ML20080R279

Confirms Commitments Made to NRC at 830825 Public Meeting in Midland,Mi Re Third Party Const Implementation Overview Program.Viewgraphs Encl

ML20080R279
Person / Time
Site:	Midland
Issue date:	08/30/1983
From:	Wild P STONE & WEBSTER, INC.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080R268	List: ML20080R279
References
NUDOCS 8310170466
Download: ML20080R279 (20)

Text

Attachment 2 STONE & WEBSTER MICHIGAN, INC.

P.O. Box 2325. Boston. M ASSACHUSETTS O2107 i

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hir. J. G. Keppler August 30, 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 This letter confirms commitments made by Stone & Webster Michigan, Inc.

(Stone & Webster) to NRC at the Public Meeting on August 25, 1983, at Midland, Michigan in reference to the Construction Implementation over-view Program (CIO). As stated in the meeting, Stone & Webster will:

1. Implement the CIO Program in a manner consistent with NkC regulations. Program details are described in program documents previously provided to NRC and the attached copies of graphics used in the Stone & Webster presentation on August 25, 1983.

2. Revise the Project Quality Assurance Plan to address Stone & Webster audits of the CIO Program. An initial audit will be conducted within 90 days of NRC approval of the CIO Program followed by audits on a twice a year basis. This audit schedule will be increased if activi-ties warrant.

3. Revise the Project Quality Assurance Plan to address Stone & Webster trend analysis. This trending will be conducted to ensure that sampling levels and changes thereto are consistent with the performance of Consumers Power Company.

We trust that these commitments are in agreement with your understanding of what was stated at the Public Meeting, and meet with your approval.

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'f . v h P. A. Wild *f Vice President Enclosure gEP 2 Jgg3 cc: JWCook-CPCo 8310170466 830930 PDR ADOCK 05000329 G PDR

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S. BARANOW PROGRAM MANAGER j 15 YEARS NUCLEAR EXPERIENCE

! 10 YEARS NUCLEAR SITE EXPERIENCE I

5 DIFFERENT SITES F. BEARHAM SUPERVISOR OF PROGRAM EVALUATION

! 25 YEARS OF NUCLEAR EXPERIENCE 13 YEARS NUCLEAR SITE EXPERIENCE 8 DIFFERENT SITES J. THOMPSON

"$0PERINTENDENT OF PHYSICAL VERIFICATION'

14 YEARS NUCLEAR EXPERIENCE 12 YEARS NUCLEAR SITE EXPERIENCE 4 DIFFERENT SITES l .3-n. .

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11 '11 e BACKGROUND i

i CONSTRUCTION COMPLETION PROGRAM-CCP STONE & WEBSTER PROPOSED AS l lNDEPENDENT THIRD PARTY

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SCOPE i INDEPENDENTLY ASSESS IMPLEMENTATION OF 1

! CCP ACTIVITIES; V PHASE I PLANNING V MANAGEMENT REVIEWS V INSTALLATION AND INSPECTION STATUS

\ W VERIFICATION OF COMPLETED

\ INSPECTIONS (QVP) l W HVAC/ZACK -

i W SPATIAL SYSTEM INTERACTION PROGRAM (SSIP)

! W PHASE II

CIO ORGANIZATION O

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MANAGER OF SENIOR '

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• SYSTEMS ELECTRICAL / CONTROLS b NONCONFORM ANCES

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TERMINATIONS

• WELDING an=====> ammme TECHIC AL DIRECTION ammmme e amuse OVERVIEW

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DOCUMENT TREE l

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D ,SSURANCE A. ASSESSMENT AND NEEDED DIRECTIVES) REPORTING l

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i SWEC CIO PROGRAM l

• OBJECTIVE IS TO ASSESS QVP AND CCP RESULTS TO ESTABi.iSH l THE PROGRAM'S EFFECTIVENESS.

• KNOWN STATISTICAL METHODS WILL BE USED TO ESTABLISH THE NUMBER OF INSPECTIONS / ASSESSMENTS.

