ML19208D032
| ML19208D032 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/29/1979 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7909270769 | |
| Download: ML19208D032 (4) | |
Text
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h UNITED STATES 3 v, ( '
,n NUCLEAR REGULATORY COMMISSION 3
- #'j WASHINGTON, D. C. 20555 d.
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AUG 2 91979 Docket Nos.: 50-329/330 Mr. S. H. Howell Vice President Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
Dear Mr. Howell:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION We have reviewed your response to question 1 of NRC's March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill," and have some more questions regarding the QA program for the Midland project.
Per conversation with Mr. Margulio of your staff, it is our er..'erstanding that these matters will be discussed at our September 5 mceting. An additional copy of the meeting notice for that date is enclosed for your convenience.
Sincerely, C
U D-L. S. Ru enstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management
Enclosures:
1.
" Request for Additional Infomation" 2.
Meeting Notice cc w/ encl. 1:
~ See next page 74909 270 76 f g 1042 098
Consumers Powr Company CCs:
Michael I. Miller, Esq.
Isham, Lincoln & Beale Suite 4200 One First National Plaza l
Chicago, Illinois 60503 Judd L. Bacon, Esq.
Constrners Power Company i
212 West Michigan Avenue Jackson, Michigan 49201 Mr. Paul A. Perry Secretary Consumers Power Corapany 212 W. Michigan Avenue Jackson, Michigan 49201 Myron M. Cherry, Esq.
One IBM P1aza Chicago, Illinois 60611 Mary Sinclair 5711 Summerset Drive l
Midland, Michigar; 48640 Frank J. Kelley, Esq.
Attorney General State of Michigan Environmental Protection Division 720 Law Building Lansing, Michigan 48913 Mr. Wendell Marshall Route 10 j
Midland, Michigan 48640 I
Grant J. Merritt, Esq.
l
'hompson, Nielsen, Klaverkamp & James i
4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van Farom, Chief Division of Radiological Health Department of Public Health P. O. Box 33035 Lansing, Michigan 48909 1042 099
h ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION We have reviewed Consumers Power Company's response to question 1 of NRC's March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill" and conclude that the infor-mation provided is not sufficient to determine that an acceptable QA program has been, and is being, implemented for the Midland project.
Accordingly, in order to gain a better understanding of your response to question 1, provide your response to the following:
1.
Your response to question la does not provide sufficient information relative to the root causes of the 13 deficiencies.
In order to determine the acceptability of the corrective actions for the 13 deficiencies considering the possibility that these deficiencies are of a generic nature that could affect other areas of the facility, a more complete understanding of the root cause of each deficiency is neces sa ry.
Accordingly, provide a clearer description of the root causes of each of the 13 deficiencies, including a detailed discussion of the conditions that existed to allow these deficiencies and the changes that have been made to preclude the recurrence of such deficiencies.
2a.
The first seven paragraphs of your response to question 1b do not provide sufficient information to assure that contradictions do not continue to exist in the PSAR, FSAR, design documents, implementing procedures, and as-built conditions since the controls described in these seven paragraphs were in effect prior to the I&E find-ings. Modify your response to clearly describe the control revisions you have instituted to preclude design contradictions.
b.
Items 1, 2, and 3 of the eighth paragraph describe the review and update of the PSAR commitment list, the review of the inactive sections of the FSAR, and the review of procedure EDP 4.22, " Preparation and Control of Safety Analysis Reports,"
without describing the extent of the review process or the qualifications of personnel involved in the review. Accordingly, describe what each of these reviews entails, including the extent these reviews are verified, approved, and documented.
Identify the organizational unit that is, or will be, involved in these reviews and the qualifications of the involved personnel.
c.
Item 2 of the eighth paragraph includes a statement that a review of the remaining sections of the FSAR is not necessary, "...because of the ongoing review process described above." Describe your rationale for not reviewing these remaining sections at the FSAR when it appears that the original review of the FSAR was performed prior to the I&E findings, d.
Describe the extent of the audit comitted to in item 4 of the eighth paragraph.
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2-3.
Question Ic requested that other activities be invest.igated to determine whether programatic quality assurance deficiencies exist in view of the apparent break-down of certain quality assurance controls, and that the activities investigated and the results ba identified.
Your response addressed certain specifications and instructions that received a review in 1977; providing for more in-depth verification; increasing management audits from one to two per year; increasing the staff of Bechtel's QA engineers at the site from five to eight; instituting an overinspection program on certain Q-listed construction activities; assigning resident engineers at the site to aid in the interpretation of drawings and increasing their number from one to twenty-two; and initiating a trend analysis program. According to your response, most of these actions were initiated in 1977.
Describe your rationale for assuming that these actions provide confidence that quality assurance deficiencies do not exist in other areas.
In order to determine if other areas have deficiencies, work already accomplished in these areas should be investigated.
This includes'the review of completed documentation, including inspection results, to verify consistency with design and SAR requirements.
Also, representative sample inspections of completed work would seem appropriate to determine the acceptability of this work. Accordingly, describe a program in detail to accomplish the above or provide rationale as to why it is not necessary.
Also, the use of generalizeo statements such as the review of, increase audits, overinspection, identifying trends, and increase of staff does not provide sufficient specificity regarding the detail and extent these actions will take place and the effect they will have in assuring other areas are not deficient.
Accordingly, in each of these areas provide a clearer description of these actions to permit one to understand the full impact they will have in assuring an effective QA program and that other areas are not deficient.
In those cases where credit is taken for actions already accomplished (such as reviews, inspections, and audits), provide a sumary of the results of these actions such that the success or failJre of the actions can be detemined.
4.
Considering the results of your investigation requested in our question ic, question ld requested that you describe your position as to the overall effectiveness of the QA program for the Midland facility. Accordingly, an overall assessment of the effectiveness of your program should be based on your revised response tc our question Ic.
The results of this assessment, including a description of the scope and extent of the assessment effort and the identification and qualifications of the individuals involved in this assessment, should be document'd and reported to us.
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