ML20081H994

Forwards Summary of 831028 Meeting Re Independent Design & Const Verification Program

ML20081H994
Person / Time
Site:	Midland
Issue date:	11/01/1983
From:	Levin H TERA CORP.
To:	Jackie Cook, Eisenhut D, James Keppler CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation
References
ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8311080234
Download: ML20081H994 (14)

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November I,1983 Mr. James W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Mr. J. G. Keppler Administrator, Region ill Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Mr. D. G. Eisenhut Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket Nos. 50-329 OM, OL and 50-030 OM, OL Midland Nuclear Plant - Units I and 2 Independent Design and Construction Verification (IDCV) Program Meeting Summary

Dear Sirs:

The third meeting on Confirmed items was held on October 28,1983. A summary is provided to document items discussed and actions agreed upon by the participants.

Sincerely, w

/ s mv4 '( ch Howard A. Levin Project Manager Midland IDCV Program cc: Participants Midland IDCVP Service List

. R. Erhardt, CPC D. Ouommy, CPC (site)

B. Palmer, CPC (site)

D. Hood, NRC ()hl J. Taylor, NRC, l&E HO i l

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8311080234 831101 HAL/djb PDR ADOCK 05000329 A PDR TERA CORPORATION 7101 WISCONS!N AVENUE BETHESDA, MARYLAND 20814 301 654 8960

0 SERVICE LIST FOR MIDLAtO INDEPEPOENT DESIGN AtO CONSTRUCTION VERIFICATION PROGRAM cc: Harold R. Denton, Director Ms. Barboro Stomiris Office of Nuclear Reactor Regulation 5795 N. River U.S. Nuclear Regulatory Commissio Freeland, Michigan 48623 Washington, D.C. 20555 Mr. Wendell Marshall James G. Keppler, Regional Administrator Route 10 U.S. Nuclear Regulatory Commission, Midland, Michigan 48440 Region lil 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Illinois 60137 2120 Corter Avenue U.S. Nuclear Reguiotory Commission Resident inspectors Office Ms. Billie Pirner Garde Route 7 Director, Citizens Clinic Midland, Michigan 48640 for Accountable Government Government Accountability Project Mr. J. W. Cook Institute for Policy Studies Vice President l901 Que Street, N.W.

Consumers Power Company Washington, D.C. 20009 1945 West Pornoll Road Jackson, Michigan 49201 Charles Bechhoefer, Esq.

Atomic Safety & Licensing Board Michael 1. Miller, Esq. U.S. Nuclear Regulotory Commission Isham, Lincoln & Beale Washington, D.C. 20555 Three First National Plazo, 51st floor Dr. Frederick P. Cowan Chicago, Illinois 60602 Apt. B-125 6125 N. Verde Trail James E. Brunner, Esq. Boca Roton, Florido 33433 Consumers Power Company 212 West Michigan Avenue Jerry Harbour, Esq.

Jackson, Michigan 49201 Atomic Sofety and Licensing Board U.S. Nuclear Regulatory Commission Ms. Mary Sinclair Washington, D.C. 20555 5711 Summerset Drive Midiond, Michigan 48640 Mr. Ron Collen Michigan Public Service Commission Cherry & Flynn 6545 Mercontile Way Suite 3700 P.O. Box 30221 Three First National Plaz Lansing, Michigan 48909 Chicago, Illinois 60602 Mr. Paul Rau Ms. Lynne Bernobei Midland Daily News Government Accountability Project 124 Mcdonald Street 1901 Q Street, NW Midland, Michigan 48640 Washington, D.C. 20009

SUMMARY

OF THIRD MEETING ON CONFIRMED ITEMS OCTOBER 28,1983 MIDLAND IDCV PROGRAM A meeting was held on October 28,1983 at Bechtel's Ann Arbor, Michigan offices to obtain additional information related to Confirmed items identified in IDCVP Monthly Status Reports dated September 20,1983, and October 17, 1983, and to status other outstanding items identified previously. Attachment I identifies the attendees of the meeting which included representatives from TERA, CPC, Bechtel, and NRC. Attachment 2 presents the agendo used for the meeting.

