ML20090A451
| ML20090A451 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/07/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Rubenstein L Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-13, FOIA-84-96 NUDOCS 7909260580 | |
| Download: ML20090A451 (3) | |
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SEP 0 71979 Distribution:
-MFocket Files (2)
QAB Projects QAB Chron. File NRR Reading File dB Docket Nos.:
29 u
' 50-330 JGilray,QAB WHaass,QAB.
l MEMORANDUM FOR:
L. S. Rubenstein, Acting ~ Chief, Light' Water Reactors Branch No. 4 Division of Project. Management -
FROM:
Walter P. Haass, Chief, Quality Assurance Branch, Division of Project Management
SUBJECT:
SUPPLEMENTAL REQUEST FOR -ADDITIONAL SOILS SETTLEMENT INFORMATION
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As a result of'the NRC meeting ~on Midland QA with personnel from Bechtel Power Corporation and Consumers Power Company on September 5, 1979, we have reviewed
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and revised the enclosure to our memorandum to you of August 29, 1979. Our revised version is enclosed for transmittal to Consumers Power Company.
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OriginalsigneJ Tl Walter.N Walter P. Haass, Chief Quality Assuranc~e Branch Division of Project Management
Enclosure:
R; vised Supplemental Request for Additional Soils Settlement
'Information-
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.s SUPPLEMENTAL REQUEST FOR ADDITIONAL SOILS SETTLEMENT INFORMATION
- 23. We have reviewed your response to questica 1 of our March 21, 1979 letter, z
"10 CFR 50.54 Request Pegarding Plant Fill," including related amendments or supplements in your lette~ dated May 31, July 9, and August 10, 1979. We find that the infomation provided is not sufficient for completion of our review. Accordingly, provide the following additional information:
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(1)
Your response to question la do'es not provide sufficient infomation relative to the~ root causes of the 13 deficiencies.
In order to determine the acceptability of the corrective actions for the 13 deficiencies considering the possibility.that.these deficiencies are of a generic nature.that ceuld affect other' areas of the facility, a more complete understanding,0f the root cause of each deficiency is necessary.
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Accordingly, provide'a clearer description of the root causes of each of the 13 deficiencies, including a detailed discussion of. the conditions that existed to~ allow the3e deficiencies and the changes that have been made to preclude the recurrence of such deficiencies.
In this regard, if contributing causes are inadequate procedures, inspections, specifi-cation call outs, design reviews,'and_its, and/or technical direction, a clear and detailed description isln' ce'ssary ts' to wnat allowed these e
conditions to exist and why.
(2)
Regarding your response,to questicrc lb:
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The first seven paragraphs do:not provide. sufficient informati m to a.
assure that contradictions do. not continue to exist in the PSAR, FSAR, design documents, implementing procedures, ' aid as-built condi-tions since the controls described in these seven paragraphs were in effect prior.to the I&E finding's~ reported in J. Keppler's letter of March'15,.1979., Modify your-response.to clearly describe tne control revisions you have~.institutcA to preclude design, contradictions.
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..m b;. Items 1, 2; and 3 of the eighth' paragraph describ$ the review and
~~ update of 'the PSAR cormitmer,t'liste the reviewfof the inactive sections of the FSAR, and the review of proceiure EDP 4.~'22,/ Preparation and I
i Control of Stfety' Analysis Reports," withoutzdescribing the' extent of
.the review process or.the qualificatioils of' personnel inyolved in the
-review.
.Accordingly, describe what eacVof the % reviews entails, W-includidg the* extent to which these reviews dre verified, approved, n
and documented, c' Identify the organizaticnaFunit that is, or will be, involved in'these reviews and the quajificethits;'of the' involved personnel. a
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- c., item-2 of the eighth paragraph states that a reviev of the remaining sections qf the FSAR is not necessary,"... beifausF qflthe ongoing review process described above."
Describe your_rationa rcviewing these remaining sections of the FSAR wben it'le:fer not 3
appears that the original review ~of the FSAR was performed prior to issuance of f,
th'e March 15, 1979 letter providinp the I&E findingsla'nd prior to any
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jcorrective actions resulting therefrom.
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- d. /bDe cri'bE the extent of the audit to whichi'you have coNhtt)d in. item l QN
?;,A of the eign.th paragraph.
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(3)
Question Ic requested that other activities be investigated to cetermine whether programmatic quality assurance deficiencies exist in view of tne apparent breakdown of certain quality assurance controls, and that the activities investigated and the results be identified.
Your response addressed certain specifications and instructions that received a review of 1977; providing for more in-depth verification; increasing management audits from one to two per year; increasing the staff of Sechtel's QA engineers at the sit'e from fivi to eight; instituting 'an overin~spection program on certain Q-listed construction activities; assigning resident engineers at the site to aid in the interpretation of drawings and increas-ing their number from one to twenty-two; and initiating a trend analysis program.
According to your response, most of these actions were initiated-in a.
1977.
Describe,your rationale for assuming that these actions provide confidence that quality assuran:e deficiencies do not exist in other areas.
In order to determine if other areas have deficiencies, work already accomplished in these areas should be investigated.
This includes the review of completed documentation, including inspection results, to verify consistency with design'and SAR requirements.
Also, representative sample inspections of completed work would seem appropriate to determine the acceptability of this work.
Accordingly, describe a program in detail to accomplish the above or provide rationale as to why it is not necessary.
b.
Your use of general'ized statements such as "the review of", " increased audits," "overinspection," " identifying trends,"'and " increase of staff" does not provide sufficient specificity regarding' the detail and extent these actions will take place and the effect they will have in assuring other areas are not_ deficient.
Accordingly, in each of these areas provide a clearer cascripti.on of these actions relative to the full impact they will have in assuring an effective QA program and in sufficient detail to assure that other areas are not deficient.
In those cases where credit is taken for actions already' accomplished i
(such as reviews, inspections, and audits), provide a summary of.the j.
results of these actions. such that the success or failure of the actions can be determined.
l (4) Considering' the results of your investigation requested in our question Ic, question ld asked that you describe your position as to the overall effectiveness of-the QA program for the Midland Plant.
Your overall assessment of. the effectiveness of your program should be bar.ed on your i-l revised response to our question Ic.
(see above question 23(3))..The results of this ' assessment, including.a description of the ; scope _and.
extent of the assessment effort and the. identification and qualifications l
of the individuals involved in this assessment, should be reported to us.,'
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