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DISTRIBUTION-AUG 2 71992 0 cumet control RHernan (50-329/330)
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DEisenhut/
MEHORANDUM FOR:
J. P. Knight, Assistant Director fo ~
EAdensam "
Purple Components and Structures Engineering FROM:
T. M. Novak, Assistant Director for Division of Licensing
SUBJECT:
CSE INPUT TO filDLAhD SSER f2 Your memorandum of August 16, 1982 forwarded the CSE input for Midland SSER #2 documenting conclusion of the staff's lengthy review of soils settle m nt probleas. As you know, the staff's review in this area has been without precedence, not only in tems of manpower and consulting resources, but also in tems of review detail due to the uniqueness, extent and complexity of the soils problem and its solution. The issue has been one of high exposure throuohout the industry since Mid-1970 and the SSER will undoubtedly be of interest to a wide and varied audience. Documentation of this staff review, therefore, will have special significance as a record and reference source, both now and in the future, in addition to its significance as a principal hearing document.
Undoubtedly, such a docunent should reflect the highest possible Quality in its description of the extent, substance, standards, conclusions and bases of staff review.
I am aware that the August 16 inputs were prepared to severe time restraints, and that a better record could be established given additional time. Having reviewed this input, I agree more time should be taken.
As a first step in this direction, DL and technical editors have made sone improvements to the August input by the enclosed SSER. However, much more is needed to produce the final. report that this special review deserves.
The Enclosure identifies some of the deficiencies about which we have con-cerns. Ve are continuing to review the enclosed SSER to identify more specific areas where improvement is needed, and will provide these to your staff when we are completed with this effort. However, we ask that you provide DL with modifications of the attached SSEP draft that respond to these concerns on an expeditious basis consistent with fulfilling our needs.
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc.
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ENCLOSURE COMMENTS ON MIDLAND SSER #2 l.
Each of the licensing conditions previously identified for staff approval of the Auxiliary Building should be covered by the SER (see Table A-20 in staff's testimony at December 3,1981 Hearing, Transcript 5839, as corrected at pp. 5820-5821).
2.
Underground piping should cover the open items from 02/18 & 02/19/82 hearing.
3.
Writeup needed describing seismic margin study, status and staff position on applicant's ongoing effort.
4.
Several sections in 3.8, and some elsewhere, refer to applicant's calculations (sometimes at an audit) as the basis for staff acceptance, but gives no discussion of that calculation sufficient to establish it's basis of acceptance. This deficiency is particularly acute because the referenced calculations are not part of the published record.
5.
No clear account of the construction activities au orized by the SSER is given as directed by the Board (May 7,1982 Orde 6.
Several areas need conclusions and bases.
7.
The sliding analysis for the SWPS is not addressed.
8.
Several items (see SSER Section 1.7 for summary) remain open for which little additional effort appears to be needed (a phone call) to close them out. Also, some of the " soils settlement" open items from 1.7 of the SER are not addressed.
9.
Some items identified at the front of the writeups as having been reviewed are not subsequently discussed.
- 10. Section 3.9 on underground piping needs to be reorganized and restructured for easier reading. An example of this problem is given on SSER page 3-32:
"(9) The nonitoring programs of (6) - (8) above will provide the same assumption as (5) above."
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AUG 2 71982 MEMORANDUM FOR:
J. P. Knight, Assistant Director for Components and Structures Engineering FROM:
T. M. Novak, Assistant Director for Division of Licensing
SUBJECT:
CSE INPUT TO MIDLAND SSER #2 Your memorandum of August 16, 1982 forwarded the CSE input for Midland SSER #2 documenting conclusion of the staff's lengthy review of soils settlement problems. As you know, the staff's review in this area has been without precedence, not only in terms of manpower and consulting resources, but also in terms of review detail due to the uniqueness, extent and complexity of the soils problem and its solution. The issue has been one of high exposure throughout the industry since Mid-1978 and the SSER will undoubtedly be of interest to a wide and varied audience. Documentation of this staff review, therefore, will have special significance as a record and reference source, both now and in the future, in addition to its significance as a principal hearing document.
Undoubtedly, such a document should reflect the highest possible quality in its description of the extent, substance, standards, conclusions and bases of staff review.
I am aware that the August 16 inputs were prepared to severe time restraints, and that a better record could be established given additional time. Having reviewed this input, I agree more time should be taken.
As a first step in this direction, DL and technical editors have made some improvements to the August input by the enclosed SSER. However, much more is needed to produce the final report that this special review deserves.
The Enclosure identifies some of the deficiencies about which we have con-cerns. We are continuing to review the enclosed SSER to identify more specific areas where improvement is needed, and will provide these to your staff when we are completed with this effort. However, we ask that you provide DL with modifications of the attached SSER draft that respond to these concerns on an expeditious basis consistent with fulfilling our needs.
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: See next page t
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ENCLOSURE l
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' COPMENTS ON MIDLAND SSER #2
- l.. Each of the licensing conditions previously identified for staff-approval of the Auxiliary Buildir.g should be covered by the SER (see Table A-20 in staff's testimony at December 3,1981 Hearing,-
Transcript 5839, as corrected at pp. 5820-5821).
-2. ' Underground piping should cover the open items from 02/18 & 02/19/82 hearing.
3.
Writeup needed describing seismic margin study, status and staff Position on applicant's ongoing effort.
4.
Several sections in 3.8, and some elsewhere, refer to applicant's calculations (som6 times at an audit) as the basis for staff acceptance, but gives no discussion of that calculation sufficient to establish it's basis of acceptance. This deficiency is particularly acute because the referenced calculations are not part of the published
- record, t
5.
No clear account of the construction activities au horized by'the SSER is given as directed by the Board (May 7,1982 Orde 6.
Several areas need conclusions and bases.
7.
The sliding analysis for the SWPS is not addressed.
8.
Several items (see SSER Section 1.7 for summary) remain open for which little additional effort appears to be needed (a phone call) to close them out. Also, some of the " soils settlement" open items from 1.7 of the SER are not addressed.
9.
Some items identified at the front of the writeups as having been reviewed are not subsequently discussed.
- 10. Section 3.9 on underground piping needs to be reorganized and restructured for easier reading. An example of this problem is given on SSER page 3-32:
"(9) The monitoring programs of (6) - (8).above will provide the same assumption as (5) above."
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~M. Fliegel W. Paton E. Adensam
_D. Hood R. Hernan '
R. Gonzales
'H. Singh, COE S.,Poulos, GEI 4
J. Kane G. Harstead J. Matra.
F. Rinaldi H. Brammer P. Chen 9
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. 1 AUG 2 71982 MEMORANDUM FOR:
J. P. Knight, Assistant Director for Components and Structures Engineering FROM:
T. M. Novak, Assistant Director for Division of Licensing
SUBJECT:
CSE INPUT TO MIDLAND SSER #2 Your memorandum of August 16, 1982 forwarded the CSE input for Midland SSER #2 documenting conclusion of the staff's lengthy review of soils settlement problems. As you know, the staff's review in this area has been without precedence, not only in terms of manpower and consulting resources, but also in terms of review detail due to the uniqueness, extent and complexity of the soils problem and its solution. The issue has been one of high exposure throughout the industry since Mid-1978 and the SSER will undoubtedly be of interest to a wide and varied audience. Documentation of this staff review, therefore, will have special significance as a record and reference source, both now and in the future, in addition to its significance as a principal hearing document.
Undoubtedly, such a document should reflect the highest possible quality in its description of the extent, substance, standards, conclusions and bases of staff review.
I am aware that the August 16 inputs were prepared to severe time restraints, and that a better record could be established given additional time. Having reviewed this input, I agree more time should be taken.
As a first step in this direction, DL and technical editors have made some improvements to the August input by the enclosed SSER. However, much more is needed to produce the final report that this special review deserves.
The Enclosure identifies some of the deficiencies about which we have con-cerns. We are continuing to review the enclosed SSER to identify more specific areas where improvement is needed, and will provide these to your staff when we are completed with this effort. However, we ask that you provide DL with modifications of the attached SSER draft that respond to these concerns on an expeditious basis consistent with fulfilling our needs.
v Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: See next page
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ENCLOSURE COMMENTS ON MIDLAND SSER #2 1.
Each of the licensing conditions previously identified for staff
. approval of the Auxiliary Building should be covered by the SER (see Table A-20 in staff's testimony at December 3,1981 Hearing, Transcript 5839, as corrected at pp. 5820-5821).
2.
Underground piping should cover the open items from 02/18 & 02/19/82 hearing.
3.
Writeup needed describing seismic margin study, status and staff position on applicant's ongoing effort.
4.
Several sections in 3.8, and some elsewhere, refer to applicant's calculations (sometimes at an audit) as the basis for staff acceptance, but gives no discussion of that calculation sufficient to establish it's basis of acceptance. This deficiency is particularly acute because the referenced calculations are not part of the published record.
5.
No clear account of the construction activities au orized by the SSER is given as directed by the Board (May 7,1982 Orde 6.
Several areas need conclusions and bases.
7.
The sliding analysis for the SWPS is not addressed.
8.
Several items (see SSER Section 1.7 for summary) remain open for which little additional effort appears to be needed (a phone call) to close them out. Also, some of the " soils settlement" open items from 1.7 of the SER are not addressed.
9.
Some items identified at the front of the writeups as having been reviewed are not subsequently discussed.
- 10. Section 3.9 on underground piping needs to be reorganized and restructured for easier reading. An example of this problem is given on SSER page 3-32:
"(9) The monitoring programs of (6) - (8) above will provide the same assumption as (5) above."
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DISERIBUTION
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(50-329/330)
DHood PRC System TNovak LBf4 Reading DEisenhut8 HE!VRANDUM FOR:
J. P. Knight, Assistant Director fo" EAdensam Purple Components and Structures Engineering FRCH:
T. M. Novak, Assistant Director for Division of Licensing
SUBJECT:
CSE IMPUT TO MIDLAND SSER !2 Your cenorandum of August 15, 1982 forwarded the CSE input for 'if df and SSER 42 <focunenting conclusion of the staff's lengthy review of soils settlenent problems. As you know, the staff's review in this area has been without precedence, not only in terms of manoower and consulting resources,.
but also in tems of review detail due to the uniqueness, extent and complexity of the soils problem and its solution. The is:ue has been ene of high exposure throughout the industry since Mid-1978 and the SSER will undoubtedly be of interest to a wide and varied audience. Docunentation of this staff review, therefore, will have special significance as a record and reference scurce, both now and in the future, in addition to its significance as a principal hearing document.
Undoubtedly, such a docueent should reflect the highest possible cuality in its description of the extent, substance, standards, conclusions and bases of staff review.
I am aware that the August 16 inputs were preoared to severe titt restraints, and that a better record could be established given additional time. Itaving reviewed this input, I agree more time should be taken, e
A's a first step in this direction, DL and technical editors have made some improvements to the August input by the enclosed SSER. !!owever, nuch nore is needed to produce the final report that th.is special review deserves.
The Enclosure identifies some of the deficiencies about which we have con-
'le are continuing to review the enclosed SSER to identify nore cerns.
specific areas where improvement is needed, and will provide these to your staff when we are completed with this effort. However, we ask that you provide OL with codifications of the attached SSER draft that respond to these concerns on an expeditious basis consistent with fulfilling our needs.
Thomas M. Movak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated 2-b 'WC 3 WJ Y DL:LBf4 DL:LBf4 DL:L DHood:h:
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"EMORANDUP FOR:
J. P. Knight, Assistant Director for Components and Structures Engineering FROM:
T. M. Povd Assistant Director for Division of Licensing SUBJr.CT:
' CSE D:PbT TO !!IDLAno SSER 32
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Your cerorandun of August 16, 1992 forwarfed the CSE input for fif dland SSER tr2 dccutenting conclusion of the staf f's lengtily review of soils
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settlenent problens.. As you know, tre staff's review in this area has bee'n without precedence, not only in terms of nanpower and consulting rescurces, but also in-ter'as of review detail due :;o the unicueness, extent and c6colexity of the soils prnblen and its slution.' Th'e issue has been one of high excesure throughout the industry since "id-1978 and the SSER will undoubtedly be of interest to a wide and varied audience. Decumentation of this staff review, thereforehwill have special significance as a record i{
and reference source, both now and in the future, in addition to its significance as a orincipal hearin's document.
Undoubtedly, such a document should reflect the highest possinle quality in its description of the extent, substance, standards, conclusions and bases of staff review.
I an aware that the August 16 inputs were prepared to severe tine restraints, and that a better record could be established M
given additional time. Having reviewed this input, I agree nore tir,e should be taken.
As a first step in this direction, CL and technical editors have :nade scre icprovenents to the August input by the enclosed SSER. However, cuch -ore is needed to pre.'uce the final report that this special revfew deserves.
We are present!j reviewing the enclosed SSER to identify specific areas where improvement is needed, and request to meet with you at your earliest opportunity to discuss results of this review.
l i
Thomas 51. 'iovak, Assistant Director for Licensing Division of Licensing
Enclosure:
1 As st'ated DL:LBf4 DL:LBf4 AD:L/DL DHood:eb EAdensam TMNovak or so, ann n.
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J. Kane '
G. Herstead J. !!atra F. Rinaldi H. Brammer l
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,h' Docket flos. 50-329/330 LB #4 r/f
,j MDuncan Docket Nos: 50-329 -
and 50-330 HEMORAllDUM FOR:
L'. Rubenstein, Assistant Director for Core and Plant Systems
.' l T. Speis, Assistant Director for Reactor Safety R. Narnick, Region III l
J. P. Knight, Assistant Dimetor for Components and Structures Engineering W. Paton, OELD FRON:
Thomas M. Novak, Assistant Director q
for Licensing. DL
SUBJECT:
MIDLAND 1 AND 2 SSER t2 l
Attached.for your concurrence prior to issuance is the second supplement to the j
tafety Evaluation Report for the Midland Plant. This SSER closes some of the J
open and confirmatory issues from the >SER. The open items closed relate to j
soil settlement issues. Contributors to this SSER are listedi;n Appendix E.
j The data given the Licensing Board for publication of this SSER is August 27, 1982, and the subsequent soils hearing (Oct. 5-8 and 29-22,1982) has been scheduled based upon this date. Please mark any changes associated with your concurrence on the attached SSER copy, and return to the project manager,lohtlwith Darl Hood (492-8474, Room 118.of the Phillips Annex) by.C0BJugus,t 25,1982,- a indication of your approval. Changes received by this time will be incorporated j
into the final copy.
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Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
3 As stated cc:
R. Vollmer F. Schauer
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D. Eisenhut R. Bosnak l
J. Keppler G. Lear i
R. Mattson B. Sheron l
E. Adensam O. Pare R. Hernan E.. G~oodwi n D. Hood R. Warnick j
J. Scinto DL:LB #4 DL:LB !4 AD:L:DL DHood/hmc
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I MEETING
SUMMARY
DISTRIBUTION September 22, 1982 Docket Nc(s): 50-329/330 OM, OL g//
NRC/PDR Local PDR TIC /NSIC/ TERA JKeppler LB #4 r/f WPaton Attorney,.OELD RWarnick OIE RVollter E. Adensam Project. Manager nunna Licensing Assistant pn.,nean NRC
Participants:
T. Novak D. Hood W. Shafer (RIII) f bec:
Applicant & Service List A
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September 22, 1982 Docket Nos: 50-329 OH, OL and 50-330 OM, OL
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APPLICANT:
Consuners Power Company FACILITY:
Itidiand Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF SEPTEMBER 8, 1982,itEETING ON SOILS-RELATED QUALITY ASSURANCE IMPROVEMENTS On September 8,1982, the NRC staff met in Bethesda, Maryland with Mr..J.
Mooney of Consuners Power Company (the Applicant) to discuss measures being considered to.
assure s,uccessful implementation of the quality plan for the Midland soils remedial-work. Meeting attendees are listed in Enclosure 1.
During a September 2,1982, meeting between NRC management and CPCo management and during an earlier SALP meeting, the NRC indicated that implementation of the qual-ity assurance program needs to be improved, especially in the soils remedial areas.
Mr. Mooney noted that in response to these NRC ' concerns, he is preparing a letter to address measures which will be taken to gauge and assure the successful imple-mentation of the quality program, with particular emphasis in the soils areas.
The purpose of the meeting was to discuss a preliminary draft of the letter (Enclosure
- 2) in the soils areas. Another letter covering the total Midland Quality Program implementation is also being drafted by Mr. Mooney.
Mr. Mooney expects to issue his letters in about a week.
Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated cc: See next page A 9,iAs > n u i u
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. - MIDLAND Mr. J. W. Cook Vice President Lee L. Bishop Consuners Power Company Harnon & Weiss 1945 West Parnall Road 1725 I Street, N.W., Suite'506 Jackson, Michigan 49201 Washington, D. C.
20006 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 Three First Nation'al Plaza, Lansing, Michigan 48909 51st floor
- Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consuners Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms., Mary Sinclair Midland, Michigan 48640 5711'Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris -
5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consuners Power Company 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 C1ausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
,F Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babccck & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III.
Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Ron Callen Michigan Public Service Commission Mr. Paul Rau Midland Daily News 6545 !$ercantile Way 124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909 i
f Mr. J. W. Cook,
l 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 NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Wa shi ngton, D.
C.'
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 -
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j ENCLOSURE 1 ATTENDEES September 8,1982 NRC T. !!avak
- 0. Hood W. Shafer (P.III)
CPCo J. Mooney J. Cook (part time via telephone) i i
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' Consumers O
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Company vic rr is na - rr.i t. ensin rins and Construction General Offkes: 1945 West Pernell Flood. Jackson, MI 49201 * (51 4 788 0453 L
September 7, 1982 7
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Harold R Denton, Director Office of Nuclear Reactor Regula' tion Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 RESPONSE TO OPEN ITEMS OF DRAFT SER FILE 0485.16 SERIAL 19158 DRAFT This letter summarizes Consumers Power Company's discussions with the NRC management regarding our mutual desire to implement a successful quality program for the Midland soils remedial work.
The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co. Follow-up discussions with the NRR staff and Region III Inspectors led to the conclusion that the Quality Program and its definition was adequate; however, there was concern that certain aspects were not being or might not be satisfactorily implemented.
This was corroborated by the fact that the majority of the NRCs recent inspection findings at the Midland Site were in the soils area.
t oc0982-2607a102 gggf.;..u.: {.
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t-2 Consumers Power has performed an in-depth review of all aspects of the
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implementation plans for the Midland Soils work activities.
This review
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included the areas of design and construction requirements and plans, organization and personnel, project controls and management involvement.
The results of this review and the proposed steps for the successful implementation of the Quality Program were discussed with the NRC management in a' meeting held in Chicago on September 2, 1982.
In addition, because of the expanded underpinning activities scheduled to begin shortly, Consumers propose,s to retain a qualified third party for an assessment of the initial phase of the implementation of these work activities.
The highlights of the September 2 discussions are presented in the following paragraphs.
The design for the required remedial activities is in an advanced state; design details and adequacy have been reviewed by numerous organizations.
A special ACRS Subcommittee reviewed the soils activities and concluded that there were no open items, while commenting favorably on the thoroughness and conservatism of the review and remedial approaches.
Numerous submittals to
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the NRC have been presented to clarify the design intent. The NRC Staff has subsequently completed its detailed review of all design aspects, has reached the conclusion that no open issues remain, and is in the process of issuing an SSER.
Following-up on design activities, Bechtel has assigned to the site a design team comprised of experienced structural and geotechnical engineers under the Resident Engineer.
This team will monitor and review the field implementation, resolve on a timely basis routine construction questions l
requiring engineering response and immediately administer contingency plans immediately if any problem should arise during tf$e underpinning work.
oc0982-2607a102 UId$I
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Following, coupled with an effective design process, the next step in quality performance of the soils remedial work involves a system to assure that all design
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requirements and commitments are properly reflected in the final product.
To this end, all soils activites covered by the' ASLB Order of April 30, 1982;are "Q-listed" and are covered under soils-specific QA plans.
These require that appropriate procedures are in place to accomplish the work in a quality manner successfully and that detailed inspection plans and over-inspection plans have been developed and are utilized. Additionally, the Work Authorization Procedure and Work Permit System insure ~the NRC and CP Co have specifically approved and released the work.
