ML19321B123
| ML19321B123 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/30/1980 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 9267, NUDOCS 8007280060 | |
| Download: ML19321B123 (8) | |
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CORSumBIS Q
Power CQQ}G8Q}
vsce nesuent, Asut.mJ hoject General of fices: 1945 West Parnall Road, Jackson, Michigan 49201 e (517) 788 0640 June 30, 1980 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLA?ID NUCLEAR PLANT - RESUMPTION OF SAFETY-RELATED WORK BY THE ZACK COMPANY FILE:
0.h.2 SERIAL: 9267
Reference:
Letter J G Keppler to S H Hovell, dated May 22, 1980 This letter responds to the two actions required by the URC in the referenced letter prior to the resumption of work by The Zack Company. outlines the complete program for '.he resumption of safety-related work activities by The Zack Company. The program describes actions that have been or are being taken by Consumers Power Company, Bechtel Power Corporation and The Zack Company.
Cor:mitment dates are identified for milestone activities. describes the various methods utilized to cause management to be aware of site problems and certain enhancements to the procedure regarding the issuance of a "stop work."
We are available for further discussions with the NRC on the resumption of activities by The Zack Company. We request that a meeting or telephone dis-cussion of these matters be held prior to mid-July.
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PROGRM4 PLAU FOR RESUMPTION OF SAFETY-RELATED WORK HY THE ZACK COMPANY I
I.
PROCEN4 EVALUATION Q*
l Consumers Power Company and Bechtel Power Corporation (BechteF) in response to previously identified concerns and the results of the HRC investigation, under-took a comprehensive QA/QC program review of The Zack Company. Ufhe. purpose of the review was to ensure that all aspects of the Zack quality program were..
included in the current remedial program. Thus, when the "stop work" is finally lifted, there vill be full confidence that no additional problems have been overlooked.
t The program review by Consumers Power and Bechtel consisted of the following:
The Zack Company QA Manual and Quality Control Procedures (QCPc) were re-A.
viewed for adequacy and clarity. Comments generated are being addressed by Zack through procedural revisions.
B.
Bechtel Material and' Quality Services (M&QS) has reviewed Zach velding procedures. The procedures are being rewritten and requalified i pre-vious velding evaluated for adequacy.
C.
The Zack Chicago facility was audited by a joint Consumers Pover/Bechtel audit team. The results of this audit are being addressed by Zack.
D. ' Implementation of the QCPs in all areas has been verified. Discrepancies were identified and additional QCP comments generated.
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E.
Bechtel Specification M-151A (HVAC Seismic Class I Equipmesit and Ductwork Installation) was reviewed and revised in the area of code references for velding to clearly indicate the app 31 cable codes.
F.
All HRC findings. vere included for corrective action. Additional URC items l
vere identified or clarified subsequent to the March URC investigations en site.
i In addition to the above comprehensive program review by Consumers Power and
-Bechtel, The Zack Company conducted its own internal program reviews.
l Significant corrective actions had previously been initiated as a result of Consumers Power and Bechtel involvement in Zack quality activities. These cor-rective actions were initiated prior to the NRC investigation, and included a
' change in the top production and Quality Contro1'manar,ement positions at the
~ job site. -Another action vas to expand the Zack'QC manning levels. The positive
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effect of these actions -and others had not been fully real$ zed when the HRC
' investigation was initiated.
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PROGRAM 4ATIC CHANGES BY THE ZACK COMPANY j
The. Zack Company has responded to the identified concerns by providing a re-structured QA program that provides well defined responsibilities and actions.
This effort centered primarily.on rewriting the Quality Control Procedures (QCPc) which are the mechanism for implementing the QA program.
n The previous ' forty-one (b1) QCPs have been reviewed in depthiand consolidated.
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The result of this review is that there vill be fourteen
- Field Quality Control Procedures (FQCPs) for the site, ten
- Plant Quality Control Procedures (PQCPs) for the Chicago facility, and seven Welding Procedure Specifications (WP3s) for.use at the site and at the Chicago facility. These procedures are as de-tailed below:
Field Quality Control Procedures MB-FQCP-1 Requisition / Receipt Inspection MB-FQCP-2 Storage & Maintenance MB-FQCP-3 Field Fabrication MB-FQCP-4 Rework and Repair MB-FQCP-5 Installation
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MB-FQCP-6 Weld Filler Metal Control MB-FQCP-7 Document Control MB-FQCP-8 UCR MB-FQCP-9 Testing 4
-MB-FQCP-10 Calibration l
MB-FQCP-11 Training, Certification & Evaluation of Quality Control Inspectors MB-FQCP-12 Anchor Bolt Installation / Inspection
-f MB-FQCP-13 Painting MB-FQCP-lh Hold i
Plant-Quality Control Procedures PQCP Receiving Inspection PQCP-3 Fabrication PQCP-6 Weld Rod Control PQCP-7 Document Control PQCP-8 Nonconformance PQCP-9 Testing PQCP-10 Calibration PQCP-11 Training PQCP-13 Painting (Coating) t.
PQCP-lh Hold
'This figure in the number of procedures as provided by Zack.
