ML20073D729
| ML20073D729 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/11/1983 |
| From: | Rutgers J BECHTEL GROUP, INC., CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8304140174 | |
| Download: ML20073D729 (33) | |
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i 4/11/83 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos. 50-329 OM
) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OL (Midland Plant, Units 1 & 2) ) 50-330 OL TESTIMONY OF JOHN A. RUTGERS ON QUALITY ASSURANCE Ol. Please state your name and position.
Al. My name is .Tohn A. Rutgers. I am Bechtel Power Corporation's Project Manager for the Midland Plant.
My qualifications are detailed in the resume which follows transcript page 3059 and which was submitted in the proceedings on August 5, 1981.
Q2. Mr. Rutgers, have you read the testimony of James Keppler on quality assurance which was filed October 29, 1982?
A2. Yes, I have and I would like to respond to some specific items addressed in the attachments to Mr.
Keppler's October 29, 1982 testimony.
Q3. Mr. Rutgers, referring to the technical issues of Attachment A, page 2, paragraph 2 and to Attachment E304140174 830411 PDR ADOCK 05000329 T PDR
B, paragraph 1 to Mr. Keppler's October 29, 1982 testi-many, what is your position as to the adequacy of the program for reinspection of electrical cables which was initiated as a result of NRC concerns on the adequacy of the qualifications of selected QA inspectors?
A3. As a result of a May, 1981 NRC inspection at Mid-land, the qualifications of certain OC inspectors certified to perform electrical cable installation inspections were questioned. The NRC considered the inspections performed by these inspectors to be in-determinate and requested that MPQAD perform over-inspections. In response, MPQAD performed overin-spections of 100% of the work done by all but one of these inspectors and 50% of the work done by the last one. Fifty-five cables out of 1,084 checked (5%) were found to be misinstalled in part.
The results of the overinspections were analyzed for the purpose of ensuring that each identified prob-lem was fully understood and appropriate corrective action taken. The cable installation problems were i
categorized to further determine if the concerns were generic. The result was that, for 38 of the 55 cables (3.5% of the total overinspected) , it was determined either that the problems were not generic or that if the problems were to occur elsewhere in the plant, f
there would be no impact on safety. For the remaining 17 cables (1.6% of the total overinspected), it was determined that there could be a concern if similar problems occurred elsewhere in the plant. The 17 cables fell into two categories. First, some cables were overlapped in adjacent trays at transition points.
This could lead to inducing noise in instrumentation cables perhaps leading to distortion of instrument signals. Second, some trays had too many cables in them leading to potential overheating if those trays were to be wrapped with asbestos blankets for fire pro-tection.
To ensure that these items of potential concern if occurring elsewhere would be properly identified and dispositioned, the following actions were planned or
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taken:
- 1. Revision of the QC area walkdown inspections (PQCI 7220-E-3. 0) to require additional inspections of all cable transitions from raceways to ensure that no voltage violations occur.
- 2. Thermal analysis of wrapped trays conser-vatively accounting for cable mispulling.
This would identify specific cable trays which would be inspected by QC to verify 4
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i correct loading requirements.
- 3. Additional training for Quality Control inspectors.
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.' Thus, all the types of nonconformances identified by the overinspections were analyzed for their impact on safety. Either there was no impact or additional inspections and actions were planned to preclude impact for those attributes important to safety. The fore-going plan was presented to the NRC in May 1982.
Subsequently, the NRC requested that all Class 1E cables be reinspected in accordance with circuit and -
raceway requirements to ensure correct routing. Con-sumers Power Company is currently in the process of performing the reinspection requested by NRC, which will inc'ude reinspection of approximately 9,200 Class 1E cables. To date, the reinspection is approximately 91% complete.
Because a 100% reinspection of all Class lE cables is being carried out, the concern that only a partial overinspection was being conducted, raised in Attach-ment A, page 2, paragraph 2 and Attachment B, paragraph 1 of Mr. Keppler's October 29, 1983 testimony, has been addressed.
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Q4. Mr. Rutgers, what is your response to the state-ment concerning the use of a statistical analysis for addressing the adequacy of quality control inspections of pipe supports during 1980 as stated in Mr. Keppler's October 29, 1982 testimony, Attachment A, Technical Issue 3?
