ML20040E316

From kanterella
Jump to navigation Jump to search
QA Dept Procedure A-1M,Revision 3, Organization. Bechtel Audit Repts Encl
ML20040E316
Person / Time
Site: Midland
Issue date: 02/01/1982
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20040E307 List:
References
A-1M, NUDOCS 8202040170
Download: ML20040E316 (52)
v • d • e


Text

{{#Wiki_filter:. ENCLOSURE 3 MIDLAND PROJECT Consumers QUALITY ASSURANCE PROC NO A-1M j p0WK o DEPARTMENT PROCEDURE PAGE 1 0F 7 C0mp3Q REVISION 3 ORGANIZATION DATE 2/1/82 l ~_ 1.0 PURPOSE To define the Midland Project Quality Assurance (MPQA) Department organization and the responsibilities and authorities of each organizational segment. 2.0 SCOPE This Procedure applies to the MPQA Department. 3.0 DEFINITIONS None. s 4.0 REFERENCE DOCUMENTS 4.1 Quality Assurance Program Policy 1 4.2 Quality Assurance Program Procedure 1-1 (Volume II). 5.0 PROCEDURE 5.1 Department Organization and General Responsibilities The MPQA Department is responsible for setting Quality Assurance standards for design and construction of the Midland Nuclear Power Facility consis-tent with CP Co objectives, and for assuring the establishment and implementation of quality policies and procedures to meet these standards. In performing their responsibilities, MPQA personnel have no responsibility for overall project cost and scheduling; have the authority and organiza-tional freedom to identify quality problems, initiate, recommend or provide corre'etive action and verify implementation of corrective action; and are independent from the individuals or groups performing the activities being inspected, tested or audited. Additional Quality Assurance-related activities, as given below, are assigned to.MPQA for work performed either by CP Co or by principal suppliers, major subcontractors and subtier suppliers, or the activities may be done in conjunction with or be delegated to a principal supplier's corresponding organization. MPQA retains responsibility and authority for these activities and for assuring their adequate and timely accomplishment. The objective of the assignment of responsibilities and authorities to MPQA is to yield a total Quality Assurance Program resulting in the attainment of a facility which is de-signed in accordance with its design basis criteria and which is con-structed in accordance with its drawing and specification requirements. The MPQA Department reports directly to the Midland Project Office as described in Reference Documents 4.1 and 4.2 above. The management consists of the Director, Environmental and Quality Assurance; the Manager; the Site Proj ect Quality Assurance Superintendent and the Assistant Manager. 8202040170 820128 PrIO80-0045a112 PDR ADOCK 05000329 G PDR

MIDLAND PROJECT COMM QUA1.lTY ASSURANCE PROC NO A-1M c L ) POW 8f DEPARTMENT PROCEDURE PAGE 2 0F 7 CORipaq REVISION 3 ORGANIZATION DATE 2/1/82 Administration and Special Projects. Attachment A provides the MPQA organization and reporting relationships. Following is a discussion of their responsibilities: 5.1.1 _ Director, Environmental & Quality Assurance The Director, E&QA is the most senior manager in the MPQA Department and a member of the Project Office. He has direct line respon-sibility for the MPQA Department. 5.1.2 Manager, MPQA The Manager, MPQA, reports to the Director, E&QA, and is responsible for the overall administration and management of the MPQA Department especially with regard to: 5.1.2.1 Planning, scheduling and resource allotment; 5.1.2.2 Coordinating CP Co reviews of conditions for reportability to the NRC under the requirements of 10 CFR 50.55(e) and 10 CFR 21 and, as necessary, reporting to the NRC; + 5.1.2.3 Providing direct supervision of the QA Services and HVAC QA Sections. 5.1.3 Site Project QA Superintendent The Site Project QA Superintendent reports to the Manager, MPQA:and is responsible for: 5.1.3.1 Supervising the Fluids and Mechanical, Civil, Electrical and Instrumentation QA Sections; 5.1.3.2 Providing the primary MPQA Department interface with other CP Co departments and contractor organizations located at the site; 5.1.3.3 Coordinating activities in support of NRC site inspections; 5.1.3.4 Preparing responses to NRC site inspection reports. 5.1.4 Assistant Manager - Administration and Special Projects ,The Assistant Ma, nager - Administration and Special Projects reports to the Manager, MPQA, and is responsible for: 4 ~~ - pr1080-0045a112

MIDLAND PROJECT gg QUALITY ASSURANCE PROC NO A-1M l pg DEPARTMENT PROCEDURE PAGE 3 0F 7 gggq REVISION 3 ORGANIZATION DATE 2/1/82 5.1.4.1 Supervising the Administrative Group; i 5.1.4.2 Providing staff assistance to the MPQA Department l management; 5.1.4.3 _ Administering the department's personnel aquisition: 5.1.4.4 Representing the department in the Quality Improvement Program; 5.1.4.5 Preparing management information documents. 5.1.5 Within MPQA, there are five sections and an Administrative Group. The five sections are: Fluids and Mechanical Quality Assurance, Civil Quality Assurance, Electrical and Instrumentation Quality Assurance, HVAC Quality. Assurance, and Quality Assurance Services. The four discipline oriented sections contain within them Quality Assurance Engineering (QAE) and Inspection, Examination and Test Verification (IESTV Groups). The IE&TV Groups include NDE & Welding, HVAC Inspection and Verification Activity Groups. Following is a discussion of the responsibilities of each of the sections and the Administrative Group. 5.1.6 The QA Services Section and the Quality Assurance Engineering Groups are responsible for: 5.1.6.1 During the design concept activity for any CP Co design work, preparing the Project Quality Assurance Plan and assuring the Plan's timely issuance with the mutual concurrence of the organizations involved. ~ ~ 5.176.2 During the design activity, assuring that the established engineering procedures are followed through review and audit of the engineering function. _ __5.1.6.3 During the hardware and services procurement activities: Establishing or assuring the establishment of supplier a. quality assurance requirements;

  • b.

Performing preaward supplier evaluations for quality assurance and quality control activities;

  • c.

Preparing plans and procedures for procured item l inspections, nondes,tructive examinations and tests; ~ pr1080-0045a112

MIDLAND PROJECT Comm S QUALITY ASSURANCE PROC NO A-1M l ! POW DEPARTM.ENT PROCEDURE PAGE 4 0F 7 COMP 3Q REVISION 3 ORGANIZATION DATE '2/1/82

  • d.

Evaluating and, when specified, approving supplier quality assurance related documentation.

  • For CP Co direct procurement's.

5.1.6.4 During the construction activity: Preparing plans and procedures for the inspections, a. nondestructive examinations and tests (other than checkout, preoperational, hot functional and major modification tests and functional tests for the establishment of in-service baselines) for installed items for use by Department personnel; b. Reviewing and approving of Bechtel Quality Control Instructions and B&WCC Field Construction Procedures; Participating in the resolution of hardware and c. systematic nonconformances and obtaining process corrective action. 5.1.6.5 During the checkout, preoperational, hot functional test activities: Reviewing the Project Testing Program Manual with a. respect to compliance with the Quality Assurance Program and annotating satisfactory completion of such review by a concurrence signature; b. Auditing the individual preoperational, hot functional and functional in-service baseline test procedures to assure: 1. The preparation of procedures in compliance with the requirements of 10 CFR 50, Appendix B; ANSI N45.2; Quality A*earence-related Regulatory Guides, codes and se a, arc:; and CP Co procedures; 2. The establishect t ~ ality-related prerequisites for the perfota.a rash test; 3. The adequacy of the data collection format and content relative to the needs of the Quality Assurance Program regarding quality records. pr1080-0045a112

MIDLAND PROJECT QUALITY ASSURANCE PROC NO A-1M l j l l DEPARTMENT PROCEDURE PAGE 5 OF 7 ggggg REVISION 3 ORGANIZATION DATE 2/1/82 i Preparing procedures for the inspection, nondestructive c. examination and test verification of preventive and corrective maintenance activities. 5.1.6.6 Throughout all activitiest Assuring the maintenance and reporting of hardware a. design quality and corrective action status; b. Reviewing Principal Supplier reports of nonconformances for adequacy of their program implementation; Evaluating the implementation of the Quality Assurance c. Program and recommending improvements; d. Reviewing and concurring (or approving) of other Midland Procedures which are quality related; In accordance with Title 10 of the Code of Federal e. Regulations, Parts 21 and 50.55(e), making the determination as to the need to report any noncon-formances and test deficiencies to the NRC; f. Preparing 50.55(e) reports and responses to NRC Construction I&E Reports; 8 Issuing "Stop Work Orders," as appropriate; h. Performing quality audits; 1 i. Certifying NDE personnel. (This responsibility is vested in the QA Services Section only.) ( 5.1.7 The Inspection, Examination and Test Verification Groups are responsible for: 5.1.7.1 During the procurement and installation activities, performing source, receiving, fabrication, assembly and installation inspections, nondestructive examinations and i tests (within the MPQA jurisdiction - other than checkouts, and preoperational, hot functional and functional tests for the establishment of in-service baselines) and determining l the acceptability or nonacceptability of hardware items. 5.1.7.2 During preoperational and hot functional test activities, performing maintenance inspection, examination and tests (within the MPQA jurisdiction). pr1080-0045a112 l

MIDLAND PROJECT CMMMW5 QUALITY ASSURANCE PROC NO A-1M N l POW 81 DEPARTMENT PROCEDURE PAGE 6 OF 7 C0mpaQ REVISION 3 ORGANIZATION DATE 2/1/82 5.1.7.3 Prior to the performance of the preoperational, hot functional tests, and the functional in-service baseline tests, directly verifying the accomplishment of quality-related construction prerequisites and signing off on each such prerequisite to signify: That there has been a turnover acceptance of the test a. unit (s); b. That each nonconformance and deficiency, both preturn-over and post-turnover, has been identified; c. That each such nonconformance and deficiency has been adequately dispositioned. 5.1.7.4 At any time, prior to or during the performance of the checkout, preoperational, hot fynctional tests, and functional in-service baseline tests, auditing compliance with other prerequisites, signifying the prerequisites actually audited by the application of a QA signature for each such prerequisite. 5.1.7.5 During the performance of the checkout, preoperational, hot functional tests, and functional in-service baseline tests, evaluating compliance with test procedures on an audit and surveillance basis, signifying the test procedural steps actually audited and s,urveilled by the application of QA signatures adjacent to these steps. 5.1.7.6 During the performance of the preoperational, hot func-tional tests, and functional baseline tests, contributing to the identification of plant quality status by trans-mitting MPQA-originated NCRs to the testing organization for their incorporation into the overall plant status accounting system. 5.1.7.7 Throughout the construction activities: Issuing "Stop Work Orders," as appropria'te; a. b. Making the initial determination as to the need to re-port any nonconformances and test deficiencies to the NRC; Identifying inspection and examination problems and c. test problems within MPQA's test jurisdiction, and causing their timely and adequate correction; pr1080-0045a112

