ML20028E373

Forwards Const Completion Program Requested at 821202 Meeting.Util Prepared to Support Public Meeting Proposed for 830126 in Midland,Mi

ML20028E373
Person / Time
Site:	Midland
Issue date:	01/10/1983
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20028E372	List: ML20028E373
References
NUDOCS 8301210272
Download: ML20028E373 (24)

Text

• *

, e i

Consumers Power James W Cook O&f Vice President - Projects, Engineering and Construction General offices: 1945 West Parnell Road, Jackson, MI 49101 * (517) 788 o453 January 10, 1983

_ PR,IM yIPA' SIAN n

'L_i n /;3 !

_. K. .

i ~]/ ' e i

~ Ntf_.-.

1 --

Mr J G Keppler, Administrator, Region III {. . . , _._

Nuclear Regulatory Commission i ~"

i __

799 Roosevelt Road Gle n Ellyn, IL 60137 l 14 .p s_ i .tM i

- '~

gd I MIDLAND NUCLEAR C0 GENERATION PLANT I-- --

MIDLAND DOCKET NOS 50-329, 50-330 CONSTRUCTION COMPLETION PROGRAM FILE 0655 SERIAL 20428 REFERENCE LETTER TO J W COOK, DATED DECEMBER 30, 1982, FROM NRC REGION III REGARDING CONSTRUCTION COMPLETION PROGRAM On December 2, 1982, Consumers Power Company met with Mr Warnick and other members of your staff to discuss the general concept of our proposed Construction Completion Program. The enclosure to this letter documents in detail the Construction Completion Program, as requested at the meeting and in your follow up letter (Reference).

Since our meeting, the program has undergone considcrable development and evolution. Details have been supplied and more specific objectives and implementing methods have been established. Further o

• ails are still being developed. While the Company expects the Program, as presently constituted, to be a workable and sufficient framework for future action, revisions may be necessary as future needs and experience dictate.

The Construction Completion Program is a positive step in the overall advancement of Project goals. It represents the best efforts of Project management, support and quality assurance personnel. We believe it will produce an improvement in Project installation and inspection status, systems construction and QA implementation. The quality verification effort should provide increased confidence of the NRC that the plant has been properly built. Other aspects of the Program, including the measure to improve ongoing inspections and scheduling interfaces, should contribute to that result. This Program, together with recent Consumers Power Company commitments regarding quality assurance and remedial soils work, can establish a basis for improved relations between the Company and the NRC Region group assigned to inspect Midland. The Construction Completion Program demonstrates the Company's responsiveness to both NRC concerns and the particular needs of this Project.

It is our expectation that the Program, created out of a desire to enhance the oc0183-0308a100 8301210272 830117 PDR ADOCK 05000329 #N11 %0 A PDR

2 orderliness and quality of construction, will achieve its intended purpose and lead to the successful " completion of construction" of the Midland Plant in accordance with regulatory requirements.

We hope that this submittal fulfills your request for written information regarding the Construction Completion Program. Consumers Power Company is prepared to support the public meeting proposed for January 26, 1983 in Midland, Michigan.

U JWC/DMB/cl CC Atomic Safety and Licensing Appeal Board CBechhoefer FPCowan, ASLB JIIarbour, ASLB DSlicod, NRC MMCherry RWilernan, NRC RJCook, Midland Resident Inspector FSKelley HRDenton, NRC WilMa rshall WDPaton, NRC WDShafer, NRC RFWarnick, NRC BStamiris MSinclair LLBishop oc0183-0308a100 2

r-CONSUMERS POWER COMPANY Midland Units 1 and 2 Docket No 50-329, 50-330 Letter Serial 20428 Dated January 10, 1983 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Power Company submits its Construction Completion Program.

CONSUMERS POWER COMPANY By j Cook, Vice7 residdnt Proj ts, Engineering and Construction Sworn and subscribed before me this L day of favup/,19f3 l'

aztwL 0 0bi)

Notary Publit #

Bay County, Michigan My Commission Expirec d - t/- ((z, oc0183-0308a100

Construction Completion Program Executive Summary ,.

The Construction Completion Program has been formulated to provide guidance in the planning and management of the design and quality activities necessary for completion of the construction of the Midland Nuclear Cogeneration Plant.

Construction completion is defined in this Plan as carrying all systems to the point they are turned over to Consumers Power Company for component checkout and preoperational testing. The Construction Completion Program does not include the Remedial Soils Program which is treated in separate interactions between Consumers Power Company and the Nuclear Regulatory Commission.

Background

The Construction Completion Program was developed in response to a number of management concerns that have been identified during the period preceding the initiation of the Program. The Midland Project had been proceeding at a high level of activity as it approached completion. The final transition from area construction to system completion, using punch lists, has been difficult for most nuclear projects. The Midland Project has not escaped these difficulties which have been compounded due to the congested space and the continuing numerous design changes, both generally attributable to the age of the Proj ect. These factors lead to the need for improved definition of work status, increased emphasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of systems for short-term milestones and increased effort to complete engineering ahead of ,

field installation.