To assure that all commitments made to the NRC are properly accounted for in design documents, Consumers reviews written records of commitments and incorporates them in design detail. The Project is also undertaking a review of past correspondence to create a computer listing of all commitments not j
already placed in construction documents. This' computer list will be periodically reviewed to insure that commitments are incorporated in design or construction documents in a timely fashion.
Another aspect of the Company's quality implementation program calls foF an efficient, integrated quality organization staffed by qualified, experienced personnel.
The present project organization provides single-point accountability, dedicated. personnel, minimum interfaces - particularly at the working level, and a quality organization integrating quality assurance and quality control. This organization is staffed by personnel with the experence
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4 necessary to successfully accomplish the work.
(The qualifications of key personnel were discussed in more detail in our recent meeting.)
To enhance the performa'ce of key project organizations, the Company will n
maintain day-to-day control over scheduling, both through the construction approval process and by frequent meetings with the involved contractors and subcontractors.
Each week, underpinning subcontractors wil.1 present proposed construction work to the Company.
In addition, to reduce schedule pressures on involved subcontrators, all subcontracts were entered into on a time-material basis. This should improve subcontractor attention to detail in performance of specific construction activities.
Another important element of the proposed soils implementation plan involves employee training. The training program, which includes all organization and personnel, covers both general training in quality and specific training relative to the construction procedures. More specifically, all personnel J
associated with Remedial Soils w-
% have attended a special Quality Assurance Indoctrination Session.
This includes Bechtel Remedial Soils Group, Bechtel QC, MPQAD,fiergentime and Spencer, White and Prentis (SW&P) personnel down to the craft foreman level.
This training consits of one three-hour session covering Federal Nuclear
- Regulations, the NRC, Quality Programs in general, and the Pemedial Soils Quality Plan in detail.
In addition to the forementioned training, both Mergentime and SW&P Procedures for Quality Related Training require specific training prior to initiating any quality related construction activity. The extent of this training, and identification of individuals to receive it, are spelled out in i
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5 the each separate procedures governing quality related' activities. Training requirements are listed in the prerequisites section of each procedure, and are QC and QA Hold Points, which must be signed by a QC and QA representative prior to the.b'eginning of relevant activities.
Beyond training, an additional measure to improve performance involves the creation of a new Quality Improvement Program (QIP) for the soils project. To '
launch their effort, an indoctrination program will be presented to all individuals, stressing the absolutes of. Quality and the concept of "Doing it right the first time." ' Measures specific to soils will le developed for those critical areas which are indicative of a " quality product". Tracking these activities will provide an indication of the effectiveness of the program. The QIP will -provide mechanisms for individual " feedback" and will enhance existing QIP programs.
In addition to embracing well-defined design and implementation requirements, a qualified organization and strict performance standards, the soils remedial work will include a high level of senior management involvement.
Towards this end, project senior management will conduct weekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. The Company's CEO is briefed on a regular basis and schedules bi-monthly briefings on all aspects of the project including soils. During the bi-monthly briefings the CEO tours the Midland site.
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Complementing the enhanced CP Co management role, NRC Region Management overview of the construction process will be assured by monthly ineeting, agreed upon by the Region, to overview the results of the quality program and the progress of the s' oils project. These meetings will cover any or all aspects of the project of general or special interest to the NRC management.
A final element of the ' Company's of quality implementation effort is the establishing of an independent appraisal program.
This program is independent of the design and construction effort and will assess implementation during the initial three months of the underpinning of the auxiliary building or longer if circumstance warrant. This independent appraisal program implementation will be in place prior to starting Phase 3, which is defined as starting with the removal of soil for the grillage beams at Piers East and West #8 (Piers E/W8 are installed as Phase 2).
The independent appraisal will be conducted by a team of nuclear plant
)
construction and quality assurance experts. This team will be supplemented by the addition of an underpinning consultant who will review the design documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consis*ent with industry stan'dards.
The assesment will further assure l
that the OC program is being implemented satisfactorily and that the construction itself is being implemented in accordance with the construction documents.
Contract negotiations ~are in process wita Stone and Webster _to assume the lead role in this appraisal.
They will te assisted by Parsons, l
Brinkerhoff, Quade and Douglas, Inc who will provide technical expertise.
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Based on the discussion outlined above, CP Co believes that the soils program
,has been thoroughly and critically evaluated, and that all: prerequisites for.
successful implementatio'n have been or are being accomplished.
The Company's program, with the initial overview from the independent implementation assessment, and the continuing overview by the NRC staff and management should provide proper assurance that the remedial soils activities will be successfully completed.
JWC/ JAM /cl CC Atomic Safety 'and Licensing Appeal Board CBechhoefer, ASLB, w/o MMCherry, Esq, w/o FPCowan, ASLB, w/o RJCook, Midland Resident Inspector, w/o SGadler, w/o JHarbour, ASLB, w/o GHarstead, Harstead Engineering, w/a DSHood, NRC, w/a (2)
DFJudd, B&W, w/o JDKane, NRC,.w/a FJKelley, Ewq, w/o p
RBlandsman, NRC Region III, w/a WHMarshall, w/o JPMatra, Naval Surface Weapons Center, w/a W0tto, Army Corps of Engineers, w/o WDPaton, Esq, w/o SJPoulos, Geotechnical Engineers, w/a FRinaldi, NRC, w/a HSingh, Army Corps of Engineers, w/a BStamiris,w/o DRiii oc0982-2607a102 i
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CONSUMERS POWER COMPANY Midland Units.1 and 2 Docket No 50-329, 50-330 Letter Serial Dated At the request of the Commission ano pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits CONSUtiERS POWER COMPANY By J W Cook, Vice President Projects, Engineering and Construction
- Sworn and subscribed before me this day of Notary Public Jackson County, Michigan 2
My e mmission Expires
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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial Dated i
At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the
. Commission's Rules and Regulations thereunder, Consumers Power Company submits CONSUi'ERS POWER COMPANY By
/s/ J W Cook J W Cook, Vice President Projects Engineering and Construction Sworn and subscribed before me this day of
/s/ Barbara P Townsend Notary Public Jackson County, Michigan J
My Commission Expires i
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September 22, 1982 Docket Nos: 50-329 OM, OL and 50-330 OM, OL APPLICANT:
Conswers Power Company FACILITY:
Midland Plant, Units 1 and 2
SUBJECT:
SUMMARY
-0F SEPTEMBER 8, 1982, MEETING ON S0ILS-RELATED QUALITY ASSURANCE IMPROVEMENTS On September 8,1982, the NRC staff met in Bethesda, Maryland with Mr. J. Mooney of Constrners Power Company (the Applicant) to discuss measures being considered to assure successful implementation of the quality plan for the Midland soils remedial work. Meeting attendees are listed in Enclosure 1.
During a September 2,1982, meeting between NRC management and CPCo inanagement and during an earlier SALP meeting, the NRC indicated that implementation of the qual-ity assurance program needs to be improved, especially in the soils remedial areas.
Mr. Mooney noted that in response to these NRC concerns, he is preparing a letter to address measures which will be taken to gauge and assure the successful imple-metitation of the quality program, with particular emphasis in the soils areas. The purpose of the meeting was to discuss a preliminary draft of the letter (Enclosure
- 2) in the soils areas. Another letter covering the total Midland Quality Program implementation is also being drafted by Mr. Mooney.
Mr. Mooney expects to issue his letters in about a week.
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Darl S. Hood, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated cc:
See next page gnAAm GW T LTf N f l}/f' M ^ ^*
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MIDLAND i
Mr. J. W. Cook Vice President Lee L. Bishop Consumers Power Company Harmon & Weiss 1945 West Parnall Road 1725 I Street, N.W., Suitt 506 Jackson, Michigan 49201 War.hington, D. C.
20006 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 Three First National Plaza, Lansing, Michigan ' 48909 51st floor
- Chicago, Ulinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consuners Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Ma ry Si ncl ai r Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General 4
State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consuners Power Company 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 Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory -
Nuclear Power Generation Division 9l00 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III.
Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way 124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909
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.Mr. J. W. Cook.
cc: Comnsnder, Naval Surface Weapons Center ATTN; P. C. Huang Whito 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 NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board -
U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
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Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN-Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 l
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ENCLOSURE 1 ATTENDEES September 8,1982 i.
NRC T. Novak D. Hood-W. Shater (RIII)
I CPCo J. Mooney J. Cook (part time via telephone) i d
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7E September 7, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 RESPONSE TO OPEN. ITEMS OF DRAFT SER FILE 0485.16 SERIAL 19158 DRAFT This letter summarizes Consumers Power Company's discussions with the NRC management regarding our mutual. desire to implement a successful quality program for the Midland soils remedial work.
The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co.
Follow-up discussions with the NRR staff and Region III Inspectors led to the conclusion that the Quality Program and its definition was adequate; however, there was concern that certain aspects were not being or might not be satisfactorily implemented.
This was corroborated by the fact that the majority of the NRCs recent inspection findings at the Midland Site were in the soils area.
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.A Consumers Power has performed an in-depth review of all aspects of the i
implementation plans for the Midland Soils work activities: This review included.the areas of. design and construction requirements and plans, organization.and personnel, project controls and management involvement.
The results of this review and the proposed steps for the successful implementation of the Quality Program were discussed with the NRC management in a meeting held in Chicago on September 2,1982.
In addition, because of the expanded underpinning activities scheduled to begin shortly, Consumers proposes to retain a qualified third party for an assessment of the initial phase of the implementation of these work activities.
The highlights of the September 2 discussions are presented in the following paragraphs.
The design for the required remedial activities is in an advanced state; design detafis and adequacy have been reviewed by numerous organizations. A special ACRS Subcommittee reviewed the soils activities and concluded that there were no open items, while commenting favorably on the thoroughness and J-conservatism of the review and remedial approaches. Numerous submittals to the NRC have been presented to clarify the design intent. The NRC Staff has subsequently completed its detailed review of all design aspects, has reached the conclusion that.no open issues remain, and is in the process of issuing an SSER.
Following-up on design activities, Bechtel has assigned to the site a design team comprised of experienced structural and geotechnical engineers under the Resident Engineer.
This team will monitor and review the field implementation, resolve on a timely basis routine construction questions requiring engineering response and immediately administer contingency plans immediately if any problem should arise during the underpinning work.
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Following, coupled with an effective design process, the next step in quality performance of the soils remedial work involves a system to assure that all design.
requirements and comitments are properly reflected in the final product. To this end, all soils activites covered by the ASLB Order of April 30, 1982 are "Q-listed" and are covered under soils-specific QA plans.
These require that appropriate procedures are in place to accomplish the work in a quality manner
[
successfully and that detailed inspection plans and over-inspection plans have been developed and are utilized. Additionally, the Work Authorization Procedure j.
m and Work Permit System insure the NRC and CP Co have specifically approved and released the work.
To assure that all comitments made to the NRC are properly accounted for in design documents, Consumers reviews written records of comitments and incorporates them in design detail. The Project is also undertaking a review 4
of.past correspondence to create a computer listing of all comitments not already placed in construction documents. This computer list will be periodically reviewed to insure that commitments are incorporated in design or construction documents in a timely fashion.
Another aspect of the Company's, quality implementation program calls for an efficient, integrated quality organization staffed by qualified, experienced personnel. The present project organization provides single-point accountability, dedicated personnel, minimum interfaces - particularly at the working level, and e quality orgdofzation irnegrating quality assurance and quality control. This organization is staffed by personnel with the experence oc0982-2607a102 e
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necessary to successfully accomplish the work.
(The qualifications of key personnel were discussed in more detail in our recent" meeting.)-
9 To enhance th'e performance of key project organizations, the Company'will maintain day-to-day' control over scheduling, both through the construction approval process and by frequent meetings with the involved contractors and subcontractors..Eachweek,unddrpinningsubcontractorswillpresentproposed construction work to the Company.
In addition, to reduce schedule, pressures on J-involved subcontrators, all subcontracts were entered into on a time-material basis. This should improve subcontractor attention to detail in performance of specific construction activities.
F e
Another important element of the proposed soils implementation plan involves employee training. The training program, which includes all organization and personnel, covers both general training in quality and specific training relative to the construction procedures. More specifically, all personnel associated with Remedial Soils work have attended a special Quality Assurance Indoctrination Session. This includes Bechtel Remedial Soils Group, Bechtel l
QC, MPQAD, Mergentime and Spencer, White and Prentis (SW&P) personnel down to the craft foreman level. This training consits of one three-hour I
session covering Federal Nuclear Regulations," the NRC, Quality Programs in general, and the Remedial Soils Quality Plan in detail.
In addition to the forementioned training, both Mergentime and SW&P Procedures for Quality Related Training require specific training prior to initiating any quality L
related construction activity. The extent of this training, and l
identification of individuals to receive it, are, spelled out in M,d,]
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the each separate procedures governing quality related activities.
Training L
requirements are listed in the prerequisites section of each procedure, and are QC and QA Hold Points, which must be signed by a QC and QA representative prior to the beginning of relevant activities.
Beyond training, an additional measure to improve performance involves the creation of a new Quality Improvement Program (QIP) for the soils project. To launch their effort, an indoctrination program will be presented to all individuals, stressing the absolutes of Quality and the concept of "Doing it right the first time." Measures specific to soils will be developed for those critical areas which are indicative of a " quality product'.'. Tracking these activities will provide an indication of the effectiveness of the program. The QIP will provide mechanisms for individual " feedback" and will enhance existing QIP programs.
In addition to embracing well-defined design and implementation requirements, a
)
qualified organization and strict performance standards, the soils remedial work will inqlude a high level of senior management involvement.
Towards this end, project senior management will conduct weekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. The Company's CEO is briefed on a regular basis and schedules bi-monthly briefings on all aspects of the project including soils.
During the bi-monthly briefings the CEO tours the Midland site.
1 oc0982-2607a102 t
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6 Complementing the enhanced CP Co management role, NRC Region Management o0erview of the construction process will be assured by monthly meeting, agreed upon by the Region, to overview the' results of the quality program and
~
the progress.of the soils project. These meetings will cover any or all aspects of. the project of general or special interest to the NRC management.
A final element of the Company's of quality implementation effort is the establishing of an' independent appraisal program.
This program is independent of the design and construction effort and will assess implementation during the initial three months of,the underpinning of the auxiliary building or longer if circumstance warrant. This independent appraisal program implementation will be in place pr!or to starting Phase 3, which is defined as starting with the removal of soil'for the grillage beams at Piers East and West #8 (Piers E/W8 are installed as-Phase 2).
The independent appraisal will be conducted by a team of nuclear plant construction and quality assurance experts.
This team will be supplemented by the addition of an underpinning consultant who will review the design
. documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consistent with industry standards. The a'ssesment will further assure that the QC program is being implemented satisfactorily and that the construction itsAlf is being implemented in accordance with the construction documents.
Contract negotiations are in process with Stone and Webster to assume the lead role in this appraisal.
They will be assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc who will provide technical expertise.
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7 Based on the discussion outlined above, CP Co believes that the soils program has been thoroughly and critically evaluated, and that all prerequisites for successful implementation have been'or are being accomplished. The Company's A
program, with the' initial' overview from the independent implementation assessment, and the continuing overview by the NRC staff and management should provide proper assurance that the remedial soils activities will be successfully completed.
JWC/JAli/cl CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB, w/o MMCherry, Esq, w/o FPCowan, ASLB, w/o RJCook, Midland Resident Inspector, w/o SGadler, w/o JHarbour, ASLB, w/o GHarstead, Harstead Engineering, w/a DSHood, NRC, w/a (2)
DFJudd, B&W, w/o JDKane,NRC,w/a FJKelley, Ewq, w/o
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RBlandsman, NRC Region III, w/a WHMarshall, w/o JPMatra, Naval Sur, face Weapons Center, w/a W0tto, Army Corps of Engineer:, w/o WDPaton, Esq, w/o SJPoulos, Geotechnical Engineers, w/a FRinaldi, NRC, w/a HSingh, Army Corps of Engineers, w/a BStamiris, w/o e
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Docket No 50-329, 50-330 s
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At the' request'of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974,'as amended and.the Commission's Rules and Regulations thereunder, Consuma7s Power, Company submits
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6 CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial Dated At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974,-as amended and the j
Commission's Rules-and Regulations. thereunder, Consumers Power Company submits 1
.t CONSUMERS POWER COMPANY By
/s/ J W Cook J W Cook, Vice President Projects, Enginee' ring and Construction
. Sworn and subscribed before me this day of
/s/ Barbara P Townsend Notary Public Jackson County, Michigan
(
My Commission Expires P-2i oc0982-2607a102 p
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,psneuq'o,j UNITED STATES E\\
"g NUCLEAR REGULATORY COMMISSION g '-
- j WASHINGTON, D. C. 20555 s$.'..../
a September 22, 1982 O
Docket Nos: 50-329 OM, OL and 50-330 OM, OL o
APPLICANT:
Consuners Power, Company FACILITY:
Midland Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF SEPTEMBER 8,1982, MEETING Off S0ILS-RELATED QUALITY ASSURANCE IMPROVEMENTS On September 8,1982, the NRC si;aff met in Bethesda, Maryland with Mr. J. Mooney of Consuner's Power Company (the Applicant) to discuss measures being considered to
' assure successful implementation of the quality plan for the Midland soils remedial work. Meeting attendees are listed in Enclosure 1.
During a September 2,1982, meeting between NRC management and CPCo management and during an earlier SALP meeting, the NRC indicated that implementation of the qual-ity assurance program needs to be improved, especially in the soils remedial areas.
Mr.- Mooney noted that in response to these NRC concerns, he is preparing a letter to address measures which will be taken to gauge and assure the successful imple-mentation of the quality program, with particular emphasis in the soils areas. The purpose of the meeting was to discuss a preliminary draft of the letter (Enclosure
- 2) in the soils areas.
Another letter covering the total Midland Quality Program implementation is also being drafted by Mr. Mooney.
Mr. Mooney expects to issue his letters in about a week.
N
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Darl S. Hood, Project Manager Licensing Branch No. 4 s
Division of Licensing
Enclosures:
As stated
'cc:
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e MIDLAND.
Mr. J. W. Cook Vice President Lee L. Bishop
. Consuners Power Company Harmon & Weiss 1945 West Parnall Road 1725 I Street, N.W., Suite 506
^
Jackson, Michigan 49201 Washingtc1, D. C.
20006 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 e.0. Box 33035-Three First National Plaza, Lansing, Michigan 48909 Sist floor
- Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consuners Power Company 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 Midland, Michigan 48640 Battelle Pacific North West Labt. (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, 'Illinoi s 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator l
U.S. Nuclear Regulatory Commission, Cherry & Flynn Reg' ion III Suite 3700 799 Roosevelt Road l
' Three First National Plaza Glen Ellyn, Illinois 60137 l
Chicago, Illinois 60602 j
Mr. Ron Callen i
Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way i
124 Mcdonald Street P.O. Box 30221 l
Midland, Michigan 48640 Lansing, Michigan 48909 l
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l Mr. J..W. Cook _
cc: Commander, Naval Surface Weapons center ATTN:
P. C. Huang White Oak Silver Sprir.g, 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 NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 P
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ENCLOSURE 1 ATTENDEES' September 8,1982 NRC' T. Novak D. Hood W. Shafer (RIII)
CPCo J. Mooney J. Cook (part time yia telephone)
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-Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 RESPONSE TO OPEN ITEMS OF DRAFT SER FILE 0485.16 SERIAL 19158 DRAFT This letter summarizes Consumers Power Company's discussions with the NRC management regarding our mutual desire to implement a successful quality program for the Midland soils remedial work.
The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co. Follow-up discussions with the NRR staff and Region III Inspectors led to the conclusion that the Quality Program and its definition was adequate; however, there was concern that certain aspects were not being cr might not be satisfactorily implemented.
This-was corroborated by the fact that the majority of the NRCs recent inspection findings at the flidland Site were in the' soils area.
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2 Consumers Power has performed an in-depth review of all aspects of the implementation plans for the Midland Soils work activities. This review included the areas of' design and construction requirements and plans, organization an'd personnel, project controls and management involvement. The results of this review and the proposed steps for the successful implementation of the Quality Program were discussed with the NRC management
'in a meeting held in Chicago on September 2, 1982.
