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{{#Wiki_filter:. ...g. - .s. GOVERNMENT ACCOUNTADIUTY PROJECT Institute for Pohey Studies .} 1901 Que Street. N.W.. Woshington. D.C. 20009 (202)23d 9352 November 11, 1982 [ Mr. Harold P. Denton Office of Nuclear Reactor Regulation Division of 1,1 censing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. James G.' Kappler Administrator, Regica III U. 5. Nuclear Regulatory Camission 799 aoosevelt Road Glen Ellyn, Illinois 60137 Re: Midland Nuclear Power Plant, Units I & II ~ 1 - Consumers Power Company, Quality Assurance Program Implementation for Soils Remedial Work j - Consumers Power Company Midland Independent Reviev Procram
Dear Sirs:
This letter provides a comprehensive review of the written materials and presentations frem the October 24 and November 5,19C2 meetings between C.insumers Power Company (CPCo) and the NRC'at the Bethesda offices. We are subditting these comments on behalf of those former employees, local citi'zens and the 4 Lone Tree Council of the tri-city area surrounding the plant. .j We are pleased with a number of results to dater specifically the inclusion of the Tera Corporation's vertical slice review, the expertise of Parsons and Brinkerhoff, and the impressive qualifications of certain personnel selected to perform the independent assessment. Further, we are pleased with the consensus .'b for the independent auditors to subau.t their reports simultaneously to CPCo and the Nuclear Regulatory Ceaunission. } In general, however, we remain skeptical of the plan being provided by.CPCo to allay legitimate NRC and public concerns over the safety of the Midland project. Although we are operating at a handicap due to the generalized nature of CPCo's i j presentations, the following specific ccncerns and observations may be helpful 4 as you review the final CPCo proposal. s .h j I. Summary of October 22, 1982 Mecer-menda tion s on October 22, 1982 CAP provided an extensive review of the three Consumers Power Company letters outlining the utility's proposed relief. The review 'k. & & f 840317 ~~ -~ RICE 84-96 pg
I l . cy A. i l. Mr. Harold P. Denton 2-November 11, 1982 Mr. James G. Keppler included a number of specific concerns which remain unresolved, as well as pertinent recommendations. Based on our review of the licensee proposals (and subsequent presentations) we are asking the NRC: 1. To withhold approval of the independent audit proposal in its present form. 2. To require two further public meetings, in Michigan,,that finalize - the details of the independent contracts. At least one of these meetings should be in Midland, so that a. local residents can be informed: -and one of these meetings should fully explain the proposed' single-point accountability (SPA) proposal, including having the individuals who are to perform this function explain their personal understanding of their respective responsibilities. ~ 9 b. Further, GAP recommends that: 1. Final approval of the SPA individuals rest with the NRC 2. SPA officials should ccamit to at least one meeting and site tour with public nuclear employee witnesses to re-solve their allegations: 3. SPA officials should be accessible to the public on a regularly scheduled basis to discuss the status of the work. The second meeting should provide an opportunitt for all the c. contracted independent auditors to meet directly with the NRO staff, in public, and review the terms and requirements of .their contracts. To require the expansion of tne proposed training sessions, it.cluding 1 - 3. ) NRC review of the training materials relating to NRC regulations and requirements. 1. To increase direct contact between NRC regional management officials and QA/QC personnel performing work on the soil remed8.a1 project, including written materials for each employee, a site yisit by J Mr. Keppler, and an "open door" policy with resident inspectors. .j 5. To reject the INPC evaluation by Management Analysis Company as the independent assessment. (Although CAP believes the INPO evaluation may be beneficial to CPCo management, it does not meet the minimum requirements for either independence or a comprehensive evaluation.) i ^\\ 6. To reject the selection of Stone & Webster for the independent g. ' assessment of QA implementation. i 7. To request that the entire record, including all relevant, material taw data,be provided to the NRC with the weekly and monthly reports. ( t e --n- ,.--*-,-n.-. r-e,a <nn, m,w -- y w w,, ---n.--- y- ,,g------ca,
