ML20093N028
| ML20093N028 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/07/1983 |
| From: | Fischer D Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX14-008, CON-BX14-8, FOIA-84-96 NUDOCS 8408010152 | |
| Download: ML20093N028 (7) | |
Text
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MLAW s
r February 7,1983 MEMORAN0'Jit FOR: ACRS Nahers FR0tt:
D. C. Fischer, Staff Engineer
SUBJECT:
MIDLAMD QA/QC During the future ACRS activities portion of the 274th ACRS meeting:
- 1. _ Dr. Okrent will be soliciting your opinion on three items (see attached status report).
2.
Ms. Billie Garde (GAP) will be making a 2-5 minute presentation sumaarizing the points she makes in her January 13, 1983 letter to Dr. Okrent and updating the Comittee on recent QA/QC acti-vities at Midland.
B408010152 840718
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WASHINGTON,D. C. 20506 February 7,1983 MEMORANDUM FOR: ACRS Members FROM:
D. C. Fischer Staff Engineer
SUBJECT:
MIDLAND QA/QC During the future ACRS activities portion of the 274th ACRS meeting:
1.
Dr. Okrent will be soliciting your opinion on three items (see attached status report).
2.
Ms. Billie Garde (GAP) will be making a 2-5 minute presentation summarizing the points she makes in her January 13, 1983 letter to Dr. Okrent and updating the Committee on recent QA/QC acti-vities at Midland.
Attachments:
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MIDLAND PLANT UNITS 1 & 2 QUALITY ASSURANCE / QUALITY CONTROL PROJECT STATUS REPORT 274TH ACRS MEETING, FEBRUARY 10, 1983 Purpose During the " future ACRS activities" portions of the 274th ACRS 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.
1.
Provide the NRC Staff with confirmation of the Comittee's request as stated in the June 8,1982 ACRS Interim Report on Midland.
In that letter report, the Committee deferred its recommendation regarding operation of Midland at full power until-it "had the opportunity to review the plan for an audit of plant quality and..." The Staff should complete its re-view and approval of the CPCo plan for an independent design
- verification and audit at Midland by March. The NRC Staff wants to confirm that-it is this plan that the Committee wants
.to review and not the results of the audits.-
2.
Assess the adequacy of the NRC Region III report on design and construction problems at Midland for the period from start of construction 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-blems, their disposition, and the overall effectiveness of the effort to assure appropriate quality." If the Committee believes it needs further information, the needed information should be clearly identified.
3.
Determine i.f the Committee should " aggressively pursue a leadership role in holding Constners Power Company accountable -
for public safety" as requested by Ms. Billie Garde of the Government Accountability Project (GAP). Ms Garde has urged the Committee "to consider seriously the current events at Midland, and to take.ecisive action through the ACRS meeting
_ process to pull together the fragmented Midland story."
History The ACRS~ reviewed Midland for a CP license in June' 1970.
In response
.to requests for additional information from the AS8LB the ACRS wrote an additional Supplemental Report on Midland Plant Units 18 2 dated November 18 ~, 1976.
On April 29, 1982 an ACRS Ad Hoc Subcommittee met to discuss the remedial actions for soils-related structural settlement problems at the Midland site. The Ad Ho:. Subcommittee's recommendations were accepted by the full ACRS during the May Full Committee meeting and promulgated to the Staff by a May 14,1982 memorandum from R. Fraley to P
the EDO (Attachment 1). While the April 29, 1982 Ad Hoc Subcommittee vs'a-w
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2-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 tha 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-cation of CPCo for a license to operate the Midland Plants Units 1 & 2.
-The resulting ACRS Interim Report is included as Attachment II. QA hearings for. Midland are now expected to start on April 12, 1983.
Region III Report on Midland Design and Construction Problems In my December 9,1982 memorandum to all ACRS Members (Attachment III) I described and cmsmeated on Region III's report on Midland's construction QA deficiencies through June 30, 1982.
I would like to add a few comments to thost that I have already made. Not only has the licensee continued to experience problems in the implementation of. quality in construction but many of the noncompliances identified are of a recurring nature.
I also have convinced myself that many QA/QC deficiencies at Midland identified before June 30,1982 nave not been included in the Region III report. A thorough review of mail received by the ACRS on the Midland docket between April 1981 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 canerators to the AFW turbine and prevent proper operation of the AFW system (MCAR-58),
2.