A4. During May 1981, the NRC conducted an inspection where they noted that some pipe supports installed in 1980 had not been installed in accordance with the design drawing and specification requirements. As a result of this, MPQAD conducted an overinspection of a sample of 123 supports installed prior to January 1, 1981, for the purpose of assessing the acceptability of the original installations and inspections. Fifty-five (45%) of the 123 supports inspected were found to have at least one nonconforming condition. None of the nonconforming conditions existing with these 55 sup-ports presented a safety concern. In a report submitted ,
to the NRC in August 1982, this information was pre-sented in the form of number of characteristics over-inspected. While the report did include statistics, its main theme was specification of the problems and planned corrective actioni. The report documented our approach which is outlined below.
The report analyzed the nonconforming conditions, classifying them into 14 groups. This assisted in ensuring that the problem was understood and therefore was useful in determining the significance of the ncnconformances and in framing appropriate corrective actions.
For 9 of the groups of nonconforming conditions it was determined that there would be no impact on safety even if the condition should occur elsewhere in the plant. An example would be a member which has a length exceeding the design drawing dimension but which is attached to the structure in the correct place and sup-ports the pipe at the pipe's correct location. For the remaining five conditions (missing components, in-correct component orientation, incorrect clevis ro-tation, incorrectly located welds, and incorrect clear-ances between pipe and support) which could be a con-cern if they occurred elsewhere in the plant, addi-tional inspections were planned to ensure that these were identified and resolved if they existed elsewhere.
Planned inspections were:
- 1. Prior to turnover, field engineers and QC inspectors were to perform additional in-spections of each hanger installed prior to January 1, 1981 for, among other things, missing components, incorrect component orientation, incorrectly located welds, and incorrect clevis rotation.
- 2. Design engineers were to inspect for correct clearance between pipe and support for all Q supports in addition to previously planned items of inspection during their functional stress walkdown. This inspection was to ap-ply to all 0 supports regardless of instal-lation date.
Subsequent to their review of this plan, the NRC requested that Consumers Power Company reinspect all pipe supports installed prior to January 1, 1981, and
! reinspect a sample of pipe supports installed after January 1, 1981. Later, during development of the Construction Completion Program, we concluded that it would be more practical and timely to reinspect all installed supports regardless of the time of their installation or turnover.
Additionally the following actions are planned coincident with the Construction Completion Program:
- 1. Improve the quality of pipe support instal-lation by requiring installation checkoff lists for crafts, craft supervision, and field engineers; by consolidation of di-mensional tolerances to simplify specification l
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interpretation; and by reducing field-initiated changes through an improved space control program.
- 2. Rewrite Project Quality Control Instructions (POCIs) to incorporate acceptance criteria into the inspection instructions. Project engineering and field engineering are re-viewing these to ensure that correct inter-pretations of requirements are provided in the inspection instructions. Reinspections will be performed with these revised PQCIs.
The reinspections for all attributes and the planned actions described above will ensure the adequacy of pipe support construction.
Q5. Mr. Rutgers, would you please explain the situ-ation involving use of a Coordination / Installation Form as described in Attachment B, paragraph 3 of Mr. Keppler's October 29, 1982 testimony?
AS. At a May 28, 1982 NRC exit meeting, Mr. R. Gardner of NRC stated the need for a coordination form to interface and control the sequencing of work. The approval of this form was necessary to allow under-pinning instrumentation installation to continue.
A conversation was held between Mr. M. Schaeffer l
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of MPQAD and Mr. Gardner of the NRC on June 1, 1982, confirming NRC approval of a coordination form which had been drafted by MPQAD and Bechtel engineers.
During June, 1982,-a meeting was arranged with working level representatives from Bechtel and MPQAD to review the instrumentation work and develop addi-tional coordination forms. When the Bechtel site manager and his staff reviewed the outcome, they sug-gested changes in the format of the coordination forms including the form previously approved by NRC, i primarily to distinguish the coordination forms from other quality related documents.
Subsequently, on June 18, 1982, Mr. Schaeffer phoned Mr. Gardner and obtained his approval for use of the revised coordination form and the additional forms.
Mr. Schaeffer advised Mr. Gardner that the changes to the previously approved coordination form were ad-ministrative and that they did not change the intent or purpose of the form. Following the approval by Mr.
