ML20087P162

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Forwards Summary of 840328 Independent Design & Const Verification Program Eighth Meeting on Confirmed Items & Findings
ML20087P162
Person / Time
Site: Midland
Issue date: 04/04/1984
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
OL, OM, NUDOCS 8404060113
Download: ML20087P162 (17)


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L J April 4,1984 Mr. James W. Cook Vice President Consumers Power Company 1945 West Pornoll Road Jackson, Michigan 49201 Mr. J. G. Keppler Administrator, Region 111 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commissicn 799 Roosevelt Road Glen Ellyn, Illinois 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 50-330 OM, OL Midland Nuclear Plant - Units I and 2 Independent Design and Construction Verificotton (IDCV) Program Meeting Summary Gentlemen:

The eighth meeting on Confirmed items and Findings was held on March 28, 1984. A summary is provided to document items discussed and actions agreed upon by the porticipants.

Sincerely, Howard A. Levin Project Manager Midland IDCV Program cc: See Attached Sheet Enclosure 8404060113 840404 PDR ADOCK 05000 g

TERA CORPORATION I

7101 W1SCONSIN AVENUE BETHESDA MAFMAND 20814 301 654 8960

Mr. J. W. Cook 2

April 4,1984 Mr. J. G. Keppler Mr. D. G. Eisenhut ec

Participants:

L. Gibson, CPC R. J. Erhardt CPC D. Budzik, CEC D. Quamme, CPC (site)

R. Whitaker, CPC (site)

D. Hood, NRC J. Taylor, NRC, l&E T. Ankrum, NRC, I&E J. Milhoon, NRC, I&E E. Poser, Bechtel R. Burg, Bechtel J. Agar, B&W J. Korr, S&W (site)

IDCV Program Service List HAL/djb TERA CORPORATION

SERVICE LIST FOR MIDLAto INDEPEPOENT DESIGN Ato CONSTRUCTION VERIFICATION PROGRAM cc Harold R. Denton, Director Ms. Borboro Stamirls Office of Nuclear Reactor Regulation 5795 N. River U.S. Nuclear Regulatory Commission Freeland, Michigan 4,8623 Washington, D.C. 20555 Mr. Wenoell Marshall James G. Keppler, Regional Administrator Route 10 U.S. Nuclear Regulatory Commission, Midland, Michigan 48440 Region til 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Illinois 60137 2120 Corter Avenue U.S. Nuclear Regulatory 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 Parnall Road Jackson, Michigan 49201 Charles Bechhoefer, Esq.

Atomic Safety & Licensing Board Michael I. Miller, Esq.

U.S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D.C. 20555 Three First National Plaza, Sist 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 Safety and Licensing Board U.S. Nuclear Regulatory Commission Ms. Mary Sincla.ir 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 Plaza Lonsing, Michigan 48909 Chicago, Illinois 60602 Mr. Poul Roo Ms. Lynne Bernobel Midland Daily News Government Accountability Project 124 Mcdonald Street 1901 Q Street, NW Midland, Michigan 48640 Washington, D.C. 20009

SUMMARY

OF EIGHTH STATUS REVIEW MEETING ON COWIRMED ITEMS Ato FINDINGS March 28,1984 Midland IDCV Program A meeting was held on March 28,1984 at Bechtel's Ann Arbor, M;chigan offices to obtain additional information related to Confirmed items identified in the February IDCVP Monthly Status Report dated March 16,1984 and to status other outstanding items identified previously. Attachment I identifies the attendees of the meeting which included representatives of TERA, CPC, Bechtel, and NRC. Attachment 2 presents the ogendo issued for the meeting in a notice dated March 20,1984.

Howard Levin, TERA, opened the meeting with a discussion of the agendo. All items noted on the agenda were agreed upon for discussion by the participants; however, the order was modified to improve the flow of the meeting and to utilize resources effectively. While not specifically colled out on the agendo, o discussion of the status of selected construction verification items was added.

The meeting then proceeded with its primary objective which is to ensure that all participants have a complete understanding of the technical issues expressed as Confirmed items and Findings in the February Monthly Status Report. The responsible TERA personnel described each item, followed by discussion by either CPC or Bechtel, who were requested to identify additional information that may have bearing on the issues or to provide clarification which would allow these issues to be dispositioned directly.

