ML20076C400
| ML20076C400 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/15/1983 |
| 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 | |
| NUDOCS 8308220347 | |
| Download: ML20076C400 (7) | |
Text
L J August 15,1983-Mr. James W. Cook Vice President Consumers Power Company 1945 West Pornoll Road Jackson, Michigan 49201 Mr. J. G. Keppler Administrator, Region til 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. Nucieor Regulatory Commission Washington, D.C. 20555 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 Conceptual Options for independent Quality Verification Program Methodologies in accordance with direction provided during the August 5,1983 meeting to discuss options for modification of the Midland IDCV program with respect to initiatives associated with Section 13 of Public Law 97-415 (Ford Amendment),
TERA has identified several conceptual methodologies considering input provided by Consumers Power Company and NRC representatives. The ottoched " white paper" is intended for comment and is planned as a topic for discussion at on upcoming meeting which is tentatively set for August 26,1983, at Bechtel's Ann Arbor offices.
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TERA CORPORATION L
7101 WISCONSIN AVENUE BETHESDA MAIMAND20814 301 c54 8900
Mr. J. W. Cook 2
August 15,1983 Mr. J. G. Keppler Mr. D. G. Eisenhut it is envisioned that future discussions between CPC, NRC, and TERA will enable o definition of what reprogramming, if any, is required to make the Midland IDCV progrom responsive to the Ford Amendment legislation.
Sincerely,
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Howard A. Levin Project Manager Midland IDCV Program cc:
L. Gibson, CPC F. Buckman, CPC D. Miller, CPC (site)
B. Palmer, CPC (site)
J. Taylor, NRC, l&E HQ D. Hood, NRC P. Keshishion, NRC, I&E HQ G. Gower, NRC, l&E HQ Midland IDCVP Service List Attachment l
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SERVICE LIST FOR MIDLAtO INDEPENDENT DESIGN AND CONSTRUCTION VERIFICATION PROGRAM cc:
Harold R. Denton, Director Ms. Barbara Stomiris 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, Regiono! Administrator Route 10 U.S. Nuclear Regulatory Commission, Midland, Michigan 48440 Region 111 799 Roosevelt Road Mr. Steve Godler Glen Eliyn, Illinois 60137 2120 Corter Avenue St. Paul, Minnesota 55108 U.S. Nuclear Regulatory Comm.ission Resident inspectors Office Ms. Billie Pirner Garde Route 7 Director, Citizens Clinic Midland, Mich.igan 48640 for Accountoble Government Government Accountability Project Mr. J. W. Cook Institute for Policy Studies V,ce Pres,ident 1901 Ove Street, N.W.
i Consumers Power Company Washington, D.C. 20009 1945 West Pornoll Road Jcckson, Michigan 49201 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board Michael 1. Miller, Esq.
U.S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D.C. 20555 Three First National Plaza, 51st floor Dr. Frederick P. Cowan Chicago, Illinois 60602 Apt. B-125 6125 N. Verde Trail James E. Brunner, Esq.
Boca Roton, Florido 33433 Consumers Power Company 212 West Michigan Avenue Jerry Herbour, Esq.
Jackson, Michigan 49201 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Ms. Mary Sinclair Washington, D.C. 20555 5711 Summerset Drive Midland, Michigan 48640 Mr. Ron Collen Michigan Public Service Commission Cherry & Flynn 6545 Mercontile Way Suite 3700 P.O. Box 30221 Three First National Plaza Lonsing, Michigan 48909 Chicogo, Illinois 60602 Mr. Paul Rau Ms. Lynne Bernobei Midland Daily News Government Accountability Proj.ect 124 Mcdonald Street 1901 O Street, NW Midland, Michigan 48640 Washington, D.C. 20009
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c CONCEPTUAL OPTIONS FOR INDEPEf0ENT QUALITY VERIFICATION PROGRAM METHODOLOGIES The independent Design and Construction Verification (IDV, ICV) components of the Midiond IDCV program focus on on engineering evoluotion of the quality of end products of the design and construction processes. Due to the focus on end products, process reviews were not intended to be a port of the IDV and ICV programs. The NRC has expressed a desire to modify the Midland IDCV program to include o review of these processes. Several conceptual options have been identified for the potential addition of an independent Quality Verification (IOV) program os on integral part of the Midland IDCV progrom to selectively evoluote the implementation of the design control, construction control and QA/QC processes. The melding of the IQV and IDV/ ICV components potentially provides enhanced capability to evoluote overall quality through the combination of a limited " horizontal slice" process review with a " vertical slice" three-system test of these processes. The relative benefits of such on approach versus the existing opproach is subject to o degree of speculation in view of the fact that the nature of the Midland IDCV program Findings and the depth of penetration into process reviews is indetermincte at this time.
Added assurance may be gained in extrapolating the conclusions (i.e., to other safety systems provided that these other systems were designed and constructed by similar processes) reached through a combined hori7ontal and vertical review; however, such benefit hos not as yet been quantified through industry experience.