The Midland Project has been criticized by the NRC regional office as not having met their expectations for implementation of the Project's Quality Assurance Program. The result has been that the Project management has too often, during the past few months, been in a reactive rather than proactive posture with regard to quality assurance matters.

In recognition of these conditions, management has concluded that a change in approach wat needed to effectively complete the Project while maintaining high quality standards.

Objectives l

The development of the Program has considered the Project's current status and recent history and attempts to address the underlying or root causes of the problems currently being experienced. In order to develop the Program the following overall objectives were established under three general headings.

The Program must:

Improve Project Information Status By:

Preparing an accurate list of to go work against a defined baseline.

mil 282-3489b100

2 Bringing inspections up-to-date and verifying that past quality issues have been or are being brought to resolution.

Maintaining a current status of work and quality inspections as the Project proceeds.

Improve Implementation of the QA Program By:

Expanding and consolidating Consumers Power Company control of the quality function.

- Improving the primary inspection process.

- Providing a uniform understanding of the quality requirements among all parties.

Assure Efficient and Orderly Conduct of the Project By:

Establishing an organizational structure consistent with the remaining work.

Providing sufficient numbers of qualified personnel to carry out the program.

Maintaining flexibility to modify the Plan as experience dictates.

Description The Construction Completion Program entails a number of major changes in the conduct of the final stages of the construction process and can be described in summary as a two phase process.

First, after certain necessary preparations, the safety-related systems and areas of the plant will be systematically reviewed. This first phase will be carried out on an area-by-area basis, but will be accomplished mainly by teams organized with systems responsibility and a separate effort to verify the completed work. The product from this phase of the program will be a clear status of remaining installation work and a current inspection status which provides quality verification of the existing work. The teams organized to carry out this first phase will continue to function in the second phase as the responsible organizational units to the complete the work.

In order to achieve its complete set of objectives, the Program contains a number of activities and elements that support and are linked to the two major phases described above. The major components of the Plan, which are discussed in more detail in the balance of this report, can be described as follows:

. A significant reduction in the construction activity in the safety-related portion of the plant, material removal and a general cleanup will be carried out in preparation for installation and inspection status assessment and quality verification activities.

mil 282-3489b100

3

. A review will be made of equipment status to assure that the proper lay-up precautions have been implemented to protect the equipment until the installation work is completed.

. The integration of the Bechtel QC function into the Midland Project Quality Assurance Department (MPQAD) under Consumers Power Company managcment will be completed.

. The Consumers Power Company is carrying out recertification program of Bechtel QC inspectors, and a review of the inspection procedures to be utilized.

. The system completion teams will be organized, staffed and trained according to procedures developed to define the team's work process.

. The systems completion teams wili 1) accomplish installation and inspection status assessment, 2) perform systems construction completion and construction quality performance and 3) determine that all requirements have been met prior to functional turnover for test and operation.

. Quality verification of completed work will be carried out in parallel with installation and inspection status activities of the system completion teams.

. A series of management reviews will be carried out to carefully monitor the conduct of the Program and to revise the plan as appropriate.

. Review and resolution will proceed on outstar. ding issues related either to QA program or QA program implementation as raised by the NRC or third party overviews of the Project.

. Third party reviews will be undertaken to monitor Project performance and to carry out the NRC's requirements for independent design verification.

Schedule Status The Program was initiated on December 2, 1982 by limiting certain ongoing safety-related work and starting preparations for the phase-one work of status assessment and quality verification activities. Since the Program also has incorporated a number of commitments made to the NRC during the past few months, activities in support of these commitments such as QC integration into MPOAD and the recertification of QC inspectors, had been initiated prior to December.

Status and schedules for each element of the Plan are enumerated in the text.

In general, preparation for the Phase 1 activities are underway and will continue through January. A pilot team to develop the procedures and training requirements will be initiated during January. It is expected that the first mil 282-3489b100

4 areas to undergo Phase 1 status assessment will be defined and teams mobilized during March.

Quality verificatica of completed work will start in late January or early February.

The Program provides for the Phase I results on a system or partial system to be reviewed and avaluated prior to initiating Phase 2 system completion work on that system or partial system. Management will monitor both process readiness and Phase I evaluation results.

The major areas of continuing safety-related work are NSSS construction as performed by B&W Construction Co, HVAC work under the Zack subcontract, the Remedial Soils Program and post-turnover punch list work released to Bechtel construction by Consumers Power Company. The Zack work is currently limited until a recently identified question on welder certification is resolved.

During the implementation of the Program in 1983, the NRC Resident Inspectors can use the Plan to monitor safety-related construction activities at the site. Since a substantial portion of the Plan directly relates to commitments made to NRC management, Consumers Power Company intends to schedule periodic reviews of Program status and progress with the NRC.