In addition,.because of the expanded underpinning activities scheduled to begin shortly, Consumers proposes to retain a qualified third party for an assessment of the initial phase of the implementation of these work activities. The highlights of the September 2 discussions are presented in the following paragraphs.
The design for the required remedial activities is in an advanced state; design details and adequacy have been reviewed by numerous organizations. A special ACRS Subcommittee reviewed the soils activities and concluded that there were no open items, while commenting favorably on the thoroughness and conservatism of the review and remedial approaches. Numerous submittals to the NRC have been presented to clarify the design intent. The NRC Staff has subsequently completed its detailed review of all design aspects, lias reached the conclusion that no open issues remain, and is in the process of issuing an SSER. Following-up on design activities, Bechtel has assigned to the site a design team comprised of experienced structural and geotechnical engineers under the Resident Engineer. This team will monitor and review the field implementation, resolve on a timely basis routine construction questions requiring engineering response and immediately administer contingency plans immediately if any problem should arise during the underpinning work.
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Following, coupled with an effective design process, the next step in quality I
performance'ofthe'soilsremedialwork[involvesasystemtoassurethatalldesign i
- requirements and commitments,are properly reflected in the final product. To f
this'end, all' soils' activites covered by' the ASLB Order. of April :30,1982 are
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"Q-listed" and are covered under soiIs-specific QA plans. -These require that t
appropriate procedures-are in plac'e'to accomplish the work'in a quality manner
.successfully and that detailed' inspection plans and over-inspection plans have been developed and are utilized. Additionally, the Work Authorization Procedure' and Work Permit System insure the NRC and CP Co have specifically approved and released the work.
To assure that all commitments made to the NRC are properly accounted for in If
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design' documents, Consumers reviews written records of commitments and ir:orporates them in design detail. The Project is also undertaking a review of past correspondence to create a computer listing of all commitments not-i' already placed in construction documents. This computer. list will be o[
periodically reviewed to insure that commitments are incorporated in design or i-construction documents in a~ timely fashion.
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Another aspect of the Company's quality implementation program calls for an i
efficient, integrated quality organization staffed by qualified, experienced personnel. The present project organization provides single-point accountability, dedicated personnel, minimum interfaces - particularly 'at the-t.
l' working level, and a quality organization integrating quality assurance and quality control. This organization is staffed by personnel with the experence i'
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necessary to successfully accomplish the work.
(The qualifications of key
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personnel were discussed in more detail in our recent meeting.)
To enhance the performance of key project organizations, the Company will maintain day-to-day control over scheduling, both through the construction approval process and by frequent meetings with the involved contractors and subcontractors. Each week, underpinning subcontractors will present proposed.
construction work to the Company.
In addition, to reduce schedule pressures on involved subcontrators, all subcontracts were entered 'into on a time-caterial basis. This should improve subcontractor attention to detail in performance of
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specific construction activities.
Another important element of the proposed soils implementation plan involves employee training. The training program, which includes all organization and personnel, covers both general training in quality and specific training relative to the construction procedures. More specifically, all personnel associated with Remedial Soils work have attended a special Quality Assurance Indoctrination Session. This includes Bechtel Remedial Soils Group, Bechtel QC, MPQAD, Mergentime and Spencer, White and Prentis (SW&P) personnel down to the craft foreman level. This training consits of one three-hour session covering Federal Nuclear Regulations, the NRC, Quality Programs in general, and the Remedial Soils Quality Plan in detail.
In addition to the forementioned training, both Mergentime and SW&P Procedures for Quality Related Training require specific training prior to initiating any quality related construction activity. The extent of this training, and identification of individuals to receive it, are spelled out in h!)j}-
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the each separate procedures governing quality related activities. Training requirements are listed in the prerequisites section of each procedure,
- and are QC and QA Hold Points, which must be signed by a QC and QA representative prior to the beginning of relevant activities.
Beyond training, an additional measure to improve performance involves the creation of a new Quality Improvement Program (QIP) for the soils project. To launch their effort, an indoctrination program.will be presented to al,1 individuals, stressing the abs.olutes of Quality and the concept of "Doing it right the first time." Measures specific to soils will be developed for those critical areas which are indicative of a " quality product". Tracking these activities will provide an indication of the effectiveness of the program. The QIP will provide mechanisms for individual " feedback" and will enhance existing QIP programs.
f In addition to embracing well-defined design and implementation requirements, a qualified organization and strict performance standards, the soils remedial work will include a high level of senior management involvement.
Towards this end, project senior management will conduct weekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. The Company's CEO is briefed on a regular basis and schedules bi-monthly briefings on all aspects of the project including soils. During the bi-monthly briefings the CEO tours the Midland site.
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Complementing the enhanced CP Co management role, NRC Region Management overview of the construction process will be assured by monthly meeting, 5
agreed upon by the Region, to overview the results of the quality program and the progress of the soils project. These meetings will cover any or all aspects of the project of general or special interest to the NRC management.
L A final element of the Company's of quality implementation effort is the establishing of an independent appraisal program.
This program is independent of the design and construction effort and will assess implementation during the initial three months of the underpinning of the auxiliary building or longer if circumstance warrant. This independent appraisal program implementation will be in place prior to starting Phase 3, which is defined as starting with the removal of soil for the grillage beams at Piers East and West #8 (Piers E/W8 are installed as Phase 2).
The independent appraisal will be conducted by a team of nuclear plant construction and quality assurance experts. This team will be supplemented by the addition of an underpinning consultant who will review the design documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consistent with industry standards. The assesment will further assure that the QC program is being implemented satisfactorily and that the construction itself is being implemented in accordance with the construction documents. Contract negotiations are in process with Stone and Webster to assume the lead role in this appraisal. They will be assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc who will provide technical expertise.
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Based on the discussion outlined above, CP Co believes that the soils program has been thoroughly and critically evaluated, and that all prerequisites for successful implementation have been or are being accomplished. The Company's program, wi'th the. initial overview from the independent implementation J
assessment, and the continuing overview by the NRC staff and management should pro' vide proper assurance that the remedial soils activities will be successfully completed.
JWC/ JAM /cl CC Atomic Safety and Licensing Appeal Board CBechhoefer,ASLB,w/o l
MMCherry,Esg,w/o FPCowan, ASLB, w/o RJCook, Midland Resident Inspector, w/o SGadler, w/o JHarbour, ASLB, w/o GHarstead, Harstead Engineering, w/a DSHood, NRC, w/a (2) p 0FJudd,B&W,w/o l
JDKane,NRC,w/a FJKelley, Ewq, w/o RBlandsman, NRC Region III, w/a WHMarshall,w/o JPMatra, Naval Surface Weapons Center, w/a W0tto, Army Corps of Engineers, w/o WDPaton, Esq, w/o SJPoulos,-Geotechnical Engineers, w/a FRinaldi,NRC,w/a HSingh, Army Corps of Engineers, w/a BStamiris,w/o oc0982-2607a102 3
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CONSUMERS POWER COMPANY Midland Units 1 and 2 i -
Docket,No 50-329, 50-330 Letter Serial Dated At'the' request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits CONSUMERS' POWER COMPANY By
. J W Cook, Vice President Projects, Engineering and Construction Sworn and subscribed before me this day of Notary Public Jackson County, Michigan My Commission Expires hf[kf[
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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial Dated At the request of the Commission and pursuant to'the' Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits CONSUMERSP0hERCOMPANY By
/s/ J W Cook J W Cook, Vice President Projects, Engineering and Construction Sworn and subsc-ibed before me this day of
/s/ Barbara P Townsend Notary Public Jackson County, Michigan My Commission Expires DMF oc0982-2607a102 i
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Docket Nos: 50-329 OH, OL s
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l APPLICANT:
Conswers Power Cocpany I
FACILITY:.
Hidland Plant, Units 1 and 2~
SUBJECT:
SUMMARY
OF SEPTEMBER 8,1982, MEETING ON SOILS-RELATED QUALITY ASSURANCE IMPROVEMENTS d
On September 8,1982, the NRC staff met in Bethesda, Maryland with Mr. J. Nocney of Consmers Power, Company (the Applicant) to discuss' measures being consiuered to il assure successful implementation of the quality plan for the Midland soils remedial
,ork.
Heeting attendees are listed in Enclosure 1.
w During a September 2,1982, meeting between NRC management and CPCo management and during an earlier SALP meeting, the NRC indicated that implemeritation of the qual-ity assurance program needs to be improved, especially in the soils remedial areas.
7 Mr. Mooney noted that in response to these NRC concerns, he is preparing a letter
_i to address measures which will be taken to gauge and assure the successful imple-j mentation of the quality program, with particular emphasis in the soils areas. The purpose of the meeting was to discuss a preliminary draft of the letter (Enclosure
- 2) in the soils areas.
Another letter covering the total Midland Quality Program implementation is also being drafted by Mr. Mooney.
i Mr. Mocney expects to issue his letters in about a week.
l Carl S. Hood Project Manager Licensing Branch No. 4 i
l Division of Licensing l
Enclosures:
h As stated i
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ENCLOSURE 1 ATTENDEES September 8,1982 NRC 1
T. Novak O. Hood W. Shafer (R.III)
CPCo r
J. Mooney J. Cook (part time via telephone) a t
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APPLIC, ult; Consumer Power Company
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Midland Plant, Units l' and 2 i
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SUBJECT:
SUMMARY
OF SEPTEM8ER 8, 1982, MEETING ON i
SOILS-RELATED QUALITY ASSURANCE IMPROVEMENTS 4
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On September 8,1982, the NRC staff met in Bethesda, Maryland with Mr. J. Mooney of Consumer Power Company'(the Applicant) to discuss measures being considered to assure successful implementation of the quality plan for the Midland soils remedial work. Meeting attendees are listed by Enclosure 1.
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During a September'2, 1982, meeting between NRC management and CPCo management and during an earlier SALP meeting, the NRC indicated that implementation of the qual.
ity assurance program needs to be improved, especially in the solis remedial areas.
Mr. Mooney noted that in response to these NRC concerns, he is preparing a letter to address measures which will be taken to gauge and assure the successful imple-i mentation of the quality program, with particular emphasis in the soils areas. The 4
i purpose of the meeting was to identify a few of the items presently being considered l
for the letter.
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Changes intended to provide greater control of the QC program to the applicant are being considered.
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All personnel associated with remedial soils work have attended a three-hour QA indoctrination session covering federal regulations, the NRC, and the remedial soils quality plan.
s 3.
A new Quality Improvement Program to advertise the values of "doing it right the first time" is being launched for the soils project.
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Weekly on site reviews of senior management and bi-monthly briefings
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of Consumer's chief executive officer are being planned.
5.
The applicant is presently establishing an appraisal program which 1-will be independent of the dr,1gn and construction effort to assess implementation during at least the initial three months of the e
underpinning of the auxiliary building. This independent appraisal l
progran implementation would be in place prior to any excavation beneath the Electrical Penetration Area or the Control Tower..The independent appraisal will probably be conducted by a team of nuclear plant construction and quality assurance experts, and sup-planented with an underpinning consultant who will assure that the P
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desih intent'is being implemented and that construction is consis-tent with industry standards.
The assessment is further. intended to assure that the OC program is being implenented satisfactorily and that. construction is being implemented in accordance with con-
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'struction documents.
Contract negotiations were said to be in process.-
'N 6.
Mr. Mooney stated that Constmers plans to have an Independent Design Verification study performed for the Midland plant, and will note this committnent. in its letter. However, detailed discussions with the FIRC must be daferred until sufficient detail has been established.
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Mr. Mooney expects to issue his letter n about a week.
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' Darl S... Hood,: Project Manager 1
LicensingsBranch No. 4 Division of Licensing s
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Enclosure:
List of Attendees
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s DISTRIBUTION September 22, 1982 Document Control (50-329/330)
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Docket Nos.: 50/329/330 DHqod RHernan '
MMiller DEisenhut/RPurple MEMORANDUM FOR:
Harold S. Bassett, Director TNovak Division of Data Automation and JKerrigan Management Information Office of Resource Management FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
REQUEST FOR CASELOAD PANEL VISIT FOR MIDLAND PLANT We request that Midland Plant, Units 1 and 2 be scheduled for a visit by the Caseload Forecast Panel at your earliest opportunity. The last visit was in July 1981. The visit should include assessment of schedules for remedial soils activities.
We request that the visit be completed within the next month.
Original signed by Darrell G. Eised Darrell G. Eisenhut, Director -
Division of Licensing cc: W. Lovelace
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50-329/330 RHernan-MMiller I
DEisenhut/RPurple TNovak IIM0 rat!Duri FOR: Harold S. Bassett, Director JKerrigan Division of Data Auto"'ation and "anager'ent Information Office of Resource Panagesent FROM:.
Carrell G. Eisenhut, Director Division of Licensing
SUBJECT:
REI)UEST FOR CASELOAD PA!!EL VISIT FOR HIDLA!!D PLANT l
Pe request that Midland Plant, Units 14 2 be scheduled for a visit by the Caseload Forecast Panel at your earliest opportunity. The last visit was in Jul.y 1W1. The visit should include assessrient of schedules for recedial soils activities.
If possible, we would prefer the visit to be completed prior to start of the OL hearing scheduled to begin October 4,1982.
Darrell G. Eisenhut, Director Division of Licensing
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NUCLEAR REGULATORY COMMISSION
/.j WASHINGTON, D. C. 20555
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September 22, 1982
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Docket Nos.: 50/329/330 MEMORANDUM FOR:
Harold S. Bassett, Director Division of Data Automation and Management Information-Office of Resource Management FROM:
Darrell G. Eisenhut, Director-Division of Licensing
SUBJECT:
REQUEST FOR CASELOAD PANEL VISIT FOR MIDLAND PLANT k'e reguest that Midland Plant, Units 1 and 2 be scheduled for a visit by the Caseload Forecast Panel at your earliest opportunity. The last visit was in July 1981. The visit should include assessment of schedules for remedial soils activities.
We request that the visit be completed within the next month.
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. Eisenhut, Director Division of Licensing cc: W. Lovelace y
J. Keppler e
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t'ENRM00:1FOR: Harold S. Bassett, Director fKer gan
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Division of Data Automation and ifanagecent Info mation Office of Resource Panagement FR0f':
llarrell G. Eisenhut, Of rector Division of Licensing
SUBJECT:
REQUEST FCP. CASELOAD PANEL VISIT FOR tlIDLAUD PLANT
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' l Ne request that tidiand Plant, Units 1 & 2 be sche fuled for a visit I
by the Caseload Forecast Panel at your earliest caportunity.. The last I
visit was in July 1981. The visit should include assessnent of schedules i
for renedial soils activities
- If possible, we would prefer the visit to be completed orior to start
.j of the OL hearing scheduled to begin October 4,1902.
4 Darrell G. Eisenhut, Director Division of Licensing cc:
- u. Lovelace J. Xeppler
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BOARD NOTIFICATION 82-94
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Midland - Zack Part 21 Report on Welder Record Discrepancies DISTRIBUTION Document Control (50-329/330)
NRC POR L POR PRC System i
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Vollmer S. Hanauer Attorney, OELD OI&E W. J. Dircks, ED0 (3)
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E. Christenbury, OELD J. Scinto, OELD S. Chesnut, DL R. Warnick, R-III ACRS (16) Members of Midland Project 4
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SEPTEMBER 1 6 1982 Docket Nos: 50-329 OM, OL and 50-330 OM, OL MEMORANDUM FOR: The Atomic Safety & Licensing Board for Midland Plant, Units 1 and 2 FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
BOARD NOTIFICATION - ZACK PART 21' REPORT ON WELDER. RECORD DISCREPANCIES (BN 82-94)
In accordance with present NRC procedures regarding Board Notifications, the enclosed infomation is being provided for your infomation as constituting new infomation relevant and material to' safety issues.
This infomation deals with a report by the Zack Company entitled " Potential 10 CFR 21 Reportable Deficiency Evaluation for Accuracy of Welder Records". The report discusses deficiencies concerning the accuracy of welder records of Zack with regard to heating, venti-lation, and air conditioning (HVAC) at the Midland Plant.
The Zack Company is conducting an investigation of the Welder record discrepan-cies. Zack's report of this investigation is expected on or about September 24, 1982.
omas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: Board Service List Licensee Service List
Contact:
S. Chesnut. ONRR X29788
.. w, y q r l a a 4 Y92-
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MIDLAND Mr. J. W. Cook Vice President Lee L. Bishop Consmers Power Company Harmon & Weiss 1945 West Parnall Road 1725 I Street, N.W., Suite 506 Jackson, Michigan 49201 Washington, D. C.
20006 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 Three First National Plaza, Lansing, Michigan 48909 51st floor
- Chicago, Illinois 60602 Mr.' Steve Gadler 2120 Carter Avenue
~
James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consmers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consmers Power Company 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 Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIG4A IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager i
NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Ron Callen Mr. Paul Rau Michigan Public Service Commission Midland Daily News 6545 Mercantile Way l
124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909
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Mr. J. W. Cook.
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 NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massschusetts 01890 f
- 1
4600 W 12TH PLACE o CHICAGO (CICERO)ILL 6o65o
- 312/242-3434 44ol WESTERN + FLINT MICHIGAN 485o6
- 313/736-2odo the EA@X co.
CUSTOM METAL FABRICATION August 2.,
1982 U.S.N.R.C. Region III Office 799 Roosevelt Road Glen Ellyn, Illinois 60137
' Attn:
Mr. J.
G. Keppler Re:
Telecon of July 29, 1982 to Mr. Robert Walker at 4:20 P.M.
Subject:
Potential-10CFR21 - Weld Records Gentlemen:
This letter is to confirm the verbal telephone report given by Mr. D. E. Calkins, Manager of Engineering for the Zack Company on Thursday, July 29, 1982 at 4:20 P.M.
to Mr. Robert Walker at the Region III, Glen Ellyn offices of the Nuclear Regulatory Commission.
The attached report and corrective action plan has been pre-pared by Mr. Martin Skates, Quality Assurance Manager, as my designee for all Zack Company quality related matters.
During the course of an existing internal Zack Company investi-ga '; ion, initiated by the Zack Company officers, a box of paper-work was observed being taken to the trash by a plant employee.
The company maintenance man brought the documents to the atten-tion of Zack management.
A preliminary review of the documents (see attached report for details) indicates a possible discrepancy between the welder of record and the welder who may have actually performed the welds.
This potential discrepancy is still in the process of being fully investigated, but the initial indications are that it could have occurred during the 1977 to 1981 time frame.
- FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY
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- DEDICATED TO CLEANING AND CUSTCMlZING THE AIR OF THE WORLD '
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U.S.N.R.C.
Region III Office August 2, 1982 j
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The Zack Company has initia~ted and is still in the process of conducting a full scale investigation of this potential discrepancy.
However, in an attempt to keep all relevant information open and available to the appropriate parties, the Zack Company is initiating this potential 10CFR21 be-fore it has been determined that a deficiency does exist.
.By copy of this letter and the attached report the Zack Company is also confirming the verbal notifications given to the effected utilities.
The Zack Company will cooperate with the Nuclear Regulatory Commision and the respective utilities to the fullest de-gree possible in the performance of this investigation and its closure.
Should you have any questions or problems concerning this matter, please do not hesitate to contact me or Mr. Martin Skates at (312) 242-3434.
Very truly yours, THE ZACK COMPANY d
CHRISTINE ZACK DE ZUTEL, PRESIDENT CZDZ/ art Encl.
cc:
Mr. William Harrington Baldwin Associates Mr. L.
E. Davis Bechtel Power Company Mr. Dan L. Shamblin Commonwealth Edison Company 1
.o
THE ZACK COMPANY 4
POTENTIAL 10 CFR21 REPORTABLE DEFICIENCY EVALUATION FOR ACCURACY OF WELDER RECORDS PREPARED BY:
N ED Vavid E. Calkins, Manager Engineering REVIEWED BY: %. L. % b_
B[2/82.
M. L. Skates. Manager Quality Assurance APPROVEDBY:[_
2MD7
'f(Q' CliFistine Zack DeZy, PreifidenQ t
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Paga 1
1.0 Notification
1.1 The Zack Company in accordance with the intent of the reportability requirements within the Code of Federal Regulations, is reporting a Potential 10CFR21 condition relating to a possible discrepancy in the documentation that reflects the welder of record and the welder who may have actually performed the welds.
