ML19326D473

Forwards Util Responsive Positions,Per 750815 Ltr,Re Reg Guides 1.28,1.30,1.37,1.38,1.39,1.58,1.64,1.74,1.88 & 1.94, & ANSI N45.2 Stds.Reg Guide 1.54 Response Will Be Submitted W/Miscellaneous Positions

ML19326D473
Person / Time
Site:	Midland
Issue date:	10/15/1975
From:	Bauman R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
1841, NUDOCS 8006110505
Download: ML19326D473 (23)

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, P0'.73T i CDmp3ny General Omces: 212 West Michtgen Avenue. Jackson. Michigan 49201. Area Coce S17 788-0550 October 15, 1975 h F

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QA Regulatory Guide Responses _p,$2-File: 0505.2 Serial: 1841 On August 19, 1975 we sent a letter to Mr. Angelo Giambusso containing a schedule for submittal and review of Midland Project QA Regulatory Guide Positions. That letter suggested the submittal of responsive positions for each QA Regulatory Guide by October 15, 1975, therefore, attached to this letter are responsive positions relative to Regulatory Guides 1.28, 1 30, 1.37, 1 38, 1 39, 1 58, 1.64, 1.74, 1.88 and 1 94 l The response to Regulatory Guide 1.54 will be submitted with the j miscellaneous Regulatory Guide Positions. Also attached are responsive 1 positions to draft ANSI N45.2 standards, N45.2.8, N45.2.12 and N45.2.13 While much of the activity relative to the Midland Project is being performed in accordance with the attached positions, exceptions to full compliance do exist. Upon completion of the review cycle with the NRC ,

of the attached responsive positions, Consumers Power will determine j how best to modify its Quality Assurance Program and obtain modification l to Bechtel's and Babcock and Wilcox's Quality Assurance Programs to I implement the responsive positions for the remainder of the Midland Project nuclear Safety related activities. Appropriate effectivity dates will be selected and submitted to the NRC in February,1976.

In the August 4, 1975 " Staff Position Implementation of Regulatory Guides for the Midland Plant, Units 1 and 2", Guideline D states:

"The plant should conform to all Guides applicable to quality assurance, surveillance, and reporting procedures. 'Ihe staff will consider exceptions from such guides only in instances where the plant design, procurement, fabrication or construction would have to be modified to conform to the THIS DOCUMENT CONTAINS 8006110 g/g POOR QUAllTY PAGES 32.273

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,. .. File: 0505.2 Serial: 1841 .

Guides." Sufficient review has been perfomed by Consumers Power, Bechtel and Babcock and Wilcox to know that even given a proper regard for the effectivity dates discussed above, it will be necessary to request consideration of exceptions from the responsive positions. For example, while the responsive position relative to a Re6ulatory Guide will be applied to all procurement documents issued after the effectivity date for the position, Consumers Power may have to seek relief in the imposition of the responsive position for existing procurements. A more detailed analysis of the need for exceptions will be perfomed after completion of the review cycle (with the NRC) of the attached responsive positions. The results of this review will also be submitted to the NRC in February, 1976.

We have been informed by Mr. Sam MacKay that the NRC has scheduled a meeting to review the attached positions on November 14, 1975.

R. C. Bauman Project Engineer RCB/HWS/mc

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k REGULATORY GUIDE 1.28-QUALITY ASSUR/.NCE REQUIRDIEITfS (DESIGN AND CONSTRUCTION)

A. Consumers Pouer Activities

References:

Regulatory Guide 1.28 ANSI N45.2 - 1971 Gray Book Section D-1 During the Design, Procurement and Construction Phases of the Midland Project, the Consumers Power Quality Assurance Program implements the guidance contained in Regulatory Guide 1.28, and Section D-1 of the " Gray Book" (Guidance on Quality Assurance Requirements Daring Design and Procurement Phase of Nuclear Power Plants-Revision 1) for safety-related activities not delegated to '

its Architect-Engineer, Nuclear Steam Supply System Supplier, or Construction Contractor with the following exception:

Subsection "a" of Section D-1 in the Gray Book requires that, "A schedule of all safety-related nuclear power plant activities to be performed by each organization along with the required procedures or instructions to implement the corresponding quality assurance program for the activity should be prepared (and periodically updated to indicate status) to assure timely development, approval and implementation of these quality assurance procedures or instruc-tions prior to initiation of the activity." Consumers Power does not have a schedule relating to timely development, opproval and implementation of procedures and instructions. In lieu of this schedule, Consumers Power does require that quality assurance pro-cedures be prepared (and revised when necessary) and does verify, during audits, that the procedures have been prepared and are being implemented.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

References:

Regulatory Guide 1.28 (6/7/72)

ANSI N45.2 - 1971 Gray Book Section D-1 The Midland Project complies with the referenced Standard for safety cnd related items.

C. Babcock and Wilcox (Fuelear Steam Supply System Supplier) Activities Reference : B&W Topical Report EAR-LOO 96A, Rev. 1 The B&W position for activities not, yet completed or remaining to be done, with proper regard for effectivity, is contained in B&W Topical Report BAW-LOO 96A, Rev. 1 "B&W NPGD Quality Assurance Program for Nuclear Equipment." -

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.. . REGULATORY GUIDE 1.30 QUALITY ASSURANCE REQUIR31EI.TS FOR THE INSTALLATION AND TESTING OF INSTF3tENTATION AND ELECTRIC EQUIR4ENT A. Consumers Power Activities

References:

Regulatory Guide 1.30 (8/11/72)

AN3I K45.2.4 - 1972 During the Design, Procurement and Construction Phases of the Midland Project, the Consumers Power Quality Assurance Program implements the guidance contained in Regulatory Guide 1 30 for safety-related activities. Many of the activities addressed by this guide are delegated to Consumers Power's Construction Contractor but Consumers does conduct a preoperational test program which complies with the testing requirement of the Regulatory Guide.

B. Bechtel (Construction Contractor) Activities i

Reference : Bechtel Topical Report BQ-TOP-1, Rev. lA The Bechtel Quality Assurance Program will comply with the position contained in its Topical Report #BQ-TOP-1, Rev. lA "Bechtel Quality Assurance Program for Nuclear Power Plants."

C. Babcock and Wilcox (Nuclear Steam Supply System Supolier) Activities

. Reference : B&W Topical Report BAW-10096A Rev. 1 The B&W position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in B&W Topical Report BAW-10096A, Rev. 1 "B&W NPGD Quality Assurance Program for Nuclear Equipment."

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. QUALITY ASSUPANCE REQUIRH4E:;TS FOR CLEANING OF FLUID SYSTH/G AND ASSCCIATED COMPONENTS OF WATER-COOLED NUCLEAR PCWER PLAUTS A. Consumers Power Activities

References:

Regulatory Guide 1.37(3/16/73)

ANSI U45.2.1 - 1973 During the Construction Phase of the Midland Project, Consumers Power delegates activitics relative' to Regulatory Guide 1.37 and ANSI N45.2.1 to its Construction Contractor.

B. Bechtel (Construction Contractor) Activities

References:

Regulatory Guide 1 37 (3/16/73)

ANSI N'45.2.1 - 1973 The requirements of the referenced Standard as modified in the Regulatory Position will be applied to cleaning activities specified or applied by Bechtel to safety related items as modified and interpreted below.

1) Section 2.1 Planning. The required planning in frequently performed on a generic basis for application to many ,

installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the Standard.

Individual plans for each item or system are not normally prepared unlet _ the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section 11 Paragraphs 2 and 3 of ANSI N45.2-1971 which provides for examination, measurement or testing to. assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

2) Section 4 Pre-Installation' Cleanness. Items stored in place will be treated as installed equipment and reasonable measures of protection will be exercised to prevent damage or deterioration.

