Text

Revised Self-Initiated Const Project Evaluation (Per INPO Guidelines)
	ML20072N074
Person / Time
Site:	Clinton
Issue date:	01/18/1983
From:	; ILLINOIS POWER CO.
To:	;
Shared Package
ML20072N052	List: ML20072N045; ML20072N054; ML20072N074;
References
	NUDOCS 8304010440
	Download: ML20072N074 (201)
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lLLINDIS POWER COMPANY CLINTON POWER STATION l UNIT ~1 SELF INITI/ TED CONSTRUCTION PROJECT EDLU/ TION (PER INPO GUIDELINES) j /

P R I)OC K 0 0 1 A P D:s i

l ILLIN0IS POWER COMPANY 4

CLINTON POWER STATION UNIT 1 SELF-INITIATED CONSTRUCTION PROJECT EVALUATION (PER INPO GUIDELINES) .

DECEMBER 17, 1982 (REVISED JANUARY 18, 1983)

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Illinois Power Company Self-Initiated Construction Project Evaluation Clinton Power Station December 17, 1982 (Revised January 18, 1983)

Scope In accordance with guidelines developed by the Institute of Nuclear Power Operations, Illinois Power Company conducted a self-initiated evaluation of the current construction and engineering activities involved in the construction of its Clinton Power Station. Construction activities were severely limited due to ten open stop work orders plus a limited hold on traveler installation packages.

A team of twenty-five people was used in this evaluation effort. Included in this team were seven people from consulting firms and four people from other utilities all of whom had broad backgrounds in one or more areas of design, construction, management, and quality assurance. The remaining fourteen team members were from Illinois Power management with experience ranging from engineering, construction, operations, start up and quality assurance through training, purchasing, auditing, accounting and computer applications.

The evaluation effort began on October 22, 1982 and con-cluded on December 17, 1982 with a presentation to the Company i

executives. The total time expended by the team in the evalua-tion effort was approximately 3,400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months .

The evaluation w s conducted at the construction site, the Illinois Power corporate offices in Decatur and the Sargent &

Lundy corporate offices in Chicago. Evaluations at Sargent &

Lundy were being conducted siraultaneously by Public Service Company of Indiana, Commonwealth Edison and Illinois Power Company. Although these teams operated independently for the most part, team representatives from these three utilities met frequently to discuss the results of their efforts.

It is important to note that Illinois Power Company was either in the process of making or had just recently made major modifications to the management structure of this project at the time of this self-initiated evaluation. These changes resulted from independent assessments of this project that the Company had arranged for earlier in 1982. This evaluation did not attempt to use previously identified deficiencies or subse-quent corrective actions from these independent assessments.

Summary An evaluation was conducted of design and construction activities at Illinois Power Company's Clinton Power Station during the period from October 22, 1982 through December 17, 1983. The evaluation was initiated by Illinois Power Company and was conducted by an evaluation team comprised of technical and management personnel from Gulf States Utilities, Public Service Company of Indiana, Illinois Power and from two con-sulting firms, Management Analysis Company and Sargent & Lundy.

The evaluation team utilized performance objectives and criteria developed by the Institute of Nuclear Power Operations specifi-cally to support the Institute's sponsoring utilities in this

l type of evaluation. The plant, which is located six miles east of Clinton, Illinois, incorporates a 950 MWe General Electric BWR/6 nuclear steam supply system (NSSS). It is approximately 86% complete and is scheduled to begin commerical operation in August, 1984. !

The purpose of this self-initiated evaluation was to:

a) identify weaknesses and deficiencies in the current construction / start-up activities in order to facilitate improvement of the project b) make information discovered during the evalua-tion available to the nuclear industry in order to aid the industry's self improvement effort, and c) fulfill a commitment by the nuclear utility industry to the Institute of Nuclear Power Operations.

An overall perspective of this program is provided by the performance objectives, the results, and the corrective actions specific to this evaluation and as contained in the body of this report.

Of the Performance Objectives eval'1ated, about 35% had no weaknesses identified. The remaining 65% of the objectives have 41 weaknesses and 5 good ,'ractices identified against them. Nearly half of the weaknesses can be corrected with no significant impact on project programs and construction activities while the balance will require a more significant effort to correct. It should be recognized that there were minor or isolated deficiencies shown as details behind all of these objectives. However, these were not in all cases

considered to be of sufficient importance to support a " finding of weakness" for that objective.

The management of Illinois Power Company has a high level of confidence that, with the corrective actions proposed in response to the " findings" associated with this evaluation, in addition to the modifications to the management structure of the project as referred to earlier, the control of the design and construction will be adequate for the completion of a nuclear power plant which will meet the requirements for safe operation.

The corrective actions for the identified weaknesses have been scheduled to be completed in accordance with the following schedule:

% Corrective Action Period Completion 4Q82 20 1083 57.5 2083 22.5 A system is being developed and is to be implemented to follow up on the commitments made through corrective action responses to the findings.

Following is an overall assessment of each of the seven areas evaluated in accordance with the Performance Objectives set forth by INPO.

1. Organization and Administration The site organizational structure after modifica-o tion as mentioned in the Scope section will be adequate for the successful completion of this project. The

l reorganization of the project management structure will also affect minor deficiencies noted in the performance evaluation details.

2. Design Control The efforts of the Architect-Eagineer, Nuclear Station Engineering and Baldwin Associates in the design activities are estisfactory. A weakness in detecting design errors in piping hangers was identi-fied but controls will be initiated to correct this.

Control of certain HVAC hanger drawing preparation is to be st .angthened by issuance of a project instruction.

3. Construction Control The Construction Engineering area was adequate.

Weaknesses identified in other areas have prompted rewriting or strengthening of procedures, review of existing programs for possible improvements as well as development of new programs where warranted.

4. Project Support Industrial Safety practices are to be improved by formalization of certain safety procedures and by better enforcement of the eye safety program.

Revisions are to be made which will result in the production of an integrated project schedule; in better methods for reporting work completed; in strengthening control in subcontract area; and in improving document transmittal, turnover and micro-filming efforts.

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5. Training Additional procedures and training facilities; (

compliance with existing procedures concerning training and attendance records; and verification of ,

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employment background information are needed and will be provided in this area.

6. Quality Programs Weaknesses were identified in monitoring of a i suocontractor's activities; audit and surveillance findings tracking system; QA manual and implementing procedures not being up-to-date due to organizational changes mentioned earlier; independence of subcontractor's 4

QC organization; and timely responses to nonconformance reports and corrective action reports. Better adherence to existing procedures and revision and/or development of procedures and programs were listed as the correc-tive action items as a result of these weaknesses.

7. Test Control @*

The Test Program, Organization and Staffing Plan, and System Status Controls areas were found to be satisfactory. Turnover procedures needed to be up- .

graded. Identification of procedures for timely com-pletion of systems for turnover to start up and to ,

4 define ;ystem walkdown methodology prior to turnover were needed. A written instruction was needed for ,

guidance in the detail and format in the preparation of test procedures and a method was needed for expedit- ,

ing approval of test procedures.

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CPS Evaluation Team Co-Team Leader T. Daggett IP H. Adkins MAC Design Group C. Wheeler IP Co-Group Leader -

M. Dye MAC Co-Group Leader W. Walling GSU P. Zimmer IP R. Meyer PSI Construction and Test Control Group J. Pulley IP Co-Group Leader J. Weaver MAC Co-Group Leader J. Dunkelberg GSU R. Eimer IP J. Philipps S&L G. King' GSU ,

G. Wuller IP ,

Project Support, Training and Quality Programs H. Heisler IP Co-Group Leader L. Chambers MAC Co-Group Leader '

S. Bakunas IP ~,

R. Carlson IP W. Futrell S&L J. Joullian IP C. Kileen IP R. Kruep IP D. Schweickert IP R. Spinner IP Organization and Administration H. Adkins MAC Group Leader

( K. Perkins MAC ,

J. Weaver MAC M. Dye MAC Key: GSU Gulf States Utilities IP Illinois Power Company MAC Management Analysis Company -

PSI Public Service Company of Indiana S&L Sargent & Lundy

SCHEDULE FOR CLINTON POWER STATION SELF-INITIATED INPO EVALUATION September October November December 6 13 20 27 4 11 18 25 1 8 15 22 29 6 13 20 INPO TRAINING (14-15) -

I EVALUATION PLANNING (20-18)

DOCUMENTATION IDENTIFICATION AND COLLECTION (14-18) -

l WORKSHOP AND DOCUMENT REVIEW (13, 19-21) - -

SITE ORIENTATION AND FAMILIARIZATION l (19-20) -

PILOT OBSERVATION (22) =

DATA COLLECTION AND EVALUATION (25-10)

CONSOLIDATE FINDINGS AND DRAFT REPORT (8-18) =======

REPORT REVIEW (18-16)

ISSUE FINAL REPORT (20) =

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Listing of Findings and '.orrective Actions l

l FINDING: The IP corporate organization does not have a Project is (OA.1-1) Manager whose primary and preferably sole responsibility is e to direct the project in accordance with the INPO "

definition.

pORRECTIVE The Executive Vice President's current responsibilities ACTION: are focused principally on the Clinton Power Station and, sj tnerefore, is in effect the Project Manager as defined in the INPO Criteria. Effective Februarv 1, 1983, one IPC Vice b.

President will assume overall responsibility for design, "c -

engineering, licensing, start-up, operations, and quality assurance activities. The Project Manager's responsibilities continue to be the procurement, construction, and construction control activities.

In addition, Illinois Power Company is developing an organization transition plan that includes consideration of the INPO Criteria. This transition plan is scheduled to be completed by June, 1983.

PINDING: The current organization relationships and interfaces IOA.1-2) are not clearly defined or understood. Very recent organizational changes have not been documented other than through an organization chart.

?ORRECTIVE Illinois Power Company has made significant

\CTION: organizational changes in the past three months. These changes have resulted in changes to assignments of responsibility, communications paths, interfaces, etc.

The Illinois Power Company Construction Quality Assurance Manual, which describes organization relationships and ,

interfaces, is currently being revised and will be issued by January 3, 1983.

In addition, the organization transition plan identified in OA.1-1 will address organization responsibilities, authorities, relationships, and inter # aces. The plan is scheduled for completion by June 1983.

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'INDING: After the BA CAT-I piping iso drawings are reviewed and (DC.2-1) the status identified by S&L, there is no S&L formal method to update the ison with respect to later revisions to the S&L piping drawings.

ORRECTIVE This is a BA responsibility and BA's Job Instruction

\CTION: P-026 is a formal instruction for the Piping Department review of incoming design changes. Paragraph 3.2.la identifies the Piping Department Drafting Supervisor as having responsibility to determine if isometric drawings require revision. After revision, they again are reviewed and statused by S&L, per BA and S&T. nrocedures.

'INDING: There is no planned system of checks to verify that (DC . 3-1) retraining, procedure changes and reorganization of the on-site small bore piping hanger-design group will preclude undetected design errors in the future.

JORRECTIVE In addition to S&L's re-review of small bore piping

\CTION: hanger calculations, S&L will perform periodic independent spot checks of calculations to assure the procedures have been implemented.

Also, IP's Nuclear Station Engineering Department is developing a program for an on-going technical surveillance of this activity. The specific plan to implement this program is to be available in February of 1983.

Unique HVAC hanger drawing preparation is being lPINDING:

(DC . 3-2 ) controlled by an interoffice memorandum rather than an approved project instruction.

CORRECTIVE The unique HVAC hanger drawing preparation is controlled ACTION: by existing S&L procedures and standards. Unique requirements are covered by the reference memorandum.

Although we believe the system is adequately controlled, S&L has agreed to enhance the program by issuing a project instruction. The project' instruction for these unique activities is being prepared and is scheduled for issuance by December 30, 1982.

PINDING: The following good practice was noted:

IDC.4-1) Both IP and S&L have provided direction and expertise well beyond their established responsibilities for CRD piping and hanger designs in order to expedite the contractor's design, analytical, fabrication, and construction work.

PINDING: Various site plans providing key locations of ICC.2-1) construction facilities lack consistency and are not maintained in an updated mode.

ORRECTIVE The. construction facilities drawings are being updated.

LCTION: We anticipate a new issue April 1, 1983. After that, quarterly updates will be issued.

'INDING: Access control and an adequate system of well defined (7 1CC.3-1) authorities and responsibilities for storage control does not exist for the Illinois Power Permanent Uarehouse.

ORRECTIVE A CPS plant procedure will be prepared and implemented CTION: by December 15, 1982 to delineate responsibilities and methods for access control, and material storage area control.

In addition, the following measures have also been taken:

1. Storeroom personnel have been directed to insure that all CPS plant personnel, not on the authorized access list, are logged and badged prior to entrv, and are l escorted while in the storage areas.

2. Storage personnel have been directed to detain all other personnel, not on the authorized access list, desiring access to the construction material storage areas until the IPC Receiving and Warehousing Supervisor can provide j an eccort, and such personnel are logged and badged for access.

3. Signs have been posted at the storage area entrance which identify personnel who are authorized unescorted access, and which prohibit access to all other personnel without an escort.

4. Signs are being prepared, and attached to the flagged

> ropes surrounding the construction material storage areas, to clearly identify these flagged areas as l construction material storage areas. This action will be completed by December 3, 1982.

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'INDTNG: Permanent-plant equipment requiring a nitrogen purge is lCC.3-2) not being maintained per requirements.

ORRECTIVE BA will evaluate the procedural requirements and their LCTION: implementation. Action as a result of this evaluation will be taken by March 1, 1983.

FINDING: Most field personnel including Superintendents and area ICC.4-1) engineers are not notified in advance of future activities and plan much of their work on an "as needed" basis.

ORRECTIVE Current project direction, based on the criticality LCTION: of stop work orders, is to close-out the inspection backlog.

B.A. planning and scheduling is currently involved in the development of Level III schedules to provide detailed direction on work activities leading to ti'e lifting of stop work orders. Other Level III schedules, as well as summary schedules are being developed for those activities not affected b'y stop works. This work scheduling activity is expected to be implemented by flay 31, 1993.

'INDING: BA traveler program is unduly complex and requires 2CC.4-2) streamlining. In addition, the unknown status of travelers I and associated design changes is adversely impacting the '

turnover process.

k' ORRECTIVE BA shall review the entire traveler p rogram in order NCITOM: to evaluate the program for necessary changes which will simplify the system while ensuring that the traveler status and the associated design changes are readily determinable.

The review of the entire traveler program will be completed by March 31, 1983. Enhancements, indicated by the review results, will be incorporated into the procram.

A Traveler Tracking System is being developed using the IP

. Computer System and is expected to be operational by Tune 30, 1983. Until that time, manual checks can be accomplished to serve our needs.

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e PINDING: Inspection acceptance criteria, tolerances, and scope -

(CC.5-1) are not clearly understood or uniformly applied by QC inspectors. 4

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[ORRECTIVE All BA Procedures, Quality Control Instructions and ACTION: Technical Services Instructions have been rewritten and applicable training of QC Inspectors has been completed as of December 7, 1982. This will be an ongoing effort.

INDING: The Quality organizatirns~are controlling the pace of f(CC . 5-2 ) the project instead of coordinating ~their efforts with that of construction for the support of the project.

pORRECTIVE Earlier this year, it was found that the Construction ACTION: pace of work was proceeding without any consideration for timely inspection. A commitment has been made to change the e scheduling concept and work off the inspection backlog of completed work to an acceptable level by May 1, 1983.

By May 31, 1983, quality requirements will have been inserted into the Project schedule to assure achievement of timely inspection.

i PINDING: The BA corrective action system is not fully achieving (CC.6-1) effective corrective actions involving construction crafts, h0RRECTIVE A Guality Accountability Program is being developed by 4' 4CTION: BA Project Management and should be implemented during the first quarter of 1983.

F1NDING: The present trending analysis system is not identifying (CC.6-2) trends nor assigning actions to correct the underlying

problems in an effective or timely manner.

ORRECTIVE The following items are being implemented:

ACTION: A) A CRT Terminal is to be added on December 10, 1982, and tied into IPC's Main Frame Computer for the NCR/DR Tracking Program.

B) On December 1, 1982, the BA NCR/DR coding system was

} enhanced such that generic concerns were addressed.

L C) Complete overhauling by January 15, 1983, of the BA trending system will include addition of a data processor, more comprehensive training of personnel, and adding to the staff of people experienced in this area.

[INDING: Quality assurance pre-award evaluations or post-award (CC.7-1) audits are not being done for suppliers of safety related calibration services.who calibrate measuring and test ,

equipment (M&TE) standards utilized by IP Startup Plant .

Staff, BA Construction, BA QC, and the independent lab. 1 This service includes:

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1) suppliers who offer. calibration services for M&TE which are not manufactured by them.

2) suppliers who offer calibration services for H&TE which they manufacture.

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50RPECTIVE Baldwin Associates Quality Assurance and Illinois Power TCTION: Quality Assurance will review all suppliers of measuring and-test equipment calibration services to assure the quality of the service and product provided. This review will be completed by March, 1983.

'INDING: The BA control of measuring and test equipment (both for CC.7-2) construdtion and inspection) in the area of egaipment recall is inadequate, jORRECTIVE In order to obtain the prompt return of tools for 1CTION: recalibration, BA will evaluate a potential way to streamline the system of recall of tools requiring calibration. This evaluation will be complete by January 31, 1983.

jINDING: There are no written procedures in place which:

PS.1-1) n) clearly delineate the responsibilities of the safety department, b) provide for a Fire Extinguisher Inspection Program on site, c) provide policy for control of hazardous materials on site.

1 jORRECTIVE a) The BA Safety Department will develop a written

}CTION: safety program which formalizes present

', responsibilities, duties, and practices by February 1, 1983.

b) The site fire extinguisher inspection program will be formalized in the written safety program address in a)

above, c) BA expects to have written procedures on control of hazardous materials by March 15, 1983. Both IP Operations and Project Management have procedures i relating to hazardous materials.

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INDING: The enforcement of the eye safety program on the site PS.1-2) is deficient.

{0RRECTIVE DA Project Management will issue a memorandum by oCTION: January 15, 1983, reaffirning the eye safety policy which includes disciplinary action up to dismissal for repeated violations.

IllDING: The current CPM Schedule does not integrate PS.2 &. construction activities with engineering and qu'ality S.3-1) review on a Level II basis. A Level ITT schedule of construction activities is needed.

joRRECTIVE The CPM Schedule on a Level TI scheduling e~ffort 3CTION: will be revised to integrate engineering, quality review, and procurement interfaces. A Level III detail schedule will be developed for construction activities. New procedures will be written by May 31, 1983 to cover these specific requirements.

IPC is evaluating the planning and scheduling needs, and an integrated schedule will be implemented in June 1983.

IMDING: The methods for reporting work completed'are not PS.? & uniform.

S.3-2)

ORRECTIVE Work in progress (WIP) is accepted as work lCTION:

\ completed for certain commodities including electrical conduit and major piping commodities. While WIP is acceptable as work completed from a construction standpoint, it is not necessarily ready for final review by Quality Control.

An evaluation of current reporting procedures will be performed. A procedure will be completed and implemented by May 31, 1983.

INDING: The following good practice was noted:

,PS.4-1) The computerized tracking system for replacement / spare

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parts, required by startup and o7erations, significantly assists in avoiding or reducing delays from requisition preparation through material receipt.

[IMDING: Procedure CSPQ-7 in IPC Site Purchasing does not address

'j PS . 4-2 )

transmittal of documentation to the Document Records Center.

0RRECT7VE Construction Site Purchasing Quality Procedure-7 has

{CTION:

been revised as of Novemb?r 24, 1982 to incorporate the clarification that appropriate documentation will be forwarded to the responsible Stores Supervisor for transmittal to the Clinton Power Station, Document Records Center.

lINDIMGs BA Procedures governing the Subcontract functions are PS.5-1) inadequate for control of this area, and training of personnel is deficient.

ORRECTIVE A new BA cubcontract Manager, due to report after

,CTION: January 1, 1983, will evaluate procedures, controls, training and staffing requirements and make recommendations to management by February 1, 1983. ,

IN3ING: Adequate procedures do not exist to provide for the PS.6-1) orderly turnover of documents from BA, GE and S&L to IP.

DRRECTIVE A procedure is being developed to provide for turnover HTION: of documents to IP from BA. We expect an initial draft to be available by January 30, 1983. Additionally, the Records Task Force is preparing a new Records Management Plan which provioes for a system to transfer records from BA, GE, and S&L to IPC. The Records Management Plan will be prepared by February 15, 1983.

3MDING: CPS Records Center does not have microfilm processing PS.6-?) equipment or associated trained operating personnel i available to microfilm the records to be transferred.

pRRECTIVE The Records Task Force is addressing the Records STION: Turnover and will address microfilning associated with the turnover in a meeting set for November 30, 1982. The Plant Services Budget will be amended to reflect microfilm equipment and system for second quarter 1983. Personnel I will be trained on the equipment at that time.

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f1MDING: The following good practice was noted:

]PS-6.3)

An internal surveillance program of drawings and procedures is in operation within the DDC and the Project Engineer's

, Department.

[INDING: The IP site purchasing group is not implementing (TN.1-1) Mhnagement Guide 2-1; Administration of Nuclear Training Activities.

0RRECTIVE IP Training - The site IP Purchasing group will be

{CTTON:

> retrained under Project Management. Appropriate procedures are being revit d and developed. Trainino and support will be.provided to the site Purchasing group by Project Management, all as outlined in the "Drocurement Recovery Plan" recently submitted to the NRC. The date established for this corrective action is delineated in the " Procurement Recovery Plan" as December 30, 1982.

lINDING: To date, no copies of QA Training Attendance Record Form TN.2-1) OAP-102.04F07 are in the central file, as is required by Procedure QAP-102.04, Rev. O. Paragraph 4.5.4.

Action has been taken to comply with QAP-102.04, Rev. O, f0RRECTIVE pCTION: Paragraph 4.5.4 in that completed training records have been forwarded to CPS /DRC on November 10, 1982 and November 15, 1982.

/INDING: The following good practice was noted:

TM.2-2) BA has implemented a computerized systen for tracking training evolutions. This facilitates management review and

- aids timely completion of required training by personnel.

>INDING: The following good practice was noted:

TM.2-3) BA instructors aEe assigned to work in the field for several days to develop subject matter expertise prior to developinent of lesson plan.

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l FINDING: No written policy exists on the. verification of lTN.3-1) background information for BA personnel and contract personnel'of the IP Startup aroup.

jORRECTIVE DA Personnel Manager has a written Personnel Department 3CTION: hiring instruction which requires this verification. This

- instruction will be reviewed for adequacy and-revised, if necessary, by January 31, 1983.

IP Startup Administrativo Procedure 7, Qualification and Certification of Test Personnel, will be revised by January 3, 1983, to provide adequate assuratice that education and !

experience information used for certification, is accurate .

[INDING: The training facilities.and equipment available to lTN.4-1) the IP project management and IP QA/QC are inadequate for .'

the current training requirements.

ORRECTIVE Illinois Power QA will perform an evaluation of our

{uCTION: training facilities during the first quarter of 1983. Based upon thin evaluation, appropriate action will be taken-to provide the necessary facilities to support the QA/QC training function.

Illinois Power QA has placed an order, through our purchasing group, for the necessary equipment to support the QA/QC training function. This order includes equipment for presenting video programs and overhead projection.

Currently, coordinated sight / sound equipment is available within the QA Department.

An evaluation of all available training equipment will be performed during the first quarter of 1983 to determine

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further needs. This evaluation will be ccepleted by March 31, 1983.

FINDING: BA OA monitoring of HVAC Contractor iF inadequate.

DOP.1-1)

OPRECTIVE Prior to 7/1/82, one Vendor Surveillance Engineer was CTION: assigned to the HVAC contract. This engineer was responsible for three other contracts in addition to the HVAC contractor. As of 7/1/82, two Vendor Surveillance

?, Engineers were assigned to the HVAC contract.

Stop Work Actions 014, 015, and 0?0 were issued on 6/23/82 (014 and 015) and 8/2/82 (020). Efforts on the part of the i Vendor Surveillance Engineers have been directed toward the f

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lifting i of these Stop Work Actions. Once they have been lifted, surveillance of the HVAC' contractor will be conducted per the requirements of BOA "

170, Supplier Surveillance, which states in part, Surveillance shall be e provided in the form of periodic surveillance visits to the supplier of -subcontractor . . . Periodic coverage shall be determined by the Manufacturing and. Testing Hold Points designated in the Supplier Quality Assuran'ce Surveillance Check Plan, or as directed by the Manager of Quality Assurance".

Corrective Action shall also include an assessment of other subcontractor safety related activities being performed on site with a comparison of BA Vendor Surveillance coverage to '

insure that enough qualified personnel are assigned to the work. This assessment shall be completed by January 31, 1983 and realignment of personnel assets nade accordingly.

IP QA will verify and document the completion and effectiveness of the above proposed action via IP QA surveillance.

[INDING: The IP Construction QA Manual an'd some of the LOP.1-2) implementing procedures are out of date.

ORRECTIVE The IP Construction QA Manual is currently being revised

{CTIOMs to reflect organizational and functional changes made as a result of organizational changes. The draft of the revision to the QA Manual is in the review cycle. Estimated issue date is January 3, 1983.

After the IP Construction QA Manual is issued, IP QA will perform surveillances to insure that departmental procedures are current with the latest revision of the IP Construction QA Manual. The surveillances will be completed by January 31, 1983.

JINDING: BA QA systen for tracking and resolving audit and QP.1-3) surveillance findings is not adequate.

ORRECTIVE BA QA is in process of installing a new data processor ,

'CTION: which will be utilized for the control of tracking audit and surveillance findings, track response tine, and the closure of audits. This new system.will be implemented by 3/1/83.

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IINDING: Some sub-contractor QC organization's independence OP.2-1) is in question.

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'ORRECTIVE BA OA Audit Section will conduct an audit of all seven CTION:

3 subcontractors on site to verify the independence of quality organizations from production pressures and their independence to identify and recommend solutions to quality ~

problems. The audits will be completad by 3/31/83 on contractors presently performing work and other current contractors prior to their commencement of contracted ~ work.

.In addition, BA QA Auditing Section will revise the checklist used for vendor and subcontractor program audits to require the auditor to establish the independence of the quality organization. 'This will be accomplished by 1/31/83.

FINDING: An effective BA Quality accountability svstem for

,OP.4-1) . corrective action is not well established or enforced.

Responses to nonconformance reports and Corrective Action Requests (CAR's) are not timely.-

joRRECTIVE A considerable amount of effort has been devoted to the 3CTIONt development of a Quality Accountability Program. It is anticipated that implementation of this system will be acccmplished by April 1, 1983.

This system will provide accountability, adequate reviews, timely processing and management attention to nonconformances, corrective action requests, internal audits, external audite, nite surveillances, and audits of BA by outside agencies.

[INDING: DA turnover procedure BAP 2.17 does not accurately (TC . 4 -1 ) reflect the process by which the system turnovers are actually made.

joHRUCTIVE BAP 2.37 is presently being revised to strengthen ICTION: and clarify the turnover process. Expected issue is December 31, 1982.

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PINDING: An ASf1E code system was turned over to IP to start-up 3TC.4-2) without a written QC procedure for turnover of ASME code-systems.