MIDLAND PROJECT QUALITY ASSURANCE PROC NO A-1M q' ggg DEPARTMENT PROCEDURE PAGE 7 0F 7 REVISION 3 I ORGANIZATION DATE 2/1/82 d. Assuring that nonconforming items identified on CP Co NCRs are properly dispositioned; e. Evaluating the implementation of the Quality Assurance Program and recommending improvements; f. Assuring effectiveness of site principal and subtier primary quality control activities and conformance of all construction and installation activities to the established Program Procedures through audit and over-inspection. 5.1.7.8 Certifying MPQA personnel to perform inspection and test. 5.1.8 The Administration Group is responsible for: 5.1.8.1 Performing departmental administrative functions, especially with regard to department reports and records. 5.1.8.2 Coordinating departmental quality assurance education, training and indoctrination. 5.1.8.3 Maintaining systems to trend quality data to identify adverse repetitive quality conditions. 5.1.8.4 Maintaining tracking systems of quality open items. 5.1.8.5 Participating in audits. I i l l l l l l i 6 I pr1080-0045a112

O 9 i ATTACHMENT A MIDLAND PROJECT PROC NO A-1M Consumets QUALITY ASSURANCE s PAGE 1 0F 1 I I Power DEPARTMENT PROCEDURE Company REVISION 3 DATE 2/1/92 ORGANIZATION I i 1 i f ( N a 8 Pd I aE Om se s e sw g s CE S5 o o' = = EO S S SG m w< z z 4 I I I ( mJ M d5 SM w .M 50 -r am 5 35 S5

  • O W<

SG "a W g' w w

  • o w

o N M a w mN< EN i "2 E ES 9 S o = <a E S ew g a E O e 3 a' o ~ 5 = e 3 -c = m 5 ] Ed E x 0S g m m e e m h w 8 -e S M m a w-Q S M 2 ga .e E k 5 S E 2 3 = = aE 5< E Ec <M C Su C CW c5 O M5 SG 8 ~ $~ g 2 w w S-8 E l o k d W wa e E g -N b E a <d a EmE wSE E 5 = l CQM U E w g m i I I f I g

  • t C

O = <a d M <d W S5 az w n d5 i ~ a w* w z

A e 0 4 e-ENCLOSURE 4 e IEEBusb saarne= orrrat TTCE FREstB5BT runC J W Cosa i StuacNR, INT!soggerfAL Am sant.ITT "***F' 3 W merges 11e I assum Fu MET SIALOT AassRasCE nar-M C-e a W merwisLie C-s s Armoute (see'r) RusadW C4 W 3 atre C4 L 81eaeres (Ses*FI 7taa t-a s A Dietrica

  1. D d L Peserees (See'f) l 8!TI eaALOT

~ AAB'T RASAGER amIAAsCT ABN[I & SPECIAL mrumm sunrat==s 84 5 L Curiama (3/1) C4 S M Twete11 l I f l l FfADE & sere *81 CAL c rY". a ermire x a I aa sxxvicts fva: a na E!IDE ERAD 8EcTIOS EIAD ~ $3cT:Os EEAD sat:Tes ERAD SECT 205 EEAD C.s a g Sere C.s u J senseffer eC4 J L unsee C-8 3 P f-q f*.4 W Aserter C-8 E A111oes (See *T ) e Evac 3 en 2302rIRIm; a rv3try tsc a Iss:Trr3I3c anst!III"taf!!B 223III A E3C ' O ga g gyWTIS M e4 "WN SIFWTISta (3(3p strygyrtyg SIFEIT!stm

  • .4 i Per8er C.4 a t whitaaer 40 J A Bersea C4 4 8 Eeole to.g g gegeer C-8 N Setterfieed
  1. B.A 3 Jma (See'y) 8.e T E Toms as a C Sired C-8 E 3*be e,g SC N

C N Ce C4 & 3 Gert e4 J n.i t j C-8 8h y 36 4 C & Oles AEf e 83FTE* "4 E A N#8'***

    • 4 J Tesemen To.4 J D&samen j

C.8 J Deeses M D 8 Reta g,g g g,g, C.e E Beree 8 NoCas,se To.8 C4 T unseg

  1. t=A E Eirtleed eg g g,,3_

.g a., C.g C Thesesse M L Susano e.g r.., mn, Bd 3 messe I2Af' SEIFERT13tm f3E3MM 34 C5 er g g M.e 64 9 t teve gyggggg og crm y t,,seen o =- -e . so y ggg 34

  1. C Shen IaC Cree 9 a=4 9 t wta 6-4 F sommaantster
  • .4 C E Earwur
  • =8 I E 1***' '

e=4 J D1stenair M e B esseroom 88 5 Palmer e.e O C 5eserts = es &Im o G.8 7 Peset C.4 9 Peels e.g B 4 EteeJoes F *- '33 hMS e.g a y 9-- Elastrieel og C.e o a seat f teeds sta 6 1:.'Isc

    • 8 3'******

N Leee'n e.e my,33 e.g gg w EE A 3 FECIAL 37 - "Mt? I g.g J B Beeter SEGEEEIS ggygyggggg C4 8 9 Doets arWTrana 88 W v stiler 64 1 R Charette C.J J t unsee e,g 9 ed O E saltanes EFee? At ame?"AEffS I C.J 8 8 Gereae

  • -8 J Sets g,,g 9 g g,g,,,,,,,, {

C4 F in Launde e4 Euf-e. J orr C4 5 L 81eeep C e CDCs 8 e aseatek m, m-e e Chetreet hyamyge 8 e Bate SIPEPTISc3 J e seegare

  • =0 J t.1tmerest

&

  • asa Arter e.g y g, gg,,,

e e 34 Capacity e.g gum J e anataistrettee Seppert e.g B Eaas amt am Leen e.g 0 merges (tsmersed Segerttas Datel e.S eTauretee T e Tregerary G.3 y get, l Seetoed 1/23/42 I IFC1 A13 T Z 3 ? j o.4 l 3 E Seeale j, l l I

PROJECTS. D:GINMR;!!G C0ldS51RSf3 AND CONSTRUCTION-l POW 8f M QUAUTY ASSURANCE DEPARTMENT Costpally v v '" 1 " 4 QA23-0 umw.m. nm: ::o: WRBird JARutgers M-01-24-1 CAChien/KFH AESchlaifer ra ranu JWCook 'ESmith 18.4.3.6 MADietrich DATaggart L M OF l.W IT: GSKeeley JLWood June 2 - Julv 3, 1981 BWMarguglio MPQAD Routing orsuma n::In DBMiller RAWells Bechtel Quality Control m.or " ' a/ n: AFFW T pg.::: (. T~XETr 7-2/"8/ 7'2 N / Midland 1 and 2 g l l I. AUDIT SCOPE AND OBJECTIVES The scope of the audit was training and certification of Bechtel Quality control personnel. The purpose was to assess compliance with, and the adequacy of, the present program. It is noted that Revision 4 of PSP G-8.1 became effective dur-ing the audit. Also, an assessment was made as to how the present Bechtel QC training program meets Revision 1 of Regulatory Guide 1.58 as discussed in the NRC Generic Letter 81-01 dated May 4, 1981. II. IDENTIFICATION OF AUDITORS The audit was performed by the following personnel: DR Keating - Audit Team Leader AE Schlaifer - Technical Specialist III. PERSONS CONTACTED DURING AUDIT The following Bechtel personnel were contacted during the course of the audit: Attended Entrance Attended Exit Name Title Meeting Meeting E Smith Project Field Quality Control Engineer X X E Urbanawiz QC Training Coordinator X X S Kirker QC' Lead Services IV. AUDIT

SUMMARY

A. An audit entrance meeting was held on June 2, 1981, with personnel in attend-ance as noted in Paragraph III. The audit team was introduced, and the audit scope, plan and schedule were discussed. B. Audit checklists were developed from PSP G-8.1, " Qualifications, Evaluation, Examination, Training and Certification of Construction Quality Control Personnel," Revision 3, and ANSI N45.2.6-1973. Specific sections from the documents are as noted on the checklists. Data was collected by pro-ceeding through the checklists which are attached to the file copy of this report.

PROJECTS. ENGINEERING AND CONSTRUCTION- @ POW 8f Av -] QUALITY ASSURANCE DEPARTMENT ~ M-01-24-1 urm so: m ra _2_ cr 4 C. The audit resulted in two findings which are attached to this report. D. The following observations were made as a result of this audit: 1. The amount of training in particular Quality Control instructions prior to certification varies considerably. No minimum training requirement was evidenced, nor was there documented evidence of credit taken for previous experience or certifications. It appears that considerable on-the-job training in QCIs is being performed that is not documented which provides an erroneous impression that training is less than actually performed. (Also reference AFR M-01-24-1-01.) 2. Section 8.3.2 of PSP G-8.1, Revision 3, required that the effec-tiveness of the job site training program be evaluated by a review of the Corrective Action Log described in PSP G-3.2. The.re was no documentation of this review. It is noted that PSP G-8.1, Revision 4, deletes this requirement and that the new PSPs which went into effect on June 29, 1981, do not require the Corrective Action Log. Discussion with the PFQCE indicates that, rather than reviewing the log, he has and will continue to review the MPQA Trend program output, administer the Bechtel NCR program, and through these items and discussions with his lead QCEs, will continue to direct the training program based on the PFQCE's evaluation of its effectiveness. It is suggested that an evalu-ation be made of these actions and should be incorporated into PSP G-8.1. E. The following Unresolved Items were identified: 1. Section 4.2.1.4 of PSP G-8.1, Revision 3, indicates that Level I personnel provide on-the-job training 'for uncertified constru'c-tion Quality Control Engineers as a job responsibility. It is considered that Level IIs should also have on-the-job training of uncertified personnel as a job responsibility. Consideration should be given to revising PSP G-8.1 to show that training uncertified QCEs is a responsibility of a Level II. M-01-24-1-01 (URI) 2. Section 8.3.1 of PSP G-8.1, Revision 3, that discusses monthly l training sessions, requires clarification. It has been construed previously that this section required that each QC engineer attend a minimum of one, one-hour training session per month. Presently, Bechtel QC considers that not to be the case. The procedure does not literally require all QCEs to attend a session. It was observed during the audit that some QCEs had not attended any training sessions during certain months and that others had attended only half-hour sessions during the month. M-01-24-1-02 (URI)

