ML20094M312
| ML20094M312 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/10/1982 |
| From: | Paton W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Adensam E NRC |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX21-011, CON-BX21-11, FOIA-84-96 NUDOCS 8408150616 | |
| Download: ML20094M312 (2) | |
Text
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nr.
August 10, 1982 Note to: Elinor G. Adensam From:
William D. Paton
Subject:
Quality Assurance Issues to be Addressed at an Evidentiary Session in the Midland Proceeding Attached to this note is the July 7,1982 Memorandum and Order (hereafter
" July Order") by the Midland licensing board in which they comment on issues they wish to have addressed at the forthcoming evidentiary session on quality assurance and quality control matters. Those issues are:
1.
As discussed on page 3 of the July Order, Staff testimony should discuss "in detail" the basis for the Staff's position set forth in our June 29, 1982 letter in which we expressed our conclusion that it was necessary to supplement the testimony previously submitted with respect to quality assurance. The Board suggests that not only Mr. Keppler be available but also any QC inspectors who might have more detailed knowledge of significant matters dealt with by Mr. Keppler to the extent that their presence might in assist creating an adequate record. We will have to consult with Mr.
Keppler to determine precisely what he had in mind when he concluded that it was necessary to supplement his previous testimony, but it appears at this point that one of the major factors was the apparent discrepancies in the facts set forth in our recent SALP report and Consumers' response to that report.
2.
Qualifications of QC inspectors.
(July Order, p.4) 3.
Qnstions asked by the Board concerning the adequacy of the QA prugram for underpinning activities.
(July Order p.4) 4.
"Certain matters" discussed in the Licensing Board's April 30, 1982 Memorandum and Order (hereafter April Order).
(I also attached a copy of the April Order).
A.
The coverage of the QA program for soils related activities.
2 8408150616 840718 gg)Q 1 3 PDR FOIA RICEB4-96 PDR
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. B.
The matter referred to by the Licensing Board beginning at page 16 of its April Order concerning a 42. inch diameter hole that was drilled to a depth of 40 feet within the "Q" fill area apparently without proper authority without the development of or adherence to written procedures without the participation of the onsite geotechnical engineer and without adequate QA/QC surveillance.
C.
The matter referred to at page 17 of the Board's April Order concerning loose sands.
L D.
Staff inspection reports 82-05 (Detp) and 82-06 (Detp).
. E.
NCR #M01-9-2-051 (April 21,1982), Bechtel Non-Conformance Reports Nos. 4199 (including Stop Work Order FSW-22) and 4245.
F.
The suggestion in.the. interim ACRS report of June 8,1982 that there be a broader assessment of Midland's design adequacy and construction quality.
G.
The results of the Staff evaluation of Drawing 7220-C-45 (See Memorandum and Order of May 7,1982).
Th'e above subjects were addressed by the Licensing Board in its April 30, and July 7, 1982 Orders. There are other QA matters that will have to be addressed at the evidentiary hearing. One is fairly extensive testimony concerning the impact of the subject matter of the " management meeting" that is to take place with CPC sometime within the next 3' weeks.
If Mr. Keppler
.. believes that the outcome of that meeting remedies CPC's QA problems, he will have to explain that to the Board.
We may also have to address the subject of recent affidavits provided NRC by GAP and other documents provided Region III concerning ZACK (provided by s
T.Howard).-
Region III confinned yesterday that they expect to be able to prepare their QA testimony by October 31, 1982.
W a
D. Paten Midland Counsel
Enclosures:
July Order April Order cc w/ enclosures Robert F. Warni k (Reg. III)
Ross B. Landsman (Reg. III)
!Darl Hood c
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UNITED STATES OF AMERICA M
NUCLEAR REGULATORY COMMISSION
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ATOMIC SAFETY AND LICENSING BOARD fk Before Administrative Judges:
g Charles Bechhoefer, Chairman Dr. Frederick P. Cowan g
' Ralph S. Decker
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Docket Nos. 50-329 OM In the Matter of
)
50-330 OM
).
CONSUMERS POWER COMPANY
)
Docket Nos. 50-329 OL
)
50-330 OL (Midland Plant, Units 1 and 2) )
)
April 30, 1982 MEMORANDUM AND ORDER (Imposing Certain Interim Conditions -
Pending Issuance of Partial Initial Decision)
(
Pending before this Licensing Board are consolidated proceedings arising out of the NRC Staff's December 6, 1979 Order Modifying Construction Permits No. CPPR-81 and No. CPPR-82 (OM proceeding), and the application by Consumers Power Co. for operating licenses for Midland Nuclear Power Plant, Units 1 and 2 (OL proceeding).1/ The facility, currently under
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construction, consists ~ of two pressurized water reactors located in Midland, Michigan.
The Modification Ord'ei was generated as a result of the excessive settlement which occurred with respect to the f acility's diesel generator 1/ The proceedings were consolidated at the request of Consumers Power Co.,
the Applicant in the OL proceeding and the Licensee in the OM proceeding (hereinafter referred to as " Consumers").
See Prehearing Conference
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Order, dated October 24,1980 (unpublished).
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k building and other plant structures.
Hearings which have been held to dat'e concern the soils settlement. issues raised by the Modification Order, ds well as related contentions of intervenors in each of the proceedings.
(The majority of the soils settlement contentions have been sponsored by Ms.
Barbara Stamiris, an intervenor in the OM proceeding.) As reflected in our Memorandum / of October 2,1981, we have determined to issue.
2
. separate ' partial initial decisions dealing with various aspects of the soils
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issues.
The first, now under preparation, deals with quality assurance / quality control (QA/QC) and management attitude issues, as.
delineated in the October 2, 1981 Memorandum.
With limited exceptions, the record on these matters was closed on February 19, 1982, following some thirty-five days of hearings.3_/ The second will deal with proposed i ~ (-
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remedial, actions to correct the soils settlement problems.
Hearings on these matters are not yet completed, partially as a result of the as-yet r
developing positions of all parties on these questions.
With respect to the QA/QC.and management attitude issues, proposed
, findings of f act and conclusions of law, and supplemental proposed findings and conclusions covering matters as to which the record was reopened, have been received from all interested parties, and Consumers has just recently fileditsrepliestoeachof,the proposed and supplemental proposed f_indings and conclusions of the other parties.
During the course of our
-2/ ' Memorandum (Concerning Telephone Conference Call of September 25, 1981 and Applicant's Motion for Partial Decision), dated October 2,1981 (unpublished).
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3/ ~Certain aspects of these issues will remain open until our second partial initial decision.
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N review of these various filings, as well as of the entire record, we have determined that certain conditions governing further construction, as set forth in Section VI of this Memorandum and Order, should be put into effect immediately' pending the completion of our review and the issuance within approximately two or three months of our first Partial Initial 3ecision.1/
Our reasons ' follow.
'I.. Bac'kground Under construction permits such as are in effect for the Midland plants, n
a permittee may normally engage in construction activities in accordance with the principal architectural and engineering criteria and environmental commitments set forth in the application for the facility and the
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construction-permit hearing record, without seeking prior approval of the NRC Staff.
The permittee undertakes such activities at its own risk; they are subject to. Commission approval before an operating license may be granted.
See 10 C.F.R. 50.57; Cf. Northern Indiana Public Service Co.
(Bai.11y Generating Station, Nuclear-1), CLI-79-11,10 NRC 733 (1979),
reversed on other grounds, sub nom. People of the State of Illinois v. NRC
"-4/.This procedure has been previously utili ed by the Appeal Board with respect to these very same reactors. ALAB-106, 6 AEC 182 (1973).
We note that, in a telephone conference call on April 28, 1982, the Staff indicated that'it might reconsider certain earlier testimony expressing reasonable assurance that Consumers' QA program will be appropriately implemented with respect to future soils construction activities (Keppler, prepared testiony, p. 9, fol. Tr. 1864).
It requested that we cancel certain near-term hearings which we had scheduled, and we did so. Memorandum and Order (Cancelling Evidentiary
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. Hearings and Conference of Counsel or Representatives), dated April 28, 1980 (unpublished).
As a result, our first Partial Initial Decision s
could be delayed beyond the time frame we are now projecting.
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( D.C. Cir. No. 80-1163, July 1,1981).