1 mil 282-3489b100

TABLE OF CONTENTS Section Title Page 1.0 Introduction 1 2.0 Preparation of The Plant 5 3.0 QA/QC Organization Changes 6 4.0 Program Planning 8 5.0 Program Implementation 13 6.0 Quality Program Review 15 7.0 Third Party Reviews 16 8.0 System Layup 19 9.0 Continuing Work Activities 20 mil 282-3489b100

-- -._ .-. - ~ - .- - ..-_-__ . - _ _ . _

1

1.0 INTRODUCTION

The Construction Completion Program has been formulated to provide guidance in the planning and quality activities necessary for completion of the construction of the Midland Nuclear Cogeneration Plant. Construction completion is defined in this Plan as carrying all systems to the point they are turned over to Consumers Power Company for component checkout and preoperational testing. The Construction Completion Program does not include the 7emedial Soils Program which is treated in separate interactions between Consumers Power Company and the Nuclear Regulatory Commisrion. The Construction Completion Program will be referred to as the Program in this document which contains the Plan for Program development and implementation.

Background

The Construction Completion Program is being develcped in response to a number of management concerns that have been identified during the period preceding the initiation of the Program. The Midland Project had been proceeding at a high level of activity as it approached completion. The final transition from area construction to system completion, using punch lists, has been difficult for most nuclear projects. The Midland Project has not escaped these difficulties which have been compounded due to the congested space and the continuing numerous design changes, both generally attributable to the age of the Project. These factors lead to the need for improved definition of work status, increased emphasis on overall Project objectives as well as continued focus of construction and inspection resources on completion of systems for short-term milestonec and increased effort to complete engineering ahead of field installation.

The Midland Project has been criticized by the Nuclear Regulatory Commission regional office as not having met their expectations for implementation of the Project's Quality Assurance Program. The result has been that the Project management has too often, during the past few months, been in a reactive rather than proactive posture with regard to quality assurance matters.

In recognition of these conditions, Consumers Power Company has concluded that a change in approach is needed to effectively complete the Project while maintaining high quality standards.

Objectives The development of the Program has considered the Project's current status and recent history and attempts to address the underlying or root causes of the problems currently being experienced. In order to develop the Program, the following overall objectives were established under three general headings.

The Program must:

Improve Project Information Status By:

Preparing an accurate list of to go work against a defined baseline.

mil 282-4106a-66-102

2 Bringing inspections up-to-date and verifying that past quality issues have been or are being brought to resolution.

Maintaining a current status of work and quality inspections as the Project proceeds.

Improve Implementation of the QA Program By:

Expanding and consolidating Consumers Power Company control of the quality function.

Improving the primary inspection process.

Providing a uniform understanding of tue quality requirements among all parties.

Assure Efficient and Orderly Conduct of the Project By:

Eatablishing an organizational structure consistent with the remaining work.

Providing sufficient numbers of qualified personnel to carry out the Program.

Maintaining flexibility to modify the Plan as experience dictates.

PLAN CONTENTS The Program was initiated on December 2, 1982 by limiting on-going work on Q-systems to pre-defined tasks cnd preparing the major structures housing Q-systems for an installation and inspection status assessment and verification of completed work. The relationship of the major elements of the Plan is shown in Figure 1-1. The sections of the Plan address the following major activity areas:

PREPARATION OF THE PLANT (Section 2.0)

The buildings are being prepared for a status assessment and verification of completed work.

QA/QC ORGANIZATION CHANGES (Section 3.0)

A new QA organization that integrates the QA and QC functions under a Consumers Power Company direct reporting relationship is being established. As a part of this transition, the Bechtel QC inspectors are being recertified to increase confidence in the quality inspection perfo rmance.

mil 282-4106a-66-102

1 .

i 3 PROGRAM PLANNING (Section 4.0)

The overall Plan for the Program is being developed in two major phases.

The first phase includes:

- A team organization assigned on the basis of systems is being developed to determine present installation and inspection status.

The inspection status assessment includes performing inspections on completed work to bring them up to date. A closely coordinated effort involving the construction contractor and Consumers Power Company (QA/QC, testing and construction) will improve quality performance.

- The quality verification of completed worn will be based, in part, on a sampling technique using re-certified inspectors as described in Section 3.0. -

The second phase includes:

Following installation and inspection status assessment the team 1 organization will retain responsibility for systems completion work.

- The QC inspection process of new work will be integrated with the systems completion work to ensure adeorate quality performance.

PROGRAM IMPLEMENTATION (Section 5.0)

The first phase implementation of the Program will be initiated with a review of the process, procedures and team assignments that will be used. The plan for verification of completed work will be reviewed separately. The teams will conduct the installation and inspection status assessment; verification of completed and inspected work will proceed, as planned, in coordination with the team effort. Following l phase I completion of the first work segment, a management review of the plan effectiveness will be made.

i In second phase Program implementation, the assigned team will plan i and schedule the remaining work needed for completion including QC inspections.