• TECHNICAL EVALUATIONS WILL BE MADE TO ESTABLISH THE SIGNIFICANCE OF NONCOMPLYING CONDITIONS.

a CORRECTIVE MEASURES WILL BE REQUIRED IF CPCo PROGRAMS

! PERSONNEL OR IMPLEMENTATION ARE TURNING DVER LOTS WHICH i

CONTAIN SIGNIFICANT DEFICIENCIES.

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! ASSESSMENT MATRIX l FOR j PHYSICAL VERIFICATION GROUP ASSEff#ENT REVIEW OF REVIEW OF CHECKLIST EVALUATION VERIFICATION P Cls SUPPORTING DEVELOPMENT ELENENTS DOCUMENTS

1. STATUS INSTALLATION M $ I A l INSPECTION M A A N $

I i 2. QUALITY VERIFICATION i PROGRAM ACCESSIBLE $ M Y k INACCESSIBLE 5 $ $ $

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DOCUMENTS PROCEDURES

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I MANAGEMENT REVIEW y $ $

MEETINGS CCP ORGANIZATION N Y  %

MPGAO ORGANIZATION N N Y INSPECTION PLANS M N NRC ANO CIO HOLO PolNTS i SSMMITMENTS TO NRC l

l 2. PROCEOURES CONSTRUCTION PROCEOURES N N N Y MPGAO PROCESURES N N N M.

3. TRAININ0!v. m CCP TEAMS N N

• Y Y MPGAO INSPECTORS Y CONSTRUCTION CRAFT M M N

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PRODUCT OBJECTIVE CIO m SAMPLE -

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> FULL TIME CIO MONITOR ASSIGNED TO OVERVIEW EACH TEAM'S ACTIVITIES AND ALL INSPECTIONS WITHIN THE PERVIEW OF THE TEAM.

1 l > A STATISTICAL SAMPLE OF MPQAD INSPECTIONS WILL BE TAKEN AND EVALUATED BY INDEPENDENT CIO INSPECTION. ,

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> IF TEAM PERFORMANCE AND INSPECTION RESULTS ARE DEEMED SATISFACTORY - FULL TIME CIO MONITORING WILL BE ADJUSTED DOWNWARD. INDEPENDENT SAMPLING INSPECTIONS WILL BE

, MAINTAINED.

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f > IF TEAM PERFORMANCE OR INDEPENDENT INSPECTION RESULTS REVEAL j UNSATISFACTORY, CPCO CCP/QVP FULL TIME CIO MONITORING WILL BE l MAINTAINED.

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i AREAS TO BE CLOSELY MONITORED i

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I WELDER QUALIFICATION PRODUCTION WELDING DocVMENT CHANGE CONTROL CABLE PULLING l

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QA RECORDS STORAGE l PREVENTIVE MAINTENANCE CORRECTIVE ACTION FOR NONCONFORMANCE '

"'"' TRENDING & ROOT CAUSES l i b -

FLOW CHART FOR -

NONCONFORMANCE REPORTS

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CPCO IIEVIEW FOR REPORTAalLITY AND D4SPOSITION I

CONCURRENCE Of CORRECTIVE go ACTION BY PROGRAM MANAGER YES REJECT VERIFY CORRECTIVE ACTIO N .

i lACCEPT ,-j PROGRAM LG4 AND MANAGER DISTRIBUTE CLOSE OUT m ORielN A L- CPCO NCR C OPIE S - N RC ,

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• SWEC WILL USE MIL-STD-105D AS THE BASIC l STATISTICAL METHOD.

I e COMPLIANCE BASELINE WILL BE ESTABLISHED AS FOLLOWS:

) - EACH QVP TEAM'S WORK WILL BE SAMPLED USING 95-5 l CONFIDENCE FOR 1ST (3) SUBMITTALS

- IF ALL PASS THEN SAMPLING WILL BE REDUCED TO 90-10 CONFIDENCE

- IF A TEAM HAS SINGLE FAILURE BASED ON SIGNIFICANT

. ATTRIBUTE THEN RETURN TO 95-5. THIS WILL CONTINUE UNTil (3) CONSECUTIVE PASSES ARE ACHIEVED.

