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oLEu aLovu,st u Nois sotor May 12, 1981 MEMORANDUM FOR:
C. C. Williams, Chief. Plant Syste.ms Section FROM:
R. B. Landsman, Reactor Inspector
SUBJECT:
MEETING WITH CONSU)ERS POWER COMPANY ON MAY 2-4, 1981, REGARDING MIDLAND UNITS 1 AND 2 SOIL ISSUES A meeting was held on May 2-4, 1981, with Consumers Power Company, Bechtel and their consultants in Headquarters regarding the Midland plant fill settlement issue. The main purpose was to discuss:
(1) remedial actions and' update of soils deficiencies; and (2) review status of amendment 85 of application. In particular the following were discussed:
1.
Dewatering.
2.
Underground Piping.
3.
Additional Soil Borings.
4.
Borated Water Storage Tank.
5.
Amendment 85.
6.
Remedial Fixes.
New points brought out during the meeting were:
1.
The borated water tank fix will be to construct a new ring wall foundation outside of the existing and to tie them together with dowels.
2.
The auxiliary building fix was changed from caissons to a concrete pier foundation.
([s.k'.)M. A 7
R. B. Landsman Reactor Inspector cc:
L. Spessard i
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NRC FEETING ON SOILS If SUES MAY 5, 6, 7,198:
1.
Devatering (5/5/81)
(a) Field Activities since submittal of Amendment 85 (b) Devatering Responses to 50.5h(f)
(c) Items Regarding Installation of 20 IU Interceptor Wells 2.
Underground Piping (5/5/81)
(a) Review of Calculations to Date (b) Plans for Reprofiling (c) Acceptance Criteria (d) Long Term Settlement 3
Additional Borings (5/5/81)
(a) Location (b) Types of Sampling (c) Types of Testing (d) Interpretation of Test Results h.
BWST (5/6/81)
(a) Description and Cause of Problem (b) Current Status (c) Proposed Remedial Work 5
Amendment 85 (Soils) (5/6/81) 1 6.
Amendment 85 (Structural) (5/7/81) 7 Remedial Fixes (5/7/81)
(a) Service Water Structure (b) Auxiliary Building GSK 5/1/81 p -,
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5,. Document Name VIOLATION OF THE BOARD Requestor's ID: SHERYL Author's WasseV~T ~'" " ~% s Massell/se6/05/24 t Document Commentst continuation of Midland findings g ) s- ) n
- 4 III. ALLEGED VIOLATION OF ASLB ORDER OF APRIL 30, 1982 A.
. Introduction On December 6, 1979, the Director of the Office of Inspection and Enforcement and the Director of the Office of Nuclear Reactor Regula-tion issued jointly an Order Modifying Construction permits for the Mid-land plaat. (45 Fed. Reg. 35950 (May 28, 1980)). This order was based in part on a breakdown in quality assurance related to soil construction activities under and around safety-related structures and systems at the Midland site. (Id.; Joint Exhibit 1, Tr. 1175). The licensee petitioned for a hearing on that order, and the proceeding on that order was eventually consolidated with the proceeding on the licensee's application for operating licenses for the Midland plant. During the course of the consolidated proceeding, we issued a memorandum and order that authorized the Director of the Office of Nucle-ar Reactor Regulation to amend the Midland construction permits to incor-porate certain conditions on the conduct of remedial soils work at the Midland site. (See Consumers Power Co. (Midland Plant, Units 1 and 2), LBP-82-35, 15 NRC 1060, 1072-73 (April 30, 1982)). In accordance with the Board's memorandum and order, the con-struction permits were amended on May 26, 1982 to include the conditions imposed by our order. (47 Fed. Reg. 23999 (June 2, 1982)). Among the restrictions imposed by our order of April 30, 1982 was a condition that the licensee shall obtain explicit prior approval from the NRC staff before proceeding with the following soils-related activities, with the exception of those already approved by the NRC staff l and those the NRC staff agrees are not critical, (a) any placing, l 4 l
compacting, excavating, or drilling soil materials around safety-related structures and systems, and (b) construction work in soil materials under or around safety-related structures and systems such as field installa-tion, or rebedding, of conduits and piping. (LBP-82-35, supra, 15 NRC at 1072-73). On May 7, 1982, we issued an order which clarified some aspects ~ of our April 30, 1982 order. Consumers Power Co. (Midland Plant, Units 1 and 2), Memorandum and Order (Telephone Conference Call of May 5, 1982), slip op., (May 7, 1982). The May 7, 1982 order made clear that " verbal approval before proceeding with soils-related activities is acceptable for activities which are routine and/or relatively small in scope". (Id. at 5). That order also noted that such approvals should be documented by the NRC staff and that either the Office of Inspection (IE) or the Office of Nuclear Reactor Regulation (NRR) can give approvals as appropriate to the activity and practice of the respective office. (Id. at 6). In late July 1982 Dr. Ross B. Landsman, NRC Region III Soils Inspector, was at the Midland Nuclear Power Plant site to conduct an inspection of the remedial soils work. (Staff Ex. 26, Office of Investi-gations (01), Report of Investigation dated June 2, 1983 ("First 01 Re-port") at 2, 3). On July 28, 1982, he was at the Midland site and inspected the electrical deep "Q" duct bank, and found that the licensee had excavated approximately twelve feet beneath the duct bank. (Id. at 3; Landsman, Tr. 21,549-50). He alleged that the licensee had con-ducted this excavation without prior NRC (NRR) approval as required by the Board's April 30, 1982 order. (Staff Ex. 26, First 01 Report at 2 l and Attachment 2).
During Dr. Landsman's next inspection, he discovered on August 4, 1982 that the licensee had conducted another excavation in "Q" soils by relocating a fire line along side the service water pump struc-ture. (Id.; Landsman, Tr. 21,551,21,556-57). He alleged that this excavation was also conducted by the licensee without receiving the re-quired NRC approval. (Id.). The Regional Administrator, Region III, U.S. N.R.C. requested the Commission's Office of Investigations (01) to conduct an investiga-tion to determine the circumstances in which the licensee allegedly vio-lated our April 30, 1982 order by excavating below the deep "Q" duct bank and relocating the fire line. (Staff Ex. 26, First 01 Report at 2). On June 2, 1983, OI issued a report of its investigation into the alleged violations of the Board's April 30, 1982 order. (Staff Ex. 26, First OI Report). Subsequently, at the request of the Regional Administrator, Region III, OI reopened its investigation of the alleged violations of the April 30, 1982' Board order to conduct additional interviews in deter-mining the circumstances surrounding the alleged violations. (Staff Ex. 27, Office of Investigations, Report of Investigation dated September 12,1983 ("Second OI Report"), Summary). We scheduled and held evidentiary hearings concerning these allegations on November 1, 2, 3, 4, 7, 8 and 9, 1983 in Midland, Michi-gan. We also held one evidentiary hearing session on December 3, 1983 in Bethesda, Maryland in order to permit a subpoenaed witness to te.stify. The NRC staff presented a panel of NRC witnesses consisting of the fol-lowing persons: (1) Mr. Harold Walker, Investigator, Office of l L
Investigations, Region III; (2) Mr. Charles Weil, Complaint Specialist, Region III: (3) Mr. Darl Hood, Project Manager, Office of Nuclear Reactor Regulation (NRR); (4) Mr. Joseph Kane, Geotechnical Engineer, NRR; (5) Mr. Ronald Cook, Senior Resident Inspector, Midland site, Region III; and (6) Dr. Ross Landsman, Reactor Inspector, Region III. (Tr. 21,330-31). These witnesses presented testimony concerning their involvement in matters associated with the licensee's alleged violation of our April 30, 1982 memorandum and order. The licensee presented a panel of witnesses consisting of Mr. James A. Mooney, Executive Manager, Consumers Power Company and Mr. Robert M. Wheeler, Soils Section Head, Consumers Power Company. (Tr. 21,953). At the request of the Board and parties, the licensee presented Mr. John Schaub, Assistant Project Manag-er for the Midland project. (Tr. 22,489, 22,491). Mr. John L. Donnell, who was a former Babock & Wilcox soils inspector at the Midland site, testified in response to a subpoena. (Tr. 22,571). B. May 20, 1982 Meeting / Landsman Prohibition The deep "Q" electrical duct bank is a safety related electri-cal duct bank located quite deep in the ground. (Staff Ex. 27, Second 01 Report at 13, Attachment 12 at 7; Hood, Tr. 21,693-94). In the licensee's January 6,1982 submittal, the deep "Q" duct bank location is depicted as crossing number 3. (Kane, Tr. 21,706; Staff Ex. 26, First OI Report, 4). Mr. Mooney testified that initially the licensee intended to insert freeze elements in a manner that would have frozen the so.il
directly beneath the deep "Q" duct bank. (Id.) The licensee proposed to protect the deep "Q" duct bank from any heaving which would have been caused by the freezewall by excavating the soil directly below the duct bank. (Id.) However, the licensee abandoned this plan when it discov-ered that the duct bank was deeper than they previously expected. (Id.) On May 20, 1982, Mr. Hood and Mr. Kane were at the Midland site participating in an ACRS subcommittee tour of the site. (Hood, Tr. 21,723; Kane, Tr. 21,725). During a lull in that site tour, Dr. Landsman approached Mr. Hood and Mr. Kane and requested that they attend a meeting with him along with the licensee because he had become aware that the licensee intended to excavate below the deep "Q" duct bank, which he did not want them to do. (Hood, Tr. 21,723-24; Kane, Tr. 21,725; Landsman, Tr. 21,549, 21,754; Staff Ex. 27, Second OI Report at 13). At the May 20 meeting, the licensee informed the NRC staff that the deep "Q" duct bank was deeper than the licensee expected and proposed an alternative method, involving excavating the soils below the deep "Q" duct bank and installing a plug of either clay or concrete. (Staff Ex. 27, Second 01 Report, Attachment 12 at 7, 8). At the time of the May 20, 1982 meeting, the excavation was not below the deep "Q" duct bank. (Kane, Tr. 21,720, 21,728). Mr. Hood testified that at the May 20,1982.neeting during the course of the licensee's presentation, Mr. Schaub indicated that a view should be taken that the excavation itself could proceed and that at a later point in time after the excavation a decision could be made on the technical issue of the backfill material and the technique of placing the
