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GLE N E LLYN. lL LINOIS 60137 f
SEP 2 4 882
. MEMORANDUM FOR: James G. Keppler, Regional Administrator FROM:
R. F. Warnick, Acting Director, Office of Special Cases
SUBJECT:
REVIEW OF CONSUMERS POWER COMPANY COMMITMENTS As directed by you on September 7, 1982, the Midland Section has reviewed the licensee's draft commitments to improve the implementation of their Quality Program in the remedial soils area and in the remaining construction activities at the Midland site. These commitments resulted from discussions you and D. G. Eisenhut had with J. D. Selby and J. W. Cook of CPCo on September 2, 1982.
The licensee's draft commitments are meant to confirm and/or improve the quality of the work performed at Midland and address some of the suggestions made by the Midland Section as described in my memo to you of August 18, 1982. However, the licensee's draft commitments fall short of what we believe is needed to turn this Project around.
We believe the changes described below must be made. Items 1 thru 4 should be 'impicmented prior to allowing CPCo to resume the remedial soils work.
-Items 5, 6, and 7 pertain to the licensee's commitments for all other plant work.
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1.
The licensee's draft commitment letter describes how CPCo is under-taking a review of past correspondence to create a computer listing of all commitments not already reflected in the construction documents.
We feel that Consumers Power Company must provide a master list of
.all commitments made regarding remedial soils work prior to starting work. To reduce any unnecessary delays that would impact on the project, we would accept a partial list that would identify all commitments made on specific work activities planned for the first 60 days of work with a follow-up master list for all remaining remedial work to be issued within 60 days from the start of the work.
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F james G. K;pplcr
- SEP 2 4 032 2.-
The draft letter states that CPCo will integrate the soils QA and QC functions under the direction of MPQAD.
We believe that Consumers Power Company should remove all responsibility for Quality Control activities from Bechtel. This should include administrative functions such as hiring, firing, promotions, salary, etc.
CPCo must also qualify and certify all QC personnel to CPCo standards.
3.
CPCo's draft letter commits to "substantially upgraded training programs".
We believe that the training program should be implemented for all personnel involved in remedial soil activities. The thrust of the program should be directed towards building " quality" into the work and ensuring that everyone is knowledgcable of their responsibilities and authority. This training program should be accomplished before the start of soils work.
4.
The draft letter indicates that a third party will be retained to independently appraise the initi,al phases of the construction of the auxiliary building underpinning.
We believe the special team that will evaluate Consumers Power Company performance should be in place prior to start of work on pier 12.
The Midland Section strongly recommends that you do not issue blanket authorization for Consumers Power Company to proceed with the soils project. Rather, we recommend that work projects be authorized piece-meal by the Section*as provided in our work authorization agreement with CPCo in order for our staff to evaluate the licensee's quality effort. When the work effort shows that the licensee is adequately implementing their program, additional work projects would be authorized.
5.
We do not feel that an INPO type " horizontal" assessment will provide sufficient confidence that the current work in progress is being properly implemdnted, particularly if the INPO report suffers from the same lack of detail that exists in the operations type INPO reports. It is also our understanding that 1NPO has minimal assessment experience at construction sites. Even if INPO or a contractor has the necessary expertise, a two-week overview of Consumers Power Company capability will only give us a snap-shot perspective. The licensee's draft commitment J
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'J men G. K:ppler '
SEP 2 4 G32
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Ictter does not address an ongoing assessment team beyond the INPO effort. 'We need a detailed and indepth inspection. effort that extends over a much longer period of time. We don't believe the INPO assessment will accomplish what we intended to accomplish by our
-original recommendation.
We originally requested the use of five contract-type personnel, rcportir.g directly to the NRC for a period of six to twelve months, in order for the Midland Section to assess the licensee's current work effort. In addition to following the remedial soils and other ongoing work, we must complete enough construction inspections to determine ~ whether or not the plant is built as designed and to determine whether or not any of the types of problems identified at Zimmer exist at Midland. We must resolve the allegations regarding Zack HVAC work and the allegations in the affidavits supplied by CAP. We must also get CPCo to take the actions that will produce the results which in turn will allow the NRC staff to have confidence in CPCo management and Midland. We need additional manpower on site to do the job.
6..
We do not feel that the proposed CPCo QA/QC organization will be effective as long as Bechtel supervisory personnel are still in place and the administrative functions are still being controlled by Bechtel.
We believe it is necessary for Consumers Power Company to take total control of QC. This comment is an extension of comment 2.
7.
There is insuf ficient information contained in the draf t letter to be able to tell much about the " vertical slice" review. We believe it should incorporate a skewed vertical slice through the plant to ensure that interrelationships between various safety systems have been adequately addressed.
We intend to work with CPCo and feel we will be able to accomplish most of our comments and recommendations.
In fact, we met with CPCo on September 22, 1982, and resolved item 1 (they will give us a list of commitments and we agreed to 90 rather than 60 days because of the magnitude of the task). We ' expect to be able to accomplish items 3, 4 and 7.
We are meeting with CPCo and Bechtel on September 29 and will discuss items 2 and 6.
Regarding item 5, 1 believe there are several possible solutions. The contract personnel from Argonne National Laboratory will be assigned to Midland approximately 50% of their time and that should help. Another alternative to our recommendation is to d
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have the licensee provide personnel of our choice who would act in the capacity of NRC representf tives and would report directly to the Senior Resident, Inspector onsite. This alternative is described in SECY 82-352, dated, August 20, 1982..,,
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%ShouldyouhaN-any, quest'ionsregardingthismemorandum,Ishallbehappy to ; discuss then 'with 'ys." '
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' R. F. Warnick, Acting Director i-Office of Special Cases
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