DAP 2.17 is currently being rewritten and is expected (ORRECTIVE eCTIONs. t'o be issued for review by December 31, 1982.- OCI-601 will subsequently be revised.to delineate QC responsibilities for system walkdown inspections for ASME and non-ASME Code Systems. QCI-602 will be issued delineating QC responsibilities for turnover documentation review and approval of ASME and non-AS!!E Code Systems. The OCIs.are expected to be issued for review by February 1, 1983.

PINDING: BA QC and QA responsibilitics during the turnover

]TC.4-3) process are not adequately addressed in Quality Procedure OPI-601 System-Subsystem Turnover.

BAP 2.17 ir presently being rewritten by Project (ORRECTIVE oCTION: Engineering. A rough draft is expected to be issued for review by December 31, 1982. Subsequent to the revision of BAP 2.17, QCI 601 will be revised to delineate inspectors responsibilities for system walkdown inspections. QCI-602 will be issued delineating responsibilities for turnover documentation review and approval. Target date for issuance of the QCIs for review is February 1, 1983, INDING: A construction process has not been identified which can

[1TC . 4-4 ) complete systems in a timely manner for turnover to the IP

s. tart-up group.

ORRECTIVE BA and IP Management are currently reviqwing a proposed

{pCTION: " CPS System Release and Completion Program" that will provide the process indicated. This program will have been implemented by July 1, 1983.

FINDING: No document control system exists to assure that changes to the Startup Turnover Packages (such as' Exception list,

}TC.4-5) Travelers affected, etc.) are transmitted to each party which has responsibility for the turnover of Systems to IP l

Startup. Turnover Packages do not provide for a controlled s Index which lists the current status of eac:t sectio'n of the Turnover Package.

{0RRECTIVE A portion of the " Proposed Syst'me Release and' Completion eCTION: Program" entitled " Documentation for Turnover Program Developmen't" deals with this and should correct this problem. Imp]cmentation is expected to be completed by July 1; 1983. i FINDING: There is no procedure to define the methodology'of

]TC.4-6) system walkdown.oy IP prior'to system turnover.

f0RRECTIVE The IP Startup Administrative procedures will be revised oCTION: to more clearly addresa Startup's involvement in walkdowns prior to system turnover, and to emphasize the following points':

1) IP Startup Engineers are responsible for conducting walkdowns in order to keep abreast of their system's status. They are further responaible for assuring that deficiencies noted on walkdowns are documented on the exception list at turnover.

2) The exception list is the means by which IP Startup documents the results of such'walkdowns.

3) The Startup Supervisor's signature on the turnover form indicates acceptance of the turnover with the exceptions listed.

IP Quality Assurance:

1) Will conduct periodic surveillances (in accordance with existing procedures) of the entire turnover process.

Surveillances will include the area of walkdowns.

2) Will utilize notification points (as described in existing QA procedures) for informing the Startup organization of which turnovers IPQA desires formal participation in. ~

3) Will on a sampling basis review turnov'e'r documentation.

This review will include the Turnover Packages'and exception list items gathered from walkdowns.

4) Will review, on a sampling basis, the documentation in the vault which is not included with the turnover package but which supports the turnover package scope for the system / subsystem / component.

IP Startup procedures will be written and approved by 1/31/83 to incorporate the above changes.

I t

FINDING: Delinquent return of comments on procedures in the yrc.S-1) review cycle is causing a backloq of unapproved test t procedures.

GORRECTIVE The entire " Preparation, Review and Approval" process is ACTION: being streamlined to remove the backlog of unapproved procedures. Improvements include:

a) Assigning an individual to be responsible for tracking and expediting procedures. Individual assigned October 18, 1982.

, b) Preparation of a schedule for writing, typing, reviewing, and approving procedures. To be complete February 15, 1983.

c) Holding periodic " Approval" mencings to resolve final comments and to approve procedures. First ice.eting scheduled for 'iovember r 30, 1982.

IIIDING: The IP Startup Department has no written instruction J(TC. 5-2 )

~

which gives direction and guidance as to the level of detail.

and format of test procedures, f0RRECTIVE A Startup Administrative Notice will be prepared by

$CTION: March 1, 1983 to' provide direction and guidance as to the level of detail of procedures.

I i

i l

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Organizational Structurt Objective No.: OA.1 Trformance Area:

valuator (s) : 11 . Adkins, K. Perkins, ff.' Dye, J. Weaver I. Performance Objective The owner's corporate organization and all other project organizations responsible for the design, engineering, planning, scheduling, licensing, construction, quality assurance, and testing of a nuclear plant should provide an organizational structure that ensures effective project management control.

II Scope of Evaluation The evaluation of this performance objective involved interviews with the Chief Executive Officer, the Executive Vice President responsible for the Clinton Station, twr. IP Vice Presidents, and others in the upper level management of Illinois Power Company (IP) and Baldwin Associates (BA) concerning the organization, the effectiveness and evolution of the organization, and their direct participation in the Clinton Project.

Approximately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months were devoted to preparation, interviews and discusr. ion with management.

KII. Conclusion The IP corporate organization's management control of the Clinton Project has not been fully offective. There are two findings noted.

Recently, positive actions are being taken to make management's control more effective.

)-

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT prformance Area: Organiza,tional Structure Objective No.: OA.1 Faluator (s) : H. Adkins, K. Perkins, M. Dye, J. Weaver IV. Areas of Weakness and Corrective Action; Good Practices FINDING: The IP corporate organization does not have a Project (OA.1-1) Manager whose primary and preferably sole responsibility is to direct the project in accordance with the INFO definition.

CORRECTIVE The Executive Vice President'k- current responsibilities ACTION: are focused principally on the Clinton Power Station and, therefore, is in effect the Project Manager as defined in the INPO Criteria. Effective February 1, 1983, one IPC Vice President will assume overall responsib!.lity for design, engineering, licensing, start-up, operations, and quality assurance activities.

The Project Manager's responsibilities continue to be the procurement, construction, and construction control activities.

In addition, Illinois Power Company is developing an organization transition plan that includes consideration of the INPO Criteria. This transition plan is scheduled to be corqsleted by June, 1983.

FINDING: The current organization relationships and interfaces (OA.1-2) are not clearly defined or understood. Very recent organizational changes have not been documented other than through an organization chart.

CORRECTIVE Illinois Power Company has made significant P ACTION: organizational changes in the past three months. These changes have resulted in changes to assignments of responsibility, communications paths, interfaces, etc.

The Illinois Power Company Construction Quality Assurance Manual, which describes organization relationships and interfaces, is currently being revised and will be issued by Januacy 3, 1983.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT prformance Area: Organizationci Structure Objective No.: OA.1 valuator (s): H. Adkins, K. Perkins, M. Dye, J. Weaver IV. Areas of Weakness and Corrective Action; Good Practices In addition, the organization transition plan identified in OA.1-1 will address organization responsibilities, authorities, relationships, and interfaces. The plan is scheduled for completion by June 1983.

l

PERFORMANCE EVAI.UATION DETAILS CLINTON CONSTRUCT 1CN PROJECT

(

erformance Area: Organizational Structure Objective No.: OA.1 1

Provide Factual Information that Supports the Performance Evaluation Summary S. IP's Executive Vice President is the first level at which all functions associated with the project come together. The Executive' vice President is the individual who coordinates, integrates and directs the project.

3. IP's Executive Vice President has other responsibilities outside of the Clinton Project, however, his principle responsibility is the Clinton Project.

3. IP recently hired Stone and Webster Engineers and Constructors (SWEC) to provide experienced personnel for management of the Clinton Project.

'4. IP has recently hired a new Vice President whose present role includes responsibility for Quality Assurance. He is located at the site.

5 .- The latest organization chart to be issued was dated 10-5-82. This chart showed the placement of the SWEC personnel and the new IP VP.

6. The relationship between the IP VP's and the Project Manager are identified on the latest organization chart. It shows they have access to the CEO through the Executive VP.

7. The individual assigned the responsibility as the IP Project Manager is a SWEC employee. He is Manager of the Clinton Project Management Department (CPMD) and is responsible for managing the construction activities.

.8. The organizational relationships identified on the latest ;

organization chart are not defined in writing and not well

~

k understood.

9. The IP Manager of CPMD has coordination lines identified on the organization chart to project functions outside of construction.

These include; Quality Assurance, Engineering and Startup. These relationships are not yet well understood.

O. BA's Project Manager does not appear on the latest organization chart. (BA is shown en masse).

I

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT crformance' Area: Organizational Structure Objective No.: OA.1

, Provide Factual Information that Supports the Performance Evaluation Summary

1. An IP Engineering and BA Engineering interface exists. This interface is not proceduralized or identified on the organization chart.

2. Several IP middle managers of the Project Management Department feel they have little control of the constructor; they identify their role as strictly to support.

3. The IP QA Program Manaal does not reflect the organization issued in the latest organizat ion chart.

S. The IP organization was found to be in a state of change due to the recent hiring of SWEC and a new IP VP.

5. BA has been trying to fill the position of Project Superintendent (equivalent to Construction Manager) for approximately two months.

6. Two of BA's first level managers have been in their positions less than ten months.

7. BA OA'has just hired a new Manager of Training to replace an " acting" manager.

8. BA's Management, in general, has a low experience level of nuclear power i~lant construction on projects other than Clinton.

9. The Nuclear Station Engineering Department is short of experience in specific areas; i.e., one is Controls and Instrumentation. They are looking for contract personnel to fill the experience gap.

O. IP Construction Management team (exclusive cf SWEC personnel) , in

? general, has a low experience level of nuclear power olant construction management on projects other than Clinton.

)l . TP QA first level management, in general, has a low experience level of nuclear power plant Quality Assurance.

2. Job descriptions are available for most of BA's personnel.

PERFORMi\MCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Organizational Structure Objective No.: OA.1

. Provide Factual Information that Supports the Performance Evaluation Summary

3. The new IP Vice President, headquartered at the Clinton site, has responsibility for the project quality assurance program, developing a Nuclear Program Management Plan, and integrating the project activities.

4 The Project Manager (SWEC) is in process of establishing scope and conte 16t of new project assignments.

5. The IP Design and Construction Q.A. Manual is out-of-date due to the very recent project reorganization.

6 '. IP QAI 202.01 Rev. O issued 1/9/81 assigns stop work authority to the Supervisor-Construction Quality Assurance - a position which doesn't exist since the reorganization of the project QA offort.

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I PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Brformance Area: Management Involvemer;t and Objective No.:, OA.2 Conmitment to Quality valuator (s) : 11 . Adkins, J. Weaver, M. Dye, L. Chambers, R. Carlson, K. Perkins, R. Meyer, P. Zimter, J. Pulley, R. Eimer, G. Wuller, W. Futrell, R. Spinner, H. Heicler, G. King I. Performance Objective Senior and middle canagers in the owner's corporate office, designer's office, and at the construction site who are assigned functional responsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness, and knowledge, a direct involvement in significant decisions that could affect their responsibilities.

I. Scope of, Evaluation This evaluation involved interviews with management personnel from the Chief Executive Office) of IP to a BA Area Cable Termination Engineer. It also included the review of various r.?'cuments and the attendance of team members at various meetings. Sixteen members of the team provided input information. The work acti"ities covered ranged from general managericnt of the progran to use of the traveler system.

II. Conclusion Senior and middle managers who are assigned functional responsibility for matters relating to the project are being involved in decisions and are committed to goality.

1 1

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Management Involvement and Objective No.: OA.2 Commitment to Quality valuator (s): H. Adkins, J. Weaver, M. Dye, L. Chambers, R. Carlson, K. Perkins, R. Meyer, P. Zimmer, J. Pulley, R. Eimer, G. Wuller, W. Futrell, R. Spinner, H. Heinler, G. King IV. Areas of Weakness and Corrective Action, Good Practices No findings.

\

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

$rformance Area: Management Involvement and Objective No.: OA.2 Commitment to Quality

.. Provide Factual Information that Supports the Performance Evaluation Summary

1. Top management personnel make frequent visits to the site and keep in close contact with senior NRC management personnel on Clinton Project matters.

2. The objectives of the project have been given verbally to the

. Executive Vice President by the President and the Board of Illinois Power. These objectives are not documented.

3. The " Management Guides" which are the basis for Department Procedures are being " restructured" to " Executive Policy Statements" with more emphasis on compliance and are to include. project objectives.

4. The IPC Director of QA expressed an awarenesr of the need for upgrading skills of QA personnel and has a training program in place.

5.. The AE has a satisfactory system for controlling the. quality of the design effort.

6. 'A periodic NSED report that provides an overview of design changes that may affect quality is provided to Management.

7. The BA Project Manager regularly receives schedules to Level II, audits of commodities, rejection rates and costs. He conducts a regular Monday morning senior staff meeting.

i a

1

PERFORMANCE EVALUATION SUtiMARY CLINTON CONSTRUCTION PROJECT Objective No.: OA.3 erformance Area: The Role of First-Line Supervisors and Middle Managers valuator ( s) : J. Weaver, G. Wuller, J. Pulley, R. Eimer, J. Philipps, H. Adkins, M. Dye, J. Dunkelberg I. Performance Objective The project first line supervisors and middle managers should be qualified by verified background and experience and ha're the necessary authority to carry out their functional area responsibilities.

II. Scope of Evaluation The evaluation of this activity included discuscions and interviews with numerous supervisors, superintendents, engineers and managers.

Approximately 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months were expended in accumulating and documenting the information for this Performance Objective. Most all of the evaluation team members provided input into this objective.

II. Conclusion The.first line supervisors and middle managers appear to be effectively carrying out their functional responsibilities as they perceive them.

t

.I PERFORMANCE EVALUATION

SUMMARY

l CLINTON CONSTRUCTION PROJECT erfornsnce Area: The Role of First-Line Objective No.: OA.3 Supervisors and Middle Managers valuator (s) : J. Weaver, G. Wuller, J. Pulley, R. Eimer, J. Philipps, H. Adkins, M. Dye, J. Dunkelberg 1

RV. Areas of Weakness and Corrective Action; Good Practices ,

No findings.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT arformance Area: The Role of First-Line Objective No.: OA.3 Supervisors and Middle Managers

. {rovide Factual Information that Supports the Performance Evaluation Summary R. Position descriptions providing responsibilities are available for Sargent and Lundy (S&L) project personnel. Personnel were generally aware of the position descriptions. .

2. Position descriptions providing responsibilities and authorities are available for IPC engineering and construction personnel. Personnel were generally aware of the descriptions.

3. Position descriptions for BA personnel are available. However, BA construction persannel are not generally aware or knowledgeable of the descriptions.

4. BA construction personnel generally know what their responsibilities are even without knowledge of position descriptions.

S. BA position descriptions do rot sufficiently define the minimum qualification, experience and training requirements for the positions.

6. BA Superintendents know they are responsible for ensuring personnel are qualified. !

7 The majority of BA Field Engineers and Area Engineers have little engineering experience prior to Clinton.

B. A direct interface exists between BA construction and S&Lr this interface is not charted. There are S&L procedures which describe the interface.

. A direct interface exists between BA and IP construction. This interface provides information and problem solutions. This interface is not well understood,

). IP Nuclear Station Engineering Department (NSED) has an interface ,

1 with BA engineering that warks well, but is net charted or proceduralized.

J. The BA Senior Discipline Superintendents each function as discipline project manager. They have both construction superintendents, engineering, and administrative personnel reporting to them.

M FORMANCH EVALUATION DETATLS CLINTON CONSTRUCTION PROJECT 2rformance Area: The Role of First-Line Objective No. OA.3 Supervisors and Middle Managers

. ' Provide Factual Information that Supports the Performance Evaluation Summary

8. The BA Warehouse Supervisor is cognizant of his responsibilities and the procedures applicable to his responsibilities.

D. The IP Manager of NSED has directed that training on specific subjects be developed for various levels of management and appropriate supervisory and technical personnel.

4 BA Oc has had almost a 100 percent turnover in personnel in the past year.

5. Per the organizational chart, all senior discipline superintendents report directly to the BA project manager.

3. The reJationship between the Senior Electrical Engineer and his assistant is documented only on the organizational chart.

7. BA supervision perceives the IP project managtment personnel as having a support and expediting role but not a substantial role in the control of BA's activities.

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em----,---,

PERFORMANCE EVAL.UATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 3rformance Area: Design Inputs Objective No.: DC.1 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer I. Performance Objective Inputs to the design process should be defined and controlled to achieve complete and quality designs.

II. Scope of Evaluation A five man team expended approximately 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months interviewing design personnel, observing design activities rel.ited to design inputs.

Organizations contacted included IP/NSED, BA, S&L design, bcth in the field and in Chicago.

II. Conclusion The design inputs are defined and controlled by S&L such that they meet the intent of this performance objective.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Design Inputs Objective No.: DC.1 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer EV. Areas of Weakness and Corrective Action; Good Practices No findings.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Design Inputs Objective No.: DC.1 Provide Factual Information that Supports the Performance Evaluation Summary

3. Sources of design data used in Sargent & Lundy (S&L) design work include documents such as S&L standard designs for certain systems and reference materials from other jobs, including vendor data and work scopes.

3. The IP Nuclear Station Engineering Department (NSED) reviews and comments on the designs, but does not formally approve them.

Comments are resolved between S&L and IP prior to formal issuance of the reviewed documents.

D. NSED Procedure #10 required that a selected number of safety related (SR) specifications, P&ID's, and design criteria documents be reviewed by them. Actual practice was to review all of them.

3. Design bases for the post-accident monitoring system include information and design criteria from the latest industry documents such as NUREG 0660 and 0737, plus Reg. Guide 1.97.

3. Feedback from industry is provided to the design process through review of past plant designs and through owners group meetinge.

3. In answer to an NRC question on system viability, IP submitted _to the NRC new test and analytical information requested of the supplier of the 36" containment isolation valves in the containment vent and purge system. S&L assisted in development of the approach and reviewed the information prior to submittal to the NRC.

7. G.E.'s CRD Piping P&ID's were integrated into S&L's P&ID's., Analyses of Grand Gulf Piping by Pechtel were provided to make an initial assessment of the potentiul effects of waterhammer in these lines dur.ing startup PCRAMS at CPS. These analyses led to the extensive

) design and analytical effort which has proceeded from that time.

s. Utilizing computer analysis programs developed by G.E. a comparison was made by S&L of inputs and outputs from Bechtel on Grand Gulf Unit

1 with similar data from Clinton to help resolve the drywell weir swell problems.

PERFORMANCE EVALUATION DETAILS, CLINTON CONSTRUCTION PROJECT erformance Area: Design Inputs Chjective No.: DC.1

, Provide Factual Information that Supports the Performance Evaluation Summary

9. Loads analyses for several suppression pool and weir swell problems have had input from members of the Mark III Containment Owners Group, which includes both domestic and foreign plants.

G. System designs are formally reviewed for constructability by the appropriate IP construction engineers. ,

1. Considerable effort hcs been expended by S&L to encore constructability of the CRD piping system as multiple problens have had to be resolved.

2. The complex CRD piping design process has been well documented in an organized and understandable fashion.

3.- Inspectability and maintainability will be made easier by use of an integrated, simplified sampling / analysis unit for post-accident sanpling of the drywell. These characteristics plus constructability '

and operability are identified in Specification K-2920.

4. The post-accident monitoring system design utilizes both S&L snd vendor calculations and confirming tests. The pumping unit is being tested by the vendor for operability in reference to Net Positive Saction Head (NPSH) and environmental qualification.

5. Two specifications inspected which showed clarity and consistency are K-2998, DC Power System, and K-2995, Hydrogen Igniter System.

$. Equipment acceptance tests requirements are included in Article 2.1 of Form 1932 of D.C. power system Specification K-2988 and the diesel generator owners group component testing specification.

). Calculations are supplied to S&L for verification, and independent testinc is performed prior to purchase, such as by the vendor for the Post-Accident Sampling System.

J. Pipe hanger basic source information came from the supplier's (Basic Engineers) certified capacity load data sheets. The data conform to requirements of ASME B&PV Code,Section III, 1974 edition, summer 1974 addendum.

h.

PERFORMANCE EVALUATION DETAILS CLIllTON CONSTRUCTION PROJECT 3rformance Area: Design Ir. puts Objective No.: DC.1

.. Provide Factual Information that Supports ,the Performance Evaluation Summary

9. Pipe hanger design information includes bills of material, Basic Engineers load capacity data sheets, and S&L load calculations for related components, all of which were readily available, for the specific one investigated.

O.. Design drawing input and review are governed by S&L design standards.

1. The S&L QA manual was set up in accordance with 10CFR50, and is used with company procedures and drafting standards for generating all work activities plus establishing required project specific instructions (PI-CP's) and specifications.

3. Changes to design inputs are documented and approved, in accordance with S&L QA procedures and project instructions. S&L engineers i interviewed were maintaining complete working files of correspondence and other documents relating to changes made to three specifications reviewed.

3. Vendor technical expertise is utilized where complete subsystems are provided by that vendor, as is the case with the Hydrogen Igniter System described in Specification K-2995.

%. Other examples of utilization af vendor technical expertise are:

a) The vendor having performed analyses and supplied data to S&L and RCI on the Hydraulic Control Units; b) The manufacturer of the 36" butterfly valves in the Containment t Vent and Purge System having supplied operating data nnd stress analyses;

. c) Acceptance of recommendations from the vendor of the submersible pump in the Post-Accident Sampling System.

. Design information usually is readily available to accomplish the design work required.

)

$ J I /

t

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

~;rformance Area: Design Interfaces Objective No.: DC.2 valuator (s): M. Dye, R. Meyer, U. Walling, C. Wheeler, P. Zimmer I. Performance Objective Dasign organization external and internal interfaces should be identified and coordinated to ensure a final design that satisfies all input requirements.

II. Scope of Evaluation A five man team expended approximately 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months on interviews, observations, document review, and evaluation of interfaces in the design process. Methods of defining and controlling design interfaces were reviewed. Organizations contacted included Sargent 5 Lundy in Chicago and on the Clinton site, IP/NSED and Baldwin Associates.

II. Conclusion S&L internal and external interfaces are identified and coordinated, with some minor exceptions. One finding is noted.

PRRPOPMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Design Interfaces Objective No.: DC.2 valuutor (s) : M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer IV. Areas of Weakness and Corrective Action; Good Practices FINDING: After the BA CAT-I piping iso drawings are reviewed and (DC.2-1) the status identified by S&L, there is no S&L formal method to update the isos with respect to later revisions to the S&L piping drawings.

CORRECTIVE This is a BA responsibility and BA's Job Instruction ACTION: P-026 is a formal instruction for the Piping Department review of incoming design changes. Paragraph 3.2.la identifies the Piping Department Drafting Supervisor as having responsibility to determine if isometric drawings require revision. After revision, they again are reviewed and statused by S&L, per BA and S&L procedures.

l

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT Design Interfaces Objective No.: DC.2 frformanceArea:

Provide Factual Information that Supports the Performance Evaluation Summary R. The IP responsibilities for design review are covered by procedure NEED-10 for initial design review, plus NSED-23 and NSED-24 for design' change review. S&L responsibilities are defined by Project Instructions ?I-CP-003, 004, 005, 021, 022, 030, 035, 036 & 040 and distributien lists.

2. To simplify construction and inspection of safety-related piping systems IP also authorized S&L to proceed with a review of certain safety-related piping isometrics (isos) generated by BA.

a) The isos are being reviewed at a rate of approximately 50/wk.

b) S&L procedure PI-CP-040 defines S&L's scope of work and how the interfaces with BA are to be handled, c) S&L QA Procedure GQ 3.09, and General Drafting Standard (GDS) 5.C include rules for handling specific tasks such as the isos review.

d) As yet there is no S&L procedure to control these isos if revisions are made to S&L Design Drawings (i.e. MO5's, MO6's, MO7's) after the date of the review.

e) kesponsibility for resolving dimensional differences between S&L design documents and the isos was confirmed as BA's in a meeting on site on 11-?-82.

3. Information flow is controlled by distribution lists dc fined by S&L procedures. The timeliness of this information flow is governed by

the Project Management Division of S&L, in conjunction with IP project management.

4. IP and S&L have expedited the Reactor Controls Irc. (RCI) design of the CRD piping system by establishing interfaces between themselves and RCI, and have utilized established interfaces between S&L piping and structural designers. Communications lines were established through letters, telecon~, frequent meetings, and even to the sending of S&L and IP engineers to RCI's offices for extended periods. All these interfaces are defined, and the activities are authorized and carried out in accordance with SL-3356 and SL-3021, " Outline of Procedure" and " Scope of Work" for the Clinton Power Station, plus S&L OA procedure GO 4.01.

PERFOPMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT i

erformance Area: Design Interfaces Objective No.: DC.2 l

Provide Factual Information that Supports the Performance Evaluation Summary

5. The containment drywell weir swell analysis was found to be another good example of coordination among the departments of S&L, including Mechanical, Electrical, I&C, Structural, Licensing, and computer support groups.

6. Procedures for writing specifications (i.e. GO-4.'01) control the initial review of the specification by affected disciplines.

7. Specification reviews are expedited by the writer through memos and personal contact, as seen in a review of the development of specification K-2920, " Post-Accident Sampling System".

8. Acceptance of informal review comments is confirmed in later correspondence or phone nemoranda and are incorporated into the specification.

9. S&L and IP communicate regularly with various owners groups, such as the TMI Owners Group, concerning problems such as Post-Accident Sampling ~ System problems of LaSalle and other projects.

O. Informal meetings have been held between IP, S&L and the NRC, regarding Containment Vent and Purgc System Modifications, to resolve problems. Several IP/S&L meetings also were held.

1. System interaction is considered in the development of a design by distributing the design to various discipline engineers, who review other systems which could be affected bv the design. An example of system interaction review is the auxiliary power system, which is influenced by the design of ot..er systems.

2 At IP's direction S&L developed a prcgram of interaction analyses to I. be carried out in accordance with project instruction PI-CP-034.

3. Lines of communication are established by S&L and IP Project Procedures. Individual engineers communicate informally on any given task, but requests for action or changes to design are handled formally according to procedures.

4. IP/NSED has principal communication responsibility with S&L on design matters.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Design Interfaces Objective No.: DC.2 Provide Factual Information that Supports the Performance Evaluation Summary

5. The "As Built" program for reanalysis of CAT-I piping and supports per NRC I&E Bulletin 79-14 is an example of S&L lines of communication with BA, plus IP design and construction personnel.

6. The transfer of "as built" data (i.e., from the CAT-1 piping program) from the field to S&L in Chicago for analysis and final acceptance is described in procedures PI-CP-028 & 030.

7. Information is coordinated with affected disciplines through S&L and IP/NSED procedures which include required distribution lists, forms, and modes of response.

8. The BA Procedures and S&L Project Instructions indices show procedure and instruction numbers with missing titles and no explanations for the actions or subsequent dispositions.

D. PI-CP-16 describes coordination of pipe and hanger interfaces with structural design. Checklists in this PI provide for coordination with other disciplines.

@. BA records control is covered by BAP 2-1, and is accomplished through various methods, including three day drawing checkout' limit, periodic audits, and followup audits if record errors exceed 2%.

1. Interface coordination of electrical and structural designers was noted in the electrical hanger design process.

PERFORMANCE EVALUATION SUMIiARY CLINTON CONSTRUCTION PROJECT erformance Area: Design Process Objective No. DC.3 valuator (s): M. Dye, P. !! eyer, W. Walling, C. Wheeler, P. Zimmer I. Performance Obiective The management of the design process should result in designs that are safe, reliable, verifiable, and in compliance with the design requirements.

KI. Scope of Evaluation The design process was evaluated by a five man team. Approximately 240 hours0.00278 days 0.0667 hours 3.968254e-4 weeks 9.132e-5 months were expended in interviews, observations, document reviews and evaluations. Sargent and Lundy was the principle focus of this review.