1.2 This report constitutes the Zack Company's official written notificaiton of a Potential 10CFR21 condition and confirms our verbal notification on Thursday, July 27, 1982 at 4:20 PM to Mr. Rbger Walker at the Region III Glen Ellyn Offices of the Nuclear Regulatory Commission.
The information relative to this report was obtained Tuesday, July 27, 1982.
The maintenance man observed a box of paperwork being taken to the trash by a plant employee. The maintenance man checked with manage-ment to see if the documents should be kapt. A review of some of the documents raised questions about welding documentation.
2.0 Identification
The possible deficiency being investigated is that certain working copies of the shop travelers were obtained and that these copies were compared against the official quality record copies. A possible discrepancy exists between certain infor-mation contained on the working copy versus the Q.A. record Copy.
The components involved are ductwork (geometrically shaped sheet metal) and hangers (structural steel support members) shipped to the following nuclear facilities:
t.
t
Page 2
- 1. LaSalle Nuclear Power Station Marseilles, 1111 noir
- 2. Clinton Power Station Clinton, Illinois
- 3. Midland Power Station Midland, Michigan 2.2 The work being reviewed for a potential discrepancy by the Zack Company is limited to work performed at its Cicero, Illinois and Chicago, Illinois facilities.
3.0 Potential Deficiency Discription:
3.1 The Zack Company utilizes a traveler system to fabricate the components and to record as built, as welded coriditions and c
as inspected verifications. Certain " working" copies (photo-copies) of the official travelers utilized by the production tradesmen contain the initials of various tradesmen who apparently performed some function on that component. Relevant information (i.e. welders numbers, material identification, etc.) was then transfered to the official copy (original traveler). The initial review of the working copies of certain travelers indicates that they tantain inconsistencies.
The Zack Company is in the process of trying to detemine if the initials of a welder on the working copy indicate that the individual actually welded on the component, or whether they represent some other function he performed.
4.0 Action Taken To Date:
The Zack Company has initiated the following actions in an effort to determine the ramifications of, the validity of the inconsistencies and the possible safety implications, if any.
l t
i t _.
Page 3 4.1 The Zack Company has initiated an investigation into the authenticity and validity of the information, the basis for
+
the accumulation for the information, and the reason the in-formation was being discarded.
4.2 The individual discarding the' box of paperwork (working copies of certain travelers) has been suspended for thirty days pending the results of the Zack investigation.
4.3 Pinkerton Security service was obtained to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance of all Zack records to provide assurance that no relevant documents would leave the premises.
4.4 The Zack Company has also initiated the gathering of the following types of information to substantiate the quality records and
- , provide the information necessary to determine whether a safety problem exists or.not Payroll records will be used to validate time frames welders x
worked.
Validation that all welders available were qualified and certified to perform work.
Va.lidating the other inspections perforrned (i.e. shop, site, client).
Obtaining additional clarification relevant to the meaning of information on working copies (photocopie~ ) from avail-s able personnel. This information could be obtained in form of telephone conversations, atatements, etc.
l 4.5 A management directive has be9n issued to all Zack Company employees regarding'lhe disposal of documents.
i l
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l l
l l
Page 4 i.
5.0 Corrective Action Plan:
5.1 To do a full scale -investigation of Safety Related Travelers, Weld Wire Issue Slips, Welder Qualifications and Shipment Packages corresponding to tho working copies of travelers obtained for the time frame of 1977 through 1981 on the' LaSalle Power Station, Midland Power Station and the Clinton Power Station.
5.2 As additional temporary surveillance program to verify the-identification of the record of' welders will be established to substantiate that correct welder identifications are transposed to the record documents.
5.3 To bring in-house, additional qualified personnel to assist in the investigation.
5.4 To submit a final report to the N.R.C. by August 31, 1982, e
i
LaSalle Project - 3300 Traveler Information:
1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permanent records systen for final turnover, also for the Quality Control Inspector verification.
2.
The white traveler was a copy of the yellow traveler used by the shop fabrication foremen to record as-built or as-welded conditions during actual fabrication.
A review of one hundred and seventy yellow and white safety-related shop.
travelers has revealed the following conditior.s; A.
Category-I, Seventeen (17) travelers shows the yellow travelers and the white travelers reveals the same welder information.
B.
Category-II, Thirty-eight (38) travelers shows the white traveler contains more welder identification than the yellow traveler.
1 C.
Category-III, Fifty-eight (58) white travelers shows different welder identification than the yellow traveler.
l 0.
Category-IV, Fifty-seven (57) yellow travelers shows more welder identifications than white traveler.
e e
6
r
.+
I.
1 Midland Project - 2400 Traveler Information; 1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permanent system for final turnover, also used for the Quality Control Inspectors verifications.
2.
The white traveler was a copy of the yellow traveler used by the shop fabrication foreman to record as-built or as-welded conditions, during actual fabrication.
A review of nine hundred and fifty-one safety-related shop travelers has revealed the following conditions at this time; A.
Six hundred and eighty-one (681) travelers shows the yellow travelers and the white travelers reveals the same welder information.
B.
One hundred and thirty (130) travelers shows the white travelers contains more welder identifications than the yellow traveler.
C. 'One hundred and forty (140) travelers show unverified welder qualification at the time of issue on > the travelers.
f t
Attachment #3.
9 Clinton Project - 2900 Traveler Information:
1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's pennanent system for final turnover, also used for the Quality Control Inspectors verifications.
2.
The white traveler was a copy of the yellow traveler used by the shop fabrication foreman to record as-built or as-welded conditions, during actual =. fabrication.
A review of eleven hundred and sixty-six (1166) safety-related shop travelers has revealed the following ' conditions at this time:
A.
Seven Hundred and twenty (720) travelers shows the yellow travelers and the white travelers reveals the same welder information.
B.
One Hundred and sixty-two (162) travelers show the white traveler contains more welder identifications than the yellow traveler.
C.
Two Hundred and eighty-four (284) travelers show unverified welder qualification at the time of issue dates on the travelers.
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n0ARD NOTIFICATION-82-94 Midland - Zack Part 21 Report on Welder Record Discrepancies
. DISTRIBUTION 1:
Document Control (50-329/330)
?
LB#4 Reading 3
E. Adensam-J
- D. Hood 4'
M. Duncan T. Novak/L. Berry a
D.Eisenhut/R. Purple.
M. Williams -
PPAS H. Denton/E. Case H. Thompson R. Mattson R.
Vollmer S. Hanauer Attorney, OELD OI&E W. J. Dircks, EDO (3)
A. Bennett, OELD (3)
E. Christenbury, OELD J. Scinto, OELD S. Chesnut, DL R. Warnick, R-III ACRS (16) Members of Midland Project h
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UNITED STATES
.! i p ~, ( (g NUCLEAR REGULATORY COMMISSION r, / y.,.
/, : l WASHINGTON, D. C. 20555 SEPTEMBER 16 S82 Docket Nos: 50-329 OM, OL and 50-330 OM, OL 4
HEMORANDUM FOR:
The Atomic Safety & Licensing Board for Midland Plant, Units 1 and 2 FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
BOARD NOTIFICATION - ZACK PART 21 REPORT ON WELDER RECORD DISCREPANCIES (BN 82-94)
In accordance with present NRC procedures regarding Board Notifications, the enclosed infomation is being provided for your information as constituting new infomation relevant and material to saf3ty issues.
This infomation deals with a report by the Zack Company entitled " Potential 10 CFR 21 Reportable Deficiency Evaluation for Accuracy of Welder Records". The report discusses deficiencies concerning the accuracy of welder records of Zack with regard to heating, venti-lation, and air conditioning (HVAC) at the Midland Plant.
The Zack Company is conducting an investigation of the Welder record discrepan-cies. Zack's report of this investigation is expected on or about September 24, 1982.
omas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: Board Service List Licensee Service List
Contact:
S. Chesnut, ONRR X29788 l
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MIDLAND Mr. J. W. Cook
- Vice President Lee L. Bishop Consumers Power Company Harmon & Weiss 1945 West Parnall Road 1725 I Street, N.W., Suite 506 Jackson, Michigan 49201 Washington, D. C.
20006 5
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 Three First National Plaza, Lansing, Michigan 48909 Sist. fl oor
- Chicago, Illinois 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consuners Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan ~17201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 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 Company
~
720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Wal t Apl ey Route 10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL)
Battelle Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass Avenue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III.
Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602 Mr. Ron Callen Mr, Paul Rau Michigan Public Service Commission Midland. Daily News 6545 Mercantile Way 124 Mcdonald Street P.O. Box 30221 Midland, Michigan 48640 Lansing, Michigan 48909 I
I 2
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Mr. J. W. Cook _
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 NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbour, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Engineers, Inc.
ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890
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4600 W 12TH PLACE
- CHICAGC (CICERO)ILL 60650
- 312/242 3434 4401 WESTERN FLINT MICHIGAN 485o6
- 313/736 2040 CUSTOM METAL FABRICATION August 2, 1982 U.S.N.R.C. Region III Office 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attn:
Mr. J.
G.
Keppler Re:
Telecon of July 29, 1982 to Mr. Robert Walker at 4:20 P.M.
Subject:
Potential-10CFR21 - Weld Records Gentlemen:
This letter is to confirm the verbal telephone report given by Mr.
D. E. Calkins, Manager of Engineering for the Zack Company on Thursday, July 29, 1982 at 4:20 P.M.
to Mr. Robert Walker at the Region III, Glen Ellyn offices of the Nuclear Regulatory Commission.
The attached report and corrective action plan has been pre-pared by Mr. Martin Skates, Quality Assurance Manager, as my designee for all Zack Company quality related matters.
During the course of an es:isting internal Zack Company investi-gation, initiated by the Zack Company officers, a box of paper-work was observed being taken to the trash by a plant employee.
The company maintenance man brought the documents to the atten-tion of Zack management.
l A preliminary review of the documents (see attached report for details) indicates a possible discrepancy between the welder of record and the welder who may have actually performed the welds.
l This potential discrepancy is still in the process of being l
fully investigated, but the initial indications are that it could have occurred during the 1977 to 1981 time frame.
. FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY
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+ DEDICATED TO CLEANING AND CUSTOMIZING THE AIR OF THE WORLD
- 8 m 7 Q _U.Le v t - *
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a U.S.N.R.C. Region III Office August 2, 1982 Page 2.
. The Zack Company has initiated and is still in the process of conducting a full scale investigation of this potential discrepancy.
However, in an attempt to keep all relevant information open and available to the appropriate parties, the Zack Company is initiating this potential 10CFR21 be-fore it has been detennined that a deficiency does exist.
By copy of this letter and the attached report the Zack Company is also confirming the verbal notifications given to the effected utilities.
The Zack Company will cooperate with the Nuclear Regulatory.
Commision and th6 respective utilities to the fullest de-gree possible in the performance of this investigation and its closure.
Should you have any questions or problems concerning this' matter, please do not hesitate to contact me or Mr. Martin Skates at (312) 242-3434.
Very truly yours, THE ZACK COMPANY
-M d
E CHRISTINE ZACK DE ZUTEL, PRESIDENT CZDZ/ art Encl.
cc Mr. William Harrington Baldwin Associates Mr.
L. E. Davis Bechtel Power Company Mr. Dan L. Shamblin Commonwealth Edison Company S'
n_
THE ZACK COMPANY POTENTIAL 10 CFR21 REPORTABLE DEFICIENCY EVALUATION FOR ACCURACY OF WELDER RECORDS PREPAREDBY:[
N
[D Vavid E. Calkins, Manager Engineering REVIEWED BY: %. L. %
9[2 /82.
M. L. Skates, Manager Quality Assurance i
APPROVED BY:
Mb7
' 7. ( Q CFristine Zack Dery, PresidenQ 1
i w.
Pag 2 1
1.0 Notification
1.1 The Zack Company in accordance with the intent of the reportability requirements within the Code of Federal Regulations, is reporting a Potential 10CFR21 condition relating to a possible discrepancy in the documentation that reflects the welder of record and the welder who may have actually performed the welds.
1.2 This report constitutes the Zack Company's official written notificaiton of a Potential 10CFR21 condition and confirms our verbal notification on Thursday, July 27, 1982 at 4:20 PM to Mr. Roger Walker at the Region III Glen Ellyn Offices of the Nuclear Regulatory Commission.
The information relative to this report was obtained Tuesday, July 27, 1982 The maintenance man observed a box of paperwork being taken to the trash by a plant employee. The maintenance man checked with manage-ment to see if the documents should be kept. A review of some of the documents raised questions about welding documentation.
2.0 Identification
The possible deficiency being investigated is that certain working copies of the shop travelers were obtained and that these copies were compared against the official quality record copies. A possible discrepancy exists between certain infor-mation contained on the working copy versus the Q.A. record copy.
The components involved are ductwork (geometrically shaped sheet
~
metal) and hangers (structural steel support members) shipped to the following nuclear facilities:
- l l
~
__m....m...._..._.
r Page 2
- 1. LaSalle Nuclear Power Station Marseilles, Illinois
- 2. Clinton Power Station Clinton, Illinois
- 3. Midland Power Station Midland, Michigan 2.2 The work being reviewed for a potential discrepancy by the Zack Company is limited to work performed at its Cicero, Illinois and Chicago, Illinois facilities.
3.0 Potential Deficiency Discription:
3.1 The Zack Company utilizes a traveler system to fabricate the components and to record as built, as welded conditions and as inspected verifications. Certain " working" copies (photo-copies) of the official travelers utilized by the production tradesmen contain the initials of various tradesmen who apparently performed some function on that component. Relevant information (i.e. welders numbers, material identification, etc.) was then transfered to the official copy (original traveler). The initial review of the working copies of certain travelers indicates that they contain inconsistencies.
The Zack Company is in the process of trying to determine if the initials of a welder on the working copy indicate that the individual actually welded on the component, or whether they represent some other function he performed.
4.0 Action Taken To Date:
The Zack Company has initiated the following actions in an effort to determine the ramifications of, the validity of the inconsistencies and the possible safety implications, if any.
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Page 3 i
4.1 The Zack Company has initiated an investigation into the authenticity and validity of the information, the basis for the accumulation for the information, and the reason the in-formation was being discarded.
4.2 The individual discarding the box of paperwork (working copies of certain travelers) has been suspended for thirty days pending the results of the Zack. investigation.
4.3 Pinkerton Security service was obtained to provide 24 hcur surveillance of all Zack records to provide assurance that no relevant documents would leave the premises.
4.4 The Zack Company has also initiated the gathering of the following types of information to substantiate the quality records and provide the information necessary to determine whether a safety problem exists or not Payroll records will be used to validate time frames welders worked.
Validation that all welders available were qualified and certified to perform work.
Validating the other inspections performed (i.e. shop, site, client).
Obtaining additional clarification relevant to the meaning of information on working copies (photocopies) from avail-able personnel. This information could be obtained in form of telephone conversations, statements, etc.
4.5 A management directive has been issued to all Zack Company employees regarding the disposal of documents.
i
.i Page 4 5.0 Corrective Action Plan:
5.1 To do a full scale investigation of Safety Related Travelers, Weld Wire Issue Slips, Welder Qualifications and Shipment Packages corresponding to the working copies of travelers obtained for the time fraee of 1977 through 1981 on the-LaSalle Power Station, Midland Power Station and the Clinton Power Station.
S.2 As additional temporary surveillance program to verify the
~
identification of the record of welders will be established to substantiate that correct welder identifications.are transposed to the record documents.
5.3 To bring in-house, additional qualified personnel to assist in the investigation.
5.4 To submit a final report to the N.R.C. by August 31, 1982.
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LaSalle Project - 3300 Traveler Information:
1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permanent records system for final turnover, also for the Quality Control Inspector verification.
2.
The white traveler was a copy of the yellow traveler used by the shop fabrication foremen to. record as-built or as-welded conditions during i
actual fabrication.
A review of one hundred and seventy yellow and white safety-related shop travelers has revealed the following conditions; A.
Category-I, Seventeen (17) travelers shows the yellow travelers and the white travelers reveals the same welder information.
i B.
Category-II, Thirty-eight (38) travelers shows the white traveler contains more welder identification than the yellow traveler.
C.
Category-III, Fifty-eight (58) white travelers shows different welder identification than the yellow traveler, D.
Category-IV, Fifty-seven (57) yellow travelers shows more welder identifications than white traveler, 1
l 1
1 e
i
=~
Midland Project - 2400 Traveler Infonmation; i
l 1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permanent system for final. turnover, also used for the Quality Control Inspectors verifications.
f 2~
The white traveler was a copy of the yellow traveler used by the shop fabrication foreman to record as-built or as-welded conditions, during actual fabrication.
A review of nine hundred and fifty-one safety-related shop travelers has revealed the following conditions at this time; A.
Six hundred and eighty-one (681) travelers shows the yellow travelers and the white travelers reveals the same welder information.
B.
One hundred and thirty (130) travelers shows the white travelers contains more welder identifications than the yellow traveler.
C. 'One hundred and forty (140) travelers show unverified welder qualification at the time of issue on the travelers, a
e
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.... _..__ _ -.. i-.-._ __ _
~
Attachment #3
~
Clinton Project - 2900 Traveler Information:
4 1.
The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permane'nt system for final turnover, also used for the Quality Control Inspectors verifications.
2.
The white traveler was a copy of the yellow traveler used by.the shop fabrication foreman to record as-built or as-welded conditions, during.
actual fabrication.
A review of eleven hundred and sixty-six (1166) safety-related shop travelers has revealed the following conditions a.t this time:
A.
Seven Hundred and twenty (720) travelers shows the yellow travelers and the white travelers reveals the same welder information.
B.
One Hundred and sixty-two (162) travelers show the white traveler contains more welder identifications than.the yellow traveler.
C.
Two Hundred and eighty-four (284) travelers show unverified welder qualification at the time of issue dates on the travelers.
s.
. '. - J y
3 SEPTEMSER 1 6 1982 DISTRIBUTION See Attached Sheet
~
Docket Nos: 50-329 OM, OL and 50-330 OH, OL m
MEMORANDUM FOR:
The Atomic Safety & Licensing Board for Midland Plant, Units 1 and 2 i
FROM:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing
SUBJECT:
BOARD NOTIFICATION - ZACK PART 21 REPORT ON WELDER RECORD DISCREPANCIES (BN 82-94)
In accordance with present NRC procedures regarding Board Notifications, the
- M enclosed information is being provided for your information as constituting new 1
information relevant and material to safety issues. This information deals with
.l a report by the Zack Company entitled " Potential 10 CFR 21 Reportable Deficiency Evaluation for Accuracy of Welder Records". The report discusses deficiencies
.l concerning the accuracy of welder records of Zack with regard to heating, venti-lation, and air conditioning (HVAC) at the Midland Plant.
Tne Zack Company is conducting an investigation of the Walder record discrepan-cies. Zack's report of this investigation is expected on or about September 24, 1982.
Original Signed by:
Romas M. Novak Thomas M. Novak, Assistant Director for-Licensing Division of Licensing
Enclosure:
As stated
'cc: Board Service List Licensee Service List t,
l/
Contact:
/S. Chesnut, ONRR l
/X29788 s
i l
/i sl &@ Y #LP F DE:L DL:L Schesnut:lb TMNovak nni 109 nGI 109
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y
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gpl3 MEMDRANDLH FOR: Elinor G. Adensam, Chief Licensing Branch M. DL Cecil 0. Thomas, Acting Chief Standardization & Special Projects Branch, DL FROM:
Thomas M. Novak, Assistant Director for Licensing, DL i
SUBJECT:
ZACK COMPANY WELDING RECORDS It has been detennined that the attached information conceming Zack Company welding records may be related to Midland and Clinton and worthy of notification to the appmpriate Boards and parties.
For those cases in which this issues is related to a contention, but the hearing has not yet started, you should assure that the substance s
of this board notification is addressed in the appropriate SER or SSER.
