ML20127N394
| ML20127N394 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/31/1985 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20127N387 | List: |
| References | |
| PROC-850131-01, NUDOCS 8505230514 | |
| Download: ML20127N394 (50) | |
Text
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MIDLAND ENERGY CENTER SURVEILLANCE & MAINTENANCE PLAN ., g * (- REVISION O MI1284-0000A-MP03 1/31/85
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-MIDLAND ENERGY CENTER SURVEILLANCE & MAINTENANCE PLAN-TABLE OF CONTENTS 1 #
1.0 ~ SURVEILLANCE AND MAINTENANCE PLAN
SUMMARY
1
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- 1.1 Purpose 1 1.2-.0bjectives .I 1.3 Major Components of the Plan .1 2.0 ORGANIZATION AND RESPONSIBILITY 4
'2.1 Project Surveillance and Maintenance Organization 4
-2.2 Site Organization .
6 2.3 : Quality Assurance Organization 17 2.4 General. Office. Organization 20
.3.0 . FUNCTIONAL PLANS 24 3.1 NRC Licensing Requirements and Regulatory Interface Program 24
'3.2 Quality Assurance Plan 26
'3.3 Layup & Maintenance Program' 30 3.4' Salvage & Sale Plan. 34
'-' 3.5 . Security Plan 37 3.6 Records Management Plan 39 3.7 Future Planning Considerations 41
'4.0 STAFFING AND COST ESTIMATE 42 4.1 Bases and Qualifications. 42 4.2 Staffing Plan 42 4.3' Cost Estimate 42 g.. - Attachment A '- J D Selby Response (November 1,1984) to MPSC Rate Case U-7380 Interrogatory 3A-AB-69 l'
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F' ] i l l MIDLAND ENERGY CENTER j
.1 SURVEILLANCE & MAINTENANCE PLAN-LIST OF FIGURES & TABLES fage
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' Figure 2-1 Midland Project Surveillance & Maintenance Organization
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-5 Figure 2-2
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Site Surveillance & Maintenance Organization- '8 Figure.2-3 Facilities & Materials Division 9 Figure-2 Security Division 12
- ~. Figure 2-5 Services Division 13
' Figure 2-6 Operations & Maintenance Division L16 Figure 2-7 Quality Assurance. Department 19
-Figure 2 General office Organization 22 Table 4-1 Staffing. Plan 43 Table 4-2 Cost Eatinate 44 4
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1: 1.0 SURVEILLANCE AND MAINTENANCE PLAN
SUMMARY
1.1 PURPOSE 1The purpose of the Midland Energy Center Project Surevillance and Maintenance Plan is to provide a mechanism to manage this phase of the Project shutdown in such a way as to provide Company' management,
- the stockholders, and the applicable regulatory bodies with confi-dance that the' Company has undertaken this task with a set of logical and understandable objectives, and is prepared to achieve those objectives in a prudent and effective manner.
1.2 OBJECTIVES The following primary objectives are established for the Surveillance and Maintenance Phase of the Midland Energy Center Project shutdown:
-A. ' Carry out activities for this phase of the shutdown at minimum cost while preserving the assets that have accumulated over the life of the Project-B. -Preserve the option to complete one or both of the units under the appropriate conditions C. Attempt to obtain the maximum value for any Project equipment and material that can be sold or salvaged without invalidating the Project restart option D. Carry out the planning and support activities required to assist in the Corporate decision regarding the ultimate disposition of the facility E. To the extent practicable, carry out the surveillance and mainte-nance activities with CP Co personnel The objectives listed above are consistent with the Corporate policy .- issued by J D Selby in response to an interrogatory in MPSC Rate Case U-7380. A copy of this response is provided in Attachment A.
1.3 MAJOR COMPONENTS OF THE PLAN , This section of the plan describes the major activities identified to accomplish the objectives of Section 1.2 above. The Surveillance and Maintenance (S&M) Phase is based on a planned set of continuing activities requiring minimum resources while preserving the plant in its shutdown condition. This phe.se continues until the decision is made to either restart Project activities or to plan and carry out-permanent abandonment of the facility. January 1, 1985 is the nominal starting date for this phase of the plan. Some surveillance and maintenance activities were initiated prior to thic date and some demobilization activities will extend beyond this date. 4 l l MI1284-0000A-MP03
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-All active contracts and material purchase orders were terminated at shutdown,' retaining only those portions necessary to carry out S&M.
activities.1' Settlements were reached with all but a-few vendors and contractors, and these remaining contract closures,-which are part of "the Demobilization Phase effort, will'be completed during11985.
?Upon' Project shutdown,.a detailed shutdown Records Management Plan ,
was prepared and implemented. Personnel were instructed to return l ' Project records to the appropriate Document Control Center or Project i File.; Personnel departing the Project turned over documents in their possession, indexing and identifying the status =according to Project
- fnstructions. These documents are classified as' inactive and stored.
They are managed under a program which can make them available with some effort. -The active records necessary to support the S&M activi-ties-are maintained by the ongoing Project Surveillance and Mainte-nance Organization and controlled under normal records management 1 procedures. The retrieval and preservation systems for both active and inactive records are maintained until the remaining final records dispostion questions-are resolved. b The permanent equipment 1and facilities were, or are' being, placed in a safe, maintainable condition. A Layup & Maintenance Program was ~ ' developed to preserve the equipment and facilities as long as may.be required. 1m engineering Treview was performed to establish the
- technical requirements for these activities.. Industry' experience, vendor recommendations'and existing contractor programs were among
, the information utilized in developing these requirements.
1 All temporary equipment and materials were demobilized and either-removed from or secured at the site. All items owned by CP Co were recovered and stored. . Salvage and sale operations _on non-permanent '; equipment-and material is underway, and salvage and sale questions en permanent equipment are being evaluated on a case-by-case basis. As-long as' sale of individual components does not adversely impact'the possible sale or restart of the entire Project, the sales are' pro-ceeding under a specific 1 set of guidelines. Sale and salvage are . being-pursued both within CP Co and with external sources. To preserve the option of possible Project resurrection at a later "
-1 date, the licensing activities necessa y to maintain the Construction !
Permits and Operating License application were identified and imple ' mented. Chief among these' activities is the establishment of a quality assurance (QA) program that covers the S&M Phase. The focus of the QA program is to assure that S&M' Phase' activities are conduct-j ed in'accordance with established requirements. The majority of S&M ' QA activities have to do with record preservation and equipment layup l and maintenance. The continuation of the NRC licenses and the-QA program also maintains the equipment as nuclear grade for possible sale. The security organization at the site has completed the transition-p? " 4 from a program preparing'for nuclear plant operation to a program
-protecting the assets of a demobilised construction site. The chief activities are site security and fire prevention. The work is e
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4 3 carried out under the direction of'CP Co by a small force of contract
. pers'onnel.
