ML20093M994
| ML20093M994 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/03/1983 |
| From: | Fischer D Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX14-002, CON-BX14-2, FOIA-84-96 NUDOCS 8408010135 | |
| Download: ML20093M994 (6) | |
Text
c A->c UNITEJ STATES f
NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS r
g WASHINGTON. D. C. 30005 March 3,1983 i
l MEMORANDUM FOR:
ACRS Members C b5 FROM:
D. C. Fischer, Staff Engineer
SUBJECT:
MIDLAND'S INDEPENDENT DESIGN VERIFICATION
REFERENCE:
(1)
J.W. Cook Letter to H.R. Denton and J.G. Keppler, Serial 18879 Dated 10/5/82 (2)
J.W. Cook Letter to H.R. Denton and J.G. Keppler, Serial 19750 Dated 12/3/82 (3) USNRC Letters to CPC0 Dated 2/22/83 cnd 2/23/83 Re Tera Corporation's Project Quality Assurance Plan and Engineering Program Plan for the Midland Independent Design and Construction Verification Program References (1)and(2)describeConsumersPowerCompany'sIndependentRevitv This Program includes Midland's Independent Design and Construct'on Program.
Verification Program to be performed by the Tera Corporation (see page 3 of A detailed description of the Tera Corporation Engineering AttachmentI).
Program Plan and Project Quality Assurance Plan is contained in Reference (3).
Copies of reference (3) have been sent to the Midland Plant Subcomittee members and consultants.
If any other members are interested in receiving these documents, please let me know (202) 634-1413.
Attachment:
Midland Plant Units 1 & 2 QA/QC Project Status Report from the February Full Committee meeting cc:
R. F. Fraley M. W. Libarkin J. C. McKinley G. R. Quittschreiber g 8 g 35 840718 RICE 84-96 PDR o
l MIDLAND PLANT UNITS 1 8 2 QUALITY ASSURANCE / QUALITY CONTROL PROJECT STATUS REPORT 274TH ACRS MEETING, FEBRUARY 10, 1983 i
Puroose During the " future ACRS activities" portions cf the 274th ACR$ meeting, the Committee will discuss and perhaps plan some of its future activities related to Midland QA/QC. Dr. Okrent will solicit the Committee's views on the following items.
t 1.
Provide the NRC Staff with confirmation of the Committee's
" g ma p.p.aa) request as stated in the June 8,1982 ACRS Interim Report on
>"g%g Midland. In that letter report, the Committee deferred its
- WW *O recomendation regarding operation of Midland at full power until it "had the opportunity to review the plan for an audit
- 46C. J ea.
of plant quality and..." The Staff should complete its re-m%14Ag i
view and approval of the CpCo plan for an independent design N M I**
verification and audit at Midland by March. The NRC Staff
- **h" FW W wants to confirm that it is this olen that the Committee wants to review and not the results of the audits.
(sad) in Apr,l, j
Assess the adequacy of the NRC Region III report on design 2.
and construction probisms at Midland for the period from start of constructinn through June 30, 1982. This report was written as partial response to the Committee's request to
" receive a report which discusses design and construction pro-bloms, their disposition, and the overall effectiveness of the effort to assure appropriate quality." If the Committee believes it needs further information, the needed information I
t should be clearly identified.
Determine if the Committee should " aggressively pursue a r
3.
leadership role in holding Consumers Power Company accountable for public safety" as requested by(Ms. 81111e Garde of the l
Government Accountability Project GAP). Ms Garde has urged f
the Committee "to consider seriously the current events at Midland, and to take decisive action through the ACR$ meeting process to pull together the fragmented Midland story."