QUALITY PROGRAM REVIEW (Section 6.0) t The adequacy and completeness of the quality program will be reviewed on an ongoing basis, taking into consideration questions raised by MRC inspections and findings by third party reviewers. The results of these reviews will be considered as part of the management review that are a part of the Program implementation (Section 5).

mil 282-4106a-66-102 f

- . - - - .- m-- .r - . - , - - - - . _ . , . . . , - , , . . . . _ . _ _ _ . , _ _ , _ _ - , . _ _ _ . - , , . . _ . , . _ , _ - _ - - _ . _ , . _ _

4 THIRD PARTY REVIEWS (Section 7.0)

Indeperdent assessments of the Midland Project will provide management and LP,. with evaluations of Project performance.

SYSTEM LAY-UP (Section 8.0)

The on going work to protect plant equipment and systems will be augmented as necessary to provide adequate protection during implementation of this Plan.

CONTINUING WORK ACTIVITIES (Section 9.0)

Work on Q-Systems has been limited to specifit activities. This limitation permits important work to proceed while allowing building preparation for status assessment and verification activities.

SUMMARY

Each section of this Plan presents detailed objectives, a description of the activity involved, and a schedule for achieving major milestones. The Program, however, is still in an evolutionary state and revisions to the Plan may be necessary as Consumers Power Company gains experience in the implementation of Program elements.

i mil 282-4106a-66-102

1 FIEURE 1-1 -

l CONSTP.UCTION COMPLETION PROGRAM SCHEMATIC

' PHASE 1 PHASE 2 SECTION PLANNING IMPLEMENTATION PLANKING IMPLEMENTATION '

1 '

PREPAR ATION . -

l 2

OF THE PLANT QA/QC REORGANIZATION PHASE 1 -

PHASE 2 4 '

PLANNING PL ANNING MANAGEMENT

' ^'

p _

REVIEW COMPLETED IN8PECTIONS EVALUATION SYSTEMS 5 -

AND -

COMPLETION MANAGEMENT

^

_ AND _

REVIEW INSPECTION STATUS JL d i

8 QUALITY PROGRAM REVIEW 7 THIRD PARTY REVIEWS 8 SYSTEM LAY UP 9 CONTINUING WORK ACTIVITIES

5 2.0 PREPARATION OF THE PLANT 2.1 Introduction The preparation of the Plant will clear the auxiliary, diesel generator and containment buildings and the service water pump structure of materials, construction tools and equipment and temporary construction facilities.

2.2 Objective To allow improved access to systems and areas for the Program activities.

J 2.3 Description The preparation activities minimize obstacles ani interferences for the Program activities. This is being ace,mplished through the following steps.

1. Limitation of Q-work to activities and areas deft. ed in Section 9 resulting in subatantial work force reduction.

2. Removal and storage of construction tools and equipment, and temporary construction facilities (scaffolding, etc) from the buildings identified in Section 2.1.

3. Removal, control and storage of uninstalled materials from the buildings identified in Section 2.1.

4. Appropriate housekeeping of all areas following material and equipment removal.

The preparation for each area will be complete before initiating further Program activity. The on-going work described in Section 9 will continue as scheduled during the preparation.

2.4 Schedule Status The preparation of the Plant began on December 2, 1982. It will be complete by January 31, 1983.

mil 282-4106b-60-102

FIGURE 3-1 MPOAD ORGANIZATION BECHTEL MIDLAND PROJECT OC PROGRAMMATIC QUALITY ASSURANCE DEPT EXECUTIVE MANAGER ASME I

OUALITY ASSURANCE MANAGER l (OFFSITE) l I

I I

I SITE S TE -

ADMINISTRATIOA HVAC OA/QC SOILS OA/OC

& TRAINING SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT l 1

1 I

1 NOTE: THIS CHART IS INTENDED TO INDICATE ONLY THE INTEGRATION OF THE CIV:L ELECTRICAL PIPE / MECH / WELD BECHTEL QC FUNCTION.

QC OC (ASME) OC

6 f

3.0 QA/QC ORGANIZATION CHANGES 3.1 Introduction The Consumer Power Company's Miuland Project Quality Assurance Department (MPQAD) is being expanded to assume direct control of Bechtel QC activities. The new organization and the plan for the transition are described below. The transferred QC Inspectors will be recertified as part of th4.s transition.

3.2 Objectives Establish New QA/QC Organization Establish an integrated organization which includes the transition of Bechtel QC to MPQAD while accomplishing the following objectives:

1. Establish direct Consumers Power Company control over the QC inspection process.

2. Establish the responsibilities and roles of the QA and QC Departments in the integrated organization.

3. Use qualified personnel from existing QA and QC departments and contractors to staff key positions throughout the integrated organization.

Recertify QC Inspectors Ensure that thoss Quality Control inspection personnel transferring to MPQAD from Bechtel will be trained and recertified in accordance with MPQAD Procedure B-3M-1.