II. Conclusion S&L's overall design process meets this performance objective, with minor exceptions. Two findings are noted.

I

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Design Process Objective No.: DC.3 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer IV. Areas of Weakness and Corrective Action; Good Practices FINDING: There is no planned system of checks to verify that (DC.3-1) retraining, procedure changes and reorganization of the or-site small bore piping hanger-design group will preclude undetected design errors in the future.

CORRECTIVE In addition to S&L's re-review of small bore piping ACTION: hanger calculations, S&L will perform periodic independent spot checks of-calculations to assure the procedures have been implemented.

Also, IP's Nuclear Station Engineering Department is developing a program for an on-going technical surveillance of this activity. The specific plan to implement this procram is to be available in February of 1983.

FINDING: Unique HVAC hanger drawing preparation is being (DC.3-2) controlled by an interoffice memorandum rather than an approved project instruction.

. CORRECTIVE The unique HVAC hanger drawing preparation is controlled ACTION: by existing S&L procedures and standards. Unique requirements are covered by the reference memorandum.

Although we believe the system is adequately controlled, S&L has agreed to enhance the program by issuing a proiect instruction. The project instruction for these unique activities is being prepared and is scheduled for 1 issuance by December 30, 1982.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Design Process Objective No.: DC.3 3 .

Provide Factual Information that Supports the Performance Evaluation Summary

1. The design process is documented, planned, and individually scheduled in accordance with S&L procedures. The scope of work is included in each system specification. Planning and scheduling of design work is-handled by the Project Management Division.

2. Precedence networks are being used for planning and control of selected design tasks which have complicated interfaces, such as the Containment Vent and Purge System.

3. A schedule has been established to complete all (approximately 2700)

Seismic. Cat-I unique HVAC Hanger drawings by April 29, 1983.

4. Responsibilities for the design process are clearly defined in the Scope of Work SL-3021, K Specifications and position descriptions for each position at S&L.

3. BA had prepared, and was using for installation and inspection, isometric drawings (isos) of large bore safety related piping.

A. In order to insure that the piping was installed properly, S&L instituted a program for reviewing and assigning an official status to the isos.

B. Isos are verified as conforming to Status 1 No.6 and No.7 series

~ drawings.

C. The program has been implemented in accordance with the provisions of GQ 3.09 GDS 5.0, PI-CP-040 and a letter from IP authorizing the change in status.

D. These documents define the scope applicability, and QA requirements.

E. Reviewing is being done by senior lead designers who have been trained and evaluated in accordance with GQ 2.05.

N. Project instruction PI-CP-040, "S&L Review of Contractor's Isometric Piping Drawings", does not provide for formal preservation of the review checklists. At the verbal direction of the supervisor in charge of this review, they were being retained by one of the designers.

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PERFORMANCE EVALUATION DETAILS CLINTON COMSTRUCTION PROJECT orformance Area: Design Process Objective No.: DC.3 l

l

. Provide Factual Information that Supports the Performance Evaluation Summary

7. Scope charges such as the orelininary design for a major modification to the Containment Vent and Purge System, and producing individual HVAC duct hanger designs using computer-aided design / drafting (CAD) have been authorized by IP letters to S&L.

8. New computer aided HVAC hanger drawings will be subject to the same review and approval as the original drawings and will become the official design drawings. This process is governed by an interoffice memo dated 10-L5-82, signed by a supervisor. Currently there is no controlled procedure for this process. However, we were informed that a Project Instruction is being prepared.

9. In rasponse to NRC I&E Bulletin 79-14, containing ASME III requirements to perform reanalysis of "As Built" seismic Cat I piping, S&L has implemented procedures PI-CP-028 and 030. Reanalysec will'be done by computer, and only when design tolerances have been exceeded.

O. Review and follow-up of this analysis work is based on subsystems identified and tracked by schedules.

1. The division of responsibility for the Post-Accident Sampling System design was demonstrated. S&L performed the design and writing of the purchase specification, while BA will procure the. material after obtaining IP approval.

2. Interoffice memoranda (IOM) were used as a means for recording several decisions governing safety related work in the small bore piping hanger design area. When this was detected by S&L OA, procedure PI-CP-036 covering this work was revised to incorporate these decisions.

3. NSED procedure #10 provides for their review of a s^1ected number of safety related documents. Actual practice was to review 100% of all safety-related specifications, P&ID's and design criteria.

Specification K-2887, Rod Control Drive System was verified to have been reviewed by NSED. Comments had been resolved. The spec was certified by a registered professional engineer (PE), and the amendment was certified by another PE.

l PERFORMANCE EVALUATION DETAILS CLINTOM CONSTRUCTION PROJECT prformance Area: Design Process Objective No.: DC.3 Provide Factual Information that Supports the Performance Evaluation Summary

1. The K Specification includes scope and applicability and like the design drawings shows tho originator, reviewer, and approver.

(. > . Calculations or worksheets cere filed by the lead S&L engineer with the record copy of the Specification. This was demonstrated by a review of certain selected worksheets developed for the DC Power System Specification.

6 Pump. size and capacity calculations were made by the supplier for the post-accident monitoring system. Tests are scheduled to be performed to verify the calculations ano to satisfy the design requirements.

@. Computer analysis is used whenever possible to simplify the calculations involved such as the Drywell weir swell phenomenon.

Copies of programs are controlled according to procedures.

D. A backup for each computer code is maintained in a separate vault administered by QA. The source code is not available to the user.

If the source code is changed the program is given a new distinct name.

F. An independent reviewer or checker is assigned by the Senior Project Engineer responsible for the design process. The review is made in accordance with S&L standards, including the reviewer signing and dating the document at the conclusion of the review.

O. GQ 3.08 provides for independent review of design calculations, and provisions are implemented, for example, by PI-CP-16 for the piping analysis, component support, and structural load verification.

I

. The independent analytical results from Bechtel, S&W, and S&L of the postulated weir swell trancient provide an independent verification of the analytical techniques. (See DCl.)

f. Calculations supplied by the post-accident sampling System vendor were verifi,d and much of the equipnent had been independently tested prior to purchase.

p. Generic process problens are identified at the division level through weekly meetings with the S&L staff, from design work done on other projects, and from process review in the field.

PERFORMANCE EVALUATION DETAILS

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CLINTON CONSTRUCTION PROJECT erformance Area: Design Process Objective No.: DC.3 Provide Factual Information that Supports the Performance Evaluation Summary

6. Technical specialists in each area are designated by S&L procedures

-and are consulted on process problems.

5. An.Engineerind Division head interviewed was knowledgeable of the design process. His involvement in the design process includes allocating manpower to the project as required, controlling the release of confidential material, being the focal point for industry feedback, and maintaining an appropriate set of design standards.

The administration of the design staff is covered under departmental administrative procedures.

5. During an NSED review for potential seismic interactions, several errors were discovered in the small bore piping hanger designs.

A. These errors resulted from misinterpretation or misuse of procedures and/or standard designs. For instance several errors were the result of incorrect transposition of information from standard diagrams and tables to the unique designs. Some additions of pipe lengths to determine a total span also were found to be in error. The designs had been reviewed, but in several cases the errors were not detected.

B. The designers and reviewers had been trained by the S&L Engineering Mechanics (EM) Division in Chicago as to the basic techniques of designing these hangers, per EMD procedure EMD-015666 Rev. O. Then they were trained on site'as to the specific responsibilities and control methods delineated by Project Instruction PI-CP-036 " Design of Component Supports for 2 inch Diameter and Smaller Piping and Instrument Sensing Lines at the Clinton Site".

To correct this situation:

l A. The procedures were rewritten to amplify and clarify several steps, plus update and formalize an hitherto unofficial addendum.

p B. The designers were taken back to Chicago for retraining and the on site design group structure was rearranged t'o provide for closer monitoring of the design process.

C. All of the hangers for the 320 subsystems effected were recalculated to insure that there would be no safety problems.

PERFORMANCE EVALUATION DETAILS .

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CLINTON CONSTRUCTION PROJECT I erformance Area: Design Process Obiective No.: DC.3 i l

i k Provide Factual Information that Supports the Performance Evaluation Summary D. There-is no system of checks to verify that retraiqing, procedure changes, and reorganization of the on-site small bore piping hanger-design group will preclude undetected design errors in the future.

4 -Per mutual agreement of IP and S&L, there is no integrated overall design on design / construction schedule.

A. Timely support of the design process is dictated by the individual system design schedules. These schedules primarily are. driven by the schedule for turning over systems for testing and startup.

B. Design and design change priorities are established between IP and S&L in a monthly meeting (also attended by BA). Meeting notes contain a matrix of concerns and action items.

C. There also is a " turnover" meeting between BA and IP to establish schedules and associated requirements. These meetings also are used as followup mechanisms in an attempt to ensure that the design meets construction needs.

D. ~S&L project design team coordination meetings are held every two weeks to determine status, provide for information exchange-within S&L, and establish future action items. Working meetings on the potential modifications required on the Containment Vent and Purge System are examples.

S. Design processes are monitored for compliance with standards by checking them against the requirements of equipment & system specifications which contain the design standards.

. S&L Standard ME 1.11.2 describes the use of a checklist to ensure that all design commitments are in compliance with ASME B&PV code sect. III. The checklist for rod control Spec K-2887 was completed

.on 6-6-78 but did not have the preparer's name. Revision A of the standard dated 6-24-81 provides a space for the preparer's name.

. An S&L Senior Project Engineer has the responsibility for compliance with industry codes (ASME, IEEE, and NRC Reg. Guides and NUREG's).

Any significant code changes are distributed to each discipline on a weekly basis.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Design Process Objective No.: DC.3

, . Provide' Factual Information that Supports the Performance Evaluation Summary L. Special design process monitoring requirements are included in the specifications such as in Specification K-2887 (CRD Piping) the requirements for welding (GWS-1), Safety (R 140), etc.

2. Design control measures used in the S&L design process included field change requests (FCR), nonconformance reports (NCR), field engineering change notice (FECN), field engineering request (FER),

speed letter, and engineering change notice (ECN).

l. Quality Control Procedures were referred to by the S&L Engineers involved with the CRD Piping Design work.

l. IP/NSED decided to model its design control procedures after those of another utility, with nuclear plant design and operating experience.

They are in the process of changing their existing procedures into the new format and generating others required.

i. S&L considers cost in designing a system, as evidenced in a training class held at-the S&L offices in Chicago on November 2, 1982. Class instruction demonstrated that the S&L designers are taught to find and consider using the least expensive design required to meet the design criteria.

i. Design coordination can take the forn of a meeting (as the case of one observed on 11-3-82 wherein was discussed the status of action items related to design of the control rod-drive piping system),

telecons,_cr' assigned document reviews.

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I PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT arformance Area: Design Output Objective Nom : DC.4 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. ~immer I. Pfrformance Objective Project design documents should specify constructable designs in terms of complete, accurate, and understandable design requirements.

II. Scope of Evaluation A five man evaluation team reviewed selected design documents for the Clinton Plant. About 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months were expended in interviews, observations and evaluation of this design area. Organizations contacted were IP, S&L, and BA.

II. Conclusion S&L's design output is in accord with this performance objective, with minor-exceptions. There in one good practice noted.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT arformance Area: Design Output Objective No.: DC.4 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer:

IV. Areas of Weakness and Corrective Action; Good Practices FINDING: The.following good practice was noted:

(DC.4-1) Both IP and S&L have provided direction and expertise well beyond their established responsibilities for.CRD

' piping and hanger designs in order to expedite the contractor's design, analytical, fabrication, and construction work.

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I PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT prformance Area: Design Output Objective No.: DC.4 3

Provide Factual Information that Supports the Performance Evaluation Summary

i. The purpose of each type of design document is clearly defined in project instructions developed by S&L. Examples covering design documents include PI-CP-003, 004, 0021, and 0022.

@. A checksheet is being used for review of the CAT-I piping isos review to assure that the fincl design product is ccmplete and understandable.

@. S&L QA, and OC procedures related to CAT-I hanger orawings are being revised in the field to facilitate final check-out of the hangers.

Final review and approval still resides in S&L in Chicago.

B. In general the design packages are complete and understandable.

Exceptions noted were:

A. The use of generic designs for cable tray hangers. At one time several documents were required for fabrication, installation, and inspection of one electrical hanger. It was noted that BA now incorporates the details from these various inputs into unique hanger drawings of the BA-EHD series, thus reducing the number of documents used in the shop and field.

B. As a result of many problems in the field,.IP requested that S&L develop a program for CAT-I " Unique" HVAC hanger Drawings to produce a complete and easily understood drawing for QC final check-out and inspection. Items from several drawings, documents and complex tables, are required to produce these unique drawings. The S&L Computer Aided Design System (CAD) accomplishes this and turns out mylars of superior detail and clarity.

. S&L generally has been responsive to design clarification needs of IP, as implemented by speed letters or phone calls.

)

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT Design Output Objective No.: DC.4 3rformance Area:

Provide Factual Information that Supports the Performance Evaluation Summary

6. S&L was not immediately responsive to certain design and documentation needs of BA as evidenced by the lack of a timely response to BARK letters written by BA between April and July of 1982. These letters were at S&L Chicago undergoing a routine review by an S&L engineer. No priority or deadline had been assigned for responding to them. This appeared to be an isolated incident rather than a general practice.

7. Generally, the electrical design appears to have taken into account the capabilities and requirementa of suppliers and the constructor.

However, problems have been encountered since changes in the CRD piping and support systems which have resulted in having to make several changes in conduit routing and supports.

D. S&L has worked closely with Reactor Controls Inc. (RCI) and BA to.

help ensure constructability of the CRD piping. Both IP and S&L have gone beyond their established scope with RCI in the design and analysis of the CRD piping. They have provided technical guidance and expertise in the solving of several significant technical problems, even going so far as to place engineers in RCI's offices to assist and expedite.

9. Construction drawings are issued by S&L after proper review and approval by persons authorized by S&L procedures.

O. Once construction drawings are issued to the site, the drawings become the responsibili ty of BA, per Procedure BAP 2-1. Construction drawings are checked out of central drawing control centers and are limited to a three day checkout period.

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l PERFOlUiANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Design Chances Objective No.: DC.5 valuator (s): M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer I. Performance Objective Changes to released project design documents should be controlled to ensure that constructed designs comply with the most recent design requirements.

II. Scope of Evaluation A five man team expended approximately 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months reviewing documents, interviewing, observing and evaluating design change activities, both at Clinton Site and at S&L Chicago. Organizutions contacted included Illinois Power (NSED & Construction), Baldwin Associates (Project Engineering), and Sargent & Lundy.

II. Conclusion Design Changes are controlled in a manner so that they meet the intent of this performance objective.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 3rformance Area: Design Changes Objective No.: DC.5 valuator (s) : M. Dye, R. Meyer, W. Walling, C. Wheeler, P. Zimmer IV. Areas of Weakness and Corrective Action; Good Practices No findings.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Design Changes Objective No.: DC.5 Provide Factual Information that Supports the Performance Evaluation Summary

1. IP/NSED prepares a requisition justification memorandum indicating the impact on the safety and operation of the project of a proposed design change.

2. Cost effects are reviewed through all responsible IP organization levels, including top management.

3. Design changes can be initiated and incorporated in drawings by S&L field or Chicago based engineers. Changes are subject to a final review in accordance with S&L standards and project instructions.

4. S&L procedures require reviews and control measures to maintain consistency between the original designs and subsequent changes.

Authorized signatures are required.

. S&L has designated a field liaison group, by project instruction PI-CP-010, with responsibility to coordinate original design and design change activities between various organizations and disciplines in the field.

i. Overall design ichange) review is controlled by the same S&L standards and GQ Procedures as for initial designing and by project instructions written specifically for the Clinton project. At CPS, FCRs and NCRs are covered by PI-CP-003; and other change documents are covered by PI-CP-004, 021 and 022.

7 Reasons for design change requests are identified in design change documents, including Field Change Request (FCR) , Nonconformance Report (MCR), Field Engineering Change Notice (FECN), Field Engineering Request (FER), Speed Letter, and Field Problem Report

, (FPR). Design change documents are monitored by IP NSED for completion status and cost impacts.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT rformance Area: Design Changes Objective No.: DC.5 3

l Provide Factual Information that Supports the Performance Evaluation Summary

. Construction personnel indicated that some drawings are excessively complicated an require excessive revisions prior to construction or are subject to excessive field changes. (See also DC.4, item 4).

. Many changes have been required on the motor control centers (MCC) which were delivered to the site on a schedule set by IP and S&L, prior to implementation of then known design changes. IP Management determined that the need for MCC equipment delivery was greater than the potential difficulties which might be created by later field revisions.

. Design changes are reviewed by S&L Engineers for compatibility with original designs, and when approved are incorporated into the specifications by amendments. Interim changes (between amendments) may be made by attachment of ECN's.

. S&L and IP appear to have considered all the original system design inputs for the proposed changes to the Containment Vent end Purge System.

. S&L procedures do not specify a time period within which changed documents must he revised.

. Design and construction drawings are issued and updated by S&L under a controlled process. However, changes are not always posted to the drawings on a timely basis.

. PI-CP-01 governs the schedule / status of all design specifications.

The three safety-related specification examples listed below have large numbers of ECN's which have not been incorporated into the j

original specification. The nost recent revision was 10 months ago and the oldest was 54 months ago. One of the specifications had 42 change _ documents logged against it at the time of the INPO

, evaluation.

Spec Amendment Amendment Date No. ECNs K-2861 1 5-11-78 10 K-2865 2 6-10-81 12 K-2910 4 1-21-82 42

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT rrformance Area: Design Changes Objective No.: DC.5 Provide Factual Information that Supports the Performance Evaluation Summary

.. Currently S&L has a goal for rapid reduction of the backlog of documents requiring changes, and limiting the implementation of new document changes to 90 days. (Reference letter from S&L to IP, SLMI-8899, December 9, 1982).

,. It is expected that the three month backlog goal for FCR's and NCR's will be reached by the end of 1982, and for ECN's and FECN's by May 15, 1983.

. IP uses a computer to track change documents through the review stage. IP, S&L, and BA have access to the computer file but changes to the file are controlled by the use of entry pasewords. Terminals are located at S&L Chicago, on site, at NSED Decatur, and at IP headquarters.

. Intra- or inter-system impacts related to potential changes are reviewed by engineers of the affected disciplines, who have training, experience and responsibilities comparable to the original designer and original reviewers.

Such interface activities between mechanical, electrical and structural engineers were noted during observations of the CRD piping system design and the weir swell analysis work.

. S&L selectively utilizes precedence networks for planning and scheduling, and to determine impacts of proposed changes such as the containment vent and purge system.

. There is no formal design change control group. A design change control committee is being considered and the procedure to implement this activity is being reviewed. Proposed members include IP

' Engineering, Startup and Operations, S&L, Construction, and GE. It is expected that a procedure defining this committee will be implemented in January 1983.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

!formance Area: Construction Engineering Objective No.: CC.1

?

91uator(s): J. Dunkelberg, J. Pulley, R. Eimer I. Performance Objective Engineering and design performed under the' authority of the construction organization should be controlled as to consistency with the basig design criteria to ensure compliance with applicable codes, standards, and regulatory commitments.

8. -Scope of Evaluation The evaluation of this performance objective involved essentially-three team members. Approximately 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months were expended in interviews-with various levelstof IP, S&L, and BA supervision and engineering personnel and in various document reviews.

F.- Conalusion The activities evaluated under this performance objective were found to be acceptable.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT rformance Area: Construction Engineering Objective No.! CC.1 sluator(s): J. Dunkelberg, J. Pulley, R. Eimer V. Areas of Weakness and Corrective Action; Good Practices No findings.

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PERFORMANCE EVALUATION DETAILS CLINTnN CONSTRUCTION PFOJECT 1

I trformance Area: Construction Engineering Objective No.: CC.1 Provide Factual Information that Supports the Performance Evaluation Summary

. BA engineering activities are covered by procedures.(BAP's). They originate requisitions for the purchase of caterial, traveler packages, FCR's'and some drawings.

. Formal BA engineering interfaces with S&L are via controlled documents routed through NSED. Informal paths of communication are also used to support resolution of construction problems.

i. BA engineering interfaces with subcontractors and vendors other than G.E. and the independent testing company. The interface with.GE and the independent testing company is through IP.

l. Specific position descriptiens are not written for positions under the BA Senior Discipline Engineer. Only general descriptions are available.

i. The present time requirement to make a minor change / revision to a traveler ("Rud Line") is in many cases " slow".

i. The IPC-NSED Construction Engineering Supervisor is responsible for the control of NCRs, FCNs, etc. and establishes the direction of S&L's site groups effort. He also expedites GE work.

7 Control of changes (FCRs, FCNs, ECNs) at the site is being effectively maintained by IPC-NSED.

1 BA engineering is responsible for recommending dispositions for all NCRs and FCRs. S&L approves or re-diGpositions.

1 BA erection drawings for reinforcing steel are generated by BA engineer ing and reviewed by S&L. No desion is performed by BA.

1 There presently is not an engineering design freeze prior to system turnover to IP, although a " Design Change Control Program" is in development and in expected to be operational early in 1983.

'. IP construction engineers are the interface mechanism to resolve special problems and situations.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT trformance Area: Construction Engineering Objective No.: CC.1 Provide Factual Information that Supports the Performance Evaluation Summary

!. The.BA lead cable engineer has an effective interface with the S&L on site design group.

l. Cable pull and termination cards are distributed by the Document ,

Control Center with a transmittal letter.

l. The relationship between the Senior Electrical Engineer and his assistant is~not documented (other than on the organizational chart) nor is.it clearly defined.

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1 PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT rrformance Area: ' Construction Facilities OI'j ective No. : ;CC.2

& Equipment (

'aluator(s): J. Weaver,-1. Dunkelberg, G. Wuller

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I. Performance Objective Construction facilities and equipment should be planned for,

' acquired, installed, and maintained consistent with proje.ct needs, to support quality construction.

I. Scope of Evaluation This evaluation included interviews of Baldwin Associates Project Engineering personnel, Construction Equipment Superintendent, and >

various supervisors. It also included a review of maintenance i records, a walkdown of laydown areas, craft shops, maintenance shops, equipment storage and facilities. Approximately 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months were expended by 3 members of the evaluating tean in this effort.

I. Conclusion Site Construction Facilities and Equipment are adequate to support

. 0uality Construction. However, there is one finding noted.

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PERFORMAIICE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT-i.

rformance Area: Construction Facilities Objective No.: CC.2

& Equipment raluator ( s) : J.' Weaver, J. Dunkelberg, G. Wuller

V. Areas of Weakness and Corrective Action, Good Practices FINDING: Various site plans providing key locations of (CC.2-1) construction-facilities lack consistency and are not maintained.in an updated mode.

CORRECTIVE The construction facilities drawings are being updated.

ACTION: We anticipate a new issue April 1, 1983. After that, quarterly updates will be issued.

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PERFORMANCE EVALUATION DETATLS CLINTON CONSTRUCTION PRO.TECT rformance Area: Construction Facilities Objective No.: CC.2,

& Eculpment Provide Factual Information that Supports the Performance Evaluation Summary i

. BA Project Engineering group has drawings titled " Area Designations i (Laydown and Warehousing) Construction Facilities". The latest j The BA Asst.

revision (1979) does not incorporato added facilities.

Project Manager, The BA Safety Director and IP Security Department cach have a combination of drawings such as fire protection layout, electrical grounding, and BA Construction office trailer layout.

None of the drawings incorporates all of the existing laydown areas, offices, warehouses, and construction facilities.

. Periodic and Annual Construction Equipment Inspection records are maintained. Inspection and maintenance is verified by BA QC and is performed on a regular basis with a 4 to 6 week time span.

. Magnetic Particle Inspection is performed on all lifting hooks on an annual basis. Records verify these inspections are performed.

Automotive maintenance and heavy equipment maintenance is performed and recorded.

. Various building Superintendents coordinate crane requirements in his area for all disciplines. Equipment needs are coordinated through the BA Equipment Superintendent and an IP representative.

.. Electrical & Piping Area Superintendents indicated that they have proper tool., to perform their work.

. Heavy slings and chokers used by all crafts, are stored in a rack, with a cover, in a neat and orderly fashion.

. Safety and Non Safety materials are segregated and areas are g

identified by signs.

. Pipe conduit, forms. structural shapes and HVAC duct are stored on donnage or in racks.

. Pipe and. duct ends are capped.

. Laydown areas have a crushed stone base and proper dunnage has been provided.

PERFORMANCE EVALUATIOM DETAIT.S CLINTON CONSTRUCTION PROJECT rformanco ?.rea: Construction Facilities Objective No.: CC.2

& Equipment Provide Factual Information that Supports the Performance Evaluation Summary

. Roads provide sufficient access to all areas, shops and facilities.

. A crane laydown area has been established and is of sufficient size to store crano counterweights, booms, hooks, cable, etc.

. -A parking area has been established for construction equipment, trailer mounted generator / lights, trucks, scrapers, etc.

. Gas bottles are stored in vertical racks and tied off.

Miscellaneous conduit pipe and structural shapes are stored in racks for the craft fabrication and assembly shops.

. i'he need for' equipment is identified in advance and coordinated to support construction activities.

PERFORMANCE EVALUATIOFI StiMMARY i

CLIUTON CONSTRUCTION PROJP,CT 4

rfornance Area: Material Control Objective No.: CC.3 91uator(s): J. Weaver, G. Wu))er, R. Eimer I. Performance Objective Material and. equipment should be inspected, controlled, and maintained to ensure the final as-built condition meets design and operational requirements.

I. Scope of Evaluation The evaluation of this objective was conducted by physically following the receiving and inspection process, the identification of materials, warehouse or storage designation, issuance of material-and the proper tagging per procedure. Inventory control, access control and the control of non-conforming materials were also reviewed.

Approximately 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months were devoted by three team members to discussions with various levels of management, supervision and those performing the physical work and in the raview of procedures and (

documents.

I. Conclusion Activities involved in this evaluation were generally good, although two areas of weakness were noted which should he addressed to improve the quality program.

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l PERFORMANCP EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT rfbrmance Area: Material Control Objective No.: CC.3 91uator (s) : J. Weaver, G. Wuller, R. Eimer V. Areas of Weakness and Corrective Action, Good Practices FINDING: Access control and an adequate system of well defined (CC.3-1) authorities and responsibilities for storage control does not exist for the Illinois Power Permanent Warehouse.

' CORRECTIVE A CPS plant procedure will be prepared and implemented ACTION: by December 15, 1982 to delineate responsibilities and methods for access control, and material storage area control.

In addition, the following measures have also been taken:

1. Storeroom personnel have been directed to insure that all CPS plant personnel, not on the authorized access list, are logged and badged prior to entry, and arc escorted while in the storage areas.

2. Storage personnel have been directed to detain all other personnel, not on the authorized access list, desiring access to the construction material storage areas until the IPC Receiving and Warehousing Supervisor can provide an escort, and such personnel are logged and badged for access.

3. Signs have been posted at the storage area entrance which identify personnel who are authorized unescorted access, and which prohibit access to all other personnel without an escort.

4. Sxons are being prepared, and attached to the flagged ropes surroundi'ng the construction material storage areas, to clearly identify these flagged areas as construction material storage areas. This g

action will be completed by December 3, 1982.

