ML20093N078
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July 19.1982
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e y-f fi; MEMORANDUM FOR: Dr. David Okrent Chairman, ACRS Subcommittee on Midland Plant Units 1 & 2
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FROM:
David Fischer, Staff Engineer I !..
SUPPLEMENT NO. 1 TO THE MIDLAND PLANT SAFETY EVALUATION REPORT t
SUBJECT:
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Attached is Supplement No. I to the NRC Staff's Safety Evaluation Report (SER) 1it related to the operation of Midland Plant, Units 1 and 2.
It addresses the Committee's recommendations as contained in its interim report on the Midland Plant, dated June 8, 1982.
It also provides more recent information regarding
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resolution of some of the open items and confirmatory issues identified in the SER. The only new open item is one prompted by the ACRS interim report; it deals with natural circulation during small break loss of coolant accidents.
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>g In reviewing the ACRS interim report on Midland the staff identified 12. topics l
2 which need to be addressed / tracked. Each is identified below with a summary e
of what the Supplemental Safety Evaluation Report (SSER) says.
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1.
Design Adequacy and Construction Quality: MC Region III is preparing
- NI a report which will address Midland Construction problems, their-
,Fi disposition, and the overall effectiveness of the Consumers Power 1
Company's (CPCo) efforts to ensure appropriate plant quality. The l
' b, report will cover construction up to June 30, 1982 and will be issued
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p ni by October, 1982. Another report will cover July 1,1982 through,
- I construction completion.
The NRC staff is still considering the need for the applicant to acquire an independent evaluation of the adequacy of Midland's design and construction.
(Ina,lettertoCPCodated n_'
July 9,1982 the staff requested CPCo to " start to perform an evalua-4 4 '
tion leading to such a report on a schedule compatible with your o
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licensingneeds.")
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?I 2.
Decay Heat Removal Following More Severe Earthquakes: This section addresses the Committee's recommendation that plants be designed for earthquakes more severe but less probable than the SSE.
The Staff responded that "because of the margin inherent in the design L
of individual components and the fact that redundant components of a safety system typically are not exposed to the same loads because t
- of different locations, it is likely that systems functions would not be lost in case of earthquakes more severe than the SSE.* We j
should htar nare from the staff nn the basis for this position.
I The staff admits that their argument lacks a quantative basis. Perhaps i
we could persuade the staff (and applicant) to deal with this issue in I
a technically rigorous fashion rather than have them apply their gut j[
feeling that the margins inherent in designing a plant to the SSE are I
good'enough.
ACRS DFISCHER/w 7-19-82 FILE: MIDLAND BRSER 8400010168 840710 PDR FOIA RICE 84-96 PDR
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- 3. _ Reactor Vessel Head Vent:
Issue still open s
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Reactor Vessel Level Indication: The NRC Staff is still requiring (as a licensing condition) the applicant to provide the itemized documentation required by Item II.F.2 of NUREG-0737.
Their submittal should address additional differential pressure instrumentation between i
the vessel head and the lower level of the hot leg. The SSER states p.
the staff's preliminary position that "further submittals by the l'
applicant also should include a reactor coolant pump current monitor, or equivalent, to trend void content of reactor coolant during forced 1
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ci rculation. An acceptable equivalent would be a differential pressure
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transmitter sensing pressure change from a tap at the bottom of the vessel, and design to trend voiding with the pumps running." I am not quite sure what the staff has in mind as far as the aforementioned 4i
" acceptable alternative" goes.
I am curious about their differential E
pressure transmitter sensing pressure change from a tap and also about j'
the ability of a differential pressure instrument to trend voiding
.C with punps running.
I doubt the ability of either of the mentioned techniques to detect voiding (no less trend voiding). We should pursue b
the staff's justification for their preliminary position at our next k
Subcommittee meetir.g.
tp7 5.
Operating Shift Experience:
The SSER indicates that the applicant b
intends to meet thi staff (and ACRS) position that each operating jf shift at Midland be augmented with at least one person having experi-F ence on a large Commercial PWR for at least the first year of h,
commercial operation at Midland (i.e., until the permanent Midland operators have acquired at least one year of commercial operating
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experience).