l 3:. Mr. Harold P. Denton 3-November 11, 1982 Mr. James G. Kappler d O. To require a mandated percentage of field verification of the systems being reviewed. Finally, GAP provided a series of specific recommendations fer the charters of the independent contractors and subcontractors. These are noted below j 1. The independent contractor should be responsible directly to the NBC, submitting all interim and final product simultaneously with j CPCo and the NRC. 2. The independent contractor should do a historical assessment of CPCo's prior work, including a frank report of the causes of the i soils settlement problem. ~ .i 3. The charter should ensure that, once hired, CPCo cannot dismiss the independent contractor frcza the project without prior notice i to the NRC and an NRC-sponsored public meeting to justify the decision. 4. The charter should require that each auditor, "at least five already identified, subcontract any services for which its direct personnel are not qualified. i 5. The charter should require that the proposed methodology be elis-l -i closed: specifically selection criteria and size of the samples for inspections and testing. 6. The charter should require the auditors to provide calculations demonstrating that it is possible to adequately complete its work f ,{ during the proposed timeframe. .i 7. The charter should require the auditor to support its proposed s methodology through references to established professional codes (ASIM, ASME, ANSI, AWS, etc.). 1 8. The charter's should require all auditors to report all safety- } related information directly to the NRC. 9. The employees and auditors should demonstrate that the personnel assigned to the project are free from conflicts of interest. 'I'
- 10. The auditors must recommend corrective' action, and then control
~ its implementation. our further comments can be categorized into priority items and methodology. A.. Priority Items i ~No soils work should be allowed to co (orvard until all cuesti3ns on l 1. l isolementacion review crocess are resolved, j I .l s ~ ~ ~ e ~ 4- ,n,e-w,-,., --e. --,,w
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Mr. Harry P. Denton Mr. James G. Kappler November 11, 1982 J a. Lack of independence. At the November 5,1982 meeting it was obvious that the most basic questions about Stone & Webster's (S&W) work had not been resolved. The disclosure that S&W in fact had done previous work for CPCo was particularly disturbing. This places S&W in the same position as MAC. According to the "Independency criteria" outlined in the February 1,1982 letter from Chairman Palladino to Congressman John Dengell, as well as the previous independence criteria used in Region III, S&W must be rejected. b. Conflict of interest. Further, the conflict-of-interest clause pertaining to "significant amounts" of stock has not been ade-quately explained, nor has the specific stockholding been ade-l 4 quately disclosed for the members'of S&W's management review l team and the S&W corporation itself. Insignificant conflicts should be fully disclosed and explained, subject to NBC approval. c. Lines of authority. Additionally, S&W and Consumers representatives could not provide adequate answers to explain who has final deci-sionmaking authority within and between S&W, Bechtel and Consumers. It was quite clear that consumers "does not anticipate" any prob-less between the numerous involved parties. This optimistic attitude bel,ies a sense of security that is inconsistent with both the potential and the historic prooiens between Bechtel and Stone & Webster. (Specifically, GAP recommends the use of the NBC dissenting professional opinion procedure throughout this process. 2. The CPCo option to provide QA implementation for only a 90-day period must be dropped. , As proposed, the 90-day initial assessment period will cover only the 3 t trial period of constructics. This limited ecope cannot realistically 3 present any assurance that CPCo and Bechtel have reversed a decade-long .} history of failures and bungling. Anything less than 100% review will fall short of accomplishing the goal of the proposed remedy. 3 3. Until the soecific methodoloov of how S&W is going to evaluate the adecuacy of technical, construction and cuality procedures is dis-I closed, no aporoval should be issued. J Although the evaluation will be cumulative, it is critical that NRC l t taff and the public are aware of the methodology for S&W's review. otherwise, faulty fact-finding techniques will be faits accomoli l when the public has an opportunity to review them. I i 4. T.elease and Review of the Project Quality Plan for soils CA review is essential. .i ~{ This document evidently holds the key to S&W review. It is through this Plan that the actual implementation will be reviewed and i
