ML20082M554
| ML20082M554 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/01/1983 |
| From: | Lucks A STONE & WEBSTER, INC. |
| To: | Cook R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20082M450 | List: |
| References | |
| MPF-58, NUDOCS 8312060183 | |
| Download: ML20082M554 (19) | |
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STONE & WEBSTER MICHIGAN, INC.:)/RA JE A/HA Ji(AS F P.O. Box 2325. BOSTON. MASSACHUSETTS O2107 4C DRMA f'l,lf,.*
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United States Nuclear Regulatory Commission November 1, 1983 Midland Site Resident Office Route 7.
J. O. No. 14358 Midland. '!I. 48640 Ref. MPF 58 Attention:
Mr.
R.
Cook DOCKET NO. 50-339/330 MIDLAND PLANT UNITS 1 & 2 INDEPENDENT ASSESSMENT OF UNDERPINNING REPORT No. 58 A copy of the Independent Assessment of Underpinning Weekly Report No. 58 for the period of October 23. 1983 through October 29. 1983 is er.elosed with this letter. Included as attachments are the minutes of the daily meetings held during the week between members of the Assessment Team and Site Engineering. Construction, and Quality Assurance personnel.
In addition, the notes of the first Monthly Meeting of Stone & Webster and Consumers Power with the Nuclear Regulatory Commission are attached.
If you have any questions with respect to this report please contact me at
( 617 ) 589-2067.
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Stanley Lucks I
Project Manager f
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l MINUTES OF THE MEETING ON OCTOBER 13, 1983 STATUS OF INDEPENDENT ASSESSMENT OF UNDERPINNING AND REMEDIAL S0ILS
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i Purpose To discuss Third Party Overview a'ctivities of Stone & Webster (S&W) and problems encountered regarding underpinning and remedial soils work.
Summary
'Mr. A. S. Lucks, Project Manager for the Indepen ent Assessment of Under-d pinning and Remedial Soils Work, prisented a summary of the assessment pro-gram for the past year. Highlights follow:
, Assessment Team has been on site for over twelve months.
- The scope of work for the Assessment Team includes overviewing the,
constructionoftheunderpinningandallremedialsoJlsactlyities, the Quality Assurance activities associated withthe underpinning and remedial soils activities, and reviewing.the Work Activity Packages i
for completeness.
- The Assessment Team includes staff with expertise in Geotechnical Engineering, structural engineering, Quality Assurance, construction, and underpinning.
' The underpinning activities are proceeding on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> day, 7 days per
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. week schedule and the Assessment Team operates as two units to provide One unit is headed up by W. E. Kilker, the second unit 7 day coverage.
f' is headed up by P. J. Majeski.
- The Assessment Team submits weekly reports, Nonconformance Identification l
Reports (NCRs) and periodic summary. reports directly to the NRC with copies to Consumers Power Company (CPCo).
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Minutes of Meeting PAGE 2
- To-date 16 underpinning piers have been installed for the Auxiliary Building underp'inuing and the first set of grillages have been installed.
- Work at the Service Water Pump Structure (SWPS) has included installation of the soldier piles a,nd dewatering systems in preparation for underpinning.
- Preparations are" in progress for the extension of the Borated Water Storage Tank foundations.
- Th; Assessment Team has had the opportunity to see most of the operations
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necessary for the underpinning work.
- Astotal of 55 weekly reports,15 NCRs and a 90-Day Sumary report have been issued.
Basedonactivitiesduringthepasttwelvemonihs,'tlieAssessmentTeamhasthe follcwing observations:
'The'underpinningthathasbeeninstalledisofaverphighquality.
- The Quality Assurance staff are perfoming as an effective quality l
organization.
- All of the organizations involved in th'e underpinning have demonstrated a positive attitude and concern towards quality.
- The instrumentation system installed to monitor building movements adds 1
.to the confidence in the. success of the underpinning work.
- Both CPCo and Bechtel have been responsive to the requests and needs of the Assessment Team.
- Currently 14 of the 15 NIRs have been closed out. Seven of the NIRs were related to Specifications or Construction Procedures, six were related to QA Procedures, and two were hardware related.