The December 6,1979 Modification Order would have modified this regime by prohibiting certain construction activities with respect to safety-related structures and systems affected by
.the soils settlement problems which have been aired in 'the ongoing consolidated proceeding. The prohibited activities could.not be undertaken absent (1) submission of an amendment to the applicatien seeking approval of remedial actions, and (2) isruance of an amendment to the construction permits authorizing the remedial actions.5/.The Modification Order further provided that a hearing could be requested b'y Consumers or other interested person and, if it were, the Order would go into effect only as a re' it of-an order made following the hearing.1/
The construction activities which the Modification Order would have prohibitedconsistofthe.following:2/
(a) any placing, compacting, or excavating soil materials under or around safety related structures and systems-
$O O (b) physical implementation of remedial action for correction of soil-related problems under and around these structures and systems, including but not limited to:
(i) dewatering systems
/
(i.i) underpinning'of service water ' building h
5/ Modification Order, Part IV. \\The Modification Order has been admitted into evidence as Stamiris Exh.
3, Attachment 15 (Tr.
2479).
6/ ' Modification Order, Part V.
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7/'. Modification Order, Part IV.
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(iii) removal and replacement or fill beneath the feedwater isolation valve pit area (iv) placing caissons at the ends of the auxiliary building electrical. penetration areas (v) compaction and loading activities; (c) construction work in soil materials under or around safety-related structures and systems such as field installation of conduits and t
piping.
Had the hearings in the OM proceeding not been requested, Consumers could not have undertaken any of the foregoing activities without submitting an amendment to its application and obtaining construction permit
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amendments authorizing such activities.
Since the hearing was requested, the normal construction permit authority remains in effect, and no construction permit amendment (or other NRC authorization) needs to be l
h sought in order for Consumers to engage in the activities in question.
I Both the Modification Order (Part V) and the Commission's Notice of in 9-.
Hearing of March 14, 1980 (45 Fed. Reg.18214, March 20,1980) stated-that g.
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this Board is to consider and decide the following issues:
(1) Whether the facts (concerning quality deficie cies) set for;h in Part II of the' Order are correct; and (2) Whether that Order should be sustained.
II.
Facts Und5rlying Modification Order One of the bases for the Modification Order was the allegati that there had been 'a breakdown ir. quality assurance related to soils.
Another 1
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basis was that Consumers _had not provided the information which the Staff and'its consultants required to permit a thorough safety review of proposed remedial actions.8_/
As a result of these deficiencies, the Staff concluded that it did not have reasonable assurance tha't the safety-related portions of ithe Midland f acilities would be so constructed that they could be ope' rated without undue ~ risk to public health and safety.
With regard to the first' basi.s, Consumers and the Staff entered into a stipulation on June 5,1981, in which Consumers conceded that prior to
-December 6,1979 there were quality assurance deficiencies related to soil construction activities.
Consumers agreed not to contest the Staff's conclusion that these deficiencies constituted a breakdown in' quality
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assurance with respect to soils placement at Midland, and it acknowledged that the deficiencies constituted an adequate basis for issuance of the Order.9_/ With regard to the second basis for the Order, the Staff and Consumers entered into two additional stipulations in which Consumers agreed not to. contest that, as of December 6,1979, the NRC Staff had insufficient information to evaluate the proposed remedial actions for the auxiliary building, for the borated water storage tanks and underground piping.N 8/. We are here making no findings and reaching no conclusions with respect to a third basis for the Order, an alleged material false statement.
Hearings on that ' subject are not yet completed although we have heard testimony on the management-attitude aspects of the alleged statement.
9/
Applicant / Staff Joint Exh. l., following Tr.1175, admitted at f~
Tr. 1188.
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10/ Applicant / Staff Joint Exhs. 2 and 3, dated December 1,1981 and
. February 9, 1982, respectively (Tr. 5447,7164).
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As a result of these stipulations, we are able at an. early stage of our review to conclude, with respect to the first hearing issue, that the facts set forth in Part II of the Modification Order (to the extent they relate to soils QA deficiencies and the adequacy on December 6,1979 of the Staff's information to review remedial actions) are correct and constituted an adequate basis for issuance of the Order.
Consumers, the NRC Staff, and intervenor Barbara Stamiris each submitted proposed findings to this effeet11/
III.
Facts Giving Rise to Interim Reduirements We have not yet completed our review of the second hearing issue-_i,.e.,
whether and, if so, to what extent, the Modification Order s'hould be,
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sustained.
Consumers has described this issue as "whether the safety issues
[giving rise to the facts set forth in Part I of the Modification Order]
have been resolved so that the quality assurance program with respect to soils is now being properly implemented and there is reasonable assurance such implementation will continue through the construction process.".12I Ms. Stamiris has described it somewhat similarly, as
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"whether as a result of revisions, improved implementation, and other f actors, this Board has reasonable assurance that the QA and QC programs will be appropriately impleniented with respect to future soils construction and remedial activities".1.1/ However, they reach different answers to this question.
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11/ Consumers Proposed Findings 1 35; Staff Proposed Findings,
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15 236-237; Stamiris Proposed Findings,1 10.
H/ Consumers Proposed Findings, t 37 [ sic; should be 36].
,l_3/ Stamiris Proposed Findings, i 10.
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- Consumers asserts that, as a result of organizational and procedural changes which it has put into effect since the issuance of the Modification
' Order, its QA program is now being properly implemented.
It urges us to find reasonable assurance that the future soils construction activities including the remedial actions taken as a result of inadequate soils placement will be accomplished in accordance with QA principles of public health and safety.El On the other hahd, although Ms. Stamiris concedes that Consumers' organizational changes represent a " positive response",'g/ she nonetheless concludes that the implementation of QA at Midland is inadequate 16/.and that the same kind of problems and weaknesses currently exist as had lead to ' problems in the past.E/
7I She would have us put the Modification Order into effect and shut down
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. soils-related construction immediately 1,8/ The NRC Staff also gave its reasonable assurance that the QA program would be properly g / Consumers Proposed Findings, 11 81-83.
15,/ stamiris Proposed Findings, 1 222.
g/.StamirisProposedFindings,1221.
-g/ Stamiris Proposed Findings, 1 225.
M/ Stamiris Proposed Findings, '1254; Part III.C.
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implemented 19/ although at least one of its witnesses expressed some reservations (Tr.- 2441 42 (Gallagher)).2,,0f
' We do not at this point in our review express any opinion with respect to those positicns--except to note that none of them is baseless and all have. evidentiary support.
The resolution of this broad issue will, as we have seen, affect the degree to which and the manner in which soils-related construction activities (and part,1cularly remedial actions) will be permitted to continue 21/
As background for our approach to this question, we deem it important to note that the QA/QC deficiencies which are addressed by the Modification Order are not the first instances where Consumers has experienced difficulty
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in properly implementing its QA/QC program.
The Appeal Boaro pinpointed one such. instance in-ALAB-106 (fn. 4, supra), and it imposed conditions designed to alleviate the deficiencies which it found to exist. Later, questions N
-were raised concerning the QA/QC organization being utilized for this facility. ALAB-132, 6 AEC 431 (1973); ALAB-147, 6 AEC 636 (1973); ALAB-152, 6 AEC 816 (1973).
Subsequently, the Staff issued a show-cause order which
,l_9/ NRC Staff Proposed. Findings,1375.
9 20/ Mr. ' Gallagher stated th'at he supported Mr. Keppler's conclusions concerning implementation of the QA program " entirely" but added that he "would like to sea some other things to be included" (Tr. 2455).
See also fn. 4, supra,12.
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21/ As we have pointed out (pp. 4-5, supra), the most stringent
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condition we could impose on those activities under the Modification Order would be to -prohibit such activities pending submission of an f
amendment to the applications and issuance of construction-permit
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amendments authorizing remedial action.
All or any portion of that condition could be put into effect. Cf. Public Service Co. of Indiana (Marble Hill Nuclear Generating StatiTn", Units 1 and 2), CL1-80-10,11 NRC 438 (1980); Wisconsin Electric Power Co. (Point Beach, Unit 1),
CLI 80-38, 12 NRC 547 (1980).
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was founded on other QA/QC deficiencies, and additional corrective acti,ons were mandated.
ALAB-283, 2 NRC 11 (1975), clarified, ALAB-315, 3 NRC 101 (1976).