The status of previously outstanding Confirmed items and Findings was also discussed, except for those noted in the meeting announcement. The meeting announcement listed certain OCRs os being on hold or that sufficient informa-

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tion is available for TERA to disposition the item. A summary of the significant aspects of the discussion is provided in Attachment 3 olong with any course of oction identified.

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ATTACHMENT l

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MIDLAbD. NUCLEAR PLANT - UNITS I Ato 2 INDEPEtOENT DESIGN htO CONSTRUCTION VERIFICATION PROGRAM OCR STATUS REVIEW MEETING March 28,1984 M.

NAfAE AFFILIATION Rob Burg Bechtel/ Licensing Paul Milward Bechtel/ Site F. A. Dougherty TERA H. Levin TERA G. E. Setka TERA C. Mortgat TERA H. Wang NRC/IE/DOAISP D. F. Lewis Bechtel R. E. Whitaker CPCO/MPQAD R. F. Schofer Bechtel/ Nuclear G. Singh Bechtel/ Control Systems L. Lampson Bechtel/ Nuclear Dave Horvath Bechtel/ Mechanical B. K. Shete Bechtel/ Mechanical Mike Gerding Bechtel/ Control Systems Lou Gibson CPCo A. Amin Bechtel/ Mechanical Al Strunk Bechtel/ Mechanical A. Rajn Bechtel/ Electrical Dennis Kelly Bechtel/ Electrical P. V. Regupathy Bechtel/ Civil V. Vegma Bechtel/ Civil A. Juluo Bechtel/ Electrical i

l S. Rco Bechtel/ Civil Structural l

P. C. Gupta Bechtel/Flant Design C. H. Perron Bechtel/P.O. Staff T. R. Thiruvengadum CPCo b

,g,

ATTACHMENT 2 MIDLAND INDEPENDENT DESIGN AND CONSTRUCTION VERIFICATION PROGRAM AGENDA FOR MARCH 28,1984 OCR STATUS REVIEW MEETING BECHTEL OFFICES AtN ARBOR, MICHIGAN 1.

Estimated Time Start:

9:00 AM Lunch:

12:00 PM to 12:45 PM Adjournment: 3:00 PM 11.

Discussion of Confirmed items, Findings, Observations, and Resolved items item TERA Lead A.

Mechanical / Systems R-026

  • Dougherty Z-043
  • Dougherty C-Il2 Setka R-129
  • Witt C-133 Setka C-144 Witt C-148, Setka B-I S8
  • Dougherty B.

Electrical R-097

  • Witt C-109 Setka C-l 10
  • Setka R-l l I
  • Setka R-132
  • Setka R-134
  • Setka C-l3S Setka C-14 l Setka C-146 Setka C-147 Setka R-153
  • Dougherty B-159
  • Setko 3

ATTACHMENT 2 (continued)

Item TERA Lead C.

Civil / Structural F-015

  • Mortgat R-071
  • Mortgat R-102
  • Mortgat R-103
  • Mortgot R-i l4
  • Mortgat R-i l 6
  • Mortgat B-155
  • Mortgat C-156
  • Mortgot C-157*

Mortgot 111.

Presentation of plans / schedule for response Burg to issues discussed at the March 1,1984, (Bechtel) civil / structural review meeting.

IV.

Discussion of programmatic issues - as required.

V.

Discussion of Action items and Logistics for Information Exchange Notes: 1.

Items are grouped to the degree practical to facilitate discussion and minimize manpower requirements during the entire meeting.

2.

Items that changed status during the February reporting pericd are denoted with an asterisk.

3.

The following OCRs have nnt reached a final disposition; however, further TERA or Midland Project actions have been identified during past public meetings.

Accordingly, discussions are not contemplated by TERA unless the Midland Project has identified new information that is pertinent to the ongoing octivities.

