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March 12, 1982 2:08 p.m.
Conference telephone call between Bechtel/ Consumers and NRC.
Call initiated by Don Horn /Al Boos to Dr. Ross Landsman, NRC, Region 3.
in attendance:
1 BECHTEL/CPCo NRC-Region III -Chicago Ross Landsman Al Boos J.
Fisher Mr.,Boyd R.
Cook (NRC - Site)
D.
Horn J. Schaub Jim Moore Ben Marguglio J.
Simpson Bob Sevo Dave Ronk
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Gary Rogers Ray Oberleitner (Mergentime)
Ken Vanderjack Boos:
Hello, Ross, this is Al Boos, with Don Horn.
Who is there with you?
Ross:
Landsman and Boyd.
Boos:
Who else?
BoYD
-Feer:
That is it.
Were you able to get through to the NRR or not?
raise anybody - will handle withoutilfm.
/
Couldn't Boos:
(Brief introductory remark) With respect to remedial soils work, it was the staff?s position that all items I
were Q unless applicant could demonstrate that certain activities should be non-Q data.
When I came back to Michigan, we have a weekly coordination meeting and one of the first things we did this morning was to draw up a list l
of those items which either have been completed or in l
process or are proposed which we feel can, in fact, be l'
treated as non-O items.
Since we are working under the 8408170126 840718 i
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. business as usual concept of.you making audits, we felt t
it was prudent to review with you this list prior to c
If making inspection so that we would have a very clear
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dialogue in terms of_those items remaining Q, primarify because in some respects we elect to bid it may not be physically possible to replace that item - like removing L
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Q a f ~ drift.
de; " 08 or Since we don't want to be cited, we are going to attempt to identify items we feel are non-Q.
We feel.it is essentially a complete list.
May be a need from time to time to offer other items.
We will y.
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I wi11 ask l
Don to take us through this.
Boos:
Access shafts below 609 - drifts, the piers and instrumentation.
(Ron Cook has a copy of it.
If necessary for interpretation, he can help me).
1.
Access shafts below 609 - Soldier Pile's.
It may help you if you have a clean sheet of paper to
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put down four column headings.
I will try and summarize.
With respect to soldier piles, we have procured those piles and have installed'them as non-Q as you are aware.
With respect to access shafts below 609.
In this case, in general, other than just ace'ess shafts at 609, we feel that the purchase of tools and equipment like torque wrenches, jacks, gauges and threading machines should be f
non-Q.
Our rationale is that there is either provision for calibration or an end inspection of the fabrication, like the reinforcing steel that is threaded by the thread'ing 2
machine.
Again, tools and equipment is intended.to be U
- a. generic comment.
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. uestion:
Is this c'onstruction equipment?
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Answer:
Yes, tools and equipment.
g, s (This is being transcribed for purposes of preparing a telephone summary.
QA required it.)
3.
Access shafts below 609.
Purchaseof steel and wood t;ggius and I believe we talked about that the other day in Bethesda.
J.
Fisher:
To differentiate - steel shape = whalers in wood i
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'Ross:
Whenwetalked$ntheWashington, we were' talking about k
the no certs.
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A1:
That is what makes it a O purchase.
We would not be buying this with mill certs because this steel doesn't stay in - it is temporary and non permanent.
Standard manufactured item'.
Ross:
We are just talking about the mill cert?
A1:
We are not talking about buying it O.
Cook:
The tons of concrete that you pour around here - did you have mill certs on the wood forms you used before?
Why
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on this particular job?
Isn't wood 443,-sg steel shapes?
A1:
That is right - We didn't think it needs to be bought O.
p Cook:
You didn't talk about this before.
A1:
This is a whole new thing.
Cook:
NRC
- what is the meaning of all this?
A1:
We were directed that everything was to be Q unless the applicant could demonstrate.that item could be classified l
as non-Q - we feel that it is imperative for us to check
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off with you even though you may say need not be purchased O.
We want to leave a trail that is crystal clear.
Cook:
The point is that historically we never have approved anything.
Our function is that you are obligat d e
to assure the world that you have done all thi and have invoked QA.
ngs appropriate 11:
We cannot either agree or disagree I am not asking for you policy in advance.
