ML20105D076
| ML20105D076 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/17/1982 |
| From: | Cook R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Foster J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20105C399 | List: |
| References | |
| FOIA-84-96 NUDOCS 8502090587 | |
| Download: ML20105D076 (1) | |
Text
y e
s-a U'.'s T E D i 7t, f ;
,r N UC L E /,R H E G U Lt. T O R Y f., :, *.'.'/ 'L5 ' ON i. ~~.. '. 5 R E G t0'.' III f
e e
7C9 Hoc!dVELT r.O AD e
o,
,~*.-
o y
Gt. EN EL LYN, lL LINO S t;i37 j
o *..*
Sep'.:-rber 17, 1982 s
.g MEMORANDUM FOR:
1 es E. F:s '_ er, 'seting Lirector, "r i c yo Field Office FROM:
E. J.
Cook, Aenior Aasi de:n: Inspector, Mi dland Site S try,35m.
- . = ~, : =. x
.c. n.. y.:
v.
y _
m On Septerber
.5, 1961, Ms. 5.
5t amirls re q erled, via te ecen~.:nication wid De Midland Site Resident Of fice, dat the Of fice cf Investigation be ade aware of At achr.ent A to " Star. iris Mota or, fcr F artial Initial Decision on ' A s
Adequacy ir. Sonis Aerediai Wc rk Frior tc Cormencement of Fenedial Underpinninc Ex c av a ti : r.s ", da ted Sep tember 4, 1982.
This was discussed with Mr. C. Weil of your office during a site visit on Septerber 15, 1982, whc indicated he was aware of Ms. Stamiris ' Septerber 4, 1982 nction.
As discussed with you on Septerber 17, 1982 by telecorr.unication, I an encic'cing Sta-iris ' Attachment A to her Se,r:eier 4, 1982 motien before the a copy of Ms.
ocarc.
Mc. Stamiris felt that those individuals involved ir. investigating the issue of Consumers Power Company violating the April 30 Soard Order should be rade aware of her compilation of events associated wid the remedial scils wcrk.
I'n 0 0
o i, L e,.
-v
, cor:
r..
Senior Fesident Ir.spect:r Midland Site Resident Of fi ce c: w/ Attachments:
W.
T.
Shafer 8502090587 840517 PDR FOIA RICE 84-96 PDR
~ --
3
,h.
k,5.
3
,j
,,r N
rm.:> rtt nur l
4
'0
,d
[
j_ ~. I'; t d__ d _
'.g,6
/
r
- l,,
l) 2lM__ I__[.- 52 _ _ /
i 7
<, '1. /
%y b,
/Un._ ;
s1 ys
.ct,RP )]'wlW: v( s-;;.
y
\\
g 7 V
U-f.0Li 15! 0 / p, _
i h, T I$_i.TTl l
l I
L. 5. Nuclear hegulatory Comission 3L lF I LE I h_('
Ir. the >btter cf Docket Nos.
' Pro. Midland 0:an 50-329 01
" nits 1 L 2 SC--33u OL FE C Cr:I TF1 ATOMIC SAFETY AND LICENSING SOARD STAMIRIS E! ION FOE PALTI AL INITI AL DECISION ON QA ADEQUACY IN SOILS EE'EDI AL 'n'ORK FEIOE TO COMJENCEFENT OF REFEDI *.L L3DEEMNNING EXCAVATIONS 9/4/E2 Due to the reperted voilations of established QA/QC procedures f or soils rere-dial work, the failure tc institutc proper QA/QC procedures for that work, the rerrted violations of NRC/CPC agreerents and of the Boards April 30, 1982 Order regarding scils renedial work; the question of Cor.sumer's QA adequacy with respect te soils cust be resolved by this Scard prior to the co=ence:ent of excavations f or reredial underpinnings if public health and safety is to be protected.
ISSUES EEF0EE THE BOARD All parties in the OM-CL proceeding have addressed QA beyond soils due to the terms of the e /5 /M OA Stipulation. since the NRC based their reasonable assurance of QA adequacy (Stipulation part 3) upon evaluation of the period from December 6,1979 to June 1,1981 during which little soils work was occuring.
Yet the more narrow question of QA adequacy with respect to soils is the urgent question presently before this board.
This question, originally raised in the December 6,1979 Order Modifying Construction Fermits, must now be resolved as soon as possible in order to determine "the degree to which and the manner in which soils related construc-tion activities (particularly remedial actions) will be permitted to continue"I IASI.E 4/30/82. Order, p. 9 o n Jn J j ~,/
- SEP, 9A
" y ( / s?fD $O0 r '
w
-~.....
3 2
.' tSase Board considerations are to retain viabic.
The Board states in its April 30, 1952 Order (p. 7) that they have not yet cr.:nieted their review of the second haaring issue "ie whether and, if so, to what e r h ni the Skidification (Tder should be sustained."
This key issue is described t.y Consurer's as "whether the safety issues (r.iving rise to the f acts set forth in part II of the fxidification Order) have been resolved so that the QA prograr with re s;ect tc soils is now being preperly inpienented and there is reasonable assurance suc':.1:pienentaticn will continue thrctgh the construction process."',
The Decer.ber 6,1979 Modification Order sought prohibition of soils activities until ths e,'uestien of QA adequacy with res;+ct to soils and the-related safety ques-tions were resolved.
These QA adequacy / safety questions retain unresolved in late 1982, yet the complex and dif ficult' soils remedial work which the Order sought to prohibit has been permitted to begin in the interic due to the wording of the Order.
The unresc1ved safety questions asrociated with the issue of soils QA adequacy, of renewed concern due to the course of recent 3, must be considered before events i
the presently projected December 1982 QA hearing dates or they will, by that time, become moot questions as the soils remedial work in question will be irrevokably underway.4 For the imminent underpinning excavation work will certainly commit the applicant to this course of remedial actions once it is begun, in a canner unlike the other prerecuisite remedial steps previously approved by the Board.
As most recently and simply refined, the "QA* question. before us is whether the soils reredial work will be properly implemented (as opposed to the " technical" question of whether that work is theoretically feasible).5 A hearing conducted
~
2 CPC findings, p. 36, 3see attachrent A.
'During the 8-14-82 site - tour we were informed that the excavation work was expected to begin within a week as the baseline data measurements had been cocpleted.
On 9-1-82 R. Ross landsman inforned me the excavations had not yet begun.
5 Judge 5echhoefer's description in 9-1-82 conference call.
s.,
1 o.
-9 3
tc d<. terr.ine whether the soils reyedial wcrk is likely to be properly inplenented can only be reaninC ul if conducted !efore that work takes place.
f
, iTo await a December QA hearinE and an overall (QA adequacy-technical adequacy) decision in 1983 as presently projected, would leave us with the untenable situa-tion of putting the answet (ie. continuation of soils rer.edial work) before the question (whether it is likely to be perforced safely).
In so doing, the Applicant's scheduliLC needs woulo be placed ahead of public health and safety needs.
Although soils re.tedial work has been approved prior to resolution of the related safety questions before in this proceeding, it has up till now been of a relatively
' miner nature and has been approved in this f ashion because it did not constitute an irreversible comr.itrent to the soils remedial' work to fo110w.6 However the very nature of the excavation work and the proportions of this underpinning job certainly qualify it as the major task of the soils remedial work at issue, from which there is no going back.
Therefore, to allow the underpinning excavation work to go for-ward prior to the resolution of *the related QA/ safety questions by this Board, would be tantamount to prejudging the entire proceeding.