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) Mr. Harry P. Danten Mr. James G. Kappler November 11, 1982 monitored. It is critical that this document be released for public review and analysis before any NRC approval is given. 5. It is critical that CPCo conunission an independent assessment team as quickly as possible. 1. As indicated previously, GAP cannot accept MAC and the INPO evaluation as a substitute for an independent review. (See October 22, 1982 letter, pp. 17-18.) As a result we have re-frained from providing specific comment on the MAC preposals. However, some of the major programmatic weaknesses are listed below-- ~; - lack of historical analys5s of problems to get to the " root cause," leaving unanswered questions with regards to the causes (contradicting the ACRS's June 9,1982 request to the NRC staff): - lack of trending of systems or nonconformances to identify specifically weak areas of construction or QA/QC functions: - time guidelines dictated by the utility, hamperug the independence of any company to define the scope of necessary evaluations: - lack of specified criteria to identify the qualifications of the key factfinders and inspectors - reporting procedures that exclude independent contact wit $ the NBC: - evaluation / contact report that provides a weak substitute for Nonconformance Reports without verification of correttive action: - lack of recomunendations for resolution of identified weak-nesses and - lack of recognition for the gravity of Midland's problems, evidenced by attempting to substitute INPO for aggressive independent assecament. 4. Excansion of the role performed by Tara Corporation is accropriate, a. The Tara Corporation proposed to look at the Auxiliary reedwater System for its independent safety system. This system has been reviewed several times in previous audits. CAP reconunends tP.at this system he rejected in favor of a combination of two systems: one system under controversy - the HVAC system specifica11yf/ -- and another system yet unidentified for major review or auditing. M n an October 12, 1982 letter from Mr. J. C. Keppler to Ms. Billie Carde, it I j was suggested that the indeoendent assessment would resolve the questions of the
,.d 4 i Mr. Harry P. Denton Mr. James C. Xeppler November 11, 1982 i b. Tera's work, although admirable, failed to provido an acceptable or even identifiable level of field verification of the as-built i condition and failed to. explain the disclosed inconsistencies in the scope of its proposed field verification effort. It is our recoamendation that Tera provide additional qualified personnel to conduct comprehensive field review of the system (s) under scrutiny. f: c. Tera should be removed from any reporting line through MAC, answering directly (and simultaneously) to the NRC and the licensee with reports and findings. (This was already reflected in Tara written presentation, but was not ' clear in the MAC/CPCo ccaments at the October 24 meeting.) 5. Methodology j Generally, the specific methodology for assessments / audits was non-existent. Without the information on such issues as the size of samples, specific system criteria for examination, evaluation criteria, forms used for evaluations and reporting procedures, it is impossible to accept any re-view as adequate. The Tera's presentation was a refreshing deviation frcus the otherwise ~ public relations-style presentations. It is our request that any further meetings be delayed until after CPCo provides adequate comprehensive metto-l dologies for analysis. (Perhaps the NRC could provide examples of parti-cularly noteworthy independent reviews to CPCo in an effort to demonstrate a truly broad scope assessment.) It is our earnest hope that this methodology, once provided, will provide a basis to begin restoration of public confidence in the plant. Anything ) short of an "open book" at this point will fall short of the goals of this expensive effort. We have attempted,to provide a thorough review ~ of the massive independent assessment efforts at the Midland site. But a comprehensive effort is impos-sible based on the minimal public disclosure to date. As a retult, wt request the following specific plans or documents from the NRC in order to finish our } evaluation. 1. The details of the Quality Improvement Plan (QIP) (september 17 letter to Denton). + i, 2. The Project Quality Plan (S&W presentation, November 5,1982) 3. The Single Point Accountability System. (September 17,*1982 CFCo letter to Denton) (footnote continued) HVAC systems adequacy. It does not appear to be the case in any of the presentations thus far. s