Gardner, the forms were posted in the field for use by the field engineers and superintendents.
Q6. Does the foregoing issue suggest that Bechtel determines the regulatory environment for the Midland project?
A6. An engineer-constructor for a nuclear plant does
not dictate the regulatory environment under which it will work. This is the purview of the NRC and the owner. Bechtel does advise and make recommendations to Consumers Power Company. In the case of this particular coordination form, the advice from Bechtel supervision happened to follow contact between Consumers and the NRC, thereby accentuating Bechtel's input. Normally, Bechtel's review and input would occur before NRC approval is sought. We feel that such advice would be expected from an experienced contractor who performs design, procurement, and construction. It is clearly understood that Consumers Power Company and the NRC have review and approval authority. There was no attempt to use a revised form without such approval and there is no question that Consumers does dictate the regulatory environment.
- 07. Mr. Rutgers, would you please respond to the con-cern raised in Mr. Keppler's October 29, 1982 testi-mony, Attachment B, paragraph 4, regarding deficiencies in material storage conditions and procedures at the Midland site?
A7. Consumers Power Company and Bechtel are committed to a storage and maintenance program that covers all
materials and equipment which are stored at the Midland site or are in place in the plant. This storage and maintenance program's objective is to preclude sig-nificant degradation of any material or equipment.
Problems related to storage have occurred, but when they have, steps have been taken to resolve them.
For example, in recognition of the extension of project schedule announced in early 1980, a special task force, the Long-Term Environmental Control Working Group, was formed to identify and resolve long-term storage problems. Initially, the group, consisting of representatives from Consumers Power Company, Bechtel, and Babcock & Wilcox, met bi-monthly. Later, the meetings were monthly. Specific items addressed by the group were:
- 1. Secondary Side of the Once Through Steam Generator
- 2. Turbine Lay-Up
- 3. Pipe Cleanliness
- 5. Condensate Pumps
- 6. Evaporator System Meetings were chaired and documented by Consumers Power Company and provided a means for Consumers Power .
l Company, Bechtel, and Babcock & Wilcox to air and 2
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t resolve storage and maintenance concerns on the spot.
l In some instances, specific detailed instructions were generated as a follow-up to the neeting. A specific example of this was a Contractor Work Request (CWR) ,
generated for the lay-up of the evaporator system.
- With storage problems resolved for the major pieces of equipment, the group was dissolved.
We have responded to problems noted in routine audits. The routine auditing process by MPQAD in 1981 and early 1982 identified several areas of concern in regard to Bechtel's outside storage and maintenance program. In general, the biggest areas of concern I
were:
- 1. Missed storage / maintenance intervals.
- 2. Material not properly protected from the 4
elements.
- 3. Material not maintained as required by pro-cedure.
- 4. Inspection intervals were too far apart.
In response to these concerns the manual method of tracking storage intervals was superseded in January 1982 by a computerized method of control which has proven far more effective in maintaining on-time inspections.
Another step to improve storage was taken when in November 1982, in addition to the vendor recommended 4
storage / maintenance intervals, field engineering insti-tuted weekly checks of the Poseyville laydown area to review storage conditions. We are monitoring the results of these reviews and taking corrective actions as conditions warrant. Additionally, in response to two findings involving marking of material documented in the NRC's special inspection related to the diesel generator building, Inspection Report 82-22 (February 8, 1983), formal quality control inspections of various jobsite laydown areas were changed from monthly to weekly and procurement personnel responsible for marking a steel were retrained.
I believe that our responses to problems noted in the material storage and maintenance program are positive. Bechtel and Consumers are both committed to proper material storage and maintenance. This com-mitment is illustrated by the changes that have been implemented.
- 08. Mr. Rutgers, would you please respond to the con-cern about support of cables awaiting routing or ter-mination raised in Mr. Keppler's October 29, 1982 testi-mony, Attachment B, paragraph 57 A8. Meeting in-process requirements for installation of cables is a particularly difficult aspect of con-l
struction -- one which constantly provides the po-tential for nonconformances, especially in the area of cable coil support and end-capping. We are alert to this potential and respond to indications of problems.
Thus, as nonconformances have been identified, prompt action has been taken to correct the conditions.