It is noted that..pending completion of the review of the procedures by Consumers Power and Bechtel, the need for additional or fever procedures may be identified.
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3 33 2d Procedure Specifications WPS-1 Carbon Steel - GMAW WPS-2 Carbon Steel - SMAW WPS-3 Stainless Steel - GMAW WPS-h Stainless Steel - SMAW WPS-5 Silicon Bronze - Arc Brazing WPS-6 Silicon Bronze - GMAW WPS-7 Qualification / Certification of Welders All of the above procedures are being reviewed and approved by Consumers Power Training of cognizant personnel vill be conducted prior to lift-and.Bechtcl.
ing of the Stop Work.
The Zack Company Quality Assurance Ma: ual vill be revised to reflect programmstic This manual vill be revi ewed changes made as a result of the identified concerns.
The manual has been sub-and approved by CP Co and Bechtel Power Corporation.
mitted with review and approvals of CP Co and Bechtel to be accomplished prior to lifting the Stop Work on Installation activities.
111. CORRECTIVE ACTION As a result of the Consumers Power /Bechtel review of the complate Zack Company Program at both the site and the Chicago facility, discrepanei.s were identified and evaluated for specific part corrective actions. These itete include all outstanding findings against Zack. Each item has a commitment date established and is being tracked through a listing that has been prepared and is available The duration of these actions vary from immediate action, such for URC review.
as the cerapping of an improperly fabricated and documentedturning vane, to actions which, due to craft availability and schedule coordination with the 1 -ime contractor, will require work through mid-November of 1980 to completely resol 7e.
An example is the reinspection of velds, and the subsequent rework or scrapping of any component as required. As many of the Zack open items require repairs to upgrade comfonents to an acceptable condition, the lifting of the Stop Work will be required in order to complete the part corrective actions.
Th? adequacy of previous work is being assessed through reinspections that cre These reinspections being accomplished in response to identified discrepancies.
include duct, hangers and equipment installation. Additionally, Bechtel Engineering is dispositioning the effect on past work of the veld procedure qualification anos ilies discovered as part of the overall review.
The following is a summary and schedule of the corrective action both underway and to be taken:
A.
Items not related to the lifting of Stop Work:
The completion of 22 open item part corrective actions to date has been 1.
accomplished. These items involved scrapping.of material and the for-varding of certifications from the Chicago facility to the site records.
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Twenty-six additional open items vil'1 be closable'in the part corrective 2.
action areas without a lifting of Stop Work.
These items concern the review of material certifications and the corrections of QC documentn-tion (for example, transposing velder ids from a component onto the Trave 11er'.
Also included in this category is the closure of the audit findings at 3.
the Chicago facility, and approval of all the revised PQCPs.
B.
Corrective action required prior to lifting the Stop Work:
The revised All FQCPn and WPS 1, 2 and 7 vill be reviewed and approved.
1.
QA manual vill be reviewed and approved by Consumers Pcaer and Bechtel.
All process corrective action vill be complete for the Quality Control 2.
i personnel within two vecks after procedure review and approvr1 is com-I The main point of the process corrective actions is the train-pleted.
ing and respective certification of the QC personnel to assure their proficiency in executing the new quality program.
Site production personnel vill be trained in the procedural requirements 3
of the Quality Program.when they are assigned to work in the safety-related areas. Training vill be conducted prior to the lifting of the Stop Work for those personnel who will be doing the initial safety-related work.
h.
To date, ten open items have process corrective action complete, where l
retraining was conducted under the requirements of the existing procc-These items were in the areas of weld filler metal control and dures.
its documentation, of which the requirements are basically the se=c under 1
the nov Quality Program.
5 The present estimated date for completion of the corrective action re-quired prior to lifting the Stop Work is on or about July 15, 1980 C.
Open items requiring a lifting of Stop Work:
Mid-November 1980 closure date is established for closing out Consurers 1.
Power NCRs M-01 h-9-057, 083, 087, which requires a 100% reinspection of
. specific welds due to veld process and veld acceptance problems noted in As the upgrading of velds and the methods utilised to attain mid-1979 acceptability requires Ecchtel Engineering input, Consumers Pover/Bechtel review of these upgrading activities and the coordination of the repairs With the other plant construction activities by the prime contractor,
'the duration of these actions is considered realistic.
2., Certain other activities require 12 weeks after lifting of the Stop Work These activities involve the verification of material to be completed.
control identification tarkings on items installed.
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requirements will parallel the veld reinspection activities in Item C.1 As these activities vill require either removal or a use-as-is above.
disposition, the duration for completion vill be slightly less than that required for the possible veld rework activity.
3.
Another group of corrective action activities require two to four weeks after lifting of Stop Work. The bulk of these items involve inspections presently in progress and concern comparing design details to actual installed configurations. As the amount of discrepancies is considered to be isolated cases only and all rework, based upon existing data, vill require three weeks to complete.
Also, scoped in this duration is the upgrading of specific open items noted by the NRC. As all information concerning the problem has been identified, these items require a rela-tively short amount of time to upgrade to accepthble status, and two veeks is considered reasonable. Tnese items include:
a.