l backfill. (Hood, Tr. 21,559). The NRC staff did not accept that view because it had certain technical concerns. (Hood, Tr. 21,559; Staff i Ex. 26, First 01 Report at 13; Kane, Tr. 21,563-64). Mr. Kane explained the NRC staff's technical concern at the May 20, 1982 meeting. (Staff Ex. 26, First 01 Report at 12, 13; Kane, Tr. 21,563-64; Hood, Tr. 21,559). The extent of the gap below the deep "Q" duct bank that the licensee had originally proposed (January 6,1982 submittal) to excavate was 12 inches. (Kane, Tr. 21,709; Staff Ex. 26, First OI Report at 13). The licensee's January 6,1982 submittal depicting the location of the deep "Q" duct bank shows a vertical scale where 1 inch is equal to 10 feet. (Kane, Tr. 21,707; Staff Ex. 26, Attachment 14, Figure 7). The reasons for the gap was to assure that if soil beneath the duct bank froze and caused heaving it would not impinge the duct bank. (Kane, Tr. 21,710, 21,563). Based on a series of meetings and licensee meetings, the li-censee and the NRC staff reached an understanding that the licensee in-tended the excavation below the deep "Q" duct bank to be a 6-inch gap or space. (Kane, Tr. 21,563, 21,709-10, 21,845). Mr. Kane testified that at the May 20, 1982 meeting the licensee proposed for the first time doing something significantly different; namely, removing all of the fill below the deep "Q" duct bank down to the natural clay material and replacing it with a concrete plug to create an impervious barrier, which involved an approximately 11 foot excavation. (Kane, Tr. 21,564, Staff Ex. 26, First OI Report at 13). Mr. Kane explained at the meeting that the NRC staff's concern was that _ -. ~ _ _
this proposal might create the problem of differential settlement because a hard spot would be' created that could cause differences in settlement and the possibility of voids. (Kane, Tr. 21,564,21,763). He testified that a good engineering approach would not be to separate this work into two phases since the excavation phase creates the problem and the back-fill would add to the problem created by the excavation. (Id.) Mr. Kane told the licensee at the May 20, 1982 meeting that it should stop now and not get into this problem without thinking through what is to be done once the excavation is completed. (Kane, Tr. 21,564-65, 21,763; Staff Ex. 26, First 01 Report at 13). Mr. Kane testified that it was his understanding of the May 20, 1982 meeting that the licensee was not to excavate below the deep "Q" duct bank until the problem was thought through, addressed, a solution developed, and NRC approval obtained. (Kane, Tr. 21,565, 21,763; Staff Ex. 26, First OI Report at 13). Mr. Kane's understanding of the May 20, 1982 meeting was confirmed by Mr. Hood. (Hood, Tr. 21,556; Staff Ex. 26, First OI Report at 12). Mr. Mooney's testimony about the nature of NRC staff's techni-cal concerns as expressed at the May 20 meeting regarding the nature of the permanent backfill for the deep "Q" duct bank is consistent with Mr. Kane's testimony. (Staff Ex. 27, Second 01 Report, Attachment 12 at 8). However, Mr. Mooney testified that none of the licensee's personnel understood that the NRC staff's concern at the May 20 meeting also related to excavation below the deep "Q" duct bank. (Id.) In n.is inter-view with OI investigators, Mr. Mooney also stated that he did not remember anything being said about excavation beneath the deep "Q" duct bank during the May 20, 1982 meeting. (Staff Ex. 27, Second 01 Report
a-at 13). Mr. Mooney explained that this statement meant that he did not recall any prohibition against excavation below the deep "Q" duct bank. (Mooney, Tr. 22,355). During the May 20, 1982 meeting Dr. Landsman told Mr. Mooney and Mr. Schaub explicitly not to excavate beneath the deep "Q" duct bank - without NRC approval. (Landsman, Tr. 21,610, 21,653, 21,764; Kane, Tr. 21,563-65; Hood, Tr. 21,761-62). Dr. Landsman testified that he looked them in the eye and that he believed that either Mr. Mooney or Mr. Schaub nodded his head in agreement with Dr. Landsman's prohibition against further excavation. (Landsman, Tr. 21,653, 21,763-64). Mr. Kane and Mr. Hood both corroborated Dr. Landsman's testimony that daring the May 20, 1982 meeting, the licensee was told by the NRC not to dig beneath the deep "Q" duct bank without NRC approval. (Hood, Tr. 21,761-62; Kane, Tr. 21,762-63). Mr. John F. Fisher, a Bechtel Underpinning Contracts Manager, attended the May 20, 1982 meeting and prepared handwritten notes of that meeting. (Staff Ex. 27, Second 0I Report at 6 and Attachment 12 at 8). His handwritten notes directly support and corroborate Dr. Landsman, Mr. Kane and Mr. Hood's understanding that the licensee was not to excavate below the deep "Q" duct bank without NRC approval. The notes state: "We will proceed w/ exposing utility and not preceed with excavating the pit below deep "Q" until NRC approval." (Staff Ex. 26, First 01 Report, Attachment 8). Mr. Mooney testified that after becoming aware of Mr. Fisher's notes he did not dispute that the statement was apparently made at the May 20, 1982 meeting although he did not remember such a commitment being made. l (Staff Ex. 27, Second OI Report, Attachment 12 at 8).
Robert E. Sevo, a Bechtel Superintendent of Underpinning Veri-fication, had a set of notes that reflected the NRC staff's prohibition against excavating beneath the deep "Q" du:t bank. (Staff Ex. 27, Second OI Report at 22 and Attachment 17). Mr. Sevo's notes state: "No further deepening of the deep duct bank until NRR concurrence after [ sic]". (Staff Ex. 27, Second 01 Report, Attachment 17). We find that this entry corroborates Mr. Fisher's notes. Mr. Sevo's notes contains another entry that states: " Deep duct bank opened up to allow freeze to start-then finish excavation to till." (Id.) Contrary to the licensee's unex-plained statement in its findings that this contradicts Mr. Fisher's earlier entry noted above, this entry can be read as Intervenor Stamiris' findings suggest, namely, that Mr. Sevo probably believed that the exca-vation as originally proposed by the license and approved by the NRC could proceed and that at some later time the additional excavation could be done, which is consistent with much of the evidence adduced in the record. More importantly, we observe that of the 11 entries made in his notes, Mr. Sevo was careful to record in several other instances whether a particular activity had to be reviewed or approved by the NRC. (Staff Ex. 27, Second 0I Report, Attachment 17 at 1-4). Consequently, we find that the entry on its face does not necessarily contradict Mr. Fischer's notes, At an exit meeting on May 21, 1982, Dr. Landsman warned the j licensee again not to excavate the additional depth below the deep "Q" duct bank without getting prior NRC approval. (Staff Ex. 26, Fi,rst 01 Report, Attachment 2 and 9; Landsman, Tr. 21,610). The licensee prepared minutes of this exit meeting that corroborate Dr. Landsman's testimony that during that meeting he prohibited the licensee from conducting addi-l m
tional excavation below the deep "Q" duct bank. Those minutes state: "Dr. Landsman confirmed his understanding that this pit [ deep "Q" duct bank pit] would terminate a relatively short distance below the duct, and not be extended lower, as originally intended." (Staff Ex. 27, Second OI Report, Attachment 8; Staff Ex. 26, First OI Report Attachment 9). During an exit meeting on May 28, 1982, the licensee was again told by Dr. Landsman not to excavate beneath the deep "Q" duct bank until .they obtained NRC approval. (Landsman, Tr. 21,610). Dr. Landsman docu-mented this NRC hold point in an inspection report. (Staff Ex. 26, 1; Landsman, Tr. 21,580, 21,768-69). Mr. Weil testified that Mr. Horn, who was head of the civil section for MPQAD, informed him during an interview that Mr. Horn's group recognized a commitment made to Dr. Landsman in May of 1982 that excava-tion would not take place below the deep "Q" duct bank without Dr. Landsman's approval. (Weil, Tr. 21,529-31). Mr. Schaub, who attended the May 20, 1982 meeting, testified that he was listening to a conversation during that meeting involving several other people and Mr. Kane, and that Mr. Kane said that the li-censee could proceed at its own commercial risk to place a temporary backfill in the deep "Q" duct bank. (Schaub, Tr. 22,504-506).
- However, Mr. Schaub did not participate in that conversation.
(Id., at 22,505). Mr. Kane testified that the discussions at the May 20, 1982 meeting were not limited to either the type of the backfill or the method of placing the backfill. (Kane, Tr. 21,845-47). He also testified that he not make a statement to either Mr. Schaub or anyone else at the May 20, 1982 meeting which would lead that person to believe that L
Mr. Kane approved the use of concrete at the licensee's commercial risk. (Kane, Tr. 21,852). Mr. Kane explained that it was his understanding of the May 20, 1982 meeting that the licensee's plans for the deep "Q" duct bank, which involved an 11 foot excavation, were to be submitted for review by NRC prior to the excavation being initiated. (Staff Ex. 26, First 01 Report at 13). Mr. Kane's understanding was corroborated by Mr. Hood statements in his interview during the OI investigation. (Staff Ex. 26, First 01 Report at 12). He also stated in his interview during the OI investigation that he neither personally stated nor implied any permission for the licensee to initiate any excavation work concerning either the deep "Q" duct bank or the relocation of the fire line without obtaining prior approval from the NRC. (Id.) Mr. Hood also explained that he did not approve either the excavation beneath the deep "Q" duct bank or the excavation for relocation of the fire line. (Staff Ex. 26, First OI Report at 12). Mr. Hood testified that the May 20, 1982 meeting was not an official NRC meeting because no official notice had been given of it and he requested that no minutes be published. Because this meeting was informal in nature, he explained that information the licensee provides is not of the type which the Staff should rely on as a basis for its safety conclusion. (Hood, Tr. 21,726). Such information is not proper in an informal meeting; consequently, Mr. Hood stated the NRC staff had granted no approvals during the May 20, 1982 meeting. (Hood, Tr. 21,726-27). Mr. Hood and Mr. Kane testified that to date the licensee has not submitted its proposal for conducting the additional excavation below the deep "Q" duct bank. (Kane, Tr. 21,691, 21,695; Hood, Tr. 22,313).