3.3 Description Establish New QA/QC Organization A new organization will be implemented under Consuaers Power Company and will be described in appropriate Topical Reports (CPC-1A and BQ-TOP-1) and quality program manuals (Volume II, BQAM and NQAM).

Changes to these documents will be submitted to NRC.

Features of the new organization include:

1. Lead QC Supervisors report directly to a QC Superintendent who reports to the MPQAD Executive Manager. Any required support from Bechtel Corporate QC and QA functions (except ASME N-Stamp activities) is provided at the level of the MPQAD Executive Manager.

2. The MPQAD Executive Manager will review the performance of lead personnel in his department.

mil 282-4106c-66-102

7

3. QA will develop and issue Quality Control inspection plans and be responsible for the technical content and requirements of such plans. QC will be responsible to implement these plans.

4. QA will continue to monitor the Quality Control inspection process to insure that program requirements are satisfactorily implemented.

5. MPQAD will continue to use Bechtel's Quality Controi Notices Manual (QCNM) and Quality Assurance Manual (BQAM) as approved for use on the Midland Project.

6. ASME requirements imposed upon a contractor as N-Stamp holder will remain with that contractor. MPQAD QA will monitor the implementation of ASME requirements.

s An organization chart (Fig 3-1) showing reporting relationships in the new organization is attached.

Recertify QC Inspectors The training and recertification process for QC inspectors has been revised to include commitments made during the September 29, 1982 public meeting with the NRC. Those inspectors transferred from Bechtel to MPQAD will be trained and examined in accordance with MPQAD Procedure B-3M-1. Upon tutisfactory completion of the training and examination requirements, inspection personnel will be certified for the Project Quality Control Instruction (s) (PQCI(s))

they are to implement. Inspection personnel will be certified on a schedule which supports ongoing work and system completion team activities.

3.4 Schedule Status Establish New Organization Advise NRC of the structure of the integrated organization. 12/15/82 Transfer the Bechtel QC Organization to MPQAD. 1/17/83 Submit changes to Topical Reports and quality program manuals to NRC. 2/17/83 Recertify QC Inspectors Specify the revised training and examination 1.0/25/82 requirements for certification (B-3M-1).

Complete recertification 4/01/83 mil 282-4106c-66-102

8 4.0 PROGRAM PLANNING 4.1 Introduction The detailed planning for the major portion of the Construction Completion Program is described in this section.

Planning in support of Phase 1 consists of the activities to set up a team organization to assess the installation and inspection status of Q-systems within major structures (Section 4.2) and to verify the adequacy of completed inspection effort (Section 4.3).

The Phase 2 planning effort covers the process and procedures that will be used by the team organization for systems completion work (Section 4.4). The procedures to integrate the quality program requirements with continuing systems completion work will be developed (Section 4.5).

4.2 Team Organization (Phase 1) 4.2.1 Introduction Organize and train teams and prepare procedures for an installation and inspection status assessment.

4.2.2 Objective

1. Establish and implement a team organization ready to inspect and assess systems for installation and inspecti3n status.

2. Develop the organizational processes and procedures necessary to implement the team approach for status assessment.

3. Provide training to ensure required inspection and installation status assessment activities are satisfactorily performed.

4.2.3 Description

1. The team organization structure will vary depending upon the assigned scope of work. The organization will consist of a team supervisor and personnel as appropriate from field engineering, planning, craft supervision, project engineering, MPQAD and Consumers Power Company Site Management Office. The team may be augmented by procurement personnel, subcontract coordinators and turnover coordinators.

Teams will be assigned a specific scope of work and held accountable for status assessment and overall completion within this scope. The scope includes the requirements mil 282-4106d-66-102

9 to develop a viable working schedule .nd insure early identification and resolution of problem areas. Project processes and procedures will be reviewed and modified to incorporate the team organization. The team MPQAD representative is responsible for providing the QA/QC support for the team. He receives scheduling direction from the Team Supervisor and technical direction from MPQAD. For his team's work, he analyzes the quality requirements and plans the QC activities to integrate them with the team effort. He assures the necessary PQCI's and certified inspection personnel are available for performing the inspections. He maintains cognizance of the quality status of the verification activities.

The Washington Nuclear Plant #2 (WNP-2) team organization will be used as a starting point for a Midland specific approach.

A pilot team or teams will be utilized to develop and test processes and procedures during the development stage to assure that Program objectives can be met. This will also provide practical field input to assure that efficient and workable methods are used.

Team members will be physically located together to the extent practicable to improve communication, status assessment, problem identification and problem resolution.

2. Training for inspection and installation status assessment will be provided to team members. It will include respensibilities, reporting functions, indoctrination of project processes and procedures and familiarization with the project quality program to ensure effective implementation.

3. A separate organization of design engineers (presently existing) will coordinate spatial interaction, review and examination with the activities of these teams.