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Minutes of Meeting PAGE 3
- From time-to-time the Assessment Team has stated that the completions i
of underpinning pie'rs, from excavation to load transfer, should be accompl'ished in a more timely manner. This item is still of concern to the Assessment Team, although some impro,vement has taken place and l
Quality has not been impacted.
Mr. W. E. Kilker presented a description of the major underpinning activities during the previous month. Highlights follow:
- The installation of the Pier 8 grillage beams on the east and west ends
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of the Auxiliary Building was the major underpinning activity during the month. They were installed in accordance with project procedures.
and the Assessment Team was particularly impressed with the teamwork demonstrated during the load transfer to the beams.
- Progress was made in obtaining, access for underpinning activities through i
the Utility Access Tunnels. The soil stabilization by grouting is being effectively accomplished.' Grout takes are high.
- Outstanding NCRs on the reinforcing steel for the BWST foundations have I
been resolved and installation of the reinforcing steel has begun.
- At the SWPS the installation of the soldier piles ls almost complete and initial testsof the dewatering systems suggest that it may be more effective than anticipated.
- Miscellaneous activities have. included installation of cathodic protection systems, removal of two 36 inch casings, piezameter installation and soil investigation work.
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- During the, installation of a piezameter there was an incident of drilling into a beam that extends from the Auxiliary Building. A stop work order was issued on drilling and the occurrence.was investigated.
In the future, structural drawings will be reviewed, in addition to utility
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Minutes of Meeting PAGE'4 drawings, before a drilling permit is issued.
- One NCR was issued during this period.
It concerned certification of QC supervisors. This NCR has been closed.
- Five Work Activity Packages were reviewed and Assessment Team questions l
l were satisfactorily resolved.
Questions and Answers
- Mr. J. J. Harrison.(NRC) asked if Stone & Webster tracked commitments'
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made by CPCo in closing open items from the daily meetings, for example, Item 52-14. A check by th'e NRC had shown that some six weeks after the commitment had been made the drawing had not b'een changed. Mr. W. E. Kilker I
(S&W) replied that Stone & Webster does not track an item after closing, but the item would be brought to CPCo attention if the drawing were to I
r be used for construction without the change being..made R. A_ Wells _
(CPCo) stated that if it is flagged on a formal q'uality document it would be tracked.
J. A. Mooney (CPCo) stated that he will check on the CPCo tracking process.
l Mr. R. Landsman (NRC) commented that a drawing with a detail noted as N'on-Q had been ident'ified and this also had not been corrected.
- Mr. J. J. Harrison (NRC) remarked that daily meeting notes ind'icated that an item on a drawing was only a suggested method and not a l
l requirement and asked why it was shown on the drawing, if it is l
only a suggestion. Mr. W. E. Kilker (S&W) stated that the procedure associated with this item points out that it is a suggested method.
Mr. J. A. Mooney (CPCo) stated that he will check on this item.
- Mr. J. J. Harrison (NRC) commented that in weekly report No. 49, the Assessment Team suggested a solution to possibly' avoid proble.ms with welding. This suggestion had also been made in weekly report No. 30.
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Minutes of Meeting PAGE 5 He asked why had CPCo not acted sooner. J. A. Mooney (CPCo) stated that they had reviewed the. situation and had thought that the existing procedure was adequate but that this,was subsequently not the case and the suggested change had been implemented. Mr. W. E. Kilker (S&W)' con-firmed that the change was being made.
- Mr. R. B. Landsman (NRC) asked if the lagging spacing problems had been solved. He not4d thatit had appeared again in recent weekly reports.
Mr. W. E. Kilker (S&W) stated that at the Auxiliary Building, the Contractor had opened up.the lagging spacing as requested by the Assessment Team. The latest occurrence was at the SNPS and the problem I
has now been addressed.
- Mr. R.~ ~ B. Landsman (NRC) asked whattis being done to rssolve the venting 1
problems associated with the grouting of bearing plates. -
Mr. W. E. Kilker (S&W) stated' that the Assessment Team was tracking this problem.
It occurs when the foundation surface is very irregular, and the Assessment Team is aware that the Contractor is expending considerable effort to solvethe problem. The inspection of the cured grout is being performed very carefully.