During that show-cause proceeding, the Appeal Board remarked that
",non-compliane, was + % rnmmission's quality assurance' regulations is * *
- a problem which has plagued the construction of this facililiy." ALAB-270, 1 NRC 473, 476 (1975).69-With this history before us,,early in this proceeding we expressed concern about the adequacy of and the potential safety impact of ongoing construction activities (Tr. 754-55).
On the opening day of the hearing, the Staff responded to our inquiry by presenting testimony regarding soils-related construction of the type that would be going on during_the period of time before we could issue a decision governing construction encompassedbytheModificationOrder.El From that testimony, it appeared to us that Consumers was at that time consulting with and seeking approval of the Staff before engaging in any of the construction activities there under consideration--i.e., installation of 20 aermanent back-up interceptor wells in the area near the Service Water Structure and the Circulating Water Intake Structure, and surcharging of the two valve pits R/ See also Board Exhs. d'and 1B (Tr.1875), which contain a summary of problems experienced at Midland since the start of construction.
23/ Testimony and Supplemental T'estimony of Darl S. Hood, both following Tr.
1097.
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e which are adjacent to each of the Borated Water Storage Tanks.El Although all of the outstanding questions raised by tne Staff concerning
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thosh proposed remedial activities had not then been resolved, the Staff expressed its " reasonable assurance" that the activities would be performed
--in an acceptable manner.El We interpret that reasonable assurance conclusion as premised upon Consumers' affording the Staff the opportunity to review the proposed resolution of the unresolved questions.E/-
In addition, Consumers advised us'that, in February,1980, it had voluntarily comitted not to proceed with further remedial actions without Staff review and concurrencey/
(Insofar as the reccrd reflects, this
-commitment appears to have been an oral one, not reduced to writing prior to its incorporation into testimony in this proceeding.)
That Consumers will provide the Staff with sufficient information to permit a thorough safety I
review is inherent in this conrnitment.
We find no indication in the record that Consumers has failed to honor this commitment.
For its part, the Staff agreed that it would accept information through meetings and presentations rather than an amendment to 24/ Hood, prepared testimony, p. 2.
Those were the only two soils-related activities thtp under way or planned to be undertaken by Consumers in the near t'erm (Tr. 1112).
w 25/ Hood, supplemental. testimony, p. 3.
Subsequently, on December 10,
'y the Staff approved the installation of 5 additional temporary dewatering wells.
Staff Exh.13 (Tr. 6901).
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g/ Hood, prepared testimony, p. 3; supp test., pp. 2,3; Tr.1113-14, F
1119.
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E/ Testimony of Gilbert S. Keeley, fol. Tr.1163, p.13.
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the application.
Beyond the ts.o matters about which the Staff initially testified, the Staff has utilized this arrangement to approve such activities as construction of access shafts and a freezewall in preparation for underpinning the auxiliary building and feedwater isolation valve pits,28,/ and any drilling activities near seismic Category I underground utilities and' structures (Tr. 5485-86).
During the hearing, Consumers agreed that the commitment wbuld be extended to the matter of crack evaluation, a question which Consumers. judged to be less important than does the Staff (Tr. 5735-38). As f ar as we are aware, certain additional remedial actions to which the commitment is being applied are currently under review or in progress.
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From the present stage of our review, it appears that Consumers' voluntary agreement has resulted in adequate Staff surveillance of the proposed remedial actions covered thereby, prior to Consumers' commencement of the remedial actions. Consumers itself has acknowledged the usefulness
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to it of its consultation with the Staff prior to the initiation of remedial activities (Tr. 5660-61). At this time, we are making no changes to the procedures utilized under this arranaement.
w It is important to note, however, that Consumers' commitment does not extend to all the activities'which Part IV of the Modification Order would have prohibited (Tr. 1202-1212, 1390).
The scope of the oral commitment is not clearly defined.
While it ap' pears essentially to cover those major 28/ Letter dated November 24, 1981, from Darl Hood (NRC) to James W.
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Cook (CPC) (Staff Exh. 5, Tr. 5467).
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remedial actions within the scope of Section 1(b), but not activities falling within Sections 1(a) and 1(c), of Part IV of the December 1979 Ordei- (Tr. 1420-1422), there is some ambiguity whether certain activities may fall within Section 1(b) or one of the other categories.
Although we have no objection to the Staff / Consumers working
~ relat'ionship for those portions of the remedial work to which the commitment r
7 applies, several matters of record cause us to be (dissatisfied,with the limited scope of activities covered. More specifically, as a result of the matters described in this section of this Memorandun and Order, augmented by the related information appearing in Part IV, we are of the view that certain activities outside the scope of Consumers' comitment but within the c
e' coverage of the prohibition in the Modification Order should be whipet to_ _ -
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prior Staff review and approval.
The first of these matters which gives us concern is that cf underground piping.
Consumers proceeded with work associated with underground piping which carries cooling water essential to safety without seeking or receiving formal Staff concurrence (Tr. 7784,7788a).
This work
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would clearly have been prohibited under Part IV, Section 1(c) of the k
Modificat Order, and it could also be interpreted as falling within f'
Section Tr. 7788c).
The' record is cer.fusng as to whether the Staff
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g regarded Consumers' commitment as in f act covering that type of remedial action (Tr.
7781-7783, 7788a-7790, 7894-7901).El The Staff expressed
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29/ We disagree with Consumers' response to Ms. Stamiris' Proposed
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the opinion that underground piping should be covered by the commitment (Tr.
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7788c,7789,7899).
Underground piping was of concern to the Staff prior to itsissuanceoftheModificationOrder.E/ One rtason we believe it essential that safety-related activities such as the re^ bedding of piping should have, prior full Staff review and concurrence is that once such work is performed and the piping then recovered with earth, it is no longer accessible for inspection for such concerns as have been identified during the course of this hearing--e_.o., corrosion (Tr. 7683-85,7827-35),
h deformation (Tr. 7913-14), quality of foundation soils (Tr. 7911), pipe
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welds (Tr. 7652-56), and condition of pipe wrapping materials (Tr.
- 7860, 7914-15). Therefore, adequate QA/QC surveillance is fundamental to assuring
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safety.
The Staff has expressed its desire, in f act, to review such matters
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W as compaction criteria and procedures prior to the work taking place, and to be able to inspect the work while being performed (Tr. 7899).
Moreover, the 1
Staff has stated that it h cient soil-profile information to evaluate distortion in pipes buried in soils which have settled._3Il I-The second reason for our requiring further Staff review and approval prior to the start of soils-related construction differs from the first in that it does not stem from a single type of construction activity.
- Rather, it pervades the entire speitrum of soils-related construction activities.
As a result of Board questioning, we have some doubt whether, in the absence N
3_0f I.E. Rept. 79-06, dated April 4,1979 (Stamiris Exh. 3, Att.
8, at
- p. 5).
31,/ Kane, prepared testimony, fol. Tr. 7752, p. 3.
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of Staff review and approval, Consumers would carry out certain remedial soils activities using appropriate QA procedures and orincioles.
Its witnesses presenting the remedial plans for the auxiliary building were (unsurelof the manner in which QA principles would be applied to that operation (Tr. 5530-32).
With respect to the engineering of the remedial actions, Consumers was able to describe the QA procedures it had already followed (Tr. 5718-20), but it, also irtdicated that it did not consider the engineering a problem area and was therefore not applying any specialized procedures to those activities (Tr. 5622)--despite the f act that it had to formulate and rework its, plans four different times before it obtained a system acceptable to the Staff (Tr. 5647-58).
Consumers does not appear to
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have obtained Staff approval with respect t'o the engineering QA procedures which it had followed (Tr. 5750).
Furthermofe, Consumers seems to have a 7
_ tendency to treat as many s.tructurae ir mM: =,;- Q m tad (and, hence, as not subject to QA controls) (Tr.
5626,5671-72).
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For these reasons, we are [ completely satisfied) as to the extent to which QA plans and controls are to be applied by Consumers to underpinning activities. p particular, we are concerned about areas adjacent to, but' g necessarily directly under, safety-class structures. These activitics include boring of large diameter, closely spaced holes for soldier piles which would penetrate low shear-strength soil layers at elevations below the foundations of adjacent safety-class structures (Tr. 5674-79; 5765-71), and essentially all underpinning activities beneath the turbine building the failure or tilting of which might infitence the safety or future seismic
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esistance of the adjacent safety-class structures (Tr. 6083-85; 7125-27).