Additionally, throughout 1981 and 1982, construction '
management and the electrical superintendent issued s memoranda to their supervision and foremen calling for 3 improvement in their performance in supporting coile and end-capping. Such supervisory actions served to reinforce long standing field procedures such as elec-trical field procedure, FPE-4.000, originally issued in 1977 and revised in August 1981, to provide instruction for supporting cable coils to field installation per-sonnel. Additionally, in response to reported coil support nonconformances, and in order to provide an overcheck and to keep management informed of per-
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formance in congested cable termination areas like the control room, in August 1981, we added a check for proper coils support in in-process inspection project quality control instruction (PQCI) E-1.60. This in-
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struction currently requires a weekly inspection of selected plant areas for conformance to seven instal- !
lation attributes including coils support. 1 J
i We have included support of cable coils in a ,
' continuing orientation program for electrical supervision,
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fo'r'exen and craftsmen in electrical field installation procedures.. Moreover, our inspections will continue and prompt action will be taken to correct any problems detected.
These actions illustrate our coItinuing attention to this concern. 1 a
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- 09. Would you please respond to the assertion in Mr.
Keppler's October 29, 1982 testimony, AttaNhment B, paragraph 6, that there was an inordiante amount of resistance to. marking instrumentation impulse lines?
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\ A,9 . The NRC, during an' inspection at the end of April 1981, raised a concern relating to identif cation of.
safoty-related instrumentation impulse lines. Initially, l , .
there'was a period of time during,which we did not un-T derstand that the'NRC's concern'with identification of' instrumentation' impulse s lines referred .to physically marking the. lines rather than identification of the lines on' drawings. Ultimately, we understood that the L
NRC's position was that instrumentation impulse lines are part of-the protection system'and therefore are
' required to be, physically marked pursuant to IEEE Std.
s-279-1971. Our' position was that marking of instrumentation
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' 1971.- 'We interpreted tihe scope of IEEE Std. 279-1971 to be,fron'the transmitter to the actuating device and 1
not 'to incl'ude Epulse lines. Our practice is to classify impulse lines as an extension of the process
.d lines and therefore govern them by ASME criteria,
'rather than IEEE standards. The NRC disagreed with
this position and' asked for addit!onal response.
i Consomers Power Company subsequently responded to
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the NRC and agreed to identify each safety grade im-palse line with a two-letter designator. Thereafter, LConsumers directed Bechtel to initiate actions to
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support the commitment to the NRC. Bechtel followed w,
s Consumerd Power Company's direction, but also reiterated
'our differing interpretation'of,IEEE Std. 279-1971 from
,tha't of theJNRC.
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- 010.' Mr. Rutgers, what is your response to paragraph 7
'- .of Attachment B of Mr. Keppler_'s October 29, 1982
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\ testimony wh'ich cites _the licensee's attitude toward t.heNRC'sfindin@ofimproperlyinstalleddrop-in anchors as an'1Mication that: slipshod workmanship is i
tolerate}i on the Midland project?
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AIO . ,- Dachtel' helped to pioneer nuclear power technology ontmof a firm convictionf that nuclear energy could y .
/, become'a clean, sa#e, economical way to generate elec-
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tricity. s We have had prime responsibility for en-2 4 %
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gineering or construction of about 40% of the nuclear power units presently in operation in the United States.
In the course of our nuclear activities we have achieved a work record of three times fewer lost work days from injuries on nuclear power projects than the heavy construction industry average. Twelve Bechtel nuclear power projects have achieved one or more million hours worked without a lost-time injury. The Midland project has achieved this record three times. I offer this as a
background because I believe that this track record is not one of'a company which tolerates " slipshod" per-formance in any aspect of its work.
While I am proud of our accomplishments, I must acknowledge that we are not perfect -- nor is any enterprise consisting of human beings. What we are attempting to foster are attitudes of improvement.
These include striving for the next million hours without lost-time injury and striving for zero defects relative to design requirements. We view these com-mitments to excellence as being incumbent on individual performers and we orient all employees to our safety program and to our quality improvement program. Basic-ally, we expect safety and quality to be built in.
Although we have high expectations of individual per-formance, our work processes include checks on this performance. Employment of safety and quality control engineers are examples of these checks.