12 - Dr. Landsman testified that there was some disagreement at the f 2 May 20, 1982 meeting about what are either major or minor design changes. (Landsman, Tr. 21,558). The licensee thought the excavation below the deep "Q" duct bank was a minor design change; however, the NRC staff thought it was a major design change. (M. ) Thus, Dr. Landsman stated that a decision was made that from then on he would decide whether it was a major or minor design change, and he then would decide whether to have NRR approve the change. (Landsman, Tr. 21,558; Staff Ex. 27, Second OI Report, Attachment 5 at 2). Mr. Kane and Mr. Hood corroborated Dr. Landsman's testimony that at the May 20 meeting it was decided that the procedure for handling design modifications was to first have Dr. Landsman evaluate the significance of the design modification, and if he decided it was significant then he would involve NRR. (Kane, Tr. 21,770; Hood, Tr. 21,771). In response to the licensee's request for clarification at the meeting about whether approval would come from NRR or Region III, Mr. Hood stated that approval would come from Dr. Landsman ir. Region III. (Hood, Tr. 21,559,21,771). Mr. Fischer's notes directly corroborate the testimony of Dr. Landsman, Mr. Kane and Mr. Hood that the procedure for the licensee to obtain NRC staff approvals. The notes state: D. Question on what is significant change - They have to be or should be submitted for approval. Agreed procedure - all items will be discussed with Landsman (Region 3). If R. Landsman thinks it is significant, CPCo will submit. (Staff Ex. 26, First OI Report Attachment 8 at 2). After weighing the evidence, we find that the licensee'was told at the May 20, 1982 meeting not to excavate below the deep "Q" duct without prior NRC staff approval. We also find that the licensee was required to L
submit additional information to the NRC staff showing its proposal for the additional excavation below the deep "Q" duct bank. We find that Mr. Mooney's testimony that he doesn't recall the excavation below the deep "Q" bank being discussed at the May 20, 1982 meeting is not credible in view of the other evidence. Moreover, we find that Mr. Schaub's testimony that Mr. Kane authorized the licensee to proceed with the excavation below the deep "Q" duct bank at its commer-cial risk during the May 20, 1982 meeting is unsubstantiated by the evi-dentiary record and thus is not credible. C. May 25, 1982 Letter Mr. Mooney testified that the NRC staff gave explicit approval for the additional excavation beneath the deep "Q" duct bank in an NRC staff letter dated May 25, 1982 (Staff Ex. 27, Attachment 12 at 9). The NRC staff's May 25, 1982 letter was responding to the li-censee's letter of May 10, 1983, which addressed certain soils construc-tion work the licensee believed had staff approval prior to our April 30, 1982 order. (Staff Ex. 26, First 01 Report, Attachment 4 at 1). The NRC staff's response to which soils construction work had NRC staff approval prior to April 30, 1982 is contained in paragraphs I and II of Enclosure 4 of the May 25, 1982 letter. (Id.; Hood, Tr. 22,309). Paragraph numbered I.c. of Enclosure 4 of the NRC staff's May 25, 1982 letter is the NRC staff's response to paragraph I.c. of the licensee's May 10, 1982 letter. (Hood,Tr. 22,309-10; Staff Ex. 26, First OI Report, Attachment 3 at 1, 2 and Attachment 4, Enclosur.e 4 at 1). Paragraph I.c. of the licensees' May 10, 1982 letter defines the following scope work previously approved by the NRC: "freezewall
installation, underground utility protection, soil removal cribbing and related work in support of the freezewall installation, freezewall moni-toring and freezewall activation" (Staff Ex. 26, First OI Report, at 1, 2; Hood, Tr. 22,309-10). NRC staff's response in paragraph I.c. of Enclosure 4 of the May 25, 1982 letter, states that " References 5 and 7 provide staff concurrences for freezewall installa-tion and activation, respectively". (Staff Ex. 26, First OI Report,, Enclosure 4 at 1). This paragraph also identifies the licensee letter of January 6, 1982 as an NRC staff basis of approval. (Id.; Hood, Tr. 22,310). Reference 7 is the NRC staff letter of February 12, 1982 which Mr. Mooney testified provided the specific NRC approval of the additional excavation below the deep "Q" duct bank. (Staff Ex. 26, Attachment 4; Mooney, Tr. 22,350, 22,362). He also testi-fied that the NRC staff's February 12, 1983 letter is documenting the NRC staff's approval for excavating below the deep "Q" duct bank as described in the licensee's January 6, 1982. The testimony of Mr. Hood and Mr. Mooney that the basis for the NRC staff's approval for excavating below the deep "Q" duct bank is set forth in the licensee's submittal of January 6, 1982. (Hood, Tr. 22,310-11; Mooney, Tr. 22,351). However, Mr. Mooney testified that the design presented in the licensee's submittal of January 6, 1982 does not show any limit to the proposed excavation below the deep "Q" duct bank even though he acknowl-edged it was drawn to scale. (Mooney, Tr. 22,353). We do not find Mr. Mooney's testimony about the design concept credible. Mr. Hood tes-tified, and the licensee's January 6, 1982 letter shows, that the deep "Q" duct bank is 22 feet deep and is the only safety-related utility line
in the freeze zone, and it will be excavated as shown in Figure 6 and 7. (Hood, Tr. 22,311; Staff Ex. 26, Attachment 14). After looking at the licensee's proposal for excavating below the deep "Q" ducc bank, Mr. Wheeler, who was in the panel with Mr. Mooney, testified that the proposed excavation below the deep "Q" duct bank as described in the licensee's January 6,1982 submittal was different by 12 or 13 feet than the excavation which tool place below the deep "Q" duct bank. (Wheeler, Tr. 22,340-44). This is consistent with Mr. Kane's description of the vertical scale of the drawing contained in the licensee's January 6, 1982 submittal, which is that one inch equals 10 feet. (Kane, Tr. 21,707). Mr. Kane, a geotechnical engineer, testified that the licensee's proposal at the May 20, 1982 meeting, which involved an approximately 11 foot excavation, was significantly different than its original proposal of 12 inches. (Kane, Tr. 21,564-65, 21,709, Staff Ex. 26, First 01 Report at 13). Mr. Mooney testified that in the May 25 letter the NRC staff concerned that related work in support of freezewall activation had been previously approved. (Mooney, Tr. 22,361). However, we find that Mr. Mooney's testimony is not corroborated by the evidence. The licensee's May 10, 1982 letter states, in relevant part, that: Remedial soils work previously approved by the NRC is contin-uing. Concurrence as to the scope of this work was obtained from Mr. Darl Hood, and is as defined below: A A A I.c. freezewall installation, underground utility, pro-tection, soil removal cribbing and related work Li
.in support of the freezewall installation, freezewall activation. (emphasis supplied) (Staff Ex. 26, First OI Report, Attachment 3 at 1, 2). The NRC staff's May 25 letter, in response to the licensee's May 10 letter, quotes all of item I.c., and goes on to state: ... the staff agrees that prior explicit concurrence for the activities listed in paragraph I.c. of CPCo's letter, May 10, 1982 had been obtained by the staff prior to the April 30,1982 Order, except for the ambiguous ph[r]ase you included "and related work in support of...". Therefore, the staff did not approve "related work" in its letter of concurrence or other records. (Staff Ex. 26, First OI Report, Attachment 4, Enclosure 4 at 1). Mr. Hood, who prepared the May 25th letter explicitly confirms that this is where the NRC staff addressed paragraph I.c. of the licensee's May 10th letter. (Hood,Tr. 21,699, 22,310). to the NRC staff's May 25, 1982 letter goes on to state: In summary, ambiguity associated with CPCo's use of the terms " Phase I work" and "related [freezewall] work" preclude con-firmation of specific prior approval of these activities Consequently, continuation of these activities in conformance with the foregoing staff comments will be in accordance with the Board Memorandum and Order of April 30, 1982. Any deviations must be reported and approved by the staff. (Id., at 2). The last sentence was intended as a warning to the licensee not to excavate below the deep "Q" duct bank because its proposed modifi-cation at the May 20, 1982 meeting had not been approved. (Hood,, Tr. 21,798-800).
Mr. Hood testified that the May 25th letter in no way approves a modification to the licensee's originally proposed design and excava-tion that was presented to him for the first time on May 20, 1982. (Hood, Tr. 22,312, 21,799-800). Mr. Kane corroborated this testimony. (Kane, Tr. 21,657-58). Furthermore, Mr. Kane testified that his input to the May 25th letter occurred long before the May 20th meeting and thus his input did not address approving the licensee's proposed excavation, which first offered at the May 20, 1982 meeting. (Kane, Tr. 21,657-58). We find Mr. Mooney's testimony that the NRC staff's May 25, 1982 letter gave explicit NRC approval for the additional excavation below the deep "Q" duct bank conducted by the licensee is unconvincing based on the evidence presented. After considering all the evidence, we find that the NRC staff's May 25, 1982 letter did not authorize either implicitly or ex-plicitly the licensee to conduct the further excavation below the deep "Q" duct bank without prior NRC approval. D. Design Audit Meeting During a Midland site visit on July 28, 1982, Dr. Landsman inspected the deep "Q" duct bank and discovered that the licensee had excavated approximately 12 feet below the deep "Q" duct bank. (Staff Ex. 26, First 0I Report, Attachment 2 at 2; Landsman, Tr. 21,550). Dr. Landsman voiced his concern to the licensee that the excavation belcw the deep "Q" duct bank was in violation of the Board's April 30, 1982 order. (Id.) However, the licensee did not stop excavating below the d.eep "Q" duct bank until the next day, July 29, 1982. (Id.; Wheeler, Tr. 22,088). The licensee did not issue the stop work order until it had completed excavating to the clay. (Staff Ex. 26, First 01 Report, Attachment 2 at 2; Wheeler, Tr. 22,084-97).
During the time period from July 27 to July 28, 1982, the NRC staff and its consultants met in Ann Arbor, Michigan with the licensee, Bechtel and their consultants to audit analyses, designs and preparations for remedial' measures to correct the foundations ard utilities on inade-quately compacted fill at the Midland site. (Hood, Tr. 21,812; Staff Ex. 26, Attachment 16 at 1). Mr. Hood and Mr. Kane attended that design audit meeting. (Id.) While the design audit meeting in Ann Arbor, Michigan was in progress, Dr. Landsman attended an exit meeting with the licensee at the Midland site on July 30, 1982. (Staff Ex. 26, First OI Report at 3 and at 2). At that meeting, Dr. Landsman informed the licensee that it was in direct violation of the April 30, 1982 order and its con-struction permit. (Id.) The licensee told Dr. Landsman that earlier that morning it had discussed and received approval from Mr. Hood and Mr. Kane in Ann Arbor for the technical adequacy of what they were doing. (Id.) After receiving a call from the Midland site, Mr. Schaub stated in his interview during the OI investigation that he spoke with Mr. Kane at the design audit meeting on July 29, 1982 about using concrete as a backfill in the deep "Q" duct bank recognizing that this would be done at the licensee's commercial risk. (Staff Ex. 26, First OI Report, Attach-ment 15). Mr. Kane testified that that statement is incorrect, because he did not talk to Mr. Schaub at all during the design audit meeting about the deep "Q" duct bank. (Kane, Tr. 21,853). At the time of the July audit, the only conversation about the deep "Q" duct bank t. hat Mr. Kane could recall was that the deep "Q" duct bank was an outstanding issue on which the NRC was waiting to receive further information from
the licensee. (Kane, Tr. 21,566-67, 21,853; Staff Ex. 26, First OI Report at 13). Mr. Hood also testified that the only discussion about the deep "Q" duct bank as an agenda item was the licensee's acknowledge-ment that it would a report to the NRC staff; but, it was not discussed in terms of resolving an issue as a formal agenda item. (Hood, Tr. 21,567, 21,815-16; Staff Ex. 26, First 01 Report at 12). In the latter stages of the audit, Mr. Hood recalled a brief discussion with either Mr. Mooney or Mr. Schaub about Dr. Landsman's dissatisfaction that excavation had occurred at the deep "Q" duct bank. (Hood, Tr. 21,568) Mr. Hood replied that he would have to resolve that matter with Region III. (Id.) There was some discrepancy in the NRC staff's testimony about whether the deep "Q" duct bank was properly classified as either an open item or confirmatory item in the final version of the agency of the July audit meeting and the SSER. (Tr. 21,815-25). However, we note that the final version of the agency was issued on 'hvember 12, 1982. (Staff Ex. 26, First 01 Report, Attachment 16; Kane, Tr. 21,820-21). The SSER in question was issued in October 1982. (Kane, Tr. 21,821).
- Secondly, the licensee prepared an agenda, which was based on a draft SSER, that had its designation of whether an item was confirmatory, and that agency was used as the main agenda during the design audit meeting.