These potential QA/QC gaps lead us to believe that, at least in the near future,-the commencement of safety-related activities of this type should be subject to the Staff's approval--particularly as to whe'ther specific activities are to be covered or not covered by an appropriate QA p1an 32/
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IV.
Related Matters Substantiating The Need'for Interim Conditions Q
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Certain matters which have been the subject of notifications by various parties to the Board tend to accentuate what we regard as the need for the intarim conditions we are imposing. These matters have not yet been the subject of evidentiary hearings, and we express no final view as to their accuracy or import.
Nonetheless, we regard these matters as closely relevant to the facts on which we have taken evidence and pertinent to our determination that interim conditions should be imposed.
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As one example of this type, representing an activity we believe should be covered by the commitment, the Board has been informed by way of a Consumers' Non-Conformance Report that a 42-inch diameter hole was drilled to a depth of 40 feet within the "Q" fill ar'ea, apparently without proper authority; without the deve.lopment of, or adherence to, written procedures; 32/ We understand that Consumers, later indicated that monitoring instruments would be placed before commencing underpinning activities to measure horizontal movements between the turbine building and adjacent structures "in response to questions raised by the Atomic Safety and Licensing Board". Memorandum dated March 11, 1982 from Darl Hood, Summary of March 8, 1982 Telephone Conversation Regarding Soil
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Spring Stiffnesses for Auxiliary Building Underpinning and Phase II Construction.
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without the participation of the On-Site Geotechnical Engineer; and without f.
adequate QA/QC surveillance, if any.3,,3/. We hasten to point out that-we-h' ave not yet heard evidence on this report and express no view as to its accuracy.
It appears, however, to describe the type of activity which is encompassediby the prohibition in Part IV, Section 1(a) of the Modification
' Order.- Moreover, if th'e NCR is accurate, the activity would constitute a
. prime example of the' kind of work which we believe should be subject to prior-Staff review and concurrence.
Additionally, we have also recently been notified of loose sands located in the plant fill north of the Service Water Structure and Circulating Water Intake Structure. This loose sand reportedly underlies
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about 500 feet of seismic Category I pipe.
We understand that Consumers
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a has decided to remove and replace this material to avoid potential liquefactionproblems.El Once again, we express no view as to the validity of this infermation.
But considering the vagueness as to the limits of Consumers' comitment and the apparent potential effect on public safety of these construction activities should the plant later be allowed to operate, we deem it necessary at this time to eliminate any uncertainty and i.
33/ NCR # M01-4-2-008 Rev7T, dated February 25, 1982, transmitted to the Board and parties by letter dated March 12, 1982, from James E.
Brunner, CPC.
The Board requested that it be provided with audit reports of this type (Tr. 5975-76).
34/- Memorandum from Darl Hood, Notification of Loose Sands Beneath Service Water Piping, March 16, 1982.
See also letter from James W.
Cook to Harold R. Denton, Additional Information Concerning Safety Grade Buried Piping, March 16, 1982.
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to require that any remedial actions intended to rectify this matter receive full Staff review and concurrence before being undertaken.
Finally, the Board notes that the Staff has disagreed with ConsumersEl over the extent of QA coverage and control of the m
underpinning activities beneath the safety-class and adjacent non-safety
~
class buildings.
The disagreement apparently has been resolved by Consumers' agreeing that essentially all underpinning activities would be subject to Q-controls, except for certain already completed activities and 36/
certain agreed-upon non-critical activities Although the Board recognizes that these disagreements may reflect genuine differences of interpretation of requirements in Appendix B to 10 C.F;R. 50, we deem it important to public safety that, pending the completion of our QA review, the Staff's more conservative interpretation should apply to remedial work activites, some of which are, or shortly will be, in progress.
Accordingly we have made the elements of that, agreement part of this Interim Order. Again, while we express no views as to the validity cf those matters brought to our attention outside the actuai hearings, they represent the kinds of issues that were alleged in the December 6,1979 Mcdification
-35/ Memorandum dated March 12, 1982, from Darl Hood, subject:
Summary of March 10, 1982 Mee' ting Concerning Quality Assurance To Be Applied To Remedial Foundation Work.
36/ Letter, James W. Cook (CPC) to J. G. Keppler (NRC), dated April 5,
1982, subject:
Quality Assbrance for Remedial Foundation Work.
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Order, and that were the subject' of ongoing efforts by the Staff and Consumers to resolve them.
V.
Description of Interim Requirements As a result of the various safety problems which we have described in Section III, above, the potential and related problems described in Section IV, above, and the iminence of the commencement of additional safety-related work activities, on remedial measures for the soils. settlement problems which we have been considering, we find it necessary to act now to remove ambiguities in Consumers' commitment to obtain prior Staff approval for remedial measures.
Pending the completion of our review of the record and issuance of a partial initial decision, we are requiring that the construction permits be amended to orchibit '(in the absence of Staff approval) the same activities as would have been prohibited by Section IV of s
the Modification Order.
(We are updating the requirement to take account of certain developments which have occurred since December 6,1979.) This requirement would not apply to any of the activities as to which the NRC has already given its approval.
Nor does it dictate the manner in which the Staff may exercise its review--i.,e,., whether piecemeal (individual construction steps) or as an integrated package.
In addition, for the reasons we have outlined, Re are requiring tnat certap of,these activities
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be governed by a QA plan.3,8/ We have pointed out that some of the material which we have considered in this order has not yet been the, subject of a completed evidentiary hearing; indeed, the scope of our QA requirement is premised in part upon an apparent agreement between Consumers and the Staff contained in material of this' sort.
Letter of James C. Cook, fn. 36,
)
We expect Consumers and the NRC Staff to present testimony on theseg
- supra,
_ open items at a later evidentiary session.
h We stress that in our forthcoming Partial Initial Decisien we will reexamine the terms and conditions which we are here imposing on an interim basis.
At that time, we may reaffirm, expand or remove them.
Until such time, however, we find that the Modification Order should be, made effective to tha extent which we have described.
We stress that we are not at this time requiring the submission or approval'of any amendments to the applications for construction permits (as provided by the Modification Order).
In our opinion, the Staff consultation and approval which we are requiring will achieve the substantive results we believe necessary without adding certain procedural requirements of an application for a constructicn permit amendment which, in the present context, do not appear to be necessary to attain the safety goals which we believe should be achieved.
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38/ To require a QA plan for safety-related remedial soils construction activities is consistent with the requirements of 10 C.F.R. 50.34(a)(7).
We note that 4he large-scale underpinning and other remedial activities which are being undertaken are sufficiently distinct from the activities contemplated during the construction-permit review as to warrant a supplementation of the applicable QA program.
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VI. Order
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Based on the foregoing, it is, this 30th day of ril, 1982
. ORDERED That the Director of Nuclear Reactor Regulation, in accordance with 10 t
1 C.F.R. s2.764(b), is authorized to amend Construction Permits CPPR-81 and d
CPPR-82 as follows:
(1)
Construction Permits CPPR-81 and CPPR-82 shall be ainended to require that the permit holder obtain; exolicit prior approval from the NRC Staff.(to the extent such approval has not already been obtained) before proceeding with the following soils-related activities, and that these activities, with the exception of those already approved by the NRC, and those that the Staff agrees are not critical, shall be controlled by a Staff-app' roved Quality Assurance Plan:
C-h g-(a) any placing, compacting, ng, or drillin soilh materials [aroundisafety-related structures and systems; (b) physical implementation of remedial action for correction of soil-related problems under and around safety-related structures and systems, including but not limited to:
(i) d'ewatering systems (ii) underpinning of service water building (iii) removal and replacement of fill beneath the feedwater isolation valve pit areas, auxiliary t
building electrical penetration areas and control 2 { tower, and beneath the turbine buildino O
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(iv) placing of underpinning supports beneath any of '.
the structures listed in (iii) above w
(v) compaction and loading activities; (c) construction work in soil materials under or around safety-related structures and systems such as field installation, or rebedding, of conduits and piping.
(2) Paragraph (1) above shalth apply to remedial actions
~
approved by the ARC Staf'f prior to the effective date of this Order, nor to any exploring, sampling, or testing of soil samples associated with determining actual soil properties en site which"has the approval of the Director of Region III, Office of Inspection and Enforcement.
These testing
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activ.ities, however, shall be controlled by a Staff-approved Quality Assurance plan which includes _ procedures for controlling excavation or drillino activities more than 6-feet deep in "Q" areas.
