ML19210B914

PSC of in Project Diagnostic.

ML19210B914
Person / Time
Site:	Marble Hill
Issue date:	10/02/1979
From:	MANAGEMENT ANALYSIS CENTER, INC.
To:
Shared Package
ML19210B905	List: ML19210B907 ML19210B910 ML19210B914 ML19210B918
References
FOIA-79-239 NUDOCS 7911130040
Download: ML19210B914 (21)

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. TABLE OF ONTENTS

.e Page I. I NTR OD U C T I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 IT. S UM%"R Y . . . . . . . . . . . . . . . . . . . . . . . ............................. 3 III. GEi!ERAL CONCLUSIONS.......................................... 7 IV. GENERAL RECOMMENDATIONS...................................... 8 V. SPECIF IC IMPLEMENTI NG RECOMMENDATIONS. . . . . . . . . . . . . . . . . . . . . . . 11

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i I." INTRODUCTION Public Service Company cf Indiana, Inc. (PSI) has suspended ccnstruction of iti Marble'5ill Nucleai- Generating Station. An order frca the United States Nuclear Regulatory Commission confiming that suspensicn has been issued. In crder to assist PSI in restarting construction under prcper j conditions and controls, Management Analysis Company (MAC) performed a diagnostic evaluation cf the Marble Hill Project. The diagnostic focused primarily on the areas of Quality Assurance, Construction Management and

. Project Managem2nt. The purpose of the diagncstic was to provide the management of PSI with a measure of the overall Quality Assurance and management effectiveness of the participati1g organizations in the Marble Hi.ll project. Additi onal ly, it was to provide a frameucrk for any neces sary correcti ve a cti ons. This report summarizes the MAC evaluaticas and recccmendations for appropriate acticn to restart con-strucci ca at the Marble Hill Nuclear Generating Station. It provides recommended organizational realignments to effectively manage the sccpe, schedale and cost of the project at the necessary level of quality.

By nature, a repcrt such as this focuses cn problem areas with appropri-Tte soluticns in order to be of maximum value to executive management.

!M, as a policy, prepares management diagnostic reports in this manner to w.'.e the executive aware of problem areas only. Thrcughout the project there are fine management systems and suborganizations in place which were functioning well with excellent staffs. This report is not mm m - -

intended to highlight those areas.

D CC C .- J During the evaluation, a team of experienced personnel frce MAC inter-viewed invc.ved personnel frcm PSI, Sargent & Lundy Engineers, Newberg Constructi on Ccmp a ny , Cherne Constructicn Company, Ccmmanueal th-L ord Joi nt Venture and the Ccmmonwealth Edison Ccmpany. The i ntervi ewees represented the functicnal portion of the project - Engineering, Quality Assurance, Constructi cn Management, Li censi ng, Startup and Test, Pur-chasing Ccntracts, Perscnnel and Finance - and personnel in the plants being replicated. These people were stationed at the Marble :iill site, the corp ora te headqua rt ers at Plainfield, Sargent & Lundy Engineers offices in Chicago, and the Byron statica in Illinois whi ch is the m

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replication model for the Marble Hill station. A team of ten experi-enced pecple from iMC reviewed a nd evaluated the results of these interviews to prcdued this report. The team represents over one hundred thirty years cf cc:r:nercial nuclear experiende associated viith more then one hundred nuclear pcwer generation projects.

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SUMMARY

MAC believes that PSI's approach to the management of this project parallels their excellent fcssil pcwer plant expe ri en ce. However, the macnitude, complexity, and demands of a nuclear project exceed those of There are greater material quantities and components of a fcssil unit.

every type. The systems are more ccmplex. The demands for quality assuranc2 are more rigcrcus and the safety and licensing requirements are more s tri n' gen t. A higher level of exparience with ccamercial nuclear pcwer plants is required to efficiently dval with these problems than is presently available cn the Marble Hill Project. The deficien-cies in the C"'gcry I concrete whi.ch led to the PSI order and the HRC order confirming suspending constructicri are a symptom of this lack of experience.

