ML20063P070

Forwards Independent Design Adequacy Review & Performance Objectives & Criteria for Const Project Evaluations, INPO Preliminary Rept

ML20063P070
Person / Time
Site:	Midland
Issue date:	10/05/1982
From:	Jackie Cook DUKE POWER CO.
To:	Harold Denton, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation
Shared Package
ML20063P071	List: ML20063P070 ML20063P074
References
18879, NUDOCS 8210120276
Download: ML20063P070 (30)

Text

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• e Consumem Power James W Cook C0mpanY Vice President - Projects, Engineering and Construction oeneral offices: 1945 West Parnell Road, Jackson, MI 49201 e (517) 788-0453 October 5, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 J G Keppler Administration, Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 MIDLAND PLANT INDEPENDENT REVIEW PROGRV1 FILE: 0485.16 SERIAL: 18879

REFERENCES:

(1) R L TEDESCO LETTER TO J W COOK DATED JULY 9, 1982.

(2) J W COOK LETTER TO H R DENTON, SERIAL 18850 DATED SEPTEMBER 17, 1982.

ENCLOSURES: (1) MIDLAND PLANT INDEPENDENT REVIEW PROGRAM (2) PERFORMANCE OBJECTIVES AND CRITERIA FOR CONSTRUCTION PROJECT EVALUATION INPO, SEPTEMBER 1982 The ACRS interim report on the Midland Plant, dated June 8, 1982, contained a recommendation for a broader assessment of Midland's design adequacy and construction quality. In its correspondence of July 9, 1982, which is Reference 1 above, the NRC endorsed this ACRS recommendation and requested our proposal for performing an independent design adequacy review.

We briefly outlined several assessment activities for the Midland Project in ODf our correspondence of September 17, 1982, identified above as Reference 2.

i Additional details of the program referred to in Reference 2 are enclosed for the NRC's review.

We have contacted our NRC Project Manager, Darl Hood, to arrange a meeting ith the NRC Staff to discuss our Independent Review Program and to receive sur concurrence or redirection of our plans. We will complete the planning phase, including team orientation and training, for the INPO program by oc0982-0249a100 __

iB21012O276 821005 PDR ADOCK 05000329 A _.

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2 October 29, 1982. We wish to initiate the implementation phase of the INPO program by November 8,1982, in order to support our own and industry commitments to NRC.

l JWC/GSK/RLT/bjw CC Atomic Safety and Licensing Appeal Board, w/a 1 CBechhoefer, ASLB, w/a 1 MMCherry, Esq, w/a 1 FPCowan, ASLB, w/a 1 RJCook, Midland Resident Inspector, w/a 1&2 RSDecker, ASLB, w/a 1 SGadler, Esq, w/a 1 JHarbour, ASLB, w/a 1 GHarstead, Harstead Engineering, w/a 1 DSHood, NRC, w/a 1 & 2 (2)

FJKelley, Esq, w/a 1 WlIMarshall, w/a 1 WDPatton, Esq, w/a 1 WDShafer, NRC, w/a 1 & 2 BStamiris, w/a 1 MSinclair, w/a 1 LLBishop, Esq, w/a 1 oc0982-0249a100

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CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 18879 Dated October 5,1982 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits Midland Plant Independent Review Program.

I CONSUMERS POWER COMPANY By J ook, Vice pre Tdent Projee , Engineering and Construction Sworn and subscribed before me this f day of _ ,/f/2..

^-21 Notary Public Jackson County, Michigan My Commission Expires _ d su /'4 f, /f 7 /

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oc0982-0249a100

D MIDLAND PLANT INDEPENDENT REVIEW

1. INTRODUCTION &

SUMMARY

2. BIENNIAL QUALITY AUDITS

.3. INPO CONSTRUCTION EVALUATION

.4. INDEPENDENT DESIGN VERIFICATION

5. APPENDIX: PREVIOUS ASSESSMENTS rp0982-2769a141-100

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1. INTRODUCTION AND

SUMMARY

The ACRS report dated June 8, 1982 on Midland Units 1 and 2 stated that "the NRC should arrange for a broader assessment of Midland's design adequacy and construction quality with esphasis on installed electrical, control, and mechanical equipment as well as piping and foundations."