- Mrs. Sinclair, member of public, asked Mr. J. J. Harrison (NRC), if he was satisfied with t'he answer to the question on tracking commitments used in closing items from daily meetings. Mr. Harrison stated that CPCo had committed to tracking those items; however, the subject would have to be discussed further at the next monthly meeting.
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Minutes of Meeting PAGE 6 Action Items
- CPCo will review the implementation of commitments made to close out daily meeting items.
- Stone & Webster Will refine the tracking system for open items.
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J. O. No. 14358 Midland Plant Units 1 & 2 Independent Assessment of Underpinning l
' Weekly Report N'o. 58 October 23, 1983 through October 29, 1983 l
Personnel on Site Store & Webster Michigan, Inc.
W.
Kilker 10/23 - 10/25 B.
Helsinger 10/26 - 10/29 P.
Majeski 10/25 - 10/29 J.
Springer 10/23 - 10/27 Parsons Brinckerhoff Michigan, Inc.
P.
Parish 10/25 - 10/28 Meetings Attended Date Represented Purpose 10/24-10/28 Stone'& Webster Daily Assessment Bechtel Team Meeting Consumers Power Parsons (10/26 & 10/27) 10/26 MPQAD Assessment Team Stone & Webster Meeting with MPQAD Parsons 10/28 MPQAD Soils MPQAD FCR Stone & Webster Stop Work Order Summary 10/28 MPQAD FCR Stop Work Order Bechtel Steering Committee Consumers Power Meeting Stone & Webster Underpinning and Remedial Soils Activities - Construction Because of the site Stop Work Order issued on October 21 by MPCAD, regarding the misapplication of FCR's/FCN's, no w6rk, other than maintanence activities, has been accomplished in the.past week, l
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l Assessment Team Observations - Construction Because of cessation of work at the site, the Assessment Team's activities l
l have been limited to reviewing construction documents in preparation for upcoming work.
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J. O. No. 14358 Midland Plant Units 1 & 2 Independent Assessment of Underpinning n
Assessment Team Observation - QA/QC The effort to resolve the problem of misapplication of FCR's/FCN's to affected documents is continuing.
It is too early tp determine the impact of this problem on completed construction. The effort to date has been directed towards identifying those FCR's/FCN's that are a problem; determining the issues which must be addressed; and, developing a procedure to resolve the issues before lifting the Stop Work Order.
The Assessment Team observed that this effort is being undertaken with diligence.
During an Assessment Team review of the BWST drawings it was observed that one FCR was not posted on the correct drawing, The correct drawing had been ' referenced on the second page of the FCR.
However, this drawing number was not inserted in the appropriate block.on the first page of the FCR.
An additional fifty-three drawings were reviewed without finding a similiar condition. MPQAD was notified
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of this one condition.
This condition is related to the Stop Work Order and the resulting investigation regarding the misapplication of FCR's/FCN's to drawings.
Therefore, an NIR was not issued.
Work Activity Packages The comments and questions on WAP 64, which were previously submitted. were satisfactorily resolved.
Therefore. this package is considered complete. Comments and questions regarding WAP 68 and 70 were submitted to FSO. WAP 59 remains open awaiting FSO response to an action item.
Nonconformance Identification Reports NIR No.
Description Date (Openedi (Closed) 14 Nut Procurement 8/11/83 Open Items Items discussed during meetings are categorized as follows:
OPEN ITEM - An item for which an action is required.
The item will remain open until the required action has been taken.
Tracking is required.
CLOSED ITEM - An item, usually brought forward by the Assessment Team, that is discussed and adequately responded to.
No tracking is required.
INFORMATION ITEM - An item, brought forward to provide general background information regarding the work, such as work status or an upcoming design change. No tracking is requ' fred.
OPINION ITEM - An opinion or suggestion, given by the Assessment Team'.
expressing an alternate construction or quality assurance technique.
The opinion or suggestion is given as a possible alternate that may facilitate an operation.
No response or implementation is required as a result of an Opinion Item, CLOSES ITEM XX-XX - This notation identifies an action that closes a previously identified cpen item. Tracking of the open item stops.
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u J. O. No. 14355 Midland Plant Units 1 & 2 Independent Assessmen,t of, Underpinning Tne following is a listin5 of all open Items from the Daily Meeting No.*2 with Bechtel and the Weekly Meeting with MPOAD.