- We have been criticized by NRC for over-reliance on the checks in our process, and I can understand and accept this criticism as being construc'.ive. At the same time, I think it is important to recognize that checking is part of our process and it is important to management to probe findings to see if the total pro-cess is working. In the case of drop-in anchors, as I understand the situation, the work coordination forms showed the work to be construction complete when in fact one anchor did not have the proper embedment depth. Because of this improper embedment, the work did not conform to design requirements, and that is not satisfactory performance in our book.
I agree that when conformance is achieved upstream in the process, we are all better off. That is what is behind our quality improvement motto "Do it right the first time." At the same time, in this instance I cannot ignore the fact that the total process was not complete -- the checking by QC had not been performed.
Therefore I cannot conclude that a total process fail-ure had occurred. As a manager, I believe I have the right to rely on the total process to produce a product conforming to requirements without being viewed as j tolerating " slipshod workmanship."
We have reviewed our installation and checking process effectiveness based on the results of the 1982-1983 diesel generator building inspection which found some instances of nonconforming work which had escaped the QC inspection process. In response to the inspection findings, Consumers initiated the Construction Completion Program which includes both verification of past work and improved control of future work. This improved control addresses clearer communication of design requirements and work acceptance criteria to the per-formers, and better coordination of the inspection activities in the total work process. We believe the craftsmen's skills are excellent -- essentially their work reflects the instructions they have been given.
What management must do is insist that design, super-vision, and field engineering are lockstepped to assure that the instructions given are exactly in accordance with design and procedural requirements and, if for some reason changes are required, that not only are 1
they properly approved before work is performed but alsosthe record proves that they were.
In summary, I do not believe that Bechtel toler-ates " slipshod workmanship." We simply have no in-centive to do anything other than to strive for ex-cellence. Our record in the nuclear industry is a good one and we want to keep it that way. It is my ex-pectation that the verification conducted under the Construction Completion Program will give us valuable feedback regarding the true condition of the plant. We
will use this feedback constructively and adapt our approaches to see that the plant is constructed in a manner which protects the public health and safety.
Oll. Mr. Rutgers, would you respond to the view ex-pressed in Mr. Keppler's October 29, 1982 testimony, 7ttachment B, paragraph 10 that there is an unwill-inaness on the part of Bechtel to share information with the NRC as reflected by the response to an NRC 2
inspector's request to review resumes of persons in-volved in remedial soils work?
All. Bechtel is not reluctant to provide information to the NRC. With regard to the example cited, Dr. Ross Landsman indicated on May 18, 1982 during a site entrance meeting that he would like to see the resumes of the geotechnical engineers. The resumes were main-tained in the Ann Arbor Personnel Department. Because these resumes contain personal information, such as family data and career aspirations, they are not routinely provided to third parties.
On May 21, 1982, at the exit meeting, we provided Dr. Landsman with resume information prepared to re-spond to his request, but which excluded personal in-formation which we believed unnecessary to his pur-pose. Dr. Landsman commented that the information l
provided was not_ specific enough. In response, Dr.
i Landsman was advised that day that more detailed re-20-
4 sumes would be prepared consistent with an FSAR level of detail and telecopied to him in Glen Ellyn. These resumes were sent on May 25, 1982.
In order to avoid this problem in the future, the current practice is to provide suitable resumes at the site for resident structural engineers and resident geotechnical engineers.
012. Mr. Rutgers, would you please respond to the con-cern raised at the end of paragraph 11 in Attachment B to Mr. Keppler's October 29, 1982 testimony that there may be " memorandums written to the effect that ' peri-pheral vision' should be curtailed and communication with the NRC stifled?"
A12. I am aware of no memoranda to this effect, and I say that having learned of this concern on NRC's part some time ago and having made attempts to uncover any memoranda which could have led to this concern. We have identified one memorandum which was issued about
- two years ago denoting individuals within the Bechtel organization at Midland responsible in various subject areas for responding to questions from Consumers Power Company, NRC, or other Bechtel personnel not assigned to the Midland Project. (Attachment A). It may be that this memorandum either by mischaracterization or misunderstanding hae given rise to the concern registered by NRC. This mamarandum was issued to minimize the l
4 i opportunity for inadequate or incorrect responses to questions beyond the knowledge of individuals who may i
l be questioned in areas outside their responsibility.
'- The memorandum served to provide all personnel with a ,
cormon list of knowledgeable persons in the various
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disciplines and technical areas. Referral of questions
- to these cognizant individuals identified in the memo-
- randum was intended to allow a more rapid and factual response and to facilitate a more productive process for responding to questions.