-7 Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc:
D. Hood, LB M H. Williams, SSPB M. Williams, DL R. F. Warnick, R-III I
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.....9.9Ip.8.?...... 091j..6.2..... c.m y NAC FCEM 314 (10-40) NACM 024o OFFICIA' . WORD COPY usam n-m
1 '#4 E,( %g% . UNITED STATES NUCLEAR REGULATORY COMMISSION o t -l WASHINGTON, D. C. 20555 SEP i 3 1992 MEMORANDlN FOR: Elinor G. Adensam, Chief. Licensing Branch #4, DL Cecil 0. Thomas, Acting Chief Standardization & Special Projects Branch, DL FROM: Thomas M. Novak, Assistant Director for. Licensing,- DL
SUBJECT:
ZACKCOMPANYWEi.DINGRECORDS It has been determined that the attached information concerning Zack Company welding records may be related to Midland and Clinton and worthy of notification to the appropriate Boards and parties. For those cases in which this issues is related to a contention, but the hearing has not yet started, you should assure that the substance of this board notification is addressed in the appropriate SER or SSER. d5 Thomas M. Novak, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated cc: D. Hood, LB#4 H. Williams, SSPB M. Williams, DL R. F. Warnick, R-III I'- s / b >,- r i w 2 s .i m r
WI D
- jen:vy),,
UNITED STATES NUCLEAR REGULATORY COMMISSION
- [
),. (, g . e, l WASHINGTON, D. C. 20$55 "k'...../ September 8, 1982 MEMORANDUM FOR: Thomas Novak, Assistan't Director for Licensing Division of Licensing FROM: Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
BOARD NOTIFICATION 82-94 I have determined that the attached information concern.ing the Zack Company welding records should be sent to the appropriate Boards and parties in accordance with the procedures of Office Letter No.19 (Rev.1).- You should note that the procedure requires that this infonnation either be issued as a Board Notification, or if more than 30 days exists prior to the hearing, be included in the SER as a testimony. This notification relates to LaSalle, Midland and Clinton. Issue this. item as Board Notification Number 82-94. "y Darrell G. Eisenhut, Director Division of Licensing
Enclosure:
As Stated ,9 $f.ls-s'.. G. Meyer w " h([f h5 /~ i;. 7 1
m... ~ gPa mah UNITS 3 STATsS f ),, NUCLEAR RE2ULATORY COMMISSl!N ascion ::: y g 2. .-a ne noosavatt noao atsu attyn, stunois som September 1, 1982 MEMORANDUM FOR: D. G. Eisenhut, Director, Division of Licensing, NRR FROM: R. F. Warnick, Acting Director, Office of Special Cases
SUBJECT:
RECOMMENDATION FOR NOTIFICATION OF LICENSING BOARD Enclosed is a potential 10 CFR 21 report from the Zack Company. The Zack Company is a heating, ventilation, and air conditioning (HVAC) subcontractor at three power plant construction sites within Region III (Clinton,'LaSalle and Midland). The subject report discussed deficiencies concerning the accuracy of welder records'and is limited to work performed program is an issue which will be addressed in the )(Quality Assurance (QA) at the Zack facility in Cicero, Illinois. The Zack idland OM/0L proceedings. Region III has reviewed the materiality and relevancy of this matter and perceives the information identified in the enclosure 'to be material and relevant to the Midland OM/0L proceedings. Region III believes NRC policy dictates that the information be forwarded to all sitting boards for cases involving Zack Company as the HVAC subcontractor. The Zack Company has initiated an investigation of the welder record discrepancies. Region III is presently waiting for a followup report from the Zack Company which will identify the results of this investigation. This followup report is expected by September 10, 1982. If you have any questions or desire further information regarding this matter, please call me. R.K. hr h R. F. Warnick, Acting Director Office of Special Cases
Enclosure:
As stated cc w/o enclosure: W. D. Shafer R. N. Gardner R. B. Landsman R. Cook B. Burgess 1 I d A 9 ! ) A 9 / ism,f$ -s' O U e 1 r--- w--,. - e-
4600 12TH PLACE
- CHICAGO (CICERO)ILL 60650
- 312/242 3434 440' WESTERN e FLINT MICHIGAN 40506
- 313/736 2040 1.
the 2?A@X l co. ~ CUSTOM METAL FABRICATION August 2, 1982 U.S.N.R.C.' Region III Office 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attn: Mr. J. G. Keppler Re: Telecon of July 29, 1982 to Mr. Robert Walker at 4:20 P.M.
Subject:
Potential-10CFR21 - Weld Records Gentlemen: This letter is to confirm the verbal telephone report given by Mr. D. E. Calkins, Manager of Engineering for the Zack Company on Thursday, July 29, 1982 at 4:20 P.M. to Mr. Robert Walker at the Region III, Glen Ellyn offices of the Nuclear Regulatory Commission. The attached report and corrective action plan has been pre-pared by Mr. Martin Skates, Quality Assurance Manager, as my designee for all Zack Company quality related matters. Dur 7g the course of an existino internal Zack Company investi-gatien, initiated by the Zack Company officers, a box of paper-work was observed being taken to the trash by a plant employee. The company maintenance man brought the documents to the atten-tion of Zack management. A preliminary review of the documents (see attached report f,or details) indicates a possible discrepancy between the weldnr of record and the welder who may have actually performed the welds. This potential discrepa: cy is still in the process of being fully investigated, but the initial indications are that it could have occurred during the 1977 to 1981 time frame.
- FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY *
- DEDICATED TO CLEANING AND CUSTOMlZING THE AIR OF THE WORT O
- h A
U.S.N.R.C. R3;ien III Offico ~ August 2, 1982 Page 2 i The Zack Company has initiated and is still in the-process f conducting a full scale investigation of this potential -o discrepancy. However, in an attempt to keep all relevant-information open'and available to the appropriate parties, the Zack Company is initiating this potential 10CFR21 be-fore it has been determined that a deficiency does exist. 1 By copy of this Ietter and the att' ached report the Zack Company is also confirming the verbal notifications given to the effected utilities. ~ The Zack Company will cooperate with the Nuclear Regulatory Commision and the respective utilities to the fullest de-gree possible in the performance of this investigation and its closure. Should you have any questions or problems concerning this matter, please do not hesitate to contact me or Mr. Martin Skates at (312) 242-3434. I very truly yours, THE ZACK COMPANY CHRISTINE ZACK DE ZUTEL, PRESIDENT F CZDZ/ art i: E n'cl. cc: Mr. William Harrington if Baldwin Associates Mr. L. E. Davis l Bechtel Power Company l Mr. Dan L. Shamblin l Commonwealth Edison Ccmpany ( d - - +., v., -,...-_e+- m.-- - e
m = p. ^ THE ZACK COMPANY ~ POTENTIAL 10 CFR21 ~ REPORTABLE DEFICIENCY EVALUATION FOR ACCURACY OF WELDER RECORDS A PREPARED BY: Tavid E. Calkins, Manager Engineering REVIEWED BY: %. l. S bw - B[2[S2. M. L. Skates, Manager Quality Assurance a,Jo 7 7 L.Q APPROVED BY: 2 CTiristine Zack DeIg, PresidenQ f 4 l l 4 e e
b +-e6 AsWw Paga 1
1.0 Notification
1.1 The Zack Company in acccrdance with the intent of the reportability requirements within the Code of Federal Regulation.c. is reporting L a Potential 10CFR21 condition relating to a possible discrepancy ) t in the documentation that reflects the welder of record and the welder who may have actually performed the welds. i 1.2 This report constitutes the Zack Company's official written notificaiton of a Potential-10CFR21 condition and confirms our verbal notification on Thursday, July 27, 1982 at 4:20 PM to Mr. Roger Walker at,the Region III Glen Ellyn Offices of l the Nuclear Regulatory Commission. l The information relative to this report was obtained Tuesday, July 27, 1982. The maintenance man observed a box of paperwork being taken to the trash by a plant employee. The maintenance man checked with manage-ment to see if the documents should be kept. A review of some of the documents raised questions about welding documentation.
2.0 Identification
The possible deficiency being investigated is that certain working copies of the shop travelers were obtained and that these copies were compared against the officiti quality record copies. A possible discrepancy exists between certain infor-mation contained on the working copy versus the Q.A. record copy. The components involved are ductwork (geometrically shaped sheet metal) and hangers (structural steel support members) shipped to the following nuclear facilities: / e O___ _z__ __m____ _ _ _ _ _ ____________m_ _ ___._ i __
a ~ Page 2
- 1. LaSalle Nuclear Power Station Marseilles Illinois
- 2. Clinton Power Station Clinton, Illinois
- 3. Midland Power Station Midland,' Michigan 2.2 The work being reviewed fdr a potential discrepancy by the Zack Company is limited to work performed at its Cicero, Illinois and Chicago, Illinois facilities.
3.0 Potential Defic.iency Discription: 3.1 The Zack Company utilizes a traveler system to fabricate the components and to record as built, as welded conditions and as inspected verifications. Certain " working" copies (photo-copies) of the official travelers utilized by the production tradesmen contain the initials of yarious tradesmen who apparently performed some function on that component. Relevant information (i.e. welders numbers, material identification, etc.) was then transfered to the official copy (original traveler) The initial review of the working copies of certain travelers indicates that they contain inconsistencies. The Zack Company is in the process of trying to determine if the initials of a welder on the working copy indicate that the individual actually welded on the component, or whetiier they represent some other functior. he performed.' 4.0 Action Taken To Date: The Zack Company has initiated the following actions in an effort to determine the ramifications of, the validity of the inconsistencies and the possible safety implications, if any. t li
^ .1_ I Page 3 i 4.1 The Zack Company has initiated an investigation into the authenticity and validity of the information, the basis for the accumulation for the information, and the reason the in-formation was being discarded. 4.2 The individual discarding the box of paperwork (working copies of certain travelers) has bee'n suspended for thirty days pending the results of the Zack investigation. 4.3 Pinkerton Security service was obtained to provide 24 hour surveillance of all Zack records to provide assurance that no relevant documents would leave the premises. 4.4 The Zack Company has also initiated the gathering of-the following types of information to substantiate the quality records and provide the information necessary to determine whether a safety problem exists or not Payroll records will be used to validate time frames welders worked. Validation that all welders available were qualified and certified to perform work. Validating the other inspections performed (i.e. shop, site, client). Obtaining additional clarification relevant to the meaning of information on working copies (photocopies) from avail-able personnel. This information could be obtained in form of telephone conversations, statements, etc. 4.5 - A management directive has been issued to all Zack Company employees regarding the disposal of documents. 't i 2 e m . '= .a
- Pag 2 4
- 5.0 Corrective Action Plan: 5.1 To do a full scale investigation of Safety Related Travelers, Weld Wire Issue Slips, Welder Qualifications and Shipment Packages corresponding to the working copies of travelers-obtained for the time frame of 1977 through 1981 on the LaSalle Power Station, Midland Power' Station and the Clinton Power Station. 5.2 As additional, temporary surveillance program to verify the identification of the record of welders will be established to substantiate' that correct welder identifications are transposed to the record documents. 5.3 To bring in-house, additional qual /ied personnel to assist in the investigation. 5.4 To submit a final report to the N.R.C. by August 31, 1982. ~ t 1 ( / p / A 4 in
o s LaSalle Project - 3300 Traveler Information: l 1. The yellow traveler is the-Quality Control Document that is maintained as a part of Zack's permanent records system for final. turnover, also I for the Qual'ity Control Inspector verification. 2. The white tr&veler was a copy of,the yellow traveler used by the shop fabrication foremen to record as-built or as-welded conditions during actual fabrication. A review of one hundred and seventy yellow and white safety-related shop travel'ers has revealed the following conditions; l A. Category-I, Seventeen (17) travelers shows the yellow travelers and the white travelers reveals the same welder information. B. Category-II, Thirty-eight (38) travelers shows the white traveler contains more welder identification than the yellow traveler. C. Category-III, Fifty-eight (58) white travelers shows different welder identification than the yellow traveler. D. Category-IV, Fifty-seven (57) yellow travelers shows more welder identifications than white traveler. 1
Midland Project - 2400 Traveler Information; 1. The yellow traveler is the Quality Control Document that is maintained as a part of Zack's permanent system for final turnover, also used for the Quality Control Inspectors verifications. 2. The white traveler was a copy of the yellow traveler used by the shop fabrication foreman to record as-built or as-welded conditions, during actual fabrication. [ A review of nine hundred and fifty-one safety-related, shop travelers has revealed the following conditions at this time; A. Six hundred and eighty-one (681) travelers shows the yellow travelers and the white travelers reveals the same welder information. B. One hundred and thirty (130) travelers shows the white travelers contains more welder identifications than the yellow traveler. C. One hundred and forty (140) travelers show unverified welder qualification at the time of issue on the travelers. i 'k I e -.....,.-,,--...,,,,-.-,,-,y.-
Attachment #3 i Clinton Project - 2900 Traveler Information: 1. The yellow traveler is the Quality Control Document that is maintained as a part of Zack's pernianent system for final turnover, also used for the Quality Control Inspectors verifications. 2. The white traveler was a copy of the yellow traveler used by the shop fabrication foreman to record as-built or as-welded conditions, during actual fabrication. A review of eleven hundred and sixty-six (1166) safety-related shop travelers has revealed the following conditions at this time: A. Seven Hundred and twenty (720) travelers shows the yellow 'tr.avelers and the white travelers reveals the same welder information. B. One Hundred and sixty-two (162) travelers show the white traveler contains more welder identifications than the yellow traveler. C. Two Hundred and eignty-four (284) travelers show unverified welder' qualification at the time of issue dates on the travelers. 4 d s e
6-4 h.! e, gc127 DISTRIBUTION: Doc t Nos. 50-329/330 densa.n Docket Nos: 50-329 OM, OL MMiller and 50-330 OM, OL MDuncan E HORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing i j Division of Licensing THRU: Elinor G. Adens'an, Chief Licensing Branch No. 4 Division of Licensing 2 FROM: Melanie A. Miller, Project Manager Licensing Branch No. 4 Division of Licensing
SUBJECT:
ADMITTED HIDLAND CONTENTIONS Enclosed is a tabular listing of all contentions accepted by the board for litigation (Attachment 1). The table is provided for informational purposes and will be continuously updated as changes in contention status occur. The intervenor's name and contention nianber are 41sted with a corresponding key phrase provided for each contention for easy reference.. Additionally, the date under the contention number refers to the year it was accepted by the board and is listed to avoid confusion in redundant contention ntabers.
- sumarizes the contentions and the revieners responsible for j
testimony. This attachment is also subject to change. We are sending this table to responsible m yiewers by copy of this memorandian. l If there are questions, I can~ be reached at X24259. a i MeItnia A. Miller, Project Manager [ Licensing Branch No. 4 l Divisior of Licensing l
Enclosures:
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f f e. e-s. ec w/ enc 1: W. Paton H. W11 cove N. Wright D. Hood R. Hernan ~ F. Rowsome J. Carson. ANL H. Walker W. Shafer. RIII J. Kane J. P. Knight 'O. Rohrer W. Lafave C. Anderson C. Cheng R. Gonzales B. Elliot H. Messier N. Fields F. Cardile F. Rinaldi P. Chen. ETEC S. Tsai, ANL / / l OFFN:E) suaameb onep wne ronu ais o+en nacu ose OFFICIAL RECORD COPY usam mi-m. a
i f n y ? I e ATTACHMENT 1 ADMITTED MIDLAND CONTENTIONS ( k s l I j
e Admitted Midlan1 Contentions Contention # Key Phrase Cont'ention L Sinclair 3 severe accidents The assessment of the likelihood and (1982) severity of " severe accidents" (or class 9 accidents) in the DES is inadequate in that it relies for methodology and prob-ability of occurrence of severe accidents on the Rasmussen Report (WASH-1400) DES 5-45-66. However, a new NRC report reveals that the Rasmussen methodology, at least as it pertains to more severe accidents (total meltdown), significantly understates the risk of such accidents by a factor of 20. Precursors to Potential Severe Core Damage Accidents: 1969-1979, a Status Report, NUREG/CR/2497 (June 1982).* This report. shows that probabilities of severe accidents should be derived on the basis of ' actual accident sequences and significan.t events, rather than the Rasmussen methodology. The failure of the DES to incorporate this analysis cripples the entire Class 9 analysis of the DES. s Sinclair 5 cooling pond The staff DEIS is deficient in that it (1982) continues to base its analysis of the cooling pond's effectiveness in controlling themal discharges (DEIS at 4-6) and ice and fog generation (DEIS at 5-9) on a study. based on cooling pond perfonnance in a sub-stantially different cli.aatic region. Instead, the DEIS should analyze infonnation from the Dresden, Illinois nuclear facility n (or other data from a com.arabley sized and situated facility) for both purposes, and present the baseline data from that facility to allow the agency and the public to reach an infonned decision on the adverse affects of the cooling pond. Sinclair 7 synergi sm The issue of synergism between chemicals and (1982) radiation (Contention 61, (old 55) Contentions of Mary Sinclair,1978) must be re-opened based on a new study. Scientists at Sandia National Laboratory, Albuquerque, New Mexico, have conducted tests sponsored by the NRC on polymer cable insulation and jacketing used in nuclear power containment buildings. (Indus-trial Research and Development, June,1982) t 1 1k- ,1.~_~,,,-r.. m ,m__...- .m-_ -,;,-.,%f__-.E-,.,, yr ,i.~,.-.,-
r e -2 ~ Contention # Key Phrase Contention ~ They have found that long-term low doses of 4 gamma radiation degrades many polymers more than do equal doses administered at higher rates in shorter testing times. Besides the dose rate effect, the researchers have also found that synergistic effects.can occur when polymers are exposed to radiation and mildly elevated temperatures. Dr. Roger Clough, of Sandia National Laboratory, has stated that the present testing method underestimates the long-term effects and synergisms that display themselves only in longer tests. This study indicates that the useful life of the plant 4 wili be shortened considerably because of this problem. Sinclair 6 QA-Howard See Enclosure 1 (1982) Sinclair 8 QA-records The Zack Company of Chicago which has been the (1982) ' contractor responsible for the heating, cooling and ventilating system of the Midland nuclear plant has filed a non-compliance report with the NRC on or abour August 4,1982, indicating that two sets of records -- a shop record and a QA record -- which are required to be kept to guarantee the integrity of the welds anu therefore, must be signed by the same welder, were, in fact, signed by two different persons. This violates the federal standards for docu-mentation for safety-related systems in a nuclear power plant. This breakdown in quality control means thc principal method that the NRC has for guaranteeing the integrity of the welds in the HVAC system (which is already built into a large part of the plant) has failed and that therefore the protection of the public health and safety cannot be guaranteed as required by 10 CFR 50.57(1),50.57(2),and50.57(3)and Part 50, Appendix B. Sinclair 16 QA-welders In the Part 21 report that Zack Co. filed which (1982) was signed by Dave Calkins of Zack and prepared by Howard McGrance of Consuners Power Co., it was disclosed that 140 Travelers showed unver-f ified welder qualifications for fabrication welds. Without qualified welders for this large f
Contention # Key Phrase Contention number of welds, the necessary guarantee for 5 the protection of the public health and safety cannot be met as required by 10 CFR' 50.57(1), 50.57(2) and 50.57(3). In addition, this report indicates that the quality assurance in construction of these plants has not been met as required by Part 50, Appendix B. Sinclair 24 ground stability The present site for the Midland facility is (1979) not only inappropriate for the reasons set forth in Contention 9, but also affirmatively unsafe. Serious questions have been raised concerning the ground stability of portions of the site. At least one of the essential buildings of the reactor complex is reported sinking, and con-struction has been halted on that building. As a result of the serious and unresolved questions concerning ground stability, the findings required by 10 CFR 50.57(a)(3)and50.57(a)(6) cannot be made. Sinclair 27 evacuation Recently discovered information indicates that (1979) the Advisory Committee on Reactor Safeguards conditioned the acceptability of the present Midland site for the project on the existence of a highly effective evacuation system. However, no adequate evacuation plans exist. Aerial surveys of traffic conducted during the con-struction permit stage of these proceedings, and taken during shift changes, indicated that evacuation in an acceptable time cannot be accompli shed. Further, relying on the evacu-ation plans of Dow Chemical Company is inade-quate. During the evacuation following the recent chlorine leak, evacuacion procedures were chaotic and all communications were l either jammed or ineffectual. In fact at an l NRC conference held in Midland, Michigan on September 8,1978, both the County Road Com-mission and the Midland Planning Commission admitted that they have not considered evacu-ation routes. As a result, the findings 50.57(a)(3)(1)and required by)10 CFR i 50.57(a)(6 cannot be made. j I l l tl r
4 4-Contention # Key Phrase Contention ~ Sinclair 28 water hammer Contention 28 deals with the water hammer (1982) problem of pressurized water reactors of the Midland type. This problem.is identified as one of the unresolved safety issues applicable to Midland 1 & 2 in the SER, C-4.. Babcock and Wilcox (B&W) plants with an internal auxiliary feedwater' (AFW) feed ring of the.same design as Midland in recent events, have shown a marked susceptibility to internal damage of the feed ring as a result of water hammer. From this, reduced cooling in the steam gen - erators could occur as a result of inadequate AFW flow following loss of normal feedwater fl ow. (NRC Response to Interrogatory 7) Since this effect involves critical ' safety systems, the Task A-1 report (Jan.,1980) states that systematic review precedures in the OL review process will requirt the Appli-cant to: 1) address potential water hammer , problems in various systems; 2) demonstrate that there are adequate design fea:ures and
- 3) expand the preoperational testias program to insure that these design features and operating procedures do prevent damaging water 2
hammer events. 4 However, the SER does not indicate that these criteria have been met by the Applicant. As a result of this omission, the findings required by 10 CFR Q 50.57(a)(3)(1) and 50.57(a)(6) can-not be made. Sinclair 30 tube integrity The degradation of steam tube integrity due to (1982) corrosion induced wastage, cracking reduction in tube diameter, and vibration in$'ced cracks is a serious unresolved safety problem at the Midland nuclear plant. It is admitted that the chemistry of the cooling water is critical to l prevention of steam tube failure, (NUREG-0886). However, the fact that these plants depend on cooling water from the cooling pond increases the likelihood of ' corrosion and poor water chenistry because the DEIS states that the plant dewatering system will first be discharged to the cooling pond. '(DEIS at 5-2). That means that many wastes, including radioactive j i Y r r ,-.._.-.-..r, . - ~ n-..- n -.,
'~ 5-2 - Contention # Key Phrase Contention materials from leaks and spills on the-reactor site, can enter the cooling pond and disrupt the chemistry of the pond. Therefore, due to this contribution of an undetermined amount and quality of ground dewatering inflows to the cooling pond, the NRC's bland assurance that corrosion is unlikely due to the lack of sodium thiosul fate, is ' unsatisfactory. (NRC Response to Interrogatroy 9.j.) In fact, due to the contribution of groundwater, the NRC is not fully aware of the likely constituents of the coo:ing pond, and the findings required by 10 CFR 950.57(a)(3)(i) and 50.57(a)(6) cannot be made. Stamiris Ib, c cost benefit NRC's economic cost benefit analysis of the DES 1 (1982) is faulty' and misleading because it: i
- b. underestimates decommissioning costs
- c. overestimates lifespan of Unit 1 Stamiris 2 internal reporting C'PC/NRC internal reporting systems intended to (1982)
~ allow plant workers to raise concerns or criti-(consolidatedwith ci:ms about inadequate workmanship or practices Sinclair 6) are ineffective because they have resulted in job losses due to QA/QC reporting. (Midland Daily News articles dated //20/82, 6/28/82, and Howard affidavit, 7/30/82) Stamiris 6 groundwater The NRC risk assessment in the DES does not con-(1982) sider potential effects of permanent dewatering on groundwater relationships. Stami ri s 8 audit The ACRS has recommended an assessment of (1982) Midland's design adequacy and construction quality in their 6/18/82 report'(SER Supplement 1, Appendix G). In order to assure that this audit be thorough and objective, it must be performed by an independent third party of a competing contracting firm. Such a requirement was imposed by the ASLB in the Houston Power and Light, 50-498 and 50-499 OL proceeding, i 4/30/82. And, due to the pattern of design deficiencies (4/20/82 SALP, p.16) such an independent tedit is necessary to assure the design integrity of this plant. However, the t A-i -r, r-, ,~,- -,- - - - =, - -, -,. --n+--n.---
~ i 6-Contention # Key phrase Contention NRC has not required (SER Supplement ~1, p. 19-2(1)), and CPC has not canmitted (7/9/82 Tedesco to Cook letter) to such an independent audit. Stami ri s 10, b, d managerial attituce See Enclosure 2 (1980) Jtamiris 2a-d schedule pressares See Enclosure 3 (1980) Stamiris 3 QA-soil s See Enclosure 4 (1980) Stant ris 4 inadequate renediation See Enciesure 5 (1980) Marshall 2 settling Preser.t geological conditions, according to (1979) newspaper accounts, is causing the settling of the generator building at the Nuclear Power Plant site. s Warren 1 fill soil The composition of the fill soil used to pre-(1980) pare the site of the Midland Plant - Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have pennanently corrected soil settlement problems. The NRC has indicated the random fill dirt was used for backfill. The canponents of random fill can include loose rock, broken concrete, sand, silt, ashes, etc. all of which cannot be com-pacted through pre-loading procedures. Warren 2 seepage A. Because of the known seepage of water from the cooling pond into the fill soils in the power block area, permanent dewatering pro-cedures being proposed by Consumers Power Company are inadequate, particularly in the event of increased water seepage, flooding, ~ failure of pumping systems and power outages. Under these conditions, Consumers cannot pro-vide reasonable assurance that stated maximum levels can be maintained. l A e!