(Staff Ex. 26, First OI Report, Attachment 16 at 1; Hood, 21,816). The licensee was informed that the draft SSER designations can not be relied l on as approval for any work. (Staff Ex. 30). Nevertheless, the.NRC staff consistently testified, which the final agenda and SSER-2 show, that the licensee still had to provide the NRC staff information about l l
the additional excavation below the deep "Q" duct bank. (Staff Ex. 26, First 01 Report, Attachment 16; Kane, Tr. 21,566-67, 21,570, 21,853; Hood, Tr. 21,567, 21,815-16, 21,874; Staff Ex. 26, First OI Report at 12, 13. Based on our consideration of the evidence presented, we find that Mr. Schaub's statement that Mr. Kane indicated that the license could proceed to backfill the excavation at its won commercial risk is not credible. Further, given the time frame in which Mr. Schaub alleges Mr. Kane made the statement, the alleged statement could not have formed the basis for a belief by the licensee that it had explicit prior NRC staff approval before conducting the additional excavation below the deep "Q" duct bank. We find that the agenda of the July audit meeting did not pro-vide the licensee explicit prior NRC staff approval to further excavate beneath the deep "Q" duct bank. C. Wheeler / Landsman Agreement On August 4, 1982 during a site visit, Dr. Landsman discovered that the licensee had conducted an excavation that involved the relocation of a fire line along side the service water pump structure, which was in "Q" soils. (Staff Ex. 26, First OI Report, Attachment 2 at 2; Landsman, Tr. 21,553-54, 22,220). Based on Dr. Landsman's measurements, this excavation was approximately 7 to 8 feet deep. (Landsman,Tr. 21,553-43). Dr. Landsman informed the licensee on August 4, 1982 that the NRC had not authorized the excavation fo.r relocation of the fire line. (Landsman, Tr. 22,220). The fire line relocation took place between June 30, 1982 and August 4, 1982.
e (Landsman,.Tr. 21,551-52).' This excavation was not. stopped until either August 9 or 10, 1982. (Staff Ex. 26, First OI Report Attachment 17, Landsman Tr. 22,220-21). Dr. Landsman stated unequivocally that the NRC staff.had not authorized licensee to continue the excavation the fire line relocation until that work was completed. (Landsman, Tr. 22,223; Staff Ex. 26, First 01 Report, Attachment 2 at 2). ~Mr. Wheeler testified that on June 11, 1982 he reached an agreement with Dr. Landsman that minor excavations did not need prior-approval from Dr. Landsman before beginning the work. (Staff Ex. 27, Second 01 Report, Attachment 12 at 3). For major excavations, such as the excavation for the service water underpinning, he testified that the understanding was that Dr. Landsman would review prior to starting the work. (Id.) Mr. Wheeler documented his understanding of the agreement in a personal handwritten note dated June 11, 1982, which states: " Excavation permit procedure is OK. will review signed off permits from site visit to site visit. He is only concerned with major excavations such as SWS underpinning." (Staff Ex. 26, First 01 Report 0). Mr. Wheeler testified that both the additional excavation below the deep Q duct bank and the relocation of the fire line were minor excavations that were covered by this agreement. (I_d. ) Dr. Landsman testified that his understanding of the June 11, 1982 agreement with Mr. Wheeler was that he did not need to review before work began those excavation permits for minor excavations that had prior NRC approval. (Landsman,Tr. 21,933-34). For major excavations, involving prior approved work, Dr. Landsman wanted to review before the licensee began the work. (ld. at 21,934). Dr. Landsman testified
further that for work that was not previously approved, he had to review those permits to authorize the work. (Landsman, Tr. 21,911). Since the only work the licensee was doing onsite at this time was work that prior NRC approval, he saw no need to document the agreement. (Landsman, Tr. 21,929, 21,932). We find that Mr. Wheeler's testimony that the June 11, 1982
- s.....
i agreement with Dr. Landsman was as Mr. Wheeler understood it to be 9 unconvincing. Mr. Wheeler's explanations of what items of work required Dr. Landsman's prior approval were contradictory and inconsistent. (Wheeler,Tr. 22,359-76). He was uncertain about precisely what work activities fell within the scope of his alleged June 11, 1982 agreement with Dr. Landsman. (Id.) Dr. Landsman documented the NRC staff's hold point for the additional excavation below the deep Q bank, which arose out of the May 20, 1982 meeting, in an inspection he prepared after July 2,1982. (Landsman, Tr. 21,768; Staff Ex. 26, Attachment 11). Such an action by Dr. Landsman is totally inconsistent with Mr. Wheeler's testimony that the agreement he reached with Dr. Landsman covered the excavation below the deep Q duct bank. Moreover, as we noted earlier, the NRC staff was in total agreement at the May 20, 1982 meeting that the licensee was not to excavate beneath the deep Q duct bank without prior NRC approval. The NRC staff as we noted above, has consistently testified that the licensee was to provide additional information before it could proceed with the excavation below the deep "Q" duct bank, Contrary to Mr. Wheeler's testimony that the excavation for relocation of the fire line was covered by the June 11, 1982 agreement
'O E thus did not require NRC approval, the licensee's Soils Progress Schedule Status Reports for June 23, 1982 and June 30, 1982 show that for those dates that NRC approval was required. (Staff Ex. 32 at 2). Mr. Schaub was responsible for making that determination. (Id.) For the additional excavation below the deep "Q" duct bank, Mr. Schaub apparently approved the excavation. (Stamiris Ex. 123; Wheeler, Tr. 21986-88, 21990). Mr. Wheeler stated he does not recall whether he ever told Mr. Schaub about his June 11, 1982 agreement with Dr. Landsman. (Staff Ex. 27, Second OI report at 30; Wheeler, Tr. 22007). Mr. Schaub himself stated he did not know when he first learned of Mr. Wheeler's agreement with Dr. Landsman. (Staff Ex. 27, Second 01 Report at 33). There is evidence based on a licensee prepared document that Mr. Schaub confirmed that NRC approval was given for these two excavations in question. (Stamiris Ex. 123; Wheeler, Tr. 21992). Further, the record contains no credible evidence that Mr. Schaub was aware of the agreement between Mr. Wheeler and Dr. Landsman. Given the presence of our April 30, 1982 Order and the other measures on site that control the approval and initiation of soils related activities, we find that Dr. Landsman's understanding of his agreement with Mr. Wheeler is much more consistent with the evidence that was addressed during the hearing. After weighing the evidence we find that neither the excavation below the deep "Q" duct bank nor the relocation of th,e fire l line was covered by the June 11, 1982 agreement as understood by l Mr. Wheeler. We find that the Wheeler / Landsman agreement as understood l 1
e.. by Mr. Wheeler does not constitute explicit prior NRC staff approval to conduct the excavations in question. D. Conclusion At least two of the NRC staff witnesses testified that they believed at a minimum that the licensee's actions regarding these excavations constituted a careless disregard of NRC requirements. (Cook, Tr. 21642; Landsman, Tr. 21642). Both these witnesses testified that in their view there was an element of deliberateness in the licensee's action. Based on the whole record on the issue of whether the licensee violated our April 30, 1982 Order, we find that the licensee did violate our April 30, 1982 Order in not obtaining explicit prior NRC staff approval before conducting either the additional excavation below the deep "Q" duct bank or the excavation necessary to relocate the fire line. Because of the conflicting testimony about who in the licensee's organization knew precisely what the status of NRC approvals was at any point in time, we_are able to findlthat the licensee intentionally 2 violated our April 30, 1982 Order.
/g.9 5 f ?g% g j w. gRtNCIPALSTAFF UNITED STATES (h 4 O [](f),-[4[,1 [E NUCLEAR REGULATORY COMMISSION v aA l gMFP g* WASHINGTON, D. C. 20555 -)/RA JL I/R.a WY Cs. '.,.., g MAY 2 21334 Q-(wA 4 SEA y l m ;)w wp \\ MEMORANDUM FOR: Harold R. Booher, Chief Licensee Qualifications Branch, DHFS /h THRU: Larry Crocker, Section Leader Licensee Qualifications Branch, DHFS FROM: Pete McLaughlin Licensee Qualifications Branch, DHFS
SUBJECT:
TRIP REPORT - MIDLAND, MICHIGAN, MAY 4, 1984 The purpose of this memo is to report on my May 4, 1984 trip to Midland, Michigan to participate in a public meeting on the Management Appraisal Program (MAP) to be performed on Consumer's Power Company's (CPCo) Midland Nuclear Project. Another program already in place at Midland, the Construction Completion Program (CCP), was also discussed. The all-day meeting was broken up into morning and afternoon sessions to discuss the CCP and MAP, respectively. The morning discussion of the CCP was well attended by public and press (about 100 people), as well as, four television crews. The program's status was discussed and no major issues were identified. The program is a very ambitious one (a 100% reinspection of all available work with rework, as required) on a tight schedule (fuel load - July 1986). The afternoon session was devoted to a presentation by Cresap, McCormick and Paget (CMP) on their proposed program to appraise management of the Midland Nuclear Project. Consumer's Power had engaged CMP to' develop the program in response to a Ccnfirmatory Order issued by Region III. The format of the CMP presentation was to briefly discuss their plan, introduce the key team members and respond to the 11 comments that Region III had provided as a result of their review of the plan. I have enclosed a copy of the comments. I felt all the comments were successfully resolved except for 2 and 4 which I will now discuss. CMP is an independent management consulting firm and is qualified to perform this type of appraisal program. However, for reasons not fully explained CMP has sub-contrac+ad some of the work to TERA Corporation. Since, TERA is already doing the Independent Design and Construction Verification Program at the Midland Project, the question of conflict of interest can be raised. Several questions were asked concerning the conflict of interest issue and even though the plan was subsequently approved without bias to TERA's involvement, I believe it is still a potential problem. The fish-bowl environment in which the Midland Project exists makcs it highly susceptible to public scrutiny and coment. I feel that the controversy surroundinc the poor quality of work performed at Midland and CPC0's management involvement g%%M 2.00 / v-
w -2 in it, will~not be helped by even the-suspicion of conflict [of in'terest. 'I do not believe that the benefft to be received by TERA's involvement in the MAP.is of sufficient magnitude to outweigh the potential damage to the credibility of the MAP's recommendations that can be caused by the inference 4
- of conflict of interest and/or whitewash.
Another area in which I also believe that the MAP is flawed is in its assessment of the capability of the CPCo's management of the Midland Project. The Confirmatory Order directing that the MAP be performed, specifically stated that, "....the appraisal shall include a review of the licensee's site and corporate construction management and supervisory personnel involved in the Midland project to determine their capability and competency for managing construction activities consistent with regulatory requirements." The MAP proposal, as submitted, was not clear on whether or not the program would address this area or not. Under questioning at the meeting it was stated by j CMP that they planned to do a function and roles analysis of all management / supervisory positions.in the Midland Project organization. They then planned to evaluate each positions incumbent."compentency" through resume review and interview. I believe that the appraisal of " capability" or how well did the individual actually perform his job will not be addressed. t Since this was a specific requirement of the Order, it appears that the MAP i may not be responsive to the Order in this area. The seriousness of this lack of responsiveness depends on the importance of the " capability and i competency" issue to the authors of the Order. Finally, having sat through 8-9 hours of discussion related to the Midland Project I have two personal observations to make. First, the Midland Project got into the position it is presently in because 4 of certain shortcomings, maybe in management and maybe not, but in any case, I to correct the situation, in October of last year they proposed and we accepted their Construction Completion Program (CCP) plan. Part of that plan involved changes and realignments in management of the Midland Project. It also strengthened the Company's commitment to quality and schedule.