The memorandum was in no way intended to inhibit communications. In fact, the intent was just the i
opposite. It was designed.to identify individuals who i
could provide information when questioners sought information in a given subject area and to alert employees to the availability of these resources. It did not address situations where a questioner was
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interested in the knowledge of a particular person
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rather than information about a particular subject, 1
regardless of the source. Nor did it address any individual employee's right to initiate discussions with anyone -- NRC or anyone else. l Two memoranda are attached to.this' testimony. We expect that the concern expressed by NRC may have come from the earlier memorandum promulgated in January
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1981. Thus, after learning-of the concern, the memo-l i
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randum was reviewed with that sensitivity in mind and rewritten to enture there was no misunderstanding among l
Bechtel employees or within NRC. The second memo-i randum, issued in November 1982, remains in effect for our employees. (Attachment B).
1 013. Mr. Rutgers, would you please explain Bechtel's treatment of cost and scheduling as related to quality on the Midland project, a subject discussed in Mr.
Keppler's October 29, 1982 testimony, Attachment D, Enclosure 4, page 2?
A13. We do not agree that quality is taking a back seat with Bechtel management. We do agree that cost and schedule are emphasized, but not to the detriment of quality. All three are essential.
As project manager, I must respond to Consumers in all three areas. Any two alone out of three are just not responsive to the requirements of a major project.
Schedule and cost objectives are generally best served by doing work right and doing it only one time.
When I was assigned to Midland in late 1979 I noted that there were no routine project management level meetings of all team members with an agenda 1
solely dedicated to quality issues. Accordingly, I expanded the monthly meeting of the Bechtel team to ,
1 include a quality agenda. The agenda included pro-l gressing closure of open quality actions and reviewing l
l quality trend reports for management action. I con-tinued to chair this meeting after formation of MPQAD and until September of 1982 when weekly meetings chaired by Mr. Cook were initiated.
I recently have sought counsel from higher Bechtel management and from Consumers as to priorities in-volving cost, schedule, and quality. Their guidance states that all three are priority, with quality standing first. I do not view this guidance as contrary to the philosophy my team has espoused in the past. We will continue to emphasize quality in the construction of the Midland Plant.
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20# G216022 99:21 10/80 s
Bechtel Power Corporation ;
inter-offi, , Memorandum )
i To Distribution o.te January 29, 1981 Job 7220 Midland Project prom L.E. Javis saject Quality Assurance Matrix 0-3695 of Construction At Midland, Mt.
copies to J. Rutgers (AA) P. Hansen (AA)
L. Curtis (AA)
The attached matrix identifies individuals who are to respond to questions posed by the Client, NRC, or other outside agencies during their routine visits, inspections and audits at the job site.
The purpose of this authorization is to minimize the opportunity for inadequate or incorrect responses to specific questions.
The identification of individuals will also allow for more rapid, f actual responses.
Contacts with AA0 engineering staff should be handled through the identified QA engineer and the resident engineer.
Individuals not identified on the attached' matrix should contact their supervisor when questioned by the Client or an IRC or other outside or non-project agency.
