ML20080K098
| ML20080K098 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/06/1984 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | STONE & WEBSTER, INC. |
| References | |
| CSC-7285, NUDOCS 8402150296 | |
| Download: ML20080K098 (9) | |
Text
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CONSUMERS POWER COMPANY So-35i xIDtinD EnERcr CEurER
$O '.- g Transmittal No:
CEC-7285 Date: February 6, 1984 To:
Stone & Webster P O Box 1963 Midland, MI 48640 jl r. n_n i PM.. ST f F F
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Attached Is:
Partial Response To
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g Complete Response To For Your Information
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Description:==
Tracked Ir. formation Items 045 and 050.
Tliese were previously transmitted without a SMO signature in the respondent space.
1 Signature:
4 cc: cJGKeppler NRC Region III w/a JJHarrison, NRC Region III w/a RJCook, NRC Site w/a RAWells, MPQAD w/a BHPeck, MEC w/a NIReichel, MEC w/a DDJohnson, MEC w/a 0
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CONSUMERS POWER COMPANY MIDLAND ENERGY CENTER Transmittal Not CSC-7269 Date:
February 1, 1984 Toa Stone &~ Webster P O Box 1963 Midlaud, MI 48640 Attached Is:
Partial Response To X
Complete Response To For Your Information Other
==
Description:==
Tracked Information Item 050.
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1 cc JGKeppler, NRC Region III w/a JJHarrison, NRC Region III w/a RJCook, NRC Site w/a RAWells, MPQAD w/a BHPeck, MEC w/a l
NIRe.ichel, MEC w/a DDJohnson, MEC w/a i
Sheet 1 of 2
E" fMBERl HOLD POINT STONE & WEBSTER 5
CONSTRUCTION IMPLEMENTATION O TRACKED ACTION ITEM OVERVIEW
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M/DLAND NUCLEAR PLANT./.0. NO.14509 gACKEo RECOl r E DA 0 lieu REFERENCE (S)
O UNTRACKEDITEM CPCo Memo, CSC-7119 of 12/23/83 (cooy attachad3 0 HOLD POINT NOTIFICATION CONDITION DETAILS The following documents discuss Q and/or Q-interface CWP's/ items:
1)
FPG-7.300, Rev. 3 " Construction Work Plans (CWP)"
- 2) MPQAD Procedure T-3, Rev. 1, " Control, Release and Handling of Constructior: Work Plans (CWP) and Quality Work Packages (QWP)"
- 3) CPCo " Ground Rules for Construction bark", dated June 2, 1983 In discussing the above with CPCo personnel, the following was noted:
1
- 1) Q-interface work may or may not require INpection.
2)
The inspection /non-inspection guideline in use presently by the TQR's/MPQAD QCE's is a handwritten list.
b YES '((.s,1 DNO ATTACHMENTS
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SEE SHEET 2 0F 2 y
APPROVED /DATE
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INI A DATE RESPONSE REO'D.
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RESPONSE
A) CPCo attached letter CsC-7229 dated January 31, 1984 is Consumers l
Pcher Company's complete response to Item #050.
l B) The above referenced memo CSC-7119 dated December 23, 1983 is not a issue in Item #050.
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NO ATTACHMENTS n
n EST. CORRECTIVE ACTION RESf ND T
TITLE DATE 4
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'laPf COMPLETION DATE v
RESPONSE ACCEPTED DATE RESPONSE VERIFIED / CLOSED DATE
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Item Number 050 CONDITION DETAILS (continued)
Sheet 2 of 2
- 3) There is no specification /PQCI/ Procedure which establishes which Q-interface items receive or do not receive inspections. Thus, there is no design / engineering consideration being given to the present inspection /non-inspection guidelines.
Please advise CIO of the resolution of this condition where there is no formal direction for which Q-interface items do or do not require inspection.
NOTE: The subject above was addressed prior to utilization of this reporting form.- As such, this information item is being issued as a tracking mechanism.
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.y Midland Project: PO Boa 1963. Midland. Mt 48640. ($17) 6318550 Jarvary 31, 1984 Mr G A Hierzer Bechtel Power Corporation P O Box 2167 Midland, MI 48640 MIDLAND ENERGY CENTER CWO 7020 Q-INTERFACE CWP POLICY STATEMENT File: 0'456, 0655, Bl.1.7 UIF: 99*08, 53*50*01, 12*50 Serial: CSC-7229 Recently Stone & Webster had a concern about what inspections were necessary for Q-Interface CWPs.
This was a result from a Stcne & Webster representative having discussions with various Field Engineers and Team Quality Reps on the Teams.
The result of these discussions indicated that there was some confusion among these Team members as to what was the purpose of a Q-Interface CWP, what work was required to be inspected and also where to find these requirements.
It was agreed by Consumers Site Manage =ent and Stone & Webster that a policy statement 'should be distributed to the Teams.
The attached policy state:ent should be distributed to all System / Area Teams for their immediate notification.
Team Supervisors and Lead TQR should ensure that all Team cembers receive a copy and that the Field Engineers and Team Quality Reps fully understand all aspects of Q-Interface CWPs.
If any questions s: 111 retain, the Team should contact their CPCo Construction Engineer for further clarification. This action should be completed by February 8, 1984.
Furthermore, this policy statement should be incorporated in MPQAD Procedure T-3 and-FPG-7.300 as an attachment. This will ensura that any personnel requiring training in either cf these procedures in the fu ture will be instructed ai to the purpose of Q-Interface and how to determine what inspections are necessary.
The attached policy statement's development was coordinated with Bechtel and MPQAD.