On July 9, 1982, the Staff issued a letter to Consumers Power Company requesting a report on Midland Design Adequacy and Construction Quality. In this letter, the Staff stated that "With respect to assessment of Midland's design adequacy, such assessment would represent a significant contribution to the licensing review process if performed by a qualified, independent source following procedures utilized by some operating plants for Independent Design Verifications."

On September 17, 1982, the Company issued a letter to Mr Harold R Denton and Mr J G Keppler outlining the approach Consumers Power Company proposed for an Independent Review of the Midland Project and indicated that there had also been a Bechtel Corporate Staff project evaluation performed (described in more detail in attached appendix). It was stated that Consumers Power Company believes that the approach we are proposing for the forthecming Independent Review will give a broader overview than assessments currently being recommended by the NRC for other NTOL plants.

The overall Independent Review Program described herein consists of three specific evaluations combined into a single program. The INPO type construction evaluation (horizontal type review), will examine the current rp0982-2769a 141-100

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3 overall project against the criteria developed by INPO for this program (a copy of the INPO Performance Objectives and Criteria for Construction Project Evaluations is attached). As indicated in the September 17, 1982 letter to Mr Denton and Mr Keppler, the INPO program for Midland will be different from most of industry's celf-initiated evaluations in that an independent contractor rather than utility personnel will carry out the INPO evaluation.

The second part of the Program described is the Biennial QA Audit which has been a requirement of the Company's QA Program for several years. The third part of the Pecgram described in more detail is the Independent Design Verification (Vertical slice) of all aspects, historical and current, of a critical plant system or subsystem.

Consumers Power Company received proposals from several potential contractors to perform the complete program described above. With respect to the INPO type construction evaluation and Biennial QA Audit, we have selected Management Analysis Company (MAC) to perform these activities based on our evaluation of their technical capabilities and experience.

MAC bas many years of experience in the Nuclear Industry and has performed Biennial QA Audits in addition to other type reviews of Company activities.

MAC has previously consulted extensively at nuclear construction sites with identifed QA problems. MAC was also a major participant in the development and implementation of the Palisades Regulati4ry Performance Improvement Program which has resulted in significant improvement to date at that facility. A description of other MAC assessments of Midland activities is included in the Appendix to this document.

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4 The MAC Team will be under the direction of Mr L J Kube who has over 20 years experience in project management, engineering management, marketing, planning / scheduling, and design engineering having been employed by General Atomic and A O Smith Corporation prior to his employment with MAC. Mr Kube has been involved in the development of the INPO evaluation criteria, has participated in the three INPO Pilot evaluations and is the Project Manager-for MAC for conducting an INPO evaluation on River Bend. The INPO type evaluation will be independent in that no Consumers Power Company or Bechtel personnel will be involved and MAC has never performed a direct line engineering or construction activity for Consumers Power Company.

For perfecmance of the Independent Design Verification, we have selected Tera Corporation based on our evaluation of their technical capabilities and experience. Tera has many years of varied experience in the r.uclear industry including independent design reviews, FSAR preparation, initial design of certain systems, and engineering, construction, operation and administration planning. Tera personnel are experienced in system design in the areas of mechanical, electrical, structural, and thermal hydraulic evaluations. Mr John W Beck, Vice President of Tera will be Project Manager for the Tera team.

Mr Beck previously worked for Vermont Yankee Nuclear Power Corp as Executive Vice President serving as Chief Operating Officer. Prior to that he was Director of Engineering for Yankee Atomic Electric Co responsible for supervision and management of the plant, reactor, and environmental engineering departments. Prior to employment with Yankee, he was a Scientist at Bettis involved in Shippingport core design.

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5 Individuals taking part in any of the three specific evaluations which make up the overall Independent Review Program will meet the Independency Criteria" of Chairman Palladino's February 1,1982 letter to Representative John Dingell and which are described as follows:

1. No individuals on the Project team will have been previously utilized by Consumers Power Company to perform design or construction work.

2. No individual involved will have been previously employed by Consumers Power Company.

3. No individual owns or controls significant amounts of Consumers Power Company stock.

4. No members of the present household of individuals involved are employed by Consumers Power Company.

5. No relatives of individuals involved are employed by Consumers Power Company in a management capacity.

MAC will be responsible for integrating an overall evaluation report made up of the three inputs.

The major objective of the overall evaluation report is to provide the NRC, ACRS, and the Consumers Power Company Chief Executive Officer with an i assessment of the overall quality of the Midland Project. We believe that this assessment will adequately address the NRC, ACRS, and public's questions regarding the_ adequacy and construction quality of the plant.