The scheduling needs of Consumer's Power Co, no matter how pressing, cannot be placed ahead of the unresolved questions affecting public health and safety.
In a case involving the Midland plant, an Appeal Board affirmed "under the Atomic Energy Act, the Co=nission responsibility is to protect the public health and safety, the pocket >ooks of owners or customers of electric utility. investors."I not This Board has listened to CPC and NRC witnesses discuss the technical feasa-bility and thecretical adequacy of the underpinning reredial work, but that has no bearing upon the practical implementation of that work.
The Board, in fact, found the QA' aspects of the proposed underpinning work to be conspicuously lacking 8
- 7/7/81 tr. 1133-1137
^
4 7AIAB 458, 2/14/78, 7 NRC 4 p. 476, CPC its 1 and 2, Midland.
BASLB 2/5/82 Memo, tr. 7122-7128 r-
" g 3..
. f.,
,,c,g,g.,
.g,..
g [.
p.
I
.-;......n..--.-
~ - -
~ ~ * <
4 and their underpinning QA questions remain unresolved today.
To have assurance that any plans will be carried out safely, this boaYd nust first establish that there, is an effective QA pr ogram to accomplish thore plans.
\\'ARIOUS PE OPOSED HEARING PLANS Unlike the af ter-the-fact December QA hearings currently envisioned, the pre-excavation QA hearings I propose would a11ow fair consideration of ultimate hearint outecres and cptions to all parties.
I would have tne Loard consider the now urgent QA question of the December 6 Ceder, as formulated by Consumer's, "whether the safety issues... have 1+en resolved so that the QA prograt with res;ect to soils is now being properly implerented and there is reasonable assurance such implenentation will continue through the construction process," particularly the soils renedial work at handl An expedited partial initial decision in the Applicant's favor on the soils renedial aspect of QA adequacy could allow the soils remedial work to go forward with only slight delay and with the added assurance that the public safety questions associated with the soils reredial work had first been resolved.
Consurer's themselves sought this assurance for the public in their 9/2/81 Motion for an Initial Partial QA Decision.
The urgency of the QA question which I assert is reflected in the public state-ments of Mr. Keppler at the recent SALP neetings, hegarding the soils renedial work he said, " clearly sorething is wrong, its not proceeding as it should proceed."
At this point, he said, "I have to wonder--can Consumer's do the job?"
He added that NRC was "n'ot comfortable about where we stand is an agency" and that he person-ally felt "very uneasy" about his 1981 testimony fore the ASLE.9 As a result of the negative SALP rating, anc ne continuation of soi1s retedial work problems up to that day (6/21/82), Mr. 'Keppler announced the formation of a special inspection team to oversee Midland's work. Shortly thereafter he called 9
5/21/32 SALP teeting, statements as reported in 6/22/82 Pldland Daily News.
~
\\A ky,.f,
.Z.[ s c
a _..-
= - - - -
7-9 5
for a reopening of the OM-OL h(arings to reconsider his QA reasonable assurance testimony.
Mr. Keppler's testimony was expected by late August and "Mr. Paton advTsed that there were sutstantial differences of opinion between the Applicant and.the Staf f regarding certain f actual ::aterial."IO These reopened QA hearings, as.first entertained, woald have properly trought the facts and evidence regarding the NRC-Consurer's differences before the board for their judgerent and resolution.
But by July 12,19 2 a drar.atic chance in the form and scope of the reopened QA hearings was announced by NRC counsel, Mr. Faton, in a conference call on the subject. "Tne Staff now advised that
.t.
Keppler wished to confer with certain high-level NRC officials, formulate suggestions with respect to Consuter's QA/QC pro 6:a::., and present those suggestions to high-level ~Consurer's officials (Selby and Cook). According to the Staff, if Consuner's accepted the NP.C suggestions-(to which CPC counsel indicated there would likely be "a very quick turn-around") then the f actual questions now in dispute between Consumer's and the Staff would becone of lesser importance.
'Ihe Staff and Consurer's could then file testimony (perhaps simultaneously) concerning the proposed QA/QC solutions."Il In the hopes of avoiding lengthy contested hearingsi and perhaps as the only way to allow construction-to proceed at the plant, the NRC, Consurer's, and the Board, are willing to accept hearings based once again on subjective judgerents and concluscry statenents about future QA adequacy and " proposed QA/QC solutions."
In 1981, the hearings held to resolve the QA/ safety questions of part III.
of the December 6,1979 Order regardin6 "the adequacy of the remedial action to correct the deficiencies in the soil construction under and around safety related structures,"12 were necessarily conducted in the abstract future form, sin ~ce that OASLL 7/7/82 remo, p. 3.
11ASLB 7/13/82 memo, p. 2.
1212/6/79 Order, p. 4.
., i. 9, -.p 3 0
.; n.
!ccun.
But the question of QA adequacy with respect to soils reroditi wori :.a s not actions, which is 14 fore the Board in 1962, is in the very real present tense.
.Se ilt Vork has recured and so have the related QA problems..Once again we i,< v[ ' c f ore us evidence;of the state of Qi with respect to soils.
This evidence is ' available in the form of Cpl Appendix E violations, inspection reports, noncon-f ernance reports, _ audit -reports and findincs, stop werk reports,and their manner of r ron. tion.
We have nc need in 19E2 tc loot to thc future to answer the question
~
cf soils QA adequacy--and whether the soils reredial work is likely to procedt-rat ely and caref ully according to regulations. We can consider all the relev:r.t
'.. a nce tr.: now n'.
- : - r: "
rencdia: ver! !'ir.; 7:rrerly intlere.it.
~
and is Consuncr's QA/Q1 impler:cr.tation effective in caintaining the recui-si te standardt cf safct) a:.d ;;9r.
c.irt in this wc k?
To ecndutt Q; hstring
.stcad uper reascnatic assurance for thc fut-r.
a ccording tc high level QA/QC irprevc:.snt plans and sclutions, af ter tne worh in que stion was irrevokably underway, would bc to take a neckery cf the serious pub-lic safety questions at issue it. inis proceeding.
Fcr tnere is no futurc ic!. nc; tira f or QA inprovenent when thi ;1 tnt it. alr.c:t finished and - the rtilt rcr c : i L'.
werk is underway.
The QA deficiencies which have plagued this plant since the ear 13 seventies O
have been repeatedly condence and oetriochcd on the basis of the prenire cf rcie;-
raticn, and perceived improve ents v.ict. hzvc E11 cued the NRC te maintain rcerenadic assurance for the future time and time again.13 When the future comes to pass
( as it has in this proceeding) only te dispreve the assurances giver. inLpart 3 of 6/5/81 QA Stipulation, the NRC n2 rely f:rectr the past and present,.and coves on to the future once more.
In the case bef ore us nos, the continued inadequacy and deficiencies of ' Con-
)
I surer's QA -as documented in the 1950-81 SA'_1 evaluation and subsequent I & E reports; l
r i
~"ht ct cry p. 9-10, ASLB 4/30/ El crd; r.
I l
L
2
.,_...a..._..
_._1____.
.._._..i.
7 as addressed by the Board in their 4/30/82 Order and 7/7/82 Memorandum; as discussed in the 4/15/82 Spessard memo; as addressed by Mr. Seppler as recently as 6/21/82;
- u..
as. reflected in the continuing record of NRC and audit findings regarding soils; e-and as discussed in the 8/20/82 Landsman remo, cannot be adequately resolved with a new QA Stipulation drawn up to reduce the importance of " factual questions now in dispute" (7/13/25 remo) by shif ting the focus fro.- the present to the future.