3) Section 5 Installation Cleaning. The responsible engineer will determine the necessity for removing rust.

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EG. GUIDE 1.37

,, 4) Section 5 Installation Cleaning. The responsible engineer will determine the necessity for cleaning after completion

. of work on piping.

C. Babcock and Wilcox (Nuclear Steam Sucoly System Supplier) Activities

Reference:

B&W Topical Report BAW-10096A, Rev. 1 l The B&W position for activities not yet completed or remaining to be done, with proper re6ard for effectivity, is contained in B&W Topical Report PE,f-10096A, Rev. 1 "B&W NPGD Quality Assurance Program for Nuclear Equipment."

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, , REGULATORY GUIDE 1.38 QUALITY ASSURA1:CE REQUIPE ENIS FOR PACKAGING, SHIPPING, RECEIVING, STORAGE AND HANDLING OF ITmS FOR WATER-COOLED NUCLEAR POWER PLANTS A. Consumers Power Activities

References:

Regulatory Guide 1.38 (3/16/73)

ANSI Nh5.2.2 - 1972 During the Design, Procurement and Construction Phases of the Midland Project, Consumers Power delegates activities relative to Regulatory Guide 1.38 and ANSI N45 2.2 to its Architect-Engineer, Nuclear Steam Supply System Supplier and Construction Contractor.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

References:

Regulatory Guide 1.38 (3/16/73)

ANSI Uh5.2.2 - 1972 The requirements of the referenced Standard as modified and interpreted in the Regulatory Position will be applied to the Bechtel quality program for safety-related items, except as ,

, modified and interpreted below.

1) Section 2.7 Classification of Ite=s. The four level .

Classification system may not be used explicitly. However, the specific requirement for each classification as specified in the Standard will be applied to the items suggested in each classification and for similar items.

2) Section 2.7 Classification of Items. The listings in paragraph 2.7.1 through 2.7.4 will be used as a guide in determining the categorizing of items under levels A through D for the project. Categorization differing from Section 2.7 will be considered acceptable provided that no degradation in commodity quality is assured.

3) Section 2.7.4 Level D Classification. The last sentence 1st paragraph is interpreted to read "These items require pro-tcction against the elements, airborn contamination, and physical damage as necessary and commensurate with the ultimate use of the item."

4) Section 5.2.2 Receiving Item Inspection. For source inspected items, if damage to the package is evident at the time of receipt, receiving inspection will be performed in accordance with the appropriate portions of Para. 5.2.2. Also, prohibition

. relative to unpacking may be in documents such as specifications or instructions provided by the supplier.

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5) Section 6.2 Storage Areas. Paragraph 6.2.1. requires control and limited access to storage areas. In lieu of and to

, amplify this paragraph the following will be applied:

" Access to storage areas for level A, B'and C will be controlled by the individual (s) responsible for material storage." Level D items will be stored in a site area which will have access control consistent with Zone IV of AUSI N 45.2.3 - 1973 While the areas will be posted to limit access, other positive controls (other than that for the overall site area) or cuards may not be provided.

6) Section 6.2.2 Cleanliness and Housekeeping Practices in Storage Areas. Detrimental soil is defined as material or items uhich could degrade the stored material.

7) Section 6.2.h Storage of Food and Associated Items in Storage Areas. The control and use or storage of food, drinks and salt tablets dispensers shall be in accordance with the Bechtel position in response to Regulatory Guide 1.39. Food, drinks and salt tablots will be considered to be eating.

8) Section 6.2.5 Measures to Prevent Entrcnce of Animals in Storage Areas. Reasonable measures will be taken to minimize the incidence of entrance of rodents and other animals into indoor storage areas or equipment to minimize possible contamination and mechanical damage to stored caterial.

9) Section 6.5 Removal of Itecs from Storage. Ite=s stored in -

place will be treated as installed equipment and reasonable measures of Protection will be exercised to prevent damage or deterioration.