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C-005 F-050 l

C-022 F-052 thru -056 F-031 C-077 F-036 C-084 C-038 C-085 F-047 C-087 thru -089 F

C-048 F-09I l

F-049 C-092 thru -096 l

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ATTACHMENT 3

SUMMARY

OF DISCUSSION OF CONFIRMED ITEMS, FibOINGS, OBSERVATIONS, abo RESOLVED ITEMS 3201-008-F-047 Mr. Paul Milward, Bechtel, led a discussion which provided the project's response to this Finding which pertains to certain inconsistencies observed within the site storage and maintenance programs. He addressed specific TERA information requirements identified during the February 29,1984 IDCVP Status Review Meeting and documented in a letter from Levin to Burg dated March 6,1984.

e Volve 2LV-2975Al:

During the last meeting, TERA indicated concurrence that storage and maintenance activities for control volves would be relatively consistent regardless of the operator and concurrence with the proposed revision to the site storage instruction F1-197.

The additional information requested pertains to clarifying references contained in Bechtel's January 8,1984 response in a letter from Poser to Levin. There oppeared to be o discreponey between the refer-enced document (7220-J225B-54-6), which is on instruction manual for a CCI valve, whereas the installed valve is manufactured by Copes Vulcon. 'Mr. Milward indicated that the wrong document was referenced; however, the proper document contains the same require-ments (i.e., the storage and maintenance program is the some for both the CCI and Copes Vulcan volves).

e Valve 2MO-3965Al:

In their Jcnuary 8 letter, Bechtel indicated their position that the prime vendor, Anchor / Darling, misinterpreted Limitorque's lubrica-tion instructions. TERA indicated at the February 29 meeting that 5

Bechtel's position appears inoppropriate relative to instructions con-toined in Anchor / Darling's instruction manual, Vendor Document

  1. 7220-Mi17-142, page 19, paragraph 4.1, and that it appears these 1

instructions relate specifically to the volve itself and are not related to the operator.

Mr. Milward stated that certain instructions are confusing relative to when specific instructions apply (i.e., in-ware-house, in-place, or in-service). He indicated Bechtel's interpretation that the lube / stroking requirements for the volve and the operator lobe requirements all apply once these components are placed in operation.

e Transmitter 2FT-3969A:

At the February 29 meeting, TERA indicated that taking credit for the functional capabilities of the transmitter is oppropriate for a transmitter which is energized and properly sealed, i.e., a transmitter which is in operation. However, since TERA is oddressing those octivities necessary to maintain proper conditions for a transmitter which was in storage, it would appear that the vendor's recommended storage Instructions should prevail unless a suitable alternative is identified. Mr. Milward indicated that while in storage, transmitters are placed in a " storage level A" humidity controlled environment.

where the humidity level is continually chart recorded..Therefore, individual component control through humidity indicators or desic-conts is not necessary.

Once transported to the general in-plant area, the transmitters cre placed in a local " tented" environment which has dehumidifiers.

The areas are monitored once a week.

Mr. Milward indicated that he had reviewed dato applicable back until March, 1981 and. found the relative humidity to overage approximately 45%

e Air Handling Unit 2VM-54A:

Bechtel's January 8 response indicated that the TRANE Company was responsible for the meggering requirement prior to release from 4

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storage. TERA's investigation revealed that the meggering require-ment was derived from Bechtel's storage instruction in effect at the time the fan motor was released to construction--F-314, Rev.1. At the February 29 meeting, TERA requested information which would serve to reconcile the apparent dis::repancy and those procedures, instructions, etc. used to accomplish the transfer of maintenance responsibility from Bechtel To Zack.

Mr. Milward indicated that motors (such as these) of less than 50 hp were to be meggered at turnover; however, most motors have been subjected to this requirement. TERA found I of 2 which were not.

Bechtel supplied equipment becomes the responsibility of the subcon-tractor (Zock) when released for installation. The material withdraw request (MWR) is the means of notification. Zack is then responsible for maintenance in accordance with their own procedures.

Mr. Lou Gibson, CPC, indicated that the project would document their com-pleted response to this Finding in a transmittal to TERA.

3201-008-F-052 Bechtel indicated that a response was not complete. A schedule will be provided along with the 10-day response to issues discussed at this meeting.

3201 -008-F-049, -050, -055, -056 Levin indicated TERA was awaiting information on these Findings. The project concurred, and it was agreed that the status remains unchanged.

3201-008-F-053 -054 l

Levin indicated that resolution of these Findings was on hold pending recom-mencement of TERA's ICVP octivities.