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~ _ _ - .P.,*.'. Mr. Harry P. Denton Mr. James G. Xeppler November 11, 1982 I 4. The criteria for selection of the independent auditors 5. The criteria for choosing the, specific safety system 6. A reporting (ccannunication line) chart,'frem the worker up and the NRC down 7. The conflict-of-interest disclosures for all independent assessment corporations, individuals and management 8. The training materials to be used as part of the QIP ~ 9. The criteria for selection of field verification inspections by Tera personnel
- 10. The breakdown of SAW personnel with nuclear experience by plant site.
II. Conclusion Finally, we wish to thank you for your inclusion of public comment into this pr.ocedure. It is a positive step forward on behalf of public safety issAas. We icok forward to notification of the next meetings on the independent assess-ment of the Midland plant, as well as notification of any other portine,nt 4 meetings on the Midland project. As the role of the Government Accountability Project in the Midland investigation grows, it seems appropriate to repeat an oft-used phrase of Mr. James G. Kappler about the William H. Zincter Nuclear Power Station. The "real sin" at Zimmer is that the plant is in the grodnd at 974 complete. Since Midland is far from complete, there remains an cpportunity to avoid the sins of Zimmer, - but it will take concerted of fort by all parties at this critical juncture. Sincerely,
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1 BII.I.IE P. CARDE j Director. -{ Citizens Clinic for Accountable Government s nG/my ? s s 4 0
l SON ',/,. / s AGENDA Opening Remarks JWCook Construction Completion Program Introduction ~ DBMiller Detailed Description RAWells Third Party Review GSKeeley/ TERA Bechtel Comments JARutgers Closure JWCook 9 4 9 P
CONSTRUCTION COMPLETION PROGRAM SOURCES OF INPilT 1. EVALUATION OF SYSTEMS COMPLETION 2. TRANSFER OF QC To CPCo QA (MPQAD) 3. INP0 SELF-INITI ATED EVALIIATION 4. 1981 SALP REPORT AND SilBSEollENT DISCllSSIONS 5. THE OCTOBER /NovFMnER DIF.SEL-6ENERATon Ru!LDING INSPECTION S. NOVEMBER NRC LETTER TO THE ACRS 7. NEED TO PLACE MORE EMPHASIS ON SOILS START
C0llSTRilCflM CafFLETiON PROGRM ORJECTIVES 1 IMPROVE PROJECT INFORMATION STATUS RY: PREPARING AN ACCURATE LIST OF To-GO NORK AGAINST A DEFINED BASELINE. BRINGING INSPECTIONS UP-TO-DATE AND VERIFYING THAT PAST GUALITY ISSUES HAVE BEEN OR ARE BEING BROUGHT TO RESOLUTION. MAINTAINING A CURRENT STATUS OF NORK AND QUALITY INSPECTIONS AS THE PROJECT PROCEEDS. IMPROVE IMPLEMENTATION OF THE DA PROGRAM RY: EXPANDING AND CONSOLIDATING CONSUMERS PONER COMPANY CONTROL OF THE QUALITY FUNCTIONS. IMPROVING THE PRIMARY INSPECTION PROCESS. t -PROVIDING A UNIFORM UNDERSTANDING OF THE QUALITY REQUIREMENTS AMONG ALL PARTIES. g
CallSTRUCTInfl CafFLETI0li PROGRAM.(CONTn) ASSURE EFFICIENT AMn ORnERLY CONDUCT OF-THE-PROJECT-RYt -ESTABLISHING AN ORGANIZATIONAL STRUCTURE CONSISTENT WITH THE REMAI'NING WORK. ~ 1 -PR0 vining SUFFICIEMT MUMBERS OF QUALIFIEn PERSOMMEL TO CARRY OUT THE PROGRAMi -MAINTAIMIMG FLEXIMILITY TO MODIFY THE PLAN AS EXPERIENCE nICTATES; 1 1 4 l 4 i e m
FIGURE 1-1 CON 8TRUCTION COSAPLETlON PROGRAM 8CHEMATip 'PHA8E 1 PHASE 2 SECTION PLANellNG ltAPLEAAENTATION PLANNING ltAPLEMENTATION PREPARATION. 2 OF THE PLANT ~ QA/QC I REORGATHZATION PHASE 1 PHASE 2 4 PLANNING , PLANNING y,,1: in o. -r )o, hp MANAGEMENT REVIEW COMPLETED IN8PECTIONS EVALUATION SYSTEMS 5 AND COMPLETION REVIEW WORK MANAGEMENT N REVIEW INSPECTION STATUS JL
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OUALITY PROGRAM REVIEW 7 THIRD PARTY REVIEWS 8 SYSTEM LAY UP 9 CONTINUING WORK ACilVITIES ~. e l 1 l i i