Howard Levin, TERA, opened the meeting with a discussion of the agendo and a summary of the purpose of the meeting. The minimum objective for the meeGg was to ensure that all participants gained a complete understanding of the technical issues expressed as Confirmed items. This is intended to enable Midland project personnel to identify additional information that may have a bearing on the issues at hand. Direct clarification or presentation of additional information by Midland project personnel is also sought so that specific issues may be further dispositioned directly.

Lou Gibson, CPC, discussed recent actions taken by the Midland project ic, facilitate the flow of information to TERA. These actions have included the revision of certain internal Bechtel procedures for handling the transmittal of

. information. Levin indicated that these procedures were reviewed by TERA and with representatives of the NRC, and that since their adoption on improvement in turnaround time has been recognized. Gibson indicated that the issue of information flow is on the agendo for mangement review, and that routine reports are provided to management to enable a verification that turnaround time is not compromised by other priorities.

The status of outstanding Confirmed items and Findings was discussed next, including a cursory review of Observations and Resolved items. A summary of significant aspects of these discussions is provided in Attachment 3 olong with I

any couru of action identified. The responsible lead TERA personnel described each item followed by a discussion of either CPC or Bechtel personnel, as appropriate.

During these discussions, the topic of Observations was presented. Observations are items that are not considered sufficiently serious to warrant classification as Confirmed items; however, these cannot be dismissed directly as Resolved items because certain review and potential corrective actions may be necessary on the part of the Midland project. A consensus was developed to the effect that Observations would continue to be transmitted via the Monthly Status Reports.

Any necessary clarification required by the Midland project could be gained at

[ similar meetings. Without such questions, time will not be consumed in reviewing Observations at these meetings.

The stated topical report on the AFW system performance requirements was discussed. TERA indicated that the original concept for the report was to provide intermediate input that may be useful to the NRC in their efforts associated with the Ford Amendment. It was originally anticipated that while such a topical report is but a piece of the IDCVP scope, it would provide a glimpse into the implementation of the overall IDCVP methodology. TERA indMated that most of the outstanding Confirmed items and Findings are associated with the AFW system and that in view of this, it is premature to draw substantive conclusions. Accordingly, it has been determined that such a topical report would merely be o topical status report and not a consummate statement on the AFW system performance requirements. The NRC representatives indicated that they would review the situation to assess whether or not the current monthly status reporting would suffice in lieu of the slated topical report.

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. MEETING NOTICE

. BECHTEL JOJ NO. ..7220. __ .__ . ._

PROJECT SUBJECT OF THE MEETING Independent Design and Construction Verification (IDCV) Program DAY Friday - October 28, 1983 TIME 9:00 a.m. TO 3:00 p.m.

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ATTACHMENT 2 INDEPENDENT DESIGN AND CONSTRUCTION VERIFICATION (IDCV)

AGENDA for OCTOBER 28, 1983, MEETING ANN ARBOR, MICHIGAN I. Introduction and opening remarks II.

Discussion of Confirmed Items, Findings, Observations, and Resolved Items TERA LEAD CPCo/B&W/BECHTEL LEAD ITEM Const ruction B-Const ruction F-045 Tulodieski Tulodieski B-Const ruction F-046 B-Const ruction F-047 Tulodieski Tulodieski B-Construction C-049 B-Const ruction C-050 Tulodieski Tulodieski B-Construction C-052 B-Const ruction C-053 Tulodieski Tulodieski B-Construction C-054 (Agar)

Mechanical B&W/B-Mechanical C-005 Dougherty Dougherty B-Mechanical R-017 B&W/CPCo C-018 Dougherty Dougherty B-Mechanical C-020 CPCo C-027 Dougherty Dougherty B-Mechanical /CPCo

'C-028 B-Mechanical C-048 Dougherty B-Mechanical /B-Plant Design C-043 Do ugherty Dougherty CPCo C-025 B-Mechanical C-038 Bates Witt B-Mechanical C-066 B-Mechanical C-073 Witt 1

Witt B-Mechanical C-074 B-Mechanical C-075 Witt Witt B-Mechanical C-076 B-Mechanical f B-057 Witt Witt O B-Mechanical B-067 B-Mechanical B-063 Dougherty Dougherty B-Mechanical B-064 B-Plant Design F-031 Tulodieski B-Plant Design F-036 Tulodieski i