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6 The final report will be submitted to the NRC and an auditable record will be maintained of all comments on any draft or final reports, any changes made as a result of such comments, and the reasons for such changes.

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2. BIENNIAL QUALITY AUDITS Background Of Biennial Quality Audit' Requirements The Consumers Power Company Quality Assurance Program Manual For The Midland Nuclear Plante Topical Report CPC-1-A, requires the review of the Consumers Power Corporate Nuclear Quality Assurance Program to be performed at least once every 24 months or once every second calendar year by a Quality Assurance Program Audit (referred to as the Biennial Quality Audit).

This audit may be accomplished by a team consisting of Environmental & Quality Assurance personnel, selected employees from other Consumers Power Company departments or by an audit team of Quality Assurance personnel under contract to Consumers Power Company.

Plans For The 1982 Biennial Quality Audit The scope of the 1982 Biennial Quality Audit will be similar to the audits conducted in 1976, 1978 and 1980. The audit will evaluate the Quality Assurance Program being utilized by Consumers Power Company and by Bechtel and will evaluate on a sampling basis, the degree of compliance with the Program by Consumers Power Company and by Bechtel. Specifically, the 1982 Biennial Quality Audit will be conducted by Management Analysis Company (MAC) and will comply with the requirements of NRC Regulatory Guides 1.144 (9/80, Rev 1) and 1.146 (8/80, Rev 0).

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3. INPO CONSTRUCTION EVALUATION General In early 1982, utility nuclear power plant construction problems stimulated industry initiative and action to ensure that programs in effect nationwide meet performance goals as intended. Accordingly, the Institute of Nuclear Power Operations (INPO) was tasked u 'y the Utility Industry to develop and manage a construction project evaluation program. The first effort was to define Performance Objectives and Criteria for project evaluations. Use of these criteria for an overall evaluation is intended to provide considerably more depth than an audit, for an audit generally does not go beyond conformance to program requirements. The evaluations include some assessment of administrative and quality records, but more important, focus on evaluating the success and efficiency of the project organization, systems and procedures in achieving the desired end results.

Following the drafting of the Performance Objectives, three pilot evaluations were conducted by INPO on plants under construction ie, Vogtle, Shearon Harris, and Hope Creek. During the last pilot a representative from NRC was present during data collection, evaluation and exit interview with utility personnel.

Following the pilot evaluations, the Performance Objectives and associated Criteria were modified to reflect experiences gained. A copy of the criteria to be used for the INPO evaluation is attached.

rp0982-2769a141-100

9 The performance objectives are broad in scope; each generally covers a single, well-defined area. The supporting criteria are more narrowly focused statements of activities that support or help meet the performance objectives.

Several criteria are listed under each performance objective.

There are five Performance Objectives and associated Criteria which specifically address design effort. These are:

DC.1 Design Input Process for defining and controlling design input DC.2 Design Interfaces The identification and coordination of interfaces to ensure input requirements are satisfied DC,3 Design Process Process followed to ensure safe, reliable and verifiable designs in compliance with requirements DC.4 Design Output Development of designs which are complete, accurate, understandable and constructable DC.5 Design Changes Control of changes to ensure compliance with design requirements In addition there are numerous Performance Objectives which support evaluating design control. These include: Construction Engineering, Project Planning, Training, Independent Assessments, etc.

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10 The above INPO Performance Objectives and associated Criteria will be utilized for planning the Independent Design Verification.

The 1NPO type self evaluation is aimed at achieving a level of performance above that required to meet Regulatory Requirements. Members of 35 Utilities (including Consumers Power) met, draf ted and reviewed performance objectives and criteria to support the performance objectives of seven areas including design. A complete list of the areas whose objectives are intended to define optimum performance is:

Organization and Administration Design Control Construction Control Process Support Training Quality Programs Test Control The thrust of this type of evaluation is that if utilities attempt to meet standards above those normally required to achieve quality, there will be greater assurance that Regulatory Requirements are met. The program was then applied during three pilot evaluitions and modified based on the experience gained during the pilot evaluations. It essentially looks at all aspects of work in progress. This program has been developed during the calendar year 1982 and industry has made a commitment to the NRC to initiate INPO type evaluation on nuclear plants under construction by the end of 1982. The only exceptions will include those plants very close to fuel load.