- I am making a statement of our We will know in an audit what our position is.
If he is not in agreement with that position it is in our mutual interests fo r us to know now from a cost, schedule quality and personn l j
e safety standpoint.
Cook:
Go ahead and revert back to the fact of concrete.
that you poured tons Fisher:
We are doing this because of what y ou told us the other day.
Al:
Last item under access shafts below 609 rock bolts.
is purchase of Ross:
Which rock bolts?
A1:
Rock bolts Turbine Building and butt ffgf
- Again, bh
- ress access shaft, purchase A installation would be handl d In e
as Q.
all of these cases, I have talked about you will note I have talked about only procurement of material with exception of soldier piles.
Installation would be Q.
Tools and equipment, etc.
Ross:
Continue.
A1:
New subject drifts.
We are planning to procure material for the steel sheets which are b the box-shaped frames that asically the accept in the drift Fabrication of those steel sheets w as non-Q.
ould be Q and installation.
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A1:
The next item - the procurement o'f the wood begging and wood wedges for the drifts would also be non-0.
Procurement.
Procurement of the back packing material for the drifts would be non-Q.
And as a 4th item, the procurement of the rock and earth anchors would be non-Q.
Those are the sets of items under the classification of drifts.
Under piers Don has asked me to again reiterate that fabrication and installation of the drif ts classification items would be Q.
Under classification of piers, Ross, you m be aware that there is Ethifoam to be put behind metal 1-33u.3a-as back packing.
May be gluing Ethifoam to steel We will propose to procure that glue as a non-Q commodity.
Verification that is in place would be a 0-listed activity.'
That is the only entry I have under piers.
Last item is instrumentation.
We are talking about the settlement monitoring instrumentation, pier monitoring instrumentation, etc.
Our position here is that the raceway, the wire and the brackets that would accept the instrumentation would be procured and installed as non-O.
The checkout of the system and the -Muz, of the reading would be Q.
Ross:
What would you say about the instrumentation in that area?
A1:
j Instrumentation has been purchased O.
The instrumen.tation system is in a data room - it has been procured and installed with environmental controls as non-Q.
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A1:
The last item which is essentially a repeat of that above under access shafts e auges backup gauges).
j Javebeenprocured'asnon-Qbutwouldbecalibrated under a Q program.
These are existing dial gauges.
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our instrumentation well under way.
Wiring has been pulled - raceway has been installed, etc.
Those are the only comments I have.
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Ross:
Okay.
Let us talk here a minute and we will get back with you in just a second.
B.
Marguglio:
Didn't those dotted lines mean all non Q?
A1:
Yes, across the board.
BM:
Did that come across in the conversation?
A1:
I will reiterate it.
It becomes Q at the checkout of the system.
Cook:
I am here.
Ross:
Feel free to make your own comment.
Boyd:
We would like to digest this list and get back with your designated person on Monday.
We'd like to sit down and look it over and get back with you, but not to say that we approve or disapprove.
If we have any problems or
= does not constitute approval - it means we don't have any problems with what is here.
l A1:
We recognize that you are not going to sign anything as co-approvers.
Boyd:
But we can look over and make judgments whether we have any problems and identify anything that does give us problems.
Who should we get back with on Monday?
A1:
Don Horn.
Boyd:
Okay.
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j Ron, do you have any problems with that?
-Boyd:
Cook:
I think that can be quite livable.
We might appear not to have any problems but later on we get into construction and problem is created.
.I don't want to have relinquished our.right to enforcement in that area.
Ross:
That is exactly why we don't go in approval process.
My judgment is there will be very that will happen that way but we want the door open.
Ross:
Okay.
A1:
Very good.
The rest of us in the ro'om will wait to hear from you.and your results on Monday.
I have a question.
Will it be both of you gentlemen BM:
4 calling Don Horn Monday?
- Boyd:
Ron Cook and Ross and myself will get together' and talk -
one of us will make the call.
We will get back with you on Monday with our findings.
4 A1:
To clarify one point, to make sure I didn't mislead,the people in Chicago - with respect to the raceway material
- the wire, the fabrication of brackets that 7
m-m r-instrumentation $and termination of wire that we are talking
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about that, with respect to procurement through installation.