B. Given the facts alleged in Contention 2.A. and considering also that the Saginaw Valley is built upon centuries of silt deposits, these highly permeable soils which underlie,. in part, the diesel generator b'uilding and other class I structures may be cdversely affected by increased water levels producing liquefaction of these soils. The following will also be affected: 1 borated water tanks 2 diesel fuel oil tanks. Warren 3 DGB stress Pre-loading procedures undertaken by Consumers (1980) Power have induced stresses on the deisel generating building structure and have reduced the ability of this structure to perform its essential functions under that stress. Those l remedial actions that have been taken have pro-I duced uneven settlement and caused inordinate stress on the structure and circulating water lines, fuel oil lines, and electrical conduit. s l l l t
Ericicsura1 Sinclair Contention #6 NRC regulations at 10 CFR Part 50, Appendix B require that applicants for oper-ating licenses develop and implenent a quality assurance program for the protection of the public from improper materials or unworkmanlike practices. This QA program includes such elements as procurement document control, control of purchased material, equipnent, and services, proper inspections and handling of nonconforming materials, corrective actions, and audits by trained personnel. However, the affidavit attached to this contention and summarized below shows clearly that the QA program for the Midland plant was not in compliance with these requirements, and that therefore, quality assurance and control cannot be established at the Midland nuclear plant. l As basis for this contention, intervenor Mary Sinclair references the affidavit of Mr. Albert T. Howard, a former Quality Assurance Documentation Supervisor for Zack Company, (from October 19, 1981 through April 30,1982) which was under contract to supply equipnent for the heating, ventilating and air conditioning (HVAC) system of the Midland plant. His affidavit documents the complete breakdown of the QA program for the Midland plant, leading to his dismissal for refusing to confrom to Zack's improper QA prac-tices. Those improper practices, with regard to the Midland plant specifically, or 4 all of Zack's nuclear clients generally, are detailed as follows: 1. Howard states that his supervisor, Mr. Calkins, had investigated and reported the QA problems Zack was having with the Midland plant to the Midland plant to the Midland Site Manager as early as August 28, 1981. (at4) i 2. As a result of this report, " major QA reorganizations" were undertaken at Midland, to correct improper QA documentation. Iji,. 3. Soon after Howard's promotion to Supervisor of the Documents Assurance Department, Howard became aware of " serious deficiencies" in QA docu-mentation. (at 5). 4. On November 18, 1981, a Midland QQ contract employee directed Howard to sign a form attesting to having completed the requisite training for his position, in spite of the fact that Howard did not receive 1 such training. Id i 5. On November 30, 1981, Howard reviewed reports which summarized various QA deficiencies at Midland, including such tenns as: ( "certs altered"; " white out used and retyped"; and " heat number altered to agree with certification"; missing signa-tures; certifications missing; lack of test data for pur-chases; correspondence that steel had been purchased without verification and traceability; and stickers indicating com-pliance with professional standards. As the summary noted on the latter item, " Authenticity of the signatures is questionable." (at6). I A. e' m . ~ -. _.,. _, _. - .-_._,,-._,..-,.yr_... _,~,,_..---,..---..s.- , - +.,,
- t 6.
On November 30, 1981, Howard also received a report from Calkins describing the " breakdown of the quality assurance program", resulting in, inter alia, improper modifications to documents. Ici. 7. The report described in 6 concluded that the corrective action recommended was to " promise -.with a plan -- not to repeat the misconduct." No " offenders" were to be dismissed. (at7). 8. Bechtel communicated to Zack in a December 21,1982 [ sic], letter that the reported deficiencies (see 1, 5) were a " paperwork problem", and that it was their opinion that "It is highly probable that Zack ordered correct materials for the Midland project from their sub ' tier vendors and that the vendors' intent was to comply with Zack's purchase order requirements." (emphasis added). Howard disagreed strongly with Bechtel's attempt to minimize the seriousness of the QA document breakdown at Zack. (at9). 9. Howard states that the Zack " internal report / audit" of Bechtel's QA documentation (in
- 8) was seriously deficient in that it knowingly understated the number of purchase orders to be evaluated, and therefore that Zack's assurance to Bechtel that a " total document audit" was completed was " simply not true." (at 10).
- 10. Howard reports that "several times" he discussed with Zack manage-ment that " delivered materials did not confonn to site specifica-tions, and that many of Zack's vendors were unapproved as suppliers of material to nuclear sites." (at 11).
- 11. Howard's affidavit then states that a Mr. Perry contacted Common-wealth Edison QA manager about the deficiency in delivered materials, who then contacted Consumers Power at the Midland site.
Consuners apparently then contacted the president at Zack, who informed Howard that she "did not appreciate our calls outside the company." (at11,12).
- 12. On November 5,1980, the Bechtel Power Corporation sent a letter to the Zack Company. Howard reports that the letter "makes it clear that Bechtel Power Corporation had sufficient knowledge of material being shipped to the site in nonconforming condition." (at 14).
- 13. Howard states that a September 1981 letter to Zack Company from U.S.
Steel describes a " serious misunderstanding" regarding purchases of steel fof 26 purchase orders at all three sites (including Midland). I 1
~ 0 1- -3 Howard states that the letter points outi that the Zack " confirming orders" all read " Safety-Related". The U.S. Steel letter points out that first, the orders had not been purchased as " Safety-Related"; and second, that since the purchase orders were not called in as safety-related, they were not handled through the "V&T" (Verification and i Testing) program."- (at 16). Howard points out that the use'of the term " Safety-Related" implied that the items received the quality verification required by regula-I tion, which was inaccurate. M. i ' 14 Mr. Howard's affidavit states futher that Zack did not confine its ~ ~ [ purchases to those from " approved" vendors. "Another vendo'r, the Delta Screw Company, also failed a fall audit. A fall 1981 Zack letter from Mr. Calkins allegedly removed Delta Screw Co. from the approved vendors list for l-failure to comply with the requirements of a Quality Assur-ance program as required by the NRC. However, I knew that Zack Company did not follqw its own " approved vendors list". A list of the P.O.s from December 21, 1981 to February 1982 i; reveals that, in fact, Delta Screw received approximately 38 purchase orders from the Zack Company before being back 'on the approved vendors list in February 1982." (put at 18). s
- 15. Howard also describes that Zack personnel were not adequately trained to perfonn their duties. This lack of training included the president of Zack, who " assured the utility management that all problems relating to the Zack QA/QC breakdown were under control and her personal super-l' vision". (at18,19).
1 Howard's affidavit describes the notes of a meeting on November 3,1981, 16. at the Midland site, with all relevant QA personnel in attendance. The i i notes show that the principal purpose of the meeting was to decide "thether or not to report the QA breakdown under 10 CFR 50.55(e) to the i NRC". (at 19). The notes further state that Zack was to "try to get 4 j material certified to federal specifications", and to " revise or clarify I existing requirements so that the purchases would be acceptable." g. ) j
- 17. Howard describes a steadily increasing level of " intimidation and verbal abuse" from management, apparently designed to induce Howard's resigna-l ti on. (at 22).
i f i f. 4[ I ll
O ~
- 18. Howard then states that he confided in Mr. Leonard of MPQAD (at Midland) of the " awkward difSculties" with QA at Zack. (at 22).
He advised Howard that he recognized Zack's "large number of pro-blems over the years," and that he should report any specific allegations under a confider.tiality agreement. Jb{. I
- 19. On April 13, 1982, Howard called Leonard-and report QA problems at Zack. Howard reported these allegations officially through the MPQAD allegation system on April 15. (at 23).
- 20. Despite Leonard's promise of confidentiality, Howard reports that "on April 16, 1982, Mr. Calkins [his supervisor at Zack] called me into his office and told me I had betrayed him and that he was not going to speak to me anymore".
Id. 21. Soon after his visit with Calkins, Howard received a copy of a memo-randum fran the president of Zack to all employees. "Without mentioning me by name, this memo referred to and then denied the allegations I had made to Mr. Leonard. It also denied us access to the files without upper management permission". Jgi.
- 22. After a short review of the Zac'k files, Mr. Leonard informed Howard that he failed to find anything wrong "of substance" with the Zack QA documents. Mr. Leonard stated to Howard that "I was fired once, too, you know."
(at 24).
- 23. On April 30, 1982, Howard was fired by the president of Zack for "incompentence".
Nevertheless, she acknowledged that Zack's QA perfonnance was " appalling". (at 24, 25).
- 24. On May 3,1982, Howard reported the QA deficiencies at Zack to NRC investigators. (at 25). While he left with them documents relating " alterations", "possible forgeries", and admissions by Zack that it's failure to qualify vendors was a " serious program deficiency", the NRC has not contacted Howard further until July 21,1982 (the date of the affidavit). Although he called and visited the office several times, no interest was shown by the NRC in his revelations.
(at 26). f A t'
Stamiris Contention 1 (1980) Consumers Power Company statement and responses to NRC regarding soil settlement issues reflect a less than complete and candid dedication to providing information relevant to health and safety standards with respect to resolving the soil settlement problems, as seen in:
- (a) the material false stat > ment in the FSAR (Order of Modification, Appendix B);
- (b) the failure to provide information resolving geologic classifica-tion of the site which is pertinent to the seismic design input on soil settlement issues (Responses to FFAR Questions 361.4, 361.5, 361.7 and 362.9);
(d) the failure to provide adequate acceptance criteria for' remedial actions in response to 10 CFR 50.54(f) requests (as set forth in Part II of the Order of Modification); and this managerial attitude necessitates stricter than usual regulatory supervision ( ALAB-106) to assure appropriate implementation of the renedial steps required by the Order Modifying Construction Permits, dated December 6,1979.
- April 20, 1981, Supplement to Contention 1 Examples of CPCo. reluctance to provide requested information:
1. 3/31/80 NRC meeting notation of Applicant's reluctance to provide NRC consultants with requested information. 2. Vol. III, Tab 65 50-54f, 8/6/79 meeting, attitude that " needlessly conservative decisions may be formulated on the 'what it' type questions" by the NRC on dewatering. 3. The 11/24/80 S.A.L.P. assessnent on CPCo. - NRR inferface as pre-sented by D. Hood in the following statements regarding soil settle-ment issues: A big contributor to the inability to make meaningful pro-gress in this matter is the quality of responses gotten. We have set some kind of record on the number of questions re-asked, which speaks poorly for CPCo.-NRR interface. ...The bottomline is there seems to be a lack of apprecia-tion or support of Staff review necessities and a tendency to push ahead despite the lack of proper assurances." 4. The perfunctory manner in which CPCo. deponents answered questions. (I will tabulate examples from the depositions I attended.)
- These items have previously been litigated.
i 1 s
2-Examples of information withheld or incorrectly given: 5. The failure of CPCo. to discuss the Administrat~ ion Building settlement problem with the NRC, as they did with their consultants, in the early meetings on the DGB settlement. 6. The false FSAR statements beyond the one cited as a " material false state-ment" in the December'6 Order, as discussed in the 4/3/79 Keppler - Thornburg memo, and the 6/13/79 Thornburg - Thompson memo. k 4 l l t
j p
- Stamicis Contention 2 (1980)-
Consmers Power Company's financial and time ~ schedule pressures have directly 'and adversely affected resolution of soil settlement issues, which constitutes a compromise of applicable health and safety regulations as demonstrated by: i a) the admission (in response to 50.54(f) question #1 requestin'g identification of deficiencies which contributed to soil settlement 5 problems) that the FSAR was submitted early due to forecasted OL intervention, before some of the material required to' be included was available: b) the choice-of remedial actions being based in.part on expediency, as noted in Consmers Power Company consultant R. B. Peck's state-ment of 8-10-79; c) the practice of substituting materials for those originally speci-fied for " commercial reasons" (NCR QF203) or expediency, as in the use of concrete' in electrical duct banks (p. 23 Keppler Report) **; d) continued work on the diesel generator building while unresolved safety issues existed, which precluded thorough consideration of Option 2 - Removal and Replacement P1an.
- April 20,1981, Supplement to Contention 2 Further examples of the effect of financial and time pressures on soil settle-ment issues:
p Exampl es Effect on soil settlement issues 1. 11/7/78 Bechtel action item: 1. Root causes not adeq. investi- " proceed with preparations for gated. Organizational defi-preload as rapidly as possible" ciencies not eliminated prior to proceeding with remediation 2. 11/7/78 decision to fill pond 2. Affected piezometric measure- "immediately, because the ments during preload amount of river water avail-able for filling is restricted" 3. 11/7/78 "5-month period is 3. The surcharge was removed at the available in the schedule ~ for end of this 5 months despite prel oading" lack of NRC satisfaction that secondary consolidation was, assured
- These items have previously been litigated
- March 22,1979, Keppler Investigation Report conducted by Region III, Dec. 78-Jan. 79.
l t .,..[.
2-4. Failure to grout gaps prior to 4. Resulted in additional stresses cutting of duct banks, failure to DGE which could have been s to cut condensate lines when~ avoided first suggested, failure to break up mudmat at DGB 5. Choice to continue construction 5. Eliminated practical considera-of DGB tion of Removal & Replacement Option 6. Early FSAR submittal and inade-6. ' Precluded early detection of quate review of FSAR inconsistencies which could have prevented some of the s.s. pro-bl ems 7. Failure to reconstruct. geometry 7. Varying degrees of caution and of area prior to. fill placement, conservatism were foregone in failure to await NRC approval in favor of cost and schedule before proceeding with Preload, advantages ~ selection of "least costly feasible alternative" for DGB 8. Failure to excavate loose sands 8. Contributed to inadequacy of as committed to in PSAR subsoils 9. Installation of ; aload instru-9. Expenditures for preload inster. mentation was subject to time mentation (CJD 11/1/78 memo) pressure assoc. with frost pro-prior to formal adoption of pre-tection consi'derations load = prematrue canmitment
- 10. Appeals to NRC to consider 10.
