ML19249E971

Fowards Supplemental Requests for Soils Settlement QA Info & Other QA Matters

ML19249E971
Person / Time
Site:	Midland
Issue date:	09/11/1979
From:	Rubenstein L Office of Nuclear Reactor Regulation
To:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 7910020802
Download: ML19249E971 (5)

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SEP 111979 Docket Nos.: 50-329/330 Mr. S. H. Howell Vice President Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201

SUBJECT:

REQUEST FOR ADDITIONAL QUALITY ASSURANCE 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. These requests are contained in Enclosure 1.

An earlier draf t of Enclosure 1 provided the agenda for our meeting on September 5,1979, with members of your staff and Bechtel. We request that you supplement your written responses to our letter of March 21, 1979, to include this additional information.

Also, our continuing review of the quality assurance program described in the FSAR for Midland Plant, Units 1 & 2 indicates the need for additional informa-tion in other areas. These are requested by Enclosure 2.

We would appreciate your responses to Enclosures 1 and 2 at your earliest opportunity.

Should you desire clarification of these requests, please contact us.

Sincerely,

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L. S. Ru'oenstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management

Enclosures:

1.

Supplemental Requests for Soils Settlement QA Information 2.

Requests Regarding Other QA Matters cc w/ enclosures:

See next page 1074 062 291 0020

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l Consumers Pover Company CCs; Michael I. Miller, Esq.

Ishan, Lincoln & Beale Suite 4200 One Fi rst it +,onal Pl aza Chicago, Illinois 60603 Judd L. Bacon, Esq.

Consuners Power Company 212 West Michigan Avenue Jackson, Nichigari 49201 Mr. Paul A. Perry Secretary Consumers Pover Company 212 W. Michigan Avenue Jackson, Michigan 49201 flyron M. Cherry, Esq.

One IBM Plaza Chicago, Illinois 60611 Mary Sinclair 5711 Surmerset Drive Midland, Michigan 48640 frank J. Kelley, Esq.

At torney General State of Michig in Lnvironmental Protection Div ision

/20 Law Builriing Lansing, Michigan 48913 Mr..Wendell Marshall Route 10 Midland, Michigan 48640 Grant J. Merritt, Esq.

Thompson, Niel sen, Kl averkanp & James 4444 IDS Center 80 South Eighth Street Minneapolis, Minnesota 55402 Mr. Don van farove, Ch ief Division of Radiological Health Department of P:blic Health P. O. Box 33035 Lansing, Michigan 48909 1074 OuS3

P00ROR8UL SUPPLEMENTAL REQUEST FOR ADDITIONAL SOILS SETTLEMENT INFOR"ATION 23.

We have reviewed your response to question 1 of our March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill," including related amendments or supplements in your letters dated May 31, July 9, and August 10, 1979. We find that the infornation provided is not sufficient for completion of our review. Accordingly, provide the following additional information:

(1) Your response to question la does not provide suf ficient infomation relative to the root causes of the 13 deficiencies.

In order to deternine 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 necessary.

Accordingly, provide a clearer description of the root causes of eacn cf the 13 deficiencies, including a detailed discussion of the conditions that existed to allow these deficiencies and the changes that have teer made to preclude the recurrence of such deficiencies.

In this regard, if contributing causes are inadequate procedures, inspections, specifi-cation call outs, design reviews, audits, and/or technical direction, a clear and detailed description is necessary as to what allowed these conditions to exist and why.

(2) Regarding your response to question lb:

a.

The first seven paragraphs do not provide sufficient information to assure that contradictions do not continue to exist in tne PSAR, FSAR, design documents, implementing procedures and as-ouilt condi-tions since the controls described in these sever paragraphs we~e in ef fect prior to the I&E findings reported in J. Aeopler's letter of March 15, 1979.

Modify your response to clearly describe the centrol 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 to which these reviews are verified, approved, and documented.

Identify the organizational unit that is, or will be, involved in these reviews and the cualifications of the involved personnel, c.

Item 2 of the eighth paragraph states that a review cf the rerairinc sections of the FSAR is not necessary,"

teecause of the ongoing review process described above." Describe your rationale for not reviewing these remaining sections of the FSAR when it appears that, the original review of the FSAR was performed prior to issuance of the March 15, 1979 letter providing the I&E findings and prior to any correcti ve actions resulting therefrom.

d.