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RAWells, MPQAD BHPeck, MEC DDJohnson, MEC NIReichel, MEC JChristy, MPQAD JReins*ch, BPCo a
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1 To Bechtel System / Area Team Members
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From Post
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Date January 27, 1984 Subject Q-INTERFACE CWP POLICY STATEMZhT Q-Interface is a word coined by Consumers Power Site Management.
Its purpose is to ensure that any work which comes in contact with a Q Commodity or renders a Q Commodity inaccessible, is ultimately controlled by Consumers Site Management.
Q-Interface CWPs in an area will be discontinued at cocaence-ment of Phase II of the CCP.
The reason CPCo requires control of these Q-Interface CWPs is two-feld:
(1) to ensure that the installation of a commodity will not conceal Q items that need verit'ication inspection and (2) to ensure that the work activities being donc does not violate Phase I controls set up by CPCo & the NRC.
These controls are being incorporated into Section 7 of FPC-7.300 Rev 4, and are delineated in the CCP Confirmatory Order.
(These controls were formally referred to as the
" Ground Rules".)
' Actual work that is performed in the field is Q or Non-Q.
CWPs are marked as Q-Interface only as a management tool to ensure that the above requirements are met.
Some Non-Q work p?rformed by' a Q-Interface CWP may have programmatic QC hold points which are addressed in the PQCI.
The Field Engineer will fill out a CWP in accordance with FPG-7.300 and cake the determination of which block (No,-Q, Q-Interf ace or Q) to check based on drawings and specifications in which he is working with.
Hold points are assigned based on the applicable specifications and the PQCI.
This is des-cribed in Section 4.5.3 of the Construction Completion Program.
The Team Quality Representative receives the Q-Interface or Q CWP following the initial preparation and reviews the hold po;nts ensuring the requirecents of the PQCI are-met, per FPG-7.300 and MPQAD Procedure T-3.
The TQR shall not sign the CWP until all quality planning is complete.
Once all the above items are completed per applicable specifications and procedures the Q or Q-Interface CWP is forwarded to CPCc Site Management O f fice for review and sign-off.
CONSUMERS POWER COMPANY MIDLAND ENERGY CENTER Transmittal No:
CSC-7268 Date:
February 1, 1984 To:
Stone & Webster P O Box 1963 Midland, MI '48640
'~1'ttached Is:
Partial Response lo X
Complete kesponse '2o For Your Information Other
Description:
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Tracked Information Item 045.
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cc JCKeppler, NRC Region Ill w/a JJHarrison, NRC Region III w/a l
RJCJok, NRC Site w/a RAWells, MPQAD w/a l
BHPeck, MEC w/a NIReichel, MEC w/a i
DDJohnson, MEC w/a i
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Sheet 1 of I
}lfMBERl HOLD POINT NUM STONE G WERSTER CONSTRUCTION IMPLEMENTATION O TRACKED ACTION ITEM OVERVIEW
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m TRACxEo iNrORMATION ITEM M/DidND NUCLEAR P!dNT J.0, N0. MSO9
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O TRACKEo RECauuENDATION ITEM REFERENCE (S) CIO Item Number 038 0 UNTRACKEDITEM CPCo Letter CSC-7134 of January 5,1984 ~d HOLD POINT NOTIFICATION CONDITION DETAILS The response provided to CIO. Item Number C38, copy attached, by the above referenced CPCo letter is not acceptaole to CIO. Therefore, Item Nuenber 038 has been closed and thic report issued to address the cencern.
Without appropriate administrative controls,
~
the tendancy will be for personnbl to develop a reliance on checklists rather than the
~
governing procedures and Engineering documents.
If it is your intention to utilize incomplete checklists for porticos of the work, CIO needs to know what actions will be taken by CPCo to assure that work is done to Engineering documents and that a reliance on checklists does not develop.
It is al:o noted that the checklist for FPM-7.000 has been r:evised to include all procedural items and incorporated as a part of the procedure.
,,0,4 X YES Y[.si I NO n
ATTACHMENTS D ATE RESPOhfN REQ'D.
It!ITI A T O /DATE INITI TlON. APPROVED /D ATE Jan. 27,1984
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RESPONSE
Reference attached letter CSC-7221 dated January 26, 1984.
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ONO ATTACHMENTS EST. CORRECTIVE ACTION RESP t FT TITLE DATE COMPLETIO DATE i
\\f AW ll RESPONSE ACCEPTED DATE RESPONSE VERIFtED/ CLOSED DATE G
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J Sise Manager 0h.
Mid*and Projet:
Midland Project PO Boa 1963 Midland MI 48640. (517) 631 8650 January 26, 1984 Mr G A Hierzer Bechtel Power Corporation P O Box 2167 Midland, MI 48640 MIDLAND ENERGY CENTER 7020 CID' OBSERVATION 045 FILE:
Bl.17 UFI:
99*08, 53*50*04, 12*50 SERIAL:
CS.C-7221 Per conversation with Stone & Webster the subject of using checklists in procedures has been clarified.
As you are aware, the checkl'ist for FPM 7.000 has been revised to include all procedural items and incorporated as part of the procedure. This re-solved Stone & Webster's concern in that area.
Any existing procedures which utilize checklists snust be reviewed and revised if necessary, to insure the checklist is complete and fully consistant with all requirements of the procedure it is to be used in conjunction with. Any nev procedures and related checklists must also conform to these requirements.
It is also requested that cach checklist to be used contain a statement that it is a memory key aid and not a substitution for the required use of Design Drawings and Specifications.
Please have this completed and reply back by February 24, 1984.
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cc:
TASpelman NIReichel BHPeck e
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