CP Co_has-set up'a new Project organization to-carry out the various
- surveillance and maintenance duties. Project S&M Organization person-nel are-located both at the General. Office (Jackson) and the-Site
. (Midland). Staffing levels for the continuing S&M tasks were de-4: fined, and'as of January 1, 1985, the appropriate staff was in place
-and the Project destaffing was essentially complete.
t A specific budget based on this plan for'the SEM Phase was prepared. Budget. controls and reporting requirements were established. w a
4 2.0 ORGANIZATION AND RESPONSIBILITY
~2.1' PROJECT SURVEILLANCE AND MAINTENANCE ORGANIZATION The overall CP Co organization for the Project Surveillance and-Maintenance (S&M) Phase is shown in Figure 2-1. ' Subsequent sections describe'the individual organizational units and their responsibili-
' ties in more detail.
' s The Engineering and Licensing, Administration, and Schedule and Cost functions are headquartered,in' Jackson.. Quality Assurance and the
*. multiple functions under Site Management are located in Midland. In the S&M phase, all personnel at each location are closely' tied physically and informally structured to maximize shared services,-and facilitate communications. The organizational planning clearly defines all external services required but the organization is essentially self-sustaining with minimum staff requirements. The-only full-time Bechtel support required for the S&M phase is an-inspector to fulfill the requirements of the N-Stamp maintenance program (see Section 3.2.3.H).
In developing the Surveillance and Maintenance Organization fseveral considerations were utilized beyond the Surveillance and Maintenance Plan primary objectives of Section 1.2. The Organization structure was collapsed fron the pre-shutdown Project organization to fitLthe
' tasks anticipated for the S&M Phase. Flexibility is a: central theme. .- To retain a core of technical staff some individuals were placed in.
new situations and some, for the near term, were placed in positions-of lesser-responsibility _than'they held previously. It is also expected-that as events progress and as the Company's planning horizon broadens, additional shifts in organizational responsiblity will be required. The overall S&M Organization and the staff de-scribed in this document are those in effect as of January 1985. D MI1284-0000A-MP03
FIGURE 2-1 M10 LAND PROJECT SURVEILLANCE & MAINTENANCE ORGANIZATION 1-I Projects, Engineering & Construction l-J W COOK l Vice President I
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g O M BUDZlK RJERHAROT A R MOLLENK0PF R S GIRARD H P LEONARO J A MOONEY l I
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- 2;2 SITE ORCANIZATION The' Site: Surveillance and Maintenance Organization includes the five
. Divisions shown in Figure 2-2, which report to the Site Manager.
2.2.1 , Facilities and Materials Division The mission of the Facilities and Materials Division is to provida-for.the maintenance of all plant facilities and to direct the plant
-warehousing, material service, salvage and sale; operations in support of the surveillance and maintenance of the Midland Energy Center.
The Facilities and Materials Division is organized'into the three , areas shown in Figure 2-3 and whose. responsibilities are described below. 2.2.1.1 Soils A.. Monitor as-build conditions of auxiliary building underpinning , and take corrective actions as necessary B. Provide for data collection on building monitoring instrumentation C. Provide Feedwater Isolation Valve Pit support' system' load > monitoring D. ,0versee and provide for stormwater discharge and maintenance of the cooling pond E. Provide for collection and removal of localized groundwater where necessary
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2.2.1.2 Facilities' Maintenance A. ~ Provide for the upkeep and maintenance of all plant facilities
. . (buildings), both permanent and temporary. This includes the following: ; ~(1)' Janitorial service for all facilities (2) Coordinate-administrative aspectr of facility maintenance work with Operations and Maintenance Division (3) Coordinate all office relocations i (4) Direct outside contractors called in to support surveillance and maintenance activities (5) Operate and maintain Company heavy equipment required to support surveillance and maintenance activities B.. Provide for the upkeep and maintenance of all exterior.and yard areas. This includes the following:
M11284-0000A-MP03
7 (1) Grade _and repair roads, as required
.(2) Mow grass and control weeds (3) . Remove snow (4) ' Assure properidrainage of yard areas ,
(5) ' Maintain integrity of plant security boundary 2.2.1.3 -Material ~ Services, Sales and Salvage A .' Conduct, coordinate and administer the material services function which includes the following: (1) . Receive and store materials (2) Issue materials in support of surveillance and maintenance activities (3) Maintain an up-to-date, accurate inventory of all items not installed but located at the plant, including all temporary, construction-related items
-(4) Transfer stock to other Company facilities (5) Implement the storage requirements in warehouses and laydown areas (6) Interface with the Quality Assurance Department in support-of their inspection program
*B. Implement the Salvage & Sale-Plan. This includes the-following:
(1) Develop and maintain the listing of surplus / unneeded ' items to be salvaged - (2) Develop and maintain the inquiry listing for plant equip-ment, tools and materials from both interested outside , , parties and other Company facilities (3) Maintain the-required documentation to support the Salvage &
' Sale Plan (4) Perform and coordinate the required research and analysis to determine theoeconomic and technical feasibility of the sale of plant equipment, tools and materials to interested
.outside parties (5) Ensure that salvage and sale materials are properly stored and maintained as required
- Demobilization activities; included for completeness L
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. FACILITIES & MATERIALS OlVISION Site Management J A MOONEY i
Facilities & Materials Division B H PECK 4 t h 1 Facilities Material Services, Soils Maintenance Sales & Salvage
- R H WlELAND W F SABO D D JOHNSON 4
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s 3 L2.2.2 Security Division The mission of the Security Division is to provide security services 24 hours per day and staff supe' r vision of the site fire prevention and protection programs. The Security Division-is organized as shown on Figure 2-4 and whose responsibilities are (with support from the Property Protection
- -Department):
A. Prepare and administer budget for personnel, equipment and
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contract. security agency services B. Oversee. control of vital and protected area keys, card-keys, and locks C. Establish and maintain compliance with Federal, State and local-fire protection regulations and Corporate and insurance company standards 1 D. Develop and implement fire protection procedures and supervise fire brigade requirements E. Administer anti-theft, traffic and access control programs F.. Conduct liaison with local fire and law enforcement agencies G. Develop and implement' site security procedures to be followed by site employees and enforced by the contract security. force. H. In conjunction with Services Division implement the control and storage of Safeguards Information 2.2.3 Services Division 13:e mission of the Services Division is to provide effective and efficient document control, records management, and support services during the Surveillance and Maintenance Phase. The Services Division is organized into the four areas shown in Figure 2-5 and whose responsibilities are described below. 2.2.3.1 Documentation Services A. Provide document control and active records management services
-for the Project B. Coordinate with off-Project organizations for document control and active records management activities C. _ Collect, store, and maintain inactive Project records that are to be stored at the site MI1284-0000A HP03 r
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D. Coordinate;with off-Project organizations for the storage and'
. maintenance of inactive records that are to be' stored off site E. Consolidate, sort and file inactive records to improve retriev-ability and reduce volume :
4 2.2.3.2:' General Services , !U!- 'A. , Provide general' site support for text processing, mail delivery,
* ; stationery supplies and pool vehicle administration _,-
[ 'B. Coordinate site office' equipment, (eg, IBM 5520, Xerox, etc). m. h C. Interface with Information Systems Department for site hardware and software needs D. Provide clerical support for on-site organizations e 2.2.3.3 Litigation Technical Support A. Coordinate. documentation searches and provide copies of ' documentation Bg Respond to requests to search records and provide technical evaluations
-2.2.3.4 Accounting.