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AGENTA - PJge 2 TERA LEAD CPCo/B&W/BECHTEL LEAD ITEM Civil Mortgat B-Civil R-037 B-Civil C-015 Mortgat Mortgat B-Civil C-068 B-Civil /B-L/S C-077 Mortgat Electrical B-Electrical Z-012 Bates Bates B-Electrical /B-L&S C-039 B-Electrical C-040 Bates Bates B-Electrical C-022 Miscellaneous B-L&S R-041 Bates Bates B-L&S R-042 B-L&S B-044 Dougherty Dougherty B-L&S B-059 B-Control Systems B-061 Witt

11. Discussion of Action Items and Logistics for Information Exchange t

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ATTACHMENT 3 DISCUSSION OF COWIRMED ITEMS, FItOINGS, OBSERVATIONS, AND RESOLVED ITEMS 320 l-008-F-045, -046, -047 All three of these items relate to the storage and maintenance area of review.

F-045 and F-046 are specific discreponcies noted in the storage and maintenance programs, while F-047 is more generic as it questions the process by which vendor recommended storage and maintenance requirements are reflected in project procedures. TERA is currently reviewing actions taken by the project to improve the storage and maintenance programs. TERA is also currently reviewing the charter for a new organization with full-time responsibility for these issues, as well as interviewing key personnel. The emphasis of these efforts is on how vendor requirements are reconciled and the effectiveness of implementation. TERA will also review specific changes to the in-place maintenance procedure for the AFW pump motor and witness a future overhaul of the AFW pumps and turbine.

3201-008-C-049 TERA indicated that a response was received from Bechtel which addressed physical changes to be made which include placing a cover on the cable tray to create a barrier between the noted channels. It was concluded that this action

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would address the noted separation issues in the locations covered, but not in the air-lined region as the cables terminate into cabinets. CPC indicated that they had uncovered similar problems and that the EFE staff (team 24) was investiga-ting solutions such as wrapping. CPC is also looking into gaining dispensation from the 3-foot separation requirement in the vicinity of cabinet entries. TERA will factor these actions into the continuing review.

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3201-008-C-050 TERA indicated that a response was received from Bechtel which addressed the engineering significance of the noted cable being routed outside of its scheduled via. It was observed that guidelines in the cable overinspection program may not be definitive in establishing criteria for dealing with such a routing. Accord-ingly, OC personnel may have interpreted such circumstances in different ways.

TERA will' complete a review of the technical arguments presented in this specific instance and expand the existing sample to verify that the overinspec-tion has been consistently applied.

3201-008-C-052, -053, -054 All three of these issues relate to documentation that TERA was unable to secure. C-052 addresses the completeness of vendor supplied documentation, while C-053 and C-054 address construction / installation documentation. At this juncture it is not clear whether TERA could simply not locate the information, if it is misplaced, in process, or never created. Bechtel will attempt to locate the noted documents. TERA will review the closeout procedure for vendor supplied documentation including site and Ann Arbor activities. Discrepancies between direct spec requirements and 32lD requirements will be reviewed further. TERA questioned whether the CCP has a focus on a verification of completeness of vendor supplied documentation. CPC indicated that it did in a peripheral manner, primarily the installation requirements. C-053 and C-054 bear directly on items that are within the CCP scope and are slated to be verified as the program progresses. Accordingly, TERA will review the closecut of these specific items after the CCP has been through and expand the sample at a future date to verify that similar items are caught and resolved.

y01-008-2'-012 TERA described the bases for resolving this Finding and indicated that no further action is contemplated at this time.

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. 3201-008-C-039 TERA has received a letter from Bechtel on this item; however, there is still some discussion of the opplicobility of the test data to the actual design where aluminized mylar tape is used on some cables and not others. Bechtel will provide further information justifying their position that the qualification test dato is applicable.

3201-008-C-040 Bechtel indicated that the lengths shown on the circuit schedule are shop-cut lengths and may not necessarily be actual installed lengths. Notwithstanding this, Bechtel has indicated that for the specific MOV application, calculation OPE-8 is too conservative and not necessarily applicable. They further indicated engineering judgment is the principal means by which cables are sized. TERA indicated that this process would be reviewed along with the methods of GC verification. Additional sampling of sizing under these applications may be warranted pending the process review.