In accordance with 10 C.F.R. 2.760, 2.762, 2.764(a), 2.785 and 2.786, this Memorandum and Order shall be effective imediately upon issuance and shall constitute the final action of the Commission on the matters considered herein forty-five (45) days after issuance, subject to, 7
any review pursuant to the above-cited Rules of Practice.
Exceptions to this Memorandum and Order may be filed by any party within ten ('10) days after its service.
A brief in suhport of the exceptions shall be filed within thirty (30) days thereafter (forty (40) cays in the case of the NRC Staff).
Within thirty (30) days 'of the filing and service of the brief of t
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,i THE' ATOMIC' SAFETY AND
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LICENSING BOARD 7
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'Dr.f Tre:lerick P. Cowan, Member ADMINISTRATIVE JUDGE
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Ralpnj$. Decker, Member
/ ADMINISTRATIVE JUDGE Dated at Bethesda, Maryland "
A thd-30th day of April,1982. ~ -
.Jedge Jerry Harbotr who'has.. Served, as. a technical interrogator and an alt'ernate Board, member. durin'g portion's of the hearings concerning management attitu'de and quality assurance matters, and who has replaced Judge Decker for the forthcoming segmenis' offthe consolidated OL-0M proceeding (with the exception of the first Part'sel Initial Decisien and orders, such as this.,
one, whictCape inte'gral to that hecision), supports the rulings and
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Vice President - Projects, Engsnernng
< J Constmessos oeneros offises: 1948 West Perno64 fleed. Jaskeen. MI 492ot + (817) 798 o483 August 9, 1982
(_ __PRillCIPAt. STAFF 9
np Mr Harold R Denton, Director 9py Office of Nuclear Reactor Regulation g
Division of Licensing rg-US Nuclear Regulatory Commission din. -
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Washington, DC 20555
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MIDLAND NUCLEAR C0 GENERATION PLANT F
MIDLAND DOCKET 50-329, 50-330 N
I I~ M E 8 ' K '"
FEEDWATER ISOLATION VALVE PIT (FIVP)
LOAD VERIFICATION g
FILE: 0485.16, 0.4.9.20.6, 5.17 SERIAL:
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REFERENCE:
(1) LETTER D G EISENHUT TO J W COOK, COMPLETION 0F SOILS REMEDIAL ACTIVITIES REVIEW, DATED MAY 25, 1982 (2) LETTER W P HAASS TO J W COOK, NRC ACCEPTANCE OF REVISED CP CO QUALITY ASSURANCE TOPICAL REPORT, DATED MAY 19, 1982 Attached are copies of (1) the Midland Project Quality Plant for Underpinning Activities (MPQP-1, Revision 3) and (2) the Midland Project Quality Plan for Remedial Soils Activities and Soils Related Work in Q Areas (MPQP-2, Revi-sion 0).
These plans have been previously reviewed by Dr Ross Landsman and Mr John Gilray, as indicated in the attached Summary of CP Co-NRC Meeting between W R Bird and J Gilray on July 6, 1982.
(Attachment 3).
On August 3,1982, Mr J A Mooney was advised that NitR desired a submittal of the enclosed Quality Assurance Plans to formally document the material previously reviewed with Mr Gilray and Dr Land. man. This submittal meets that request.
It is anticipated that minor revisions of the Quality Assurance Plans or of the topical reports referenced above may occasionally be necessary. The Company intends to submit proposed revisions to the Quality Plans bearing on the work covered by the April 30 Board Order for approval by NRR before putting such revisions into effect. Changes to the Topical Report will be continued to be handled as per the approved CPC-1A Topical as given by NRR n n L) g
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letter of May 19, 1982 (Reference 2).
It would be very helpful if the NRR Staff could act promptly in such circumstances.~so that necessary revisions can be made and implemented in a timely fashion.
7 JWC/WRB/bjw Attachments:
1.
Mildand P'roject Quality Plan for Underpinning Activities (MPQP-1, Revision 3) 2.
Midland' Project Quality Plan for Remedial Soils Activities
- and Soils Related Work in Q Areas (MPQP-2, Revision 0) a 3."
Summary of CP Co-NRC Meeting between W R Bird and J Gilray g,
on Julyq6, 1982 v
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CC: Atomic Safety and Licensing Appeal Board CBechhoefer,' ASLB t
MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB N-SGadler JGilray, USNRC JHarbour, ASLB GHarstead, Harstead Engineering DSHood, USNRC DFJudd, B&W JDKane, USNRC FJKelley, Esq RBLandsman, USNRC WHMa'rshall JPMatra, Naval Surface Weapons Center W0tto, Army Corps of Engineers WDPaton, Esq SJPoulos', Geotechnical Engineers FRinaldi, USNRC HSingh, Army Corps of Engineers BStamiris miO882-0330a-29-100
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3 BCC AJBoos, Bechtel JEBrunner, M-1079 MLCurland, Midland PJGriffin, P-24-513 RWHuston, Washington BWMarguglio, Midland JKMeisenheimer, P-14-208 JAMooney, P-14-115A DBMiller, Midland MIMiller, IL&B (3)
'JARutgers, Bechtel
.JRSchaub, P-14-305 PPSteptoe, IL&B, Chicago TJSullivan/DMBudzik, P-24-624A LASutkus, Bechtel FCWilliams, IL&B, Washington NRC Correspondence i
miO882-0330a-29-100 l
CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 18045 Dated August 5, 1982 At the request of the Commission and pursuant to the Atemic 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 a request to release the remaining soils remedial work. This letter delineates the scop'e of the remedial soils work including the acceptance criteria.
CONSUMERS PO%T.R C0 By
' I W C&tfk ' '
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/ rojects, Engineering and Construction Vice President P
Sworn ubscribed be this day of August 1982 Notary Public
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Jackson County, Michigan RAMBARE P. Tommio
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.A-v ATTACIDENT 1 QUALITY PI.AN FOR UNDERPINNING ACTIVITIES Effective Date July 26, 1982 AV App roved -
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES i
-1.
GENERAL
^All activities for the remedial soils work are covered by the existing Consumers Power Company and Bechtel Power Corporation Topical Reports CPC-1-A and.BQ-TOP-1, Revision IA, respectively. This Quality Plan provides a more' detailed written description of the accomplishment of activities specific.to certain soils remedial work. This Quality Plan was developed to describe how quality programas. tic coverage is extended to encompass the underpinning subcontractors as required by the Quality Plan for Remedial Soils Work (MPQP-2).
The-senior management, consisting of the Vice President of Projects, O
En ineerins and Construction. Consumers Power ComPanr. and the Mid1and Project-Manager, Bechtel Power Corporation (CP Co's contractor for the Midland Nuclear Plant), reviews and approver major decisions and-design concepts regarding underpinning work. For CP Co, a Midland Project Office Executive Manager and an Assistant Project' Manager, and for Bechtel, a Bechtel Assistant Project Manager, will manage the 4
underpinning work. The.Bechtel Site Manager manages overall field activities -including the underpinning work.
The Manager of MPQAD and the Civil Section Head will manage the MPQAD
. support of underpinning work with the overview of the Director of Environmental and Quality Assurance.
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MPQP-1 REVISION 3 July 26, 1982 Page 3 R
QUALITY PLAN FOR UNDERPINNING ACTIVITIES 2.
SCOPE This Quality Plan is applicable to the auxiliary building and service waterstructuret$nderpinningtasks. The "Q" list for this work 9 all inclu'ive and, as such, covers activities, items and structures beyond s
the requirements provided by the FSAR. This. extension to provide Quality Assurance Program coverage over and above the coverage for safety related items provides an additional assurance that the non-safety related activities will not have an adverse affect on safety related structures.
The following major categories of the underpinning work are specifically covered by this Quality Plan.
O i
1.
Underpinning of the Service water Pump Structure as delineated by Specification 7220-C-194(Q).
2.
Underpinning of Auxiliary Building (removal, replacement of fill, and underpinning beneath the feedwater isolation valve pit areas, auxiliary building electrical penetration areas, control tower, and beneath the turbine building) as delineated by Specification 7220-C-195(Q).
(Reference MPQP-1)
Any activity or structure which will be excluded from Quality Assurance Program coverage shall be specifically documented on an exception basis.
