ML19326D194

Responds to Questions Raised by Aslab in ALAB-152 Per 731031 Discussions.Discusses Bechtel Field QC Personnel & Project Superintendent Relationship

ML19326D194
Person / Time
Site:	Midland
Issue date:	11/09/1973
From:	Kessler W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Mackay S US ATOMIC ENERGY COMMISSION (AEC)
References
620, NUDOCS 8006090618
Download: ML19326D194 (8)

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.:IDL;J:D PLA:;T /d st-Proceedings Pursuant to ALA3-152 /J, g T'kh- Y,%'p A Docket :ios. 50-329 and 50-330 il*aif Od, *d,Ti,F g I File: 0505.2 Serial: 620 -

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Mr. S. D. ::acKay, Project :anager f?m *., . " /,.'?

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United States Atcaic Energy Conmissien Washington, D.C. 205h5 Dear Mr. 1-iacKa-'J Enclosed is Consumers Pcver Ccnpany's response to questions raised by the Appeals Board in ALA3-152, as discussed in our meeting with you on October 31, 1973, and also the vords which appear in the 3echtel Project Special Provisions :otice #3, Eev. 2, which is in existence en the I:idland Project. We believe the enclosed verds con-tained in Project Special Provisions !!otice #3, including the Revised Organizational Chart , vill eliminate the ccnfusion concerning the relationship between Bechtel's Field 0.uality Control personnel and the Project Superintendent which was created by an earlier Organiza-tional Chart.

You vill recall that in ALA3-106 the Appeal Board expressly stated:

". . . We have found nothing which would cause us to overturn the Licensing Board's findings as to the consistency of the CA program with the requirenents of Appendix 3. We have reviewed the CA r.anuals for both the applicant and its architect-engineer. Eoth of these manuals, as presently revised, appear to present a satisfactory overall progran to neet the quality assurance criteria in Appendix 3."

THIS DOCUMENT CONTAINS P00R QUAUTV PAGES 8006090 [/[

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Mr. S. D. MacKay

. 2 Docket Hos. 50-329 and 50-330 November 9, 1973 However, in' ALAE-lh7, the Appeal Eoard expressed concern that the-relationship between the Bechtel Field Cuality Control personnel and Project Superintendent night be in violation of Criteria 1 of Appencix E to 10 CFR Part 50. This concern was based upon a Eechtel organisation chart which attempted.to depict the entire Eechtel field organisation and used the phrase " functional supervision" to describe the relationship between the field quality control personnel and the Project Superintendent. The Appeal Eoard then expressly found, "We have found no other Q/A problea pertaining to Bechtel which requires a direction of corrective action. (Footnote 10, Page 16)."

Consuners Power Conpany filed its Petition for Reconsideration of ALAB-lh7 detailin6 the actual existing relationship between Bechtel's field Q/C forces and its Project Superintendent in written form rather than in chart form; recognizing the confusion created by the earlier chart to describe too =uch with a summary notation on that chart. In this regard, both Consumers Power Company and Eechtel recoenice that while the earlier chart attempted to place labels on the relationships

- between all of Eechtel's field forces , such a broad chart forced summary descriptions which eculd not adequately cescribe the very limited rela-tionship between Eechtel's field Q/C forces and its Project Superintendent.

The Appeal Board reviewed this longhand description of the Quality Control Organization at length in ALAE-152, and concluded:

"If all of these representations are well-founded, the actual relationship between the Project Superintendent and the Quality Control Engineers is , of course, quite different from that suggested by the Eechtel Organiza-tion Charts in our possession. The picture vhich the applicant paints is scarcely one which the term 'func-tional supervision' would readily bring to mind."

(pp. 13-14, ALAE-152).

The Appeal Ecard then requested the AIC Regulatory Staff to:

" . . . resolve the apparent conflict between what the Eechtel Organization Charts reflect and what the applicant avers are the real facts". I We wish to assure you that the actual existing relationship l

- between Eechtel's Field Q/C personnel and its Project Superintendent is

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!Ir. S. D. MacKay 3 Docket lios. 50-329 and 50-330 Ilovember 9, 1973 as described in the attached material, including the Revised Organiza--

tional Chart , and to e=phasize our firm belief that that organization and its inter-relationships are in "ull cenpliance with both the letter and spirit of Appendix B to 10 CFR Part 50 and the governing opinions of the Appeal Ecard.

