ML20076A819
| ML20076A819 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/09/1983 |
| From: | Levin H TERA CORP. |
| To: | Jackie Cook, Eisenhut D, James Keppler CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8308180345 | |
| Download: ML20076A819 (7) | |
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- 374 August 9,1983 W-(p[/il.E6C
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c Mr. James W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Mr. J. G. Keppler Administrator, Region 111 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Mr. D. G. Eisenhut Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 no Re: Docket Nos. 50-329 OM, OL and 50-033 OM, OL Midland Nuclear Plant - Units I and 2 Independent Design and Construction Verification (IDCV) Program Meeting Summary A meeting was held on August 5, 1983 at TERA Corporation's Bethesdo, Maryland offices to discuss options for modification of the Midland IDCV program with respect to initiatives associated with Section 13 of Public Low 97-415, NRC Authorization Act for Fiscal Year 1983 (Ford Amendment). A list of participants is provided in Enclosure 1.
The meeting opened with a discussion of elements of the Ford Amendment (Enclosure 1) and specifically, NRC's plans and logistics for responding to the legislation. Darl Hood, NRC Midland Project Manager, presented on overview, pointing out that the NRC is studying six pilot programs in addition to the Midland IDCV program (Morble Hill, Millstone 3, Polo Verde, Limerick, South Texas, Beaver Valley) in on effort to report back to Congress in April 1984 on the efficacy of certain opproaches to assuring and verifying the quality of nuclear power plants under construction. The headquarters of the NRC's Office of Inspection and Enforcement under the direction of James Taylor has lead for this effort. Paul Keshishion and George Gower have been assigned responsibility for implementing the NRC's cctivities. Mr. Hood pointed out that he felt certain minor modifications of the Midland IDCV program were necessary to make the B3o8180345 830809 PDR ADOCK 05000329 A
PDR 1 2 TMO TERA CORPORATION N/
7101 WISCONSIN AVENUE BETHESDA, MARYLAND 20814 301 654:8960 2
Mr. J. W. Cook 2
August 9,1983 Mr. J. G. Keppler Mr. D. G. Eisenhut program fully responsive to the intent of the Ford Amendment legislation. These
" enhancements" would be to include o " horizontal slice" component in the areas j
of design / construction control and QA/QC implementation.
Billy Garde, Government. Accountability Project, voiced her organization's concurrence that these reviews are required to be responsive to the Ford Amendment legislation and that she felt that the IDCV program should be studied as port of the NRC's response to the Ford Amendment legislation.
Louis Gibson, Consumers Power Company (CPC), reiterated CPC's agreement to provide for TERA resources to support NRC's observation of the Midland IDCV program implementation and a review of its outputs; however, he pointed out that expansions of scope were not contemplated under the agreement. He further pointed to the numerous efforts that were ongoing, and questioned the need for expansion of the program to include " process" reviews when it was considered in the overall context of these other programs which include similar elements.
Paul Keshishion, NRC, l&E, indicated that process or " horizontal slice" elements were necessary; however, he wanted a better understanding of the degree to which the current Midland IDCV program would address these so that a determination could be made relative to the need for program modifications.
l Howard Levin, TERA Project Manager, indicated that the Midland IDCV program principally focused on a review of the quality of the end products of the design or construction processes rather than the processes by which these products were j
created. Generally, process related issues are considered only as the need arises os dictated by Findings whose root causes may potentially be related to deficiencies in the implementation of various processes. When questioned on the degree to which process issues would be reviewed, he indicated that at this point in the program certain issues were under review; however, the full set of issues would be indeterminate in view of the fact that the nature of any future Findings is unknown.
The NRC representatives asked questions relative to the ability of the Midland IDCV program to draw conclusions about the implementation of the QA plan and the degree of compliance to 10 CFR 50, Appendix B.