Carry-over items from cast weeks which have been Closed this week are aise listed.
Item No.
Descriptien Closure 45-50 Discussien on Mechanism Open of Identifying Outlity Cbrcerns 4S-60 Structural Backfill Open POCI Adecuacy 52 0 M?OAD Independent open Welding Inspection
?.eview s
55-2 Plasticized Concrete Open Mir Tests 56-;2 Lean Flyash Placement Open Open 57-17 Wall Ties 57-18 Tubular Steel SE-3 Sheeting i
57-50 M?OAO Supervisory open Personnel 57'-7 0 Welcing Inspecticn Open 55-3 Tutular Steel Lagging 0 er 55 1 FSC Evaluation'cf Open FC?.'s/?CN's Status SE-11 Winterization of Open SW?S Dewatering System h
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J. O. No. 14358 Midland Plant Units 1 & 2 Independent Assessment of Underpinning 1
Item No.
Description Closure 58 12 Number of FCR's on Open Drawings 58-13 Slurry for Removal Open 4
of 36 Inch Diameter Casing
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' Notes of Daily Meeting Independent Assessment of Underpinning Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location Midland, MI.
October 24, 1983 Present For:
Consumers Power Bechtel MPOAD Stone & Webster G.
Murray E.
Cvik1 R.
Sevo W.
Kilker J.
Gaydos J.
Springer J.
Kelleher Parsons None Purpose This meeting is held each day to discuss items regarding the Independent Soils Assessment at the Midland Plant. Units 1 & 2.
Discussion Item 58 Stop Work Order.
E.
Cviki reported that as of late on October 21, an MPQAD Soils issued SWO had resulted in a halt to virtutlly all of the soils remedial work.
A CPCo audit revealed the referencing of Bechtel drawings and specifications had rendered the FCR/FCN process indeterminate.
E.
Cviki provided a copy of the SWO and the exceptions FSO had taken to maintain,for example,such items as instrumentation, monitoring, training, testing, surveying and dewatering.
W.
Kilker replied that the Assessment Team was aware of the SWO. However, the Team is also interested in the methodology of resolution of tne SWO.
J.
Kelleher replied that FSO had identified and retrieved from Document Control the FCR/FCNS applicable to the soils remedial work.
As of this morning ( 10/24/83 ) the FSO evaluation was nearing completion. Up to this point the evaluation had revealed some risapplication of the document control of the forms but no cases of inadequate document control.
Once the evaluation is completed, the review will be forwarded to MPOAD for verification.
( OPEN ITEM )
Item 58 Use of Visual Reminder (VR) Form.
W.
Kilker requested information of a yellow tagging system (VR) that has recently appeared in the auxiliary building underpinning work areas.
J.
Gaydos replied that the tags are generated by Mergentime to convey information to the crafts on such icems as limits of work, state of the work at the end of a work shift or requirements to proceed to the next work stage.
W.
Kilker said the concept appeared good as long as the number of tags in a given area was kept to a reasonable number.
Too many tags could lead to either confusion or disregarding the tags. ( CLOSED AND OPINION I?"M )
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,Nst:s of Daily Mestisg)
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Independent Assessment of Underpinning Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location Midland, MI.
October 24 1983 Item 58 Tubular Steel Lagging.
In response to Item 57-18. E.
Cviki stated that the Subcontractor will be given an option to fill the void space on permanently installed tubular sheeting with either ethafoam or grout. The options will be reflected on
- Bechtel drawin6 C-2025 and C-2025 - 13
( OPEN ITEM. CLOSES ITEM 57-18) 9
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Notes of Daily Meeting Independent Assessment of Underpinning Midland Plant Units 1 & 2,
Consumers Power Company Held at Midland Site Location Midland. Michigan October 25, 1983 Present For:
Consumers Power Bechtel M?QAD Stone & Webster G.
Murray E.
Cviki R.
Sevo W.
Kilker J.
Gaydos J.
Springer J.
Fisher N.
Swanberg Parsons J.
Kelleher y
Purpose This meeting is held each day to discuss items regarding' the Independent Soils Assessment at the Midland Plant Units 1 & 2.
Discussion Item 5B 4 - FSO Evaluation of FCRs/FCNs Status.
J.
Kelleher updated the FSO evaluation effort.
