ML20065C680

Summarizes 820902 Meeting W/Nrc Mgt in Chicago,Il Re QA Program Implementation of Soils Remedial Work.Soils Program Thoroughly Evaluated & All Prerequisites for Implementation Accomplished

ML20065C680
Person / Time
Site:	Midland
Issue date:	09/17/1982
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Harold Denton, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), Office of Nuclear Reactor Regulation
References
18845, NUDOCS 8209240272
Download: ML20065C680 (7)

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Consumers i Power CONU r J Vice l>esiJent - Projects, Engineering and Construction oeneral offices

1945 West PerneH Road, Jackson, MI 49201 * (517) 78& O453 j September 17, 1982 Harold R Denton, Director Office of Nuclear Reactor Regulation Division of Licensing US Nuclear Regulatory Commission Washington, DC 20555 .

J G Keppler i Administrator, Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT i MIDLAND DOCKET NOS 50-329, 50-330

, QUALITY ASSURANCE PROGRAM IMPLEMENTATION FOR S0ILS REMEDIAL WORK FILE: 0485.16 SERIAL: 18845 a

l This letter summarizes recent discussions with NRC management regarding j implementation of soils remedial construction and presents the Company's

documentation of those discussions.

BACKGROUND The 1980/1981 SALP Report, presented to Consumers in late April of this year, indicated that activities in the soils area should receive more inspection effort on the part of both the NRC and CP Co. Follow-up discussions with the

NRR staff and Region III Inspectors led to the conclusion that the Quality Assurance Program and its definition was adequate; however, there was concern j that certain aspects were not being or might not be satisfactorily

, implemented.

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Consumers Power has performed an in-depth review of the implementation plans

for the Midland soils work activities. This review included the areas of design and construction requirements and plans, organization and personnel, l project controls and management involvement. The results of this review and r the proposed steps to assure the successful implementation of all aspects of

the work were discussed with the NRC management in a meeting held in Chicago on September 2, 1982.

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1 STEPS TO IMPROVE IMPLEMENTATION A number of new steps have or are being taken by Consumers Power Co to enhance the implementation of the quality program with regard to the soils remedial work. These measures touch upon all aspects of the work, from design to post-construction verification and include the following:

(1) Retaining a third party to independently assess the impler entation of the l auxiliary building underpinning work; (2) Integrating the soils QA and QC functions under the direction of MPQAD; (3) Creating a " Soils" project organization with dedicated employees and single-point accountability to accomplish all work covered by the ASLB order; (4) Establishing new and upgraded training activities, including a special

quality indoctrination program, specific training in underpinning activities, and the use of a mock-up test pit for underpinning construction training; (5) Developing a quality improvement program (QIP), specifically for soils remedial work; (6) Increasing senior management involvement in the soils remedial project through weekly, on-site management meetings wherein both work progress and quality activities are reviewed; (7) Improving systems for tracking of and accounting for design commitments.

What follows is a description of the soils implementation plan, as it will be carried out using the new approaches outlined above, together with other specific aspects which we believe will be criticial to the successful performance of the job. The discussion is JImited to the implementation features specific to soils, is divided into areas roughly describing the progression of the job from design to completion and ends with a description of organizations, management involvement and NRC cverview.

DESIGN ADEQUACY AND IMPLEMENTATION The design for the required remedial activities is in an advanced state; design details and adequacy have been reviewed by numerous organizations. A special ACRS Subcommittee reviewed the soils activities and commented favorably on the thoroughness and conservatism of the review and remedial approaches. Numerous submittals to the NRC have been presented to clarify the design intent. It is our understanding that the Staff is completing its detailed review of all design aspects and is in the process of issuing an SSER. This advanced state of design has permitted the early development of a thorough planning effort and assisted in the organization and development of a detailed training effort. Following-up ou design activities, the Project has assigned to the site a design team comprised of experienced structural and geotechnical engineers under the Resident Engineer. This team will monitor  !