The replication concept adopted by PSI after sel e cti on of the basic comp onent supplie rs is excellent. Almost certainly it reduced the engineering costs, licensing prcbl ems , and overall schedules when related to a custom plant. The combinaticn of the replication concept and fixed price ccatracts has solid merit for further minimizing the ccst of the project. However, the number of detailed changes occurring at the base plant, canbined with the lack cf ccetercial raclear ex-perlenced perscnnel at the site, diminished the full potential cf this combination to the extent that the currently anticipated cos t and schedule may Le impacted significantly. It is MAC's opinien, hcwever, that the original cost and schedule anticipations, even with the benefits of .eplit.ation and fixed price contracts, were t" cptimistic There has been insufficient overall scheduling and integration of major contractor efforts at the site. As the project proceeds into the more complex combined mechanical, piping, and electrical phases, the need for integraticn will grow. Withcut a strong and aggressive program of integrating contractor efforts, PSI can expect additional change orders and delays that will edd to the cost cf the project.

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_4 PSI's contractors at the site require more experienced ccmmercial nuclear personnel. PSI's insufficient attention to Newberg's QA/Qg, combined with the lack cf t experienced personnel in bcth crganizations, has been a contributing factor to the Category I concrete problems. .

Additionally, Newberg planning ef forts are too short range and do not a

provide a sufficient basis for planning by the electrical, piping, and mechanical contractors. The pipi ng/mechani cal contractor, Cherne, i

appears to be developing a detailed network planning approach. It has not however, been prcpe rly integrated with the master schedule.

C cc:nonwe al th-l.ord 's planning efferts and QA/QC procram seem to be starting cut well, however it is too early to gat a clear indication of their capabilities. It should be noted that it is difficult to objectively measure the performance of any cf the contractors without an i ntegrated schedule netwerk aggressively managed by PSI as the construction manager.

The Vice P res ide nt , Electrical System, became the de facto Project Manager in the latest reorganization. The combi nati on of his vice presidential duties and the proj ect management duties may exceed the capaDilities cf a single manager. There is a need for a project manager with strong nuclear experience to manage the project and report directly to the Vice President, Electrical System. This person must have the full authority to act and resolve problems expediticusly. The chart set forth in Figure 1 is a suggested apprca ch to organizing the project effort.

Of major importance to the project is the management di recti on of an equally experienced Project Quality Assurance Manacer, to be located at the site. The Quality Assurance staff must have the capacity and expe-rience to reccgnize devel oping prcblems early and cust also have the ability to wcrk with the Project Manager in a team effort to institute solutions before problems become major.

In order to b-2 completely ef fective, the Project .' tanager and the Project Quality Assurance Manager cust have proper tools to be able to work with D* *)

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all the parties in the preject. Thus, an integrated total project plan must be develcped and the prcper project centrol tcols and measurement devices which are already avsilabla must ba more ef fectively used. The e.<is ti ng mat < ri al controis system shculd be improved and integrated to provide better support for corstruction activities. A revised baseline cost and schedule estimate should be established in order to properly measurepedcrmancear.dprogress.

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III. GE?iERAL C0fiCLUSIO?iS The Category I concrete problems that led to the suspension of ccastruction wre primarily a result af insufficient comnercial nuclear experience ~ within PSI and its contractors. The ccncrete probl ems primarily involved workmanship. It was brought to our attention that the inspection and technical analysis of existing concrete is underway to demonstrate that there are no 5- ..ni fi c a nt safety probl ems. After necessary repair work has been dc: .ied and carried cut under the h nuidance of experienced and qualified construction and quality assurance personnel , the plant sh'oul d meet nuclear stancards. The existing personnel, when supplemnted with sufficient experienced personnel and more effective management tools, can in the future manage and ccmplete the Marble Hill station within a . reasonable tim and at a reasonable cost.

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IV. GENERAL RECOS"<ENDATIONS These general reccrmendations are pcsitive steps that PSI can take which will assist in improving the timely and cost-effective construction of the Marble Hill Generating Station with the requisite quality. These are based on MAC's assessment of M ?ble Hill and are as follcws:

A. Changes in Project Management A Project Manager should be established fcr Marble Hill reporting directly to the Vice President, Electri c System. He should have j

all activities reporting him with the exception of Quality Assur-l ance. It is also recormended that a seasoned Quality Assurance Manager be hired for the Marble Hill Project.

B. Quality Assurance It is reccr:nended that the Qualitv Assurance crganization and program be restructured and staffe; with experienced pe rs onnel .

j The objective is to provide a " hands cn" QA management t 3am that is i

structured to emphasize the importance of preplanning cf activities 1

to maxinize problem prevention. Present staf fing numbers at the requisite experience levels are more than adequate to cperat: the QA function effectively.