If granted, would af fect seismic-- financial plight and schedule soil settlement standards deadlines as in Seismic Defer-ral Motion
- 11. Depth and breadth of surcharge
- 11. Afforded less than optimum con -
limited by practical considera-ditions for surcharge tion of DGB, Turbine B. struc-tures
- 12. Changes to design (DGB founda-
- 12. Contributed to settlement or tion), material, or proceedural stress problems and allowed con-
[ sic] specifications without flicts to go unnoticed as pre-proper approval ventative indicators b f 1 e i - -, ~ - -,-a + m e .e w r-
f.Itbl ubut t 4 l
- Stamiris Contention 3 (1980)
Consumers Power' Company has not implemented its Quality Assura~nce Program regarding soil settlement issues according to 10 CFR Part 50, Appendix B regula-tions, and this represents a repeated pattern of quality assurance deficiency reflecting a managerial attitude inconsistent with implementation of Quality Assurance Regulations with respect to soil settlement problems, since reason-able assurance was given in past cases ( ALAB-100, ALAB-106 and LBP-74-71) that proper quality assurance would ensure and it has not. The Quality Assurance deficiencies regarding soil settlement include: a) 10 CFR Part 50, Appendix B, Criteria III, V, X and XVI as set forth in the Order of Modification; b) 10 CFR Part 50, Appendix B, additional criteria denoted by roman numerals below; I. The Applicant has failed to assume responsibility for ~ execution of the QA program through its failure to verify and review FSAR statements (pp. 6-8 and p. 21, Keppler Report) and through its reliance on final test results not in accordance with specified requirements (p.16, Keppler Report); II. The QA program was not carried out according to written policies, procedures and instruction, in that oral directions were relied upon and repeated deviations from policies occurred regarding compaction procedures (p. 9-14, Keppler Report); VII. Control of purchased material has not been maintained, in that examination and testing of. backfill materials did not occur in accordance with regulations (NRC QF29, NRC QF147); IX. Control of non-destructive testing was not accomplished by qualified personnel using qualified procedures regarding a) moisture control (Keppler Report p.14-16; QA Request 5040, NRC QFS52, 172, 174 and 199); b) compaction procedures (Keppler Report, p. 9; NRC QFS 68, 120 and 130); and c) plant fill work (pp 24 and 25, Keppler Report);
- These items have previously been litigated, i
a .e. o y -,,,.,,,. e, g n,. .w2
i 2-4 XI. Test programs did not incorporate requirements and accep-tance limits adequately in the areas referenced in a, b and c above, and do not meet these requirements regarding soil settlement remedial actions; XIII. Measures were not adequately established to prevent damage or deterioration of material regarding frost effects on compacted fill (pp.16 and 17, Keppler Report); XV. Measures were not taken to control non-conforming material in order to prevent the inadvertent use (NRC QF29 and i QF127); c) the settlement of the Administration Building in 1977 should have-served as a quality indicator, preventing the same inadequate proce-dures from occurring in the 1978 construction of the diesel generator building causing its eventual settlement. s v 8 f e l
~ ~ 4: Stamiris Contention 4 (1980) J Consumers Power Company perfonned and proposed remedial actions regarding soils settlement that are inadequate as presented because: A. Prel.oading of the diesel generator building
- 1) does not change the composition of the improper soi.s tc meet the original PSAR specifications;.
- 2) does not preclude an unacceptable degree of further differential settlement of ' diesel generator building;
- 3) does not allow proper evaluation of compaction procedures because of unknown locations of cohesionless soil pockets;
- 4) may adversely affect underlying piping, conduits or nearby struc--
tures; and i.
- 5) yields effects not scientifically isolated from the effects of a rise in cooling water and therefore not measured properly;-
- B.
Slope stability of cooling pond dikes is not; assured because they were built with the same improper soils and procedures (NRC QF172); j~ C. Remedial soil settlement actions are based on untested assumptions and inadequate evaluation of dynamic responses of those structures to such things as dewatering, differential soil settlement, and seismic charac-I teristics: a. Auxiliary Building Electrical Penetration Areas and Feedwater Isolation Valve Pits b. Service Water Intake Building and its Retaining Walls a f c. Borated Water Storage Tanks [ d. Diesel Fuel Oil Storage Tanks; I D. Pennanent dewatering
- 1) would change the water table, soil and seismic characteristics 4i-of the dewatered site from their originally approved PSAR charac-teristics - characteristics on which the safety and integrity of the plant were based, thereby necessitating a reevaluation of these characteristics for affected Category I structures; 4
j'
- These items have previously been litigated.
e i. r 4 ( .__..._..gm ..-,,,.n_,,~_.a~-....___,,..._.4_.._--,_,_.,..,,_
i 1 i 2-L
- 2) may cause an unacceptable degree of further settlement in safety related structures due to the anticipated drawdown effect;
- 3) to the extent subject to failure or degradation, would allow inadequate time in which to initiate shutdown, thereby neces-sitating reassessment of tnese times.
Therefore, unless all the issues set forth in this contention are adequately resolved, the licensee actions in question should not be considered an acceptable remediation of soil settlement problems. B E 9 e W k o l l 4 e _..._,....---.--y-.y v.,.- 4 c E .I s Sumnary of Contentions to be Litigated j -j 1 Contention Key Phrase Reviewer (s) Sinclair 3 severe accidents Frank Rowsome Sinclair 5 cooling pond Jim Carson and Steve Tsai, ANL Sinclair 7 synergism Hal Walker Sinclair 6 QA - Howard Wayne Shafer, RIII Sinclair 8 QA - recortis Wayne Shafer, RIII Sinclair 16 QA - widers Wayne Shafer, RIII Sinclair 24 ground stability Joe Kane, J. P. Knight Sinclair 27 evacuation Dave Rohnr Sinclair 28 water hanner Bill LaFave, t.1 Serkiz Sinclair 30 tube integrity Cy Cheng, Ray Gonzales Stamiris Ib, Ic cost benefit Barry Elliot, Maurice Messier, a (1982) Nick Fields, Frank Cardile Stamiris 6 groundwater Joe Kane, Ray Gonzales Stamiris 8 audit Darl Hood 5 Stamiris Id managerial attitude Joe Kane (1980) Stamiris 4 inadequate remediation Joe Kane, Ray Gonzales. (1980) Frank Rinaldi Marshall 2 settling Joe Kane,.1. P. Knight Warren 1 fill soil Joe Kane Warren 2 seepage Joe Kane, Ray Gonzales, Frank Rinaldi Warren 3 DGB stress Joe Kane, J. P. Knight, Frank Rinaldi, Paul Chen l I i l l CmCE) su m me) emy , pe rom ais oow mcu oua OFFICIAL RECORD COPY u om mi-=
unans o, UNITED STATES E-NUCLEAR REGULATORY COMMISSION g E WASHINGTON, D. C. 20556 %.... / C^T ? !??2 Docket Nos: 50-329 OM, OL and 50-330 OM, OL MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing Division of Licensing' Elinor G. Adensam, Chie N j THRU: Licensing Branch No. 4 h Division of Licensing FROM: Mclanie A. Miller, Project Manager Licensing Branch No. 4 Division of, Licensing
SUBJECT:
ADMITTED MIDLAND CONTENTIONS Enclosed is a tabular listing of all contentions accepted by the board for litigation (Attachment 1). The table is provided for informational purposes and will be continuously updated as changes in contention status occur. The intervenor's name and contention number are listed with a corresponding key phrase provided for each contention for easy reference. Additionally, the date under the contention number refers to the year it was accepted by the board and is listed to avoid confusion in redundant contention numbers. sumarizes the contentions and the reviewers responsible for testimony. This attachment is also subject to change. We are sending this table to responsible reviewers by copy of this memorandum. If there are questions, I can be reached at X24259. 0a.r v Melanie A. Miller, Project Manager Licensing Branch No. 4 Division of Licensing
Enclosures:
As stated cc: See next page t Q i.,, ( { 9 7 5 P D M ? 5: ?=' 1
OCT 2 'T 1982 2-2 cc w/ encl: W. Paton. M..Wilcove N. Wright-D. Hood R. Hernan F. Rowsome J. Carson, ANL H. Walker W. Shafer, RIII J. Kane J. P. Knight D'. Rohrer W. Lefave C. Anderson C.,Cheng R. Gonzales B. Elliot M. Messier N. Fields F. Cardile s F. Rinaldi P. Chen, ETEC S. Tsai, ANL J m, M' j s. I r i S- ,,-.-,,.,e,
r' e 9 O 8 e l 5 ATTACHMENT 1 ADMITTED MIDLAND CONTENTIONS v l i ^ '- -
4 Admitted Midland Contentions Contention # Key Phrase Contention 3 Sinclair 3 severe accidents The assessment of the likelihood and (1982). severity of " severe accidents" (or class 9 accidents) in the DES is inadequate in that it relies for methodology and prob-ability of occurrence of severe accidents on the Rasmussen Report (WASH-1400) DES 5-45-66. However, a new NRC report reveals that the Rasmussen methodology, at least as it pertains to more severe accidents (total meltdown), significantly understates the risk of such accidents by a factor of 20. 2 Precursors to Potential Severe Core Damage Accidents: 1969-1979, a Status Report, NUREG/CR/2497-(June 1982). This report shows that probabilities of severe accidents should be derived on the basis of actual accident sequences and significant events, rather than the Rasmussen methodology. The F failure of the DES to incorporate this analysis cripples the entire Class 9 i analysis of the DES. s .Sinclair 5 cooling pond The staff DEIS is deficient in that it (1982) continues to base its analysis of the cooling pond's effectiveness in controlling thermal discharges (DEIS at 4-6) and ice l and fog generation (DEIS at 5-9) on a study based on cooling pond perfonnance in.a sub-3 stantially different climatic region. Instead, the DEIS should analyze infonnation from the Dresden, Illinois nuclear facility (or other data from a comparabley sized and situated facility) for both purposes, and present the baseline data from that facility 4 to allow the agency and the public to reach an infonned decision on the adverse affects of the cooling pond. ~ Sinclair 7 synergi sm The issue of synergism between chemicals and i (1982) radiation (Contention 61, (old 55) Contentions of Mary Sinclair,1978) must be re-opened i based on a new study. Scientists at Sandia l-National Laboratory, Albuquerque, New Mexico, l have conducted tests sponsored by the NRC on polyner cable insulation and jacketing used in nuclear power containment buildings. (Indus-trial Research and Development, June,1982) f i E g-e ---~~,,n,n-na. ,.-e-,-<w n,~,-+..- em <r-sA ve,--v,-wn--
,,e - F -2 ~ Contention # Key Phrase-Contention They have found that long-term low doses of gamma radiation degrades many polymers more than do. equal doses administered at higher rates in shorter testing times.. Besides the dose rate effect, the researchers have also found that synergistic effects can occur when polymers are exposed to radiation and mildly elevated temperatures. Dr. Roger Clough, of Sandia National Laboratory, has stated that the present testing method underestimates the 'long-term effects and synergisms that display themselves only in longer tests. This study indicates that the useful life.of the plant will be shortened considerably because of this problem., Sinciair 6 QA-Howard See Enclosure 1 (1982) Sinclair 8 QA-records , The Zack Company of Chicago which has'been the (1982) contractor responsible for the heating, cooling and ventilating system of the Midland nuclear plant has filed a non-compliance report with ~ the NRC on or abour August 4,1982, indicating that two sets of records -- a shop record and a QA record -- which are required to be kept to guarantee the integrity of the welds and therefore, must be signed by the same welder, were, in fact, signed by two different persons. This violates the federal standards for docu-mentation for safety-related systems in a nuclear power plant. This breakdown in quality control means the principal method that the NRC has for guaranteeing the integrity of the welds in the HVAC system (which is already built into a large part of the plant) has failed and that therefore the protection of the public health and safety cannot be guaranteed as required by 10 CFR 550.57(1),50.57(2),and50.57(3)and Part 50, Appendix B. Sinclair 16 QA-welders In the part 21 report that Zack Co. filed which (1982) was signed by Dave Calkins of Zack and prepared by Howard McGrance of Constners Power Co., it was disclosed that 140 Travelers showed unver-ified welder qualifications for fabrication welds. Without qualified welders for this large f ,-,,-s .. w, y
4 Contention # Key Phrase Contention nunber of welds, the necessary guarantee for the protection of the public health and safety cannot be met as required by 10 CFR 50.57(1), 50.57(2) and 50.57(3). 'In addition, this report indicates that the quality assurance in construction of these plants has not been met as required by Part 50, Appendix B. 31nclair 24 ground stability The present site for the Midland facility is (1979) not only inappropriate for the reasons set ' orth in Contention 9, but also affirmatively unsafe. Serious questions have been raised concerning the ground stability of portions of the site. At least one of the essential buildings of the reactor complex is reported sinking, and con-struction has been halted on that building. As a result of the serious and unresolved questions concerning ground stability, the findings required by 10 CFR 50.57(a)(3)and50.57(a)(6) ,cannot be made. Sinclair 27 evacuation Recently discovered information indicates that (1979) the Advisory Committee on Reactor Safeguards conditioned the acceptability.of the present Midland site for the project on the existence of a highly effective evacuation system. However, no adequate evacuation plans exist. Aerial surveys of traffic conducted during the con. struction pennit stage of these proceedings, and taken during shift changes, indicated tnat evacuation in an acceptable time cannot be accompli shed. Further, relying on the evacu-ation plans of Dow Chemical Company is inade-quate. During the evacuation followirg the recent chlorine leak, evacuation procedures were chaotic and all conmunications were either jammed or ineffectual. In fact at an NRC conference held in Midland, Michigan on September 8,1978, both the County Road Com-mission and the Midland Planning Commission admitted that they have not considered evacu-ation routes. As a result, the findings requiredby)10CFRQ50.57(a)(3)(1)and 50.57(a)(6 cannot be made. I i e ,o n n
4-Contention # Key phrase Contention Sinclair 28 water hammer Contention 28 deals with the water hammer problem of pressurized water reactors of the (1982) Midland type. This problem is identified as one of the unresolved safety issues applicable to Midland 1 & 2 in the SER, C-4. Babcock and Wilcox (B&W) plants with an internal auxiliary feedwater ( AFW) feed ring of the same design as Midland in recent events, have shown a marked susceptibility to internal damage of the feed ring as a result of water hammer. From this, reduced cooling in the steam gen-erators.could occur as a result of ' inadequate AFW flow following loss of normal feedwater fl ow. (NRC Response to Interrogatory 7) Since this effect involves critical safety systems, the Task A-1 report (Jan.,1980) states that systenatic review procedures in the OL review process will require the Appli-cant to: 1) address potential water hammer problems in various systems; 2) denonstrate s that there are adequate design features and
- 3) expand the preoperational testing program to insure that these design features and operating procedures do prevent damaging water hammer events.
However, the SER does not indicate that these criteria have been met by the Applicant. As a result of this omission, the findings required by 10 CFR 5 50.57(a)(3)(1) and 50.57(a)(6) can-not be made. Sinclair 30 tube integrity The degradation of steam tube integrity due to (1982) corrosion induced wastage, cracking reduction in tube diameter, and vibration induced cracks is a serious unresolved safety problem at the Midland nuclear plant. It is admitted that the chemistry of the cooling water is critical to prevention of steam tube failure, (NUREG-0886). However, the fact that these plants depend on cooling water from the cooling pond increases the likelihood of corrosion and poor water chenistry because the DE!S states that the plant dewatering system will first be discharged to the cooling pond. (DEISat5-2). That means that many wastes, including radioactive l 4
Contention # Key Phrase Contention. materials from leaks and spills on the reactor site, can enter the cooling pond and disrupt the chemistry of the pond. ' The refore,. due to this contribution of an undetermined amount and quality of ground dewatering inflows to the cooling pond, the NRC's bland assurance that corrosion is unlikely due to the lack of sodium thiosulfate, is unsatisfactory. (NRC Response to Interrogatroy 9.j.) In fact, due to the contribution of groundwater, the NRC is not fully aware of the likely constituents of the cooling pond, and the findings required by 10 CFR Q 50.57(a)(3)(1) and 50.57(a)(6) cannot be made. Stamiris Ib, c cost benefit NRC's economic cost benefit analysis of the DES (1982) is faulty and misleading because it:
- b. underestimates decommissioning costs
- c. overestimates lifespan of Unit 1 Staniris 2 internal reporting CPC/NRC internal reporting systems intended to (1982) allow plant workers to raise concerns or criti-(consolidatedwith cisms about inadequate workmanship or practices Sinclair 6) are ineffective because they have resulted in job losses due to QA/QC reporting. (Midland Daily News articles dated 7/20/82,6/28/82, and Howard af fidavit, 7/30/82)
Stamiris 6 groundwater The NRC risk assessment in the DES does not con-(1982) sider potential effects of permanent dewatering on groundwater relationships. Stamiris 8 audit The ACRS has recommended an assessment of (1982) Midland's design adequacy and construction quality in their 6/18/82 report (SER Supplement 1 Appendix G). In order to assure that this audit be thorough and objective, it must be perfonned by an independent third party of a competing contracting firm. Such a requirement was imposed by the ASLB in the Houston Power l and Light, 50-498 and 50-499 OL proceeding, 4/30/82. And, due to the pattern of design I deficiencies (4/20/82 SALP, p.16) such an independent audit is necessary to assure the design integrity of this plant. However, the t A e
4 = I Contention # Key phrase Contention NRC has not required (SER Supplement 1, p. a 19-2(1)), and CPC has not emnmitted (7/9/82 Tedesco to Cook letter) to such an independent audit. Stamiris la, b, d - managerial attitude See Enclosure 2 (1980) Stamiris 2a-d schedule pressures See Enclosure 3 (1980) r Stamiris 3 QA-soils See Enclosure 4 j (1980) inadequate remediation See Enclosure 5 Stamiris 4 (1980) Present geol' gical conditions, according to . Marshall 2 settling o (1979) newspaper accounts, is causing the settling of the generator building at the Nuclear , Power Plant site. Warren 1 fill soil The composition of the fill soil used to pre. (1980) pare the site of the Midland Plant - Units 1 and 2 is not of sufficient quality to assure that pre-loading techniques have permanently corrected soil settlement problems. The NRC J has indicated the random fill dirt was used for backfill. The canponents of random fill can include loose rock, broken concrete, sand, silt, ashes, etc. all of which cannot be com-pacted through pre-loading procedures. Warren 2 seepage A. 8ecause of the known seepage of water from the cooling pond into the fill soils in the power block area, permanent dewatering pro-cedures being proposed by Consumers Power Company are inadequate, particularly in the event of increased water seepage, flooding, t failure of pumping systems and power outages. Under these conditions, Consuners cannot pro-vide reasonable assurance that stated maximum levels can be maintained. t t 4l e l
l 7-t B. Given the facts alleged in Contention 2.A. l1 and considering also that the Saginaw Valley is built upon centuries of silt deposits, L these highly permeable soils which underlie, in part, the diesel generator building and othar class I structures may be adversely affected by increased water levels producing liquefaction of these soils. The following will also be affected: 1 borated water tank's 2 diesel fuel oil tanks. Warren 3 DGB stress Pre-loading procedures undertaken by Consumers (1980) Power have induced stresses on the deisel generating building structure and have reduced the ability of this structure to perform its essential functions under that stress. Those remedial actions that have been taken have pro-duced uneven settlenent and cause'd inordinate stress on the structure and circulating water lines, fuel oil lines, and electrical conduit. s i 8 f 4 0 e
r Sinclair Contention #6 NRC regulations at 10 CFR Part 50, Appendix B require that applicants for oper-ating licenses develop and implenent a quality assurance program for the protection of the public from improper materials or unworkmanlike practices. This QA program includes such elements as procurement document control, control of purchased material, equipnent, and services, proper inspections and handling of nonconfoming materials, corrective actions, and audits by trained personnel. However, the affidavit attached to this contention and summarized below shows clearly that the QA program for'the Midland plant was not in compliance with these requirements, and that therefore, quality assurance and control cannot be established at the Midland nuclear plant. As basis for this contention, intervenor Mary Sinclair references the affidavit of Mr. Albert T. Howard, a fomer Quality Assurance Doceentation Supervisor for Zack Company, (from October 19, 1991 through April 30,1982) which was under contract to supply equipment for the heating, ventilating and air conditioning (HVAC) system of the Midland plant. His affidavit documents the complete breakdown of the QA program for the Midland plant, leading to his dismissal for refusing to confrom to Zack's improper QA prac-tices. Those improper practices, with regard to the Midland plant specifically, or all of Zack's nuclear clients generally, are detailed as follows: 1. Howard states that his supervisor, Mr. Calkins, had investigated and reported the QA problems Zack was having with the Midland plant to the Midland plant to the Midland Site Manager as early as August 28, 1981. (at4) l l 2. As a result of this report, " major QA reorganizations" were undertaken ( at Midland, to correct improper QA docmentation. M. 3. Soon after Howard's promotion to Supervisor of the Documents Assurance Department, Howard became aware of " serious deficiencies" in QA docu-I mentation. (at5). 4. On November 18, 1981, a Midland QQ contract employee directed Howard i to sign a fom attesting to having completed the requisite training l for his position, in spite of the fact that Howard did not receive such training. M. 5. On November 30, 1981, Howard reviewed reports which summarized various QA deficiencies at Midland, including such tems as: l "certs altered"; " white out used and retyped"; and " heat number altered to agree with certification"; missing signa-tures; certifications missing; lack of test data for pur-chases; correspondence that steel had been purchased without verification and traceability; and stickers indicating com-pliance with professional standards. As the summary noted on the latter item, " Authenticity of the signatures is questionable." (at6), i s e e
q l kl
- 6.
