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A 8 )q(k NUCLEAR REGULATORY COMMISSION L 2 REGION lli %k' / t 799 ROOSEVELT ROAD br 8 GLEN ELLYN,ILLINolS 60137 o August 23, 1983 MEMORANDUM FOR: James G. Keppler Regional Administrator FROM: R. L. Spessard, Director Division of Engineering
SUBJECT:
LETTER FROM TERA REGARDING MIDLAND IDCV PROGRAM (F03038183) I reviewed the TERA " white paper", since there were no other cognizant DE personnel available, and I have no significant comments to offer. This paper is very difficult to understand, especially without a detailed knowledge of the various programs (IDCVP, CCP, etc.) being implemented at Midland; however, it appears to me that Option 1 would satisfy the NRC's needs to have information on " process reviews" without significantly im-pacting the scope of IDCVP as it presently exists. I discussed this subject with J. Taylor (IE) since that office has the responsibility and resources to manage the NRC's efforts concerning the QA Initiatives. I believe that my views, as described, are consistent with IE's, and IE will be present at the upcoming meeting on this subject. f'2'M v R. L. Spessard, Director Division of Engineering cc: R. F. Warnick i j i 8406020111 840517 PDR FOIA RICES 4-96 PDR
f L J l-M @g-gvxtIF 3 rJ ' O/RA 6O A A/RA to OPP' ac August 15,1983 0 g OE-L \\L QL Mr. James W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Mr. J. G. Keppler Administrator, Region til Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road i 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 Re: Docket Nos. 50-329 OM, OL and 50-033 OM, OL Midland Nuclear Plant - Units I and 2 Independent Design ono Constr_uction 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 modificotton of the Midland IDCV program with respect to initiatives associated with Section 13 of Public Low 97-415 (Ford Amendment), TERA has identified uveral conceptual methodologies consider put provided b ntatives. T u s+7-M AUG 131883 TERA CORPORATION s2aosumeaewetAvaws fire.edtiuweaanseau inbaumeo
4 Mr.. 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 program responsive to the Ford Amendment legislation. Sincerely, / d 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, I&E HQ D. Hood, NRC P. Keshishion, NRC, I&E HQ G. Gower, NRC, I&E HQ Midland IDCVP Service List Attachment A HAL/djb m cm ~
SERVICE LIST FOR MIDLAbO INDEPEPOENT DESIGN AFO CONSTRUCTION VERIFICATION PROGRAM ec: Harold R. Denton, Director Ms. Barboro Stamiris Office of Nuclear Reactor Regulat.im 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 lil 1 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Illinois 60137 2120 Carter Avenue U.S. Nuclear Regulatory Commission Resident inspectors Office Ms. Billie Pirner Garde Route 7 Director, Citizens Clinic 1 Midland, Michigan 48640 for Accountable Government Government Accountability Project Mr. J. W. Cook Institute for Policy Studies Vice President l901 Que Street, N.W. Consumers Power Compmy Washington, D.C. 20009 1945 West Parnall Road Jackson, Michigan 49201 Charles Bechhoefer, Esq. Atomic Safety & Licensing Board Michael I. Miller, Esq. 'U.S. Nuclear Regulatory Commission .lsham, Lincoln & Beale Washington, D.C. 20555 Three First National Plaza, Sist 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 Harbour, Esq. Jackson, Michigan 49201 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Ms. Mary Sincla.ir Washington, D.C. 20555 5711 Summerset Drive Midiond, 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 Chicogo, Illinois 60602 Mr. Poul Rou Ms. Lyme Bernobel Midland Dolly News Government Accountability Proj.ect 124 Mcdonald Street 1901 Q Street, NW Midland, Michigan 48640 Washington, D.C. 20009
3 i CONCEPTUAL OPTIONS FOR INDEPEIOENT GUALITY VERIFICATION PROGRAM METHODOLOGIES I The independent Design and Construction Verification (IDV, ICV) components of I the Midland IDCV program focus on on engineering evoluotion of the quality of i end products of the design and construction processes. Due to the focus on end products, prccess reviews were not intended to be o part of the IDV and ICV programs. The NRC hos expressed a desire to modify the Midiond IDCV program to include o review of these processes. Several conceptual options have been identified for the potential addition of an Independent Ovality Verification (IOV) { program os on integral part of the Midland IDCV program to selectively evoluote i the implementation of the, design control, construction control and QA/QC processes. The melding of the lOV 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 opproach 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 indeterminate at this time. Added assurance may be gained in extrapolating the conclusions (i.e., to other safety systems provided that these cther systems were designed and constructed by similar processes) reached through a combined horizontal and vertical review; however, such benefit has not i os yet been quantified through industry experience. 