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PERPORf!ANCE EVALUATION

SUMMARY

CI.TNTON CONSTRUCTTON PHO.TECT

rformance Area: Material Control Objective No.: CC.3 eluator(s): J. Weaver, G. Wuller, R. Eimer

k. Areas of Weakness and Corrective Action; Good Practices FINDING: Permanent-plant equipment requiring a nitrogen purge is (CC.3-2) not being maintained per requirsments.

CORRECTIVE DA will evaluate the procedural requirements and their ACTION: implementation. Action as a result of this evaluation will be taken by March 1, 1983.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'rformance Area: Material Control Objective No.: CC.3 Provide Factual Information that Supports the Performance Evaluation Summarv i

. Authorities and responsibilit.ies regarding the IP Permanent Warehouse

are not defined clearly enough to assure that materials are properly j iden~tified and srcred. Some safety-related material is stored in the IP Permanent Warehouse without tagging to identify the storage status or required disposition.

!. Safety related permanent plant materials are stored in an area (IP Permanent Warehouse) which does not have a procedure for access control.

. The' Storage and Maintenance Program is not being totally implemented or followed in accordance with the approved procedures and instructions. Some examples of problem areas are

a) some equipment designated for controlled nitrogen purging has not l had a purge since November 1981, due to construction work in

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progress.

b) the purge pressure is being exceeded on some equipment being stored in its permanent position in the plant.

l.- A lubrication inventory has been completed but a lubrication control program has presently not been implemented.

!. Computer printouts are utilized and updated by PA Project Engineering l for identifying equipnent locations and time spans for maintenance requirements.

i. An accurate inventory control system which identifies the location of l items in storage is being implemented using the constructors

procedures. Personnel are knowledgeable of and are generally l

following approved procedures.

I The in-plant ntoreroom process appears to be working well and

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.provides adequate controlled issuance of materials.

.: The receiving process is conducted competently and, with very few

[ problems, in accordance with approved procedures. Equipment and

materials are properly evaluated upon receipt, identified and inspected. Adequate records are now being maintained.

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PERFORMANCE EVALUATION DFTAILS CLINTON CONSTRUCTION PROJECT

'rformance Area: Material Control Objective No.: CC.3 Provide Factual Information that Supports the Performance Evaluation Summary

. A very cooperative relationship exists in receiving inspection between warehouse personnel and quality control receiving inspectors.

. Quality control receiving inspectors and supervision are involved in the review process (i.e., reviews prior to final approval) for procedure changes in the areas of their involvament.

. The issuance of safety related materials from the warehouses is being handled satisfactorily and personnel involved are informed of the procedure and the documentation required.

. The cable pulling and pre-cutting system works well; and personnel are conscious of the need for good records and traceability. Each reel of cable is identified, stored in recorded locations, and monitored. Each length of cable removed is recorded on the reel records and on the cable pull cards.

. Maintenance of equipment in the warehouses is being perforned in accordance with procedures and the manufacturer's manuals.

. The handling of a specific nonconformance dealing with piping materials was evaluated and it was found that the approved procedure was properly followed to close out. The nonconforninc item was returned to the vendor for replacement.

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PERFORMANCE EVALUATION SUMMAM CLINTON CONSTRUCTION PROJECT

'erformance Area: Control of Construction Objective No.: CC.4 Processes

' valuator (s) : R. Eimer, J. Pulley, J. Weaver, W. Futrell I. Performance Objective The construction organization should monitor and control all construction processes to ensure the project is completed to design requirements and that a high level of quality is achieved.

IT. Scope of Evalr.ation The evaluation of this objective involved four team members.

Approximately 110 hours0.00127 days 0.0306 hours 1.818783e-4 weeks 4.1855e-5 months were devoted to observations, discussions, document reviews, and interviews with various levels of management, supervision, and craftsmen. It should be noted that most of the effort for this evaluation was focused on electrical and piping, the two areas where the majority of work is left to_be done. Also of importance is the fact that present construction activitiee are severely constrained due to Stop Work Orders and subsequent recovery efforts. This recovery effort resulted in recent and ongoing changes in organization, training and procedures.

II. Conclusion The construction processes evaluated and activities observed were found to be generally satisfactory and performed in accordance with procedures. There were, however, two areas of weakness which were identified.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

'erformance Area: Control of Construction Objective No.: CC.4 Processes

valuator ( s) : R. Eimer, J. Pulley, J. Weaver, U. Futrell IV. Areas of Weakness and Corrective Action; Good Practices FINDING: Most field personnel including Superintendents and area (CC.4-1) engineers are not notified in advance of future activities and plan nuch of their work on an "as needed" basis.

CORRECTIVE Current project direction, based on the criticality ACTION: of stop work orders, is to close-out the inspection backlog. B.A. planning and scheduling is currently involved in the development of Level III schedules to provide detailed direction on work activities leading to the lifting of stop work orders. Other Level III schedules, as well as summary schedules are being developed for those activities not affected by stop works. This work scheduling activity is expected to be implemented by May 31, 1983.

FINDING: BA traveler program is unduly complex and requires (CC.4-2) streamlining. In addition, the unknown status of travelers and associated design changes is adversely impacting the turnover process.

CORRECTIVE BA shall review the entire traveler program in order ACTION: to evaluate the program for necessary changes which will simplify the system while ensuring that the traveler status and the associated design changes are readily determinable. The review of the entire traveler program will be completed by March 31, 1983. Enhancements, indicated by the review results, will be incorporated into the program.

A Traveler Tracking System is being developed using the IP Computer System and is expected to be operational by June 30, 1983. Until that time, manual checks can be accomplished to serve our needs.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rformance Area: Control of Construction Objective No.: CC.4 Processes

. Provide Factual Information that Supports the Performance Evaluation Summary L. One lead engineer stated that his department was efficiently handing work with less than the authorized thirty or so people. He stated that QA cudits verified the quality of their work and that the department's procedures worked well.

I. All procedures affecting cable pulling and terminating are being revised as part of the recovery effort on the Stop Work Orders.

l. An electrical superintendent indicated that the entire electrical organization was striving to produce a quality job, but had experienced a certain amount of frustration because of QC rejects and Stop Work Orders.

. A field superintendent indicated that drawings were generally current and that termination cards provided a method to cross check drawing revision to assure that field installation prints were up-to-date.

. Cable pull cards are released for construction based on a

" Candidates for Pull" list.

. Cable engineering does not release termination cards until after a cable has been pulled and all of its documentation approved.

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. Field engineers and craft personnel consider the cable pull cards to

! be a good method to install and track cable installations.

. The individuals interviewed who are involved in electrical activities indicated that the procedures and job instructions, especially those issued in the last several months, are adequate and are being used.

They also indicated that proper tools were available and used.

4 Cable pre-cut activities are handled by methods and procedures which were mainly developed by on-the-job experience, some of which are not written procedures.

o Some electricians indicated that they have received no formal training on cable pulling, but they felt they were qualified based on the job experience and the union apprenticeship program.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT srformance Area: Control of Construction Objective No.: CC.4 Processes

> Provide Factual Information that Supports the Performance Evaluation Summary

!. A superintendent and a foreman indicated that cable pulling and associated procedures (QC, nonconformances, etc.), though adequate, were spread out over many manuals.

1. The final approval signatures required for procedures are the BA Project Engineer, the BA Manager of Quality and Technical Services, the BA Project Manager, and Illinois Power. Some of the contractor's disciplines were concerned that they were not involved during the approval stage of the procedural review.

I. Baldwin Associate's QC does not perform "in process" inspection for piping work packages. Only final inspections are made. The Technical Services Department (TS) is the inspecting authority on all safety related welding. TS does perform "in process" welding inspection.

. The piping discipline has established a verification group which performs audit type functions before release of work packages to QC.

This group also maintains a complete status of all work packages released to the field for construction.

!. Inspections performed by field engineers of conduit and raceway hangers are performed as per written procedures.

. A team of craftsmen has been established by the electrical discipline which pre-inspects all hangers, conduit, and tray installations before releasing the work to QC for final inspection.

. A field superintendent responsible for cable terminations has established his own procedure by which he or his foremen inspect all completed work before releasing it for final inspection. This effort as well as the efforts of his crews were directed at keeping the work rejected to a minimum.

. Illinois Power Engineers have been assigned to monitor hanger documentation in the containment area. One craft foreman indicated that this help has been quite valuable.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

?arformance Area: Control of Construction Objective No.: CC.4 Processes

[. Provide Factual Information that Supports the Performance Evaluation Summary L9. Work associated with safety related cable trays is released based on a priority list established by Illinois Power as part of the recovery effort to lift the Stop Work Orders.

H3 . One engineer indicated that work activities generally are assigned and scheduled on an "as needed" or " reactionary" basis.

fl. Raceway work is released to field superintendents based on a schedule which identifies which trays can be built. The field superintendent must then request the work which he is ready to do.

2: . A lead QC inspector indicated that their work was mainly

" reactionary" and not planned in advance. He received little advance notice of future activities.

3. A BA QC group, the "Inprocess Traveler Control Group" has been established as the overall controlling organization of work released for construction in the safety related areas. Many construction personnel feel this group has and will continue to slow construction activity. So far, only a trial group of work activities has been released through this group.

4 A superintendent indicated that he has little advance notice of work activities. He, therefore, has difficulty determining his manpower requirements in time to sufficiently train new craftsmen.

5. A subcontractor for sealing penetrations shows low productivity levels and little control by the contractor. Most penetrations had not yet been released to the subcontractor and no planning or scheduling was evident for the subcontractor's activities.

.6. An electrical superintendent whose crew is involved in mostly non-safety related work, indicated that his crews were generally kept busy.

7. The contractor's area civil engineers are not formally trained and have no required reading material for training.

8. Field engineers are not required to have college degrees. Many have worked their way through the lower discipline organizations.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT Parformance Area: Control of Construction Objective No.: CC.4 Processes I. Provide Factual Information that Supports the Performance Evaluation Summary

29. A raceway engineer had no experience other than that attained by working through the cable engineering group. He had been on the job site about two years and in his present position for about a year.

30. One BA area engineer stated that most of BA's field engineers lacked experience and had little formal engineering education. Because of redundancy built into the field construction process, this inexperience rarely affected product quality.

31. Cable tray hangers are installed using individual drawings generated by the contractor's drafting department and field engineers using S&L's specifications. Drawings must then be approved by S&L before field installation. Field engineers are responsible for ensuring that final drawings reflect as built conditions.

12l . Technical Service personnel submit DR's and NCR's to field engineers for recommendations on resolving welding problems.

13 . The AE allows by specification, the installation of reinforcing steel using detail drawings as the basis for placement acceptance.

Reinforcing steel is inspected by QC using detail drawings which have l been reviewed by the AE, and the design drawing.

4. Large bore piping traveler packages are excessively large and I cumbersome to work with.

5. No listing of Travelers is available which reflects the current status of who has responsibility for action; such as Field Engineering, Traveler Control, Construction, QC Vault. The necessary additional follow-up and unknown status to Travelers are creating delays in the overall turnover process.

6. The traveler package used to release construction work has sufficient detail. Traveler package procedures are being followed.

7. Several activities observed in the piping area were being performed in accordance with procedures. These included ostaining safety related equipment from a warehouse, rework of a piping spool, and pipe fit up work.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT grformance Area: Control of Construction Objective No.: CC.4 Processes

. Provide Factual Information that Supports the Performance Evaluation Summary

8. Rework on electric hangers is handled by procedure. Minor changes on work packages can be made by obtaining a QC and TS sign-off. This takes about a half a day.

9. Many senior level superintendents in both electrical and piping disciplines have many years of related construction experience. Some examples include the Construction Equipment Superintendent (16 years), Containment Building Superintendent (12 years) and Senior Piping Superintendent (8 years onsite plus previous nuclear experience).

). Several IP project personnel felt that Baldwin Associates electrical partner's corporate organization is small and lacks nuclear experience from which to draw.

L. Most piping personnel indicated that proper tools were available and used.

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. Most personnel interviewed indicated that both their superiors and their subordinates were qualified for their jobs.

l. Cable pans are installed with torque wrenches as per procedures.

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. Recent organizational changes, especially in the upper management l level of the IP-BA project group, are perceived by field personnel as I

an aid in resolving problems.

. There is no formal mechanism for timely feedback to IP or S&L the construction completion status of an authorized change. Often the fact that a change has been made is not known by IP until the "walkdown" for system turnover.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Performance Area: Construction Quality Inspections ' Objective No.: CC.5 qva luator (s) : J. Pulley, R. Eimer, J. Weaver, G. Wuller, D. Schweickert S. Bakunas, J. Dunkelburg I. Performance Objective Construction inspections should verify and document that the fi al product meets the design and quality requirements.

II. Scope of Evaluation The evaluation of Construction Quality Inspections included the following:

a) Observations of various inspectors and crafts performing their inspections in the field.

b) Interviews and discussions with crafts, inspectors, superintendents, engineers, supervisors, and middle managers.

c) Reviews of inspection records, training reccrds, certification records, and traveler packages.

Approximately 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months were spent by 7 members of the evaluating team accumulating and documenting the information concerning this performance objective.

XI. Conclusion Presently the quality inspection activities are satisfactorily meeting the design and quality requirements of'the project,.although there are indications of problems with their ai;ility to keep up with an accelerated construction schedule. There are two findings noted.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT ierformance Area: Construction Quality Inspections Objective No.: CC.5 ivaluator(s): J. Pulley, R. Eimer, J. Weaver, G. Wuller, D. Schweickert S. Bakunas, J. Dunkelburg

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IV. Areas of Weakness and Corrective Action; Good Practices FINDING: Inspection acceptance criteria, tolerances, and scope (CC.5-1) are not clearly understood or uniformly applied by QC inspectors.

4 CORRECTIVE All BA Procedures, Quality Control Instructions and' ACTION: Technical Services Instructions have been rewritten and applicable training of QC Inspectorn has been completed as of December 7, 1982. This will be an onacing effort.

FINDING: The Quality organizations are controlling the pace of (CC . 5-2 ) the project instead of coordinating their efforts with that of construction for the support of the project.

CORRECTIVE Earlier this year, it was found that the Construction

!. ACTION: pace of work was proceeding without any consideration for tiraely inspection. A commitment has been made to change the scheduling concept and work off the inspection backlog of completed work to an acceptable level by May 1, 1983.

By May 31, 1983, quality requirements will have been

inserted into the Project schedule to assure achievement i of timely inspection.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT berformance Area: Construction Quality Inspections Objective'No.: CC.5

. Provide Factual Information that Supports the Performance Evaluation Summary

1. The Electrical and Piping Departments' personnel feel that the inspection process used by OC needs clarification in allowable tolerances.

2. Some BA superintendents are not familiar with the inspectors acceptance criteria.

3. Some QC inspectors feel that their procedures could be more definitive.

4. Installations may be rejected without giving clear definitive reasons for the rejection to the construction personnel.

i. Many construction personnel indicated some QC inspectors do not know how to properly use inspection tools.

6. Welding inspections performed by BA Tech Services (TS) a'r.e defined by code; AWS or ASME as indicated in the traveler package.

7. The reporting of degraded quality is effective and paths for reporting are open. There was no evidence of the discouragement of the reporting degraded quality from any source.

p. Both the Electrical and Piping Departments have formed their own

" Inspection / Verification Teams" to perform inspections, reviews, and walkdowns prior to notifying QC for a final' inspection.

). Both'the construction and quality organizations feel that the QC and 1

TS inspectors are separate from the production function.

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The Electrical Department feels that QC and TS are so separate that they do not support the construction effort.

Core drilling is monitored from start to finish by QC, from the withdrawal of to the return of the drill bit to stores.

f. The Piping and Electrical Department maintains that there is a need for increased "in-process" inspections to be performed by QC.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 5erformance Area: Construction Quality Inspections Objective No.: CC.5

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. Provide Factual Information that Supports the Performance. Evaluation Summary

3. The Piping Department maintains that the assignment of,0C supervisors to building areas would improve the coordination of inspection activities and avoid delays.

4. Inspection "!!ald Points" are indicated in the traveler package.

Notification to inspectors is by phor.e or radio.

5. Welding inspection is presently meeting the projects work' scheduling requirements. The recent loss of a number of TS welding inspectors leaves doubt as to the ability of the TS Department to keep up with

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required inspections when the "Stop Work" orders are lifted.

6. Personnel in the Electrical and Piping Departments maintain that the "In Process Traveler Control Group" (ITCG) are and will continue to slow down the construction effort, especially after the stop work orders are lifted.

7. Some-QC, TS, and Construction personnel felt that the Quality group is separate from the rest of the project to a degree that they are not necessarily supporting the construction effort.

@. A calibration recall system is in effect to ensure that inspection

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measuring and test equipment is properly calibrated.

p. The Inprocess Traveler Control Group (ITCG) controls the safety related work released for construction. The ITCG reports to BA QC.

B. QC inspectors use checklists to perform their inspections. Results are recorded on the checklists and travelers.

$. TS inspectors use a checklist for hanger inspection and use the f traveler as a checklist for_ piping. Results are recorded in the traveler package.

h. Inspection Records are reviewed by the Construction Organization and Ouality-organization before final storage.

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PERFORMANCE EVALUATION SUtiMARY CLINTON' CONSTRUCTION PROJECT Srformance Area: Construction Corrective Actions Objective No.: CC.6 Faluator(s): J. Dunkelberg, G. Wuller, R. Eimer I. Performance Objective The construction organization should evaluate audits, inspections, and surveillances; process replies and follow-up; and take

. corrective action to prevent recurrence of similar problems.

.11. Scope of Evaluation The evaluation of this area involved three members of the team.

Approximately 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months were expended in discussions with various t -- levels of the project supervision and management and.in the review of documents.

2I. Conclusion i'

The evaluation of this performance objective identifies some weaknesses which allow recurrences of conditions and activities .

adverse to quality. This resulted in two findings, j

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PERFORMisNCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

'erformance Area: Construction Corrective Actions Objective No.: CC.6 svaluator(s): J. Dunkelberg, G. Wuller, R. Eimer IV. Areas of Weakness and Corrective Action; Good Practices FINDING: The BA corrective action system is not fully achieving (CC.6-1) effective corrective actions involving construction

. crafts.

CORRECTIVE A Quality Accountability Program is being developed by ACTION: BA Project Management' and should be implemented during the first ouarter of 1983.

FINDING: The present trending analysis system is not identifying (CC.6-2) trends nor assigning actions to correct the underlying problems in an effective or timely manner.

CORRECTIVE The following items are being implemented:

ACTION: A) A CRT Terminal is to be added on December 10, 1982, and tied into IPC's Main Frame Computer for the NCR/DR Tracking Program.

B) On December 1, 1982, the BA NCP/DR coding system was enhanced such that generic concerns were addressed.

C) Complete overhauling by January 15, 1983, of the BA trending system will include addition of a data processor, more comprehensive training of personnel, and adding to the staff of people experienced in this area.

PERFORMANCE EVALUATTON DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Construction Corrective Actions Objective No.: CC.6

. Provide Factual Information that Supports the Performance Evaluation Summary

1. An understanding of required interfaces between Quality control and Construction to support the work effort is lacking.

2. A philosophical difference appears to exist between BA Project Engineering and BA Quality Assurance over the requirement for corrective action for nonconformances. The positions are: a. BAQA feels a condition is significant simply because an NCR has been generated, b. Project Engineering feels NCR's do not inherently imply the existence of a significant adverse quality condition, i.e., some NCR's are dispositioned by " accept as.is".

3. Nonconformances are handled in accordance with a procedure. The procedural requirement for corrective action on deviations (DR's) and nonconformances (NCR's) is not fully effective in preventing recurrence.

4. Proposed revisions to the procedure for the handling of nonconformances are in the review cycle. Responsibility for vendor interfacing on NCR's is anticipated to transfer from BA Project Engineering to the BA Discipline Engineering Groups.

$. The majority of corrective actions for deviations and nonconformances are selected by Proicct Engineering from a matrix of standardized responses,

b. Project Engineering reviews deviations and nonconformances on a discipline basis; there is no eviaence that Project problems are considered other than as may be discussed at weekly staff meetings.

7. About~one-half of the deviation reports are written against construction craft problems; the balance are against paper problems.

D. Currently Piping Engineering meets weekly with QA to review DR's and NCR's.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT berformance Area: Construction Corrective Actions Objective No.: CC.6

. Provide Factual Information that Supports the Performance Evaluation.

Summary

9. The problems with current methodology for trending analysis are:

a) reporting is about 3 months behind schedule.

b) a large backlog of QC inspections exists.

c) old work being inspected is generating deviations in areas where tPe construction activity is completed, d) tracking / trending does not consider the level of construction activity, c) trend analysis reports do not make assignments for action items, f) Nonconformances and problems are not categorized in a consistent nanner, and the discipline engineers are not in full agreement on the categories which QA has established.

Efforts are underway to upgrade the trending efforts.

O. As of 10/22/82 -a total of 34,457 electrical travelers were issued; approx. 13,000 are completed and in the vault. In a past accountability determination, the electrical department could not find or account for approximately 30 travelers out of a total of about 32,000.

3. The Project Engineer has been given an additional new assignment to develop a " Quality Accountability Program" with the objective of enhancing qual'ity work by craftsmen. Target schedule for program implementation is January 1983.

R. The piping department maintains a status log of NCR's, DR's, CWR's, FCF's, etc. which are updated on a weekly basis. The records are used as a system to control work and to track and expedite dispositions for close out of the documents.

h. Problem areas in the piping department which need management attention are reported to upper management verbally at staff meetings.

. Approximately five people in the electrical department have been terminated for failure to follow procedures over the last four years.

PEhFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Test Equipment Control Objective No.: CC.7 valuator (s): R. Einer, G. King I. Perfornance Objective Measuring and test equipment should be controlled to support construction testing effectively.

TI. Scope of Evaluation The evaluation of this objective involved two team members.

Approximately 25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months were spent observing work practices and interviewing personnel associated with the contractor's QC calibration lab, the independent testing company's calibration lab, and the utility's calibration lab. Lab and calibration procedures were examined along with various documents including calibration records, out-of-tolerance reports, and approved vendor's lists.

TI. Conclusion The majority of test equipment control evaluated by this team was found to be satisfactory and according to procedures. However, two noted findings indicate weaknesses in some of these procedures.

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PERFORf1ANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT lerformance Area: Test Equipment Contiol Objective No.: CC.7 ivaluator ( s) : 'R. Eimer, G. King

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IV. Areas of Weakness an'd Corrective Action; Good Practices FINDING: Quality assurance pre-award evaluations or post-award (CC.7-1) audits are not being done for suppliers of safety related calibration services who calibrate measuring and test cquipment (?!&TE) standards utilized by IP Startup Plant Staff, BA Construction, BA OC, and the independent lab. This service includes:

1) suppliers who offer calibration services for M&TE which are not manufactured by them.

2) suppliers who offer calibration services for M&TE which they manufacture.

CORRECTIVE Baldwin Associates Quality Assurance and Illinois Power ACTION: Quality Assurance will review all suppliers of measuring and test equipment calibration services to assure the quality of the service and product provided. This review will be completed by March, 1983.

FINDING: The BA control of measuring and test equ'ipment (both for (CC.7-2) construction and inspection) in the area of equipment recall is inadequate.

CORRECTIVE In order to obtain the prompt return of tools for ACTION: recalibration, BA will evaluate a potential way to streamline the system of recall of tools requiring calibration. This_ evaluation will be complete by January 31, 1983.

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Pi RPORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'crformance Area: Test Equipment Control Objective No.: CC.7

. Provide Factual Information that Supports the Performance Evaluation Summary Utility's Calibration Facilities

1. IP's calibration program is established as per procedures.

2. Each item is tracked for recall & recalibrations and the files are current.

3. Individual calibration procedures are written for the calibration of each piece of M&TE.

4 A computer is used to track devices calibrated by each piece of test equipment. This computer facilitates corrective action when out of tolerances are found.

5. The calibration lab is an environmentally controlled area and ronitored by recorders.

p. There is a system in place to segregate and control out-of-tolerance l and noncontrolled equipment from controlled equipment.

h. Preliminary standards are used to calibrate portable M&TE. The l

primary standards are sent out for calibration and certification and are traceable to National Bureau of Standards (NBS). The original vendor is utilized in most cases. These vendors are not surveyed or audited by IP QA. The calibration service is not considered a safety related service.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT rrformance. Area: Test Equipment Control Obje ctive No. : CC.7

. Provide Factual Information that Supports the Performance Evaluation Summary BA's Calibration Facilities

1. All test and calibration is identified by a unique " control number" as per a QC procedure.

2. Calibration cycles have been established based on manufacturer's specifications and industry history. Further adjustment to cycles are made based on usage and fie!d experience.

3. Calibration Deficiency Notifications (CDN) are used by procedure to notify lead field personnel of out-of-tolerance or damaged equipment.

The disposition and return of these CDN's is the responsibility of the field personnel. Any nonconformances which are necessary because of a CDN are submitted by field personnel.

4. Equipment sent off site to be calibrated by outside agencies is required to have a Certificate of Compliance from the agency. The certificate addresses all special requirements submitted by the contractor and assures that the equipment is traceable to NBS or nationally recognized standards. These agencies are not surveyed or audited by BA QA for a safety related service.

5. The contractor's calibration lab is of sufficient size to handle the calibration needs of the job site.

2 Controlled equipment is segregated from non-controlled equipment through the use of lockers.

f. Individual calibration procedures have been established for each type l of device which is calibrated in the lab. These are QA procedures l

which have had limited distribution, but will eventually be incorporated in the main Quality Control Instruction manual.

3. Quality test equipment is tracked bv procedure through the use of a sign out forn. It the device is to be used tor quality inspection work, it must be nigned out and all work packages for which the device will be used must be recorded on the log.

p. Craft personnel do not always return calibrated tools to the calibration lab before the expiration date.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Test Equipment Control Objective No.: CC.7

. Provide Factual information that Supports the Performance Evaluation Summary B. The calibration lab has no method to follow up on calibrated tools which are lost.

1 All "as found" and "as left" readings are recorded on individual forms which are identified by the individual calibration procedures.

If a device is found in calibration, it is not adjusted and the "as found" readings become the "as left" readings.

2. BA calibration lab is environmentally controlled, for both temperature and relative humidity. ,

1 Calibration lab personnel contro) equipment through the use of a dual card system.

1. The entire calibration cycle control system is a manual operation.

i. Equipment observed in the field was noted to be uniquely identified and within the current calibration cycle.

h. Cable terminators enter the control number of the crimpers they use j on the cable termination card.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTIOW PROJECT forformance Area: Test Equipment Control Objective No.: CC.7 E. Provide Factual Information that Supporte the Performance Evaluation Summary Independent Testing Company's Pacilities

1. The calibration lab, though it shares its facilities with the photo lab, is of sufficient size to support calibrations.

2. Uncalibrated equipment or damaged equipment is segregated from the calibrated devices through the use of lockable storage cabinets or holding areas and out of calibration tags.

3. Checkout and control of calibrated equipment is not handled by the calibratior, log. There is no sign out log in the cal. lab.

4 The lab is not environmentally controlled. This was identified in an earlier IP QA audit.

5. Test equipment used in testing and construction is tracked to individual tests by procedure using Non-Destructive Examination and Civil Material Testing reports.

'6. Test and tested equipment is identified by a unique number. The system of numbering is an internal procedure.

7. A card file index is used to control calibration cycles. Cards for next months calibrations are pulled one to two weeks early. A listing of the devices which need to be calibrated is put on a form and sent to field personnel. These personnel are then responsible for returning the equipment to the lab for calibration.

