ML20078M266
| ML20078M266 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/30/1983 |
| From: | Laney R, Roddis L, Sheets H TECHNICAL AUDIT ASSOCIATES, INC. |
| To: | |
| Shared Package | |
| ML17277A953 | List: |
| References | |
| 1126-F1, 1126-F1-V01, 1126-F1-V1, NUDOCS 8310250093 | |
| Download: ML20078M266 (100) | |
Text
AN INDEPENDENT EVALUATION OF l
l THE PLANT VERIFICATION PROGRAM l
AT THE WASHINGTON NUCLEAR power STATION No. 2 l
l Vot Une I QUAUTY VERIFICATION TAA REPORT 1126 -F1 i
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PDR SEPTEMBER 1983 TECHNICAL AUDIT ASSOCIATES, INC.
589 OENOKE RIDGE, NEW CANAAN, CT 06840
4 VOLUME $
AN INDEPENDENT EVALUATlON or THE QUALITY VER$FICATION PROGRAM AND QUALITY CONTROL EFFECTlVENESS AT THE WASHINGTON NUCLEAR Power STATION No. 2 i
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TECHNICAL AUDIT ASSOCIATES, INC 589 OENOKE RIDGE, NEW CANAAN, CT 06840
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i II Au luoepanoEur EVALUADON OF THE REOutREMEurs Ano DEStan REVERIFICATION PROGRAM 111 TECHNICAL AuorT ASSOCIATES REPORTS OF WNP-2 Auotrs i
l TAA TECHNICAL AUDIT ASSOCIATES, INC.
1 589 OENOKE RIDGE, NEW CANAAN, CT 06840 l
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TABLE OF CONTENTS Pace I.
Summary and Conclusions 1
Background
1 IB Evaluation of the PVP Plan.
3 IC Evaluation of Implementation of the OVP Program 5
ID Evaluation of Management's QA Effective-ness Since Work Restart in July 1981.
8 II.
Introduction.
10 II A
Background
10 II B Characteristics of a Self-Audit Program 14 III.
Audit Process 18 III A Evaluation of PVP Adequacy.
18 III B Audit of QVP Implementation and Manage-ment's Quality Effectiveness 20 IV.
Audit Results 24 IV A Evaluation of the PVP Plan.
24 A-1 Management Attitudes and Understandings 25 A-2 Adequacy of PVP Objectives.
26 A-3 Assurance of Objective Performance 27 t
A-4 Adequacy of Plan Scope 28 A-5 Adequacy of Resources to Execute Plan 29 A-6 Adequacy of Sampling Procedures 31 Conclusion Concerning PVP Adequacy 34 TECHNIC %L AUDIT ASSOCIATES. INC.
TABLE OF CONTENTS - 2 Page IV Audit Results Continued IV B Evaluation of QVP Implementation.
34 B-1 Scope Adequacy.
35 B-2 Sample-Size Distrubution and Enlargement 37 B-3 Standards of Competance for Field In-inspection Teams 40 B-4 Managers Response to Challenge 42 B-5 Adequacy of Evidence Supporting Conclu-sions of Written Reports 45 D-6 Visible Management Acions Supporting Ef-fective Implementation 46 B-7 Effectiveness of Task Close-Out 48 Conclusion Concerning QVP Implementation 51 IV C Evaluation of Management's QA Effective-ness 52 C-1 Improvement in Management's Control of Construction Quality.
52 C-2 Obtaining Experienced Construction Man-agement 54 C-3 Improving Quality of Work Procedures 56 C-4 Reduction and Control of Deficiency Documentation Backlog 57 Conclusion Concarning Management's QA Effectiveness Si.nce Restart 59 TECHNICAL AUDIT ASSOCIATES. INC.
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TABLE OF CONTENTS -3 Figures:
Page Quality Verification Program Report Hierarchy.
49 Quality Verification Matrix, Safety Related Work.
50 Appendices:
A.
Categories and humbers of Documents Selected and Reviewed by TAA B.
_TAA QVP & QA Related Recommendations, Findings & Observa-tions from On-Site Audits and Supply System Responses C.
List of Persons Interviewed by TAA D.
List of TAA/ Supply System /NRC - Visits / Meetings E.
Biographical Information en TAA Team Members l
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I.
SUMMARY
AND CONCLUSIONS:
I-A BACKGROUND:
By concract dated March 12, 1982 and subsequent modifications, the Washington Public Power Supply System (Supply System) retained Technical Audit Associates, Inc. (TAA) to review and evaluate its WNP-2 Plant Verification Program (PVP) and to audit the effectiveness and objectivity of its implementation.
TAA assessed and made recommendations on the entire PVP.
It audited the Supply System's implementation of three designated areas, namely Requirements and Design Reverification, the Quality Verification Program (QVP), and the effectiveness of quality control after the restart of construction in July 1981.
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TAA evaluated those parts 01 the PVP plan used by the Supply System to verify construction quality and assessed the effectiveness with which they were implemented.
Although TAA has not directly appraised the quality of construction in the field, it observed the value of a comprehensive and scrupulously executed validation program in providing additional confirmation of quality.
Where, as in this case, TECHNICAL AUDIT ASSOCIATES. INC.
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l the entire process is audited by a team of indepen('ent technical managers, those auditors can form valid j._ugements on the adequacy of implementation and the level of quality achieved.
This portion of TAA's report, Volume I, addresses three designated areas:
e Adequacy of the PVP Plan e
QVP Implementation e
The Effectiveness of Supply System Management in Resol. ring Quality Problems Arising Since the Restart of Construction TAA's evaluation of another major part of the PVP, the Requirements and the Design Reverification Program, is the subject of Volume II of this report.
TAA was not asked to comment on two other parts of the PVP, namely Performance Verification (Test) and Operating Envelope Verification.
3 The PVP was developed by the Supply System after a 1980 breakdown in WNP-2 management control and work quality and a suspension of safety-related work.
Substantial changes in Supply System management and construction contractors ig TECHNICAL AUDIT ASSOCIATES. INC.
followed.
Seeing a need for independent oversight of the recovery program which was then developed, the new Managing Director instructed TAA to carry out such surveillance as TAA believed to be necessary to assure it and him that the PVP program was sound and that implementation was objective and thorough.
TAA was directed to make its reports to the Managing Director.
I-B EVALUATION OF THE PVP PLAN TAA's first task was to review, evaluate, and report on the adequacy of the PVP plan in its entirety, including verification of design, construction, plant performance, a,3 operating envelope.
TAA's evaluation of the plan took several attributes into consideration:
l Management Attitudes and Understandings e
Adequacy of PVP Objectives e
e Assurance of Objective Performance e
Adequacy of Plan Scope Adequacy of Resources to Execute the Plan e
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e Adequacy of Sampling Procedures l
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The TAA Panel evaluated a first draft Plan dated April 9, 1982, discussed it with recponsible managers at an on-site meeting at Richland, and reported that the Panel considered it unsatisfactory.
Iri its report of May 28, TAA made a number of suggestions for improvement.
In June 1952, the Supply System responded in writing to the TAA suggestions and provided a modified Plan titled "WNP-2 Plant Verification Report" dated June 1982.
TAA reviewed the June plan.
In its report of j
August 6, 1982, TAA advised that it considered the June report adequate, subject to the incorporation of a number of previously agreed upon modifications.
The recommended modifications were later incorporated, and the final PVP plan was subsequently issued as Revision 1 in October 1982.
(See TAA reports of May 28 and August 6 contained in Volume III of this report.)
Details of TAA's evaluation of the PVP are in Section IV A of this report.
Based on information presented there, document reviews, and on-site discussions, TAA reached the following l
conclusion:
Conclusion Concerning PVP Adequacy The TAA Panel believes that the final PVP Plan dated October 1982 describes a comprel.cnsive and integrated set of activities which l
are capable of providing confidence that WNP-2 has been designed and l
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, N constructed to meet applicable regulatory requirements and Safety An-alysis Report commitments.
We further believe that the PVP, together with related procedures and instructions, contains adequate measures to assure that it is objectively carried out.
It is our opinion that, if properly implemen:cd, the PVP will provide convincing evidence that WNP-2 has been designed and constructed to meet committed require-men ts.
I-C EVALUATION OF IMPLEMENTATION OF THE QVP PROGRAM TAA's second task was to evaluate and report on the implementation of the QVP program, which was designed to verify the quality of safety related work completed and accepted prior to July 1986.
TAA's appraisal of the QVP program and management's QA was t
based on a series.of document reviews, on-site visits, interrogations, and discussions spanning the period from September 1982 to the date of this report.
TAA selected the documents to be reviewed.
The types and numbers of documents reviewed are indicated by the list in Appendix A.
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As noted thern, TAA reviewed numerous documents prepared'by the Supply System, ir.cluding the Project units and corporate Quality Assurance.
In order to give a broader perspective, TAA also reviewed numerous critical evaluations and audit reports from other sources, such as the Nuclear Regulatory Commission; the construction manager, Bechtel Power Corporation; the architect-engineer, Burns & Roe; and other construction contractors and suppliers.
Each on-site audit focused on discussions of written questions raising points of challenge or doubt which TAA sent to the Supply System before each audit visit.
TAA's questions were discussed and answered during the on-site visits or 1
later.
Each TAA visit included a tour of the work site.
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visit was documented in a TAA audit report containing Findings and Observations expressing TAA's residual conc 6rns.
By agreement, all Findings required acceptable written responses from the Supply System to TAA.
Volume III of this report contains copies of all TAA audit reports.
TAA's Recommendations, Findings and Observations related to the QVP and QA, together with the Supply System's responses, are in Appendix B of this volume.
TECHt4tCAL AUC T ASSOCIATES. INC.
, TAA's evaluation of QVP implementation utilizes attributes which were selected for their relevance to that task and because they were, with a few exceptions, susceptible to tangible confirmation.,These criteria, discussed fully in Section IV of this report, are listed below and are followed by TAA's conclusions concerning the adquacy of QVP implementation.
Attributes Used to Evaluate the Adequacy of QVP Implementation e
Scope Adequacy e
Sample Size, Distribution, and Enlargement Standards of Competence for Field Inspection Teams e
e QVP Manager's Response to Challenge Adequacy of Evidence Supporting Conclusions of Written e
Reports Visible Management Actions Supporting Effective e
Implementation e
Effectiveness of Task Close-Out Based on the information presented in Section IV B of this report, document reviews, on-site audits, and face-to-face discussions, the TAA Panel reached the following conclusion:
TECHNICAL AUDIT ASSCCIATES. INC.
_ - _ - _ - - - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ - _ _ _ - _ - - _ - _ _ - _ _ _ _ Conclusion Concerning QVP Implementation The TAA Panel believes that the Quality Verification Program as set forth in the Plant Verification Program of October 1982, and the Ouality Verification Instruction Manual of June 1981, has been ef-fectively implemented as reported in the Supply System's " Quality Ver-ification Program Report, Volume I" dated Septebmer 21, 1983.
I-D EVALUATION OF MANAGEMENT'S QA EFFECTIVENESS SINCE WORK RESTART IN JULY 1981 TAA's evaluation of the Supply Systen. Management's effectiveness in assuring adequate quality after work restart was performed in a manner similar to that described above for QVP inplementation.
TAA reviewed documents, conducted on-site visits and interrogations which probed management's quality attitudes and actions, and assessed the adequacy of answers to its Findings.
The following selected attributes were used in this evaluation.
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Improvement in Management's Control of Construction Quality Obtaining Experienced Construction Management e
Improving Quality of Work Procedures e
e Reduction and Control of Deficiency Document Backlog TECHNICAL AUDIT ASSOCIATE 3. INC.
i TAA's appraisal of the Supply System's performance in each of these areas is discussed in Section IV C.
Based on the s
information presented there, its review of relevant documents, on-site audits, and discussions with top management, the TAA panel reached the following conclusion:
Conclusion Concerning Management's OA Effectiveness Since Restart The present quality assurance program which grew out of exten-sive management, contractor, and ~ procedure changes during the period of,, work suspension is built upon a forceful, uncompromising quality a ttitude.
It is bolstered by improvad work control practices develop-ed in the Restart Program and by the services of a new, experienced i
Construction Manager.
TAA believes that the resulting Quality As-l j
surance Program is effective and adequate.
TECHNICAL AUDIT ASSOCIATES, INC.
II. INTRODUCTION II-A BACKGROUND The Washington Public Power Supply System (Supply System),
in March 1982, retained Technical Audit Associates, Inc. (TAA) to review and evaluate its WNP-2 Plant Verification Program (PVP) and to audit the effectiveness and objectivity of its implementation.
TAA assessed and made recommendations on the entire PVP.
