ML20090A456
| ML20090A456 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/29/1979 |
| 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 7909290355 | |
| Download: ML20090A456 (3) | |
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DIslP.I-BUTION:
M ntral File.
AUG 21 1973 QAB Projects
-QAB Chron. File NRR Reading File DJSkovholt, DPM JGilray, QAB pg WHaass,QAB DHood, DPM 11EMORANDUM FOR:
L. S. Rubens.tein, Acting Ch,ief, Light Water Reactors Branch No. 4, Division of Project Management FROM:
Walter P. Haas's,~ Chief," Quality As:;urance Branch',
Division of Project Management
SUBJECT:
QAB REVIEW 0F CONSUMERS' RESPONSE.T0 10 CFR 50.54(f)'
QUESTION 1 We have reviewed Co'nsumers Power Company's (CPC) response' to question 1 of NRC'~s
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March 21.1979 letter, "10 CFR 50.54 Request Regarding Plant Fill." Question 1 addresses the quality assurance program for the design and construction of. the Midland Nuclear Power Plant. and the response by CPC was provided by letters j
dated April 24 and flay 31, 1979.
(An additional CPC letter dated July 9,1979 l
did not revise the response to question 1.) As a result of our review, we have d:termined that additional information is necessary.
~ Wa reconnend that a meeting with CPC~ be arranged to discuss this matter. For this purpose, we have prepared items -where additional information is needed that can serve as an agenda for the meeting. The enclosed request for additional infonnation should be transmitted to Consumers Power Company in advance of the meating.
.: Originalsigned by
., ;.Q' P. Haass f
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Walter P. Haass, Chief Quality Assurance Branch Division of Project Management Enclosiire:
Request for, Additional Infonnation ~
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a REQUEST FOR ADDITIONAL INFORMATION j
l We have reviewed Consumers Power Company's response to question 1 of NRC's March 21, 1979 letter, "10 CFR 50.54 Request Regarding Plant Fill" and conclude that the infor-mation provided is not sufficient to determine that an acceptable QA program has been, and is being, implemented for the Midland project.
Accordingly, in order to gain a
.better understanding of your response to. question 1, provide your response to the following:
1.
Your response to question la does not provide sufficient information 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 could affect other areas of the facility, a more complete understanding of the root cause of each deficiency is necessary. 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 these deficiencies and the changes that have been made to preclude the recurrence of such deficiencies.
2a.
The first seven paragraphs of your response to question. lb do not provide sufficient 1
1 information to assure that contradictions do not continue to exist in the PSAR, FSAR, design documents, implementing procedures, and as-built conditions since the controls described in these seven paragraphs were in effect prior to the I&E find-ings. Modify your response to clearly describe the control revisions you have instituted to preclude design contradictions.
b.
Items 1, 2, and 3 of the eighth paragraph describe the review and update of the PSAR comitment list, the review of the inactive sections of the FSAR, and the review of procedure EDP 4.22, " Preparation and Control of Safety Analysis Reports,"'
without describing the extent of the review process or the qualifications of i
. personnel involved in the review.
Accordingly, describe what each of these reviews entails, including the extent these reviews are verified, approved, and documented.
Identify the organizational unit that is, or will be, involved in l
these reviews and the qualifications of the involved personnel.
Item 2 of the eighth paragraph includes a statement that a review of the reniaining c.
sections of the FSAR is not necessary, "...because of the ongoing review process described above." Describe your rationale for not reviewing these remaining sections of the FSAR when it appears that the original review of the FSAR was performed prior to the I&E findings.
d.
Describe the extent of the audit committed to in item 4 of the eighth paragraph.
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Ouestion-Ic requested that'5ther^adidtfes be investigated to detcr iine ;;hether programm& tic ' quality; assurance defiihncies exist in view of the apparent break-dom of certain quality assuranceNontrols, and that the activities investigated and the results be identified.
Your response addressed certain specifications a'ndsinstructions that' received a review in 1977; providing for more in-depth verification; increasing management audits,from.one to two per year; increasing
, the staff of i'echtel's QA engineers at the site,from five to eight; instituting
. an overinspect; ion program on certain Q-listed construction activities; assigning
' resident. engineers at the site to aid in the interpretation of drawings and t'
increasing thefr muQer from.one to twenty-two; and initiating a trend analysis program. According'to your response, most of these p.tions were initiated in 1977.. Describe your rationale for assuming that thesesactions provide confidence that quality assurance deficiencies do not exist in other crees.
In order to i
determine if other areas have deficiencies, work alreWdy accomplished in these
' areas should be investigated. This includes the reviewgf.cogleted documentation, including inspection results, to verify consistency with design and SAR requirements.
4 Also,' representative sample inspections of completed work would seem appropriate l
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.
Also, thewse of generalized statements such as the review of, increase audits, nyerinspection, identifying trends, and. increase of staff does not provide sufficient
,5pecificity 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 description of the'se actions to permit one to understand the full impact they Will havs'in assuring an effective QA program i
and that other areas are not deficient In-th actions already accomplished (such as}evhys,ose cases where credit is taken for inspections,'and audits), provide
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a summary of the results of these actions 'such thst the success or failure of the actioiisicanbedetermined.
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Considering the results of your investigation req \\uested in our question ic, question id requested that you describe your position as to the overall effectiveness of the QA program for the Midland facility. Accordingly, an overall assessment of the effectiveness of your program should be based on your revised response to our question 1c.
The results'of this assessment, including a description of the scope' 1
and extent of the assessment effort and the ic'entification.and qualifications of theindividualsinvplvedinthisas(essment,sh'ouldbedocumentedandreportedtous.
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