8. Retest requirements for out of tolerance equipment is defined by procedure through an Internal Corrective Action Request (ICAR).

Although the Level III inspector can issue NCR's, most nonconformances due to out of tolerance equipment are submitted by appropriate field discipline personnel.

p. All test equipment is traceable to material standards.

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PERFORMANCE EVALUATION DETAILS j' CLINTON CONSTRUCTION PROJECT ,

3rformance' Area: Test Equipment Control ' Objective No. : j CC.7

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. Provide Factual Information that Supports the Performance Evaluatic.n, ;

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0. All test equipment is purchased and submitted'for.outhide calibration when necessary, through the' utility's organizationc All outside agencies us'ed in' calibration were stated to be on the.e9pr'oved. _

vendor's list and qualified,.unless they were governmenta].-bodies.- . ,

Outside calibration services, however, are handled-throughtthe- /

utility's purchasing organization. ,j 1.- Individual. calibration instructions for each unique piece of .. .'-

-equipment are available and often reference ASTN standards'. -

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PEDFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

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trformance Areai Industrial Safety- Objective No.: PS . l~

' valuator (s); ER. Kruep, D./Schweickert, G. Wuller,.R. Eimer, J. Weaver J -

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ff I. Performance Obiective

> w The construction site industrial safety program should achieve a high degree of personnel safety.

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II. Scope of Evaluation

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The evaluation of-this objective involved the entire team.

Approximately 55 hours6.365741e-4 days 0.0153 hours 9.093915e-5 weeks 2.09275e-5 months were devoted to: discussions with various levels of site management and craft personnel; observations, and analysis,of documentation and procedures related to the industrial safety' area.

s RI .- Conclusion The industrial safety. program at-Clinton does achieve a high degree Jof personnel sa,fetp. However, there are 'ru3 written procedures which clearly delineate the responsibilities of the safety department, and the. eye safety program-is deficient. Two findings are noted.

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r PERFORMANCE EVALUATION

SUMMARY

)

CLINTON CONSTRUCTION PROJECT

'erformance L Area: Industrial Safety Objective No.: PS.1-l valuator (s) : ' R. Kruep, D. .Schweickert, G. Wuller, R. Eimer, J. Weaver 8V. Areas of Weakness and Corrective Action; Good Practices FINDING:- There are no written procedures in place which:

(PS.1-1) a) clearly delineate the responsibilities.of the safety department, b) provide for a Fire Extinguisher Inspection Program on site, c)- provide policy ~for control of hazardous materials on site.

' CORRECTIVE. a) The BA Safety Department will develop a written ACTION: safety program which formalizes present

responsibilities, duties, and practices by February 1, 1983.

b) The site fire extinguisher inspection program will

-be formalized in the written safety program address in a) above.

c) BA expects to have written procedures on control of hazardous materials by March 15,'1983. Both IP I

Operations and Project Management have procedures relating to hazardous materials.

l.

L FINDING: The enforcement of-the eye safety program on the-site l - (PS .1-2 ) is deficient.

. CORRECTIVE BA Project Management will issue a memorandum by ACTION: January 15, 1983, reaffirming the eye safety policy l- which includes disciplinary action up to dismissal for repeated violations.

t

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'orformance Area: . Industrial Safety Objective No.: PS.1

. Provide Factual Information that Supports the Performance Evaluation Summary

1. There is no industrial safety program manual on site.

2. ,It is tho' initial observation of SWEC's Project Manager that there is

. a good safety' program on site.

3. A site safety engineer indicated that his biggest concern for safety centers on enforcement of eye safety - not enough " clout" is provided-for enforcement.

8. BA's Safety Manager indicated that it is difficult to enforce eye safety on the site, since disciplinary action has not been taken against. violators within the past year.

$. An electrician was. observed improperly utilizing a ladder, leaning it

-against a scaffold while leaning out to a cable tray. The individual was not wearing safety glasses.

6. On a walk through on Level 737 of the Power Block, 14 individuals were note'd not wearing any form of eye protection.

7. A project nurse indicated that she treats many more eye injuries than any other form of injury.

$. Eye injuries are more numerous than any other form of injury on site, i There were 1346 cases for the period Jan-Sept 1982.

h. Correspondence from the site insurer, American Nuclear Insurers, indicated a definite need to identify one individual to be responsible for the care and maintenance of fire protection equipment. At this point, there is no one person or group responsible for this equipment.

. There is no written procedure on site which governs the action (s) to be taken as a result of an accident involving hazardous materials.

.. IIPPA Codes require monthly inspection of fire extinguishers and documentation of the inspection. Records of these inspections, if do.ne,~are not available.

r PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT orformance Area: Industrial Safety Objective No.: PS.1 l

Provide Factual Information that Supports the Performance Evaluation l Summary

2. There are over 600 fire extinguishers on site, with no written I licy regarding the inspection of same.

1. A random review of fire extinguishers indicated the last inspection dates of 8/81, 11/81, and 2/82.

1. Several observations were made regarding the absence of fire extinguishers in areas where welding was hoing done.

i. There are two fire trucks situated on site.

3. All of the safety engineers on site have attended a week long program at the University of Illinois dealing with fire brigades.

l. Monthly documentation is done by the safety department is as follows:

hours worked, doctor's cases, cost of doctor's cases, lost time injuries, days lost, cost of days lost, injury performance index, frequency, severity, cost / hour.

4 Accident Analysis - 1982 July August September Hours worked 795,194 698,241 733,209 Number of first aid treatments 745 714 594 Number of doctor caces 72 69 68 Number of eye iniuries 212 179 159 Days lost 78 76 121 Lost time injuries 7 7 12 Frequency 1.76 2.00 3.27 Severity 19.61 21.77 33.00

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Industrial Safety Objective No.: PS.1

. Provide Factual Information that Supports the Performance Evaluation Summary

' Construction Industry Experience for 1981 Frequency Severity National Safety Council 4.29 68.00 National Constructors Association 3.89 63.00 Associated General Contractors 4.05 116.20 Clinton Project (Jan-Sep 1982) 2.63 26.89 P. There have been 3 fatalities during the life of this project.

O. There has been only 1 OSHA citation in the history of the project (dealt with improper ventilation).

1. Overall housekeeping on site is satisfactory.

2. The safety section does have a list of hazardous materials on site.

3. There is a well-equipped ambulance on site.

6. Two of the three project nursos on site have 4 yr. degrees in nursing, while the third is actively pursuing same.

5 All three project nurses are RN's.

in the first aid office.

Their certificates are displayed

[. Trauma training has been provided to'the project nurse working in the Power Block First Aid Annex.

. Safety engineers make daily " walk throughs" throughout the power block.

. Two First Aid facilities are located on site.

).

There is a site standard safety procedures manual which is provided to site personnel.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Industrial Safety Objective No.: PS.1

, Provide Factual Information that Supports the Performance Evaluation Summary B. Foremen do conduct weekly tool box safety meetings that are documented. According to the BA Safety Manager, additional meetings are conducted at the discretion of the superintendents, general foremen, and foremen.

1. There are weekly safety meetings conducted for union stewards.

2. A weekly safety newsletter is distributed by the safety department to all employees on site.

3. BA's project manager does get personally involved in accident investigation where hospitalization of an injured employee is required.

4. According to BA's Project Manager and BA's Safety Manager, there is an opportunity for safety matters to be discussed at the weekly staff meeting conducted by the BA Project Manager.

5. A written policy does exist on " Tagging". Interviews with a variety of craftsmen indicate a good working knowledge of tagging procedures.

5. DA does have a written policy on rigging, hoisting, and handling (BA 2.11). The procedure covers the inspection of cranes, chain hoists, buck hoists, etc.

,. BA OC (Calibration Lab) is responsible for the inspection of rigging, hoisting, and handling equipment. BA P2.11 requires-12 in'spections annually.

3. The site insurer (American Nuclear Insurers) stated that formal site i policy needs to be established regarding the inspection of Fire 5

Protection Equipment.

Except for IP Operations, all personnel who are on the site work under the BA safety program.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT srformance Area: Project PJanning & Control Objective No.t PS.2 &

PS.3 Naluator(s): W. Futrell, R. Carlson, H. Adkins, L. Chambers, R. Eimer, J. Pulley, R. Spinner, K. Perkins, G. King, H. Heisler, D. Bieyer I. Performance Objective PS.2 Project plans should ensure completion of the project to the highest industry standards by identifying, interrelating, and sequencing the tasks of the project organizations.

PS.3 Project scheduling and work planning and coordination should ensure that the objectives of the project plan are met through effective and efficient use of project resources, kl. Scope of Evaluation The evaluation of this performance objective involved approximately 310 hours0.00359 days 0.0861 hours 5.125661e-4 weeks 1.17955e-4 months of discussion and documentation review. Various levels of management and supervision were interviewed from each of the various organizations involved with the Clinton project (Illinois Power, Baldwin Associates, Sargent & Lundy, and Stone & Webster as well as subcontractors).

RI. Conclusion The construction management systems evaluated under these performance objectives should be modified and incorporated into a fully integrated management system, to ensure the completion of the project.is obtained through an efficient use of resources. Two findings are noted.

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l PERFORMANCE EVALUATION

SUMMARY

-CLINTON CONSTRUCTION PROJECT

'erformance Area: Project Planning & Control Objective No.: PS.2 &

, PS.3 l valuator ( s) : W. Futrell, R. Carlson, H. Adkins, L. Chambers, R. Eimer, J. Pulley,R. Spinner, K. Perkins, G. King, H. Heisler D. Meyer IV. Areas of Weakness and Corrective Action; Good Practices ,

FINDING: The current CPM Schedule does not integrate

'(PS.2 & PS.3-1) construction activities with engineering and quality review on a Level II basis. A Level III schedule of construction activities is needed.

' CORRECTIVE The CPM Schedule on a Level II scheduling ~ effort ACTION: will be revised to integrate engineering, quality review, and procurement interfaces. A Level III detail schedule will be developen for construction activities. New procedures will be written by May 31, 1983 to cover these specific requirements.

IPC is evaluating the planning and' scheduling needs, and an integrated schedule will be implemented in June 1983.

FINDING: The methods for reporting work completed are not (PS.2 & PS.3-2) uniform.

CORRECTIVE Work in progress (WIP) is accepted as work ACTION: completed for certain commodities including electrical conduit and major piping commodities.

While WIP is acceptable as work completed from'a construction standpoint, it is not necessarily ready for final review by Quality Control.

j An evaluation of current reporting procedures will be performed. A procedure will be campleted and implemented by May 31, 1983, t

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT t;rformance Area: Project Planning & Control Objective No.: PS.2 &

PS.3

. Provide Factual Information that Supports the Performance Evaluation Summary 1 The'IPC Project Planning & Control Mgmt. (PCM) indicates they have had responsibility for project cost & scheduling for the past several months but no authority to make the necessary changes to the system.

2. The IPC and DA-PCM have discontinued scheduling meetings during the recovery period. The IPC-PCM indicated this form of critique would be beneficial to reinstate these meetings.

3. IPC-PCM function is to review planning, scheduling, and cost data supplied by BA-PCM and is not empowered to exert control over this group.

4. BA and IP-PCM do not work to any written procedures.

S. IPC has recognized a problem with the planning and scheduling of the project and recently hired Stone & Webster Engrs. to manage the project.

6 On October 25, 1982, BA Mgmt. was reassigned the responsibility for giving overall direction to the BA Planning, Scheduling, Cost and Information Systems Departments.

7 Written BA project procedures are inadequate relative to the overall organization and how each group and individual interface, concerning their areas of responsibility for planning, scheduling, and estimates.

B. BA Mgmt. recognizes the development and documentation of responsibilities would be beneficial.

. There is little evidence of written communication on key project planning issues. Thus Formal Management Approval was'not demonstrated.

. With the absence of an overall plan each group within BA is unable to develop individual plans that will support the overall objectives of the project.

PERFORMANCE EVALUATIOS DETAILS CLINTON CONSTRUCTION PROJECT arformance Area: Project Planning & Control Objective No.: PS.2 &

PS.3

p. Provide Factual Information that Supports the Performance Evaluation Surna ry

3. Field Construction Management are frequently uninforned of planning and scheduling beyond one week which restricts the management of some activities.

@. The latest revision to current CPM schedule was April.1982; the startup and tect schedule was revised in June, 1982.

D. CPM schedule is related to a Level II schedule and Level I and Level III schedules are needed.

3. Fragnets are also a type of Level II schedule, not Level III. A new Level III schedule is needed.

$. CPM Schedule does not integrate construction with engineering, quality review, on a Level II basis.

$. BA-PCM indicated that the present CPM schedule is inadequate for Level II construction purposes.

f. An integrated overall design schedule is not maintained.

. A fully integrated schedule is needed.

h. Construction turnover is hampered in the effort to organize and control system turnovers due to the lack of a project schedule which integrates engineering, construction, turnover and startup.

h. Engineering or recovery schedules are not a part of the existing CPM schedule.

. Many of the BA subcontractors are not included as a part of the project scheduling effort, because work is done on immediate need, turnover schedules, and independent turnover bases.

s. BA QC has not been scheduled into work activities, the work progresses to a hold point and then stops until a OC nan arrives to sign off the hold point.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area:. Project Planning & Control Objective No.: PS.2 &

PS.3

~

.. Provide Factual Information that Supports the Performance Evaluation Summary

3. The current CPM and Fragnet-scheduling system imposes unrealistic goals upon the supts. which leads to a morale problem.

9, Work'in the field is based on both bulk and system needs.

D' . .There are currently approximately 2000 open NCR's and a-system to

< track the~m is now being planned.

6 A planner should work in each area and be responsible for creating the Level III schedule under the direction of the superintendent.

7.- Field Construction Superintendents do scheduling based on their own.

quantity take-offs, traveler availability, and material availability.

D. The Large Bore Piping Traveler Package is too large in scope and size and thus are not manageable segments which can be completed within a definite schedule.

9. Baldwin Associates-is in the process of creating a 3-month Level II schedule and a 5-week Detail Schedule (Level III)

~

1 The Commodity' Tracking System which.is used for all tracking on the job, is not documented in terms of_what the system does.

L. The BA-PCM has the responsibility over the commodity tracking system,

.but limited authority to introduce changes or enhancements.

2. BA-PCM pursued a problem with the Commodity Tracking System where the detail did not match the summary.

3. Uniformity is lacking in the reporting of installed quantities in the field due to three separate unique systems of the different companies that make up Baldwin Associates.

i. Written procedures for material quantity development or verification have not-been developed.

i. Installed quantity verification is the responsibility of the superintendents in the field.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT P;rformance Area: Project Plannina & Control Objective No.: PS.2 &

PS.3

2. Provide Factual Information that Supports the Performance Evaluation Summary

36. The current estimate of installed quantities in piping may be inaccurate. There is currently a re-evaluation of installed piping being made in the Turbine Bldg.

37. Credit for installed quantities previously was taken at conatruction completion but recently has been changed to reporting at traveler completion.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Arformance Area: Project Procurement Process Objective No.: PS.4 Waluator(s): C. Kileen, H. Heisler, S. Bakunas-i I. Performance Objective 1

l The project procurement process should ensure that equipment, materials, .and services furnished by suppliers or contractors meet project requirements.

l EI. Scope of Evaluation

The evaluation of this area involved three members of the evaluation team.- Approximately 59 hours6.828704e-4 days 0.0164 hours 9.755291e-5 weeks 2.24495e-5 months were devoted-to discussions with personnel from the two purchasing organizations on the site, Baldwin Associates and IPC Site Purchasing, and BA construction disciplines.

Operation procedures and procurement documentation were reviewed during the evaluation as reflected in the performance evaluation details.

hI. Conclusion The-Project Procurement Process evaluated under this performance-objective for Baldwin Associates and IPC Site Purchasing adequately ensures that materials and equipment furnished by suppliers meet

project requirements. One weakness and one " good practice" were identified.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

?crformance Area: Project Procurement Process Objective No.: PS.4 2 valuator (s): C. Kileen, H. Heisler, S. Bakunas IV. Areas of Weakness and Corrective Action; Good Practices FINDING: The following good practice was noted:

(PS.4-1) The computerized tracking system for replacement / spare parts, required by startup and operations, significantly assists in avoiding or reducing delays from requisition preparation through material receipt.

FINDING: Procedure CSPO-7 in IPC Site Purchasing does not address

'(PS.4-2) transmittal of documentation to the Document Records Center.

CORRECTIVE Construction Site Purchasing Quality Procedure-7 has ACTION: been revised as of November 24, 1982 to incorporate the clarification that appropriate documentation will be forwarded to the responsible Stores Supervisor for transmittal to the Clinton Power Station, Document Records Center.

PERFORMANCE EVALUATION DETAILS

.CLINTON CONSTRUCTION PROJECT 2rformance Area: Project Procurement Process Objective No.: PS.4

.. Provide Factual Information that Supports the Performance Evaluation Summary T. IPC Site Purchasing utilizes an adequate system for inquiry (bidding process) and purchase order approval of safety related purch'ases.

2. An IPC OA qualified supplier listing is maintained in the Site Purchasing Section.

3. IPC QA does not review items previously classified as " commercial".

4. A stop work action resulting from inadequate procedures related to req'uisition preparation, review of technical and quality requireme.;s and. receipt activities is presently affecting safety related procurement of spare and replacement parts.by TPC Purchasing section.

5. A Procurement Recovery Plan Task Force has been formed to identify and correct system deficiencies to enable resumption of the procurement of safety related items.

5. Replacement and spare parts requisitions for turned over systems are tracked by computer by IPC Operations to avoid undue delay (Form C30-1).

7. 'The INPO 8/26/82 report recommends a streamlining of the procurement document flow process. This -is being accomplished by the Procurement Recovery Plan.

3. IPC Site Purchasing transmits documentation to Operations Storeroom.

This transaction is-not proceduralized in CSPQ-7.

4 Personnel authorized to approve requisitions for various activities appear on a list-dated October 21, 1982.

F. The JUliA 10-5-82 report states that there appears to be adequate controls and knowledgeable personnel to insure quality requirements

.are being met.

l. Items purchased by BA require 5 levels of approval prior to release of the purchase _ order. (Form JV-4)

!. BA expedites all safety related procurements as a matter of routine.

_ PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'crformance Area: Project Procurement Process Objective No.: PS.4

.. Provide Factual Information that Supports the Performance Evaluation Summary

.3. IPC QA regularly audits the BA OA organization to insure that BA is auditing their suppliers in accordance with BA QA procedures.

4. The BA piping section has a good tracking system (computerized) for requisitions.

5. The BA piping section has an excellent system for statusing and tracking of valves.

6. All DA disciplines contacted advised that delays in the requisition approval process usually occurred in the QA area - not purchasing.

7. The BA electrical section utilizes a card file system which is updated daily to account for material flow and to track requisitions.

8. All BA requisitions are reviewed and approved by BA OA.

D. The BA accounts payable function reports to the Manager of Purchasing but the division of duties and the system of checks and balances appears adequate to provide sufficient control.

O. None of the present BA purchasing personnel had prior experience in nuclear plant procurement.

3. The BA approved supplier listing issued by QA is maintained by the Manager of Purchasing and is readily available. Only four persons purchase safety related items (includes the Mananer).

?. Chances to Purchare Orders (Riders) follow the same approval route as the original.

3. Buyers review all acknowledgenents returned on vendor's forms to insure thev agree with BA Terms and Conditions.

1. Orders in excess of $1,000.00 are not awarded until approved by IPC after review of the bid summary and recommended supplier,

i. Interfaces are understood by IPC and BA procurement personnel. 1 S. Requisitions are normally routed for approval through the BA mail system. This process contributes to forty percent of requisitions ;

requiring in excess of 7 days for approval.

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l PERFORMANCE EVALUATION SUf1 MARY CLINTON CONSTRUCTION PROJECT Jerfornance Area: Contract Administration Objective No.: PS.5 Ovaluator ( s) : C. Kileen, H. Heisler, S. Bakunas, J. Pulley, W. Futrell I. Performance Objective Methods for administering and controlling contractors and suppliers and for managing changes to their contracts should ensure effective control of performance.

II. Scope of Evaluation The evaluation of this area involved five team members, who dedicated approximately 33 hours3.819444e-4 days 0.00917 hours 5.456349e-5 weeks 1.25565e-5 months to discussions with the Baldwin Associates Subcontract Section. Operation procedures and documentation were reviewed in the evaluation process as reflected in the performance evaluation details.

II. Conclusion The management and administrative functions evaluated under this objective indicate a lack of control mechanisms to effectively direct and monitor the performance of subcontractors. One finding has been noted.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Srformance Area: Contract Administration Objective No t PS . 5' Waluator(s): C. Kileen, H. Heisler, S. Bakunas,.J. Pulley, W. Futrell HV, -Areas of Weakness and Corrective Action; Good Practices FINDING: BA Procedures governing the Subcontract functions are (PS.5-1) inadequate for control of this area, and. training of personnel is deficient.

CORRECTIVE A new BA subcontract Manager, due to report after ACTION: January 1, 1983, will. evaluate procedures, controls, training and staffing requirements and make recommendations to management'by February 1,:1983. ,

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Contract Administration Objective No.: PS.5 Provide Factual Information that Supports the Performance Evaluation Summary

.. Changes affecting dollars are made by ECNs which are reviewed by NSED and then initiated and approved by S&L. Changes in the scope of work and clarification of work to be performed ~are made by FCR.

!. Field Change Requests (FCR) are approved by: BA discipline engineer, BA project engineer, Appropriate senior IPC discipline representative, Design Engineer, and the BA QC Manager (if applicable). They are added to the original contract via a Rider.

f. S&L approval required on changes other than items with unit pricing.

l. R:quisitions are approved by Project Engineering, Subcontracting, QA, BA Project Mgr. and IPC.

. Pro award meetings are held to define the scope of work to be subcontracted.

2. BA has a manual system to review contracts and ensure all cartification is received.

'. The. Subcontract Section only performs an administrative function with subs and limited direction. The BA construction disciplines furnish the required direction.

4 A Stone and Webster Contract Mgr. is now on site'to look into the Subcontracting area and make recommendations for improvement.

). Quality requirements are specifically spelled out in the contract.

). All contracts have a provision addressing subletting of portions of a contract. Owners approval is required for any subletting of BA contracts.

. Invoices for subcontract work are approved by the " engineer" in the Subcontract Section who is assigned responsibility for that specific contract.

. . The BA procedures do not define responsibilities and e:: plain interfaces for the subcontract section.

PERFORfiANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rformance Area: Contract Administration Objective No.: PS.5

.- Provide Factual Information that Supports the Performance Evaluation Summary

9. Formal! training provided to the BA Subcontract section personnel is deficient and consists primarily of basic-orientation.,

3. Subcontractors work within the confines of the BA safety program as they generally do not have their own program.

@. 'There is insufficient manpower management of the penetration sealing

-subcontractor. An.IPC Engineer handles coordination in the field on

-this cost-reimbursable contract.

$. There has never been an actual take-off of penetrations that are to be sealed in order to substantiate a cost estimate. Take-offs are made-by the penetration sealing contractor.

9. The project manager for the penetration sealing contractor indicated that the sealing contract was~ initiated too early in the proje'ct schedule. He-stated that they are very limited in available areas in

-which to work.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Documentation Management Objective No.: PS.6 valuator (s): R. Spinner, R. E.imer, C. Kileen, J. Weaver, S. Bakunas, G. Wuller, P. Zimmer, R. Meyer, C. Wheeler, J. Pulley, J. Dunkelberg I. Pnrformance Objective The management of project documentation should support the effective control and coordination of proje-t activities and provide a strong foundation for the documentation /Anformation requirements of the plant's operational phase.

II. Scope of Evaluation This evaluation involved a review of the organization and responsibilities of the Baldwin Associates' Document Control Center (DCC), Document Records Center (DRC), and IPC's Clinton Power Station's (CPS) Record Center. The evaluation included interviews and observations of the various personnel with various levels of responsibility. Contacts were made with various field personnel to ascertain the function of the document control system.

Approximately 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months were expended by twelve members of the team during this evaluation conducting interviews, reviewing procedures, reviewing prior audit or evaluation reports and documenting the results.

EI. Conclusion The management of documentation on this site is relatively efficient. However, additional methods of information processing are available and should be considered. Adequate procedures are not available to provide for the transfer of records from BA, GE and S&L to IP to support the operation of the plant. There are two findings and one " good practice" for this objective.

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P1'RFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Documentation Management Objective No.: PS.6 valuator (s) : R. Spinner, R. Eimer, C. Kileen, J. Ucaver, S. Bakunas, G. Wuller, P.-Zimmer, R.-Meyer, C. Wheeler, J. Pulley, J..Dunkelberg TV. Areas of Weakness and Corrective Action; Good Practices FINDING: Adequate procedures do not exist to provide for the (PS.6-1) orderly turnover of documents from DA, GE'and S&L to IP.

CORRECTIVE A procedure is being developed to provide for turnover ACTION: of documents to IP from BA. We expect an initial draft to be available by January 30, 1983. Additionally, the Records Task Force is preparing a new Records Management Plan which provides for a system to transfer records from BA, GE, and S&L to IPC. The Records Management Plan will be prepared by February 15, 1983.

t FINDING: CPS Records Center does not have microfilm processing-(PS.6-2) equipment or associated trained operating personnel available to microfilm the records to be transferred.

-CORRECTIVE The Records Task' Force is addressing the Records ACTION: Turnover and will address microfilming associated with the turnover in a meeting set for November 30, 1982.

The Plant Services Budget wil] be amended to reflect microfilm equipment and system for second quarter 1983.

Personnel will be trained on the equipment at that time.

FINDING: -The following good practice was noted:

(PS-6.3) An internal surveillance program of drawings and procedures is in operation within the DDC and the Project Engineer's Department.

t

I PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Documentation Management Objective No.: PS.6

. Provide Factual Information that Supports the Performance Evaluation Summary R. An extensive number of written procedures exist concerning the processing and control of the various documents used for the construction site. Collectively, these procedures represent the present records management system.

2 The records management system is operated by BA and monitored by IP personnel.

3 DRC reports to the BA/OA organization.

.. DCC reports to the BA Project Engineer.

>. CPS has an established record center with an approved vault for the receipt of all permanent plant records.

i. DRC has an approved vault and has responsibility for keeping all specifications, procedures, manuals and completed permanent plant records until system is turned over to IP.

'. There are procedures available providing for turnover of documents from DA to IP. These procedures are inadequate and are being revised by the Records Task Force.

.. Procedures for properly handling document turnover has been talked about for some time. Only recently, through the Record Task Force, has any progress been made.

The Records Task Force was established under the leadership of a Records Management Coordinator from the IP/QA Department.

There is some confusion as to what documents should be sent to the BA/DRC and the CPS Records Center.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

'erformance Area: Documentation Management Objective No.:

PS.6

. Provide Factual Information that Supports the Performance Evaluation summary R. The purpose of the Records Task Force is to prepare and have approved a new Records Management Plan which includes:

a )' BA/QA review and approve all safety related documents in the vault as of July, 1982.

b) BA/QA review and approve all safety related in process documents since July, 1982 before they go to the vault.

c) A system for transfer of records from BA, GE and S&L to IP.

d) A syatem for handling records during startup.

e) A system for handling records generated during operation, maintenance and modification activities.

2. BA has proposed to reorganize the DRC to incorporate a group of QA engineers who will review all records presently in the vault and those in process prior to going to the vault. This reorganization has not'been implemented.

