ML20072L838
| ML20072L838 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/22/1983 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 22027, NUDOCS 8307140211 | |
| Download: ML20072L838 (17) | |
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@ Consumers POWar James W Cook C0mpany vu,n,,u,.,- now a.s.,a.,
and Const*wction General officas: 1945 West Pernall Road, Jackson, MI 49201 e (517) 788-0453
- MIT! PAL S
- .. M April 22, 1983 UbE 1.!-
SD-331
$$THC Nf 3 ro.sao w
90R Mr J G Keppler, Administ rator, Region III
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h Nuclear Regulatory Commission g y.p
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799 Roosevelt Road at g
p Glen Ellyn, IL 60137
}DL l - p. gg MIDLAND NUCLEAR C0 GENERATION PLANT -
MIDLAND DOCKET N0's 50-329, 50-330 -
CONSTRUCTION COMPLETION PROGRAM FILE 0655, B1.1.7 SERIAL 22027 REFERENCES 1.
LETTER TO MR J W COOK DATED MARCH 28, 1983 FROM MR J G KEPPLER REGARDING CONSTRUCTION COMPLETION PROGRAM 2.
LETTER FROM MR J W COOK DATED APRIL 6, 1983 TO MR J G KEPPLER REGARDING CONSTRUCTION COMPLETION PROGRAM THIRD PARTY OVERVIEW Your letter of March 28, 1983 regarding the Construction Completion Program (CCP) consisted of Parts A, B and C.
My letter of April 6, 1983 to you replied to items AS, all of Part B, all of Part C and to Enclosure 1, the Protocol document for the Indepandent Design Verification. At the April 13, 1983 maeting in Bethesda on Independent Design Verification (IDV), we provided additional discussion and clarification of the communications between the parties during the IDV.
The enclosure to this letter provides responses to items A1, 2, 3, 4, 6, 7, 8 and 9 of your letter of March 28, 1983.
Based upon this letter and my April 6, 1983 letter, we believe that complete responses have new been provided to your March 28, 1983 letter.
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EGO 7140211 830422, APR 25 G83 DR ADOCK 0500032 PDR oc0483-0426a100 l -
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JWC/GSK/bjb CC Atomic Safety and Licensing Appeal 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)
WHMarshall (w/o att)
WDPaton, NRC (w/o att)
BStamiris (w/o att)
MSinclair (w/o att)
LLBishop (w/o att)
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i Response To NRC Questions On Construction Completion Program QUESTION Al s
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"1.
Because of problems identified by the NRC during the special inspection of the diesel generator building and because similar problems were found in other areas of the plant during subsequent inspections by CPCo, we believe that 100% reinspection of accessible safety related structures, systems and components is warranted.
Should you intend doing less than 100% reinspection, please provide the details of your proposed program and the technical rationale for accepting a sampling approack."
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RESPONSE
l-s Consumers Power Company has developed two major progr,ams,already committed to in addition to the Quality Verification Plan (includelsin the CCP). These two programs include the following 100% verification effort?si
't A.
Verification of approximately 13,500 closed Inspection Reports 1
through reinspection of approximately*7,000 piping supports and; restraints.
B.
Reinspection of accessible attributes of approximately 9,00dl 1-E cables installed to PQCI E-4.0 including cable routing and identification.
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The Quality Verification Plan includes the following 100% reinspections:
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l A.
All closed Inspection Reports (IR) that contain In-Process Inspecti6n Notices (IPINs). ~This involves approximately 4,300 irs.
B.
All closed irs that contain Deficiency Reports (DR). This includes approximately 4,500 irs.
- g-C.
All closed irs associated with specific PQCI which have less than 100-irs.
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In addition, the Quality Verification Program also' requires \\ that 100%
l inspection of the remaining PQCIs will be initiated and continued until it has i
been-demonstrated with 95% confidence that 95% of the insp'ectable elements j
meet quality requirements. Upon demonstration'of the 95% quality level, Consumers Power Company will reconsider the basis on which to continue the
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verification effort for the remaining pop,ulation of each PQCI. This may include the statistical sampling techniques as noted below.
