ML20078K195

Response to Interrogatory IV Re Contention 8 on Independent Design Audit

ML20078K195
Person / Time
Site:	Midland
Issue date:	05/12/1982
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	STAMIRIS, B.
Shared Package
ML20077K116	List: ML20078K195 ML20078K270 ML20078K278 ML20078K284 ML20078K294 ML20078K306
References
FOIA-83-449 NUDOCS 8310180629
Download: ML20078K195 (8)

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Barbara Stamiris ISTERROGATORY IV 0l

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RE INDEPENDENT DESIGN AUDIT: COVTESTION K f Ouestions

1. How much tice, coney, and effort is involved in the Bechtel Audit of Bechtel construction and design announced at the 3/2,0/S2 ACRS ceeting? What is the purpose and justification for this self-audit? Who will pay for it?

2. What plans have been made toward an independent design and construction audit at Midland?

3. What contacts have-been, established thus far with various fir =s concerning the design and construction audit?

4. Provide names and addresses of all fir:s considered for performing the independent design and construction audit.

5. What criteria are being used to select the firm for the independent design and construction audit--what are the job requirements?

. 6. Explain in detail the job description, scope of the audit, and other descriptions of what exactly is to be done during this audit.

7. Provide all documents and correspondence exch'anged thus far between CPC and prospective companies or individuals regarding the design and construction audit.

8. Explain to what extent the audit scope, depth, or cethodology will be controlled by CPC. ,

9. Explain CPC's proposed plan of action for responding to audit findings.

10. When.does CPC expect the selection of this audit fir = to be decided?

11. When does CPC expect the audit to begin? To be concluded?

12. How is it possible for an outside auditor to independently assess the structural adequacy of the containment structures and other structures (due to the missing reinforcing bars) without relying upon CFC's statements and analysis of internal wall conditions?

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.Reponses

1. This question refers to a "Bechtel audit of Bechtel construction and design announced at the 5/20/82 ACRS meeting." During the 5/20/82 meeting'there was discussion of an " independent design verification" conducted by Bechtel and CP Co. k'e a s s ume tha t is wha t the question addresses.

The Midland Independent Design Review Program conducted by Bechtel &

CP Co personnel (who were independent of the Bechtel Ann Arbor office and CP Co Midland' Project) involved 3183 manhours of the personnel on the review team, at a cost of $204,100.

The purpose of the Program was to review Bechtel project engineering activities to determine if design criteria are being correctly implemented and if the design assumptions, design methods and the design processes are satisfactory. As discussed at the 5/20/82 ACRS meeting, CP Co decided that based on occurrences at Diabl'o Canyon and other plants, a design audit was prudent, even without a specific NRC request.

CP Co decided that such an audit could be optimized by using people who were knowledgeable about the system but were not working on Midland design such as Bechtel personnel located in offices other than Ann Arbor or CP Co personnel that have not been involved in Midland. The Company

, also did not at that time, nor do we as yet, know what NRC staff requirements would apply to independent audits for plants that are in the construction and licensing stage similar to Midland. The Company believes that the Bechtel-CP Co audit will be extremely useful either in confirming the adequacy of design and construction, or, if problems are miO982-0054fl68

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found, in providing timely identification.so that corrective action may E

. be-taken consistent with overall project schedules.

2. To date the fo11 cuing plans have been =ade for an independent design and construction verification program on Midland.

CP Co Management decided that the Independent Design and Constructica Verification Program should censist of two parts, and that both parts ,

should be 12tegrated into cne repcr under the jurisdicticn of one

. subcontractor.

The first part is to be an INPO-type evaluation. This type of evaluation has been under development since March of 1982 with INPO developing criteria to be used by the Utility Industry in perforcing their self

. evaluation. INPO evaluation teams made up of utility persennel and consultants have conducted evaluations of s'everal pilot plants in 1982 and, in September 1982, issued the latest draft of the " Performance Objectives and Criteria for Construction Project ' Evaluations." In September 1982, workshops were held by INFO = for utility and consultant personnel on how to i=plement the evaluttion. ISPO has discussed the programw ' ith the NRC Staff and NRC Staff.has taken part in training sessions and INPO pilot plant programs. Although the INPO Evaluation Program was designed as a self evaluation program by the utility using its own e=ployees in conjunction with assistance frem other utilities or censultants, CP Co has decided to have the INPO evaluation performed by ncn-CP Co employees to obtain an extra degree of independence in the 1NPO-type evaluation.

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.s1 4-The second part of the Independent Design and Construction Verification Program will'be similar to what has been conducted on several plants which were or are to be licensed in 1982. This would be an in-depth review of a system which is i=pertant to safety and whose initial design required interf aces within the principal design organization and with another organization, such as .the NSSS supplier. This type of program has been accepted by the NRC Staff on other plants. The centractor who will perform the independent, in-depth design and construction verification will be required to meet the independency criteria provided in Chairman Pallad,ino's 2/1/82 1ctter to Representative John Dingell.