- Since, the situation has changed so significantly from what existed previously and we, the NRC have already approved and are monitoring their CCP, I don't know what purpose is to really be served by performing a Management Appraisal j
Program at this time. As a matter of fact, I would say that the MAP may have a deleterious impact on the CCP since performance of the MAP will require several people on site and at corporate offices doing interviews and observing administrative procedure and control implementation. I think this 4 " mucking about" in the Project could dhart attention from the CCP and cause l. more problems than it fixes. Also, the results of the MAP will not be known until Fall of this year, about a year and a half from fuel load, not much time will be left to implement recommendations much less make.a difference to past and/or existing quality problems. Second, the afternoon session of the Midland meeting was to discuss the CMP's i proposed plcn and the NRC's comments on it. To hold that kind of pre-decisional meeting in a public forum seemed inappropriate to me. I i o
believe the presence of the public and media inhibited to'some degree the unrestricted meaningful exchange of information (n) the MAP _and any constructive changes to the Program that might have-resulted from that exchange of information. Depending on the topic, the constriction of free infornation exchange may be worth the cost, but I don't think that this was one of'those' topics. l \\ "*/ ~ '.., .' l I u g, 7 Pete McLaughlin Licensee Qualifications Branch, DHFS
Enclosure:
11 Comments of CMP Plan cc: H. Thompson, NRR J. Taylor, I&E J. Keppler,' Region III R. Purple, NRR 4 O w 4
Enclost e 1 NRC Comments on the Independent Manaaement Appraisal of CPCo By Cresap, McCormick, and Paget 1. The independent management appraisal of CPCo is proposed to be performed by Cresap, McCormick, and Paget (CMP) and TERA Corporation (TERA). The plan does not identify how the two organizations will function and inter-face nor how the responsibilities for performing the appraisal, analyzing the findings, and making reconnendations will be assigned or shared between the two organizations. The plan should identify the. roles and responsi-bilities of CMP and Tera in working together as a team in performing this appraisal. 2. The participation of TERA in the independent management appraisal has the potential for creating a conflict of interest based on previous and current TERA involvement at Midland. Please explain the basis for your conclusion that TERA's participation does not represent a conflict of interest. 3. Appendix A includes a list of "likely" members of the appraisal team. CMP and TERA should provide the list of actually assigned team members. This list, tocether with independence statements and resumes for all ectual team members, needs to be furnished to Region III for the hRC staff evaluation of team members' competence and independence. Additional or substitute team members are expected to also meet the competence and independence criteria. 4. The Order specifically requires the appraisal to include review of "mac.ag; ment and supervisory personnel involved in the Midland project to determine their capability and competency for managing construction activities consistent with regulatory requirements," but the appraisal plan ma'res no reference to sych an evaluation. The appraisal plan shculd addeets this requirement. 5. The depth of the CMP manag'r ner.t appraisal is not clear. No reference is z r, ace to specific events or cases to be independently examined to determine if the inf o-r.ation developed through the ir.terview process can be sub-startiated. 6. The Order specifically requires the appraisal to include a review cf " management controls, [ management) conmunication systems and [r.anagement) practices, both at the Midland site and between the corporate office and the site." The appraisal plan should describe the intended evaluation of management cormunication systems and ran*gement practices. 9
n' The' NRC Order specifically requires the appraisal plan to include the 7. provision of recommendations f or cha,nges that will provide assurance that the licensee will implement NRC requirements. The appraisal plan The should confirm that the required recommendations will be mada. appraisal should also consider whether or not any past c'onsideration l of cost and schedule factors affected construction quality. The CMP management appraisal appears to be limited to a prospective 8. evaluation to determine how CPCo should proceed in completing the Midland The Order requiring the management appraisal was issued because project. of the past history of continued quality problems. The appraisal plan needs to include a retr 9spective evaluation of sufficient past events / problems to icentify ths contributing factors and causes of problems and This will provide CMP with an under-management's responses to them. standing of how the project got to where it is today, in order to permit CMP to oewelop recommendations where necessary for idprovements in organi-zational responsibilities, management controls, communications, and practices to comply with the Order. Tne plan should identify the "various contractors' referred to in Part I, 9. The list of interviewees Objective and Scope, of the appraisal plan. includes only Bechtel; no other contractors are identified. CMP should consider interviewing representatives from all levels of 10. supervisien and management, as well as construction workers, QA/QC inspectors, and other workers. CMP should also consider interviewing previous workers of CPCo and Bechtel. 11. The SALP 3 for Midland, dated September 16, 1983, identified continuing The 5 ALP Board recommended that the peoblems in the soils area. licensee review the performance of construction, engineering, and Quality Assurance managers in the soils area. The management appraisal shoulc include a. review of the licensee's follo.up actions in response to this NRC recommendation. N 2
4,;[i... l 9 INTRODUCTION ' GOOD AFTERNOON. I AM JOHN SELBY, CHAIRMAN, PRESIDENT AND CHIEF' EXECUTIVE OFFICER OF CONSUMERS POWER COMPANY. WE APPRECI-ATE THE OPPORTUNITY TO ADDRESS THE COMMISSION TODAY ON THE ST700US .0F THE MIDLAND PROJECT. WITH ME TODAY ARE STEPHEN HOWELL, EXECUTIVE VICE PRESIDENT WITH OVERALL CORPORATE RESP'ONSIBILITY f 0R THE MIDLAND PROJECT; JAMES COOK,.VICE PRESIDEKT WITH DIRECT MANAGEMENT RESPONSIBILITIES OVER THE DAY-TO-DAY ACTIVITIES OF 13iE , MIDLAND PROJECT; AND ROY WELLS, EXECUTIVE MANAGER OF THE MIDLAPG) QUALITY ASSURANCE DEPARTMENT. IN ADDITION, BECHTEL MANAGEMENT PERSONNEL ARE IN THE AUDIENCE. ON APRIL 10, FOLLOWING DELIBERATIONS BY OUR BOARD OF DIREXTTOR5, WE ANNOUNCED NEW COST AND SCHEDULE PROJECTIONS FOR UNIT 2 0F'11EE 4 MIDLAND PLANT. THE BOARD OF DIRECTORS CONCURRED WITH MANAGEMENT'S RECOMMENDATION THAT UNIT 2 0F THE MIDLAND PLANT SHOULD BE COMPLETED, AND BASED ON-CURRENT, PROJECTIONS, THIS PROCESS WILL RESULT ~IN COMMERCIAL SERVICE BY DECEMBER 1986 AT A COST OF 3.95 BILLION l DOLLARS. A CORRESPONDING FUEL LOAD DATE OF JULY,1986 WAS ALSO i PROJECTED. WE HAVE NOT DECIDED'UPON A COMPLETION COST OR SCHEINJLE ~ l FOR UNIT 1, WHICh WAS DEFERRED LAST YEAR' AFTER THE DOW CHEMICAL l M10484-0580A-TM18-TM18 j
