ML20073R731
| ML20073R731 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/02/1983 |
| From: | Edelman M, Leidich G CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20073R712 | List: |
| References | |
| NUDOCS 8305040516 | |
| Download: ML20073R731 (38) | |
Text
P 1 May 2, 1983 I
2 UNITED STATES OF AMERICA 3
^ ^
4 Before the Atomic Safety and Licensing Board 5
6
)
7 THE CLEVELAND ELECTRIC ILL*JMINATING ) Docket Nos. 50-440 COMPANY, et al. ) 50-441 8 (Perry Nuclear Power Plant, g Units 1 and 2) )
0 APPLICANTS' TESTIMONY OF MURRAY R. EDELMAN AND 11 GARY R. LEIDICH ON THE CLEVELAND ELECTRIC ILLUMINATING COMPANY'S 12 QUALITY ASSURANCE PROGRAM FOR CONTROL OF SAFETY-RELATED CONTRACTORS AT PERRY N A OWER PLANT (ISSUE #3) 13 14 15 Q. 1 Please state your names, current positions, and business addresses.
7 A. 1 (Mr. Edelman): My name is Murray R. Edelman. My Current position is Vice President, Nuclear Group, of The g
Cleveland Electric Illuminating Company ("CEI"). My business
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20 (Mr. Leidich): My'name is Gary R. Leidich. My current position is Senior Engineer, Nuclear Construction Engineering Section of CEI. My business address is 10 Center Road, Perry,.
Ohio 44081.
24 25 26 8305040516 830502 PDR T
ADC'K 05000440 PDR ll
e I
- l 1
l 1
1 May 2, 1983 l l
UNITED STATES OF AMERICA 3
^ ^
4 Before the Atomic Safety and Licensing Board 5
6
)
T3E CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 7
COMPANY, et al. ) 50-441 8 (Perry Nuclear Power Plant, 9 Units 1 and 2) )
0 APPLICANTS' TESTIMONY OF MURRAY R. EDELMAN AND GARY R. LEIDICH ON THE CLEVELAND ELECTRIC ILLUMINATING COMPANY'S 12 QUALITY ASSURANCE PROGRAM FOR CONTROL OF SAFETY-RELATED CONTRACTORS AT PERRY 13 NUCLEAR POWER PLANT (ISSUE #3) 14 15 Q. 1 Please state your names, current positions, and business addresses.
16 7
A. 1 (Mr. Edelman): My name is Murray R. Edelman. My Current position is Vice President, Nuclear Group, of The g
Cleveland Electric Illuminating Company ("CEI"). My business address is 10 Center Road, Perry, Ohio 44081. -
O (Mr. Leidich): My name is Gary R. Leidich. My current 21 position is Senior Engineer, Nuclear Construction Engineering Se tion of CEI. My business address is 10 Center Road, Perryc 3
Ohio 44081.
24 25 26 8305040516 830502 PDR ADOCK 05000440 T pon 11
l 1 Q. 2 Please summarize your professional qualifications and educational backgrounds. j 2
A. 2 (Mr. Edelman): I joined CEI in 1961. Between 1961 3
and 1972 I occupied various non-nuclear engineering positions 4
in the CEI Civil and Mechanical Engineering Department, 5
in luding Engineering Assistant, Engineer and Senior Engineer.
6 During this period I was a Project Engineer on several CEI 7
g fossil plant projects.
I began working on the Perry Nuclear Power Plant ("PNPP")
9 10 in 1972 as the CEI Senior Licensing Engineer responsible for 11 PNPP NRC licensing activities. In 1975 I was promoted to 12 General Supervising Engineer of the Licensing and Administra-g tion Section of the Nuclear Engineering Department. I retained g my licensing responsibilities and also became responsible for ther administrative areas.
15 In 1977 I was transferred from the Perry Project to the 16 g Civil and Mechanical Engineering Department as a General Supervising Engineer.
8 g Between April 1978 and April 1981 I held the position of Manager, CEI Nuclear Quality Assurance ("QA") Department. In -
that capacity I was responsible for planning and directing the PNPP quality assurance program. I reported directly to CEI's Vice President, System Engineering and Construction Group.
In April 1981 I was appointed Manager, Nuclear Engineering Department, a position I held until April 1982. In that position I was responsible for PNPP engineering, construction, 1
testing, procedures, records, licensing and cost control and 2
r p rted to the Vice President, System Engineering and Con-struction Group.
Between April 1982 and December 1982 I was CEI Division 4
Manager, Nuclear Engineering and Construction Division, 5
resp nsible for all PNPP nuclear engineering, construction, 6
licensing, fuel management, and cost administration. I 7
Continued to report to the Vice President, System Engineering and Construction Group.
9 10 Since December 1982 I have held the position of CEI Vice yy President, Nuclear Group. I have responsibility for all areas 12 f the Perry Project including Construction, Engineering, Plant 13 Operation and Quality Assurance, and report to CEI's Senior g Vice President.
25 I obtained a Bachelor of Science in Mechanical Engineering from Case Institute of Technology in 1961, and Juris Doctor from Cleveland Marshall Law School in 1965.
My professional memberships include the American Society 8
g of Mechanical Engineers, Cleveland Engineering Society, and the American Nuclear Society. In addition, I am currently Chairman -
of the Atomic Industrial Forum's Committee on Reactor Licensing And Regulation.
(Mr. Leidich): I joined CEI in January 1974. In 1974 and 1975 I held various fossil plant electrical engineering positions in the Plant and Substation Engineering Department.
26 1
In 1975 I joined the Perry Project. My first position at 2
PNPP was that of Responsible Engineer for procurement of plant ele trical equipment. I was also responsible for the electri-3 cal system design calculations, voltage and short circuit 4
studies, and transmission system interface criteria for the In 1978 I was promoted to Lead Electrical 6 lPerryProject.
Engineer with responsibility for CEI's overall field engi-7 nee ng n de elecMcal area of We hoject, incMng 8
g technical overview of all electrical contractor work. I held 10 that position until September 1980.
