ML20080H418
| ML20080H418 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/10/1984 |
| 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 8402140194 | |
| Download: ML20080H418 (5) | |
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L J February 10, 1984 Mr. James W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jacosn, Michigan 49201 Mr. J. G. Keppler Administratcr, Region Ill Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Rood Glen Ellyn, Illinois 60137 Mr. D. G. Eisenhut Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket Nos. 50-329 OM, OL and 50-330 OM, OL Midland Nuclear Plant - Units I and 2 Independent Design and Construction Verification (IDCV) Program Future Direction of the Midland IDCVP Gentlemen:
The current status of the Midland project is a major factor offecting the planned progress of the IDCVP.
A portion of the design and construction products originally selected within the IDCVP scope are still in process, impacting on expeditious completion of a " vertical slice" review of the Midland project considering the " quality of the end product." The existing IDCVP methodology has assumed that items within its scope are complete, placing emphasis on on evoluotion of the quality of the end product rather than the process by which the items were designed and constructed. A thorough examination has been made to assess means by which the original stated goals of the IDCVP would be met f
without a needless delay for all Midland project design and construction activities to be completed. We have determined that a limited modification of the IDCVP methodology is required to accomplish these goals. Our modified approoch includes:
e Maintaining the existing vertical slice approach to design verification by:
Reviewing end products for majority of sample:
Reviewing engineering procedures and oction plans and their impimentation for the remainder of the sample where items are not complete.
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6 ko TERA CORPORATION 7101 WISCONSIN AVENUE BETHESDA MAFMAND 20814 301 654 8960
> o Mr. J. W. Cook 2
February 10,198h Mr. J. G. Keppler Mr. D. G. Eisenhut Postponement of the construction verificotton until com-e pletion of Phase I of the Midland project Construction Completion Program (CCP), thus, taking advantage of the assemblage of relevant quality documentation by the Quality Verification Program (OVP). During the period of postponement, conduct a verification review of selected OVP documentation processes to allow expedited docu-mentation and physical verification offer Phase I of the CCP.
o Focused review of identified process-related issues result-Ing from exist'ng Findings and ongoing work.
Thus, the principal alteration involves verification of a limited portion of the design verification sample by reviewing engineering procedures and action plans and their implementation for items not currently completed. It is estimated that opproximately 10 to 20 percent of our sample would be verified in this manner and thot 80 to 90 percent of our sample will continue to be verified with emphasis on the quality of the end product. We believe that this approach is superior to the current IDCVP methodology since the results of the "end product" review will be combined with a review of the design programs to assure greater confidence in the conclusions reached.
The following paragraphs address issues relevant to the design and construction verification efforts and details of how our modified opproach will be imple-mented. We anticipate that this approach would allow the design verification to be bifurcated from the construction verification. The design verificction could be completed by July of 1984, at which time the results would be evollable to external porties and the physical verification may potentially re-commence consistent with the status of the CCP.
Design Verificotton Although the design verificotton program is proceeding with its original plan of reviewing completed products, some design areas in our sample are currently incomplete or are being revised. Often there are sufficient sets of end products to allow odauote review to be made even though certain design areas are not yet complete. In other cases, it has been necessary to put verification work on
" hold" pending further progress in design. We have made on assessment of the current status of the IDV program and the status of the plant design. Presented below is on outline of our recominendatior's for modification of the IDV program to accommodate the areas which are not currently complete.
At this time, IDV programs con be divided into two major subcomponents: the current program for the areas where sufficient end products exist to allow application of the current program and the proposed modifications for other TEPA CORPORATION
o Mr. J. W. Cook 3
February 10,1984 Mr. J. G. Keppler Mr. D. G. Eisenhut design oreos.
The current program includes dispositioning of Findings and Confirmed items os well as review of design aspects which are complete or substantially complete.
For design areas still in progress or in revision, we recommend that the review use ovalloble end products (or intermediate products) combined with a limited review of the engineering action plans and implementing processes by which the design effort will be completed. This would be accomplished by confirming the status of all design areas and dividing them into those which are substantially complete and those which are subject to the modified program.