4.2.4 Schedule Status

. Designate pilot team. 1/21/83

. Complete grouping of systems for assignment 2/28/83 to teams.

. Complete assignment of team supervisors and 3/31/83 ,

members to designated systems.  ;

I mil 282-4106d-66-102

10 4.3 Quality Verification (Phase 1) 4.3.1 Introduction The verification program is the activity undertaken to determine, using a variety of methods, that the inspections performed on completed work were done correctly.

4.3.2 Obj ectives The objectives of the verification program are to:

. Review existing PQC1's and revise as necessary to assure that:

a. Attributes important to the safety and reliability of specific components, systems, and structures are i identified for verification.

b. Accept / reject criteria are clearly identified.

c. Appropriate controls, methods, inspection and/or testing equipment are specified.

d. Requisite skill levels are required per ANSI N45.2.6 or SNT-TC-1A.

. Develop and implement verification inspection plan for completed work which considers:

a. Re-inspection of accessible items.

b. Review of documentation for attributes determined to be inaccessible for re-inspection.

c. Sampling techniques using national standards.

4.3.3 Description PQCI's will be revised as necessary to meet the objectives in Section 4.3.2. Verification of the quality of accessible completed contruction, which has been previously inspected will be performed by use of sampling plans based on MIL-S-105D (1963) or other acceptable methods. Attributes determined to be inaccessible for direct re-inspection due to embedment or the status of completed construction or installation (eg, weld preparation of completed welds, reinforcement in placed concrete, installed anchor bolts, etc) will be verified as appropriate, by examination of records.

mil 282-4106d-66-102

11 4.3.4 Schedule Status

. Complete review and revision of PQCI's. (Date to be determined.)

. Establish verification inspection plan for completed work. (Dete to be determined.)

4.4 System Completion Planning (Phase 2) 4.4.1 Introduction Establish the processes for system completion, prepare procedures and expand training to cover systems completion work.

4.4.2 Objective The objectives of the systems completion planning are as follows:

. Establish processes and interfaces for system completion.

. Prepare procedures defining tasks of each system completion team.

. Train team members by expanding upon training received previously for inspection and status assessment.

. Establish scheduling methods to be used during system completion activities.

4.4.3 Description The team organization (developed in Section 4.2) and the processes and procedures will be extended to accomplish the systems completion work.

. Training will be conducted to assure that superviaors understand the team objectives and their role. Emphasis will be placed on completion of all work in accordance with the design requirements, the change control process used when the design must be modified, and changes to the established team processes and procedures.

4.4.4 Schedule Status

. Complete team preparation for systems completion work.

(Date to be determined.)

l mil 282-4106d-66-102 l 1

12 4.5 QA/QC Systems Completion Planning (Phase 2) 4.5.1 Introduction The QA/QC systems completion activity covers the planning to support of system completion work.

4.5.2 Objectives Establish in process inspection program and complete review and modification of PQCIs.

4.5.3 Description The QC in process inspection program vill be directly coordinated with future installation schedules to insure that inspection points, identified by MPyhD QA in the PQCI's, are integrated with the installation schriule. The identifi-cation of applicable PQCI's and required inspection points will be used by system completion teams to insure that QC inspections are adequately scheduled into the process. The system completion team quality representative will be responsible for providing the link between the system completion team and MPQAD to insure that quality requirements are satisfied.

PQCI's will be reviewed, and modified as necessary, to insure that proper attributes are being inspected, that inspection plans are clear and concise, that inspection points are specifically scheduled with installation activities and that inspection results are properly documented. MPQAD QA will be responsible for the PQCI review activity and will obtain assistance, as required, from other project functions, such as Project Engineering and Quality Control. Revised PQCI's will be used to conduct inspection of future installation activities.

4.5.4 Schedule Status Issue procedure for integrating inspection points into the construction schedule. 2/22/83 mil 282-4106d-66-102

FIGURE 4-1 -

CONCEPTUAL TEAM ORGANIZATION SYS. TEAM SUPV. PROJECT MPQAD ENGR.

s l 1 l

I I I LEAD SYS. TEAM LEAD SYS. MECHJI & C , ELECT. SYS. TEAM LD.SYS.TM.  !

1 REPRESE TATIVE ' TEAM F.E. SUPT; SUPT. PLANNER PROJ. ENGR. I I

............. I

' SUPPORT GROUPS , l

, I

, toc ,--3 8 ,

i PROCUREMENT -*--g

, e 8 I

1. i

-" 1 CPCO TEST i

SUSCONTRACT G/M'-0460 , a

13 5.0 PROGRAM IMPLEMENTATION 5.1 Introduction The implementation of the Phase 1 Construction Completion Program activities will be initiated after a management review of the overall process insures that Project performance and quality objectives have been addressed. The Phase 1 work will then be carried out by the various teams in accordance with the procedures described in the preceding sections. The installation and inspection status assessment of a system or partial system will be followed by a review of results by MPQAD and a second management review before initiating the Phase 2 systems completion work. The Phase 2 work will then be initiated on that system or partial system.

