of such f mds.

The Chemical Bank of Nee York is trustee for the E=ployee Retire-ment Plan of Stone & Webster. Inc. and for participattat subsidiaries.

Thera are no CPCo securities held in the plan.

s e e e

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~ . _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

n.-_, .

February 15, 1983 Mcf02ANDUM FOR: R. T. Warnick, Director, Office of Special Cases THRU: 'W. D. Shafer, Chiaf, Midland Section FROM: R. 3. Landsman, Reactor inspector, Midland Section SUBJETI: LICENSEE PERFO'EMANCE ON PIIES 12E and 12W RIII on Decenbar 9, 1982, authorized CPCo to initiate work activities pertaining to the drif t, excavation and installation of Piers 12E and 12W. Subsequent to that authorization the licensee began work on Decenber 13, 1982. Due to the Diesel Generator zuilding Inspection I have had only enough time. to perform five inspections to det==4n= the acceptability of the licensee's work in regards to these piers including removal of fill concrete, shaf t excavation and bracing, bell excavation and bracing, and reinforcing derm 41= and proposed concreting activities.

I have identified three coocerns since underpinning work began which have been subsequently corrected or are in the process of being ,

corrected by the licensee. 'They are:

a) That the craf tverkmen were not receiving the required amount of spei nlized r"4 =1 soils underpinn4nt training. The licensee has agread to expand the scope of craft training, but does not have the details workad out to data.

b) That the licensee wanted to use a super plasticizer as an additive to the concrete adz in lieu of good concreting practicas, i.e.,

consolidation by vibration. Th,e licensea af ter what I' consider to be

  • ezesasive discussions 84==117 agreed to . vibrate all underp4==4n.

concrete in accordance v1th good engineering practica.

c) That the third party independent assessment tasa is not reviewing the design documents for technical adequacy. They are only doing implementation review to assure that the design documents are being followed. From discussions with Stone and Webster personnel, it was deter =4nad that this important parameter was not included in their contract. S e licensee is presently considering including this in the contract documents.

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Besides these three concerns no other issues or deviations from reguistory requirements have been identified.

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l g STONE & WEBSTER MI.CHIG AN. INC. ;5.~5 P.O. Box 2325. Bos7ON. MAssAcHusET7s 02107

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{ Mr. J. C. Keppler February , 14, 1983 l Ad=inistrator, Region III .- J.O. NO.14358 1

U.S. Nuclear Regulatory Com=ission FJS-8 l 799 Roosevelt Road j Glen Ellyn, IL 60137 RE: DOCKET No. 50-329/330 MIDLAhD PLANT - UNITS 1 AND 2 j INDEPENDENT ASSESSMENI 0F AUXILIARY BUILDING UNDERPINNING ASSESSMIh'r OF WORK ON PIERS W12 AND E12 i .

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As of Tebruary 11, 1983 the Stone & Webster - Parsons Brinckerhoff 1 Assessment Team has observed the excavation, placing of reinforcement,  !

l and concreting of underpinning pier W12, and the excavation, and

" placing of reinforcement for underpinnhg pier E12. In addition, the Assessment Team has reviewed the drawings, procedures and other documents

} pertaining to the underpinning work and has observed the performance of I the Quality Assurante and Quality Control Organizations during the pro-l gress of the work.

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j During the period that the Assessment Team has been on site, daily

meetings have been held with Construction, Quality and Engineering j personnel to obtain additional information and discuss observations. .

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' The Assessment Team has issued twenty Weekly Reports to the U.S.

Nuclear Regulatory Com=ission. These reports have described the activities of the Assessment Team and su=marized their observations and j findings.

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1 The Assessment Team has issued a total of five Nonconfor=ance Identification l Reports.. Four of these Nonconformanc's Identification Reports have been 1 closed out to the satisfaction of the Assessment Tean. The remaining open

! Nonconfcirmance Identification Report was issued on February 10, 1983 and l the Assessment Team feels that it can be closed out in the near future

! without impacting the progress of the underpinning.

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The underpinning work is being performed in accordance with the construction j and quality procedures. As the work has progressed,the procedures have

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been modified based upon experience gained during the construction of l piers W12 and E12. The Assessment Tean feels that these minor changes i are appropriate and vill have a positive effect on the quality of the under-

! pinning work.

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- e 2 February 14, 1953 yg.g Eased upon these observations and findings, the Assessment Tean is This of the i opinion that additional piers could be released for construction.

vill benefit the quality of the work by allowing the Contractor to main-tain the experienced labor teams from piers k'12 and E12.

If you have any questions, please contact me at (617) 589-2067.

A.S. Lucks

  • Project Manager O

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Ertnteve Ata sfer r.blis*yCh, Le Atifad Project Office General offices: 1945 West Pernell Road, Jackson, MI 49201 .(517) 788-0774 February 24, 1983 .

Mr A S Lucks Stone and Webster Mielfigan, Inc PO Box 2325 .

Boston, MA 02107 FILE 0485.16 SERIAL 20498

Dear Mr Lucks:

In accordance with Constimers Power Company Specification CC-100, Rev 1,

" Independent Assessment of Auxiliary Building Underpinning", Section 2.1 (j),

Stone and Webster Michigan, Inc shall expand the scope of the independent assessment of Soils Remedial Activities to include the following:

1) Provide a QA overview and assessment of the design work packages to ensure accuracy and adequacy. This overview .

is to insure conformance to procedural and programmatic requirements .

2) Provide a QA overview and assessment of the QO inspector -

requalification and certification program.

3) Provide a QA overview and assessment of the training conduc'ted for all personnel in the soils remedial work effort. -
4) Expand the work contract to include an assessment of all -

underpinning work on safety related structures on which underpinning work is done while the contract with Stone and Webster Michigan, Inc is in effect.

This scope revision shall become'ef fective immediately.

Very truly yours,

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