Assurance of NRC Region III concurrence with any general exclusion from the Quality Assurance Program is required prior to conducting any work Ni/
activities in the excluded area.
' miO382-4025a-66-141 '
I MPQP-1 REVISION 3 July 26, 1982 Page 4 i
M
..a QUALITY PLAN FOR UNDERPINNING ACTIVITIES Specifications, procurement documents, drawings and procedures are specific as to the design attributes and activities which require quality verification e need for verification shall be dictated by the
-following principal:
The Quality Assurance Program shall provide control over activities affecting the quality of the identified structures, systems and components to an extent consistent with (a) their importance to m
safety; (b) their possible detrimental interaction or effect on 7
safety related structures and items; or (c) assuring obtainment of the overall Project objectives.
3.
UNDERPINNING WORK ORGANIZATIONS Organizations involved with the underpinning are defined in the Functional Matrix, Attachment 1 and as follows:
CP Co Project Management Sets policy, coordinates licensing review, and submittals to the NRC.
CP Co Safety and Licensing Performs licensing reviews and coordinates FSAR revisions.
CP Co Design Production Provides client design input and performs reviews of and comments on
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Bechtel Design Documents.
,miO382-4025a-66-141 I
MPQP-1 REVISION 3 July 26, 1982 Page 5 f3 QUAT.ITY PI.AN FOR UNDERPINNING ACTIVITIES CP Co Site Management Provides overview and direction as necessary for underpinning activities for complicnce with NRC commitments. Monitors underpinning activities with respect to commercial type items, construction activities (such as equipment care, labor and production).
Bechtel Project Management Coordinates with client and sets project policy for Bechtel organizations.
Bechtel Project Engineering O
Establishes design criteria and reviews input from non-Bechtel sources.
Originates and issues design documents for construction.
Bechtel Project Geotechnical Engineer Functions as Project Engineering's Geotechnical representative on project. Performs geotechnical reviews related to design criteria and procedures.
Interfaces with Geotech Services and. Resident Geotechnical Engineer.
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QUALITY PI.AN FOR UNDERPINNING ACTIVITIES t
Bechtel' Site Management Performs the overall on-site management of all construction activities including coordination between Bechtel, CP Co and Subcontractor.
Includes a Construction Remedial Soils Group who is responsible for coordinating the activities of the underpinning subcontractors.
Geotech Services Provides design and field geotechnic.al services as requested by Project Engineering.
.d Resident Geotechnical Engineer O
V.
~ Performs foundation inspection and-on-site geotechnical monitoring of underpinning activities.
Interfaces with the Project Geotechnical Engineer.
Resident Structural Engineer Represents Project Engineering on site and provides structural expertise for the underpinning activities.
Receives and evaluates data from the underpinning instrumentation systems.
g -, 9 &D COMB g ecntel quality Control (QC) y %" 46 h
s Performs first-line inspection and verification, of items under the Quality Assurance Program. Reviews construction procedures, drawings and specifications for inclusion and establishment of inspection criteria.
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REVISION 3 July 26, 1982 Page 7 N
U-QUALITY PLAN FOR UNDERPINNING ACTIVITIES Midland Project Quality Assurance Department (MPQAD)
Provides the quality assurance for all underpinning work including work done by Bechtel and Bechtel Subcontractors. Develops quality plans, reviews design documents and construction procedures. Performs over-inspections and pre planned audits.
Subcontractor Perform construction activities as contracted for, within the framework of the Midland Project Quality Program.
Consultant O
Provides advice to Bechtel Project Engineering or Bechtel Construction on construction methods, design, instrumentation or geotechnical items.
- 4. DESIGN CONTROL Design Control for the underpinning of the Auxiliary Building (Electrical Penetrations and Control Tower Structure), Feedwater Isolation Valve Pit fill material replacement and Service Water Pump Structure underpinning will be provided by Project Engineering. Engineering Department Procedures (EDPs), Engineering Department Project Instructions (EDPIs),
and Project Engineering Procedures (PEPS) provide the controls for Engineering activities which are responsive to the Quality Program requirements of MPQP-2.
e miO382-4025a-66-141 1
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REVISION 3 July 26, 1982 Page 8
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES
-Design criteria will be developed from input from consultants, the Midland Plant Safety Analysis Report, 50.54(f)-responses submitted to the NRC staff, meetings with and submittals to the NRC staff, and testimony during the ASLB Soils hearing.
Design documents, including specifications, drawings and material requisitions, shall be specific as to what is required to ascertain that processes, activities and final products meet their design requirements.
Design documents, including specifications and drawings (as well as changes and revisions to these documents), will be reviewed and checked for compliance to design requirements by Bechtel Project Engineering.
Design documents will be reviewed by Quality Control and MPQAD. The MPQAD review applies to all design documents.
(MPQAD Procedure M-11)
MPQAD will act as the focal point for the assurance of the resolution of quality related comments.
Technical specifications and revisions thereof will be generated, reviewed, approved, and controlled by Bechtel Project Engineering in j
accordance with EDP 4.49.
Initial specifications will also be reviewed by CP Co Design Production and comments submitted to Bechtel Project Engineering. Specification Change Notices (SCNs), used as interim change documents between revisions of the specification, will receive the same 4
level of review and approval by Bechtel Project Engineering as the basic specifications. Specification Change Notices shall be administered and
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controlled in accordance with EDPI 4.49.1.
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MPQP-1 i'
REVISION 3 July 26, 1982 Page 9 O='
QUALITY PLAN FOR UNDERPINNING ACTIVITIES Project Engineering prepares, reviews, approves, issues and controls design drawings in accordance with EDP 4.46.
Changes to engineering-drawings receive the same level of review and approval as the basic drawing and are administered in accordance with EDP 4.47 and EDPI 4.47.1.
Bechtel design calculations are originated, checked, approved, controlled and documented by Project Engineering in accordance with EDP 4.37.
All design calculations submitted by the consultant are checked, reviewed and approved by Bechtel Project Engineering in accordance with EDPI 4.25.2.
Bechtel Construction shall request from or notify Project, Engineering of changes to design documents by Field Change Requests (FCRs) and Field j ())
Change Notices (FCNs), respectively. The FCRs will be reviewed, evaluated, dispositioned, controlled and administered in accordance with EDP 4.62.
FCNs will allow Bechtel Construction to initiate field changes in design documents within the allowable guidelines of Field Procedure FPD-2.000 and Specification G-34 (Q) as provided by Project Engineering.
FCNs will be reviewed, evaluated, dispositioned, controlled and administered according to EDP 4.62.
The design interface for the underpinning activities between Project Engineering, project groups, technical support groups and consultants shall be administered as illustrated in Attachment 2, Design Document Interface Flowchart.
Geotech Services will receive design for review in accordance with EDPI 4.25.2.
The Subcontractor receives design documents sd I
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's QUALITY PLAN FOR UNDERPINNING ACTIVITIES from Bechtel Construction in accordance with FID 1.100.
The Resident Structural Engineers daties on site are defined in PEP 2.14.9.
Inspections are performed by Bechtel QC to verify that construction is being performed to the latest revisions of the design documents. Audits and/or overinspections are conducted by,MPQAD. Field geotechnical activities, inc hding subgrade acceptance, are accomplished in accordance with EDPI 2.14.8.
S.
PROCUREMENT AND Z T.VING Procurement of items and services for the remedial underpinning work is performed by Bechtel employing the technical and quality requirements O
established in the specifications and drawings. Q-material requisitions
~
are originated by Bechtel Construction in accordance with FPG-8.000.
Becht:1 Construction is responsible for assuring that applicable Quality Program requirements, design bases, specificacions, procedures and 1
drawings are included and referenced in the material requisitions.
$ h Bechtel Field Procurement Department initiates formal purchase orders and f will be responsible for ensuring that the procurement package conforms to the material requisit'on. MPQAD reviews and approves procurement i
documents in accordance with MPQAD Procedure M-5 to assure that necessary Quality Assurance Program requirements are included.
Upon receipt of Q-material, inspections are performed by Quality Control in accordance with PSP G-5.1 to verify items comply with the procurement package requirements and quality verifications packages are complete.
miO382-4025a-66-141
1 MPQP-1 REVISION 3 July 26, 1982 Page 11 O"
QUALITY PLAN FOR UNDERPINNING ACTIVITIES Quality verification packages are reviewed for availability, traceability 1,
and legibility by Bechtel QC and audiced by MPQAD (MPQAD Procedure F-1M).