SECTION 2.0 PREPARATION OF THE PLANT DRICTIVES: TC ALLOW IMPROVED ACCESS TO SYSTEMS FOR PROGRAM ACTIVITIES DESCRIPTION: REDUCE THE WORKFORCE AND LIMIT Q ACTIVITIES i REMOVE THE CONSTRUCTION EQUIPMENT AND CLEAR AREAS INSPECT, STORE AND SALVAGE EQUIPMENT RESULTS: PLANT IS IN A CONDITION TO FACILITATE INSTALLATION AND INSPECTInN STATUS AND VERIFICATION OF COMPLETED WORK 4 STATUS: REDUCTION IN FORCE STARTED 12/.l/R2 WITH CLEANHP COMPLETED ON 1 1/31/83. i
SECTION 3.0 GA/QC DRGANIZATIONAL CHANGES OBJECTIVE: . ESTABLISH INTEGRATED QA/QC ORGANIZATION UNDER CPCO CONTROL er.- a.u n. n.......... -...,....,.. v i,-.. . TRAIN AND RE-CERTIFY QC INSPECTION PERSONNEL DESCRIPTION: . oC ORGANIZATION REPORTS DIRECTLY AND SOLELY TO CPCO MPQAD t . QA AND QC RESPONSIRILITIES REDEFINED AS AN INTEGRATED TEAM . Q/. DEVELOPS INSPECTION PLANS - QC IMPLEMENTS PLAYS - QA MONITORS 3 - n v7 a ; t...,....... i ~. ! = n, u,, '. w a.,, i,. y.z. u., ;,..,,- .,x.. c .. BECHTEL S QC AND QA MANUALS USED AS APPROVED FOR MIDLAND i 4 cofr-i Tv. ~ in rc. m, WJ ..w e..c. j-hn e.. nx ? L. ca ' A$MIREQUIREMENTSREMAINIMPOSEDONCONTRACTORASN-STAMPHOLDER-QA MONITORS l 1 1 t i QC INSPECTORS RECERTIFIED [ [ bbED: . FULLY INTEGRATED QUALITY ORGANIZATION UNDER CPCO CONTROL UNIFORM UNDERSTANDING OF QUALITY REQUIREMENTS AMONG ALL PARTIES i a 4 r IMPROVED PRIMARY INSPECTION PROCESS WITH RECERTIFIED PERSONNEL i IMPROVED AND AGGRESSIVE IMPLEMENTATION OF QA PROGRAM i i s l STATUS: TRANSFER QC SUBMIT PROGRAMMATIC COMPLETE INSPECTOR ORG TO CPCO CHANGES TO NRC RECERTIFICATION Il 1/17/R3 2/17/R3 11/1/R3 ~
t , i i c 1 i + D C Il ll s l I l Il l 1 i I,,I' L I T EC A WQ MT ,a T I l N H E MR ,v E C / E T AO 7[luD E )E M H RP tN M M C G P 8 U A E E / E O TcT E B D S R OH P A I I ( P S l P n 0 E 0 PU I S 'L A o jT i ' 'N R 0 - l* E T 0 M a* N D O C E ~ E E L T hT E 1 ON 8 I T R N P E P O .E d R U IT T E S .A ,C E G 1 Z ECA JNN T I SN QAA N E A SRM l iQ R G PU -r. Q E V O-OD l E O' 8 /N U R D V A E e ~ .s; GO. N 8I 'OT T ~ A. l 0 I N F. D 0 s I Ts i. I A D R l l C oE u ,h (.ijN P P d E S U t M U S O _I. T E T T E A N C O 0 E l N Q D E o e A / 8 N N 8 R A 1 R )E E o ~ U E Q f T T t fe S Gl 0IN n S e N N. Aa AR A NF VE o0 m s 1 F t YA NP a 1 l T M (O U A O i R N t IL s eoU A s a l' i T U s o t a Q N n t O A t L se t t G a i I 1 T N Y t AI sL e s a RN mt r TI T t s A S R
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.. <a....:. e,,.r -y.... ;... 1 ~.; .__y., a 3,., OC RECERTIFICATION PROGRAM: COVERS ALL QC INSPECTORS INTEGRATED WITH MPQAD l CLASS ROOM TRAINING;f,0N PROGRAMMATIC AND INSPECTION PLANS WRITTEN CLOSED BOOK EXAMINATIONS WITH 80% ACHIEVEMENT REQUIREMENT ON PROGRAMMATIC AND INSPECTION PLANS ON THE JOB TRAINING AND PERFORMANCE DEMONSTRATION EXAMINATIONS WITH 100% ACHIEVEMENT REQUIREMENT ON INSPECTION PLANS FINAL CERTIFICATION GIVEN BY MPQAD PERSONNEL QUALIFIED AS ANSI LEVEL III TRAINING STAFF: UNDER MPQAD DIREC. TION DEDICATED STAFF WITH SUPPORT BY EXPERIENCED MPQAD STAFF EXPERIENCED TRAINING SUPERVISION AND SELECTED INSTRUCTORS-PRESENT COMPLEMENT SUPERVISORS INSTRUCTORS i PROGRAM SUPPORT (LESSON PLANS - EXAMS) l STATUS: ALL PERSONNEL RECERTIFIED TO QC PROGRAM -(AS OF 2/4/83) NEARLY 500 INSPECTOR - POCI TESTS OVER.100 PERFORMANCE DEMONSTRATIONS APPROXIMATELY 75 INSPECTOR - PQCI CERTIFICATIONS l
SECTION li.2 AND ll.Il PROGRAM PLANNING TEAM DRGANIZATION ORJECTIVE: ORGANIZE AND TRAIN TEAM AND PREPARE PROCEDURES FOR INSTALLATION AND INSPECTION STATUS ASSESSMENT.AND FOR SYSTEMS COMPLETION. DESCRIPTION: . DEVELOP TEAM CONCEPT . SELECT PILOT TEAM TO TEST PROCESSES AND PROCEDURES . PREPARE JOR RESPONSIBILITIES AND PROCEDURES . PROVIDE TEAM TRAINING FOR STATUS ASSESSMENT AND SYSTEMS COMPLETION RESULTS . IMPROVED INSPECTION AND INSTALLATION PLANNING AND EXECUTION EXPECTED: . IMPROVED DIRECTIONS TO CRAFTS . IMPROVED COMMUNICATION BETWEEN CONSTRUCTION, QC, ENGINEERING AND IESTING STATUS ESTABLISH TEAM CONCEPT AND DESIGNATE PILOT TEAM 1/21/83 o
[. \\ i i l BENEFITS OF ' COMPLETION TEAM" APPROACH r J e SINGLE GROUP RESPONSIBLE FOR ALL ASPECTS OF SYSTEM COMPLETION i f TO FUNCTIONAL TURNOVER l e IMPROVED COMMUNICATION BY BEING PHYSICALLY LOCATED TOGETHER
- IMPROVED MAINTENANCE OF STATUS OF WORK
- SINGLE POINT CONTACT FOf? QUALITY INSPECTION REQUIREMENTS i
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- IMPROVED i 4TEGRATION OF QUALITY INSPECTION PLANS WITH THE
} INSTALLATION PLANS i .] j 1 l..:I j l .* BINGLE POINT CONTACT FOR ENGINEERING / DESIGN REQUIREMENTS ~ .! i' ^ e 8 INGLE POINT CONTACT FOR TESTING REQUIREMENTS r7;;[ / - i I j l \\ I atu-oser-s l
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3 5 . \\ SYSTEM TEAM DEVELOPMENT i ORGANIZATIONAL PROCESS & PROCEDURE DEVELOPMENT i ,i a i I VISIT OTHER DEVELOP SELECT PILOT TEAM PREPARE TEAM PROJECTS