4 Design and Construction control processes and the parallel QA/QC verification ore important in producing a quality constructed facility. For the evolvation of a facility in later stages of construction, a review of process issues is of lesser significance in reaching conclusions. A more direct approach 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 means. Process reviews Secome potentially more useful when evoluoting inoccessible items or items where quality is otherwise difficult to measure. 5 1 ERA CORPORATION
i As specific design or construction related deficiencies are identified within either the IDV or ICV programs, process related questions are potentially raised as part of the evoluotions associated with root cause determination. Decisions may be mode at any time to initiate focused reviews os circumstances worront. 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 program and wait until later stages of the program to make decisions relative to the need for expansion of scope to systemotleolly 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 a broader perspective. A third optional approach for on IQV program may be a focused review of process issues biased towards items that evolve from: IDV and ICV program Findings; o An evoluotion of project experience and noted process o related deficiencies; Process related issues known to have presented problems o within the nuclear indust.ry. The implementation of all design / construction control and GA/QC processes relative to criterio of 10 CFR 50, Appendix B will not be e.uluoted under this option for on lOV 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 areas that worront greater attention, recognizing that certain process issues are more significant and have o greater potential to compromise quality. An ottempt would be made to identify potential areas where identified root causes may also have manifested in problems (however, as ye* unidentified) in the some or similar form. This opproach is supported by the fact that industry experience dictates that undetected problem areas (which are of greatest concern) are likely to be the result of similar root causes os detected problems. 2 TERA CORPORATION
s The. identification of the portion of the IQV scope that is derived from the IDV and ICV program Findings would be ongoing and subject to change os the IDCV i i program progresses. This subset would be supplen.ented, os necessary, by additional oreos 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 I purpose. i j lt 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. o NSSS/ BOP Interfoce control (i.e., B&W and B echtel); o Inte.foce control between disciplines (e.g., civil /struc-tural and mechanical groups within Bechtel); t Vendor Interfoce control (e.g., between Terry Turbine and o Bechtel for the AFW turbine); j o Control of design changes; o Document control (i.e., of site and design office); j o Control of field changes; Translation and interpretation of design requirements into o procedures; Development of QA/QC inspection procedures and imple. o mentation. This listing would constitute the initici scope of the IQV 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. L As with option 2, on important element of the option 3 IQV program would be the review and evoluotion of the overoll 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
f... whether the CCP rem <tdial measures odequately attend to the issues for which the CCP was created. The review would verify that the CCP process which is now the primary construction proceu, os supplemented with odditional verifico-j tion activities, odequately addresses potential quality concerns. Outputs from i 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 evoluotion process. Selected orcos outside the CCP scope could also be selected sveh as Bobcock and Wilcox and Zock HVAC octivities; however, the specific organizations or programs to be evoluoted 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 a common quality r assurance audit. The quality assurance manuals, procedures and records would be reviewed against opplicable requirements of 10 CFR 50, Appendix B ond other i industry standards. The audit would include a re, view of objective evidence that } the QA program was odequately implemented and documented. Given the status 4 of the Midland project and various other considerations, this option may not be 4 technically viable and is most costly. i. 6 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 j more obvious schedular consideroflons. Option 2 would oppear to be the least I resource intensive effort. Options I and 3 may very well be equivalently cost-j effective. If the IDCV program identifies few process related Findings, then option I may be most effectives otherwise, option 3 may provide for o more t systematic and efficient review process. 4 I unAconsonAnON