PROJECTS. ENGINEERING AND CONSTRUCTION - C0ftSumIf3 QUAUTY ASSURANCE DEPARTMENT l POW 8f v l COmpmf ami no: M-01-24-1 I c=r=r:ATEN W ru 3 er 4 3. There are no set criteria available for use that provides reason-able assurance that a person can competently perform an assigned task where specific education and experience requirements are not met. There also is no basis available for determining " equivalent" experience. It is not clear that successfully completing the cer-tification process is a satisfactory substitute for education and experience. M-01-24-1-03 (URI) 4. Section 8.5 of PSP G-6.1, Revision 5, requires, in part, that: "...the necessary training and orientation in the application and use of each new and revised PQCI..." prior to implementation in the field. It was observed that, in one case of ten reviewed, no training in the QCI was performed prior to certification (QCE VanDoorne in QCI C-2.10 ). This training is conducted so that each CQCE responsible for performing the inspections fully under-stands the requirements contained in the PQCIs. There is no basis for determining whether such training is "necessary" or not. Con-sideration needs to be given to clarify this point. M-01-24-1-04 (URI) F. An audit exit meeting was held on July 3,1981, with those in attendance as noted in Paragraph III. Draft audit findings, observations and unre-solved items were presented and discussed. Bechtel Quality Control did not concur with the findings or Unresolved Item M-01-24-1-03 (URI). Discussion ensued. Based on discussion and additional information pre-sented in the exit meeting, as well as discussions with Bechtel QC sub-sequent to the exit meeting, the final audit results are as presented in this report. Bechtel is requested to respond to the audit findings, observation No. 2, and the Unresolved Items. G. Responses are to be sent to: Mr D M Turnbull Consumers Power Company Midland Project Quality Assurance Department PO Box 1963 Midland, MI 48640 Responses are requested within 30 days of the receipt of this report. V. EVALUATION OF EFFECTIVENESS The Bechtel Quality Control Training Program and its implementation, in general, meets the requirements of PSP G-8.1 and ANSI N45.2.6. There are areas where clarifications and improvements would help clearly demonstrate compliance to the requirements. These items are covered in the Recommended Corrective Actions of the findings and the observations. It is noted that there have been several recent improvements and positive actions in the area of QC training. These include: 1. The naming, in February 1981, of a full-time training coordinator. It is also planned to add an assistant to the training coordinator, and upon approval,T there will be two, persons administ= ring the training pro-gram full time.

PRSJECTS. ENG1tEERING AND CONSTRUCTION-CDA$um0ft ) QUALITY ASSURANCE CEPARTMENT Power vA Company mir rn M-01-24-1 ns 4 e 4 2. The training coordinator has recently attended a formal seminar conducted by Stat-A-Matrix in training of inspection personnel. 3. Bechtel QC has obtained the " Construction Technology Transfer Program" which is a Bechtel slide / tape presentation covering various specific sub-jects such as cable terminations, cable pulling, etc. The program covers all disciplines and is being integrated into the certification process. Additional visual aids are being prepared to cover other aspects of the QC program. 4. Further standardizing of performance and oral certification is being accomplished by the QC training coordinator. 5. Bechtel QC has begun documenting on-the-job training as part of the cer-tification/ training process. This training, which has been conducted, was not previously documented and resulted in the training documentation not actually representing the total number of training hours received prior to certification. The present Bechtel Quality Control program does not meet the position in the NRC Generic Letter which proposes compliance with Revision 1 of Regulatory Guide 1.58. Education and experience are considered absolute in Revision 1, and the Bechtel program does not consider them absolute (reference Section 6 of Regulatory Guide). Also, Section 10 of the Regulatory Guide indicates that, where it is desired to establish that an individual has the required qualifications in lieu of required' education and experience, documented evidence in the form of procedures and a record of a written test must be available. Bechtel does not administer a written test or provide evida'ce in lieu of the education and experience other than certification to the QC1s. The Management Analysis Company (MAC), during their QA program assessment, reviewed one-fourth of the certified Bechtel Quality Control Engineers. Their conclusion is that the training and certification records are acceptable to the requirements of ANSI N45.2.6 and PSP G-8.1 (reference Final Report for Consumers Power Company dated May 27, 1981, MAC project No MAC-81-G-31, pages 367-369 ). VI. LIST OF ATTACHMENTS 1. Audit Finding Reports 2. Completed Checklists (file copy only)

n s PROJECTS. ENGINEE:: LNG AND CoNSTRUCTtoN- @COR$3lR$f5 AUDi~ FI ND ~N G R,,,. 301.. QUALITY ASSURANCE DEPART t

L wc-a Priority:

4 Trend: I-3(I 5) Start Up: Indeterminate AI: S 920 'u Ir caomc= msus u am.umr en smcr comsmca vira axrmacu m so noi M-01-24-1-01 ANSI N45.2.6-1973, " Qualifications of Inspection Examination, te OC and Testing Personnel for the Construction of Nuclear Power ars cT amxAncn: Plants," requires that on-the-job training be part of the Julv 3,1981 program (Section 2.2.1 Training). rra nani 18.4.3.6 While on-the-job training is conducted by Bechtel Quality cImmIrom: Control, there is no documentary evidence available that WRBird it is conducted. EAEhien/KFH/ CMC JWCook MADietrich GSKeeley BWMargug1io DBMiller JARutgers AESehl-aifer ESmith DATaggart RAWell's JLWood ALAB-2 MPQAD Routine R141PD'.kA.G CLkm7IYL AC*IION: 1. Document on-the-job training as part of the certification process. (Bechtel has begun documenting this training.) CWh4TIVE ACICN &>MITMk TI a Bechtel Quality Control did not concur that this item constituted a finding. A formal response, detailing the techtel QC position, is requested within 30 i days of receipt of this report. cArz cr c/A cose:rI:si cas. mur im es A: man = = c/AcumIMerI urs or e/A i.iie. Bechtel QC N/A ML HCL GF VDITIcATILN: BGLMGL QC A 0MentSTRATWE lusTKocTion # Bol, R& V 0, M TED l0- 4 61 PRowoGs-ThE coatMrTAfNT 70 poc vg&q7 o,j,T., gysw TwauGH S 9(o, poes nor AW TW A N) 8 A1 45'.2. (, asOprecs suca occumew7AT7ed. uasamslaa m x.m.n u,u,arsciaan m=c: IF " TIS". rINE CF RDORr M NBC: IF 713*. RAME cF MRC OTTICIAL TG WHOM Ba.nar;u: N/A Ir 7u. vuo men mDen: N/A /A J.Th WIGIMAft S ' 8 IG 'Ut.g: SNI '$ SIGAAT'JRE: c,. 7Db Im, aas+,

1 F T - 23440 AB 77.20 MIDLAND PROJECT No n N PLEASE RECDPT ANO RETURN v E N /8

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHERS O steurttonamass e

O vtaoon onamass v 1.O arraovto. uro. may enoctro 6 0 roa arraovat O uartlaatatoussarion MR O sert:ricanons S ~ 2.O sEUEmat own. uro. mar 7.0 consinucnom O mo atoutsr an O ouoranons Q

3. 0 ***aovto txcret as worto. uant s.O rattiminany ust O runenast oncen PO

$^" a'v'EttoIs ANvYo - O coarta m cr worts CN 9.D arrentact O sio summany BS 4.O nor Arenovto. conater ano nesusuit O sueCoNTRACTS SC 10.6 Compl ete response n X

5. O N"u"v Mtto' O

Y TENT 10N VENDORS: ALL FINAL DRAWINGS SUBMITTED TO b CHTEL MUST BE CERTIFIED TRANSPARENCIES.

  • * " * * " ucntu roescu re. uo. O nts

"E v5"oo" "o. acnon coot gl I ucum ou.a.o. O no MpOAn AFD M 01. 2 4 -1 01 OA'AI S-920 OC AI 1251B i I l l 'ONSUfiNJ{'f,]"y'j'Am I N F l' l1 U L F't 4f

  • F' N

i i t ..I /r/ .m. l l i NON.,,a ivo I I t i i FIEl.D OUAllllY AdsuiW JE ' MIDLAN!D, U!CH!GA N i I i l l 1 I n MENTS: i !?.. 7,:;;,,Te_...:.....I6.o D FROM D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. O VENDOR PRINT gy O OTHER N

s.. 7 r o. QC AI 1251B MPQAD AFR M-01-24 1-01 QA AI S-920 Quality Control ()C) has revised and formalized the method of documenting on the job training as an additional good man-agement practice )nly. Documentation of on the job training is as described il QC Administrative Instruction No. 801. The above action <as not taken to comply with ANSI N.45.2.6 or PSP G-8.1. As it is and has been QC's position that our training program is in full compliance with the stated require-ments. Additionally, the recent CPCo Audit of the Quality Control training program :onfirmed that the QC training program meets and exceeds ANSI cequirements. The audit did not identify any findings, but.did note that-Quality Control has a good and pro-gressively improting training program. T/N 23440 ~w e ,m--

O Bechtel Power Corporation Inter-office Memorandum To All QCE's Date October 6,1981 subject Documentation of From E. Sinith On The Job Training copies to D. l.. Daniels At Midland, MI Ext. 204 Job No. 07220 ADMINISTRATIVE INSTRUCTION No. 801, Rev. 0 1.0 Purpose 1.1 This procedure is issued to provide a standard method of documenting on-the-job training (0.J.T.) towards certifi-cation in a specific PQCI. n L 1.2 Thd checklist referenced in this instruction is used to identify the subject areas in which 0.J.T. is conducted. This checklist does not establish a minimum number of training activites or time-hours, as these variables are dependent on the availability of 0.J.T. opportunities, classroom training, personal study, and previous exper-ience. 2.0 Responsibility " The CQCE Administering training (CQCE certified level I, i II, or III in the PQCI) is responsible for identifying the training activities as shown in tha attached example (Exhibit 1). s 2.2 The QC Training Coordinator is responsible for transfer-l ing the total duration hours of training to the respec-tive individual training records (Figure 8.1 - 4). 3.0 Organizations Affected l This administrative instruction affects only the Project l Field Quality Control Organization. ( 4.0 Forms Required l 0.J.T. Checklis't & Field Training Summary. No. 7220/ QCFF-T-1 Rev. O.