It audited the Supply System's implementation of three designated areas, namely Requirements and Design Reverification, the Quality Verification Program (QVP), and the effectiveness of quality control after the restart of construction in July 1981.
It is worth noting that the Supply System's QVP program includes not only verification work performed di.rectly by the QVP Staff assisted by Bechtel's reverification group, but also special inspections and reviews performed by the Project or other site contractors.
In order for these latter inspections to be accepted for inclusion in the QVP program, they must first be evaluated and accepted according to instruction QVI-05.
TAA has evaluated the entire QVP program.
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! TAA evaluated those parts of the PVP plan used by the Supply System to verify construction quality and assessed the effectiveness with which they were implemented.
Although TAA has not directly appraised the quality of construction in the field, it has observed the value of a comprehensive and scrupulously executed validation program in praviding additional confirmation of quality.
Where, as in this case, the entire process is audited by a team of independent technical managers, those auditors can form valid judgements on the adequacy of implementation and the level of quality achieved.
This portion of TAA's report, Volume I, addresses three designated areas:
e Adequacy of the PVP Plan o
QVP Implementation G
e The Effectiveness of Supply System Management in Resolving Quality Problems Arising Since the Restart of Construction TAA's evaluation of another major part of the PVP, the Requirements and the Design Reverification Program, is the subject of Volume II of this report.
TAA was not asked to TECHNICAL AUDIT ASSOCIATES. INC.
. comment on two other parts of the PVP, namely Performance Verification (Test) and Operating Envelope Verification.-
The PVP resulted from the discovery at WNP-2, in 1979 and 1980, of inadequate management controls and construction quality and from ensuing changes in Supply System management, contractors, and practices.
The new Managing Director, in taking responsibility for a partly completed plant on which construction had been suspended, directed the development of a detailed completion plan to include, among its other features, a thorough and systematic review of past work in order to provide a documented basis for final acceptance of plant completion, safety, and technical adequacy.
The Plant i
Verification Program was prepared in response to this directive.
As stated above TAA was directed to assess the entire PVP and to evaluate the adequacy of implementation of specified portions of it, namely:
Requirements and Design Reverification e
e The QVP, which was designed to establish the adequacy of construction completed before the July 1980 work shutdown TECHNICAL AUDIT A SSOCIATES. INC.
_ _ _ _ _ The effectiveness of management actions to resolve o
quality problems arising after the restcrt of construction in July 1981.
The Supply System elected to perform the evaluation, analysis, and audit work defined in the PVP with its own personnel, assisted by personnel of its on-site contractors.
The Supply System assured itself of independent attitude and judgment in two ways.
Internally, verification activities were conducted by qualified individuals who had had no previous responsibility for the work being verified.
Some were drawn from Supply System corporate staffs and from other Supply System power plants.
Others were obtained from the new construction manager, Bechtel Power Corporation, or from special engineering sub-contractors such as Stone and Nebster and Westinghouse.
Where reliance for certain reinspections was placed on existing construction contractors, as in portions of the QVP program, quality assurance oversight was performed by new personnel not previousl1 involved.
1 For external verification of objectivity, the Managing Director instructed TAA to monitor, evaluate, and report to him on the adequacy of the QVP Plan and its implementation, including maintenance of bias-free attitudes at all levels.
TECHNICAL AUDIT ASSOCIATES. INC.
. The contract between the Supply System and TAA emphasized a strong joint commitment to an independent TAA audit.
It granted TAA full access to Supply System personnel and documents needed in its work, and specified that the need was to be determined by TAA.
It assured the funds required to do the job.
It provided that TAA should submit its reports directly to the Managing Director, and that those reports were not subject to any prior revicw.
Finally, each member of the TAA Panel filed with the Supply System a certificate affirming no conflict of interest.
Copies of all TAA's audit reports have been sent to the Nuclear Regulatory Commission.
71-3 CHARACTERISTICS OF A SELF-AUDIT PROGRAM The Supply System's self-initiated Plant Verification Program, directed by its own employees, is an innovative way to validate the adequacy of a plant which has experienced managemer.t and quality breakdowns during construction.
In TAA's opinion, a self-audit program can, when performed under the right circumstances, be extremely effective.
Its effectiveness comes from two unique features, namely, a reliance on in-house personnel combined with an independent, external audit of performance.
The design and construction TECHNICAL AUDIT ASSOCIATES. INC.
l inspections, reviews, and analyses leading to validation are directed or performed primarily by the same Supply System employees who, during future plant operation, will be J
responsible for the plant's safe performance.
Anticipation of this future responsibility ensures a searching evaluation.
Moreover, Supply System employees acquire a detailed knowledge of plant design and as-built configuration which could not readily be obtained in any other way.
Coupling the in-house assessment with an independent oversight audit, mandated by the top executive, assures depth, balance and objectivity.
Auditing an in-house validation program is quite different from conducting an independent assessment using personnel from an outside organization.
Instead of hands-on analysis or inspection of selected samples, a self-audit requires the external auditors to observe and test the validity of sample selections and analyses performed by others, in this case, the Supply System.
A successful self-audit requires a firm commitment from senior management, a team of qualified reviewers who did not take part in the original work, and a searching audit by a team experienced in evaluating engineering and construction which has been performed under cost and schedule pressures.
TECHNICAL AUDIT ASSOCIATES. INC.
The Supply System's Plant Verification Program is
'innovativa and has proven to be effective.
This approach of fers advantages which are not available f rom conventional external assessments.
The TAA Panel believes that these advantages are valuable to the owner, contribute to the safety of operation, and, in this case, have been attained without sacrificing the integrity of the evaluation process.
TAA emphasizes that a strong, visible management committment to quality is essential to the success of a self-audit program.
We observed such a committment during our audit of this program.
We recognize, however, that this committment reflects the attitudes of the individual managers in charge of tne project.
Hence the important attribute, management committment, must be reassessed when changes take place in key personnel.
TAA used the services of three broadly experienced i
technical managers, two expert consultants and a highly i
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qualified assignment manager to perform this audit and prepare its report.
Pertinent biographical information is contained in Appendix E.
Appendix C lists the persons whom the TAA Panel i
interviewed in the course of the eudit, and Appendix D shows all of TAA's meetings and visits.
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l The following Secti0n III, AUDIT PROCESS, describes the f
methods used by TAA to evaluate the PVP,-QVP-implementation, i
l and management's quality. control effectiveness after restart.
Section'IV, AUDIT RESULTS, presents the details of its evaluation which form the bases for TAA's conclusions.
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III AUDIT ' PROCESS III-A EVALUATION OF PVP ADEQUACY TAA's first responsibility was to review and evaluate the adequacy of the Supply System's proposed Plant Verification Program and to report to the Managing Director on its adequacy, taking into consideration its scope, proposed depth of analysis, and prescribed audit methods.
TAA received and reviewed an early draft PVP Plan dated April'9, 1982.
The TAA team assembled at the Supply System's Richland offices and the WNP-2 site on April 26, 27 and 28 in order to discuss the draft Plan directly with Supply System and principal contractor personnel who would be responsible for executing the plan and utilizing its results.
i The TAA panel used this opportunity to evaluate the quality I
attitudes expressed by key managers at corporate, project and contractor levels.
It observed if these attitudes were the same or different throughout the organization, and if there were varying perceptions of the PVP's purpose or importance.
It enquired into the magnitude of the tasks laid out in the PVP I
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s and who would perform them.
It asked what level and quality of resources management expected'to commit in order to fulfill the PVP_ purposes.
i Following these' interviews the TAA Panel prepared a report l
' dated May 28, 1982 containing its overall evaluation of the proposed PVP.
(The text is in Volume III of this report.)
This report states that the Panel considered the April 9 draft e
plan to be unsatisfactory for the purpose intended and contains 4
a number of suggestions for improvement.
The Supply System forwarded written responses to TAA's comments in June, and followed these by-sending a modified PVP later the same month.
Based on reviews of these and various other supporting documents and additional on-site interviews, TAA concluded that the June "WNP-2 Plant Verification Report" presented an l
adequate plan for plant verification, provided it were further modified to include certain additions which had been discussed
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and agreed upon.
These views were expressed in TAA's final Ph'ase I report of August-6.
The final Supply System PVP,
_ as issued as Revision 1 in l
containing the recommended changes, w
1 October 1S62.
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III-B AUDIT OF OVP 1MPLEMENTATION AND MANAGEMENT'S QUALITY EFFECTIVENESS TAA's second responsibility was to audit the Supply System's implementation of selected portions of the PVP.
Specifically, TAA was directed to conduct continuing reviews so as to be able, at the program conclusion, to make a credible statement concerning the adequacy of the Supply System's implementation of the QVP program and the effectiveness of management's actions to resolve quality problems arising after the restart of construction in July 1981.
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TAA's audit process utilized the review of an extensive list of documents selected by TAA, a series of written questions to the Supply System arising from these document reviews, on-site visits and discussions with those responsible for QVP and QA, formal TAA audit reports with Findings following each visit, and evaluation of the Supply System's written responses to those Findings.
Each of these activities ic briefly described.
3 TAA selected and reviewed a large number of documents s
relevant to the audit subjects.
These included documents L
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_- prepared by the Supply System; the Nuclear Regulatory Commission; the construction manager, Bechtel; the archetect-engineer, Burns and Roe; the NSSS supplier, General Electric; 4
on-site construction contractors; and Suppliers.
They included QA audits, policies, procedures, reports, and correspondence.
Because the list is so extensive and diverse, the only satisfactory way of describing it is to attach, as Appendix A to this report,-a list of document categories which were reviewed showing the number of documents in each category.
(Appendix A contains TAA's total list of document categories, including those related to Design Reverification as well as QVP and QA.)
i These documents represent only a sample of the total of such documents, although the sample is a significant one.
With few execptions, they were reviewed by all TAA Panel members and many were reviewed by its consultants as well.
For example, TAA reviewed and prepared written evaluations of all of the nine contract completion reports in either their final form or in near-final draft form.
It reviewed and evaluated a sample of six of the reports covering special inspections for which the QVP program "took credita under QVI-05.
Similarly, TAA reviewed drafts or final versions of a sample of three of the i
Special Task reports.
These reviews frequently raised
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. questions in the minds of Panel members which were then written and sent to the Supply System to be discussed during the next on-site audit.
Each TAA audit report contains the questions which were taken p during that audit.
(TAA's Audit Reports are in Volume III of this report.)
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TAA's questions were prepared by professional managers each J.
of whom is experienced in reviewing and assessing complex operations and uncovering weaknesses.
Their questions were usually searching and aggressive in tone.
They might reflect, for example,'a demand for further evidence, question an apparent contradiction, or note a failure to proceed in accordance with program guidelines so as to meet program objectives.
Such questions raised issues around which to structure face-to-face discussions with the responsible persons and assisted TAA to increase its understanding of the
' implementation process.
TAA conducted six three-day on-site audits.
(See Appendix D.)
Each on-site audit was followed by a formal report, including Findings and Observations.
TAA's Findings and Observations reflect TAA's residual concerns about program implementation at the end of each audit.
By agreement with the Supply System, each Finding required a written response from TECHNICAL AUDIT ASSOCIATES. INC.
the Supply System.
These responses were an important source of information used by TAA.in reaching its conclusions.
Findings and Responses are discussed individually in the following l
Section IV, AUDIT RESULTS.
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TAA's Recommendations, Findings and Observations relating to the QVP, together with the Supply System's responses, are in Appendix B, and a list of persons interviewed is in Appendix C.
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l IV. AUDIT RESULTS TAA performed two related tasks for the Supply System.
The first task was to evaluate and comment on the adequacy of the Plant Verification Program (PVP) in its entirety.
The second task was to evaluate and report on the Supply System's implementation of the QVP program and on the effectiveness of management's actions in handling quality problems since work restart in July 1981.
The audit results of these two tasks are reported in this section.
An additional task, related to the Requirements and Design Reverification portion of the PVP, is covered in Volume II of this report.
IV-A EVALUATICN OF THE PVP PLAN Preparation of the '.?VP in 1982 can be traced back to an order of the Supply System's Managing Director in a memorandum dated January 22, 19f.'1, a few months after assuming his new responsibilities.
He directed that acceptance review plans be developed.which would give him "a well-documented basis for my acceptance of plant completion, safety and technical adequacy."
TECHNICAL AUDIT ASSOCIATES. INC.
- TAA assessed the adequacy of the PVP plan by examining whether it measured up to each of a list of attributes which, taken together, evaluated its ability to achieve the above-quoted objective.
TAA's evaluation results are discussed under each of the selected attributes.
IV A-1 Management Attitudes and Understandings TAA discussed an early (April 9, 1982) draft PVP plan with various levels of managers from the Supply System; the architect-engineer, Burns and Roe, Inc. (from both Richland and New Jersey of fices) ; the Bechtel Power Corporation; and the General Electric Company.