11 From September 1980 to October 1982 I held the position of Supervis r, Construction Quality Engineering Unit. My respon-12 sibilities included monitoring construction contractors' 13 g quality assurance performance. I was one of three unit supervis rs reporting to the General Supervisor of the 15 Construction Quality Section. Personnel under my supervision 6
g performed procedure reviews, surveillance, inspection and auditing for the 16 safety-related contractors employed at that 18 g
time on the Perry Project.
Since October 1982 I have been a Senior Engineer in CEI's _
Nuclear Construction Engineering Section. I supervise 30 engineers who provide construction support for electrical, civil, structural and chemical disciplines. I report to the General Supervising Engineer, Nuclear Construction Engineering Section. -
25 26 1
I earned a Bachelor of Science in Electrical Engineering at the University of Toledo in 1972, and Master of Science in 2
Engineering Science at the University of Toledo in 1974. I am 3
a registered Professional Engineer in the State of Ohio. I am 4
- ** *# * *Y" *" "9 "**# "9 " 'Y ' "" * " * * * "
- 5 as Chairman of that organiza tion's Public Utilities Division.
In addition to the above, I have been a member of the 7
g Institute of Electrical and Electronic Engineers ("IEEE") since g 1969. IEEE is an international professional society of electrical engineers and scientists. I am currently serving an 10 11 app intment as Secretary, and Executive and Administrative 12 Committee Member, of the Nuclear Power Engineering Committee
("NPEC") of the Power Engineering Society of IEEE. The NPEC 13 full committee includes approximately 40 engineers and 14 s ientists from industry, university and governmental back-15 gr unds. NPEC is responsible for overseeing those subcommit-16 g tees and working groups which develop nuclear electrical 18 g Q. 3 What is the purpose of your testimony?
20 A. 3 (Panel): The purpose of our testimony is to address ~
the four issues of material fact under Issue #3, as admitted by the Atomic Safety and Licensing Board in this proceeding.
These four issues, which relate to CEI's QA program applicable to safety-related contractor work at PNPP, are as follows:
25 26 1 The existence, cause, severity, duration and extent of an alleged instance in which 2
applicant's quality assurance program failed by not properly controlling its electrical con-tractor 3.
Whether the alleged deficiencies in 4
properly controlling electrical contractors extend to the proper control of other con-5 tractors.
6 Whether deficiencies in the control of 7
contractor activities have resulted in unsafe conditions at Perry.
8 Whether applicant has an adequate system g for periodically reviewing its program for assuring the quality of contractor performance 10 and ascertaining and correcting deficiencies that have arisen, particularly in systems 11 essential to safe plant operation.
12 See Memorandum and Order (Concerning Summary Disposition:
13 Quality Assurance, Corbicula and Scran Discharge Volume g Contentions), December 22, 1982, at 9-10, 16.
In addressing the first two issues of material fact, our 15 testimony discusses CEI's control of electrical contractor work 16 g performed at PNPP, including CEI's response to the NRC'.s 81-19 investigation. The testimony demonstrates that CEI's QA program has properly controlled the work performed to date by 9
the electrical and other PNPP contractors. __
0 With respect to the third issue of material fact, the testimony describes how CEI's QA program assures the proper documentation and correction of all nonconforming contractor .
construction work.
24 In addressing the fourth issue of material fact, the testimony explains the QA systems used for periodically A
1 reviewing CEI's program for controlling safety-related ntractor work, and shows how deficiencies are identified and 2
rre ted under CEI's QA program.
3 4
Q. 4 Describe CEI's project management system for the 5 '#Y b'
- A. 4 (Mr. Edelman): CEI's management organization for 7
control of PNPP is shown on Attachment 1 hereto. CEI manages the Perry Project th;ough an organization referred to as the 8
g' Project Organization. The Project Organization consists of all 10 CEI and consultant personnel at the Perry site responsible for 11 the design, procurement, installation, construction, inspection and testing of PNPP. This includes approximately 650 CEI per-12 13 s nnel supplemented by approximately 700 consultants. Consul-14 tants are used to provide specific expertise or short-term 15 supp rt to CEI, and they are fully integrated into the Project Organization. Contractors are not part of the Project Organization.
As e ce n a en , v rall responsibility for 18 g
the Perry Project is that of the CEI Vice President, Nuclear Group. I work exclusively on the Perry Project and am the -
senior Project Organization official. There is a close organizational and day-to-day working relationship between my office and those of other senior CEI executivos. The Senior Vice President and I have offices on-site, and at CEI's Cleveland corporate offices adjacent to the offices of the President and Executive Vice President. There are weekly and 1
ften daily communications among these four senior CEI exe utives concerning Perry Plant issues.
2 3
Q. 5 Generally describe the current QA organization and staffing at Perry.
4 5
A. 5 (Mr. Edelman): CEI's current Nuclear Quality 6
Assurance Department organization is depicted on Attachment 2.
7 The Department is headed by the CEI QA Department Manager. He 8
rep rts to me and has organizational status and authority equal g to the managers of the Construction, Engineering, and Perry 10 Plant (Operadons ) Depadments.
11 Under the QA Department Manager are various quality 12 sections headed by CEI Gervral Supervisors responsible for 13 quality assurance activiti es for the procurement, construction, g and operations phases of the Project. Procurement and adminis-15 tration QA is the responsibility of the Procurement and Administration Quality Section. Construction QA is under the 6
g Construction Quality Section. Testing and operations QA is under the Operational Quality Section. Separate from these 18 g
three sections is a Quality Auditing Unit responsible for auditing Project Organization and contractor activities. -
O The CEI QA organization shown on Attachment 2 is located entirely on the construction site. CEI in 1978 was one of the first nuclear utilities to reorganize its QA organization so as to consolidate all QA activities at the site. Other utilities have since undergone similar reorganizations with the endorse-ment of the Nuclear Regulatory Commission. CEI has found that 1 this close proximity increases the ability of the QA Department 2
to monitor other Project Organization departments and 3
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Since 1978 CEI's QA Department has increased from fewer 4
5 than 50 to approximately 200 CEI and consultant personnel. It g iS one of the largest nuclear plant QA departments in the 7 country, according to a June 1982 NRC Staff comparison of QA/QC 8
staffing at 35 nuclear plants under construction. The Staff's g compilation also indicated that in June 1982 Perry had the best 10 (1 west) ratio of craft personnel to QA/QC personnel (a 4.6 to 11 1 ratio) of any plant under construction.