The applicant is exploring the availability of experi-enced personnel through several agencies.
6.
Augmented NRC Audit of Operations: NRC Region III will implement an augmented audit of operations at Midland during the early years i-of operation as recommended in the Committee's interim report.
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Probabilistic Risk Assessment: The applicant has advised the NRC i
staff that its PRA will be submitted for review in early 1982 (changed from fall of 1982).
8.
Natural Circulation During a Small-Break LOCA:
The staff is continuing its evaluation of small-break LOCA models including those for Midland under Items I.C.1 and II.K.3.30 of NUREG-0737. The staff is working with the B8W owners and NRC's Office of Research to obtain confirmatory experimental data in this area. This topic will be considered an j
open l>>ue for Itidiand "until an experimental program to obtain the necessary data is funded and established to further confirm'the stiff's understanding of portions of the B&W system dynamics, and to provide additional verification of existing analytical methods." This staff l'
response is puzzling.
The item will remain open until a program (
is funded and established, not until results are obtained. At our next Subconmittee meeting it might be a good idea to find out why(the i
staff is taking this approach.
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o 9.
Systems Interaction: The Committee indicated its desire to be informed of the results of Midland's systems interaction study. By a letter dated June 25, 1982, the staff requested that the applicant provide a summary report of their plans in this regard and provide the results of their program for staff review. The staff will report the results of its review to the Committee.
- 10. Population Density Consideration: The Comittee stated its belief that in view of the population density near Midland, additional pru-dence is appropriate for the Midland Plant in the resolution of the issue of anticipated transients without scram and other Unresolved Safety Issues. The staff will specifically consider this ACRS recom-mendation when grouping the plants for implementation of the technical resolution of Unresolved Safety Issues.
- 11. Emergency Procedures: The staff endorses the Committee's suggestion that there be active participation by Midland Plant personnel in emergency procedures developed on the basis of an assumed accident at the DOW Chemical Plant. The staff has asked the applicant to provide a brief description of the interfaces between the emergency plan for the Midland Plant and that for the DOW Plant, emphasizing the actions that Midland Plant personnel would take in the event of an accident at DOW.
- 12. Turbine Missile:
This open item remains unresolved and will be discussed in a later supplement pending staff receipt and review of.the General Electric analysis which explains the GE missile genera-tion probabilities.
Additional topics addressed in the SSER include:
1.
Tornado Missiles: While this open item remains unresolved, missile protection need not be provided before the first refueling i
outage, but shall be provided no later than January 1,1985.
In addition, the staff is requiring the applicant to install concrete tornado-missile shielding above diesel fuel oil pipes (buried under 2 feet of soil) between the diesel fuel oil tanks and diesel generator building.
2.
Emergency Preparedness: This area is addressed in detail in the SSER but will remain an open item. Based on its review, the staff concluded that the Midland site Emergency Plan, on 7
satisfactory completion of the items listed below, will be accep-table. The items are summarized as follows:
(a) The applicant must provide a brief description of the inter-faces between the emergency plan for the Midland Plant and for the DOW plant emphasizing the actions that Midland personnel l
will take after being notified of an accident at 00W.
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(b) The staff has under review the applicant's f.r (1) meteorological and dose assessment proposals
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(2) concept of operations and method for meeting the ~ 4
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staffing guidelines of NUREG-0654 for the EOFs (3) ' description of the prompt notification system The applicant must resolve satisfactorily any deficiencies
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that result from this review.
it' The confirmatory issues identified below have been closed out. There is l j.
some discussion of each in the SSER.
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1.
Supplemental ECCS Calculations (4.2.3.3)
- 2.. Adequacy of BWSTs to Provide Boric Acid to RCS (5.4.4.2) 3.
MFW Overfill Protection (5.5.6) f.,
4.
Applicability of Power Train Code (15.1.2)
P 5.
Steam Generator Water Inventory as a Function of Power i"
Level (15.2.3)
K 6.
Loss of Flow Transients (15.3.1) n K
I suggest that we address each of the 12 staff-identified follow-up topics
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from the Comnittee's interim report at our next Midland Plant Subcommittee
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meeting..We probably should concentrate on Midland's design adequacy and j(
construction quality, on natural circulation during a SBLOCA. and on decay. heat 1i renoval following earthquakes more severe than the SSE.