C. Excerience and Staffing Levels Specific areas in the project organizaticn have been identified as needing increased staff. Experienced personnel must be brcucht into key positions to strengthen the proj e ct team. This can be acccmplished by hiri ng key personnel in certain areas and by supplementing existing PSI personnel with experienced censulting support perscnnel en an as needed basis. .

D. Management Focus Due to the significance of the Marble Hill proj ect to the overall financial picture cf PSI, it is recc.rmended that the President and Vice President, Electric System attend a monthly site meeting that 0

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focuses on everall project status, definiticn of problems and establishment cf a key action list.

E. Centralization of Activities at the Site There is a need to relocate some forces and functions fraa the headquarters offices in Plainfield to the constructicn site. This need is primarily in the areas of cost and s chedule , material centrol, document control, contract administraticn, and Quality Assurance / Quality Control.

F. Byrcn Liaison It is recomended that the benefits of the replication approach be enphasized through the assignmarit of key personnel at the Byron site to provide early information on any problens and the as-built configuraticn.

G. Activity Intearction A project of this magnitude and complexity requires closest coor-dination and integration to minimize ccst and schedule. It is recommended that the use of a scheduling resource tool such es the PREMIS progra:a (presently in existe'ce at PSI) be expanded to utilize its full capability in integrating the activities of PSI, S&L and major contra ct ors . Additicnally, it is reccmmended that the material management program as presently structured around the existing PIE system be further expanded and develcped into a mcre effective management tool.

l H. Financial Controis and Manag2 ment Reacrts Financial controls associated with contractcr change ceders and contract administration should be improved. It is recommended that a full time financial auditor be assigned to the site. An evaluaticn should be made fer potential improvements in nanager.ent reports, document control and design change centrol.

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I. Effective Use of Fixed Price Centracts The fixed price apprcach utilized by PSI has solid merit ice controlli ng costs. Fixed price ccntractors tend to place their best persennel on the job and labor tends to be more supportive.

To derive the maximum benefits of the fixed price construction contracts in the environment of constant change, PSI should in-vestigate breaking down the sccpe cf existing . centracts i nt o scaller elem2nts and aggressively monitoring then at the site by more experi enced pe rsonnel augm2nted by contracts administration people. Significant nuclear experience in ccatract monitcring and admi nistrati on is a necessary ingredient to handling changes and minimizing cost and schedule irspacts. A larger staffing level is required to effectively accccplish this.

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V.' SPECIFIC IMPLEMENTING RECOMME.NDATIONS In crder to derive maximum banafit from the general recccnendaticns, the followinh specific implementing recomcendations are suggested:

. A. The Project Manager's effectiveness can best be maintained with an

' organization such as shown in Figure 1, Project Managemant Organi-i -

zation.

B. The functicns of contract er administration and proj ect auditor shculd be created and staf fed with suitable persennel en site. PSI project financi al rep crti ng practices chculd be reviewed and appraised with respect to adequacy to meet management's need for apprcpriate information for decisions.

C. Activity integration can ba best echieved with the follcwing steps:

1. Revise Master Schedule, validate and integrate Engineering, Materials, Construction and Startup.

2. Put CRTs cnd printer in field.

3. Establish area system cf controls.

4. Combine tha ccst systcm with PREMIS.

5. Outline specific management reports.

6. Develop a six-month action plan. (See Section E.10)

7. Redefine the weekly ccordination meeting.

8. Transfer the Precurement-Inventery-Expediting (PIE) system to the ficid and integrate with PREMIS. Revise PIE procedures to nake it more useful.

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D. Because of the importance cf the Marble Hill project to the o/erall financi al picture of PSI, risk analysis acpraisals s hcul d be

initiated by PSI management < These appraisais weeld be initiated by a re-validatica of cost and schedule activities using g probabilistic techniques. Based cn those results, a series of contingency plans should be prepared for a series of possible tctal costs. The impact of the proposed Capital Ccst Recovery Act should be included in the analysis. Likewise, a series cf contingency plans shculd be prepared for delayed startup dates as indicated by

,the risk analysis.

E. In staffing and develeping the project organization, the following issues should be considared:

1. PSI should continue its re-evaluaticn of salaries for project pe rscnnel . PSI should consider revising its overtime policy and special site pay (relocaticn and/or par diem) for exempt pers cnnel who are required to work extended overtime because cf conditions beyond their control.

2. MAC believes that the major effort of the Constru cti on i Engineer s hc .'l d be in the preplanning of the work with the contra ctors. The purpose of this plan is to ,centify potential p, oblems, interpretation of regi i remant s , control points, etc. This perci ts a unified approa ch whi ch is beneficial to all concerned. The area team must be intimately i nvol ved with the contra ctors and should l ock ahead to minimite pecblems.