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11 Consumers Power Company selected MAC to perform the INPO Construction Evaluation primarily because of MAC's involvement in the development of the Performance Objectives and participation in all three pilot evaluations. The team supplied by MAC will be individuals experienced in multi-discipline activities associated with nuclear power plant engineering and construction.

In addition, team members will be experienced in interviewing and evaluating ie, the type of activity MAC has been performing for the" nuclear industry over the past seven years.

PREPARATION FOR INPO TYPE EVALUATION The evaluation team leader will review the job status, select work areas to be s evaluated and select team members based on the above. A request will then be made to CP Co for background documents. The team will then review the documents and prepare a schedule. Individual assignments will also be made.

Three Tera members of the team organization representing Civil, Hechanical, and Elect rical disciplines will be part of the MAC INPO type evaluatios team. ,

Prior to actually performing the evaluation, all team members will receive "i

training in plant orientation, procedures and INPO evaluation techniq'oes.

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PERFORMING THE EVALUATION The entire evaluation team will initially meet at the Site to review the work in progress. Sections of the team will then move to the Designer's and Owner's Offices. Team members will then begin the task of collecting pertinant facts relative to various aspects of the job via observations, inspections, discussions and review of documents. These facts will be assigned to the appropriate performance objective and reviewed against that rp0982-2769a141-100

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At the conclusion of the evaluation, the team will verbally conununicate their findings to the project. A formal report will then be prepared and presented r'

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INPO. INFO will assimilate various utilities reports into a comprehensive sununary documen,t and report the overall program progress to the NRC.

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4. . INDEPENDENT DESIGN VERIFICATION

, Goals and Objectives The independent design review is directed at verifying the quality of design engineering for the Midland Plant. The approach selected is a review and evaluation of a ' detailed " vertical slice" of the project design by a

- technically competent, independent organization. The design and as-built configaration of a selected safety system will be reviewed to assure its adequacy to function in accordance with its safety design bases and to assure applicable licensing commitments have been properly implemented.

Summary and Scope of Effort The independent design verification (IDV) will consist of an independent design review of the Unit 2 auxiliary feedwater system (AFW) as an applicable sample of the design engineering effort at Midland Plant. This system was selected based upon system selection criteria discussed below. The review

, will be conducted by Tera Corporation and will utilize a multidisciplinary team of senior staff personnel to assure that the design and as-built configuration of the AFW conforms to its safety design bases and Consumers Power Company's licensing commitments as a benchmark for its acceptability.

The design process, from concept to installation, will be identified and I:

interfaces between design eno ineers evaluated to assure sufficient controls were placed on the transfer and specification of important design information.

Although the review will focus on the AFW, the interfacing systeins will be reviewed to determine that appropriate design constraints were imposed to rp0982-2769a141-100 4

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14 assure functionability of the AFW. Initially, important design elements for-I AFW will be outlined to assure the IDV includes an appropriate sseple of the I design interfaces between Consumers Power, B&W the nuclear steam supply system 1

I (NSSS) vendor, Bechtel the architect engineer, and other service related contractors. Design elements such as environmental qualification envelopes, seismic analysis, hydraulics and system control requirements will be selected to allow a diverse review of.the-various' engineering disciplines (eg,

. Mechanical, Civil, Electrical). The design reviews in each area will evaluate the design approach used and, there appropriate, independent analytical techniques will be used to confirm questionable approaches or to permit assessment of the significance of any identified discrepancies.

To assure that the installed equipment reflects system design requirements, design specifications and drawings will be reviewed and in-field inspection of selected sections of the AFW conducted. The in-field inspection will confirm that the AFW is configured as specified in the design documents.

Throughout the IDV, all findings will be documented by each reviewer. Each ,

finding will then he evaluated by the team leaders and more significant findings forwarded to a senior review team. At the conclusion of the effort, 1

a preliminary report will be provided to Consumers Power and the original designers Ier review and provision of additional documentation that could have an impact on the final report findings. An auditable record of comments and additional information provided will be maintained. The final report will summarize the work accomplished, procedures used and a complete list and description of all findings from the review.

.rp0982-2769a141-100

15 System Selection Criteria The selection of a system to be reviewed by the independent contractor was based on the six criteria which follow.

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• Importance to Safety - The system should have a relatively high level of importance to the overall safety of the Midland Plant.