,, (. ^ .2 COMPANY'S CANCELLATION OF ITS CONTRACT TO PURCHASE STEAM FROM THE PLANT. I PROPOSE TO REVIEW WITH YOU TODAY THE ELEMENTS OF OUR CONSTRUCTION COMPLETION PROGRAM (CCP), AND TO PRESENT THE REASONS WHY WE BELIEVE IT CAN AND WILL ASSURE COMPLI ANCE WITH PRESENT NRC REGULATIONS. THE CONSTRUCTION COMPl.ET10N PROGRAM THERE WERE TWO MAJOR FACTORS WHICH LED TO OUR DECISION NEAR THE END OF 1982 TO INSTITUTE THE CONSTRUCTION COMPLETION PROGRAM. ~ FIRST, THERE WAS AN AWARENESS ON OUR PART THAT PLANT CONSTRUCTION WAS NOT MEETING OUR OWN AND NRC EXPECTATIONS FOR DETAILED ADHER-ENCE TO PROCEDURES AND REQUIREMENTS. IN PARTICULAR, AN HRC TEAM INSPECTION CONDUCTED IN THE DIESEL GENERATOR BUILDI.NG DURING THE FALL' 0F 1982 FOUND PROBLEMS WITH OUR INSPECTION PROCESSES AND RESULTS. SECOND, WE PERCEIVED AN INCREASING LEVEL OF EMPRASIS AND EXPECTATION REGARDING CONSTRUCTION QUALITY ASSURANCE ON THE PART OF THE NRC AS A RESULT OF EVENTS IN THE INDUSTRY DURING THE PRECEDING 18 MONTHS. IN DECEMBER 1982, THE COMPANY STOPPED MOST SAFETY-RELATED WORK OF OUR PRIME CONTRACTOR, BECHTEL, IN JANUARY 1983, wE SUBMITTED A PROPOSAL FOR E1E CONSTRUCTION COMPLETION PROGRAM. THE NRC STAFF INVITEh PUBLIC COMMENT AND HELD SEVERA MEETINGS ON THE PROPOSAL. DURING THE REVIEW OF OUR CCP SUBMITTAt_, THE COMPANY REVISED ITS INITI AL PROPOSAL SEVERAL TIMES. IN t e .m---- w
j i. \\ ~ 3 OCTOBER 1983, THE STAFF FORMALLY APPROVED THE CCP IN' A CONFIRMA-TORY ORDER WHICH MADE THE CCP PART OF THE CONSTRUCTION PERMIT FOR THE PLANT. IDE'1) THE MAJOR ELEMENTS OF THE CCP ARE SHOWN IN SLIDE 1 AND CAR BE DESCRIBED AS FOLLOWS: l. THE FIRST STEP WAS TO' SHUT DOWN MOST SAFETY-RELATED WORK BEING PERFORMED BY BECHTEL. KONSAFETY-RELATED WORK AND CERTAIFT OTHER SAFETY-RELATED WORK WHICH I WILL ADDRESS SHORTLY WAS NOT COVERED BY THE CCP AND WAS ALLOWED TO PROCEED. 2. TO ASSURE THE EFFECTIVENESS OF GA IMPLEMENTATION UNDER THE CCP, WE REORGANI2ED OUR QA DEPARTMENT A.ND ABSORBED BECHTEL'S QC FUNCTION UNDER DIRECT CP CO. MANAGEMENT. THIS ACTION, WHICPJ . _. BEGAN IN THE FALL OF 1982 AS A RESULT OF A STAFF SU.GGESTION, ~ MARKED THE LAST STEP.IN OUR ASSUMPTION OF MOST QUALITY ASSURANCE AND O_UALITY CONTROL FUNCTJONS.FOR THE PROJECT. THE COMPANY ON ITS OWN INITI ATIVE HAD ASSUMED THE MANAGEMENT OF PROJECT QUALITY ASSURANCE IN 1980. THE TAKE0VER OF QC Inv0LVED THE TRAINING, TESTING,. AND RECERTIFICATION OF ALL BECHTEL QC INSPECTORS TO THE STANDARDS ESTABLISHED BY CONSUMERS POWER COMPANY's OA DEPARTMENT. QC INSPECTORS WERE TESTED COR PROGRAMMATIC KNOWLEDGE AND CHECKED OUT ON EACH INSPECTION PLAhj.WHICH THEY WILL BE REQUIRED TO EXECUTE.- IT 'IS ESTIMATED THAT AP, PROXIMATELY 187 MAN-YEARS HAVE BEEN CONSUMED IN THE INSPECTOR TRAINING AND TESTING EFFORT TO DATE. IDE 2) 3., THE WORK UNDER THE CCP IS DIVIDED INTO TWO PHASES. THE FIRST PHASE INCLUDES BOTH A STATUS ASSES.SMENT OF PARTIALLY
w
~ m ww,- m'
....z.- __.u. a.. Q COMPLETED WORK COVERED BY THE PROGRAM AND A VERIFICATION OF THE . ADEQUACY OF COMPLETED INSPECTIONS ON PRIOR WORK. OUR VERIFICA-TION PLAN, CALLED THE QUALITY VERIFICATION PLAN (QVP), IS AT PRESENT A 100% REINSPECTION OF. ACCESSIBLE ATTRIBUTES AND A REVIEW OF DOCUMENTATION FOR INACCESSIBLE ATTRIBUTES ON COMPLETED WORK WITHIN THE PLANT. 4. TO CARRY OUT THE REMAINING WORK, WE HAVE CREATED A COMPLETION TEAM STRUCTURE FOR PRODUCTION WORK. EACH TEAM OPER-ATES UNDER A SINGLE SUPERVISOR AND IS RESPONSIBLE FOR THE COMPLE-TION OF ASSIGNED PLANT SYSTEMS AND AREAS. MEMBERS OF THE TEAMS INCLUDE ENGINEERING, QUALITY ASSURANCE, TESTING AND CONSTRUCTIOftt PERSONNEL FROM BOTH CONSUMERS POWER AND BECHTEL. THE COMPLETION TEAMS CARRY OUT THE CONSTRUCTION ASPECTS OF THE STATUS ASSESSMEstT PORTION OF PHASE 1. IN ADDITION, QC BRINGS ALL OPEN INSPECTIOK RECORDS UP TO DATE AS PART OF STATUS ASSESSMENT. 5. THE SECOND PHASE OF THE CCP INVOLVES THE PHYSICAL COMPLETION OF THE VARIOUS SYSTEMS OR AREAS, INCLUDING NECESSARY REWORK AS INDICATED FROM THE RESULTS OF THE FIRST PHASE. THIS PHASE MARKS THE RETURN TO THE NORMAL SEQUENCE OF FINISHING l NUCLEAR PLANT CONSTRUCTION. THE WORK'IS CARRIED OUT BY THE COMPLETION TEAMS WITH.THEREQUID.ED INSPECTIONS OF NEW WORK .PROVIDED BY THE QC D'EPARTMENT. THE SEQUENCE OF ACTIVITIES U9tDER THE CCP RESULTS IN CONSIDERABLE EFFORT BEING EXPENDED BEFORE TEE P'" ~ ~ ~.AL COMPLETION WORK IS RESUMED. THIS IS A MAJOR DIFFERENCE BETWEEN THE MIDLAND WORK SEQUENCE AND THAT OF THE OTHER NUCLEAR l ese e v -w. ,.-,,-.---,-,--4-.---,-,----mm+e.-,--,-r
I;' ,5 PROJECTS THAT ARE CURRENTLY PERFORMING MASSI THE VERY END OF THEIR COMPLETION SCHEDULE. SPECIFIC DETAILED PLANNING PRECEDED EACH PHASE O 6. THE PHASE 1 CCP AND HAS TAKEN CLOSE TO A YEAR OF EFFORT. PLANNING, WHICH HAS BEEN COMPLETED, CONSISTED OF ORGANIZING TH TEAMS, WRITING PROCEDURES AND INSTRUCTIONS AND TRAINING BO THE PROGRAMMATIC ASPECT OF THE PHASE 2 PERSONNEL AND THE TEAMS. THIS INCLUDED TRAINING OF PLANNING HAS ALSO BEEN COMPLETED. i PERSONNEL, INTEGRATION OF QC INSPECTIONS INTO THE WORK PACKAGES AND PREPARATION OF PROCEDURES. THE RESULTS OF THE PLANNING FOR EACH PHASE ARE REVIEWED BY MANAGEMENT, BY :THE THIRD-PARTY OVER-VIEWERS AND BY THE NRC PRIOR TO EXECUTION OF THE WORK. $LIDE 2:0FF) CONSUMERS POWER COMPANY HAS CONTRACTED FOR AN INDEP 7. DEtiT THIRD-PARTY OVERVIEh',0F THE IMPLEMENTATION OF THE CCP AND THE PURPOSE OF THE ALL OTHER SITE CONSTRUCTION ACTIVITIES. CONSTRUCTION IMPLEMENTATION OVERVIEW IS TO ENSURE THAT WORK l'S BEING PERFORMED. IN ACCORDANCE WITH APPROPR I-f AND REQUIREMENTS AND THAT THE COMMITMENTS MADE IN T l AUDITS OF THE MANAGEMENT REVIEWS OF THE CCP BEING FULFILLED, ALSO.COVEREDBYTHEJON RUCTION IMPLEMENTATION OVERVIEW. CONSUMERS POWER COS'P'ANY HAS RETAINED STONE 8 WEBSTER, AN ENGI-NEERING AND CONSTRUCTION COMPANY WITH EXTENSIVE EXPER l STONE NUCLEAR POWER PLANT CONSTRUCTION PROJECTS, FOR THIS WORK. r INCLUDING & WEBSTER HAS. PARTICIPATED IN OTHER THIRD-PARTY REVIEWS, e O
s ', - 6 THE DESIGN VERIFICATION FOR DIABLO CANYON. IN ADDITION, STONE & WEBSTER IS PRESENTLY PERFORMING AN INDEPENDENT OVERVIEW OF THE AUXILIARY BUILDING UNDERPINNING WORK AT THE MIDLAND SITE. THE NRC STAFF HAS APPROVED THE CONSTRUCTION IMPLEMENTATION OVERVIEW AND SOILS REVIEW PLANS, AND THE TECHNICAL QUALIFICATION AND INDEPENDENCE OF STONE 8 WEBSTER. IN ADDITION, AN INDEPENDENT DESIGN AND CONSTRUCTION VERIFICA-TION PROGRAi4 (IDCVP) lS BEING CARRIED OUT BY THE TERA CO. THis PROGRAM IS A " VERTICAL SLICE" EVALUATION OF THE DESIGN AND CONSTRUCTION OF THREk SYSTEMS CHOSEN BY THE COMPANY AND APPROVED BY THE NRC STAFF. THE PROGRAM IS TYPICAL OF THE INDEPENDENT DESIGN VERIFICATIONS ENCOURAGED BY THE STAFF FOR NTOL'S. ~ AN INDEPENDENT MANAGEMENT APPRAlSAL., ORDERED BY THE STAFF IN JANUARY, IS THE FINAL AREA OF THI.RD-PARTY REVIEW FOR THE PIIDLAND PROJECT. IT WILL CONSIST OF AN INDEPE DENT THIRD-PARTY OVERVIEW ~ OF THE MANAGEMENT APPROACH OF THE COMPANY FOR COMPLETION OF THE PLANT. IT WILL FOCUS ON THE APPROPRI ATENESS OF THE EXISTING AND PROPOSED MANAGEMENT ORGANIZATION, SYSTEMS AND METHODS FOR PLANNING AND CONTROLLING ALL. ASPECTS OF THE PROJECT WHICH HAVE A BEARING UPON THE QUALITY AND SAFETY OF THE COMPLETED FACILITY AND UPON CONSUMERS POWER COMPANY'S, ABILITY.TO COMPLY WITH NRC REGULATORY .. ? REQUIREMENTS. A PLAN..TO CONDUCT THIS APPRAISAL AND A RECOMMENDA- + l TION OF A FIRM TO CONDUCT THE REVIEW HAVE BEEN SUBMITTED TO THE NRC STAFF FOR APPROVAL. A PU$LIC MEETING TO DISCUSS THIS FRG-POSAL HAS BEEN SCHEDULED FQR EARLY NEXT MONTH. a. MIO484-0580A-TM18-TM18