10) Section 7 2 Handling Methods and Procedures. All items do not require procedures and instructions. However, where they are used, they are written in compliance with provision of ANSI N45 2.15 (Draft 2 Rev. O).

11) Section 7.2 Handling Methods and Procedures. Pertinent

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features to be included in the procedures are arrived at by evaluating the overall operations. ,

12) Section 7.3.1 Hoisting Equipment Certification. Equipment l is rated, tested, certified and used in accordance with the requirements of OSHA.

13) Section 7.h Inspection of Equipment and Rigging. Insoection criteria are established by equipment manufacturers n'nd equipment superintendents and operating engineers. Additionally, Bechtel- has established. cquipacnt maintenance programs that are issued by the Safety and Equip:ent Department.

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. 'C . ' Babcock and Wilcox (Nuclear Steam Supply System Supplier) Activities

Reference:

MW Topical Report BAW-10096A Rev. 1 The MW position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in EW Topical Ecport EAW-10096A, Rev. 1 " mW nroD quality Assurance Program for Nuclear Equipment."

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., . REGULATORY GUIDE 1 39 HOUSEKEEPIUG REQUIRE'C.TS FOR WATER-COOLED EUCLEAR FO* DER PLAETS A. Consumers Power Activities

References:

Regulatory Guide 1 39 (3/16/73)

AUSI U45.2.3 - 1973 During the Construction Phase of the Midlend Project, Consumers Power delegates activities relative to Regulatory Guide 1.39 and ANSI U45.2.3 to its Construction Contractor.

B. Bechtel (Construction Contractor) Activities

References:

Regulatory Guide 1 39 (3/16/73)

AUSI U45.2.3 - 1973 The requirements of the referenced Standard will be applied to the Bechtel quality program for construction of safety related items except as modified or interpreted below:

1) Section 2.1 Planning. The required planning is frequently performed on a generic basis for application to many instal-lations on one or more projects. Ihis results in standard procedures or plans for installation and inspection and test-ing which meet the requirements of the Standard. Individual ,

plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case.

Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality.

2) Section 2.1 Planning. Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject Stancard. For example, situations in which-shoe covers and/or coveralls are required but material i accountability is not.

3) Section 2 1 Planning. It is the Projects intent to use four cleanliness zones instead of the five zones listed in this paragraph. These zones will provide the necessary cleanliness and will provide less confusion in the field. The requirements of zones I and II in the standard will be included in Zones A and B of the field procedure. The requirements of Zone III of the standard will be covered by including these items into Zone B or upgrading Zone C for the particular items. Zone IV will be included in Zone C except the restrictions on tobacco or eating is not required. This zone can be upgraded to include these restrictions for particular items if necessary.

/' <"eg. Guide 1 39 Zone V will be incorporated into Zones C or D as required.

NOTE:

Zone C provides no restriction except that the areas will be maintained free of detrimental scrap caterials' and will be swept regularly. Protective coverings will be utilized in work areas to minimize grease and oil spillage on finished surface. Zone D areas will be heavy construction areas without cleanliness restrictions and will be u) graded to Zone C when the heavy construction is completed.

Restriction List Zones A B C D Clothing changes Yes No No No Clean gloves, shoe covers, Yes Yes No No Head covering Filtered air Yes No No No Material precleaning Yes No No No Material accountability Yes Yes no No Personnel accountability Yes Yes No No No use of tobacco or eating Yes Yes No No

4) Para 2.2 Procedures and Instructions. This paragraph requires procedures for safety and fire regulations. It is the Projects intent to use procedures which describe ex.isting national, state and local codes and regulations to control safety and fire.

5) Para. 3 1 Convrol of Site Area. This paragraph requires .

grading, drainage, road, etc, to be in accordance with specified requirements. These items will not in all cases be specified but will be done in accordance with good working practices.