' o m "- - ANY TEAM SUBMITTING (3) CONSECUTIVE FAILED LOTS WILL BE ,

SUBJECT TO RETRAINING AND 100% INSPECTION UNTIL IT IS JUDGED SAFE TO RETURN TO SAMPLING - NORMALLY THIS WILL

, BE (3) CONSECUTIVE PASSED LOTS WITH NO SIGNIFICANT CONDITIONS DBSERVED.

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A COMP ARISON DETWEEN S AMPLE SIZES - -

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'iANLE SIZE (n) i MS-105D LOT SIZE (N) 9 95-5 9 90-10 9 20%*

! 2 to 8 ALL ALL 1/2

9 to 15 ALL ALL 2/3 16 to 25 A

.L All to 20 4/5 l

26 to 50 ALL 20 6 / 10

! 51 to 90 50 20' 11 / 18 91 to 150 50 20 19 / 30 i

} 151 to 280 50 32 21 / 56 i

l 281 to 500 50 50 57 / 100 501 to 1200 80 80 101 / 240 1201 to 3200 125 125 241 / 640 1

2 3201 to 10,000 200 200 641 / 2000 l

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• SWEC APPROACH WILL ENSURE

- OBJECTIVE ASSESSMENT '

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- REPORTS TO NRC, CPCo, PUBLIC I

) - CORRECTIVE ACTION

• PERFORMANCE WILL BE REWARDED AND i

ENCOURAGED BY SAMPLE REDUCTIONS, WHEN JUSTIFIED.

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- Ii "NAMPLING OVERVIEW -

k UPON COMPLETION OF CIO, SWEC WILL i STATE:

-; > THAT CPCO's, QVP AND CCP HAVE BEEN l ASSESSED AND FOUND ACCEPTABLE.

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! > THAT ALL SIGNIFICANT CONDITIONS ADVERSE l TO QUALITY HAVE BEEN. IDENTIFIED AND RESOLVED.

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l A CONCLUSION THAT MIDLAND STATION MEETS' l OR EXCEEDS ALL APPLICABLE REGULATIONS, l CODES AND STANDARDS.

Attachment 3 7

STONE & WEBSTER MICHIGAN, INC.

P.O. Box 2325. BOSTON. M ASsACHusETTS O2107 Mr. J. W. Keppler September 9, 1983 Administrator, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 THIPD PARTY CONSTRUCTION IMPLEMENTATION OVERVIEW PROGRAM MIDLAND NUCLEAR C0 GENERATION PLANT Stone & 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 regttested by Mr. J. J. Harrison on September 6, 1983.

P. A. Wild Vice President APA:efb Enclosure cc: JWCook-CPCo.

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Q SEP 1 2 1983

SUMMARY

OF PRESENTATION TO NRC ON AUGUST 25, 1983

'. CONSTRUCTION IMPLE"ENTATION OVERVIEW (CIO) PROGRAM Background to CIO

,The Construction Coupletion 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 & 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/B6W

- 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.

ZIhe Program Fbnager is responsible for directing the day-to-day activities of

?these two groups. The Program Manager receives technical direction from the gStone & Webster Manager of Quality Assurance and resource support from the Project Manager.

2.

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. Ihe 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 l

procedure for processing Nonconformance Identification Reports. Additional project procedures will be issued as needed to cover unique items that arise during the CIO cffort.

CIO Fkthodology The methodology to be used in assessing the installation and inspection status and Quality Verification Program (QVP) of the CCP consists of (1) surveying the activities of each CCP team and all inspections within 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 y evaluating the results by conducting independent inspections with CIO team

- members to assess the final product. A full time monitor from the CIO team 1 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 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-confor=ances, 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. Sarpling the product from MPQAD inspections udll previde a reliable assessment of that effectiveness.

Proerammatic and training aspects of the CCP will be assessed by reviewing Ir;1erenting documents and commitments and then developing 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 Identifiestion 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 l 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.

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Manning Plan for CIO Team

! Nine members of the CIO team are currently on site. These people have been r reviewing documents; preparing checklists; and evaluating training, organi-zation11 practices, and procedures. .

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I P5ansaretohaveoneteammemberassignedtoeachCCPteam,fiveauditors to conduct the program evaluation function, one to three support engineers depending on the workload, two group 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 will be carried out to ensure that the Midland plant is built in accordance with applicable codes, standards, and regulations.

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