7 of ' CONSTRUCTION COMPLET10N PROGRAM EXCLUSIONS THE CONSTRUCTION COMPLETION PROGRAM IS A COMPREHENSIVE APPROACH TO THE QUESTION OF QUALITY ASSURANCE IMPLEMENTATION FOR THE MIDLAND PROJECT. HOWEVER, THERE ARE CERTAIN EXCLUSIONS To ' THE SCOPE OF THE CCP. THOSE ARE AREAS OF WORK IN WHICH QA IMPLEMENTATION WAS DEMONSTRATED TO BE EFFECTIVE OR WHICH WERE SUBJECT TO QUALITY PROGRAM UPGRADING SIMILAR TO,THE CCP. THE-MAJOR EXCLUSIONS FROM THE.CCP ARE SOILS; HEATING, VENTILATING AND AIR CONDITIONING (HVAC); AND THE NSSS ERECTION WORK. MANY OF THE ELEMENTS OF THE CCP DIRECTLY PARALLEL STEPS PREVIOUS"LY TAKEN IN THE SOILS AREA TO IMPROVE THE IMPLEMENTAT10N i 0F QUALITY ASSURANCE. AS AN EXAMPLE, THE COMPANY ON ITS OWN INITIATIVE ABSORBED THE CONTRACTOR'S 0C FUNCTION FOR SOILS BEFORE DOING SO FOR.THE BALANCE OF BECHTEL SITE WORK. SIMILARLY, AN. INDEPENDENT THIRD-PARTY REVIEW OF THE SOILS WORK WAS COMMISSIONED IN 1982 AND USED AS A MOLEL FOR THE CONSTRUCTION IMPLEMEETATION OVERVIEW. OTHER STEPS TAKEN TO UPGRADE QUALITY OF SOILS WORIC IN 1982 INCLUDED A MAJOR TRAINING PROGRAM WHICH ENCOMPASSED BOTH, ~ MANAGEMENT-LEVEL AND CRAFT EMPLOYEES AND A DETAILED NRC COMMrTMENT TRACKING SYSTEM. THE HVAC AREA, LIKE SOILS, RECEIVED SPECI AL ATTENTION BEFORE T-THE IRITI ATION OF THE..CCP IN 1981, HVAC BECAME THE FIRST AR3EA ~ OF WORK IN WHICH WE ASSUMED DIRECT RESPONSIBILITY FOR BOTE QE AND QC, AFTER PROBLEMS WERE IDENTIFIED IN CERTAIN ACTIVITIES OF THE HVAC SUBCONTRACTOR, THE ZACK CO. ALSO, IN RESPONSE TO THESE l PROBLEMS, MAJOR REINSPECTION EFFORTS OF HVAC HANGERS At(D SYSTEM l M10484-0580A-TM18-TM18
8 = p COMPONENTS WERE CONDUCTED. A NUMBER OF OTHER IMPROVEMENTS HAD BEEN MADE IN THE HVAC QA AREA, SUCH AS QA PROGRAM ENHANCEMENTS, STAFF INCREASES AND INSPECTOR TRAINING AND CERTIFICATION. IN ADDITION, THE COMPANY HAS CLOSELY MONITORED THE ZACK CO IN AUDITS ONSITE AND AT THE CONTRACTOR'S MANUFACTURING FACILITY IN CICERO, ILLINOIS. IN FACT, THE COMPANY WAS WELL INTO THE ZACK HOME OFFICE RECORDS PROBLEMS BEFORE THEY BECAME THE SUBJECT OF CONTRO-VERSY FOR ALL OF ZACK S NUCLEAR PROJECT ACTIVITIES. THE FINAL AREA 0F WORK EXCLUDED FROM THE CCP IS THE NSSS WORK BEING PERFORMED BY THE BABCOCK & WILCOX CONSTRUCTIOpt COMPANY. B&W HAS PROVED ABLE TO PERFORM ITS OPERATION WITH AN ACCEPTABLE QUALITY IMPLEMENTATION AND, THEREFORE, WAS EXEMPTED FROF5 THE CCP. THEIR EFFORTS IN THE CRITICAL PRIMARY SYSTEM COMPONENTS #fERE UNDER VIGOROUS SCRUTINY BY BOTH CONSUMERS POWER OVERINSPECTIONS AND THE NRC RESIDENT INSPECTOR AND REGIONAL STAFF. WHEN: PROBLEMS HAVE BEEN ENCOUNTERED, APPROPRI ATE CORRECTIVE ACTIONS HAWE BEEN TAKEN. RECENTLY, THE PROJECT FOUND INSPECTION RESULTS FOR EEW ERECTED HANGERS TO BE INADEQUATE, AND INSPECTOR RETRAINItNG AND REINSPECTION OF THIS WORK HAS BEEN INITIATED. _ CURRENT PROJECT STATUS LET US TURN NOW FROMOTHE DESCRIPTION OF THE CCP AN11 THE N VARIOUS ACTIONS WE Hf E TAKEN' TO PUT MIDLAND'S QUALITY ASSURANCE PROBLEMS BEHIND US. HOW IS THE PROJECT CURRENTLY PERPOREING? IHUS FAR, THE PROGRESS OF THE CCP HAS BEEN SATISFACTORY. THE PHASE 1 AND 2 PLANNING.IS COMPLETE. THE TEAMS ARE ORGANIZED AND TRAINED. THE STEPS T^ KEN TO UPGRADE OUR 0A PROGRAMS--THE M10484-0580A-TM18-TM18
,9 RECERTIFICATION OF QC INSPECTORS, THE QA REORGANIZATION, AND THE REVIEW OF QUALITY CONTROL INSTRUCTIONS--ARE COMPLETE. MANAGEMENT REVIEWS HAVE BEEN CARRIED OUT AND ACTION ITEMS IDENTIFIED A!ED CLOSED. THE CONSTRUCTION IMPLEMENTATION OVERVIEWER HAS BEENE CONDUCTING ITS REVIEW OF CCP ACTIVITIES SINCE AUGUST OF 1985. EVEN THOUGH THE CCP WAS FORMALLY APPROVED BY THE STAFF IN OCTOBER OF 1983, PHASE 1 IMPLEMENTATION DID NOT ACTUALLY STAET UNTil JANUA'RY 1984. THIS OCCURRED BECAUSE WE NEEDED TO COREtECT A SITE PROBLEM WITH THE PROCEDURES FOR DESIGN DOCUMENT REVISICE'S. AS A RESULT, WE HAVE ONLY LIMITED RESULTS AVAILABLE FR0rt THE VERIFICATION AND STATUS ASSESSMENT WORK. HOWEVER,-THE IINIT13 AL PHASE 1 DATA, INSPECTION PLAN PILOT REPORTS AND RESULTE FROM4 THE MAJOR CABLE AND HANGER REINSPECTIONS (UNDERTAKEN PRIOR 70 TIHE INITI ATION OF THE CCP IN 1982 AND 1983) HAVE INDICATED INO MAJOR PROBLEMS WITH THE FUNCTIONAL CAPABILITY OF THE COMPONEKYS IKiSPECTED. HOWEVER, NUMEROUS NONCOMPLI ANCE REPORTS HAVE BEEN WRITTIEN ANID WILL HAVE TO BE RESOLVED TO ENSURE FULL COMPLI ANCE OF TEfE HARDWARE WITH CURRENT DESIGN DOCUMENTS. THE CCP IMPLEMENTATION HAS PROGRESSED TO A LEVEL OF SEWERAL HUNDRED NON-MANUAL AND INSPECTION PERSONNEL IN THE FIELD. PERSONNEL ARE BEING ADDED2-lN A CONTROLLED FASHION. WE EXPECT TO
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STARTTHEINITIALPHME2 ACTIVITIES IN THE NEXT MONTH. ~ IN THE SOILS AREA, WE RECEIVED REGION 111 APPROVAL TO INSTALL THE FIRST UNDERPINNING PIERS BENEATH THE AUXILLARY l l BUILDING IN DECEMBER OF 1982. TO DATE, 24 0F THE 57 TEMPORARY PIERS HAVE BEEN' INSTALLED. MORE IMPORTANTLY, ALL CORNE3tS CNF THE Se* e MinhRh-09RnA TM1R-TM1R
u u. 30 MAJOR STRUCTURAL ELEMENTS HAVE BEEN. SUPPORTED, WHICH CONCLUDES THE RISKIEST PORTION OF THE UNDERPINNING. ALL THE MAJOR UNDER-PINNING CONSTRUCTION ACTIVITIES HAVE NOW BEEN DONE ONCE; THE LEARNING CURVE FOR CARRYING OUT THIS UNIQUE TECHNICAL ACTIVHTY UNDER AN EXTREMELY RIGOROUS OA PROGRAM HAS BEEN EXPERIENCED AND THE LESSONS LEARNED INCORPORATED INTO OUR PROGRAMS AND ' PROCEDURES. IN SHORT, WE ARE IN A PRODUCTION MODE IN SOILS; AND, I BELIEVE, DOING WELL. IN BOTH THE 90-DAY AND 270-DAY REPORTS OF THE INDEPENDENT SOILS REVIEW PROGRAM, THE INDEPENDENT REVIEMER IIN THE SOILS AREA COMMENDED OUR WORK, AS WELL AS THE COMPETENCE ANID EXECUTION OF QUALITY ASSURANCE, SAYING IN THE 270-DAY-R:EPORY, "THE ASSESSMENT TEAM CONTINUES TO BE SATISFIED WITH THE PERFOR-MANCE OF THE MIDLAND PLANT GUALITY ASSURANCE DEPARTMENT. TiHE QUALITY PROGP,AM IS EFFECTI,VELY PROVIDING ASSURANCE THAT THE CONSTRUCTION IS BEING CONDUCTED IN ACCORDANCE WITH THE 2)ESIE3N DOCUMENTS." THE HVAC ACTIVITIES ARE ALSO PROCEEDING SATISFACT05RILY,, AND MAJOR QUESTIONS HAVE BEEN RESOLVED. RECENTLY, THE NRC $TAFi: ISSUED A SPECI AL INSPECTION REPORT CONCERNING A NUMBER OF 01UTSTAND-ING HVAC ALLEGATIONS AND OTHER HVAC-RELATED CA ISSUES. ALTTAOUGH SOME ITEMS OF NONCOMPL'I ANCE WERE FOUND', THE INSPECTION REPORT f CONCLUDES: " BASED ON THE RESULTS 6F THIS INSPECTION, ANIi ASSUMING ADEQUATE RESOLUTION OF THE CONCERNS ASSOCI ATED WITH THE IDENTIFIED VIOLATIONS, WE CONCLUDE THAT THE INSTALLED HVAC SYSTEMS AND M10484-0580A-TMIG-TM18
I n-11 COMPONENTS AT THE MIDLAND
- NUCLEAR POWER PLANT ARE ACCEPTABLE AND THAT AN ADEQUATE QA PROGRAM IS BEING IMPLEMENTED WITH REGARD TO ONGOING HVAC:
ACTIVITIES." OTHER EFFORTS HAVE BEEN TAKEN BY BOTH THE COMPANT AND> THE STAFF TO VERIFY THE ADEQUACY OF HVAC COMPONENTS. IN PARTIItULAR, PHYSICAL TESTING OF HVAC COMPONENTS AS.PART OF A.VEP,IFICATJ ON EFFORT SIMILAR TO THE ONE 'USED AT THE LA SALLE FACILITY HA*.VE PROVED THE COMPONENTS ACCEPTt.BLE UNDER THEIR DESIGN CONDIT.1ONS. THE MAJORITY OF MY REMARKS HAVE BEEN FOCUSED ON THE PiLANT'S SAFETY-RELATED WORK. WE ARE ALSO MAKING SIGNIFICANT PROGRIESS IN THE SECONDARY SIDE OF THE PLANT. LAST MONTH WE SUCC5ESFUL*LY PULLED VACUUM ON THE UNIT 2 CONDENSER AND THE PROJECT-IS PolNTED TOWARD A MID-SUMMER MILEST0l'E OF TURBINE ROLL USING STEAM 'FROM .THE PLANT'S HIGH PRESSURE AUXILIARY BOILERS. THE SIGNIIFIC;ANCE OF THIS EVENT IS TWOFOLD. FIRST, COMPLETION OF THIS NON-Q WO3RK IS BEING CARRIED OUT USING OUR CCP PROCEDURES AND TEAM CONCEP'T. WE ARE THU'S GIVING OUR STAFF " HANDS ON" EXPERIENCE ON HOM TO IDO PHASE 2 WORK. SECOND, COMPLETION OF THE SECONDARY SIDE OF THE. PLANT THIS FAR FROM OUR FUEL LOAD DATE ENABLES US TO RESOL'VE ANY TESTING-RELATED PROBLEMS TH THIS EQU1 MENT AND THEREEY ADDS CONFIDENCE TO OUR OVjRALL-COMPLETION SCHEDULE. PROJECT COMPLET10N SCHEDULE AS 1 NOTED EARLIER, OUR'RECENT SCHEDULE AND COST DETERMINA-TION INDICATED THAT JULY 1986 IS OUR NEW PREDICTED FUEL LOAD DATE. THE RESOLTS OF OUR EXPERIENCE LAST YEAR IN DEVELOPING AND M10484-0580A-TM18-TM18
