ML20091N305
| ML20091N305 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 07/12/1983 |
| From: | Baranow S STONE & WEBSTER, INC. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17198A223 | List:
|
| References | |
| CON-BOX-10, FOIA-84-96 NUDOCS 8406120272 | |
| Download: ML20091N305 (18) | |
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STONE & WEBSTER MICHIGAN, INC.
P.O. box 2325. BOSTON. M ASSACHUSETTS O2107 Mr. J. G. Keppler, Administrator, Region III July 12, 1983 Nuclear Regulatory Commission J.0. No. 14509 799 Roosevelt Road NRC File #83-07-12 Glen Ellyn, IL 60137 I
RE: DOCKET NO. 50-329/330 MIDLAND PLANT - UNITS 1 AND 2 OVERVIEW 0F THE CONSTRUCTION COMPLETION PROGRAM l
REPORT NO. 4 A copy of the Construction Implementation Overview Report No. 4 for the period June 27 through July 7,1983 is enclosed with this letter. Included are meetings attended and a status of the CIO program development.
If you have any question with respect to this report, please contact me at (517) 631-8650 extension 486.
Very truly yours, h= }A S.W. Baranow Program Manager Enclosure SW8/ka cc: JJHarrison, NRC Glen Ellyn RCook, NRC Midland (site) j DBMiller, CPCo Midland (site)
RBKelly, S&W 3
APAmaruso, S&W i
C0 Richardson, S&W i
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Report No. 4 June 27, 1983 through June 24, 1983 i
Personnel on Site Stone & Webster Michigan, Inc.
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S. Baranow W. Miller F. Bearham A. Smith R. Scallan J. Chawla
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J. Langston W. Sienkiewicz C. Larson (temporary) l Meetings _ Attended ___
Date Attendees Purpose June 28, 1983 Stone & Webster PQCI Status i
CPCo Bechtel i
Meetings i
, June 28, 1983 - Attended a meeting conducted by Bechtel for familiarization of the i
statusing and development of PQCI's. Those meetings are conducted on a daily basis between CPCo and Bechtel which provides for an up-to-date status of all PQCI's.
Activities
- 1) System Interaction Walkdown of the Auxiliary Building recomenced on July 7, 1983. The walkdown is being performed in accordance with WTP-3-Q, " Procedure for Performing Walkdowns of SSIP/S Targets."
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The CIO evaluation was perfomed utilizing attribute checklist MP-MIS-WTP-3-Q.
One interaction was analysed, documented and witnessed by CIO.
Action Items Responses to CIO questions and concerns were received on July 6, 1983 covering dates
,of correspondence of the following:
- 1) May 18, 1983 Management Review Comittee meeting of the Bulk Hanger Organization Five areas of CIO concerns have been satisfactorily responded to.CIO considers these items as closed
-2) June 3, 1983, Report #1 1
Item 8 "CIO concerns noted during reviews of PQCI's" j
" Method of Communication / Notification is under' consideration" Resolutions: -It was agreed to in a meeting, July 7, 1983,'with Mr.-M.P. Leonard, General Superintendent of. Quality Assurance, that CIO concerns would be discussed I
with Mr. G.E. Parker, Section Head Plant' Assurance Engineering.
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14509 MIDLAND PLANT - UNITd'1 AND 2 l
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OVERVIEW 0F THE CONSTRUCTION PROGRAM i
REPORT NO. 4 PAGE 2 l
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- 3) June 14, 1983 Report #2 Item (e) "Need to identify commitments made to NRC" l
Resolutions: CIO has received a partial listing of commitments on June 16, 1983.
j Subject still remains open.
I
- 4) June 17, 1983 (Letter)
Item 6 "CIO considers the list of commitments to the NRC a constraint to the QVP."
Resolutions: Pending receipt of a matrix, this item remains open.
Item (c) "The 14 required to resolve Management Review Team Observations should be approved and issued."
3 Resolutions: The 14 observations classified as constraints have been resolved through the issuance of approved "N" procedures dated June 20, 1983.
- 5) June 28, 1983, Report #3 Item 2 "CIO concerns in the conduct of training of Supervisory personnel."