Tnt Boards directive in its 7/13/82 menc to " include prior dif ferences" arid their 4
nenner of resolution in prepared testimony, could only be of value if the work in question awaited the consideration of those differences.
The tire has co.e for the NRC to follow the plan Mr. Keppler announced at the November 1980 SALP reeting--that is to lay out til the facts before the Board (leav-ing conclusions aside) and let them decide the increasingly difficult question *
.:he ther QA is still defensible?" *Ihis intention similarly repeated by Mr. Keppler at the close of the 6/21/82 SALP reeting would have been ret in the reopened QA hearings if they had gone forv'ard as originally planned (contested QA proceedings between the Staff and the Applicant following August testimony).
But that intent is lost in the new hearing plans (7/13/82 remo).
The events surrounding the August 12, 1982 stop work as described in the S/20/S2 Landsman remo on the violation of the ASLI April 30th Order, make a contested hearing all the more ir. perative now. It is the intent of this motion to seek a 4
hearing, based on a review of all the evidence before us concerning the state of QA adequacy today, as opposed to hearing statements about expected icprovements, CPC com ittnents, or NRC suggested "QA/QC solutions" for Consurer's, as anticipated in the 7/13/82 Board Memorandum.
It is the intent of this cotion that he'arings on the narrov question of QA adequacy with res;ect to soils, must precede the soils reredial work (ie. underpinning excavations) they seek to consider, if public l
health and safety is to be protected.
O
..:...q.
w.;:...
.g g v;.
y
~ -.
.-._w E
RESPONSIBILITY TO DECIDE ISSt'ES OF THIS WOCEEDING LIES WITH ASLE, NOT NRC STAFF hT.C regulations provide that "a Licensing Board may not delegate its obliga-tio.to decide significant issues to the (NRC) Staff'.'14 It must follow then that neither should the ST:C take upon itself the decision of the key."A/ safety question of this proceeding in the forn of a reasonable assurance judgement.
Such conclusory judgements must be left to the Board.
The parties are obliged to bring forward all the relevant evidence on the question of QA adequacy tc: the Board f or their decision, upon completion of the review of that evidence.
The bur-den of decidinS the question of QA adequacy in this case should not and does not lie with one party (the NRC) or one person (Mr. Keppler).
Tne borden of proof
'of QA adequacy lies with the Applicant. And the continuation of the soils remedial work,particularly the irreversible underpinning excavation steps, cannot be per-mitted (according to the terms of the December 6,1979 Order and the NRC system of regulations) in the absence of such a finding of QA adequacy by this Board.
The Board has not yet resolved "whether, and if so, to what extent the Decer.ber 6 Order will be sustained" (as stated in its April 30, 1980 Order) in order to determine "the degree to which and the canner in which soils related construction activities (and particularly the remedial actions) will be permitted to continue."15 Yet the pcesent course of action regarding soils remedial work at the plant, leaves the implerentation of this hearing issue, and its underlying decision, en-tirely up to the NRC staff.
This becomes particul rly unfair when we approach the a
irreversible underpinning excavations immediately~ at hand, without the resolution of the essential QA safety questions related to that work. It is unfair to all parties and to the public dependent on this hearing process.
14NRC TTactice and ITocedure Digent, Suppl. I to Digest 2, February 1980 p.
12; Public Service of Indiana, Marble Hill 1 and 2, AIAB 461, 7 NRC, 313-318 (1978).
15ASLB 4/30/80 Order, p. 7, 9 O
< 0 Qha,.
- 4..,7x.g., f, -
.p:
s
.t
-n_--
9 Because the NRC has ret with the Applicant and progressed in their evaluation of the technical and theoretical adequacy of the soils remedial fixes (prir.arily an NR R responsibility), it does not mean that the NRC has simultaneously progressed in their approval of the practical implerentation of the soils reredial work (pri-marily a Region III, I & E responsibility) as related to the question of QA ade-q ua cy.
In fact, the I & E as.sessment of QA adequacy appears to have regressed during the course of the soils reredial work.
Implerentation of the reredial underpinning excavation work cannot proceed on its theore tical feasability alone.
Mr. Landsman and the other rembers of the I & E Staff closest to the reredial work, are attempting to do a conscientious and careful job of determining which remedial work should go forward, nevertheless they should not bear the burden of deciding the outcome of the complex and difficult QA/ safety issues of this proceeding.
Yet this is the practical reality of the pre-sent situation.
The flow of NRC-CPC documents, the board notifications, and memos from Region III indicate a need, for Board attention and help in resolving these difficult questions.
EXEDIENCE AND SAFETY RESULT FROM.
PARTIAL INITIAL DECISION ON QA FRIOR TO EXCAVATION In seeking a partial initial decision on QA, Consurer's asserted that "an early resolution of (QA). issues will benefit the public by assuring that the remedial work, when auth cized, can begin promptly in accordance with the decision...If the Board issues findings in the Applicant's favor, the applicant can confidently direct resources to maintaining and improving its QA program and its implementation.
If the decision outlines further requirerents the applicant must meet, then resources can irrediately be directed toward accomplishing then so that any authorized reme-dial work can begin procptly and in accordance with the Board's dictates..16 Thus the Applicant sought the Board's explicit prior approval for soils reme-dial actions 'in the form of a partial initial QA decisione, That' motion for a partial
>.c.
i
, -[*... ' 16CPC.9/2/81 tion, p',5. -
h%. M f 5.[h,$ y.,f;, Nag.[fg h.4,;. 4;d%f'*., ~
2 W
9 9
_ -_ ~.. _
..",2.
. -.. - - -. ~
~
10 initial decision. on QA prior to implerentation of the soils remedial work,which was granted by the Board in 1981, is precisely the, motion I am presenting today.
1-because of significant new questions concerning QA adequacy which have arisen since 1951, the motion is all the more compelling today. As cited by the Applicant in the Doucias Fcint Case, an early decision benefits the public by obviating
" wasteful expenditures of time and roney".
and "by alerting the Applicant pro:ptly" of the needs which must be met to ensure plant safety.17 Consurer's add s. " Sir-i-larly here, a decision at a time early enough for the parties to effectively anti-cipate and ameliorate any concerns rather than retroactively take them into account n.akes the resultant benefit to the public (not just the Applicant) manifest '*lE Tne fact that significant safety questions arose necessitating a reopening of the record on QA, only serves to strengthen the foregoing argunents presented by the Applicant. Awaiting a full (technical adequacy-QA adequacy) decision in 1983 i
l as discussed during the August prehearing conference would be acceptaDie.,.perhaps even preferable in terms of an integrated approach, if the remedial underpinning 1
excavation work were not permitted to proceed in the interim.
But in the interest of expedience, it makes more sense to single out the narrowest QA issues (which will still proteu public health and safety considerations) essential for resolu-1 tion prior to implerentation of the remedial underpinning excavations. Other QA and technical issues can be f eres:alled without compromising safety.
j According to rr.y hearing propos.1, the tire and effort spent working out a new QA agreecent between the Staff snd the Applicant would be saved. The contested hearing could then go f orward sooner The eventual QA hearings will probably be about the sane length whether or 1.ot an agreement between NRC and CPC is reached as past QA problems and differences will be conridered by intervenors with or 17CPC 9/2/81 motion, p. 6.
t 18 Ibid p. 6.
k 4 *.
4
- ',. I j
A,,
E',
k, I -
- ~e,g i
- g e.
,i
-....m_-__._
11 without Staff support.
Therefore not only public safety, but expedience is served by the partial inYrial decision I seek regarding the QA adequacy of soils reredial work.