- TEAM PILOT TEAM
- FINAL TRAINING
- Review of CONCEPT
& ISSUE Charter CHARTER. FOR PRELIMINARY PROCESSES, STATUS TEAM
- Test the
& PROCE-ASSESS-CHARTER Processes & DURES MENT l Procedures i i i f
- Team Training l
i REVIEWS AND APPROVALS l [ l MGMT m REVIEW i COMMENCE WORK i TEAMS ( Commence Status I Assessment o i l y ~ s-= i a o . U) C t
~ J UJ O Cg SYSTEM TEAM OPERATIONS c, ~ QUALITY CPCo TEST & I REPRESENTATIVE 7 CONSTR. ENGR.'S TEAM SUPERVISOR
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- COMPARE PHYSICAL STATUS TO THE DOCUMENTS
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- PERFORM QUALITY VERIFICATION ACTIVITIES AS ASSIGNED
- IDENTIFY REMAINING WORK i
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- DEVELOP DETAll SYSTEM COMPLETION SCHEDULES
- DIRECT & ACCOMPLISH THE WORK
- MONITOR & REPORT STATUS / PROGRESS
- IDENTIFY PROBLEMS FOR RESOLUTION & MGMT. REVIEW
- COMPLETE THE SYSTEMS FOR FUNCTIONAL TURNOVER l
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[ 'I 'f SYSTEM TEAM ORGANIZATION L ri i l o3 I ia " i F. I Y 3 SYS. TEAM i !'4 s PROJECT SUPV. PROJECT ~ 00 ENOR. Eoc 3 i i = (*Q* SYSTEMS ONLY) l i S t------ s ? 1 e n e r'-> LEAD SYS. MECH.Il & C ELECT. SYS. TEAM LD.SYS.TM. !l nrq TEAM F.E. SUPT. SUPT. PLANNER PROJ.ENOR. ) i i l Cyt$ ff 0.l,j& ~ < l', e SUPPORT OROUPS CRAFT
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SECTION 11.3 ~ PROGRAM PLANNING - PHASE 1 QUALITY VERIFICATION 0BJECTIVES: DEVELOP AND IMPLEMENT A QUALITY VERIFICATION PROGRAM FOR COMPLETED INSPECTIONS DESCRIPTION: REVIEW EXISTING INSPECTION PLANS (PQCI) AND REVISE AS NECESSARY WRITE NEW INSPECTION PLANS (PQCI) IF REQUIRED VALIDATE PAST COMPLETED INSPECTION e RESUL" EXPEC"ED: . ESTABLISH THE VALIDITY OF COMPLETED INSPECTIONS AND INSTALLATION QUALITY STATUS DOCUMENT AND CORRECT ANY NONCONFORMING CONDITIONS STATUS: PQCI REVISION TO DEVELOP VERIFI-DEVELOP DETAILED SUPPORT START OF CATION PROGRAM PLANS FOR'VERIFI-REINSPECTION CONCEPT CATION EFFORT 1 2/15/83' 2/28/83 2/22/83-t e
1 INSPECTION PLAN (POCI) REVIEW AND REVISION s.- EXISTING POCI'S REVIEWED AND REVISED, AS NECESSARY, BY MPQAD-QA NEW PQCI'S WILL BE WRITTEN IF REQUIRED PQCI'S MUST MEET 3ELEVANT CRITERIA INCLUDING: CONFIRM THAT ATTRIBUTES IMPORTANT TO SAFETY ARE INCLUDED ACCEPT / REJECT CRITERIA CLEARLY STATED INFORMATION NECESSARY FOR INSPECTION CONTAINED IN POCI INSPECTION POINTS CLEARLY NOTED . V r Iv.. (,,..... u. ir PROCEDURE FOR DOCUMENTATION UNDER REVIEW AND REVISION 3 INSPECTION PLANS REVIEWED BY PROJECT ENGINEERING AS AN OhERVIEW Al F"~ TO INSURE ALL TECHNICAL REQUIREMENTS INCLUDED REVISED /NEW PQCI PILOT '(ESTED BEFORE IMPLEMENTATION QC INSPECTORS RETRAINED.TO REVISED PQCI g '; ),_[. J L %,j +..y Ir.v h d *, ~ c-Is y e-d s'.!i , ' - ~w. ' * * "< j * ~' l f f.% $$**'A.0 a 'A Y "*' h 4 . l d4.r.e r.., a..,. d r T. -r,per e r s j j 3 =0 g
e VERIFICATION PROGRAM CONCEPTS' ESTABLISH THE VALIDITY OF PAST/ CLOSED INSPECTION .,o ~ IN' l5 > > REPORTS CONFIRM THE ACCEPTABLE CONDITION OF INSTALLED COM-PONENTS, SYSTEM AND STRUCTURES DOCUMENT AND CORRECT NONCONFORMING CONDITIONS SCOPE' 0F PROGRAM INCLUDES ALL COMPLETED INSPECTION REPORTS INSPECTION REPORTS CATEGORIZED BY PQCI VERIFY THE QUALITY OF COMPLETED HORK USING AN ACCEPTABLE SAMPLING PLAN WHERE APPROPRIATE VERIFICATION PLAN BASED UPON SPECIFIC INSPECTION REPORT POPULATIONS: ITEM ACCESSIBLE FOR REINSPECTION DOCUMENTATION ONLY IS AVAILABLE UNIQUE AREAS OF CONCERN ~ LOT SIZES NOT APPROPRIATE FOR STATISTICAL' SAMPLE CONTINUATION OF REINSPECTIONS ALREADY foshTTE6-- CABLE ROUTING AND IDENTIFICATION ~ HANGERS DETAILS OF PLAN STILL UNDER DEVELOPMENT 4 4
~ SECTION 4.5 QA/QC SYSTEMS COMPLETION PLANNING (PHASE 2) i OBJECTIVE: FORMALLY INTEGRATE INSPECTION PLANNING WITH CONSTRUCTION SEQUENCE VERIFY THAT PQCI'S ARE FULLY ACCEPTABLE FOR NEW INSPECTIONS DESCRIPTION: .' ESTABLISH AN IN PROCESS INSPECTION PROGRAM . CLEARLY DEFINE INSPECTION POINTS IN PQCI UTILIZE QUALITY REPRESENTATIVE ON SYSTEM COMPLETION TEAM . MPQAD-QA CONDUCT FINAL REVIEW OF PQCI ~ RESULT ~ EXPECTED: . TIMELY COMPLETION OF QC INSPECTIONS ON SYSTEM COMPLETION WORK . CLEAR AND DETAILED INSPECTION REQUIREMENTS . TIMELY DOCUMENTATION AND CORRECTION OF NONCONFORMANCES STATUS: l DEVELOP CONCEPTUAL DEVELOP PROCEDURES PROCEDURES FOR IN-FOR INTEGRATED IN-FINAL REVIEW OF TEGRATED INSPEC-SPECTION WITH PILOT PQCI TION TEAM 2/22/83 4 5 m eme.