4 Resolutions: The response by CPCo is under review and will be addressed in our next report.
l Action Items
- 1) "CPCo response to items requiring resolutions:
1 Resoluticns: Response B. M. Palmer to R. A. Wells memorandum (Serial 22897A) dated June 14, 1983 is under review and will be addressed in our next report.
- 2) "Are job descriptions and responsibilities of CPCo personnel engaged to implement the QVP available?"
Resolutions: Job descriptions and responsibilities have been received by CIO and are under review.
- 3) "Has a program been developed and responsibilities established of personnel assigned to process nonconfomances?"
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Resolutions: CIO understands that the program is in the development state
, remains as open.
Status of CIO Program Development
- 1) Project Quality Assurance Plan - issued June 16, 1983.
NOTE
.In our report #83-06-16 dated June 16, 1983, for Item N' 1, the date should read June 13, 1983.
- 2) S&W QCI 15.01.Nonconformance Identification and Reporting Rev. O, June 14, 1983 -
issued June 14, 1983.
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14509 MIDCAND PLANT - UNITS 1 and 2 OVERVIEW 0F THII CONSTRUCTION PROGRAM 1
l REPORT NO. 4 PAGE 3 l
- 3) S&W QCI 10.1 Construction Implementation Overview Assessment, Rev.1, June 27, 1983 - issued June 28, 1983
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- 4) Third Party Construction Implementation OverviewRev.1 - to be issued week of July 11, 1983
. t,5) Of a total of 96 PQCI's scheduled for issue by MPQAD for CIO review, 65
}d have been submitted for review and checklist development Li
' 6) To-date a total of 79 change notices and 29 revisions to the PQCI's has been received by the CIO
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- 7) Checklist development status a) first draft -52 t
i b) review and approval - 38 j
c) typing completed - 27 d) approved for issue -11
- 8) MP-MIS Activity Checklists (i.e. Interaction Walkdown, Training, j
Management Evaluation etc.)
a) first draft - 11 b) review and approval - 6 I
c) typing completed - 4 d) approved for issue - 3 i
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Sf 4) cto CORSum8FS POW 8r sm u Company I
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Mnciend Project: PC som 1963, Midland. MI 4464o e (517) 631-866o i
July 1, 1983 PR lHC I PA L S Tn.= =,
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Mr. Stanley Baranow ORMA l H.3 i
Stone & Webster CR;,is:1 l
7 Midland Nuclear Cogeneration Plant DE l
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P.O. Box 1963 ML i
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Midland, MI 48640 OL l
F iggy MIDLAND ENERGY CENTER STONE & WEBSTER CORRESPONDENCE File: 0655 Bl.l.4 UFI: 99*08, 08*06*04*03 Serial: CSM-0656 Please find attached our response to questions raised in your memorandums to J. G. Keppler.
This response covers memorandums issued from May 19, 1983 through June 28, 1983.
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J. J. Harrison R. J. Cook R. A. Wells R. B. Kelly A. Pamaruso i
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SUMMARY
OF RESPONSE TO S&W CIO REPORTS I.
May 19,31983 (S&Wel) l
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No items requiring response II.
No date (S&W#2) - May Management Committee Review (May 18, 1983)
Response contained in Attachment I III. June 3, 1983 (S&W#3) - Report #1 (5) Program requires revision to address how trainers are trained.
Response
FPG-2.000, Paragraph 7.3 defines how trainers will be trained.
(8) Need a method for SWEC to communicate concerns found during PQCI review.
Response
A satisfactory method for communication on PQCI reviews has been established and will be defined in a S&W memorandum; IV.
June 14, 1983 (S&W44) - Report #2 The response to items (a) through (d) are provided in Attachment 2; (e) Need to identify commitmants made to NRC; Response: A project has been started in the Site Management Office (SMO) to collect all of the CCP commitments made to the NRC and to track them to the imclementing mechanism.
Page 3 CIO's review of System Interaction Program Response: Committed to CIO not to start program until SWEC had completed j
their review and the NRC had been briefed on the program. CPCo
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(Jackson) met with NRC and was given permission'to start.
I notified SWEC that on Monday, June 22, we would begin. CIO l
stated that they would be ready to support that effort.
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f V.
June 15, 1983 (S&W45) - organizational Chart i
No' response required.
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June 16,1983 (S&W#6) - SWEC D'oeument Transmittal t'
No response required.