The other nine topics p
might adequately be addressed by shorter status reports or by questions onlig
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The NRC staff has indicated to me that they see no need for an ACRS Subcommittee
[C meeting on Midland until the spring of 1983 (anything before March would impose a severe hardship.on them).
However, we may want to schedule one sooner 4
after we have seen the I&E report on Midland construction problems, etc.
(October,1982), the Applicant's PRA (early 1983), or the systems interaction study summary. By spring we may even be able to get.a good status on the Applicant's plans to conduct an independent design audit.
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,f I look forward to talking to you about tentative plans for our next Subcommittee
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't meeting.
We might want to start lining up our consultants soon. Perhaps
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you could give some~ thought as to whom you would like to help us.
I will keep
- you posted on events related to Midland.
Attachment:
As~ Stated k
cc:.ACRS Members E. Epler l
j W. Lipinski-3-
J. Osterberg I
'R. Fraley N. Libarkin J. Mckinley G. Quittschreiber e
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MI!XAND PLANT LBIITS 1 & 2 OPERATDIG LICEREE REVIllW JUNE 2, 1982 PROJECT S1hTts REPORT
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PURPOSE:
. The purpose of this meeting is to review the application of Consumers Power company for a license to operate the Midland Plant thits 1 & 2.
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BACMGROLMD:
Pertinent facts concerning the Midland Project are included in my May 17, 1982 project status report for the ACRS Subcommittee Meeting on Midland Plant thits 1 & 2 - May 20-21,1982. That project status report contained:
4 a description of the plant site a ' description of the plant i
comments on plant elevation and design water levels a status of the ACRS review l
a list of open items and licensee conditions 4
Attachnents to the May 17th status report included:
a map of the Midland a diagram at Midland's reactor coolant system 4
a table comparing Midland features with those of Rancho Seco,.
Oconee, and Turkey Point past ACRS letters Staff response to connents made in past ACRS letters Dr. Siess' report of the Ad Hoc Subconnittee on foundation problems and renedial actions at Midland Plant thits 1 & 2 Cbnsultant reports
- Dr. R. Fbster, Conments on Midland's EES and Bnergency Plan
- Mr. P. Davis, Evaluation of Aux. Feedtater Reliability at Midland
- Dr. P. Pbmeroy, Comments on Midland Seimnic Site Specific Response Spectra
.- Mr. J. Hickman, Comments on Midland's Aux. Feedwater Design
' Statement of Ms. Mary Sincialt e
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MIDUGC PUdff S'IM1JS RlWORT i r
. Copies of the status report for the May 20-21 Subcomunittee Meeting are available upon request.
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'the status of open items and licensing conditions has not changed since my last status report. As presented by the lac Staff during the May 20 :
Subccennittee Meeting, these items are listed on Attachment I to this report.
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' MIDU@iD PIANT SUBCOPHITTEE PEETINGS 10 REVIDi CONSUPERS OL APPLICATION f
On April 29, 1982 an ACRS Ad Hoc Subccennittee met to discuss the remedial actions for soils-related structural settlement problans at the Midland i
. site. Of particular note in this report is the Ad Hoc Subconunittee's re-commendation (accepted by the full ACRS during the May N11 Committee meeting) that the Midland Plant Subcommittee review:
1.
'!he adequacy of the seimnic input criteria and 2.
'Ihe seismic Site Specific Response Spectra and its relation to the proposed permanent site dewatering as a means of re-ducing the probability of liquefaction due to an earthquake.