3 DCC and DRC is audited or surveyed on a periodic basis by both BA/QA and IP/QA.

1. Internal surveillances of the DCC and DRC are conducted by the Project Engineer's staff and the DCC staff.

i. It is estimated that between 12,000,000 and 18,000,000 records will ultimately be stored in the CPS Records Center vault. The vault is expected to be full sometime in 1984.

.. IP does not have microfilm equipment available on site and has not included any such equipment in the 1983 Construction Budget.

Personnel for the operation of this equipment has not been included in the 1983 Operating Budget.

. BA has microfiln equipment available and has microfilmed certain

support documents.

. CPS Records Center personnel wants to be responsible for all microfilning for permanent plant records.

. A field satellite system has been set up to make relevant documents available at specific locations throughout the construction site.

PERFORMANCE EVALUATION DETAILS

-CLINTON CONSTRUCTION PROJECT erformance Area: Documentation Management Objective No.: PS.6 Provide Factual Information that Supports the Performance Evaluation Summary

). El.ectric drawings can be signed out of the satellite for a maximum of 3 days while all other drawings have a maximum signout of 1 day. All

. drawings must be turned in at the end of the shift on Wednesday and Saturday (Friday if work is not performed on Saturday).

.. Drawings and changes to drawings are distributed to the field 3 or 4 times a day.

!. The satellite operations are responsible for seeing that all " sticks" are updated with the current drawings and annotated for all changes applicable thereto. Urgent changes are taken to the field while others are made when the stick is returned to the satellite.

I. If a question arises concerning the correct revision of a drawing or the changes thereto, the satellite supervisor can call DCC to receive information concerning the most current revision of the drawing and all changes relating to that revision,

l. The satellite supervisor periodically secures the DCC records and' checks the sticks to make sure they are up-to-date.

.. . Field people interviewed felt the drawings used for their work were always current.

, . . Document Control Center objectives.

1) 98% accuracy of documents in their control.

2) Distribution of documents within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of receipt. '

. A list of persons authorized to receive documents from the DCC is not

. maintained. If a request for a document is signed by a supervisor, the request is honored based on an authorized distribution list SL-3356.

. A computer system is available for tracking drawings, NCR's and DR's.

. A system is not available for tracking ECN, FECN, other changes and correspondence, since the changes are incorporated as required into installation documents.

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J PERFORMANCE EVALUATION DETAILS

'i}

CLINTON CONSTRUCTION PROJECT r

, 'n Jrformance Area: Documentation Mana'gement Objective No.: PS.6

(

)

. Provide Factual Information that Supports the' Performance Evaluation Summary.

@. Status of CWR and FCR are maintained in different locations for different disciplines.

Q.

Personnel of the DCC and DRC receive the recuired training for the position and on-the-job training.

9 _Various'IP and BA audits and surveillances were reviewed covering operation of the DCC and the DRC. Findings in these audits and surveillances indicated that certain records could not be retrieved and that procedures had not been followed. The records ha4 not been I

received at.the DRC. These problems appear to be people,related >

problems rather than system related problems. Training was proposed and accepted as the corrective action.

6. The DCC is responsible for the reproduction of controlled copies 'on-the site. They have 3 blueline machines in operation. During tho

period August, 1981 - January, 1982 they averaged afeut 25,000 f <

blueline copies a month. Since February, 1982, the number of

' l 3 blueline copies produced has increased to about 50,000 per month; . .

There are two large Xerox machines available which produce a totaltof" about 650,000.copics per month.

!. Actual time required trom the time a drawing is re'ceived until a '[

drawing reaches the field DCC increased to 3 days during May, June, #

July and September, the objective is one day. During August and' October it was 2 days. During February, March and April it was 1 day. '

I Time increase is due to the number of drawings being reproduced end the' stamping process required. )

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i PERFORMANCE EVALUATION DETAILS *

.CLINTON CONSTRUCTION PROJECT

'erforrance_ Area: Documentation Management Objective No.: PS.6 "4

l s- Provide Factual Information that Supports the Performance Evaluation Summary 3.. IP's Data Processing Department has the following programs under

' development to aid in docunent tracking and control:

a) Nuclear Records System being developed in 3 phases Phase I - Drawings (completed and in use)

't',, Phase II Correspondence (included in Phase III)

Phase III - Permanent Plant-Records-(tested and waiting'forfuser

./ to' load records)

.b) Program to assist in processing DR's and NCR's (Documentation' is

. being completed).

c- Program change to incorporate ECP into NCR tracking system.. .

- (Waiting for completion of NCR progran).

d) Request to put. traveler system on S*iAIRS-(waiting tc see if >

traveler file is ok).

' le) .)rogram to: track'NRC commitments.

f)- Program to cross-reference' references in CPS procedures.

i. The report of the INPO Startup Assistance- visit conta' ined a recommendation " Documentation requirements should be' simplified to eliminate' redundant quality reviews." The' implementation of this recommendation will help reduce the amount of records, processed and stored.

l..

. A system of. planned.and scheduled audits and surveillances-is in place for BA/QA and IP/QA. The system provides for findings to be '

logged-and: tracked until corrective action has been verified.

I. No procedures were found for the turnover of records.from GE to IP.

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PERPORMANCE EVALUATIOff

SUMMARY

CLIt! TON CONSTRUCTION PROJECT 3rformance Area: Training Management Support Objective No.: TN.1 valuator (s): R. Kruep, J. .Toullian 4

I '. Performance Objective Management should ensure that an effective program exists for indoctrination, training, and qualification of personnel involved in the project.

II. Scope of Evaluation The evaluation of management involvement with the indoctrination, training, and qualification of project personnel primarily-enc'ompassed the Illinois Power (IP) and Baldwin Associates (BA) organizations. In evaluating this performance objective, approximately fifty hours were spent by two team members conducting interviews, reviewing procedures, training program documentation, and documenting results. Interviews were conducted with IP management, BA management, Stone & Webster ( S'WEC) management, F&M Technical Services (FMTS), training department, and vendor personnel.

EI. Conclunion Training proccdures for indoctrination, training, and qualification

~

of personnel have been developed, but are not yet fully implemented.

There is'one finding noted.

4 I

l-PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTIOil PROJECT erformance Area: Training Management Support Objective No.: TN.1 valuotor(s): R. Kruep, J. Joullian IV. Areas of Weakness and Corrective Action; Good Practices FINDING: The IP site purchasing group is not implementing (TN .1-1 ) Management Guide 2-1; Administration of Nuclear Training Activities.

CORRECTIVE IP Training - The site IP Purchasing group will be

. ACTION: retrained under Project Management. Appropriate procedures are being revised and developed. Training and support will be provided to the site Purchasing

' group by Project Management, all as outlined in the

" Procurement Recovery Plan" recently submitted to the NRC. The date established for this corrective action is delineated in the " Procurement Recovery Plan" as

. December 30, 1982.

l PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Arcat- Training Management Support Objective No.: TN.1

- ___ l 2 Provide Factual Information that Supports the Performance Evaluation Summary

1. IP startup training and project management training are governed by (Startup Administrative Instruction) SAI-11.and Clinton ProjGct Management Procedure C-6 respectively.

2. IP' Management Guide 2.1 is the guidance document for all training related to nuclear activities. This document requires an annual review of training and was issued October 11, 1982.-

3. IP NfiED training is governed by an NSED training procedure.

l. The training coordinators for IP project management and IP startup are assigned other duties besides the coordination and conduct of training activities.

3 The NSED and the IP QA training coordinators are assigned full time to coordinate training activities.

i. .IP OA/QC training is governed by applicable procedures.

7 IP-QA reviews the BA-training plans and manuals.

4 FMTS (consultant) has been brought on site to assist in implementing improvements'in the training program.

). I.P QA management ac:ively assesses personnel qualifications and certifies individuals accordingly.

1 The IP Director of Compliance has requested additional staffing in the tra'ining area for project management.

.. The CPS training department has been delegated the rcsponaibility of reviewing IP startup training. The CPS training department reports to the plant. manager.

!. The IP Vice-President responsible for QA/QC is planning to develop a monthly a sessment of IP OA/QC training.

. Training is an ongoing topic between the IP director of QA ar.d the i

Vice-President responsible for QA/OC.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT Drformance Area: Training Management Support Objective No.: TN.1 3

Provide Factual Information that Supports the Performance Evaluation Summary

3. IP lesson plans for IP QA are developed by lead personnel and reviewed by the appropriate supervisor, the Training Coordinator, the Supervisor of Programs and Procedures, and then reviewed and approved by the Director of QA.

4. The IP Director of QA has personally taught a number of training sessions.

3. The IP site purchasing group has a training procedure CSPQ-4 but does not currently have a training program in place.

P. The Clinton Plant Manager has been personally involved in developing the training program for the IP startup group.

D. The Director of Compliance for IP Construction is currently spending 50% of his time developing a full training program for the Clinton project management group.

D. The IP electrical supervisor feels that he definitely has input into training for his subordinates.

d. The superintendent for cabic terminations (BA) feels that he definitely has input into the training of his personnel.

>l . IP executive management implemented reviews of site training by outside consultants in the 2nd and ord quarters of 1982. These reviews were ccnducted to identify weakness in site training.

Responses to these reviews were fornulated. These reviews were conducted by:

a) PMTS b) LAPP, RICE & STAKER consultants (I.RS )

R. Management of the Clinton project has an active involvement in the development and administration of training programs. The recent reviews conducted by FMTS and LRS have increased this involvement.

I PERFORMANCE EVALUATIO'1 DETATM CLINTON CONSTRUCTION PROJECT erformance Area: Training Management Support Objective No.: TN.1 I

Provide Factual Information that Srpports the Performance Evaluation Summary

3. BA training is governed by the BA training plan. Sub-tier training manuals regulate training for the following BA groups:

a. Construction Engineering

b. Quality Assurance

c. Quality Control

d. Tech Services 4 For tracking purposes, BA maintains a computerized record of required training attendance. Personnel who miss training are rescheduled.

Attendance is documented and hardcopy records are maintained in the vault.

5. The majority of the training provided by the BA training organization is related to procedures and procedural changes.

5. The BA training manager position is being filled by an individual with a PhD in education and experience in training at a nuclear construction site.

7 Audits, inspection reports, and trend assessment will provide the major vehicle for modifying the BA training program.

4 No formal mechanism exists for BA personnel to provide feedback to management regarding the effectiveness of the training program.

3. Training coordinators are provided for the following BA groups:

a. Tech Services

b. Quality Assurance

c. Quality Control 0 BA QA will perform annual audits of the HVAC Contractor's training.

1. The BA Project Manager attended the exit interview with the consultant outlining the new training program being introduced.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rformCnce Area: Training Management Support Objective No.: TN.1

, Provide Factual Information that Supports the Performance Evaluation Summary

?. Tha.BA Project Manager does review attendance lists for mandatory trcining and calls the cognizant superintendent if he denotes a problem.

I. The Manager of BA Training (acting) is not aware of any budgetary constraints on his training program.

f. BA lesson plans are developed by lead personnel and reviewed by the appropriate manager, the Manager of Training, and then reviewed and approved by the Manager of Q & TS.

,. IP and BA Supervisors play an active part in determining the content of training and the training requirements for subordinate personnel.

This determination is based on job experience, codes and standards, and industry practice.

.. SWEC is currently on site evaluating many areas, including training.

, Feedback on training needs some improvement.

. To be excused from training requires prior approval at upper management levels and those personnel so excused are rescheduled at a later date.

. Minimal formal training is provided to procurement personnel.

1 PERFORMAllCE EVALUATIO!!

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Training Organization Objective No.: TN.2 and Administration valua tor ( s) : R. Kruep, J. Joullia'n I. Performance Objective The training organization and administration should ensure effective control and implementation of training activities.

II. Scope of Evaluation The effectiveness of the training organization in controlling and implementing training activities was evaluated for Illinois Power Company (IP), Baldwin Associates (BA), and the HVAC Contractor organizations. In evaluating this performance objective, approximately 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months were spent bv two team members conducting interviews with management personnel, training personnel, and trainees. Three training sessions were attended and evaluated.

Review of documentation included training plans, training manuals, management guides, training implementation schedules, training procedures, and individual trainee records.

JI. Conclusion While some deficiencies do exist, the training organizations on the Clinton site are effectively implementing and controlling training activities. One finding and two " good practices" are noted.

._. . = . - _.

PERPORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 3rformance Area: Training Organization Objective No.: TN.2 and Administration valuator (s): R. Kruep, J. Joullian

[V. Areas of Weaknecs and Corrective Action; Good Practices

' FINDING: To date, no copies of QA Training Attendance Record Form (TN . 2 -1 )' QAP-102.04F07 are in the central file, as is required by

'>rocedure OAP-102.04, Rev. O, Paragraph.4.5.4.

j CORRECTIVE Action has been taken to comply with QAP-102.04, Rev. O, ACTION: Paragraph 4.5.4 in that completed training records have been forwarded to CPS /DRC on November 10, 1982 and November 15, 1982.

FINDING: The following good practice was noted:

(TN.2-2) BA has implemented a computerized system for tracking training evolutions. This facilitates manaaement review and aids timely completion or required training by personnel.

FINDING: The following good practice was noted:

(TN.2-3) BA instructors are assigned to work in the field for l several days to develop subject matter expertise prior to development of lesson plan.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Training Organization Objective No.: TN.2 and Administration 3 Provide Factual Information that Supports the Performance Evaluation Summary R. There are' presently two programs being utilized by IP to enhance instructor training techniques:

'a. A series of lectures developed by FMTS - Total duration: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. A'cne week course presented by the University of Illinois

~ Department of Vocational and Technical Education on " Training the Trainer".

2 IP QA training requirements are defined in " TOR's" (Training and

-Qualification Requirements).

3. IP QA is not transmitting QA training attendance sheets to the vault in accordance with QAP 102.04.

4 Illinois Power Management Guide 2-1; " Administration of Nuclear Training Activities", requires the establishment of an annual training plan, including training goals and objectives, and quarterly training schedules.

5. Illinois Fower Management Gaide 2-1, provides for a yearly audit of training by the QA organization and in-process' evaluations by cognizant directors or managers.

.$ . Much of the training provided for IP QC personnel is practical or OJT. This training is documented.

9. 'The CPS Training De'partment monitors startup training and provides feedback. IP QA also monitors IP startup training.

9. IP startup does not have a formal me' hod to document on the job tr.aining.

). Training requirrTents for IP QA/QC personnel will be determined by

.the lead auditorn/ inspectors and supervisory personnel. These requirements arc to be reviewed by the training coordinator and the

-Director - QA.

p. IP Project Management placed a new training procedure into effect j 10-11-82. This precedure clearly identifies training goals and objectivec.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Training Organization Objective No.: TN.2 and Administration

. Provide Factual Information that Supports the Perforrance Evaluation Summary R. IP startup group has recently added a training specialist to their staff'.

2 The IP startup group plans to place training documentation on a word processor.

3. IP OC does have a full time training coordinator on staff.

4. IP QC does have a written procedure covering training.

5. Requirements for certification within the IP OA/QC are clearly id:ntified in a written procedure.

6. IP Environmental Affairs Dept. has a written procedure governing training.

7. IP NSED has a formal procedure governing training and a full time training supervisor.

8 BA QC is developing position descriptions which will address the training requirements of individuals by position.

9. BA has developed a computerized matrix system to track required training attendance by position / individual.

O. Documentation of Certification is maintained by the BA individual training coordinators and it is their responsibility to ensure that personnel maintain their certificaiion.

1.' Within the BA Organization, the training department is. responsible for procedural training. Technical training is the responsibility of the individual discipline training coordinators, who are assigned full time training responsibilities.

2 BA currently has no program to " train the trainer".

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

>erformance Area: Training Organization Objective No.: TN.2 and Administration

. Provide Factual Information that Supports the Performance Evaluaticn Summary

3. Written procedures govern BA training.

9. No formal mechanism exists within BA for feedback on training.

3. Foremen expressed concern that the BA training department is not always aware of their (foremen) needs in the training area.

B. The QA Manager for HVAC Contractor is responsible for implementation of training for their personnel.

7 .The HVAC Contractor does not establish any formal goals /ohjectives for their training program.

Q. The HVAC Contractor has recently implemented procedures to govern training. Ti tles are:

a. HVAC Contractor Training Program

b. Qualification of QA Program Audit Personnel

c. Training Certification and Evaluation of QA/QC Personnel

8) . The personnel assigned to responsibilities in the training area are delineated on organization charts.

D. The training organizations on site are segregated into several nubgroups. These subgroups do not routinely cenmunicate to coordinate training activities and/or use of available training materials.

. To date, training personnel throughout the site have received a ninimum of training. Programs, however, are being implemented to enhance instructor skills.

. There is a required reading list found in all training organizations for IP and BA.

1

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Training Organization Objective No.: TN.2 and Administration

> Provide Factual Information that Supports the Performance Evaluation summary

3. Lead personnel throughout the si te have the primary responsibility for the development of lesson plans.

1 BA's acting training manager stated that prior to development of lesson plans, he assigns the individual responsible for the lesson plan to work with the particular discipline to develop subject matter expertise.

i. No project integrated training program was found.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 3rformance. Area: General Training Objective No.: ,'TN.3 and Ovalification Faluator ( s) : R. Kruep, J. Joullian I. Performance Objective The training program should ensure that all employees receive

' indoctrination and training required to perform effectively, and that employees are qualified as appropriate to their assigned responsibilities.

@I. Scope of Evaluation Indoctrination, training, and qualifications of personnel were primarily evaluated for the Illinois Power (IP) and Baldwin Associates (BA) organizations. During this evaluation 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months were 1 spent by two team members conducting interviews, reviewing documentation of training, and documenting results.

Interviews were conducted with management, personnel, training personnal, and trainees. Training records were also reviewed.

(I . Conclusion The implementation of new training procedures and requirements will ensure all employees receive the required indoctrination and

. training to perform effectively their assigned responsibilities.

There is one finding noted.

i

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: General Training Objective No.: TN.3 and Qualification t/alua tor ( s) : R. Kruep, J. Joullian IV. Areas of Weakness and Corrective Action; Good Practices FINDING: No written policy exists on the verification of (TN.3-1) background information for BA personnel and contract personnel of the IP Startup group.

CORRECTIVE BA Personnel Manager has a written Personnel Department ACTION: hiring instruction which requires this verification.

This instruction will be reviewed for adequacy and revised, if necessary, by Ja.iuary 31, 1983.

IP Startup Administrative Procedure 7, Qualification and Certification of Test Personnel, will be revised by January 3, 1983, to provide adequate assurance that education and experience information used for certification, is accurate.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: General Training Objective No. TN.3 and Qualification i

Provide Factual Information that Supports the Performance Evaluation Sunmary

1. IPOC Supervisor indicates that he has been quite pleased with the caliber of personnel being brought into his organization.

2 Rccertification within the IPQC group is the responsibility of the Supervisor - QC,

3. An employee within the IPQA/QC organization indicated that he receives frequent training - he also stated that the training has been relevant.

1. IP Quality Specialist indicated that he has received regular training since being on site, and that the instructors have been well prepared and knowledgeable in their area of training.

3 IP QC Training Coordinator has 10+ years of relevant training experience,

i. The IP Director - QA indicates that he has been satisfied with the caliber of personnel brought into the QC organization - has some concerns about the level of experience within the recent additions to the QA group.

7 IP QA/QC has plans to implement a new procedure / system on indoctrination - no effective date established.

3. IP Startup and IP Project Management are lacking a formal program to verify'the background of contract personnel. Permanent employees of IP do undergo a background investigation by the Industrial Relations Department.

). The training specialist within the IP Startup group will spend 40 -50%

of his time in training.

J. No formal method of documenting On-The-Job Training currently exists within the IP Startup group.

IP OC requires written verification of background and audits of

l. . personnel records at company offices.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT orformance Area: General Training Objective No.: TN.3 and Qualification 3 Provide Factual Information that Supports the Performance Evaluation Summary

2. The training record of a piping turnover coordinator (IP) did not have documentation of indoctrination. The individual has been on site over three years.

3. IP project managenent procedures do not address personnel review of procedural / policy changes.

1. The lack of organized training for IP project manacement was the subject of a management corrective action request.

i. BA has an unwritten policy that requires reference checks are to be made with an applicant's current employer, plus the last employer.

This unwritten policy also requires that the highest level of education claimed by the applicant be verified. All verification is done by maii,' utilizing an unnumbered form.

i. A millright foreman indicated that additional training of personnel was not necessary.

7 A bricklayer indicated that he has not received any training within the past four months - he did feel that his initial indoctrination on site was satisfactory.

. An. ironworker foreman indicated that he felt his initial indoctrination on site was adequate, and further stated that he has attended as many training sessions in the past 6 months as he had attended during his first 6 years on site.

Training within BA Tech Services (BATS) is scheduled on an "as

/. needed" basis as identified by supervision.

The BATS organization has been well satisfied with the quality of personnel being brought into the organization.

. There is no forma] mechanism for feedback from trainers, supervisors, superintendents.to BA Management and the BA Training Department.

. The NRC, in the performance of a previous compliance inspection, was critical of BA's deficiencies in the area of verification of personnel education and experience.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: General Training. Objective No.: TN.3 and Qualification Provide Factual Information that Supports the Performance Evaluation Summary

3. Tha BA Manager of Quality and Technical Services has issued an unwritten policy that there will be no waivers of educational or experience requirements for certifying personnel.

4. Tha training coordinators are responsible for ensuring that recertification of personnel is completed in a timely manner. The BA training group is not involved in the recertification process.

3. A check of welding inspector training records verified up to date documentation. Two individuals were due for eye exams within a week.

A follow-up verified they were notified.

i. The BA training manager (acting) utilizes informal feedback /

suggestions to the instructor for the training sessions which he has attended.

7. BA subcontracting section has no formal training program.

3. In the past, IP & BA indoctrination and orientation was ill defined and not well documented. The recent emphasis on training has resulted in proceduralized indoctrination and improved record keeping.

). It appears that the Recertification Program within the various QA, QC, TS organizations on site is well managed and well documented.

I 1 In one orientation session, the movie was significantly out of date.

PERFORMANCE EVALUATION

SUMMARY

CI,INTON CONSTRUCTION PROJECT erfornance Area: Training Facilities, Objective No.: TN.4 Equipment, and Material valuator (s): R. Kruep, J. Joullian I. Performance Objective The training facilities, equipment, and material should support and enhance training activities.

]I. Scope of Evaluation The availability and adequacy of training facilities, equipment, and material support for training activities was evaluated for both the Illinois Power (IP) and Baldwin Associates (BA) organizations.

Approximately twenty hours were expended by two team members inspecting training facilities and conducting interviews.

Interviews were conducted with management personnel and training personnel.

JI. Conclusion With the exception of inadequate training facilities and equipment for IP QA/QC, and IP project management, the training facilities, equipment, and material do support and enhance training activities.

There is one finding noted.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT <

erformance Area: Training Facilities, Objective No.: TN.4 Equipment, and Material ra lua. tor ( s). : R. Kruep, J. Joullian

[V. Areas of Weakness and Corrective Action; Good Practices FINDING: The training facilities and equipment available to (TN.4-1) the IP project management and IP QA/QC are inadequate for the current training requirements.

CORRECTIVE Illinois Power QA will perform an evaluation of our ACTION: training facilities during the first quarter of 1983.

_, Based upon this evaluation, appropriate action will be taken to provide the necessary facilities to support the QA/QC training function.

Illinois Power OA has placed an order, through our purchasing group, for the necessary equipment to support the QA/QC training function. This order includes equipment for presenting video programs and overhead projection. Currently, coordinated sight / sound equipment is available within the QA Department.

-An evaluation of all available training equipment will be performed during the first quarter of 1983 to determine further needs. This. evaluation will be completed by March 31, 1983.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT-erformance Area: Training Facilities, Objective No.: TN.4 Equipment, and Material o Provide Factual Information that Supports the Performance Evaluation Summary

1. The current' emphasis on training has increased the utilization of-training facilities to the point where scheduling of training is extremely difficult. IP QA has had to reschedule training due to lack of. availability of facilities.

2. All training groups have an adequate and up to date reference library.

3. IP startup group training does not have an overhead projector.

L. BA training has a very good support system for training including adequate clerical support and audio / visual aid production capability.

5. IP QC indicated they have received assistance from plant staff.in the area of training facilities / materials.

i. IP_QA training coordinator indicated that he has a difficult time finding _the necessary equipment on site to conduct training sessions.

7 In BA training sessions attended, attendance sheets were utilized.

Training materials and facilities were adequate.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

'rformance Area: Ouality Programs Objective No.: QP.1 1aluator(s): S. Bakunas, D. Schweickert I. Performance Objective The quality assurance program scope, content and applicability should be appropriate, defined clearly, and understood.

EI. Scope of Evaluation The evaluation of this performance area was conducted by two members of the evaluation team. Approximately 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months were devoted to interviews with IP Quality Assurance personnel, BAQA, QC, and TS personnel, the BA Project Engineer, the Manager Quality and Technical Services, selected S&W and S&L personnel, and sub-contractor personnel and in the review of documents, audit reports, correspondence, manuals, procedures. The stop work orders limited the evaluation.

[I. Conclusion The IP Quality Assurance program content and current applicability are not cJearly defined. IP QA and BA OA are reviewing and evaluating previously identified quality problems and are presently implementing changes to improve the scope, content and applicability of the QA program. Three findings are noted.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT arformance Area: Quality Programs Objective No.: QP.1 valuator (s): S. Bakunas, D. Schweickert IV. Areas of Weakness and Corrective Action; Good Practices FINDING: BA OA monitoring of HVAC Contractor is inadequate.

(QP.1-1)

CORRECTIVE Prior to 7/1/82, one Vendor Surveillance Engineer was ACTION: assigned to the HVAC contract. This engineer was responsible for three other contracts in addition to the HVAC contractor. As of 7/1/82, two Vendor Surveillance Engineers were assigned to the HVAC contract.

Stop Work Actions 014, 015, and 020 were issued on 6/23/82 (014 and 015) and 8/2/82 (020). Efforts on the part of the Vendor Surveillance Engineers have been directed toward the lifting of these Stop Work Actions.

Once they have been lifted, surveillance of the HVAC contractor will be conducted per the requirements of BQA 170, Supplier Surveillance, which states in part,

" Surveillance shall be provided in the form of periodic surveillance visits to the supplier of subcontractor ...

Periodic coverage shall'be determined by the Manufacturing and Testing Hold Points denignated in the Supplier Quality Assurance Surveillance Check Plan, or as directed by the Manager of Quality Assurance".

Corrective Action shall also include an assessment of other subcontractor safety related activities being performed on site with a comparison of BA Vendor Surveillance coverage to insure that enough qualified personnel are assigned to the work. This assessment i shall be completed by January 31, 1983 and realignment of personnel assets made accordingly.

IP QA will verify and document the completion and

- effectiveness of the above proposed action via IP QA surveillance.

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PERFORMANCE EVALUATION

SUMMARY

j CLINTON CONSTRUCTION PROJECT , j 1

erformance Area: Ouality Programs Objective No.: QP.1 valuator (s): S. Bakunas, D. Schweickert l

[V. Areas of Weakness and Corrective Action; Good Practices FINDING: The IP Construction QA Manual and some of the (QP.1-2) implementing procedures are out of date.

CORRECTIVE The IP Construction QA Manual is currently being revised ACTION: to reflect organizational and functional changes made as a result of organizational changes. The draft of the revision to the QA Manual is in the review cycle.