Design and Construction control processes and the parallel GA/QC verification are important in producing a quality constructed facility. For the evoluotion of j
o facility in later stages of construction, a review of process issues is of lesser significance in reaching conclusions. A more direct opproach is on engineering evoluotion of completed products (e.g., the existing Midland IDCV program
" vertical slice") provided the quality is readily measurable by physical or other l
means.
Process reviews become potentially more useful when evoluoting l
l inaccessible items or items where quality is otherwise difficult to measure.
I TERA CORPORATION
As specific design or construction related deficiencies are ider..
i within either the IDV or ICV programs, process related questions are potentially raised as part of the evaluations ossociated with root cause determination. Decisions may be made at any time to initiate focused reviews as circumstances warrant.
In view of the substance of such matters, these decisions are generally by consensus of CPC, NRC, and TERA. Clearly, option I may be to retain this element of the existing IDCV progrom and wait untlI later stages of the program to make decisions relative to the need for expansion of scope to systematically review process related issues.
Option 2 may be not to initiate process reviews within the specific scope of the IDCV program; however, utilize the program os a mechanism to assimilate the outputs of various other ongoing programs that address process related issues to provide o broader perspective.
A third optional approach for on lOV program may be o focused review of process issues biased towards items that evolve from:
o IDV and ICV program Findings; o
An evaluation of project experience and noted process related deficiencies; o
Process related issues known to have presented problems within the nuclear industry.
The implementation of all design / construction control and QA/QC processes relative to criteria of 10 CFR 50, Appendix B will not be evaluated under this option for on IQV program. The selection of specific issues within scope would be based upon the judgement of senior reviewers on the IDCV and lOV project teams. The objective would be to devote resources on a priority basis in creas that worront greater attention, recognizing that certain process issues are more significant and have o greater potential to compromise quality.
An attempt would be made to identify potential areas where identified root causes may also have manifested in problems (however, as yet unidentified) in the some or similar form. This opproach is supported by the fact that industry experience dictates l
that undetected problem oreas (which are of greatest concern) are likely to be l
the result of similar root causes os detected problems.
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l TERA CORFORATION
The identification of the portion of the IOV scope that is derived from the IDV and ICV program Findings would be ongoing and subject to change os the IDCV program progresses.
This subset would be supplemented, os necessary, by additional areas determined through on evoluotion of project experience.
Sources of information such as NRC inspection reports, SCREs, MCARs,50.55e reports, quality assurance and inspection reports, etc. would be reviewed for this purpose.
It is contemplated that the following issues would be reviewed on on a priori basis in view of their importance to complex projects and general impact within the industry.
NSSS/ BOP interface control (i.e., B&W and B?chtel);
o o
interface control between disciplines (e.g., civil /struc-tural and mechanical groups within Bechtel);
o Vendor interface control (e.g., between Terry Turbine and Bechtel for the AFW turbine);
o Control of design changes; o
Document control (i.e., at site and design office);
o Control of field changes; o
Trcnslation and interpretation of design requirements into procedures; Development of QA/CC inspection procedures and imple-o mentation.
This listing would constitute the initial scope of the IOV for option 3.
As discussed, a potential exists that these areas of review may have to be supplemented subject to the project experience evoluotion and IDCV Findings.
As with option 2, on important element of the option 3 IQV program would be the review and evoluotion of the overall odequacy of the implementation of the Construction Completion Program (CCP) and its effectiveness in identifying and correcting potential undetected problems ossociated with post activities and for completion of the remainder of work. The IQV objective would be to determine 3
TERA CORPORATION
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whether the CCP remedial measures adequately attend to the issues for which the CCP was creoted. The review would verify that the CCP process which is now the primary construction process, os supplemented with odditional verifico-tion activities, odequately addresses potential quality concerns. Outputs from the Construction implementation Overview (ClO) of the CCP would be assimu-lated into this assessment. Accordingly, TERA's review would not duplicate the ClO efforts, but complement it through integrating its outputs into the IDCV evaluation process. Selected creas outside the CCP scope could otso be selected such as Babcock and Wilcox and Zack HVAC octivities; however, the specific organizations or programs to be evaluated should be determined based upon the involvement in the design or construction of the three systems within the IDCV program scope.
Option 4 may be consideration of a program that is similar to o common quality assurance audit. The quality assurance manuals, procedures and records would be reviewed against applicable requirements of 10 CFR 50, Appendix B and other industry standards. The audit would include o review of objective evidence that the GA program was odequately implemented and documented. Given the status of the Midland project and various other considerations, this option may not be technically viable and is most costly.
Options I through 3 are all technically feasible. There may be cost-benefit trade-offs associated with the selection of any of these options, including the more obvious schedular considerations. Option 2 would appear to be the least resource intensive effort. Options I and 3 may very well be equivalently cost-effective. If the IDCV program identifies few process related Findings, then option I may be most effective; otherwise, option 3 may provide for o more systematic and efficient review process.
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