C. Babcock and Wilcox (Nuclear Steam Supply System Suppl ~ier) Activities

Reference:

BLW Topical Report-BAW-10096A Rev. 1 Activities relative to this Regulatory Guide are not within the B&W scope of supply.

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? .c REGULATORY GUIDE 1.58 QUALIFICATION OF UUCLEAR POWER PLAUT IUSPECTION, EXAMINATION AND TESTING PERSONNEL A. Consucers Power Activities

References:

Regulatory Guide 1 58 (August, 1973)

ANSI M45.2.6 - 1973 During the Design, Procurement and Construction Phases of the Midland Project, the Consu=ers Power Quality Assurance Program implements the guidance contained in Regulatory Guide 1.58 for safety-related activities. Many of the inspection, examination and testing activities addressed by this guide are delegated to Consumers Power Architect-Engineer, Nuclear Steam Supply System Supplier and Construction Contractor but qualifications for Electric Plant Projects QA personnel and qualifications for personnel conducting the preoperational test program will comply with the qualification requirements of the Regulatory Guide.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

References:

Regulatory Guide 1 58 (August, 1973)

AUSI U45.2.6 - 1973 The requirements of the referenced Standard as modified by the Regulatory position is applied to the Bechtel quality program for safety related items.

The Regulatory Guide states that the provisions of ANSI U45.2.6-1973, are " generally s'pplicable.........during fabrication prior to receipt of items at the construction site." Bechtel satisfies this Guide by performing the following activities to ensure that off site inspection, examination or testing is performed adequately. Bechtel performs surveillance inspection of suppliers by using qualified inspectors, also quality assurance audits are performed on suppliers and additionally, nondestructive examinations performed according to the quality requirements of Section III, of the ASME Boiler and Pressure Vessel Code are performed by supplier personnel certified to SUT-TC-1A.

C. Babcock and Wilcox (Nuclear Steam Supply System Supplier) Activities

Reference:

B&W Topical Report BAW-10096A, Rev.1 The B&W position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in B&W Topical Report BAW-10096A, Rev.1 "B&W NPGD Quality Assurance Program for Nuclear Equipment."

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References:

Regulatory Guide 1.64 (Revision 1)

ANSI R45.2.11 - 1974 During the Design Phase of the Midland Project, Consumers Power delegates design activities relative to Regulatory Guide 1.6k and ANSI R45.2.ll to its Architect-Engineer, Nuclear Steam Supply System Supplier, and Construction Contractor.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

Reference:

Bechtel Topical Report BQ-TOP-1, Rev. lA The Bechtel Quality Assurance Program will comply with the position contained in its Topical Report #EQ-TOP-1, Rev. lA "Bechtel Quality Assurance Program for Nuclear Power Plants."

C. Babcock and Wilcox (Nuclear Steam Supply System Supplier) Activities

Reference:

B&W Topical Report ,

BAW-10096A Rev. 1 The B&W position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in B&W Topical Report BAW-10096A, Rev. 1 "B&W NPGD Quality Assurance Program for Nuclear Equipment."

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REGULATORY GUIDE 1.7h QUALITY ASSUPECE TERMS AND DEFIITITIONS A. Consumers Power Activities

References:

Regulatory Guide 1.7h (February, 1974)

ANSI Uh5.2.lo - 1973 .

During the Design, Procurement and Construction Phases of the Midland Project, Consumers Power uses the definitions of terms provided in ANSI N45.2.10 for safety-related activities with the following exceptions :

Audit is defined as "A documented activity performed in accordan'ce with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of a quality assurance program have been developed, documented and effectively it'plemented in accord-ance with specified requirements. An audit does not include surveillance or inspection for the purpose of process control or product acceptance."

Construction Phase is defined as " Activities at the building sita necessary to erect and verify proper installation and performance of nuclear power plant facilities prior to initial fuel loading."

Nonconformance is defined as "A deficiency in characteristic, documentation, or procedure which renders the quality of an

• item unacceptable or indeter=inate and which is considered  ;

significant to quality or safety. Examples include: Physical defects, test failures, incorrect or inadequate documentation, deviation from prescribed processing, inspection, or test procedures."