In addition, a technical review will be performed by Bechtel QC in quality verification packages for non-shop inspected items.
6.
PREPARATION AND IMPLEMENTATION OF PROCEDURES / INSTRUCTIONS Written instructions to the Subcontractor are in the form of engineering specifications, drawings, and approved changes thereto.
The G-321D form (controlled by EDP 4.58) attached to the specifications identify the procedures and other vendor submittals, which are the einimum required to be submitted by the Subcontractor prior to the start of fabrication and construction. These procedures are logged, controlled, and distributed by the Field Document Control Center and reviewed by Project Engineering, Bechtel QC and MPQAD.
Project Engineering defines, the specific quality attributes of each procedure.
The procedures will be specifically reviewed by MPQAD for appropriate inclusion of quality requirements. (MPQAD Procedure M-10)
These procedures, when approved by Bechtel QC, MPQAD, and Bechtel Project Engineering, provides authori:ation for fabrication / construction to proceed.
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QUALITY PLAN FOR UNDERPINNING ACTIVITIES 7.
INSPECTION EXAMINATION, TEST AND CALIBRATION Quality verification, inspection and testing of Subcontractor activities i
-is performed by Bechtel Qurlity Control, independent of the Subcontractor and Bechtel. Construction.
Bechtel QC will prepare inspection plans (in accordance with PSP G-6.1) utilizing inputs from technical specifications, design drawings and Subcontractor procedures.
Project Quality Control Instructions (PQCIs) are prepared to cover all Subcontractor quality related activities. Existing PQCIs are adapted for standard construction activities such as concrete batching, placement and testing, and reinforcing steel installation. Additional PQCIs are developed as necessary to verify new underpinning activities such as O
temporary support installation, load transfer and threaded reinforcing coanectors. All PQCIs are subject to MPQAD review and approval according to MPQAD Procedure E-2M.
In addition, inspection and test activities are-monitored by MPQAD through the use of overinspection plans based on an independent evaluation of design and procurement docu.sests per MPQAD Procedure E-15.
The Subcontractor is indoctrinated to Bechtel QC and a
MPQAD procedures and inspection planning to assure that hold points, included as an integral part of the Subcontractor's procedures, are adhered to.
For site construction activities, the detailed implementing procedures shall utilize integrated construction planning, as follows:
a) Hold points shall be clearly identified in the procedures.
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REVISION 3 July 26, 1982 Page 13
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b QUAI.ITY PLAN FOR UNDERPINNING ACTIVITIES
[b) The procedures shall provide for QC/QA signoff to record the completion of the inspection holdpoints prior.to proceeding with the further execution of subsequent procedural steps.
Tests are performed to qualify, demonstrate or assure that the quality of precured items or completed construction is as defined in applicable engineering drawings and procurement documents.
Calibration, maintenance and control of measuring and test equipment is provided by an approved agency which will be pre-qualified by MPQAD.
This agency provides for the traceability to national standards, the unique identification of each instrument or equipment requiring
([)'
-calibration, the maintenance of calibration frequencies, and the identification of calibration status.
Calibration records are maintained by the agency and transmitted to Bechtel Construction for review.
At the
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completion of the subcontract, these records will be turned over to Bechtel Quality Control.
Performance and effectiveness of the agency is verified by MPQAD audits and/or overinspections in accordance with MPQAD Pr9cedures F-1M and E-LM, respectively.
6 HANDLING AND STORAGE All Q-list material is stored and handled in accordance with general Field Procedures FPG 4.000 and 5.000 and supplemented by the Subcontractor's procedure. Storage and handling of material and equipment is subject to Bechtel QC inspection and verification according N.
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miO382-4025a-66-141 6
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MPQP-1
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REVISION 3 July 26, 1982 Page 14
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QUALITY PI.AN FOR UNDERPINNING ACTIVITIES to PSP G-5.1 and MPQAD overinspections and/or audits per MPQAD Procedures E-1M and F-1M, respectively.
9.
DOCUMENT CONTROL AND QUALITY RECORDS Subcontractor documents which are to be submitted for review and comment by Bechtel Project Engineering, Bechtel QC and MPQAD are controlled by the Field Document Control Center (FDCC) in accordance with Bechtel Field Procedure FPD 1.000.
Prior to the start of work, the Subcontractor submits construction procedures, drawings, purchase orders, as required by the specifications, to Bechtel Construction.
Bechtel Construction and the FDCC distributes the procedures for review and approval as defined in
(])
the Quality Plans included with specifications 7220-C-194 and C-195.
Bechtel Project Engineering and/or Resident Engineering, as designated, is responsible for resolving review comments.
All quality records are controlled by EDPs 5.16 and 5.24, Bechtel QC Procedure PSP G-7.1 and MPQAD Procedures F-11M and F-12M.
These procedures prescribe the requirement for preparation, control, distribution and transmittal of all Q-related procedures, specifications, drawings and inspection records.
10.
NONCONFORMING ITEMS AND CORRECTIVE ACTION Nonconformances discovered during construction inspection activities are documented and controlled by Bechtel QC in accordance with PSP G-3.2 and MPQAD in accordance with MPQAD Procedure F-2M.
These procedures provide miO382-4025a-66-141 m
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L QUAI,ITY PI.AN FOR UNDERPINNING ACTIVITIES for the identification and documentation of the nonconforming item, identify the authority for and disposition of the nonconforming condition, and provide for documenting the reinspection and closecut of
,g\\, he nonconfomance. Bechtel QC and/or MPQAD will be involved in the s
specific wording of non-conformance reports to assure an accurate description of the condition. Dispositions to non-conformance reports Itf will be reviewed by MPQAD to assure that the disposition is acceptable, that engineering rationale is adequately documented and that quality a t.b plauning is available for the verification of the disposition.
Bechtel QC and/or MFQAD will inspect and provide verification of disposition implementation prior to closing of the non-conformance report.
O Within the Midland Project Quality Program, the identification of C
reportable items is accomplished by Bechtel QC and MPQAD through the revie'w of nonconforr..nce reports, supplier surveillances and quality assurance audits.
Corrective action for quality problems will be controlled by Bechtel PSP G-3.2 and MPQAD Procedure F-3M.
In the design phase, investigation of cause and action taken to preclude recurrance of design deficiencies will be accomplished through EDP 4.65.
cies include those items which are not identified in the course of design development and which ultimately require changes..
v miO382-4025a-66-141
MPQP-1 REVISION 3 -
July 26, 1982 Page 16
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QUALITT PLAN FOR UNDERPINNING ACTIVITIES J
- 11. AUDITS Audits are performed by MPQAD to verify conformance to quality requirements. MPQAD Procedure F-1M includes provisions for the identification of deficiencies, the determination of corrective action, and the necessary follow up to verify that timely and effective action is ta ken.
12.
TRAINING AND CERTIFICATION All inspectors and quality auditors are trained and certified in accordance with PSP G-8.1 or MPQAD Procedures B-1M and/or B-3M.
Subcontractor field supervisory and engineering personnel are O
indoctrinated to the Midland Project Quality Program. This indoctrination includes an introduction to the quality system, inspection activities, nonconformance control, NRC activities, field and engineering design changes and site organizations and interfaces.
The indoctrination is initially completed prior to any Q-listed work proceeding. Additional training sessions will be scheduled by MPQAD to indoctrinate personnel which are assigned after the initial indoctrination.
The Subcontractor is required to implement training for the procedures covering the Subcontractors Q-listed activities.
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. LIST OF APPLICABLE O
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MPQP-1
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REVISION 3
. List of Applicable Procedures July 26, 1982 Page 18 f*i MIDEAND PROJECT QUAEITY ASSURANCE DEPARTMENT PROCEDURES B-2M Personnel Training B-3M Qualification and Certification of Inspection and Test Personnel E-1M Site Inspection Planning and Site Inspection E-2M
. Review of Site Inspection Planning Prepared by others than MPQA F-1M Audit F-2M Nonconfo'mance Reporting, Corrective Action and r
Statusing F-3M Resolution of Significant Quality Problems F-11M Documentation Control F-12M Quality Records M-5 QA Review of Bechtel Field-originated Procurement
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Documents M-10 MPQAD Review of Subcontractor Procedures and Instructions for Underpinning Related Activities M-11 MPQAD Review of Bechtel Design Specifications, Drawings and Procedures for Underpinning and Related Remedial Activities.