A. Provide accounting services, including site payroll administra-4 tion, business expense reimbursement ard reporting requirements for FERC and MPSC B. Coordinate the preparation-of the' site budget, monitor-the budget, and provide budget variance analysis ,' C. Provide. assistance for the preparation and administration of -- contracts used on site during the Surveillance and Maintenance
's Phase
- D. Cicsecut all open Bechtel subcontracts and field purchase orders
, 2.2.'4 Oferations and Maintenance Division 1The mission of the operations and~ Maintenance Division is to;
- 1) operate and maintain the-equipment necessary to provide house u services and environmental control, 2) implement a Layup & Mainte-nance Program which preserves the quality and functional capability of the equipment and structures, 3) and implement those activities required to comply with various licensing requirements and
' regulations 4
*Demobilisation activities; included for completeness
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5 4 FIGURE 2-4 SECURITY OlVISION Site "r:,_ ..;.;t 4 J A MOONEY Security Division S C COTE Contract Security Fire Prelection Force G C W ATTERS 8 i N
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'The Operations and Maintenance Division is organized into the five areas shown in Figure 2-6 and whose responsibilities are defined below.
-2.2.4.1 Operations A. Operate the minimum equipment necessary to provide house services
; (HVAC, water, lighting, power and sewage), to provide fire protection and to prevent environmental damage to equipment and facilities a B. Implement and record activities to moniter equipmeic operation aqd.layup condition. Coordinate this program with che Mainte-nr.nce Coordination group ,
C. Assist the Security Division in implementing a fire brigade / watch program which meets insurance requirements 2.2.4.2 Mechanical Maintenance Implement activities to layup and to perform corrective and preven-tive maintenance on plant mechanical equipment, both installed and in storage 2.2.4.3 Electrical / Instrumentation and Control. Maintenance (with support from System Protection and Laboratory Services Department) A. Implement activities to layup and to perform corrective and preventive maintenance on plant electrical equipment and instru-
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mentation both installed and in storage 4 B. Maintain and. calibrate measuring and' test-equipment 2.2.4.4 Chemistry / Health Physics (with support from the Environmental Depart-ment and Radiological Services Department)
. . A. Maintain and implement programs which achieve compliance with the Special Nuclear Material Licenses, By-Product Material License and NPDES Permit
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=B. Provide for collection, storage and disposal of vastes regulated by the State of Michigan and Federal authorities C. Provide for chemical analyses as needed to support site activities 2.2.4.5 Maintenance Coordination Maintain and implement a system for planning, documenting and sched-
'uling Operations and Maintenance' Division activities. 'The methods used meet the quality requirements specified by the Quality Assurance Department and are consistent with Midland Project methods M11284-0000A-MP03
15 2.2.5. Human Resources The mission of the Human Resources group is to support the Surveil-lance and Maintenance Plan of the Midland Energy Center through the administration of human resource policies. Their responsibilities are: l A. Provide guidance and direction to all levels of management I regarding union relations matters and the proper interpretation of the working agreement . B. Provide guidance to management as well as SE-W employees on the proper administration of General Order 35 and its provisione C. Provide guidance to management as well as EA&P employees on General Order 45 and all other matters pertaining to promotion, selection, advancement and associated topics
-D. Prepare and maintain all on-site personnel employee records and associated documents E. Coordinate all safety activity ,
F. Provide coordination of all medical and worker's compensation activity G. Coordinate the implementation of all affirmative action and EE0 activities, including the investigation of any charges of illegal or discriminatory action H. Coordinate sufficient staffing and assist with the placement of all levels of employees as the need arises l ! I
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FIGURE 2-6 OPER ATIONS & MAINTENANCE DIVISION Site Management J A MOONEY Operations & Maintenance Division , J T CHRISTY s
. Mechanical Electrical /l&C Chemistry / Maintenance Operations Maintenance Health Physics Coordination Maintenance J T KILLE OJV0KAL O R GNAEDINGER P J GROVES G W R0WE i
, 5
17 2.3_ -QUALITY ASSURANCE ORGANIZATION , The mission of-the. Quality Assurance Department (QAD) is to support the licensability of the Midland Energy Center and the preservation
- of assets by implementing s' Quality Assurance Program to assure that Surveillance and Maintenance Phase activities are conducted in accordance with established requirements.
The QAD' goals are to c- A. Execute the assurance functions ,
'B. Utilize resources effectively C. Maintain regulatory confidence in the assurar.ce program
.QAD is accountable for' development, execution and evaluation of quality. assurance programs and systems.
~Th'e QAD is organized into two creas as shown in Figure 2-7 and whose
-responsibilities are described below:
2.3.1 Assurance Engineering A. Prepare and maintain the Quality Assurance Program Plan.(QAPP) and the OAD procedures B. Review procedures, specifications and procurement documents which describe or affect Q-activities or Q-hardware C. Conduct trend analyses D. Determine reportability in accordance wit'a 10 CFR 50.55(e) and 10 CFR 21 E. Coorc'inate QAD input to responses to the NRC for Noticar of
- 3. Viol.stion,10 CFR 50.55(e) reports and 10 CFR. 21 reports i'
[ F. Evaluate suppliers 1 ! G. Evaluate allegations H. Design, control data base, maintain and administer QAD informa-tion systems
- 1. Coordinate QAD periodic reports 2.3.2 . Verification -
A. Prepare and maintain inspection plans . B. Inspect layup, maintenance, remedial soils, storage and salvage activities ' MI1284-0000A-MP03 at . - . , - . - - , -- -
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18 C. ' Conduct source and receipt inspections-
.D. . Conduct periodic surveillance of safety-related structures,
. systems, components, equipment and materials E. Prepare and' maintain the audit plans and schedules and audit Q-activities .
F. Certify inspection, audit and Non-Destructive Examination personnel . G. Control the use of measuring and test equipment by QAD personnel H. Log, maintain and store.in-process quality documentation and turn over documentation at the point of designation as a quality record l' * [ F i __ MI1284-0000A-MP03 -. ____
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20 2.4 GENERAL OFFICE ORGANIZATION The Midland' Project' Surveillance and Maintenance Organization within the General Office supports.the on-site activities required to maintain the plantuin a state such that the Construction Permits and the Operating License application are retained and the physical equipment.and facilities are maintained in accordance with the
- , requirements specified by the Engineering & Licensing Department.
The General Office S&M Organization is comprised of three departments as shown on Figure 2-8. 2.4.1 Engineering & Licensing Department
.The mission of the Engineering & Licensing Department is to provide technical requirements and support during for the Midland Project Surveillance and Maintenance Phase.