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i and review the field implementation as specified in design documents, resolve j on a timely basis routine construction questions requiring engineering response and administer the specific contingency plans immediately if any

, problem should arise during the underpinning work. Additional engineering resources for the soils work will continue to be located in Ann Arbor.

IMPLEMENTATION OF Lc. SIGN FEATURES AND COMMITMENTS All soils activities covered by the ASLB Order of April 30, 1982 are covered j under soils-specific-QA plans. These plans require that appropriate

! procedures are in place to accomplish the work in a quality manner and that detailed inspection plans be developed and utilized. Additionally, a Work Authorization Procedure and Work Permit System insure that the NRC and CP Co 4

have specifically authorized and released the work. Under this system, the NRC reviews proposed work details, asks for additional information when 4 necessary and authorizes construction activities in advance. CPCo then l

authorizes the work to proceed.

I 3 To further assure that commitments made to the NRC are properly accounted for in design documents, Consumers Power and Bechtel review the written records of comn..tments and insure that they are being incorporated into design documents.

The Project is currently undertaking an additional review of past correspondence to create a computer listing of commitments. This computer list will be periodically reviewed to insure that commitments are incorporated in design or construction documents in a timely fashion.

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PERFORMANCE OF PROJECT CONSTRUCTION, QUALITY ASSURANCE AND QUALITY CONTROL ACTIVITIES

To assure that project construction, quality assurance and quality control personnel correctly carry out their appointed tasks, a number of measures have been taken, including a reorganization of quality control, upgraded training 1 programs, direct Company involvement in construction scheduling and control, and utilization of a contract format to minimize any cutting of corners by j contractors. These elements of enhanced performance are described more

! specifically below.

l First, the project has reorganized the Soils QA-QC effort, creating an

integrated organization with single point quality accountability under the i MPQAD. This new organization is expected to improve QC performance, increase l CPCo involvement in the management of the quality control function and improve 4

QA-QC interfaces.

Second, extensive training programs for the soils underpinning work have been l developed. This overall training program, which includes the major

Construction and Quality organizations involved in soils work, covers both

( general training in quality and specific training relative to the construction procedures.

] The majority of the personnel associated with Remedial Soils work have i attended a special Quality Assurance Indoctrination Session. The QA

! indoctrination has been provided to Bechtel Remedial Soils Group, CPCo oc0982-0232a100-164

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. 4 Construction, QC, QA, Mergentime and Spencer, White and Prentis (SW&P) personnel down to the craft foreman level. This training consists of one three-hour session covering Federal Nuclear Regulations, the NRC, Quality ,

Programs in general and the Remedial Soils Quality Plan in detail.

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With regard to the work procedures, a requirement on both Mergentime and SW&P is that specific training on the procedures be provided prior to initiating any quality related construction activity. The identification of individuals to receive this training is spelled out in each procedure pertaining to a specific construction activity. Completion of the specific training requirements is a QA hold point which must be satisfied before work can proceed.

In further recognition of the importance of training to the underpinning work, the Company is utilizing a mock-up test pit as part of its training program for underpinning construction. The purpose of this test pit is to provide specific training in the construction of a pier, bell and grillage assembly from initial issuance of design drawings through completion of construction.

This allows supervisory and craf t personnel to perform work under the conditions, requirements and restraints which will be encountered when the actual underpinning starts. It also allows the various quality organizations to inspect the work and insure that their concerns and requirements are properly reflected in the procedures.

Third, to further enhance the performance of key project organizations, Consumers Power will maintain control over scheduling, both through the construction authorization process and by frequent meetings with the involved contractors and subcontractors. Each week, underpinning subcontractors will present proposed construction work to the Company. In addition, to assure the best quality work, the major subcontracts were entered into on a time-material basis. This should improve subcontractor attention to detail and acceptance of owner direction in the performance of specific construction activities.

Last, the Company is establishing a separate Quality Improvement Program (QIP) for the soils project. Although not part of the formal Quality Assurance program, the QIP is a management system that should be helpful in communicating and reinforcing project policies and expectations to all project participants. To launch this effort, an indoctrination program will be presented to all individuals, stressing the absolutes of Quality and the concept of "Doing it right the first time." Measurements specific to soils will be developed for those critical areas which are indicative of a " quality product". Tracking these activities will provide an indication of the effectiveness of the program. The QIP will provide mechanisms for individual

" feedback" from all individuals involved, including the craft personnel.

