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k w.. i. 2 James W Cook
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Vice Prrsident - Projects, Engineering and Conssmesion General Offices
- 1945 West Pernell Road, Jashoon, MI 49201 e (617) 788-0453 April 5, 1982 Mr J G Keppler Regional Administrator US Nuclear Regulatory Commission
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Region III 799 Roosevelt Road Glen Ellyn, IL-60137 MIDLAND PROJECT.- DOCKETS 50-329 AND 50-330 QUALITY ASSURANCE FOR REMEDIAL FOUNDATION WCRK FILE 0.h.9 20.6 SERIAL 16161 Reference 1: Letter from Mr D Hood, dated March 12, 1982 on the subject:
" Summary of March 10, 1982 Meeting Concerning Quality Assurance to be Applied to Remedial Foundation Work" On March 30, representatives from Consumers Power Company (Messrs J W Cook, J A Moeney, B U Marguglio, en al) met with representatives from the NEC (Messrs C E Norelius, W Little, E G Adensam, D S Hood, et al) in the Region III office in Glen Ellyn, Illinois to discuss the Quality Assurance Program for the Midland Remedial Foundation Work. The purpose of this letter ic to document the conclusions and cccmitments that were made at that meeting and subsequently discussed during several telephone conversations on April 2,1982.
4 The major conclusion reached at the meeting was the Consumers Power Company commitment to place essentially all of the to-go underpinning work under the coverage of the Quality Plan For Underpinning Activities, MFQP-1, which had previously been discussed with the staff, most recently at the March 10, 1952 meeting in Bethesda as summarized in the correspondence cited rs Reference 1.
This expansion of the QA program coverage for the underpinning work is effec-tive immediately, but recognizes specific exceptions to cover previously completed non-Q-listed work and certain future work as identified in Attach-ment 1 to this letter. Expansion of QA program coverage is in recognition not only of the importance of this work to public health and safety b'tt also to the overall success of the Midland Project. As a result, the program is being applied to both safety-related and nonsafety-related items and activ-ities without any further attempt to reselve prior discussions as to the exact definition and boundaries of safety-related as applied to each !ndi-vidual aspect of the underpinning work.
Certain other concepts related to the extended application of the QA program to the underpinning work were discussed at the prior meeting on March 10 (Reference 1) and reaffirmed in the discussion at our meeting on March 30.
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2 Both parties agreed that the Quality Assurance Program for Remedial Foundation Work vill be applied to the multitude of underpinning items and activities to the extent commensurate with the importance of the individual items. This will be implemented by identifying the specific quality requirements that apply to each of the items and activities now covered by the program so that all pa'rties whether carrying out or inspecting the work will have a clear understanding of what the actual quality requirements are for each item and activity.
As the underpinning work progresses, any new exceptions to the coverage under
.the QA program which are considered appropriate vill be communicated in writ-ing to M'r C E Norelius of the NRC Region III such that it is rece'.ved at least five working days prior.to the scheduled start of the affected work.
It was agreed that this communication mechanism vill provide NRC with sufficient time to review any such requests and respond to Mr J A Mooney of Consu=ers Power Company prior to the scheduled start of the affected work.
With regard to the exception list, subsequent to the March 30 meeting, discus-sions have been held with the NRC Region III staff on April 2 during which the NRC raised questions about the Q-list status of two items:
(1) the rock bolts and rock and earth anchors, and (2) the connecting piping for the permanent devatering system. In response to the first item, program coverage vill be extended to all rock bolts and rock and earth anchors to be installed after April 2,1982 which includes all per=anent installations. With regard to the second item, the exception list as provided during the March 30 meeting, in-cluded the permanent devatering system. However, this item has been deleted from the attached exception list.because it is not a part of the underpinning work.
It should also be noted that the non-Q classification of the permanent devatering system, except for the installation of wells and the monitoring of fines, had been specifically resolved previously with the NRR staff.
In order to facilitate communications between Consumers Power Company and NRC R' gion III personnel during the course of the underpinning work, a number of e
agreements were reached as to communication channels. Dr R B Landeman has been designated as the Region III lead inspector for underpinning work with Mr R J Cook to assist in his capacity as resident inspector at the site.
