ML20091P361
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7 h m eda, Maryland (LOCATION)
Anril 16. 1982 (DATE)
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Darl S. Wood
, hereby make the following
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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 l
been made to me.
.PS// On March 10, 1982, I attended a meeting in Bethesda, Maryland with other NRC, Consumers Power Company (CPCo), and Bechtel personnel to discuss quality assurance to be applied to remedial foundation work at the Midland Plant.
Units 1 and 2.
A summary of this meeting, dated March 12, 1982, was sub-i 3
sequently issued under my signature.
I also attended a meeting on March 30, 1982, in Glen Ellen, Ill. with other NRR,-Region III, and CPCo personnel regarding earlier observations of Region III inspectors that ca$>1e pulling for monitoring instrumentation to be relied upon during underpinning con-struction of the Midland Auxiliary Building was not being performed in accordance with appropriate quality requirements. The purpose of this state-ment is to describe my recollection of statements during the March 10 and March 30, 1982, meetings to whether installation of underpinning monitor-i-
ing instrumentation was t
-listed.
p.5N As noted in the March 12, 1982, sun..iary report of the March 10 meeting, CPCo l
and Bechtel proposed a new desig ion of "QA" for certain underpinning work on the basic premise that adver mpact to the structure from this temporary work would only affect CPCo's ability to obtain a license, and would not psn impact public health and safety. The proposal, however, as described by Mr. A. Boos of Bechtel on behalf of CPCo was that a monitoring program to determine the affect on safety-related structures of all work, including temporary loads, would be in place and would be "Q".
Following a caucus y
to consider the proposal, I advised CPCo that the NRC does not accept the i
"QA" classification, and that "from this point forward", March 10, 1982, all C
further underpinning activities are to be Q-listed except for very specific items which can be shown on a specific basis to justify non-Q treatment. I further stated that NRC concurrence in this justification must be obtained prior to conducting any work efforts completely outside the quality plan.
In the March 12, 1982, sumary report, the term "NRR" is used, rather than "NRC".
At the March 30, 1982, meeting I identified this error and reiterated
.that the March 10, 1982, discussion had identified this as a Region III lead I-item.
i' Mr. Mooney of CPCo asked if this position applied to " Phase I" activities which had already been approved by the NRC, and he noted that "certain activities are now in process". Mr. A. Boos also stateo this meant they would have to imediately stop work.
I replied that by "from this point forward", I did not mean to include Phase I since the staff had already approved that on a non-Q basis, and that I was aware that installation of the vertical access shaft was well underway. Rather, I continued, I meant the position to begin with the start of Phase 2.
Other than the possibility g [f l
p;/t 36 e40517 Page 1 of 1 pages.
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i Continuation of Statement of Darl S. Hood 38/f of Mr. Mooney's coment that "certain activities are now in process" (which I took to be directed to installation of the vertical assess shaft). I do not recall any statement, on March 10, 1982, that instrumentation was to be other than Q or that CPCo considered this to be part of Phase 1.
I do not recall any discussion at the March 10th meeting regarding the status of instrumentation installation.
On March 18, 1982, I'was at the Midland site along with Messrs Joseph Kane and Frank Rinaldi of NRR to observe and discuss cracks in the Diesel G1Lnerator i
Building. Mr. Kane and I observed the location of a deep seated benchEar) DJ /f being relocated inside the Auxiliary Building which had encountered artepsian p.S if pressure. We were told that the new location had not been established at that time. We also met briefly with Messrs. R. Landsman, R. Gardner, and R. Cook of Region III who infomed us that underpinning instrumentation was being l
installed without Q listed cable pulling procedures and that they had called their Region III Office about issuance of an Imediate Action letter.
Mr. Landsman also stated that he had been told by CPCo personnel that installation of the instrumentation was in progress during the March 10, 1982, meeting and therefore was not subject to the NRC position given at that meeting.
i Mr. Landsman said that this statement by CPCo personnel was not accurate. He had also been told that CPCo planned to perform a post-installation check and
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J that CPCo considered this to be sufficient. Mr. Landsman then asked me if I would support a decision to issue an Immediate Action letter to stop the work.
I replied that installation without Regions III's previouse concurrence of non-Q status was inconsistent with the NRC's March 10, 1982, position since the instrumentation is part of Phase 2, and that I would support his decision on this basis. I also replied that whether a post-installation check was t-sufficient was up to Region III, and that NRR's position is that the monitor-t i
ing instrumentation must be both reliable and accurate.
l On March'30, 1982, I attended a meeting at the Region III Offices, Glen Ellen, 4
Ill. with other NRR, Region III and CPCo personnel to discuss Region III's f
concern on this instrumentation matter. During this meeting Mr. J. Cook of
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CPCo indicated he considered installation of the instrumentation to be part of Phase 1.because NRR had previously stated that instrumentation must be in place and operational before beginning Phase 2.
