ML19309D361
| ML19309D361 | |
| Person / Time | |
|---|---|
| Site: | Marble Hill |
| Issue date: | 03/06/1980 |
| From: | Shields S PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19309D357 | List: |
| References | |
| NUDOCS 8004100291 | |
| Download: ML19309D361 (7) | |
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PUBLIC SERVICE March 6, 1980 INDIANA S. W. Shields V ce President Ucctret System Mr. James G. Keppler, Director Docket Nos.:
STN 50-546 U.S. Nuclear Regulatory Commission STN 50-547 Region III Construction Permit Nos.:
799 Roosevelt Road CPPR-170 Glen Ellyn, Illinois 60137 CPPR-171
Dear Sir:
In accordance with the provisions of Section 2.201 of Part 2, Title 10, Code of Federal Pegulations, Public Service Company of Indiana, Inc. (PSI) offers the following information, which is supplemental to its letter of November 1, 1979, in response to the items of noncompliance identified in Inspection Report numoored 50-546/79-11 and 50-547/79-11.
Item of Noncomollance (546/79-11-01; 547/79-11-01)
Public Service Indiana has not sufficiently implemented its Quality Assurance Program at the Marble 11111 Plant Site.
For example:
a.
The management support, qualifications, numbers and methods of operations of the site QA/QC group have been inadequate to assure that extensive licensee and contractor noncompliances have been identified, documented and corrected.
b.
At least 25 of 29 members of the site based Quality Control Organizataion do not have sufficient QA/QC and construction experience to qualify them for their current QC Organization assignments and to this extent PSI procedures for personnel qualifications (CMP 3.10 and QAP 6.8) are nonconforming as implemented.
c.
The PSI Marble Hill Ge'nerating Station Construction Management Procedure Number CMP 3.7 which provides u004100b 1000 East Main Street, Plainfield. Indiana 46168 317. 839.9611
Jf Mr. James G.
Keppler March 6, 1980 PUBUC stRVICE INmANA Instructions for "stop-work" authority does not provide adequate independent authority to the QC Organization, inspectors and engineers to prevent unsatisfactory work and assure control over subsequent resolution of identified nonconformances.
Corrective Action Taken and Results Achieved All construction work on nuclear safety-related systems and structures has been stopped.
PSI retained an independent consultant, Management Analysis Company (MAC), to perform a management analysis of the PSI Marble Hill project.
The results of the analysis were submitted to the NRC on October 9, 1979.
PSI is implementing the results of that evaluation as described in its February 28th submittal to Mr. Victor Stello, Director, Office of Inspection and Enforcement, U. S.
Nuclear Regulatory Commission.
Corrective Action to Prevent Recurrence a.
The following improvements have been or are being made to the PSI Quality Assurance organization:
1)
The Quality Assurance Organization has been revised to provide additional supervisory capacity.
The Organization has been divided into three (3) major functions (i.e.,
inspection, engineering and quality systems), each with a superintendent or manager.
These functions have in turn been subdivided to provide eleven (11) additional superintendents or supervisors.
Key positions have been upgraded from supervisors to superintendents or managers to attract persons with more applicable experience.
The Quality Assurance Manager reports directly to the Vice President-Electric System and is therefore free from undue cost and schedule influence.
The Quality Assurance Manager also has further access to senior PSI management through Executive Review Committee l
Meetings held at the site and through the PSI Quality l
Assurance Review Committee Meetings.
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2)
A Quality Engineering group has been added to the Quality Assurance Department.
This group is responsible for preparation of inspection procedures or checklists which contain accept / reject criteria to be used by the PSI Quality Assurance inspectors.
Quality Assurance inspectors will not be allowed to deviate from these criteria without written authorization by their supervisors.
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r Mr. James G. Keppler March 6, 1980 PUBUC SERVICE INDIANA 3)
The Quality Assurance Organization, as well as other project organizations, has been reorganized to incorporate dual manning of certain key supervisory positions where PSI did not have the requisite nuclear experience.
These positions will consist of two individuals, one consultant and one permanent PSI employee.
The consultant function will be experienced in nuclear power and will initially provide direction for the position.
The direction will then be turned over to the PSI counterpart consistent with that person's experience and ability.
Individuals now in the Quality Assurance Management positions, which include both PSI and consultant personnel, range from five (5) to more than twenty (20) years of applicable experience.
Experienced PSI counterparts have been hired for the Quality Assurance and Quality Engineering Managers' positions.
The PSI Manager Quality Engineering has already reported to the job; the PSI Quality Assurance Manager is scheduled to report in Mid-March.
4)
Management and administrative improvements have been instituted to support Quality Assurance, as well as other project functions, in order to attract and hold experienced personnel.
These improvements include:
1.
An overtime pay policy for exempt employees has been instituted.
This plan is intended to address nonincidental overtime needed to complete the regular duties of a position.
Such overtime normally occurs on a construction site like Marble Hill.
ii.
A shift pay program has been instituted for exempt and semi-professional employees assigned to the Marble Hill construction project.
This l
program is intended to address sporadic shift work which typically occurs during the l
construction and startup activities of a large construction project.
iii. An additional construction site pay allowance program has been revised and extended to include all non-bargaining unit employees assigned to PSI station construction sites, iv.
A comprehensive relocation expense allowance program has been instituted to address the special circumstances involved in relocating the Marble Hill Engineering and QA/QC functions to the site.
C Mr. James G. Keppler March 6, 1980 FUBUC GERVICE INDIANA v.
The Employment Manpower Committee no longer functions for the Marble Hill project.