PATTERN OF FROBLEMS AND VIOLATIONS IN SOILS REMEDI AL WORK In intrcducing this notion, I refered to violations of QA/QC procedures, failure to institute proper QA/QC procedures, and repcrted violations of NRC/CPC agreecents and the Board's April 30 Order, as bases for requesting a partial initial QA decision on soil related issues, prior to excavation work.9 l
This pattern of problems and violations in soils work extends from the crigi-nal QA breakdown of the December 6,1979 Order, to the present day.
When Consurer.'s rer.oved the preload at the Diesel Generator Building without NRC concurrence, it was described as a rcisunderstanding of the NRC position.
"Ihe failure of the NRC to intercede was interpreted as approval.19" When Consurer's continued soils reredial work (which would have been pro-hibited by the December 6 Order) beyond their voluntary soils workstop, at the borated Water Storage Tanks, near the Service Water Structure, and in excavations 20 at the Diesel Generator Building it was called a differing interpretation of soils reredial work as defined in the December 6 Order, not a violation of that commitrent.
When Consurer's proceeds without prior NRC approval in soils remedial work involving piping,21 instrurentation,22 drilling,23 and excavating,24 (and in some 19see attachrent A.
19atr. M33, 1817 - 8 207/7/81, tr. Ill 7,, p.Jt.- 12, 21tr. 7784-86a.
224/15/82 Spessard cemo.
23items 3, 4, 5,12,13,14, attachment A.
~
248/20/82 Landsman' memo; I & E report 62-03
. 'i
- f..*h. uh!.bdQ'h,%,,',4 p:
- yJg,,..; 7
..gf, glh, :. ?,./} l.. J,..!;,.
12 cases proceeds with this work beyond their own stopwork directives) these inci-dents are terred miscommunications or misunderstandings caused by varying inter-
~
pretation's of adrecrents.
Two investigations have been launched by Region III on the subject of Consumer's "possible misleading staterents" and "possible violations of the Board's April 30, 1982 Order" involving soils recedial work.25
~
5 At sore tire we must at least consider the possibility that all these events i
h weren't really misunderstandings at all, but were conscious violations of agree-
<A
-JNI rents and calculated risks undertaken because of pressure to push ahead and because N
'.7 of an expectation that nothing would be done about it anyway.
H W
If these possibilities are not even considered, or the results of the Region III or Office of Investigation probes are not considered by this Board before the underpinning excavations att premitted to begin, then they might, as well be dis-missed altogether.
For once again, inaction or failure to intercede would be inter-
~
preted by Consumer's as approt*al of the status quo and the soils re cedial work will continue in the sane manner as it has thus far proceeded.
The concerns of the Region III staff, Mr. Keppler, and this Board (in their April 30th Order) about Consurer's ability or willingness to carry out proper QA on their own initiative in the soils reredial work must be addressed now as 26 it becores increasingly apparant from the course of recent events that the " Staff consultation and approval" nethod of handling soils remedial work which the Board set forth in their April 30th Order, is not succeeding in attaining the proper care and conservatism in the soils renedial work. '.
The reanner in which the soils renedial events 27 took place and whether these events dc or do not constitute violations of Consumer's own, the NRC, or Board 254/15/82 Spessard nemo; 3/20/82 Inds=an remo.
26see,attachrent A.
27Ibid.
a.
, *** l f; ~ *
- '$' j',
- '; *f
- )f'* *
,q
- * *,,}, s s
e
- p,.
13
~'.
directives, must be resolved now in an attempt to restore the necessary board, NRC and public assurance about the adequacy of the soils reredial work.
1hstever the underlying reason,whether c.: not ir:-niicr.al. unsafe and uneenser-vative workranship cannot be tolerated in the extrerely difficult and "very conplex" V:;.inninc operaticns which as Judge Harbour cautioned "have the pc:ential for r aduzing irreversible danage in safety class structures."2E
/: the outset c.f this proceeding, the board c.)sidered the nece ssity of pro-irint cc r:ain s:ils rc:. diti wcrl. te f c>:2 cc:rl.rist. cf their review and final
$s
..r.cr.--
2n s ctr.r :::at en was Lar::. _p e:. cr e. :.ua t or. c:. "the adequacy and v,
- ht ; c:ential safety impact of ongoing construe:ic: ac tivities!" If petential f or
~
,;thititing soils re edial work by the..ird E - '. :. at the outsc: cf Inis ;rt-c-;eding, it must also be valid today.
u _ _ a. c.-
Interrenor sutnits that an ini:i al p..rtiti ce:.r :
- ;. with respect tc soils renedial work, prior to cor.rencefjent of the reredial underpinning excava:iers is the 0:it y hearir.; epticr able to serve public heal:t 2:.
- .fety ir a:erts.:
this tire.
The recent events givint rise tc safety concerns and nee'.srititing 28tr. 7126 ar.d 2 /5/E2 board nota.
o
'- January El prohcaring cor.ference questio., discussed ;. 1C 4/30/32 CTder.
30./20/F2 Ec rd Ceder p.10, rr. 754-55.
7
14 a reopening of the record on QA, which have occured in the implementation of soils reredial work, cannot te put off until the recedial work in question is completed or irrevokably underway. The resolution of the December 6,1979 soils QA adequacy question is im;erative now.
For these reasons, as discus sed in the motion, intervenor Stamiris moves that the board 1.
Place a temperary work hold on underpinning excavatior, work, pending Scerd assurance of QA adequacy with respect to soils recedial work.
4 2
Request that the office of Investigation expedite their investiEation of soils reredial events and possible violations of the Board's April 30 Order, in the interest of unusual safety and scheduling needs at
- Midland, i
3.
Direct all parties to begir. preparing testimony at once on the ques-I tion of soils remedial QA adequacy, based upon evidence currently i
r available.
4 1
4 Establish the earliest possible hearing dates for resolution of the
- soils remedial QA adequacy issues prior to commencement of underpin-4 ning excavations.
Respectfully Submitted, M
]
Earbara Stamiris 5795 North River Road cc. ASIJ nembers Freeland, MI 48623 R' Taton, NRC
{
H. Miller, CPC Secretary, NRC
{
1 i
e
AT1 ACH.*-ENT A CHRONOLOGICAL LISTING OF SOILS-REFEDI AL EVENTS I. This listing provides the basis for my assertions about ongoing problems and violations in the soils terr dial work (par.1) on which this motion is based.
In listing these events, I intenc only to represent a brief showing of issues relevent to the hearings I propose--issues which represent open questions and dif-fering viewpoints rire for adjudication.
As such, the following soil related QA events or reports warrant ASLE consider-ation prior to continuation of the soils reredial work.? Some of these docunents a
reveal significant inconsistancies which cust be resolved in order to afford an accurate understanding of the events they portray, 1.
10/13/81, QAE F120 lack of Q procedures for FVIF and control tower supports (drilling and torquing of bolts) 2.
12/15/E1 closeout, audit justification of well fine monitoring by M01-241-02 finding 2 vront Level inspector (CPC exh. 23) 3.
2 /2 /82, NCE M01-4-2-00E 40-foot hole drilled into Q soils 4
2/26/E2 incident 2 45-foot boring holes drilled into Q soils 3/6/ 82, NCE M01-9-2-036 5.
3/4/E2 incident improper drilling procedures at freezewall 3/5/ E2 NCF. M01-9-2-039 involving use of grout and hole cave-in 6
2/35 and 3/82 Inspection Criterion V violation:
4 instinces, involv-Report 82 - 05 ing unapproved actions and lack of acceptance criteria in soils renedial work. Deviation:
inadequately qualified personnel in civil /
soils 7.