A During the May 20-21 Midland Plant Subccennittee Meeting the following topics were discussed:
'Ihe status of the MIC Staff's OL review
'Ibe quality of design and construction Itanan factors review of the control room Alternative shutdown panel Instrumentation to detect inadequate core cooling i
AC/DC system reliability Process steam Seimnic issues (including seimnic input criteria, seimnic site specific response spectra, and liquefaction)
Probabilistic risk assessment Auxiliary feedwater system reliability Utility organization, management, and training Snergency operating procedures System high point vents
. Snergency planning Radiation protection progran Ehvironmental issues at Midland htential for ground water contamination I
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. MIDuem MAlfr SMTUS REPORT j l
i Several items which were scheduled to be discussed during the May 20-21 meeting were deferred until the June 2nd ***==ittee Meeting. tese topics include:
. - Items from previous ACRS letters i
.Matho s to re uce ccomon cause failure d
d Seismic and envirc mental qualification of equipment important Integrated control system h pl a t a fety IIm system operation i
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". Bolting and other high strength material l
Fire protection i
Habitability Industrial Security will be discussed at the June 2nd a h ittee Meeting since we have the facilities in Washington to hear this pecpriatary pre-E sentation.
Se tentative schedule for the June 2nd Subccumittee Meeting was issued on May 25, 1982.
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ADDITICBIAL INFORfRTICBI FOR THE JLBIE 2 SUBCONGTFEE DEETIlG Se lac Staff's Midland Plant Project Manager, Mr. Darl Hood, has compiled a list of ACRS concerns from past ACRS letters. Mis list, Attactunent 2, is complete and should obviate your review of chapter 19 in the OL SER. Mr.
Hood' references the section(s) of the OL SIR which addresses each ACRS corr-cern. Ibr 'ench concern, he muunarises:
j the ACRS concern the CP SER response to the ACRS cdncern j
the OL SER section that relates to the ACRS concern i
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Familiarity with Attachment 2 should allow us to move more quickly through the
" ITEMS FR(M PREVIOUS ACRS LETIERS" section of the June 2nd Subccomittee Meeting.
ADDITIONAL INFORMhTION FOR 1HE JUNE 4 FULL CONGTFEE fEETING f
Attached to this project status report is a menorandtsn from Mr. Hood to me dated April 7,1982 -(Attachment 3) that discusses the Midland breakdown in quality assurance with respect to soils activities. S e testimony filed June 6 1981 referred to in this memorandum is voltminous. Rather than transmit it to i.
you, I would like to tell you dat is in it. If yea would like to see all or l
part of this testimony, please let me know. 1he June 6th, 1981 lac staff testi-p-
'sony contains:
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t MIDUGC MANF SM'NB RFJORT 1.
hetisony of Eugene J. Gallagher with respect Quality Assurance Program Implementation Prior to December 6,1979; Attached to Mr. Gallagher's testimony are those documents listed on Attachment 4.
Se conclusion of his testimony states *he quality assurance deficiencies related to soil construction activities under and around safety relates structures and systems arising from improper implementation of the quality assurance progra provide adequate bases to modify the construction permits by suspending those soll con-struction activities."
2.
E Staff testimony of James G. Neppler with respect to the quality assurance implementation prior to December 6,1979; Significant attachments to this testimony include:
- Midland Susunary Report - an overall assessment of the Midland construction project to mob. 15, 1979 Midland Construction Status Report as of Oct.1,1979 March 15, 1979; Summary of Feb. 23, 1979 and March 5, 1979 meeting March 12, 1979; Midland Diesel Generator Building and Plant Area Fill 3.
E Staff testimony with respect to quality assurance; 4.
Watimony of Joseph D. Kane with
- respect to the quality assurance progran implementation prior to December 6,1979; 5.
hetimony of Darl S. Hood with respect to the gality assurance progran implementation prior to December 6,1979; 6.
MC 9taff testimony with respect to implementation of quality assurance for soils work and remedial measures after December 6,1979; he testimony includes as an attactunent major sunenary findings in the areas of managene1 effectiveness, pipirvi and supports, QVQC program assessment, civil (soils) activitees, and electri-r cal work.
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MIDum PLANF S1MUS REPORT,
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WC Staff testimony of Darl S. Hood, Jeffrey K. Kimball and Rgene Gallagher on Stamitis contention 1; 8.
MC Staff testimony of Darl Hood, Joseph Nane, Frank Rinaldi and Eugene Gallagher on Stamitis contention 2; and 9.
mc staff testimony with respect to intervenor stamiris con-tanti,on number 3.
I have extracted Ms. Stamitis' three contentions from the applicable testi-many and have included them as Attactment 5.