12 The QA Department includes quality control ("QC")
13 inspectors, quality engineers ("QEs"), supervisors and clerical 14 Support. The QC inspectors perform field surveillance and 15 inspection, as an overview to the contractors' "first-line" inspections, to ensure that contractor construction activities 16 g are being performed consistent with specified requirements.
" * "" "* '*' 9"""## Y * " 9#** # * #"
18 g training and experience than inspectors, are responsible for reviewing, approving, and interpreting QA program requirements. -
20 CEI's professional QA staff has a large number of cer-tified inspectors and auditors. For example, there are 24 CEI 23 National Standards Institute (" ANSI") requirement N45.2.23
" Qualifications for QA Auditing Personnel for Nuclear Power Plants." There are 44 CEI QC inspectors qualified under ANSI
_g_
y N45.2.6 " Qualifications of Inspection, Examination, and Testing 2 Personnel for the Construction Phase of Nuclear Power Plants."
These inspectors also hold 43 certifications in various 3
4 nondestructive examination techniques such as radiographic testing, ultrasonic testing, magnetic particle testing, 6
p netrant testing, and visual weld inspection. Of special 7
sig ifi ance, ten of CEI's inspectors have passed the American "9 * "" "" "*^* " ** Y~
8 '
g ing the inspectors as AWS weld inspectors. Thirteen inspectors 10 have also passed a State of Ohio examination for inspection of 11 Pressure piping systems and are certified as Special Inspectors by the State of Ohio.
12 13 The turnover of these CEI QA professionals has been g extremely low. Since 1978, only six CEI QA employees have left g the Project. CEI has been able to retain an experienced and qualified QA staff for a number of reasons. CEI's salary structure for QA personnel is identical to the salary structure used for personnel in engineering and construction, a clear 8
g indication from senior management that quality assurance at Perry has co-equal status with construction and engineering _.
functions. CEI's record of training and promoting inspectors has also contributed to CEI's ability to retain these person-nel. Another factor has been CEI's ability to attract experi-enced personnel with local community ties.
CEI's management personnel understand and support the PNPP quality assurance program. As noted earlier in the testimony, 1
I previously held the position of QA Department Manager.
2 Similarly, the CEI Manager of the Perry Project Services De-par men , and the CEI General Supervisors of the Nuclear Con-3 struction Engineering, Nuclear Project Training, and Admini-4 5
stration and Special Projects Sections formerly occupied QA
, Department management positions. CEI benefits from having o
7 management personnel across the Project with strong QA back-g grounds.
The primary consultants assisting CEI's QA staff in the 9
verview f contractor QA programs tre Gilbert Associates, Inc.
10 11 ("GAI") and Raymond Kaiser Engineers ("RKE"). GAI's support 12 r le is predominately in the quality engineering area. This 13 in ludes evaluation of conctruction and equipment specification g requirements, review of contract proposals, and review of ntractor QA programs. RKE primarily provides inspectors for 15 surveillance of Contractor QC activities, and also furnishes g clerical support in the records storage area. As with'CEI's QA personnel, none of the consultants' QA personnel perform first-18 g line inspection of safety-related construction activities.
First-line inspection is the responsibility of each contractor ~
20 performing safety-related work.
Currently safety-related contractors at Perry have over 300 QA/QC personnel providing first-line inspection and QA audit coverage of all safety-related work being performed at the. Project. For each such contractor the QA organization and staffing, as well as the written QA program, are carefully 1
reviewed by CEI's QA Department prior to implementation. CEI 2
reviews personnel qualifications of every QA/QC auditor and inspe tor proposed by the contractor to assure that he or she 3
has the required education and experience. CEI follows up its 4
5
- "" * * *# * " * # * *E "9 # #*5* "9 the individual.
6
/
Q. 6 Generally describe the scope and content of CEI's quality assurance program requirements for the control of 8
g safety-related construction work at Perry.
10 A. 6 (Panel): CEI's QA program for safety-related work 11 is structured in accordance with the 18 criteria set forth in 12 10 CFR Part 50, Appendix B, of the Nuclear Regulatory Commission's regulations. The " quality assurance" activities 13 g covered by the program, as defined in Appendix B, include "all 15 those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will 16 g perform satisfactorily in service." Quality assurance. includes
" quality control," defined in Appendix B as "those quality l
l g assurance actions related to the physical characteristics of a material, structure, component, or system which provide a means ._
to control the quality of the material structure, component, or system to predetermined requirements." CEI's QA program also follows the QA requirements set forth in various industry codes and standards, such as the American Society of Mechanical Engineers ("ASME") Boiler and Pressure Vessel Code, and ANSI Standards.
26 4
1 CEI's QA program requires, among other things, sufficient h QA authority and organizational freedom to identify and respond
- 3 to quality problems, including the necessary access to manage-4 ment; proper documentation of the QA program in written p es,~pr eu s, r instructions; an adequate inspection
~'5 .
6 program to verify conformance with the documented program 1
7 requirement's; regular management review of the status and ade-g ~quacy of the QA program; and the necess&ry training and quali ication of all personnel.
9 CEI retain's the ultimate responsibility for the develop-10 11 ment, approval, application, administration, and control of the 12 total quality assurance program for the Perry Plant. Every 13 safety-related contractor is required by CEI to have a QA 14 program for accomplishing the specific scope of work covered by 15 their contract. CEI's Corporate Nuclear _ Quality Assurance Program Manual and all. implementing procedures and instructions 16 g set out the details- of the QA program to be implemented by all site personnel. Safety-related construction is only performed 18 g at PNPP after CEI carefully reviews and approves the con-tractor's quality assurance program, and after Project -
Organization QA and engineering personnel fully review all procedures, instructions, and specifications. During program implementation, CEI reviews and alsproves all changes to the .
contractor's program and procedures, and verifies, by checking, auditing, and surveillance, that contractor activities affect-ing the safety-related functions have been correctly performed.
i
,~_m , m ,m_. -
1 Later in our testimony we will discuss in greater detail how 2
this overview function is performed at Perry.