Very truly yours, j,' _t- _-

W. E. essler Project Ennager WD:/jmb

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gegulatory Docket Re.

g f.g.1) n .;o4 3,w aid _.a MEMORANDU4 0F ASSURANCE OF COMPLIANCE BECHTEL'S FIELD QC ORGANIZATION WITH CRITERIA 1 APPENDIX 3 TO 10 CFR 50, AND ALAB 152 The following procedures for the Midland Project have been established as supplenentary requirements to the subject Field Inspection Manual Procedure G-1. (Project Special Provisions Notice SP/ PSP #3, REY. 2, 7220). These special provisions were initiated at Bechtel Construction Management's request, with full concurrence of Bechtel Project Management and Consumers Power Company.

The same special provisions shall also apply to each of the other procedures contained in the Field Inspection Manual wherever applicable.

1. FIELD SCOPE OF THE QUALITY CONTROL PROGPAM The requirements for construction quality control contained in the Field Inspection Manual and Quality Control Notices Manual shall be applied to all "Q" listed materials and equipment. Application of these requirements to other pemanent or temporary pl.mt :nterials and equipment shall be as directed by Bechtel Construction Man gement and Consumers Power Company.

2. DEFINITIONS OF PEPORTING P2SPONSIBILITIES

a. Project Coordination: Coordination of the interfacing activities of the Field Quality Control Organization with the activities of job site construction forces. Project Coordinatica does not give the Project Superintendent authority to (1) direct tha.t a quality control inspection be by-passed, or (2) proceed with construction beyond a particular control point unless the inspections called for at that point have been properly completed.

b. Functional Direction: The positive mandatory instructions and directions given to control a function or activity.

c. Functional and Administrative Direction: The positive mandatory instruct-ions and directions given to control a function or activity including responsibility for hiring, dismissal, training, assignment, performance review and salary.

3 ADMINISTRATION OF THE FIELD QUALITY CONTROL PROGRAM

a. The Chief Field Quality Control Engineer shall be responsible for the functional and Administrative direction of the Quality Control Engineers at the job-site. This responsibility shall be exercised through and upon the recommendations of the Ann Arbor Quality Control Supervisor and Project Field Quality Control Engineer, (see Figure 1).

b. The Chief Field Quality Control Engineer shall be responsible for perfomance evaluation and initiation of salary actions for the Ann Arbor Quality Control Supervisor and Project Field Quality Control Engineer.

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2 AININISTRATION OF THE FIELD QUALITY CONTBOL PROGRAM (Contd)

c. The Project Field Quality Control Engineer shall be responsible for performance evaluations and initiation of salary actions for the Quality Control Engineers at the jobsite. With respect to salary actions the project construction organization does no more than to assure that any salary increases recommended by the Project Field Quality Control Engineer are within the limits established by Bechtel's personnel policy for the various pay grades, and within goverrmental wage guidelines. Any conclusion by the project construction organization that a particular increase would not fall within such policy limits and guidelines requires the concurrence of the Chief Field Quality Control Engineer. With respect to salary actions, the project construction organization does no more than to assure that any salary increases recommended by the Project Field Quality Control Engineer are within the limits established by Bechtel's personnel policy for the various pay grades, and within governmental wage guidelines. Any conclusion by the project construction organization that a particular increase vould not fall within such a policy limit and guidelines requires the concurrence of the Chief Field Quality Control Engineer.

d. The Project Superintendent shall be responsible for coordination of the interfacing activities of the Field Quality Co'ntrol Organization with the activities of job site construction forces, (see Figure 1).

4 k. PROJECT FIELD QUALITY CONTROL ENGINEER'S STOP WORK AUTHORITY

a. The Project Field Quality Control Engineer is responsible for supervision 4

of the Construction Quality Control Program at the job site to assure that the work falling under the scope of the progran is properly inspected and documented. The Project Field Quality Control Engineer receives administrative and technical direction from the Chief Field Quality Control Engineer for the preparation of Field Inspection Plans. The Chief Field Quality Control Engineer provides this direction through Master Inspection Plans which are prepared by home office staff discipline Quality Control Engineers based on the progrsn criteria. The Project Field Quality Control Engineer has authority to stop work. This authority, communicated throgh the Project Superintendent, shall require immediate stoppage of work operations and other ccnstruction activities determined to be improperly controlled or otherwise in nonconformance with the quality require.sents of the applicable design specifications, drawinga and other program criteria. Similarly, the Project Field Quality Control Engineer has the authority to stop work if a designated quality control inspection, examination or test operation is bypassed to the point where the work is no longer capable of being properly inspected. Such stop work orders cannot be countermanded by the Project Superintendent,

b. The Project Field Quality Control Engineer has the same authority as stated in (a) above to stop the work of subcontractors.

c. The Project Field Quality Control Engineer shall be responsible for reviewing and approving field prepared requisitions for "Q" listed materials, services and equipment. He shall assure the requisitions

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3 PROJECT FIELD QUALITY CONTROL ENGINEER'S STOP WORK AUTHORITY (Contd) and resultant field purchase orders contain a Project Engineering specification governing applicable supplier QA requirements. The Project Field Quality Control Engineer has the authority to stop the placement of field purchase orders for "Q" list material, services and equipment if the procurement documents do not contain a Project Engineering prepared specification governing applicable supplier QA requirements.