3/19/82 Inspection Criterion II and X violations:
involving Report 82-06 underpinning instrurentation
- I do not have 1981 inspection reports 81-13 thru 61-20, they should be considered to che.
extent they contain significant soils remedial information'.
(1 will supplement later)
NCRS involving cables should be considered to the extent they involve soils remedial work (QAR F180, M01-9-2-097, -098, -099),
-}
'~
'8.
'4 /15/62 4/9/82 Sressard memo on QA inadequacy in board Notice 82 soils recedial work and possibic mislead-ing statements
- 9. _ 4 /2 0/82 Category 3 rating in soils e' valuation, 1980-S1 SALP report,
Keppler statements at 4/26/82 and 6/21/82 Related Keppler statenents and SALP meetings, formation of Special Inspec-events tion team (6/21/82)
~y.
10.'
4/12 /23 Insrection Criterion V violation:
3 instances involv-Eeport 62-03 ing outstanding FCRS, BWST undermining unauthorized field changes 11, 4/21/S2 NCE unauthorized excavation of duct bank under-M01-9-2-051 mines BWST valvepit 12.
4/2E/82 nonconforming drilling by Mergentime and ve rbal s t opwor k lack of bechtel control Miller to Davis letter 13, 4/29/82 incident nonconforming drilling, hitting ductbank bechtel NCR 4199 and damaging electrical conduit and cables, no hold tags applied until 5/10/82 14 5/19/82 incident drilling of obs, well 4 encountered void Dral Communic. Record at 10:30 A.M., resumption of drilling OCR 016E on well la allowed till 2:40 to finish job despite stop work FSW-22 15.
5/19/82 issued at 1:00, 1:15 or 1:30 P.M/ (accord-Stepwork Order FSW-22 ing to various times given) af ter Landsman and Cook inspected void. Stopwork written retroactive to 4/28/82 16.
5/20/82 SCRE-51 55e Safety Reportability Evaluation of (attached to 5/26/82 5/19 void: Extent of void doesn't appear Bird to Hughes letter to impact any safety rel.
1 structures or utilities.
~
'7 5/21/82 Hergentime bypassed MPQAD hold points for NCE MDI-4-2-062 weld inspections, no part corrective action 16.
5/24-27/82 conditional release to fill 5/19 void, Nonconforming material Release and related documents attached to 6/30/82 Paton to Marshall letter 19, 6/25/82 letter Inconsistancies exist between statements Brunner to Board in this letter and the referenced supporting
- d ocuments.
(bechtel NCR 4199 is dated 4/29/82--it is said to have prompted a
^
4/28/82 Stopwork Order.) There is no record of ~ the 4/24/82 incident mentioned.
The FSW 22 Stopwork Order was actually issued on 5/19/82 after void incident.
,g.j...,..,,,,,:/
,.,,. g,., g j; Q J.y., y.. fai,.f., -
t-
'. g ;. i -
a,, '... t y
1
i i
20 6/7-9/82 Audit finds civil soils group interface on soils M01-206 -2 reredial work acceptable x
21.' 6/22/82 violations involving grouting of underpin-i Ste; work Orde r FSW-23 ning bracke ts, MPQAD verbal stor, work at 12:15, bu: work continued till 2:35 when t rackets we re grouted i
22.
7/7/82 grout improperly tixed for Turbine wall NCh M0'.-4-2-084 bracket i
23, 7/8/82,
. soue,ht advice (and possible relief) on QAR F187 necessity of periodic field tests 4
24 7/9/82 sought interpretation (and possible relief)
QAR F186 of sample point depth in well 25.
7/21/82 requests explanation of "71 individual QAR 189 deficiencies" on IPIN's (Inprocess Inspec-tion Notices) between 7/8/82 and 7/19/82 i
26.
8/17/82 letter QA orEanization change, J. Meisenheirer Brunner to board as QA Supt. for Eeredial Soils Work i
27, 8/20/82 8/24 Landsman memo on violation of April 30
~
Keppler to Fitzgerald board Order, related Stopwork'(8/12/82)
Investigation Request events, new communications vehicle and l
and related' events subsequent application, scope and purpose of investigation sought i
}
l l
l 3
}
4 5
e i
.a n
p
/
- 7 y St&=N
, f::qy '
,, [.....
James W Cook 3
- s akay.*sa)
Vice President - Projects Engsneenng y
j
,,/
and Construction
~
'~
o.n.?.: ovvi : to4s w i Pern.is no.d. 2.cm.on, ui 4e201 + tai 7) 7sso4s3 r
November 3, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 PROPOSED ORGANIZATIONAL MODIFICATION OF THE NUCLEAR ACTIVITIES DEPARTMENT FILE: 0505.813 SERIAL: 19400
Reference:
July 20, 1982 Letter to H R Denton from J W Cook, Serial 17966 Meetings were held between Consumers Power Company (CP Co)and the NRC Staff on October 14 and 20, 1982 to discuss the Independent Safety Engineering Group (ISEG) concept described in NUREG-0737, Item I.B.I.2.
.This item is presently listed as confirmatory on the Midland docket.
As a result of these meetings, CP Co is sending this letter to clarify the information submitted in th'e reference letter to H R Denton.
Attached is a revised copy of Appendix A, Organization Modifications of the Nuclear Activities Department and the revirions to Appendix B, Draft Technical Specifications as changed from the reference letter to H R Denton. The Draft Technical Specifiction sheets enclosed have been revised in general.
The Nuclear Activities Plant Organization (NAPO) described in Appendices A and B will be in place with standards and procedures at least 90 days prior to fuel load.
A submittal similar to Appendix A will also be included with the Big Rock Point and Palisades technical specification change requests which will be entered on their respective dockets for NRC approval under separate cover.
The response to NUREG-0737, I.B.1.2, in the Midland FSAR will be updated to address the modified organization after NRC approval is received.
oc1082-1386a131 m.
._ _ ]h) h kdV
2 This letter should provide the information needed,to close the ISEG issue on the Midland docket.
{
JWC/KJT/jvm CC DSBrinkman, US NRC RJCook, Midland Resident Inspector RHernan, US NRC DBMiller, Midland Construction (3)
RWHuston, Washington JMPeschel, US NRC Region 3 oc1082-1386a131
4 e
CONSUMERSPOWERCOMPANY i
'j -
Midland Units I and 2 4
Docket No 50-329, 50-330 i
Letter Serial 19400 Dated November 3, 1982 I
At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits additional information pertaining to the Independent Safety Engineering Group concept described in NUREG-0737, I.B.I.2.
CONSUMERS POWER COMPANY By
/s/ J W Cook J W Cook, Vice President Projects, Engineering and Construction Sworn and subscribed before me this 8 day of November. 1982 1
/s/ Barbara P Townsend 1
Notary Public Jackson County, Michigan My Commission Expires September 8, 198k i
f I
}
l t
l l
l oc1082-1386a131 I
!'4 A
i 1
4 1
~ s,.
a i
4 t
i, 4
4 i
l
,1 f.
APPENDIX A f
4 ORGANIZATIONAL MODIFICATION h
j OF THE NUCLEAR ACTIVITIES DEPARTMENT i
4 1
i s
i i
1 1
i-4 2
e i
i i
l l
\\
i mi1082-1387b131 Rev 1 l
1
-,e=
a
-+m~v
-s,
,,e
-,e w w -
re-,-e-+,-
=
c--rw--
---,r---e.