Mr. J. Cook's statement appears to be consistent with the title of Enclosure 1 of Mr. R. Tedesco's letter of l
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March 22, 1982.
R. Tedesco's letter of March 22, 1982, " Compilation of Infor-mation Requested for Completion of Staff Review of Phase 2 Underpinning of Midland Auxiliary Building" forwards an Enclosure 1 entitled " Identification I
of Review Concerns Prior to Initiating Phase 2 Underpinning Work Midland-Auxiliary Building". Page 1 of that enclosure (which documents earlier, identifieddiscussions) lists,inpart:
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CPC commitment to have 6 deep seated bench marks with instruments installed and operational before beginning Phase 2a work.
(Telephone record, March 8,1982, Par. 4.8 and Par. 5). Also instruments DMD-1W, DMD-1E, DSB-1W, DSB-1E are to be installed and operational. (Feb.3-5DesignAudit).
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of Page 2 of 3
Pages.
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' Continuation of Statement of Darl S. Hood i,
l I replied to Mr. J. Cook that this interpretation was not what had been intended.
It was the NRR's intent that the instrumentation be in place and operating before any excavation beneath structures comences. Moreover, activities associated with installation of the vertical assess shaft was part of Phan 1 and activities associated with excavation beneath structures (the Turbine Building and Feedwater Isolation Valve Pits) was Phase 2.
Hence, it was the NRR's intent th'at instrumen-tation be installed under the Quality Assurance program ant', operating as the initial step of Phase 2.
On the basis of Mr. J. Cook's statement of March 30, 1981., I am now of the opinion that miscommunication occurred between NRR and CPCo with respect to whether the instrumentation was required by NRR to be Q-listed and that this apparently con-pflt tributed to CPCo's decision to pull the cables without Q-listed procedures.-
2 NSh I have read the foregoing statement consisting of 1
pages.
I have made any necessary corrections, and I have initialed those corrections. This statement is the truth to the best of my knowledge and belief. I declare under the penalty of perjury that the foregoing
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is true and correct. Executed on
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UNITED STATES a o
NUCLhAR REGULATORY COMMISSION 3
g WASHINGTON, D. C. 20555 4j
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MAR 2 21962 M
i Docket Nos: 50-329/330 OM, OL
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Mr. J. W. Cook Vice President j
Consumers Power Company 1945 West Parnall Road.
Jackson, Michigan 49201
Dear Mr. Cook:
Sub. ject: Compilation of Information Requested for Completion of Staff Review of Phase 2 Underpinning of Midland Auxiliary Building Pursuant to the request of Mr. J. Mooney of your Company on March 11, 1982, is a compilation of the infomation needed for completion of
-the NRC's review of " phase 2" of the construction activities for underpinning of the Midland Auxiliary Building. " Phase 2" is defined by the Construction Sequence Logic Diagram provided the staff during a January 18-19,1982 audit meeting (Enclosure 1 of our meeting sumary dated March 10,1982), and generally provides for further deepening of the vertical access shaft, construction of limited drifts under the Feedwater Isolation Valve Pits (FIVPs) and-Turbine Building, and installation of certain piers.
Your prompt attention to these matters should provide for staff concurrence with minimal impact to your present construction schedule'.
The reporting and/or recordkeeping requirements contained in this affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, I.
hYED.wc2 Robert L. Tedesco, Assistant Director for Licensing I
Division of Licensing
Enclosure:
As stated i
cc: See next page 4
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MIDLAND.
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Mr. J. W. Cook Vice President Consumers Power Conpany 1945 West Parnall Road Jackson,' Michigan 49201 I
cc: Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.
Division of Radiological Health..
- Alan S. Farnell, Esq.
Department of Public Health
.Isham, Lincoln & Beale P.O. Box 33035 I
Suite 4200 Lansing, Michigan 48909 1 First National Plaza i
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Chicago, Illinois' 60603 William J. Scanlon, Esq.
2034 Pauline Boulevard James E. Brunner, Esq.
Ann Arbor, Michigan 48103 Consumers Power Conpany 212 West Michigan Avenue U.S. Nuclear Regulatory Connission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Midland,MicSt'gan 48640 Ms. Mary Sinclair 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris l
5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Conpany 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Walt Apley Route 10 c/o Mr. Max Clausen
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Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
i Mr. Roger W. Muston SIGMA IV Building Suite 220 Richland, Washington,99352
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7910 Woodmont Avenue i
l Bethesda, Maryland 20814 Mr.1. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory i
Nuclear Power Generation Division 9700 South Ca,ss Avenue 1
' Babcock & Wilcox Argonne. Illinois 60433 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Conmiss.1,on,.
