ML20069J057
| ML20069J057 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/11/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20069J056 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304130262 | |
| Download: ML20069J057 (191) | |
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COLKETED
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CObgS{Ipyj p4;55 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
,Mi In the Matter of:
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Docket Nos. 50-329 OM
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50-330 GM CONSUMERS POWER COMPANY
)
Dock'et Nos. 50-329 OL (Midland Plant, Units 1 & 2)
)
50-330 OL TESTIMONY OF JAMES W.
COOK ON QUALITY ASSURANCE I.
Introduction and Scope My name is James W. Cook.
I am Vice President, Projects, Engineering and Construction for Consumers Power Comprmy.
I have previously set forth my background in uiy testimony of July 10, 1981 (see my prepared testimony after Tr 1693.)
My testimony today is intended to outline the Company's plans for the completion of the plant, particularly as the plans relate to quality assurance and quality control.
The focus of the quality assurance issues in this proceeding has always been somewhat more expansive than those quality assurance matters which relate directly to soils remedial work.
The NRC Staff has presented evidence regarding its evaluation of Consumers Power Company's overall quality assurance program and implementation of that program as bearing on the Staff's conclusion concerning reasonable assurance that the program will meet or exceed all regulatory requirements.
Since approximately September of 1982, however, the staff has given 8304130262 830411 PDR ADOCK 05000329 T
PDR j
somewhat separate consideration to the Company's quality assurance program and activities for soils remedial work-and for all other safety-related work.
Mr. Keppler's October 29, 1982 prepared testimony relates mostly to soils remedial quality assurance matters.
Mr. Keppler's March 25,.1983 testimony deals with all aspects of the Company's quality assurance program.
I believe that whatever difficulties the Company may
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have encountered regarding the scope and implementati,on of the j
soils-related quality assurance program are largely in the past.
This is demonstrated by the performance that has been achieved in the auxiliary building underpinning work which has now been underway for almost four months.
This record is gratifying to me and to the entire management of Consumers Power Company.
All of-us on the management team, including myself, have worked long and hard to formulate and imp 1.ement the measures which have led to these improvements in the soils program.
The details of recent soils quality assurance implementations are included in the testimony of Mr. Mooney.
On December 1, 1982, Consumers Power Company initiated a comprehensive program, the Construction Completion Program (CCP), to complete the Midland nuclear cogeneration plant.
This plan is a major initiative both conceived and managed by Consumers Power Company.
The overall objectives of the program were established under three general headings.
These were:
(1) to improve project information status, (2) to improve imple-mentation of the quality assurance program, and (3) to assure _ _ _ _ _ _
r efrective and orderly conduct of the remaining project work.
Beneath these three general headings, we formulated more detailed objectives which reflected the project's current status and attempt to address comprehensively the underlying or root causes of the problems experienced by the project.
The plan developed meets these objectives and entails a number of major changes in the conduct of the final stages of the construction process.
In my view, the Company's decision to undertake the CCP was prompted by two major factors:
(1) an awareness on the part of the Company that we were not fully meeting our own and NRC expectations for che appropriate level of disciplined adherence to procedures and requirements, and (2) an increasing level of emphasis and expectation regarding QA on the part of the agency as a reuult of events in the industry in the last J8 months.
The NRC's scrutiny of nuclear plant construction quality has always been substantial, but it is clear to me and others in the industry that both the emphasis and expectations of the NRC regarding quality assurance at construction sites has increased in the last 18 months.
Both as part of an industry-wide initiative and on a project specific basis, Consumers Power has taken steps to respond to the challenge put forth by Chairman Palladino in his November, 1981, speech in San Francisco and the detailed interpretation of these objectives by the NRC regional staff.
I My characterization of what it is we are trying to achieve can be summarized by the concept of developing both a
' i e e
s more disciplined project construction process and a documentation system which generates a set of design documents and inspection records that are up-to-date, consistent, and unambiguous.
l A number of specific events during 1982 influenced the l
Company's decision to initiate the CCP.
These were:
(1) exam-ples of inadequate implementation in the soils work during the first half of 1982; (2) the identified inspection deficiencies in the areas of electrical cable routing and pipe hangers; (3) the NRC Staff's calls for improved implementation of the Company's Quality Assurance Program; (4) the Company's exper-l ience with system turnovers being delayed; (5) the results of our self-initiated INPO evaluation conducted by the Management Analysis Company (MAC); and (6) the NRC's October-November team inspection of the Midland diesel generator building.
l II.
Construction Completion Program The Company was already studying the concept of using system-by-system teams for project completion at the time the NRC I
was carrying out its diesel generator building inspection.
We had, by then, decided on significant changes in the QA/QC program, but had not fully implemented them.
When we became aware of the possible implications of the diesel generator building inspection, we decided that the project needed a major change in approach to effect or'derly completion of the project
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while improving implementation of quality assurance.
As a result, we decided to institute several additional measures and l
integrate those new measures with the other. measures regarding quality assurance which had already been decided upon.
Our analysis of all the information then available to us brought us also to the conclusion that an opportunity existed to integrate our responses to all of the issues affecting the project into a comprehensive plan.
Such a plan would systematically resolve _all of the various outstanding issues under a single program.
On December 2, 1982, we initiated the CCP by halting most safety-related work of the prir.e contractor (necessitating the layoff of approximately 1,100 workers).
The major concepts in the Company's construction completion plan are set forth in my January 10, 1983 letter to Mr. Keppler (Attachment 1).
These are as follows:
significantly reduce safety-related construction by the prime contractor and clear the plant of construction equipment and materials in affected areas; review equipment status to assure that proper layup precautions are in place; absorb the prime contrector's Quality Control function into the Company's QA department and reorganize to assure effective management and single point accountability; recertify quality control inspectors and strengthen the inspection process; bring quality inspections up to date; i
verify quality inspections on completed work; review the adequacy of certain QA program elements; completely survey the plant and develop an accurate and up-to-date stat 9s report on construction completion; reorganize the construction production forces into teams on a system or area basis to conduct the status assessment; i
I complete construction under the direction of the same team that carried out the statusing; provide for a formal management re'iew program to monitor CCP activities; and estab]ish a third-party review.
1 Under the construction completion program, all i
remaining work will be done in two conceptual steps, which we refer to in our documentation as Phase 1 and Phase 2.
The objective of Phase 1 is to obtain a definitive picture of the current status and condition of construction work and quality inspections conducted prior to December 2, 1982.
In this step, i
we will do a complete construction and inspection status assessment of all work covered by the program.
We will also verify the adequacy of completed inspections on prior work.
This i
will be done by a combination of reinspections and documentation reviews.
The objective of Phase 2 is simply to execute the
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remaining work.
The plant will be divided into many distinct modules and the CCP sequence will be applied to each module.
As a result, there will be situations in the plant where Phase 2 activities will be occurring immediately adjacent to an area undergoing Phase 1 activities.
In order to carry out the remaining work more effi-
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ciently, we have created a team structure for production work on a system or area basis.
The quality organization (MPQAD) will be directly represented on the various teams through the team quality representative.
This individual will insure that all l
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quality resources and information are made available as required j '
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and that quality inspections are fully coordinated in a timely manner with the production effort and that quality program requirements are fully implemented.
However, the quality representative will receive only scheduling requirements from the team and will take all other management direction from MPQAD.
The program is designed to insure that the proper independence
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between production and quality functions is maintained.
We saw the need for reorganization of the quality function itself both to make it work effectively in.the new production environment and to accommodate the integration of the QC function into MPQAD.
Accordingly, we made the changes in MPQAD which are described in the testimony of Mr Wells.
Some activities were exempted from the CCP.
Particular activities that have demonstrated effectiveness in quality program implementation will continue during the construction completion program.
These are described in subsection H below.
In the attachment to my January 10, 1983 letter.to Mr.
Keppler, the Company divided the elements of the plan into eight distinct categories: preparation of the plant, QA/QC organization changes, program planning, program implementation, quality program review, third-party reviews, system layup, and continuing work activities.
Each category of work is described briefly below.
A.
Preparation of the Plant The preparation of the plant'for the CCP is now complete.
During this activity, we cleared the Auxiliary, Diesel.:.
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I Generator, and Containment buildings and the Service Water Pump Structure of the majority of construction materials, tools, i
equipment, and temporary facilities including scaffolding and the 1
l like.
We have also ordered removal, control and storage of 4
uniprtalled materials in the work areas and have instituted j
appropriate hcusekeeping measures for all areas which will be l
involved in the remainder of the program and have instituted the
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necessary measures for proper storage of materials.
These i
actions have been taken to allow adequate access to systems and i
spaces for personnel carrying out the status survey and'the i
remainder of program activiti'es.
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B.
QA/CC Reorganization In my September 17, 1982, letter to Mr.
J.
G.
- Keppler, (Serial No. 18850) (Attachment 2), I indicated that the Company had decided to assume direction of the (non-soils) portion of the quality control function previously managed by Bechtel.
This approach was consistent with the earlier integration of the j
quality control function under MPOAD for both heating, ventilating, and air conditioning work being performed by the Zack Company and the soils remedial work.
When the CCP was l
initiated in December the Q ' integration task was incorporated as part of it.
On December 15, 1982, we advised the NRC of the i
structure of the integrated organization; on January 17, 1983, the transfer to the new organization was complete.
l The QA reorganization included the recertification of QC inspectors other than those previously certified to Consumers
1 Pcwer Company procedures.
The recertification effort is described more fully in both the testimony of Mr. Wells and the-testimony of Mr. Mooney.
C.
Progran: Planning Since the CCP execution takes place in two phases, there is specific planning for each phase.
1.
Phase 1 Planning The Phase 1 planning consists primarily of (1) planning l
a team organization to assess the installation and inspection status of Q-Systems and other components within major safety-related structures as previously noted, and (2) planning for the program to verify the adequacy of previously completed i
inspections.
During Phase 1 planning, project construction will establish team organizations ready to inspect and assess particular systems for installation status and MPQAD will develop 1
the processes and procedures necessary to ascertain inspection status and implement the quality verification program.
Team Organization A team organization will consist of a team supervisor and personnel from field engineering, planning, craft i
supervision, project engineering, MPCAD, and Consumers Power Company test and' construction personnel.
The team may be augmented as required by procurement personnel, subcontract coordinators, and turnover coordinators.
This organizational 1
structure and the components thereof will vary depending on the particular systems or areas assigned to the team.
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i Each team will contain a team quality representative from MPQAD whose line reporting relationship is to the MPQAD organization and not to the team leader.
The team quality representative receives scheduling requirements from the team supervisor.
The team quality representative will analyze the quality requirements and will plan quality activities for inte-l gration into the team effort.
He will assure that the necessary Project Quality Control Instructions (PQCI's) and inspection personnel are available for performing required inspections on a l
timely basis.
He will maintain an up-to-date awareness of the i
status of quality inspections and verification. activities that relate to his team's activities.
He will insure thct construction planning provides for the necessary inspection hold 4
points.
I i
As a part of Phase 1 planning, team members will receive training on the Phase 1 activity assigned to the team, ie, bringing system or area completion status information up to date.
(The teams are not involved in the verification effort, which is to be carried out by MPQAD, as described below.)
Team members will also be trained in areas of team responsibility, l
reporting functions, proced'ures and other matters.
Supervisors will be trained to assure that they fully understand team t
I objectives and team role in accomplishing those objectives.
Also, during the Phase 1 planning, a pilot team has t
I been utilized to develop and cest processes a'nd procedures for t
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teams.
The use of a pilot team will assure that the final procedures will allow smooth functioning of the CCP teams.
The Phase 1 planning has progressed to the point that team procedures have been drafted, the team organization has been set, available personnel have been assigned, and initial status assessment work in Phase 1 is awaiting management review and team training.
Verification As part of Phase 1 planning activity we are also developing a plan to verify that quality inspections previously performed en completed work were done correctly.
The first step is to review the PQCIs in order to improve the total inspection performance and support the verification program.
The second step is to develop a plan for verifying past inspections to assure that completed work has been adequately inspected for compliance with quality requirements.
In order to assure that the verification will fulfill those two major objectives, as part of the Phase 1 planning we are reviewing existing POCI's and revising them as necessary to assure that we identify the attributes of the particular systems, components, or structures which are critical to the safety and reliability of those items, to assure that accept / reject criteria are clearly identified, to specify appropriate controls, methods, inspections and testing equipment for the particular item, and to I
assure that requisite skill levels are required for the particular job in hand.
( I
i As part of the planning, we are also developing a verification plan for completed inspections.
This plan involves some reinspection of items of work which are accessible and I
review of dccumentation for attributes which are inaccessible for reinspection, such as placement of reinforcing bar in concrete.
f This verification program is still under review and may rely in part on sampling techniques using accepted statistical procedures and national standards for acceptance or rejection of a sample.
At present, all project PQCI's involved in the verifi-cation program are scheduled for review, with the majority of the task scheduled for completion by the middle of May, 2.
Phase 2 Planning The Phase 2 planning effort develops the work pro-r cedures that will be used by the team organizations to complete work on systems and areas.
During Phase 2 planning, procedures will also be established to integrate the quality program and requirements into the on-going completion work.
In the Phase 2 planning activity, we are developing the i
specific process for completing various system and area work.
I Under this activity, we will prepare necessary procedures and expand training of team members to cover systems completion work.
Teams will be assigned to a specific scope of work and held accountable for the overall completion within this scope.
Phase 2 planning will also establish scheduling methods to be used during completion activities.
The team organization I
which will already be in place as a result of the status and i I
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1 assessment work will accomplish the actual system and area completion.
Each team will undergo training in Phase 2 activ-ities.
In this effort, we will increase emphasis on implementa-tion of design in accordance with design requiremsnts and on proper handling of design changes or fields modifications.
The final part of the Phase 2 planning activity will be planning for the QA/QC effort necessary to inspect the construc-tion activities planned for Phase 2.
In this activity, we are establishing a n3w in-process inspection program.
This program will require that inspection be directly integrated with future i
installation schedules to insure that inspection points are f
I integrated with the construction process.
In addition, we will j
I assure that the review of PQCI's performed during Phase 1 planning covers all attributes to be inspected during completion work, and that inspection plans for completion work are clear and concise.
D.
Program Implementation Program implementation for Phase 1 activities consists of executing the previously described plans for the installation and inspection status assessment of incomplete work and the quality verification of completed work.
Program implementation for Phase 2 consists of carrying out the previously planned construction work necessary to complete the plant on a system or area basis.
The results of ecch planning phase will be the subject of a management review before execution of that phase's work on a designated system or area will be allowed to proceed..
_a
After we have completed the installation and inspection status assessment of each system, subsystem or area, production and quality management will review the results before we allow any Phase 2 completion work to be initiated on a particular system or area.
The management reviews of the Phase 1 and Ph'ase 2 planning results will cover the activities involving verification f
of completed inspections, the installation and inspection status program, and the plans for the system completion work themselves.
L Project Management will conduct these management reviews in order to assure that they are satisfied that these programs and processes are thorough, complete, and correct.
I am personally participating in these reviews so that I will be satisfied that the project has met its commitments and is ready to proceed with the implementation of these programs.
Other Project senior managers will conduct the detailed Phase 2 management reviews of Phase 1 results under my supervision.
In this manner, the production and quality managers will review and release each new piece of Phase 2 work having assured themselves that Phase 1 requirements have been met and that a proper disposition of any findings has been achieved.
The first segment of the management review of the Phase 1 planning results is scheduled for mid-April to late l
April.
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E.
Quality Program Review-I bel.ieve that the Midland Quality Assurance Program was and remains in most respects sound.
The inspection of the Diesel Generator Building, however, did raise several open items relating to programmatic issues.
These concerns have been categorized under the headings of material traceability, the design control process, Q-listing requirements, cocunent control t
and receipt inspection.
I have directed that MPQAD provide an evaluation of these is' sues (except for Q-listing, which is 1
assigned to licensing) for the management review which vill be completed prior to initiation of Phase 2 activities (actual construction for system completion).
In addition, we are pursuing the normal process of addressing and resolving the various individual items identified in the NRC inspection report.
i We will, of course, incorporate any indicated program changes y
into the program.
F.
Third-Party Reviews I will describe both the history and the scope of the planned third-party reviews in detail below.
Accordingly, I will not discuss them here except to state that in' carrying out the CCP we will take into account the findings or recommendations of the third party reviews.
We will implement any recommended
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changes on a case-by-case basis as documented in our responses to particular findings.
(See below at p. 18.)
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i G.
System Layup i
During the months of January and February, we took steps to protect completed and partially completed plant systems l
for the duraticn of tne status assessment and until work on system completion resume.
These layup activities tock various forms on the systems on which construction was halted for the I
system assessment.
The walkdowns on which the layup requirements are based have been completed and the layup activities are ongoing.
H.
Continuing Activities Certain activities were exempted from the CCP.
Particular activities that have demonstrated effectiveness in l
l quality program implementation were allowed to continue during the initial steps of the construction completion program.
These are NSSS installation by Babcock & Wilcox Construction Company; EVAC installation by Zack Company with QA/QC provided by Consumers Power Company; post-system turnover work.under the direct control of Consumers Power Company; hanger and cable reinspections under separately established commitments to the NRC; and remedial soils work which is proceeding under the work r
I authorization program.
Design engineering for the remaining installation work and engineering support of various other I
project activities will continue as needed.
i I.
Completion of Program Definition l
The Project Management team initially described the CCP.
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concept to the NRC regional staff on December 2, 1982.
We then 16 -
developed this program definition to the point documented in my January 10, 1983, letter and then amplified that material at the public meeting on February 8, 1983.
The dialogue with the NRC Staff is continuing on both a formal and day-to-day basis.
We have received a letter from Region III dated March 28, 1983, (Attachment 4), outlining the remaining review items of interest to the NRC.
We have formally responded to their request in part and will complete that response shortly.
(See Attachment 3).
We will then proceed to resolve any open items.
In the meantime, we are proceeding carefully to implement the program in a step-by-step basis, including initiation of third party audits of the management reviews of the planning for the various phases of the CCP.
III. Third-Party Reviews As I noted earlier in this testimony, Consumers Power Company has formulated an Independent Review Program now con-sisting of an Independent Design Verification (IDV) and a Construction Implementation Overview (CIO).
The purpose of this portion of my testimony is to describe the organization, implementation and status of these independent reviews.
Consumers Power Company had planned to perform some type of third-party independent review based on the NRC's recent practice of requiring IDV's for plants at the operating licensing stage.
The Company followed developments in other dockets to keep abreast of the evolution of the NRCs informal requirements.
In the summer of 1982, the Company began to formulate specific i
plans; and after the NRC Staff made a formal request on July 9, 1982, that the Company perform an IDV, the Company developed what we considered an innovative third party review program for non-soils work.
An independent review of soils remedial work is described in the testimony of Mr. Mooney.
The concept for the review of the non-soils work was to establish a program consolidating several reviews being conducted or to be conducted, thereby producing a comprehensive evaluation of the project and to require that all of this work be conducted by third parties.
The three elements of the program as it was conceived at that time, is described in my October 5, 1982 letter to Mr. Denton and Mr. Keppler, (Attachment 5) and consisted of (1) an independent design verification, (2) the biennial QA program audit and, (3) a self-initiated construction project evaluation (SIE), to meet an industry commitment to conduct plant reviews coordinated through INPO.
This program combined a broad horizontal review of project activities through the INPO SIE with a so-called
" vertical slice," in-depth independent design review of a critical plant safety system.
Thus, the project's implementation could be examined both over its breadth currently and in depth historically.
In addition, the biennial audit would fold in programmatic considerations.
In October, 1982, the NRC advised the Company that the.
INPO evaluation to be carried out by MAC would not meet the agency's independence criteria.
Therefore, the MAC study is no.-
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longer considered a formal part of the Company's independent j
review program.
The INPO SIE study was carried out by Management Analysis Company (MAC) during late 1982.
The results have been transmitted to the Company and the NRC.
Project management has reviewed and responded to the findings.
Appropriate corrective actions have been completed to or are underway and have been evaluated by MAC and overviewed by INPO for adequacy.
The results of the MAC study have been discussed with the NRC Staff and provided to the TERA Corporation, which was selected to conduct the Independent Design Review.
As a part of the formulation of the construction completion program, the Company later added another element to its third-party review program, consisting of the CIO.
This activity was modeled to be similar to the construction overview underway in the soils area.
The following describes, in some detail, the two non-soils elements of the independent third-party review as presently constituted, the IDV and the CIO.
A.
Indeoendent Design Verification The first part of the third party review program is an IDV of all aspects, historical and current, of selected safety-related systems.
The IDV program proposed in my October 5 letter was to consist of a " vertical slice" independent review of the design and some aspects of the construction of the Midland Unit 2 Auxiliary Feedwater System in order to. ensure the system's capability of functioning in accordance with its safety design '
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i bases and to ensure that applicable licensing commitments have i
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been properly implemented.
The TERA Corporation was selected as the independent contractor to carry out the program.
On October 25, 1982, the Company met with NRR and Region III personnel to, among other things,. discuss the l
Company's proposed IDV program, and the process TERA would use'to I
report its findings to the NRC Staff.
On December 3, 1982,-I sent a letter to Messrs. Denton and Keppler-which-responded to r
certain questions raised by the Staff, and specifically expanded the scope of the IDV by increasing the construction coverage and by adding an additional system (Attachment 6).
Subsequently, on l
I February 8, 1983, a public meeting was conducted in Midland, Michigan at which time additional details concerning the IDV f
program were presented to the NRC Staff and the public.
TERA l
provided further details about the IDV program to the NRC Staff i
by a transmittal dated February 9, 1983.
l 1.
TERA Qualifications 1
The TERA Corporation is highly qualified to carry out f
l the IDV.
TERA specializes in providing consulting services for all areas of the nuclear industry. Before deciding to retain l
TERA, Censumers Power reviewed the qualifications of three i
i i
potential contractors.
TERA was selected based upon the strength j
of its technical competence, quality assurance program and direct
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experience with independent design verification assessments at l
such nuclear construction projects as Diablo Canyon, Grand Gulf and Palo. Verde.
The qualifications of the TERA Corporation and :
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the TERA Personnel to be assigned to the IDV team were discussed at the October 25, 1982 meeting with the NRC Staff.
j The TERA team assigned to the Midland IDV include personnel experienced in system design in the areas of mechanical, electrical, structural and thermal hydraulic l
l evaluations.
The Senior Manager for the TERA team, I
Mr. John Beck, Vice President of TERA, has served as the Chief Operating Officer and Executive Vice President for Vermont Yankee, and also as the Director of Engineering responsible for the supervision and management of Yankee Atomic Electric Company's plant, reactor and environme'ntal engineering departments.
2.
TERA Independence The TERA Corporation and the personnel assigned to the IDV team meet the independence criteria established by Commissioner Palladino in his letter of February 1, 1982, to Representative John Dingell and called out in the Company's contract with Tera, Contract No. CP10-8782, dated Norsmber 18, 1982.
TERA and the individuals assigned to the IDV have attested to their independence in affidavits supplied to the NRC Staff and attached to Mr. Howard A.