Procurement Documentation is defined as " Purchase Requisitions (Pas), Purchase Orcers (fos), Division Purchase Orders (DPCs),

Returned Material Requisitions (RMRs), drawings, contracts, i specifications, and instructions used to define requirements for l the purchase of materials, equipment or services.

B. Bechtel (Architect-Encineer and Construction Contractor) Activities

References:

Regulatory Guide 1.74 (February, 1974)

, ANSI N45.2.10 - 1973 The require =ents of the referenced Standard as modified by the Regulatory Position will be applied to the Bechtel program for safety related items. subject to the following exception:

.  ;. Guide 1.74

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ANSI N45.2.10 includes core, support structure in the listing of examples of' components but the Bechtel " quality Assurance Manual ASME III, Nuclear components Division I" includes core support structure in the listing of examples of-items.

C. Babcock and Wilcox (Uuclear Steam Supply System Supplier) Activities Reference : B&W Topical Report

• BAW-100C6A Rev. 1 The BLW position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in BSW Topical Report BAW-lC096A, Rev. 1 "BLU NPGD Quality Assurance Program for Nuclear Equip =ent."

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REGULATORY GUIDE 1.88 COLLECTION, STORAGE AND MAIITENANCE OF NUCLEAR POWER PLAIE OUALITY ASSURANCE RECOPSS A. Consumers Power Activities

References:

Regulatory Guide 1.88 (August,1974)

ANSI N45.2 9 - 1974 During the Design, Procurement and Construction Phase of the Midland Project, the Consumers Power Company quality Assurance Progrem implements the guidance contained in Regulatory Guide 1.88 for safety-related activities with the following exception:

Section 5.6 of ANSI R45.2.9 requires that the permanent record storage facility have " structure, doors, frames , and hardware should be Class A fire-rated with a recommended four-hour minimum rating." In lieu of this the existing Consumers Fower permanent record storage facility has a two-hour fire rating.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

References:

Regulatory Guide 1.88 (August, 1974)

ANSI U45.2 9 - 1974 Bechtel complies with the Regulatory Guide for safety related items with the following exception: Section 5.6 of ANSI N45.2 9 requires that the permanent record storage facility have " structure, ,

doors, frames, and hardware class A fire rated with a recommended <

four hour minimum rating". In lieu of this the existing Jobsite record storage facility has a two hour fire rating.

C. Babcock and Wilcox (Nuclear Steam Supply System Supplier) Activities

References:

Regulatory Guide 1.88 (August, 1974)

ANSI R45 2 9 - 1974 The B&W position in response to this Regulatory Guide is as follows:

This guide endorses ANSI N45.2 9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records 'for Nuclear Power Plants" for use in compliance with Criterion XVIII of Appendix B l to 10CFR50. The majority of such records are, of course, the respon-sibility of the plant owner and this guide should be considered in planning the QA record keeping system. For those records which are the responsibility of B&W, NPGD's Records Retention Program has been designed to comply with this Regulatory Guide.

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, REGULATORY GUIDE 1.94 QUALITY ASSURANCE REQUIRE 4EITIS FOR INSTALLATION, IN3PECTION. AND TESTING OF STRUCTURAL CONCRETE AND STRUCTUPAL STEEL DURING THE COUSTRUCTION PHASE OF UUOLEAR PO'4ER PLALTS A. Consumers Pcwer Activities References : Regulatory Guide 1 94 (April, 1975)

ANSI N45.2.5 - 1974 During the Construction Phase of the Midland Project, Consumers Power delegates activities relative to Regulatory Guide 194 to its Construction Contractor.

B. Bechtel (Construction Centractor) Activities

References:

Regulatory Guide 1 94 (April, 1975)

ANSI N45.2.5 - 1974 Bechtel complies with the referenced Regulatory Guide and ANSI Standard with the following exceptions:

1) Section 1.4 Definition of Sampling Point. See the comments on Section 4.8 belcw.