It found that the responsible individuals understood clearly that the new Supply System management was dedicated to an objective and total "new look" at all aspects of WNP-2 quality and operational readiness.
At the time of TAA's interviews, April 26-29, there was still an incomplete understanding of the roles of the various participants as defined in the plan's draft sections which were then in circulation and review.
In retrospect, it is clear that several months of effort were required to put in place all TECHNICAL AUDIT ASSOCIATES. INC.
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i the pieces of such a comprehensive verification plan as the l
WNP-2 PVP.
Despite this lack of detailed knowledge at the time, however, TAA found an unmistakable general understanding I
that the Supply System intended to conduct a thorough l
i reappraisal, would spare no effort to obtain it, and would 1
remedy any defects which might be found.
At all times, management was responsive to suggestions or critisms intended to strengthen the verification process.
Management leadership was strong.
Management attitudes towards quality were healthy, positive and continued to be so.
IV A-2 Adequacy of PVP Objectives TAA's review of the April 9 draft plan resulted in its l'
recommending that the plan's stated purpose be simplified (see l
TAA Audit Report of May 28, 1982, Vol. III of this report).
l The result of that recommendation was the deletion of education and training of Supply System personnel from the objectives, leaving as the primary purpose establishing confidence that i
WNP-2 is designed and constructed to meet committed i
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F 1 4 As stated earlier, TAA acknowledges that PVP performence by Supply System personnel contributes substantial, valuable knowledge to the future operating staff and will improve its understanding of operation.
TAA sees this, however, as a by-product rather than an objective of the PVP.
4 TAA believes that page 1 of the final PVP of October 1982, contains an adequate statement of purpose:
"This report 5
-presents in a single document the bases for confidence that WNP-2 has been designed and constructed to meet applicable regulatory requirements and Safety Analysis Report Committments."
IV A-3 Assurance of Objective Performance
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TAA's Audit Report of May 28, 1982, in commenting on the April 9 PVP, made six recommendations for improving the objectivity of PVP execution.
The principal thrust of TAA's recommendations was to:
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. Provide PVP direction from the Managing Director's Office i
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l e insitute a formal, documented "no conflict" program for reviewing personnel e
Involve some external (not Supply System) personnel in the process.
t The Supply System adopted all of these recommendations, wrote them into the final plan, and made them a part of the implementation process.
The Supply System's responses to TAA's recommendations are in Appendix B, attached, " Supply System Responses to May 28, 1982 Evaluation."
These strengthened Management's requirement for independence in plan implementa-f tion.
Throughout the Audit TAA observed evidence of individual and organizational dedication to objectivity.
i IV A-4 Adequacy of Plan Scope The scope of the PVP plan was assessed by first recognizing that it is a part of a broader plan titled "WNP Plant Completion Plan," whose four main elements are Construction Completion, Plant Verification, Organizational Readiness, and Operational Readiness.
Looking at Plant Verification by itself, TAA noted that its principal parts were:
TECHNICAL AUDIT ASSOCIATES. INC.
Requirements and Design Verification o
e Constuction Verification e
Performance Verification (Test) o Operating Envelope Verification l
Each of these is defined in Section II, pages 2-9, of the PVP of October 1982.
Viewed against the background of the broader Plant Completion Plan, TAA reviewed, questioned, and discussed the details of the individual PVP elements and their constituent parts.
Dased on its review, TAA believes that the PVP contains the major functional elements which are necessary in order to conduct a comprehensive review of final quality and to provide a basis for confidence that WNP-2 is designed and constructed to meet applicable regulatory requirements and Safety Analysis Report commitments.
IV A-5 Adequacy of Resources to Execute Plan l
In its first review made in April 1982, and in its May 28 Audit Report, TAA observed what it believed to be a serious underestimate of the personnel resources which would be needed i
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._ to perform the requirements and design reverification program as described in the PVP plan.
The principal deficiencies which TAA noted were in:
The resources available to assemble system information e
packages to be used in reviews; The retention of architect-engineer personnel e
necessary to assure design continutity; Provision for formal resolution of deficiencies e
discovered in the review; and The proposed selection of a sample of six partial e
systems which we believed would strain available resources and was larger than required to meet program objectives.
These observations were discussed with the Supply System following its review of TAA's report.
Supply System's written responses are in the attached Appendix B,
" Supply System Response to May 28, 1982 Evaluation."
TAA believes that the Supply System's responses to these comments, including its actions to augment personr.al resources, were appropriate and effective.
An additional work task was added to the burns and Roe contract, under direction of the TECHNICAL AUDIT ASSOCIATES, INC.
- Technology organization, which permitted Technology to devote more effort to Design Reverification while assuring AE design continuity.
The revised PVP report presented a detailed description of Reverification reviews and a procedure for processing findings.
The Supply System selected three complete systems for review in lieu of six partial systems-(see IV A-6 below).
When it became evident during the course of the RFW System review that additional personnel were required, several experienced reviewers were obtained through sub-contract (see TAA Finding No. 12 and Supply System response, Appendix B).
IV A-6 Adequacy of Sampling Procedures Since most of the activities which make up the PVP utilize sampling, it is not surprising that this subject was frequently discussed.
It is referred to in several of TAA's pre-audit questions and figures in no less than seven of TAA's formal Findings and Observations.
The PVP plan defines sampling at the top level, and sampling details are found in lower tier documents such as the three individual System Design Reverification Plans or in the Quality Verification Instruction Manual.
TECHNICAL AUDIT ASSOCIATES. INC.
_ TAA's review of the PVP resulted in its recommending and the Supply System agreeing to adopt a sample size of three complete systems rather than six partial systems.
TAA stressed complete systems to insure that contractor interface relation-ships were included and evaluated in the sample.
This deci-
. sion, and the selection criteria and process described on page 20 of the PVP report of October 1982, led to the adoption of a composed of the:
a..
e Residual Heat Removal System (supression pool cooling mode) [RHR]
e High Pressure Core Spray System [HPCS]
e Reactor Feedwater System (from condensate side of reactor feed pumps to reactor vessel nozzles) [RFW]
TAA believes that this sample is adequate in size and in diversity, complexity, interfaces, and safety functions'to afford a reliable basis for assessing design adequacy.
In reaching this conclusion, TAA gave consideration to the details of the verification process which are described in the three system verification plans, but are not found in the PVP itself.
Sampling in the Quality verification Program is described in the PVP, page 6 ("The minimum sample size for reinspections 4
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TECHPJtCAL AUDIT ASSOCIATES. INC.
is ten percent of the hardware installed, inspected, and accepted prior to July 1980."), and in PVP, Appendix E, j
i, pages 10, 12, and 14.
The minimum 10 percent i
sample size and the method of selecting samples from a contractor's work scope gave TAA confidence that initial i
samples would permit locating problem areas.
Hence, TAA found the PVP adequate, in terms of initial sample sizes and selection, for Design Verification as well as QVP.
The PVP provides little guidance with respect to sample enlargement when initial sampling reveals problems.
This matter was discussed with the Supply System and Bechtel on several occasions, and was the subject of TAA Findings Nos.
4, 5, 10 and Observation No.
5.
It was not possible to establish any general rules of procedure for sample enlargement because of the wide diversity of materials and work being sampled.
TAA's early concern about this was allayed as it observed how frequently the Supply System adopted a 100 percent sample when inspection of the 10 percent sample indicated there might be a generic problem.
Based on its evaluation of the above attributes of the PVP plan, TAA reached the following conclusion:
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, l Conclusion Concerning PVP Adequacy l
The -TAA Panel believes that the final PVP Plan dated October 1982 describes a comprehensive and integrated set of activities which are capable of providing confidence that WNP-2 has been designed and constructed to meet applicable regulatory requirements and Safety An-l alysis Report commitments.
We further believe that the PVP, together with related procedures and instructions, contains adequate measures to assure that it is objectively carried out.
It is our opinion that, if properly implemented, the PVP will provide convincing evidence that WNP-2 has been designed and constructed to meet committed require-men ts.
IV-B EVALUATION OF QVP IMPLEMENTATION TAA's evaluation of the Supply System's QVP program made use of a number of attributes or criteria by which to assess the adequacy of implementation.
Audit results are discussed below under each attribute.
TECHNICAL, AUDIT ASSOCIATES. INC.
IV B-1 Scope Adequacy TAA found the QVP program to be complex in structure, and it initially experienced some difficulty in understanding the QVP scope.
The complexity arises partly because the plant itself and the contracting structure are complex, but also because the QVP program is defined as applying only to safety quality work which was constructed, inspected, and accepted before July 1980.
This definition created time-dependent interfaces in the work of each on-site contractor and created an interface within the work scope of WBG (the 215 contractor) between the QVP program and the system completion contractor, Bechtel.
In view of TAA's difficulty in understanding the QVP scope, it felt some concern that there might be blind spots in which critical items of work were neither sampled under the QVP program, nor inspected by Bechtel or other contractors as a s
part of the ongoing construction or system completion programs.
This uncertainty was tested in TAA's Findings Nos. 15 and 16 which raised a question as to who was responsible to inspect the final installation and alignment of major power plant components which had been installed by the 215 contractor.
The TECHNICAL AUDIT ASSOCIATES. INC.
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s Findings were based on an inspection report from a Supply System design reverification engineer who found, duririg a walk-down inspection, two components whose installation was visibly incomplete but which had apparently been signed-off.
The Supply System's investigation confirmed that there had been a breakdown in verifying certain features of installation i
(
within the work scope of the 215 cor. tractor who had departed the site with work incomplete, leaving Beclitel with completion responsibility.
Supply System and Dechtel replies to the TAA Findings make clear that the problem was unique to the 215 work, was not caused by confusion about the QVP program scope, but rather because Bechtel had difficulty in ascertaining from work records what was complete and what was incomplete.
An action program to remedy this problem is recorded in the responses to l
Finding No. 15 in Appendix B, and is detailed in Bechtel j
procedure SWP/P-G-21.
From our review of QVP progr.am descriptive documents, evaluation of a sample of contract completion reports, special task' reports, and reports of areas which were indirectly j
evaluated by QVP, TAA was convinced that the Supply System has put great effort into achieving a comprehensive coverage of all I
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TECHN. CAL AUDIT ASSOCIATES. INC.
safety related construction completed and accepted before July 1980.
TAA identified no significant omissions of such work..
i The importance of Findings Nos. 15 and 16 was to focus attention on and introduce improvements in Bechtel's inspection of partially completed work, and to bring about a Supply System l
reassessment of the adequacy of QVP scope.
This reassessment, described in Appendix B under responses to Finding No. 16, found that all 215 work was treated as incomplete and hence as part of Bechtel's System completion scope.
Thus, the reassessment validated the adequacy of QVP scope.
IV B-2 Sample-Size Distribution and Enlargement i
As noted earlier in this report, TAA considers the " minimum l
of 10%" sample size to be an acceptable starting level because, when considered together with the method of sample selection, l
sbch a sample is capable of identifying generic quality l
problems which may be present.
TAA believes that sample selection and sample enlargement are also important sampling factors, and TAA's audit addressed both of them.
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T
- TAA notes that-QVP sample selection begins with identifying all safety related work completed by each contractor prior to July 1980, dividing this work into typen of installation units, t
1 and then selecting a random 10% sample of each type of unit.
This same result was sometimes accomplished by taking a 10%
random sample of, for example, piping isometrics, and using all of the valves, hangers, and other unit types shown on those isometrics as the sample.
TAA believes that these methods of sample selection assure randomness, result in "significant samples," and give adequate coverage of the work of interest.
TAA noted also that the Supply System has demonstrated by analysis that the time frame of samples matched well with the time frame of the work populations.
TAA recognizes that a few reasonable exceptions to this
~
process were accepted when the stage of construction made i
i reinspections impractical.
OmittingLfrom reinspection, for example, the inaccessible thermal insulation under the reactor vessel or the pre-coated socket welds inside containment were regarded as acceptable.
Such exceptions were few, and do not seriously diminish the weight of credibility established by the-sampling program as a whole.
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i The PVP plan and the Quality Verification Instruction Manual contain only general instructions for sample enlargement.
These documents refer to reinspections as follows (QVI-01, Rev.
1, page 28) :
"The need for further sampling and I
selection, which may go as high as 100%, will be based on the nature and numbers of discrepancies disclosed by the initial and subsequant verification samples."
After several 1
discussions with QVP managers, TAA concluded that the diversity of QVP reinspection programs made it difficult, perhaps impossible, to specify a detailed procedure for all conditions which might require s' ample enlargement.