Levin's letter to Mr. Keppler and Mr. Eisenhut, dated March 18, 1983, (Attachment 7).
l Specifically, neither TERA nor its personnel assigned to perform the IDV at Midland have had any direct previous involvement with the Midland activities being reviewed by TERA.
l TERA and its personnel asesigned to perform the IDV have not been
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previously hired to perform the design, construction or quality work on the Midland Project.
The personnel assigned to the Midland IDV have not been previously employed by Consumers Power Company within the last three years.
Further, the TERA personnel assigned to the IDV do not have household members employed _by Consumers Power Company, do not have relatives employed by l
Consumers Power in a management capacity, and do not own or control significant amounts of Consumers Power Company stock.
3.
Scope The IDV will consist of an evaluation of historical and current aspects of the design and construction of the Midland l
Unit 2 Auxiliary Feedwater System, the diesel generator electric power system and the habitability aspects of the control room HVAC.
The scope of the design portion of the review consists of the following:
Review of design criteria and commitments 7,eview of implementation documents Review of calculatione and evaluations Combination of calculations or evaluations Evaluation of drawings and specifications The construction elements to be reviewed will consist of the following:
Review of supplier documents Review of storage and maintenance documents 1 - -
s i
Review of construction installation documents Review of selected verification activities Verification of physical configuration The scope of the design review being perform by TERA j
may expand to include additional areas of other systems to accommodate design review findings with generic implications.
l Similarly, construction review findings with generic implications will be provided to the independent third-party contractor performing the CIO (see below at p.
25), who will factor such findings into the performance of its responsibilities.
4.
Activities to Date The TERA team assigned to the IDV was on-site and began the design verification for the Auxiliary Feedwater System on November 2, 1982.
To support the design verification, Consumers Power and Bechtel have provided TERA with the pertinent FSAR chapters, drawings, specifications and design calculations.
In addition, Consumers Power and Bechtel have oriented the IDV team as to the organizations involved with the Midland Project, each organization's responsibilities and provided the IDV team with procedures manuals.
The de;ign review of the Auxiliary Feedwater System continues.
As part of this assessment, TERA has reviewed the Section 50.55 (e) reports and the nonconformances related to this system.
The design reviews of the diesel generator electric power system and habitability aspects of the control room HVAC t
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have not yet begun.
These two systems were only recently 1
determined to be appropriate for IDV assessment.
I was informed of this determination by a letter from Mr. Eisenhut to myself, dated March 22, 1982 (Attachment 8).
The construction verifi-cation portion of the IDV will not commence in detail until the Construction Completion Program Phase 1 activities to determine the installation and inspection status of these systems have been implemented.
5.
Reporting and Communication
.)
As of the date of this testimony, the TERA Corporation will communicate the results of the IDV to the NRC and Consumers Power through the issuance of " findings" and the submission of a final report.
This procedure was set forth in the TERA Corporation's Project Quality Assurance Plan which was issued on November 11, 1982, and submitted to the NRC Staff and Region III on February 9, 1983.
The Company has received a letter dated March 28, 1982, from Mr. Keppler of Region III which contains a protocol for 1
communicating within the IDV (Attachment 4).
The Company has instructed TERA to prepare a detailed procedure embracing'the
]
concepts of the protocol.
B.
Construction Implementation Overview The other major component of the third-party review program for non-soils activitiec is the Construction Implementa-tion Overview (CIO) which will consist of an independent third-party observing and evalur. ting the construction activities 24 -
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being performed at the Midland job site.
The purpose of the CIO is to ensure that site work is being performed in accordance with the appropriate procedures and requirements and that the commit-ments made in the CCP are being fulfilled.
The decision to initiate the CIO was first described to the NRC as part of the initial presentation of the CCP concept on December 2, 1982.
In my letter to Mr. Keppler dated January 10, 1983, (Attachment 1), which conveyed the description of the CCP to the Region III NRC Staff, the Company stated that an independent third party would evaluate the CCP work activities.
1.
Stone and Webster Qualifications By a letter to James W.
Cook from Region III. dated March 28, 1983, the NRC Staff requested Consumers Power Company to recommend a contractor tc perform the CIO and submit a pro-posal defining the scope of the contractor's responsibilities (Attachment 4).
On April 6, 1983, Consumers Power responded to the NRC Staff Region III recommending that Stone and Webster Engineering Corporation perform the CIO (Attachment 3).
In preparing to select a party to conduct the CIO, the Company I
considered Stone and Webster and the TERA Corporation, because each had previously been selected to conduct an independent design or construction review at Midland, was familiar with procedures at the site and could quickly and efficiently gear up for a further review effort.
The Company had considered both candidates qualified, but, decided that the Stone & Webster proposal was superier based primarily on the experience of team.
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personnel and the depth of organizational resources within Stone
& Webster to support the program.
In addition, the Company believed that the TERA Corporation would not be acceptable because Region III held the opinion that the CIO could possibly interfere with the IDV TERA is now conducting.
Stone and Webster is a highly respected engineering construction firm with considerable nuclear power pl'nt design a
and construction experience.
Stone and Webster has acted as engineer-constructor of a number of large nuclear power projects.
As a large nuclear architect-engineer, Stone and Webster has the necessary pool of competent personnel to draw from in the many disciplines involved in the CIO.
In addition, Stone and Webster has specific experience in conducting independent design reviews at Diablo Canyon and Indian Point 3.
The Stone and Webster team assembled for Midland will include personnel experienced in quality assurance / quality control and construction activities in the electrical, mechanical, instruments and controls, and special process areas.
The Program Manager for the CIO, Mr. W.
McKay is eminently qualified for this assignment.
He has over 25 years experience in power plant construction projects at Stone and Webster.
Prior to this assignment, Mr. McKay had served as the Resident Manager at Millstone Nuclear Power Station Unit 3 for Northeast Utilities Service Company at Waterford, Connecticut.
As such, he was Stone and Webster's primary manager, responsible for directing all of the Company's activities at that site.
He also has experience as -
4-,.
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l a superintendent of construction for two 815 MW units at Surrey, Virginia.
l 2.
Stone and Webster Independence i
j The Stone and Webster Corporation has affirmed that, in i
accordance with the criteria set forth in Chairman Palladino's I
letter, it is independent from Consumers Power Company.
Specifically, neither Stone & Webster, nor its 1
1 personnel assigned to perform the CIO work at Midland, have had t
j any direct previous involvement with the Midland activities being i
j reviewed by Stone & Webster.
Neither Stone & Webster nor its I
personnel assigned to perform the independent assessment have j
been previously hired by Consumers Power Company to perfcrm the i
Midland design, construction, or quality work relative to the I
items under review.
The personnel assigned to this independent j
assessment have not been previously employed by Consumers Power 1
i Company within the last three years.
Further, the Stone &
j Webster personnel assigned to the assessment project do not have I
household meubers employed by Consumers Power Company, do not have any relatives employed by Consumers Power Company in a manager.ent capacity, and do not own or control significant amounts of Consumers Power Company stock.
4 1
3.
Scope The Stone & Webster program contains the following major elements comprising the CIO:
a.
Development of an assessment program and preparation of a Project Quality Plan,
)
o b.
Monitoring of the implementation of the Construction Completion Program An O'erview Evaluation c.
v The independent contractor will field a site team to monitor the effectiveness of the CCP and other site activities.
The team will perform two functions.
First, the team will assess the adequacy of and compliance with CCP procedures and inspection plans.
Second, the the team will review aspects of construction activities which relate to the, performance of the Quality Control Inspection Program.
The team will use special procedures, checklists, and sampling techniques to evaluate the following:
Adequacy of controls and practices in the Quality Assurance Program to determine that design information is incorporated in installed hardware; Conforraance of installed hardware to design information in specifications and drawing; Completeness of Consumers Power Company's and Bechtel's procedures regarding construction activities, personnel qualifications, training programs, and organizational practices; Compliance of Construction Completion Program Teams with prescribed procedures; Compliance of Quality Control personnel with applicable procedurcs; Compliance of construction activities with applicable procedures.
In my letter of April 6, 1983, (Attachment 3), to l
Mr. Keppler responding to a letter from Region III dated March 28, 1983, (Attachment 4), the Company expanded the scope of the CIO to include audits of the management reviews of the CCP described earlier in my testimany.
The Company alno committed
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not to proceed beyond these management reviews without the concurrence of the CIO independent reviewer.
4.
Reporting and Communication l
To satisfy its overview evaluation responsibilities,.
the independent contractor will hold weekly progress meetings on i
site with Consumers Power Company, its contractors and the NRC Staff.
At these meetings, the independent contractor will summarize the activities which the CIO site team has observed, the meetings they attended, the quality documents and records they have reviewed and the observations they have made.
In addition, the observations of the CIO site team will be submitted to a Senior Overview Committee, comprised of Senior management of the independent contractor, on a monthly basis.
I Further, programmatic observations of a serious nature will be submitted immediately to the Committee for review and evaluation.
i If, upon review, the Committee feels the observations raise significant concerns, the observations will be reported to Consumers Power Company and the NRC.
After six months of CIO operation, the Midland Project's cumulative performance will be evaluated.
The indepen-dent contractor will submit a report summarizing its findings to the NRC and Consumers Power Company.
Based on these findings, Consumers Power Company will recommend to the NRC what modifica-tions, if any, should be made to the independent contractor's CIO responsibilities and reach agreement with the NRC on these actions.
The CIO will continue until Consumers Power ~ Company and -
1 the NRC have confidence in the adequacy of the Consumers Quality Assurance Program for the Midland Project.
IV.
Diesel Generator Building Inspection During the NRC's October-November 1982 team inspec-tions, results and findings were reported to the Company on a periodic basis.
Our initial understanding of the apparent implications of these findings were factors which enterec' into the Company's decision to institute the Construction Completion Plan.
A further significant result of the inspection-dealt with In-Process Inspection Notices (IPIN's).
On January 18, 1983, immediately after the NRC Staff advised us that weaknesses in the I
use of IPIN's, in their opinion, could have contributed to missed inspections, I asked Roy A. Wells to investigate all aspects of the issue and recommend corrective action.
The task force chartered by Mr. Wells carried out its charge as described in Mr. Wells' testimony and in Attachment 1 to the Response to the Notice of Violation (See Attachment 1 to the testimony of Mr. Bruce H. Peck).
The Company has also investigated and analyzed all specific findings of the NRC's team inspection, and has taken both generic and specific corrective steps.
These are described in Attachment 2 to the Response to the Notice of Violation and in Mr. Peck's testimony.
The Company's Response was, in my opinion, a comprehensive and candid presentation of the Company's findings l l
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and prcposed corrective actions, and is, I believe, an appro-priate basis for resolution of all matters identified during the inspection.
1 VI.
Conclusion In light of the measures which we have instituted to d
improve the Project's status assessments, systems construction, and quality assurance implementation, I believe that the Midland 4
Plant when completed will conform to NRC regulatory requirements.
5 My belief is based in part on the successful implementation of 2
the remedial soils quality ansurance program since December, 1982.
The remedial soils quality assurance program was carefully tailored to meet the specific requirements of that activity.
The j
Construction Completion Program likewise represents a major initiative by the Company in instituting an enhanced program for the balance of plant construction.
It is my expectation that the Construction Completion Program will assist the Company in s
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completing construction in an orderly manner and with satisfactory implementation of the quality assurance / quality control requirements.
3
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Company nu ~, - -~e<,,.1 r - :
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and Constructnan c.a..ieme : 1s45 w c Pera.n ao.a. Jeet.oa. m 4sses. min tes o4ss January 10, 1983
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I Mr J G Keppler, Administrator, Re'gion III l'
Nuclear Regulatory Com=ission l (, C 799 Roosevelt Road Glen Ellyn, IL 60137
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MIDLAND NUCLEAR C0 GENERATION PLANT f
MIDI >.ND DOCKET NOS 50-329, 50-330 CONSTRUCTION COMPLETION PROGRAM FILE 0655 SERIAL 20428 REFEPINCE LETTER TO J V COOK, DATED DECEMBER 30, 1982, FROM NRC REGION III REGARDING CONSTRUCTION COMPLETION PROGRAM l
j On December 2,1982, Consumers Power Company met with Mr Warnick and other i
membns of your staff to discuss the generd concept of our proposed Construction Completion Program.
The enclosure to th b letter documents in i
detai) the Construction Completion Program, as requested at the meeting rod in i
your follow up letter (Reference).
1 l
Since our meeting, the program has undergone considerable development and j
evolution.
Details have been supplied and more specific objectives and implementing methods have been established.
Further details are still being j
developed.
While the Company expects the Program, as presently constituted, to be a workable and sufficient framenc,rk for future action, revisions may be necessary as_ future needs and experience dictate.
The Construction Completion Program is a positive step in the overall edvancement of Project goals.
It represents the best efforts of Project c;ana gement, support and quality assurance personnel.
We believe it will produce an improvement in Project installation and inspection status, systems construction and QA implementation.
The quality verification effort should provide increased confidence of the NRC that the plant has been properly built.
Other aspects of the Program, including the measure to improve ongoing inspections and scheduling interfaces, should contribute to that result.
This Program, together with recent Consumers Power Company commitments regarding quality assurance and remedial soils work, can establish a basis for improved relations betwee'n the Company and the NRC Region group assigned to inspect Midland.
The Construction Completion Program demonstrates the Company's responsiveness to both NRC concerns and the particular needs of this Project.
j It is our expectation that'the Program, created out of a desire to enhance the
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J orderliness and quality of construction, will achieve its intended purpose and i
lead to the successful " completion of construction" of the Midland Plant in i
accordance vith regulatory requirenents.
We hepe that this sub=ittal fulfills your re. quest for written infor=ation regarding the Construction Completion Program.
Consumers Power Co=pany is prepared to support the public meeting proposed for January 26, 1983 in Midland, Michigan.
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CC Atomic Safety and Licensing Appeal Board CBechhoefer FPCowan, ASLB i
JHarbour, ASLB 1
LSHoad, NRC Y*1 Cherry RWHernan, NRC RJCook, Midland Resident Inspector FSKelley KRDenton, NRC WEMarshall VDPaton, NRC WDShafer, NRC RFWarnick, NRC 1
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JEErunner, M-1079 RCBau=an, M-14-314A VEBird, P-14-418A KRKline, P-14-3143 GSKeeley, P-14-113B ARMollenkopf, P-14-209A DBMiller, Midland 4
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F%3uck=an, P-14-113A j
DMBudzik, P-24-517A FCVilliam, IL&B EIMiller,'II43 DFlewis, Bechtel DFJudd, B&W RWHuston, Washington JRSchaub, P-14-305 1
DJVandeWalle, P-24-614A' Bob Lee e
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CONSUMERS POTr.R COMPAhT Midland Units 1 and 2 Docket No 50-329, 50-330 Tetter Serial 20428 Dated January 10, 1983 At the request of the Coc=ission and pursuant to the Atonic Energy Act of 1954, and the Energy Reorganization Act of 1974, as aciended and the Coc=ission's Rules and Regulations thereunder, Consumers Power Company submits its Construction Co=pletion Program.
CONSUMERS POrr.R COMPAhT 1
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M J
Cook, Vice tresident Proj ts, Engineering and Construction Sworn and subscribed before me this L day of
+,,no.<>,1993 a
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aztua 0 dha Notary Publit4 Bay County, Michigan My Commission Expires 8 - t/- f [o t
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CONSLE RS PO'.T.R COMPAhT Midland Units 1 and 2 Docket Na 50-329, 50-330 Letter Serial 20428 Dated Janu.t ry 10, 1983 At the request of the Com=ission and pursuant to' the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as acended and the Com=ission's Rules and Regulations thereunder, Consumers Power Company submits its Construction Co=pletion Program.
CONSLE RS POWER COMPAh7 By
/s/ J W Cook J W Cook, Vice President Projects, Engineering and Construction Sworn and subscribed before me this day of
/s/ Patricia A Puffer Notary Public Eay County, Michigan My Com=ission Expires
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Construction Completien Program Executive Su==a ry The Construction Cocpletion Program has been formulated to provide guidance in the planning and manage =ent of the design and quality activities necessary for co=pletien of the construction of the Midland Nuclear Cogeneration Plant.
Construction completion is defined in this Plan as carrying all syste=s to the point they are turned over to Consumers -Power Company for component checkout and preoperational testing.
The Construction Completion Program does not include the Remedial Soils Program which is treated in separate interactions between Consumers Power Co=pany and the Nuclear Regulatory Commissich.
Background
The Construction Co=pletion Program was developed in response to a nu=ber of canagement concerns that have been identified during the period preceding the initiation of the Program.
The Midland Project had been proceeding at a high level of activity as it approached completion.
The final transition from area construction to syste= completion, using punch lists, has been difficult for most nuclear projects.
The Midland Project has not escaped these difficulties which have been co= pounded due to the congested space and the continuing numerous design changes, both generally attributable to the age of the Project.
These factors lead to the need for improved definition of work status, increased e=phasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of syste=s for short-term milestones and increased effort to complete engineering ahead of field installation.
The Midland Project has been criticized by the NRC regional office as not having met their expectations for implementation of the Project's Quality Assurance Program.
The result has been that the Project management has too often, during the past few months, been in a reactive rather than proactive posture with regard to quality assurance matters.
In recognition of these conditions, management has concluded th:t a change in opproach wcs needed to effectively complete the Project while maintaining high quality standards.
Objectives The development of the Program has considered the Project's current status and recent history and attempts to address the underlying or root causes of the problems currently being experienced.
In order to develop the Program the following overall objectives were
- established under three general headings.
The Program must:
Improve Project Infor=ation Status By:
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Preparing an accurate list of to go work against a defined baseline.
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=il2S2-3aE9b200 l
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Bringing inspections up-to-date and verifying that past quality issues have been or are being brought to resolution.
Maintaining a current status of work and quality inspections as the Project proceeds.
I= prove Imolementation of the QA Program By:-
Expanding and consolidating Consumers Power Company control of the quality function.
Improving the primary io<pection process.
Providing a unifor= understanding of the quality requirements among all parties.
Assure Efficient and Orderly Conduct of the Project By:
Establishing an organizational structure consistent with the remaining work.
Providing sufficient numbers of qualified personnel to carry out the program.
Maintaining flexibility to modify the Plan as experience dictates.
Description The Construction Completion Program entails a number of major changes in the conduct of the final stages of the construction process and can be described in summary as a two-phase process.
First, after certain necessary preparations, the safety-related systems and areas of the plant will be systematically reviewed.
This first phase will be carried out on an area-by-area basis, but will be accomplished mainly by teams organized with systems responsibility and a separate effort to verify the completec work.
The product from this phase of the program will be a clear status of remaining installation work and a current inspection status which provides quality verification of the existing work.
The teams organized to carry out this first phase will continue to function in the second phase as the responsible organ'zational units to the complete the work.
i In order to achieve its complete, set of objectives, the Program contains a number of activities and elements that support and are linked to the two major phases described above.
The major components of the Plan, which are discussed in more detail in the balance of this report, can be described as follows:
A significant reduction in the construction activity in the safety-related portion of the plant, material removal and a general cleanup will be carried out in preparation for installation and inspection i
status assessment and quality verification activities.
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A review will be made of equipment status to assure that the proper lay-up precautions have been implemented to protect the equipcent until the installation work is co=pleted.
l The integration of the Bechtel QC function into the Midland Project Quality Assurance Department (MPQAD) under Consumers Power Company management vill be completed.
The Consumers Power Company is carrying out recertification program of Bechtel QC inspectors, and a review of the inspection procedures to be utilized.
4
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The system e;wpletion teams will be organized, staffed and trained according to procedures developed to define the team's work process.
The systems completion teams will 1) accomplish installation and J
inspection status assessment, 2) perform systems construction completion and construction quality performance and 3) determine that all requirements have been met prior to functional turnover for test and operation.
Quality verification of ccepleted work will be carried out in parallel with installation and inspection status activities of the system completion teams.
A series of management reviews will be carried out to carefully monitor the conduct of the Program and to revise the plan as appropriate.
Review and resolution will proceed on outstanding issues related either to QA program or QA program implementation as raised by the NRC or third party overviews of the Project.
Third party reviews will be undertaken to monitor Project performance and to carry out the NRC's requirements for independent design verification.
Schedule Status The Program was initiated on December 2, 1982 by limiting certain ongoing safety-related work and starting preparations for the phase-one work of status essessment and quality verification activities.
Since the Program also has incorporated a number of commitments made to the NRC during the past few conths, activities in s'upport of these commitments such as QC integration into MPQAD and the recertification of QC inspectors, had been initiated prior to December.
Status and schedules for each element of the Plan are enumerated in the text.
In general, preparation for the Phase 1 activities are underway and will continue through' January.
A pilot team to develop the procedures and training require =ents will be initiated during January.
It is expected that the first mi12S2-3'89b100
areas to undergo Phase I status assessment will be defined and teams mobilized during March.
4 Quality verification of ce=pleted vork will start in late January or early February.
1 The Program provides for the Phase I results on a system or partial system to be reviewed and evaluated prior to initiating Phase 2 system completion work on that system or partial system.
Management will monitor both process readiness and Phase 1 evaluation results.
The major areas of continuing safety-related work are NSSS construction as performed by B&**' Construction Co, HVAC work under the Zack subcontract, the i
i.
Remedial Soils Program and post-turnover punch list work released to Bechtel S
construction by Consumers Power Company.
The Zack work is currently limited l
ntil a recently identified question on welder certification is resolved.
During the implementation of the Program in 1983, the NRC Resident Inspectors can use the Plan to monitor safety-related construction activities at the Since a substantial portion of the Plan directly relates to commitments site.
made to NRC management, Consumers Power Company intends to schedule periodic j
reviews of Program status and progress with the NRC.
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TABLE OF CONTENTS i
Section Title g
t 1.0 Introduction 1
2.0 Preparation of The Plant 5
t 3.0 QA/QC Organization Changes 6
l 4.0 Program Planning 8
5.0 Program Implementation 13 6.0 Quality Program Review 15
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7.0 Third Party Reviews 16 8.0 System Layup 19 9.0 Continuing Work Activities 20 i
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4
1.0 INTRODUCTION
4 i
The Construction Co=pletion Program has been formulated to provide guidance in j
' the planning and quality activities necessary for completion of the construction of the Midland Nuclear Cogeneration Plant.
Constructien 4
ce=pletion is defined in this Plan as carrying all systems to the point they j
are turned over to Consumers Power. Company for c6mponent checkout and preoperational testing.
The Construction Completion Program does not include the Remedial Soils Program which is treated in separate interactions between j
Consumers Power Co=pany and the Nuclear Regulatory Commission.
The Construction Completion Program wi'll be referred to as the Program in this document which contains the Plan for Program development and implementation.
Background
(
- The Construction Completion Program is being developed in response to a number of management concerns that have been identified during the period preceding the initiation of the Program.
The Midland Project had been proceeding at a high level of activity as it approached completion.
The final transition from
,l area construction to system completion, using punch lists, has been difficult l
for most nuclear projects.
The Midland Project has not escaped these j
difficulties which have been compounded due to the congested space and the-i continuing numerous design chan'ges, both generally attributable tb the age of the Project.