History In response The ACR$ reviewed Midland for a CP license in June'197D.
l to requests for additional information from the A5&LS the ACRS wrote an additional Supplemental Report on Midland Plant Units 18 2 dated j
i November 18, 1976. On April 29, 1982 an ACR$ Ad Hoc Subcommittee met l
to discuss the remedial actions for soils-related structural settlement J
l problems at the Midland site. The Ad Hoc Subcomittee's recommendations i
were accepted by the full ACRS during the May Full Committee meeting and l
promulgated to the Staff by a May 14, 1982 memorandum from R. Fraley to While the April 29, 1982 Ad Hoc Subcomittee theE00(Attachment 1).
i
, U.~
~
e g
STATUS REPORT / MIDLAND 182.
~
meeting focused on the remedy rather than the cause of the soils problems, background documents on the cause of the soils problems were made available to the ACRS prior to the June 1982 Full Committee meeting. Midland Plant Subcommittee meetings were held on May 20-21, 1982 and June 2,1982. These meetings did address the quality of design and construction at Midland.
During the June Full Committee meeting the Committee reviewed the appli-i cation of CPCo for a license to operate the Midland Plants Units 1 12.
The resulting ACRS Interim Report is included as Attachment II. QA hearings for Midland are now expected to start on April 12, 1983.
1 Region III Report on Midland Design and Construction problems
)
In my December 9,1982 memorande to all ACRS Members (Attachment III) I described and commented on Region III's report on Midland's construction i
QA deficiencies through June 30, 1982.
I would like to add a few comments to those that I have already made. Not only has the licensee continued to experience problems in the implementation of quality in construction but I also have many of the noncompliances identified are of a recurring nature.
convinced myself that many QA/QC deficiencies at Midland identified before have not been included in the Region III report. A thorouqh
)
June 30,1982 review of mail received by the ACRS on the Midland docket between April ' 981 and June 1982 bears this out.
Examples include:
1.
The AFW pump turbine steam admission valve interlock system was found to block steam from both steam generators to the i
AFW turbine and prevent proper operation of the AFW system (MCAR-58),
i Non-Q HVAC systems were found to be providing required cooling 2.
l to safety related equipment in the auxiliary building (MCAR-59),
- and, 3.
An error was found in the ECCAS wiring when comparing the drawing to the hardware's condition (50.55e report).
While the nonconformances identified in the Region !!! report are numerous, a significant number of them represent ' paper' problems and not physical plant construction nonconformances. As a result of these and previously identified shortcomings of the Region !!! report, I suggest that it not be relied upon too heavily to get an impression of the quality of construction at Midland.
i p
~
3-STATUS REPORT / MIDLAND 182 Third Party Assessments CPCo plans an Independent Review Program to ensure the quality of the The details of the Independent Review 1
Midland construction project.
Program have not yet been worked out between the NRC Staff (Region III)
Documents describ!ng the program proposed by CPCo are avail-and CPCo.
able upon request. Correspondences are also available describing the separate QA program for soils remedial work. An independent third party appraisal of the initial phases of the construction of the auxiliary Additional assessment programs have building underpinning is underway.These are in addition to the assessments been undertaken at Mid19nd.
planned to satisfy the NRC's required (criteria not yet defined) inde-pendent third party assessment.
Assessments completed to date:
- 1.
Consumers Power Company Biennial Quality Audits 1976 - Nuclear Audit and Testing Company (NATCO) a.
b.
1978 - Management Analysis Company (MAC) c.
1980 - MAC 2.
Special Assessment of Midland QA (1981).MAC Bechtel Corporate Staff project evaluation (1982), results 3.
not yet availabe.
Assessments planned:
1.
Independent Review Program INPD type construction evaluation (horizontal type I
a.
- MAC review)l QA Audit - MAC Biennia b.
Independent Design Verification Program (IDVP) (vertical slice) - Tera Corporation. Tera witl review the Aux. Feed-c.
i Water System plus one of the following systems.
1.
Electrical Power System (Diesel Generator) 2.
Safeguards Chilled Water System
-M i-
- O.
Centet ;;at ;;ht h : C,ehm Region !!! concurrence on the Midland Plant Independent R l
verification will include only the work to be done by the Tera Corporation.
imminent.
i l
amw
-m--a m, v o, m -- - e n~
w-e r n,vr.
g,.