On November 30, 1981 Howard also received a report from Calkins describing the " breakdown of the quality assurance program", resulting in, inter alia, improper modifications to documents. ld.. d 7. The report described in 6 concluded that the corrective action recommended was to " promise -- with a plan -- not to repeat the misconduct." No " offenders" were to be dismissed. (at 7). 8. Bechtel communicated to Zack in a December 21,1982 [ sic], letter that the reported deficiencies (see 1, 5) were a " paperwork problem", and that it was their opinion that "It is highly probable that Zack ordered correct materials for the Midland project from their sub. tier vendors and that the vendors' intent was to comply with Zack's purchase order requirements." (emphasisadded). Howard disagreed strongly with Bechtel's attempt to minimize the seriousness of the QA document breakdown at Zack. (at9). 9. Howard states that the Zack " internal report / audit" of Bechtel's QA documentation (in
- 8) was seriously deficient in that it knowingly understated the number of purchase orders to be evaluated, and i-therefore that Zack's assurance to Bechtel that a " total docunent audit" was completed was " simply not true." (at 10).
- 10. Howard reports that "several times" he discussed with Zack manage-ment that " delivered materials did not confonn to site specifica-tions, and that many of Zack's vendors were unapproved as suppliers of material to nuclear sites." (at 11).
- 11. Howard's affidavit then states that a Mr. Perry contacted Common-wealth Edison QA manager about the deficiency in delivered materials, who then contacted Consumers Power at the Midland site.
Consumers apparently then contacted the president at Zack, who infonned Howard that she "did not appreciate our calls outside the company." (at11,12).
- 12. On November 5,1980, the Bechtel Power Corporation sent a letter to the Zack Company. Howard reports that the letter "makes it clear that Bechtel Power Corporation had sufficient knowledge of material being shipped to the site in nonconfonning condition." (at 14).
- 13. Howard states that a September 1981 letter to Zack Company from U.S.
Steel describes a " serious misunderstanding" regarding purchases of steel for 26 purchase orders at all three sites (including Midland). l a
, Howard states that the letter points out that the Zack "confinning orders" all read " Safety-Related". The U.S. Steel letter points out that first, the orders had not been purchased as " Safety-Related"; and second, that since the purchase orders were not called in as safety-related, they were not handled through the "V&T" (Verification and Testing) program." (at16). Howard points out that the use of the term " Safety-Related" implied that the items received the quality verification required by regula-tion, which was inaccurate. ,I_d,. d 14 Mr. Howard's affidavit states futher that Zack did not confine its purchases to those from " approved" vendors. "Another vendor, the Delta Screw Company, also failed a fall audit. A fall 1981 Zack letter from Mr. Calkins allegedly removed Delta Screw Co. from the approved vendors list for failure to comply with the requirements of a Quality Assur-ance program as required by the NRC. However, I knew that Zack Company did not follow its own " approved vendors list". A list of the P.O.s from December 21, 1981 to February 1982 reveals that, in fact, Delta Screw received approximately 38 purchase orders from the Zack Company before being put back on the approved vendors list in February 1982." (at 18).
- 15. Howard also describes that Zack personnel were not adequately trained to perfonn their duties. This lack of training included the president of Zack, who " assured the utility management that all problens relating to the Zack QA/QC breakdown were under control and her personal super-vision". (at18,19).
16. Howard's af fidavit describes the notes of a meeting on November 3,1981, at the Midland site, with all relevant QA personnel in attendance. The notes show that the principal purpose of the meeting was to decide "whether or not to report the QA breakdown under 10 CFR 50.55(e) to the NRC". (at19). The notes further state that Zack was to "try to get material certified to federal specifications", and to " revise or clarify existing requirements so that the purchases would be acceptable." I d,.
- 17. Howard describes a steadily increasing level of " intimidation and verbal abuse" from management, apparently designed to induce Howard's resigna-tion.
(at22). I e e: u
i
- 18. Howard then states that he confided in Mr. Leonard of MPQAD (at 1
Midland) of the " awkward difficulties" with QA at Zack. (at22). He advised Howard that he recognized Zack's "large number of pro-blems over the years," and that he should report any specific allegations under a confidentiality agreement. M.
- 19. On April 13, 1982, Howard called Leonard and report QA problems at J
Zack. Howard reported these allegations officially through the MPQAD allegation system on April 15. (at23). 4
- 20. Despite Leonard's promise of confidentiality Howard reports that "on April 16, 1982, Mr. Calkins [his supervisor at Zack] called me into his office and told me I had betrayed him and that he was not going to speak to me anymore". M.
21. Soon after his visit with Calkins, Howard received a copy of a memo-randum from the president of Zack to all employees. "Without mentioning me by name, this memo referred to and then denied the allegations I had made to Mr. Leonard, it also denied us access to the files without upper management pemission". 3
- 22. After a short review of the Zack files Mr. Leonard infonned Howard that he failed to find anything wrong "of substance" with the Zack L
QA documents. Mr. Leonard stated to Howard that "I was fired once, too, you know." (at24).
- 23. On April 30, 1982, Howard was fired by the president of Zack for "incompentence". Nevertheless, she acknowledged that Zack's QA perfonnance was " appalling". (at24,25).
- 24. On May 3,1982, Howard reported the QA deficiencies at Zack to NRC investigators. (at25). While he left with them documents relating " alterations", "possible forgeries", and admissions by Zack that it's failure to qualify vendors was a " serious program deficiency", the NRC has not contacted Howard further until July 21,1982 (the date of the affidavit). Although he called and visited the office several times, no interest was shown by the NRC in his revelations. (at26).
l 8 ( 4'
Stamiris Contention 1 (1980) Consumers. Power Company statement and responses to NRC regarding soil settlement issues reflect a less than complete and candid dedication to providing information relevant to health and safety standards with respect to resolving the soil settlement problems, as seen in:
- (a) the material false statement in the FSAR (Order of Modification, Appendix B);
- (b) the failure to provide infomation resolving geologic classifica-tion of the site which is pertinent to the seismic design input on soil settlement issues (Responses to FSAR Questions 361.4, 361.5, 361.7 and 362.9);
(d) the failure to provide adequate acceptance criteria for remedial actions in response to 10 CFR Q50.54(f) requests (as set forth in Part II of the Order of Modification); and this managerial attitude necessitates stricter than usual regulatory supervision ( AI.AB-106) to assure appropriate implementation of the remedial steps required by the Order Modifying Construction Pemits, dated December 6,1979. , April 20, 1981, Supplement to Contention 1 Examples of CPCo. reluctance to provide requested infomation: 1. 3/31/80 NRC meeting notation of Applicant's reluctance to provide NRC consultants with requested information. 2. Vol. III, Tab 65 50-54f, 8/6/79 meeting, attitude that " needlessly conservative decisions may be fomulated on the 'what it' type questions" by the NRC on dewatering. 3. The 11/24/80 S. A.t..P. assessment on CPCo. - NRR inferface as pre. sented by D. Hood in the following statements regarding soil settle-ment issues: A big contributor to the inability to make meaningful pro-gress in this matter is the quality of responses gotten. We have set some kind of record on the number of questions re-asked, which speaks poorly for CPCo.-NRR interface. ...The bottomline is there seems to be a lack of apprecia-tion or support of Staff review necessities and a tendency to push ahead despite the lack of proper assurances." 4. The perfunctory manner in which CPCo. deponents answered questions. (I will tabulate examples from the depositions I attended.)
- These items have previously been litigated, f
4
\\ 2-Examples of infomation withheld or incorrectly given: 5. The failure of CPCo. to discuss the Administration Building sett1 ment proble with the NRC, as they did with their consultants, in the early meetings on the OGB settlement. 6. The false FSAR statements beyond the one cited as a " material false state-ment" in the December 6 Order, as discussed in the 4/3/79 Keppler - Thornburg memo, and the 6/13/79 Thornburg - Thompson memo. k f I 4, .l w { ^
- Stamiris Contention 2 (1980)
,Consmers Power Company's financial and time schedule pressures have directly and adversely affected resolution of soil settlement ~ issues, which constitutes a compromise of applicable health and safety regulations as deonstrated by: a) the admission (in response to $50.54(f) question #1 requesting identification of deficiencies which contributed to soil settlement problems) that the FSAR was submitted early due to forecasted OL intervention. before some of the material required to be included was available: b) the choice of remedial actions being based in part on expediency, as noted in Consumers Power Company consultant R. 8. Peck's state-ment of 8-10-79; c) the practice of substituting materials for those originally speci-fied for " commercial reasons" (NCR QF203) or. expediency, as in the use of concrete in electrical duct banks (p. 23 Keppler Report) **; d) continued work on the diesel generator building while unresolved safety issues existed, which precluded thorough consideration of Option 2 - Removal and Replacement Plan.
- April 20.1981 Supplement to Contention 2 Further examples of the effect of financial and time pressures on soil settle-ment issues:
Examples Effect on soil sett1 ment issues 1. 11/7/78. Bechtel action item: 1. Root causes not adeq. investi- " proceed with preparations for gated. Organizational deft-preload as rapidly as possible" ciencies not eliminated prior to proceeding with remediation 2. 11/7/78 decision to fill pond 2. Affected piezometric measure- "immediately, because the ments during preload amount of river water avail-able for filling is restricted" 3. 11/7/78 "5-month period is 3. The surcharge was removed at the available in the schedule' for end of this 5 months despite preloading" lack of NRC satisfaction that secondary consolidation was assured
- These items have previously been litigated
- March 22,1979 Keppler Investigation Report conducted by Region 111, Dec. 78-Jan. 79.
A e e
. 9 4. Failure to grout gaps prior to 4. Resulted in additional stresses cutting of duct banks, failure to DGB which could have been to cut condensate lines when avoided first. suggested, failure to break up mudmat at DGB 5. Choice to continue construction 5. Eliminated practical considera-of DG8 tion of Removal & Replacement Option 6. Early FSAR submittal and inade-6. Precluded early detection of quate review of FSAR inconsistencies which could have prevented some of the s.s. pro-blems ~ 7. Failure to reconstruct gesnetry 7. Varying degrees of caution and of area prior to fill placement, conservatism were foregone in failure to await NRC approval in favor of cost and schedule before proceeding with Preload, advantages selection of "least costly feasible alternative" for DGB s 8. Failure to excavate loose sands 8. Contributed to inadequacy of as committed to in PSAR subsoils 9. Installation of preload instru-9. Expenditures for preload instru-mentation was subject to time mentation (CJD 11/1/78 memo) pressure assoc. with frost pro-prior to formal adoption of pre-tection considerations load = prematrue conmitment
- 10. Appeals to NRC to consider 10.
If granted, would affect seisnic-- financial plight and schedule soil settlement standards deadlines as in Seismic Defer-ral Motion
- 11. Depth and breadth of surcharge 11.
Af forded less than optimum con-limited by practical considera-ditions for surcharge tion of DGB, Turbine B. struc-tures
- 12. Changes to design (DG8 founda-12.
Contributed to settlement or tion), material, or proceedural stress problems and allowed con- [ sic] specifications without flicts to 30 unnoticed as pre-proper approval ventative indicators I a, e
- Stamiris Contention 3 (1980)
Consumers Power Company has not implemented its Quality Assurance Program regarding soil settlement issues according to 10 CFR Part 50, Appendix B regula- ~ tions, and this represents a repeated pattern of quality assurance deficiency reflecting a managerial attitude inconsistent with implementation of Quality Assurance Regulations with respect to soil settlement problems, since reason-able assurance was given in past cases ~( ALAB-100 ALAB-106 and LBP-74-71) that proper quality assurance would ensure and it has not. The Quality Assurance deficiencies regarding soil settlement include: a) 10 CFR Part 50, Appendix B, Criteria III, V, X and XVI as set forth in the Order of Modification; b) 10 CFR Part 50, Appendix B, additional criteria denoted by roman numerals below; I. The Applicant has failed to assume responsibility for execution of the QA program through its failure to verify and review FSAR statements (pp. 6-8 and p. 21 Keppler Report) and through its reliance on final test results not in accordance with specified requirements (p.16 Keppler Report); II. The QA program was not carried out according to written policies, procedures and instruction, in that oral directions were relied upon and repeated deviations from policies occurred regarding compaction procedures (p. 9-14, Keppler Report); VII. Control of. purchased material has not been maintained, in that examination and testing of backfill materials did not occur in accordance with regulations (NRC QF29, NRCQF147); IX. Control of non-destructive testing was not accomplished by qualified personnel using qualified procedures regarding a) moisture control (Keppler Report p.14-16; QA Request 5040,NRCQFS52,172,174and199); ~ b) compaction procedures (Keppler Report, p. 9; NRCQFS68,120and130);and c) plant fill work (pp 24 and 25, Keppler Report);
- These items have previously been litigated.
t
2-XI. Test programs did not incorporate requirements and accep-tance limits adequately in the areas referenced in a, b and c above, and do not meet these requirements regarding soil settlement remedial actions; XIII. Measures were not adequately established to prevent damage or deterioration of material regarding frost effects on compacted fill (pp.16 and 17 Keppler Report); XV. Measures were not taken to control non-conforming material in order to prevent the inadvertent use (NRC QF29 and QF127); c) the settlement of the Administration Building in 1977 should have served as a quality indicator, preventing the same inadequate proce-dures from occurring in the 1979 construction of the diesel generator building causing its eventual settlement. 9 0 0 4
Encles:re 5 Stamiris Contention 4 (1980) Consmers Power Company perfonned and proposed remedial actions regarding soils settlement that are inadequate as presented because: A. Preloading of the diesel generator building
- 1) does not change the composition of the improper soils to meet the original PSAR specifications;
- 2) does not preclude an unacceptable degree of further differential settleent of diesel generator building;
- 3) does not allow proper evaluation of compaction procedures because of unknown locations of cohesionless soil pockets;
- 4) may adversely affect underlying piping, conduits or nearby struc-turet; and
- 5) yields effects not scientifically isolated,from the effects of a rise in cooling water and therefore not measured properly;
- B.
Slope stability of cooling pond dikes is not assured because they were built with the same improper so11s and procedures (NRC QF172); i 4 C. Remedial soil settlement actions' are based on untested assumptions and inadequate evaluation of dynamic responses of those structures to such things as dewatering, differential soil settlement, and seismic charac-teristics: a. Auxiliary Building Electrical Penetration Areas and Feedwater Isolation Valve Pits b. Service Water Intake Building and its Retaining Walls l c. Borated Water Storage Tanks d. Diesel Fuel Oil Storage Tanks; i D. Pennanent dewatering
- 1) would change the wat',er table, soll and seismic characteristics i
of the dewatered site from their originally approved PSAR charac-teristics - characteristics on which the safety and integrity of the plant were based, thereby necessitating a reevaluation of these characteristics for affected Category I structures; 'These items have previously been litigated. l t ei e
.s', 2-
- 2) may cause an unacceptable degree of further settlement in safety-related structures due to the anticipated drawdown effect;
- 3) to the extent subject to failure or degradation, would allow inadequate time in which to initiate shutdown, thereby neces-sitating reassessnent of these times. Therefore, unless all the is' sues set forth in this contention ar'e adequately resolved, the licensee actions in question should not be considered an acceptable remediation of soil settlement problems. e k ~ ~ e e ) 1 he ~ 1 i e \\ ~k ,.s +,, > - 9 e c - er, .l --
r-ATTACHMENT 2 .- e >. 7: ~ n Summary of Contentions to be Litigated Contention Key Phrase Reviewer (s) Sinclair 3 severe accidents Frank Rowsome Sinclair 5 cooling pond Jim Carson and Steve Tsai.ANL Sinclair 7 synergism Hal Walker Sinclair 6 QA - Howard ' Wayne Shafer, RIII Sinclair 8 QA.- records Wayne Shafer, RIII Sinclair 16 QA - welders Wayne Shafer, RIII Sinclair 24 ground stability Joe Kane, J. P. Knight Sinclair 27 evacuation Dave Rohrer Sinclair.28 water hanner Bill LeFave, Al Serkiz Sinclair 30 tube integrity Cy Cheng, Ray Gonzales Stamiris Ib, le cost benefit Barry Elliot, Maurice Messier, (1982) Nick Fields, Frank Cardile Stamiris 6 groundwater Joe Kane, Ray Gonzales Stamiris 8 audit Darl Hood Stamiris ld managerial attitude Joe Kane (1980) Stamiris 4 inadequate remediation Joe Kane, Ray Gonzales, (1980) Frank Rinaldi Marshall 2 settling Joe Kane, J. P. Knight Warren 1 fill soil Joe Kane Warren 2 seepage Joe Kane, Ray Gonzales, Frank Rinaldi Warren 3 OGB stress Joe Kane, J. P. Knight, Frank Rinaldi, Paul Chen t Al l
' /,1 c/? t W ] *; ' - ~ pi/ .-+ ~ . ' il Docket Mos: 50-329 Otl, OL and 50-330 OH, OL IE10RANDU:4 FOR: Thomas H. trovak', Assistant Director for Licensing ~ Division of Licensing THRU: Elinor G. Adensam, Chief f Licensing Branch 110. 4 Division of Licensing FR0tt:
- 4alanie A. fliller, Project Manager
'l Licensing Branch :10. 4 Division of Licensing
SUBJECT:
ADMITTED 14IDLAND CONTENTI0ns Enclosed is a tabular listing of all contentions accepted by the board of litigation (Attachnent 1). The talle is provided for informational purposes ~ and will be continosusly updated as changes in contention status occur. The intervenor's name and contention neber are listed with a corresponding key phrase provided for each contention for easy reference. Additionally, the date under the contention number refers to the year it was accepted by the board and is listed to avoid confusion in redundant contention numbers.
- swearizes the contentions and the revisaars responsible for testimony. This attachment is also subject to change.
We are sending this table to responsible reviewers by copy of this memorandum. If there are questions, I can be reached at X24259. 3, 1 g Helante A. fltller, Project Manager Licensing Branch 110. 4 Division of Licensing t
Enclosures:
7 As stated cc: See next page s e e
x; W =A 2- '~. _,.. cc w/ encl: W. Paton ~ it. Wilcove
- 11. Wright D. Hood Ro Hernan F. Rowsore J. Carson, Nil H. Walker U. Shafer, RIII J. Kane J. P.. Knight D. Rohrer e'
- 11. Lafave C. Anderson C. Cheny R. Gonzales
. 'l B. Elliot H. I*ssier ~ li. Fields c F. Cardile F. Rinaldi P. Chen, ETEC i .. l
- i
.] I l I 9 4 + v me---
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- n,,
yy
- 3;
~. - .N 3 ,,3 8 11 ??:: d -c i Suncary of Contentions to be Litigated [ .\\. f. Contention Key Phrase Reviewer (sl .f ~ Sinclair 3 severe accideni.s Frank Rowsome' Sinclair 5 cooling pond Jim C' ason and Steve Tsai, AHL - q i Sinclair 7 synergism Hal Walker Sinclair 6 QA - Howard Wayne Shafer, RIII j Sinclair 8 QA - records Wayne Shafer, RIII j Sinclair 16 QA - welders Wayne Shafer, RIII Sinclair 24 ground stability' Joe Kane, J. P. Knight ' Sinclair 27 evacuation Dave Roheer Sinclair 28 water hacuer Bill LcFave. Al Serkiz 4 '1 Sinclair 30 tube integrity C.y Cheng, Ray Gonzales . l Stamiris Ib, Ic cost benefit Barry Elliot, F.aurice t'essier. (1982 Nick Fields. Frank Cardile ~ l Stamiris 6 groundwater ~ Joe Kane, Ray Gonzales .j Stamiris 8 audit Dar Hood. Stamiris Id managerial attitude Joe Kane (19C0) Stamiris 4 inadequate remediation Joe Kane, Ray Go'nzales, i (1930) Frank Rinaldi ] Marshall 2 settling Joe Kane, H. P. Knight }l Warren 1 fill soil Joe Kane ] Uarren 2 seepage Joe Kane, Ray Gonzales, Frank Rinaldi i i Warren 3 DGB stress-Joe Kane, J. P. Knight, Frank Rinaldi, Paul Chen .' I l i 'I i. i l l ( 1 - -.-.}}