• Tnclusien of Design Interfaces - The system should be one which involves multiple design interfaces among engineering disciplines as well as design organizations, such as the NSSS vendor, architect engineer and sub-tier contractors. The system should also be one where design changes have occured and thus provide the ability to test the effectiveness of the design process exercised by principal internal and external organizations er disciplines in areas of design change.

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• Ability to Extrapolate Results - The system should be sufficiently representative of oth r safety systems such that the design criteria, design control process and the design change process are similar so that i

extrapolation of findings to other systems can be undertaken with confidence.

• Diverse in Content - The major engineering disciplines should all have input to the design of the system.

• Sensitive to Previous Experience - The system should be one which includes design disciplines or interfaces which have previously exhibited problems and thus a test of the system should be indicative of any generic condition.

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• Ability to Test As-Built Installation - The system construction should be sufficiently completed that the as-built configuration can be verified against design.

The auxiliary feedwater system was selected for the independent design review after consideration of a number of other candidate systems. The euxiliary feedwater system had a sufficiently high profile for each of the criterion to justify its selection. Specifically, it involves interface with the NSSS vender criteria, with containment design criteria, interface with design organizations, and the methodology of determining a water system's mechanical, electrical, and control component design criteria.

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17 Technical Approach The independent design verification (IDV) effort is comprised of three phases; Program Development, Review and Reporting.

The Program Development Phase includes the preparation of an IDV work plan and the development-of a detailed review scope. The'IDV work plan will. include procedures and instructions for the work to be performed by Tera Corporation, the IDV contractor. An initial identification of the specific verification methods and depth of review to be. utilized in addressing system design elements will also be completed as part of this phase.

The Review phase is the major activity of the IDV. This phase includes a design review of the systems as well as a field installation /as-built review to assure conformance of the design and the constructed facility. Initial efforts of the system design review will focus on the identification of the design process (chain) for the selected system. Emphasis will be placed on identifying design organizations and their subelements who contributed to the design and understanding the design practices and interactions between the design engineers. Paralleling this effort, the design and licensing criteria will be reviewed. It is anticipated that system design criteria information will include utility, B&W and Bechtel design requirements, licensing commitments, as well as other sub-tier documents.

The methods to be utilized in the review of system design elements will vary in depth. Depending upon the design area, the specific method may be a review of deuign criteria, a review of design calculations, a " blind" confirmatory rp0982-2769a141-100

6 18 evaluation (eg alternative calculation or computer analysis by the IDV contractor) or a combination. Where appropriate, independent analytical techniques will be used to confirm design calculations or to permit assessment of the significance of any identified discrepencies. It is anticipated that the primary review method will be a review of calculations. Ultimately, the choice of review method will depend upon the nature of the design area and the-type of verification method which is most effective in enabling the IDV 1

reviews to reach a judgement as to the design adequacy in that design area.

. This review will concentrate on each major step in the design process, for example:

• Design input information . (transfer among designers, conformance with design criteria and commitments).

• Analyees and Calculations (selected review of inputs, assumptions, ,

methodology, validation and usage of computer programs and reasenableness of certain analytical outputs).

• Drawings and Specifications (selected reviews for conformance with system i

design criteria, commitments, and incorporation of results of analyses and calculations).

• Field Verification (audit to assure that the as-built configuration reflects design requirements and pre-operational tests verify design analyses).

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Findings.from the INPO review as well as input from other sources such as, audit reports, 50.55e reports, design change reports and other documents will rp0982-2769a141-100

19 also be considered to concentrate review in more depth in any areas where the design process may be suspect by historical evidence.

The IDV review scope will be broad enough in terms of design elements to include samples from each significant design organization, design interface and major engineering discipline.

The design elements to be evaluated. include:

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• Civil / Structural design of structures housing the AFW (eg, external or internal flooding, wind or tornado loads, seismic analysis, foundation design or missile protection).

• Mechanical / Electrical design of AFW systems and components (eg, pipe rupture protection, swismic subsystem evaluation, ASME code considerations, equipment qualification, penetration design, cable routing and separation, instrumentation and control system, system interlocks, fire protection, seismic and quality group classification or use of appropriate codes and standards).

• System performance requirements (requirements for accident mitigation, design transients and normal operation, hydraulic design, over pressure prctection, reliability, NPSH for pumps).