ENGINEERING DEPARTMENT PROCEDURES EDP - 4.37 Design Calculations EDP - 4.46 Project Drawings EDP - 4.47 Drawing Change Notice EDP - 4.49 Project Specifications EDP - 4.58 Specifying and Reviewing Supplier Engineering and Quality Verification Documentation EDP - 4.62 FCR/TCN EDP - 4.65 Design Deficiency miO382-4025b-66-27
7 Mygg-1 REVISION 3 List of Applicable Procedures July 26, 1982 Page 19
.(i DP - 5.16 Supplier Document Control EP - 5.24 Document Distribution Control Center t
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MPQP-1 REVISION 3
-I.ist of Applicable Procedures July 26, 1982 Page 20 C
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FIELD PROCEDURES
.FPG-8.000 FMRs FFD-2.000 Field Change Request / Field Change Notice FPG-4.000 Storage Maintenance / Inspection of Equipment and Materials FPG-5.000 Maintenance / Inspection of Material and Equipment Released for Construction FID-1.100 Vendor Document Review FPD-1.000 Field Documentation of Correspondence Control PROJECT SPECIAL PROVISIONS PSP G-3.2 Control of Nonconforming Items PSP G-5.1 Material Receiving and Storage Control O
PSP G-6.1 Inspection elanninS
-PSP G-7.1 Document, Records and Correspondence Control PSP G-8.1 Qualification, Evaluation, Examination Training and Certification of Construction Quality Control Personnel ENGINEERING DEPARTMUT PROJECT INSTRUCTIONS EDPI - 2.14.8 Resident Geotechnical Engineer for Midland Remedial Underpinning Operation.
EDPI - 4.1.1 Preparation of Design Requirements Verification Checklist.
EDPI - 4.25.2 Interface Control Design Documents for Remedial Soils Underpinning Operation.
EDPI - 4.47.1 Interim Drawing Change Notice for the Midland Project 7220 EDPI - 4.49.1 Specification Change Notification i
miO382-4025b-66-27 l
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REVISION 3 List of Applicable Procedures July 26, 1982 Page 21 PROJECT ENGINEERING PROCEDURES PEP-2.14.T Resident Structural Engineer for Midland Remedial Underpinning Operation O
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July 26, 1982
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7 ATTACR4E:;7 2 i
QUALITY PLAN FOR.
REMEDIAL SOII.S ACTIVITIIT and SOII.S RELATED WORK IN Q AREAS ^
r-O Effective Date July 26, 1982 4
Approved M.
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f~f!~ ~_F#" # 'j Approved 8echtel Assistant Project Manager Approved O & th tid)'and Projectj office g%
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MPQP-2 REVISION 0 July 26, 1982 Page 3
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QUALITY PIM TOR RI..DIAI, SOILS ACTIVITIES AND SOII,5 REI.ATED WORK IN 0-Mm T
6.
BWST foundation repairs and tank releveling.
7.
Underground service water and BWST piping rebodding or replacement.
8.
Any placing, compacting, excavating, or drilling soil asterials under or around safety-related structures and systems, as defined by Bechtel drawing C-43 (Q).
9Idi_Mie This Quality Plan is applicable for all aspects of the above defined work and as such the activities and asterials associated with this work is deemed to be "Q-listed."
It is recognized that this "Q-listing" covers activities, itees AV and structures beyond the requirements provided by the FSAR. This extension to provide Quality Assurance Program coverage over and above strictly safety related itses will provide an additional assurance that no activity will have an adverse effect on safety related structures.
U @ lM MLVr3 1.
The activities included in the scope will be done to approved design documents and procedures; where existing procedures developed under the requirements of the topical reports do not provide specific coverage, additional procedures will be developed.
Design documents will be reviewed by MPQAD to assure that quality planning is in place to support the verification of requirements.
Procedures will be reviewed by MPQAD to assure that appropriate quality requirements are included.
Specifica-
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miO682 2246a102 ' '
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MPQP-2 REVISION 0 July 26,1982 Page 4
.R QUALITY PLAN FOR REMEDIAL SOILS ACTIVITIES AND SOILS RELATED WORK IN Q-AREAS assure that appropriate quality requirements are included.
Specifica-tions,procurementdocuments,drawingsand-hroceduresshallbespecificas to the design attributes and activities which require quality verifica-tion. The need for verification shall be dictated by the following principal:
The Quality Assuraate Program shall provide control over activities affecting the quality of the identified structures, systems and components to an ' extent consistent with (a) their importance to~
safety; (b) their possible detrimental interaction or effect on safety related structures and items; or (c) assuring < obtainment of the
()
overall Project objectives.
2.
MPQAD will be involved in the review of work activities to 1) determine the extent of QC" inspections and QA overinspection, 2) assure the adequacy or detail of implementing procedures / instructions, and 3) to determine the
,i extent of qcality records.
The MPQAD reviews will be documented in accordance with MPQAD Department procedures.
s 3.
An excavation procedurt ; hall be in place to control excavation, drilling
~
and pile driving in Q-listed soils as defined on Bechtel drawing C-45 (Q).
4.
A specific Quality Plan will be developed for providing Quality Program coverage of underpinning subcontractors who do not have their own Nuclear Quality Assurance Programs.
(Reference MPQP-1) miO682-2246a102 m
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IfPQP-2 REVISION 0 July 26, 1982 Page 5 A
QUALITY PLAN FOR REMEDIAL SOILS ACTIVITIES AND SOILS RELATED WORK IN Q-AREAS 5.
Any activity or structure or item or procurement in support of the remedial soils work which will be excluded from Quality Assurance Program coverage will be done on an exception basis.
Concurrence of NRC Region III is required prior to conducting any work activity in the excluded are s.
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July 26, 1982
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Page 2 A
QUALITY PLAN FOR REMEDIAL SOILS ACTIVITIES AND SOILS'RELATED WORK IN Q-AREAS GENERAL All activities perfoceed by Consumers Power Company or Bechtel Power Corporation and their subcontractors for the remedial soils work and work within the area coverd by C-45Q is covered by the existing Consumers Power Company and Bechtel Power Corporation Topical Reports CPC-1-A and BQ-TOP-1, Revision IA, respectively. This Quality Plan provides a more detailed written description of the accomplishment of activities specific to such work.
SCOPE This Quality Assurance Plan is applicable to those activities associated with O
the fo11 win.:
1.
Underpinning of service w'ater pump structure.
(Reference MPQP-1) 2.
Removal, replacement of fill, and underpinning beneath the feedwater isolation valve pit areas, auxiliary building electrical penetration tress, control tower, and beneath the turbine building.
(Reference MPQP-1) 3.
Installation of monitoring system and the monitoring of structural response to underpinning activities.
4.
Dewatering systems.
The installation, operation, and monitoring of both permanent and temporary dewatering systems.
5.
Freeze wall.
miO682-2246a102
ATTACHMENT-3
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SUMMARY
OF CP CO - NRC MEETING W R BIRD AND J GILRAY ON JULY 6, 1982
-Mr Bird met.with Mr Gilray at the Bethesda Office on July 6,1982, to present draft copies of a revised MPQP-1 and of a new MPQP-2 for coordination with Mr' Gilray..Mr Gilray and Dr Landsman had previously been provided copies of these draft-documents via mail. A detailed discussion was held on these documents,'and specifically for MPQP-2,~ a comparison of the wordings _and understandings of the ASLB Memorandum and Order of April 30 was conducted.
'Several-wording changes and recommendations to assure clarity were made by Mr Gilray, which are incorporated-in the document.
From the NRR Offices, a' phone call was made by Mr Bird to Mr Schaub to assure i-the acceptability of the revisions. In addition, another phone call was made to Dr Landsman to go through the document to see if he had any comments of his own, and to inform him of the changes agreed to by Mr Bird 'and Mr Gilray. The end result was that the documents, as marked up, were agreed to.
Note: Subsequent to the July 6 meeting.and phone calls, some additional i ~
comments.were generated on MPQP-1 and MPQP-2. These additional comments were coordinated by phone on July 16 and July 19 with Dr Landsman and Mr Gilray, 4
respectively and their concurrence on the changes was obtained. The actual N
signoff'and release of the-Quality Plans occurred on July 26, 1982.
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