The Engineering & Licensing Department is organized into two areas as shown on Figure 2-8 and whose responsibilities are described below. 2.4.1.1 Procurement Technical Support
- Identify and recommend for resolution the settlement of all General Office purchase orders and contracts in concert with the Purchasing Department, except for the Bechtel contract. This includes General
- Office and Bechtel-Ann Arbor purchase-orders and contracts 2.4.1.2 Engineering & Licensing Technical Support This section performs-the two functions expressed in its title.
A. Engineering Technical Support has personnel at both the Midland Plant Site and the General Office. These site personnel receive technical direction from their General Office supervisor and they coordinate their day-to-day activities with the Operations and
. Maintenance Division.
The Engineering Technical Support group responsibilities are
.g. limited to the following specific activities:
(1) Function as-the design authority for providing engineering criteria for Surveillance and Maintenance Phase activities (2) Provide a system for configuration control of the design documents and plant hardware. Configuration control in this context means documenting the modifications made during the Surveillance and Maintenance Phase
- Demobilization activities; included for completeness MI1284-0000A-MP03
21 i i (3) Assist the Operations and Maintenance Division in developing specific maintenance work orders for implementing the engineering criteria (4) Provide technical support for remedial soils work (5) Coordinate and evaluate results of optical structural- ,. settlement surveys and of ground subsidence surveys I (6)- Implement the corrosion monitoring program , (7) Provide technical review and disposition of nonconformance reports as needed f , (8) Review adequacy of technical requirements in procurement documents B. Licensing group responsibilities are: , 1 (1) Document and maintain the Correspondence Logging and Track- I ing System to ensure conformance to all commitments made to the NRC (2) Coordinate all written communication with the NRC for those reports and/or responses required to maintain the' Cons;suc-tion Permits and the Operating License application (3) Coordinate and track the maintenance of any other-permits and/or licenses. required to keep the plant available for , restart
- 2.4.2 Schedule & Cost Department c
The mission of the Schedule & Cost Department is to establish and implement those management systems required to integrate the efforts of other departments and to' provide-specialized resources and servic- - es to facilitate the work of other departments during the Surveil - lance and Maintenance Phase. These services include cost estimating, Project budget administration, and computer applications. . The Schedule and Cost Department includes three areas as shewn in Figure 2-8 and whose responsibilities are described below. l 2.4.2.1 Cost & Schedule Engineering A. Provide cost engineering and estimating support for the Project B. Coordinate long-term cost document and data base retention with Documentation Services lC . Provide scheduling services if required MI1284-0000A-MP03
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FIGURE 2-8 i GENERAL OFFICE ORGANIZATION 4 k j - Projects, Engineering & Construction J W COOK Vice President S 4 --- Engineering & Licensing Administration le & C W RJERHARDT R S GIRARD A R MOLLENKOPF 4 i Engineering & Licensing Cost & Schedule Budget Computer Procurement Technical Suppori* Technical Suppori Engineering Administration Services R C BAUMAN T R THIRUVENGADAM A 0 SARKAR D G RANDOLPH S M MATTHEWS
- Carry-over Demobilization Effort U
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~ .2.4.2.2f Budget Administration Develop and monitor the Project. budget
- 2.4.2.3~ Computer Services A. Provide services and expertise in the use of the Project Personal Computers for all Project Departments B. Develop data bases for management information. Design and
- ~. program management. output reports. Update data bases and issue t periodic management reports 2 .~4 . 3 Administration Department
-The mission of the Administration Department is to support the-Surveillance and Maintenance Phase by providing-administrative services.to the Project Departments.
The Administration Department shown on Figure 2-8 provides: A. Staff support to Project management B. ' Supervision for all Project General Office-SE-W employees other than individual secretaries C. . General Office Project filing, stenographic and internal mail services
- MI1284- 0000A-MP03
24 3.0 FUNCTIONAL PLANS The Surveillance and Maintenance Phase of the Midland Energy Center shutdown process is controlled by a series of functional plans covering the identified major activities. These plans are summarized in the sectior which follow. Several of the plans are further detailed in the form of department guidelines and procedures. {)( 2 Each plan' defines (1) the guiding principles and policies established E by Project Management, (2) the work scope required to accomplish the ] plan including the major issues and activities to be addressed, and (3) the interfaces and coordination required between organizations ] (on-Project, off-Project, contractors) to carry out the plan. ] 3.1 NRC LICENSING REQUIREMENTS AND REGULATORY INTERFACE PROGRAM b Al 3.1.1 Principles a EEQ This program preserves the construction restart and facility market- P ing options and shall: . A. Maintain the NRC Construction Pernits and the Operating Licensing ( - application for both units l B. Maintain all other necessary Federal, State and local licenses and permits 2
- M j C. Minimize new commitments, regulatory reviews and licensing j l expenditures consistent with preserving the option for resumption -
of construction or marketing a licensable facility D. Maintain a management system to collect, track, and assure that licensing and regulatory commitments are met g - 3.1.2 Scope 4
, A. Identify and implement the licensing requirements to support surveillance and maintenance activities including, disposition of g -
nuclear fuel and the NRC nuclear fuel license application, removal of plant equipment and responses to NRC. requests for i
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( comments on proposed rules and regulations
=R B. Request suspension of ongoing ASLB hearings and staff review d except for what is necessary to support surveillance and mainte-nance activities
]a C. Periodically update status and take the necessary licensing actions to renew required permits and licenses g m
D. Remain current on ASLB rulings and orders, NRC regulatory rules, issues and documents and maintain a continuing liaison with
]
3 nuclear power industry groups and utilities to stay current on == specific issues and 6 vents which also may impact the d g licensability of the Midland Project or require actions during MI1284-0000A-MP03 E m
25 the Surveillance and Maintenance Phase. Examples of necessary actions include: (1) AIF-NTOL participation
'(2) Review publications such as (a) Inside NRC (b) Nucleonics Weekly (c) Federal Register .
E. Perpare, review, finalize and submit all NRC correspondence, including supporting documentation. Maintain a Correspondence Logging and Commitment' Tracking System (CLCTS) and assure that commitments are met in a timely manner F. Disposition NRC Bulletins, Notices and Generic Letters with regard to Surveillance and Maintenance activities G. Respond to ASLB items by assuring the review of motions, orders, and requests for Project action and make necessary responses H. Take licensing related actions necessary to address facility abandonment should this be the ultimate disposition I. Obtain NRC. approval of Project requests and submittals such as the Quality Assurance Program Plan 3.1.3 Interfaces Engineering & Licensing Technical, Support implements this program and the interfaces, such as: A. Interface with appropriate Midland Project Departments / Divisions in maintaining the CLCTS and administering NRC interfaces B. P1 ovide the primary interface with the NRC Washington, DC, offices and interface with other Federal, State and local agen-cies with support from other CP Co departments as applicable. , C. Support the Site Manager in his interfaces with NRC Region III and interface with the NRC Staff on Site inspections D. Interface with Project and off-Froject Company departments for Midland Project permits, licenses and ASLB hearing items; Generic Letters; and comments on proposed rules and regulations
-MI1284-0000A-MP03
26 l 3.2 QUALITY ASSURANCE PLAN Prior to the shutdown, the' principal safety-related (i.e. quality-related or "Q") activities were design, procurement, con-struction,'and testing.- At shutdown, these activities were suspended
.and the responsible organizations largely disbanded. The Demobiliza-tion Phase was a transition period during which the Project identi-fied the "Q" activities needed to meet the objectives of the
.' Surveillance and Maintenance Phase and developed the controls to
. assure successful completion of these activities.