The installation /as-built verification review will include a walkdown of the selected system and inspection of system components. This review is intended to confirm system geometry and component nameplate data. Input from this evaluation will be assessed for its compatability with design documents such as specifications and drawings.

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20 The IDV will be conducted under project instructions and procedures that will require apparent discrepancies to be documented throughout the review.

Initially, these findings will be categorized based upon the lead reviewer's judgement as to status as.follows:

1) Open- The finding has the potential for becoming a confirmed error, but additional investigation or confirmatory analysis is necessary to make a final judgement;

2) Confirmed - The finding is judged to be an apparent error by the review team and will require corrective action, such as additional documentation not utilizeo by the team that documents the resolution of the findings or additional analysis, design or construction changes or procedural changes that may be necessary to resolve the finding;

3) Resolved - Sufficient additional information was available in the ongoing review to resolve the findings and to completely close out any additional concern about the findings.

Additionally, findings will be categorized as to whether or not they affect the AFWs safety function or licensing criteria. Additional design information will be solicited to allow the lead reviewers to reach disposition of each finding. As the reviews of each major design element reach a suitable stage, the individual findings will be evaluated in an integrated manner by the project team to further define or resolve the findings and to assure the

. classification is proper. After the team has completed its review, each finding will be submitted to a senior level review team to provide additional professional opinion regarding the classification of the finding.

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Reporting will be in two stages, preliminary and final. The preliminary report, including the findings, as modified L/ the senior review team, will be provided to Consumers Power Company for review by the original designers. The preliminary report will provide an opportunity for additional information to l

be supplied which could have an impact on the findings but was not known to i the IDV project team. All comments, additional information and changes to the findings will be maintained in an auditable manner. The final report will summarize the work accomplished, procedures used and include a complete

' description of all findings.

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Al APPENDIX PREVIOUS ASSESSMENTS OF DESIGN AND CONSTRUCTION QUALITY AT MIDLAND Historically, Consumers Power Company and its contractors have been committed to perform their work us:ng QA programs which respond to all 10CER50 Appendix B Quality Assurance criteria.

In addition to the Consumers Power Company audits in the areas of design and construction, the Company has utilized outside consultants to conduct Biennial Quality Audits. The Consumers Power Company Biennial Quality Audits were first instituted in 1976 and were subsequently conducted during 1978 and 1980.

These audits were conducted to determine the Program's adequacy and to determine, on a sampling basis, the degree of compliance with the program. A sunnary of those audits are as follows:

A. 1976 Biennial Quality Audit In 1976, the Biennial Quality Audit was conducted by the Nuclear Audit and

' Testing Company (NATCO) and included approximately 24 man-days of audit effort. The audit involved auditing for adequacy and implementation of the Consumers Power Company QA' Program Procedures at the Consumers Power i

Company General Office in Jackson, Michigan and at the Midland Site. In addition, the audit involved-auditing for adequacy and implementation of the Bechtel Nuclear Quality Assurance Manual at the Midland Site. Audit findings resulting from this audit have been closed out. ,

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A2 B. 1978 Biennial Quality Audit In 1978, the Biennial Quality Audit was conducted by the Management Analysis Company (MAC) and included approximately 70 man-days of audit effort. The audit involved auditing for adequacy and implementation of the Consumers Power Company QA Program Proceduces at the Consumers Power Company General Office in Jackson, Michigan and at the Midland Site. In addition, the audit involved auditing for~ adequacy and implementation of the Bechtel Nuclear Quality Assurance Manual at th'e Bechtel Ann Arbor, b

[ Michigan offices (engineering) and at the Midland Site. Audit findings resulting from this audit have been cic ?d out.

C. 1980 Biennial Quality Audit In 1980, the Biennial Quality Audit was conducted by the Management Analysis Company (MAC) and included approximately 46 man-days of audit effort. The audit involved auditing for adequacy and implementation of the Consumers Power Company QA Program Procedures at the Consumers Power Company General Office in Jackson, Michigan and at the Midland Site. In addition, the audit involved auditing for adequacy and implemenation of the Bechtel Nuclear Quality Assurance Manual at the Bechtel Ann Arbor, Michigan offices and at the Midland Site. Audit findings resulting from this audit have been closed out.