These factors lead to the need for improved definition of work j
status, increased emphasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of systems for short-term milestones and increased effort to complete engineering ahead of field installation.
].
i i
The Midland Project has been criticized by the Nuclear Regulatory Co= mission l
regional office as not having met their expectations for implementation of the j
Project's Quality Assurance Program.
The result has been that the Project i
management has too often, during the past few months, been in a reactive rather than proactive posture with regard to quality assurance matters.
)
In recognition of these conditions, Consumers Power Company has concluded that j
. change in approach is needed to effectively complete the Project while.
l eaintaining high quality standards.
Objectives t
The development of the Program has considered the Project's current status and I
recent history and attempts to address the underlying or root causes of the problems currently being experienced.
In order to develop the Program, the following overall objectives were established under three general headings.
The Program must:
Improve Project Information Status Bv:
Preparing an accurate list of to go work against a defined baseline.
i ci;2i2 '10da-66-102 4
3.
Bringing inspec*. ions up-to-date and verifying that past quality issues have been or are being brought to resolution.
Maintaining a current status of work and quality inspections as the Project proceeds.
Impreve Implementation of the QA Program By:-
Expanding and consolidating Consumers Power Company control of the quality function.
Improving the primary inspection process.
Providing a uniform understanding of the quality require =ents among all parties.
Assure Efficient and Orderly Conduct of the Project By:
Establishing an organizational structure consistent with the remaining work.
Providing s.ufficient numbers of qualified personnel to carry out the Program.
Maintaining flexibility to modify the Plan as experience dictates.
PLAN CONTENTS The Program was initiated on December 2, 1982 by limiting on going work on Q-systems to pre-defined tasks and preparing the major structures housing Q-systems for an installation and inspection status assessment and verification of completed work.
The relationship of the major elements of the Plan is shown in Figure 1-1.
The sections of the Plan address the following major activity areas:
PREPARATION OF THE PLANT (Section 2.0)
The buildings are being prepared for a status assessment and verification of completed work.
QA/QC ORGANIZATION CHANGES (Section 3.0)
A new QA organization tha.t integrates the QA and QC functions under a Consumers Power Company direct reporting relationship is being established.
As a part of this transition, the Bechtel QC inspectors f
are being recertified to increase confidence in the quality inspection performance.
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l ci:252-4106a-66-IC2
PROGRAM PI.ANNING (Section 4.0)
The overall Plan for the Program is being developed in two major phases.
The first phase includes:
A team organization assigned on the basis of systems is being developed to determine present installation and inspection status.
The inspection status assessment includes performing inspections on completed work to bring them up to date.
A closely coordinated effort involving the constructicn contractor and Consumers Power Company (QA/QC, testing and construction) will improve quality perfor=ance.
The quality verification of completed work will be based, in part, on a sampling technique using re-certified inspectors as describec in Section 3.0.
The second phase includes:
Following installation and inspection status assessment the team organization will retain responsibility for systems completion work.
The QC inspection process of new work will be' integrated with the systems completion work to ensure adequate quality performance.
PROGRAM IMPLEMENTATION (Section 5.0)
The first phase implementation of the Program will be initiated with a review of the process, procedures and team assignments that will be used.
The plan for verification of completed work will be reviewed separately.
The teams will conduct the installation and inspection status assessment; verification of completed and inspected work will proceed, as planned, in coordination with the team effort.
Following phase I completion of the first work segment, a management review of the plan effectiveness will be made.
In second phase Program implementation, the assigned team will plan and schedule the remaining work needed for completion including QC inspections.
QUALITY PROGP.AM REVIEW (Sect-ion 6.0)
The adequacy and completeness of the quality program will be reviewed on an ongoing basis, taking into consideration questions raised by NRC inspections and findings by third party reviewers.
The results of these reviews will be considered as part of the management review that are a part of the Program implementation (Section 5).
mil 282-4106a-66-102
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THIRD PARTY REVIEWS (Section 7.0)
I Independent assessments of the Midland Project will provide management and NRC with evaluations of Project perfor=ance.
4 SYSTEM LAY-UP (Section 8.0) t i
The on going work to protect plant equipment and systems will be j
augmented as necessary to provide adequate protection during i
implementation of this Plan.
4 l
CONTINUING WORK ACTIVITIES (Section 9.0) i Work on Q-Systems has been limited to specifir activities.
This i
limitation per=its i=portant work to proceed while allowing building
]
preparation for status assessmert and verification activities.
SUTiARY Each section of this Plan presents detailed objectives, a description i
i of the activity involved, and a schedule for achieving major milestones.
The Program, however, is still in an evolutionary state and revisions to the Plan may be necessary as Consumers Power Company l
gains experience in the implementation of Program elements.
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mil 282-4106a-66-100
_ ~... _ _ _ _ _ _ _.. _ _. _ _ _ _ _. _. _ _ _ _ _ _ _ _. _. _
FIGURE 1-1 CONSTRUCTION COMPLETION PROGRAM SCHEMATIC PHASE 1 PHASE 2 DEC TION PLANNING lMPLEMENTATION PLANNING IMPLEMENTo e
PREPARATION 2
OF THE PLANT OA/OC 3
F1EDRGANIZATION
?
PHASE 2 PHASE 1 4
PLANNING PLANNING i
i VERIFICATION MANAGEMENT op l
REVIEW COMPLETED ~
EVALUATION SYSTEl IN8PECTIONS COMPLEl AND 5
IN8TALLATION REVIEW W O Ri<'
MANAGEMENT
-.AND REVIEW INSPECTION i
STATUS n
A i
i O
QUALITY PROGRAM REVIEW t
j 7
TillRD PARTY REVIEWS 1
4 8
SYSTEM LAY UP
^
n CONTINUING WORK ACTIVITIES l
2.0 PFIFARATION OF T'C PLAh7 l
2.1 Introduction The preparation of the Plant will clear the auxiliary, diesel generator and containment buildings and the service water pump i
structure of materials, construction tools and equipment and temporary construction f acilities.
i 2.2 Objective i
To allow improved access to systems and areas for the Program activities.
2.3 Description i
The preparation activities minimize obstacles and interferences for the Program activities.
This is being accomplished through the following steps.
1.
Limitation of Q-work to activities and areas defined in Section 9 resulting in substantial work force reduction.
j 2.
Removal and storage of construction tools and equipment, and te=porary construction facilities (scaffolding, etc) from the i
buildings identified in Section 2.1.
3.
Remeval, control and storage of uninstalled materials from the buildings identified in Section 2.1.
4.
Appropriate housekeeping of all areas following material and equipment removal.
j The preparation for each area vill be complete before initiating
~
further Program activity.
The on going work described in Section 9 i
will continue as scheduled during the preparation.
j 2.4 Schedule Status The preparation of the Plant began on December 2, 1982.
It will be complete by January 31, 1983.
I r.il:52-4106b-66-102
3.0 OA/QC ORGANIZATION CHANGES 3.1 Introduction The Consuner Power Company's Midland Project Quality Assurance Department (MPQAD) is being expanded to assune direct ccatrol of Bechtel QC activities.
The new organization and the plan for the transition are described below.
The transferred QC Inspectors will be recertified as part of this transition.
3.2 Obiectives Establish New QA/QC Organization Establish an integrated organization which includes the transition of Bechtel QC to MPQAD while accomplishing the following objectives:
1.
Establish direct Consumers Power Company control over the QC inspection process.
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2.
Establish the responsibilities and roles of the QA and QC Departments in the integrated organization.
3.
Use qualified personnel from existing QA and QC departments and contractors to staff key positions throughout the integrated organization.
Recertify QC Inspectors Ensure that those Quality Control inspection personnel transferring to MPQAD from Bechtel will be trained and recertified in accordance with MPQAD Procedure B-3M-1.
3.3 Description Establish New QA/QC Organization A new organization will be implemented under Consumers Power Company and wil; be described in appropriate Topical Reports (CPC-1A and BQ-TOP-1) 4 ud quality program manuals (Volume II, BQAM and NQAM).
Changes to these documents will be submitted to NRC.
Features of the new organization include:
1.
Lead QC Supervisors report directly to a QC Superintendent who reports to the MPQAD Executive Manager.
Any required support from Bechtel Corporate QC and QA functions (except ASME N-Stamp activities) is provided at the level of the MPQAD Executive Manager.
2.
The MpQAD Executive Manager will review the perfor=ance of lead personnel in his department.
ni.252-4106c-66-102 I
l
m 3.
QA will develop and issue Quality Control inspection plans and be responsible for the technical content and requirecents of i
such plans.,QC will be responsible to imple=ent these plans.
4.
QA will continue to monitor the Quality Control inspection process to insure that program requirements are satisfactorily implemented.
5.
MPQAD will continue to use Bechtel's Quality Control Notices Manual (QCNM) and Quality Assurance Manual (BQAM) as approved j
for use on the Midland Project.
6.
ASME requirements imposed upon a contractor as N-Stamp holder will remain with that contractor.
MPQAD QA will monitor the implementation of ASME requirements.
An organization chart (Fig 3-1) showing reporting relationships in the new organization is attached.
Recertify QC Inspectors The training'and recertification process for QC inspectors has been revised to include commitments made during the September 29, 1982 public meeting with the NRC.
Those inspectors transferred from Bechtel to MPQAD will be trained and examined in accordance with MPQAD Procedure B-3M-1.
Upon satisfactory completion of the training and examination requirements, inspection personnel will be certified for the Project Quality Control Instruction (s) (PQCI(s))
they are to implement.
Inspection personnel will be certified on a schedule which supports ongoing work and system completion team activities.
3.4 Schedule Status Establish New Organization Adv se NRC of the structure of the integrated organization. 12/15/82 Transfer the Bechtel QC Organization to MFQAD.
1/17/83 Submit changes to Topical Reports and quality program manuals to 2/17/83 NRC.
Recertify QC Inspecto~rs Specify the revised training and' examination 10/25/82 require =ents for certification (B-3M-1).
4/01/S3 Complete recertification ti:2E2-4106c-66-102
FIGURE 3-1 I
MPQAD ORGANIZATION DECllTEL MIDLAND PROJECT OC PROGRAMMATIC QUALITY ASSURANCE DEPT i
EXECUTIVE MANAGER ASME l
1 1
QUALITY ASSURANCE I!
MANAGER
[
(OFFSITE)
[
I SITE SITE ADMINISTRATIOA HVAC OA/OC SOILS OA/OC
& TRAINING SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT e
NOTE: Tills CHART IS INTENDED TO INDICATE
~~"
ONLY THE INTEGRATION OF THE ELECTRICAL PIPE / MECH /WE civil BECHTEL QC FUNCTION.
OC OC (ASME)
OC L._L
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4:0 PROG?.AM. PLANNING l
i 4.1 Introduction I
I The detailed planning for the major portion of the Construction Completion Program is described in this section.
Planning in support of Phase 1 consists of the activities.to set 2p a team organization to assess the installation and inspection status of Q-systems within major structures (Section 4.2) and to verify the adequacy of completed inspection effort (Sectica 4.3).
The Phase 2 planning effort covers the process and procedures that will be used by the team organization for systems completion work (Section 4.4).
The procedures to integrate the quality program requirements with continring systems completion work will be developed (Section'4.5).
4.2 Team Organization (Phase 1) 4.2.1 Introduction Organize and train teams and prepare procedures for an installation and inspection status assessment.
4.2.2 Objective 1.
Establish and implement a team organizatien ready to inspect and assess systems for installation and inspection status.
2.
Develop the organizational processes and procedures necessary to implement the team approach for status assessment.
3.
Provide training to ensure required inspection and installation status assessment activities are satisfactorily performed.
4.2.3 Description 1.
The team organization structure vill vary depending upon the assigned scope of work.
The organization will consist of a team supervisor and personnel as appropriate from field tagineering, planning, craft supervision, project engineering, MPQAD and Consumers Power Company Site Management Office.
The team may be augmented by procurement personnel, subcontract ecordinators and turnover coordinators.
Teams will be assigned a specific scope of work and held accountable for status assessment and overall completion within this scope.
The scope includes the requirements
=il282 '106d-66-102
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i to develop e viable working schedule and insure early identification and resolution of problem areas.
Project l
processes and procedures will be reviewed and modified to j
incorporate the team organization.
The team MPQAD 1
representative is responsible for providing the QA/QC support for the team.
He receives scheduling direction 1
from the Team Supervisor and technical direction from MPQAD.
For his team's work, he analyzes the quality requirements and plans the QC activities to integrate j
them with the team effort.
He assures the necessary PQCI's and certified inspection personnel are available for performing the inspections.
He maintains cognizance of the quality status of the verification activities.
I The Washington Nuclear Plant #2 (VdP-2) team organization will be used as a starting point for a Midland specific approach.
j A pilot team or teams will be utilized to develop and q
test prorasses and procedures during the development stage to assure that Program objectives can be met. This will also provide practical field input to assure that j
efficient and workable methods are used.
i ieam members will be physically located together to the j
extent p: 2cticable to improve communication,' status j
assessment, problem identification and problem l
resolution.
i l
2.
Traicing for inspection and installation status
)
assessment will be provided to team members.
It will include responsibilities, reporting functions, indoctrination of project processes, and procedures and j
familiarization with the project quality program to ensure effective implementation.
i l
3.
A separate organization of design engineers (presently existing) will coordinate spatial interaction, review and j
examination with the activities of these teams, i
I 4.2.4 Schedule Status j
Designate pilot team.
1/21/83 4i Complete grouping of systems for assignment 2/28/83 j
to teams.
4
)
Complete assignment of team supervisors and 3/31/83 j
members to designated systems, i
i i
i i
mil 282-4106d-66-102 4
4.3 Quality Verification (phase 1) 4.3.1 Introduction l
The verification program is the activity undertaken to determine, using a variety of methods, that the inspections performed on completed work were done correctly.
1 4
4.3.2 Objectives 1
l The objectives of the verification program are to:
4 l
Review existing PQC1's and revise as necessary to assure that:
)
a '.
Attributes important to the safety' and reliability of specific co=ponents, syste=s, and structures are identified for verification.
b.
Accept / reject criteria are clearly identified.
1 j
c.
Appropriate controls, methods, inspection and/or j
testing equipnent are specified.
d.
Requisite skill levels are required per ANSI N45.2.6 or SNT-TC-1A.
J Develop and implement verification inspection plan for 7
j completed work which considers:
j a.
Re-inspection of accessible items.
i 4
b.
Review of documentation for attributes determin~ed to be inaccessible for re-inspection.
i c.
Sampling techniques using national standards.
i, 4.3 S Description
/
i PQCI's will be revised as necessary to meet the objectives in Section 4.3.2.
Verification of the quality of accessible j
completed contruction, which has been previously inspected j
will be performed by use of sampling plans based on MIL-S-105D (1963) or other acceptable methods.
Attributes determined to be inaccessible for direct re-inspection due to embedment or the ' status of completed construction or i
installation (eg, weld preparation of completed welds, reinforcement in placed concrete, installed anchor bolts, i
etc) will be verified as appropriate, by examination of.
records.
i ci".2E2-4106d-66-102
~
i 4.3.4 Schedule Status Co=plete review and revision of PQCI's.
(Date to be determined.)
Establish verification inspection plan for completed work.
(Date to be deter =ined.)
l
]
4.4 System Co=pletion Planning (Phase 2) 4.4.1 Introduction i
Establish the processes for system completion, prepare procedures and expand training to cover systems completion work.
4 I
4.4.2 Objective l
The objectives of the systems completion planning are as follows:
J Establish processes and interfaces for system completion.
Prepare procedures defining tasks of each system i
completion" team.
Train team members by expanding upon training received previously for inspection and status assessment.
Establish scheduling methods to be used during system completion activities.
4.4.3 Description The team organization (developed in Section 4.2) and the processes and procedures will be extended to accomplis ~n the systems completion work.
Training will be conducted to assure that supervisors understand the team objectives and their role. Emphasis will be placed on completion of all work in accordance with the design requirements, the change control process.
used when the design must be modified, and changes to the established team processes and procedures.
4.4.4 Schedule Status Complete team preparation for systems completion work.
(Date to be determined.)
ci1282-4106d-66-102
'sA.
4.5 QA/QC Systems Co=pletion Planning (Phase 2) l i
l 4.5.1 Introduction l
The QA/QC systems completion activity covers the planning to support of system completion work.
4.5.2 Objectives E'stablish in process inspe' tion program and complete review e
and modification of PQCIs.
4.5.3 Description The QC in process inspection program will be directly coordinated with future installation schedules to insure that inspection. points, identified by MPQAD QA in the PQCI's, are integrated with the installation schedule.
The identifi-cation of applicable PQCI's and required inspection points will be used by system completion teams to insure that QC inspections are adequately scheduled into the process.
The system completion team quality representative will be responsible for providing the link between the system completion team and MPQAD to insure that quality requirements are satisfied.
PQCI's will be reviewed, and modified as necessary, to insure that proper attributes are being inspected, that inspection plans are clear and concise,"that inspection points are specifically scheduled with installation activities and that inspection results are properly documented.
MPQAD QA will be respons.ible for the PQCI review activity and will obtain assistance, as required, from other project functions, such as Project Engineering and Quality Control.
Revised PQCI's will be used to conduct inspection of future installation activities.
4.$. 4 Schedule Status Issue procedure for integrating inspection points into the construction schedule.
2/22/83 s_
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- 12252-4106d-66-102 6
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FIGURE 4-1 CONCEPTUAL TEAM ORGANIZATION
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SYS. TEAM SUPV.
PROJECT MPOAD i
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ouA IlEEllEGEttTATIVE
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PLANNER PROJ. ENGR.
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PROCUREMENT
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o 5.0 PROGRAM IMPI.EMENTATION 5.1 Introduction The implementation of the Phase 1 Construction Completion Program activities will be initiated after a management review of the overall process insures that Project performance and quality objectives have been addressed.
The Phase 1 work will then be carried out by the various teams in accordance with the procedures described in the preceding sections.
The installation and inspection status assessment of a system or partial system will be followed by a review of results by MPQAD and a second management review before initiating the Phase 2 systems completion wo,rk.
The Phase 2 work will then be initiated on that system or partial system.
5.2 Objectives The objectives to be met are:
Establish the present installation completion and quality status.
Integrate the construction and quality activities for all remaining work.
Improve performance in demonstrated conformance to quality goals l
in all system completion work.
5.3 Description Management Reviews Project management will conduct formal review of the plans for implementation activities prior to initiation of team activities for the 'hase I work.
These reviews will ensure that identified project management and quality issues have been adequately addressed by specific actions and that Program' objectives are met.
The reviews l
will cover the process for both 1) the verification of completed inspection activity and 2) the installation and inspection status activity.
-The installation and inspection status assessment will be performed l
on a system and/or area basis.
Phase 2 is initiated after a formal Project management review of the first status assessment results to evaluate implementation. effectiveness. After completion of this review, a work segment will be released for systems completion.
Subsequent status assessment results will be reviewed by site management prior to initiation of additional systems completion segments.
Reports will be made to Project management at regularly scheduled meetings.
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Phase 1 Impicm:ntatien The exi: ting installation and inspection status will be established in accordance with the plan presented in Section 4 Evaluate Phase 1 Results l
M?QAD will review the status assess =ent results to determine if any i
progra==atic or implementation changes must be made.
Verification scope 'will be adjusted, as necessary, based on evaluation results.
Also, the evaluation will check for reportability to the NRC (as required by 10 CFR 50.55(e)) and Part 21.
Phase 2 Implementation This activity starts systems complet on for turnover.
Work will be scheduled as installation and inspection status assessments are completed and revie'ved.
Correction of identified problems will be given priority over initiation of new work, as appropriate, an'd the system co=pletion teams will schedule their work based on these priorities.
5.4 Schedule Status Complete Management review and initiate implementation of plan for verification of completed inspections.
(Date t6 be dete rmined. )
Complete Management review and initiate implementation of plan for status assessment.
(Date to be deter =ined.)
Complete Management review of initial installation and inspection status results and initiate systems completion work.
(Date to be determined.)
l
=il2E2-t:06e-66-102 l
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e 6.0 QUAI.ITY PROGRAM REVIEV 6.1 Introduction The adequacy and completeness of the quality program is reviewed as part of the ongoing Project management attention to quality.
These reviews consider any questions raised by NRC inspections or findings raised by third party evaluations.
6.2 Obiective Address issues raised by internal audits, NRC inspections and third party assessments.
Program changes, if needed, will be evaluated and, as findings are processed, will be factored into the Project work.
6.3 Description Consumers Power Company believes Midland QA program is sound.
From time to time, questions arise on detailed aspects of the program or program implementatio,n The normal process of addressing these issues ensures that all necessary information is provided to NRC and that internal confidence in the program is maintained.
The recent inspection of the diesel generator building has raised several issues of programmatic concern.
These are in the areas of material traceability, design control process, Q-system related requirements, document control and receipt inspection.
Project management has directed that MPQAD provide an expeditious evaluation of these issues to be considered as part of the management review prior to initiation of Phase 2.
Once the NRC inspection report is received and specified item: are identified, these items will be addressed and resolved through the normal process of closing the insgettion findings.
Any corrective action or program changes will be implemented as appropriate in Project work on a schedule provided in the inspection report response.
The Project will also receive, from time to time, findings from third party assessments (Section 7).
These findings or recommendations may also result in program modification or adj us tments.
Corrective action taken by the Project will be implemented on a schedule stated in the response to these findings.
- r..~i2-4106f-66-102
UW 7.0 THIRD PARTY REVIEWS 1
7.1 Introduction j
This section describes third party evaluations and reviews that have been perfor=ed and are planned to assess the effectiveness of design and construction activity implementation.
Third party reviews being conducted as part of the Remedial Soils Program are not included in this activity.
7.2 Objectives To assist in improving Proje:t implementation and assessment of Midland design and construction adequacy, consultants will be utilized in order to:
~
Achieve a broad snapshot of current Project practices and performance in relation to a national program.
Provide continuous monitoring and feedback to Management of Proj ect perfor=ance.
Identify any activ,ities or organizational elements needing improvement.
Improve confidence (including the NRC's and the public's) in overall Project adequacy.
7.3 Description The use of consultants to overview Project design and construction activities with particular emphasis on construction is part of the effort to improve the Project's implementation of the quality program.
Specifically, the plan overview employs the use of consultants for three separate functions:
(1) To carry out a self-initiated evaluation (SIE) of the entire Project under the INPO Phase I program, (2) to utilize a third party overview of ongoing site construction activities to provide monitoring of the degree of implementation success achieved under the new program and (3) to j
l conduct a third party Independent Design Verification (IDV) Program.
1 1
1.
.The INFO self-initiated evaluation was planned. as part of an industry commitment to the NRC in response to concerns over nuclear plant construction quality assurance.
For the Midland SIE, the evaluation was contracted to be carried out entirely by third party, experienced personnel from the Management Analysis Company.
f (f.,
C-The evaluation was performed by a team of 1T consultants faciliar with the INPO criteria and evaluation methodology.
Over a period of a month they interviewed Project personnel at various locatio.ns and observed work in progress.