5 INSPEcrION BY FIELD ENGINEERS AND QUALITY CONTROL ENGINEERS The Project Field Engineer shall be responsible for assi 6ning Field Engineers to perform in process , production control, inspection activities. The Project Field Quality Control Engineer shall be responsible for providing quality control surveillance over the inspections perfomed by Field Engineers as well as assigning Quality Control Engineers to perfom all quality verifi-cation inspections. In process , production control inspections and quality verification inspections shall be predeternined and identified on the Master Inspection Plans prepared by San Francisco home office staff Quality Control Engineers and approved by the Chief Field Quality Control Engineer. The Master Inspection Plans do not permit work which is required to be performed by Quality Control Engineers to be performed by Field Engineers.

6. SURVEILLANCE INSPECTION OVER WORK PERMRMED BY SUBCONTRACT 0PS

• It shall be the responsibility of the Project Field Quality Control Engineer to assure that the work performed by on site subcontractors is done in full compliance with their Bechtel approved Quality Assurance / Quality Control manuals and other quality requirements of the subcontract documents. This assurance shall be provided by means of surveillance inspection performed by subcontractors.

7 TESTING LABORATORIES AND INSPECTION SUBCONTRACT 0PS The Project Field Quality Control Engineer shall be responsible for assigning Field Quality Control Engineers to provide functional technical direction over the work performed by testing laboratories and inspection subcontractors, (see Figure 1).

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AEC F*TRIBUTION FOR PART 50 DOCKET F^: RIAL

, . (TDiPORARY FORM) CONTROL N0s_8241

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FILE: /." /

FRCH: DATE OF DOC DATE REC'D LTR MEMO RPT OTHER Consumers Power Company J ckson, Michigan 49201 11-9-73 11-13-73 X W. E. Kessler TO ORIG CC OTIER SENT AEC PDR X S. D. MacKay 1 signed SENT LOCAL PDR X-CLASS UNCLASS PROP INFO INPUT NO CYS REC'D NO:

XXX 1 _ 50-329 330 DESCRIPTION: ENCLOSURES:

Ltr re meeting 10-31-73.....trans the following Response to questions concerning Memorandiam of Assurance of Compliance ACKNOWLEDGZD PLANT NAME: Midland Unit 1 & 2 DO NOT REMOVE

( 1 cy rec'd )

FOR ACTION /INFORMATION 11-14-73 CC BUTLER (L) AC151ENCER(L) ZIDIANN(L) REGAN(E)

W/ Copies W/ 4 Copies W/ Copiea W/ Copies CLARK (L) STOLZ(L) DICKER (E) .

W/ Copies

• W/ Copies W/ Copies W/ Copies GOLLER(L) VASSALLO(L) KNIGHION(E)

W/ Copies W/ Copies W/ Copies W/ Copies KNIEL(L) SCHEMEL(L) YOUNGBLOOD(E)

W/ Copies W/ Copies W/ Copies W/ Copies ,

_ INTERNAL DISTRIBUTION W G FILE 3 TECH REVIEW DENTON A/T IND hAECPDR IfENDRIE GRIMES LIC ASST BRAI'DiAN OGC, ROOM P-506A SCHROEDER CAMMILL DIGGS (L) SALEMAN MUNTZING/ STAFF MACCARY KASTNER GEARIN (L) 3. HURT CASE KNIGHT BALLARD 40ULBOURNE (L) PLANS GIAMBUSSO PAWLICKI SPANGLER LEE (L) MCDONALD BOYD SHA0 MAIGRET (L) DUBE MOORE (L)(BWR) STELLO ENVIRO SERVICE (L)

DEYOUNG(L)(PWR) HOUSTON MULLER SHEPPARD (E) INFO SKOVHOLT (L) NOVAK DICKER SMITH (L) C. MILES P. COLLINS ROSS KNIGHTON TEETS (L)

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FILE & REGION (3) LONG PROJECT LDR WILSON (L)

MCP.T.IS LAINAS STEELE yENAROYA HARLESS WOLIMER e EXTERNAL DISTRIBUTION V./

/1 - LOCAL PDR Midland, Mich.

- DTIE(ABERNATHY) (1)(2)(10)-NATIONAL LAB'S 1-PDR-SAN /LA/NY

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