Under these circumstances, TAA paid particular attention to the actual practices used by Supply System management when the 10% sample reinspection yielded a reject rate which indicated a possible I
j generic problem.
TAA noted that the Supply System and Bechtel, when L
confronted with a possible trend, used deficiency analysis as the initial means of identifying the trend and locating its
(
- source, i.e. similar types of deficiencies, causes traceable to the same individual or condition, etc.
By such means the problem might be bounded and a remedy indicated.
When such f
methods were not sucessful OvP managers frequently resorted to a 100% inspection of the questionable population.
In caragraph TECHNICAL AUDIT ASSOCIATES. INC.
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40 IV B-4 below, TAA discusses an example of trend analysis and sample enlargement involving welding performed by WBG, the 215 contractor.
TAA believes that Supply System's sample selection processes, its use of trend analysis, and its sample
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enlargement practices were effective in locating root causes, have been applied in a consistent manner, and were adequate to meet program objectives.
-IV B-3 Standards of Competence for Field Inspection Teams The Supply System used field inspection teams which included Burns and Roe design engineers in order to make it possible to evaluate and resolve observed deviations in welded
[
structures in the field.
The team procedures are described in Quality Verification Instruction No. 08.
By having qualified design engineers as team members, it was possible frequently to decide on the spot as to the adequacy of apparent deviations.
This treatment of deviations by field teams is described and controlled by Quality Verification Instruction No. 09.
QVI-09 defines visual acceptance criteria for several classes of deviations under the American Welding Society (AWS) Dl.1 TECHNICAL AUDIT ASSoCIAliS, INC.
.. _.,. _. _, _ _.. _ _ _ -~... _ _ _ _ _. _
i Structural Welding Code, and identifies the equipment or structures for which the listed deviations may be accepted in the field by suitably qualified persons.
Documentation of such dispositions are required to be recorded on Quality Control reports.
The purpose of QVI-09 and of the inspection teams is to allow field inspections to be made expeditiously, under effective control, and with a minimam number of variances being referred to the design office.
TAA raised several questions about these practices.
Its concerns are documented in TAA's Report of Audit dated January 10, 1983, Findings Nos. 6 and 8 (See Appendix B).
TAA was concerned that the team members might not be technically qualified to make the dispositions of variances allowed under QVI-09.
TAA also questioned whether QVI-09 itself was an j
acceptable procedure under AWS Dl.l.
These matters were discussed with QVP managers and were answered in the Supply Systems responses to TAA's findings Nos. 6 and 8.
l The replies point out that QVI-09 is not a code revision, but a generic instruction for the disposition of allowed deviations, when made by a qualified design engineer.
The TECHNICAL AUDIT ASSOCIATES. INC.
P L r l
replies also state that the engineering members of the teams j
are. qualified desigr. engineers who disposition deviations only within their own disciplines.
When a question came up during this investigation about the disposition d'ecisions of a l
.particular engineer, all disposit' ions which had been made by I
that engineer were reevaluated for correctness.
'From its review of this sample case and from other related E
[
observations, TAA believes that the QVP program has maintained a' level of personnel qualification appropriate to the tasks to be performed.
I IV B-4 Managers-Response-to Challenge The TAA Panel tested the' soundness of some features of the QVP process by using several examples which seemed on the surface to reflect on its validity.
Two examples are discussed.
During TAA's first implementation audit TAA noted (see l
Finding No. 7,-Appendix B) an apparent anomaly in the results l.
l of reinspection of two groups of WBG radiographic film.
'Specifically, it.noted that there were three to four times more rejections for weld quality in the first sample of 1373 welds i
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than in the second sample of 1317 welds.
TAA also noted that, whereas the first sample was also reviewed for film quality, the second sample was not.
The two samples were from the same population and should have yielded equivalent rejection rates.
The observed differences in rejection rates seemed significant.
TAA pressed for an explanation.
The Supply System's and Bechtel's reply was a twenty-four page document containing a methodical analysis and reevaluation of the reasons for discontinuing film quality review for the second sample, and a series of statistical analyses attempting to uncover specific reasons for the different reject rates.
The fact that the review submitted was unable to prove why the rates were different does not detract from the evident fact that it was a serious, reasoned effort to better understand the results of a reinspection which had already looked at a 100%
sample.
Considering all the above circumstances, TAA views this as an example of acceptable, conscientious program execution.
A cecond example of the Supply System's response to challenge is provided by its August 1983 report " Evaluation of WNP-2 Class I Cast-in-Place Concrete."
This report presents TECHNICAL AUDIT ASSOCIATES. INC.
r the Supply System's evaluation of the work of sixteen contracts over an eleven year period.
The analysis includes the information provided by the dig-out work which the Supply System did in response to the Nuclear Regulatory Commission's Construction Appraisal Inspection (CAT) No. 50-397/83-29, dated July 26, 1983.
The evaluation looked at eight major areas, namely, concrete strength, rebar placement, default of the reactor building contractor, sacrificial shield wall, biological shield wall, slab S-4 at the 441 elevation level, rebar steel coverage, and five 10CFR50.55(e) reportable occurrances.
The TAA Panel considered the evaluation presented in this report to be thorough and competent, justifying the conclusion that the cast-in-place concrete at WNP-2 should be accepted.
TAA observed from these and other examples, that the Supply System seldom resorted to defensive tactics when a question of quality was raised.
Instead, TAA found that Supply System managers responses to challenge were characterized by accepting the possibility that there could be a problem and devoting their energies to searching out the facts.
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IV B-5 Adequacy of Evidence Supoorting Conclusions of Written Reports TAA has reviewed a sample of all nine contract completion reports, either finals or drafts, a sample of three Special Task Reports, and a sample of six of the reports covering areas of construction which the QVP program reviewed indirectly under QVI-05.
In addition, as shown in Appendix A, TAA evaluated numerous other documents which contain evidence on the above attribute.
TAA audit reports in Volume III contain numerous questions related to the adequacy of details provided in Supply System reports to support stated conclusicns, or the adequacy of responses to TAA findings.
The number and variety of questions by which TAA tested the Supply System's conclusions is shown by the following examples (See volume III of this repor t) :
In TAA Audit Report dated January 10, 1983:
Appendix C; Questions 29, 30, 31, 32, 44, 45 o
In TAA Audit Report dated February 15, 1983:
Appendix B; Questions 2, lla, llb, 12, 13.
-e In TAA Audit Report dated May, 16 1983:
Appendix B; Questions 14, 18.
In TAA Audit Report dated August 29, 1983:
Appendix B; Questions 1, 3.
TECHNICAL AUDIT ASSOCIATF.S. INC.
Based on its document reviews and subsequent dicussions with the Supply System concerning questions such as those cited, TAA concluded that adequate supporting evidence is presented in QVP written reportb.
IV B-6 Visible Management Actions Supporting Effective Implementation TAA stated above in Section IV A-1 of this report that it found, in April 1983, a general recognition throughout the Supply System and its contractors that Supply System corporate management intended the QVP program to be an objective and thorough appraisal of plant construction quality before July 1980.
It was of interest to TAA to know whether this attitude and intent was sustained and reenforced by management actions taken during the process.
TAA's principal measure of whether there was sustained dedication to quality came from observing how management reacted when confronted with evidence of potentially severe quality problems.
A few examples will indicate what the TAA Panel observed.
TECHNICAL AUDIT ASSOCIATES. INC.
For example, TAA advised Supply System management during the exit interview at the conclusion of its on-site audi.t of January 26-28, 1983 that it saw evidence of a serious backlog of unreconciled pipe stress / nozzle stress problems; and that, given the stage of construction, this backlog required the attention of the Managing Director.
TAA's report resulted in prompt evaluation by a Supply System task force and a remedial program which, within about two months, reduced the backlog from some eighty open items to six.
Corporate leadership, by this example, gave a clear, consistent signal of intent to have effective program implementation.
In another example, TAA noted that on a number of occasions the Supply System or its contractors adopted a 100% sample for inspection when it appeared that a lesser sample might have sufficed.
By readily accepting the additional costs of inspecting a 100% sample, management consistently reenforced its quality committement when viewed from lower levels of the constructing organizations.
Such evidence was observed by TAA in numerous cases, including each of the following construction contracto:
213A (Pittsburg-Des Moines); 215 (WBG) ; 219 (O. B.
Cannon) ; and 220 (Johnson Controls).
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IV B-7 Effectiveness of Task Close-Out
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j The effectiveness of QVP task close-out is best discussed g
q in the context of Figure 1-1 and.in Figure 4-3 of the Supply
' Sjstem's "QVP Program Overview Report".
These figures, which are reproduced on the following two pages, display the subjects
. ks and interrelationships between seventeen separate' primary QVP a
n I g,. s,j
- reports as well as twenty-two other reports by which QVP
'q 91 "(.
. indirectly evaluated specific construction features.
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TECHNICAL AU0iT ASSOCIATES. INC.
OVERVIEW REPORT (VOL. I) BOOK 1 l
1 PREPURCHASE AND SPECIAL TASKS SYSTEMS INACTIVE CONTRACT (VOL.!!!)
COMPLETION (VOL.II)
BOOK 1 (VOL.IV) ennx 1 BOOK 1 B00K 2 3
4 B00K 2 3
4 5
6 7
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INACTIVE DEFTCIENCY RECEIVING
[0RCRETE 5
CONTRACTS DOCUMENTATION IN!PECTION EVALUATION
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PREPURCHASE' SPECIAL PERSONNEL GROUT N.D.E.
O CONTRACTS PPIA QUALIFICATIONS EVALUATION VERITICATION
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DOCUMENT REPORTS a
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C-213A C.215 C-216 C-217 C-21B C-219 C-220 C-234 Z
9 BOOK 2 BOOKS 3 8
9 10,11 12 13 14 1HRU 7 I
I SYSTEM REPORTS SENTitY FISCHBACH/ LORD JOHNSON CONTROLS, WRIGHT-SCHUCHART-FIRE PROTECTION ELECTRIC COMPANY l'KORPORATE0 HARBOR /B0 ECON /GERI ELECTRICAL 1&C PIPING MECHANICAL PITTSBURGH-DES MOINES THE WALDINGER CORPORATION 0.B. CANNON 8.50N 0.B. CANNON 1 $0N STEEL COMPANY H.V.A.C.-PLUMDING C0ATINGS COATINGS CONTAINMENT QUALITY. VERIFICATION PROGRAM REPORT HIERARCHY Figure 1-1 sl
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- JALITY E
- 2 CONTRAC15' VERI FICAil0!i O
CRfTICAL ACTIYliv R"
PERFORMINr. WORC ACil035 WNP-2 1
Soll work 10;. 206.200A.205.210.6426. 2.1.T Qt1ALITY VERIFICATION MATRIX gg.m-SAFETY-RELATED WOPK a8 t
215 E.fi Figure 4-3 2
Concrete /Rebar/Enbeds 95% 205.206.~206A.~64 26.~210 2.3 (Including Pipe)
T2T.fH 215 3.A.M 216.218.220 3.A DIRECT VERIFICATION PROGRAMS _
3 Cantainment 90% 213 2.V 1 - QVP Active Contracts g
i 2 - QVP Prepurchased & Inactive 4
Structural Steel 90% 206.206A.207.225 2.F Contracts 215
- 1. A.tl. F.it. N 3 - QVP 5pecial Tasks 5
Equipment Installation 851 209 2.7 2.!.6..]I_8.L20 1.J.0
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215 J.M.O.5 07.235 2.J 0
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INDIRECT PROGRAMS EVALUATED BY QVP 6
Piping /Yalves 851 205.206.206A.213.233, 2.J
- A - Sacrificial Shield Wall 6425
- 8 - Pipe Whip Restraints Repair 2.!.3A220 1.J 3
C - Concrete Expansion Anchor Bolts (79-02) 215 1.1.J.tt, P
. D - Weld Radiograph Review 7
Hangers 801 213.233 2.J
. E - Soil Backfill Testing
-213A.216.217.220-1 F - Structural Steel Bolting 1.G.H.I.M.Q G - Lubrite Plate Inspection 245 8
crete Inserts / Anchor 801 206.206A.210.233.6426 2.C H - Sway Brace Bracaet Inspection (PipeSupport) 213A.216.217.218.2,20, C
2 I - Pipe & Hanger As-Built 2.J.5 1.C,M J - Test & Start-Up Component Inspection 9
Cable Tray /Condult/
801 218(Insta11ed,not N/A K - Pre Service Inspection Supports QC~ Accepted) 217 1.R L - Coating Rework M - WBG Documentation Completion
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1.J 218 N - 541' Steel Fabrication Program 10 Cable / Terminations 701 11 HVAC Ducting / Supports 501 M I
O - Equipment Qualification 12 Tubins/ Supports /
601 M 1.J.0 P - Arc strike Inspection Instrumentation Q - Hanger Balancing R - Fire Protection Raceway Support Welds 206.206A.210,6426 2
0 13 Cathodic Protection /
901 5'- 8PC Equipment inspection Grounding 215 M
2i8(Installed,not N/A T - RPV Set Task Force QC Accepted)
U - Building Settlement M
V - 213 Documentation Task Force 14 Insulation 60%,215, 15 Loatings 501 213.219.234 L
3 16 NDE 751 Prepurchase and 2.3 Inactive Contracts Active 5tte Contracts 3.3 215 1.D.K.M 17 Procurement 901 Prepurchase and 2
Inactive Contracts Active Site Contracts, 1
- ltajor contracts performing the critical a'ctivity are wderlined.