5.0 Procedure A m. 5.1 The 0.J.T. Checklist & Field Training Sumary shall be processed in accordance with the instructions provided ~ on the form. The data on this form shall be neatly printed. Reference Exhibit 1 for typical entries. 5.2 The completed 0.J.T. Checklist & Field Training Sumary shall be submitted with the oral and performance demon-stration records for incorporation into the individual training record (Figure 8.1 - 4). E. Smith j Project Field Quality Control Engineer ES/SDYJEU/kib t i e O e O / e e 4

REQUEST FOR FURTHER RESPONSE l ACTICN PARTY D E PT". COM P A 4 Y E.. % rrH GC

8. E.Ce -

i E AFR. M-ol-vt-I - ol 7.zy-e t Fit. %- REFittkr.E DocJMcuT" Am. DATE op OccuM UT* em neus %. D. M. y._nonI vzu avuL. 6 - 3o 8 au = ure ,c u v., o^re , meu o 9 - 2.I-bl 10 8 1 l EVALCATION OF EAPIIER RESPONSE Ymp 9p990436 s Ays, /N ESSEMCE. ThA-T %f PitcM nM MW ALL ktsTIMr,- EFonteFMPnrrs kno r714T %me. ur oru nor BE CHAN (-E0 WITHet 3r A FogH AL P E 9 1/6 s T'. ~ YtsIG TO ADYl62 YOU ~T744-Y IT IS A 0 RD. WGutREWT TJwr hw TEAiMiNw NFFDPh to stosTIFY GLT1FirA T/oM TO AuSI N US. 2. G, IHrLv D/ML \\ M lTt A L cl21&nYA-YfoU A-ND OM 'THE -Jos rflarHI^16. SS GbcvM6xtTED lN A1) DITA 9LA i&t-Mh-T AMD BG AVA It-AM2 IM SUFFIC(2A1T OO771)L 70 P/2ovJDE rA}&CTI\\/G G-VIDGM W OF CDMPUAMm TD A M sI N t/-S. 2. (, AtJ D Anhs? G-8. I. 26 spen 0, ADDITIONAL DATA /ACTICN Rf.yuL e A FF//2 M IM G. Yat)fl JMTEMT/GM/ TD Co M PLY LUIT'n TTis hbovG. IM TMF CASE hF (>LL CEST1FIC&TIDN S FROM T'HIS 0 h-TG-VOfL\\vMLD. TM L Im-T OF THE 19e0MIhl>- AvDIT) kJPICH LUILL Fot)EJL &Y4STtM(y CER.TIFtc4Trons, E 57A6LIGHfMG. C. P[e. CortmoEoc2 m O' DISTRIBUI'ICN f ACDRESSEE LUtLL NOT PE 11&lk) IRE 4)a, ' DB MIILER l WR BIRD l ePcA Poumn

CRIGI l

l E A l DISCWSED WI'IE b, b ITl4 ON (DATE) 10-l?_- O l NEXT REPLY Atue:.u 'IO SY (DATE) ( PLEASE Ruby BY (DATE) IC 8( GIVING DATE BY WHICH NEXT REPLY CAN EE i EXFELu.v. 1 SIGNARTRE f (/ A DATE io-l2.-Ol PHONE 6-309 - - -2

r aos n20 MIDLAND PROJECT 'm c N ~ 23428 PLEASE RECEIPT AND RETURN TRd$$MNSL bRM f[1,

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHERS O secMitt onawiuos B

O vemoon onawincs v 1.0 arenovgo. ura. may enocato s.O ron aernovat O mattniat atouisition MR O secciricatois S 2.O,s,,sujrggowa. uro. may u 7.0 consinuction O sio atqutsi BR O ovorations Q 3.O arenovto txeter as notto. uant

s. O enttiminany ust O evnexast onota PO O coartatnct norts CN uG ve Ctto A av 9.O ntrentact O sio summany BS 4.O nor arenovto. connter amo ntsusuit O suscominacts SC 10.rY ('omnlete resnonse.
5. O F uEv
  • E 8E"E'o' O

x O Y ATTENTION VENDORS: ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANSPARENCIES. ! sECHfft roeECN PS, NO, O ntv' SECHfEL osaWING NO. O ao-MPOAD AFR M-01-24-1-01 OA'AT S-920 dr' A T 12 51 A l i i i 3 b I,. i,! a s ,m.i -~ P m ir A ?t\\ s p j 'il j.. 'eq.. e. is m. 4 Qf!l h l-lp-gj !) ~ h P if = yf q- !C 4 bnnn b7 4M4 i ,0 F 4 :O

1001, i i

-it L u V us:Li. tf na xjiMEUt I f.11DI Mif) G lf'HIM M i ACTION Pa6NT U t-N '#U *" ^ COMMENTS: MPM ^Ct* TING D'ATlD\\El l PAINT TO FILE _h 'E 0 0,,, y,3 , ORtc ' O FILE /b,C T3 FROM D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. i (- O VENDOR PRINT h,f p ql gd7) O OTHER E / v esa recu iersi ORIGINAL

3 ( ) / = QC AI 1251A MPQAD AFR M-01-24-1-01 QA AI S-920 After giving consideration to the request of MPQAD in QA AI S-920, and evaluating the requirements of ANSI N45.2.6 and AA/ PSP G-8.1, it is the position of Bechtel Quality Control that our current program for documentation of training is in compliance with these standards. QA AI S-920 indicated that on the job training must be documented to provide the detail necessary to render the quality of the docu-ment determinate. The following items provide more than adequate assurance that training and certification documents support qualification of Bechtel CQCEs. i i 1. Training necessary to establish the minimum level of ed-ucation is always documented in accordance with AA/ PSP G-8.1. 2. On the job training is documented when necessary to support certification where minimal related experience exists. 3. The approximate duration of which on the job training takes place can be identified by the difference between the com-mencement of CQCE training and the certification evaluation dates. 4. Finally a comprehensive oral and performance evaluation is conducted by a level II Quality Control Engineer which at-tests to the fact that a satisfactory level of training and/ or experience exists prior to certification. In view of this response, Bechtel Quality Control will continue with their current program of training documentation; however, if formally requested by the client, Bechtel Quality Control will begin documentation of on the job training relative to initial certification in a given PQCI. T/N 23428 l

N ACTION HEQUEST FOR FURTHER RESPONSE M M - t :.' \\ /~ ACTsond PARTY DEPT. COMPA N Y 6. bni D o m. tt Y Oc uT a.M _.. 19C R E F E R E OC.E Doc.Q MCMT NO. DATE os oceveur FILE*- MPG A AFiz. ti-ot -aA.t - o \\ T-2A 4i. RtA NMEL DATC "TotMY'a OATE MP4A b EVALUATOR PHONE 2. 9 + 8\\

9. - 1. -S \\

A.E. E AAir-eg. 5EI EUALt.RTION OF EARLIER RESPONSE N. S Joiskt46 wh 'tI U hteeku'tA Yn a bo it*bMS k a.co,s dfc t T"hdr.ux1J M OAtwi#d th ft1tu ck ho it. lt GmMn Fuch 04r ohnAM b Oli -~ ab t'titibN (J ffL69hi d A %aebv Y auskhhiN' yb dn -E bb 3dtn$ mask k mnh0ek r&d to. %dtits Id t R, TRn1 % d* @J 1%r p Vdt ci,$ e_, OCCO NdM @%1W TR Oobb it Ohlme cbbn m t t ~ 0 ( 0 ADDITIONAL DATA / ACTION REQUIRED he%Edo Mcamp.k s eytdatta Mini eGd O U n el d Veri dt cae ccmcurP id ois ne kt, ws r od6'dofti bef.n O Uew 06i-le hk, Itiniits d n o l, a M, M%l ts cokc.itex W 01ssin T@%ar.rdd rLa lhrb oma hu.At Jrant i .) DTSTRIBUTION UW d OI ADDRESSEE DB MZLLER F( BIRD MFQ4 FOUTING ORIGINATOR SUBJECT FILE TICKLER )[ DISCUSSED WITH d. N8 N ON (DATE) 7-A -d l NEXT REPLY AGREED TO BY (DATE) 9 \\M C-of( h / PLEASE REPLY BY (DATE) Q - 4. - 8 l GIVING DATE BY WHIGI NEXT REPLY CAN BE EX m ;1ui. SIGNATURE DATE k 8 l PHONE (([ c,, m.s,, _,,,

JOB 7220 MIDLAND PROJECT N 23415 s PLEASE RECEIPT AND RETURN E T CO BLUE COPY IMMEDIATELY 9/1/81 oart

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHERS O scenitt onawincs B

O vtaoon onawines v 1.0 aernovto. uro. may enoctro 6 0 ton arenovat O martniat atouisation MR O serciricArions S 2.O sIEEW=at own. urc. may 7 0 consinuction O sio atoutst BR O Quorations Q ' O '"a"?cu"a'n's'u'.^5 "nah"w^c?

  • O "'""'"^"y us t O rumenaston in PO t

O constatmet morts CN urc may PaoCEED As APPRovtD 9.O ntrentact O sio summany BS 4.O nor arenovto. connter ano nisusuir O suecominACis SC 10.d Complete resnonse, g x

5. O Erfu"v Wr"c'D O

Y ATTENTION VENDORS: ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANSPARENCIES. , e petun g l BECMTEL roatiGN PR No O nev. riitt VEN0on No. ACrioN Coot O rv. secutet otAwiMo wo. O "o. MPOA AFR M-01-24-1-01 OA'AI S-920 OC AT 1251 i anURllMCPRI PnW R ROMPA W H (E_ryi "iir riinut ~~ i lU [, l l [, I I

5. 1 1!
  • ISER-1 1981 FIEl:DMA%hASS$p~Gi.

s c= - '_- ? j l @Oy [ MTOLAi10,!iWICliiGAN ,1 w, INFQ FRIR l a m ROUTIN4i e s' I '1 j PRINT TO FILE l _)THIS M PV F0"a -. on_to To FILE I I/O'D I l l l l r I COMMENTS: l 1 TO FROM D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. I i O VENDOR PRINT j O OTHER r ces ronu i.ni ORIGINAL

r, a QC AI 1251 NPQA AFR M-01-24-1-01 QA AI S-920 The above reference identifies that on the job training is to be a part of the QCE certification program. It also states that on the job training is being conducted by Bechtel Quality Control, but not documented. Para. 8.5 of AA/ PSP G-8.1 Rev. 4 sets forth specific require-ments for documentation of training sessions. It is the position of Bechtel Quality Control that this reference as well as ANSI N45.2.6 Section 2.2.1 identify the documentation requirements for formal (i.e. classroom) training sessions. Quality Control is and will continue to document all classroom training sessions. Quality Control feels that this meets the requirements of PSP G-8.1 and ANSI N45.2.6. The frequency of documenting on the job training has increased in the past five (5) months for the purpose of evaluating the total amount of training being conducted within Quality Control, In summary, it is Bechtel Quality Control's position that we are meeting the requirements of the appropriate standards and procedures in respect to documentation of training. No further action by Quality Control is therefore required. T/N 23415 1