On September 2,1982 a meeting was held with Region 3 and the staff to discuss the above plans. .

.3. -Three firms have been contacted as potential suppliers of the services described in Item 2 above. All th'ree fir =s have presented proposals and met with the Company.

4 The three firms considered were: .

(a) ?!anagement Analysis Co 11095 Torreyana Rd San Diego, CA 92121 ,

A subcontractor for the second part of the independent design verification proposed by . hem was:

CYGNA Energy Services 141 Battery Street Suite 400 San Francisco, CA 94111

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5 (b) TERA Corporation 3131 Turtle Creek Boulevard Dallas, TX 75219 (c) Torrey Pines Technology PO Box 81608 San Diego,- CA 92138

5. The basic criteria that are being used to select the fir: for

he Independent Design and Construction Verification - Progra= include

a. QA Knowledge and Experience

b. Technical Capability Including Experience of Persennel

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c. Independency

d. Program Planning

e. Cost

• The job requirements are explained in the answer to Question 6.

6. As discussed in the answer to Question 2, the independent design and construction verification pregram will consist of two parts.

Part 1 - ISP0 The description of the work is found in the Septe=ber 1982 INFO Performance Objectives and Criteria for Construction Project Evaluations.

The contractor performing Part i vill assemble a team of perscanel who will use these' criteria in implementing the evaluations. The preplanning phase will consist of selecting review areas based on complexity, status, interfaces, safety significance, and history of problems (Plant and Industry); and defining review material required (procedures, SAR, miO982-0054f166

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' Spec's, drawings, develop tentative assignments and schedule). There will then be core detailed planning of the above, with a plant tour and identification of interfaces. The actual evaluation will . consist of interviews, reviews of material provided, observation of activities, discussion of findings within the team, and drafting of performance evaluations.

Part 2

, The INPO evaluation team will include one or core mechers who are e= ployed by the Contractor doing the Part 2, in-depth review. They will assist in the INPO design review aspects, and use the infor=ation from the INPO activities to assist in detereining the system to be verified in-depth.

The in-depth Part 2 design verification will confir= the design adequacy of an important safety system and will consist of the following

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a. Reviewing' design inputs for conformance to system design criteria and co=mittments;

b. Confir=ing that - the design process conforms with design control requirements and that interface recuirements were factored into design;

c. Reviewing drawings and specifications for confor=ance with design criteria, co=mitments, and incorporation of results of analysis and calculations; miO9S2-0054f168

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d. For analyses and calculations, reviewing input assu=ptions, methodology, validation and usage of computer progra=s and checks of certain calculations outputs;

e. Performing confir=atory analyses and calculations of certain original design analyses and calculations; P

f. Verifying as-built conditions by inspecticns and walkdowns of selected syste=s and cceponents for ccnforcance with design, inspection and test documentation.

The above would include all engineering disciplines involved in the system (electrical, mechanical, nuclear, civil, instrumentation and control, materials selection, and equip =ent qualification).

8. Consumers Power Co=pany will not be controlling the Independent Design and Construction Verification Program. CP Co personnel will be answering . questions during Parts 1 and 2, and will' be providing information on the appropriate organization within CP Co or other Companies to obtain the answers to questions of reviewers. The i- methodology has been defined in the answer to Question 6. The scope and I

depth of the audit is pre-defined in accord with the audit methodology as

! described in the Response to Question 6. Once a contractor is retained, l'

the Co=pany will not interfere with the auditor's ability to carry out its function in accordance with the cethodology. The auditors will be free to pursue areas to a depth which they believe necessary to support their conclusions. .

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. 9. Findings from the program will be evaluated to determine what corrective action, if any, should be taken. Depending on the nature of the finding, action could include re-analysis, rework, or replacement of hardware items or modifications of programs.

10. The selection of the fir =s to be involved in Parts 1 and 2 was made on September 16, 1982.

11. Consumers Power Company expects the Independent Design and Construction Verification Program to begin shortly af ter we make an

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additional presentation to the NRC. This presentation has not been Some scheduled. We hope that the Program can begin in October 1982.

prelimincry activities such as training of review tea = personnel is expected to' start the last week in September 1982 and may co=mence before the additional presentation to the NRC. We expect that the Program would be concluded approximately four months after it commences.

12. For either of the structures mentioned, the independent design and construction verification reviewer wou,1d not have to rely upon CP Co ,

statements and analysis of internal wall conditions other than to utilize the as-built drawings for the rebar. He could then use his own method of analysis to assess the adequacy. This is covered in the answer to Question 6, Part 2, Item (e). (Whether or not an independent audit would a

pursue the rebar matter on these structures depends on whether the audit encompasses them, and, if it does, whether the auditor judges Consumers Power Company's analysis to be adequate.)

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