As a result of the above listed testimony the conclusions of Attactunent 6 were reached. Mt. Hood adequataly summerised these conclusions in his April 7th meno to me een he said "the applicant assequently agreed, by joint stipulation with the staff, not te contest the Staff's findings that a m breakdown in the soils area existed as of Decenber 6,1979. 1he
' stipulation went.on to note that changes hai been made to the organisation anij procedures,'and that the staff now finds these areas to be acceptable.'
'I also here a.oEpy of the ASta's Findings of Fact and Conclusions of law (dated December 30, 1981 and supplement thereto dated March 26,1982). The supplement addresses the same s@jects addressed in the original findings -
quality assurance and management attitude. W ific adjects addressed in the supplement include (1) SALP (2) 1he MPSD reorganisation (3) Quality control inspector quellfications and (4) Audit Report F-77-32. 1he con-clusions reached in the December 30, 1981 findings were not changed.
(Attactonent 7).
The two Systematic Assesanent of Licensee performance (SALP) reviews dich have been completed on Midland are attached (Attachment 8 and 9). Consumers has responded to the latter of these two reviews in a adsnittals dated May 17th 1982 (Attachment 10). Attactanent 11 is a Midland Project Quality Assurance Program tydate Executive Sununary. If you are interested in reviewing Midland's Quality Assurance Program in detail, a two volume description of it is avail-able.
As a result of the most recent SALP report, Mr. Neppler (Region III Admin-istrator) la reevaluating the testimony he made to the ASta. This reevalu-ation will be completed in mid June. Selected I&E inspection reports are included as Attactsnent 12.
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... i MIDEAND PLANT UNITS 1 & 2 d'
OPERATING LICD58 IEVIEW MAY 20-21, 1982 PEQJECT 9FA'ItB IEFORT PURPOSE:
S e purpose of this meeting is to review the application of consumers Power Company for a license to operate the Midland Plant Units 1 & 2.
BActl0ROUND:
l Pertinent facts concerning the Midland Project include:
Locations t o Midland site is located partially within the city of Midland, M!dland County, Michigan. 'the city of Midland is approximately 105 miles IWW of Detroit and about halfway up Michigan's lower pontosula on the Lake Ituron (east) side. Se facility is located.
along the south shore of the Tittabaweasee River and south of the city of Midland. Se site is adjacent to the Dow Chemical company's (Dow) main industrial complex in Midland (1<,cated on the north side of the Tittabawassee River and dus north of the plant). Within l
10 miles of the plant, the 1970 estimated population was 72,706, t
within 5 miles, there were 48,501 residents. Circulating water for the two mits is obtained from a cooling pond. Se cooling pond i
receives make-up water from the Tittaba:essee River. A map of the Midland plant site is included as Attachment 1.
p Plants Each of the two units at the Midland plant employs a Babcock and Wilcox-designed nuclear steam supply system (NSS3) consisting of a pressurised water reactor (PWR) rated at 2468 megawetts thennal (MWt),
a pressuriser, two steam generators, four reactor ocolant pumps, and the associated piping required to connect these components. Attach-ment 2 shows the NSSS arrangement. H is rated power level includes 2452 MWt generated in the core plus 16 MWt added to the NBSS by the four reactor coolant pumps. Se maximum core design output (excluding pump heet) is 2552 MWt. 21s power level is referred to as the stretch level and is the value used in the radiological accident an-l l
alyses. S e Midland plant is unique in that the heat generated will be used not only to produce electrical energy but also to produce steam for the Dow Chemical C a pany plant. Se facility's turbine L
generators will produce 504 megawetta electrical PWe) from Unit 1 and 852 MWe from Unit 2.
We remaining heat from it I will normally i
at 1200 be used to produce 460 kg/s (approximately 3.6 x 1 lbg)b/hr) at kre gauge (175 peig) and 50 kg/s (approximately 0.4 x 10 l
4100 kPa gauge (600 peig) of process steam for use at the Dow plant.
l Se process steam system is a tertiary system utillaing heat extracted C
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i STATLE REPORT /MIDEAND Se containment for the nuclear steam supply systen (NSSS) is a post-tensioned, reinforced concrete structure with a steel liner to provide leak tightness. % e containment s ich was designed and constructed by Bechtel Power Corporation has a design pressure of 70 psig.