The initial results of their evaluation have been presented to the Company mi 232-4106i-66-102
and a Project response to each finding will be prepared and included as part of the evaluation report to be submitted first to INPO and then to the NRC Region III Administrator, together with the INPO overview.
2.
A third party installation implementation overview is being undertaken using, as a model, the program developed specifically for the underpinning portion of the soils remedial work.
The over'iew will be initiated by retaining an independent firm, v
having' considerable experience and depth of personnel in the nuclear construction field.
The consultant's overview team will be located at the Midland Plant site and will observe' the work activities being conducted in accordance with this Plan on safety-related systems.
The overview will continue for a period of six months, after which the Project's cumulative performance will be evaluated.
Based on the overview team's findings, a determination will be made by the Company's top management on what modification, if any, should be made to the consultant's scope of work.
Findings identified by the installation overview team will be made available to the NRC in accordance with the procedures established for the conduct of independent verification programs.
3.
An Independent Design Verification (IDV) is being conducted by Tera Corporation.
The IDV is directed at verifying the quality of design and construction for the Midland Plant.
The approach selected is a review and evaluation of a detailed " vertical slice" of the Project design and construction.
The design and as-built configuration of two selected safety systems will be reviewed to assure their adequacy to function in accordance with their safety design bases and to assure applicable licensing commitments have been properly implemented. The field work done in support of this activity will not take place until after Phase I implementation (Section 5) has been completed on the
- systems being reviewed.
g The Unit 2 Auxiliary Feedwater System (AFW) plus another system to be selected with NRC concurrence, will be reviewed to fulfill the requirements of the IDV.
i 1
mil 2S2-41061-66-102 l
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7.4 Status / Schedule 1.
INPO Construction Project Evaluation Select consultant and conduct
. Complete evaluation Sub=it report to INPO Jan 20, 1983 2.
Independent Construction Overview Define scope Dec 30, 1982 Select consultant Jan 31, 1983 Mobilize assessment team (Date to be determined)
Receive assessment team (Date to be determined) report 3.
IDV Select 2 Systems
.AFW System Complete
.0btain NRC concurrence (Date to de determined) for second system.
Complete Evaluation (Date to be determined) ei:2E2 '10di-66-102
1 8.0 SYS~EM I.AYLT 8.1 Introduction j
Perfor= system lay-up activities to protect plant equipment.
I 8.2 Objectives j
Expand the protection of co=pleted and. partially completed plant systems a'nd components until plant start-up, to take into account j
any special considerations during the status assessment.
b
{
8.3 Description
}
Procedures and instructions are provided in the Testing Program i
Manual to protect equipment during the on-going installation and test work.
These will be extended to cover special considerations i
associated with the Program implementation.
Both the pre-and post-turnover periods are covered.
System and component integrity is ensured through existing programs and implementation of control and verification procedures.
4 In su= mary, these procedures and instructions require:
Test Engineers to co=plete walkdowns of Q-Systems (in the auxiliary, 1
l diesel generator and. containment buildings and the service water i
pump structure), paying particular attention to systems / components
{
that are open to the atmosphere (eg open ended pipes, open tanks, i
missing spools, disconnected instrument lines, etc).
Systems that i
have been hydrotested but are not currently in controlled layup j
require action to place the system in layup.
Layup will vary from system to system but in general will consist of air blowing to remove moisture and closing the system from the atmosphere.
8.4 Schedule / Status i
Start extended layup activities 1/15/83
)
_ Issue walk down schedules 1/15/83 Complete the layup preparation walkdown 2/28/83 i
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9.0 CONTfNUING VORK ACTIVXTIES t
9.1 Introduction i
l This section describes the activities that are proceeding in accordance with previously established commitments during the implementation of the Program.
I l
9.2 Obiectives Maintain installation and support effort on work that will alleviate work interference in congested portions of the plant i
and facilitate completion and protection of equipment on systems j
turned over to Consumers Power Company.
Meet previous NRC commitments on activities which do not impede I
the execution of the Program.
Provide design support for orderly system completion work and i
resolution of identified issues Establish a management control to initiate additional specified work that can proceed outside of the systems completion
[
activities ~
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~
9.3 Description f
Those activities that have demonstrated effectiveness in the Quality Program implementation will continue during implemen.tation of the
{
Construction Program.
These are:
I NSSS Installation of systems and components being carried out by 1.
B&W Construction Company.
2.
HVAC Installation work being performed by Zack Company.
Welding I
activities currently on hold will be resumed as the identified i
problems are resolved.
j 3.
Post system turnover work, which is under the direct control of f
Consumers Power Company, will be released as appropriate using i
established work authorization procedures.
4.
Hanger and cable re-inspections which will proceed according to separately establisned commitments to NRC.
5.
Remedial Soils work which is proceeding as authorized by NRC.
[
i I
c11252-4106t-is-102
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6.
Design. engineering which will continue fcr the Midland Plant as will engineering support of other project activites.
Additional activities related to the systems completion effort, may be initiated, as appropriate, to support orderly completion of the I
overall Project.
Any activities in this category that are initiated prior to release of an area for systems completion work will be reviewed with the NRC Resident Inspector before initiation.
4 9.4 Status Schedule These activities are proceeding with schedules that are independent of this Plan.
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k' Jernes W Cook Vice Presdens - Projects. Esgeneri=g
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and Construction General officas: 1945 West Parnell Road, Jackson, MI 492o1 * (517) 788 o453 September 17, 1932 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 James G Keppler Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR COGENERATION PLANT MIDLAND DOCKET NOS 50-329, 50-330 QUALITY ASSURANCE PROGRAM IMPLEMENTATION FILE: 0485.16 SERIAL:
18850 i
REFERENCE:
CPCo Letter Serial 18845, 9/17/82, " Quality Assurance Program Implementation for Soils Remedial Work" The referenced letter summarized Consumers Power Company's discussions with the NRC management regarding the implementation.of the Quality Assurance Program for the Midland soils remedial work.
In addition to the discussions specifically related to soils, the total Midland Quality Assurance Program implementation was reviewed and areas were identified where additional efforts should be directed to insure successful overall project implementation and the t
performance of the primary inspection function (QC) on site.
In response to these concerns Consumers Power made two significant new commitments which are conceptually described in the following paragraphs.
Additional documentation will be provided as the details of these commitments are worked out.
Quality Control Function In order to improve the performance of the Quality Control function and to I
make it more responsive to direction from the Quality Assurance organization, the responsibility for directing the entire Quality Control function will be assumed by Consumers Power. The Quality Control group will functionally report to MPQAD. The programmatic aspects now in place will continue to be used and the combined inspection resources of both Bechtel and CPCo will be integrated. This reorganization will be fully implemented as soon as the appropriate procedural changes are finalized.
The integration of the QC resources for soils into MPQAD has already been accomplished as a separate action.
oc0982-4024a-66-164 ATTACE S T 2
Page 2 Independent Verification - Total Project Consumers Power proposes a n'ew and expanded approach for verifying the overall quality of the project. This approach will give a broader overview than the assessments currently being recommended by the NRC for other NTOL plants.
The I
assessment which is suggested for Midland is to. combine an INPO type construction proj'ect evaluation, which is a broad " horizontal" type review of many aspects of current project operations with the detailed " vertical slice" review of all aspects, current and historical of a critical plant system or subsystem. The entire review will be performed by one or more independent contractors who are currently being selected. With the assistance of the selected contractors. the detailed plans for this extensive independent assessment will be finalized and presented to NRC management shortly for their concurrence prior to initiating the major work activities.
The INFO portion of the program will be initiated immediately at least through the planning phase to comply with the INPO schedule and industry commitments to the NRC. The INPO constructica program evaluation for Midland will differ from the majority of the industry's self-initiated evaluations in that an independent contractor rather than utility personnel will carry out the INPO evaluation. The results.will then be overviewed by the INPO staff to assure adequacy and consistency with other evaluations.
Additional Assessment Programs In addition to the above, Consumers Power has proposed to retain a qualified third party for an assessment of the underpinning activities as detailed in the referenced letter.
Consumers Power Company has also initiated other appraisals to assess the adequacy of the Quality Assurance Program.
Two major recent examples of this practice that have occured are as follows.
In 1981, Management Analysis Company (MAC) conducted an assessment which focused on performance in three major areas as follows:
1.
Adequacy and timeliness of both part and process corrective actions taken on a sample of the historical hardware problems that have been identified at Midland over its lifetime.
2.
The degree to which the physical characteristics o'f selected supplied components and parts meet their respective quality requirements.
3.
The overall adequacy of the Quality Assurance Program with particular emphasis in corrective actions, effectiveness of the supplier documentation review efforts and personnel qualifications.
This assessment has been completed, the results were positive and all open items have been resolved and closed. The final report has been previously submitted to the NRC.
A Bechtel Corporate Staff pr,oject evaluation was initiated in April 1982. A report on the results of this assessment is being finalized at this time.
The oc0982-4024a-66-164
Page 3 j
purpose of this evaluation was to review the Midland engineering activities to determine if design criteria have been implemented and if the design assumptions, design methods, and the design processes are satisfactory.
Bechtel Corporate Management was asked to initiate this assessment in order to certify that the Midland project met all the standards expected of any Bechtel proj ect. To carry out this assignment the assessment team was specifically chosen to be independent from the Bechtel Ann Arbor Power Division.
The team consisted of senior experienced personnel with appropriate expertise having previously performed similar work on other projects. A Consumers Power representative was a direct participant on the r ssessment team. T,he final a
report will be sent to the NRC upon completion and whatever other documentation or discussion as may be requested will be provided.
Conclusion Based on the discussion outlined above and in the reference letter, Consumers Power believes that steps have been taken to insure both the successful implementation of the remaining work to complete the plant and a verification program, including quality records, test program results, and third party assessments, that will certify the adequacy of the plant as constructed.
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Page 4 CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harstead Engineering DSHood, NRC (2)
DFJudd, B&W JDKane, NRC FJKelley, Esq RELandsman, NRC Region III WHMarshall JPMatra, Naval Surface Weapons Center i
W0tto, Army Corps of Engineers WDPatton, Esq SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers j
BStamiris
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oc0982-4024a-66-164
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CONSUMERS POWER COMPANY Midland Units'1 and 2 Docket No 50-329, 50-330 Letter Serial 18850 Dated Sette=ber 17, 1982 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the.
Commission's Rules and Regulations thereunder, Consumers Power Company submits information regarding the implementation of the Consumers Power Company Quality Program for the Midland Plant.
CONSUMERS POWER COMPANY By
/s/ J W Cook J W Cook, Vice President Projects, Engineering.and Construction Sworn and subscribed before me this 17th day of Sept 1982
/s/ Patricia A Puffer Notary Public Bay County, Michigan My Commission Expires 3 h-86 miO982-0000a100-164
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James W Cook 7
g. l v s.& L Vice Pressdent - Projerts, Engsneereng and Construction General offices: 1945 West PerneH mood, Jackson, MI 49201 * ($17) 788 o453 i
April 6, 1983 Mr J G Keppler, Administrator, Region III Nuclear Regulatory Commissi.on 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT -
MIDLAND DOCKET N0's 50-329, 50-330 -
CONSTRUCTION COMPLETION PROGRAM THIRD PARTY OVERVIEW -
FILE 0655, B1.1.7 SERIAL 22268 REFERENCES 1.
LETTER TO J W COOK DATED MARCH 28, 1983 FROM NRC REGION III REGARDING CONSTRUCTION COMPLETION PROGRAM.
2.
LETTER FROM J W COOK DATED MARCH 10, 1983 TO MR R C DEYOUNG REGARDING MIDLAND PROJECT RESPONSE TO NRC NOTICE OF VIOLATION EA83-3 DATED FEBRUARY 8, 1983 Your letter of March 28, 1983 regarding the Construction Completion Program (CCP) consisted of Parts A, B and C.
The following is in partial reply to the I
referenced letter:
A.
Items A1. through A9. sill be addressed in a subsequent l'etter to you except for Item A5. for which our response is as follows:
Mr Keppler has asked that we develop measures that vill ensure that our key hold points are honored and that critical parar.eters of our program are in place before proceeding to the next step.
In order to. ensure the Project's readiness to undertake the various steps in the CCP, the CCP includes provisions for management review at key points in the process.
The review will examine plans for future implementation and ensure that programs and processes are thorough, complete, and correct. To provide the NRC with additional assurance that the CCP processes have, in fact, been and will be implemented as described in my January 10, 1983 letter, this letter, and the forthcoming response to Questions Al-A9 of Mr Keppler's March 28 letter, we will include in the duties of the third party construction overviewer responsibility for audits of our performance of these management reviews of the CCP process.
We will not proceed with the CCP implementation beyond these points until the third party overviewer has documente,d their satisfaction with our readiness to proceed, including satis. faction with our initial response to any audit oc0483-4076a141 ATTACMENT 3
9 -
2
[
findings, in their weekly reports.
This commitment will also assure that i
the CIO is in place in time to audit the management review of Phase I i
planning, and hence before any physical verification under Phase I takes l
place.
(Note: The title of this particular third party overview is now being entitled Construction Implementation Overview, CIO).
The Company has or will provide information' regarding all items which the NRC wished to review through the normal exchange of information with the NRC Staff.
This information was provided through the response to the
~
Notice of Violation regarding DGB inspection, through the forthcoming response to Questions Al-A9 of Mr Keppler's March 28 letter, and through
~
daily interaction with the NRC Resident Inspector (the adoption of the QC organization within MPQAD and the res'olution of the CP Co stop work order on Zack welding).
B.
A more detailed description of the third party installation implementation overview (now titled CIO) is provided in the enclosed proposal (3 copies i
attached) from Stone and Webster (S&W).
i 1.
The CIO will encompass all aspects of the CCP from the point that the CIO is mobilized onsite (including the process aspects discussed in A above and the reinspection work).
The exception is that the CIO will not include an overview of the other third party evaluations being conducted as described in my letter to Region III. dated January 10, 1983.
2.
As defined on Page 2 of Section 2 of the S&W proposal, there will be weekly meetings with S&W, Consumers Power and the NRC and weekly minutes (reports) of these meetings will be issued.
The protocol for communications between the parties will be the same as used by S&W on the soils remedial activities.
- 3. 'The CIO will continue until Consumers Power and the NRC have confi-dence ih the adequacy of the Consumers Quality Assura'nce Program for the Midland Project.
1 i
C.
Consumers Power Company proposes that Stone and Webster be the organi-zation to perform the CIO.
This is based on the fact that we consider S&W technically capable to perform the activities both in terms of the indi-vidual team proposed and in the corporate depth to support this effort.
They are presently conducting what we believe is a highly professional overview of the soils remedial activities and have been found acceptable by the NRC for corporate independence.
In addition, your letter indicated that it would not-be acceptable for the CIO organization to also be involved with the IDV, thereby disqualifying the other evaluated bidder, I
Tera Corporation.
The proposal submitted by S&W addresses Items C1, 2 and 3 of your letter except that the statements provided in the attachment concerning corporate and personnel independence were inadvertently not notorized.
This situation will be immediately corrected and the sworn statements of independence will be sent to you directly by S&W by approximately April 8, 1983.
- ,:Gl.S3-4076aI41
3 1
Enclosure I to your letter of March 28, 1983 discussed protocol fcr ILV on the Aux Feedwater System, Electric Power System (diesel generator), and the :flAC system assuring control room habitability.
This protocol will be adopted by asking Tera Corporation to prepare a detailed procedure implementing this protocol.
Based on the need to.have the S&W team audit our pending initial management reviews, we have requested S&W to be able to mobilize their team as soon as possible.
This is currently scheduled to occur the week of April ;8, 1983.
We plan to proceed at our risk upless instructed otherwise by your office.
However, we would very much appreciate your expeditious review of S&W as a satisfactory contractor for the third party overview of the CCP.
JWC/GSK/lc CC Atomic Safety and Licensing Appea. Board (w/o att)
CBechhoefer (w/o att)
FPCowan, ASLB (w/o att)
JHarbour, ASLB (w/o att)
MMCherry (w/o att)
FSKelley (w/o att)
HRDenton, NRC (w/att) kW!arshall (w/o att)
WDPaton, NRC (w/o att)
BStamiris (w/o att)
MSinclair (w/o att)
LLEishop (w/o att)
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BCC RAWells, Midland (w/att)
JEBrunner, M-1079 (w/att) l GSKeeley, P-14-113B (w/o att)
ARMollenkopf, P-14-209A (w/o att) l DBMiller, Midland (w/att) l FWBuckman, P-14-113A (w/o att)
DMBudzik, P-24-517A (w/att)
MIMiller, IL&B (w/o att)
DFLewis, Bechtel (w/o att)
DFJudd, B&W (w/o att)
RWHuston, Washington (w/att)
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CSundstrum, S&W Boston (w/o att)
PJGriffin, P-2h-513 (w/o att)
I TA3ue:winski, Midland (w/oatt)
UFI (w/att)
NRCCorrespondenceFile,P-2h-517(w/att) l e
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NUCLEAR REGULATORY COMMISSION
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Docket No. 50-329 Docket No. 50-330 Consumers Power Co=pany ATIN:
Mr. James W. Cook Vice President 1
Midland Project 1945 West Parnall Road Jackson, MI 49201 2
Gentlemen:
By letter dated January 10, 1983, Consumers Power Company described its proposed Construction Completion Program (CCP) for the Midland nuclear facility.
This submittal was followed by a public meeting in Midland on February 8,1983 for the NRC to obtain a better understanding of your proposed program and to obtain public input on the CCP.
As a result of 4
our review of the CCP to.date, we find we need the following additional J
information.
A.
Please provide a more detailed description of the scope of the COP and how it is going to function.
Your discussions she'uld address the following subjects or concerns:
1.
Because of problems identified by the NRC during the special inspection of the diesel generator building and because si:ilar problems were found in other areas of the plant during subsequent inspections by CPCo, we believe that 100% reinspection of access-ible safety related structures, systems, and components is war-ranted.
Should you intend doing less than 100% reinspection, please provide the details of your proposed program and the technical rationale for accepting a sampling approach.
2.
A description of the reinspection program for accessible systems and components important to safety.
3.
A description of the measures you intend to institute to assure that QC reinspection will be sufficiently independent of team controls.
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Censu ers Power Company 2
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4.
A description of the training that will be provided to all i
personnel including craftpersons. Concerning QC inspector recertification training, describe the actions you have re-cently taken to address the adequacy of the review of PQCI's prior to training being initiated on the PQCI's.
In addition, describe the steps you have taken to ensur'e that all questions i
raised during PQCI training sessions will be resolved prior to certification to affected PQCI's.
5.
As a result of the diesel generator building inspection, hold points were established by the NRC for the purpose of determin-ing that you adequitely performed all of the actions to which you have committed before allowing the work to proceed beyond the hold point.
In view of the total CCP effort, the NRC does not wish to remain in the approval chain; therefore, you are requested to develop measures that will ensure that key hold j
points are honored and that critical parameters of your program-j are in place before proceeding to the next step.
J l
6.
A description of the controls you will use to ensure all problems j
have been identified during reinspection of a system or area prior to start of repair work or new work on th&t system or in 3
j that area.
1 7.
A description of the controls you will use to ensure that no new work will be performed that would cause a known nonconformance i
to be inaccessible.
I 8.
A description of your proposed program for in process QC sur-veillance (inspection) of rework and new work.
9.
A description of the CPCo management review process for changes to CCP and how CPCo intends to keep the NRC informed of such i
changes.
1 I
3.
Please provide a more detailed description of the third party in-sta11ation implementation overview mentioned in your January 10,
[983 letter.
Your description should address the following subjects l
or concerns:
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1.
The installation implementation overview appears to focus solely on future construction and rework. We believe the overview should also encompass all aspecta of the CCP,_ including the reinspection work.
Please expana the installation implementation overview to include other aspects of che CCP and provide us with additional details of the overview.
2.
Weekly reports, similar to those issued by Stone and Webcter to inform the NRC of the results of the soils overview, are needed.
Please provide your commitment to have the third party CCP over-viewer prepare wee.kly reports similar to the soils overview weekly reports.
3.
The CCP overview should continue until CPCo and the NRC have con-fidence in the adequacy of the CPCo quality assurance program.
C.
Please propose a candidate organization that Consumers Power Company i
considers acceptable for the installation implementation overview together with your rationale for selecting that organization.
The NRC will also need the following:
1.
Sworn statements from the candidate corporation' and all personnel who will be involved in the third party installation implementa-tion overview, addressing the independence f actors described in Chairman Palladino's letter of February 1, 1982 to Congressmen Ottinger and Dingell.
The resumes of th' key personnel to be involved in the third party 2.
e overview.
3.
A description of the experience of the candidate corporation that. qualifies the corporation td perform an independent third party overview.
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The NRC will determine the acceptability of the candidate corporation and will notify CPCo.
Our~present view is that the installation implementation overviewer would not be acceptable to also perform the independent design and construction verification program.
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}c-In order to ensure adequate communications between the NRC, CPCo, the independent third party proposed or selected to conduct the independsat design / construction verification program, and the public, the proto::1 in Enclosure 1 should be adhered to.
This protocol does not apply t: the third party overview of the remedial soils work or the third party crer-view of the CCP.
Should you have any questions regarding this letter please contact Mr. R. F. Warnick of my staff.
Sincerely, hh ryJames G. Keppler 1 Regional Administrator 9
Enclosure:
As stated cc w/ encl:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII The Honorable Charles Bechhoefer, ASLB The Honorable Jerry Harbour, ASLB The Honorable Frederick P. Cowan, ASLB The Honorable Ralph S. Decker, ASLB William Paton, ELD
, Michael Miller Ronald Callen, Michigan Public Service Co= mission Myron M. Cherry Barbara Stamirit Mary Sinclair Wendell Marshall Colonel Steve J. Gadler (P.E.)
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4 Docket No. 50-329
-l Docket No. 50-330 i
1 PRCTOCOL GOVERNING COMMUNICATIONS BETWEEN CONSUMERS POWER COMPANY AND THE ORGANIZATION CONDUCTING THE INDEPENDENT DESIGN /
I CONSTRUCTION VERIFICATION PROGRAM t
i 1.
Reco=mendations, findings, evaluations and all. exchanges of
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correspondence, including draf ts, between the independent reviewer and CPCo will be submitted to the Regional Administrator at the same time as they are submitted to CPCo.
For purposes of this protocol, l
the independent reviewer includes the independent reviewer and any of I
its subcontractors and Consumers Power Company (CPCo) means CPCo.
}
Babcock and Wilcox, Bechtel, Management Analysis Corporation, S&W, and all of their subcontractors.
i 2.
The independent reviewer has a clear need for prompt access to i
whatever information is required to fulfill its role. To this end, the independent reviewer may request documentary material, j
meet with and interview individuals, conduct telephone conversa-tions, or visit the site to obtain information without prior notification to the NRC. All communications and transmittals of l
information shall, however, be documented and such documentation j
shall be maintained in a location accessible for NRC examination.
l 3.
