ML19330B390
| ML19330B390 | |
| 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) |
| Shared Package | |
| ML19330B387 | List: |
| References | |
| NUDOCS 8007310529 | |
| Download: ML19330B390 (8) | |
Text
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-Chtd CODSlimBIS Power Jernes W Cook O
C0mpany V
v,ue,,,a... wi.. m.,u, 49201 + (517) 788-06A0 General Offices.1945 West Parnell Road, Jackson, Michigan June 30, 1980 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Co= mission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLMiT - RESUMP'I' ION OF SAFETY-RELATED WORK BY THE ZACK COMPANY FILE:
0.h.2 SERIAL: 9267 Letter J G Keppler to S H Howell, dated May 22, 1980
Reference:
This letter responds to the two actions required by the NRC in the referenced letter prior to the resumption of work by The Zac) Company. outlines the complete program for the resumption of safety-related work activities by The Zack Company. The program describes actions that have been or are being taken by Consu=ers Power Company, Bechtel Power Corporation Commitment dates are identified for milestone activities.
and The Zack Company. describes the various methods utilized to cause management to be aware of site problems and certain enhtncements to the procedure regarding the issuance of a "stop work."
We are available for further discussions with the NRC on the resu=ption of activities by The Zack Company. We request that a meeting or telephone dis-cussion of these matters be held prior to mid-July.
envs JUL 7 1999 80 07310529
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'i PROGRAM PLAN FOR RESUFPTION OP SAFETY-RELATED WORK BY THE ZACK COMPAW I.
PROCRAM EVALUATION r
Consumers Power Company and Bechtel Power Corporation (Bechtel) in response to previously identified concerns and the results of the NRC investigation, under-took a comprehensive QA/QC program review of The Zack Company.
The 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 proble=s have been overlooked.
The progran re7iew by Consumers Power and Bechtel consisted of the following:
A.
The Zack Company QA Manual and Quality Control Procedures (QCPs) were re-viewed for adequacy and clarity.
Comments generated are being addressed by Zack through procedural revisions.
B.
Bechtel Material and Quality Services (MLQS) has reviewed Zach velding procedures.
The procedures are being rewritten and requalified and pre-vious velding evaluated for adequacy.
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C.
The Zack Chicago facility was audited by a joint Consumers Power /Bechtel audit team. The results of this audit are being addressed by Zack.
D.
Impicmentation of the QCPs in all areas has been verified. Discrepancies were identified and additional QCP comments generated.
E.
Bechtel Specification M-151A (HVAC Seismic Class I Equipment and Ductwork Installation) was reviewed and revised in the area of code references for velding to clearly indicate the applicable codes.
F.
All NRC findings were included for corrective action. Additional NRC items were identified or clarified subsequent to the March NRC investigations on site.
In addition to the above comprehensive program review by Consumers Power and Bechtel, The Zack Company conducted its own internal program reviews.
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 Control management positions at the job site. Another action was to expand the Zack QC manning levels. The positive effect of these actions and others had not been fully real$ ted when the NRC inventigation was initiated.
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PROGRAMMATIC CHANGES BY THE ZACK COMPANY II.
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 revriting the Quality Control Procedures (QCPs) which are the mechanism for imblementing the QA program.
r The previous forty-one (hl) QCPs have been reviewed in depth *and consolidated.
The result of this review is that there vill be fourteen
- Field Quality Control Procedur s (FQCPs) for the site, ten
- Plant Quality Control Procedures (PQCPs) for the Chicago facility, and seven Velding Procedure Specifications (WPSs) 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-h Revork and Repair MB-FQCP-5 Installation MB-FQCP-6 Weld Filler Metal Control MB-FQCP-7 Document Control MB-FQCP-8 NCR MB-FQCP-9 Testing MB-FQCP-10 Calibration MB-FQCP-11 Training, Certification & Evaluation of Quality Control Inspectors MB-FQCP-12 Anchor Bolt Installation / Inspection MB-FQCP-13 Painting MB-FQCP-lh Hold Plant Quality Control Procedures PQCP-1 ReceivingInspectjon PQCP-3 Fabrication PQCP-6 Weld Rod Control PQCP-7 Document Control PQCP-8 Nonconformance PQCP-9 Testing PQCP-10 Calibration
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PQCP-11 Training PQCP-13 Painting (Coating)
PQCP-lh Hold It is noted
'This fi6ure is the number of procedures as provided by Zack.
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 Weld Prc edure Specifications WPS-1 Carbon Steel - GMAW WPS-2 Carbon Steel - SMAW WPS-3 Stainless Steel - GMAW WPS b Stainidas Steel - SMAW Silicon Bronze - Arc Brazing a
WPS-5 WPS-6 Silicon Bronze - GMAW Qualification / Certification of Welders WPS-7 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 Manual vill be revised to reflect programmc 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.
III. 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, discrepancies vere identified These items include all and evaluated for specific part corrective actions.Each item has a commitment date established outstanding findings against Zack.
and is being tracked through a listing that has been prepared and for NRC review.
as the scrapping of an improperly fabricated and documente contractor, vill require work through mid-November of 1980 to completely resolve.
An example is the reinspection of velds, and the subsequent rework o of any component as iequired.
upgrade components to an acceptable condition, the lifting of the Stop Work v be required in order to complete the part corrective actions.
The adequacy of previous work is being assessed throygh reinspections that are These reinspections being accomplished in response to identified discrepancies. Additionally, Bechtel include duct, hangers and equipment installation.
Engineering is dispositioning the effect on past work of the veld procedure qualification anomalies discovered as part of the overall review.
The following is a summary and schedule of the corrective action both underway l-and to be taken:
Items not related to the lifting of Stop Work:
l A.
