ML20076K747
| ML20076K747 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/09/1983 |
| From: | Wild P STONE & WEBSTER, INC. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8309150255 | |
| Download: ML20076K747 (5) | |
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s Mr. J. W. Keppler September 9, 1983 Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 THIRD PARTY CONSTRUCTION IMPLEMENTATION OVERVIEW PROGRAM MIDLAND NUCLEAR C0 GENERATION PLANT Stone 6 Webster Michigan, Inc. (Stone & Webster) letter of August 30, 1983, confirmed commitments made to the NRC at the Public Meeting on August 25, 1983, and forwarded copies of the graphics used in the Stone & Webster pre-sentation. This letter forwards a summary of the presentation as requested by Mr. J. J. Harrison on September 6, 1983.
P. A. Wild Vice President APA:efb Enclosure cc: JWCook-CPCo.
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SUMMARY
OF PRESENTATION TO NRC ON AUGUST 25, 1983 CONSTRUCTION IMPLEMENTATION OVERVIEW (CIO) PROGRAM Background to CIO The Construction Completion Program (CCP) has been developed by Consumers Power Company to control the construction and quality activities needed to complete the Midland Nuclear Power Station. One feature of the CCP is the use of an independent third party to assess the CCP's effectiveness in evalu-ating existing systems, structures, and components and efforts to complete unfinished work.
Consumers Power Company has proposed Stone 5 Webster as the third party.
This selection was based on Stone & Webster's independence with respect to the work to be performed, and on Stone & Webster's experience and technical capabilities to do the job.
Scope of CIO Program The scope of the CIO Program is to independently assess CCP adequacy.
CCP activities presently assigned to the CIO team for assessment are:
- Phase I Planning
- Management Reviews
- Installation and Inspection Status
- Quality Verification Program (QVP)
- Phase II Activities outside of the CCP, but included in the CIO Program for assessment, are:
- HVAC/ZACK
- NSSS/B&W
- Spatial System Interaction Program (SSIP)
CIO Organization The CIO Team is made up of two functional groups - the Program Evaluation Group and the Physical Verification Group. The Program Evaluation Group is responsible for assessing compliance with programmatic provisions of the CCP, plans, procedures, commitments, personnel qualifications, training programs, organizational practices, and nonconformances.
The Physical Verification Group is responsible for assessing compliance of CCP team, MPQAD, construction, and craft personnel with pertinent procedures and instructions.
The Program Manager is responsible for directing the day-to-day activities of these two groups.
The Program Manager receives technical direction from the Stone & Webster Manager of Quality Assurance and resource support from the Project Manager.
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A Senior Overview Committee is responsible for monitoring the performance of the CIO Program and providing direction when appropriate. Monitoring will be done by reviewing reports, correspondence, and nonconformances and observing site activities during periodic visits.
Experience level of CIO Team Key members of the CIO Team have significant experience with the construc-tion of nuclear power stations. The Program Manager has 15 years of nuclear experience with 10 of those years spent at 5 new construction sites. The Supervisor of Program Evaluation has 25 years of nuclear experience with 13 of those years spent at 8 new construction sites. The Superintendent of Physical Verification has 14 years of nuclear experience with 12 of those years spent at 4 new construction sites.
Supporting Documents for CIO Program The Stone & Webster Corporate Quality Assurance Program is described in the NRC approved topical report, SWSQAP 1174A, " Stone & Webster Standard Nuclear Quality Assurance Program". This base document is supplemented by volumes of Quality Standards and Quality Assurance Directives. Provisions of these documents that are applicable to a project and special instructions that are needed to accomplish unique work items, are covered by project procedures and instructions.
Corporate generic procedures and instructions are avail-able for use or as models for project document development.
For the CIO effort, four project procedures have been approved by the Cor-porate Manager of Quality Assurance to supplement Corporate documents in carrying out the assessment of the CCP. These procedures are the Third Party Construction Implementation Overview Program, which establishes the CIO Program; the Project Quality Assurance Plan, which describes quality assurance provisions for the project; QCI 10.01, which describes the pro-cedure for conducting the assessment; and QCI 15.01, which describes the procedure for processing Nonconformance Identification Reports. Additional project procedures will be issued as needed to cover unique items that arise during the CIO effort.
CIO Methodology The methodology to be used in assessing the installation and inspection status and Quality Verification Program (QVP) of the CCP consists of I
(1) surveying the activities of each CCP team and all inspections within l
the purview of each team to evaluate the process being used to carry out the CCP and then, (2) taking a statistical sample of MPQAD inspections and evaluating the results by conducting independent inspections with ClO team members to assess the final product. A full time monitor from the CIO team will be assigned to each CCP team until team performance and inspection results are deemed satisfactory. Full time monitoring might then be adjusted downward, but independent sampling of QVP inspections would continue to J
ensure that the overall CCP process is being effectively implemented.
If independent inspections indicate that problems are developing, full time monitoring will be restored.
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Sampling of QVP inspections will be conducted using MIL-STD-105D as the basic statistical method. MIL-STD-105D was selected because it is nationally recog-nized.
Sample lots will be based on the number of inspection attributes com-pleted during a period of time within a CCP team's area / module. Attributes selected for inspection will be assembled to cover the various commodities and inspectors involved and previously identified weaknesses; such as, QA records, control of purchase material, design change control, production welding, document change control, cable pulling, training, etc.
Sample size will be based on a 95-5 confidence level.
Inspection results, including non-conformances, will be collected, analyzed, and trended to determine the appro-priateness of inspection levels and will be used to evaluate changes in those levels.
One of the objectives of the CIO Program is to assess the ability of MPQAD to identify deficiencies in the plant.
Sampling the product from MPQAD inspections will provide a reliable assessment of that effectiveness.
Programmatic and training aspects of the CCP will be assessed by reviewing implementfug documents and commitments and then develeping checklists for use by CIO team members in verifying compliance by surveillance and document reviews.
Deficiencies identified by CIO team members, and not previous 1v reported by MPQAD, will be documented on Nonconformance Identification Reports. These reports will be sent to Consumers Power Company and the NRC, tracked to ensure that satisfactory corrective action is taken, and summarized on weekly reports and during monthly public meetings.
The methodology to be used by Stone & Webster in carrying out the CIO Program will ensure:
- An objective assessment of the CCP Corrective action for problem areas Awareness of Consumers Power Company, NRC, and Public about the effectiveness of the CCP through reports and meetings Stone & Webster Corporate Audits The CIO Program will be audited by the Stone & Webster Quality Assurance Cost
& Auditing Division on a regular basis to ensure the adequacy of the CIO Program's procedures, personnel, and implementation.
Manning Plan for CIO Team Nine members of the CIO team are currently on site. These people have been reviewing documents; preparing checklists; and evaluating training, organi-zational practices, and procedures.
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Plans are to have one team member assigned to each CCP team, five auditors to conduct the program evaluation function, one to three support-engineers depending en the workload, two grcup supervisors, and the program manager.
Anticipating that some 12 CCP teams will be in operation initially, a team of some 21 people will be required. When the anticipated 23 teams become operational, some 32 people will be required. These are minimum numbers and are based on a single shift work schedule. The situation is a dynamic one.
As conditions change and more people are needed to carry out the pro-visions of the CIO Program, more people will be brought in.
Summary Stone & Webster has designed and constructed a number of nuclear power stations and knows the right way to do the work.
The CIO Program vill be carried out to ensure that the Midland plant is built in accordance with applicable codes, standards, and regulations.
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