5.2 Objectives The objectives to be met are:

. Establish the present installation completion and quality status.

. Integrate the construction and quality activities for all remaining work.

. Improve performance in demonstrated conformance to quality goals in all system completion work.

5.3 Description Management Reviews Project management will conduct formal review of the plans for implementation activities prior to initiation of team activities for the Phase 1 work. These reviews will ensure that identified project management and quality issues have been adequately addressed by specific actions and that Program objectives are met. The reviews will cover the process for both 1) the verification of completed inspection activity and 2) the installation and inspection status activity.

The installation and inspection status assessment will be performed on a system and/or area basis. Phase 2 is initiated after a formal Project management review of the first status assessment results to evaluate implementation effectiveness. After completion of this review, a work segment will be released for systems completion.

Subsequent status assessment results will be reviewed by site management prior to initiation of additions 1 systems completion segments. Reports will be made to Project management at regularly scheduled meetings.

mil 282-4106e-66-102

14 Phase 1 Implementation The existing installation and inspection status will be established in accordance with the plan presented in Section 4.

Evaluate Phase 1 Results MPQAD will review the status assessment results to determine if any programmatic or implementation changes must be made. Verification scope will be adjusted, as necessary, based on evaluation results.

Also, the evaluation will check for reportability to the NRC (as required by 10 CFR 50.55(e)) and Part 21.

Phase 2 Implementation This activity starts systems completion for turnover. Work will be j scheduled as installation and inspection status assessments are completed and reviewed. Correction of identified problems will be given priority over initiation of new work, as appropriate, and the

system completion teams will schedule their work based on these priorities.

5.4 Schedule Status

. Complete Management review and initiate implementation of plan for verification of completed inspections. (Date to be dete rmined. )

. Complete Management review and initiate implementation of plan for status assessment. (Date to be determined.)

. Complete Management review of initial installation and inspection status results and initiate systems completion work.

(Date to be determined.)

mil 282-4106e-66-102

9 15 6.0 QUALITY PROGRAM REVIEW 6.1 Introduction The adequacy and completeness of the quality program is reviewed as part of the ongoing Project management attention to quality. These reviews consider any questions raised by NRC inspections or findings raised by third party evaluations.

6.2 Objective Address issues raised by internal audits, NRC inspections and third party asse:sments. Program changes, if needed, will be evaluated and, as findings are processed, will be factored into the Project work.

6.3 Description Consumers Power Company believes Midland QA program is sound. From time to time, questions arise on detailed aspects of the program or program implementation. The normal process of addressing these issues ensures that all necessary information is provided to NRC and that internal confidence in the program is maintained.

The recent inspection of the diesel generator building has raised several issues of programmatic concern. These are in the areas of mcterial traceability, design control process, Q-system related requirements, document control and receipt inspection. Project management has directed that MPQAD provide an expeditious evaluation of these issues to be considered as part of the management review prior to initiation of Phase 2. Once the NRC inspection report is received and specified items are identified, these items will be addrer,ed and resolved through the normal process of closing the inspection findings. Any corrective action or program changes will be implem(ated as appropriate in Project work on a schedule provided in the inspection report response.

The Project will also receive, from time to time, findings from third party assessments (Section 7). These findings or recommendations may also result in program modification or adjustments. Corrective action taken by the Project will be implemented on a schedule stated in the response to these findings.

mil 282-4106f-66-102

16 7.0 THIRD PARTY REVIEWS 7.1 Introduction This section describes third party evaluations and reviews that have been performed and are planned to assess the effectiveness of design and construction activity implementation. Third party reviews being conducted as part of the Remedial Soils Program are not included in this activity.

7.2 Objectives To assist in improving Project implementation and assessment of Midland design and construction adequacy, consultants will be utilized in order to:

Achieve a broad snapshot of current Project practices and performance in relation to a national program. -

Provide continuous monitoring and feedback to Management of Project performance.

Identify any activities or organizational elements needing improvement.

Improve confidence (including the NRC's and the public's) la overall Project adequacy.

7.3 Description The use of consultants to overview Project design and construction activities with pat:_icular emphasis on construction is part of the effort to improve the Project's implementation of the quality program. Specifically, the plan overview employs the use of consultants for three separate functions: (1) To carry out a self-initiated evaluation (SIE) of the entire Project under the INPO Phase I program, (2) to utilize a third party overview of ongoing site construction activities to provide monitoring of the degree of implementation success achieved under the new program and (3) to conduct a third party Independent Design Verification (IDV) Program.

1. The INPO self-initiated evaluation was planned as part of an industry commitment to the NRC in response to concerns over nuclear plant construction quality assurance. For the Midland SIE, the evaluation was contracted to be carried out entirely by third party, experienced personnel from the Management Analysis Company.