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. Exceptions to the plan may be taken in those cases where other means of verifying quality have been demonstrated as described in the plan details below.
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2 Quality Verification Program Description Consumers Power Company has prepared a Quality Verification Program to confirm the quality status of safety-related equipment and construction activities completed and inspected by the Engineer / Quality Control personnel prior to December 2, 1982.
The program will cover all closed Inspection Records of inspections performed prior to December 2, 1982, except:
A.
Remedial Soils Work which has been under the direction of Consumers Power Company quality personnel since it began.
B.
HVAC work which has been under the direction of Consumers Power Company QA personnel since the major reorganization in June 1981.
C.
Verification of 1-E cable routing and identification and verification of ASME hangers which are being performed under separate reinspection programs as noted previously.
D.
B&W Construction Company activities which have been performed under B&W Quality Assurance Programs.
The quality verification program will address safety related equipment, systems and structures in which the prior 100% inspections have been performed and completed under the direct supervision of the Engineer / Constructor. Such inspections were performed in accordance with approximately 100 Project Quality Control Instructions (?QCIs) that specified the inspection requirements to be achieved by quality control personnel. The program will include PQCIs for which no other verification activity has taken place or is u
scheduled to take place. There are closed irs for approximately 139,000 primary inspections.
Closed irs are those where the Engineer / Constructor has completed a 100% inspection of installed hardware. Where a reinspection has occurred on a specific commodity, the latest IR will be addressed.
,This~ program will assess the validity of prior inspections and provide as.drance of the quality of completed work. To accomplish this, accessible
- -attributes of items covered by completed irs will be reinspected. Fcr inaccessible attributes, the original inspection documents will be reviewed for ' evidence of acceptability and additional justification will be developed
'as required to support the validity of inspections associated with such POCIs.
Each IR relates to a specific PQCI.
PQCIs are organized by discipline ano further structured to activities within that discipline, eg, there are separate PQCIs and corresponding irs for preplacement, placement and post-pl,acement inspections of concrete.
Closed Inspection Records related to each PQCI-provide a population of like activities.
To assess the validity of these past completed inspections, Consumers Power Company will reinspect on a 100% basis, the accessible attributes of all populations where the quantity of closed irs is less than one hundred.
In addition, where the population of closed irs for a specific PQCI is more than
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. 100, Consumers Power Company will reinspect on a one hundred percent basis a S
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3 sufficient number of items to establish a quality baseline and predict with 95% confidence that the quality level is in excess of 95% for the specific PQCIs. Consumers Power Company will then make a determination as to whether further verification of specific PQCI populations can be conducted by a statistical sampling plan.
This sampling approach, which is based on a nationally accepted standard and is consistent with past NRC recommendations related to reinspections of safety-related items, is fully described in the Quality Verification Program. The NRC Resident Inspection staff will be informed of such a determination before implementation of a sampling effort.
Any nonconforming condition observed during the implementation of this program other than those previously identified on nonconformance reports, will be identified by a nonconformance report and will be dispositioned in accordance with approved procedures.
Reinspections will be conducted in accordance with PQCIs which have been reviewed-revised since implementation of the Construction Completion Program (CCP) and in accordance with current design drawings and specifications.
An acceptable reinspection will validate the installed hardware and, for the purposes of the program will validate the prior IR.
If an apparent deficiency exists between the as built condition of the item and the referenced design drawing or specification, a further check will be made to determine the design basis against which the original IR was completed. This check as well as the current stage of construction will allow a determination to be made as to whether a nonconformance of "as built vs design" exists.
Documentation of deficiencies will be noted on the newly initiated IR, entered on a nonconformance report and will be cross referenced to the original IR.
Program elements that differ from that described above will be treated as follows:
1.
Exceptions to this program may be taken where objective evidence is available of a CPCo overinspection of the Engineer / Constructor's inspections and where such overinspection demonstrates effective quality control and provides the basis to verify acceptability of the items or attributes covered by past irs and validate the original inspection with minimal or no further reinspection or review. Where such exceptions are proposed to be taken, a special report will be prepared by the tfPQAD-QA Superintendent for review and approval of the Executive ?!anager-11PQAD. This report will contain full justification for the exception. The Executive Manager-tiPQAD will inform the NRC Resident Inspection staff whenever he has made a decision to allow such a exception to the program prior to implementing the exception.