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3201-008-C-092. -094 thru -096 Levin indicated that TERA has sufficient information to disposition these Confirmed items.

3201-008-C-091, -093 These items were not discussed; however, they remain outstanding.

3201-008-R-026 TERA explained the basis for resolving C-026. There was no further discussion of this item.

3201-008-Z-043 This is a Finding Resolution Report, which was concerned with credit being taken for non-seismic pipe and a check valve following a seismic event.

TERA discussed the basis for this Finding Resolution Report. There was no further discussion.

3201-008-R-129 The basis for resolution of this item was presented by TERA. There was no further discussion.

3201-008-C-112 TERA stated that it received the March 22 submittal by Bechtel which provides a revised calculation for the diesel generator exhaust back pressure. TERA is presently reviewing the revised calculation..

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I 3201-008-C-133 This Confirmed item involves the operability requirements for the pneumatic control system. The initial response by the' project, dated February 24, provided on April 16 date for responding to this item. At the February 29 OCS meeting, 4

it was noted that.TDI has leak rate information which may be of value in resolving this item. Furthermore, it was noted that this item is being reviewed os part of the design and quality review of TDI being performed by CPC. At the March 28 meeting it was agreed that Bechtel will send TERA the available TDI leak rate data which they have. It was noted that this dato octually applies to the SMUD diesel; thus, core must be exercised in using this information. Bechtel also has developed a calculation which may in port resolve this item.

The calculation is in its final review process and should be complete within the next two weeks.

4 3201-008-C-144 1

1 This item is concerned with the assumptions used in piping stress analysis and subsequent calculation.of support. loads.

.The OCR identified differences between the analysis method used by Bechtel and the criteria which the IDVP considers appropriate. Bechtel stated that, although the analysis methods differ between those used on the project and by the IDVP, sufficient margin exists that F

the current design is adequate. Bechtel is initiating a study to demonstrate the j

. odequacy of the current margins. It is estimated that the study will be complete t

in approximately six weeks. TERA requested that Bechtel provide a copy of the program plan document, memorondum, or other similar informatioa.which outlines the scope and opprooch being used for the study.

In response to o question by TERA, Bechtel stated that they may or may not use the SMA study in developing their response to C-144.

3201-008-C-149 '

This. Confirmed ltem is - concerned with the compliance of the plant with

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NFPA-12, which requires de-energizing equ.ipment, such as the fuel oil transfer pumps, in the event of a fire. Further information on this Confirmed item will be provided to TERA before the next OCR meeting.

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3201-008-C-l50 Bechtel stated that a SAR change will be prepared within the next two weeks to clarify the project position on implementation of NFPA requirements.

3201-008-C-148 Bechtel explained the relationship between electrical drawings and orchitectural drawings showing building penetrations and fire seals.

The orchitectural drawings show the as-built condition and are updated periodically. The latest revisions of the drawings which are concerned with the penetrations discussed in this OCR ore dated November 8,1983. TERA will determine whether copies of those drawings have been received.

3201-008-R-097 TERA described the basis for resolving this OCR.

There was no further discussion.

3201-008-C-109 Bechtel has provided a response concerning the fuel lock-out, which TERA is reviewing. TERA stated that no further information is needed at this time.

3201-008-C-l 10 Bechtel will provide a formal response to this Confirmed item concerning Rev. I of the load tabulation within two weeks. Bechtel stated that they will. provide on advance copy following the meeting.

3201-008-R-l i I This item was resolved based on the receipt of a SAR change notice. There were no questions concerning this resolution.

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3201-008-R-132

-TERA noted that the documentation concerning the undervoltage set points has been updated and made consistent with the FSAR. No further discussion was held concerning this Resolved item.

3201-008-R-134 TERA presented the basis for resolving this Confirmed item regarding the LOP sequencer. No questions were raised concerning this resolution.

3201-008-C-135 Bechtel has provided a response concerning the conformance of interlocks to IEEE-308. TERA will determine the appropriate action to take.

3201-008-C-141 This Confirmed item is concerned with the air quality requirements for the air supplied to the air receiver. Bechtel stated that the specification for the diesel generator is functional, and thus it is up to the vendor to determine air quality requirements. TERA noted that the specification was modified to account for the air system offer the diesel was procured.