Boyd:
Could you give Ron Cook a copy of that so he can fax it to us?
Cook:
I will try to fax it to you right away.
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Boyd:
I think that is important.
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A1:
Thank you very much.
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QUALITY ASSURANCE PROGRAM POLICY Page z
Revision 11
-'N Date 11/18/81
)
LIST OF DEFINITIONS 1
CMMBEgpeut l
Safety-Ralated - The term applied to:
Structures, systems, components, materials, services or Operational Safety Actions or Activities named on the Q-List as necessary to assure:
1.
The integrity of the reactor coolant pressure boundary.
2.
The capability to shut down the reactor and maintain it in a safe condition.
3.
The capability to prevent or mitigate the consequences of an accident which could result in potential off-site exposures to individuals in excess of exposures specified in 10 CTR 100.
The operation of the facility within Technical Specifications limits and Nuclear 4.
Regulatory Requirements.
~
l Secondary Standard - An item of measuring and test equipment (M&TE) used to cali-brate other M&TE. They are periodically calibrated using Reference Standards and reserved for use in the calibration of working plant or field M&TE.
Section - A subdivision of a department, usually made along lines of a technical specialty; eg, Nuclear Licensing, Health Physics, Nuclear Tual, etc.
j Services - Work performed by an organization or department having no deliverable hardware type end item other than the results of construction, modifications, repairs, inspections, audits, reviews, etc.
Source Inspection - Inspection of an item at a Supplier's facility during its manufacture, or at completion of manufacture, to verify implementation of the procure-ment requirements.
t Spara Part - An item available for replacement for an item in use.
Special Nuclear Material (SNM) -
1.
Plutonium, Uranium 233; uranium enriched in the Isotope 233 or in the Isotope 235; and any other material which the NRC, pursuant to the provisions of Section 51 of the Atomic Energy Act of 1954 as amended, determines to be special nuclear material, but does not include source material; or Any material artificially enriched by any of the foregoing, but does not in-2.
clude source material.
Special Process - Those metallurgical, chemical, or other processes where assurance of the process activity is dependent on the use of qualified procedures, personnel, or equipment; and where assurance of quality cannot be by direct inspection of the in-process activity or final product. These include, but are not limited to, welding heat-treating, NDE and environmental testing of the work process.
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regulations, guidelines, or other factors separate and distinct from the components of the system itself.
The system is 1
considered as a unit, with boundaries as defined by segulatory
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Guide 1.70 and must meet specific requirements.
The design bases describe all essential characteristics of the system with sufficient clarity so that an experienced engineer, using these design bases and material referenced in the design bases, can
. understand the functions of the system with respect to the rest of the plant.
Items implicit to contemporary design (e.g., use of the English system of weights and measures or the exercise cf good engineering practice) are not specified.
1.1.2.2.1 safety Design Bases safety design bases directly establish or increase nuclear safety.
safety design bases provide for or assure the following:
a.
The integrity of the reacter ccolant pressure boundary
^
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The capability to shut down the reactor and maintain it in a safe shutdown conditicn c.
The capability to prevent or mitigate the consequences of accidents that could result in potential off site exposures comparable to the guideline exposures of 10 CFR 100 d.
The accomplishment of specific structure, system, or component requirements which are important to safe y
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The control room operator action is considered as one of the fundamental means of achieving these criteria.
safety-related structures, systems, and components important to safety are the portions of systems which are indispensable to nuclear safety.
Items which are associated with safety-related l
equipment but which do not perform a nuclear safety function are not safety-related.
Redundancy requirements and system performance conditions are considered a feature of the equipment's capability to shut down the reactor safely or to prevent or mitigate accidents.
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j; 1.1.2.2.2 Power Generation Design Bases Power generation design bases are those design bases which are not related to nuclear plant safety.
They need not relate directly to the generation of power; however, they relate at least indirectly to power generaticn in the sense that all station require.ments which are not imposed for safety reasons support the major function of the station as a whole; i.e.,
the generation of electrical power and process steam.