2.
There are 55 PQCIs which cover activities that are inaccessible for reinspection. These include rebar installation, placed concrete, containment building tendon reinspection, and PQCIs relating to surveillance of subcontractor actions. Documentation relating to these PQCIs will be reviewed as indicated in this program. These PQCIs, either individually or by groups, will be reviewed and miO483-4087a-66-44
4 justification will be developed by a document review to support the validity of completed inspections associated with these PQCIs. This 4
justification or recommendation for additional verification activites, will be provided by the MPQAD-QA Superintendent to the Executive Manager-MPQAD for decision and approval.
3.
The Executive Manager may group special populations of PQCIs or irs that may be treated as a unique population provided all other elements of this program are applied to this unique population.
1 Reports And Documentation Results of reinspections and document reviews will be recorded on irs ty red specifically for this pupose. Each such IR will cross-reference to the existing IR. A notation will be made on the new IR to identify whether the existing original inspection covered by the IR was validated, rejected or is indeterminate. The new IR will provide the basis to document the quality status of the items or attributes being reinspected.
l A weekly written report will be made jointly by the MPQAD QC 'and QA Superintendents to the Executive Manager of MPQAD summarizing the results of the program. The Executive Manager will inform the CPCo Site Manager, the Vice President, Projects Engineering and Construction and the Engineer / Constructor Project Manager of the status of the Quality Verification Program on a biweekly basis. The Executive Manager-MPQAD will provide a monthly report of Quality Verification Program results to the CPCo Site Manager and Vice President, Projects Engineering and Construction and the Engineer / Constructor Project Manager. This report will be made available to the Construction Implementation Overviewer and the NRC.
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The Executive Manager-MPQAD will have total overall responsibility and authority for the development and implementation of all quality related i
aspects of this verification program which will be solely under the direction of MPQAD.
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5 QUESTION A2 "2.
A description of the reinspection program for accessible systems and components important to safety."
RESPONSE
The Midland Nuclear Plant has been designed and constructed with a two level philosophy of quality classification. Those structures, systems or components which are safety related (such as those identified in Regulatory Guide 1.29, Section C.1, as modified by the Midland FSAR) are designated "Q".
All other structures, systems, and components are designated "Non-Q".
Items that are considered important to safety, but that are not classified as "Q" are being addressed by a separate program. This program was developed to address the generic safety task A-17 " System Interaction," and was described in a letter, J W Cook to H R Denton dated January 28, 1983. This Systems Interaction Program will provide assurance that equipment important to safety, because of its potential interaction with safety related (Q) equipment, has been evaluated to ensure that such equipment will not compromise the capability of safety systems to perform their intended functions. The protection of the safety-related systems is part of the design process.
In the installation of these systems coupled with the field routing of certain commodities, however, it is possible that new items become important to sa fe ty.
To this end the Systems Interaction Program describes a comprehensive effort which includes an integrated series of walkdowns to identify potential interactions. The evaluation of these potential interactions will assure that equipment important to safety has been identified, and that its potential for degrading the performance of safety systems has been resolved.
The seismic II/I and proximity walkdown, which forms an important part of the Systems Interaction Program, is being conducted in part by the Engineer / Constructor and in part by the consultant who performed this work for other sites. This inspection is separate from the CCP, but it is being integrated into CCP activities for purposes of scheduling the availability of uncongested areas, areas that are sufficiently complete to warrant inspection and the use of inspection aids such as scaffolding.
Three additional walkdowns identified in the Systems Interaction Program are HELBA, missiles and flooding. These walkdowns serve to further increase our confidence that the primary walkdowns are effective with respect to identifying equipment important to safety. These walkdowns are performed by individuals with perspectives different from the proximity and Seismic II/I walkdown teams. All of these walkdowns are expected to occur in 1983 and early 1984.