Cherry & Flynn Region III-1 799 Roosevelt Road Suite 3700 Three First Nationai Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Steve Gadler t
2120 Carter Avenue St. Paul, Minnesota 55108 j
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T Mr. J. W. Cook '
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cc: Commander, Naval Surface Weapons Center ATTN:
P. C. Huang White Oak
- ~ Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center.
P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers r
NCEED - T 7th Floor
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477 Michigan Avenue Detroit, Michigan 4822G Charles Bechhoefer, Esq.
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i Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission g
Washington, D. C.
20555 e
Mr. Ralph S. Decker Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission i
Washington, D. C.
20555 f
Dr. Frederick P. Cowan Apt. B-125 r
6125 N. Verde Trail t
Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commissio.n
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. Washington, D. C.
20555' Geotechnical Engineers, Inc.
r ATTH: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 E
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Identification of Review Concerns Prior to Initiating Phase 2 Underpinning Work Midland - Auxiliary Building
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GEOTECHNICAL EN'GINEERING
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.. Phase 2a*
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Review Concern
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Submitt'al of. Updated Construction Sequence Drawing (Ident
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~in Feb. 3-5 Audit and Feb. 26.,.1_.982 Meeting).
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Letter docismenting actual work', to be performed under Phas (telephone record, March 8,1982,' Par'. 3).
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comitment not to proceed with 2b until the
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Zi by NRC Staff.
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Update drawing of " Monitoring Matrix", No. C-1493(Q) th
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include tolerance criteria -(Telephone record, Mar. 8.1982, 3.
-Par. 4.b).
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CPC comitment to have 6 deep seated bench marks with instr
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installed and operational before beginning Phase 2a work.
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Also
.(Telephone record, March 8,1982, Par. 4.B and operational.
(Feb3-5 Design-Audit).
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Submittal of strain gage installation details 9 El 659 withmee limiting strain valves and basis (Feb. 26, 1982 5.
telephone record, Mar. 8,1982, Par 4.d).
n Comitment to perforri test load above design load (e.g.,1.3D
.,2, times)*on installed pier to develop load-deflection curveIdentify pi 1
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for verification of hard clay soil modulus.
(Feb.3-5DesignAudit).
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Submittal of' measures to be required during periods of. work 7.
shutdown to support faces of drifts'and' bottoms of pits (Feb.3-5DesignAudit).
L Submittal of plans for dewatering localized water.po'ckets (e.g., placing wells in sand fill around reactor perimeter 8.
advance of pit construction (Feb. 3-5 Design Audit).
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i l-I Phase 2a items are those not impacted by analyses of the'ch i
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. modulus values beneath the main, Auxiliary Building.
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Phase 2b No, _
Review' Concern 1.
Provide instrumentation details and horizontal movement tolerance,,
l criteria with basis, for 3 instruments to be insta11'ed at top of.
EPA's and Control Tower (Telephone record, March 8,1982, j
Par. 4.c and Par. 5).
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Submittal of results from analysis that establishes induced stresses at El 659 assuming EPA is supported by first temporary support (Pier W8) and using Existing Soil Springs under EPA and Control Tower and Auxiliary Building (Feb. 3-5 Design Audit) 3.
Commitment by CPC to have installed and operational all of the remaining instrument.s identified on Drwg C-1493(Q).
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II. STRUCTURAL ENGINEERING (Phase 2a) l l
Strain gauges or equivalent shall be provided at critical locations, l
, including:
a.
Elevation 659' slab b.
Control Tower shear wall c.
Slabs and walls near pcst-tensioning cables at the Control Tower and Electrical Penetration Areas d.
Steel beams shall have st ain gauges,.and not deflection meters.
Information shall be provided for these gauges regarding:
1.
Location 2.
Monitoring frequency 3.
Limits (initial and distress points) 4.
Evaluations of results (method and acceptance criteria) 5.
Commitment that instruments shall be in place and operational before beginning Phase 2a.
III. MECHANICAL ENGINEERING BRANCH (Prior to drifting beneath FIVP)
Allowable movements shall be based upon total settlements since 1.
~the main feedwater piping was first installed in 1977.
2.
- A commitment that the 2" steam generator drain lines shall first be shown not to be limiting for allowable structural movements in the event a decision should be made to connect this piping prior to completion of underpinning.
IV. QUALITY ASSURANCE Applicant shall notify NRC that all underpir.af ng construction will be Q listed consistent with the NRC Staff's findings during the meeting of March 10, 1982.
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