Estimated issue date is January 3, 1983.

After the IP Construction QA Manual is issued, IP QA will perform surveillances to insure that departmental procedures are current with the latest revision of the IP Construction QA Manual. The surveillances will be completed by January 31, 1983.

FINDING: DA QA system for tracking and resolving audit and (QP.1-3) surveillance findings is not adequate.

CORRECTIVE BA QA is in process of installing a new data processor ACTION: which will be utilized for the control of tracking audit and surveillance findings, track: response time, and the closure of audits. This new system will be implemented by 3/1/83.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rform2nce Area: Quality Programs Objective No.: QP.1 Provide Factual Information that Supports the Performance Evaluation Summary

.. Section 17.2 of the FSAR does not reflect the present organization and will be updated within the next month of two. An individual has bren assigned this responsibility.

. The IP Construction QA Manual does not define the interface with SWEC. A draft of this manual is targeted for early December 1982.

Tha manual will be revised in accordance with schedules set by the Nuclear Management Improvement Program.

. QAP-101 reflects the present IP QA organizational structure (11-1-82).

. LRS report of 8/82 states that BAQA needs to develop a system for tracking and resolving audit and surveillance findings. Interviews conducted the week of 10/25 confirmed that this had not been instituted.

. During the past two weeks (Oct. 11 thru Oct. 22) the Receiving Hold Log (quality related material that cannot be receipt inspected because of a problem in the inspection process) has increased from 120 items to over 200.

. BA QA monitoring of the HVAC Contractor's recent document processing was less than adequate.

. HVAC Contractor certified one (1) individual to a Level II HVAC, Mechanical, Dimensional rating with no basis for the certification, contrary to their procedure CB-FQCP-ll.

. IP OA's review of the BA audit reports of HVAC Contractor indicated that the BA reports were lacking in depth.

> The IP Management Guides which exist at present do not require the addressing of all criteria of 10CFR50 Appendix B.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

rformance Area: Quality Programs Objective No.: QP.1

. Provide Factual Information that Supports the Performance Evaluation Summary D. Policy statement regarding IP quality assurance program signed by the Chairman and President, dated March 15, 1982 is in effect.

l. IP QA responsibility as defined by IP Vice President is to insure that the goals that have been set are met, that is to build a quality plant with the greatest attention to workmanship. This will be accomplished in the following fashion:

a) Construction personnel must deliver a quality product the inspectors can' accept.

b) Quality field reviews must be made easier for the inspectors.

This will be done by a greater commitment to:

a) Scheduled, supervised training b) Increased on the job discussions with construction personnel.

c) Unscheduled field discussions initiated by QA inspectors, d) Employee indoctrination for new and existing employees.

. All criteria identified in 10CFR50 Appendix B are met by the IP and BA Quality Assurance program manuals.

t. The DA Manager Quality and Technical Services now reports directly to an IPC Vice President. This change in organizational structure strengthens the reporting process and was designed to place significant emphasis on the quality program.

. IP OA audits site activities at least once each vear. Audit schedules are approved by the IP Director of OA. The audit schedule includes all 18 criteria.

,. BA OA conducts segmented audits of BA OC in accordance with prescribed procedures annually. All areas are reviewed at least once a year. Timely reports are issued. IPOA receives a copy of these audits.

. IP QA audits the BA OA function.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Ouslity Programs , Objective No.: QP.1 3 Provide Factual [ Information that Supports-the Performance Evaluation Summary

7. IP QA prepares an annual Audit Plan & Schedule; the schedule is revised as necessary. The most recent revision was dated 8-24-82.

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'The 1983 Audit Plan and Schedule is due for release in December 1982.

Additionally, a monthly schedule for IPQA surveillance,' including a checklist is prepared. Each surveillance completed results in a written report.

3. Currently the final authority.to lift a "Stop Work" rests with DAQA-IPQA-NRC, in that sequence. Current procedures do not reflect '

this.

). IP QA stop work authority is identified and described in Management Guide 15-3.

). BA QA stop work authority in defined:in BAP.1.6.

L. There has been a total of 29 Stop Work Actions issued by IP and BA

'since commencement of construction. At present (11-1-82) there-are 10 currently in effect by BA and 2 by IP. These are identified as follows:

PERFORMANCE EVALUATION DETAILS i

CLINTON CONSTRUCTION PROJECT erformance Area: Quality Programs Objectivo No.: QP.1 Provide Factual Information that Supports the Performance Evaluation .

Summary __

BA Stop Work -

Number Datc Item / Reason 007 1-18-82 Installation of electrical cable tray and 4

tray attachments /See CAR 077.

010 2-26-82 Drywell refueling bellows /NCR 6328, DR 339.

014 6-23-82 HVAC Contractor - All safety related work /

See HVAC Contractor Verification Program m Report.

015 6-23-82 The integral attachment (welded) of _

hangers classified as seismic to the building structure /See HVAC Contractor Verification Program Report.

016 6-23-82 All new conduit installation except Rev. O containment / Inspection Backlog.

016 Rev. 1 Including containment 016 Rev. 2 All conduit installation 017 6-23-82 Electrical equipment installation /See BA Internal Audit I-195 and the lack of a control system for issuance of travelers.

018 6-23-82 Electrical instrumentation installation /

See Audit I-214.

019 6~23-82 Containment structural steel =

installation /See MCAR #2.

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PERFORMAMCE EVALUATION DETAILS DJ, ? ,

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Summary F., ..?

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Number Date Item steason .'. 3

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- 020 8-2-82 All IIVAC work performed in plant structures V '. . '?.

classified as category I/ Lack of adequate .. - J, . .

control on non-safety work which affect 'l' 4

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safety-related areas. : ..,-... ~ ' ,

021 10-27-82 Air filtration test on reactor y*O containment building sheath / Procedure ' J 1, i T uns not approved and test was not scheduled. ...

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IP Stop Wor k - s ,

1-28-82 Cable tray installation (same as BA 007)/ ^

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Procurement of spare parts / Lack of ; N t;

/ 3-12-82 procurement document review procedures. '..

'. BA Project Engineering reviews all purchase requisitions to ensure '

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4 that the correct QA category is assigned. . a p.-,,

s 1. Design drawing changes resulting from NCR's, FCR's, ECN's and FECN's Q. j .ii,;

need to be completed on a more timely basis to reduce field problems G l. <'

i of system turnover and startup. As of 10-22-82 there were 264 NCR's, * : .r ,3 I.

798 FCR's, 400 ECN's and 675 FECN's for a total of 2137 open

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documents requiring changes. S&L has been concentrating on the . c.%1 backlog of open FCR's and NCR's and has reduced them by approximately jjl).- '

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? i. A plan has been developed for the evaluation of Certification of QC Insoectors. This program is scheduled for implementation in October d,* 17

. 1982 and scheduled for completion by January 1983. ;T }\ ..

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made as to the short tenure of the interviewees in their present 'yf.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT c" formance Area: Quality Programs Objective No.: QPc1 I. Provide Factual Information that Supports the Performance Evaluation Summary Job Title Present Pcsition Start Date BA' Project Engineer 5-82 BA Material Control Superviscr 11-81 BA, Project Manager - Quality & TS 1-82 BA. Quality Control Manager 7-82 BA Assistant Quality Assurance Mgr 8-82 IPC Vice President 9-82

$6 Currently-a desirable. ratio exists between th9 number of. manual force s and the number of QC personnel:in order for activity to-progress in an efficient, quality and cost saving manner. This ratio j.s in the range of-5-7% of OC personnel to. manual forces. Manpower levels of this dimension should ensure a quality product, and are to ~

be' monitored by SWEC. A comparison of manual-QC forces follows. .

Clinton Construction Site Comparison of Manual-BAQC Forces 12-81 10-82 i

Manual Fo'rce 2378 1364

DA QC Personnel 94 119

% QC to Manual 3.9% 8.7%

Includes support personnel The verification of the qualifications and certification dates of

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selected Level I and Level II Inspectors were traced to the BAQC <

Training Coordinator's employee personnel #iles. A review of the documentation'resulted in proof of certification. Since these

records were not the official BA files, a visit to the BA Document Records Center disclosed that the efficial Company records agreed with the data selected for verification.

OA and'OC programs are specified by the S&L'OA manual whose basis is f8 the NRC 18 critoria. The manual is formatted alor 7 the lines of these criteria.

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I PERFORMANCE EVALUATION DETAILS CLINTON CONSTPUCTION PROJECT errormance Area: Quality Programs Objective No.: QP.1

. Provide Factual Information that Supports the Performance Evaluation Summary

3. S&1. audit and carveillance schedules are monitored to verify the effectiveness of the program (implementation). Flexibility is built in to provide for reaudit/ follow up and special audits to investigate special problems such as potential 10CFR50.55 (e) 's. .

). S&L Procedure GQ 18.02, para. 3.0 provides for indoctrination and training personnel to insure proficiency in quality handling of documents and designs. GQ 2.04, 2.05 and 2,07 specify training in i quality assurance and tecanical subjects.

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PERFORf1ANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Program Implementation Objective No.: QP.2 forformanceArea:

valuator (s) : S. Bakunas, D. Schweickert I. ' Performance Objective Quality' assurance and quality control functions should be performed in a manner to support and control the qualit, of the proj?;t activities.

II. Scope of Evaluati.on The evaluation of this performance area primarily involved two members of the evaluation team although additional team members assisted in data collection. Approximately 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months were devoted to interviews with BA and IP quality personnel, BA project engineer and

-sub-contractor personnel, the review of activity procedures and performance of observations. The stop work action limited the evaluation.

8I. Conclusion The relationship of the IP OA, BA QA and TS organizations are c1carly defined to ensure their independence'to support and control the quality of the project activities. One finding is noted, i

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 1rformance Area: Program Implementation' Objective No.: oOP.2 valuator (s): S.-Bakunas, D. Schweickert IV. ' Areas of Weakness and Corrective Action; Good Practices, FINDING: Son.e sub-contractor QC organization's independence (QP.2-1) is in question.

CORRECTIVE BA OA Audit Section will conduct an audit of all seven ACTION: subcontractors on site to verify _the independence of

, quality' organizations from production pressures and their independence to identify and recommend solutions to quality problems. The audits will be completed by 3/31/83 on contractc ~ presently performing work and other current contractors prior to their commencement of contracted work. In addition, BA OA Auditing Section will revise the checklist used for vendor and subcontractor program audits to require the auditor to establish the independence of tha quality organization.

This will be accompli;hed by 1/31/83.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT Erformance Area: Program Implementation Objective No.: OP.2 o Provide Factual Information that Supports the Performance Evaluation Summary

1. Sub-contractors with limited sized work forces have limited and questionable quality programs with regards to independence.

/. BA OA organization is in need of a full time training coordinator.

3. IP & BA quality organizations are independent from construc. ion and engineering. IPOA quality organizations report directly to an on site IP Vice President. BAQ & TS Manager also reports directly to the same IP Vice President. The IP Vice President reports to an IP Executive Vice President in charge of the Clinton construction project.

!. The relationship between the IP QA and BA QA and TS organization is clearly defined and is one of complete independence.

i. BA OA organization functions as an independent entity. OA department receives management support.

i. The size of the BAOC & TS staff has increased during the past year.

Certified Inspectors

9-81 4-82 9-82 Level I-II 60 68 76 Level III 3 3 3 63 71 79

Includes no contract personnel.

The BA QC and TS organization as it exists today is of sufficient

k. size for the current manual work force to support management.

Some resumes of BA OC personnel have not been verified with former I.. employers.

IP QA documentation supports statements requesting the need to increase staff size. The authorized staffing levels at various dates are as follows:

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTTON PROJECT rrformance' Area: Program Implementation Objective No.:- QP.2 Provide Factual Information that Supports the Performance Evaluation Summary

'. (cont'd)

QA Department Authorized Level 10/ 2/82 7/1/82 3/19/82 11/1/81 1 1 1 1 Director-QA Technical Advisor' 1 1 0 0 Supervisor 5 5 4 3 Station QA Eng/ Spec 13 11 11 6 QA Eng/ Spec 17 14 14 9 6 6 4 1 Eng-(Trainee) 1 1 1 1 Audit Coordinator Training Coordinator 1 0 0 0 0 0 Records Coordinator 1 0 0

Level III Inspector 3 3 3 Level II Inspector ? 7 7 0 Level I Inspector 4 2 2 0 QA Analyst 3 3 3 0 1 1 1 1 Secretary C1nrical 7 5 4 2 Permanent -

Temporary - .

Consultant / Inspectors 47 28 14 TOTAL 118 88 67 23

. A. directive dated February 23, 1982 issued and s.!gned'by an IP

-Executive Vice President clearly defines the Project Policy regarding Intimidation at the Clinton Construction Project. This policy encompasses not only IP & BA Quality p'ersonnel but also NRC and Authorized Insportion personnel. The entire project management personnel enderse and support this policy.

IIVAC Contractor is in the process of implementing a new Quality Assurance manual. BA has approved the manual and S&L's review is still to' follow.

. HVAC Contractor's OA Manager has been in his present position 2-3 months.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PRO.TECT erformance Area: Program Implementation Objective No.: QP.2 n, .

> Provide Factual Inforration that Supports the Performance Evaluation Summary

3. Construction personnel stated QA/QC involvement has not been supportive, because they are not working with the Superintendents to solve problems before they become formal DR's and NCR's.

PERFORMANCE EVALUATION

SUMMARY

'CLINTON CONSTRUCTION PROJECT 3rformance Area: Independent Assessments Objective No.: OP.3

&aluator(s): S. Bakunas, D. Schweickert I. Performance Objective Management should provide an ef fective independent assessment of project activities affecting the quality of the project.

31. Scope of Evaluation The evaluation of this performance area primarily involved two members of'the evaluation team although some other team members assisted in data' collection. Approximately 56 hours6.481481e-4 days 0.0156 hours 9.259259e-5 weeks 2.1308e-5 months were devoted to this performance objective. Interviews were conducted with BA and IP quality personnel, BA project engineer and sub-contractor personnel. This time was also spent in the review of the independent assessment reports from che Joint Utility Management Association, LRS Consultants and F t M Technical Services.

@I. Conclusion IP management in tha past three months has implemented four ef fective independent qual tfied audits and assessments of .ctivities affecting the quality of the Clinton project.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Independent Assessments Objective No.: QP.3 valuator (s): S. Bakunas, D. Schweickert V. Areas of Weakness and Corrective Action; Good Practices No findings.

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-PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 2rformance Area: Independent Assessments Objective No.: QP.3 L

6 Provide. Factual Information that Supports the Performance Evaluation Summary

$. A monthly status of IP's audits and surveillances and results is

' submitted ~to an executive vice president.

S. 'An audit of Baldwin Associates, Quality and Technical Services -

Department, was performed in July of 1982'by F & M Technical

-Services, Inc.

4. An independent assessment of Clinton P.ower Plar.t was performed by LRS

- Consultants in Aug;:,st of 1982.

). A Joint Utility Management Audit (JUMA) of the IP Quality Assurance Program and QA department was performed in September of 1982.

d. The F & M Technical Services,LRS, and JUMA audits were performed by personnel with appropriate qualifications. ,

$.- The LRS and JUMA audits jointly identify major concerns.

i.e.:

a) A need for additional management level attention in the area of

-(Ni organization, QA program and correction action.

b) A naed to develop a system for tracking NRC commitments, f.-TheIPQADepartmentschedulesbothauditsandsurveillancesayear' at a time. The system is designed to cover all applicable 10CFR50 Appendix B criteria for all site contractors and vendors.

. The scope of IP audits and IP surveillances is determined by input from lead personnel in specific areas, identified trends and

' supervisory IPQA personnel.

L. LThe results of the assessments and evaluations performed by F & M l Technical Services, JUMA and LRS were reviewed by management of the applicable IP_, BA and S & L organizations. Responses were prepared in a timely manner (within 30 days).

. Anievaluation of Baldwin Associates Quality and Technical Services personnel ~ qualifications was performed 9/27-10/8/82 by the NRC. Two potential items of noncompliance and three open items were

' identified.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT orformance Area: Independent Assessments Objective No.: QP.3 4

. Provide Factual Information that Supports the Performance Evaluation summary

1. An S & L audit plan (G0 18.01) specifies that a yearly audit schedule will be prepared to ensure that each nuclear project and division (of S & L) will be audited once per year.

2. A report titled " Applicability of S & L QA Procedures to be Considered for Internal Auditing" is a management mechanism for ensuring that the total program remains effective. The report is available to senior management personnel.

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i PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 1rformance Area: Corrective Actions Objective No.: . QP.4 2aluator(s): S. Bakunas, D. Schweickert

. I .- Performance Objective Conditions requiring' corrections or improvements should be resolved in an effective and timely manner.

II. Scope of Evaluation The-evaluation of-this performance objective involved two members of the evaluation team.- Approximately 38 hours4.398148e-4 days 0.0106 hours 6.283069e-5 weeks 1.4459e-5 months were devoted to this ,

performance objective. Interviews were conducted with quality organization personnel, project engineer, and sub-contractor personnel. Time was also spent in the review of reports and statistics.

TI. Conclusion Corrective actions have not been achieved in a timely manner. One

-finding.is noted..

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance-Area: Corrective Actions -Objective No.: QP.4 valuator (s) : S..Bakunas, D. Schweickert

[V. Areas'of-Weakness and Corrective Action; Cood Practices FINDING: An effective BA Quality _ accountability system for (OP.4-?) corrective action is not well etrablished or enforced.

Responses to nonconformance reports and Corrective Action Requests (CAR's) are not timely.

CORRECTIVE A considerable amount of effort has been devoted to the ACTION: development of a Quality Accountability Program. It is anticipated that implementation of this system will be accomplished by_ April 1, 1983.

This system will provide accountability, adequate reviews, timely processing and management attention.to nonconformances, corrective action requests, internal audits, external audits, site surveillances, and audits of BA by outside agencies.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Corrective Actions Objective No.: QP.4

. n h-Provide Factual Information that Supports the Perfo.rmance Evaluation Summary A BA " Quality Accountability" program designed to reduce the number of items requiring corrective action is in the draft stage.

4. There is no BA procedure for how to perform a-trend analysis. There is no criteria for determining what is or is not trend.

C. The final disposition of cnrrective actions is impacted by: a lack of' priority and visibility to problems, stop work orders, and inputs from external organizations who identify problem.

3. As of 10/22/82, a total of 107 Corrective Action Reports (CAR's) were written on the project; 14 are presently "open". The issuance of CAR's increased drastically during the past year.

k. As of 10/22/82, a total of 7,988 Nonconformance Reports (NCR's) were written on the project; currently 1,914 NCR's are "open".

6 Three independent assessments performed in the last six'onths m by LRS, JUMA and F & M Technical Services have identified that corrective actions are not being completed in a timely manner.

. In the past, management support for corrective action was lacking.

C. Since the beginning of the year (1982) the number-of open items requiring corrective action has increased from 5200 to 6200 items.

i) . Stop works have hindered the implementation of some corrective action requests (CAR's).

$. Several DR's observed lacked an adequate fascription of the problem whichiresulted in dispositioning difficulties.

A procedure change to alleviate the problem with BA identifying nonconformances on equipment turned over to IP is being implemented.

5. While corrective actions are trended, it requires substantial man hours to update.

). BA's trending of NCR's/DR's is approximately 2-3 mont hs behind.

Other trend analyses being performed are up to date.

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rformcnce Area: Corrective Actions Objective No.: QP.4

. Provide Factual Informatio!. nat Supports the Performance Evaluation Summary

1. Some corrective actions have been returned to the dispositioner by BAQA a number of times for correctionn. This problem was also identified in the LRS and JUMA audits.

i. 'A status of corrective action items follows:

STATUS OF NCR's - DR's Date NCR's DR's Grand Total 12/30/81 Open 1525 0 1525 Total 6047 0 6047 10/1/82 Open 1862 2074 3936 Total 7821 3464 11285

PEFFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: Test Program Objective No.: TC.1 valuator (s): J. Philippo, G. King I. Performance Objective t The test program should verify the plant's full capability to operate as intended by testing the plant's systems functionally.

GI. Scope of Evaluation The evaluation of the overall test program involved two members of the. team.. Approximately 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months were expended in this effort. The majority of time was spent interviewing and discussing the Test Program with all levels of the start-up organization and reviewing the many documents which relate to the start-up. program.

TI.- Conclusion .

The overall Test Program as described and implemented by Illinois Power conforms to the objectives set forth by Federal, State, and other agencies which have jurisdiction.

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PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTIO3 PROJECT rforraance Area: Test Program Objective No.: TC.1 raluator (s) : J. Philipps, G. King V. Areas of Weakness and Corrective Action; Good Practices No findings.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Test Program Objective No.: TC.1

> Provide Factual Information that Supports the Performance Evaluation Summary B. The start-up manual and the start-up administration procedures and the start-up administration instructions are endorsed by the Plant Manager and the Project Manager.

a. The Project Manager who signed the start-up manual has recently been replaced.

E. A review of various preoperational start-up procedures indicate that the S&L Site Design Group has reviewed the procedures for which it ha responsibility and has made comments on the test objectives and acceptance criteria. Comments of a technical nature were also made to the procedure where appropriate. All comments were resolved with the reviewer prior to approval.

3. The start-up group has prepared scope documents for all er the systems or subsystems which will be tested.

i. The start-up manual, procedures, and guidelines provide detailed instructions for conducting testing. Technical review of test results by IP Engineering and the Delign Organization is also indicated.

. Condition Reports are written by the start-up group when problems are noted.

. The start-up manual and the Final Safety Analysis Report (FSAR) indicate that the plant operating and maintenance procedure will be trial tested during the Test Program.

. The qualification program of the start-up engineers is set forth in the start-up manual. Required interface with site QA and OC is also indicated.

. Observations of various initial system checks and tests indicate that the instructions and procedures are understood and followed.

. Observations of the overall testing effort indicates that the program is well staffed and organized and appears to function smoothly.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 2rformance Area: Test Program Objective No.: TC.1 Provide Factual Information that Supports the Performance Evaluation Summary

?. The start-up manual and associated procedures and instructions appear l to be well written, understandable documents. These documents set the direction and tone of the Test Program.

PERFORMANCE EVALUATIOM

SUMMARY

CLINTON CONSTRUCTION PROJECT

?rformance Area: Test Group Organization Objective No. TC.2

& Staffing zaluator(s): J. Philipps, G. King I. Performance Objective The test group organization and staffing should ensure effective implementation of the test program.

I . Scope of Evaluation The evaluation of the staffing and organization of the test group involved approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months and was conducted by two members of the team. Interviews were held with various members of the IP startup group. The entire startup manual and associated startup administrative instructions and procedures were reviewed along with personnel, qualification and training records for selected individuals.

'I. Concit sion The Start-up Test Organization is considered adequately staffed with trained professional personnel to meet the performance objective.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT orformance Area: Test Group Organization Objective No.: TC.2

& Staffing ve.lua tor ( s ) : J. Philipps, G. King IV. Areas of Weakness and Corrective Action; Good Practices N- findings.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT erformance Area: Test Group Organization Objective No.: TC.2

& Staffing Provide Factual Information that-Supports the Performance Evaluation Summary-L. The published organization chart for the startup group is current and-up-to-date.

2 The. project organization description in the startup manual reflects the actual makeup o.f the startup group.

l. Approximately'two-thirds of the startup group is made up of IP employees.- The other one-third is made up of contract personnel.

l. Personnel are qualified to a Level I, II or III Test Engineer per IP Procedure SAP-7, Reg. Guide 1.8 and'the FSAR.

i. Illinois Power does not require background checks or verification of education'and experience of the contract personnel they hire.

i. Procedure preparation schedules and man loading curves are presently being updated to meet proposed schedule objectives. The present man power appears adequate to meet these goals.

. Organizational relationships and project interfacing are described in the startup manual. Personnel interviewed were aware of responsibilities, duties and interface.

. Pers,onnel qualification records for 6 test personnel were reviewed and found to satisfy the overall education and training requirements for certification as either Level I, II or III.

6

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT

'rformance Area: Tent Plan Ob J ective No.: TC.3

/aluator(s): J. Philipps, G. King I. _ Performance Objective The test organization should prepare a plan and a schedule that describe the sequence of system and component testing to support major schedule milestones.

II. Scjpe of Evaluation The evaluation of this objective involved two members of the team.

Approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months were spent review the overall Test Plan.

Interviews were conducted with varioos personnel responsible for preparing the Start-up schedule. The schedule itself was reviewed along with all supporting documentation and printouts.

(I . Conclusion The Startup and Test Organization has compiled and issued a Logic Network Startup Schedule; however, until an overall project assessment is made, the effectiveness of the current test schedule is questioned.

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT Test Plan Objective No.: TC.3 arformance Area:

raluator ( s) : J. Philipps, G. King

[V. Areas of Weakness and Corrective Action; Good Practices No findings.

1

PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT

rformance Area: Test Plan Objective No.: TC.3 Provide Factual Information that Supports the Performance Evaluation Summary 1

h. All systems which will be tested in the Startup Test Progran have been scoped into System or Sub-System units.

9. The Startup Schedule (sequence) incorporates System and Sub-System Turnover dates which are required to support testing.

D. Schedule and Precedence Networks have been prepared for Preoperational Testing through Fuel Load.

!) . Tracking systems have been instituted to monitor the status of all testing.

$. Due to a lack of intergrated project schedule, various construction and engineering groups are using the Startup anc'. Test schedule as a Construction schedule.

6 There has not been a revised test schedule issued since June, 1982.

1

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT erformance Area: System Turnover for Test . Objective No. TC.4 valuator (s): J. Philipps, G. King I.- Performance Objective The construction testing and turnover process-should be controlled effectively to ensure that program objectives are met.

II. Scope of Evaluation The evaluation of the turnover system involved two members of the team. Approximately 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months were expended in' observing the turnover process. Interviews were held with all levels of the construction turnover group and the' start-up group. Meetings were attended which addressed turnover packages and system turnovers.

The construction and quality procedures for turnovers were reviewed.

Two turnover packages were also reviewed.

II. Conclusion The turnover process presently in place does not meet the performance. objective. There are six findings noted.

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. . , ' 3rfornance Area: System Turnover for Test Objective No. : TC.4 t{3 .l

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FINDING: BA turnover procedure BAP 2.17 does not accurately .,l'Q.f {

(TC.4-1) reflect the process by which the system turnovers are .Wf,Aq.%

g" actually made. 7. ] . +.wg:>: -

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BAP 2.17 is presently being revised to strengthen .;. t 4 .i j '

CORRECTIVE f.i .' .C; ,: '

ACTION: and clarify the turnover process. Expected issue is i-c .

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{: l; R An ASME code system was turned over to IP to start-up q .

.c PINDING: b.,. 'j. wf :.

(TC.4-2) without a wri$ ten QC procedure for turnover of ASME code , .

systems.

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T..* ? . ,p being rewritten and ic expected _j,f -Q'.; {ji e

5, CORRECTIVE BAP 2.17 is currently to be issued for review by December 31, 1982 OCI-601 g. > >'u ACTION:

V 4 will subsequently be revised to delineate QC d I: '1~,'

.II responsibilities for systen walkdown inspections for ASME and non-ASME Code Systems. QCI-602 will be issued ' .l' 4 ^3.h^ ' l. - i -

l. ( delineating QC responsibilities for turnover ~ lc ' . . ,

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.y documentation review and approval of ASME and non-ASME code Systeus. The QCIs are expected to be issued for le J.% .