The evaluation was performed by a team of 17 consultants familiar with the INPO criteria and evaluation methodology.

Over a period of a month they interviewed Project personnel at various locations and observed work in progress. The initial results of their evaluation have been presented to the Company mil 282-4106i-66-102 i

l 1

17 and a Project response to each finding will be prepared and included as part of the evaluation report to be submitted first to INPO and then to the NRC Region III Administrator, together with the INPO overview.

2. A third-party installation implementation overview is being undertaken using, as a model, the program developed specifically for the underpinning portion of the soils remedial work. The overview will be initiated by retaining an independent firm, having considerable experience and depth of personnel in the nuclear construction field. The consultant's overview team will be located at the Midland Plant site and will observe the work activities being conducted in accordance with this Plan on safety-related systems. The overview will continue for a period of six months, af ter which the Project's cumulative performance will be evaluated. Based on the overview team's findings, a determination will be made by the Company's top management on what modification, if any, should be made to the consultant's scope of work. Findings identified by the installation overview team will be made available to the NRC in accordance with the procedures established for the conduct of independent verification programs.

3. An Independent Desigo Verification (IDV) is being conducted by Tera Corporation.

The IDV is directed at verifying the quality of design and construction for the Midland Plant. The approach selected is a review and evaluation of a detailed " vertical slice" of the Project design and construction. The design and as-built configuration of two selected safety systems will be reviewed to assure their adequacy to function in accordance with their safety design bases and to assure applicable licensing commitments have been properly implemented. The field work done in support of this activity will not take place until after Phase I implementation (Sectiou 5) has been completed on the systems being reviewed.

The Unit 2 Auxiliary Feedwater System (/FW) plus another system to be selected with NRC concurrence, wi 1 be reviewed to fulfill the requirements of the IDV.

4 mil 282-4106i-66-102

, 18 7.4 Status / Schedule

1. INPO Construction Project Evaluation Select conroltant and conduct Complete evaluation Submit report to INPO Jan 20, 1983

2. Independent Construction Overview Define scope Dec 30, 1982 Select consultant Jan 31, 1983 Mobilize assessment team (Date to be determined)

Receive assessment team (Date to be determined) report

3. IDV Select 2 Systems

.AFW System Complete

.0btain NRC concurrence (Date to de determined) for second system.

Complete Evaluation (Date to be determined) i mil 282-4106i-66-102 I . -

19 8.0 SYSTEM LAYUP 8.1 Introduction Perform system lay-up activities to protect plant equipment.

8.2 Objectives Expand the protection af completed and partially completed plant systems and components until plant start-up, to take into account any special considerations during the status assessment.

8.3 Description Procedures and instructions are provided in the Testing Program Manual to protect equipment during the on-going installation and test work. These will be extended to cover special considerations associated with the Program implementation. Both ti.e pre- and post-turnover periods are covered. System and component integrity is ensured through existing programs and implementation of control and verification procedures.

In summary, these procedures and instructions require: Test Engineers to complete walkdowns of Q-Systems (in the auxiliary, diesel generator and containment buildings and the service water pump structure), paying particular attention to systems / components that are open to the atmosphere (eg open ended pipes, open tanks, missing spools, disconnected instrument lines, etc). Systems that have been hydrotested but are not currently in controlled layup require action to place the system in layup. Layup will vary from system to system but in general will consist of air blowing to remove moisture and closing the system from the atmosphere.

8.4 Schedule / Status

. Start extended la3up activities 1/15/83

. Issue walk down schedules 1/15/83

. Complete the layup preparation walkdown 2/28/83 mil 282-4106g-66-12

20 9.0 CONTIFUING WORK ACTIVITIES 9.1 Introduction i This section describes the activities that are proceeding in accordance with previously established commitments during the implementation of the Program.

9.2 Objectives

. Maintain installation and support effort on work that will alleviate work interference in congested portions of the plant and facilitate completion and protection of equipment on systems turned over to Consumers Power Company.

l

. Meet previous NRC commitments on activities which do not impede the execution of the Program.

. Provide design support for orderly system completion work and resolution of identified issues -

. Establish a management control to initiate additional specified work that can precaed outside of the systems completion activities 9.3 Description Those activities that have demonstrated effectiveness in the Quality Program implementation will continue during implementation of the Construction Program.

These are:

1. NSSS Installation of systems and components being carried out by B&W 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. Post system turnover work, which is under the direct control of Consumers Power Company, will be released as appropriate using established work authorization procedures.

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 NRC.

mil 282-4106h-66-102

21

6. Design engineering w_ich will continue for the Midland Plant as will engineering support of other project activites.

Additional activities related to the systems completion effort, may be initiated, as appropriate, to support orderly completion of the overall Project. Any activities in this category that are initiated prior to release of an area for systems completion work will be reviewed with the NRC Resident Inspector before initiation.

9.4 Status Schedule These activities are proceeding with schedules that are independent of this Plan.

t mil 282-4106h-66-102

_