2) Section 3.2.1 Qualification Tests. Table A requires that Liquid Membrane Curing Compound be qualification tested to ASIM C-309 The Midland Project does not require such tests; instead materials are reviewed and approved by Project Engineering prior to use.

3) Section 4.5 Concrete Placement. Regulatory Guide 194 (C-3) requires that ACI-309-72 be used to determine the adequacy of consolidation equipment; the Project concrete specification relative to consolidation is based on ACI-309-70.

4) Section 4.8 In-Process Tests on Concrete and Reinforcing Steel.

This section requires sampling of pump concrete at the end of the pump line. On the Midland Project, cylinder samples are collected at the centralized batch plant for all types of concrete placement. Further, for pumped concrete the sampling point for other than cylinders is at the truck discharge rather than the pump discharge, with a correlntion program to the pump discharge as recommended by ACI-304.

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5) Table B Required In-Process Tests. Relative to the tests listed in Table B the following co==ents apply:

a. Mixer Uniformity: The Midland Project uses the EMCA

" Certification of Ready-Mixed Concrete Production Facilities" rather than ASTM C-94

b. Air Content: Bechtel runs 1 test per every 100 C.Y.' when cylinders are cast. This is consistent with AEC's Guide (Creen Book) dated May 10, 1974

c. Compressive Strength of Grout: The grout is a preapproved canufactured bulk item; further compressive tests are not deemed necessary. (The percent expansion is determined in accordance with ASB1 C-31 and C-39).

d. Aggregate:

1. Finer than 200: Testing frequency is every 1500 tons.

11. Friable particles: An initial acceptance test is performed and considered adequate, iii. Light-Weight Pieces : This test is not run because the petrographic acceptance test performed gives equivalent d ata ._

iv. Soft Fragments: An initial acceptance test is performed '

and considered adequate.

v. Los Angeles abrasion; Flat and elongated particles; Potential reactivity; and Soundness: An initial acceptance test followed by tests every 2500 cu. yds. are . performed.

In addition, all aggregate sources are approved through testing prior to use. I

e. Water: Except for soundness, testing frequency is every 2500 cu.-

yds. Soundness is performed as part of cement users tests per ASIM C-150 for each 5000 cu yds. The comparison between batch plant water and distilled water soundness required by AASHO T26 is not performed,

f. Admixture: Infrared Spectrophotometry - This test is not performed because admixtures are purchased against and documented to verify the require =ents of ASTM C 494, or C-260

g. Cement: An initial acceptance test followed by tests for subsequent grinds and for each 5000 cu. yds, are performed.

6) Section 4.9 1 qualification of Cadweld Operators. The standard can be interpreted to imply that qualifications of splicing crews is required for. each position' and each bar size. The Bechtel position

~ is that the qualifications for .each position will be for the largest bar to be used.. This is also consistent with the May 15,1973 staff

-memo and CPCo's Regulatory Guide 1.10 position.

3' r~ Brg Guide 1 94 i) Section h.10 Welded Reinforcing Ear Splices. The Midland Project meets the requirements of Section 5.5 except that the basic reconmenda-tions rather than the details of AWS D12.1 are followed.

8) Section 5.k HiEh Strength Bolting. The Standard does not recognize the use of indicator washers for installation of high strength bolts and requires inspection of bolting by torque wrench inspection.

The Project permits the use of such washers in accordance with the Errata or October 22,197h to the AISC Specification for Structural Bolts using ASti A325 or Ah90 Bolts.

The Midland Project permits waiving of the AISC requirements for 2 inspection by torque or power urench provided special inspection pro-cedures are followed.

C. Babcock & Wilcox (Nuclear Steam Supply System Surolier) Activities

Reference:

BLW Topical Report

'EAW-lC096A, Rev. 1 Activities relative to this ' Regulatory Guide are not within the BER scope of supply.