All FSO Civil FCRs have been reviewed. ( A total of approximately 500).
Questions arose on nearly 30 percent of these but only 6 percent required any form of corrective action-mainly increasing FCR distributions to additional drawings.
FSO must continue to interact with the Balance of Plant on a number of specifications that are common to both areas. FCRs drawn on these documents will require evaluation to determine the extent of impact on FSO installations.
The evaluation of FCNs will commence today.
The methodology will be the same as that used for the FCR evaluation. ( Refer to Item 58-1 ) ( OPEN ITEM.
CLOSES ITEM 58-1 )
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Notes of Daily Meeting j
Independent Assessment of Underpinning Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location
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Midland. Michi6an October 26, 1983 i
Present For:
Consumers Power Bechtel MPQAD Stone & Webster G.
Murray J.
Fisher R.
Sevo J.
Springer -
J.
Schaub E.
Cviki P.
Majeski J.
Gaydos Parsons P.
Parish Purpose This meeting is held each day to discuss items regarding the Independent Soils Assessment at the Midland Plant Units 1 & 2.
Discussion Item 58 FSO Evaluation of FCR's/FCN's Status.
J.
Fisher indicated that before work may restart. two procedures concerning
. document control must be revised to prevent reoccurrance.
In addition, the balance of plant lags behind FSO in evaluatin6 the FCR's/FCN's. Before any work may restart. the impact of balance of plant FCR's/FCN's on the soils I
work must be evaluated.
R.
Sevo indicated that MPQAD is doing a 100 percent independent evaluation of the FCR's/FCN's.
After this evaluation they' will be working with FSO in resolving any problems. MPQAD will als'o verify and close out any required actions. (INFORMATION ITEM )
Item 58 Evaluation of Change and Nonconformance Documents.
J.
Fisher acknowledged receipt of the report entitled " Evaluation of Change and Nonconformance Documents" prepared by W.
Craig of Stone & Webster.
( INFORMATION ITEM )
Item 58 Field Engineering Rev'iew of US Testing.
J.
Gaydos provided the Assessment Team with the. final draft of the field engineer's review findings against US Testing.
( INFORMATION ITEM )
L Item 58 Tracking of Assessment Team Concerns.
J.
Schaub suggested that any concerns contained in the text portion of the Assessment Team's weekly report should be subsequently discussed in the meeting with Bechtel to provide for tracking and response on the part of Bechtel.
'P.
Majeski to review and revise. ( OPEN ITEM ~)
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Independent Assessment of Underpinning Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location Midland. Michigan October 27, 1983 Present For:
Consumers Power Bechtel MPQAD Stone & Webster G.
Murray J.
Fisher R.
Sevo P.
Majeski E.
Cviki J.
Springer J.
Gaydos Parsons P.
Parish Purpose This meeting is held each day to discuss items regarding the Independent Soils Assessment at the Midland Plant Units 1 & 2.
l Discussion
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- Item 58 Oil Residue at Stend-by Jacks.
i In response to an opinion given by J.
Ratner ( Item 57-22.). J.
Fisher indicated that the oil leaks have been evaluated by Mergentime and no
-jack repair or replacement is considered necessary, at present. He further indicated that jacks, when not under load will occasionally leak.
The leaking oil will be periodically cleaned up and extra care will be taken in monitoring the performance of these items in the future. ( INFORMATION ITEM )
Item 58 Concrete Backfill Behind SWPS Lagging.
P.
Parish asked how the possible loss of 6round will be monitored if concrete backfill is placed behind the lagging at the ground surface?
J.
Fisher responded that the loss of ground will be monitored from within the excavation by checking behind the lagging.
If loss of ground begins to be a problem.
soil stabilization grouting will be accomplished from the ground surface.
( CLOSED ITEM )
Item 58 Winterization.of SWPS Dewatering System ( OPEN ITEM )
l P.
Parish asked what provisions are anticipated for winterization of the SWPS dewatering system?
( OPEN ITEM )
r Item 58 Number of FCR's on Drawings.
P.
Parish indicated that he had considerable difficulty in using Drawing No.
C-1425-2 which had 16 FCR's totalins 55 pa6es attached.
This type of situation can lead to errors.
J.