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TAA noted that OVP tasks were closed out through the writing and approval of. reports such as those mentioned above.
It observed, from reviewing finals or near final drafts of sixteen of these reports, that the specific tasks were methodically identified, ' evaluated, and performed through appropriate inspections and analyses.
Processes and results were documented, and conclusions and the bases for them were clearly stated.
In TAA's opinion, this is an effective close-out process.
Based on evaluations presented in the preceding paragraphs, TAA reached the following conclusion regarding QVP Implementa-tion:
Conclusion Concerning QVP Implementation The TAA Panel believes that the Quality Verification Program as set forth in the Plant Verification Program of October 1982, and the Quality Verification Inst.~uction Manual of June 1981, has been ef-fectively implemented as reported in the Supply System's " Quality Ver-ification Program Report, Volume I" dated Septebmer 21, 1983.
TECHNICAL AUDIT ASSOCIATES, INC.
m-
. IV-C~ EVALUATION OF MANAGEMENT'S QA EFFECTIVENESS The Quality Verification' Program discussed in the preceding section assessed the quality of safety related work performed before July 1980.
TAA also evaluated the companion program intended to restore confidence in the quality of WNP-2 construction performed after restart of work in July 1981.
This program had several objectives, namely, to:
Improve Supply System Management Control of o
Construction Quality o
Obtain Experienced Construction Management Improve the Quality of Work Procedures e
Reduce and Control the Backlog of Deficiency e
Documentation Each of these principal objectives is discussed.
IV C-1 Improvement in Management's Control of Construction Quality The failure which caused work suspension at WNP-2 was a loss of confidence in management control.
This became evident TECHNICAL AUDIT ASSOCIATES. INC,
t i throughjaccumulation of unresolved hardware quality problems; an unreasonable delay in clearing work control documente, leading to a--large, growing backlog; and the absence of a 4
t management structure capable of dealing with these problems.
The nature of the. problems called.for fundamental changes in management. attitudes, structure, and procedures.
I
)
Supply System actions took place on two levels.
First, was a clear, forceful expression of management's intention to establish and maintain high quality standards.
This began with a frank acknowledgement of the problem.
The PVP Report states that Supply-System management had become " acutely aware of the lack.of' Management attention-to previously identified quality problems."
n J
TAA observed that corporate management openly recognized the-severity of.this problem and made it quite clear that E
remedies must.be thorough and comprehensive.
If the TAA Panel were to single out the one most influential factor in WNP-2's recovery campaign, it would be management's visible and unreserved dedication to achieving acceptable quality.
4 On the management structure level, the Supply System carried through several fundamental changes which, in TAA's i
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view, have substantially improved Supply System's ability to give effect to this fresh dedication to quality.
The Supply System created a decentralized Project under a new Project
-Director.
This Project, located at the plant site, was assigned adequate resources and full responsibility to do the job, making quality a priority objective.
Under vigorous Project direction, other actions necessary to obtain and maintain construction _ quality were taken, as described in following paragraphs.
IV C-2 Obtaining Experienced Construction Management In June 1981, the Supply System' employed Bechtel Power Corporation to take responsibility, under Supply System direction, for Construction Management, Construction Quality Control, and System Completion.
In addition, Bechtel furnished an Engineering. Management Group to assist Supply System Project Engineering and a Bechtel Reverification Group to assist the Project in performing the Quality Verification Program.
By i
this step the Supply System availed itself of the kind of nuclear experience which, up to this time, had been in very i
short supply at WNP-2.
Bechtel brought to the job substantial numbers of managers, design and project engineers, and quality l
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TECHNICAL AUDIT ASSOCIATES, INC.
assurance engineers, supervisors, inspectors, and auditors.
In addition, the Supply System was able thereafter to call upon the technical expertise and relevant data on generic problems which were available in Bechtel headquarters.
An important factor in the Supply System's successful employment of Bechtel experience was its willingness to utilize that experience to assist in several inter-related functions, thus allowing Bechtel a wide scope of activities while maintaining Project control.
This led, for example, to use of Bechtel schedule and cost reporting systems, milestone scheduling techniques, manpower control and reporting variance analysis, etc.
Bechtel's previous experience was used, as an example, in the preparation and use of a list of 320 potential WNP-2 problems which had been encountered on other projects or identified by industry or NRC sources.
Each was assessed to determine if it had been recognized on WNP-2.
In addition, Bechtel conducted a number of reviews for technical adequacy of existing designs, based on its experience and judgement of potential trouble spots.
Such areas as fire protection, large bore pipe stress analysis, cable separation, and soil compaction are typical examples.
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- Bechtel's assumption of construction responsibility also allowed Burns and Roe to concentrate its attention thereafter exclusively on engineering matters.
This has had important benefits for the Project, as noted below under sub-section IV C-4.
TAA's observations confirmed that the Supply System's selection and methods of utilizing Bechtel added significantly to its ability to assure adequate construction quality following restart.
IV C-3 Improving Quality of Work Procedures As part of the Restart Program conducted largely during the period of work stoppage, the Supply System carried out a comprehensive review of documentation under which construction is performed, including construction contract specifications, deficiency documents, construction and quality assurance procedures, training and qualification procedures, and f
procedures covering various phases of work planning and control.
The principal purpose of the reviews of specifications and procedures was to assure compliance with codes, standards, and the FSAR, and to provide internal consistency and quality control adequacy.
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t This work was largely completed before TAA began its surveillance of the program.
Hence its comments are limited to two observations.
First, the reviews referred te appear to address the areas of importance in restoring credible control of quality.
Second, the previous recurrent backlog of deficiency documentation which had impeded construction was brought and kept under control.
TAA concluded this resulted from improved work procedures and management controls instituted during Restart.
See following sub-section IV C-4.
IV C-4 Reduction and Control of Deficiency Documentaton Backlog At the time of work suspension there were more than 3000 individual deficiency problems which required resolution in order to permit construction to proceed in a controlled manner.
The list was not diminshing.
The problems were documented variously as corrective action requests, non-conformance reports, NRC inspection items, audit or inspection report action items, 10CFR50.55(e) reports, requests for information, startup problem reports, and others.
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, By a concerted effort involving methodical review and re-solution, this numb >r was reduced to approximately one thousand between' August 1981 and January 1982.
TAA's' review of WNP-2 s
Program Director's Monthly Progress Reports from July 1982 on-ward showed that management continued to maintain close sur-veillance of the backlog of work control documents, and that the number continued to diminish.
Backlogs, trends, and age analyses were regularly presented for management review and action.
NRC inspection items were reported individually, with completion schedules for each.
These reports, and TAA's dis-cussions of their use with the Project Director and QA Manager, led TAA to conclude that the measures initiated during the Re-start Program to reduce and thereafter maintain control of these important quality documents have been successful.
It showed evidence of the ability of Project Engineering and Burns and-Roe to provide increased engineering guidance in the field and to appreciably reduce its response time'for problem solutions.
1 TAA noted that the Restart Program was effective in j.
reducing the large backlog of deficiency documents and in providing improved procedures and specifications for work control after Restart.
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Based on the foregoing TAA concluded that the restructuring and restaffing of Supply System and WNP-2 Management, including the employment of an experienced construction manager, instilled a quality attitude and capability which assured the acceptability of construction work performed after July 1981.
Accordingly, TAA reached the following conclusion regarding
' Management's QA effectiveness since restart of construction:
Conclusion Concerning Management's QA Effectiveness Since Restart The present quality assurance program which grew out of exten-sive management, con tractor, and procedure changes during the period of work suspension is built upon a forceful, uncompromising quality attitude.
It is bolstered by improved work control practices develop-ed in the Restart Program and by the services of a new, experienced Construction Manager.
TAA believes that the resulting Quality As-surance Program is effective and adequate.
4 117-3437 TECHNICAL AUDIT ASSOCIATES. INC.
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TABLE OF APPENDICIES
-A.
. Categories and Numbers of. Documents Selected and Reviewed by TAA.
B.
TAA QVP and QA Related Recommendations, Findings and Observations From On-Site Audits and Supply System Responses.
C.
List of Persons Interviewed by TAA.
D.
TAA/ Supply System /NRC - Visits / Meetings.
E.
Technical Audit Associates, Inc., Plant Verification Program Plan Evaluation Team for WPPSS/WNP-2:
Biographical Information.
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CATEGORIES & NUMBERS OF DOCUMENTS SELECTED & REVIEWED BY TAA i
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APPENDIX A CATEGORIES & NUMBERS OF DOCUMENTS SELECTED & PEVIEWED BY TAA Category Documents Background Material 59 l
Plant Verification Program Plan 19 Supply System Design Reverification Plans.
20 WPPSS - PVP Organization and Personnel.
7 Supply System Document Transmittal Letters to TAA 59 WNP-2 Program Director's Monthly Progress Reports 13 Supply System Bi-Monthly Reports to NRC 15 Phase II Audit Implementation Procedures 5
Supply System Audit Procedures 8
Supply System Contractor and Supplies Procedures 7
Supply System Audits and Related Documents.
45 Burns and Roe Audit Reports 29 Bechtel Power Corporation Audit Reports 51 Supplier Audit Reports 39 36 Reportable Conditions 18 NRC Inspection Reports Inspection and Enforcement Letters and Bulletins 4
NRC 6xit Meeting Minutes 5
Supply System Verification Reports to NRC 7
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NRC CAT Team Report and Responses 5
Corrective Action Requests.
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Findings Review Committee (PFR's Requests and Responses, Meetings, Findings and Evaluations)
General 63 High Pressure Core Spray (HPCS) 274 Reactor Feed' Water (RFW) 69 Residual Heat Removal (RHR)
.114 Equipment Qualification (EQ).
36 Fire Protection (FP) 11 Wall Load (WL) 17 Nozzle Load (NL).
7 Pipe Break (PB) 32 Total 623 QVP Contract Completion Reports 9
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QVP Special Task Reports Reports of Verification Program Evaluated Indirectly by QVP 6
QVP Overview Reports.
5 Supply System Design Reverification Reports 21
_ 14 Supply System Responses to TAA Audits f
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Total 1158 117-3462 TECHNICAL AUDIT ASSOCIATES. INC.
APPENDIX B TAA QVP &.QA RELATED RECOMMENDATIONS, FINDINGS & OBSERVATIONS FROM ON-SITE AUDITS and SUPPLY SYSTEM RESPONSES 1
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APPENDIX B SUPPLY SYSTEM RESPONSE TO THE MAY 28, 1982 EVALUATION OF THE WNP-2 PLANT VERIFICATION PROGRAM BY TECHNICAL AUDIT ASSOCIATES, INC.
TAA Recommendation on Purpose (page 3)*
We recommend that the Plan's purpose be more exactly stated, as, for example:
"To establish confidence that WNP-2 has been designed and built to com-mitted requirements."
Supply System Response The revised Plant Verification Report (Rev. 0) now provides a clear statement of purpos'e on page 1 of Section I.
TAA Recommendations to Substantiate Objectivity (page 5) 1.
Direct the PVP plan preparation and execution from the Managing Director level rather than from the WNP-2 Program Director level.
2.
Consistent with recommendation 1,
assign responsibility for plan execution to executives at the Director level, thus involving the Director of Technology, Director of Generation, Director of Quality Assurance, etc.
3.
Require regular progress reports on implementation to the Managing Director.
4.
Assign review responsibilities only to personnel who did not perform or direct the original design or. construction work being reviewed; by including in the PVP a detailed person-by-person tabulation of reviewers' names, show that this rule has been observed.
5.
Incorporate some external (not Supply System) personnel into the Supply System review teams by using loanees (as from other utili-ties) and through subcontract (as from another AE).
6.
Incorporate in the PVP plan a specific provision for audit of its implementation by a competent independent organization which would report periodically to the Managing Director.
Supply System Response Section III of the revised Plant Verification Report (Rev. 0) now con-tains a description of the steps that have been taken to assure objectivity in the Requirements and Design Reverification reviews.