PROJECTJ, ENGINEERING AND CONSTRUCTION-COR$N18f5 AUDI.. FI \\l M) G C01.. QUAUTY ASSURANCE DEPAPTMENT Trend: I-3 I - 5_ Start Up: Indeterminate AI: S 921 uso-a Priority: 4 As In Cuc.nu vasa As am.::ac ras xxec ccer.nIc= win axmzacsst m m mo: M-01-24-1-02

1) ANSI 45.2.6-1973, Table 1, indicates that only Level II's may " Evaluate inspection and test results" and that " Reporting Bechtel QC of inspection and test results" is done exclusively by Level IIs mT CF aR::zuTzo :

2) Paragraph 4.2.2(4) of AAPD/ PSP G-8.1, Revision 3, dated Julv 3, 1981 March 14, 1980, lists " review and acceptance of report of in-rY8E'6 spection and tests results" as a Level II, not a Level I, duty mm and responsibility. WRBird

3) Quality control Instruction (QCI) 7220/C-2.00, Revision 1, CAChien/KFH Activity 3.1 calls for the following:

JWCook " Test Review MADietrich A. Review and sign Lab Test Reports verifying: GSKeeley 1. Quantity of fines is reported (PPM). BWMarguglio 2. Completeness of forms (all applicable blanks filled in). DBMiller 3. Proper date and location. JARutgers AESchlaifer B. Review and sign Lab Test Reports verifying quantities of fines meets specification requirements for: ESmith 1. Individual wells DATaggart RAWells NOTE: If fines exceed the specified tolerances, resam-JLWood ALAB-2 ple in accordance with Activity No. 2.1.B. (continued nnee 2) MPQAD Routing Ruxema caI TIvs Aerl.n: 1) Revise any pertinent procedures and instructions so as to assure that all reviews for evaluation or reporting of inspection and test results are made only be a Level II QCE. 2) If the explanation above is the official position, revise the QCI Act. No. to re-flect what the Level I is actually inspecting. (Continued on oace 2) CCA&LTIVE ACTICE CWWITMurr & Bechtel QC did not concur that it was inappropriate for a Level I QCE to sign off on Act. No. 3.1. A formal response detailing the Bechtel QC position is requested within 30 days of the receipt of this report. DATE OF C/A CDNP'JTION: CRG. RESP FOR C/A: FESCN MARIl0 C/A CuMTMerr: arr Cr C/4 umu.-ss: Bechtel QC N/A METHOD OF VDIFI"JTICN: SEE SMIAL I4)S 3 A 13 AF RIFutTAsa m N.me): gy ygs ', ;dTE GF REPWT TO 24 IF "YES*. TDS CF RIPCPT TO NBC: IF "TEs', RADE OF BC CITICIAL TU WHOM REPORTC rr Tar, m ius Rzronr: N/A N/A l m OkIGINAR 'S sCFUVISr 'S

  • N

~ l[, Y O 0 t 82-conctuma sena or ocr9/g

  1. astAr% IVI534 i

Prga 2 of 2 AFR SERIAL NO: M-01-24-1-02 PROJ/ DEPT: Bechtel QC. DATE: July 3, 1981 FILE: 18.4.3.6 t CONTINUED: "AS IS" CONDITION VERSUS "AS REQUIRED /"AS NEEDED" CONDITION WITH

REFERENCES:

4 B. 2. Average quantity of the system NOTE: If the average quantity of the system exceeds those specified,.the subcontractor has 24 hours to correct the condition. If the con-dition has not been corrected, individual wells shall be resampled and tested in accordance with Spec. C-88, Section 6.A.i tre-sampling in accordance with Activity No. 2.2.B and C)."

4) Contrary to the requirements of Paragraphs 1 and 2 above, the activity de-scribed in Paragraph 3 above was signed off by a Level I in one of five cases reviewed.

Re ference QCIR C-2.00-31.

5) An explanation was forwarded indicating that the Level I was only inspecting to ascertain that the test report was available and properly approved by a Bechtel Level II.

RECOMMENDED CORRECTIVE ACTION: I

3) Review any QC records in which a Level I QCE has performed evaluation or re-porting of inspection and test results.
4) Have a Level'II QCE review the referenced QCIR and any others identified as a result of the review in #3 above and correct in accordance with PSP G-7.1.

i

n To d FnoM DMIbrnbull, MPQAD i Consumers DATt October 9, 1981 Power SusaccT MIDLAND PROJECT .,-vi-44-1-v4 File 16.0 Serial 14153h INTcRNAL Commeswomotset cc CAChien Dehorn ESmith File 18.4.3.6 I feel the; the atdit finding takes a rather narrow view of the word " review," and that the problem is one of semantics rather than a violation of the QC program. In Activity 3.1, the inspector is inspecting a piece of paper to specific accept / reject criteria which are included in the PQCI. In my opinion, this is within his area of responsibility according to both ANSI N45.1.6 and PSP G-8.1. It is, perhaps, unfortunate that the instruction uses the word " review" instead of " inspect" or " read. " It is my opinion that the word " review" in the context of ANSI N45.2.6 involves a measure of judgment requiring experience. It differs from " inspect" which involves only comparing a characteristic with a specification or a pre-estab-lished criterion. Since both auditors involved in this audit have left the site, I am admini-

"4-'-

strativeli---,"' _.., ~..... _ DMT/ dea l l

A q 3 JOB 7220 MIDLAND PROJECT G s - 23437 No-PLEASE RECEIPT AND RETURN BECHTEL POWER CORP. BLUE COPY IMMEDIATELY TRANSMITTAL FORM 10 /15 / R 1 oart 4

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHERS O src,irst onawincs B

O vtaoon onawiacs V 1.O arenowto. urc, mar Pnoctra 6 0 Fon arenovat O mattniAt atoutstrios MR O seccincarious s 2.O sEEEnat own. uro. mar 7.0 consinuction O sao atoutst BR O ouotar a s Q 3.O arenovto exeter as notto. uant s.O entuuinany ust O Punenast onotn PO $c"Nv'en"o tro'Ea'rYaovYo ' O courtatuct worts CN 9.O ntrentact O sio summany Bs 4.O nor arenovto. conatcr ano nisusuit O sueCoNinACis SC 10.6 Complete response. n x

s. O Wo'TS#&"&

O Y ATTENTION VENDORS: ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANSPARENCIES. acIioN p l* '[ ",E'l Coot riitt vemoon No. ory. o MPOAD AFR M-01-24-1-02 OA'AT S-921 dC AT 1252R m Hii,b b-ni en:oun v i le_ p ir r d if r l Ui t W I 1 Og@9M ),,LJ, .;yuttipi49auir eqE , m <,e

rJE, v

M!DLAH D, I610H IGU Actin m uT 4 J PJ ) //3EH I INFCF" TNT 3 COMM ENTS: enna no nms i enT l WT' F l Pft NT TO FtLE IrTHIS COPY FCR g.0 TO FILE /[o, O TO FROM D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. O VENDOR PRINT gy O OTHER ces war.w iers. ORIGINAL

pn .g QC AI 1252B MPQAD AFR M-01-24-1-02 QA AI S-921 Per conversation with MPQA QAE D. Horn on 10/1/81, the Bechtel Quality Control position regarding Level I/II review and ac-ceptance of inspections was evaluated and accepted as meeting the requirements of ANSI N45.2.6. The basis for concurrence were two points: 1. When reviewing documentation, the Level I QCE is only comparing data for accuracy and completeness. 2. All inspection records with attachments are reviewed and accepted by a Level II QCE. Additionally, D. M. Turnbull letter to E. Smith #14153 concurs that AFR M-01-24-1-02 is a completed item and that no further response from Quality Control is required. T/N 23437 O

I REQUEST FOR FUPTHER RESPONSE ) s I ACTitiN PAATY O gyrr. c meAuy j E Smith Quality Control Bechtel I ~~~ R E F tW E Mc.E OccN MCMT No. DATg op Occusww Fn.E AFR M-01-24-1-02 kg 7/24/81 hs w sATc mv s oArt i upe4 e a vas.uA Ton pHous wo. g 9/14/81. 9/21/81 l A E Schlaifer X-294 EVALUATION CF EARLIER RESPCNSE Response QC AI-1252-A, dated 9/14/81, restater the BPCo position with respect to AA/ PSP G-8.1 paragraph 4.2.1, that a Level I QCE's duties and re-sponsibility is in the performance of designated inspection and tests as specified in the applicable PQCIs, specifications, etc. The response also recites AA/ PSP G-6.1 paragraph 3.3.3 which states that review means "To examine any form of documentation for the purpose of establishing its acceptability to specific requirements." ~ PSP C-6.1 goes on to state: "Signoff by the CQCE on the IR will be performed upon review and acceptance of said documentation." According to ANSI N45.2.6-1973, as recited in the earlier Request for Further Response, Evaluation of inspections and tests; Maintenance of surveillance over inspection and tests (Continued on page 2) ACOITICNAL DATA /ACTICN REUIRED Provide corrective action as 'recocxnended by the re ferenced document. DISTRIELTICN l AEDEESSEE l CB MILLER WR BITO MPCA PCLTING l CRIGINA"CR SLL M FILE TICKLER JRDecker, Cognizant QA Engr. (effective 9/28/81) Xl DISCUSSED WIIH E Smith CN (DATE) 7/3/81 NE:C REPLY Am 10 BY (DATE) x PLEASE REPLY BY (CATE) 10/5/81 GIVING CATE BY WHICH NEXT REPLY CAN BE Exemw. SIGNAn;EE la g/ M DATE 9/21/81 PHCNE X-294 (FOR MPQA SITE SUPId1INhENDENT)

4 = 9 RFFR - AI: S-921 Page 2 of 2 [ EVALUATION OF EARLIER RESPONSE: (Continued) performed by others; determining the validity - are clearly the functions of a Level II.QCE. Acceptan'ce of documentation is definitely a Level II func-tion. If " acceptance" of documentation is intended to mean merely " receipt" of documentation, then it should be defined as such. The fact that a Level'II'CQCE signs at the bottom of the IR is not relevant to the matter of Review of Documents by a Level I for Acceptability. The following tran'saction is recited frcm CPCo Serial 312FQA79, J L Corley to File 0.4.2, September,14, 1979: "....Mr Callagher countered that these people had signed Inspection Records and, therefore, they had individually accepted the items. Mr Marguglio stated each individual had signed for the characteristics he had inspected but that a Level II signature reviewing what they had done was necessary. Mr Gallagher countered by stating the Level II's were not looking at the specific " tests" that these people were performing (which, in actuality, are measurements and observations nd not tests)...." Thus, when a Level I CQCE signs an Inspection Record opposite the line word " Review" where review of documentation means " review and accept", it con-stitutes an act that is not in conformance with ANSI N45.2.6-1973, Paragraph 3.2.2a. In its response to the earlier Request for Further Response, BPCo QC failed to address the matter of the Further Request. 4 l a

n 7 JOB [220 MIDLAND PROJECT ~ N 23427 s PLEASE RECEIPT AND RETURN U W 3 7g3

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHER$

1 etcMitt osiawines B 1 vtaoonoaamincs v 1.O **enoveo. uro. may emoctto 6 0 roa arenovat i = temAt atoutstrion MR I setcaricAfions S

2. 0,s,,s,u;t y g owa. uro. May u

7.O consrauction I sio noutst BR I ovotar:ons Q

3. O y,agvjo,gt,Pt,a4Ngtg. gain t 8 0 ratuuinsav ust I rumenast omota Po I CoNFtMMCt Notts CN uso usy raoctro as arenovto 9.O atriatact I sio summaav BS 0.O nor aremovto conatcr two assusuit I suscontaacts SC 10.I] Compl e te renponMO.