This facilitates a prompt response to manpower needs.
vi, A review of PSI exempt and semiprofessional employee positions has been made against an industry survey of salaries.
Adjustments were made in PSI levels to assure that they were competitive with industry practices.
5)
All Quality Assurance personnel have been relocated to the Marble Hill construction site to assure closer coordination of efforts and support of Quality Assurance efforts related to construction.
Coincident with the organizational changes, the PSI Quality Assurance Program as documented in the PSI Quality Assurance Manual has undergone revision both to recognize organizational changes and to improve the effectiveness of the program.
a.
A review of the qualifications and training records of all PSI Quality Assurance personnel is being conducted to verify that experience and qualification requirements are met.
When personnel do not meet qualification requirements, they shall oe considered unqualified and shall not be used for functions requiring qualification.
When qualification standards allow other factors to be used in lieu of experience requirements, PSI shall not use this option unless performance is demonstrated through documented training and verified by successful completion of a written or performance examination.
b.
The stop work practices contained in the PSI Quality Assurance Program have been changed to address the need to be able to immediately stop further processing of items to preserve or assure quality.
PSI Quality Assurance surveillance, inspection and audit personnel now have full authority to stop further processing of items when nonconformances are discovered.
This stop work authority does not require prior supervisory approval.
In addition, the Quality Assurance Manager has been given wide authority to stop activities as needed to assure quality; this authority is of a broader nature than that delegated to the inspectors and can be applied to a category of activities if deemed necessary in Quality Assurance Manager's judgment.
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F Mr. James G.
Keppler March 6, 1980 PUBUC MRVCE INDIANA Date When Full Compliance Will be Achieved The Quality Assurance reorganization is complete.
The revised Marble Hill Project Quality Assurance Manual has been approved by management and issued for use on February 8, 1980.
The qualification review of PSI Quality Assurance personnel, including verification of proper qualifications and removal of certification for personnel not meeting qualification requirements will be completed by March 31, 1980.
Item of Noncompliance (546/79-11-02; 547/79-11-02)
It was determined that, even though Chicago Bridge and Iron Weld Procedure Specification E7018/73030, Revision 1, dated June 20, 1977, underwent reviews by various organizations, including Sargent & Lundy, the reviews failed to identify the omission of the weld technique to be used for passes other than vertical up and overhead, and included the same omission in subsequent revisions.
This weld procedure was being used to weld safety-related tanks on the site.
Corrective Action Taken and Results Achieved Corrective action was addressed in PSI letter number 1102795066 of November 1, 1979.
Action Taken to Prevent Recurrence The PSI Quality Assurance Organization has been changed as discussed above.
Quality Engineering Superintendent positions have been established in four disciplines (Civil, Mechanical, Weld /NDE and Electrical).
The groups reporting to these Superintendents are being staffed with experienced personnel.
Each discipline Superintendent is responsible for review of contractor procedures and for monitoring the performance of Sargent & Lundy in its review of contractor procedures for PSI.
Date when Full Compliance Will be Achieved.
Reorganization was achieved on January 2, 1980.
Item of Noncompliance (546/79-11-04; 547/79-11-04)
Established measures did not assure that conditions adverse to l
quality were promptly identified and corrected.
For example:
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6 Mr. James G. Keppler March 6, 1980 PUBUC scnvtCE INDANA a.
PSI Construction Management Procedures numbered CMP 3.1 and CMP 1.4 are insufficient in both text and implementation in that in many instances, sufficient corrective action to prevent repetition of significant conditions adverse to quality has not occurred, b.
PSI was made aware of serious issues involving noncompliance and potential noncompliance with ASME Code requirements regarding owner'r responsibilities and material certification docume.its in July, 1977; June, 1978; July 13, 1978; May 14, 1979; March 9, 1979; June 6, 1979 and July 27, 1979, by virtue of letters on these dates from site contractors identifying these issues.
However, no comprehensive and conforming corrective actiors were initiated until July, 1979 after a National Board of Boiler and Pressure Vessel Inspectors' Inspection Report regarding these matters was issued.
Corrective Active Taken and Results Achieved All construction work on nuclear safety-related systems and structures has been stopped.
An extensive evaluation and reorganization of the Quality Assurance Program and organization has been performed as described above.
Action Taken to Prevent Recurrence a.
A quality trending system which is capable of identifying and grouping the causes of nonconforming conditions has been developed.
This trend information will be provided to supervisory personnel within the Quality Assurance Organization as well as to PSI management.
This trend information will allow PSI to detect repetitive nonconforming conditions by cause and take corrective action to "fix the cause".
b.
PSI has developed an ASME Marble Hill Project Quality Assurance Manual incorporating ASME Code requirements for PSI acting as a piping systems N Certificate Holder.
PSI has filed application for and received an N Certificate Interim Letter of Authorization which provides ASME approval of the PSI Quality Assurance Program related to N Certificate Holder responsibilities.
In developing its Program to meet ASME Code requirements, PSI has obtained the assistance of experts in the field.
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Mr. James G. Keppler March 6, 1980 PUBUC SERVICE INGANA i
Date When Full Comoliance Will be Achieved a.
The quality trending system will be fully functional by March 15, 1980.
b.
The ASME Marble Hill Project Quality Assurance Manual incorporating N Certificate Holder requirements was approved by PSI management and issued on December 18, 1979.
The ASME Survey for purposes of an Interim Letter of Authorization was also completed on December 18, 1979, and the Interim Letter issued on February 4, 1980.
Should you have any questions, please contact us.
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