I ~. L J V h iff August 15,19 (,) g", Mr. James W. Cook r.' N 7 Vice President .) Consumers Power Company 'g, 1945 West Pornoll Rood Jackson, Michigan 49201 d.' ~' i Mr. J. G. Keppler l Adminis'.otor, Region til q 1 Of flee of Inspection and Enforcement f f U.S. Nuclear Regulotory Commission e 799 Roosevelt Rood Glen Ellyn,IL 60137 ~f Mr. D. G. Eisenhut [ Director, Division of Licensing s i rs Offlee of Nuclear Reoctor Regulation ,' j ^t l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Docket Nos. 50 329 OM, OL and 50-033 OM, t. Midland Nuclear Plant - Units I and 2 Independerit Design and Construction Verificotlon (IDCV) Program Conceptuct Options for Independent Guolity Verificotton Program Methodologies In occordance with directlen provided during the August 5,1983 meeting to discuss options for modificotton of the Midland IDCV program with respect to initiatives ossociated with Section 13 of Public Low 97-415 (Ford Amendment), TERA has identified several conceptual methodologies considering input provided by Consumers Power Company and NRC representatives. The ottoched " white pooer" is intended for comment and is planned as a topic for_ tilscussion at on _ upcomino meetina which is tentatively set for Avount 2019A3. at Bechtel's Ann _ Ardor of fices. y*) TERA COGCA'ON 2.4*.' 710i W!SCONDN Ai ENJ BEMSDA M Ah ' *J. 20,5 '4
' 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 program responsive to the Ford Amendment legislation. i l ) Sincerely, Howard A. Levin Project Monoger i Midland IDCV Progrom cci L. Gibson, CPC F. Buckmor', CPC D. Miller, CPC (site) B. Palmer, CPC (site) i J. Taylor, NRC, l&E HQ D. Hood, NRC P. Keshishion, NRC, l&E HQ G. Gower, NRC, l&E HQ Midland IDCVP Service List l l Attochment HAL/djb t t... v k-
a s s SERVICE LIST FOR MIDLAND INDEPENDENT DESIGN AND CONSTRUCTION VERIFICATION PROGRAM Harold R. Derton, Director cc: Office of Nuclear Reactor Regulat. 1 as. Barbero Stamiris ion U.S. Nuclear Regulatory Commission 5795 N. River Washington, D.C. 20555 Freeland, Michigan 48623 James G. Keppler, Regional Administrator Mr. Wendell Marshall U.S. Nuclear Regulatory Commission, Route 10 Region ill IAldland, Michigan 48440 799 Roosedeft Road Glen Ellyn, Illinois 60137 Mr. Steve Godler 2120 Corter Avenue U.S. Nuclear Regulatory Commission Resident inspectors Office Route 7 Ms. Billie Pirner Garde Midland, Michigan 48640~ Director, Citizens Clinic for Accountable Government Mr. J. W. Cook Government Accountability Project Vice Pres, dent Institute for Policy Studies i Consumers Pow'er C,ompany 1901 Que Street, N.W. 1945 West Pornoll Road Washington, D.C. 20009 Jackson, Michigan 49201 Charles Bechhoefer, Esq. Michael I. Miller, Esq. Atomic Safety & Licensing Boord Isham, Lincoln & Beale U.S. Nuclear Regulatory Comm,ss, ion i Three First Nationai Plaza, Washington, D.C. 20555 Chico o, il cis 60602 'jf5 p,, James E. Brunner, Esq. 6125 N. Verde Trail Consumers Power.Co:npony O' # ' 212 West Michigori Avenue Jcckson, Michigan 49201 Atom.ic Sofety and L,cens,ing Board " Y Harbour,esq. i Ms. Mary Sinc!cir U.S. tjuelear Regulatcry Commission 5711 Summer,et Drive W stungt n, D.C. 20555 Midlcnd, Michigon 46640 Mr. Ron Collen Cherry & Flynn Michigan Public Service Commission Suite 3700 6545 Mercontile Way Three First Nationo! Plazo .O.Bu3g221 Chicago, Illinois 60602 nsing, M ch,igen 48909 Ms. Lynne Bernobe. Mr. Paul Rau Midlan'd Daily News-Government Accountability Proj.ect 1901 Q Street, NW 124 Mcdonald Street Washington, D.C. 20009 Midland, Michigan 48640 A.,, = s \\ s4 m . i
/ CONCEPTUAL OPTIONS FOR INDEPENDENT QUALITY VERIFICATION PROGRAM METHODOLOGIES The Independent Design and Construction Verification (IDV, ICV) components of the Midland IDCV program focus on on engineering evaluation 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 part of the IDV and ICV programs. The NRC has expressed a desire to modify the Midland IDCV program to include a review of these processes. Several conceptual options have been identified for the potential addition of an independent Quality Verification (IQV) program as an integral part of the Midland IDCV program to selectively evaluate 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 evaluate 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 an approach versus the existing approach is subject to a 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 indeterminate 