For each incomplete design area the revised program will require identification of the processes to be used to complete the design area. The processes thus identified will then be oppropriately grouped and reviewed using ovalloble end or inter-mediate products os a means of verification of implementation. In concept, this approach represents only a small change from the current program. The current program already calls for review of processes where necessory to disposition Findings or Confirmed items. Rother than limiting such on opproach to Findings, we recommend using it to speed completion of our review of the Midland design and enhance our confidence in extropolating results.
Construction Verificotton The ability to bring several aspects of the construction verification program to completion hos been, and is in the near term, projected to be influenced by the status of the Midland project CCP. Physical verification reviews and reviews of construction / installation documentation have essentially been suspended or signi-ficantly narrowed in scope os a result of CCP status. For the near term, it is suggested that construction verificotton be suspended until such time as the CCP completes its Phase I activities on IDCVP-selected components and c3mmodities.
Proceeding in this fashion allows the CCP to perform the essential "statusing" function and allows the Midland project QVP to ossemble and verify pertinent documentation, thus enabling an efficient utilization of IDCVP resources when conducting future documentation and physical verificolion rev!ews. To date, significant (DCVP resources have been expended in assembling quality documen-totion which is used to verify the quality of instalid and constructed items and support physical verification. Under the suggested approach, the quality dato packages con be verified more efficiently, permitting less IDCVP resources to be devoted to this activity in the future by utilizing the documentation packoges assembled by the OVP and focusing resources to end product confirmation. To j
effect this, we would selectively review the OVP documentation process, to enhcnce verification of the quality of the documentation. This will also permit a f
more direct tocus on the IDCVP physical verification.
The near-term focus of the construction verification review will be on further dispositioning of outstanding items and selective review of the OVP documento-tion process.
TERA CCQPORATION i
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e Mr. J. W. Cook 4
February 10,1984 Mr. J. G. Keppler Mr. D. G. Eisenhut if desired, we will discuss the items presented herein during the next scheduled IDCVP Status Review Meeting to be held at Bechtel's Ann Arbor, Michigan offices on February 29,1984.
l Sincerely,
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Howard A. Levin Project Monoger Midland IDCVP cc:
L. Gibson, CPC R J. Erhardt, CPC D. Budzik, CPC D. Quammy, CPC (site)
R. Whitaker, CPC (site)
J. Taylor, NRC, l&E HQ D. Hood, NRC T. Ankrum, NRC, !&E HQ J. Korr, S&W J. Milhoon, l&E HQ Midland IDCVP Service List Attachments HAL/djb I
l TERA CORADRATICN
o SERVICE LIST FOR MIDLAFO INDEPEtOENT DESIGN r
Ato CONSTRUCTION VERIFICATION PROGRAM cc:
Harold R. Denton, Director Ms. Barboro Stamiris Office of Nuclear Reactor Regulat. ion S795 N. River U.S. Nuclear Regulatory Commission Freeland, Michigan 48623 Washington, D,C. 20555 Mr. Wendell Marshall l
James G. Keppler, Regional Administrator Route 10
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U.S. Nuclear Regulatory Commission, Midland, Michigan 48440 t
Region 111 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Illinois 60137 2120 Carter Avenue
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St. Paul, Minnesoto nim 11.S. Nuclear Regulatory Ccmmission Resident inspectors Office Ms. Billie Pirner Garde Route 7 Director, Citizens Clinic Midland, Michigan 48640 for Accountable Government Government Accountability Project Mr. J. W. Cook Institute for Policy Studies Vice President ip01 Ove Street, N.W.
Consumers Power Company Washington, D.C. 20009 1945 West Pornoll Road
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Jackson, Michigan 49201 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board Michoe! I. Miller, Esq.
U.S. Nuclear Regulatory Commission is; am, Lincoln & Beale Washington, D.C. 20555 Three First National Plazo, Sist floor Dr. Frederick P. Cowan Chicogo, 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 Harbour, 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 Plaz Lansing, Michigan 48909 Chicago, Illinois 60602 Mr. Paul Rou Ms. Lynne Bernobei Midland Daily News Government Accountability Project 124 Mcdonald Street 1901 O Street, NW Midland, Michigan 48640 Washington, D.C. 20009 l
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