1 X

5. O Ta"uIN="o8tTo' f

Y ATTENTION VENDORS: ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANS LRENCIES. En p l ",'o' coot Tifte vemoon no. ' Q TY 4 MpnAD AFD M- 01 7 4 1 0 7 QA AT S 071 ___QC AI I?R?-A = - - Nsu4GM42-Q0 map 40 Til EtlWt r v4 i i i ' 'SEP-it?-198t i -FI Elb-QtAtthAdSORMCE M10GND3110MN' i l I I I i a-c i INFOPa 173 _ dj COMMENTS: 7APO A F UTING DMTl \\ l l PRtMT 1 FILE /THIS COPY FOR @ ORIG Ti FILE /d. O TJ FROM D. M. Turnbull, MPQAD E. Smith, Qu lity Control Consumers Power Company Bechtel Powe Corp. / O VENDOR PRINT B O OTHER ces r:cu i,si ORIGINAL

r. -3 i QC AI 1252-A MPQAD AFR M-01-24-1-02 QA AI S-921 AA/ PSP G-8.1 para. 4.2.1 states that a Level I QCE's duties and responsibility is in the performance of designated in-spections and tests as specified in the applicable PQCI's speci-fications etc.. AA/ PSP G-6.1 para. 3.3.3 identifies the methods to be used for performing the inspection activities. One of these methods is the review, whica states, "To examine any form of documentation for the purpose of establishing its accept-ability to specific requirements". PQCI C-2.00 requires the Level I QCE to review the test report for completeness and ac-curacy. It must be noted that a Level II QCE has in all cases reviewed this test report previously to evaluate the results of the test and determine the validity of the test data in com-pliance with the proj ect specifications and subcontractor pro-gram requirements. This Level II QCE review and acceptance is documented on the test report. In summary it remains the position of Quality Control that the requirements of PSP G-8.1 and ANSI N45.2.6 are being met. T/N 23427

REQUEST FOR FUF;.HER RESFONK a 22" f;, ; "" ACTI O N PA M TY DCPT. CoC A W Y l C E.' Smith Qunlity Control ) BPC l ~ ' ' R E FF J E we.E Doc.u tac uT No. DATg os OccuMcut-Fit.E / b'

  • AFR M01-24-1-02 7/24/81 atuaan a. narc weavs oArt

. mee o e vet uA Toa P=eus m. 9/1/81 9/3/81 lAESchlaifer 551 EVALCATICN OF EARLIER PESPCNSE Based on the ANSI N45.2.6-1973 definition of the qualification of Level I vs Level II persons, CPCo's position is that the observations noted in referenced AFR are in conflict with the program requirements. This is vs BPC position to the contrary. \\ BPC oosition is based on the statement, among others, that: ".. 2) The Level I is only comparing data for accuracy and completeness..." According to ANSI N45.2.6-1973, Para 3.2.2a, a Level I person is quh11fied to: 1. Perform inspections and tests. 2. Be familiar with the tools and equipment to be e= ployed and be proficient in their u=e. 3. Be familiar with inspection and measuring equipment calibration and control methods. . (CONTINUED) ~ ACDITIONAL DAT.VAC"'ICN REUI?ID Provide Corrective Action as reco= mended by the referenced document. DISTRIELTICN ACCRESSEE DB MILLER WR BIED MPCA POLTING OFlGINAICR SUBJECT FILE TICE.ER 7/3/81 X DISCCSSED WI'13 E Smith CN (DATE) The Audit Finding Report noted that BPC QC did not concur with the Audit Finding, NEXT REPL'I AGREED TO SY (DATE) !X PLEASE REPLY BY (DATE) 9/11/81 GIVING CATE SY hEICH NEXT m LY CAN EE EXPEC"ID. SIGNA"GE, N CATE 9/3/81 p,t:CNE 551 POR MPOA SITE SUhERINTENDENT)

m y / n s .. -~) Page 2 of 2 Action Item No. S-921 RFFR. AFR M01-24-1-02 Continued Evaluation of Earlier Response (cont'.): 4. Verify that the equipment is in proper condition for use; And c Level II person is qualified to: 1. Perform inspections and tests. g w 2. Evaluate the results of inspections and tests. 3. Supervise or maintain surveillance over the inspection and tests performed by others. 4 Calibrate or establish the validity of calibration of inspections and measuring equipment. 5. Plan and set up tests. 6. Determine the validity of test results. 4 MN 4 4 5 e D r 9 l

JOB 7220 MIDLAND PROJECT I ~ 23416 N / PLEASE RECEIPT AND RETURN BECHTEL POWER CORP. BLUE COPY IMMEDIATELY TRANSMITTAL FORM 9/1/81 on,e

  • ACTION SUBJECT CODE ACTION FOR VEMDORS ACTION FOR OTHERS O scentet oaAwiNos B

O vsnoon onawines v 1.0 arenovto. uro. may emoctro 4.O ron arenovat O mattitiat atouisstion MR O setcaications s 2.O sEtTaat owo. urc. mar 7 0 consinuction O sto atoutst BR O ouotations Q 3.O ncenovio exeter as motto. uaits 8.O ratuuimany ust O evnenast osota Po aNe"novYo' O constatact morts CN war enoctto 9.0 attratact O siosummany Bs 4.O not arenovto countet amo ntsusuit O susconinacts SC 10.G Pnel at a va<nnnse, n x

5. O EePuEv,#Fr"t o'*

O Y . ATTENTION VENDORS ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANSPARENCIES. " "I * "' ' ' " " ' ' secutet postiow es wo. O arv' h I securst osawiwo wo. O ao-I 9" I i MPQA AFR M-01-24-1-02 I OA AI S-921 =.- O.C AI 1252 i l nkneriommAf n ona:Sti a re .,. ; a p .. m 3; i i _: 6 1%:i n c. r6 i d - h a# e,i i i i IS$Fn2 M TFi NTht}N1ThfTlst!RANCE [7,'"."_.".'? lf9 I fl101 AND. Mlf 411AN .T_'~ i 4 -,,i l mu...., g PfliNT.O FILE j l '%m '... - 1_ w e onlG TO FILE /f,, Q l j "" y l ll 1 I 'CoMM ENTS: T3 FROM D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. i l i O VENDOR PRINT f / / BY ^ O OTHER r lbca row s ets: ORIGNAL

O QC AI 1252 MPQA AFR M-01-24-1-02 QA AI S-921 Quality Control's position is that the observations noted in ref-crenced AFR are not in conflict with program requirements for the following reasons: 1) All test reports were reviewed and accepted by a Bechtel Level II QCE as being in compliance with specification re-quirements prior to being submitted to the QC department. 2) The Level I is only comparing data for accuracy and com-pletness. 3) All inspection records with attachments are reviewed and accepted by a Level II QCE as a QCIR closure function. In summary, it is Quality Control's position that the require-ments for review and acceptance of data by a Level II QCE are being met, and therefore there is no deficiency and no action is required. T/N 23416 9 7-. ~r c-

~ ConSum8IS h power Company Midland Project: PO Bom 1963 Midland, MI 44840*(617) 831 0951 October 29, 1981 Mr E Smith Bechtel Power Corp PO Box 2167 Midland, MI 48640 MIDLAND PROJECT - CONSUMERS POWER AUDIT M-01-24-1 6 Serial 14448

References:

1. ESmith to DMIbrnbull, FQCL-844 dated October 9,1981. 2. DMIbrnbull to ESmith, Serial 14068 dated October 15, 1981. 21s letter documents the closure _of Unresolved Item (URI) 03. Reference 2 documented the closure of Observation 2 and URIs _01_, 0_2 and 04. W e basis for closing URI 03, which involved the specificity of criteria used by certifiers in evaluating candidates for level I inspection certifi-cates, is described below. You stated, by telephone on October 29, 1981, that the practical training which led to certification would be shown on candidates' " Record of Training" in the future. W e MPQAD will conduct its own evaluation of the certification process and of the candidates on an ongoing basis as described in my letter Serial 14076, rather than depending on programmatic or documentary changes in the Bechtel system. We -h ve has no relationship to the matter of Revision 4 of AAPD/ PSP G-8.1 being put into effect without MPQA approval. I understand that you are working to correct this now. D M Turnbull Site QA Superintendent DMT/ dea CC WRBird, P-14-418A BWMarguglio, JSC-220A MADietrich, Bechtel QAE TKSubramanian, Midland QA

/ A 3 CORSun18tS Power COR1pBRy Midland Project: Po Bom 1963. Midland, MI 44640 e (517) 631-0961 October 15, 1981 Mr E Smith Bechtel Power Corporation PO Box 2167 Midland, MI 48640 MIDLAND PROJECT - YOUR FQCL-844, File 16.0 Serial 14068 AI: S-1087 Your response to Observation #2 is accepted in light of the way in which this observation was worded. However, you are aware, I am sure, that the auditors involved in this audit are no longer on site, and so your responses must be evaluated by different personnel. This naturally introduces some different thoughts on the subject. As I see it, Rev 3 of AAPD/ PSP G-8.1 contained a commitment to evaluate the ef fectiveness of the job site training program on an ongoing basis. Revision 4 of this document deleted this commitment and I am unable to find anything which replaces it. Your response, referenced above, says you do evaluate the program on a continuous basis, which mades me feel comfortable about the pre-sent, but the deletion of the commitment causes me concern about the future, and must be viewed as a degradation of the program. I would appreciate your comments on this aspect of the problem, and I would also appreciate having a print of the MPQA approval of Revision 4. We are not able to find it in our files. l Your response to URI-01 is eccepted in light of the wording used in 4.2.1 of Revision 4, which can be read as saying that providing training to uncer-tified QCE's is a duty, as opposed to a responsibility, of Level I personnel. The thrust of URI-01 was that such responsibility should rest with Level II people, even if the actual work was delegated, on occasion, to a Level I. Your response to URI-02 is acceptable. Your response to URI-03 does not resolve the basic problem we have. My interpretation of Criteria V and XVII of 10CFR50 is that QCE qualification folders should contain enough data to permit objective evaluation, by a third party, of the competency of the individual to perform his assigned tasks. At present, all we have is a certificate that in the opinion of the certifier, based on unknown criteria, the person is competent.