The design engineering process, the construction process and the Systems Interaction Program form a multi-layered approach to assuring that systems important to safety will not inhibit safety systems from performing their intended function. Once the plant is complete and turned over to Nuclear Operations Department, equipment important to safety is addressed by Nuclear Operations Department Standards A21 and the QA Topical Report CPC-2A. This miO483-4087a-66-44
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6 list starts with the construction Q list then adds structures, systems components and chemicals considered important to safety via a detailed review of the equipment data base.
Items placed on the operations Q list are then subject to applicable elements of the QA program from then on regardless whether they are safety-related or important to safety.
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7 QUESTION A3 "3.
A description of the measures you intend to institute to assure that QC reinspection will be sufficiently independent of team controls."
RESPONSE
The QC reinspection effort is independent of team controls although work schedules will be coordinated on a team level. This independence is maintained as follows:
Quality Verification Plan This effort is solely under the responsibility of MPQAD to plan, implement and evaluate results. MPQAD personnel will coordinate with construction for services support. The Quality Verification Program will be implemented under MPQAD Procedures.
Team Activities-Status Assessment And Systems Completion The Team Quality Representative and other MPQAD members assigned to the teams are independent of team control. The system team charter is defined in Field Engineering Procedure FPG 9.700, which indicates that the team quality representative will only receive schedule input from the team supervisor and that other technical and administrative direction will come from MPQAD management. MPQAD approves this procedure and MPQAD Procedure N-4 defines this interface.
All quality department personnel assigned to the team report to the Team Quality Representative who reports solely through the MPQAD management chain.
In addition, the Team Quality Representative is located, based on his permanent reporting assignment, within the MPQAD organization. He will, of course, be required to spend most of his time with the team on field assignments but nevertheless continues as a permanent member of MPQAD.
Organization charts show the reporting channels for the team quality members to emphasize the independence from team technical control.
Administrative controls for team quality members, such as time card approval, overtime, approval, etc, are the responsibility of MPQAD supervision assigned to the team organization. A high level manager within MPQAD is specifically responsible for management and performance of the team quality personnel.
The actual inspections are conducted in accordance with PQCIs and irs approved by MPQAD.
The above controls assure independence of the team quality representatives from the standpoint of location, organization, procedures.
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8 QUESTION A4 "4.
A description of the training that will be provided to all personnel including craftpersons. Concerning QC inspector recertification training, describe the actions you have recently taken to address the adequacy of the review of PQCIs prior to training being initiated on the PQCIs.
In addition, describe the steps you have taken to ensure that all questions raised during PQCI training sessions will be resolved prior to certification to affected PQCI's."
RESPONSE
Training Of Construction Personnel 1
The existing construction training procedure (FPG-2.000) is under revision to incorporate the training requirements of the CCP. The procedure sets down specific requirements for type of training and subject matter for each organization element.
The team training will include the major elements described below:
A.
General training will be provided in 1.
Quality requirements for nuclear work 2
2.
Requirements of the CCP 3.
Safety orientation 4.
Inspection and work procedures Training in Items (1) through (3) and selected parts of (4) will be conducted in a formal setting and will be given to all personnel including the craftpersons.
In addition, a " tool box" training session will be conducted j
periodically for the craftpersons by the foreman. The subject matter will be developed by the training coordinator, and will include information regarding quality issues across the job.
l B.
Training in the procedures used to govern the performance of work will be conducted for designated field engineering and support personnel as appropriate.
In some cases the training will include the craft foreman.
Formal training will be conducted for identified procedures that define the control of the designated work process, procedures for control of special processes and requirements for inspection and acceptance of completed work.
C.
Training in procedures for selected processes will be conducted for the craftpersons. This will consist of discussion and/or field l
miO483-4087a-66-44
9 demonstrations for the selected process. A list of the selected processes will be maintained by the Training Coordinator.