3 CEI's executive commitment to a strong, independent QA 4 program meeting all regulatory and industry requirements is recorded in a Written QA policy statement signed by the 6
President of CEI, a copy of which has been included in CEI's 7
Corporate Nuclear Quality Assurance Manual since the Manual's riginal issuance in 1978. The current policy statement, which 8
g differs in only minor respects from the original version, is 10 in luded as Attachment 3 to this testimony. The policy 11 statement emphasizes the importance of the Perry QA program to g the safe design, construction and operation of the Perry Plant.
13 The policy statement recognizes that the QA program requires g the support of all Project disciplines and groups. The 15 statement assigns responsibility for ensuring the establishment g and implementation of CEI's QA program to the office of the g senior Perry Project official, the Vice President, Nuclear roup. The CEI QA Department is given the responsibility and 18 g requisite authority, including stop work authority, to identify and resolve all quality problems. Finally, the policy state- -
20 ment makes all employees responsible for informing their superiors of any potential QA program deviations, " including the right of direct appeal to upper management of the Company.~"
CEI executives repeat.this quality message at many management meetings held throughout the year. The importance of every PNPP worker to the quality program, including ready y access to management, is also explained and emphasized in 2
posters on Company bulletin boards and in various printed 3
material distributed by CEI senior management to Project employees.
4 5
Q. 7 Please summarize the major QA program changes at Perry since 1978.
7 A. 7 (Panel): As with any nuclear QA program, Perry's QA 8 program has grown and evolved as activities on the Project have 9
in reased in scope and complexity. We have been able to make 10 the QA program increasingly effective over time.
g In response to items of concern in a February 8, 1978 g immediate action letter issued by NRC Region III, CEI reviewed 13 ea h letter item and performed a comprehensive management g evaluation of all Project QA/QC activities. CEI determined 15 that the underlying causes of the QA deficiencies identified in the immediate action letter included: the lack of a single, all-encompassing QA manual defining corporate QA controls and 8
responsibilities; the limited number of CEI personnel physi-g cally located at the Perry site (the majority were based in CEI's Cleveland offices); inadequate definition of surveil-lance / inspection and audit responsibilities of CEI's QA/QC personnel following the 1977 merger of CEI's QA and QC organi-
=ations; and inadequate integration of CEI's and contractors'_
QA programs.
In response, CEI instituted the QA department consolida-tion discussed previously in this testimony. This was part of 1
an verall site consolidation of all CEI QA, engineering and purchasing personnel. In addition, CEI made the following 2
3 programmatic changes. CEI's QA manual was revised to address 4
all QA-related project activities and procedures; and a series 5
f related administration, procedure and instruction manuals Were issued to address overall project QA/QC requirements; 7
programs for quarterly QA management reviews were implemented; a QA advisory committee was established to assist CEI's Vice 8
g President, System Engineering and Construction Group (now the 10 Vice President, Nuclear Group) on key QA program issues; CEI's yy audit program was restructured; and an integrated inspection /
g surveillance program of site contractors was established by CEI. In addition, important senior management administrative 13 g controls were instituted by CEI, such as formal monthly vice-15 president meetings and quarterly management meetings with the Chief Executive Officer and President. Finally, CEI instituted a project matrix system under which every safety-related Contractor is assigned a Construction quality engineer, responsible design engineer, and contract administrator from the Project Organization. -
Q. 8 Which elements of CEI's organization are most directly involved in oversight of site contractor activities?
A. 8 (Panel): The primary responsibility for the Project Organization's daily QA oversight of contractors rests with the QA Department's Construction Quality Section ("CQS"), shown on Attachment 2. CQS is divided by discipline into four units.
y These include a Civil / Structural Unit, a Mechanical / Piping 2
Unit, an Electrical Unit, and a Program and Records Unit. Each 3
unit is headed by a Unit Supervisor, who reports to the CEI General Supervisor in chargo of CQS.
4 5
The CQS units include quality engineers and QC inspectors organized by contractor area. The unit supervisor assigns a responsible QE to each contractor. He is supported by a staff 7
8 f QC inspectors and, in some cases, by other QEs. Each such 9 9r up is responsible for reviewing the contractor's QA program 10 documentation and monitoring the contractor's implementation of 11 its QA program requirements. The inspectors spend the majority 12 f their time performing field surveillance and inspection of 13 ntractor work to verify the contractor's compliance to 14 installation and quality specifications, drawings and technical requirements. The results of these are documented in 15 16 Surveillance Inspection Reports (" SIRS"). The QEs primarily g review and approve QC surveillance and inspection reports, and 18 tractor and Project Organization QA program documentation g such as procedures, instructions, specifications, nonconfor-mance reports, and design change documents. -
The size of the various CQS units has increased with the increase of construction activity at the site. For example, the CQS Electrical Unit has grown from two individuals in 1977, l to six in 1979, to a current level of 12. The Unit has i 24 -
generally had an equal number of QC inspectors and QEs. The other CQS units have undergone similar growth over time. In l
i l
l
y addition, CQS was reorganized in August 1981 to consolidate s parate QE & QC inspector units. The result was more involve-2 3
ment in field activities by QEs and more involvement in program activities by the QC inspectors. The overall result was a 4
better Coordinated overview of Contractor activities by CQS.
6 The responsible QE from CQS is the primary contact between 7
the contractor and the Project Organization with respect to all g QA matters relating to that contractor. That same QE is also a g member of a Project Organization contract team assigned to the Contractor. This contract team, which includes the QE, the g contract administrator, and a responsible design engineer from g the Nuclear Construction Engineering Section, is the vehicle 13 f r implementing the Project matrix system approach which CEI g instituted in 1978. Each contract team QE is supported by his g CQS staffs as needed. The contract teams meet regularly, often on a daily basis, to discuss the status of the contractor's program. In these meetings the QE brings any contractor QA problems to the immediate attention of his contract team 18 Counterparts. Normally the QE emphasizes potential pro-grammatic QA issues that merit action or followup by -
Construction oE Engineering. Any of these QA-related issues that cannot be resolved at the contract team level are brought to the attention of Project management for decision or manage-ment action.