i rs 1 Serial 14068 2 j We do not record any details of the certifier's evaluation of an applicant's past experience, or his assimilation of training, or the nature of the questions he asked during the oral examination. This does not permit independant evaluation of the process or the capabilities of the person, i which is the intent of criterion XVII of 10CFR50. It is also my opinion that the guidelines provided to the certifier lack specificity, particularly in the area of education and experience require-ments, and what deficiencies in these areas can be made up for by training. We frequently rely on Section 5.1.2 of G-8.1, which abrogates the specificity of Section 5.2, but without providing alternate speifics. This places all our reliance on the personal judgement of the certifier, which can vary from person to person and from time to time, depending on how badly we need people. Bearing in mind that the competency of existing personnel is to be evaluated by an upcoming special audit, and that improvements to the program we make l now need not impact past activities, it is requested that you approach this i subject in a constructive manner and see if you can provide the documentation necessary to eliminate the need for special audits in the future, or the need i for MPQA to witness certifications. Your response to URI-04 is accepted. D M Turnbull MPQAD Site Superintendent DMI/tkm 4 ~i CC WRBird JWCook MADietrich BWMarguglio DBMiller RAWells JLWood i DCC 18.4.3.6 r 4 e I

z i t m20 nn ulia r.ogin Bechtel Power Corporation F)ECEIVE n ~ b 00T141981

  • " ".'* Michigan 48640 g
  • *
  • 2iu Midland FIELD QUAL!iY A3SURANCE October 9, 1981 MIDLA.!D, MICHIGAN B

ACTION Pf11NT 6C INFO PRINTS Consumers Power Company uPoa nouTiNo ourl l l P. O. Box 1963 Midland, MI. 48640 PntNT ro rits Attention: D. M. Turnbull )THIS COPY FOR

Reference:

Midland Project, Units 162 CPCo Audit #M-01-24-1 Observations 2 6 4 URI's as detailed below FQCL-844

Dear Mr. Turnbull:

Reponse to M-01-24-1 Observation #2: Quality Control evaluates the effectiveness of the QC training pro-gram on a continuous basis through previously established programs i.e. review of NCR's, MPQAD Trending etc.. Therefore, Quality Control has determined that a revision to PSP G-8.1 is not war-rented. Response to M-ol-24-1-01 URI: PSP G-8.1 Rev. 4 aara. 8.3.1 requires that a one hour minimum training session 3e held at least once each month by a Level II or III CQCE. Additionally, training records substantiate a signi-ficant amount of training for uncertified CQCE's by Level II CQCE's. Therefore, Quality Control has determined-that a revision to PSP G-8.1 is not warrented. Response to M-01-24-1-02 URI: Clarification of PSP G-8.1 Rev. 4 para. 8.3.1 is as follows: these training sessions shall be attended by CQCE's . consistent with work operation in progress, it is logical to assume that a CQCE may not have a minimum of one hour training per month. Although we strive to give all CQCE's a minimum of one hour training l a month, PSP G-8.1 Rev. 4 does not specifically require that all CQCE's receive a minimum of one hour training per month by a Level II or III. i i i i

Becntel Power Corporation Mr. D. M. Turnbull October 9, 1981 Page 2 Response to M-01-24-1-03 URI: Current requirements in PSP G-8.1 Rev. 4 require that an oral and performance evaluations be made by Level II's prior to issuing certification in a PQCI. " Equivalent" experience is evaluated during training for certification. Because a prior determination of "how much" training an individual will require cannot be made by reviewing a resume', all perspective' applicants for certifi-cation receive standard orientation and PSP training. Additional training in specific PQCI's varies depending upon how quickly the applicant " picks up" or. the paper flow and actual field work operations. Response to M-01-24-1-04 URI: In the case stated, Mr. Van Doorne's verification of training exists in the proper completion of Appendixes 8.1.1 and 8.1.2 of PSP G-8.1 Rev. 4, the oral and performance documentation, with the recommendation of certification statement in the remarks section on the bottom of the forms. Additionally a completed QCIR reviewed and approved by the Level II or III giving certification assures that the candidate can perform the work operations. As stated above the determination of whether the candidate was ready for certification was based on interviews with the QCE during on-the-job training. If you have any further questions concerning the above, please contact this office. Sincerely, E. Smith Proj ect Field Quality Control Engineer ES/SDK/BTF/jmk

^ JOB 7220 MIDLAND PROJECT - 23440 s 3 No PLEASE RECEIPT AND RETURN TRd$NINA"L NRM f),Y1 g

  • ACTION SUBJECT CODE ACTION FOR VENDORS ACTION FOR OTHERS O secMitt onawincs B

O vtwoon onawincs v 1.O arenovio. uro. may emoctro 6 0 ton arenovat O unitmiat atouisition MR O seteiricarioas S aPenovto 2.O susuggowc. uro. uay 7.0 constaverion O sio atoutst BR O ovotations Q 3.O aernoveo excter as notto. uant s.O ratLaulNARY ust O PuncHast omotn PO N"mav'pwYetto' s ANNvYo ' O courtatmet morts CN 9.O ntrentact O seo suumany BS

4. O mot arenoveo. coenter ano nesusuit O suecominacts SC 10 (f f'omplete response O

X

5. O ErE'*uYv en" oft"#>'"

O Y ATTENTION VENDORS: ALL FINAL DRAWINGS SUBMITTED TO BECHTEL MUST BE CERTIFIED TRANSPARENCIES. p l ' ', ' ' "E'- TITLt VENooR No. Coot o ry. ,o. MpnAD AFR M 2 4 01 1 I O_A 'AI S - 9 2 0 OC AI 1251B I i 'OQEKK.9 i ~ ??lS ~' "'i 3l' A ? "i i 1, d' _,: 1.i li U L F3 s. r 'Y f i NOV2-71% i I i ! FIELD DUAltiliY AhuiN JE MIDiAND, f/!CN! GEN 1 i ii 6ImT ggr I I g' _u__ COMMENTS:

y--

g I ~ $l. d ya..a e;. 3., -- j g G.- .a a-:. TO D. M. Turnbull, MPQAD E. Smith, Quality Control Consumers Power Company Bechtel Power Corp. O VENDOR PRINT gy, O OTHER

s ras:u insi ORIGINAL j

r, .m o O QC AI 1251B MPQAD AFR M-01-24-1-01 QA AI S-920 Quality Control (QC) has revised and formalized the method of documenting on the job training as an additional good man-agement practice only. Documentation of on the job training is as described in QC Administrative Instruction No. 801. The above action was not taken to comply with ANSI N.45.2.6 or PSP G-8.1. As it is and has been QC's position that our training program is in full compliance with the stated require-ments. Additionally, the recent CPCo Audit of the Quality Control training program confirmed that the QC training program meets and exceeds ANSI requirements. The audit did not identify ar y findings, but did note that Quality Control has a good and p o-gressively improving training program. T/N 23440 l l 1

PRsJhCTS. It41NEr.R;teG c-O 4-- I A!;D CONSTRUCTtoN- . t.LM Yh jf, by CI3 CA23 1 D.UE OF ISSUANCE: YS i $ 'W I## mm ISSUZD TO: J/dlutgers, 2.!echtcl-Id m"n In: Eird, P-14-418A BWMarguglio, Midland (M RAD) MOl-72-1 )! Cook,P-26-336B JAMooney, P-14-115A , a -,

Daniels, CQCE, Bechtel (AA)

DReia, Bechtel (AA)-MPQAD(DQAE) M01-72-1 bavis, Bechtel (Site) ES=ith, MC(Bechtel-Site) M ictrich, PQAE (Site) DATcggart, JSC-206B ]/Q%'t i L*.Dreisbach, Bechtel (AA) Audit Team (Sect. II-AR) DGrcenvall, Bechtel (AA) wtgt.Sf @ %1te ~ um n/=> -

  • sm:T

.:.cr unn.m :.rua/ pus >:CCar 12 4-81 (Aut. ( S u,,e C & y 7z.,4.pt m1d I. OBJECTIVE & SCOPE ' Die objective of this audit was to evaluate the adequacy and i=ple=entation of the Bechtel Site Quality Cont.ol Inspector training and certification program. 'ibe scope of the audit included witnessing the inspection performance de=onstratiens and oral excminations of candidates for inspection certification to specific Inspection Plans for each discipline, reviewing personnel records and reviewing inspector training plans. (level I & II) f II. AUDIT TEAM 'Ihe Consu=ers Power Company audit team consisted of the following personnel: WCCarr, Group Supervisor-Quality Audit; Audit & Manage =ent Syste=s - Team Icader RDDavis, MPQAD (Site) Welding - Auditor (Level II) ~~ LRHowell. MPQAD (Site) Fechanical IE&TV Supervisor Auditor (Icvel TTT Dehorn, MPQAD (Site) Civil QA Section Head (Part-Ti=e) Auditor IcVel III G3,, G4, Cl3a) RESevo, MPQAD (Site) Civil, IE&TV Supervisor (Part-Ti=e) Level III) ELJones, !@,AD (Site) Electrical /I&C - IE&TV Supervisor !(Ievel'III)> ^) SP A...m GIEichardson, BPCo QA Staff-Auditor { if". III. PERS0mEL CONTACTED DURING AUDIT DEC151931

  • +MADietrich, PQAE/MMAD,)Bechtel (Site)

FIELD gg AssANCE

  • RAMoray, QCE-BPCo (Site m RKSiple, Lead QC Services, Bechtel (Site)

Ml9LANO,,WIONIg g

  • ES=ith, PFQCE, Bechtel (Site)

^

    • EUrbanaviz, QC Training Coordinator, Bechtel Site In addition, various other Bechtel inspection personnel vere contacted by the Audit Team.
  • Attended Audit Entrance Meeting Only
    • Attended Audit Exit Meeting Only
      • Attended both Audit Entrance & Exit Meetings IV.