M' 3.2.1 Principles.
.The' following principles were established during demobilizatio'n and shall govern the' conduct ofethe Surveillance and Maintenance Phase: H A'. Maintain the NRC Construction Permit (i.e. the' Project remains licensable)
B. Maintain the physical plant assets within available resources C. Design,, construction and testing remain stopped and no activities -
.to advance the design,-construction and test status of the plant are included in the Surveillance and Maintenance Phase D. Develop and maintain a policy level Quality Assurance Program to-address:the needs of the Surveillance and Maintenance Phase E. Establish a Midland Project. Organization including elements to execute the quality achievement functions and a Quality Assurance
, Department (QAD) to independently assess conformance to-requirements ,
F. CP Co becomes accountable for technical criteria for Surveillance and Maintenance Phase activities, assuming the role of' design-organization G. Establish a Records Management Plan to preserve the existing records while accommodating the generation, use and preservation ., of records in the Surveillance and Maintenance Phase
'3.2.2 Scope Meet the objectives (i.e. the above principles) of the Surveillance and Maintenance Phase by a-series of planned and systematic activi-ties which provide adequate confidence that the quality of design 7' .
established in the systems, structures and components'of the plant at time.of shutdown is maintained. Maintenance of quality is confor-mance-to requirements or documented modification. A. Identified the principal quality achievement activities in the 3 Surveillance and Maintenance Phase as: M11284-0000A-MP03
=d Z
27 _" e (1) System layup (2) Preventive and corrective maintenance, -} (3) Remedial soils monitoring ;; (4) Equipment and materials storage "R (5) Corrosion monitoring (6) Salvage and sales
~
B. Support-these principal quality achievement activities by a number of additional safety-related activities. These "Q" - activities include: ' h (1) Maintain the Q-list 4 (2) Procurement to support maintenance activities (3) Indoctrinate personnel (4) Document control . (5) Manage inactive and active records c (6) Change control (7) Calibrate and control measuring and test equipment
>{
C. Independently apply four primary assurance methods (Q activities) L to the work to assure conformance to requirements. .. (1) Review (usually of procedures, maintenance work orders, . purchase orders, etc.) (2) Audit (usually of process and non-hardware oriented activi-
-- ties such as procurement, document control, etc.)
(3) Inspection (usually of hardware oriented activities such as maintenance, storage, equipment salvage) 2 (4) Analysis (of trends and overall effectiveness of the quality assurance program) D. Apply the additional safety-related ("Q") supporting activities, - principally: (1) Certify audit and inspection pereonnel . (2) Nonconformance management (3) Evaluate suppliers (4) Determine reportability in accordance with 10 CFR 21 and 10 CFR 50.55(e) (5) Corrective action management E. Manage all "Q" activities by a system of controls establishing the objectives of the activity and providing mechanisms for the successful completion of the activity. This management system is embodied in the Quality Assurance Program Plan (QAPP) for the Shutdown Phase of the Midland Energy Center: M11284-0000A-MP03 . _ _ _ _ _ _ _ _ _ _ _
, 28 1
(1); The ,QAPP represents the CP Co commitment to comply with Appendix B to 10 CFR.50, Land responds to the ANSI N45.2 series.of standards and corresponding regulatory guides 1
-l
, (2) The'QAPP was prepared by reviewing existing commitments and j _ regulatory requirements, and deriving. policies appropriate ! to the needs of the Surveillance and Maintenance Phase and
-consistent.with CP Co's financial constraints. !
'.~. l (3) The Plan,does not provide for ease of restart at some future date
=. .
. 1 (4)~ The QAPP supersedes Topical ~ Report CPC-1-A (Volume I), the .I Quality Assurance Program Procedures Manual 1(Volume II) and 1
.'the Quality Assurance related commitments in the' Final' Safety Analysis Report (5) Revision 0 of the QAPP was' submitted to the'NRC by CP Co- .
letter Serial 31666 on.0ctober 1, 1984
- 3.2.3- Interfaces .
The Quality Assurance Department oversees the_ Project's implementa-tion of the QA Plan. Project interfaces include:
- A. Engineering.and Licensing Department maintains the Classification of Structures, Systems and Components.(Q-list) which is the basis used by other organizations for differentiating "Q"~and "non-Q" activities
~
B. 0rganizations assigned accountability for the adequacy-of the criteria write the "Q" activity criteria . C. Using organizations review criteria for implementability and QAD reviews for inspectability and auditability. These'eriteria form the basis for-assessing the acceptability of the work
" Fortheir"Q"actvitIecallorganizationsissuewritteninstruc-
~D'.
tions which are reviewed:
, : '[ (1) By other organizations for interface control r- (2) By the QAD for-inspectability, auditability and conformance to the QAPP
~
E.- Instructions include identification of the records generated on: the quality of. items and activities affecting quality. Organiza-tions which generate quality records transmit such records to Documentation Services for processing . F. The QAD specifies-in-process notification points (for inspection L or audit) to other organizations when necessary to achieve quality objectives. Implementing organizations notify QAD at the
- MI1284-0000A-MP03
i l l 29 Y specified point and assure that work does not proceed without a QAD decision..
~G. Organizations generating procurement. documents specify the quality-assurance elements ~ applicable to the. procurement. Teh QAD~ reviews; procurement documents for conformance to the QAPP
-H. -Bechtel and~B&WCC personnel are assigned to the QAD to overview-
' activities related to ASME code requirements. . Procedures;used b'y Bechtel and B&WCC are approved by an assigned CP Co organization .
D 9 4 MI1284-0000A-MP03
30 3.3 LAYUP & MAINTENANCE PROGRAM 3.3.1 Principles This program based on specific technical requirements shall: A. Assume a several year period before Project reactivation. This
, assumption requires placing the plant into a layup condition B. Minimize cash resources required of CPCo as much as possible, while . maintaining the option to restart the Project or to sell the equipment C. Keep the equipment within appropriate environmental conditions, clean, and exercised as necessary. Along with specific instruc-tions for the ec.uipment, maintain the environment in the perma-nent plant buildings in accordance with industry recognized standards D. Maintain configuration control such that in the event of con-struction restart the documented modifications cade during the Surveillance and Maintenance Phase can be dispositioned E. Implement a corrosion monitoring program. Early indication of a corrosion problem is necessary to alert the plant staff of a possible need to change the Layup & Maintenance Program F. Meet the quality requirements specified by the Quality Assurance Department 3.3.2 Scope 3.3.2.1 System Layup & Maintenance A. Review available information to establish a Layup & Maintenance Program. The sources of this information are:
(1) Vendor recommendations (including applicable equipment standards; eg, IEEE, ANSI, etc) (2) Programs in existence at other plants (3) EPRI recommendations for system layup (4) Information generated as part of Unit 1 deferral (5) Released plant design documents (6) Existing Bechtel, B&W, Zack and CP Co Operations Department programs for maintenance requirements that are consistent with layup conditions. Equipment included in existing maintenance programs are reviewed for changes. I MI1284-0000A-MP03
31
~
_ (7) - Discussions with knowledgeable CPCo employees who have
. specific expertise in system layup and maintenance B.- A Layup-& Maintenance Review Committee (LMRC), consisting of maintenance, quality, and~ engineering personnel,~ is established to review each "Q" maintenance work order to assure that:
(1) Established ~ maintenance criteria are met (2) Work instructions provide acceptably consistent results (3) Work instructions are inspectable and auditable C. Base the Layup & Maintenance Program on equipment cost, complexi-
;. ty,' design function, or potential for resale. ~ Equipment not included in the Layup & Maintenance Program is. excluded. based on cost effectiveness assuming a shutdown of several years 3.3.2.2 Soils EA. Stabilized the Auxiliary Building, Service Water Pump Structure (SWPS), Borated Water Storage Tanks, and~all miscellaneous yard excavations by the use of temporary fill, soil stabilization grouting, and/or lean fly. ash backfill .