24 i The other Project Organization entity with direct respon-sibility for contractor overview is the Quality Auditing Unit, l
1 shown on Attachment 2. This Unit was created in 1980 to c nduct annual independent audits of each safety-related 2
ntractor's QA program. Prior to 1980, these audits were 3
4 performed by the CQS quality engineers along with their other 5
verview resp nsibilities. The creation of a separate Quality 6
Auditing Unit allowed the quality engineers to increase their 7
inv lvement in the daily CQS overview activities. In addition, 8 this organizational change created a direct reporting line g between the auditors and the QA Department Manager. The number 10 f certified QA auditors in the Project Organization has grown 11 fr m 30 in 1978 to 90 at present.
12 CEI management also uses the Quality Auditing Unit to 13 perf rm peri dic internal audits of the Project Organization's g implementation of CEI's corporate QA program. The Quality 15 Auditing Unit is also responsible for compiling information used by the QA Department Manager in his quarterly report, g " Assessment of Quality Assurance Program Effectiveness " The use of this quarterly report is discussed later in our testi-
- "Y' 19 O
Q. 9 What are the principal QA/QC mechanisms used by the __
Project Organization in the day-to-day review of safety-related contractors? When and how extensively are these mechanisms utilized to control contractor activities at Perry?
A. 9 (Panel): The process of reviewing and approving the contractor's work procedures and instructions is the first step in CEI's overview of contractor activities. This review is an 26 1 ongoing process, since contractors' QA procedures and 2 instructions are continually updated and supplemented as the Project progresses. Implementation of the contractor's 3
4 approved program is then closely monitored and documented by 5
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me hanisms.
6 7 The most basic and widely used mechanism is the nonconfor-8 mance rep rt ("NR"). These are used by QC inspectors to 9 document any structural or equipment installation conditions 10 that do not meet specified requirements. NRs are issued by 11 b th the Project Organization and the contractor. An NR Coor-12 dinator in CEI's QA Department tracks all NRs issued by the 13 Project Organization and contractors using a computerized 14 tracking system. NRs can be dispositioned through repair, 15 rew rk, or scrap of the nonconforming item, or through a "use-16 as-is" disposition after engineering review and acceptance. In g general, when the nonconforming condition identified by Project gan a n pe s nne es an area or system w M has not 18 g yet been turned over by the contractor, CQS personnel will 20 direct the contractor to initiate the NR. After turnover, the -
NR would be initiated by the Project Organization. To date, over 18,000 NRs have been issued in safety-related construction areas by Project Organization and contractor personnel.
Approximately 2000 NRs have been issued in the electrical area.
If Project Organization QA personnel identify contractor programmatic or procedural deficiencies not involving plant 1 " hardware," these will be documented by CQS personnel as 2 bservation or surveillance Action Requests ("ARs"), or by the 3
- ^ "9 " ** * ^ ** * * ^" "9 "
4 is responsible for the tracking and followup of all ARs. A 5 mputerized tracking system is used for this purpose. Each 6
unit is responsible for closing out ARs which it generates. If 7
in reviewing an AR the unit that generated it determines that a 8 seri us pr grammatic problem is involved, that unit changes the 9 AR to a Corrective Action Request (" CAR"). The purpose of the 10 CAR is to assure that the problem receives increased management 11 attention until close-out. All open CARS are identified to 12 Project Organization managers and the Vice President, Nuclear Gr up, n a m nthly basis. To date, the Project Organization 13 g has issued approximately 140 CARS and 3900 ARs at the site.
g Seventeen CARS and 267 ARs have been issued in the electrical 16 Stop Work authority may be exercised by CQS to stop work p nding correction of an identified condition adverse to 8
g quality, where continued work would lead to a serious violation of CEI's QA program. To date CEI has issued 48 Stop Work -
Notifications ("SWNs") on the Project. CEI has issued 3 SWNs in the electrical area. Though not utilized often, the Stop Work Notification is an essential element in any QA program. -
The history of CEI's use of SWNs demonstrates our commitment to use whatever steps are necessary to assure effective imple-mentation of our QA program. The use of SWNs reflects a QA program at work, rather than one not working.
y Another significant review mechanism is the process audit, 2
which is performed by the CQS quality engineers. Process audits are conducted to provide a limited, detailed review of a 3
defined contractor work activity. They are conducted either in 4
5 response to previously identified problems, or in areas deemed 6
to be especially complex or critical from a safety standpoint.
7 With respect to all of the Project Organization in-line g QA/QC review mechanisms which we have just described, we would g like to emphasize that these are in addition to comprehensive 10 QA/QC inspections and audits of work activities conducted by 11 ea h contractor. CEI's surveillance and inspection of a g contractor involves a number of techniques ranging from reinspe tion of a contractor's work, to verification of a 13 g contractor's QC activities, to performing process audits of g field installation activities. The frequency and extent of field surveillance and inspection by the Project Organization in a given area, at a particular time, is based on a number of Considerations, such as the safety significance of the area g under construction, the level of construction activity involved, previous contractor performance, and the extent to _
which the activity involves a new type of work or procedure.
Q. 10 Describe CEI's system for periodically reviewing its program for assuring the quality of contractor performance.
1 Discuss in your answer how this system ascertains and corrects 24 deficiencies that have arisen in safety-related areas.
26 y A. 10 (Panel): CEI's system consists of a number of 2
elements. CEI management trends CEI quality engineer findings 3 through the use of monthly Performance Analysis Reports 4 (" PARS") and QA Department quarterly Assessment of Quality 5
Assuran e Program Effectiveness reports. In addition, CEI 6 management uses contractor and internal audits performed by 7 CEI's Quality Auditing Unit, as well as periodic reviews by the 8 Quality Assurance Advisory Committee ("QAAC"), to overview the 9 status and adequacy of the PNPP QA program.