CONCEPTS 0F IN PROCESS INSPECTION PROGRAM ~ MPQAD-QA ISSUES FINAL PQCI WITH IDENTIFIED INSPECTION POINTS INSPECTION POINTS INTEGRATED INTO CONSTRUCTION SCHEDULE QUALITY REPRESENTATIVE ON SYSTEM COMPLETION TEAM RESPONSIBLE FOR OVERALL QUALITY: INSURE THE TEAM PROPERLY PLANS FOR INSPECTION INSURE PROPER PQCI'S IDENTIFIED FOR TEAM INSURE AVAILABILITY OF QUALIFIED INSPECT 0as INSURE NONCONFORMANCES. REPORTED TO MPQAD-QA FOR TIMELY DISPOSITION AND ANALYSIS INSURE QC INSPECTIONS PERFORMED ON TIMELY BASIS INSURE THAT NEW WORK DOES NOT OBSCURE NONCONFORMANCES PROCEDURES TO BE DEVELOPED BY PILOT TEAM e e 4 e te - O e 6 e4 1 r--
a " ^ l SIGNIFICANT INSPECTION PROCESS IMPROVEMENTS , IMPROVED QUALITY CONTROL INSPECTIONS AND INSPECTION REPORTS REVIEWED AND MODIFIED TO: . MINIMIZE INSPEC' TOR INTERPRETATIONS BY IDENTIFYING SPECIFIC ACCEPT / REJECT CRITERIhINSELFCONTAINEDPQCI ., INSURE CLARITY AND EFFECTIVENESS OF PQCI BY i PILOT TESTS INSURE ALL INSPECTION ATTRIBUTES AND ACCEPTANCE CRITERIA ARE INCLUDED BY MPQAD-QA PREPARATION AND PROJECT ENGINEERING OVERVIEW ABSOLUTE AND TIMELY REPORTING OF NONCONFORMANCES PROCEDURES REVISED TO: . REQUIRE ALL NONCONFORMANCES ARE IDENTIFIED AND RECORDED FOR ANALYSIS AND DISPOSITION IMPROVE TREND'ING AND IDENTIFICATION OF PROCESS DEFICIENCIE'S FOR TIMELY MANAGEMENT ACTION . ELIMINATE,DUPLICATIVE.NONCOMFORMANCE REPORTING SYSTEMS -QUALITY REPRESENTATIVE ON SYSTEM COMPLETION TEAM REPRESENTS MPQAD-QA/QC INTEGRATED CONSTRUCTION / INSPECTION PROCESS IMPROVED INTEGRITY AND TIMELINESS OF INSPECTIONS BY: . USE OF DEFINED HOLD POINTS FOR INSPECTION IN CONSTRUCTION SEQbENCES .. FORMAL DOCUMENTATION-OF ALL OBSERVED NONCONFORMANCES ^ AT ALL INSPECTIDN POINTS ~~ e m -w M----
SIGNIFICANTINSPECil0NPROCESSIMPROVEMENTS (CONT'D) DEDICATED QUALITY REPRESENTATIVE FOR SYSTEMS AS MEMBER OF TEAM, INTEGRATED PLANNING FOR INSPECTIONS BY TEAM INTEGRATED QUALITY ' PROCEDURES DUE TO QA/QC INTEGRATION . ELIMINATION OF REDUNDANT OR DUPLICATIVE PROCEDURES . FOCUS ON SINGLE MISSION FOR QUALITY ORGANIZATIONS . ELIMINATION OF POTENTIAL INSPECTOR MISINTERPRETATION 9 4 e e F A e t. e g
SECTION 5.0 PROGRAM IMPLEMENTATION OBJECTIVE: . PROVIDE A PROCESS FOR CONTROL, REVIF.W AND APPROVAL OF EACH MAJOR TASK ~ AS THE PROGRAM PROCEEDS. DESCRIPTION: . ESTABLISH COMPLETION AND QUALITY STATUS . INTEGRATE CONSTRUCTION AND AllALITY ACTIVITIES .lMPROVE ON-GOING QtlALITY PERFORMANCE P RESULT . COMPLETE SYSTEMS FOR TURNOVER TO CPCO TESTING EXPECTEI) . PROVIDE CONTINUING DEMONSTRATION OF QUALITY AS WORK PROCEEDS .PROVInE VERIFICATION OF OllALITY IN COMPLETED WORK 1 Mgt Review Commence Mgt Commence of Reinspection Review Completion Verification of Plan Results Mgt Review Commence ) of Status i Status Plan Assessment
SECTION 6.0 QUALITY PROGRAM REVIEW OBJECTIVE: REVIEW THE ADEQUACY AND. COMPLETENESS OF THE QUALITY PROGRAM AND MAKE REVISIONS AS NECESSARY: ON AN ONGOING BASIS FOR GENERAL IMPROVEMENTS IN RESPONSE TO SPECIFIC CONCERNS (D/G INSPECTION) IN RESPONSE TO THIRD PARTY REVIEWS e DESCRIPTIONS: -. REVIEW SPECIFIC PROCEDURES FOR COMPLIANCE TO PROGRAM REVIEW REVIEW ACTUAL IMPLEMENTATION OF PRui.EDllRES COORDINATE REVIEWS WITH OTHER PROJECT AREAS PROVIDE. INPUT AND RECOMMENDATION TO MA'NAGEMENT l - RESilLT EXPECTED: . CONTINUED OVERALL IMPROVEMENT IN THE QUALITY PROGRAM CONTENT AND ' IMPLEMENTATION STATUS: ONGOING COMPLETE PRE-SENT SPECIFIC REVIEWS EFFORTS i e i )