Se reactor cores will be loaded with 177 fuel assemblies (15x15). H e core will have an average thermal output of 5.47 kw/ft-(based on cold BOL data). S e SSE is 0.12 g hori-zontal, 0.8 g vertical. %e CBE is 0.06 g horizontal, 0.05 g vertical. A comparison of Midland features with those of simi-lar plant designs is included as Attachment 3.
ADDITIONAL CONSIDERATICNS:
Midland Units 1 s'2 have a noninal finish grade elevation of +634 ft.
%e design high water level due to probable maximum flood, including wave run up effects is +635.5 ft. %e design water level of the Tittabawassee River, cooling pond, and ultimate heat sink are +588 ft,
+618 ft, and +G04 ft, respectively.
ACRS REVIEW:
he ACRS reviewed Midland for a CP license in Jure 1970. A Mpy of the CP letter and supplement thereto is included as Attachments 4 & 5, re-spectively. In response to requests for additional information from the Atomic Safety and Licensing Board (ASIJn) the ACRS wrote an addi-tional Supplemental Report on Midland Plant Units 1 & 2,~ dated Nov.18, 1976 and provided coments to the Commission Chairman in a letter dated March 16, 1977. %ese two letters are Attachments 6 and 7 to this status report. Supplernent No. 2 to the NRC Staff's CP SER of the Midland Plant addresses the ACRS concerns identified in the second supplemental ACRS letter report dated Nov. 18, 1976. his Staff SER supplement (less the ACRS letter) is included as Attachment 8.
.on April 29, 1982 an ACRS Ad Hoc Subcomittee met to discuss the remedial actions for soils-related structural settlement problems at the Mid-land site. %e report of that Ad Hoc Subconsnittee meeting is included as Attachment 9.
Of particular note in this report is the Ad Hoc Sub-committee's recommendation (accepted by the full ACRS during the May Full C meittee meeting) that the Midland Plant 9*mmmittee revews
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te adequacy of the seismic input criteria and 2.
%e seimnic Site Specific Response Spectra and its relation to the proposed permanent site dewatering as a means of reducing the probability of liquefaction due to an earthquake.
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' STA'IUS REPORT /MID[AND i he full ACRS is tentatively scheduled to review the OL application during its June 1982 meeting.
OPEN ITEMS:
here are currently 16 open items. About half of these items are un-resolved due to pending NRC Staff action / evaluation and half due to the need for additional information/ evaluation from consmers Power Company.
Disagreements between the NRC Staff and the Applicant still exist on several soils settlement issues and on the need for a reactor vessel head vent. A list of the current open items is included in Attachment
- 10. Attachment 10 also lists the license conditions to be imposed on the applicant. For a description of each of these open items and license conditions, please see the indicated section of the MC Staff's safety Evaluation Report.
MEETING TEVFATIVE SCHEDULE:
r he meeting tentative schedule was issued May 12, 1982. It incorporated topics identified in the NRC Staff's SER, past ACRS letters (Attach-ments 4,5,6, and 7), the ACRS Staff's list of suggested discussion items for OL Subcomittee meetings, and items identified in consultant reports concerning Midland. Se consultant reports are included as Attachment 11.
Coments received from ACRS members and staff were factored into the tenta-tive schedule as were the coments received from members of the public.
SUBCOP9tITTEE ACTIONS REQUIR_ED:
%e Subcomittee should decide if the full ACRS should review the appli-cation of Consumers Power Company for a license to operate Midland Plant Units 1 & 2 at the June ACRS full Committee meeting. If the Subcomitee decides that the full Comittee should review Consmers application in June, then the topics to be discussed during the Midland portion of the June full comittee meeting should be identified at the close of the Sub-
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committee meeting.
1 PUBLIC PARTICIPATION:
A member'of the public (Mary Sinclair/Dr. 01arles Anderson has requested
. an opportunity to make an oral statement regarding the soils / foundation question. Time has been made available on the schedule for this state-ment. In addition, Mrs. Sinclair has provided a letter, Attachment 12, for ACRS consideration.
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