6,-
L.E. Davis LED /JR/jrm Attachment- Quality Assurance Matrix Attachment A Rutgers' Testimony 4/11/83
CO# G216022 9G:2i 10/60
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pe au pen seteuez 2S281 10/80 0 DISTRIBUTION C. Choy-Hee C. Cross P. Corcoran B. Daly L. Davis C. Dart M. Dietrich J. Davis J. Gilmartin D. Delaney O. Holman T. Foote M. Petersen S. Gelnett E. Reinsch H. Hudson E. Smith S. Hulsey D. Soderholm E. Lawrence T. Valenzano W. Lemke R. Weatherred N. Ainsworth B. Akerly B. Collin J. Gilmartin D. Naberhaus J. Lillywhite X. O'Neil J. Neilstrup B. Reigelsperger L. Norfin J. Savoie E. Newman S. Schumitsch J. Russell R. Dunbar L. Brown R. Siple J. Steele G. Smith C. Stubbs P. Solomon S. Suggs D. Tewes B. Sutherland D. Wharff B. Netzela H. Adler M. Baker J. Betts R. Bradford
4 Bechtel Power Co.'poration Inter-o!!!::e f.'iemorandum To Date Distribution November 10, 1992 Subject Job 7220 Midland Project From L.E. Davis RESPONSE MATRIX 0-5097 Of construction Copies to J. A. Rutgers (AA) w/a At Midland, Michigan P.K. Hansen (AA) w/a W. Greenwell (AA) w/a This 10M is to add further clarification to the subject. Individuals, when approached by any outside agency, should answer questions specifically in his area 6f responsibiiity. If the question or situation exceeds the individual's precise and specific area of responsibility, he should inform the outside agency of his lack of knowledge and refer the agency to the identified cognizant supervisor in the subject matrix. The purpose of this referral is to minimize the opportunity for inadequate or incorrect responses to question beyond the knowledge of the questioned individual. The rr.ferral to these identified cog-nizant individuals is intended to ailow for more rapid and factual responses and facilitate a more productive process for the questioning agency. Contacts with Ann Arbor Engineering staff should be referred to the identified Quality Assurance engineer and/or the resident engineer. If you or individuals under your responsibility have any questions concerning this subject, please contact me.
$ llIh L.t. Davis LED /jrm
Attachment:
Response Matrix l Written Response Requested: No 1 Attachment B Rutgers' Testimony 4/11/83
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'll J. Gilmartin E. Smith G. Co11tns L. Davis M. Oletrich P. Corcoran E .18u95e 5 H ,*p n l i.
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*enel P. Goguen 5. Kirker N/A N/A M. Dietrich 8. Senn 5. Sobko.skt
- 5. Harvey E. Dutton - A. McClure J. Rysdon iteld Solls org. .l. Fisher M. 81endy R. Groshang N/A M. Dietrich E. Cvikt is. 5.anberg is3. ie t -
D. Lavelle D. VanDoorne A. McClure J. Darby "s%h/lge. Plpe N. 11srl D. Fredlane111 N/A N/A M. Dietrich D. Itannekamp R. Tulloch A. Killsrek C.R. Amos A. McClure V. Chawla T. Os11=eg L. tiarrison f e.,e 1 visnjers R. Marl D. Fredlanelli N/A N/A M. Oletrich D. Riat R. Tulloch J. Frank 1fn C.R. Amos A. McClure F. Almeida . it..trical D. Scott D. Prestar N/A N/A M. Oletrfch G. Warner J. Kovach R. Black J.W. Miller A. McClure P. Kelly A. Julkae lses t ra.ent a t io n D. Rennick D. Fredlanelli N/A N/A M. OletrlCh T. Lul G. Singh C. Fugate C.R. Amos A. McClure J. Clinton D. Simpson te1 Jing 5. Sprague D. Fredlanelli N/A 1/A M. Oletrich N/A T. Dallweg E. Stanktewicz A. McClure f Je s.*ne r J. Gilmartin R. Siple G. Cully N/A M. Ofetrich N/A K. Itodgtn M. Allard B. McKenzle A. McClure s .sa.itation/ N/A R. Sfple G. Cuily J. Card M. Dietrich N/A M. Dakarich
.. .: oit Control M. Allard 8. McKenzte A. McClure C. Ashlencept HVAC) M. Of etrich N/A E. Hughes ..tcontracts N/A E. Smith G. Cully K. PulltolB&W) A. McClure B. McKentle B. Intnd D. Graf (HVAC)
Ilcid Prusuen. cut / J. Gilmartin 5. Kirker G. Cully stubbs M. Oletrich N/A E. Ilughes vic lvisig Inspectf un R. MacGlashan B. McKenzte Reigelsperger A. McClure 10 1.sJits by 5FHO N/A N/A N/A ll>w s il l '
.hte;,8 personnel ,
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. . . le.vcstigations N/A N/A N/A Howantt
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'M J. Retnsch J. Russell J. Retnsch J. Reinsch J. Russell P. Corcoran N/A Ho-ant' e
l i e 0 ~ G~C Q 'l \ l l D I ST R I BUT I O!.: G. Collins B. Siple P. Corcoran J. Steele M. Dietrich R. Weight J. Gilmartin R. Amos J. Howanitz M. Baker D. Lavelle R. Bradford J. McIlstrup D. Burnard D. Naberhaus J. Card K. O'Neill E. Entrekin J. Reinsch B. Gamble E. Smith S. Harvey C. Stubbs T. Klug T. Valenzano G. Lawrence C. Ash H. Lohr B. Bane R. MacGlashan J. Betts R. Marl L. Brown M. Mart in G. Cully B. McKenzie J. Davis R. Murphy J. Eddy C. Newville J. Fisher B. Reigelsperger D. Fredianelli D. Rennick P. Goguen L. Rice D. Graf D. Scott ( S. Kirker G. Simoneau B. Matthews S. Sprague D. McIntosh B. Thind C. Norberg L. Williams D. O' Dell C. Valot D. Prestar K. Pulito J. Russell D. Short
f 4 I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSJNG BOARD In the Matter of: ) Docket Nos. 50-329 OM
) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OL (Midland Plant, Units 1 & 2) ) 50-330 OL CERTIFICATE OF SERVICE I, Rebecca J. Lauer, one of the attorneys for Consumers Power Company, hereby certify that a copy of Testimony Of John A. Rutgers On Quality Assurance was served upon all persons shown in the attached service list by deposit in the United States mail, first class, this 12th day of April, 1983 except where service was made as other-wise indicated.