10 PARS, along with any other special statistical trend 11 analyses which are performed by the QE, constitute the first 12 principal component of CEI's contractor trending / overview system. PARS are standard CEI internal reports used throughout 13 g the Company to communicate to upper management. CQS PARS 15 discuss the QA performance of each safety-related contractor at Perry. They are based on input from the responsible quality 16 l g engineer. In preparing this input the QE reviews the results of CQS inspectors' surveillance and inspections, including g SIRS, NRs, ARs, CARS and SWNs. In addition to considering this i
O quantitative data, the QE also considers other qualitative -
1 '
information obtained from the inspectors and directly from the l
contractor's QA organization. Emphasis is given to problem areas receiving special attention from CQS. Significant information in the CQS PARS is included in monthly QA l
25 Department PARS; and these are summarized in PARS prepared by
! the Vice President, Nuclear Group, for executive management.
l 26 l
l
l 1 As we have previously testified, any specific nonconforming 2
nditions or program deficiencies identified in the con-3 tractor's area will have been documented in accordance with the 4
formal QA corrective action system.
5 The next component of CEI's trending / overview program is 6 the QA Department Manager's quarterly report. This report, 7 compiled by the Quality Auditing Unit, includes input from all 8 Project departments and summarizes overall contractor QA
.g performance for the quarter. The report includes a separate 10 section on contractor performance. The quarterly report is 11 reviewed in a quarterly CEI Chief Executive meeting attended by 12 the executive staff and chaired by the President.
13 In addition to these overview mechanisms, the Vice 14 President, Nuclear Group, receives consultation and advice on 15 signifi ant QA policy issues from the QAAC. The QAAC includes 16 f ur seni r CEI management representatives, the corporate QA g managers of GAI and RKE, and an outside QA consultant.- The l
18 QAAC provides periodic assessments of the effectiveness of.the j g Perry QA program implementation. These assessments are based 20 reviews of the PARS, QA Department quarterly reports, c selected internal QA audits, NRC inspection reports, signifi-l
- cant NRs, ARs, CARS, and SWNs, and corrective action taken or j 22 i planned. The Committee members also observe site activities -
and interview site personnel involved in quality-related activities to evaluate the effectiveness of QA program imple-mentation.
26 l .
y Lastly, CEI regularly reviews the adequacy of its overview 2 program for monitoring safety-related contractors through 3 ontractor and internal audits performed by the QA Department Quality Auditing Unit, as discussed earlier in our testimony.
5 The objective of all the overview mechanisms which we have 6
described is to provide multiple communication channels to 7 assure that CEI management has the necessary information to 8
evaluate and direct the QA program. These reviews and reports g are tools which CEI management uses to stay close to, and involved in, the daily QA activities at the site. They are not g used as a substitute for CEI's formal inspection and corrective g action program. Any formal corrective action which management believes is required to address QA program deficiencies is g achieved through the NR/AR/ CAR /SWN mechanisms which we pre-vi usly described. We would emphasize that periodic QA reports 15 to CEI management are not generally for the purpose of detail-ing those program areas that are working well. Instead, management expects the reports to highlight problem areas and g to set forth the corrective actions underway to resolve those problems. -
Q. 11 Briefly describe CEI's initial review and selection of the electrical contractor at Perry.
A. 11 (Panel): In 1977 the Project Organization conduc-ted extensive reviews of proposals submitted for the safety-related electrical work to be performed at PNPP. This included a thorough review of the corporate quality assurance programs 1
f all the bidders. Included among the bidders was a joint 2
venture proposal submitted by E.C. Ernst & L.K. Comstock. The Ernst-Comstock proposal provided for L.K. Comstock to perform 3
4 project management, field engineering and quality assurance /
quality control, with E.C. Ernst in a limited role providing 5
field craft supervision. L.K. Comstock had significantly more 6
7 nu lear plant electrical experience than any other bidder. The results of the proposal evaluations indicated that the Ernst-8 g Comstock joint venture was well qualified to meet the Perry 10 Project quality assurance requirements. Their proposal was 11 also the r:)st responsive to the CEI specified technical 12 requirements. After careful consideration of all proposals, in 13 November 1977 CEI awarded the electrical contract to the Ernst-Comstock joint venture. In mid-1980 the joint venture was 14 diss lved and L.K. Comstock assumed responsibility for the 15 ntire electrical construction scope of work.
16 g Q. 12 Please summarize CEI's QA overview of the imple-mentation of L.K. Comstock'S program for the period prior to g November 1981.
20 A. 12 (Panel): After the award of the electrical -
contract and prior to the commencement of safety-related electrical work, L.K. Comstock's QA program and procedures for PNPP were thoroughly reviewed to assure full compliance with CEI's QA program. Electrical work was limited to non-safety related areas until CEI's review was completed. In August 1978 CEI released L.K. Comstock to perform limited safety-related civil excavation work.
1 Until mid-1980, safety-related work performed in the 2
electrical area was primarily underground civil ductwork, cable 3
tray hanger installation, and field placement of equipment.
4 Very little complex electrical installation was performed 5
during this initial period. For example, less than 5% of the safety-related conduit had been installed. Both L.K. Comstock 6
7 and CEI QA/QC personnel issued NRs and ARs that were typical in 8 number and severity compared to findings issued against other g contractors during comparable initial work activities. These 10 pr blems were appropriately documented; procedures were revised 11 to provide additional instructions when necessary; and formal 12 training sessions were conducted for L.K. Comstock personnel.
13 As the more complex electrical installation work began to 14 increase in the last half of 1980, the emphasis of CEI's QA 15 verview was shifted from program and procedure development and 16 review to surveillance of procedure implementation and field g installation activities. Review by CEI's QA/QC personnel documented that L.K. Comstock was experiencing conduit install-18 g ation problems that required closer monitoring. Immediate Corrective actions taken to resolve Conduit installation -
l problems included increased CEI surveillance of the installa-tion, and increased, better defined in-process inspections by L.K. Comstock. This corrective action had direct results. As g
L.K. Comstock increased its in-process inspections, the number of L.K. Comstock NRs increased, reflecting a more active contractor QA/QC program. In December 1980, CEI quality 1
engineers analyzed these NRs and identified a trend of L.K.
2 Comstock craft misinterpretations of drawings and specifica-tions. L.K. Comstock responded by instituting a comprehensive 4
training program for craft in order to correct the problem and prevent its recurrence. As a result, L.K. Comstock NRs were 5
reduced in the first quarter of 1981. Since that time L.K.