The completion of 22 open item part corrective actions to date has been l
These items involved scrapping.of material Lnd the for-1.
varding of certifications from the Chicago facility to the site records.
accomplished.
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k 7Venty-six additional open items vil'1 be closable' in the part corrective 2.
action areas without a lifting of Stop Work.
These items co'ncern the review of material certifications and the, corrections of QC doeunents-tion (for example, transposing velder ids from a component onto the Traveller).
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 FQCPs and WPS 1, 2 and 7 vill be reviewed and approved.
1.
QA manual vill be reviewed and approved by Consumers Pcwer and Bechtel.
All process corrective action vill be complete for the Quality Control 2.
personnel within two weeks after procedere review and approval is com-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-Training vill be conducted prior to the lifting of the reinted areas.
Stop Work for those personnel who vill be doing the initial safety-related work, h.
To date, ten open items have process corrective action complete, where retraining was conducted under the requirerents of the existing proce-These items vere in the areas of veld filler metal control and dures.
its documentation, of which the requirements are basically the ser.e under the new Quality Program.
The present estimated date for completion of the corrective action re-5 quired prior to lifting the Stop Work is on or about July 15, 1980.
C.
Open items requiring a lifting of Stop Work:
v M1d-November 1980 closure date is established for closing out Consumers 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 utilized to nttain mid-3979 acceptability requires Bechtel Engineering input, Consumers Power /Bechtel review of these upgrading activities and the coordination of the repairs with the other p3 ont construction activities by the prime contractor, the duration of these actions is considered realistic.
2.. Certain other activities require 12 veeks after lifting of the Stop Work These activities involve the verification of material to be completed.
control identification markings on items installed.
These verificat$on O
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A requirements will parallel the veld reinspection activities $,n Item C.1 above. As these activities will require either removal or a use-as-is 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 (nspections presently in progress and concern comparing design detai,1s to a,ctual 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 acceptable status, and two weeks is considered reasonable. Tnese items include:
a.
Hanger configuration.
b.
Hanger identification numbers, c.
Weld appearance problems.
d.
Welder ids which are missing from the hanger, but are traceabic.
Removal of parts which lack proper documentation.
c.
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 ~CONSUIERS T OWER AND BECHTEL In order to assure that safety-related activities performed by Zack Company are performed as required, the following project commitments will be implemented:
A.
Bechtel Quality Control vill have two men performing full time surveillance inspection in accordance with the Bechtel Quality Control subcontractor surveillance program.
B.
When Q vork resumes in the Zack Chicaco facility, the Supplier Quality Repre-sentative status will be upgraded from a Level 3 to Level h which is a full residency.
Consumers Power Midland Project Quality Assurance vill assign the equivalent C.
of one man full time on Zack. This person (or persons) vill perform over-inspections, conduct audits and vill reviev Zack activities to assure compli-ance with, and the viability of, the program. A heavy emphasis vill be placed on the overinspection activity.
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D.
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 unt'il such time as we ha've con-cluded that the Zack inspection activities are effective.
E.
A full scope audit of Zack activities vill be initiated approximat,ely 90 days of the lifting of the Stop Work. This audit will inc3ude the Midland
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site and the Chicago facility.
F.
Consumers Power Midland Project Quality Assurance vill verify completion of
.part (hardware) corrective action on discrepancies identified previously.
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Additionally, specific training co=mitments 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 (6) and in the Chicago facility (2). The above commitments will remain in effect pending further assessments of the Zack QC inspection effort. A reviev v311 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 vill not take place until Consumers Power and Bechtel are convinecd that Zack has demonstrated satisfactory performance.
The NRC will be informed of our findings and actions.
V.
RESlMPTION OF WORK ACTIVITIES Based on the completion of the requisite action, it is expected that Zack could begin vork on or about July 15, 1980. For this initial, limited verk, a specific scope of work will be identified.
Specific approved procedures involved would be identified and training in the procedures co=plete.
The work would be subject to the Consumers Power /Bechtel verification activity described in IV above.
Idmited work that is performed vill be evaluated and, if an acceptable level of confidence is attained, then full production can resume.
It is expected this vill happen on or about August 1,1980.
y The above program is contingent upon NRC concurrence. Review by and any necessary informational meetings with the NRC would have to be cespleted prior to lifting the Stop Vork.
JWC 6/30/80 h
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Midland Project Stop Work Procedure'
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and Manarement Awareness of Site Problems Management Involvement Consumers Power Company management is made aware of quality pr'oblems 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 Corpany's The Bechtel Project Manager is now invited to the Midland QA In addition, there is a monthly Project Management Meeting Chief Executive.
Quarterly Meetings.
This meeting is attended by the key pro-between Core,umers Power and Bechtel.
ject management individuals up through the Vice President-Midland Project for Consumers. Power and up through the Project Manager for Bechtel.
Enhancement to Stop Work Procedure In order to better assess the need for a Stop Work, the following changes, which vill 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 a The need to evaluate when the requirements for an activity would not be met.
whether activities are out of control is triggered by any of the following repetitive nonconformances in the same performance area for principal suppliers or site subcontractors as noted by the re occurrences:
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).
To support the above, Consu=crs Power vill begin a review of all Trend Reports from the site making an tssessment as to whether conditions described in those The results of that assess-Trend Reports warrant stop vork action to be taken, By the time the Stop ment vill be reported in the monthly QA activities report. Work Ord Control and Nonconformance Reports written by Zack vill be factored into that In the future, any new major subcontractor activities vill also Trend Report.
be included in the Trend Program as an individual performance area.
e JWC 6/30/80 6..
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