An example of
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IRAR 12 E Docket Nos 50-329 and 50-330 CH,0L AFFLICANT: Consumers Power Company FACILITY: Midland Flant, Units 1 and 2 10, 1982 MEETIJG CONCERNING QUALITY SLHMART OF MARCR
SUBJECT:
ASSURANCE TO BE APPLIED TO REMEDIAL FOUNDATION WORK the NRC Staff set in Bethesda Maryland with Consumers Power On March 10. 1982.
Company and Sechtel Power Corporation to discuss the application of quality Specifically, applicability to work assurance to remedial foundation work.
related to underpinning of the electrical penetration areas of the Auxiliary Building and of the Service Water Pump Structure and to construction of the new A list of meeting Berated Water Storage Tank foundation ring was discussed. Inclosure 2 is a compilation of the attendees is attached as Enclosure 1.
materials handed out and discussed at this meeting.
SUMMARY
A draf t of the Quality Plan for Underpinning Activities was submitted f or NRC During the review by Consumers Power Company letter dated January 7,1982.the Staff had course of its review, items and activities to which the plan would not apply (i.e., "non-Q" The meeting was held to allow the Applicant and his activities).
Architect-Engineer to discuss in detail the applicability of this plan.
The Applicant informed the Staff that the Quality Plan has recently been fina-It was transmitted by Bechtel by CFCo (WRaird) letter dated 11aed as NPQP-1.
March 3. 1982 (see Enclosure 2).
The Staf f noted that the programmatic aspects of the quality plan submitted January 7 appeared to be in full compliance with Appendix 5 of 10CyR50 and are Issuance of formal acceptance le avaiting the discussion of the extent of the program's applicability and specifically the items which it will acceptable.
Due to the nature of this work, the Staff's initial consideration is that essentially all construction activities related to the remedial work should not cover.
f all under this progras.
CFCo and techtet sought to limit full program applicability to those items which they considered safety-related. This term is defined in the accepted CFCo Quality Assurance Topical Report and in section 1.1.2.2.1 of the FSt ' (see ).
From a technical design viewpoint, Bechtel proposed the following clarifications as the logical application of these definitions to the remedial work Only permanent supports / structures need be Q listed.
MAR 2 5M 1.
Temporary (i.e.. construction) supporte need not be Q.
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wast a plant Support of meeHI structures (e.g., turbine h=81ai=g) is laboreetly mem-q.
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Pz W for f r farism af a safety structure (e.g., Jacking) are Q d
For *= g le, jacking 4.
ghmm the E p t=risms pendmes' final impet lan s.
from a sampecary support la esmHl. met because it is not important but heemme it is met relied as for the safety of the structu h== lek and gefety of the pablic could potsatially be at risk.
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&===<e--ing pengren to estesmine the effect ce asfety-re S.
ammisering pressum will be 4 Sam maisey-related bs11 dings and supperts strieb cas affect safety-related Esmuwer, the swalmaties of the effect of such struc-6.
scracturw are ase 4 tasas as amisty structures is 4, fj installation of 51 sus the above paists, the eseclesias must be drase that
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tempstury sedery*==taqr where it will sitiantely became a part of t e 7,
Temporary
- endarylaming (i.e., ander the control tower) is Q.
maryrrt of the electrical psmetratisa areas, met to be a n
q C.
CFCs estad that the hay peist la the above items is that adverse ingpact on a bility.
ersussure from the camperary merk has a petsatial impoet es plant licensa but est as h ?eh and mefety,as esse sect which som1d set be defined as Q is acco CpCe therefore deutsatte esmeidering the estore and estest of this work. Items sud activities se designa proposed a ese essissocion of Ot".
Q items trusted by CpCs, sechtet, and their cemetractise contractors eretly as assert f ar reportability to the suc. A pertise af the Assiliary Q
ums diamammad (see Emslesere 1).
Thr.s are certais scrivistas refnema to the underpientes work which would fall 3
As esemple diseaseed at some length was excava-is asichre of thmes cassgeries.
Although final ties of same drift (emassi) under the turbine building (see-4).
5 suustsusties danslags, preparatise of emet osm14 involve a final
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classificatssa, are est complets, the Applicast agreed this work would probably The $caff meted that failure to properly install d:-
liary Suilding, fall inte seither satagery.
the maneciated bsectes ess14 here as famediese effect en the Assi TVApplicast ww that the assitering program for the Amm111ary Building, sedah se assesdod e etatee. -ta detect such se effect.