Non-Q HVAC systems were found to be providing required cooling 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 III 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 III report, I suggest that it not be relied upon too heavily to get an impression of the quality of construction at Midland.
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k STATUS REPORT / MIDLAND 182.
Third Party Assessments' CPCo plans 'an Independent' Review Progran to ensure the quality of the Midland construction project. The details of the Independent Review Program have not yet been worked out between the NRC Staff (Region III)
L and CPCo. Documents describing the program proposed by CPCo are avail-
'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 building underpinning is underway. Additional assessment programs have been undertaken at Midland. These are in addition to the assessments 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
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3.
Bechtel Corporate Staff project eval ~u'ation (1982), results
- not yet availabe.
Assessments planned:
1.
Independent Review Program INPO type construction evaluation (horizontal type a.
review) - MAC Biennial QA Audit - MAC b.
Independent Design Verification Program (IDVP) (vertical c.
slice) - Tara Corporation. Tera will. review the Aux Feed-Water System'plus one of the following systems.
1.
Electrical Power System (Diesel Generator)
I 2.
Safeguards Chilled Water System -
3.
Containment Isolation System Region III concurrence on the Midland Plant Independent Review Program is I understand that the Staff's (ACRS requested) independent design imminant.
verification will include only the work to b, done by the Tera Corporation.
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a STATUS REPORT /MIOLAND 1 8 2.
Systems Coipletion Plan -
On December 3,1982 Consumers Power Company initiated a systems completion plan at the Midland Nuclear Cogeneration Plant. This Plan is intended to provide more efficient control over the completion of work at the nuclear plant. The Midland Plant, now 85 percent complete, initiated this comple-tun 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 th0 plan is to improve CPCo's performance in meeting the regulations s
and expectations of the U.S. NLclear Regulatory Comission. 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 Midland site. The workforce had been gradually reduced in recent months because of job completion in containment areas but the plan caused a larger layoff. Additional specialized staff will be required to carry out the program so some of the construction force may be recalled. Work is con-tiauing on the nuclear steam supply system, the turbine building, and miscel-i laneous systems. The first phase of the system completion program will be to remove all construction material and temporary equipment from the buildings included in the program. Each facility will then be cleaned, and the system 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 team will oversee the completion of any needed remaining work. The com-plated systems will then be turned over to Consumers 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 called for in the plant's initial design.~ Because of the delay in completing the foundation work, CPCo said that the project completion dates and schedules
'"will slip by some months."
Letters from Member of the Public Dr. (krent has received letters from Ms. Mary Sinclair (dated December 14, 1982) and Ms. Billie Garde (dated January 13, 1983) urging that the ACRS get actively involved in the QA/QC issues at Midland. Copies of each of these letters were sent to each of the ACRS members.
I have reviewed each of these
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STATUS REPORT / MIDLAND'l&2.
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 Committee had not previously received.. Since receiving Ms. Garde's letter I have acquired a complete set of the NRC's revised testimony to the AS&LB re Midland QA/QC (Includes This testimony is available 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 identified by the NRC Region III Staff and has Whether CPCo can assure appro-spurred public concern and media interest.
The Com-i priate quality of the Midland plants has yet to be descastrated.
mittee should convince itself that the Midlar.d plants have been or udll be Midland's QA/QC history is certainly a constructed and operated safely.
relevant fact that the Committee should make use of in making its judgement.
Rather, the Committee However, the Committee should not focus on the past.Have design ~ and const should ask itself:What is the safety significance of identified deficiencies?
and corrected?
Has the sample been sufficiently representative to assure overall plant I
Is there reasonable assurance that problems will not recur?
safety?
The Committee might consider don't have the answers to these questions.
asking the applicant or the Region III Staff to paint for us the " big picture" as far as QA/QC at Midland. I believe the' Committee should know It what deficiencies have been identified by the NRC, CPCo. and others.
should know how these deficiencies have been corrected in both the generic This will require alot of analysis, not just a and the specific senses.
Finally, the list of deficiencies or a chronology of noncompliances.
Committee should receive an integrated description of efforts being taken I think that to assure appropriate (safe) plant quality and operation.
the Committee has already asked for such an analysis. Perhaps the Committee-needs to reiterate or clarify its request.
Attachments:
As stated
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