There was general i
agreement of all participants that the QA plan itself meets 10 CFR 50, Appen-dix B and that its implementation was of interest. Levin commented that by the end of the IDCV program, TERA would at least be able to infer a conclusion relative to the implementation of GA/QC programs and conformance to 4
1 10 CFR 50, Appendix B. In certain cases, this would be more than on inference in view of the fact that objective process reviews would be undertaken as follow-up to any Findings.
All participants generally conceded that the design and construction control processes and the parallel QA/QC verification are important in producing a TE?A CORPORATION
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Mr. J. W. Cook 3
August 9,1983 Mr. J. G. Keppler Mr. D. G. Eisenhut quality constructed facility. Levin pointed out that for the evoluotion of a facility in later stages of construction, a review of process issues is of lesser significance in reaching conclusions and that a more direct approach is the
" vertical slice", provided quality is readily measurable by physical or other means. He further observed that " quality facilities have been ottoined with weaker QA/QC programs and vice verso." Levin indicated that process reviews become potentially more useful when evoluoting inaccessible items or items where quality is otherwise difficult to measure.
The subject of other independent GA/QC reviews was discussed relative to their merits and cost effectiveness. It was generally concluded that a detailed point-by-point comparison to 10 CFR 50, Appendix B was not worronted. There was a general agreement that a focused review of selected issues would potentially be most effective from all accounts. A consensus was reached that TERA should develop a " white paper" for consideration by CPC and NRC as a potential option.
The paper should address perspectives identified in the meeting tempered by TERA's experience to identify on option that is complementary to the existing IDCV program. The decided turn-a:ound time was opproximately one week.
Sincer ly,
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- Cm h :, m Howard A. Levin Project Manager Midland IDCV Program cc:
Participants F. Buckman, CP D. Miller, CPC (site)
B. Palmer, CPC (site)
Midland IDCVP Service List J. Taylor, NRC, I&E HQ TEi4 CORDORATON
m SERVICE LIST FOR MIDLAND INDEPEbOENT DESIGN AND CONSTRUCTION VERIFICATION PROGRAM cc:
Harold R. Denton, Director Ms. Barbara Stamiris Office of Nuclear Reactor Regulat. ion 5795 N. River U.S. Nuclear Regulatory Commission Freeland, Michigan 48623 Washington, D.C. 20555 Mr. Wendell Marshall James G. Keppler, Regional Administrator Route 10 U.S. Nuclear Regulatory Commission, Midland, Michigan 48440 Region ill 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Illinois 60137 2120 Corter Avenue U.S. Nuclear Regulatory Commission Resident inspectors Office Ms. Billie Pirner Garde Route 7 Director, Citizens Clinic Midland, Mich.igan 48640 for Accountable Government Government Accountability Project Mr. J. W. Cook Institute for Policy Studies Vice Pres,ident 1901 Que Street, N.W.
Consumers Power Company Washington, D.C. 20009 1945 West Pornoll Road Jackson, Michigan 49201 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board i col k'Beoie U.S. Nuclear Regulatory Commission om, Washington, D.C. 20555 Three First Nationo! Plazo, Chic o, 11 is 60602 6125 N. Verde Trail James E. Brunner, Esq.
Boca Roton, Florido 33433 Consumers Power Company 212 West Michigan Avenue Jerry Harbour, Esq.
Jackson, Michigan 49201 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W shington, D.C. 20555 71l Su e set Drive Midland, Michigan 48640 Mr. Ron Collen Mi higan Public Service Commission Cherry & Flynn 6545 Mercontile Way Suite 3700 P.O. Box 30221 Three First Not.ional Plaza Lansing, Michigan 48909 Chicago, Ill,inois 60602 Mr. Paul Rou Ms. Lynne Bernobe.
Midiond Daily News Government Accountability Project 124 Mcdonald Street 1901 O Street, NW Midland, Michigan 48640 Washington, D.C. 20009
ENCLOSUREI List of Participants Meeting to Discuss Options for Modification of the Midland IDCV Program with Respect to initiatives Associated with Section 13 of Public Low 97-415 (Ford Amendment)
Nuclear Regulatory Commission D. Hood, NRR P. Keshishion, I&E G. Gower, I&E Consumers Power Company L. Gibson TERA H. Levin D. Tulodieski R. Snaider H. George (partial)
J. Mortore J. Richardson Government Accountability Project B. Garde ERA CORPORAPON e
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(4) improvement of the Cemission's organization, methods.