6 7 Comstock has spent significant resources in the development and use of its Craft training program. For example, from January 1981 to July 1982 L.K. Comstock spent approximately 15,000 9
10 hours training craft and QA/QC personnel.
11 The QA sequence which we have just described illustrates 12 how CEI's QA program has controlled safety-related contractor work at PNPP. CEI required increased inspection, which led to g increased identification of deficiencies, which in turn allowed 15 CEI and the contractor to understand and correct a program 16 pr blem before that problem led to installation problems. This g QA process of identifying and correcting deficiencies during Construction is a Continual and iterative process that proceeds g until plant construction is complete.
In 1980 and 1981, as the more complex electrical construc- -
tion accelerated, CEI identified the need for increased numbers of L.K. Comstock QC personnel. During this period, the nuclear industry in general was experiencing a shortage of qualified -
electrical inspectors due to significant nuclear construction activity and a general strengthening of QA/QC requirements in the nuclear electrical discipline. As a result of L.K.
'l
1 Comstock's difficulty in hiring additional qualified inspection 2 pers nnel, and with increased attention being given by the Contractor to in-process inspection, final inspection backlogs increased. This was a periodic problem during 1980 and 1981.
4 a
L.K. Comstock did increase its staff throughout 1981; in 6
addition, CEI increased its field surveillance of construction 7 activities in the last half of 1980 and in 1981 in order to g assure sufficient overview of installation. Increased Con-g tractor QC staffing resulted in a reduction of the final 10 inspection backlog by mid-1981.
11 During the summer of 1981 safety-related cable pulling 12 activities began to increase. Through October 1981, cable 13 pulling deficiencies were identified and documented by the QA g programs of the contractor and CEI. Most of these deficiencies 15 were pr cedural in nature and were attributable to initial 16 Program implementation of this complex safety-related construc-g tion activity. However, in November 1981, because the number 8 and types of discrepancies identified by CEI and L.K. Comstock g had not decreased, and because of concerns raised during the 0
81-19 inspections, CEI QA issued a Stop Work Notification for -
safety-related cable pulling. The SWN required L.K. Comstock to review thoroughly its safety-related cable pulling program, and to make the programmatic changes necessary to reduce -
implementation deficiencies. L.K. Comstock significantly revised its cable pulling procedure prior to restart of work in January 1982.
y Q. 13 Please summarize CEI's QA overview of L.K.
2 Comstock's program since November 1981, including CEI's 3
r sp nses to NRC Region III's investigation of the PNPP electrical area, conducted between October 1981 and March 1982.
4 A. 13 (Panel): As indicated in Region III's report on 5
6 the investigation (the "81-19 Report"), allegations were made 7 directly to the NRC in October 1981 concerning the performance g of the PNPP electrical contractor. The NRC found no noncompli-g ances with respect to those allegations. In addition to 10 investigating the allegations, the NRC conducted a general g inspection of electrical construction activities taking place g at that time. As a result of extensive inspections (711 hours0.00823 days <br />0.198 hours <br />0.00118 weeks <br />2.705355e-4 months <br /> of inspection by six NRC representatives), the NRC identified g nine items of noncompliance. Deficiencies identified in the nn mpliances inv lved: an inadequate switchgear drawing 15 16 review; instances of incomplete procedures and procedure implementation difficulties; a failure to return six voided dravings to a central file; control and storage of nuts, bolts 8
g and cable mounting bases; three instances of incomplete inspections; two instances of inadequate housekeeping; a -
missing switchgear hold tag; eight instances of inadequate conduit separation; and a failure to trend eight NRs. The 81-19 Report assigned all of the noncompliances comparatively-low (level IV or V) severity levels. The Report identified no significant hardware deficiencies. CEI took prompt corrective action in each of the noncompliance areas.
1 In February and March of 1982, CEI met with Region III to 2
discuss preliminary findings from the NRC's inspections. In response to those meetings, CEI performed an extensive review 4 and evaluation to re-examine the effectiveness of its QA 5
program for safety-related contractors.
6 As part of this review, CEI conducted a special safety-7 related contractor QA evaluation. In the special evaluation, 8 nducted in February and March 1982, CQS quality engineers and 9 QC inspectors separately evaluated each safety-related con-tractor. Factors considered included: scope of work; 10 yy outstanding NRs and ARs; QA/QC staffing level; responsiveness 12 to CEI concerns; organizational independence; contractor 13 internal auditing performance; and status and adequacy of g documentation. The evaluation teams were directed to focus on Contractor Weaknesses, to identify deficiencies, and to recommend action items for improvement. Although NRs and ARs were identified and documented during the evaluation, the review was oriented to the management aspects of the QA program g and was independent of CEI's formal ongoing QA program. In addition to the special evaluation, interviews were conducted =
concerning the general use of the PNPP nonconformance system.
The overall conclusion of these evaluations was that there was no indication of a quality assurance breakdown in any area, and that CEI's QA program was adequately controlling safety-related construction. However, a number of areas for improve-ment were identified, including the need for increased emphasis 1 n timely resolution of findings, more training in the 2
utilization of NRs, and clearer procedures.
L.K. Comstock's QA program, including the contractor's 4
responses to the various inspections and reviews just 5 described, continues to be under the cloce scrutiny of CEI CQS p rsonnel. In addition, CEI's Project management has been 6
7 1 sely m nitoring the status of the electrical QA program.
8 This has included frequent management level discussions and g meetings between CEI and L.K. Comstock. L.K. Comstock has Concentrated on addressing and Closing out the various findings 11 which we have previously discussed. For example, in 1982 12 al ne, the contractor doubled the size of its QA/QC staff and 13 signifi antly increased the training and qualifications of its QA/QC personnel. In June 1982, L.K. Comstock in conjunction 14 15 with the National Electrical Contractors Association and the International Brotherhood of Electrical Workers held'a special two day training workshop for L.K. Comstock craft personnel w rking at Perry. The workshop emphasized conduit installation 18 g and cable pulling requirements and reviewed applicable QA requirements. Also during 1982, L.K. Comstock hired personnel -
with experience in program and procedure development, to give special attention to procedure interpretation problems identified in the earlier reviews. Management representatives from L.K. Comstock's corporate offices have spent significant effort, including time on-site, in assuring that the contractor is properly responding to outstanding issues and to all CEI QA program requirements.
