ML20077D527

Rev 1 to Third-Party Const Implementation Overview

ML20077D527
Person / Time
Site:	Midland
Issue date:	07/05/1983
From:	Baranow S, Kelly R STONE & WEBSTER, INC.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
83-07-14, 83-7-14, PROC-830616, NUDOCS 8307260547
Download: ML20077D527 (6)

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. L.' O O J.0.No. 14509 Date June 16, 1983 Midland Plant Units 1 & 2 Revision i THIRD PARTY CONSTRUCTION IMPLEMENTION OVERVIEW Approval:

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Date fd-83 Program Manager 1.0 PURPQSE AND SCOPE To estr.blish a program whereby Stone & Webster performs independent evaluations and verifications of the Consumers Power Company (CPCo) Construction Completion Program, (CCP) reports progress, observations, and nonconformances to the program,; specifically, to verify that:

1.1 Management performance is adequate in the following areas:

A. Establishment of the Management Review Comittee B. Duties and responsibilities of the Review Comittee are clearly defined C. Procedures governing the actions of the Review Comittee are in place D. Management reviews are complete, effective, and conducted in ac-cordance with the requirements of the CCP Program 1.2 CCP procedures, instructions, inspection plans, records, and prerequisites for inspections /reinspections have been satisfactorily approved prior to implementation.

1.3 Specific CPCo comitments to the NRC are iden.tified to f acilitate track-ing; dates for compliance (as appropriate) are adequately identified; appropriate action parties are clearly identified; comitted actions have been satisfactorily resolved.

1.4 Procedures, prerequisites, and reinspection attributes in References 2.1, 2.2 and 2.3 have been approved by the Management Review Comittee.

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1.5 Personnel assigned to implement the CCP Program have been properly trained, qualified and certified in accordance with the requirements of ANSI-N45.2.6; SNT-TC-1A and MPQAD Procedure B-3M-1, Qualification and Certification of Inspection and Test' Personnel. Construction and craft personnel -shall be trained to meet the requirements of the Construction Training Procedure FPG-2.000.

1.6 The effectiveness of the Quality Verification Program based onwitnessing inspections /reinspections of selected component installation, fabrication and review of applicable test / inspection reports and records.

1 1.7 Measures have been developed to ensure that NRC hold points are clearly identified and controls are in evidence to prevent continuance of work pending clearance of the hold points.

2.0 REFERENCES

2.1 Quality Verification Program Document, April 16, 1983

, 2.2 Construction Completion Program

a. Letters J.W. Cook to the IRC: JaNary 10, 1983 April 6, 1983 April 22, 1983 2.3 Nonconformance Identification and Reporting Procedure 3.0 ATTACHMENTS l 3.1 Evaluation Attribute Checklist (Later) 3.2 Verification Attribute Checklist (Later) 3.3 Nonconformance Inspection Report (Later) 4.0 DEFINITIONS 4.1 Construction Completion Program (CCP)

A 'progra:n to provide guidance in planning and management of design and quality activities necessary for completion of construction of the plant and verification nf completed work.

4.2 Quality Verificatfen Program (QVP)

An ' element of the CCP used to confirm the quality status of safety related procurement - and construction activities completed and inspected by the Engineer-Constructor personnel prior to December 2, 1982.

4.3 Evaluation Assessment of quality related activities based upon review of procedures, plans, instructions, inspection . reports, test results and additional conmittments.

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. O O J.0.No. 14509 Midland Plant Units 1 & 2 Consumers Power Company

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NOTE Documentation' resulting from resolution of CPCo committments to the NRC and NRC Hold Points shall be 100% reviewed to verify that

t. proper corrective action has been accom-plished.

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4.4 Verification f Confirming, substantiating or assuring that CCP and QVP requirements have been implemented and are active, verification actions may include docu-mentation, hardware and management systems.

NOTE Activities performed by CPCo under the CCP and QVP Programs will be monitored using random sampling techniques. The sampling will be based on a review of day to day activities in sufficient detail to ensure adequate implementation of the programs.

i' 5.0 GENERAL REQUIREMENTS 5.1 All personnel assigned quality assurance. program evaluation responsibil-ities shall be certified auditors in accordance with ANSI-N45.2.23 and applicable Stone & Webster procedures.

l 5.2 All personnel assigned construction verification responsibilities shall be certified inspectors in accordance with ANSI-N45.2.6 and applicable Stone

& Webster procedures and possess the appropriate combination of education, experience and training. ,_ ,

5.3 The Third Party Construction Implementation Overview (CIO) program will be structured to determine, by evaluation of predetermined procedures and instructions, the quality practices utilized in the construction of the Midland Plant Units 1, 2, and the effectiveness of those practices.