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'.Page 2 Summary of Response to S&W CIO Reports VII. Jur.e 17, 1983 (S&W#7) - Spatial Svsstems Interaction Program f
No response required.
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VIII. June 17, 1983 (S&Wf8) - June 1, 1983 Mgt Committee Review Item 6 - SWEC considers the list of commitme.nts to the NRC a constraint to QVP.
-The list is in development.
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-The Management Review Committee must take action relative to i
R A Wells memo dated June 7, 1983 (Serial 22848).
(Attachment to i
S&Wi8).
Conditions on QVP Acceptance 1
(a) and (c) - Response provided in Attachment 3 i
l (b) - List of commitments to NRC are being developed.
IX.
June 28,1983 (S&W#9) - Overview of the Construction Completion Program No response required.
4 2.
' June 28,1983 (S&W410) - Overview of the Construction Completion Program - Report #3 Response to Activities item #2 The CIO evaluated and commented on s training session given to personnel of the Bulk Harger Organization. A concern was expressed that evaluation sheets, filled out by approximately one-half of the class attendees, were unsigned and hence "does not provide objective evidence of who correctly or incorrectly answered the questions on the evaluation sheets."
The concern expressed by the CIO appears.co-stem from a misunderstanding of the training evaluation program as outlined in G-4.00 (Training Evaluation Team Organization and Responsibility). The objective evidence that individuals
-are qualified and have received adequate training is provided by their perfor-
.mance on the job. The individual's supervisor monitors his performance.
The training session evaluation observed by the CIO has a different' purpose which is covered.in G-4.00.
Each lesson plan includes an effectiveness measurement strategy which is designed to demonstrate that the student can master the lesson objectives for the material presented.
In many cases the effectiveness measure-ment used will be a written exam which is administered to a minimum percentage of the class as specified in G-4.00.
since the results of.the exac are used to
~ define modifications to the lesson plan acJ/or the instructor presentation, i
identification of the evaluation form to specific students is not needed.
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l The initial experience with this approach indicates that it is working to provide.
effective classroom instruction and student mastery of the lesson objectives.
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^Page 3 Summary.of Response'to S&W CIO Reports In summary, the purpose of the training session evaluation is to verify i
that the classrocm instruction has been effective in presenting the stated I
lesson objectives. If the students sampled can pass the effectiveness measurement instrument, it is taken that the lesson objectives have been met.
The ultimate test is the responsibility of the supervisor in monitoring
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individual on-the-job performance.
Response to Action Items 6
- 1) This item is closed with the response contained in Attachment #2
- 2) Job descriptions of QVP supervisory personnel are provided in Attachment #3
- 3) Will be responded to later.
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ATTACHMENT #1 4
i RESPONSE TO CIO LETTER #2 i
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After reviewing your overview observations on the Management Review of the Bulk Hanger Teams, the following is our response to your questions:
I.
Stone & Webster Question:
Subtitle and Objectives of the CCP-Two objectives are stated:
(A) to improve information status (B) to improve implementation of the QA Program These objectives are considered auditable by CIO and more details should be available. Details should include references to appropriate polic; statements, procedures, responsible personnel and orientation sessions.
CPCo Responso 1.
Response to "A" a.
Freparing an accurate list of to go work against a defined baseline.
This accurate list of to go work will be defined against the baseline established during the status assessment (Phase I) work activity. This list will be prepared in accordance with the following procedures and instructions:
FPM 9.200 - Bulk Hanger Organization Hanger Walkdown FPG 9.800 - Bulk Hanger Organization Charter FIG 7.500 - Area Release for Construction FPC 9.900 - Construction Punchlist i
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' Stone & Webster June 24, 1983 b.
Bring inspections up to date and verify that pasc quality
. l issues:have been or are being brought to resolution.
Completed hangers will be handled through the Hanger Rein-spection Program (P.2.30).
All other inspections will be brought up to date and the validity of past quality issues will be handled under the Quality Verification Program (QVP).
I 5-For instru'etion and reference please see i
1.
PQCI P-2.30 - Reinspection of Pipe Supports 2
j-i 2.