The key revisions which address the TAA recommendations are:
- Page numoer in TAA report of May 28,1982.
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1 (TAA Recommendation,1 - see Section III page 12 and Section IV pages o
22 and 26 of Rev. 0.)
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The Technical' Specialist, Office of the Managing Director has been assigned responsibility for:
Management overview of the program Approval _' of the scope of the Requirements an.d Design reverifi-cation reviews and changes in the scope of these reviews Approval of the findings review process Approval of personnel selection to assure independence i
Special findings reviews to resolve differences between the reviewer and the Findings Review Committee.
o (TAA Rec ~ommendation 2 - see Section III page' 11 and Figure 3 of j
Rev. 0.)
The responsibility' for performing the Requirements and Des _ign Reverification reviews has been assigned to the Systems Design Engi-neering group which reports to the Director of Technology, not the WNP-2 program. The responsibility for execution of the Testing pro-gram and the development / review of the operating procedures and Technical Specifications had already been assigned to the Director of Power Generation.
o (TAA Recommendation 3 - see Section IV page 28 and Figure 7 plusSection III Attachment 2 of Rev. 0.)'
The schedule for the Requirements and Design Reverification reviews 4
(Figure 7) provides for two interim reports, a final report for each system, a report of the Findings Review Coninittee and a final report from the Technology Directorate integrating the results of the reverification reviews.
The results of the Quality Verification Program are presently reported on a bimonthly basis in addition to the various contractor, system and task reports which document the completion of individual QVP activities.
In addition to the above, r'
the Management Review Group (Attachment 2,Section III) will provide periodic reports to the Managing Director on the results of the various audits and reviews related to the WNP-2 Plant Completion Plan which includes the Plant Verification program.
o (TAA Recommendation 4 see Section II page 3 and Section III i
page 11 of Rev. 0.)
1 The revised report now describes the basic approach of utilizing personnel who were not involved in the original design plus an organizational reporting relationship that is independent of the l
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WNP-2 program.
Rather than including the names of the individuals in the report, we have chosen to issue criteria for the. assessment of independence to the Manager of the Systems Design Engineering group and the Chairman of the Findings Review Committee and require them to provide written confirmation that the individuals assigned satisfy the criteria.
These eval 0olions will be reviewed by the Technical Specialist, Office of the Managing Director.
A copy of the criteria is included as Attachment I.
As indicated in Attach-ment I., copies of the individual evaluations will be maintained in the program record.
(TAA Recommendation 5 - see Section III page 11 and Sectlon IV page o
25 of Rev. 0.)
The program permits, but does not mandate, the use of.outside per-sonnel. As indicated in Section IV page 15, it is planned to utilize Bechtel personnel currently involved in reviews of f.5ME piping and supports in a similar capacity as part of the reverification reviews of the three selected systems.
We believe that the program struc-ture, which includes organizational independence plus a separate findings review process and outside independent technical audit has sufficient independence.
It also has the advantage of maximizing the participation of Supply System engineers who will have responsi-bility for future configuration control.
(TAA Recomendation 6 - see Section II page 3,Section III page 12 o
and Attachment 2,Section IV page 25 of Rev. 0.)
The program includes provisions for audit of the implementation of the Requirements and Design Reverification reviews including the findings review process by a highly qualified outside firm.
We have not yet finalized the scope of the outside auditor in the areas of Construction Verification, Performance Verification and Operating Envelope Verification.
TAA Recommendation on Test Programs (pages 5/6) 7.
.The team understands that Burns and Roe's involvement in startup testing is limited to the preparation of test acceptance criteria.
Inasmuch as the test program is intended, insofar as possible, to validate both design and construction, we recommend that Burns and Roe be required to review and comment on test procedures and to con-firm that test results satisfy the acceptance criteria.
l Supply System Response The Supply System Power Generation organization, which includes the WNP-2 plant staff and the WNP-2 Test and Startup organization, is responsible for the WNP-2 Test and Startup program.
This includes preparation, review and approval of test procedures, execution of the testing program, evaluation of i
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s the test results, preparation of test reports and documenting the satisfactory completion of the testing program.
In carrying out this responsibility, the Supply System utilizes the services of the AE and NSSS vendor to assist in the preparation and review of procedures, execution of the tests 'and evaluation of the results.
The following excerpts from Chapter,14 of the FSAR describe the AE and NSSS support 0,f the WNP-2 Test and Startup program.
14.2.2.8 Architect-Engineer Support of the Test and Startup Program Burr.- and Roe, Inc. is responsible to provide infccmation required to assure timely completion of construction testing and, equipment turnover for provisional acceptance.
Burns and Roe afso provides system oriented engineers to assist the WPPSS Test and Startup Department, as required by WPPSS, in the provision of system bound-ary definitions, a preoperational test index prepared by WPPS$ and technical direction and/or advice and consultation during system and component testing through preoperational testing.
14.2.2.9 General Electric Company Support of the Test and Startup Program The General Electric Company (GE) is the supplier of the BWR nuclear steam supply system (NSSS) for WNP-2.
GE is responsible for generic and specific WNP-2 designs and for the supply of the NSSS.
During the construction phase of the plant cycle the GE Resident Site Man-ager is responsible for all NSSS equipment disposition.
When the testing phase of the project begins, the responsibility of GE-NSSS activities are assigned to Preoperational and Startup, Group. The GE Preoperational and Startup staff responsibilities are outlined below.
14.2.2.9.1 Staff Responsibilities 14.2.2.9.1.1 GE Operations Manager The GE Operations Manager is the senior NSSS vendor representative onsite at or near official fuel loading, and is the official site spokesman for GE for preoparational and startup testing.
He coordi-nates with the Startup Superintendent for the performance of his duties which are as follows:
reviewing all NSSS test procedures, including changes to test a.
procedures, and test results as a conditional member of TWG.
providing technical direction to the station staff; b.
managing the activities of the GE site personnel in providing c.
technical direction to WNP-2 personnel in the testing and operation of GE supplied systems;
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providing liaison between the site 'and' the GE San Jose home office to provide rapid and effective so'lution to problems i
which cannot be solved onsite; and e.
participating as a conditional member of the Test Work Group when required.
14.2.2.9.1.2 GE Operations Superintenden.t The GE ' Operations Superintendent is responsible to the GE Operations Manager for supervising th.e activities of GE Shif t Superintendents.
He works directly with the WNP-2 Operations Supervisor,in" providing GE technical direction to the operating organization.
14.2.2.9.1.3 GE Shift Superintendents The GE Shift Superintendents provide technical direction to WNP-2 shift personnel in the testing and operation of GE supplied sys-tems.
They provide 24-hour per day shift coverage as required beginning with fuel loading.
They report to the GE Operations Superintendent.
14.2.2.9.1.4 GE Lead Engineer - Startup Test, Design, a'd Analysis The GE Lead Engineer - Startup Test, Design, and Analysis is respon-sible to the GE Operations Manager for supervising the GE shift engineers and for verifying core physics parameters and characteris-tics and documenting that performance of the NSSS and components conform-to test acceptance criteria.
He works with the WNP-2 Tech-nical Supervisor to coordinate and effect implementation of the Startup Test Program instrumentation including special test equip-ment required to confirm these acceptance criteria.
The test program is controlled through the Test and Startup Program manual and the WNP-2 Plant Proce'dures.
The participation of General Electric in the program is as described in the FSAR.
The participation of Burns and Roe, Inc. in the program as it is being implemented is more extensive than described in the FSAR.
In the preoperational test p'rogram, Burns and Roe receives all test procedures for review, participates in the Test Working Group (TWG) as a conditional member and will receive all test reports.
The purpose of this additional Burns and Roe participation is to confirm that the acceptance criteria related to their scope of design responsibility are cor-i rect and, through participation in the TWG review of test results, confirm that the results satisfy the acceptance criteria.
In addition, several Burns and Roe test engineers have been assigned to the Test and Sta' tup organization to assist in the conduct of the preoperational test program.
A representative of the Supply System Project Engineering also participates as a member of the TWG. He has the responsibility of assuring an bdequate engineering review of documents submitted to the TWG and maintaining a functional interface between TWG and the AE.
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During the Power Ascension testing program, the plant is administratively and technically controlled by the Plant Manager with all procedu,res, tests and test results received by the Plant Operations Committee.
Most of the testing during the Power Ascension program relates to the NSSS scope of design.
The participation of General Electric in this portion of the program is,as de-scribed in the FSAR.
Burns and Roe participa~ tion,' as identified at this time, includes, technical as'sistance plus review of test procedures and test results within their scope of design responsibility to confirm that the acceptance criteria are correct and that the results satisfy the acceptance criteria.
TAA Recommendation on QA Overview of Bechtel (page 6) 8.
The Supply System places considerable reliance on Bechtel's exper-tise and performance record in construction management and QA/QC and is therefore providing normal QA/QC surveillance of Bechtel's activ-ities.
In view of the early history of WNP-2 construction and the late date of Bechtel's assumption of its present responsibility, the team recommends that the Supply System conduct intensive surveil-lance of Bechtel's QA/QC activities and construction maintenance performance until the Supply System is satisfied that these factors have been adequately compensated.
This surveillance pattern should be explained in the PVP plan.
Supply System Response The Supply System has recently taken the following steps to enhance the effectiveness of the WNP-2 Project QA surveillance program as described in Appendix C, pages C-5 and C-9 of the revised report, o
Assigned Corporate QA the total responsibility for site audits.
This change will permit the WNP-2 Project QA organization to focus on in-process surveillances.
o WNP-2 Project QA has, replaced four of the individuals in the group responsible.for in-process surveillances with more experienced Senior QA engineers from WNP-1.
o The program for surveillance of in-process construction has been revised to:
Provide for the performance of in-depth, limited-scope and unscheduled surveillances.
In-depth surveillances will be per-formed to provide a comprehensive analysis of the capability of a specific function - to yield quality work.
The p.lan requires the performance of about five in-depth surveillances per month.
Limited-scope surveillances will be used to provide routine overview of ongoing work and unscheduled surveillances will be performed to cover specific problem areas as they arise.
increase the number of surveillances from the average of about
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9 per month since June 1981 to 12 or more per month.
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focus the surveillances on areas of complex or critical work and in areas where adverse trends are indicated based on the analysis of trend reports and current problem areas.
o Added special surveillance programs. in,two areas.
These surveil-lances are scheduled separately fro'm the routine surveillances, and i
are used to ' assess critical or complex work.
RPV Hydro preparation and performance.
This includes the con-tractor and Bechtel work in preparation for RPV Hydro, the identification and review of documentation for components within the Hydro boundary and the performance of the Hydrb.
Documentation review and turnover process.
This includes, the review of the documentation by the contractors prior to their turnover of documents to Bechtel plus the Bechtel review and' processing in their vault in support of the system turnover and contract closeout activities.
l TAA Recommendation on Augmented System Turnover Inspections (pages 6 and 7) 9.
The team was told that the Project Test and Startup Section is con-ducting an extensive open-and-inspect program for major plant compo-nents because it has found evidence that some early construction maintenance programs were defective.
We recommend that the Supply System emphasize their recognition of this problem, explain their criteria for selecting components to inspect, and give it greater prominence in the PVP.
In this connection it would add to other evidences of primary system construction integrity if it could be confirmed (as we were told) and stated in the PVP that none of the stainless steel primary system has been filled with water since installation.
Supply System Response 1
In the revised report the description of the component inspections by the
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Test and Startup organization has been given greater prominence (see Section IV pages 14 and 29).
This section also contains a discussion of the process by which components are selected for inspection by Test and Startup plus a con-firmation that the stainless steel portions of the reactor pressure boundary have not come in contact with water as a result of construction and testing activities.
This confirmation is based on follow-up discussions with knowl-edgeable project personnel plus the system configuration.
The pumps in which corrosion was observed were at the low point in carbon steel systems which are
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remote from the stainless steel portion of the reactor pressure boundary.
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TAA Recommendations to Impreve the Presentation (pages 12,13 and 14) 1.
Provide a summary as the first section of the report.
This summary should define the PVP in the context of the Plant Completion Plan, identify the PVP component parts, explain the plan's logic, and lay the groundwork for the presentation sequence to follow.
2.
In the next section describe how a baseline of acceptability is achieved.
Present and discuss briefly the adeq'uacy of the design process, referring to appendices for details.
Present the problem of unsatisfactory construction quality in the late 1970's and briefly describe the remedial programs.
Details of Restart and QVP should be put in appendices.
This section should show that WNP-2 is establishing a' baseline of adequate design and construction quality, and a management system to assure its continuation.
3.