Consumers Power Company designated Messrs J R Schaub and D E Horn as the prime contacts for Dr Landsman and Mr Cook to obtain whatever specific de-tailed information they required for this work. In addition, we agreed to provide Region III, through normal distribution, weekly or biveekly reports (frequency to be determined) summarising the results of the just completed vork and describing the schedule of work for the immediate forthcoming period.
All of the above information is in additica to the existing transmittal of nonconformance reports and other documents to Region III.
We believe that the results of the March 30 meeting as su=marised above ad-i dresses all outstanding items in the staff's review of the Quality Assurance Program for the Remedial Foundation Work. We would appreciate a written confirmation of this conclusion.
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We also discussed, as part of our March 30 meetirig, Consumers Power Company's request that the NRC's lead inspector for,the'underpinn$ng work spend as much time on the site as practicable in order:to be thorouchly conversant with all current and short-term planned activities'. KWe believe this is essential in order that we may be responsive to whatever. additional information and discussions he wishes to pursue and to minimize,the possibility of any misunderstandings. In order to facilitate thelNRC's inspection planning, ve vill provide shortly and continue tol provide updated overall underpinning schedule infor=ation and our specific recc=mendations of which aspects of this work the NRC should consider including. in their inspection plan.
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.Y JWC/BWM/kd: : Exceptions to the Project Quality Assurance Program Coverage for Underpinning CC: Atomic Safety & Licensing Appeal Board Director - Cffice of Inspection & Enforcement Att: Mr Richard C DcYoung, US NRC Director - Office of Manage =ent Infor=ation & Program Control, US NRC CBechhoefer, ASIB JDKane, US NRC INyherry,Esq W0tto, US Army Corps of Engineers A? Cook, Midland Resident In: p WHMarshall FPCovan, ASLB SJPoulos RSDecker, ASLB FRinaldi, US NRC HRDenton, US NRC HSingh, US Ar=y Corps of Engineers JHarbour, ASLB MSinclair DSHood, US NRC BStamiris CENorelius, US NRC WLittle, US NRC 6
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- t ATTACIDET:T 1 Exceptions to the Project Quality Assurance Program Coverage for Underpinning:
1.
Freeze vall, other than for the protection of Cate6ory I utilities which are covered; 2.
Auxiliary building access shaft activities above elevation 609 and soldier P,iles ;.
3 The procurement of soldier pile material; tools and equipment (such as torque vrenches, jacks, gauges and threading machines - but their cali-brations are covered); steel and wood logging; backpacking material; rock bolts and rock and earth anchors already installed for temporary installa-tions; cnd glue.
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May 13,1983 Note to: Ross Landsman Ron Cook Ron Gardner Darl Hood
SUBJECT:
CPC'S TESTIMONY ON THE CABLE PULLING INCIDENT I am enclosing CPC's tstimony on the cable pulling incident.
Please look it over and provide me with your comments.
I do not know at this point if we or CPC will go first on this issue. Listed below are questions which I think should be addressed.
(1) Is there any basis.to CPC's assertion that at the March 10 meeting, they did not commit that all to-go underpinning work would be Q-listed unless specifically exempted? (CPC testimcny, p. 11)
(2) Do the Staff's meeting minutes corroborate CPC's belief that there was.
no commitment made at the meeting?
(CPC testimony, p. 11)
(3)
Is there any basis to CPC's belief that instrumentation was not Phase 2 and therefore not required to be Q?
(CPC testimony, p. 12)
(4) Did Region III think that all wiring for the underpinning had been completed?
(CPC testimony, p.13) o'
EG 2-x (5). Why do we believe instrumentation was not "well underway?" (CPC l
- testimony, p. 13) fww % %
Michael N. Wilcove Attorney, OELD h
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N say that proper trols could be ignored o at NRC approval was unnecessary.
Because.-the fireline relocation N
was essentially an ancill'ary#a#
s t sk, I do not believe the s
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s Conpany had disc;ussi,ons with NRR'concerning it.
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Mr. Mooney, could you please describe your views of the t
so-called " cable-pulling incident" of March,1982.
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Because I was. personally involved in these discussions, I wish to explain ny view of the, " cable-pulling" incident -
referenced in the Attachments to Mr. Keepler's testinony.
This incident has been the subject of a for=al NRC~
' investigation as to wherher material false si: ate =ents were nade.
I believe that the incident arose because of ineffective ce==unication between the Conpany and the NRC Staff.