MAC also performed a special Assessment of Midland in 1981 which covered the following areas: . Corrective actions resulting from 50.55e items including adequacy of corrective action, hardware inspection and system walkdown, corrective action status closeout of 1980 biennial Corporate Audit, assessment rp0982-2769bl41

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of adequacy of Midland QA program (based on first two items), review of documentation.(supplier quality verification records, radiographic records, certificates of compliance, and Bechtel FLAGS program), and assessment of Bechtel and Consumers personnel-(Bechtel QC and auditors, Consumers auditors, )

l and Bechtel welders' qualification).

l Starting in 1976 upon the discovery of missing rebar in three areas of the  !

auxiliary building. (later this was determined to not be a safety problem),

d Consumers. instigated a surveillance of construction activities by Consumers QA personnel. Consumers Power surveillance provides formalized quality control inspections beyond those quality control inspections performed by the Bechtel Quality Control group.

In August 1980 the Quality Assurance Organizations of Consumers Power Company' and Bechtel were integrated into one group with Consumers having the responsibility for direction and management. Consumers Power at this time set up a Design QA Engineering (DQAE) group at the Bechtel Ann Arbor offices to conduct day to day monitoring of engineering activities of Bechtel. The Consumers Power DQAE provides design and procurement quality / reliability services of problem prevention and early problem detection, resolution, and corrective action. DQAE personnel are degreed and have had direct design related experience in the areas of nuclear, mechanical, electrical, electronics and civil engineering. The DQAE functions consist of:

1. Technical reviews of Design and Procurement documents (engineering procedures / instruction, selected design and procurement documents, and supplier design deviation requests).

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2. Monitors that requirements of controlling documents are being implemented (FSAR, engineering procedures, Appendix B, codes and standards) into specifications, drawings, material requisitions, supplier documentation and design calculations.

3. Audits of engineering, supplier QA Department, Bechtel Quality Lngineering and Document Control.

Starting in January 1979, NRC Region IV Vendor Inspection Branch has conducted seven inspections of the Bechtel Ann Arbor Office. The latest inspections were in May and July 1982. In three of these inspections, there were no findings. Corrective action has been completed on all of the findings frca inspections prior to 1982. There were no findings from the May 1982 inspection and the one finding from the July 1982 inspection has not been closed out as yet.

Although not requested by the NRC, Consumers Power Company decided in early 1982 that based on occurrences at Diablo Canyon and other plants, an Independent Design Audit or Review was prudent. The Company did not know what NBC staff requirements would be applied to an independent audit for plants that are in the construction and licensing stage similar to Midland. It was decided that this particular Independent Design Review would be undertaken as soon as possible in order to provide timely identification of problems so that corrective action could be taken consistent with overall project schedules.

The purpose was to review Bechtel Project Engineering activities to determine if design criteria are being correctly implemented and if design assumptions, design wethods and the design processes are satisfactory. It was also decided that the review could be optimized by using people who were knowledgeable rp0982-2769bl41

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about the.Bechtel design process but were not working.on Midland design suchL-as Bechtel' personnel located in offic'es other'than Ann Arbor or Consumers personnel that have not been directly involved in Midland.

The review team consisted of six Bechtel and one Consumers ~ Power Company employees with disciplines represented in the areas of mechanical, nuclear, electrical, civil / structural, plant design, control systems and technical support for plant operations. Short term assistance was provided-by specialists and consultants from other Bechtel offices in specific areas such as piping design and seismic analysis. The general approach of the review was to conduct a broad review of important design methods and then to review in-depth, including field walkdowns, four features of the plant. Emphasis was on 1

4 engineering and factors important to safety, calculations, and design features

.which will not be demonstrated by tests during construction and start-up.

Interfaces within Bechtel and between Bechtel and B&W were also reviewed. The I

basic criteria and commitments used by the review team were the FSAR, Bechtel Topical Reports, project procedures, and industry guides and standards.

] Design methods selected for review included piping analysis, equipment t

qualification, separation hazards, instrumentation, structural and seismic analysis, and various nuclear analyses. The piping review included i.

independent computer analysis of selected stress problems and hanger designs and a review of unique computer programs developed for the Midland Project.

' reactor cavity The four features of the plant for an in-depth review were:

design, on-site electrical systems, decay heat removal system and piping for

+._ A I the high pressure safety injection system outside containment. The review has been completed with findings issued and replied to. The final report as well i

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A6 as other design review information will be submitted to MAC and Tera for use in the performance of their activities.

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