3. Hard copy drawings, specifications and reference becks (codes and standards) shculd be made scre readily available to the PSI construction staff.

4. Improved formal ar.d informal rcutine communications must be established between the PSI site and hc e of fi ce. Reports shculd include a " lock ahead" aspect in additien to "where we D 7.I '9' f ~. -

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are" and "this is what we have dene" approaches. The reports

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should incl ude overall project status, quality trends, significant events, potential and actual problem areas and their reccmmended or ccepleted resolutions, alcng with respon-sible personnel and timetable for resolution.

5. There is a need to train everycne en the jcb in his area of perfc.~ nance and on the necessity cf a ccaitment to quality.

This includes parsennel such as clerks , pipefitters, junior engineers, and managers and shculd be done in a manner which will improve their effectiveness. It is suggested that a formal training and indoctriration program be given to each empl oyee before the site is s'.a rt ed up and then on a continuing basis.

6. A Material Ccatrols organizaticn shculd be established en the site under the PSI Construction Management crganization. This crganization will handle all procurement, expediting, and materi als problems associated with Marble Hill. After the purchase order is issued, the responsibility cf the control of the material should rest with this organization. It should provide total centrol of the material including do ,en tat i ca, equipment quality veri fi cati on, storage, preventive mai ntenance end vend or payment releases. All constructi co contractors shoul d i denti fy specific PSI supplied material requirem2nts for work packages well in advance of the construction activity. Material schedules shculd be updated and maintained current. The present systen should be expanded to incorporate all material and equipment brought on the site. The program should be expanded to include constructica and startup spares and have provisions to add cperational spares. Institute use of PIE in the field with the use of CP.Ts.

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Due to the volune of changes it cppears centract a6ninistra-tors should be assigned to each ccatract to ad.ninister changas in the field. Arrangements should be rnade which icproves PSI control over changes.

8. PSI shculd initiate a study of the design change system with particular emphasis en the following:

a. Use of a single design ch arge form for field generated changes regardless of whether chey originate with PSI or cont ract ors .

b. Utilizaticn, if pcssible, of the existing form c.nplcyed by Byron such that approved Byron changes can be utili.ed Jirectly en Marble Hill.

9. Establish a proj ect planning and scheduling centrol crgani-zatica in the field which includes the functional elements of Pl a nni ng , Scheduling, Cost Engineering, Estimating, Data Management and Material Control

10. Develop an immediate interim pian which will carry the project for the next six months while the detail staffing, planning, schedule and controls are established. The interim plan should deal with such issues as; organizatienci structure, perscnnel assignments, site f acilities, construction restart (incl udi ng analysis of exi sti ng concrete and any ne ces sary repair werk), re-inse action of safety rel a ted work as necessary, project procedures and controls, ccst and schedule estimates and risk analysis, material ccatrol systems , Byron liaisca, NRC reviews, a tctal long range project plan, and executive reviews.

11. The restructuring cf the site organizaticn with apprcpriate definiF.cn of jcb authority will establish clearer lines of responsibility and authority, and eliminate the present duplicaticn of QA/Q functions and c onst ru ct i on engineering mm m 3-9

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', f unct i on. PSI s hcul d rewrite their Ccnstructica l'anagement Manual and clearly defina the goals and objectives such that they are structu '?d and provided with the r.ecuscary procedures to control the proje ct without duplicaticn with QA/Q.

Responsibilities shculd be clearly established for prccessing I cf changes, planning / scheduling, contra ct administratica, material managemant and engineering.

F. The required improvement in the Quality Assurance crganization and progra.r.s wculd be enhanc2d with the folicwing specific recommen-dations:

1. Reunite the Quality Assurance and Quality Control functicas under one qualified manager located at the site. A suggested organizatica is shown in Figure 2, Quality Assurance Organiza-tion.

2. Reviw and assure understanding cf the PSI Quality Assu ance c%rter and its role of ccnceptually managing the quality assurance efforts of the A/E, NSSS suppliers and on site contractors.

3. Establish a program 'or formal QA on-site review of contractor quali ty programs.

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4. Provide guidance to centracter crganizations in quality

' a chi evement, but neither preecpt nor relieve contractor

! responsibility for achieving and veri fyi ng the quality required under the centract.