+--*wev--
r*--r
=w,e e =- --- +
e-
-a<---
,. -ww-
-~--*---,-v
- - - +
I 4
o 1
APPENDIX A Oraanizational Modification of the Nuclear Activities Department A
CP Co proposes to modify its organization by creating a new department titled Nuclear Activities Plant Organization (NAPO) and broadening the responsibili-ties of the Plant Review Committee (PRC) and Safety and Audit Review Board (SARB, which will be renamed the Nuclear Safety Board - NSB). This new organization will involve the General Office and all three CP Co nuclear power plant sites (Midland, Palisades and Big Rock Point). NAPO will perform or l
assure that the Independent Safety Engineering Group (ISEG) functions described in NUREG-0737, Item I.B.I.2, will be accomplished. The details of I
hog this will be. accomplished will be contained in a procedure or standard l
that will be available 90 days before fuel load. NAPO will be responsible to j
report to the NSB on significant issues and findings. Integrating these functions in this coordinated manner will improve the overall safety of the plant through more effective utilization of experienced personnel.
The NAPO group will perform independent safety appraisals, perform plant trending and safety reviews on request, and act as a technical resource to the PRC and NSB. This will result in elevating the PRC and NSB from a level of issue identifiers to.one of issue resolvers and also allow the senior and experienced managers who serve on these committees to better utilize their i
talents addressing key safety issues.
In addition, the full-time availability of NAPO will permit safety reviews to be conducted in more detail than is now j
possible using part-time PRC members.
The Vice-President of Nuclear Operations, Executive Director of Nuclear.
Activities and Plant Managers can request NAPO to provide specialized techni-cal support for problem resolution or General Office in,terface. NAPO will also interface with QA but not become an integral part of that organization.
At present, CP Co does not plan on integrating STA's into the NAPO group but certain review functions may require STA interaction.
Since NAPO will be a single entity, individuals with a specific expertise vill l
be available to support reviews at all sites regardless of their permanent i
home location. This will promote a transfer of information between the sites.
It is now projected that the ultimate staffing for the NAPO group will be I
approximately 10 professional people at Midland, 8 at Palisades, I at Big Rock Point and 3 in the General Office. There will also be additional technical /
t.
secretarial help to assist them. NAPO will report off-site to the Vice President of Nuclear Operations through the Executive Director of Nuclear Activities and is therefore independent of direct line responsibility for operating the plant. Independence from plant management will be fostered by l
development of career paths not dependent on plant management. NAPO will increase the available technical expertise located at the plant sites and permit additional systematic assessment of plant activities.
i l'
s mi1082-1387a131 Rev 1 1
I
-ai-w, t
a 9
4 1
APPENDIX H DRAIT MIDLAND TECHNICAL SPECIFICATIONS i
a e
T 1
I 1
Rev 1 4
' ' - - - ~ -. - - -.. ~ _.
2 ij,. ;,t
?
~ ~,
l
' ' ' ' ' 2 HIDLAND 1 & 2 s __
~~ %r i
ADMINISTRATIVE CONTROLS 16.6.1 RESPONSIBILITY i
16.6.1.1 The Plant General Manager shall be responsible for overall plant opera-tion and shall delegate in writing the succession to this responsibility during his absence.
16.6.1.2 The Shift Sup.ervisor (or during his absence from the control room, a designated individual) shall be responsible for the control room command function.
A Management directive to this effect, signed by the Vice President - Nuclear Operations, shall be reissued to all station personnel on an annual basis.
16.6.2 ORGANIZATION 0FFSITE 16.6.2.1 The offsite or'ganization for plant management and technical support shall be as shown in Figure 16.6.2-1.
PLANT STAFF 16.6.2.2 The plant organization shall be as shown in Figure 16.6.2-2 and:
a.
Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 16.6.2-1.
b.
At least one licensed Reactor Operator shall be in the control room when fuel is in the reactor.
In addition, while either unit is in MODE 1, 2, 3 or 4, at least one licensed Senior Reactor Operator shall be in the control room.
An individual qualified in radiation protection procedures shall be c.
on site when fuel is in the reactor.*
d.
All CORE ALTERATIONS, after the initial fuel loading, shall either be performed by a licensed Reactor Operator under the general super-vision of a Senior Reactor Operator or a nonlicensed operator di-rectly supervised by a licensed Senior Reactor Operator (or Senior Operator Limited to Fuel Handling) who has no other concurrent re-sponsibilities during this operation.
e.
A Fire Brigade of at least 5 members shall be maintained on site at all times.* The Fire Brigade shall neither include 3 members of the minimum shift ' crew necessary for safe shutdown of the unit nor any
- Radiation protection coverage and Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence provided immediate action is taken to restore the i
minimum requirements.
I nul082-0507a-43-48 16.6-1 PROPOSED /MID
~
l 10-29-82
a,.
~
ADMINIS'IltATIVE CONTROLS
. personnel required for other essential functions during a fire emergency.
16.6.2.'l NUCLEAR ACTIVITIES PLANT ORGANIZATION (NAPO)
FUNCTION 16.6.2.3.1 The NAPO shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which cay indicate areas for improving plant safety. The organization shall report to the Execut'ive Engineer - NAPO. With the concurrence of the Executive Engineer, NAPO may function as staff to the onsite and offsite review organizations and provide technical support for problem resolution and General Office interface.
COMPOSITION 16.6.2.3.2 The NAPO shall be composed of members located at other Consumers Power Company facilities, and onsite members at the Midland Plant. The NAPO on site chall consist of a minimum of five (5) technical personnel.
QUALIFICATIONS 16.6.2.3.3 Three of the full-time members shall each have a bachelor's degree in engineering, or a related science. One of the three shall have a minimum of five years professional experience which includes a minimum of two years experience in power plant operation and/or design.
Any NAPO member may be drawn upon to perform NAPO duties on a temporary basis at cny nuclear plant location.
16.6.2.3.4 REPORTS Regular reports of NAPO activities
.all be submitted to the NSB.
16.6.2.4 SHIFT ENGINEER The Shift Engineer shall serva in at
.sory capacity to the Plant Supervisor on natters pertaining to the engineerin aspects assuring safe operation of the unit.
16.6.3 PLANT STAFF QUALIFICATIONS 16.6.3.1 Each member of the plant staff shall meet or exceed the minimum quali-fications of ANSI N18.1-1971.for comparable positions and the supplemental re-quirements specified in Sections A and C of Enclosure 1 of the March 28, 1980 NRC letter.
PROPOSED /MID l
nul082-0507a-43-48 16.6-5 10-29-82
~
ADMINISTRATIVE CONTROLS
' ~~ ~
16.6.3.2 The functions of the Radiation Protection M'anager (CRPM) specified in Regulatory Guide 8.8, March 1979, shall be accomplished by an individual (or individuals) who meets or exceeds the qualifications of Regulatory Guide 1.8, May 1977.1 These functions shall be carried out by either the Chemistry / Health Physics Superintendent or by a qualified individual (or individuals) who reports to him.
16.6.3.3,The Shift Engineer shall have a. bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and/or operations and response and analysis of the plant for transients and accidents.
16.6.4 TRAINING 16.6.4.1 A retraining and replacement training program for the plant staff shall be maintained under the direction of the Director of Nuclear Operations Training and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971,10 CFR 55, Appendix "A," and the ' supplemental requirements specified in Sections A and C of Enclosure,1 of the March 28, 1980 NRC letter, and shall include familiarization with relevant industry operational experience.
16.6.4.2 The Director of Property Protection is responsible for the development, revision, approval and implementation of the Fire Brigade training program. This training shall, as practicable, meet or exceed the requirements of Section 27 of the NFPA Code-1975. Fire Brigade training drills shall be held at least quarterly.