Describe the extent of the audit to which you have' committed ir, iter 4 of the eighth paragraph.

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(3)

Question 1 requested that other activities be insestigit c t,

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whether programmatic quality assurance deficiencies exist in va-of ine i

apparent b eakdown of certain quality assurance controls, anc t.51 the activities intestigated and the results be identified.

Sour ree : se addressed certain specifications and instructions that received a.c iew of 1977; providing.fcr r. ore in-depth verification; in:-easin?

,-=y ent audits f rom one to two per year; increasing the staf' oi Eecr.tel's QA engineers at the site from five to eight instituting an oserinspectien program on certain Q-listed construction activities; assigning resicent engineers at the site to aid in the interpretation of drawings anc increas-I ing their number from one to twenty-two; and initiating a trend analysis i

program, a.

Accurding to your response, most of these actions s.tre ini'

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1977.

Describe your rationale f or assuming that tLese act w '

confidence that quality assurance deficiencies ao not e iu ir er areas.

In orcer to determine if other areas have ceficiencic

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already accceplished in these areas should be investic3ted.

Inis includes the review of completed documentation, incluaing in-

" tion results, to verify consistency with design and SAR requiren ot s.

Also, representative sample inspections of ccmpleted work waaio

"T appropriate to determine the acceptability of this worh Accoraingly, describe a program in detail to accomplish the above or arctice rationale as to why it is not necessary, b.

Your use of ceneralized statements such as "1.90 ttvice o!', "inc: c ased audits," "overinspection," "identifyino trencs," anc "inc: ase t f staff" does not provide sufficient specificits t eparding t he cetail and e> tent these actions will take place and the eifect t n e '. will l

have in assuring other areas are not ceficient Ac corcinaly in och of the<,e areas provide a clearer description of these E tiom ti.ative to tho full impact they will have in assuring an cffective QA prom ram and in suf ficient detail to assure that other areas are n:,t ceficient.

In those cases where credit is taken for actions alreaa;. acc:mplished (such as reviews, inspections, and audits), provide a su.T:ary of ine results of these actions such that the success or f ailure of tne actions can be determined.

(4) Considering the results of your investigation requested in our questien Ic, question ld asked that you cescribe your position as to the overall ef fectiveness of the QA program for the flidland Plant.

Your o.erall assessment of the effectiveness of your program should be based on your revir,ed response to our question Ic (see above question 23(3)). The results of this assessment, including a cc:- " pt i o-of ihe scc;;

extent of the assessment effort and the identification and qualifications of the individuals involved in this assessment, should be repcried to ut.

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421-1 421.0 QUALITY ASSURANCE BRANCH 421.5 The Bechtel alternatives for ANSI N45.2.12 Draft 4, Revision 1, November (17.1) 1974, which are described in FSAR Section 17.1.1.16, do not provide a clear cocmitment of your intent to comply with this standard. We are unable to determine whether these alternatives are in lieu of compliance to ANSI N45.2.12 or are intended to supplement the guidance provided by ANSI N45.2.12. Although these alternatives have been accepted in Bechtel Topical Report, BQ-TOP-1, Revision 2-A, 7/77, they alone do not constitute measures for full compliance with ANSI N45.2.12. There-fore, provide a specific description clearly indicating your commitment

.o ANSI N45.2.12. Any exceptions, alternatives, or clarifications should be specifically identified and 'ustified with sufficient supporting detail.

421.6 We have reviewed your exceptions in FSAR Section 17.1.1.13 for Revision (17.1, O of Regulatory Guide 1.94, April 1975, which endorses ANSI N45.2.5-3A) 1974.

Your position notes that the final mixing point for concrete may be at the batch plant stationary mixer or at the discharge chute of the truck mixer. While we generally agree that in-process strength testing may be conducted at the final mixing point, this position is contingent upon the establishment of an appropriate correlation test program. The 1974 version of ANSI N45.2.5 contained no guidance regarding correlation criteria and your FSAR does not discuss this item. Paragraph 6.11 of the 1978 version of the standard provides this guidance. Accordingly, we require that you address the extent of conformance to paragraph 6.11 criteria, both in terms of concrete construction completed to date and for ongoing or future concrete work.

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