ENTRA' ICE MEETING An Entrance Meeting was conducted on Nove=ber 2,1981 with those personnel, identified in III above. During the =coting, the audit purpose and scope were discussed, the audit plan was cresented, the audit sequocce,vas ciscusseu n.rp g the audit co==unication chaanels were established. l J

PROJECTS, EWelhE2RIMG -] AND CcNSTitUCTioH- )' 4 a ouAuTY AsSunAncz cePAaTuo3T / rnen -1 no../ @a=g2ny 'Wp'"'Mol um:=r est: W p l V. AUDIT SUMMAR1 l A. Areas Audited Bis audit was limited to the qualification and certification process of ' Bechtel's QC Inspectors, therefore, co=pliance to Procedure PSP G-8.1 'was the only area audited. B. Findings, Unresolved Items & Obserfations. i Within the scope of the audit, there were no findings nor unresolved ite~s identified, however, there were two (2) observations (reco=endations) in the areas of certification oral examinations and training facilities. (Reference Attachment A for details) C. Audit Evaluation he Audit Team reviewed the records of Inspection Personnel for accuracy .end co=pleteness in co=pliance with the procedure PSP G-8.1. he following re' cords were reviewed: e Oral Examination i e Perfomance De=onstration Physical Exa=ination e e Training e Certification of Qualification e Education & Experience Completed QCIR for Each Certification o 2 e quantity of records reviewed for each disciplinary area vere as follows: Civil,- 12 (Ievel I) o Electrical /I&C-50(40-IevelI&10InvelII) e Nelding - 11 (Icvel I) e Mechanical - 10 (Icvel I) e -90(IcVelI)-oral /PerforanceEvaluations here were no deficiencies identified in any of the records related to ~ inspector qualifications. he Audit Tecm witnessed the Oral / Performance de=onstration examinations as follows: Civil - 2 (Icvel I) - No failures o Electrical /I&C - 10 (Ievel I) conducted by two IcVel II Exn=iners - e 3 failed first test. Welding - 2 (Icvel I) e Mechanical - 3 (IcVel I) e = ~ =:

  • ~:.-...-.

FRoJECTS. ENCIMEERING AND CONSTRUCTION-l e,8%- l ouAury AssuaamcE esmaruEur ' ,M)q Consumers l g /. Povrer u g Company M01-72-1 7 ,3 NN " ~ QA2 +-0 h e Ahdit Team witnessed and agreed with the examiner's evaluation of all inspector candidates including the three (3) first attempt failures in i the Electrical /I&C area. We Audit Tes=) witnessed some actual inspections by recently certified '(vithin the last year inspectors as follows: Welding - 2 (Ievel I) Inspectors performing two (2) inspections each e Mechanical-6(revelI) All inspectors adequately conducted t.he inspections in co=pliance Uith procedures and Inspection Plan requirements. S e Audit Team also evaluated the Ievel II examiners while witnessing the Oral /Perfo m ce Demonstrations and concluded that they conducted co=prehensive exa=inations and co.: plied with all program requirements. he hidit Team reco== ends that MIQAD (Site) continue to overview the training / certification pro 6 ram to assure that the certification of inspectors continues to be adequate to meet the Midland Pro,1ect requirements. VI. EXIT MEETING An Exit Meeting with those personnel identified in,Section III of this report was conducted on November 6, 1981. During this meeting, the results of the ~, audit were presented. VII. CILGING ITE2E Correspondence regarding~ this audit should be foz sarded to: 'D A Ta6gart, JSC-206B, Section Head-Audit & Manage =ent Systems, in accordance with the established co---tmication agreements. VIII. ATTACHMEZE Audit Observation (s) M01-72-1 Obs. 1 & 2 Audit Notification Ietter (File Only) Audit Plan (File Only) Audit Checklists (File Only) .u

.~ t. ATTACIBENT A AUDIT OBSEEVATIONS (OBS) Audit observations are either: (c) A condition which if allowed to continue may become a nonconfon.ance, or (b) A recommendation which may improde the Quality Assurance Program. As a result of Audit Mel-72-1, 2 Audit Observation (s).aaee/ vere identified and h/are included with this attachment. No specific written response (s) 4e/are required to +" =:/these observation (s). / I . ~. ~. - - - ~ ~ ^ ~ ~ ~. - * - - - )

o o - M01-72-1 , u._ CBSERVATIONS 1. S e Audit Team recommends that a concerted effort be made to provide an area, free from interruptions and peer observations for Insper tor Certification Orcl Examinations. 2. he Audit Team recot::nends that Bechtel Quality Control and Midland Project Quality Assurance Department (Site) work together to obtain an area designated primarily for construction activities training. With the increased emphasis being applied to training, it is important to provide an abnosphere which will optimize the effective-ness of the training. e e A

~ ^t'D3I A W A N ' ; "AT'ON - d' f o' Consumen AUDIT CHECKLIST %, nruu 'W'" qA75-o J'Act 1 Or 1 4 Company AUDIT liO: IT0 JECT /!'!,AtlT: /40/- 72-/ AUDITM. OPGAi11ZATIOf3: Midland 1 and 2 Bechtel' Quality Control Cold'IriED Bf - AU:311T'l/0 ATE: REVIEWED E)/PATE: 11:Frf.ftf:D PY/IsATE: I't3tr.ol!!!Fl. CO:ITAC'll3)/TITIES: ItirgiqEticr gang 1;T. TITtJ:. ICO. I:EY: A) AAPD/PSPG-8.1, Revision 4 B) A!!SI-t!45.2. 6-197 3 C) AAPD/PSPG-6.1, Revision 6 ~ CAT. LRISAT, 8 ##'II'E DOCUtEr:TATIOff ItEVIEVED RTIEftt' rice f30. RFyUlitEfE1:T/CilARACTERISTIC l'OP. OBSERVE CERTIFICATION g fann 7 mum 1 Y.i n d r' g g t. g nenneenee b- " - - * * * * ~

  • N p- -

.erre4 eve,1 ra)Jrea t u., Lie W +r nr4a ebe-. kla6Whe r^d"- --^e d lg The oral examination shall cover the check-(A) Observe the conduct of the oral examina-points entered in Figure 8.1-1 for each PQCI 6.2.2 tion. Was the depth and accuracy of the in which the candidate is to be evaluated. As questions and answer adequate to evalu-ate the Level I's understanding of the a minimum, two questions covering each of the following areas of the instruction shall be PQCI? asked; general instructions, prerequisities, inprocess inspection activities, final inspec-i tion activities, supplementary records, and exceptions. The examiner may expand the sub-ject and number of questions to further evalu-l ate the individual's understanding of th'e in-l struction. r.q',.. l.. 'Ij; e r l m & a < ? )' 'I ,., ;, ; i j n; 7^ L.b c ' L 1.:. /,i c.t I l' o < . (,' \\.y. l } i

o l

v - - ~ ~ -

AL'Dai, At3D A!!J, filATice,' t... 411mm (f3 E% AUDIT CHECKLIST - CONTINUATION .7 It.ctiori 4^7? ') suasnt:. cottracrtv/rmine

.euit::ts: in n;:>ur - TITex, rio. Rt:v:

A) AAPD/ PSP C-8.1 Rev 4 B) ANSIN45.2.6,1973 C) AAPD/ PSP C-6.1, Rev 6 10. ItEquIntis4T/c11APAcTERIcTIc RFFErm!!Cl! DoctMEftTATIoft REVIEED St.T. (Pes 1%, The performance demonstration shall be conduc-(A) Observe the performance demonstration. l CL ted in such a manner (by actual demonstration 6.2.3 Was the perfortnance demonstration conduc-or an oral description of the specific activity ted in such a manner that the Level 11 task during a physical walk through utilizing could evaluate the Level I's ability to the actual equipment or material) as to allow implement an IR for the PQCI? I the examiner to evaluate the Level I candidate's ability to implement the IR prepared in Section 6.2.1. The checkpoints entered in Figure 8.'l-2 j shall be used to evaluate the candidate's pro-ficiency during the performance demonstration. The candidate will be required to prepare the IR for the PQCI. Also, as a minimum, two ques-8 tions covering each of the following areas of i the IR shall be asked: general information l (IR identification, scoping, reference criteria l pr'erequisites, inspection tools and instruments lj inspection activities, supplementary records, exceptions and processing. S 2 OBSERVE' INSPECTIONS l ? 2s "The lead discipline CQCEs shall be responsible (C) Request the current inspection assignment for verbally assigning CQCEs to cover the work 8.8 for a inspector from the lead activities. The lead discipline CQCEs shall discipline CQCEs records. Observe the keep a record of current inspection assignments performance of this inspection assignment I made to each of their CQCEs." 2b " lie shall be familiar with the tools and equip-(B) Verify test equipment and inspection tool j i ment to be employed and shall have lemonstrated 3.2.2 agree with instructions. Inspector dem-i proficiency in their use." onstrates proficiency in their use. 2c "lle shall be familiar with inspection and meas-(B). Verify calibration status of test equip-uring equipment calibration and control methode 3.2.2 ment and inspection tools and that the and shall be capable of verifying that~ the equit equipment is in proper condition for use. i ment in proper condition for use."- i

^ ' ; ;..... u -. (0,. gh AUDIT CHECKLIST - CONTINUAT ON is.ct: 3 or 3 i om-o ITR:X3:tIEL cotITACTED/TITIIGt 5

  • l;ll'u:Ict: lxCtOMT - TITLE. Il0, REY:

e I A) AAPD/ PSP C-8.1, Rev 4 B) ANSI-N45.2.6-1973 A AAPD/ PSP C-6,1 J v 6 No. FE7;tatust/cnAPACTERISTIC RFFERfRef E -- J0CtBENTATIoM REVI).WD SF.T. UN!. 2d "When inspect (I), witness (W), test (T), or (C) Verify the adequacy of sampling plan and review (R) activities are to be implemented by 3.3.3(7) methods when used. I use of a sampling plan, the sample plan shall I be identified in the PQCIs." 2a "The activitie(s) described in the PQCIs shall (C) Verify the inspector performs activities be inspected for conformance to the referenced 8.6 as instructions direct. Does the inspec-inspection criteria by CQCEs certified to at tor check instructions, material'tsnd set-least Level I in the applicable PQCI." up for adequacy? 3 Each certification awarded shal1 be documented (A) Check the certification package for the by entering the required information on the 9.2 inspectors observed in items 1 and 2 for appropriate forms shown in the Figures section minimum documentation requirements, of this project special provision notice. The minimum documentation requirements for certifi-cation are as follows: Figure 8.1-1 or 8.1-8, Oral Examination O. l b. Figure 8.1-2, Performance Demonstration Record. I Figure 8.1-3, Physical Examination Record. c. d. Figure 8.1-4, Training Record. i i o., Figure 8.1-5, certification of Qualification. f. Figure 8.1-6, Education and Experience. g. The QCIR completed for each certification, or for Level III, the PQCIs prepared for certifi-cation. h. Any necessary additional supporting documents. g l i I m m-me =}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20040E316&oldid=4554484"