3201-008-C-022 i

TERA indicated that a preliminary review was made of the startup test procedure and that it was judged that it may not fully exercise the SG level control system to the extent that its performance under o!! plant conditions may be verified. CPC committed to providing justification addressing why the startup testing and hot functional testing would suffice to qualify the system. j l

3201-008-C-025 TERA has received a rate calculation for SG fill and is currently reviewing it.

DCAR 731 has been written which addresses changes to switching hardware 1

associated with FOGG inversion. This information will be transmitted to TERA for review.

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3201-008-R-O l 7 TERA indicated that full clarification was received and the issue is resolved.

3201-008-C-005, -018, -020, -027 -028 TERA indicated that each of these issues have been outstanding and that Bechtel's September 30,1983 letter is anticipated to be sufficient for TERA to effect further disposition. No further Midland project action is required at this time.

3201-008-C-048 Bechtel indicated that the original spec required qualification to a 120 F environment; however, conse.n otive treatment of the blackout condition dic-toted raising the qualification temperature to 150 F. Later calculations established pump room temperatures to be 121 F. The vendor is currently qualifying to this level. Documentation will be available in early spring,1984 at which time it will be forwarded for TERA's review. This item will be placed on

" hold" and not discussed at future meetings until the documentation is received.

3201-008-C-038 Bechtel indicated that additional information in addition to the vendors previous telex was being forwarded by the vendor. CPC questioned whether the 100 gpm AFW flow would b'e maintained under a station blackout condition with a low

! decay heat load. TERA indicated that resolution of this item will require evaluating scenarios such as blackout with low decay heat load to determine whether 100 GMP can be maintained. TERA will review the later vendor submittal upon receipt.

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. 320l-008-C-066 Bechtel indicated that after three hours the air intake can be opened manually and that calculations assume that this is done at three hours after isolation, followed by continuous operation in that mode thereafter.

3201-008-C-073 Bechtel indicated that LOCA is the limiting' case for external heat loads to the control room because high energy line breaks do not affect adjacent areas.

3201-008-C-074 Bechtel indicated that the stntion blackout event is not a design basis event and, therefore, the 75 F control room temperature does not have to be maintained under these conditions. Bechtel estimated that under design basis assumptions, the maximum temperature that could be reached in the control room could reach i10 F, two hours into the station blackout. Bechtel has documented this in a calculation.

3201-008-C-075 Bechtel indicated that they assume that the double control room doors are an airlock. They referenced p. 6.4-7 of the FSAR.

3201-008-C-076 The 2000 cfm is documented on flow diagram M-765. The 104 F is a reference design basis in many areas of the FSAR. The 96 FDB and 79 FWB are based upon Saginaw meteorological data. Accordingly, Bechtei will clarify these references in the subject calculation.

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. 3201-008-F-031 TERA indicated that review was continuing to assess the process by which field changes are reconciled with the design. As elements of the CCP are directed at related issues, TER A will factor this input into the overall evaluation. In view of similar issues recently identified by MPOAD associated with the FCR/FCN process, additional emphasis will be placed in this review areo.

3201-008-F-036 TERA indicated that additional information had been received from Bechtel which will enable a further disposition of this item.

3201-008-C-043 Bechtel indicated that the M-480 Piping Class Sheets provide the classification criteria for various seismic and quality categories for piping. They indicated that while the subject piping was not subject to GA requirements, it was installed according to the M-327 spec. Bechtel will eventually walkdown all piping in this category to verify general arrangement and quality of installation.

TERA will review this information and note any required additional clarifico-tions.

3201-008-C-015 Bechtel indicated that the vertical floor flexibility study was not the only basis which supports the statement in the C-501, Civil / Structural Design Criteria document that floor flexibility need not be considered in the seismic onelysis of the Midland plant structures. Reference was made to a study by SMA which includes this behavioral effect. Bechtel could not comment on the results of this study. TERA reiterated the issues documented in C-015. It was determined that the subject study alone was insufficient and that the SMA study should be reviewed to further disposition the item.

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3201-008-C-068 Bechel will further investigate the noted discrepancy and document the results in a letter to TERA.

3201-008-C-077 Bechtel indicated that Sections 3.9 and 3.10 of the FSAR were purged at the request of the NRC to be replaced by NRC's "short form." CPC hos recently taken responsibility for the SQRT issue and should be consulted for further information regarding the status of the SORT review and FSAR update process.

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