If the independent reviewer wishes to discuss with CPCo substantive matters related to information obtained, to provide an interim
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report to CPCo or to discuss its findings or conclusions with CPCo in advance of completing its report, or if CPCo desires such j
co=munication, such discussions shall be accomplished in meetings j
open to public observation.
In this regard, CPCo shall provide a l
minimum of five days advance notice to the Regional Administrator of any such meeting. The Regional Administrator shall make reasonable efforts to notify representatives of interested members of the public j
of the meeting, but the inability of any person to attend shall not j
be cause of delay or postponement of the meeting. Transcripts or j
written minutes of all such meetings should be prepared by the i
organization requesting the meeting and provided to the NRC in a j
timely manner.
Any portion of such meetings which deals with l
proprietary information may be closed to the public.
4 l
4.
All meetings between the Staff,and CPCo and/or the independent reviewer will be open to public observation, except where the Staff determines that it is appropriate to conduct a meeting (s) in private j
with CPCo and/or the independent reviewer.
I 5.
All documents submitted to, or transmitted by, the NRC subject to this Protocol, unless exempt from mandatory public disclosure, will.
be placed in the NRC Public Document Rooms in Midland, Michigan and Washington, D. C., and will be available there for public exacination and copying.
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James W Cook E
Wet bessdent = Pro 1ren. Engsneem med Coast,wenow Generei officas: 1845 West pernen Acac. Jacamon. MI 49:01 * (5171788.Cas3 October 5, 1982 Harold R Oen:on, Directo Office of Nuclear Reacto Regula:ic:
D:..v:.s t o: c:.
ice: sing US Nuclear Regulat::7 Cec =issio:
Washing::, DC 20555 J G Xepple:
Administratie=, Regie: III
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US Nucles: Regulat ry Cec =issic:
799 Roosevel-Road Gle: Illys, II. 60137 MIDI.AND NUC.I.AR COGENE?aTION P!. ANT MIDI.AND DOCKIT NOS 50-329, 50-330 w tD.r.e.s. D
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(2) PERTOR*.ANCI 03. ECT!'lIS AND CR:-'IRIA TCR CONSTRUCTION PRCJ.:T EVAI.UAT GN I. PO, 3I.!I.'f3ER 1982 Y
The ACRS interi= repor e: the Midland Flant, dz ed June C, 1982, co:: sized. a re:cceenda::.
for a b::sde: assess =e:
of Midland's cesi2: adequacy and cc s::2cti:: qu li 7 Is i:s cc : espe =dence ci July 9,19S2, v :.:t is Reference 1 above,.he NRC e dorsed :his ACRS ree::=e dat.ia: and cquested Our proposal for peric:=i:g 2:
depe de : des:.
sdequsef review.
We briefly cut' ired several as:ess=en; activities for -he Midla:d ?: jee-.:
cur correspeteen:e of Sep ember '.7,
'.982, ide:-ii.ed above as Reference 2.
Additic:al deta:.ls of the program referred to 1: Reference 2 are e=clored fez the NRC's review.
'a'e hav e :c ett.c t ed our NRC P roj e c
.M an: g e r, Da r; '-::co,
c 2::s=;e a.:eet :g
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vith tt.e NRC Su f f te discuss our : dependen: Ee.te. ?restam and :: :ecc.ve ycur cc= cur e ce :: red. rec::,:,r. :i :ur p;3:s.
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a October 29, 1982.
k*e wish to initiate the implene::stic: phase of the IN?O progra= by November 8, 1982, in. order to suppor cur own and industry
'ce its nts o NRC
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e bna Jk*C/GSK/RI.7/bj u CC Atenic Safety and I.icensing Appeal Board, w/a 1 C3echhoefer, ASI.3, w/a 1
.T. Cherry, Esq, w/a 1 F?Cowan, ASI.3, w/a 1 RJCook, Midland Resident Inspector, w/a 1 & 2 RSDecker, ASI.3, w/a 1 SGadler, Esq, w/a 1 J'darbeur, ASI.3, w/a 1 GHarstead, Harstead Engineering, w/a 1 DS'dced, NRC, w/a 1 & 2 (2)
IJKelley, Esq, w/a 1 k'dMarshall, w/a 1 4'D?atton, Esq, w/a 1 k"JShafer, NRC, w/a 1 & 2 BStamiris, w/a 1 MSinclair, w/a 1 r-rTMishop, Esq, w/a 1 F.'
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i CONSLT.:_?.S POWER CO S.55?
Midland Units I and 2
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Docket ~No 50-329, 50-330 Letter Serial 18879 Dated Oc eber 5. 1982 At the.. request of the Commission and pursuant to the Atomic Energy Act of
,1954, and the Energy Reorgani:ation Act of 1974, as amended and the Coe.missien's Rules and Regulations thereunder, Consumers Power Co=pany submi s l
Midland Plant Independent Review Program.
CONSl:MFRS POVF.R CC.9A.YT By
/s/ J V Cook J W Cook, Vice Prestdent Projects, Engineer:. g and Construction Sworn and subscribed before me this day of
/s/ Barbara ? Teunsend h_
Notary Puolic
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Jackson County, Michigan My Co= mission Ixpires e
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i MIDLAND PLANT INDEPENDDrs ?I7IEW 1.
INTRODUCTION & SLTGT 2.
BIINNI.C QUAI.IIT AUDITS 3.
INPO CONSTRUCTION EV.CUATION 4.
INDE?INDD*T DESIGN 'GIIICATION 5.
APPINDIX:
??2V!OUS ASSESSP..NTS 4*
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1.
INTRODUCTION AND
SUMMARY
The ACRS report dated June 3, le82 on Midland U=its 1 and 2 stated that "the NRC should a :ange for a b cader assess =en: of Midland's design adequacy and constructio quality with e=phasis on installed electrical, con :el, and mechanical equip =e:: as well as piping and fou=dations."
9 On July 9, 1982, the Staff issued a le::e to Consu=ers Power Company requesting a report oc Midla:d Desig: Adequacy and Construe: ion Quality.
I this letter, the Staff stated that "Vith respect to assessment o f Midla'ad 's design adequacy, such assessment would represent a significant ce=tribution to the licensing review process if performed by a qualified, independent source following procedures utilized by so=e op,e:ating plants for I:depende:: Desig:
Ver.f. ca tions.,,
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On September 17, 1982, the Company issued a letter to Mr Harold R Dentoc and Mr J G Keppler outli : g the approach Constmers Power Compa y p:: posed for an Independent Review of the Midland ?:oject cod indicated that there had also been a 3echtel Corpora:e Staff project evaluation performed (described in more detail is attached appendix).
It was sta:ed that Cocsumers Power Compa:y believes that the approach we are proposing i:: :he for he:m::g :: dependent Review will give a broader overview tha: asse:smes:s currently being rec:mmended_iy,:he NBC for other NTCL plants.
The overall ::dependen: Rev:ev ?:og:sm described herei: ::: sis:s :f :hree specific evalua::::s c:mo::e-4 in:o a single pr:g 2:.
The :N?C :ype
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overall proj ect against the criteria developed by IN?O for this p'regram (a copy of the INFO Perfor=ance Objectives and Cri eria for Co:struction Prejec:
Evaluations is ettached).
As indicated in the September 17, 1982 len er ::
i Mr Dento: and hr Keppler, the IN?O program for Midla:d will be differe:: frem most of indust:7's se 4-4 -# ated evaluations in that an indeper. dent contractor ra:Le tha utility perse e1 will carry out the IN?O evaluatics.
The secced part of the Program described is the Bie-4al QA Audit which has been a recuirement of the Company's QA Progra= for several years.
The third part of the Program described in cre detail is the Independen: Desig:
Verificatio: (Vertical slice) of all aspects, h:storical arc current, c'f a critical plant syste= or subsystem.
Const=ers ?cwer C:mpa:y received p:cposals f:cm several potential ce:::acters to perfer= the c:=plete program describe'd abeve.
With respect to the IN?O s a-su type ccestruction evaluatio: and Bie: :a1 QA Audit, we have selected Managemen: A:alysis C::pacy (MAC) :: perform :hese activities based := cur evaluation of thei technical capabilities a:d experience.
MAC has =any years of experience in the Nuclear Industry a:d has perfer=ed 3iencial QA Audi:s in additie: to other type eviews of Company activities.
MAC has previously censulted extensively at uclear cc:strue:::: sizes wi:h iden:1 fed QA problems.
MAC uas also a major par::cipa : i: :te develepee :
a:d impleme::stien of :he Palisades.;egulatory Peri::=ance !=provemen: ?::gra=
w=1ch has resul:ed in sig:ifica:: improvemen: :: da:e at that facili:y.
A I
dese:1ptie: ci etze: MAC assessce::s of Midla:d ac :v :ies is i:cluded i: :he Appendix :s this dcct e::.
4 i-16 TheJiAC Team will be under the directie of Mr L J Xube *.ho has over 20 years l
experience is project manage = cat, e:gineering ma: age =ent, marketing, pla==ing/scheduli g, and design engineering having been e= ployed by General j
Atomic and A 0 Smith Corporation prior to his e=ployment with MAC.
Mr Kube j
has been involved in the developme:
of the IN?O evaluation criteria, has 1
participated in the :hree IN?O Filot evaluations and is the ?:ojec: Manager for MAC for conducting an IN?O evaluation on River Bend.
The INPO type evaluation will be indepe: dent is tha't no Consumers Power Co=pany or Sech:a1
]
persetsel will be involved and MAC has never perfor=ed a direct line engineering or cocstrue ice activity for Consumers Power Company.
j For perfor=ance of :he I depe: den: Desig: Verifica: ion, we have selected Tera Corporation based oc our evaluation of their technical capabilities and experie:ce.
Tera has cacy years of vaWerience is the =uclear industry s :- -
including iddependent design reviews,'FSAR preparation, initial design of certain syste=s, and engi:eering, construe:ico, operation a:d ad=inis tration plat =i:g.
Tera persoccel are experienced is syste= desig i: the areas of mechanical, electrical, structural, a:d ther=al hydraulic evaluations.
Mr John V 3eck, Vice Presiden: of Tera vill be Projec: Manager for the Tera team.
Mr 3eck previously worked for Ver=e - Tackee Nuclear ?cwer Corp as Exec _ ive 7i:e"? resident serv g as Chief Operating Officer.
?:ior :s : hat he was 1
Direc cr of E:gineering for Yankee A:cmic Elec ric Co respecsible for i
supervision and manage =e:: of :he plant, reac or, and envirst$e~n:al e:g;:eering depart =ents.
Prior to e=ployment w :h Tankee, he was a Scientis-e I
a: Iet-is i:rolved :: Sh:ppi:gpor- : ore design.
s...._
5 Individuals taking part in any of r.he three specific evaluations which make up the overall Independen: Review ?: gram will mee: the "Independency C ::erii" of Chair =an Palladine's February 1,1982 letter to Representative Job: Dingell and which are described as follows:
1.
No individuals. on the ?:oject tea = will have been prev,iously utili, ed by Consumers ?:ver Cc=pany to perfor= design or construction work.
2.
No i dividual i=volved will have been previously e= ployed by Consu=ers Power C:mpany.
3.
No ::dividual owns or centrols significan: a=eus:s of Consumers ? ver Company steck.
4 No members of the presen: household,of individuals involved are e=plcyed by Consu=ers Power Company.
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5.
No relatives of individuals i:volved are emp'cyed by Censumers ?:ver C =pany in a canage=en: capacity.
MAC will be responsible for integrating an overall evaluation report made up of the three L:pu s.
~
The major objective of the everall evaluatice report is :s provide the NRC, ACRS, and :he Consu=ers Power Ceepany Chief Executive Officer wi:h an assessment of the overall quality of the Midla:d ?:: ject.
We believe that this assess =e:: will adequately address the N?.C, ACRS, and public's ques::::s regardi:g ::e adequacy and cc strue: ice quality of ::e plan:.
6 t
The final imper: will be submitted to the NRC and an audi able record will be
=ai:i ained of all co= cents on any draf t. or final reports, any changes =ade as i
a result of such coe.=ects, and the reasons for such changes.
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BIENNIAL QUALITT AUDITS' Backpround of 3ie :ial Ouality Audit Recuirements The Co:sumers Power Company Quali:7 Assurance Program Manual 7o The Midland Nuclea: Pla::, Top,ical Report C?C-1-A, requires the review of the Const=ers Power Corporate Nuclear Quality Assurance ? ogram to be performed a: leas once every 24 months or once every sec: d calendar year by a Quali:7 Assurance
?:ogram Audit (referred to as the Bie :ial Quali y Audi:).
t This audi: =ay be acce=plished by a team consisting of Envirotmental & Quali:
7 Assura:ce perso= el, selec ed e=ployees from other Consu=ers Power Cocpany depar ments or by an audit : cam of Quali y Assurance persca:el under contrac-to Const=ers Power Cocpany, s==b- -
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plans
-- Ts. sen, 34.--4a1 Oual: v Audi:
t The scope of the 1982 3iet:ial Quali y Audi: vill be similar o the audi:s conducted in 1976, 1978 and 1980.
The audi: will evaluate the Quali:y Assurance ? ogram being u-ilized by Consu=ers ?ower Compa=y and by Bechtel and will evalua:e on a sampl::g basis, -he degree of compliance with :he ?:ogram by Consc=ers Power Co:pany and by 3echtel.
Soecifically, -te 198' 2'
--4al l
Quality Audi will be conduc ed by Macagemen: A:al/ sis Compa=y (M.AC) and will i
cecply with :he requirements of NRC Regulatory Ge des l.1 ' (9/S0, Rev 1) and i
1.10o (S/30, Rev 0).
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8 3.
IN?O CONST?.UC ION IVCA-ON General In early 1982, utility nuclear power plan: cots rue: ion proble=s s-i=u'a:ed indust:7 initiative and action to e:sure that progra.ms is effec: caticevide
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power Operations (IN?O) was tasked by :he Utility :: dust:7 :: devel:p and
=anage a c::structie: p cjec evalua tice progra=.
The firs effer: was to d. * ' ~ e = =. '...- a c w' ".i =. ~. ~. '.. e s a.- d C.-'... '.1
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Use o.*
these cri:eria f : an everall evaluation is in ended.o p:: vide considerably
=or: depth.han a: audit, for as audit ge erally does :ot go beyond confer =ance to progra= require =e::s.
Ace eva.3.ua t:. cts :. c., ude sc=e as ses s=en:
1 of ad=icistrative and quali:7 records,s;;=sa-more -i=po rtant, focus en evaluati:g
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Follew:.0; -he draf ting of.he Perfo:=ance Objectives, :::ee pile; evalua: ices vere conducted by IN?O ce plants u= der cess: nc:ie ie, *1cgtle, Shes:::
Earris, and E pe Creek.
Duri:g -he las pilot a re:reses:a t:.ve fr:= NRC was 1
presen: dur:.:g data collectist, evaluatie: are ext. i :4:v.ev w. : u.ili:7 l
.e s 7:ll:wi:g :he pilet evalua::.::s,.he Perds:=a ce Cbj ect:.ves and assoc.a:ed 4
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s ate =e::s of activities that br. he'p =ee t :he perfor=ance objectives.
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ne above D50 Perfo=ance Cbjectives and associa ed Criteria vill be utilized
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a ne IN?O :,pe self eval..a: ion is aimed at achieving a level of perfo=acce above
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(including Consu=ers Power) cet, draf ted and reviewed perfocance. obj ec-ives and criteria to suppor the perfo=acca objectives of seven areas including design.
A ce=plete list of the areas whose obiectives are inte=ded to define o c, t '_. um, e _ '_ -.. a _-. - '. s.-
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e cer:or=ance Obj ec.ives and participatic: in all three pilo evalua: ions.
The team sue lied bv. :AC vd
b e.4_- d e.-.' d,a.1 s exp e r.e:c ed :.: cul::.. dis cipline actinties associated with nuclear power plant engineeri:g and :::structie:.
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? ier to actually perfo r=ing the evalua tion, all tes= =e=cers v.'.1 recei re
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As findi gs develop, addi:ional inves :.ga-ices =ay :aka place. '
Juri g :lis :i=e, :he :.ea: will c:c=unica te wi-h :he proj ec: perse= el :o.
assure validi:r of findi gs and draf: evalua:ict su.= artes will ce prepared.
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.s A: -he conclusicc of the evaluatie=, :he :aac will verbally c:c=unica a.hei-findings :
- he projec.
A fer=al report will then be prepared and presented to C? Ce =anage=s::.
C? Co will ack:culedge the findings and ::ats=i. :he findings wi t : heir. plans f:: correc-ive ac, ice c:cc ::ently :s :he.WC and
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DT?O ill assi-"la a various u:ili:ies repor s i :s a ::cprehensive s"
a ry docu=en and repo r: the everall pr:gra p :gress :o -he.EC.
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findings forwarded to a serior review team.
At the c:cclusic of :he effert, a -..'.'_ __.=.,.- -. c.. d. _' _' 'e g ovd.ded
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The selectie: of a s7sta=
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......s s...... s _....
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.=
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i o
" Ab il'it-/ to Test As-3uil: I:stallation - The syste= const nction should be' su#ficiently c =pleted tha: the as-built configuratica can be verified -
3 agains: design.
The auxiliary feedwa:e s/s e= vas selected for the independent design rev ev l
after cocsideration of a cu=ber of other candidate systems.
The auxiliary j
feedvater syste= bad a sufficiently Eigh profile for each of -he cri:erion to i
i justif7 its selec:io=.
Specifically, it involves interface with :he NSSS
.,, a. e...
,,.. a...
e e m.., a _._ e_.. g e s ;. g. c.a....a_ a,
a.
.a...__c_.
ga..u. ges.6_.
m ergani atices, and the methodology of deter =ising a wa ter sys e='s mecha:ical, e t,...-". a ', a - d c.a c. -. '
c--, scc __-..de s ' g_ c.-"...-.=.
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l
.e a:"=e- -J E'
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i h
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.s.... 3 c _w se L:de,e:-ez. ges t -.,e <::ca.<o A
6 (TDy).::oc. 's c...r 'se. o.' ~-'-==. f ases,-
e
?:ogram Develop =act, Review and Reporting.
5.og a_- D'evei -
e_-. 2'ase 3_c'"-d-s
.'. p..- a.a-'
o#. a u-7 V wo.-k
.la a_.d s.
..a oy-
.s r
the developme:
of a detai'ad review scope.
he EDV wor.k pla will i:clude
,.. e. s... s a - d 4 _s. -"... d
. o.s. o - tm' e wo..k o b e p e #e.m e d k.v..e..~....o..'..'.-.,
.u v.
,<......ac...
a.
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a. a. i a.,
- de_..<
- :.1.a..
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u spec < <.-
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e.s. 3 as w
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. v..w o be e d'
d.
4-a d d.-.s s._ g s : s _
d..a s. g_
e
---~~
~
,, _ e _.. s..a..,.,
a, s e
....,.. s. a s,. a.. :
._..s
, ase.
The Review phase is :ta ajor activi 7 of the '3V.
This phase i:cludes a 2, s 4...
.v. y c.<. u
_,.._3 we1,1 -, ::,,
e
.4 _. s. a,,a.e
. x. 4.*.
. v..y
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.o ass.....on.:.__.... o:
ues.a _- a _. s.
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e
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s..
y a.
y g s..,.,
a
.oc s oc...
a.e_..,:....a
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.... c s s ('_a'_'
,.-...'.- s e.'.-... ^. s ~: s. _.
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u.e e.'ac "
~
a _.. a.e. 4._. e.es.. e ga_.a.a.<.s a_.s e
.s
- e -. s. e i e_.. s..ce
- s. o c.... u.. e c.
--.-~~
a.
. _. e design t:d c dars 2: ding the design practices,and interactions becseen
- e gas.
._.g._..
2, 2.,.,
,i_-.
3
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ag.s s
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--. s:s.=
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a= a.s 2
s a.
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n.<.
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.oc"_
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...a
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.. s.......
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t
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a
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....a
_ _ -. ~. _. _.
r 35 i
eval,uatie= (eg altar =ative calculatice or c:=pu: : analysis by :he IDV
,I cen rac or) c: a c:=bi:atiet.
%cere appropria ta, i:dependen: analy-ical techniques vill be used :s cocii== desig: cilculatiets or
- pe==1: assess =e :
o.* th e s '.._' c a c c
- a-, i d e- -' e ^ d' s c. r e c' - s.
.i..is a -'c'-ra..=^ -'a..
the pri=ary reviev =ethed will be a, :eview of calculatiscs.
Cl:i=a :4' y, :he choice of reviev re:hed vill' depend upon the ca ure of :he design area and -de
..;;, e.s y,-e
<e2.e..
.,.'od
".'i-'
.'s =osc e.##....'".e i
abl#--..' e.~ V c
-s
- views
- reach a ;udge=en: as e :he design adequac7 i: tha: design area.
se 4-3.. ys..;
.s..s.,
e
........g..
.. oc eac-ajc. s. e 4 _-
.' e d e s..-
,. -. c.- s s,... -
exz=ple :
D e s.' g
' ~~,. u. ' _ *. _ a - - - - (. a cs ' e. a ~._c..g gp_
,.s'.s-
.s, c..' :. a -..= '1'. '
.es.._-
g.-
C-a...1 aa
.n-..----_e..s).
Acalyses and Cal:ulati:ts (selected review of inputs,
assc=p:i::s,
=ettedelegy. valadati:: arc usage of c:=puter pr:gra=s a:d :: ass: ableness c<...
24_-
a. a 1 - e. ca.i ot.. u.s).
f
.r
- D.au..gs a.s c.e. ee.-- c2. e 3
r
, s e. -...= d...-v..ws
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.-. a c..... s ;... -
d l
- e s '..-.-. '....-. a,.....*._e-s, a-d - c.:.e..=.d. e
- .' -. s t. s o.# a a',ses 2-.
4-2.i.. i. a.e..ss.
3 a e d Ve:- :. ca Lee,sau e.-..
assu..
.s
. a.. e as..u.
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....,..,... 35
.33
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3.,
ses,s.
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s
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., s.
au..
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19
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a'so e e-sdd-s e.-. d.
o*..
c.-..a.e.-.v".=v.
- -. cor=.
de..'
a_-
a..- a s ". c e..._',-
i dasign peccess =ay be suspec: by ' 's:srical evidence.
c The IDV review se:pe -ill be b cad enough i: :er=s ei des g: ele =ents c
< c.'ude sa=r'.s.'.-.-.ac*- se g e 'e_ - ca-. c'es4 _- o.gz ' e.'.-, -es.s_.4.-.. eac-e e --
.s a - d a.i c.- - -. -.-.. "- g d.' s -"-p ' ' _..
The design ele =en s :: be evaluated i clude:
C<.esl.e.........,....-... s.s s--
s.-
c....s cuss _.
.s 6
s.ee~.-. e.g,.x.
s.
s.
- -..,.- a.,
.c ec _..,.a_-. a...._ age,cags, se;s
- a. ana, s.:s,
.z t.. a-a.a.