16.6.5 REVIEW AND AUDIT 16.6.5.1 PLANT REVIEW COMMITTEE (PRC)
FUNCTION 16.6.5.1.1 The Plant Review Committee (PRC) shall function to advise the Plant General Manager on all matters related to nuclear safety and to provide an examination of plant operating data.
[
l
- For the purpose of this section, " Equivalent," as utilized in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years l
of any one or combination of the following:
(a) Formal schooling in science or engineering, or (b) operational or technical experience / training in nuclear power.
nul082-0507a-43-48 16.6-Sa PROPOSED /MID 10-29-82 l
O
---~- -...._.,,-...__.
U
- 3 ~~
'O
- 4 4., 3 h' j
~ ' - - - -. ~ ~ ~
l ADMINISTRATIVE CONTROLS
. COMPOSITION ~
i 16.6.5.1.2 Th'e PRC shall be composed of:
i Chairman: Technical Engineer or Alternate Appointed by the Plant General Manager Member:
Plant Superintendent Member:
Operations Superintendent Member:
Technical Superintendent Member:
Maintenance Superintendent Member:
Chemistry / Health Physics Superintendent Member:
Reactor Engineer Member:
Senior Engineer Member:
Plant / Shift Supervisor or Shift Engineer ALTERNATES 16.6.5.1.3 Alternate members of the PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis. However, no more than two alternates shall participate as voting members at any one time in PRC activities.
MEETING FREQUENCY 16.6.5.1.4 The PRC shall meet at least once per calendar month, with special meetings as required.
QUORUM 16.6.5.1.5 A quorum for PRC shall consist of the Chairman.ar.d.four (4) voting members.
RESPONSIBILITIES 16.6.5.1.6 The PRC shall be responsible for:
a.
Review of:
(1) all procedures required by Specification 16.6.8.2 and changes thereto, (2) all programs required by Specifica-tion 16.6.8.4 and changes thereto and (3) any other proposed pro-cedures or changes thereto as determined by the PRC Chairman to affect nuclear safety.
b.
Review of all proposed tests and experiments that affect nuclear safety and changes to procedures as described in the Final Safety Analysis Report.
- c.. Review of all proposed changes to Appendix "A" Technical Specifi-catio.ns.
i l
d.
Review of all proposed changes or modifications to plant, systems or equipment that affect nuclear safety.
nul082-0507a-43-48 16.6-6 PROPOSED /MID 10-29-82 l
t '-v...
M.
p i
' ^ ' " -. _
,s l, %,%% l.5 ~g *,
I ADMINISTRATIVE COR1'ROI.S f
d.
Investigation of all violations of the Technical Specifications.
u i,
(A report shall be prepared covering evaluation and recommenda-
'tions to prevent recurrence and forwarded to the Vice President -
Nuclear Operations and to the Exe utive Engineer - NAPO.)
f.
Review of events requiring 24-hour written notification to the
+
Commission.
3 Performance of special reviews and investigations and reports thereof as requested by the Plant General Manager or Chairman of NSB.
h.
Review of the Site Emergency Plan.
- i. Review of each unplanned release reportable under Specifica-tion 16.6'.9.1.12 of radioactive material to the environs exceeding 25% of 10 CFR 50, Appendix "B" concentration for air and water or exceeding Appendix "C" quantities for solid materials, including the preparation and forwarding of reports covering evaluation, recommendations and disposition of the corrective action.
3
- j. Review of major changes to radwaste treatment systems.
i AUTHORITY l
16.6.5.1.7 Authority of PRC is as follows:
a.
The PRC shall:
l (i) Recommend in writing to the Plant General Manager approval
~
l or disapproval of items considered un' der ~Specifica-tions 16.6.5.1.6.a. through d. above.
1 (ii) Render determinat' ions in writing with regard to whether or not each item considered under Specifications 16.6.5.1.6.b.
l and d. above constitutes an unreviewed safety question.
(iii) Render determinations in writing with respect to the impact on safety of each item considered under Specifica-tions 16.6.5.1.6.a., c. and e.
b.
The PRC Chairman shall:
(i)' Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Operations and to the Vice Chairman of NSB of any disagreement between the PRC and the Plant General Manager; however, the Plant General Manager shall have responsibility for the resolution of such disagree-
-- ments pursuant to Specification 16.6.1.1 above.
nul082-0507a-43-4E 16.6-7 PROPOSED /MID 10-29-82 1
-e
t l l
~.
4.'s vs,.. a?
ADMINISTRATIVE CONTROLS s
_~.
i
.c.
PRC may delegate activities associated with fulfilling its responsibilities under Specification 16.6.5.1.6.
Those activities i
specified. in Specifications 16.6.5.1.7.a and b. above, however, say not be delegated.
RECORDS 16.6.5.1.8 The PRC shall maintain written minutes of each PRC meeting and shall maintain records of transactions specified in Specifications 16.6.5.1.6.b. and c.
16.6.5.2 NUCLEAR SAFETY BOARD (NSB)
RESPONSIBILITIES 16.6.5.2.1 The' Nuclear Safety Board (NSB) is responsible for maintaining a continuing examination of nuclear safety-related corporate and plant activftles and defining opportunities for policy changes related to improved nuclear safety performance.
FUNCTION 16.6.5.2.2 The NSB shall function to provide review of designated activities in the areas specified in Specification 16.6.5.2.3.
6 i
COMPOSITION i
16.6.5.2.3 The NSB shall consist of members appointed by the Vice President -
Nuclear Operations. NSB shall'be chaired by the Executive Director, Nuclear Activities, the Vice Chairman, or a duly appointed alternate. The Executive Engineer - NAPO shall be the Vice Chairman and Secretary.
Collectively, the personnel appointed to NSB shall be competent to conduct reviews in the following areas:
a.
Nuclear Power Plant Operations b.
Nuclear Engineering c.
Chemistry and Radiochemistry i
d.
Metallurgy e.
Instrumentation and Control f.
Radiological Safety g.
Mechanical and Electrical Engineering h.
Q'uality Assurance Practices 1
l nul082-0507a-43-48 16.6-8 PROPOSED /MID l
10-29-82 1
.~
1 J
. c.
..J
- . a t
I.
ADMINISTRATIVE CONTROLS
~
~.
An ind'ividual appointed to NSB may possess expertise in more than one of the above specialties. These individuals should, in general, have had professional experi-cnce in their specialty at or above the Senior Engineer level.
ALTERNATE MEMBERS l
16.6.5.2.4 Alterna'te members may be appo'inted in writing by the Vice President -
Nuclear Operations to act in place of members during any legitimate and unavoid-eble absences. The qualifications of alternate members shall be similar to those of members.
4 CONSULTANTS 16.6.5.2.5 Consultants shall be util,ized as determined by the NSB Chairman or Vice Chairman to provide expert advice to the NSB. NSB members are not restricted as to sources of technical input and may call for separate investigation from any competent source.
MEETING FEEQUENCY 16.6.5.2.6 NSB shall meet at least once per calendar quarter during the initial year of facility operation following fuel loading and at least once every six months thereafter.
QUORUM 16.6.5.2.7 A quorum of NSB shall consist of the Chairman and four (4) members.
(The Vice Chairman may be a voting member when not acting in the capacity of Chairman.) No more than a minority of the quorum shall have line responsibility for operation of the facility.
It is the responsibility of the Chairman to ensure j
that the quorum convened for a meeting contains appropriately quelified members or j
has at its disposal consultants sufficient to carry out.the review functions re-i quired by the meeting agenda.