5. Clearly define the uninhibited au th cri ty of PSI Quality Assurance to stop the performance of unsatisfactory work.

6. All l:?.C exit i nt e rv i e'- a should include key contractor personnel involved in the audit.

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NECilANICAL QUALITY EfiGIf1EER (2) QA SYSTEMS (1) I!!SPECTIO?i (1) OPERATIO!15 (2)

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Review and approve contractor o

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7. QA/QC manpcuer ceilings should be maintained at their current  !

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8. As QA manual sections and procedures are revised to reflect changes brought about by reorganization and by react %ation cf  !

Category I construction, include as a goal the simplification >

of procedures and prosisicn of clear definitive ir,structicns h en how PSI Quality Assurance performs its work. I o

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9. There is a need to have piping isemetrics reviewed by the A/E I to reduce the cozibility of errcrs in A/E drawing interpreta- I.

tien, errors i r. i ns tal l at i cn, interference, snubbing [

and L support. Consider requiring the piping fabricatica and t.

p installation drawings be reviewed and signed by the A/E for [

conformance to design. Determine by surveillance and audit 0-t i

that such reviews and approvals have been made.  !;

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10. PSI Quali ty Assuran ce should revic.v with cont ractors their h precedures for preparing inspection planning and checklists to \:

p assure that adequate definiticn of accept / reject criteria is h

provided and to assure that he carplated document will be satis f actory for a quality assurance record, including iden-f' L

tification of the inspector and varification that requi red i cuality was attained.

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11. N Establish a centralized document centrol at the site with the rasponsibility of receiving, distributin, and dispensing all h E.

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techni cal project documents, and for assuring that prope r [

i-revie.rs and approvals have been acccmplished prior to release, for identifying prcper drawing and specification status for assuring, through a receipt mechanism or similar process, that b 1

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12. Establish a manual filing capability for QA reco-ds at the site. Identify required quality reccrds and established suitt21e centrcls to assure their cd e q'ta cy upon receipt or i completien and their integr:ty, safety and security. Pes tpone I

the microfilming of QA records until after plant acceptance.

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13. Utilize the current lull in constru cti on to evaluate all reccrd packages where the hard ccpies have been destroyed to determine if there are any dccuments that a re nct cl early readable when rr-produced from microfilm /mit f i ch e. Initiate a program for the replacement of any su ch legible records while supplier /centractor criginais are still available.

14. Disccntinua the practice cf enhancing contractor documents for reproducti on purpcses. Requirn pr oirp t replacement with acceptable and reproducible docu nnts. .

15. Initiate a program of interfa .ng with cther utilities or with records management experts, to determine staffing facility and equipment requi rements for document control and records stcrage.

16. Reassess the storage progrm with assigned responsibility for a storage maintenance program. Expedite receipt cf ccmponent ma nufactu rers ' instructions for storage mai ntenance.

Institute a QA surveillance program to assure requirements are met.

17. Establish an cn-goi ng program of reduci ng all significant problems to a QA action list. The review cf the actica list should be an important adjunct to weekly QA meetings, with schedulcs updated and referrals made to apprcpriate levels of management to accceplish the action. The key objective is to retain cognicance of a prcblem until it is finally resolv- .

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18. Establish the quality trend analysis prcgram as an integral part of the management informtien system.

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Prior to a restart of safety related work on Marble Hill, two actions shculd be taken with respect to the contractors. A [

general raview . cf centractual ccmmitments should be made to b s

define in detail the cccmita. ants of the contractors to imple- 5 mentatien of the QA program. This should specifically address I staffing levels, qualifications and number and level of work instructions required to support the crafts. An in-depth J

quality assurance audit should be conducted en each major contractor to evaluate their overall QA programs.

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v As a result of the contractual review and audit noted above, a determination cf action items required prior to restartup should be made and documented. This action list should include all QA requirements as well as any additional project

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management requirements , and should be pursued in weekly [p meetings which include the Project Managers and QA Managers of

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both PSI, Newberg and MAC recccnends that Newberg continue to [

k acquire supervisica with nuclear experience a nd provide '

additional training in placement of Category I ccncrete. This _b program must be expanded to develcp detailed training for k i

n crafts personnel in areas for which they are going to L,

participate in the placement activities. I.

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Cherne and Cccmenwealth-Lcrd QA prcgrams were locked at in F detail. With the exceptien of the review and approval problem b f(

p associated with Cherne isometric drawings, there is not a y notable QA problem. These contractors should be :nitored h ci csely hcwever, as they are in the early stagt cf prcgram implement ati on.

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