Training Of MPQAD Personnel MPQAD initiated a program in late 1982 to retrain and recertify all Engi-neer/ Constructor QCE's (Inspectors) to existing PQCIs. A significant number of QCE's have been recertified under this process. Early in 1983, MPQAD decided to terminate recertification of old PQCIs, except in selected cases; focus efforts on completing the review and revision of PQCIs; and then train and recertify to the new PQCI.
MPQAD current plans are to re-train and re-certify all inspectors to the
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revised PQCIs. As a part of this activity, the Project Quality Control Instructions (PQCI) are undergoing a complete review to assure:
Attributes required for the safety and reliability of specific components, systems and structures are identified for verification.
Accept / reject criteria are clearly identified.
Appropriate controls, methods, inspection and/or testing equipment are specified.
Requisite skill levels are required per ANSI N45.2.6 or SNT-TC-1A.
After the PQCIs are revised as necessary, Quality Control Engineers (Inspec-tors) are being trained and must pass a closed-book examination and a demon-stration test to assure their proficiency in utilizing the new instruction.
Upon successful completion, each inspector is being certified to perform inspections to those PQCIs in which he was trained.
The following actions are ongoing to maximize the effectiveness of recertifi-cation training:
Review PQCI Prior To Initiation Of Training The adequacy of PQCIs prior to training is assured by the following program-matic requirements:
A.
The PQCI evaluation effort is being conducted under the direction of MPQAD QA personnel. MPQAD Procedure E-3M was issued April 11, 1983 and establishes the responsibilities and requirements for the pre-paration, revision, and control of PQCIs by QA personnel.
As part of the PQCI revision process, Project Engineering does a review of the PQCI to insure that attributes are identified for inspection according to specification requirements and that clarifications are made to specifications wherever necessary.
B.
Whenever a PQCI is revised, the revision is evaluated to determine if a pilot run for testing the implementing capability of the PQCI is l
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10 required.
If a pilot run is required, the PQCI is tested by a team from QA, QC and Training.
Based on this pilot run, the PQCI may be further reviced.
C.
Once the PQCI is ready for issue, an effectivity date is established in conjunction with the Training Department.
1.
For PQCIs on which training was not previously conducted, the training and certification process is then started.
2.
For PQCIs on which training and/or certificaticn was previously conducted, a determination is made as to the need for retraining or recertification. When a revised PQCI is issued, it is eval-uated in accordance with established procedures to determine if retraining and recertification is required.
Based on this evaluation, appropriate action is taken.
D.
During the training process, student questions (see below) are monitored. Based on this, further revision to a PQCI may be initiated.
Resolution Of Questions Raised During PQCI Training Sessions Steps taken to ensure all questions raised during PQCI training sessions are resolved prior to certification include:
A.
The development of an MPQA Department " Statement of Training Policy."
A copy of this Policy is attached.
B.
The Policy Statement is handed out at the start of each class and reviewed with the trainees.
C.
Statement 2 of the Policy deals with student questions.
Instructors handle many questions as a routine part of a class. However, when an instructor is faced with questions he cannot answer, he makes note of them for subsequent resolution with the students.
D.
When required, a QA Engineer, Project / Resident Engineer or other resource person is scheduled to participate as part of the class and answer questions raised by the students.
E.
If there are unanswered questions at the end of the scheduled class time, an evaluation is made by the instructor as to whether training can nevertheless be considered complete and the examination given without jeopardizing the students opportunity to satisfactorily write the exam.
F.
Even if the examination can be given, prior to answering questions, the questions are still tracked and answered prior to certification.
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11 G.
Trainees are encouraged to defer taking examinations or performance
' demonstrations if they feel they have received inadequate instruction.
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MPQA DEPARTMENT STATEMENT OF TRAINING POLICY l
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It is the objective of the MPQAD Training Department to provide training that l
meets the needs of the trainees.
To help meet these needs the following policies apply:
1.
Personnel who are required to attend classroom training shall not be administered an examination without 100% classroom attendance.
100%
attendance is defined as total classroom time less instructor excused absences for brief periods of time.
A lesser percentage may be requested in writing by the trainees supervisor and approved by the appropriate Training Supervisor.
2.