B. Left the soils work in the Auxiliary Building'and SWPS in a stable condition with minimal monitoring and maintenance jacking planned s C. Perform routine-checks of the support rod tension in the Feedwater Isolation Valve Pits D. Monitor. settlement markers with Electric Transmission Engineering
& Construction-Department survey personnel as required 3.3.2.3 ASME Code Items .
The following agreements were reached with the on-site N-Stamp holders (Bechtel and B&W Construction Company): ,
- A. The ASME Code items remain the responsibility of the N-Stamp ,
holder. , B. All ASME records remain intact and controlled on site. Provide written notification to the Bechtel and B&WCC Quality Control Engineer of_any additions, deletions or changes to the ASME files C. Provide necessary Quality Assurance and Quality Control services when required to monitor the ASME items D. ASME materials in storage remain segregated from non-ASME materials MI1284-0000A-MP03
32 v E. The Bechtel and B&WCC Authorized Nuclear Inspectors conduct
-periodic audits at the site to review the documents and equipment L3.3.2.4 Program Implementation -
The MidlandLLayup & Maintenance Program establishes the frequency of' checks. institutes a corrosion monitoring program, and establishes the frequency of physical activities such as equipment rotation,
. desiccant change out, and coating restoration. Examples,of the program are:
A.: Energize, where practical, the heaters supplied with motors. Other motors may be protected with' desiccant B. . Monitor piping and tanks for cleanliness and corrosion both by visual checks and a corrosion monitoring program using coupons C. Rotate rotating equipment (eg, pumps, motors, compressors, fans,
;etc) periodically as specified D. Maintain all motors 20 HP and greater in a Class B environment
-and rotate' periodically Layup_the low-pressure and high-pressure package boilers and E.
their auxiliary equipment using~ desiccant to preserve their integrity. Check desiccant periodically-1 F.- Laid up the primary system.(ie, reactor _ vessel, steam generators,
- . pressurizer,. piping, etc) using desiccant and maintain as speci-
- fied by B&W G. Protect the turbine and those specified systems, including the shell side of tho steam generator, with dehumidified air. Rotate the turbine weekly (ie, place on turning gear) and maintain the lube oil systems in an operational condition
-- H. Identified and drained those systems which were' wetted and are not in use .(eg, component cooling water system, service water system, and systems wetted for-startup testing purposes)'
I. Completed a review of Nuclear: Operations Department and Bechtel programs for maintenance on' stored / warehoused equipment. Develop the maintenance procedure ? 3.3.3' Interfaces I g Operations and Maintenance Division conducts the maintenance with' interfaces such as: A. On-Project: I L .(1) Engineering & Licensing Technical Sup; ort (a) Generates the requirements I _MI1284-0000A-MP03 ,
33 (b) Receives O&M feedback to resolve comments-and sugges-tions for incorporation into the Layup & Maintenance Program (2) Quality Assurance Department reviews "Q" work orders and overviews the maintenance on "Q" equipment B. Off-Project: (1) General Office - engineering expertise not available on ' site, as needed
-(2) Other utilities - information on_ specific issues, as needed (3) Vendors - informal discussions on specific issues with no purchase orders required, as needed (4) B&W (Lynchburg) - information on specific NSSS issues, as needed (5) System Protection and Laboratory Services Department -
material and testing equipment calibration, and analysis of corrosion coupons, as needed (6) Maintenance and Administrative Services Department - evalu-ate station battery data, periodically (7) Wiss, Janney, Elstner Associates, Inc - building monitoring equipment maintenance and calibration (soils) (8) Mergentime - jacking and underpinning maintenance activities (soils)- 9 e lMI1284-0000A-MP03
- u. .
34 3.4~ SALVAGE & SALE PLAN The Salvage & Sale Plan is a. carryover demobilization activity for accounting purposes.and not part of the Surveillance and Maintenance Plan. 3.4.1 ~ Principles The plan is based on the following general principles: A. Allow a period of two years,-1985 and 1986, to see'whether some outside party is interested in committing the necessary funds to enable the plant to be~ completed B. During this two year period sell any component or system in the plant but only after an evaluation that ensures the plant comple-tion option is not impacted significantly
.C. Dispose of salvage equipment,_ tools and materials from the plant in accordance with the existing Company policies: Salvage Policy and Procedure HMS-317-l' D. Sell other equipment, tools and materials to outside parties in-accordance with Company policies. These policies are developed for the Midland Plant and address such issues as pricing, engi-neering, construction and regulatory impact. Pricing for items sold is based on relative worth, replacement cost, removal and reinstallation' cost and other financial considerations 3.4.2. Scope A. The following items are included in the scope of the Salvage &
Sale Plan: , (1) Construction-related items:
.g (a) . Heavy equipment such as trucks, buses and automobiles (b) Smaller. equipment such as pumps, generators and port-able welders (c) . Tools such as small hand items and larger,
' power-operated devices (d) Consumables_such as veld rod, office supplies, light
' bulbs and lubricants (e) Bulk materials such as lumber, scaffolding and fasteners -
(f) Generally, any item.of a temporary, construction
~
related nature
~MI1284-0000A-MP03
s 35 E , I (2) .Non-installed items:
^
(a) Spare parts and general stores purchased for support of an operating plant (b) , Permanent plant items not yet installed such as pipe hangers, instruments, wire and cable ,
-m (c) Generally, any item which may become part of the permanent plant installation-(3) A11' installed components, systems and structures as a whole, or in part, of the permanent plant B. The following major issues and activities are included in the scope of.the. Salvage & Sale Plan:
( 1) Establish the priorities and schedule to define which items to process in what order ( 2) Develop.and maintain an up-to-date, accurate inventory of all items not installed but located at the plant including-all.. temporary, construction-related items, spare parts and general stores. Merge construction-related items into the spare parts and stores inventory wherever possible
,( 3) Develop and maintain an up-to-date,~ accurate inventory of.