.a d~s'-3_
'ss'-'e,-..-...'.-).
echan ca./:=,ec::ica,.
c: ne w syste=s a w, c =pocents (eg, pipe rup ure ces g:
pr ec-i:, svis=ic subsys ta= evalca t c=, ASMI c=de considera ticas,
a e,u',.c e _-. c," a ' ' a.'..-,,. e _ e.. z - '. a ::e
..a'..
..u.
s n ' se,.a.'
.,c.= s -.-_,
a_.s.
.e_..,....
,.a s,5.,
s,5..-. _. _....,. c.;< s,...
...e.
s e ' s 4 c.=.. ".,- "-2 ' ' - : g-.ur..'.e s s ' - '..'. ' -
o - ".s e..' a. r. r....=..
.- d e s s c standards).
- sys~e ez o a.c
..,..a. e_.es (.,u.a
._e..s
.e. a c -- a...
r
-a.:.a.<.c,
--. - s s..
s.
3e-g_..... s ;. _... a - d.-.-. a.i c, e. a...-, ' ~: d. u t '.-.d.s_ _,.- v e. -.. - s s.-.
e
...,.e..,
e.
.sre.
.. r,. L.._. s,.
e s
c
... r
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i..,..s.
1.aa - s u-
- s.....a.
s,s...
z.a e...
1.:
s:s...
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s.. -..._-..s
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s:
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20
' 2 _sV ud..i.t k. e c.- d " -.. >. c:.de.- y. o j a c. L:s..-".-.# - s a.- d. p.. c. d.u.-. s.' a.
vd._' _i PP
<a,"__'__= a r.. a.- -. d..' s..- -, t:.. s o be doc"*e:..*d. -
_-*u "cc..'- - v".ew.
s Initially, these findi:gs will be categorized based upea the lead reviewer's judge =ent as c s atus as follows:
,)
0,ye_._
ca_.a_a_g _as
.u p o. e _.. _ar,. : o... sec.c_a_.g a c..__a _e.
.._e
,.u..
a add...'..a.'
.' - ~. e s. _ s..'.- _ o. c.~ ~ _' _d.-_ a...-~, a _~ a ' is.' s.; s c.- c.- s s a -;
' a-
.. - _ake a
_ __. a. j u. e g._ e _...,
33
- c.._:a...e.
.d'_g.is. iud-.d.
s b e a. a,..-._-
v.
'..-.v'..w
..... a _. a..; a_ _ _-....a.
c..
...aye ae.d.n, su _ as add'..c.a.'
.' e c "__ e _-..* - '.-.
_ee u.<,a_..a_ u.,
....no.u. n. a e__-._._.,
.s,n. a.....:.
.u.. e
.z a _- a.__..,
addi-iccal L:alysis, design or constructica changes or pr:cedural changes
-hat may be necess'ary to resolve the.. finding; ge 3 ',
.=.e s c.'. e d.
~
. u _#_"_ - _ _ _-. ad _'* s'
' _.* -. _ a..' - - " a s a ", a '..'.= c.'
__..'. - - -. '__ g
.3
.- a. v. - v....- s.a '. -..... c.' _ g s a c. o c.mp.'.-.. _,..1 s e. u. a -, a d.".'..'
t
. c. c.._., x. c.... _s.
.s.e _ s e__. g s.
u.
A d d". e....1.',,.' ' _- d ' _. s ad._' _i k*e ca ego
"..-d as.o "..'et_ke.
or -.-
.-~ a.#.#...
z_u. _r;, s2.:.,
- __e.a r, _a. e _.,_a _....a....._ 2.
ag.a.a.a...a.,
2., s _; _- :. _:.
_.2. _...
3 v.
_-, 3. 3 _.. a.. s.
3 a.1 _. y
.w.
. - s. -. v..-.s e. s..-
.- a c_." ' s, e s.....-..#
.a _-
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.sa_ _- a. _..
2.s
.u
.s.a. ys.:
, ch _a j o.
e s.'.-_ e.:._ e _- -..-..s c_ a -.2 a k.1..- s ag.,
.w
. e._. g a. s... a.,
2_;. s..a _. _,... _, -_.e
.y,
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_s _. a i__..,..,... _,_. _...
.u.
3 3.....
r......
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.a : a _..._. o r..s e i. e
..e
.. _. _. _a _.. g g __ a.. - a s s ".....'.-
s
. a s s '.....,..'.-. ' s.......
..
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a s.... '.= *..= d.
.- = v..= v,..' c _-
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s..-....,;
se_._...
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._-....s.
2,.
yero..w_.,. v. _*,. 3e 4.
...o s.2g.s, 1.'
_d_a a_.d
'. ' _ a.'.
". ' e p...' _# _" 2.,
w yeper., i cluding -he findings, as sdified by.se senio: review
- aan, v-l, be l
I p::vided :: Censu=e.s.2.we-C
,.a,. '. ~..vd..a v bv.
- a. ' - c. e_ g_# _a 1 d.= s # gr.. s.
pre.3 =.ua.7 reper will p;sv. de an oppo: :i.r for addi-ic a1 infor=a tie:
be supplied which cocid have as impac: cc.he findings bu: was not.c. w
.e 9
.w..- cv 3.
4.--
i,
....-~~
~2_.
.s.-. c e_.. s, a d.d.' '..' o.- I
- d..# c. a. #..- - a c' c.'.a s-s findi:gs will be cai.aised is an audi able manner.
T e final repe:
v.11 s i - z.-"
vo.k a c. --r 1 ' s 'a e d.,
. - c c'...- s u s e d. a - d.' -..'. c'. a... l.a..-
.acsc..,......:..... a._
._._.s _.gs.
i 8
g..
m 9 6 l
)
. -.. l
Al i t APPD*DIJ' 4
c.o._r < OLtS
.2..c e_r_c.e v_r.y..c
.v
.:.. ey.
AND CwN e._.,,C_..mN w,.L....~. :
e
-u d._VD c..
.w ae-a.
4
"' s. o. '. c a _' ',, ~- ~ s t_ e s. 3 -. e.- C. _-f a _-, a _" - s
.- -...' c..'. s a v e ' e._-..-...'... ".
o o cerfor= -heir work using QA progra=s wcich resc. ocd :o all 10CTR50 A::endix 4
1 3eua., <.7, a. s s.. _ a _. c c._a....a. a.
s o.
In addition to -he Cocsu=ers Power Cocpany audi:s in the areas of desig: and s. s. ~. ~. e...'.~ ~,
_' - C ~~ c y. ~ v. '_ a s ".. _' _' _' _ _- A_ ou-s=
su_'.a_-
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.~.~ s " e _ s.=. ue - C. -ra _~ ~,.'.'. ___ a _, ma _' _.~ a' t.".'. s ". e_- -
- . _a _. s. _a _. s...... s. a _.,:;:. 1 g ye..
sa se.,g~._..,-... ;._.. ;
a-
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s
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.u
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, age,-1c_,
.a t
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, e. a s._-,.' _' _ g '. a s. s,
t.'..deg--- o#. c e, t' _' a -..- v d.._*.. ' -
g_-<__.
a s u==a re of -hose audi s are as follouc _-
.c_.
22..__._._,-.
.s....
a.
-. t. _.u_..
2 ee. c, 3 < _. _.. _.. _:
nu a _s _e. _2.- s _e..ys c
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y
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Tescis6 Co= pac 1 (NA! 0) and i=cluded approx =a cely 24 =a -dav. s o f sudi:
e :..:.._
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.a _._o t _. e. a ug a g_a _g.:., : age,.
7 a s a___, _, __ e _. 2. a..
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r,s
_._.ye..e. agga._i_.g :.,ge. ae./ 1.s 7
2.e._-..:
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Ass. a.c. w... a... a _3 we.a.a_.a
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a
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QL.2_i _e -~, Aud_'
was send"-..d. 'y
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o
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a g _.. t. a c_,
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s the Censu=ers ?cwer Cc=parv QA Fregra: Precedures at -he Consu=ers ? cue:
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or.
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t addi-ict, the audi-i:velved auditing for adequac7 and i=ple=e 2 :c: of 4
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I: 1980, the 3iennial Quality Audii_ gas _conduc ed by :he da: age =e:-
w i
es a
e
.._a.,s.s. __,_._ r,v:c) s_.a._--_ a a.
.r,...x:_,.,:_ te
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s c' e ~. _, c, 1 - " '-.'.___.a.....#.
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C era _-~; G e _.. a.1 w'.'#.e..- -_-.?acs:se, _"_' e.__ s _- a _- d at s
'a
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c.'...
w add _d
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_' e a u d_' - ' _- ve.' v e d. aud.'- _g.#e ace,"ac, a.d._-rt'._e_.-
i
- .._... :.....Nu _'..*. w^ ua _i ' -~ 2.s s ".- = -.
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this audi-have bee: closed ou.
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cc: ificates of c:=pliance, and 3ech:el -'_AC3 prog 1=), and assess =ent of 3cchtel and Consu=ers perseccel (3ech.el QC a:d audi:ers, Ce:su=ers audi ::s,
t a:d 3ech.el welders' cualificatie ).
Startiss is '.C7: upcc de discovery of =:.ssi:g rebar in three areas cf :he auxiliary building (la a
- tis was de:er=ized to set be a safe:7 pr ble=),
C..s" e s _'..s.#.-,..d a
su..e4a..c,. o#
c.- s.-" c. ' a c
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2: August 1980 de Qu.ality Assurance Orgari:2: ices of Ccesu=ers ?cwer C:=pa 7 a. d.: e..'... '
we..
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4.-. ece h
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Consu=ers ? ver CQ;.
pr:vides design and procure =en: quali:7/ reliabili:7 s e..-#... s
.- c_i__....-. _--. c a_-d ez._2/.c.-b.'
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September 1982 Criteria Preliminary Per':ormance Ob.ec"ives anc Cri':eria Or CONS":rUC': ion
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f C 1982 Insttute of Nuclest Power Operations. Umrted reproduction by INPO members and participants for intemat company use is permitted.
NOTICE: This document was prepared by the institute of Nuclear Power Operations (INPO). Neimer INPO.
i memoers of INPO. etner persons contnbuting to or assisting in the preoeration of the document. nor any person
[
acting on tne oehart of any of mese parties ia) makes any warranty or representation, expressed or imphec. wim respect to the accuracy. competeness, or usefulness of the mformation containec in mis document, or mat the use g
of any information acoaratus. memod or process disclosed in mis document may not mfnnge on pnvately owned T
ngets. or (b) assumes any haoilrties witn respect to the use of, or for damages resultmg from the use of any mformation, apparatus. memod or process disclosed in mis document.
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1 lL PERFORMANCE OBJECTIVES AND CRITERIA FOR CONSTRUCTION PROJECT EVALUATIONS INSTITUTE OF NUCIJ:AR POWER OPEKATIONS t
September 1982 i
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e PRELIMINARY l
For Use In 1
SELF-INITIATED EVALUATIONS j
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l h-FOREWORD i
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In early 1982, utility nuclear power plant construction'-
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problems stimulated industry initiative and action to ensure that programs in effect nationwide meet performance goals as intended.
Accordingly, the Institute of Nuclear Power Operations (INPO) was tasked to develop and manage a construction project j
evaluation program.
The first effort was to define performance I
objectives and criteria for project evaluations.
Use of the criteria is intended to provide considerably more depth than an audit, for an audit generally is regarded to be no more than a check of the paper trail.
An evaluation includes some assessment of administrative records, but more important it focuses on s
evaluating the quality of the end result of implementing the project systems and procedures.
It also includes assisting the utility by transferring technology, management systems, and pro-cedural systems when the utility is not as strong as has been observed elsewhere in the industry.
Such an evaluation can result in an uplifting, or upgrading, by specific recommendations on how to achieve a higher level of excellence.
This program is not intended to evaluate whether or not the design is adequate.
Rather, the program will evaluate if the design documents are controlled and if the plant is being con-structed as the design specifies, therefore, design control and quality of construction are the key objectives being evaluated.
These performance objectives and criteria are intended for
~
use by INPO member utilities and third parties in the evaluation of the quality of engineering and construction of nuclear power plants.
The scope of this document addresses the phase of the project beginning with the plant design process and extending
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through design, construction, and testing te issuance of the
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Nuclear Regulatory Commission operating license.
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The performance objectives are broad in scope; each gener-i ally covers a single, well-defined area.
The supporting criteria l
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f-are more narrowly focused statements of activities that support or help m.eet the performance objectives.
Several criteria are
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listed under each performance objective.
t Corporate and project organizations among INPO member utilities vary widely.
Accordingly, no specific organization has been assumed in developing this document.
The areas addressed represent those relevant to achieving the highest standards in
{
construction of a nuclear power plant.
Rather than addressing a specific orgitnizational structure, the program is' designed to i
evaluate the systematic control of functions and approaches that are necessary to pr. educe the desired results for project comple-l tion.
The performance objectives and criteria emphasize manage-f ment involvement in the design and construction of a nuclear power plant, since monitoring and control at the management level are essential to the achievement of an optimum end product.
t i
$ ~
This document is intended to provide a basis for INPO and
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l INPO member utilities to assess the qual-ity of utility management f
in selei::t areas related to nuclear plant design and construc-
. tion.
Since the performance objectives and criteria are intended for use in evaluating the results, they do not necessarily pre-l scribe or establish methods of achieving those results, t
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V PERFORMANC~. OBJECTIVES AND CRITERIA FOR CONSTRUCTION PROJECT EVALUATIONS NH PART TITLE PAGE i
OA ORGANIZATION AND ADMINISTRATION..................
1 OA.1 ORGANIZATION STRUCTURE...........................
3 OA.2 MANAGEMENT INVOLVEMENT AND COMMITMENT I
TO QUALITY.....................................
5 j
OA.3 TEE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS................................
8
~
l DC DESIGN CONTROL..................................
11 DC.1 DESIGN INPUTS...................................
13 i
DC.2 DESIGN INTERFACES...............................
15 DC.3 DESIGN PROCESS..................................
16 i
DC.4 DESIGN OUTPUT...................................
18 DC.5 DESIGN CHANGES..................................
19 a
1 CC CONSTRUCTION CONTROL............................
21 CC.1 CONSTRUCTION ENGINEERING........................
23 CC.2 CONSTRUCTION FACILITIES AND EQUIPMENT...........
25 CC.3 MATERIAL CONTROL................................
26 I
f CC.4 CONTROL OF CONSTRUCTION PROCESSES...............
27 f
i CC.5 CONSTRUCTION QUALITY INSPECTIONS.............'...
28 l
CC.6 CONSTRUCTION CORRECTIVE ACTIONS.................
29 CC.7 TEST EQUIPMENT CONTROL..........................
30 PS PROJECT SUPPORT..........~.......................
31 PS.1 INDUSTRIAL SAFETY...............................
33 PS.2 PROJECT PLANNING................................
34 PS.3 PROJECT CONTROL.................................
35 PS.4 PROJECT PROCUREMENT PROCESS.....................
37 i
PS.5 CONTRACT ADMINISTRATION.........................
38 e
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l PART TITLE PAGE L
PS.6 DOCUMENT MANAGEMENT.............................
39
....................... 41 TN TRAINING.........
TN.1 TRAINING MANAGDENT SUPPORT..................... 4 3 TN.2 TRAINING ORGANIZATION AND ADMINISTRATION........ 44 TN.3 GENERAL TRAINING AND QUALIFICATION..............
45 TN.4 TRAINING FACILITIES, EQUIPMENT, AND MATERIAL.... 46 QP QUALITY PROGRAMS................................
47 QP.1 QUALITY PROGRAMS................................
49 QP.2 PROGRAM IMPLEMENTATION..........................
50 I
QP.3 INDEPENDENT ASSESSMENTS.........................
51 QP.4 CORRECTIVE ACTIONS.............................. 52' TC TEST CONTROL....................................
53 TC.1 TEST PROGRAM....................................
55 TC.2 TEST GROUP ORGANIZATION AND STAFFING............
56 TC.3 TEST PLAN.......................................
57 TC.4 SYSTEM TURNOVER FOR TEST........................
58
TC.5 TEST PROCEDURES AND TEST DOCUMENTS..............
59 TC.6-SYSTEM STATUS CONTROLS..........................
60
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I CA.1 ORGANIZATIONAL STRUCTURE PERFORMANCE OBJECTIVE
)-
The owner's corporate organization and all other project l
organizations responsible for the design, engineering, planning, scheduling, licensing, construction, quality assurance, and testing of a nuclear plant should provide an organizational structure that ensures effective project management control.
CRITERIA A.
The project organizational structure is defined clearly and establishes. an effective relationship among the owner's and contractors' responsible executives and managers for design, construction, procurement, plan' ning, testing, quality assurance, and licensing of a nuclear power plant to support the success of the project.
B.
Managers associated with the project, either owner's, nuclear steam system vendors', architect / engineering ~
firms', or contractors', at the executive, corporate, project, design, procurement, construction, start-up, operations, and quality assurance levels, understand clearly their relationships regarding the project, including their authorities, responsibilities, and accountabilities.
C.
An owner's manager is assigned responsibility for the project activities (hereafter referred to as project i
manager).
This is his primary responsibility and preferably his sole responsibility.
Also, he has the authority to direct the project.
D.
The owner's project-level managers are assigned respon-sibility for the following listed functional areas in support of the nuclear project activities.
Sufficient authority is held by each individual to carry out assigned responsibilities.
I I
4 1.
project control, including planning scheduling, i
and cost control 4
2.
engineering, analysis, and design control f
3.
procurement control j
4.
construction control j
5.
management information systems 6.
training and qualifications
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7.
construction testing and turnover control j
8.
quality assurance j
9.
material receipt, handling, storage, and mainte-I nance i
10.
record and document management' 11.
legal and licensing requirements
~
12.
staffing, personnel policy, and salary administra.
l tion E.
The project manager exercises control in those func-tional areas assigned to managers who do not report to him to ensr e that the plant is engineered, designed, constructed, and licensed in a manner resulting in a j
safe and reliable plant.
F.
The project manager's relatior} ship 'to higher corpo. rate management and ultimately to the chief executive I
officer is defined clearly and documented.
4 l
G.
Clearly defined access to the project manager is pro-1 vided to other managers having responsibility for the functional arena under Criterion D.
H.
Corporate administration of contracts is delegated clearly with. contractual obligations well-understood and enforced.
Responsibility and appropriate authority l
for prompt action on contract changes, renegotiations, or violations of contracts have been assigned.
I.
Staffing for all project organizations is adequate for the authorities and responsibilities assigned.
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,OA.2 MANAGEMENT INVOLVEMENT AND CC""ITMENT TO QUALITT i
b PERFORMANCE OBJECTIVE Senior and middle managers in the owner's corporate office, b
designer's office, and at the construction site who are i
assigned functional responsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness, and knowledge, a direct involvement in significant decisions that could affect their responsi-bilities.
A.
Procedures or written statements of policy address subjects relating to the engineering, design, and con-struction of nuclear projects.
They include policies related to project quality, such as workmanship, problem identification and correction, action item tracking, reporting, and procedural compliance.
B.
Project personnel in the corporate office and at the construction site and designer's offices are aware of these procedures and policy statements and have them readily available for reference.
They are able to explain how they are put into practice.
C.
Project personnel demonstrate compliance with these policy statements and the statements have a high degree credibility D.
Both vertical and horizontal communication of signifi-cant problems and corrective actions are eff ective and coordinated to provide an accurate representation of conditions.
E.
Meetings involving corporate and project management personnel result in the regular review of key aspects of the nuclear project.
l l
F.
Corporate managers are made aware of and utilize appro-priate design and construction progress data and trends in setting goals and objectives and in management
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~
decisions involving the project.
~
G.
Methods are established that permit data and trends to be compared with results at other utilities with similar construction projects.
E.
Corporate managers responsible for the nuclear project are familiar with activities and reports that affect design and construction.
They are cognizant of and sensitive to problems and external factors that might
_,j aff ect progress or quality.
Examples of such involve-ment include the following:
1.
review of applicable audit, evaluation, and inspection results conducted by internal and external organizations 2.
personal interface with the engineering, design, and construction organizations and personal observations of their activities 3.
review of industry's engineering, design, and con-struction experience and trends 4.
review of project. plans an'd schedules and reports of aetual progress versus planned progress 5.
review of worker performancefindicators such as rework and reject rates I.
Management support and actions reflect appropriate attention to areas such as project management, scheduling, planning, st'affing, training, personnel i
relations, and owner-contractor relations that affect project quality.
J.
Corporate managers responsible for nuclear matters are committed to seek out and employ methods and informa-tion systems for identifying problem areas and their
(
underlying causes and for taking coordinated, correc-tive action to eliminate these problems.
s
D3si;.ated manegers associatGd with tha projcet heva K.
responsibility and author'ity, by policy and practice,
~I to stop or delay engineering, design, or construction activities when their judgement indicates that contin-untion will result in a failure to meet the project objectives.
Management accountability for the project is consistent L.
with the project structure and extends to the contrac-l tors, architect / engineering firm, and nuclear steam i
supply system supplier contractor.
M.
A complementary relationship is evident between manage-ment and quality assurance that supports implementation of a strong corporate cammitment to quality.
N.
Decisions are made known to appropriate individuals for implementation.
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OA.3 THE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS
(
l PERFORMANCE OBJECTIVE
~
The project first line supervisors and middle managers should be qualified by verified background and experience
{
and have the necessary authority to carry out their fune-
~
tional area responsibilities.
CRITERIA l
A.
Position descriptions or the equivalent are employed for each key management and supervisory position.
B.
Minimum qualification, experience, and training requirements are ' defined for project first-line supervisors and middle managers.
C.
Authorities and responsibilities are defined clearly.
Personnel clearly understand and accept their relation-ship in the organization and their authorities, respon-sibilities, and accountabilities.
D.
The first-line and middle managers are actively and personally involved in the nuclear project functional activities.
Functions that co,uld be performed include the following:
1.
approval of qualification requirements for posi-tions that report directly to them 2.
provisions for input to and understanding of pro-ject policies governing each functional area I
covered in this document 3.
assessment of selected programs and activities relating to project acti'vities, including follow-up on corrective actions 4.
close involvement with safety review groups per-forming independent reviews of matters affecting g
safety and reliability L
5.
assurance that eff ective actions are taken on
- reports of significant and unusual project defi-(
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ciencies in the managers' areas of responsibility 8-
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ragular revisw of project statun and curront
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problems t
7.
review of selected data and trends discussed in the functional sections of this document 8.
monitoring of organization's performance against established goals and objectives J
9 involvement in and understanding of trending pro-grams and corrective actions related to developing adverse trends 10.
active involvement 16 ensuring that construction practices and procedures are followed in a manner that enhances the quality of the end product 11.
responsibility for ensuring that workers are quali-fied for their individual assignments and that they perform their work to project standards The project middle managers are-sensitive to the need }
E.
to control work assignments to ensure that project-related effort is not diluted.
Appropriate supervisory, technical, and procedural F.
training is conducted for first-line and middle mana-gers having responsibilities for functional areas in support of project activitids.
Appropriate records of attendance, material presented, and test results (if are retained to document this training.
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'DC.1 DESIGN INPUTS i
PERFORMANCE OBJECTIVE Inputs to the design process should be defined and con-
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trolled to achieve complete and quality designs.
l CRITERIA A.