When trainees have pertinent questions that relate to the training subject matter the instructor shall take action to answer the questions or obtain the answers and provide them to the students prior to final examination or certification as appropriate.
3.
The time required for self-study prior to examination shall be determined and scheduled by the appropriate Training Coordinator, based on the duration of the lesson and complexity of the subject.
4.
The instructor will review the class evaluation sheets or a composite to determine the acceptability of the training prior to administering the exam to the class.
If judged unacceptable, the exam will not be admin-istered until appropriate action has been taken.
5.
When a trainee indicates that he is not prepared to take an examination or a performance demonstration he shall not be administered the examina-tion er performance demonstration until his specific concerns are resolved.
STUDENT HANDOUT
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a 13 QUESTIONS A6, A7, AND A8 "6.
A description of the controls you will use to ensure all problems have been identified during reinspection of a system or area prior to start of repair work or new work on that system or in that area."
"7.
A description of the controls you will use to ensure that no new work will be performed that would cause a known nonconformance to be inaccessible."
"8.
A description of your proposed program for in process QC surveillance (inspection) of rework and new work."
RESPONSE
The process for release of work will be controlled by procedures that ensure that the requirements of the CCP are met prior to initiation of new work.
The requirements for release of work include; checking, review and approval to ensure that verification and status assessment activities are completed and that the new work activity will not cover up (make inaccessible) items that have existing nonconformances. These procedures are identified in Figure 1.
They define the overall process for identification and approval prior to release of work. These procedures require an identification of equipment or items that may be affected by the new work package and a check to see that there are no existing nonconformances or incomplete inspections on these items.
The interactions between project management, the installation team and the QA/QC organization are as follows.
Initially, a list of Q items by area will be prepared by the installation team. The complete and inspected items will be provided to the QA/QC organization for the verification of completed work.
The remaining items will be placed in an incomplete category and will be the basis for the status assessment by the completion team. The list will be updated as the verification and status assessment activities are carried out and will result in a complete list for each system / area.
The lists from all systems in an area will be combined and will form the basis for management review prior to release of the area for new work.
The combined list will be used in the preparation of construction work packages (CWPs) for new work.
There are several major steps in the preparation and approval of the CWP.
Each CWP will have a comparable Quality Work Plan (QWP) that defines the quality activities.
Inspection hold points will be identified and included in the CWP. Following intitial preparation of the CWP, the package is taken by the team quality representative. The inspection hold points are reviewed and approved by the MPQAD organization and a QWP is initiated for this work activity. The QWP contains the inspection records that will be required for that work activity. A review will be performed to ensure existing nonconform-ances are not covered up.
The review will be based on the steps in the three procedures listed in Figure 1.
After the CWP is returned to construction, and the QWP is prepared, work can proceed.
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14 FIGURE 1 Procedures For Controlling Release Of New Work Procedure Organization Purpose Area Release Construction for Construction (FIG 7.500)
These three procedures together ensure proper completion of verification and status assessment Construction Work Construction activities prior to initiation Plans (FPG 7.300) of new work and ensure no cover-up of existing noncon-i formances 4
Control, Release and MPQAD Handling of Construction Work Plans and Quality i
Work Packages (N-17)
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' QUESTION A9 "9.
A description of the CPCo Management Review process for changes to CCP and how CPCo intends to keep the NRC informed of such changes."
1
RESPONSE
A procedure (MPPM-19) is being issued to control changes to the CCP. The procedure will provide that Q work activity will meet the requirements of the CCP or will receive management review and approval for any deviation from these requirements. The requirments that must be maintained for work activites under the CCP are:
A.
Management reviews are scheduled and held of (1) activity planning for verification and status assessment and (2) results of status j
assessment and planning for new work activity.
i B.
A process is in place to ensure that no existing nonconformances will 4
be covered up by new work activities.
C.
Procedures to control work definition and release including definition of inspection requirements and hold points are in place.
D.
Inspection and contruction personnel involved must have received all required training.
i Any work activity that does not meet these conditions will be considered a change. A change will be reviewed by the Construction Implementation i
Overviewer. The NRC Region III management will be informed prior to j
implementation.
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