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- 13(b) The Comission shall con uct a study of existing and alterna.
and programs for quality assurance development, review, and d
tive programs for improving quality assurance and quality control Inspection; and In conduct.
in the constmction of comercial nuclecr powerplants.
(5) conditioning the issuance of construction permits for com.
ing the study, the Comission sh'all obtain the coments of the.
mercial nuclear powerplants on the permittee entering into public, licensees of nuclear powerplants, the Advisory Comittee on contracts or other arrangements with an independent inspector
'vi Reactor Safeguards, and organizations comprised of professionals to audit the quality assurance program to verify quality assur.
1 The study shall include an k
having expertise in appropriate fields.
ance performance, analysis of the following:
For purposes of paragraph (5), the term ' independent inspector' (1) providing a basis for quality assurance and quality control.
means a person or other entity having no responsibility for the
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inspection, and enforcement actiorfs through the adoption of an design or construction of the plant involved. The study shall also E
approach which is more prescriptive than that cu'rrently in include an analysis of quality assurance and quality conteo1 pro.
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practice for defining principal architectural and engineering grams at representative sites at which such programs are operating Z
criteria for the construction of comercial nuclear powerplants; satisfactorily and an assessment of the reasons therefor.
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(2)conditioningtheissuanceofconstructionpermitsforcom.
- 4 mercial nuclear powerplants on a demonstration by the licensee
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13(c) For purposes of.
that the licansee is capable of independently managing the (1) determining the best means of assuring that comercia1 h
w effective perfcrmance of all quality assurance and quality con.
nuclear powerplants are constructed in accordance with the g
trol responsibilities for the oowerplant; applicable safety requiremects in ef fect pursuant to the Atomic (3) evaluations, inspections, or audits of co-reccial nuclear
,w Energy Act of 1954; and powerplar.t construction by organizations comprised of profes.
(2) assessing the feasibility and benefits of the various means w
sionals having expertise in appropriate fields which evaluations, listed in subsection (b);
inspections, or audits are more effective than those under cur.
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,--..8 the Lo mission shall undertak2 a pil:t program to revitw and evaluate from th2 public and from other p2rsons referred to in subsection (b) programs that include one or more of the alternative concepts identi*
and a statement of the Commission's response to the significant fledinsubsection(b)forthepurposesofassessingthefeasibility conenents received. The report shall also set forth an analysis of the and benefits of their implementation. The pliot program shall include results of the pilot program required under subsection (c). The programs that use independent inspectors for auditing quality assurance report shall be accompanied by the recomendations of the Comission, responsibilities of the licensee for the construction of comercial including any legislative recomendations, and a description of any avi nuclear powerplants, as described in paragraph (5) of subsection (b).
administrative actions that the Comission has undertaken or intends lhe pilot program shall include at least three sites at which com-to undertake, for improving quality assurance and quality control E,
mercial nuclear powerplants are under construction. The Comission crograms that are applicable during the const'ruction of nuclear I
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shall select at least one site at which quality assurance and quality powerplants."
control programs have operated satisfactorily, and at least two sites estese coce fees-es-c 4
SL with remedial programs underway at which major construction, quality assurance, or quality control deficiencies (or any combination thereof)
Zo have been identified in the past. The Comissier may recuire any s
changes in existing quality assurance and quality control organizations
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H and relationships that may be necessary at the selected sites to y
G implement the pilot program.
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13(d) Not later than ft(teen months after the date of the enactment "r
of this Act, the Comission shall complete the study required under g
~e subsection (b) and submit to the United States Senate and House of 8
Representatives a report setting forth the results of the study. The s
Zo report snali include a brief sumary of the information received X
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