,12 IMPLEMENTING THE CCP WERE IN.STRUMENTAL IN REACHING THAT CONCLUSIO IN PARTICULAR, THREE CCP FACTORS SHOWN IN MY NEXT SLIDE HAD A ,lDE 3) MAJOR EFFECT ON SCHEDULE DEVELOPMENT. THESE WERE: l. THE COMMITMENT TO CONDUCT A 100% QUALITY RE-VERI 1FICATION; 2. THE ESTIMATES OF THE TOTAL REWORK REQUIRED TO RESOLVE ALL CCP INSPEC'.10N FINDINGS 3. THE TOTAL PAPERWORK PROJECTED FOR THE COMPLETION OF THE PROJECT THE CAREFUL PLANNING AND TRAINING TO CONDUCT THE CCIP HAS HAD TWO IMPACTS ON OUR SCHEDULE. F'tRST, IT WAS A CAUSE OF A\\ MAJOR PORTION OF OUR SCHEDULE EXTENSION. BUT IT; ALSO PROVIDES, SOME CONFIDENCE THAT WE DO, IN FACT, KNOW WHAT IS AHEAD AND HION TO CARRY OUT THE WORK. IN ADDITION TO THE IMPACT OF THE CCP, THERE ARE SEVIERAL OTHER MAJOR ASSUMPTIONS INHERENT IN OUR SCHEDULE CONCLUS. ION. IN
SUMMARY
, THESE ARE: 1. OUR OVERALL PERFORMANCE MERITS REGULATORY SUPPolRT. WE HAVE BEEN ENCOURAGED BY THE CONSTRUCTIVE RELATIONSHIP WH[lCH NOW EXISTS WITH THE REGION 111 STAFF, BU,T WE REALIZE THAT TH'IS WILL CONTINUE ONLY AS LONG AS OUR PERFORMANCE MERITS SUPPORT. 2. WE REQUIRE ADDITf,9NAL QC INSPECTORS TO SUPPORT COUR PHASE 1 SCHEDULE. THESE P,liRSONNEL MUST BE RECRUITED, TRAINED,AND CERTIFIED TO STAFF A TWO-SHIFT OPERATION BY MID-SUMMER. 3. THE PROJECT SCOPE OF WORK CANNOT CHANGE APPRECI: ABLY FROM THE CURRENT DESIGN. M10liBIF0580A-TM18-TMls
y..... 15 4. THERE MUST BE ADEQUATE FINANCING AVAILABLE TO COMPLETE THE PROJECT. EVEN WITH THESE UNCERTAINTIES, WE BELIEVE THAT CUR NEW FORECAST 1S CREDIBLE AND, THEREFORE, ACHIEVABLE. A NUME3ER OF FACTORS CONTRIBUTE TO OUR CONFIDENCE IN THIS PLAN. I HAVE LISTED SEVERAL OF THESE IN MY FINAL SLIDE. >lDE 4) THEY ARE: 1. SOILS ACTIVITIES ARE DEFINED AND DEMONSTRATED. 2. THE CCP PROGRAM DEFINITION AND PLANNING HAVE BEEN ACCOMPL1SHED. 3. THE DESIGN OF THE PLANT WILL BE COMPLETE BY JUfME, AND THE REMAINING ENGINEERING ACTIVITIES WILL bE TO SUPPORT CONSTRUC-TION AND TESTING. ~ 4.. SINGLE PLANT CONSTRUCTION AND STARTUP. WHILE MIE REGRET THE DOW CANCELLATION, COMPLETING A SINGLE PLANT WILL BE A MAJOR i SIMPLIFICATION. 5. MORE DETAILED PLANNING IS IN PLACE. DURING THE PAST YEAR, WE HAVE EXPENDED CONSIDERABLE EFFORT NOT ONLY ON UHE CCP, BUT ALSd ON OUR PLANNING AND CONTROLS TECHNIQUES, EE TABitlSHMENT OF COMPUTERIZED DATA BASE AND OVERALL ORGANIZATIONAL SCOlPE DEFINITION AND INTEGRATION. 6. ADDITIONAL NIO[ STAFF IS IN PLACE IN BOTH-CON!SUMERS i POWER AND BECHTEL. WE HAVE SYSTEMATICALLY ADDED PERSONNIEL EXPERIENCED IN NUCLEAR PLANT COMPLETION OVER THE PAST MONTHS. THESE ADDITIONS SHOULD PAY DIVIDENDS IN THE REMAINING PROJECT ACTIVITIES. M10484.0580A-TM18-TM18
3,4 7. BY ESTABLISHING SPECIFIC l'NTERMEDI ATE MILESTONES FOR THE PROJECT, SCHEDULE PROGRESS CAN BE MORE REAblLY MONITORED. IN ADDITION, PERSONNEL PERFORMANCE IS ENHANCED BY SEEING SHORT-TERM OBJECTIVES ACHIEVED. 8. A TARGET SCHEDULE, SUPPORTED BY ANALYSIS, HA'S BEEN ESTABL1SHED. THE TARGET SCHEDULE FOR FUEL LOAD IS THREE 150NTHS SHORTER THAN THE PUBLISHED SCHEDULE CONCLUSION. - NO ONE WOULD PRESUME TO COME BEFORE YOU AND TO CLAIM THAT HIS PROJECT'S COMPLETION PLAN IS.WITHOUT RISKS. WE HAWE NOT YET HAD THE OPPORTUNITY TO PRESENT OUR SCHEDULE IN DETAIL 'TO THE NRC STAFF, ALTHOUGH WE WILL DO S0 SHORTLY. MY, PURPOSE IN FREVIEWING IT BRIEFLY WITH YOU TODAY IS TO TRY TO EXPRESS SOMiE OF THE PROJECT'S CONFIDENCE THAT WAS CONVEYED TO THE ' COMPANY.*:S BOARD OF DIRECTORS IN RECOMMENDING THAT THE COMPANY FINISH THE iPLANT, IN SPITE OF THE PROBLEMS THAT WE HAVE EXPERIENCED IN THE FPAST AND THE CURRENT ENVIRONMENT WHICH SURROUNDS NUCLEAR POWER iPLANT PROJECTS. CONCLllSION IN CONCLUSION, WE BEllEVE THE MIDLAN'D PROJECT CAN, BE COM-PLETED IN COMPLIANCE WITH NRC REGULATIONS. OUR WORK PLAN TO ACCOMPLISH THIS GOAL IS TJE CCP, A COMPREHENSIVE RESPONSE BY MY COMPANY TO THE PROB' EMS' WHICH HAVE BEEN ENCOUNTERED IM CONSTRUCT-L ING THE MIDLAND PLANT. AFTER ALMOST A YEAR OF PREPARATION, ) 4 M10484-0580A-TM18-TM18
15 .o REVIEW AND REFINEMENT, THE CCP IS r<0W IN PLACE AND WORKING. IN ADDITION, AREAS OF THE JOB EXCLUDED FROM THE CCP ARE SHOWING SATISFACTORY REGULATORY COMPLIANCE. TO CARRY OUT ALL REMAINING WORK, WE HAVE ASSEMBLED AN EXPERIENCED AND COMPETEET STAFF WHICH IS DEDICATED TO SUCCESSFUL EXECUTION OF THEIR TASKS. WE HAVE ALSO DEVELOPED A CREDIBLE AND CONSERVATIVE COMPLETION. SCHEDULE--ONE THAT PROVIDES A CLEAR ROAD MAP TO COMPLETION OF. THE PLANT. IN
SUMMARY
, WE THINK WE UNDERSTAND THE REQUIREMENTS FOR SUCCESSFUL PROJECT COMPLETION, AND AS LONG AS THEY REMAIN RELATIVELY STABLE, WE BELIEVE WE HAVE A REALISTIC PLAN FOR COMPLETI0ff!. ONE CONSTRAINT ON OUR ABILITY TO COMPLETE MUDLAMID, HOWEVER, IS PROJECT FINANCING, WHICH REMAINS UNCERTAIN AND IS IDEPENDENT ' UPON THE PROGRESS OF DISCUSSIONS BEING HELD BETWEEN TTHE COMPANY, THE MICFjlGAN PUBLIC SERVICE COMMISSION STAFF, THE STidTE ATTORNEY GENFoAL, AND OTHERS. THERE HAS BEEN CONSIDERA5LE DEBIATE OVER THE OPTIONS OPEN TO THE COMPANY REGARDING THE FUTURE (DF TiHE MIDLAND PROJECT. WE BELIEVE THE BEST INTERESTS OF THE STATE,AND THE COMPAliY ARE SERVED EY COMPLETING THE PLANT. HOWEVER,, UNLESS THE UNCERTAINTY SURROUNDING THESE DISCUSSIONS CAN BE RESOILVED, WE WILL BE UNABLE TO SECURE THE NEEDED EXTERNAL FINANCIN1G AND MIDLAND WILL TAKE ITS PLACE ALONG SIDE THE GROWING NUT 4BER OF W' ABANDONED PROJECTS. AS A FINAL MATTER, I WOULD LIKE TO INVITE MEMBER.S OF THE COMMISSION AND STAFF TO VISIT THE.MIDLAt4D SITE AtCD VH.EW FIRST-M10484-0580A-TM18-TM18
~~ o., 16 HAND THE STATUS OF CONSTRUCTION AND THE IMPLEMENTATION OF OUR PROGRAMS. I BELIEVE A VISIT TO THE SITE WOULD BE WELL WORTH THE EFFORT. I AM NOW READY TO ENTERTAIN ANY QUESTIONS YOU MAY HAVE. E d' ~~ JEB/cE 4/23/84 M10ll84-0580A-TM18-TM18
~ .. ~ 4 1. } CONSTRUCTION COMP _ETION PROGRAM (CCP) ~ Shut Down Most Bechtel Safety-Related Work e 1, j e Proceed with Nonsafety-Related Work Reorganize CP Co QA Department and Ab' sorb Bechtel QC o ( o ' Verify Past QC Inspections 41 o Form Completion Teams E 'ii - o Status To-Go Work f. Resume and Complete Safety-Related Work o o Third-Party Review j ~ i. .I i. e
s e CCP OPERATIONAL LOClO CA 5 00 i j VERiflCATION OF C0tAPLETED INSPECTIONS PHASE EVALUATION PHASE SYSTEM SYSTEM 2 C0tAPLEil0N TURN-SYSTEM 1 AND RELEASE REVILW RELEASE WORK OVE TESTING 4 A A A A INSTALLAilOrd QA & OC .\\.$ TEST AND INSPECTIOf4 MANAGEMENT STATUS COM.PLET10N TEAMS A GA '& OC ENGINEERING & OA COMPLETION TEAMS
CCP ASSUMPTIONS e 1? QVP pased gn 100'A Reinspe9ti90 2) Rework From Reinspection - Estimated to Require. 8 1.6 x 10 Hours 3) Paperwork to Compte,te Job Estimated as 80,00,0 Con- ~ struction Work Pac! cages (CWPs), 33,000 NCRs and 16,500 FCRs/FCNs ' y 1, i i?i-9 0 4 O 9 6 e S e 4
s BASES FOR SCHEDULE C NFIDENCE t o Soils Activities Defined and Demonstrated. O CCP Program Approved and Implementation Initiated. i o Design Complete ~ Single Plant Completion o Improved Overall Project Planning - y.1; e Additional Senior Staff ./5 o Project Milestones 'o Target Schedule i lt i -}}