CURRENT SPECIFIC PROGRAMMATIC REVIEWS EFFORTS PRESENTLY UNDERWAY TO REVIEW PROGRAMMATIC REQUIREMENTS AND IMPLEMENTATION FOR: MATERIAL TRACEABILITY: . REVIEW OF ALL PROJECT COMMITMENTS . REVIEW OF IMPLEMENTING PROCEDURES . REVIEW OF PRIOR AUDITS . REVISION OF RECEIPT INSPECTION PQCI Q-SYSTEM RELATED REQUIREMENTS VERIFICATION OF PROJECT COMMITMENTS BY ENGINEERING -AND LICENSING DESIGN _ DOCUMENT CONTROL . FLOW CHART OF EXISTING PROCEDURES . CHECK OF ACTUAL IMPLEMENTATION . COMPARISON WITH PROGRAMMATIC REQUIREMENTS RECEIPT INSPECTIOK . REVIEW OF SOURCE INSPECTION / RECEIPT INSPECTION SYSTEMS ~ ~ . PQCI REVISED- . RECERTIFICATION OF INSPECTORS . CONSIDERATION OF SELECTED OVERINSPECTION se 9 4 09. e a
i SECTION 8,0 SYSTEM LAYUP OBJECTIVE: PROVIDE ADEQUATE PROTECTION FOR PLANT SYSTEMS AND COMPONENTS UNTIL PLANT STARTUP DESCRIPTION: . IDENTIFY AND PROTECT SYSTEMS WETTED DUE TO HYDRO TESTING OR FLUSHING . PROVIDE SCHEDULES FOR WALKDOWN TO ENSURE CLEANLINESS AND ADEQUATE PREVENTIVE MAINTENANCE . CARRY OUT WALKDOWNS TO ENSURE COMPLETENESS OF SYSTEM LAYUP ACTIVITIES RESilLTS IMMEDIATE PROTECTION OF WETTED SYSTEMS EXPECTED: PROVIDE CONTINUED CARE FOR ALL COMPONENTS UNTIL SYSTEM TURNOVER STATUS: COMPLETE LAYUP OF ALL WETTED SYSTEMS 1/15/83 ISSUED SCHEDULES FOR WALKDOWNS 1/15/83
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SECTION 9.0 CONTINUING WORK ACTIVITIES DBJECTIVES: . MEET PREVIOUS NRC REQUIREMENTS AND CONTINUE WITH ACTIVITIES WHICH DO NOT IMPEDE THE EXECIITION OF THE PROGRAM . PROVIDE DESIGN SUPPORT FOR ORDERLY SYSTEM COMPLETION WORK.AND RESOLUTION OF IDENTIFIED ISSUES 3 . ESTABLISH A MANAGEMENT CONTROL TO INITIATE ADDITIONAL SPECIFIED WORK THAT CAN PROCEED OUTSIDE OF THE SYSTEMS COMPLETION ACTIVITIES 4 m
SECTION 9.0 CONTINUING WORK ACTIVITIES DESCRIPTION: THOSE ACTIVITIES THAT HAVE. DEMONSTRATED EFFECTIVENESS IN THE QUALITY PROGRAM IMPLEMENTATION WILL CONTINilE DilRING IMPLEMENTATION OF THE CONSTRilCTION COMPLETION PROGRAM. THESE ARE: 1. NSSS INSTALLATION OF SYSTEMS AND COMPONENTS BEING CARRIED OUT BY B8W CONSTRUCTION COMPANY 2. HVAC INSTALLATION WORK BEING PERFORMED BY ZACK COMPANY. WELDING ACTIVITIES CURRENTLY ON HOLD WILL BE RESUMED AS THE IDENTIFIED PROBLEMS ARE RESOLVED 3. POSi SYSTEM TURNOVER WORK, WHICH IS IINDER THE DIRECT CONTROL OF CONSUMERS POWER COMPANY, WILL BE RELEASED AS APPROPRI ATE IISING ESTARLISHED WORK AllTHORIZAT'ON PROCEDtlRES 4 HANGER AND CABLE RE-INSPECTIONS, WHICH WILL PROCEED ACCORDING TO SEPARATELY ESTABLISHED COMMITMENTS TO NRC 5. REMEDIAL SOILS WORK WHICH IS PROCEEDING AS AUTHORIZED BY THE NRC 6. DESIGN ENGINEERING WILL CONTINilE AS WILL ENGINEERING l SUPPORT OF OTHER PROJECT ACTIVITIES
P SECTION 9.0 CONTINUING WORK ACTIVITIES STATUS: .THESE ACTIVITIES ARE PROCEEDING WITH SCHEDULES THAT ARE INDEPENDENT OF THIS PLAN. l n .}}