The Cenpany proposed a quality assurance plan for the auxiliary building underpinning work to the NRC in a lette'r dated January 7,1982, and at a meeting with Region III on January 12, 1982.
Over the next two months, discussions between the Conpany and the staff continued regarding which underpinning activities were to be Q-listed.
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on March 10, 1982, there was a neeting betwe Company and NRR and Region III.
'At this meeting, l
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A Company sought to define those underpinning activities which were censidered safety-related and subject to the cuality assurance program and therefore needed to be Q-listed.
However, the NRC Staff did not acce'~t-the classifications p
proposed by the Company and took the p'esition that all soils -
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Activities beginning with Phase 2 work should be Q-listed 2
. except for specific items for which it could be shown, in a
' fashion acceptable ~ to the NRC, that there was a specific basis. to justify non-Q treatment.
One area of,=isunderstanding between the NRC Staff and the Company was the question of whether the compaby agreed to the Staff's position at the March 10 meeting.
Apparently some NRC Staff mechers believed that the Co=pany had co=-
1 citt.ed at that meeting that all to-go unde..ph ing work would be Q-listed unless specifically excepted.
I and other Co:pany employees believe no such co==it=ent war made.. I viewed this meeting as a chance to discuss the issue.with the NRC Staff and not as one at which a coc=itment would be made.
I can recall ihdicating to the NRC Staff that we understood the Staff's request for such a commitment and that we would get back to them on it.."
The NRC Staff's meeting minutes'do not indicate any such co==itment, corroborati$1g my recollection that no consitment was made.
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A second area of misiinderstanding arose because of the failure to define instrumentItion installation as either a part of Phase 1 or Phase:2! o'f the underpinning work.
The NRC Staff's position at the March l'O' meeting was that they
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wanted all underpinning. activities beginning with Pht.se 2 to -
'he Q-listed unless sp'e'cific5.ily excepted.
Since instru-mentation had to be installed and functioning before the start of Phase 2 w6rk; the' Company believed that the NRC Staff did not require 'that the installation of underpinning instrumentation be cov'ered by the quality assurance program.
The co=pany had stated that calibration of instruments and 4
checkout of the system would be Q-listed.
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A third area of confusion related to the co:pletion status of underpinning instrumentation on March 10 and 12, 1982.
At the March 10 meeting, Region III 4*pectors formed 4
the i=pression that underp Mng 4"trumentation had b.een co=pleted. "The NRC investigation conducted to review this matter determined that statements made by the Company at 'the Ma'y 10 meeting were understood by several NRC personnel *a i
mean " work had begun without giving a report on the s*gtus of completion."
l On March 12, 1982, I and others from the co=pany initiated a telephone call to Region III Staff.
During this f
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call, the Company identified,a l'ist of items which we
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believed could justifiably be treated non-Q.
The Region III inspectors were provided a matrix which showed that instru-mentation irJstallation was one of the items that was to be non-Q.
With no intent to mislead' the NRC Staff, but meaning only to inform the Region III inspe'etors that underpinning -
instrumentation worX had begun, Al'an Boos of Bechtel stated, "our instrumentation is essentially well underway., Wiring has been pulled'-- raceway has been installed."
The Region III inspectors apparently understood these statements to mean that all wiring for the underpinning inst:n:. mentation had been ce=pleted, an unintended inference.
The misunderstandings and poor ce=n:iications of
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March 10 and 12, 1982 came to light during the March 17-19, 1982 Region III safety inspection.
The NRC inspectors dis-covered that instru=entiation installation was in progress, not completed.
They then inferned tne Conpany that,this activity was to 'be Q.
In response, the Co=pany suspended all underpinning instrumentation installation and reclassi-
' fied the activities as Q.
Subsequent to ti ese events, Mr. Cook had a number of f
h discussions with the NRC Staff Management leading up to a March 30,1982 meeting with Region III and NRR, at which time the company committed to Q-listing essentially all of
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i N the to-go underpinning work.
As a result of the March 30 l
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commitment by Company Management,.instru=entation installed and cables pulled without being covered 'by quality assurance requirements were upgraded to ec= ply with 'all quality assurance requirements.
Since Marcli 30, 1982, all underpinning instrumentatien has been installed pnrsuant' to.
quality program requirements.
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