WI.et. . m Rebecca J.' Lauer ISHAM, LINCOLN & BEALE Three First National Plaza Suite 5200 Chicago, Illinois 60602 (312) 558-7500 i l
e SERVICE LIST Frank J. Kelley, Esq. Steve Gadler Attorney General of the 2120 Carter Avenue State of Michigan St. Paul, Minnesota 55108 Carole Steinberg, Esq. Assistant Attorney General Atomic Safety & Licensing Environmental Protection Div. Appeal Panel 720 Law Building U. S. Nuclear Regulatory Comm. Lansing, Michigan 48913 Washington, D.C. 20555 Cherry & Flynn *Mr. Scott W. Stucky Suite 3700 Chief, Docketing & Services 3 First National Plaza U.S. Nuclear Regulatory Comm. Chicago, Illinois 60602 Office of the Secretary Washington, D.C. 20555
- Mr. Wendell H. Marshall 4625 S. Saginaw Road *Ms. Mary Sinclair Midland, Michigan 48640 5711 Summerset Street Midland, Michigan 48640
- Charles Bechhoefer, Esq.
- William D. Paton, Esq.
Atomic Safety & Licensing Counsel for the NRC Staff Board Panel U.S. Nuclear Regulatory Comm. U.S. Nuclear Regulatory Comm. Washington, D. C. 20555 Washington, D.C. 20555
- Dr. Frederick P. Cowan
- Atomic Safety & Licensing 6152 N. Verde Trail Board Panel Apt. B-125 U.S. Nuclear Regulatory Comm.
Boca Raton, Florida 33433 Washington, D.C. 20555
- James E. Brunner, Esq.
- Jerry Harbour Consumers Power Company Atomic Safety & Licensing 212 West Michigan Avenue Board Panel Jackson, Michigan 49201 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Mr. D. F. Judd Lee L. Bishop Babcock & Wilcox Harmon & Weiss P. O. Box 1260 1725 "I" Street, N.W. #506 Lynchburg, Virginia 24505 Washington, D.C. 20006
- Barbara Stamiris *Ms. Lynne Bernabei 5795 North River Road Mr. Thomas Devine Route 3 Mr. Louis Clark Freeland, Michigan 48623 Government Accountability Project of the Institute for Policy Studies 1901 Q Street, N.W.
Washington, DC 20009
- Federal Express
000FEIED UNITED STATES OF AMERICA t"" ' NUCLEAR REGULATORY COMMISSION
. ., $ 7-r jg 01 3 ,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) Docket Nos. 50-329 OM
) 50-330 OM CONSUMERS POWER COMPANY ) Docket Nos. 50-329 OL (Midland Plant, Units 1 & 2) ) 50-330 OL AFFIDAVIT I, John A. Rutgers, being first duly sworn, state that my accompanying testimony on quality assurance is true and correct to the best of my knowledge and belief.
John ~A. Rutg s SUBSCRIBED & SWORN To Before Me This J.1 6 Day Of Anec, ( ,1983. f'iDAL . Q
/~ Not Publi~c Commission Expires: 9 . f D - 9 (o}}