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 horizontal and vertical review; however, such benefit has not as yet been quantified ~through industry experience. Design and Construction contrcl processes and the parallel GA/GC verification are important in producing a quality constructed fccility. For the evaluation vf a facility in later stcges of construction, a review of process issues is of lesser significance in reaching conclusions. A mort.: direct approach is en engineering evaluation of completed products (e.g., the existing Midland IDCV program " vertical slice") provided the quality is readily measurable by physical or other Process reviews become potentially more useful when evaluating means. inaccessible items or items where quality is otherwise difficult to measure. l TERA CORPORATION
,j . As ' specific design or construction related deficiencies are identified within either the IDV or ICV programs, process related questions are potentially raised as part of the evaluations associated 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 cecisions 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 until 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 as a mechanism to assimilate the outputs of various other ongoing programs that address process related issues to provide a broader perspective. A third optional approach for on IQV program may be a focused review of process issues biased towards items that evolve from: IDV and ICV program Findings; o An evaluation of project experience and noted process o related deficiencies; Proce.is related issues known to have presented problems o within the riuclear industry. W The implementotion 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 se!ection of specific issues within scope w. auld be based upoa the judgement of senior reviewers on the IDCV and lOV project The objective would be to devote resources on a priority basis in areas teams. that warrant greater attention, recognizing that certain process issues are more significant and have a 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 same or similar form. This approach is supported by the fact that industry experience dictates that undetected problem areas (which are of greatest concern) are likely to be the result of similar root causes as detected problems. h 2 TERA CORPORATION
The identification of the portion of th2 IQV scope that is dcrived from the IDV l and ICV program Findings would be ongoing and subject to change as the IDCV I program progresses. This subset would be supplemented, as necessary, by additional oreos determined through on evaluation 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 Bechtel); I o Interface control between disciplines (e.g., civil /struc-i o T tural and mechanical groups within Bechtel); 1 l Vendor interface control (e.g., between Terry Turbine and o Bechtel for the AFW turbine); Control of design changes; o Document control (i.e., at site and design office); o Control of field changes; o Translation and interpretation of design requirements into o procedures; J ) } Development of QA/QC inspection procedures and imple-o { mentation. I l This listing would constitute the initial scope of the IQV fcr option 3, As discussed, a potential exists that these areas of review may have to be supplemented subject to the project experience evaluation 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 Ccmpletion Program (CCP) and its effectiveness in identifying and correcting potential undetected problems associated with past activities and for completion of the remainder of work. The IQV objective would be to determine 3 TERA CORPORATION M
.g. whether tne CCP remedial measures adequately attend to the issues for. which the CCP was created. The review would verify that the CCP process which is now the primary construction process, as supplemented with additional verifica-tion activities, adequately addresses potential quality concerns. Outputs from the Construction implementation Overview (CIO) of the CCP would be assimu-lated into this assessment. Accordingly, TERA's review would not duplicate the CIO efforts, but complement it through integrating its outputs into the IDCV evaluation process. Selected areas outside the CCP scope could also be selected i such as Babcock and Wilcox and Zack HVAC activities; however, the specific organizations or programs to be evaluated should be determined based upon the involvement in the design or corstruction of the three systems within the IDCV program scope. e Option 4 may be consideration of a program that is similar to a 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 a review of objective evidence that [ the GA program was adequately 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 ccst-benefit trade-offs associated with the selection of any of these options, including the ~ more obvious schedular considerotions. Option 2 would copect to be the least resource intensive effort. Options I and 3 may very well be equivalen+1y cost-effective. If the IDCV progrom identifies few process related Findings, then option I may be most effective; otherwise, option 3 may provide for a more systematic and efficient review process. f I l 4 TERA CORPORATION