Bechtel maintains that the performance of the air supply is within TDl's responsibility, and that the vendor has provided filters and dryers for the air system. Bechtel further stated that they have reviewed the system provided by TDI.

TERA will review vendor Information on system performance.

3201-008-C-146 Bechtel stated that the redundancy in the diesel generator systems provides assurance of the acceptability of postulated failures. They further stated that common mode failure is not a design basis for the plant, and that factors such as maintaining air quality minimize the potential for such failures. TERA ques-tioned whether the FSAR is in error, in that the diesel generator and pneumatic 11

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control system were not included in the list of pneumatic systems which the g

project provided to the NRC in response to a question. TERA further asked whether a failure modes and effects analysis should be provided in the event that it is determined that the pneumatic control system should have been listed in response to the NRC question. Bechtel will investigate whether it, would be appropriate to include the diesel pneumatic control system in the list of pneumatic systems, and consequently whether a failure modes and effects analysis should be provided.

3201-008-C-147 This Confirmed Item noted that the Er second response time of the ESFAS system was not included in occident response times. Bechtel stated that the B&W BOP criterio documents call for the diesel' generator to stort within ten seconds of the engine's receipt of the stort signal.

The B&W criteria also call for allowances to be mode for response times. Bechtel stated they were aware of this situation and had reviewed it previously. Bechtel further stated that a SAR change notice would be needed.

3201-008-R-153 This item was fully discussed at the' Confirmed item stage at the previous OCR meeting. -During that meeting, Consumers Power Company explained that the demarcations on the J-909 drawing did not represent the steam generators, os TERA had assumed. -With this explanation, TERA was able to classify this OCR

. as resolved.

. 3201-008-C-l56 TERA described how it calculated loads on the embedded channel, which resulted in this Confirmed item stating that the calculated loads appear to exceed the allowable. Bechtel stated that a response is scheduled for April 13.

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3201-008-C-157 Calculation SG-148-K(Q) was issued in response to a previous OCR. TERA's review indicated that this calculation contained on error. TERA stated during the meeting that the error is considered to be minor. However, this calculation calls into question the checking process used on the project. Bechtel stated that they would respond by April 13 with a description of the checking process.

Other Civil / Structural items Bechtel reviewed their expected response dates for all outstanding civil /struc-tural and civil / soils OCRs. During this discussion, it was noted that TERA will provide a clarification of item number 8 of OCR 3201-008-C-104. The following table presents the scheduled response dates for civil / structural and civii/ soils OCRs.

SCIEDULE FOR civil OCRs Scheduled OCR #

Response

Civil / Structural 069 4/20 099 (items 1,2) 4/20 104 (3,6) 4/20 104 (8) later 107 (2) 4/20 108 (1, 2, 6, 7, 8) 4/20 117 (IB) 4/6 l

l l 9 (2, 3) 4/20 Civil / Soils 117 (2, 3) 4/13 117 (4) 5/2 101 4/26 130/131 4/26 125 5/2 13

e 3201-008 F-015 TERA has converted Confirmed item C-015 Into a Finding. This issue deals with the consideration of floor flexibility in the seismic analysis. TERA explained its basis for making this a Finding. Consumers Power Company stated tha,t they had discussed this issue with the NRC previously and had clearly stated that floor flexibility was not considered a design basis for the plant. TERA indicated that while the project's commitments represent an important yardstick for measuring implementation of the design, an evaluation of the adequacy and completeness of criteria is part of the IDVP review.

In TERA's view, this phenomena con potentially have a significant effect on the performance of certain components during an earthquake. Therefore, a determination should be made as to the safety significance of this issue to the Midland plant. TERA indicated that a basis was not provided in a Bechtel study referenced in the Finding, and that an SMA study establishes that floor flexibility con lead to significant additional amplification of response. CPC pointed out that SMA essentially has completed a current day "SRP" seismic analysis that considers the flexibility of floors and the impact on response and equipment qualification. It was concluded by CPC and TERA that the SMA study may provide additional information that would be useful in qualifying the significance of this Finding. A future meeting will be held to review the SMA seismic margins analysis and its applicability.

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