Quality Verification program, Midland Nuclear Cogeneration Plant Units 1&2
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Maintain a current status of work and quality inspections as the project proceeds.
i The current status of work and quality inspections will be maintained using the following ptocedurest FPM 9.200 - Bulk Hanger Organization Hanger Walkdown FPG 9.800 - Bulk Hanger Organization Charter i
FPG 9.900 - Construction Punchlist i
l 2.
Response to "B" i
l a.
Expanding and consolidating CPCo control of the quality function l
Consumers Power Company's Midland Project Quality Assurance Department-(MPQAD) was expanded to assume direct control of l
l site project quality functions including Engineer / Constructor QC 1
except ASME. Features of the new organization are described in Section 3.0 of Revision 1 of the Construction Completion Program 4
(CCF)' dated June 10, 1983. The organization has been described in the Consumers Power Company Topical Report (CPC-1A), the:
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'FSAR, appropriate quality program manuals (Volume II, BQAM i
'and NQAM) and MPQAD Procedure A-lM.
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.b.
Improving the primary inspection process.
MPQAD has initiated a program for retraining and recertifying all. Quality control Engineers (Inspectors) and for reviewing and, as necessary, revising all. Project Quality Control Instructions (PQCIs). The details of this program are also contained in Section 3.0 of the CCP.
MPQAD Procedure B-3M-1 describes training and certification of QCEs.
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MPQAD Procedure E-3M describes preparation and approval of PQCIs.
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- Page 3 Stone & Webster Jane 24, 1983 Providing a uniform understanding of the quality requirements c.
among all parties j
As a part of the PQCI revision process, project Engineering does f
a review of PQCIs partly to ensure that the PQC[ is consistent with specification requirements and that clarifications are made I
to specifications as necessary.
The Team drganization defines a relationship between the con-struction and quality organizations that will enhance a uniform j
understanding of quality requirements (See Team Charter, FPG 9.800 and MPQAD Procedure on Team Quality Representative - Tl)
Training is provided to the construction organization to improve understanding of the design requirements for construccian.
Strict adherence to design requirements is necessary to ensure quality in construction.'
(See subjects of Training Matrices)
I II.
Stone & Webster Ouestion Subtitle - Status of BHO Pilot Team This subtitle states that all procedures required for status assess-ment are approved. CIO considers this statement auditable and an index of these procedures should be available.
Additionally, this subtitl2 states that the preliminary hanger walk-downs results are available. ClO tequests as opportunity to review l
these results.
CPCo Response t
j The procedures, specifications and drawings required for status assessment were included in the handout distributed prior to ths Hanger Tecm Management Review Meeting. This document is a living list subject r.o change due to revisions in specifications, work scope and/or unforeseen items. The CIO l
will be kept informed periodically as modifications are made to the listing.
l The preliminary walkdown list is maintained by the Bulk Hanger group. It
.is available any time you would like to review it.
Please contact T A Spelman if you need any assistance.
l III.
Stone & Webster Qu'estion:
Subtitle - Hanger Team Engineers Additional information is required regarding NCRs - Trend analysis and prevention of recurrence.
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'.Page 4 Stone 7 Webster June 24, 1983 III.
(Contd) l 4
CPCo Response 4
1 All NCRs that are issued during Phase II work will be brought to the cognizant Team Supervisor *s attention by the respective team quality representative. The NCR will be evaluated and the appropriate action will be taken down to and including the craft. level to avoid recurring situations by the ' Team Supervisor or one of his leads. For those items not falling under the Team Supervisor's direct control, appropriate action will be taken by the proper discipline staff group.
t IV.
Stone & Webster Question:
i Subtitle - Hanger Team Quality Representative f
Clarification on non-Q interfaces is required. Where a "Q" support i
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has non-Q elements, to what level is the interface inspected?
CPCe Response It is Bechtel's practice to prohibit connection of "Q" pipe hangers to non-Q structural steel or walls. This is encompassed by FSAR Appendix 3A response to Regulation Guideline 1.29; FSAR Section 3.2 and referenced in the first paragraph of the "Q"-list.
The civil structural drawings clearly indicate what Structures tre "Q" by j
a ider tification on the design drawings, a
Bechtel does allow the installation of non-Q supports attached to "Q" supports. The non-Q support is shown in phanten on the "Q" support drawf gs.
V.
Stone (4 Webster Question:
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l Subtitle - Procedures / Inspections This subtitle states that 23 procedures, 19 specifications.and 8 drawings 1
are required for status assessment. CIO requests objective evidence that j
MPQAD, Bechtel and CPCo Construction agree that this listing is complete.