L J "Y n 3 -{ ..- y z j.c.. -y August 9,1983 M~7 j~ "i.6 ui 2 Mr. James W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 4 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 E Washington, D.C. 20555 Re: Docket No:. 50-329 OM, OL and 50-033 OM, OL M!dland Nuclear Plant - Units I ar'd 2 Independent Design and Construction Verification (IDCV) Program i Meeting Summary 1 ~ A' meeting was held on August 5, 1983 at TERA Corporation's Bethesda, Maryland offices to discuss options for modificction of the Midiond IDCV program with respect to initiatives associated with Section 13 of Public Law 97-415, NRC Authorization Act for Fiscai Year 1983 (Ford Amendment). A list of participants is provided in Enclosure 1. The meeting openal with a discussion of elements of the Ford Amendment (Enclosure 2) and specifically, NRC's plans and logistics for responding to the legislation. Darl Hood, NRC Midland Project Mnnager, presented on overview, pointing out that the NRC is studying six pilot programs in addition to the Midland IDCV program (Marble Hill, Millstone 3, Polo Verde, Limerick, South Texas, Beaver Valley) in an effort to report back to Congress in April 1984 on 4 the efficacy of certain approaches 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 1 for implementing the NRC's activities. Mr. Hood pointed out that he felt certain minor modifications of the Midland IDCV program were necessary to make the U g)G12 W TERA CORPORATION l 52515&rMRQ6%%Mvi@M5 INkF90&lWMrWidodiu@a WWa%A%ao - 1
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 "enhancernents" would be to include a " horizontal slice" component in the areas 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 part 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, I&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. Howard Levin, TERA Project Manager, indicated that the Midland IDCV program principolly 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 created. Generally, process related ir, sues are considered only cs the need orises as dictated by Findings wbose root causes may potenticily be related to deficiencies in tne implementation of various processes. When questioned on the degree to which process issues would be reviewed, he indicated that at this point in the progrom certain issues were under review; however, the full set of issues would be indeterminate in view of the fcet that the octure of any future Findir.gs is unimown. The NRC representatives asked questions relative to the cbility 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 agreement of all participants that the QA pion 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 o conclusion relative to the implementation of QA/QC programs and conformance to 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 i l TEPA CORPORATION l
i Mr. J. W. Cook 3 August 9,1983 Mr. J. G. Keppler Mr. D. G. Eisenhut l quality constructed facility. Levin pointed out that for the evaluation 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 opproach is the " vertical slice", provided quality is readily measurable by physical or other means. He further observed that " quality facilities have been attained with weaker QA/QC programs and vice versa." 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 QA/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 warranted. 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-cround time was approximately one week. Sincer ly, / . - ht,% C."j i~~% Howord A. Levin Project Manager Midland IDCV Program cc: Participants F. Buckman, CP D. Miller, CPC (site)
- 8. Palmer, CPC (site)
Midland IDCVP Service List J. Taylor, NRC, I&E HG TEM COi4PCRATiCN
i SERVICE LIST FOR MIDLAIO INDEPEbOENT DESIGN AbD CONSTRUCTION VERIFICATION PROGRAM cc: Harold R. Denton, Director Ms. Borboro Stamiris Office of Nuclear Reactor Regulation 5795 N. River U.S. Nuclear Regulatory Commissim 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 lli 799 Roosevelt Road Mr. Steve Godler Glen Ellyn, Ill,nois 60137 2120 Corter Avenue i U.S. Nuclear Regulatory Commission Resident inspectors Office Ms. Billie Pirner Garde Director, CWzens cmc Mbl , Michi on 48640 for Accountable Government 9 Government Accountability Project M'* *
- Cook Institute for Policy Studies Vice Pres. dent 1901 Que Street, N.W.