In the following section, highlight the. extraordinary actions which the Supply System Manageme,nt is taking to give additional assurance of quality, ov'er and above that which would result from. normal. good design and construction practices as established in the preceding section.
4.
Conclude with a section for reporting findings and co'rrection of -
deficiencies.
Demonstrate that a complete PVP program will give a basis for concluding that the plant was designed and built to meet original commitments.
5.
Put in appendices:
the detailed justification to show that Burns and Roe and GE design processes have been satisfactory (Section IV);
that pre June 1980 construction quality has been upgraded (Restart and QVP); that post June, 1980 and present construction management and QA/QC practices are satisfactory; that present Supply System Project Management and QA/QC are satisfactory (Section IV); and that Performance Testing will be effectively conducted (VF).
Supply System Response The draft report has been colapletely restructured.
In our view the l
revised report is responsive to the TAA recommendations in this area.
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Supplementary Evidence of Supply System's Response to TAA Recommendation No. 4 (see pages -B.2-and -B.3-of this ap-pendix).
ATTACHMENT I M. d4, (.9 f INTER 0FFiCE M E M 0.R A N D U M O roc wsr.li4 WAS1IINGTON PUBUC POWER SUPPLY SYSTEM O E o c w nr.2 O toc wur-3/s O Admin rii.
JR Honekamp:ar 38' Date: June 30,1982 RB Glasscock, 220 Larry Harrold, 570 PX Shen, 580
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Geoffrey Gelhaus, 420 D' Timmins, 901A.
John R. Honekamp, 387
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subject: CRITERIA FOR ASSESSING THE INDEPENDENCE OF THE TECHNICAL PERSONNEL ASSIGNED TO THE WNP-2 REVERIFICATION REVIEWS Refuence: ygp-2 Plant Verification Report, June 1982, Rev. 0 An essential element in the conduct of the Requirements and Design Reverification reviews described in the referenced document is the assurance of objectivity in thh conduct of the reviews and the processing of the findings from these reviews.
Since we have chosen to perform these reviews primarily with Supply System personnel, the burden of proof to establish objectivity in fact and appearance rei..;
with the Supply System.
To provide evidence of the independence of the personnel assigned to these reviews, you are requested to orovide a written confirmation that each individual assigned meets the attached criteria.
This confirmation should take the form of a letter signed by the individual and his supervisar which addresses each of the three areas in the attached criteria and should include, by attachment, a current resume or other supporting information as appropriate.
A copy for my review and a copy for the program record i
are sufficient.
Attachment:
Criteria l
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CRITERIA FOR ASSESSING THE INDEPENDENCE OF THE TECHNICAL PERSONNEL ASSIGNED TO THE WNP-2 DESIGN REVERIFICATION REVIEWS l
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The technical personnel assigned to direct, perfonn the design reviews, or process the findings from the reviews (Lead Engineer, Review Team Leaders, Review Team members, and Findings Review Committee members) shall meet the following criteria:
1.
Present Employment Employee of the Supply System or an organization that has not had res-ponsibility for the design of WNP-2 facilities, systems, or components.
Technical personnel assigned to directing and performing the design' reviews (Lead Engineer, Review Team Leader, Review Team members) shall, for the purpose of the design review function, report to Technology.
2.
Previous Employment If previous employment included job assignments with a firm that did have design responsibility for WNP-2 facilities, components, or systems, the individual's prior employment shall satisfy the following criteria:
a.
Not employed by the firm in question during the time period when that firm performed design work for WNP-2; or b.
The scope of the design to be reviewed by the individual does not include any design work performed by the firm in question; or If the individual will be reviewing any design work performed by the c.
firm in question during the period when he was employed by that firm, a written evaluation shall be prepared by the individual and his supervisor for the Design Reverificat. ion Review which confirms for the work being reviewed that the individual did not perform the original design work; was not the immediate supervisor of the person who did perfor:n the original design work; did not establish the detailed design inputs for the original design work; and was not the "in-process" checker or reviewer of the original d.esign work (participation in "other" reviews which are not part of the required "in-process" check / review oy the responsible design organization will not disqualify the individual for the reverification : eviews).
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Pag 2 3.- - Prior Involvement by Supply System Employees in.the Development of the_
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'WNP-2 Design
-The Supply System involvement in the development of the WNP-2 design has been primarily in the areas of program management, specification of owner requirements, participation in owner groups, technical reviews of design documents, QA reviews and audits, and preparation of licensing documents.
In almost all cases, the responsibility for performing the original design work jncluding development of the detailed design inputs and design veri-fication has been delegated to the A-E, NSSS vendor, component vendors,
", and site contractors.
However, in a few cases and/or for limited time
. periods, some Supply System personnel were directly involved in elements of the design of WNP-2.
Therefore, all Supply System personnel assigned to the reverification reviews as Lead Engineer, Review Team Leader, Review
. Team. member, or Findings Review Cqmittee member shall review their prior
' involvement in the development of the WNP-2 design and provide a written
~ confinnation that their prior involvement does not conflict with the four criteria listed under 2.c... above.
In this context, prior involvement in specifying owner requirements in broad areas such as ALARA, ISI, Fain-
.tenance, Quality Level and F;re Protection classification schemes, etc.,
is not considered to be " establishing the detailed design inputs."
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TAA Finding No. 6 We recomend that QVI-09 be revised to make clear that its purpose is to permit, with the A-E's case-by-case approval, certain specific deviations from the AWS Dl.l' code when found upon reinspection in selected applications.
If this were done, we would see no objection to its use as a basis for dis-posing of the specified deviatior.s.
We recommend - also that the Supply System clarify whether QVI-09 is intended to apply to the sacrificial shield wall and pipe whip restraints.
Supply System Response Quality Verification Instruction No. 09. (OVI-09) has been revised to make clear that it is a generic disposition for ' limited deviatior.s from AWS Dl.1 in specific applications provides the Burns & Roe input to the revised section of QVI-09.
The inspect' ion criteria contained in QVI-09 (Enclosure 3) and FSAR Amendment 27 (Enclosure 4)..are both currect as Written.
Category B of the inspection criteria does include the sacrificial shield wall (SSW) and pipe whip restraints (PWRs).
H owever., the reinspection of both of these areas was completed prior to the use of QVI-09.
Hence, the statement in FSAR Amendment 27 that the SSW and the PWRs were reinspected to AWS Dl.1 is correct.
(See also Enclosures # 2, 3, and 4; Supply System Response to Finding
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No. 6; Report of Audit No. 3; May 16,1983; TAA Volume III.)
TAA Finding No. 7 The apparent coincidence of discontinuing film quality review of WBG radiographic film, coupled with the subsequent decline in the percentage of welds actually rejected for weld quality should be investigated by the Supply System and the results documented.
Supply System Response The Supply System has directed Bechtel to review all the data from both phases of the WBG radiograph reevaluation for trends or patterns that explain the apparent anomaly in the results.
This includes an examination of the film density data taken during the first phase of the program.
A draf t report of the Bechtel review has just been issued.
Upon evaluation of the Bechtel report, the Supply System will determine if further investigation is warranted.
TAA Finding No. 8 If it is true that the Burns & Roe team engineer has authority to accept or reject structural welds which do not meet the acceptable deviation I{
criteria of QVI-09, we believe that this authority should be withdrawn and that such decisions should be referred to the responsible B&R structural design supervisor.
TECHNICAL AUDIT ASSOCIATES. INC.
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Supply System Response The activity referred to in Finding No. 8 is the Team Inspection con-ducted under Quality Verification Instruction No. 08 (QVI-08).
This activity utilizes Burns & Roe (BRI) design engineers as members of field inspection teams reexamining work completed prior to the July, 1980 stop work.
The BRI engineers disposition minor deviations within their discipline authority on the Quality Control Inspection Report (QCIR) if they are acccptable as is.
Deviations which are 'n'ot acceptable as is' or' which require more extensive evaluation are dispositioned via the normal Nonconformance Repcrt process.
It is our position that the Team Inspection process conducted under QVI-08 meets the requirements of 10CFR50 Appendix B for identif,ication and control of nonconforming conditions.
As indicated during your November, 1982 audit, the Quality Verification Program (QVP) management identified several problems in reviewing the records of dispositions prepared by one of the BRI engineers formerly assigned to the Team Inspections.
Based on this review, QVP management has requested that BRI evaluate all the dispositions prepared by this engineer.
The results of this evaluation are expected to be available in March.
. The basic reinspections conducted under QVI-08, except for the reevalu-ations mentioned above, have been completed.
However, the procedure. is being revised to' strengthen the Team Inspection process in the event that additional reinspections are required as part of the Quality Verification Program.
l TECHNICAL AUDIT ASSOCIATES, INC,
. _ _ _ ~
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PARTIAL RESPONSE TO TAA AUDIT REPORT DATED MAY 16, 1983 TAA Fiding #15 The QVP does not inspect certain important construction features such as the supporting and securing of power plant components.
This " hole" in QVP's scope should be filled.
Supply System Response It is correct that the QVP has not reinspected major mechanical equipment supports, however, it' is not correct that this fact represents a " hole" in the QVP scope.
The purpose of the QVP is to verify the adequacy of safety-related work completed, inspected and accepted prior to the stop work in July, 1980.
Independent of the QVP, substantial reinspections have been performed as part of the Test and Startup program and to resolve specific problems identified during and after the Restart Program.
Therefore, the general approach employed by the QVP is to identify the work complet-ed, inspected and accepted prior to the stop work; evaluate any special reinspections performed independent of the QVP, then perform those additional reinspections needed to meet the QVP requirements.
At the time of the TAA audit, this process had not been completed for major mechanical equipment installed by the 215 contractor, hence the general approach was discussed with TAA, but no conclusions were presented relative to the need for reinspection by the QVP.
This evaluation has now reached the point where it is clear that final alignment and inspection of Contract 215 mechanical equipment was not completed prior to the stop work and, therefore, falls outside the QVP scope.
As indicated on pages 7 and 13 of the TAA audit report, this finding was triggered by the fact that shims were observed to be missing from the RHR-B heat exchanger during a Supply System field inspection conducted as part of the Design Reverification Program. This inspection was conducted on April 27, 1983, the day prior to the Finding Review Committee (FRC) meeting attended by TAA during which Potential Finding Reports (PFR) RHR-24 and 33 related to this inspection were discussed.
The FRC classified these two PFR's as findings and requested a meeting with the Project to determine the status of the installation and the cause of the apparent discrepancies. Although the Project review is not yet complete, it has been established that final alignment and inspection of the RHR heat exchangers were not completed at the time of the stop work and that the missing shims were the result of a construction coordination problem that occurred later when Bechtel assumed responsibility for work that was partially completed by the original 215 contractor.
Since the QVP addresses work that was completed, inspected and accepted prior to the stop work, this problem which occurred after the stop work is not indicative of a " hole" in the program, therefore, no redirection of the QVP is required.
This problem will be evaluated and corrected through the ongoing l
l construction and QA programs.
TECHNICAL AUDIT ASSOCIATES, INC.
_ ~ _ _,. _
l
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The construction coordination problem that resulted in the missing shims is characterized by the coincidence of unique installation requirements and the transfer of responsibility for installation work that was partially complete.
As part of our ongoing QA program (not QVP), we intend to incre;se our confidence that there is not a generic problem with equipment installation resulting from the transfer of responsibility from UBG to Bechtel by selecting a sample of installation packages for review.
Records will be checked:
to assure that applicable vendor requirements have been incorporated in the installation; assure that closing documentation exists for all equipment installa-tions entered on the MWL; and.to assure that open items haver been transferred to the TCS.
The sample will be selscted to focus on equipment which involves special vendor installation requirements that are not covered by our anchor bolt and structural steel bolting prograrJs.
The following surrmary of re:,ults from the Project review of the RHR heat exchanger deficiencies provides t'he basis for our conclusions that the final alignment and inspection was not complete in July 1980 and that the missing shims we're the result of a construction coordination problem associated with the coincidence of unique installation requirements and the transfer of responsibility for installation work that was partially complete.
1.
The RHR Heat Exchangers were received in 1975 and installed by WBG in May, 1978.
Final alignment and inspection was not complete at the time of the work stoppage in July,1980, as identified in the WBG documentation completion program effort (Ref. WBG BEC-215-82-0363, dated 4/15/82).
The work was subse-quently transferred to BPC.
2.
WBG Inspection Report 215-IR-09880, dated 4/5/82 regarding RHR-HX-1 A indicated installation documentation is ' incomplete.
WBG Inspection Report 215-IR-09887, dated 4/19/82 regarding RHR-HX-1B indicated installation documentation is incomplete.
These IR's were closed by WBG with QC verification of installa-tion and closure to be transferred to Bechtel.
(
3.