Hanger configuration.
b.
Hanger identification numbers.
c.
Weld appearance problems, d.
Welder 1Ds which are missing from the hanger, but are traceable.
Removal of parts which lack proper documentation.
e.
f.
Missing control number ids on specific hanger subcomponents.
NOTE: The above schedules are contingent on ability to reman the work force including accomplishing all required training.
IV.
VERIFICATION ACTIVITY BY CONSUMERS POWER AT;D BECHTEL In order to assure that safety-related activitics performed by Zack Company are performed as required, the following project commitments vill be implemented:
A, Bechtel Quality Control vill have two men performing full time survei31ance inspection in accordance with the Bechtel Quality Control subcontractor surveillance program.
When Q vork resumes in the Zack Chicaco facility, the Supplier Quality Repre-B.
sentative status will be upgraded from a Level 3 to Level h which is a full residency.
Consumers Pouer Midland Project Quality Assurance vi13 assign the equivalent C.
of one man full time on Zack. This person (or persons) vill perform over-inspections, conduct audits and will reviev Zack activities to assure conpli-ance with, and the viability of, the program. A heavy emphasis vill be placed on the overinspection activity.
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Consumers Power is contracting with an 'outside inspection agency to provide additional inspection personnel to cover the commencement of the Zack work activities. The personnel would be individuals specifically qualified in the type activities associated with HVAC installation. The additional in-spection personnel would remain on the job until such time as we have con-cluded that the Zack inspection activities are effective.
E.
A full scope audit of Zack activities will be initiated approximately 90 days of the lifting of the Stop Work.
This audit will include the Midland site and.the Chicago facility.
F.
Consumers Power Midland Pro,1ect Quality. Assurance will verify completion of
.part (hardware) corrective action on discrepancies identified previously.
Additionally, specific training commitments will be verified The above commitments. represent a high verification activity level based on the ratio of overviewers to the number of Zack QC inspectors located at Midland (8) and in the Chicago facility (2). The above comr~tments will remain in effect pending further assessments of the Zack QC inspection effort. A review will be made of the overall Zack performance in conjunction with the full scope audit to be carried out 90 days after the Stop Work is lifted. Based on the audit findings and data to be developed regarding Zack's inspection effectiveness, the degree of overview may be reduced to levels consistent with the rest of the pro-ject. This reduction will not take place until Consumers Power and Bechtel are convinced that Zack has demonstrated satisfactory performance.
The URC will be informed of our findings and actions.
V.
RESUMPTION OF WORK ACTIVITIES Based on the completion of the requisite action, it is expected that Zack could begin work on or about July 15, 1980. For this initial, limited work, a specific scope of work will be identified. Specific approved procedures involved would be identified and training in the procedures complete.
The work would be subject to the Consumers Power /Bechtel verification activity described in IV above.
Limited work that' is performed will be evaluated and, if an acceptable level of I
confidence is attained, then full production can resume.
It is expected this will happen on or about August 1,1980.
The above progran is contingent upon NRC concurrence. Review by and any necessary j.
informational meetings with the NBC would have to be completed prior to lifting i
the Stop Work.
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e Midland Project Stop Work Procedure' and Management Awareness of Site Problems 1
Management Involvenent i
4' Consumers Power Company management is made aware of quality problems at the site through a Quarterly Quality Assurance Management Meeting, through the information in the-monthly activities report and, as part of the recent project reorganization, through the biveekly meetings with Mr J D Selby, the Company's j
Chief Executive. The Bechtc1 Project Manager is now invited to the Midland QA Quarterly Meetings. In addition, there is a monthly Project Management Meeting i
between Consumers Power and Bechtel. This meeting is attended by the key pro-ject management individuals up through the Vice President-Midland Project for Consumers Power and up through the Project Manager for Bechtel.
Enhancement to Ston Work Procedure 4
In order to better assess the need for a Stop Work, the following changes, which will be effective July 1,1980 have been made to the Stop Work Procedure:
The conditions under which Stop Work consideration shall be made have been expanded to include cases for which there is evidence that an activity is. not under control in addition to the previous requirement to stop vork when the requirements for an activity would not be met.
The need to evaluate whether activities are out of control is triggered by any of the following repetitive nonconformances in the same performance area for occurrences:
i f noncon-
. principal suppliers or site subcontractors as noted by the rev ew o formance reports (broad definition), when the need for an MCARR is determined,
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l or when the quality tracking graphs from the Trend Program demonstrate an increase in occurrence rate which exceeds the four-month trailing average (which is the average of the latest four-month deficiency rates),
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i To support the above, Consumers Power vill begin a review of all Trend Reports from the site making an assessment as to whether conditions described in ther,e Trend Reports warrant stop work action to be taken. The results of that assess-ment will be reported in the monthly QA activities report.
By the time the Stop Work Order against Zack is lifted, Deviation Reports written by Bechtel Quality Control and Nonconformance Reports written by Zack vill be factored into that Trend Report. In the' future, any new major subcontractor activities vill also be included in the Trend Progrsm as an individual performance area.
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