5.4 A site team will be established to monitor the effectiveness of the Con-

-- struction Completion Program. The team will consist of a Program Manager and two functional groups. One group will assess the completeness of compliance with procedures and inspection plans being used to complete the

-work. The other group will review certain aspects of construction activi-I ties which relate to the performance of the Quality Control Inspection Program. These two gro.ups will use special procedures, checklists, and random sampling techniques to evaluate the following

A. Adequacy and implementation of CPCo procedures regarding construc-tion activities, personnel qualification, training programs, and organizational practices.

'B. Compliance of Construction Completion Program teams to prescribed procedures.

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' Midland Plant Units 1 & 7 Consumers Power Company C. Compliance of Midland Project Quality Assurance (MPQAD) personnel to applicable procedures.

D. Compliance of construction activities to applicable procedures.

5.5 The Program Manager shall maintain communications with the NRC and CPCo Site Manager. Weekly progress meetings shall be held with the NRC and CPCo to discuss progress and report on nonconformance and observations.

5.6 Programmatic nonconformances of a serious nature shall be immediately reported to the NRC and CPCo.

6.0 PROCEDURES 6.1 The following procedures shall be prepared to control the activities of the Construction Implementation Overview (CIO) teams.

A. Quality Control Instruction 10.01 Construction Implementation Overview Assessment 6.2 The site teams shall develop attribute checklists for each evaluation and verification activity. Attributes shall be selected from the CCP, PQCI's, CPCo committments to the NRC and other applicable requirements.

6.3 Auditors assigned toconduct evaluations shall, utilizing checklists, itemize those quality practices evident in the performance of each activity.

The results of each evaluation shall be documented on the checklist to ensure repeatability. Summaries of the results shall be tabulated weekly for presentation to the NRC and CPCo.

6.4 Inspectors assigned to conduct verification, shall utilizing the check-list, monitor the activities of CPCo personnel involved in CCP and QVP activities.

6.5 All systems verified shall be identified and documented to assure repeat-ability.

6.6 Nonconformances identified in conjunction with this procedure shall be dccumented on a Nonconformance Inspection Report (NIR)and processed in accordance with Reference 3.3 of this procedure.

7.0 REPORTS 7.1 The following reports will be submitted to NRC and CPCo and S&W by the Program Manager.

A. Weekly Progress Reports

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Consumers Power Company C. Final Reports on Construction Completion 7.2 Weekly Progress Report - Weekly Frogress Reports will be submitted during the weekly meeting with CPCo, and the NRC.

7.3 Final Report - A final report will be submitted 30 days after completion of the program. The report will summarize the SWEC assessment. The final report will be submitted by the Program Manager to the NRC, CPCo and S&W.

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O O STONE & WEBSTER MICHIGAN, INC.

P.O. box 2325, BOSTON. M ASSACHUSETTS O2107 SD-3&4 50' N 30 Mr. J. G. Keppler, Administrator, Region III July 14, 1983 Nuclear Regulatory Commission J.0. 14509 799 Roosevelt Road NRC File #83-07-14 Glen Ellyn, IL 60137 '

RE: DOCKET NO. 50-329/330 MIDLAND PLANT - UNITS 1 AND 2 OVERVIEW 0F THE CONSTRUCTION COMPLETION PROGRAM A copy of the Stone & Webster Third Party Implementation Overview Procedure, Rev.1 dated July 5,1983 is enclosed for your review. The Procedure was revised for clarity. As periodic reports have and will be transmitted to your office, requirement for monthly reports has been deleted from the procedure.

Very truly yours, l l l

S. W. Baranow Program Manager Enclosure SWB/ka l cc: JJHarrison, NRC Glen Ellyn i RCook, NRC Midland (site)

DBMiller, CPCo Midland (site)

F8 Kelly, S&W APAmaruso, S&W C0 Richardson, S&W L

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