Design inputs such as codes, standards, regulatory commitments and requirements, criteria, and other design bases are identified, defined clearly, docu-mented, evaluated, approved, and their scope of appli-cability is define'd prior to their use in the design process.
B.
The design inputs include consideration of all of the requirements necessary to produce a quality design including feedback from pertinent industry engineering, design, and construction experience.
C.
Plant constructability, operability, inspectability and maintainability are considered in plant designs.
D.~ The design inputs are provided at a level of detail and clarity necessary to be useable and understandable by all persons using these inpues.
E.
A systems, components, and materials experience infor-mation base, to the extent available, is a key element in the design process.
Specifications for key safety-related equipment that does not have a substantial service history contain a requirement for supplier acceptance tests.
F.
The issuance and use of design inputs is controlled by the use of complete and understandable procedures.
G.
All changes to the approved design inputs are docu-mented and approved prior to their use.
f H.
Design personnel utilize supplier expertise as appli-cable in the design process.
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Design and design control information is readily available for use.by all design personnel.
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Design personnel utilize supplier expertise as applicable in the design process.
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DC.2 DESIGN INTERFACES 3
PERFORMANCE OBJECTIVE
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Design organization external and internal interfaces should
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CRITERIA A.
Design organization engineering authority is documen-ted, and limits of responsibility and authority are defined clearly.
B.
The flow of design information between both external l
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and internal organizations is controlled and timely.
C.
The external and internal interfaces and responsibili-i ties are defined and controlled by procedures.
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Oral and other informal means of communication, including letters and memos, which provide significant
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design information, are confirmed and promptly made a h
part of the design input by a controlled document.
E.
System interaction is considered in system design and l
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Systematic and effective lines of communication are established.
G.
Design and design change information are coordinated i
effectively with all affected disciplines and operating
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E.
Transfer of design responsibilities and documents from one organization to another is planned and implemented i
in a controlled manner.
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l DC.3 DESIGN PROCESS t
PERFORMAJCE OBJECTIVE l
The management of the design process should result in l
designs that are safe, reliable, verifiable, and in com-f f
l pliance with the design requirements.
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The design process is documented, planned, and sched-J uled to ensure an orderly, sequenced process for completing design.
j B.
Responsibility for controlling each function of the l
design process, including the preparation, review, and approval of input, in process, and output documents, is-defined clearly, documented, and understood.
C.
The overall design review process includes system design reviews; verifications of calculations, methods, and computer runst and validations of computer codes and models.
The reviews or verifications are performed by individuals or groups other than those who performed the original design.
D.
Design documents include scope and applicability as well as the identity of the originator and checker.
E.
Calculations and analyses clearly specify information such as applicability, assumptions., design inputs, references, methods, and results in a manner that j
allcws a technically qualified person to understand the i
calculations or analyses.
F.
When an independent check of calculations and analyses is required, it is performed by a technically qualified person, and the method of checking is noted on the documents.
G.
Design process problems are identified, and decisions I
are made to resolve the problems in a timely and effec-tive manner.
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Supervisory and management involvement in the design j
process is evident by the quality and timeliness of the output information and resolution of design problems.
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Design personnel provide timely technical support'and follow-up on systems they have designed.
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Design processes are monitored for compliance with design commitments.
K.
Design control measures, such as procedures and check-lists, are used to ensure that design inputs, such as design criteria, design bases, regulatory requirements, codes, and standards, are translated correctly into design documents, including specifications, calcula-
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Drawings, specifications, and other design documents are prepared under a controlled process that estab-lishes standards for pertinent items such as format,
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DC.4 DESIGN OUTPUT I
PERFORMANCE OBJECTIVE i
l Project design documents should specify constructable designs in terms of complete, accurate, and understandable design requirements.
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The purpose of each type of design document is defined I
clearly.
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Design output documents reflect a constructable, oper-able and maintainable design that :eets -the des.ign i
input requirements.
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The total design package is complete and understandable j
without the need for extensive coordination or inter-l pretation by construction or vendor personnel.
D.
The design organization is aware of the capabilities and requirements of the supplier and the construction organization.
E.
Sufficient detail, legibility, and clarity for inter-pretation and reproduction are provided in design output documents to facilitate correct implementation of the design.
F.
The design organization is responsive to the need for clarification of design output documents where these needs are identified.
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Design output documents are issued and kept current using a controlled process.
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- DC.5 DESIGN CHANGES l(
PERFORMANCE OBJECTIVE Changes. to released project design documents should be' controlled to ensure that constructed designs comply with 4
the most recent design requirements.
I CRITERIA A.
The design organization's response.is timely and effec-tive regarding identified changes.
B.
Reasons for the change are identified, evaluated, and, if necessary, actions taken to avoid future problems.
C.
The responsible ~ design organization considers inputs to
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the ori'inal design before a change is issued.
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Design changes are coordinated with any affected disci-pline and/or organization in a timely manner.
E.
Appropriate procedures and methods are revised if design changes make these revisions necessary.
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F.
Prior to the approval of the design change, consider-ation is given to quality, safety, cost, and schedule.
G.
Changes are subject to control measures commensurate with those of the original design.
H.
A system is utilized to determine whether or not the change being made impacts other parts of the system being changed, other areas of the plant, or other plants under construction.
I.
Methods are in place to ensure that changes are imple-mented in a timely manner.
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All changes, including those initiated by regulation, construction, vender, or design, are properly reviewed L
by the design organization and, if approved, incorpor-
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Appropriate design changes are evaluated promptly by each affected discipline, and necessary corrective action is taken and documented in a timely manner.
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Design change review' considers the change impact on I
items such as calculations, system functional require-1 ments, original safety analysis assumptions, inspect-ability, maintainability, and selection of equipment-
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CC.1 CONS"'RUCTION ENGINEERING j
PERFORMANCE OBJECTIVE Engineering and design performed under the authority of'the F
construction organization should be controlled as to consi-b stency with the basic design criteria to ensure compliance with applicable codes, standards, and regulatory commit-ments.
CRITERIA A.
Construction engineering authority is documented, and limits of responsibility and authority are defined
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clearly.
B.
Procedures are effective in controlling the engineering and design processes of the construction engineering organization.
C.
Guidelines are issued to ensure that the basic design criteria used by the construction engineering organi-zation is consistent with that used in the original plant design.
D.
Interface links between archi,tect/ engineering home office and the construction engineering group are efficient, effective, and defined clearly.
E.
Interface links among major vendors and subcontractors and the construction engineering group are efficient, ef f ective, and defined clearly.
F.
Construction engineering fi. eld change control is main-tained effectively as r.equired to support the construc-tion effort and to ensure final as-built conditions are defined.
G.
Construction engineering supports major construction
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equipment processes (e.g., special rigging studies and transportation studies) with calculations and design prior to important field construction effort.
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State-of-the-art engineering and design verification
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Adequate engineering and design issuance procedures are in effect to support the engineering and construction process and to ensure management awareness of generic,
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design or constructability problems.
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Field detail sketches and drawings for fabrication and f
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l and documents.
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Linkage to the document control system exists to ensure f
engineering and design documents are handled properly.
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CC.2 CONSTRUCTION FACILITIES AND EQUIPfENT s
d PERFORMA!"7 OBJECTIVE
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Construction facilities and equipment should be planned for, acquired, installed, and maintained consistent with project needs to support quality construction.
CRITERIA A.
A site plan has provided for key location of facilities such as warehouses, craft shops, equipment storage, and production facilities.
B.
Construction equipment is acquired in a manner to sup-port the construction schedule and is maintained in optimum condition to support quality work.
C.
Facilities and equipment, both temporary and permanent, meet the project needs and specifications, and are maintained in accordance with established requirements.
D.
Periodic inspections or surveillances of the work areas i
and activities are performed to ensure that facilities s
and equipment support construction needs.
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CC.3 MATERIAL CONTROL PERFORMANCE OBJECTIVE
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Material and equipment should be inspected, controlled,'and
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maintained to ensure the final as-built condition meets design and operational" requirements.
CRITERIA A.
The receiving process ensur'es that receiving inspec-tiens include evaluations of incoming materials and equipment against the procurement specifications.
This process results in proper and timely disposition of deviations.
B.
Materials and equipment are identified properly to control installation and use.
C.
Quality documentation for received material is accounted for, reviewed, accepted, filed, and retriev-able.
D.
Items received are processed in a timely manner to allow early identification of those items requiring special bandling,. storage, and preventive maintenance.
E.
Nonconforming items are identified and controlled to prevent unapproved use.
F.
Material and equipment storage, handling, and security are controlled effectively in accordance with specified requirements.
G.
The warehousing facility has an accurate inventory control system that provides for the effective location of items.
E.
The issuance process ensures that correct material is issued in accordance with engineering requirements.
I.
Effective preventive maintenance, including maintenance of cleanliness standards, is initiated at the appro-priate time and continues throughout.the construction process.
J.
Environmentally sensitive equipment is protected ade-quately from the degrading effects of temperature, humidity, and dirt.
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CC.4 CONTROL OF CONSTRUCTION PROCESSES 3
PERFORMANCE OBJECTIVE
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The construction organization should monitor and control all construction processes to ensure the project is com-plated to design requirements and that a high level of quality'i:s achieved.
CRITERIA A.
Construction activities are identified in advance to allow for development of procedures and selection, training, and qualification of personnel.
B.
Work procedures and instructions have sufficient detail to ensure that construction activities are in accord--
ance with engineering requirements.
C.
Construction activities are performed in accordance with work procedures, instructions, and current revi-siens of drawings approved for construction.
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Rework activities are performed in accordance with established procedures and are subject to required inspections.
E.
Work is performed by and under the supervision cf qualified personnel who recognize and accept a respon-sibility for quality.
F.
Proper tools are available and are used correctly.
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CRITERIA A.
The inspection process is defined accurately prior to the start of the work and is controlled to meet the requirements of the project.
B.
An effective system is in place to encourage the reporting of degraded quality.
C.
Inspection procedures are clear, define the inspection -
process in detail, and reference appropriate acceptance criteria.
D.
Inspections are integrated into the construction processes and work schedules.
E.
Inspections are performed using written procedures.
F.
Calibrated equipment used in inspectiona is of the proper type, range, and accura.cy.
G.
The quality control inspectors are separate from the production function.
E.
The records clearly indicate the scope of the inspec-tions, the inspector, and the results.
I.
Records are reviewed for completeness and accuracy prior to their storage in accordance with project requirements.
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CC.6 CONSTRUCTION CORRECTIVE ACTIONS j
PERFORMANCE OBJECTIVE
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The construction organization should evaluate audits, '
inspections, and surveillancesr process replies and follow-up; and take corrective action to prevent recurrence of similar problems.
CRITERIA A.
The construction organization tracks construction audits and surveillances, prepares well-researched replies that address the deficiencies, and takes prompt and effective corrective action.
B.
The construction organization evaluates audits for generic problems and trends and takes appropriate l
action to prevent recurrence.
C.
Nonconformances are identified, tracked, and closed out f
in a timely manner.
D.
The construction organization reviews nonconformances to ensure corrective actions have been'taken, evaluates 1
i for trends, and reports problem areas to upper manage-I ment.
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- l PER.FORMANCE OBJECTIVE Measuring and test equipment should be controlled to l
support construction testing effectively.
4 CRITERIA A.
Measuring and test equipment utilized for testing is i
identified uniquely.
i B.
Measuring and test equipment is controlled to ensure l
that only properly calibrated equipment is used for testing.
3 C.
Specific programs are implemented to provide regular calibration of instrumentation and to track status and i
calibration of each instrument used for testing.
D.
Special procedures are implemented to identify retest
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requirements when instrumentation is found to be defec-tive.
E.
The construction organization tracks equipment out-of-tolerance reports and work performed to correct work previously done incorrectly.
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The construction organization ' establishes regular main-l tenance and calibration intervals for all equipment and l
ensures timely calibration for each device.
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Calibration is accomplished correctly using certified equipment traceable to recognized standards or
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Calibration records are retained and retriev-1 able.
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PERFORIOLC OBJECTIVE
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The construction site industrial safety program should' achieve a high degree of personnel safety.
CRITERIA A.
An effective industrial safety program with clearly defined policies, procedures,, scheduled training requirements, and individual responsibilities is imple-mented with the full support of managers and super-visors.
B.
Selected data and trends of industrial safety activi-ties are monitored, including the following:
1.
summary analysis of first aid treatments 2.
analysis of accidents requiring doctord s care 3.
incidence of lost-time accidents 4.
frequency of safety violations identified i
C.
General housekeeping practices prevent the accumulation of debris and trash.
D.
A safe and orderly job site. working environment exists.
E.
Lif ting and rigging equipment is checked regularly.
F.
A fire protection program is defined, organized, and well-publicized.
G.
The site controls hazardous mate. rials effectively.
H.
A safety tagging program exists and is implemented effectively to protect equipment, personnel, and material.
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l PS.2 PROJECT PLANNING f
PERFORMANCE OBJECTIVE Project plans should ensure completion of the project to' the highest industry standards by identifying, inter-relating, and sequencing the tasks of the project organi-zations.
CRITERIA A.
The project master plan presents the interrelationships of tasks within and among the plans for the various elements of the project.
B.
The project plans are documented and approved by the appropriate level of management.
C.
The project plans are updated to reflect changing con-ditions.
D.
The project plans are communicated to the responsible project members.
1 E.
Clear lines of authority and responsibility exist I
between the individual assigned responsibility for plan development and those responsi,ble for plan implemen-tation.
F.
Individuals assigned responsibility for planning for each functional area of the project are provided the necessary data.
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PERFORMANCE OBJECTIVE Project scheduling and work planning and coordination should ensure that the objectives of the project plan are met t'brough effective and efficient use of project resources.
CRITERIA A.
Individuals responsible for functional areas demon-strate an awareness of the need for and knowledge of project controls and utilize these controls as required.
B.
Elements of work are defined into manageable segments that can be accomplished by a typical work unit on a definite schedule.
C.
Elements of work are defined in a way that identifies clearly the construction unit or discipline responsible for the work.
D.
Based on input and feedback from responsible project personnel, a controlling construction schedule exists that provides a plan for completion of work elements and commitments and that provides management with a clear, concise, and understandable method of tracking project milestone completion.
E.
Elements of work are recorded in a tracking system that is established prior to the work being performed and that allows project construction completion to be moni-tored based on installed quantities.
F.
Work elements are integrated into the construction schedule in a manner that facilitates construction erection sequence, minimizes interferences and rework, i
and optimizes project resources.
G.
Deviations from the project schedule and plan, caused j
by regulatory, productivity, design and other changes and interferences, are communicated to the proper level
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of management and analyzed for trends.
Corrective actions are taken to modify the schedule and plan.
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Quality control hold point inspections are integrated j
with the work activities.
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The work activities address support requirements for j
the segments of work to be accomplished.
J.
Work plans provide for a smooth transition from bulk scheduling to system completion scheduling.
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PS.4 PROJECT PROCUREMENT PROCESS d
PERFORMANCE OATECTIVE
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The project procurement process should ensure that equip-ment, materials, and services furnished by suppliers or
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contractors meet project requirements.
CRITERIA A.
Procurement documents provide clear and adequate tech-nical, quality assurance, commercial, and administra-tive requirements necessary to define the scope and requirements of the contract.
B.
The preparation, review, and approval of procurement documents are controlled in accordance with established procedures.
C.
A list of qualified suppliers or contractors is used to identify sources of quality products and services.
D.
Only those suppliers or contractors who are listed as qualified are requested to furnish bids or proposals.
E.
Proposals and bids are evaluated for compliance with the requirements and scope defined in the procurement documents.
These evaluations are performed by the l
personnel responsible for the preparation of the pro-curement specifications.
F.
The recommendation and contract award are conducted in accordance with established procedures.
1 G.
Subtier suppliers or contractors are contractually
)i bound to. adhere to related portions of the contract.
t Supplier and contractor performance histories are used l
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to improve the procurement process.
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Purchasing and contract documents are reviewed to ensure inclusion of requirements to achieve quality.
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I PS.5 CONTRACT ADMINISTRATION PERFORMANCE OBJECTIVE Methods for administering and controlling contractors and suppliers and for managing changes to their contracts f
should ensure effective control of performance.
CRITERIA A.
Changes are prepared, reviewed, and approved in a manner consistent with the original requirements.
B.
Changes are justified with respect to quality, safety, cost, and schedule and are approved by an appropriate level of management.
C.
All verbal or informal changes are approved and con-firmed promptly in writing within the guidelines of the change procedures.
D.
Performance is monitored, and corrective action is implemented as required.
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PS.6 DCCUMENTATION MANAGEMENT A.
PERFORMANCE OBJECTIVE s
The, management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /
inf ormation requirements of the plant's operational %.a==.
CRITERIA A.
A comprehensive records mangement plan and schedule exists to do the following:
1.' identify the documents and records required by regulations, purchase specifications, corporate requirements, and standards 2.
specify the minimum content and format requirements and acceptance criteria for each record / document type 3.
clearly designate responsibility for receipt, review of acceptability, resolution of deficien-cies, and control of documents during construction 4.
contain proper methods for declaring appropriate documents "as-built" during construction 5.
determine what, when, how, to whom, by whom, and in what format records will be turned over to the plant's oeprational staff B.
The records management plan is effective in identifying the current status of project documents such as the following:
1.
design drawings 2.
specifications 3.
structure / system descriptions 4.
vendor drawings and manuals L
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The records management plan effectively incorporates approved changes or revisions into the project docu-ments within an acceptable time fr'ame.
D.
The distribution system is defined and ensures timely distributier of current project documents to engineer-in'g, construction, and project support personnel within the project organization and to appropriate contractors and vendors.
E.
The project maintains master files of the latest revi-sion of project documents that are correct and acces-sible.
F.
Storage facilities provide secure maintenance of permanent and nonpermanent records.
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L TN.1 TRAINING MANAGEMENT SUPPORT PERFORMANCE OBJECTIVE Management should ensure that an effective program exists for indoctrination, training, and qualification of person-nel involved in the project.
CRITERIA A.
Corporate managers in each area have an active interest and involvement in the training program.
B.
Managers are trained and have adequate knowledge in areas related to their roles in the design and con-struction of a safe and reliable plant.
C.
Training is neither interrupted, deferred, or can-celled, nor are personnel diverted routinely from training to other activities.
D.
Management and supervisors are involved actively in assessing the qualifications and training needs of individuals with. respect to their. assigned tasks.
E.
Management makes use of feedback information to improve the effectiveness of the training program.
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Actions taken as a result of monitoring training and qualification trends are reviewed by appropriate levels of management on a periodic basis.
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The training organization and administration should ensure l
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effective control and implementation of training activi-ties.
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CRITERIA A.
The training organization is defined clearly.
B.
Training and qualification goals and objectives are established.
.j C.
Training and qualification efforts are governed by procedures that outline responsibilities of the train-I ing organization.
D.
Training personnel are provided training and opper-tunities to enhance their performance as instructors.
E.
Training programs address organizational needs at j
appropriate levels.
F.
Technical and nontechnical training requirements for individuals are defined clearly and documented.
G.
An active program exists to ac. quire feedback for the purpose of developing, modifying, and improving the training programs.
I H.
Training activit.ies are conducted regularly, and results are documented.
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TN.3 GENERAL TRAINING AND QUALIFICATION PERFORMANCE OBJECTIVE l
The training program should ensure that all employees receive indoctrination and training required to perform l
ef f ectively, and that employees are qualified as appro-priate to their assigned responsibilities.
CRITERIA A.
Initial selection, training and indoctrination enable individuals to perform assigned responsibilities effee-tively.
B.
The previous'qutlification and training of new hires I
and transfers are verified.
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Individuals are qualified as appropriate for their j
assigned responsibilities.
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Training on a continuing basis, both formal and on-the -
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job, maintains the amployee's ability to perform con-l' sistently and effectively.
E.
Continuing training provides an effective means o'f keeping employees up-to-date-regarding changes'to policies, procedures, processes, instructions, and commitments.
F.
Individuals are requalified or recertified as required to keep their qualifications current.
G.
Feedback is acquired and used to modify and improve l
training methods and content.
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PERFORMANCE OBJECTIVE
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The training facilities, equipment, and material should support and enhance training activities.
CRITERIA A.
Classroom facilities are provided for group instruc-i tion.
B.
Reference materials are up-to-date and readily acces-sible.
C.
Equipment is available as needed to support training material development.
D.
Training aids and material are provided to support the program.
E.
Test and certification records are available and are updated regularly, and a follow-up system for required recertification of personnel is utilized.
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The quality assurance program scope, content, and applica-bility should be appropriate, defined clearly, and under-9 stood.
CRITERIA A.
The quality assurance and quality control programs include all necessary program elements.
B.
Day-to-day activities are observed and monitored under a continuing program derigned to ensure the highest quality of personnel performance, workmanship and attention to detail.
C.
The quality assurance program is applied to the project in an appropriately graduated way.
D.
The relationship between manuals and the applicability of procedures is defined clearly and understood.
E.
Audit and surveillance schedules.are modified as appropriate to verify the effectiveness of program implementation and to reflect the need for increased monitoring.
F.
The utility conducts evaluations of contractors' quality assurance program with sufficient regularity and in sufficient depth to ensure program effective-ness.
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The programs provide for indoctrination and training of personnel as necessary'to ensure that suitable profi-ciency is achieved and maintained.
H.
The "stop process" and "stop work" authority is under-stood clearly and implemented effectively.
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j QP.2 PROGRAM IMPLEMENTATION PERFORMANCE OBJECTIVE Quality assurance and quality control functions should be j
performed in a manner to support and control the quality of f
i the project activities.
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CRITERIA A.
The relationship of the quality assurance and quality I
control organizations with other organizations and individuals is defined clearly to ensure their i
independence.
B.
Quality assurance and quality control personnel experi-l ence a cooperative relationship wi'th other project f
personnel and are free of harrassment and' intimidation.
I C.
Quality assurance and quality control areas function in t
i a manner that supports management.
D.
The quality assurance programs of vendors and contrac-tors include measures to achieve quality and are implemented in an effective manner. -
E.
Project organizations utilize technical specialists in j
I the implementation of the quality requirements.
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QP.3 INDEPENDENT ASSESSMENTS N
PERFORMANCE OBJECTIVE Management should provide an effective, independent assess-i ment of project activities affecting the quality of the project.-
CRITERIA A.
A plan is implemented to ensure that audits and surveillances effectively assess applicable project activities in a timely manner.
B.
The results of the independent assessments identify substantive issues affecting performance.
D.
Independent assessments are performed by individuals,
with no direct functional responsibilities for the area being assessed.
E.
Independent assessments are performed by individuals suitably qualified to conduct the assessment.
F.
The analysis of the assessments properly evaluate the activity assessed.
G.
The results of the assessments and evaluations are directed to and used by the management of, organizations to improve their effectiveness.
H.
Periodic evaluations of the effectiveness and adequacy of the total quality program are performed.
Results are reported to the senior management level, and appro-priate action is implemented.