all permanent items installed.in the plant
-( 4) Develop and maintain the-listing of surplus / unneeded items to be salvaged
(-5) Develop a procedure for the removal of installed equipment and material from the plant. This procedure will assure-that both removed items and those-left in place are pro-tected properly . ( 6) Ensure that salvage material is properly stored and main-
.tained as required ,,
( 7) Define and maintain the required supporting documentation addressing such items as maintenance, quality and commercial records
-( 8) Develop and maintain the inquiry listing for plant equip-ment, tools and materials from both interested outside.
parties and other Company facilities ( 9) Develop a policy for the sale and pricing of items sold to outside parties (10) Perform and coordinate the required research and analysis to determine the economic and technical feasibility of the sale.of all plant equipment, tools and materials to
. MI1284-0000A-MP03-
l l 36 interestedotherparties.bothinsideandoutside[the Company. . (11) Develop a marketing plan, including an advertising policy, for use at the nationwide level 3.4.3 Interfaces The Facilities and Materials. Division implements this plan and maintains the interfaces, including:
-A..: Coordinate with Material Services Department,'as required, in implementing the Salvage Policies and Procedures B. Coordinate with Engineering & Licensing Department to_ incorporate the technical and regulatory aspects of sales to other parties C. Coordinate with other groups as required; Purchasing Department.
-Regions, Plants i
i i' L. l I r MI1284-0000A-MP03
37 3.5 SECURITY PLAN 3.5.1' Principles , 'In implementing this plan, the following principles were established: A. Site security coverage shall be on a 24 hours a day, 7 days a
. veek basis using a contract security force with CP Co oversight B. .The-fire prevention and protection program shall comply with Company: fire protection standards and with-fire insurance
-requirements 3.5.2 Scope
-A. Security (1) Provide security vehicle and foot-patrols.and man site-access gates 24 hours a day, 7 days a week-
.(2) Conduct ongoing traffic and access control,' incident investigation, and site badging services. In addition, personnel and vehicle inspections and key control. services
- continue on a daily basis (3) Monitor site fences and other boundaries for signs of unauthorized activity. Take action in accordance with Division policies when such activity is discovered
~
(4) Monitor contract security force performance. . Participate in contract negotiations to acquire or alter contract security services (5) Coordinate security force training programs with Property Protection Department and contract security agency-personnel B. -Fire Prevention and Protection (1) Coordinate fire brigade training for both Operations & Maintenance and Security Divisions personnel s (2) Provide fire watch' coverage on a round-the-clock basis (3) Monitor the testing, inspection, and maintenance of fire detection and suppression systems and equipment 4 (4) Conduct fire safety inspections of buildings and facilities (5) Investigate any-fire incidents MI1284-0000A-MP03
, . - . . . _ . , , ~ . . _ _ __ -
s
._==
-5 "-
38 A i me 3.5.3 Interfaces y
=
The Security Division implements this plan and the interfaces, such 5 as: $ i
.A. Coordinate with other Site Divisions to facilitate the shipment of material off site while maintaining proper security e B. Coordinate with the Property Protection Department for security -
contract administration, fire brigade training, security force .. training, and fire insurance matters T
?
C. Coordinate with Site Management, the Property Protection Depart-ment, and other appropriate Site Divisions regarding fire detec- 1 tion and suppression system needs and fire water supplies ;
.. =
D. Conduct liaison with local police and fire agencies 1 5 m k w
'E w:,
m h 5 5 [ 5 e MI1284-0000A-MP03
7 n, r. 39
-3.6 ~ RECORDS MANAGEMENT PLAN 3.6.1 Principles' l The. Records Planishall:
A.~= Minimize the cost to preserve inactive and active records
~. . . .
B. Meet user requirements for inactive and active records C. Process records to support surveillance and maintenance
. activities 3.6.2 . Scope A. Establish the requirements, responsibilities, and' methods for
- processing inactive and active records B. Include all inactive and active records, regardless of who generated them and where they are presently. located C. Apply to organizations who are responsible for processing records-D. Meet the needs of: the Project Surveillance & Maintenance Organization; suppliers who have transferred records'to CP Co and who may need access to those records; and other organizations who may have a legitimate reason for requesting access to or. copies.
of. records E. Classify-records generated prior to shutdown as " inactive" (not needed for continuing activities) or " active" (needed for contin-
~
uing activities). Records generated after shutdown are classified. as active if they do not relate to records inprocess at the time of shutdown or inactive if they relate to records'in process at the time of shutdown a F. Separate active records from inactive records , G. Maintain records that were in Document Control Centers or Records . .- Centers at the time of shutdown as they were to' facilitate retrieval H. Retain records 1Ln Company records management systems and retrieve . them through.those systems it. Process active records according to established procedures to support the continuing activities of shutdown, and surveillance JJ and maintenance
- 3.6.3 Interfaces ,
[ Services Division implements this plan and maintains interfaces, including:
.MI1284-0000A-MP03-
. _ , _.-_ a _ _ .,_.._;..____ . - _ _ . _ . _ _ _ . . _ _ _ . . _ _ . _ _ ._ __.
m-w
;p 40
.e r
A. All Project and several off-Project organizations as the. focal _ point for~ processing inactive and, active: records B. Other CP Co records management organizations (Engineering Records
~ Center, Management and Budget Department, General Files Depart-ment) to support'the. records management effort m
9 N - M11284-0000A-MP03'
41 4 3.7 ' + FUTURE PI.ANNING CONSIDERATIONS-The Surveillance'and Maintenance Phase described in this plan is essentially a continuing or steady-state operation until a conclusion - ' is. reached regarding the final disposition of the facility. Another
'part-of the. work to be done-during this phase is the exploration and evaluation of possible disposition options and the initial planning
'that precedes any final conclusion.
- 3.7.1 Facility Disposition Outcomes 4
.- One desirable resolution of'the Midland disposition question being pursued by the Company is to complete.and use one or both units for their. intended purpose. However..as noted in the J D Selby interrog-atory response-(see Attachment A),' Company financial circumstances.
- require facility abandonment for_ tax loss purposes no later than 1987. -Therefore, the expected duration of the S&M Phase is two years or less. and the possible outcomes of the facility disposition questions are:
A. ., Completion of'one or both units under some different ownership
. arrangement B. Abandonment of~one or both units for the. purpose of claiming an income tax loss .. C. Some combination cf both +
3.7.2 .Fu'ture Planning Considerations fCurrent planning by the Project staff for these possible outcomes is-limited and future planning vill be guided by'the following considerations: A. Facility Completion Section 3.13 of the Project Shutdown Plan. summarizes che steps identified for reactivation the Project. Prior to undertaking those-activities, additional, more basic decisions are required to define the organization (s) involved in completing the plant B. Facility Abandonment
'The first step in planning for facility abandonment is to fully understand the requirements and practice under the income tax laws regarding abandonment. Thereafter the scope of the continu-ing sale and salvage operation.can be established. In addition, the Company responsibilities for final facility and site condi-
- . tion under its existing licenses and permits and under other applicable regulations and laws must be determined. With these issues defined, the Surveillance and Maintenance Plan can be revised to define how and by whom the facility abandonment is carried out.
