ML20065C723
| ML20065C723 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/17/1982 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation |
| References | |
| 18850, NUDOCS 8209240284 | |
| Download: ML20065C723 (5) | |
Text
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Consun1ers Power u
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h Vice President - hojects, Engineering and Construction oor.eral offices. 1945 West Parnell Road, Jackson, MI 49201 * (517) 188 0453 September 17, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 James G Keppler Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 QUALITY ASSURANCE PROGRAM IMPLEMENTATION FILE:
0485.16 SERIAL:
18850
REFERENCE:
CPCo Letter Serial 18845, 9/17/82, " Quality Assurance Program Implementation for Soils Remedial Work" The referenced letter summarized Consumers Power Company's discussions with the NRC management regarding the implementation of the Quality Assurance Program for the Midland soils remedial work.
In addition to the discussions specifically related to soils, the total Midland Quality Assurance Program implementation was reviewed and areas were identified where additional efforts should be directed to insure successful overall project implementation and the performance of the primary inspection function (QC) on site.
In response to these concerns onsumers Power made two significant new commitments which are conceptually ; scribed in the following paragraphs. Additional documentation will be provided as the details of these commitments are worked out.
Quality Control Function In order to improve the performance of the Quality Control function and to make it more responsive to direction from the Quality Assurance organization, the responsibility for directing the entire Quality Control function will be assumed by Consumers Power. The Quality Control group will functionally report to MPQAD. The programmatic aspects now in place will continue to be f
used and the combined inspection resources of both Bechtel and CPCo will be
{g()() h-integrated. This reorganization will be fully implemented as soon as the appropriate procedural changes are finalized. The integration of the QC resources for soils into MPQAD has already been accomplished as a separate action.
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Page 2 Independent Verification - Total Project,
Consumers Power proposes a new and expanded approach for verifying the overall quality of the project. This approach will give a broader overview than the assessments currently being recommended by the NRC for other NTOL plants. The assessment which is suggested for Midland is to combine an INPO type construction project evaluation, which is a broad " horizontal" type review of many aspects of current project operations with the detailed " vertical slice" review of all aspects, current and historical of a critical plant system or subsystem. The entire review will be performed by one or more independent contractors who are currently being selected. With the assistance of the selected contractors, the detailed plans for this extensive independent assessment will be finalized and presented to NRC management shortly for their concurrence prior to initiating the major work activities.
The INPO portion of the program will be initiated immediately at least through the planning phase to comply with the INPO schedule and industry commitments to the NRC. The INPO construction program evaluation for Midland will differ from the majority of the industry's self-initiated evaluations in that an independent contractor rather than utility personnel will carry out the INPO evaluation. The results will then be overviewed by the INPO staff to assure adequacy and consistency with other evaluations.
Additional Assessment Programs In addition to the above, Consumers Powet has proposed to retain a qualified third party for an assessment of the underpinning activities as detailed in the referenced letter.
Consumers Power Company has also initiated other appraisals to assess the adequacy of the Quality Assurance Program. Two major recent examples of this practice that have occured are as follows.
In 1981, Management Analysis Company (MAC) conducted an assessment which focused on performance in three major areas as follows:
1.
Adequacy and timeliness of both part and process corrective actions taken on a sample of the historical hardware problems that have been identified at Midland over its lifetime.
2.
The degree to which the physical characteristics of selected supplied components and parts meet their respective quality requirements.
3.
The overall adequacy of the Quality Assurance Program with particular emphasis in carrective actions, effectiveness of the supplier documentation review efforts and personnel qualifications.
This assessment has been completed, the results were positive and all open items have been resolved and closed. The final report has been previously submitted to the NRC.
A Bechtel Corporate Staf f project evaluation was initiated in April 1982. A report on the results of this assessment is being finalized at this time. The oc0982-4024a-66-164
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purpose of this evaluation was to review the Midland engineering activities to determine if design criteria have been implemented and if the design assumptions, design methods, and the design processes are satisfactory.
Bechtel Corporate Management was asked to initiate this assessment in order to certify that the Midland project met all the standards expected of any Bechtel proj ect.
To carry out this assignment the assessment team was specifically chosen to be independent from the Bechtel Ann Arbor Power Division. The team consisted of senior experienced personnel with appropriate expertise having previously performed similar work on other projects. A Consumers Power representative was a direct participant on the assessment team. The final j
report will be sent to the NRC upon completion and whatever other documentation or discussion as may be requested will be provided.
i Conclusion Based on the discussion outlined above and in the reference letter, Consumers Power believes that steps have been taken to insure both the successful implementation of the remaining work to complete the plant and a verification i
program, including quality records, test program results, and third party assessments, that will certify the adequacy of the plant as constructed.
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Page 4 CC Atomic Safety and Licensing Appeal Baard CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harstead Engineering DSHood, NRC (2)
DFJudd, B&W JDKane, NRC FJKelley, Esq RBLandsman, NRC Region III WHMarshall JPMatra, Naval Surface Weapons Center W0tto, Army Corps of Engineers WDPatton, Esq SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers BStamiris oc0982-4024a-66-164
CONSUMERSP0bT$RCOMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 18850 Dated Septe.tber 17, 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 information regarding the implementation of the Consumers Power Company Quality Program for the Midland Plant.
CONSUMERS POWER COMPANY By JW
'ok, ice President Projecte, Engineering ad Construction Sworn and subscribed before me this /'/
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