1,q Seeing the dama===lse, the Applicant supressed concers.that a Q. listing autons-h ties 139 sognered the layeeittas of ammersos difficult requirements which mig t The Staff diangreed, meting that 10CTR50 ih est sulate se the sont semessu.Appendis 9 provides that 44 shall be implamass implement is the impset es seietyg ser esemple, serile it Asse not setter what h
ound to gamese seit sense diggias as accese shaf t, the locastse, size, and dept ed the amof t are importast,
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Meeting Summary 3
Midland Plant Following a private caucus, the Staff responded to the applicant's proposals as follows:
The Staff 4
The Staff did not accept the concept of the QA Classification.
considers that all activities beginning with phase 2 work should be Q TTitelencept on very specific items whwich -an be shown on a specific p
Ban a to justify non-Q treatment. Nat concurrence in this justification i
aset be obtained prior to conducting any wurk efforts completely outside the quality plan.
The gegion will cor.tinue the level of involvement of the recent past.
svery drawing and specification does not require gegion III concurrence '
before use, although they must be completed and available prior to commen-In preparing and approving these documents.
cing the work they cover.
individual detailed activities which require or do not require specific QA controls shall be specified in accordance with the quality plan and consi-5 dering the flesibility inherent in 10CFR50 Appendiz g.
The Staff rejects the philosophy of reliance on the monitoring program as the sole Q protection for safety structures. The process controls which preclude the attainment of undesirable effects which the monitoring program
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would detect must be subjected to the full rigor of the MFQAD program.
With respect to the items of design philosophy enumerated above, the Staff disagrees with numbers 1. 2, 3 and 7.
The Staff disas-ees with the limita-tion of number 4 to final input leads. The Staf f agrees that the monitoring program of number 5 sust be Q but rejects the concept of this as the sole Q protection for safety-related structures. The staff disagrees with the aspects of member 6 which classify non safety-related butIdtngs and supports as non-Q but agrees the evaluation of effects must be Q as well as eelated construction and design work.
It was agreed at the conclusion of the meeting that the appiteant must submit a letter, prior to beginning phase 2 work, which provides the information agreed to in the March g.1932 telephone call with Mr. J. D. Kane of the Staf f (see ). The NRC will take specific action on this submittal prior to the e
start of phase 2 work.
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Darl 5. Hood. Project Manager Licensing Branch No. 6 Division of Licensing Enclosurest As Stated 1
Ces See Next page i
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f Jul AUG 2 0.1982 MEMORANDUM FOR: Jar.es A. Fitzgerald, Acting Director Office of Investigations FROM:
James G. Keppler, Regional Administrator, Region III
SUBJECT:
MIDLAND-REQUEST FOR INVESTICATION During an inspection of rer.edial soils activities at the Midland site, Dr. Ross Landssan of the Region III Midland Section identified two instances of apparent violation of the April 30, 1982 ASLE Order.
Dr.
Landsman contends that the licensee, in direct violation of the Board Order, excavated below the deep "Q" duct bank and initiated fireline relocation activities in "Q" soils without prior NRC authorisation.
A copy of the memo addressing his findings is attached.
A management meeting was held on August >11, 1982 at the Midland Site.
Ihe licensee's position, as stated during this secting, was that the ASLB Order was not violated. Ihe licennee contends that their actions, in both instances, were based on prior understandings of the NRC require-ments pertaining to the ASLB Order and prior approvals granted by the NRR staff.
Because of our concern with comunications nisunderstandings at the Midland project and the seriousness of this matter, Region III requests OI investigste this matter as expeditiously as possible. NRC personnel 4
familiar with this matter include Dr. Ross Landscan, Ron Cardner of Region III and D. Hood, J. Kane of NRR. Region III will, of course, provide technical assistance as required.
We appreciate your cooperation in this matter and will be glad to dis-cuss sny questions you any have.