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I QP.4 CORRECTIVE ACTIONS l
I PERFORMANCE OBJECTIVE conditions requiring corrections or improvements should be i
resolved in an ef f ective and timely manner.
1 CRITERIA A.
Conditions adverse to quality are reported promptly and l
accurately.
i B.
The responsible organization assumes its responsibility for and its management is involved in and supports the i
l correction of adverse quality.
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C.
The senior levels of management are apprised of adverse f
quality conditions and hold the responsible supervisors' l
accountable.
D.
Corrective action resolves not only the reported item, l1 but also the basic cause in a manner that ensures the quality of future activities.
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E.
Effective corrective action is taken in a timely I
manner.
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F.
The quality assurance, quality' control, and project organizations cooperate in identifying and solving problems effectively.
G.
Quality performance trends are developed and analyzed
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to effectively address' generic problems and basic causes of degraded quality.
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' TC.1 TEST PROGRAM i
h, PERFORMANCE OBJECTIVE
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The test program should verify the plant's full capability g
to operate as intended by testing the plant's systems functionally.
CRITERIA A.
A clear policy is developed and endorsed by top manage-ment that describes the test organization's responsi-bility for component, system, and preoperational testing.
B.
The principal design organization is involved in formulating test objectives and acceptance criteria..
C.
The test program describes the scope of system testing, provides detailed guidance for conduct of testing, and includes methods for evaluation of completed tests.
D.
Nonconforming conditions and discrepancies are identi-fied and tracked, and appropriate resolution or corree-tive action is achieved.
E.
Adequacy of plant operating and maintenance procedures is demonstrated.
F.
The test program describes the quality assurance program under which it lunctions.
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TC.2 TEST GROUP ORGANIZATION AND STAFFING I
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PERFORMANCE OBJECTIVE The test group organization and staffing should ensure effective. implementation of the test program.
CRITERIA A.
The test group organizational structure and organiza-J tional relationship to interfacing organizations are defined clearly.
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B.
The staff build-up accommodates tbe early requirements for testing procedure and schedule preparation.
C.
The staff size is sufficient to accomplish the assigned, tasks as dictated by the test schedule.
D.
Permanent plant personnel are utilized during testing, to the maximum aztent practical, in order to enhance their experience and training.
E.
Key management, supervisory, and professional positions are described in writing.
F.
Personnel who are assigned to perform testing meet the experience and qualification r'equirements as delineated in the written position descriptions.
G.
Qualifications of test personnel are maintained.
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W TC.3 TEST PLAN
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PERFORMANCE OBJECTIVE The test organization should prepare a plan and a schedule that describe the sequence of system or component testing to suppbet major schedule milestones, j
CRITERIA A.
The plan and schedule are deve16 ped by personnel experienced in test and start-up operations.
B.
The plan and schedule are coordinated with the engi-neering and construction schedules so restraints are identified for project management action.
C.
The plant systems are scoped into logical, bounded, well-defined subsystems that can bq tested as units.
D.
The schedul'a for individual system or component testing describes the required elements of testing, including
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those systems required to support individual system testing.
E.
The status of testing is monitored by a trac, king system.
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f TC.4 SYSTEM TURNOVER FOR TEST t,
t PERFORMANCE OBJECTIVE
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I The construction testing and turnover process. should be g
controlled effectively to ensure that program objectives 1
are met.
CRITERIA A.
Jurisdiction is delineated for organizations respon-sible for the conduct of tests, acceptance of results, and turnover to succeeding test programs..
B.
Tests are performed and r.esults evaluated for confor-mance to design requirements.
C.
Retests are performed when necessary and are controlled to ensure completeness of verification.
D..
System walk-downs are conducted by appropriate and qualified individuals and entities who effectively identify engineering, maintenance, and censtruction deficiencies.
E.
System turnover procedures identify clearly partici-pants, duties, responsibilities, and documentation necessary for the turnover process.
F.
Turnover documents identify boundaries, material, equipment, deficiencies, and exceptions existing at the time of turnover.
G.
Turnover exceptions are tracked effectively and are corrected in a timely manner.
H.
The lead' design, construction, quality control, and testing organizations integrate project needs effec-tively and accomplish the turnover process in a timely manner.
I.
System and area cleanliness and maintenance programs (i
are continued during the test phase.._.
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TC.5 TEST PROCEDURES AND TEST DOCUMENTS PERFORMANCE OBJECTIVE
. Test procedures and test documents should provide appro-
.priate direction and should be used effectively to verify operational and design features of respective systems.
CRITERIA A.
The necessary technical data are used in test procedure preparation.
B.
Approved test procedures are available in advance of their intended use to allow adequate test preparation and training.
C.
The test procedures describe clearly the objectives,*
prerequisitse, system boundaries, and acceptance cri-teria for teses.
D.-
Test procedures receive the prescribed review before.
approval.
E.
Tests are performed in accordance with approved proce-dures.
F.
Necessary retesting is conducted when design changes occur during or after completion of the test phase.
G.
The results of the test program receive an independent review and approval.
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g TC.6 SYSTEM STATUS CONTROLS _
PERFORMANCE OBJECTIVE A ms'thod'should exist to identify the status of each system-or component and the organization holding control o't.juris-
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dictio'n ov'er that system o'r component to prevent,inturfer -
en' ii-Jahd 'ehsuru' equipment 'and personnel saf ety.. 3 c
l.
t CiUTERIA A.'I'~folicies an,d procedures. for piant status controis are u
implemented during tesi.ing.
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A. system is. implemented 't'o ensure current knowledge of B.
.the;statusefsystems((-
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2 jetivitiesaffacting.the,itatusofsystemsandchanges
.4 C.
'$fstatusareautho'r'ifed;b[designatedpersonn.el'and are appropriately documented.'
, Tagging systems are coordinated among the. var.ious D.
groups involved in the project to' ensure.contro'1. of
. status and of' equipmerit and, personnel.saf ety.
Procedures ar'e 'impleniented to iE51iall, control,. removei E.
d review peri 6dically, temp'rary field modifications.'2 o
an' Ju'risdiction and control od,tdo$struction work on sys, #
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tems after. initial turnover are.-defined clearly and implemented.i 2
Complfte and current system.documentatio.n packages, G.
- including all' changes add:.,[evisions gesulting,from-the'U' f
testing program,. Ara provided tii', ha. plant operating "*
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..... o uie : tse...c s. n.n me.o. J.:non. vi 4s2ot ts17> 7ss o4ss December 3, 1952 Harold R Denten, Director 2ffice of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555
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J G Neppler Administration, R':gion III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAFDNUCIIARC0GENERATIONP[. ANT MIDLAND DOCKET NOS 50-329, 50-330 MIDLAND PLANT INDIPENDF.NT REVIEW PROGRAM FILE:
B1.1.5 SIRIAL:
19750
?ITEPINCES: (1) J V COOK LETTER TO H R DENTON AND J G KEEPI.ER, SERIAL 18879 DATED 10/5/82 (2) NRC
SUMMARY
DATED 11/8/82 0F 10/25/82 MEIH NG CN INDEPENDENT DESIGN VERIF.ICATION Reference (1) provided a description of the Midland Plant 2ndependent Review Program.
Reference (2) summarized the October 25, 1982 anecting wherein Consumers Power Company and their contractors, Management Analysis Company (MAC) and Tera, discussed in more detail the Independent Review Program.
During this meeting, questiens posed by the Staff were responded to by the Company and its contractors.
At the end of.he meeting, Consumers Power Company requested the Staff to provide the applicant with policy guidance on the proposed Independent Review Program. The Staff agreed to provide preliminary feedback to Consumers Power Company by October 29, 1982 and to arrange for additional meetings as deemed appropriate.
This was subsequently done and an additional meeting was held on Neve=ber 5,1952 to provide the NRR Staff more details of the Stone and Webster third party assessment of the implementation of the soils underpinning verk.
-::S'2-0272a H:
A'PT'ACHErr 6
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Iased up:n the meeting of October 25, ICS2 and subsequent feedback from the
'!KC Staff
- nsu=ers Power preposes the folicwing changes to the Independent Review Proers: as sub=itted in Reference (1) and discussed at the October 25, 19S2 meeting-(1)
The three specific evaluations will not be.cc=bined into a single program with coordination of the individual reports by MAC.
(2)
The Tera Independent Design Verification ( DV) effort will be ccepletely separate from the MAC effort, with neither subcontractor having ne=bers from' their company involved in the other company's efforts.
(3)
The Tera IDV will be on the Auxiliary Feedvater Syste= (ATWS) as originally planned, and. will also be i=ple:ented on ancther system which the Staff is to select based on three' candidates provided by Consumers Power Company on a risk assessment basis.
The three candidate syste=s proposed by Consumers Power Company are:
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a.
Electric Power System (Diesel Generator) i b.
Safeguards Chilled Water System c.
Containment-Isolation System i
(4)
The Tera IDV will be expanded to include a more in-depth re' view of construction activities to provide assurance of as-b=ilt construction adequacy of the systems included in the Tera (IDV).
(5)
For the IDV, any discussions between project persons +1 and Tera on confirmed findings will take place in formal =eetings with the NRC being notified of the meetings in time to attend, if they desire.
(6) For the INPO Construction Project Evaluatica, a copy of the final report will be given to the NRC when it is sent to INPO.
We believe that this letter documents the conclusions reached between our organizations reEnriing the Midland Independent Review.
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JVC/GSK/bjb CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler. Esq JHarbour, ASLB i
GHa: stead, Harstead Engineering l
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.CO::52ERS PCkIR COMPAhT M_dland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 1975:- Dated Zecember 3.1932 at the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Feorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company subnits
- iiland Pitn- : ieperien-Reviee Pre rs=.
- 0NSUMERS P0kIR COMPAhT Ev
/s< J V Cook J V Ccok, Vice President Projects, Engineering and Construction Sworn and subscribed before me this 2
day of r.,e,g,._
egg
/s/ Barbara P Townsend Nctary Public Jackson County, Michigan My Commission Expires Septe ber 6, 190L 8e 4
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RC E a u::. - -
- --14-3121 JBeck.
'.dE>. (Dallas)
JEBrun.cr, M-1079 DEugl.es, Bechtel RWHuston, Washington RAWells, Midland DBMiller, Midland MIMiller, IL&B GSKeeley, P-14-113B LKube, MAC JARutgers, Bechtel PSteptoe, IL&B TJSullivan/DMBudzik, P-24-624A RITeuteberg, P-24-505 FCWilliams IL&B JDeMeester, P-24-414 DFJudd. B&W ELevin, TERA (Bethesda)
~~
NRC Chron File i
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1 March 18,1983 Mr. J. G. Keppler Administrator, Region lli Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. D. G. Eisenhut
~
Director, Division of Licensing.
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. ' 20555 Re: Docket Nos. 50-329 and 50-330 Miaicnd Nuclear Plant - Units I and 2 Independent Design and Construction Verification (IDCV)' Program The following information is addressed under this cover:
Corporate and Individual independence e
e Professional Qualifications e
Scope of Review Reporting and Auditability e
e Program Status CORPORATE AND INDIVIDUAL INDEPENDENCE Consumers Power Company (CPC) Contract No. CP10-8782-Q, executed on November 18, 1982 between CPC and TERA Corporation, specifies the criteria for corporate independence and individual independence of personnel assigned to work on the Midland IDCV program. The specified independence criteria are set forth in a letter from Nunzio J. Palladino, Chairman, U.S. Nuclear Regulatory Commission (NRC), to the Honoroble John D. Dingell, Chairman, Committee on Energy and Ccmmerce, U.S. House of Representatives, dated February 1,1982.
TERA Corporation has determined that the Corporation, its subsidiaries, and individual members of the Midland IDCV team satisfy these independence criteria.
Prior to this contract, TERA Corporation has never been under contract to Consumers Power Company.
1 i
ATTACHMENT T TERA CC :OMilON MC Vi!$ CONS N AVENA:
.e_ N2 205 M 3C': N 50 0 0
i LP Mr. J. G. Keppler, 2
March 18,1983 Mr. D. G. Eisenhut Mr. John W. Beck, Vice President of TERA Corporation and Principal-in-Charge of TERA's team which is conducting the Midland IDCV program has signed on offidavit on behalf of TERA Corporation and its subsidiaries which provides a statement of corporate independence (Attachment.1). In the event that outside specialized services (e.g., nondestructive examination or material testing, etc.)
are required to meet project objectives, TERA Corporation will obtain a corporate offidavit from the subcontracted organization as well as its assigned personnel.
Signed offidavits for members of TERA's team are ottoched (Attachment 2). Irt the event that additional personnel are required to meet project objectives and are assigned to the team,. TERA Corporation will obtain offidavits from these individuals os well.
PROFESSIONAL QUALIFICATIONS The personnel assigned responsibility for project direction, the Senior Review Team, lead technical review, technical review, and site activities have been selected based upon their unique technical and management qualifications and experience. Key personnel are listed along with a short description of their arcos of expertise, number of years of experience and highlights of their previous employment (Attachment 3).
Resumes have been provided previously to the NRC under separate cover in Appendix C of the Project Quality Assurance Plon, Revision 2, for the Midland IDCV program.
(
Reference:
Letters from Mr.
Howard A. Levin to Mr. J. G. Keppler and Mr. D. G. Eisenhut dated February 9, 1983 and February 17, 1983.)
SCOPE OF REVIEW The scope of review of the Midland IDCV Program is documented in Project instruction PI-3201-009, the " Engineering Program Plan (EPP)." This document is part of the Project Quality Assurance Plan and was previously transmitted under the some cover.
The IDCV approach selected is o review and evoluotion of a detailed " vertical slice" of the Midland project with a focus on providing on overoll assessment of the quality of the design and the constructed plant.
At this time, TERA is currently reviewing the Unit 2 auxiliary feedwater (AFW) system. This system was selected based upon criterio documented in Section 1.3 of the Engineering Program Plan which was discussed at public meetings held on October 25, 1982 of the NRC's Bethesda, Maryland office and on February 8, 1983 at Midland, Michigan. It is our understanding from these discussions that the NRC plans to expand the IDCV sample based upon condidate systems -
identified by CPC (
Reference:
Letter from Mr. J. W. Cook to Mr. H. R. Denton E - 07 Era
P y
Mr. J. G. Keppler, 3
March 18,1983 Mr. D. G. Eisenhut and Mr. J. G. Keppler, dated December 3,1982). We stand ready to provide you with our comments on this selection based upon the results of the Midland IDCV program to date and the attributes of the candidate systems which would in our opinion best extend the current system sample. The multi-disciplined ospect of the systems selected is critical to the effective execution of a vertical slice Midland IDCV program effort.
Our experience to date suggests that the selection of the AFW system utilizing the criteria which were documented in the Engineering Program Plan was successful in that this system provides for a comprehensive " test" of the project design and construction efforts throughout many technical disciplines (e.g.,
electrical, instrumentation and control, civil / structural, systems and mechanical) and interfaces.
An early selection would facilitate the overall efficiency and progress of the Midland IDCV program.
REPORTING AND AUDITABILITY From project inception the Midland IDCV program has operated in accordance with the reporting requirements that are documented in Project Instruction PI-3201-008, " Preparation of Open, Confirmed and Resolved item Reports, Finding Reports, and Finding Resolution Reports" (Also transmitted to the NRC with the PGAP.) and Section 5.0 of the Engineering Program Plan. The provisions of these documents are largely consistent with the opproaches followed at other independent assessments within the nuclear industry. We seek your comments and direction relative to these documents and offer any clarifying detail that you may need.
We are acutely aware of the importance of maintaining on auditable review process. Auditable records are maintained to document substantive elements of the Midland IDCV review and evaluation process, to document technical conclu-sions including the status of disposition of items associated with the review process leading to findings, to document the revision of records, and to establish quality assurance measures necessory to provide adequate confidence and assurance of the quality of services. Section 4.0 of the Engineering Program Plan establishes documentation requirements for engineering evaluations, calcu-lations, field verification, and external communications. Section 5.0 of this Plan establishes the requirements for reporting documentation. Section 6.0 of this Plan establishes the QA documentation requirements.
PROGRAM STATUS In the interim since our last status report during the February 8,1983 public meeting, the Midland IDCV program has progressed to the point where confirmed items have been identified. A confirmed item is judged to be on opparent finding by the review team and will require action, such as additional documentation not utilized by the team that documents the resolution of the item or additional analysis, design or construction changes or procedural changes that may be
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Mr. J. G. Keppler, 4
March 18,1983 Mr. D. G. Eisenhut 1
necessary to resolve the item. Confirmed items that are later verified become l
findings as defined in the Engineering Program Plan and Project Instruction PI-3201-008.
To date these confirmed items have not been distributed outside the Midland IDCV program; however, to reach disposition of these items, interaction with the responsible design or construction organizations is necessary to obtain any pertinent additional information that may not have been available to the review team as well as clarification. Prior to initiating this activity we would like to discuss with you our procedure for handling these items as documented in Project Instruction PI-3201-008.
4 Your earliest attention to these matters will be greatly appreciated. We are prepared to immediately respond to any questions that you may have. Please J
contact either me at (301) 654-8960 or Mr. John Beck at (214) 871-1075.
l Sincerely,
/
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Howard A. Levin Project Monoger Midland Independent Design and Construction Verification Program cc:
J. Cook, CPC G. Keeley, CPC/
D. Hood, NRC Enclosures Sworn and Subscribed Before Me This Day of March 1983
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' Notary Public Mr My Commission Expires en h*a Nr 1.19ei
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UNITED STATES
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..// 1 NUCLEAR REGULATORY COMMISSION 3.g,;f[f f,i l
WAS'ilNGTON, D. C. 20555 t
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gv March 22, 1983
,g A_ gpa Docket Nos: 50-329 OM, OL
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Mr.J.h. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Cook:
Subject:
Selection of Additional System for Midland P1 ant Independent Design and Construction Verification Program Your letter of December 3,.1982, noted that the Independent Design Verification effort to be perfomed by the TERA Corporation would be based upon the Auxiliary Feedwater System (AFWS) and would also be implemented on another system which the staff would select based on three candidates provided by Consumers Power Company on a risk assessment basis.
The three candidate syst' ems identified were
. (1),the electric power system'(diesel generator), (2) the safeguards chilled -
water system, and (3) the containment isolation system.
You further noted that the TERA program would be expanded to include a more in-depth review of construc-tion activities to provide assurance of as-built construction adequacy. Your letter of January 10, 1983, the associated meeting of February 8,1983, and TERA's Engineering Program Plan transmitted February 9 and 17,1983, provided further infomation regarding the expanded program.
The staff has reviewed the three candidate systems for the second system for TERA's Independent Design and Construction Verifi. cation Program.
We have also reviewed the six selection criteria specified in TERA's Engineering Program Plan, Section 1.3 and have selected the electric power system (diesel generator) for the second system.
For both th'e AFWS and' the electric power system (diesel generator), we request that special attention be applied to the program provisions regarding cable sizing, rout-ing, and installation and to program provisions for expansion of scope and reassess-ment of elements of the review based on TERA's early observations.
The staff is also concerned that the AFWS and electric power system may not provide a sufficient sample of the independent review of heating, ventilating and air con-ditioning (HVAC) systems commensurate with QA problems and corrective actions.
For this reason, we request that the portion of the HVAC system assuring control room habitability also be selected for an independent review.
l
3
". J. W. Cook 2-Je understand that the TERA program documents will be updated to reflect the addi-tional selections and resubmitted for staff review.
Sincerely, Darrell G. Eisenhut, Director Divisio'n of Licensing Office of Nuclear ~ Reactor Regulation cc:
John Beck, TERA Corp.
J. Keppl er, RIII
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/ MlDLAND Mr. J. W. Cook Vice President Consumers Power Company 1945 West Parnall Road Jackson, Michigan ' 49201 cc: Michael I. Miller, Esq.
Mr. Don van Farrowe, Chief Ronald G. Zamarin, Esq.
Division of Radiological Health Al an S. Farnell, Esq.
Department of Public Health Isham, Lincoln & Beale P.O. Box 33035 Three First National Plaza, Lansing, Michigan 48909 Sist floor
- Chicago, Illinois. 60602 Mr. Steve Gadler 2120 Carter Avenue James E. Brunner, Esq.
St. Paul, Minnesota 55108 Consumers Power Company 212 West Michigan Avenue U.S. Nuclear Regulatory Commission Jackson, Michigan 49201 Resident Inspectors Office Route 7 Ms. Mary Sinclair Midland, ~ Michigan 48640 5711 Summerset Drive Midland, Michigan 48640 Ms. Barbara Stamiris 5795 N. River Stewart H. Freeman Freeland, Michigan 48623 Assistant Attorney General State of Michigan Environmental Mr. Paul A. Perry, Secretary Protection Division Consumers Power Canpany 720 Law Building 212 W. Michigan Avenue Lansing, Michigan 48913 Jackson, Michigan 49201 Mr. Wendell Marshall Mr. Walt Apley Route-10 c/o Mr. Max Clausen Midland, Michigan 48640 Battelle Pacific North West Labs (PNdL)
Satte11e Blvd.
Mr. Roger W. Huston SIGMA IV Building Suite 220 Richland, Washington 99352 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. I. Charak, Manager NRC Assistance Project Mr. R. B. Borsum Argonne National Laboratory Nuclear Power Generation Division 9700 South Cass A. venue Babcock & Wilcox Argonne, Illinois 60439 7910 Woodmont Avenue, Suite 220 Bethesda, Maryland 20814 James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission, Cherry & Flynn Region III Suite 3700 799 Roosevelt Road Three First National Plaza Glen Ellyn, Illinois 60137 Chicago, Illinois 60602
vr. C. W. Cook 2-cc:
Lee L. Bishop Hannon & Weiss 1725 1 Street, N.W., Suite 506 Washington, D. C.
20006 Mr. Ron Callen Michigan Public Service Commission 6545 Mercantile Way P.O. Box 30221 Lansing, Michigan.48909 Mr. Paul Rau Midland Daily News' 124 Mcdonald Street Midland, Michigan 48640 Billie Pirner Garde Director, Citizens Clinic for Accountable Government Government Accountability Project Institute for Policy Studies 1901 Que Street, N.W.
Washingt,on, D. C.
20009 Mr. Howard Levin, Project Manager TERA Corporation 7101 Wisconsin Avenue Sethesda, Maryl and 20814 4
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c Supplemental page to the Midland OM, OL Service List Mr. J. W. Cook cc:
Commander, Naval Surface Weapons Center ATTN:
P.
C'.
Huang White Oak Silver Spring, Maryland 20910 Mr. L. J. Auge, Manager Facility Design Engineering Energy Technology Engineering Center P.O. Box 1449 Canoga Park, California 91304 Mr. Neil Gehring U.S. Corps of Engineers NCEED - T 7th Floor 477 Michigan Avenue Detroit, Michigan 48226 Charles Bechhoefer, Esq.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Frederick P. Cowan Apt. B-125 6125 N. Verde Trail Boca Raton, Florida 33433 Jerry Harbo'ur, Esq.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Geotechnical Eng'ineers, Inc.
ATTN:
Dr. Steve J. Poulos 1017 Main Street Winchester, Massachusetts 01890
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