STATUS REPORT / MIDLAND 1 & 2 _
Systems Completion plan on December 3,1982 Consumers Power Company initiated a systems completion plan at the Midland Nuclear Cogeneration Plant. 1his Plan is intended to provide more efficient control over the completion of work at the nuclear The Midland Plant, now 85 percent complete, initiated this comple-plant.
tion plan to. develop a more detailed assessment of the work remaining to be done on the systems in the auxiliary building, diesel generator building, and containment buildings. The program will be carried out by design and test engineers, quality assurance personnel, and construction forces who will work as coordinated teams to implement the program. Another objective of the plan is to improve CPCo's performance in meeting the regulations and expectations of the U.S. Nuclear Regulatory Commission. Implementation of the plan resulted in the reduction of the manual construction workforce by over 1,000 workers leaving approximately 4,000 people at work on the The workforce had been gradually reduced in recent months Midland site.
because of job completion in containment areas but the plan caused a larger Additional specialized staff will be required to carry out the layoff.
Work is con-program so some of the construction force uay be recalled.
tinuing on the nuclear steam supply system, the turbine building, and miscel-The first phase of the system completion program will be laneous systems.
to remove all construction material and temporary equipment from the buildings Each facility will then be cleaned, and the system included in the program.
completion teams will carry out their reinspections on an area by area basis.
As each area is reinspected and the results analyzed, the systems completion The com-team will oversee the completion of any needed remaining work.
plated systems will then be turned over to Consmers Power for checkout and startup testing.
The system completion program work will be done in parallel with underground foundation work. CPCo has started part of the foundation work. The foundation work will resolve the plant's soils compaction problem and add seismic protection to the plant to meet more stringent earthquake protection requirements than were Because of the delay in completing called for in the plant's initial design.
the foundation work, CPCo said that the project completion dates and schedules "will slip by some months."
Letters from Member of the Public Dr. Girent has received letters from Ms. Mary Sinclair (dated December 14, Ms. gillie Garde (dated January 13, 1983) urging that the ACR$ get 1982)and Copies of each of these actively involved in the QA/QC issues at Midland.I have reviewed sach of these letters were sent to each of the ACR$ members.
e
l l
,. STATUS REPORT / MIDLAND 182
~
h r
letters carefully and have found no issues, related to Midland QA/QC, that the Committee was not already aware of. Ms. Garde did provide several in-formative attachments with her letter that the Comittee had not previously l
Since receiving Ms. Garde's letter I have acquired a complete set of the NRC's revised testimony to the ASALS re Midland QA/QC (IncludesTj received.
testimony by Keppler, Gilray, Hood, and Cook).
upon request.
General Comments There have been and continue to be significant QA/QC problems at Midland.
This situation has been identiffed by the NRC Region 111 Staff and has Whether CpCo can assure appro-spurred public concern and media interest.
The Com-priate quality of the M!dland plants has yet to be demonstrated.
mittee should convince itself that the Midland plants have been or will be Midland's 04/QC history is certainly a constructed and operated safely. relevant fact that the Committee shou; Rather, the Committee Nowever, the Committee should not focus on the past.Have design and con I
should ask itselfWhat is the safety significance of identified deficiencies?
l Has the sample been sufficiently representative to assure overall plant and corrected?
i I
Is there reasonable assurance that problems will not recur?
don't have the answers to these questions. The Committee might consider safety?
asking the applicant or the Region !!! Staff to paint for ut the "bigI believ l
picture" as far as 0A/QC at Midland.
It what deficiencies have been identified by the E O, CpCo and others.
should know how these deficiencies have been corrected in both the gener Tnis will require slot of analysis, not just a Finally, the and the specific senses.
list of deficiencies or a enronology of noncompliances. Comm j
l I think that to assure appropriate (safe) plant quality and operation.Perhaps the Comittee l
the Committee has already asked for suh an analysis.
j needs to reiterate or clarify its request.
Attachmentst l
As stated I
l l
I r
L i
l
-