Original signed by A. Scrt Davis James G. Keppler l
Regional Administrator
Attachment:
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2-AUG 2 0 582 J. A. Fitzgerald cc w/ encl:
DMB/ Document Control Desk (RIDS) l Resident Inspector, RIII The Honorable Charles Rechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB Michael Miller Ronald Callen, Michigan Public Service Commission Myron M. Cherry Barbara Stamiris Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
R. F. Warnick W. D. Shafer R. N. Ga-dner R. B. Landsman e
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%,..... /a Aug 2 41982 MEMORANDUM FOR:
W. D. Shafer, Chief, Midisad Section FROM:
R. B. Landsman, Soil Specialist-SUBJRCT:
VIOLATION OF ASLB ORDER OF APRIL 30, 1982 l
e When Darl Hood and Joe Kane were in Midland for an ACRS hearing, I asked for a meeting to be held on site between NRR, Bechtel, the licensee and myself.. The aseting took place on a Thursday afternoon in the Remedial
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Soils Trailer (May 20, 1982). The purpose of the meeting.was to discuss numerous concerns that I had about ongoing work and future work.
One of the concerns discussed was a monitoring pit for what has come to be known as the deep "Q" duct bank. During that meeting both NRR and I expressed our concerns that what the licensee was planning was not approved, that is: to excavate below the duct bank. NRR only approved an'excava-tion down to a duct bank approximately 22 feet deep. This is documented in an NRC Tedesco to Cook letter dated February 12, 1982, which references a CPCo Mooney to Denton letter dated January 6, 1982.
Since the licensee usually does not know what is in the ground or where it is, as usual the 22 foot duck bank was found at approximately 35 feet.
It also was not in the right location as evidenced by the monitoring pit sheet piling hitting one side of the duct. In addition, while drilling a nearby dewatering well, they inadvertently drilled into the duct bank, emptying the well drilling fluid into the turbine building through the duct.
I had no problem with the licensee taking the excavation pit down to 35 feet instead of the approved 22 feet, since the methodology of the approved excavation remained the same. NRR and I did have a problem with the licensee wanting to excavate below the duct bank to impervious clay in order to seal off the water flow, without first informing NRR of their plans and obtaining their prior approval.
All of the above was discussed during the meeting. The licensee was informed that they could not excavate below the deep "Q" duct bank. The licensee indicated that they would submit something formal to NRR for approval.
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The following day, I warned them during the normal exit meeting and again during the summary at the end of that meeting that they did not have prior NRR approval. I asked if everyone understood what I was saying and they acknowledged.
The following week, during my inspection to allow the licensee to activate the freeze-wall, I warned them again that they could not dig below the deep "Q" duct bank because they did not have prior NRR approval.
4 Subsequently, after the activation of the freeze-wall, the licensee apparently decided that they had to seal off the water flow beneath the duct bank and proceeded to dig below the duct bank without NRR approval.
I'm not sure when 5'
excavation began, but I was on site July 28 when I discovered the excavation in progress. The licensee, when informed of my concern, issued a Stop Work Order on July 29, 1982. I wondered why they were so agreeable until I found out that they already had the excavation down to where they wanted it (the clay).
P I informed the licensee during my exit on July 30, 1982 that they were in direct violation of the Board Order and their Construction Permit. To make j,
matters worse, the licensee during the exit, said that they* discussed this with Messrs. Heod and Kane in Ann Arbor earlier that morning and had received
" Approval concerning the technical adequacy" for what they were doing. I informed the licensee that they missed the point (basis of concern). My concern dealt not with the technical adequacy of what they were doing, but 4
rather with their ASLB order requirement to notify and receive prior staff approval before proceeding below the duct bank. Subsequently, Mr. Kane j.
indicated to me that they never even talked to him about this. Mr. Hood indicated that they talked to him about something concerning the deep "Q" duct bank, but he in no way had given approval.
a Subsequent to my leaving the site, the licensee began what I consider to be another unapproved excavation in "Q" soils. This excavation, which involves the relocation of a fire line was discovered on August 4, 1982, during my next inspection. This excavation is along side the service water pump structure.
I have not had time to look into this matter to better deline the details, but as pointed out to you and Darl Hood, they have under-mined a duct bank, an unidentified pipe thrust block, a. appear to be L
along side a safety-related duct bank.
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j Ross Landsman, Soils Specialist ec:
R. F. Warnick I
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