INDEPENDENT ASSESSMENT A third party will be retained to independently appraise the initial phases of the construction of the auxiliary building underpinaing. This consultant will be mobilized as soon as possible and, af ter familiarizing itself with the design, will evaluate the auxiliary building underpinning construction work at oc0982-0232a100-164

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the site. If significant problems or adverse trenda are observed, the third '

party assessment program will be extended in both scope and duration until a l satisfactory conclusion can be drawn. The initial evaluation will be carried out over a three-month period.

The independent assessment 'll be conducted by a team of nuclear plant

construction and quality an ,,ince experts. This team will be supplemented by the additon of an underpinning consultant who will review the soils design documents, construction plans and construction itself to assure not only that the design intent is being implemented but also that the construction is consistent with industry standards. The assessment will further assure that the QA Program is being implemented satisfactorily and that the construction is being implemented in accordance with the construction documents.

Arrangements are being made with Stone and Webster Engineering Corp to assume the lead role in this appraisal. They will be assisted by Parsons, Brinkerhoff, Quade and Douglas, Inc who will provide underpinning expertise.

The NRC will be appriced of all findings of this independent assessment in a timely manner.

ORGANIZATION, MANAGEMENT INVOLVEMENT AND NRC OVERVIEW The project organization formed for the performance of the soils remedial work incorporates single point accountability, dedicated personnel to the extent practical, minimum interfaces particularly at the working level, and a quality organization integrating QA and QC. The soils project organization is

{ tailored to the task at hand. The entire organization, including quality assurance and quality control are staffed with well qualified, experienced personnel, augmented by design consultants and construction subcontractors nationally recognized in the underpinning field.

The soils remedial ef fort will also include a high level of senior management involvement. Project senior management will conduct weekly in-depth reviews on site of all aspects of the work including quality and implementation of commitments. In addition, the reporting chains to the senior project personnel have been shortened. The Company's CEO is briefed on a regular basis and schedules bi-monthly briefings on all aspects of the project including soils. During the bi-monthly briefings, the CEO normally tours the Midland site.

Complementing the CPCo management role, NRC Region Management overview of the construction process will be enhanced by monthly meetings, agreed upon by the Region, to overview the results of the quality program and the progress of the soils project. These meetings will cover any or all aspects of the project of general or special interest to the NRC management.

CONCLUSION Based on the discussion outlined above, CP Co believes that the soils program has been thoroughly and critically evaluated and that all prerequisites for successful implementation have been or are being accomplished. The Company's program, with the initial overview f rom the independent implementation assessment, and the continuing overview by the NRC staff and management should oc0982-0232a100-164

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6 provide adequate assurance that the remedial soils activities will be successfully completed.

JWC/ JAM /bjw CC Atomic Safety and Licensing Appeal Board CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB RJCook, Midland Resident Inspector RSDecker, ASLB SGadler JHarbour, ASLB GHarstead, Harstead Engineering DSHood, NRC (2)

DFJudd, B&W JDKane, NRC FJKelley, Esq RBLandsman, NRC Region III WHMarshall JPMatra, Naval Surface Weapons Center i

W0tto, Army Corps of Engineers WDPatton, Esq i SJPoulos, Geotechnical Engineers FRinaldi, NRC HSingh, Army Corps of Engineers BStamiris i

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CONSUMERS POWER COMPANY Midland Units 1 and 2

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Docket No 50-329, 50-330 Letter Serial 18845 Dated September 17, 1982 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 information regarding the implementation of the Consumers Power Company

Quality Program for the Midland Plant soils remedial work.

. CONSUMERS POWER COMPANY By ~

J fCook,"Vice President Projecys, Engineering and Construction i

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Sworn and subscribed before me this /'/ - day of -

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s Notary Public Bay County, Michigan My Commission Expires # - '

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