1 MI1284-0000A-MP03
s 42 4.0' STAFFING'AND COST ESTIMATE
' This section of the Surveillance and Maintenance Plan defines:
- A. ' The bases and qualifications used to prepare the cost estimates
; B.'_The staffing requirements for the S&M Plan through 1986 C. The cost estimate for 1985 and a planning year cost estimate for 1986 L4.1 BASES AND QUAI.IFICATIONS A. The S&M cost estimate was developed based on the functional plans
- in Section 3 and in accordance with the following criteria:
(1) Minimize costs necessary to retain the Construction Permit (2) Exclude resources for preparation to restart construction or to abandon the plant (3) Maximize use of Company personnel and minimize use of contractor personnel B. -The cost estimate does not include: , (1) . Credit forfsalvaged material
.(2) . Payoff of long-term leases for equipment not used for maintenance or surveillance
- (3) -Property tax payments during 1985 and 1986 (4) Pension and payroll costs, administration and general ,
costs, or escalation >-e- 4.2- STAFFING PLAN 4 Table 4-1 defines the staffing plan-for the S&M effort through c - December 1986. The manpower requirements are broken down by the
. major depcrtments as shown in the Project S&M Organization, Section-2. ,
4.3: COST ESTIMATE
- Table 4-2 summarizes the estimated cost for the S&M Phase of the Midland Project Shutdown. The S&M Phase starts January 1, 1985 and is assumed to last two years while the ultimate disposition of the I
plant is determined. The cost estimate includes the staffing defined in Table'4-1 and is based on the criteria and qualifications defined j in Section 4.1. 1 NI1284-0000A MP03 s+-- eav w -,e -- e-c s .su.~ ,-- , - - - , . ,,--na- ,, .,.w.,--.- , , ,- -.,. -,,-, , - - - . ,,. ,--- - --.,,, ,,-,-e, e,-es.- -,,, ,, -~-
43 TABLE 4-1 SURVEILANCE AND MAIh*IENANCE STAFFING, PLAN Quarters Year 1985 1986
'l 2 3 4
. Engineering & Licensing
.EA&P - 4 4 4 4- 4 1 SE-W 1 1 1 -1 1 Subtotal 5 5 5 5 5 l Administration EA&P 1 1 1 'l 1
,SE-W 1 1 1 1 1 Subtotal 2 2' 2 2 '2-Schedule &' Cost
.EA&P .2. 2 2. ~2 2 SE-W- 1 1 1 1 1 Subtotal 3 3 3 3 3
' Quality Assurance L
EA&P- 14 10- 10 10 10
-SE-W' 3 3 3 3 3 Subtotal- 17 '13 13 13 13 ISite Management-I EA&P 38 38 38- 38 38
,,. SE-W 28 28 28 28 28 0M&C . 41 41 41 41 41 Subcotal 107 107 107- 107 107
-. Total On-Project
'EA&P 59 55 55 55 55 SE-W . 34 34 34 34 34 OM&C 41 41 41 41 41~
. Total 134 130 130 130 130 l Off-Project (CP Co) (Equivalent) 7 7 7 7 7 . . Contract (Security) 15 15 15 15 15. (Other)' 1 1 1 1 1 iTotal Project '157 153 153 153 153 MI1284-0000A-MP03 i.
44 TABLE 4-2 SUREVILLANCE AND MAINTENANCE COST ESTIMATE ($X1000) 1985 1986 Total Salary 4,235 4,200 8,435 ar Paid Absence 116 115 231 LBusiness Expense 209 210 419 Training Expense 41 40 81 Subtotal. 4,601 4,565 9,166
-Contracts Site 873 790 1,663
~ Contract Manpower ,
82 80 162 CP Co Off-Project. 392 395 787 Subtotal 1,347 '1,265 2,612 Computer 1,480 1,480 , 2,960 Other Miscellaneous 545 540' 1,085 Subtotal. 2,025 2,020 4,045 Contingency 795 782 1,577 Total S&M Cost Estimate 8,768 8,632 17,400 W
.- a :
.MI1284-0000A-MP03
L': ' m p i
- 5 .
V
+-
J [_ ATTAC1DfENT A
-J D SELBY' RESPONSE',(NOVEMBER 1, 1984),
' TO MPSC RATE CASE U-7380 INTERROGATORY 3A-AB-69'
; ~l, s
d 3 A 4
-Y
'^.
A s h h
. 'MI1284-0000A-MP03
l 53A-AB-69 N00049333 l
- ~
DQuestion: c 1' :In Mr. Spring's testimony, Page 7, he states that it was -assumed that 'a decision will be made in 1987 to abandon the Midland Plant. Why is' l
' Consumers' Power waiting'until-1987 to finalize'the abandonment deci- !
-sion? Please provide.'any studies that. support that decision.
. Answer:
~
Consumers Power Company is not;watting.unct1:1987:to: finally determine what it I. , will be doing 'with the Midland plant now that construction has ceased. The. Company-
- is7 not: planning to resume Midland construction or to spend any money for that purpose in~1985, '1986 or anytime in the future. ..The company will not unilaterally..
- resume Midland (construction 'in,1985, 1986.or thereafter. Only if+ appropriate governmental' agencies :and of ficials ' propose resumption of' construction. by Consumers Power Company as being - in - the ' public . interest, and ' 6e financial-cosinunity ' or - somedne else is willing to conunit' the funds necessary to enable
' completion, will the Company consider resuming construction. In order to maximize -
recovery ,-- the Company -intends .co carry out two years of surveillance and maintenance activity on the plant and has taken steps.co have its NRC construction
~
permits continued.' It' has also solicited bids on the S'00 million of nuclear fuel Lwhich would have been used.at Midland in an effort to dispose of the fuel. The
- surveillance 'and ; maintenance activity wi}1l cost approximately $10 million ' per year'plus. property taxes. . By keeping the plant properly maintained and retaining the construction permits the Company has a more marketable product because it will be 'able to keep a documented,. NRC-approved- quality assurance program in place during.that period. The Company's plan is to allow two years to see whether some outsider who is interested materializes. In the meantime, the Company will- sell' any component or system in the plant .that - does not prevent possible use of the
. plant-as a whole. If there is no one interested in finishing the entire planc,- the Company will'no later than 1987 do whatever_is necessary to claim an abandonment loss for federal income tax pur po'se s . The income tax implications of this
- decision have been explained by Mr. Schwass and'Mr. Spring. See the response to l
3A-AC-107 and 3A-AC-188. John' D. Selby. being first duly sworn, states that the above response is
$ true'and correct to the best of his knowledge, information or belief.
~ -
/
?
Sworn - to before me and subscribed in my presence th s 1st day of , November, 1984. d +7bk W Debra Lynn Mille # Notary Public ' Jackson County, Michigan
'My Commission Expiresi
'Q
, -- .~____ -
. . , _ , _ . , , _ . _ __. ,_ _}}