CPCo Response The procedures, specifications and drawings listed for status assessment were compiled and reviewed by the Bulk Hanger System Tesa Superintendent, Lead Field Engineer, CPCo Construction Enginter, Team Quality Representative-l and Team Field Engineers. Thhis list was then cross checked by Bechtel 3
staff engineering.
It must be emphasized that these lists are living documents that will. change as design or field conditions dictate. Attached g
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is the Hanger Team Training Matrix. This encompasses training requirements -
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for both. status assessment.and construction.
It is approved and signed by
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the Bechtel Project Field Engineer, Bechtel Field Construction Manager and
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- does review the list through the Team Quality Representative but does b
l not sign off on the Training Matrix.
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CONSUMERS POL CCe.
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87th4 JUN 2 41983 2
i Fm BMPalmer ggg out June 21, 1983 f0WK-l Midland rroject i C0mp3Ry "-~~ --
l susacet MIDLAND ENERGY CENTER PROJECT -
t CIO REPORT #2, DATED JUNE 14, 1983 bgZ,_
FILE 23.0 SER 22897A ce..nme r S""
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At your. request, I as providing you with a status update for items "a" through "e" in the " Meetings" section of the referenced report.
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K) Adequacy of drawings (A8) - large bore pipe hangers.
The configuration of some hangers is governed by redline drawings.
These redlines are issued and controlled by Bechtel document control.
Furthermore, Bechtel is currently in the process of incorporating redlines into upgraded revisions of the drawings. Discussions with inspectors involved in hanger reinspections indicate that the redlines are clear, legible, and sopropriate for inspections. Based upon the above, we consider that the control and "inspectability" of these
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drawings i.s acceptable. This iten is therefore censidered to be closed.
b) Additional verification of ecuipment received and installed (E2).
As you know, the QVP ccmmits only to verification of closed receipt i
inspecticn II.s.
In addition to this QVP related activity, it has beca proposed to initiate a separate prcgram with regard to vendor furnished equiptent in general. We are currently arranging, for f
PAB mana6;ement approval, a presentation in this regard. This effort would be outside the ecope of the QVP, and would not be a restraint i
to the QVP. For these reasons, this item is considered to be closed with regard to implementation of the QVP.
c) Material traceability of installed hangers (E3).
A report concerning material traceability is due by the end of this week'.
Note that the traceability issue was specifically identified in previous Manage =ent Review Meeting minutes as not being a restraint for QVP i=plementation.
-d3 Discussion of-nonconforming items with Project Engineering.
This item referred specifically to certain engineering reviews which j
would have bsen invoked by the sampling plan. Since sampling will no longer be in effect for QVP implecentation, this item is not applicable l
l to the QVP. With regard to processing NCRs, the existing mechanism (MPQAD procedure F-2M and PSP G-3.2) will be used. For these reasons, this item is considered to be closed.
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e e) Identification of QVP related commitments.
Co=mitments made by Consumers Power management to the NRC have been compiled and tracked to the implementing mechanism. Because this has been completed, this item is censidered to be closed.
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MIDLAND ENERGY CENTER PROJECT -
QVP MANAGEMENT REVIEW: CIO OPEN ITEMS inven %
CoaatsPoaot=ct FILE 23.0 SERIAL 22910 j
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References:
A) SWBaranow (S & W) letter to JGKeppler (NRC), dated 6/17/83, Management Committee Review 1
B) CPCo Serial 22834 dated 6/3/83 - Midland Energy Center
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Project - Quality Verification Program Management Review C) CPCo Serial 22848 dated 6/7/83 - Midland Energy Center Project - QVP Management Review Open Items Reference A provides a list of three actions required for CIO approval of the QVF. Below is an update on the status of these items.
a) Job descriptions for MPQAD pet sennel assigned QVP duties.
Attacnmencs 1 - 4 identify job positions and duties as they appear in current revisions of site procedures. In addition, as you know, the Administration and Training section is working on an effort to produce specific, j
detailed job descriptions fer MPQAD positions. I un:'er-stand that this effort is scheduled for completion sometime next voek.
b) Matrix of QVP NRC commitments The Vocification group has completed its. commitment list 4
with regard to those CPCo letters up to and including the l
June 10th letter. As you realize, however, this list will
. l never be " complete" until after the last commitment has been made.