?C revaew hv February 1, 1983. :

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PI:kFORMANCI' C / A .i t A'T I O N S i ' U 1A F '

C1INTON CONSTITCTION P WJ ECT O h o c t- TC.4 eriormance Area: Svstem Turnover for Test 70 No..

valuatc r (n) -T Phi!2yps, G. F rna IV. Areas of Weakness a n ti Correct;ve Action, C od P1 T e t- . 'o s _

FINDING- BA OC and QA responsibil:*ios durtrg the *nrnnver (TC 4-3) process are not adequato'. 7 addr,ssec :n Qualit' t Procedure OPI-601 S y s t em -- S u b s " s t e r 'utnover. _

CORRECTIVE EAP l' j '- p r e s e n ' l', b e ; ". g rewrit ,c! .

Prec' -

ACTION: Enc werina A rough draft is expo 'r od t C' he issued for -

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re'inw by December 31, 198?. Subsecuent- to the revision of BAP 2 l', OCI 601 vi 1 be re'ised tr delineate '

i n < :>ortor s re spon s ibi li t i o s c c>r syster wa'.kdown .

i n spm;t ion s . OCT-602 wt11 bo issued dolinoating resp,nsthilitien for turnovo; docurontatinn review and _

app r(1va i , Target dato Yr 1: u a n t: e cf the ccIs for .

rev'ow ic Februarv 1, 1983.

F I NDIN- A cor st ruct io p roc, s s ' ,;s nct i,e < > n dentified which can (TC.4-4) '; c r p l e t e svstora 2 . a t : mt 1 anner <' _urno'e: to the IP <'c-+-up ginup.

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CLTNTON CON S T R UC"'I oh P Rt LT ECT . .

3rforrunce Area: System Turnover +or Tes* Oh,'clivo No. TC.4

<aluator(s) <1 Ph11ippr, G. King IV Al ea: of Weakt.o- and Corre '/ e A*'< '

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FINDING. No <io r un.e n t control systor o .sts to ar .vo that changes (TC.4-5) to the S t a r t up Tu rna"e r Packac+ ( a:^ as E'c'ption list, Ttaveler', a'#ected, e*<' ) >

!e trancritted to each part' which has rosponsibt11i +

1 tne turn <ver o' Ss ,*. rx to IP Startup,

. Turm or P,*kaao- de act oro"ide fr~t a contre led Index wh1ch lis+: rurr<nt ;*atus of -

nach metlon o f' tho 'nrnrver r > c tc. m : ,- - '

. 0 R RECT 1 VI' A portior o: + 'le " P rc >oosed St +e r: R* : o 1=e >

Comptetion L, ACmTnN: Procram' entitled "Dn t 2me n t a t ion fo: "' U r r o ' o r Drogram Development" deals w i. +- h th:s and Lould cort- this ,

problem. Inolementatinn Is exrt- ' red t- bo mr "ted by mi ulv ', 983.

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. ~ _ _ ~ , . , . . .. -. . , . , . , , , . . . . , , . . .

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT k

N k rformance Area: System Turnover for Test Objective No.: TC.4 i

aluator(s): J. Philipps, G. King K

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! V. Areas of Weakness and Corrective Action; Good Practices a

c b FINDING: There is no procedure to define the methodology of (TC.4-6) system walkdown by IP prior to system turnover.

h CORRECTIVE The IP Startup Administrative procedures will be revised y ACTION: to more clearly address Startup's involvement in

walkdowns prior to system turnover, and to emphasize the t followinn points:

e

1) IP Startup Engineers are responsible for conducting walkdowns in order to keep abreast of their system's status. They are further responsible for assuring E that deficiencies noted on walkdowns are documented i on the execption list at turnnver.

3 2) The exception list is the means by which IP Startup

documents the results of such walkdowns.

[ 3) The Startup Supervisor's signature on the turnover form indicates acceptance of the turnover with the L

y exceptions listed.

'E IP Quality Assurance:

.P h 1) Will conduct periodic surveillances (in accordance

[

with existing procedures) of the entire turnover

process. Surveillances will include the area of

. walkdowns.

2) Will utilize notification points (as described in

]h existing OA procedures) for informing the Startup

,8 il organization of which turnovers IPOA desires formal

'IE 3) participation in.

Will on a sampling basis review turnover documentation. This review will include the "h Turnover Packages and exception list items gathered from walkdowns.

4) Uill review, on a sampling basis, the dccumentation 7 in the vault which is not incluCad with the turnover __ _

package but which supports the turnover package 5'l".: " 1' scope for the system / subsystem / component. *:,jh;,f',

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IP Startup prcicedures will be written and approved by V ' , a ';

1/31/83 to incorporate the above changes.

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PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 2rformance Area: System Turnover for Test Objective No.: TC.4 Provide Factual Information that Supports the Performance Evaluatian Summary L. There is no updated project schedule which integrates construction, start-up, engineering and turnover.

'. Due to lack of an overall integrated schedule and various stop work orders the 90-60-30 and 10 day walkdowns are not always performed.

1 Systems which are not covered under the various stop work orders and are near completion are identified for test by the start-up and start-up turnover group. These systems are man loaded until ~

sufficient work has been completed that start-up will accept the system for test. The work force is then shifted to another system until completion. ..

. The design agent focuses attention to the systems being man loaded by construction. _

i. Weekly meetings are held by the BA Assistant Project Manager which identifies systems and subsystems for turnover. Attendance at these meetings is required by BA Construction, QA, QC, Test, Engineering and the design agent.

>. BA Procedure BAP 2.17 and BA Procedure QCI-601 describe system turnovers.

. DA start-up, construction and QA-QC seem unable to resolve discrepancies in the turnover pacxages.

. Variota turnover packages have been in the review cycle for over 5 montha.

BA construction is not organized to shift from bulk or area

""3 construction to system completion for turnover.

. Once a system is turned over to TP start-up, the open exception lists items are deemphasized in favor of other systems which are scheduled for turnover.

. BA has no craft organization in the constructicn group which is dedicated to system completion during the turnover phase. 1

g PERFORMANCE EVALUATION DETAILS CLINTON CONSTRUCTION PROJECT 3rformance Area: System Turnover for Test Objective No.: TC.4 4

Provide Factual Information that Supports the Performance Evaluation Summary . .

?. BA Quality Control Instruction OPI-601 states that " additional requirements for the turnover of ASME code systems are delineated in . 'j QCI-602 which will be used ir conjunction with this instruction for the turnover of those systems." Procedure QPI-602 has yet to be written. On 1-14-82, CC-1, Component Cooling System was turned over to IP start-up group. This system is a partial ASME code system; ASME code valves were in the system turnover. A Condition Report was written to cover this particular discrepancy.

3 BAQA has begun to review turnover packages and other associated e documents prior to system turnover. There is no mention of this additional activity in turi.over procedure BAP 2.17.

1 BAQA & QC departments have begun to review non-safety turnover .

packages to ensure that no safety related equipment for systems are included in the package.

i. BAQA & QC are responsible for placing "NA" in the quality signature block. There is no mention of this requirement in BAP 2.17.

BA Procedure BAP 2.17 har no mention of the Systen Release Pacilit/

Document Supervisor Group. This group works directly for the BA AssistEnt Project Manager of Start-up/ Storage and Maintenance. This group is responsible for the listing, status, completeness, issue, distribution and sign-off of turnover packages and associated documents. This group is also given direction by the BA Start-up Coordinator in order to coordinate all turnover packages.

'. During system walkdowns, representation from all of the Clinton Project Team participate; (i.e. Design Agent, IP Engineering, BA Engineering, QA, QC, Start-up Turnover Group, IP Start-up and Test g

^

Dept., BA Construction).

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-n PERPORMANCE EVALUATION DETAILS ~- _ 3 4

CLINTON CONSTRUCTION PROJECT j

arformance Area: System Turnover for Test Objective No.: TC.4 i

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> Provide Factual Information that Supports the Performance Evaluation Summary 3 ----

1. After a review of. turnover package 1WZ.2 and discussions with QC &

QA, it was revealed that reviews are being performed to cut of date Q

O turnover packages that did not reflect the current revision listing B of exceptions, drawings, FCRS, NCRS and affected Travelers. M 2

). Lack of approved seismic or environmental reports (IEEE 344 or IEEE 323) are not shown on Exception List or System Punchlist for system w turnover. 3

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SUMMARY

~2 CLINTON CONSTRUCTION PROJECT 3rformance Arca: Test Procedures and Objective No.: TC.5 f_i Test Documents _.

taluator(s): J. Philipps I. Performance Objective n-Test procedures and test documents should provide appropriate ---

direction and should be used effectively to verify operational and j design fe6tures of respective systems.

LI. Scope of Evaluation The evaluation of the test procedures and test document section was 1 conducted by one member of the team. Approximately 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months were -

expended in reviewing test procedures and documents. Three pre-operational test procedures which have undergone final review - 3 were evaluated along with various generic construction check out procedures. Instructions for-procedure preparation in the startup manual were also reviewed.

LI. Conclusion -

Test procedures and test documents are being prepared as required. .

However, style and detail vary from procedure to procedure with the contents of the acceptance criteria section being the most inconsistent. There are two findings noted. ,_ _

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A PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT rformance Area: Test Procedures and Objective No.: TC.5 Test Documents _

alua tor ( s) : J. Philipps

=__ e V. Areas of Weakness and Corrective Action; Good Practices FINDING: Delinquent return of comments on procedures in the v (TC.5-1) review cycle is causing a backlog of unapproved test ;

procedures.

The entire " Preparation, Review and Approval" process is CORRECTIVE ACTION: being streamlined to remove the backlog of unapproved procedures. Improvements include: ;

W a) Assigning an individual to be responsible for 3 tracking and expediting procedures. Individual [

assigned October 18, 1982.

Preparation of a schedule for writing, typing, b) c reviewing, and approving procedures. To be complete February 15, 1983.

c) Holding periodic " Approval" meetings to resolve '

final comments and to approve procedures. First meeting scheduled for November 30, 1982. _

t FINDING: The IP Startup Department has no written instruction (TC.5-2) which gives direction and guidance as to the level of '

detail and format of test procedures.

CORRECTIVE A Startup Administrative Notice will be prepared by ACTION: March 1, 1983 to provide direction and guidance as to the level of detail of procedures. k i _

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_1 PERFORMANCE EVALUATION DETAILS j[

CLINTON CONSTRUCTION PROJECT '_

= .

Objective No.: TC.5 i~

3rformance Area: Test, Procedures and ;g Test Documents

,r._

Provide Factual Information that Supports the Performance Evaluation Summary N

l. Pre-operational and acceptance test procedures which are in the '.

review cycle are not being returned to the preparer on the due date. y This delay has led to a large backlog of procedures in the review i cycle. .

=

A review of pre-operational test procedures; RC-01, CONTAINMENT POLAR CRANE, HC-02, FUEL HANDLING BUILDING CRANE and DC-01, DC POWER F

DISTRIBUTION indicate that the level of detail and the content of the 7 F

acceptance criteria are different in consistency.

1 r

3. The acceptance criteria as listed in the FSAR, Chapter 14, and the criteria listed in the pre-operational test procedures is inconsistent in that some contain more than is specified by the FSAR.

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[ 1. Pre-operation and acceptance test procedures prepared by the startup group appear inconsistent in their level of detail and format. _

i. In Pre-Operational Test Procedure DC-01, DC POWER DISTRTBUTION, much 3~

of the acceptance criteria was vendor warranty information. Most of -

the procedure section was listed as a sign-off in the acceptance criteria section. {

5. There is no IP Start-up Department instruction which gives direction 3 and guidance as to the level of detail and format.

7. The startup. group has prepared installation and check out procedures

for construction testing. These procedures are understandable, easy "

to use and appear to include the required information to establish base line data'.

F 3. With the exception of the NSSS Systems, the majority of the acceptance and pre-operational test procedures have been written and are undergoing some phase of the review process.

9. Schedules and man loading curves are presently being prepared to g complete the procedure preparation titrough Start-up. .

m -

3. Test procedures follow the outline as prescribed in the Reg. Guide, 1 FSAR, and the Start-up Manual.

t

PERFORMANCE EVALUATION

SUMMARY

CLINTON CONSTRUCTION PROJECT 5_

System Status Controls Objective No.: TC.6 3rformance Area:

3 1aluator(s): J. Philipps I. _

Per'formance Objective A method should exist to identify the status of each system on component and the organization holding control or jurisdiction over t

that system or compenent to prevent interference and ensure equipment and personnel safety.

II. Scope of Evaluation .

The evaluation of the System Status Controls Section was conducted by one member of the team. Approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months were spent 2 reviewing various system control documents and observing their effectiveness in the field. 2 II .. Conclusion A system has been written and implemented to establish System :

Control during the Construction, Testing and Operational phases.

This system appears to be operating satisfactorily at the present time.

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PERFORMANCE EVALUATION

SUMMARY

CLINTOt! CONSTRUCTION PROJECT 3rformance Area: System Status Controls Objective No.: TC.6 Jaluator(s): J. Philipps LV. Areas of Weakness and Corrective Action; Good Practices No findings.

PERFORMANCE EVALUATION PETAILS CLINTON CONSTRUCTION PROJECT 2rformance Area: System Status Controls Objective No.: TC.6 Provide Factual Information that Supports the Performance Evaluation _

Summary L. IP Startup manual provides specific direction fer the type and color _

of tags and stickers which are used to identify the organization having jurisdiction over the system. 5--

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).. BA procedures are in effect to transfer system control from BA to IP.

1 IP Startup manual provides for the documentation of temporary modifications or systems to support testing and for removal of these temporary systems.

The following observations indicate that the system control in place 1.

are being used and are effective: 1) tags were found placed in the safety tag out log, 2) modifications are listed in the punch list, _,

and 3) jumpers were installed and removed by procedure. t

i. IP Startup manual provides specific direction for BA construction -

work on the system after turnover to IP.

i. Safety Tagging Systems are provided by both IP and DA. These systems -

are audited periodically and results ind'_cate that these . tagging -

systems are effective.

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Resumes for Part.icipants

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in INPO Self Initiated Evaluation M V?S of the Clinton Power Station d .; N .

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Howard E. Adkins ; ; . 1 .' .

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! Management Analysis Company k%.j. ; ],

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upplications of management techniques related to project -

management, construction, quality assurance, engineering, M..f ': ~$3

/ plant operations and information systems. Mr. Adkins has ?Q '" ,. ' ;

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been a participant and team leader on several nuclear plant . .~ f ' , , f evaluations. He has a B.S. degree in Metal]urgical ~ .J .'i M Engineering an M.S. degree in Material Science and - !7~l. : ~.; ;

Engineering and an MBA. He is a registered Professional ! T C .,

Engineer, i,c ~ b:k.. .F g4 4

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,; Stanley F. Bakunas '.l ? , j Director-Internal Auditing . M . x ,4 4 Illinois Power Company ' ?? j .

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+ Mr. Bakunas has 33 years of experience in accounting and auditing activities. For the last 13 years, he has directed

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auditing all aspects of the company's operations including the involvement in the construction of the Clinton Plant. *(' -' .4

Mr. Bakunas attended the INPO workshop on the Self Initiated - ( h J- 7.5 '

Evaluation of nuclear plants. He has a B.S. degree in y.)[-)

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% 'g ,.y Reynold C. Carlson . 4 2 3 Director-Systems and Programming

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Data Processing Department e I11incis Power Company ^ . : Y' f.' ,'. '

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( Mr. Carlson has 22 years of experience which includa .. .

4 responsibilities for development, enhancement and .4 -

naintenance of operations and applications of major computer systems for both engineering and non-engineering purposes. He has a B.A. degree in Business

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N Lawrence A. Chambers !.1 . t :4 '

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Mr. Chambers has more than 38 years experience in proiect 7;g.:a].,

management systems aevelopment and implementation; project '; J .fp pl'

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.y planning and control systems for both fossil and nuclear

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n* ,j M power stations; and industrial engineering. Mr. Chambers ha: a degree in Liberal Arts.

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.o I1]innis Power Company .

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-[ M. Daggett has mcre than 30 vears experience in the utility J i C #l

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. i., field. Activities during this time involved various levels .t, v. .,-3,L . . .

M of professionel and supervisc ry exporience in utility }.. J 'j 9 .

?. ongineering and operating matters; fossil power plant design 3. . 1 f p' '

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. X.w the Early Ftages of the Clinton Power Station. Mr. Daggett

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$ attended the INPO workshop on the Self Initiated Evaluation ' ' s.2 ' C '

'J7 of nuclear plarts. He has a B.S. degree in Electrical l :.: 7 ' .t

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Engineering. He i .c a registered Professions. Engineer.

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Mr Dunkolbera has 19 vears of experience with 5 voars of N...;Q.. ,

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tt, in hoavy construction and 10 yearm in nuclear conr*ruc*:on exoerience. Mr. Dunke] berg has a B.S.

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? decre!' In both bi"21 Engineeling and Euildina J.) % .k Cons"vuctinn. He n registered Professional Fngiroer. l T-'. :'~ 4, '. -

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Dm ha oat 30 ea r s exreri nre in the nuclea- fie:d T'? .

w h 18 incluacF engineering ao lar and interface wi t h M.bI'.w#

.- m - r 'c u r t i c n ; PA ati . ting; testina; and sta t-up om -'+ Inns h.n:e ,j1$.4 66Q

,. 3;. all asrcriated wirb various typoc of r.u c l e a r plants. He has B.S. and M.9 degrees in Elect rics1 Engineering. .'

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Pi'hard W. E irno r Supervisor-Instrunentation Engineerino -i Engineering Department _

y 711inois Pcwer Companv --

f1r . Eimer has 11 years of experience which include fossil power plant check-out and start-up, operations and instrumentation as well as power plant process computer svstems. Mr. Einer has a B.S. degree in Electrical

= Engineering. He is a registered Professional Engineer. ..

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l Nil tam Futrell '

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9mior Conetruction Enaineet ;

Sargent & Lundy Engineers _.

Mr. Futroll has 8 1, 2 voars experience in n u c '. e a r and fossil _

plant desian .nd construction. His involvement has boon in .

9tructural de i gn end field engineering management M: =

Futro'l h,' a B.S. ch g ee in Civil Engineerirg. Ho is a omilutered Profe: sianal Enaineer.

j m Harold R. Heisler .,

Prin~ipal Energv SSstems Engineer Sower Prc duct ion Department

} I1iinnis Power Comoany a

Mr Heisler has for more t..an 20 vears beon involveo 'n

+ mi l e or coal and water ro murres; cancrotaal Conion of nown, p t ci e <, ; tuol, operataon and maintenance co'ts; art % arcinaced the departmental review of the Clinton '

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ol a: nuc' ear desian and specification =. He has r * : <:2 pa t ed '

an evaluation of a nucJear plant awnre he ?

another utili+-" Ho has a B.S. dooroe in Morhantral -

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) p g ' } lld 1 Ii ! D 11 ' } + 2 /1 l' t 11' e ;D<'r i etr 'O ,]uring whj'h ;p ep ,n t j _

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.7r< :) + ~1 c<- 3 t (3 : r1 1 i q i rig ,1 c i } 1 ( s . }in hng },p o n a SP n l o l' is tt'!ctor i1 i hp ('l l n t o q PCWor S F l t i< 'n train a deTa rt nen t "osuonsible for devoiopnent o' procrans for 5 i iIe: Rtul .t nu ' O n -- l c t i , ced opera'nys and is $pO <7 e r t j [ [ p M on m-t ht' I'ack Fox 'ici

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Charles it. Kileen '> -

j' Assistant Manager of Purchasing and Stores . k." ,p g 6 Illinois Power Company '~~*

e . . .

"Y Mr. Kileen has more than 15 years experience primarJ.ly in .

,.,. procurement of electrical, gas, and power plant equipment "ii ,

't '. and fuel requirements for utilities. This has involved

>' contract r.egotiations and administration, Mr. Kileen Y-

!. t attended the INPO workshop on the Self Initiated Evaluation r# 3 p of nuclear plants. He has a B.S. degree in Biological -

Y" Sciences. . .

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I j} Gerald King s Operations OA Supervisor ff ! '

k. Gulf State 3 Utilities

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n3 Mr. King has 18 years of nuclear and aerospace experience. ', ' , -

-' ' L Included during this period of time are 9 years of nuclear nj construction and start-up in the field of quality. He has }

L1 attended various seminars and training sessions related to '

.i nuclear codes and standards and is a certified lead auditor. ?-

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"y He is a registered Quality Engineer in California. .

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y Robert D. Kruep Director-Employment jf

.. > Industrial Relations Department i

,.x Illinois Power Company 4

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yi Mr. Kruep has 13 years of experience in perronnel matters fs

' f:q relating to recruiting, labor relations and training. Mr. .ig*

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Kruep has a B.S. degree in Marketing Management.

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Richard O. Mever 'f ,.

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.j,. 4 Consultant (Public Service of Indiana) 9 ,9

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, . -ss L. K. Comstock & Co.

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'.,i Mt. Meyer has cver 25 years of experience with over 11 years in the nuclear field involving quality assurance, auditing, -4 L engineering, administration, procedure writing, training, 1,_

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c Kenwood T. Perkins Consultant g Management Analysis Company e

Mr. Perkins has 40 years of experience in the supervision i and management of nuclear activities. These include reactor i

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design, construction, start-up, operation and related services as well as consulting experiences on many of these

_ activities. Mr. Perkins has a B.A. degree in Chemistry. He is a registered Professional Engi'neer.

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_ Joseph'L.' Philipps h Construction Project Engineer Sargent & Lundy Engineers .

fir. Philipps has more than 15 years of nuclear and fossil E plant experience including nuclear reactor plant testing for -

the U.S. Navy and development and implementation of start-up t and testing procedures for several nuclear power. plants. He has a B.S. degree in Manufacturing Technology.

John Pulley 7 Supervisor-Gas Construction

'r Construction Department Illinois Power Company Mr. Pulley has 13 years of experience in several fields in r the utility business. This experience has been in gas engineering and construction as well as having been in the o quality assurance group during an earlier portion of the y construction of the Clinton Power Station. He has

& participated in an evaluation of a nuclear plant owned by

another utility. He has a B.S. degree in Civil Engineering.

~

E He is a registered Professional Enginecc.

F l David A. Schweickert r

Compliance Analyst -

Clinton Power Station 1

. Illinois Power Company Mr. Schweickert has 11 years of experience of various types of nuclear experience including 6 years as a Health Physics '

Technician and Mechanical Operator in the nuclear navy.

During his 5 years at the Clinton Power Station, he has worked in a health physics and chemistry capacity during refueling outages at two nuclear plants owned by other .

utilities. He has QA Lead Auditor training and has

.J-participated in several audits.

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m Robert M. Spinner Supervisor of Accounting Systems and Procedures "

Illinois Power Company j Mr. Spinner has over 29 years of experience in various li accounting, budgeting, corporate planning and financial positions with utilities. Mr. Spinner has a B.S. in --

Accounting and an M.B.A. dF 4

_=

C. Wayne Walling Mechanical Project Eng3neer -r River Bend Station ,

Gulf States Utilities 2 Mr. Walling has 6 1/2 years of nuclear experience which has =r included engineering, technical assistance to the crafts, ,,

and nuclear licensing activities. Mr. Walling.has a B.S. ;E degree in Mechanical Engineer. 5 i

N Jim Weaver -

Consultant Management Analysis Company

[

Mr. Weaver has 34 years of experience involving construction N management positions on both nuclear and fossil plants, cost estimating, cost control, scheduling, quality assurance, and ,

labor relations. Mr. Weaver has a B.S. degree in Business ._- '

Adminictration.

S m

Charles C. Wheeler, Jr. L'-

Supervisor of Mechanical Engineering ;

Nuclear Station Engineering Department -

111inois Power Company 7 Mr. Wheeler has 30 years of experience with various 5- -

organizations in nuclear plant design, orocess engineering, e opera

ions and testing. He has participated in an 1 evaluation of a nuclear plant owned by another utility. He ;

has a B.S. degree in Chemical Engineering. He is a j[

registered Professional Engineer. ug k

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George E. Wuller Supervisor-Licensing Nuclear Station Engineering Department Illinois Power Company Mr. Wuller has 30 years of experience relating to the -

nuclear. field. His experience includes basic research studies on uranium alloys, development projects for uranium production, health and safety responsibilities, materials accountability, quality control and licensing activities. Mr. Wuller has a B.S. degree in Chemistry. --

Paul A. Zimmer ~

Director-Research and Resource Planning Planning Department Illinois Power Company Mr. Zimmer has nearly 10 years of experien~ce within the Planning Department. He has had responsibilities in identification, evaluation and recommendations for long and short range additions and modifications to the electric generation system as well as resource planning and research and development. He has a B.S. degree in -

Electrical Engineering. He is a registered Professional .

Engineer.

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Evaluation Reference Documents /, .

..- , .a E ,,

Baldwin Associates Procedures Volumes I, II, II, IV ,...>6 . p 7 . ;

Baldwin Associates Job Instruction Volumes I and II 1. [ ' . ~

Baldwin Associates Technical Services Manual Volume.I, Book j ' ' --

}

I, II and III

~

.,.( .y 1

Baldwin Associates Technical Services Procedures Manual,

- l ,.

Welding Procedures Volume I, Book IV. .. -. . ' , -

h. ., (. .'

BA QC Instructions .. ;

j BA QA Manual . ' ,."~. ..

+ IP Nuclear Station Engineering Departuent (NSED) Procedures [ '. ' ' . i ' . .

., ^!:

IP Quality Assurance Instructions

3. . : ( l i '"' "..g :-

i..: ,2

'.; IP Clinton Project Management Procedures Manual c _ . . . v .S t 4 . .g 'n :

i IP Clinton Power Station QA Manual -

s . .% -

-l IP Clinton Power Station QA Operational Manual . .T-[ ~M. ~. !

..., l: ~ r' %

IP Management Guides :. .,

.4-3.7 .

. , .. CPS Open Corrective Action Response Summary ;. , r ,

r. w ;. ., ,

S&L Project Instructions (PI-CP-001 - 040) ' .;: 1 i- .

'q IP Startup Manual J.

j.- - .

LRS Audit Report of August, 198? ?. .'~. .l y _ . _r.

- F&M Evaluation Report + s +.-

~

.y.. .c

[ JUMA Audit Report dated 10-5-82 ,

^'*

i ' m. s -

g INPO Report dated 8-26-82

.,;4. . .-

.-. ' , BA Purchase Order Status Log 5i

+ g.

> BA K-SPEC, HVAC, MCC Powers i1~ t ;' g ' '.

4 BA Engineering Quote and Field Quote Log p

.[ BA QA Procurement Manual fi".ff "

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-., 15 . .. * . * >

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~x p ' '.j..

' ' - .#E ' ' '. * .'.;/-. / '

IP Current Specification Status Log IP Site Purchasing QA Procurement Manual IP Startup Administration Procedures IP Startup Administration Instructions IP Preoperational Test Procedures, FTP-HC-01, PTP-HC-02, PTP-DC-01 Final Safety Analysis Report, Chapter.14 Startup System Punch List Startup Personnel Qualification Records Plant Staff Procedures BA Piping Traveler Packages EA Hanger Traveler Packages

~

BA Pipe Superintendent Log BA Pipe Verification Log Stores and Maintenance Instructions / Records Receiving Logs and Receiving Inspection Reports Storage and Maintenance Training Pamphlet Various Status Reports o

_ _ _ _ _ _ _ _ _ _ _ _

ML20072N074

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