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. SUPPLDIENTARY QUALITY ASSURANCE REQUIREENTS FOR INSTALLATION INSPECTION AND TESTING OF MECHANICAL EQUIRENT AND SYSTE'S FOR TFE CONSTRUCTION FHASE OF UUCLEAR POWER PLANTS A. Consumers Power Activities

Reference:

ANSI Nh5.2.6 (Draft 3, Rev. 4)

During the Design, Procurement and Construction Phases of the Midland Project, the Consumers Power Quality Assurance Program implements the guidance contained in ANSI N45 2.8 for safety-related activities. Many of the activitics addressed by this draft standard are dele 6ated to Consumers Power's Construction Contractor but Consumers Pouer does conduct a preoperational test program which complies with the testing requirements of this draft standard.

B. Ecchtel (Construction Contractor) Activities

Reference:

Bechtel Topical Report BQ-TOP-1, Rev. lA Ihe Bechtel Quality Assurance Program will comply with tf.e position contained in its Topical Report #BQ-TOP-1, Rev. lA "Bechtel Quality Assurance Program for Nuclear Power Plants."

C. BabcockandWilcos(NuclearSteamSunplySystemSurplier) Activities

Reference:

B&W Topical Report EAW 10096A Rev. 1 Activities relative to this Standard are not within the B&W scope of supply.

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, , ANSI H45.2.12

• REQUIRD'EITIS FOR AUDITING OF QUALITY ASSUPECE PROGPXS FOR NUCLEAR POWER PLAI Q A. Consumers Power Activities

Reference:

ANSI N45.2.12 (Draft 4, Rev. 1)

During the Design, Procurement and Construction Phases of the Midland Project, the Consumers Power Quality Assurance Program i=plements the guidance contained in ANSI NL5.2.12 for safety- '

related activities with the following exception:

For Site Quality Assurance audits the organization to be audited is not normally notified in advance of the audit; and formal pre-audit and post-audit conferences are not generally conducted (See Sections h.2.4, 4.3.1 and 4.3 3 of AUSI R45 2.12).

These exceptions are taken because Consumers Power maintains a staff of Quality Assurance personnel on a full-time basis at the Midland Site, therefore, the notification and audit conferences are generally unnecessary.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

Reference:

AUSI N45 2.12 (Draft 4, Rev. 1)

Bechtel activities comply with the referenced standard.

C. Babcock and Wilcox (Nuclear Steam Sucply System Supplier) Activities

Reference:

B&W Topical Report BAW-lC096A Rev. 1 The B&W position for activities not yet completed or remaining to be done, with proper regard for effectivity, is contained in BLW Topical Report BAW-10096A, Rev.1 "BW HPGD Quality Assurance Program for Nuclear Equipment."

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, , ., ANSI Nh5.2.13

. QUALITY ASSURAECE dECUIRE!ENTS FOR CONTROL OF PROCURE!EUT OF ITD!S AND SERVICES FOR NUCLEAR POWER PLAUTS -

A. Consumers Power Activities

Reference:

ANSI n45.2.13 (Draft 3, Rev. 3)

During the Design, Procurerent and Construction Fhases of the Midland Project, the Consuncrs Poster Quality Assurance Program

, implements the guidance contained in AESI Nh5.2.13 for safety-related activities.

B. Bechtel (Architect-Engineer and Construction Contractor) Activities

Reference:

ANSI th5.2.13 (Draft 3, Rev. 3)

Bechtel activities cecply with the referenced standard.

C. Babcock and Wilcox (Uuclear Steam Supply System Supplier) Activities

Reference:

B&W Topical Report

, EAW 10090A Rev.1 The BiW position for activities not yet completed or remaining to' be done, with Jroper regard for effectivity, is contained in -

B&W Topical Report EAW-10096A, Rev. 1 "B&W NPGD Quality Assurance Program for Nuclear Equipment."

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