16.6.5.2.8 RESPONSIBILITIES l
REVIEW 16.6.5.2.8.1 - NSB shall be responsible for the review of:
Significant operating abnormalities or deviations from normal a.
and expected performance of plant equipment that aff.ct nuclear safety.
b.
All events which are required by regulations or Technical Speci-fications to be reported to NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and other violations (of applicable statutes, codes, regulations, orders, Technical Specifications, licens'e requirements or of internal procedures 6r instructions) having nuclear safety significance.
nul082-0507a-43-48 16.6-9 PROPOSED /MID 10-29-82
f
?
1 rE) 4.r.y c. C '8
.~ -
j l
ADMINISTRATIVE CONTROIS
&I Issues of safety significance identified by the Plant Manager, c.
the NSB Chairman, Executive Engineer, NAPO or the PRC.
d.
Proposed changes in the operating license or Appendix "A" Technical Specifications.
The results of actions taken to correct deficiencies identified e.
by the audit program specified in Specification 16.6.5.2.8.2 at least once every six months.
f.
Safety evaluations for changes, completed under the pro' visions of 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.
AUDITS 16.6.5.2.8.2 Audits of operational nuclear safety related facility activities shall be performed under the cognizance of NSB. These audits shall encompass:
I a.
The conformance of. plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
b.
The performance, training and qualificat' ions of the entire facility staff at least once per 12 months.
The performance of activities required by the operational c.
quality assurance program (CPC-2A QAPD) to meet the criteria of Appendix "B," 10 CFR 50, at least once per 24 months.
1 d.
The Site Emergency Plan and implementing procedures at least once per 12 months.
l e.
The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 24 months.
f.
Any other area of plant operation considered appropriate by NSB or the Vice President - Nuclear Operations.
[
i 3
The plant Fire Protection Program and implementing procedures at l
least once per 24 months.
h.
An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
1.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualifed fire consultant at intervals no greater than 3 years.
nul082-0507a-43-48 16.6-10 PROPOSED /MID 10-29-82 i
v
.TS ~2: +.,. O 7.."
.a w...
' ADMINISTRATIVE CONTROLS l
J.
The radiological environmental monitoring-program and the i
results thereof at least once per 12 months.
k.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
1.
The PROCESS CONTROL PROGRAM and implementing procedures for solidification of radioactive wastes at least on.ce per 24 months.
Audit reports encompassed by Specification 16.6.5.2.8.2 above shall be forwarded to the NSB Vice Chairman and Secretary and Management positions responsible for the areas audited within thirty (30) days after completion of the audit.
AUTHORITY 16.6.5.2.9 Authority of NSB is as follows:
a.
For responsibilities' specified in Specifications 16.6.5.2.4.1.a.
and b., the NSB shall be convened.
In making determinations and recommendations, the.NSB may utilize reviews cpnducted by NAPO.
b.
The NSB Chairman shall report to and advise the Vice President Nuclear Operations of 'significant findings. associated with NSL activities and of recommendations related to improving plant nuclear safety performance.
NSB may delegate activities associated with fulfilling its c.
responsibilities under Specification le'.6.5.2.8.
Those activities specified in Specification 16.6.5.2.9.a. above,-however, may not be delegated.
RECORDS 16.6.5.2.10 Records of NSB activities shall be prepared and distributed as indi-cated below:
a.
Minutes of each NSB meeting shall be prepared and forwarded to the Vice President - Nuclear Operations and each NSB member. Minutes shall be approved at or before the next regularly scheduled meeting following the distribution of the minutes.
b.
If not included in NSB meeting minutes, reports of reviews encom-t passed by Specification 16.6.5.2.S.1 above shall be prepared and l
forwarded to the Vice President - Nuclear Operations.
16.6.6 (Deleted) i l
nul082-0507a-43-48 16.6-11 PROPOSED /MID 10-29-82 I
I q.-
(
u 1
%.?
p ADMINISTRATIVE CONTROLS 16.6.31 SAFETY LIMIT VIOLATION
~
16.6.7.1 The following actions shall be taken in the event a safety limit is violated:
The reactor shall be shut down immediately and not restarted until j
a.
the Commission authorizes resumption of operation (10 CFR 50.36(c)(1)(1)(A)).
b.
The safety limit violation shall be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the Ccacission in accordance with 10 CFR 50.36 as well as to the Vice Presic'ent - Nuclear Operations and to the Chairman - NSB.
A report shall be prepared in accordance with 10 CFR 50.36 and c.
Specification 16.6.9'of this specification.
(The safety limit violation and the report shall be reviewed by the PRC.)
d.
The report shall be submitted within 14 days to the Commission (in accordance with the requirements of 10 CFR SP.36), to the Vice President - Nuclear Operations and to the CFairman - NSB.
16.6.8 PROCEDURES AND PROGRAMS 16.6.8.1 Written procedures shall be established, implemented and maintained cov-ering the activities referenced below:
The applicable safety-related procedures recemmended in Appendix "A" a.
of Regulatory Guide 1.33, Quality Assurance Program Requirements, as endorsed by CPC-2A QAPD.
b.
Refueling operations.
c.
Surveillance and test act'ivities of safety-related equipment.
d.
Site Security Plan implementation.
e.
Site Emergency Plan implementation.
f.
Site Fire Protection Program implementation.
3 PROCESS CONTROL PROGRAM implementation.
h.
OFFSITE DOSE CALCULATION MANUAL implementation.
- i. Conduct of a program of interlsboratory comparison of radiological analyses.
15.6.8.2 PRC is responsible for the review of each procedure of Specifica-tion 16.6.8.1 above and changes thereto (except for Security Implementing Proce-dures which are reviewed and approved in accordance with the Site Security Plan).
nul082-0507a-43-48 16.6-12 PROPOSED /MID 10-29-82
l r
s
,e l*.
p'-~~~~,,_
]
. ?.
N,,
i 9<>
l
. g,,
j
~~
ADMINISTRATIVE CONTROLS
~-
The PJant General Manager shall approve such procedures and changes prior to 4
implemhntation.
16.6.8.3 Temporary changes to procedures of Specification 16.6.8.1 above ma; i..
made provided:
a.
The intent of the original procedure is not altered.
b.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
c'.
The change is documented, considered by the PRC at the next regu-i larly scheduled meeting, and subsequently approved by the Plant Manager.
1 t
16.6.8.4 The following programs shall be established, implemented and maintained:
I a.
Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside' containment that could contain highly radioactive fluids during a serious transient or accident to as low as reasonably achievable j
levels. The systems -include the reactor building spray and safety injection system. The program shall include the following:
i 3
l (i) Preventive maintenance and periodic visual inspection i
requirements, and (ii) Integrated leak test requirements for each system at intervals not exceeding the refueling cycle.
i b.
In-Plant Radiation Monitoring i
A program which will ensure the capability to determine accurately the airborne iodine concentration in occupied areas under accident j
conditions. This program shall include the following:
(i) Training of personnel, (ii) Procedures for monitoring, and (iii) Provisions for maintenance of sampling and analysis equipment.
d c.
Secondary Water Chemistry A program for maintenance of secondary water chemistry to inhibit steam generator tube degradation. This program shall include:
nul082-0507a-43-48 16.6-13 PROPOSED /MID 10-29-82
-:7
-,--,,,---,n,-~,,,r
,-,y.,.-.-v,
.-we we~--w,m--e ew
-e-or-v
, +-
-n,.,
w
+ - -v---
~~-
-,.,-,-,ew.