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c) Management Review Team observations The fourteen GSlade team observations considered restraints, which were originally noted in references B and C, have been resolved. Attachment 5 provides an update of the original l
punchlist from reference B.
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CONSUMERS MIDLAND PROJECT 20WER-QUALITY ASSDRANCE PROC NO A-AM COMPANT DEPARTMENT PROCEDURE PAGE 4 of 10 REVISION 7 4
ORGANIZATION 4
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5.3.8 Coordinating with the Section Head Administration and j
Training for training and certification of QC personnel;- 1
.I 5.3.9 Submitting Quality Verification records for turnover; I
l 5.3.10 Ensuring implementation of the Quality Control program; 5.3.11 Reviewing QC generated nonconformance reports for poten-I tial reportability; i
5.3.12 Approving QC personnel assigned to the group i
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Additional organizational description of the Quality Control (BOP) j Or at de ed in th C Notices Manual.
5.4 General Superintendent Quality Assurance And Organizational Responsibilities
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.-The General Superintendent Quality Assurance reports.tocthe f
Executive' Manager,' MPQ'AD and ia responsible with regard tof
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Balance of' Plant and' HVAC'activi~ ties forf j
5.4.1 Sapervising the Electrical - IC and the Structural -
Mechanical Section; directing the Assistant Superinten-i l
._ dent BOP for the supervisien of Turnover & Test Support l
Secticn, QA Technical Services Organization:and the
. Qual ty Verification Group; directing the Assistant Superintendent HVAC for the supervision of HVAC QA Engineering Section, HVAC IE&TV Section and HVAC QA Administration Group.
i 5.4.2 Providing the primary Quality Assurance interface with i
other CP Co departments and contractor organizations l
1 located at the site for other than Soils related activi-ties; 5.4.3 Coordinating activities in support of NRC site inspec-tions of BOP and HVAC related activities; I
5.4.4 1reparing responses to NRC site inspection reports on BOP and HVAC related activities; l
5.4.5 Provading the preparation, review,-approval and issuance i
j of all BOP and HVAC inspection plans; i
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CONSUMERS MIDLAND' PROJECT QUALITY ASSURANCE PROC NO A-lM
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COMPANY DEPARTMENT PROCEDURE PAGE 7 of 10 REVISION 7 ORGANIZATION
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a.
Functional system turnover; I
b.
Records turnover; i
c.
Area turnover; i
d.
Preoperational testing; e.
Review of procedures relative to turnover and pre-operational testing.
I 5.4.14 Monitoring all activities concerning turnover.
5.4.15 Acquiring the required support from other CPCo organiza-tiens to meet the MPQAD commitments for timely implemen-l tation of all MP,QAD activities concerning turnover and preoperational tests.
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5.4.16 Threushout all activities:
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Assuring the maintenance and reporting of hardware design' quality and corrective action staths; b.
Evaluating the implementation of ths Quality Assur-ance Program and recormending improvements; i
c.
Reviewing and concurring (cr approving) cf other Midland procedures which are qualicy related; sistant Supe.nten a wr7 The Assistant Superintendent QA (BOP) assists the General Superin-tendent in the supervision and implementation of those activities i
applicable to Balance Of Plant as assigned by the General Superin-l tendent. The Assistant Superintendent manages the Turnover and Test Support Section, the QA Technical Services, and the Quality i
Verification Group.
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5.6 Assistant Superintendent QA (HVAC)
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l The Assistant Superintendent QA (HVAC) assists the General Super-intendent QA in the supervision and i=plementation of those activities applicable to Heating Ventilation and Air Conditioning s
System.
The Assistant Superintendent manages the HVAC Quality i
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Engineering Services Section, HVAC IE&TV Section and the Admini-j j
stration Group Supervisor.
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CONSUMERS MIDfAND PROJECT ATTACHMENT 7.1 O
QUALITY ASSURANCE PROC NO A-lM POk~r.R COMPANY.
DEPARTMENT PROCEDURE PAGE 10 of 10 REVISION 7 ORGANIZATION ggMOW l Cohl Y i
j ORGANIZATION CHARI t,
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