ML20091P348
| ML20091P348 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/28/1982 |
| From: | Boos A BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-08, CON-BOX-8, FOIA-84-96 NUDOCS 8406130030 | |
| Download: ML20091P348 (3) | |
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(LOkT i'
May 28, 1982 l
(DATE) f
$$ I, Alan J.
Boos hereby make the following statement to Charles H.
Weil
, who has identified himself to me as an Investigator of the United States Nuclear Regulatory Commission.
I make this statement freely with no threats or promises of reward having been made to me.
I am an Assistant Project Manager for Bechtel Power Corporation i
on the Midland Project.
This statement describes the events which occurred during a March 10, 1982, meeting with the NRC and 4
a subsequent March 12, 1982, telephone conference call.
Prior to the March 10, 1982, meeting in Bethesda, Maryland, it had become apparent that there was some confusion between Consumers Power Company, Bechtel, the NRR and NRC Region III, personnel as to what parts of the Auxiliary Building underpinning work were to be "Q" listed (under the Quality Assurance Program).
The March 10, 1982, meeting in Bethesda was an attempt to clarify this issue.
Consumers Power, as supported by Bechtel, presented its rationale as to which -elements of the Auxiliary Building underpinning work were to be "Q" listed.
In brief summary, these were the checkout and operation of the underpinning instrumentation system, as well as the installation of the final underpinning.
To the best of my recollection, there was no discussion of the components of the instrumentation system (e.g.,
cable, protective covers, data room) or the status of completion for this work.
A large portion of the temporary underpinning, e.g.,
installation of temporary piers underneath the Electrical Penetration Areas, was felt to be Non "Q";
however, Consumers Power committed to apply a Quality Assurance Program to this l
work, with the exception that they felt that the enforcement i
requirements of 10CFR50 Appendix B need not be applied to this work.
Other activities, e.g.,
procurement of wooden lagging, were considered to be Non "Q".
I The NRC listened to Consumers Power's presentation and, after a luncheon break, presented its position.
In'brief summary, NRR's Darl Hood stated that all underpinning activities were to be "Q"
listed unless Consumers Power could demonstrate to the satisfaction of the NRC that the item should be Non "Q".
In making this statement, Mr. Hood reviewed the position presented by Consumers Power.
I then inquired as to the effective date of the NRC's policy, since certain activities were currently underway and were being done as Non "Q" work.
Mr. Hood replied I
that the effective date for enforcement of this policy would b the start of Phase II of the underpinning work.
Bechtel 8406130030 840517 PDR FOIA Page 1 bf 3 Pa s
_ RICE 84--96 PDR 6y#2GI7'
s questioned the NRC on whether they felt a commodity like wooden lagging should be procured Non "Q".
This was an attempt to get a feeling for what items the NRC would accept as being Non "Q".
The NRC responded to this query by stating that the wood lagging could be purchased Non "Q".
. During the March 10, 1982, meeting, Consumers Power Company inquired as to whether the NRC would assign a resident inspector from Region III to the Midland jobsite to provide coverage for remedial soils work.
This request, which also had been made 4
previously, was made in an attempt to establish better.ines of communication with Region III.
Mr. Hood stated that t' e NRC's inspection and enforcement program for the remedial soils work would be conducted under a " business as usual approach", which meant that there would be periedic audits.
There were no plans i
to assign a resident inspector for this work.
i Immediately after the March 10, 1982, meeting, Mr. Jim Mooney, j
Consumers Power Company Executive Manager for the Midland Project, and myself discussed the urgent need to develop a listing of those Non "Q" activities which had been completed, were underway, or were proposed as future work.
This was in keeping with Mr. Hood's policy that the Consumers Power Company was to receive concurrence from the NRC on items it planned to undertake as Non "Q" work.
We felt it was important to reach a concurrence with the NRC on this listing since we were unable to predict when the NRC would conduct an audit and because it was not in the best interest of either Consumers Power or the NRC to leave the resolution of this list until such an audit.
To this end, on the morning of March 12, 1982, Messrs. Mooney, Boos, and other representatives of Consumers Power, Bechtel, and Mergentime (the underpinning subcontractor) developed a matrix of Non "Q" activities which were either underway or proposed.
This matrix included the underpinning instrumentation system.
An additional list was prepared which identified those work activities which had been completed as Non "Q".
On the afternoon of March 12, 1982, a conference call was held between Messrs. Landsman and Boyd of the NRC Region III office in Chicago, and Messrs. Mooney, Boos, Don Horn (Consumers ' MPQAD) and others, to present the aforementioned matrix to Messrs.
}
Landsman and Boyd.
Mr. Ron Cook, NRC Site Representative, l
participated in the call.
The intent of this call was to allow Consumers Power to present the matrix for the NRC's review and, hopefully, concurrence.
The conference call was intended to be an overview of those items which could be Non "Q" and was not intended to include a detailed schedule presentation.
Since Messrs. Landsman and Boyd did not have a copy of the matrix, we outlined it to them.
A transcript of this call was made with the knowledge of Messrs. Landsman, Boyd and Cook N i
1 Page 2
. 3 Pages
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7 Subsequent to this call, a question has arisen as to whether I made misleading statements with respect to the status of the instrumentation system installation.
On the 5th page of the transcript, I
introduced the
.i'nstrumentation subject.
Our position was that the raceway, electrical wire and brackets that would accept the instrumentation would be procured and installed as Non "Q".
I further stated that the checkout of the system and the taking of I
readings would be "Q" This position was consistent with the i
presentation which Consumers Power made during the March 10, 1982, meeting in Bethesda.
This was a statement of policy, not I
of status of completion of the work.
My comment pursuant to status of completion can be found on Page 6 of the telephone call transcript wherein I stated that, "Our instrumentation is essentially well underway.
Wiring has been pulled - raceway has been installed, etc."
This was not a statement that the work was complete, rather that the work was underway.
In fact, at the time I made those statements, I did not have detailed knowledge of the exact percentage of completion of each activity.
I had received status information on a continuing basis as to which activities were underway or completed but do not recall having exact knowledge as to percentages of completion.
It should also be reiterated that the purpose of this call was to inform the NRC as to the items which we felt could be Non "Q".
In conclusion, I feel that my statements in the March 12, 1982, conference call were accurate.
My statements were not intended to mislead the NRC or to indicate that all instrumentation activities were complete.
I have read the foregoing statement consisting of 3 pages.
I have made any necessary correction, and I have initialed those l
corrections.
This statement is the truth to the best of my
'l knowledge and belief.
I declare under the penalty of perjury that the foregoing is true and correct.
Exe ted on
~May 28, 1982 at //.WS A.M..
(Date)
(Time)
Ws-3 n nature) 777 East Eisenhower Parkway Ann Arbor, Michigan (Address)
Subscribed and sworn to before me this 28th day of May 1982 at Midland, Michigsgr
- Mdfdf m.
j Charle's H. Weil, Investigator US-NRC Region III, Glen Ellyn, IL g.
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