I 1 The most significant current QA issue is the number of 2 utstanding final inspections to be completed. Part of the Current final inspection backlog is attributable to the QA 4
resources devoted by L.K. Comstock in response to the inspec-5 tions and reviews which we have described. CEI has required L.K. Comstock to reduce the final inspection backlog in 7
accordance with an agreed schedule. CEI management and CEI's 8 CQS personnel are closely monitoring the backlog to assure that 9 it has no adverse impact on the safety of completed and 10 in-process electrical construction.
11 Q. 14 What assurance do you have that CEI's QA/QC program 12 has identified and corrected deficiencies in contractor 13 pr grams at Perry, and that contractor programs have not g resulted in unsafe conditions at Perry?
15 A. 14 (Panel): Our testimony describes in detail how g CEI's QA/QC program thoroughly overviews safety-related g contractors at Perry. CEI's overview process begins with pre-8 award QA reviews and continues through program development and g
implementation. At every stage, Project Organization QA personnel perform sufficient QA reviews, including procedure _
reviews and field surveillance, to assure CEI that the con-tractor is meeting CEI QA program requirements. We have 3
demonstrated, using the example of the electrical area program, how CEI's QA program identifies deficiencies in the con-tractor's program, analyzes the underlying causes of the deficiencies, and corrects the deficiencies and their underlying causes.
I 1 In a nuclear project of the size and complexity of PNPP, 2 indeed in any construction project of this scope, the goal is 3
perf t compliance with all project procedures and require-ments. However, there will invariably be deviations and 4
nn mpliances found by the utility, its contractors and NRC 5
insp tors. The purpose of CEI's QA program is to assure that 6
7 procedural and substantive problems at PNPP are adequately 8
identified and properly addressed. We are committed to a g program that will accomplish this purpose. CEI's senior 10 management is actively involved in seeing that this commitment 11 is met. Our QA program has assured, and will continue to 12 assure, that unsafe conditions in the Perry facility do not exist.
3 14 15 16 17 18 19
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PERRY NUCLEAR POWER PLANT NUCLEAR QUALITY ASSURANCE PROGRAM EOLICY ,,
The Cleveland Electric Illuminating Company recognizes the need for a formal' and comprehensive Nuclear Quality Assurance Program for the Perry Nuclear Power Plant. 'Ihis program is considered vital to the safety, security and i well-being of the public, our customers, employees and shareholders. As agents for the owners, we maintain ultimate responsibility for the develop-ment and implementation of a program that contributes to the safe and reliable design, construction and operation of the Perry Nuclear Power Plant.
It is the policy of this Company that such a program fully comply with the regulatory requirements of 10CFR50, Appendix B; ASME See: tion III, Article
] NA 4000; ASME Section XI, Article IWA 1000, as applicable, and any addi-tional regulatory guides, codes and standards which address quality
~
i assurance requirements that are set forth in the Safety Analysis Reports for the Perry Nuclear Power Plant.
An evaluation of the philosophy, policies and genera 1' requirements disclose that the ASME and CEI Quality Assurance Programs are counpletely compatible
- .? in scope, purpose and intent. -
The Cleveland Electric Illuminating Company has the responsibility for the accumulation and retention of all required records and cHocumentation. In additi n, CEI is conmitted to ASME Sec lon III, Ardele .NA 323D, ,and haa ' ,,_
contracted with Hartford Steam Boiler Inspection and Insturance Company as its authorized inspection agency. The inspection agency is granted access and freedom to the project to perform all required inspections. and audits.
The Cleveland Electric Illuminating Company agrees to cannply with ASME .
Section III, Article NA 3270 by preparing, certifying and filing the re-quired N-3 Data Report. c Quality assurance is recognized as a most demanding function in terms of the interdisciplinary efforts that are required. There fore,, the program will define specific individual and organizational responsibility and authority.
It will also prescribe procedures for compliance with regulatory requirements and establish appropriate guidelines for implementation of these procedures.-
All Company and other associated personnel involved in or responsible for the quality of the Perry Nuclear Power Plant shall comply with this program. All Company personnel are responsible for implementation of those portions of the Nuclear Qunlity Assurance Program pertinent to their respective areas of re-sponsibility. ,
L
- . Page 2 The Vice President, Nuclear Group, is assigned the responsibility for assuring
, that the Nuclear Quality Assurance Program is established and implemented. He shall periodically review the overall effectiveness of the Nuclear Quality Assurance Program and has authority to administer corrective action to icprove its effectiveness or to avoid potential problem areas.
The Nuclear Quality Assurance Department Manager is responsible for assuring the development of the Nuclear Quality Assurance Program. He is responsible fon assuring through audit, or other quality assurance techniques, that estab-
'lished systems are implemented, adequate, and are in fact, effective methods which will provide canagement with confidence that we are proceeding according to plan. He is further responsible for verifying and documenting that we have met all regulations, commitments and other established requirements with respect to safety-related activities, systems and equipment. "
The Nuclear' Quality Assurance Department has the responsibility to identify quality problems, initiate, recommend or provide solutions and verify imple-mentation of solutions. To accomplish these tasks, the Nuclear Quality Assurance Department is hereby given the authority to stop unsatisfactory ~~"
work or control further processing, delivery or installation of noncon-forming material pending resolution of identified quality-related problems.
Any Company employee who at any t'ime believes that The Cleveland Electric Illuminating Company's Nuclear Quality Assurance Policy or Program is not being fully complied with has the right and indeed the obligation to so inform his or her superi~o rs of any such deviations, including the right of direct appeal to upper management of the Company.
s_ The Corporate Nuclear Quality Assurance Program as described in this_ manual
. has my unqualified support. All differences of opinion concerning quality assurance which cannot be resolved by the Vice President, Nuclear Group, and -
Vice President, Administrative Services Group, will be referred to me for fina? resolution. , ___.
s F RoberiJt{ Ginn President February 25, 1983 e
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