i Consumers Power Company Washington, D.C. 20009 1945 West Parnall Road Jackson, Michigan 49201 Charles Bechhoefer, Esq. Atomic Safety & Licensing Board I'Beo!e U.S. Nuclear Regulatory Commission om of Washington, D.C. 20555 Three First National Plaza, [p*,,F e ick P. Cowan Chic o, I nois 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 tJ S. Nuclear Regulatory Commission f7il S eIs'et Drin Washington, D.C. 20555 Midland, Michigan 48640 Mr. Ron Collen Michigan Public Service Commission Cherry & Flym 6545 Mercontile Way Suite 3700 P.O. Box 30221 Three First National Plaza Lansing, Michigan 48909 Chicago, Illinois 60602 Mr. Paul Rau. Ms. Lynne Bernobei en ecountability_ Project f24M Id reet Midland, Michigan 48640 Washington, D.C. 20009
f 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 Law 97-415 (Ford Amendment) Nuclear Regulatory Commission D. Hood, NRR P. Keshishion, I&E G. Gower, I&E { Consumers Power Company { L. Gibson i TERA 1 i H. Levin j D. Tulodieski i R. Snaider H. George (partial) J. Mortore J. Richardson l Government Accountability Project B. Garde ( 'I i TERA CORPORATION
(4) imprcveme!.t cf the Cossetssitn's organf ration, methods. [
- 13(b) The Cossaission shall conduct a study of cxisti,ng and alterna-and programs for quality assiranca dev21opment, rtview,and tive programs for improelag quality assurance and quality control Inspections and In conduct.
in the construction of coupercial nuclear powerplants. (5) conditioning the issuance of construction permits for com-ing the study, the Connission stiall obtain the comunents of the. mercial nuclear powerplants on the permittee entering into puhitc. Ilcensees of nuclear powerplants. the Advisory Casunf ttee on contracts or other arrangements with an independent inspector M lleactor Safeguards, and organizations comprised of professionals to audit the quality assurance program to verify quality assur-8, The study shall include an k having empertise in appropriate fleids. ante performance. analysis of the following: For purposes of paragraph (5), the term ' independent inspector' (1)providingabasisforqualityassuranceandqualitycontrol. means a person or other entity having no responsibility for the k g ' inspection, and enforcement actiods through the adcption'of an design or construction of the plant involved The study shall also E approach which is more Trescriptive than that cu'rrently in include an analysis of quality assurance and quality control pro. a practice fo"r defining principal architectural and engineering grams at representative sites at which such programs are operating Z criterta for the construction of cosmercial nuclear powerplants; satisfactorily and an assessment of the reasons therefor. O P I (2) conditioning the issuance of construction permits for com. mercial nuclear powerplants on a demonstration by the licensee 13(c) For purposes of - that the Itcensee is capable of independently managing the (1) determining the best means of assuring that corriercial E E effective performance of all quality assurance and quality con. nuclear powerplants are constructed in accordance with the g trol responsiblitties for the powerplant; applicable safety requirements in effect pursuant to the Atomic k (3) evaluations, inspections, or audits of co:rercial nuclear ,w i Energy Act of 1954; and powerplar.t construction by organtrations comprised of profes. (2) assessing the feasibility and benefits of the various means sfonals having espertise in appropriate fleids which evaluations. listed in subsection (b); Inspections, or audits are more effective than those under cur. rent practice; . ct f- $l O 4 w
w s i the tossnission shall undertake a pilot program 13 review and cvalzats from the pubile and from ither persons ref2rred t3 la subsection (b) 3 l-programs that include one or more Ef the alt:rnative concepts identl* and a statement of the Cossetssion's response to the significant l fled in subsection (b) for the purposes of assessig the feasiblitty comuments received, the report shall also set forth an analysis of the and benefits of the e laplementation. The pilot program shall include results of the pilot program required under subsection (c). The s p programs that use independent inspectors for suditing quality assu'ence report shall be accompanied by the recossendations of the Cossatssion, responsibilities of the Iftensee for the construction of conunen:tal gneluding any legislative recommendations, aod a description of any nuclear powerplants, as described in paragraph (5) of subsection (b). administrative actions that the Cosmisstor. has undertaken or intends [ e The pilot program shall include at least three sites at which cc** to undertake, for improving quality assurance and quality control E. mercial nuclear powerplants are under construction. The Conentssion programs that are appitcable during the const'ruction of nuclear shall select at least one site at which quality assurance and quality powerplants." I 1 control programs have operated satisfactorily, and at least two sites