Fisher to look into and r'espond. ( OPEN ITEM )
Item 58 Slurry for Removal of 36 Inch Diameter Casing.
J.
Fisher asked for an elaboration on the Assessment Team's concern about the. control and mixing of the slurry which was included in Weekly Report No.
56.
P.
Majeski indicated that the bentonite was slowly poured in the drum through a spray of water.
This procedure probably would result in " balls" a
of bentonite in a thin slurry rather than a uniform slurry.
There was no mixing or checking of the slurry to assure adequate breaking down of the i
bentonite. ( OPEN ITEM )
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Notes of Daily Meeting Independent Assessment of Underpinnin6 Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location Midland, Michigan October 27. 1983 Item 58 Time Lag Between Completion of Reaming and Concreting.
J.
Fisher asked for an elaboration on the Assessment Team's concerns about' the time last between reamin6 and concrete placement at the 36 inch diameter casing.
P.
Majeski indicated that during this time period, collapse of the wall could have occurred.
J.
Fisher responded that this was considered and that the drill rig checked the hole for collapse by droppin6.the tool into the hole immediately before placement of concrete. ( CLOSED ITEM )
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k.I Notes of Daily Meeting Independent Assessment of Underpinning Midland Plant Units 1 & 2 Consumers Power Company Held at Midland Site Location Midland. MI. 48640 October 28. 1983 Present For:
Consumers Power Bechtel MPOAD Stone & Webster None J.
Fisher R.
Sevo P.
Majeski E.
Cviki Parsons None Purpose This meeting is held each day'to discuss items regarding the Independent Soils Assessment at the Midland Plant. Units 1 & 2.
Discussion Item 5'B Tracking of Assessment Team Concerns.
P.
Majeski ruggested that to assure that all Assessment Team concerns are entered into the Bechtel's action item list, the contents of each Weekly Report will be discussed in the next Daily Meeting. Similarly, action items from other Assessment Team Reports and the Notes of Meetings with MPQAD will also be identified for tracking. ( CLOSES ITEM 58-8 )
Item 58 Slurry for Removal of 36 Inch Diameter Casing.
J.
Fisher asked if the Assessment Team had any concern about the adequacy of the completed work involved with the 36 inch diameter casing'.
P.
Majeski responded that the Team is satisfied with the completed work but believes that the procedure requires change if similar operatices are performed in the future. ( CLOSED ITEM. item 58-13 remains open )
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Notes of HPQAD Meeting Independent Assessment of Underpinning Midland Plant Unjts 1 & 2 Held at Midland Site Location Midland. Michigan October 26. 1983 Present For:
Stone & Webster MPQAD P.
Majeski R.
Field J.
Springer M.
DeWitt J.
Meisenheimer Parsons R.
Oliver P.
Parish I
Purpose This meeting is held to obtain and discuss information relative to 0.A.
activities for soils underpinning work at the Midland Plant Units 1 & 2.
Discussion Item' 58 Status of NIR # 14 The response to NIR # 14 is nearly complete.
The remainir.g action item
~1s a QC inspection to verify that the material was -scrapped.
This will be accomplished as soon as the SWO has been lifted. ( INF0EMATION ITEM )
Item 58 Status of Mechanism For Identifying Quality Concerns.
Tne final draft is in the approval cycle. ( INFGRMATION ITEM )
l Item 56 Status of MPQAD Welding Inspection Review.
The final report will be issued this week. ( INFORMATION ITEM )
Item 58 Status of Comments on PQCI for Backfill.
A copy of the final draft,which is in the approval cycle,was given to the Assessment Team, who will review to determ'ine if all the Team's concerns we're adequately addressed. ( TNFORMATION ITEM. ITEM 48-80 remains open )
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Item 58 MPQAD Involvement in FCR/FCN Review.
l MPQAD will be makin6 a 100% review of the FCR/FCKito identify which will require action before lifting of the SWO.
They will also participate with FSO in determining the, appropriate action required for each identified FCR/FCN As a result of this review NCR's may be required if any work is left indete.minant.
Procedural changes are requried to prevent reoccurrance of i
the present situation.
Censtruction work will be allowed on discrete l
items of work when the total problem has been defined and sufficient actions I
have been taken on any related identified FCR/FCN's.
('INFORMATION ITEM )
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