== s=== cosa rees.au: 4 with remedial programs underway at which major construction, quality o assurance, or quality control defletencies (or any con 6tnation thereof) f have bcen identified in the past. The Conentsstor. may require any changes in existing eve 11ty assurance and quality control organizations and relationships that may be necessary at the selected sites to f a implement the pilot program, p Y 3' = 13(d) Not later than fifteen months after the date of the enactment R of this Act, the Cossetssion shall complete the study required under .[ subsection (b)andsubmittotheUnitedStatesSenateandHouseof Representatives a report setting forth the results of the study. The
- 2l o
report shall include a brief susunary of the information received n 1 6
. 'c ,a nreg*'o, e -/ UNITED STATES /' ! '- NUCLEAR REGULATORY COMMISSION n {.;[ 1,,. WASHINGTON, D. C. 20555 FRlNCIPAL STAFF =[#,;8 t %' RA ENF August 8,1983 D/RA SCs A /R.A OAO Docket Nos. 50-329 LFRP SLO 50-330 DR2 RC DRMSP 1 DE 1 ML /' Mr. J. W. Cook OL j F I LEM Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 {
Dear Mr. Cook:
Subject:
Clarification of July 22,-1983 Acceptance of TERA Corporation Some questions have been raised recently regarding our July 22, 1983, acceptance letter to you. This is to clarify our position. The staff finds TERA Corporation to be both independently and technically qualified to conduct the revised and expanded IDCV program for Midland. The staff further finds the program scope in the May 18, 1983 Engineering Program Plan and Project Quality Assurance Plan to be acceptable. Sincerely, W-pomasM.Novak,AssistantDirector for Licensing Division of Licensing
Enclosure:
As stated cc: See next page l 4# AUG 15 gg3 \\
MID' LAND ' Mr. J. W. Cook ~ Vice President i s Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 cc: Michael I. Miller, Esq. Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq. Division of Radiological Health Alan S. Farnell, Esq. Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza, Lansing, Michigan 48909 51st floor
- Chicago, Illinois 60602 Mr.~ Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Company 720 Lau Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall - Mr. Walt Apley Route 10 c/o Mr. Max C1ausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNWL) Battelle Blvd. ~~ Mr. R. B. Borsum SIGMA IV Building Nuclear Power Generat.on Divisien Richland, Washington 99352 Babcock & Wilcox 7910 Woodmont Avenue, Suite 220 Mr. I. Charak, Manager Bethesda, Maryland 20814 ' NRC Assistance Project Argonne National Laboratory Cherry & Flynn 9700 South Cass Avenue Suite 3700 Argonne, Illinois 60439 Three First National Plaza Chicago, Illinois 60602 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 i
l Mr. 'J. W.' Cook - cc: Mr. Ron Callen Michigan Public Service Commission 6545 Mercantile Way P.O. Bcx 30221 Lansing, Michigan 48909 Mr. Paul Rau Midland Daily News-124 Mcdonald Street M.idland, Michigan 48640 Billie Pirner Garde ~ Director, Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W. Washington, D. C. 20009 Mr. Howard. Levin, Project Manager TERA Corporation 7101 Wisconsin Avenue Bethesda, Maryland 20814 Ms. Lynne Bernabei Government Accountability Project 1901 Q Street, N.W.- Washington, D. C. 20009 \\ t 9 L.-
o.,. ' ' Supplemental page to the Midland OM, OL Service List Mr. J. W. Cook 's cc: Commander, Naval Surface Weapons Center ATTN: P. C. Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design. Engineering Energy Technology Engineering Center P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq. A~ omic Safety & Licensing Board c U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Frederick,P. Cowan Apt. B-125 ~ 6125 N. Verde Trail - Boca Raton, Florida 33433 Jerry Harbour, Esq. Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Geotechnical Engineers, Inc. ATTN: Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890 i -}}