The GE Specification 22A5233, " Installation Instructions for RHR Heat Exchangers" provided installation instructions for the upper keyway fitup clearances'and the lower support clearances between the slotted hole and the bolt.
This instruction allowed either the use of shims or restraining pads for the lower supports.
This specification was included in the 215 contract, Appendix IV.
4.
RFI-PQA-107, dated 1/16/79 identified that foundation detail 5772 does not call for shims or restraining pads for the supports as required by GE Specification 22A5233.
The'RFI was disposi-tioned by agreeing that the changes shall be made to the support bracket per GE instructions and the installation shall be in accordance with procedures and verified by QA/QC.
TECHNICAL AUDIT ASSOCIATES. INC.
B.16 -
5.
Letter WNP-2 WBG-215-F-80-1096, dated 4/14/30, transmitted PED 215-CS-2677 which provided direction to install shims on the upper keyway support to reduce the gap (X + Y) on both The heat exchangers in compliance with GE Spec. 22A5233.
PED contained as-built dimensions of the gaps required to be shimmed for both heat exchangers.
GE FDDR KKl-165, dated 3/24/80, was issued to disposition 6.
two cases at azimuths 90 and 180 where the as-built "Z" dimensions on the upper keyways exceeded the GE specification.
These cases were dispositioned "use-as-is" based on GE calcula-tions.
A review of WBG heat exchanger work packages found preliminary 7.
and incomplete sketches and calculations for restraining pads at the lower support.
Neither the shim installation nor the restraining pads had been completed by the-time of the stop work order.
In closing the WBG IR's (item 2) Bechtel addressed the require-8.
ments contained in GE Specification 22A5233 for torquing the nuts on the anchor bolts, but apparently overlooked the require-ments for shirmiing the upper and lower supports which are contained in the same document.
Washington Public Power Supply System P.O. Box 968 3000 GenrpeWashingtonWay Richland Washington 99352 (509)372-5000 Mr. Robert V. Laney Technical Audit Associates, Inc.
589 Oenacke Ridge New Caanan, CT 06840
Dear Mr. Laney:
Subject:
RESPONSE TO FINDINGS N05.15 AND'16 IN TAA AUDIT
~
f REPORT DATEC MAY 16, 1983.
Enclosed is our response to findings Nos.15 and 16 which relate to the Quality Verification Program.
This response has been revised to clarify those areas you discussed with John Honekamp l
on June 6.
We will provide our response to finding No.14 at a t
later date.
Very truly yours, N
J IY D. W. b Managing Director TECHNICAL AUDIT ASSOCIATES. INC.
_ _ _. - _ ~
B.17 -
June 8, 1933 PARTIAL RESPONSE TO TAA AUDIT REPORT DATED MAY 16, 1983 TAA Finding #15 The QVP does not inspect certain importent construction features such as the supporting and securing of power plant components.
This " hole" in QVP's scope should be filled.
Supply System Response It is correct that the QVP has not reinspected major mechanical equipment supports, however, it is not correct that tais fact l
l represents a " hole" in the QVP scope.
The purpose of the QVP is to verify the adequacy of safety-related work completed, inspected and accepted prior to the stop work in July 1980.
Independent of the QVP, substantial reinspections have been performed as part of the Test and Startup Program and to resolve specific problems identified during and after the Restart Program.
Therefore, the general approach employed by the QVP is to identify the work completed, inspected and accepted prior to the stop work, evaluate any special reinspections performed independent of the QVP, then perform those additional reinspections needed to meet the QVP requirements.
At the time of the TAA audit, this process had not been completed l
for major mechanical equipment installed by the 215 contractor, hence the general approach was discussed with TAA, but no conclusions l
l were presented relative to the need for reinspection by the QVP.
l This evaluation has now reached the point where it is clear that l
all 215 mechanical equipment was transferred to Bechtel prior l
to the completion of final alignment and document review.
Although installation of some equipment was essentially complete, the fact that final alignment and document review were not complete has led the Project to treat all WBG equipment installations as' incomplete.
Therefore, this element of the 215 Contract work does not fall within the scope of QVP.
)
As indicated on pages 7 and 13 of the TAA audit report, this finding was triggered by the fact that shims were observed to be missing from the RHR-B heat exchanger during a Supply System field inspection conducted as part of the Design Reveri'fication Program. This inspection was conducted on April 27, 1983, the day prior to the l
Finding Review Committee (FRC) meeting attended by TAA during which Potential Finding Reports (PFR) RHR-24 and 33 relative to l
this inspection were discussed.
The FRC classified these two i
PFRs as findings and requested a meeting with the Project to determine the status of the installation and the cause of the apparent discrepancies.
Although the Project review is not yet complete, it has been established that final alignment and inspection of the RHR heat exchangers were not completed at the timc of the TECHNICAL AUDIT ASSOCIATES. INC.
- B.18 -
stop work and that the r.dssing shims were the result of a construction coordination problem that occurred later when Bechtel assumed responsibility for work that was partially completed by the original 215 contractor.
Since the QVP addresses work that was completed, inspected and accepted prior to the stop work, this problem which occurred after the stop work is not indicative of a " hole" in the program, therefore, no redirection of the QVP is required.
This problem will be evaluated and corrected through the ongoing construction and QA programs.
The construction coordination problem that resulted in the missing shims is characterized by the coincidence of unique installation requirements and the transfer of responsibility for installation work that was partially complete.
As part of our ongoing construction completion program (not QVP),
we intend to increase our confidence that there is not a generic problem with equipment installation resulting from the transfer of responsibility from WBG to Bechtel by reviewing all Contract 215 QC-I equipment installation packages to assure that vendor equipment installation requirements have been implemented.
Records will be checked to assure that applicable vendor requirements have been incorporated in the installation; assure that closing documentation exists for all equipment installations entered on the MWL; and to assure that open items have been transferred to the TCS. Where documentation is not adequate to provide objective evidence that these requirements have been met, field verification L
will be used to assure that they have been implemented regardless of who did the work.
The following sumary of results from the Project review of the RHR heat exchanger deficiencies provides the basis for our conclusions that the final alignment and inspection was not complete in July 1980 and that the missing shims were the result of a construction coordination problem associated with the coincidence of unique installation requirements and the transfer of responsibility for
~
installation work that was partially complete.
1.
The RHR heat exchangers were received in 1975 and installed by WBG in May 1978.
Final alignment and inspection was not complete at the time of the work stoppage in July 1980 as identified in the WBG documentation completion program effort (Ref. WBG BEC-215-82-0363, dated 4/15/82).
The work was sub-sequently transferred to BPC.
2.
WBG Inspection Report 215-IR-09880, dated 4/5/82, regarding RHR-HX-1 A indicated installation docun.entation is incomplete.
WBG Inspection Report 215-IR-09887, dated 4/19/82, regarding RHR-HX-1B indicated installation documentation is incomplete.
These irs were closed by WBG with QC verification of installation and closure to be transferred to Bechtel.
TECHNICAL AUDIT ASSOCIATES, INC.
~
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3.
The GE Specification 22A5233, " Installation Instructions for RHR Heat Exchange-s" provided installation instructions for the upper keyway fitup clearances and the lower support clearances between the slotted hole and the bolt.
This instruction allowed either the use of shims or restraining pads for the lower supports. This specification was included in the 215 Contract, Appendix IV.
4.
RFI-PQA-107, dated 1/16/79 identified that foundatien detail on BRI Drawing No.S772 does not call for shims or restraining pads for the supports as required by GE Specification 22A5233.
The RFI was dispositioned by agreeing that the changes shall be made to the support bracket per GE instructions and the installation shall be in accordance with procedures and verified by QA/QC.
5.
Letter WNP-2 WBG-215-F-80-1096, dated 4/14/80, transmitted PED 215-CS-2677 which provided direction to install shims on the upper keyway support to reduce the gap (X + Y) on both heat excnangers in compliance with GE Spec. 22A5233.
The PED contained as-built dimensions of the gaps required to be shimmed for both heat exchangers.
6.
GE FDDR KKl-165, dated 3/2a/80, was issued to disposition two cases at azimuths 90 and 180 where the as-built "Z" dimensions on the upper keyways exceeded the GE specification. These cases were dispositioned "use-as-is" based on GE calculations.
7.
A review of WBG heat exchanger work packages found preliminary and incomplete sketches and calculations for restraining pads at the lower support.
Neither the shim installation nor the restraining pads had been completed by the time of the stop work order.
8.
In closing the WBG irs (item 2) Bechtel addressed the requirements contained in GE Specification 22A5233 for torquing the nuts on the anchor bolts, but 'pparently overlooked the require-a ments for shimming the upper and lower supports which are contained in the same document.
TECHNICAL AUDIT ASSOCIATES. INC.
_m.__
- B.20 -
Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richland, Washington 99352-0968 (509)372-5000
- #V%
V bt-Robert V. Laney O
Technical Audit Associates, Inc.
d 24 Trout Farm Lane Duxbury, Massachusetts 02332
Subject:
CLARIFICATION OF RESPONSE TO FINDINGS NOS.15 AND 16 IN THE TAA AUDIT REPORT DATED MAY 16, 1983.
During your audit of July 20-22, 1983, the TAA team requested clarification of the Supply System response to TAA audit findings NOS 15 and 16 regarding the adequacy of equipment installation.
This letter confirms the information provided to you by Hugh Crisp during your visit and is intended to clarify our previous response on this matter.
As we explained during your visit, all Contract 215 equipment installation activities were transferred to the Bechtel work scope as incompleted work.
Consequently, the installation of equipment for l
Contract 215 was not included in the quality reverification program scope l
of hardware reinspection. Certain other site contractors did perform inspections of equipment installations as part of the quality reverification program (e.g., Contract 216 reviewed HVAC equipment installation, Contract 218 reviewed electrical equipment installation).
Because of the problems identified with the RHR heat exchangers, we have initiated a complete review of the Contract 215 equipment installation work. This review consists of:
o Research of plans and specifications, including PEDS and vendor instructions, and the preparation of a list of attributes.
o A comparison of the attributes with existing inspection records.
Where the inspection records are specific with respect to the attributes inspected and indicate objectively that the attribute which required inspection was specifically inspected, the inspection record is taken as proof that the requirement is met in the field.
If the inspection record is not specific, that attribute is inspected in the field and the reinspection recorded.
This program will look at some 432 equipment installations; a 100% sample.
On completion of the program, it appears that some attributes will have been reinspected in the field on each item of equipment in the program.
TECHNICAL AU~JIT ASSOCI ATES, INC.
- B.21 -
R. V. Laney Page 2 August TAA Audit Report - May 16, 1983 Additionally, the Supply System has completed a detailed review of the reverification processes applied to the work done prior to June 1980. A matrix was prepared describing the construction commodities and the reverification performed including many special programs.
A copy of this matrix was provided to you during your visit.
j We believe that these actions address the issues raised by the subject TAA findings and we are hopeful that this clarifies any items of confusion that may have resulted frcr.: our previous response.
Very truly yours, G. D. Bouchey Technical Specialist to Managing Director I
cc ewett, Jr.
Y i.t:vy-C. Miller LH Roddis, Jr.
HE Sheets TAA Finding No. 16 In view of the gap in the QVP inspection program identified in Finding No.15, we believe there should be a fresh, systematic appraisal of the QVP scope to determine if there are other significant areas which are not covered by it.
s_
Supply System Response Our discussion with..TAA reprerentatives on April 29, 1983, may Vzyn have unintentionally left the impression that equipment installations are not being verified.
The Bechtel Reverification Group (BRG) was performing an evaluation of project programs which address contract 215 equipment installation at the time of TAA's visit.
This evaluation will be included in the contract 215 reverification report.
TECHNICAL AUDIT ASSOCIATES. INC.
, _. ~,
I:
- B.22 -
At our April 29th meeting, we responded tb TAA's questions on the RHR heat exchanger mounting by taking action to investigate whether or not the missing shims should have been discovered by QVP reinspections. At the receipt of this audit finding (5/19/83) we were concluding a part of our investigation, which has reverled that contract 215, equipment installations were not. completed prior to July 1980, and are therefore ou'tside 'the. scope of.QVP (Re:
response to finding No. 15).
To clear the path for understanding the completeness of QVP's examination of contract 215's work scope not only to determine the total quantity of hardware to be reinspected, but to identify specific items to be selected for reinspection, you may need to be aware that WBG's computer control lists were used as the basis for establishing the QVP scope.
These lists provide an identification of work packages for piping, hangers, structural items and equipment; the only substantive categories of work in the contract.
The coverage of QVP reinspections, including contract 215, is typified in the following lists:
QVP ELEMENTS Systems Completion o
Piping and Hangers o
Structural Steel o
Equipment Installation o
Ductwork and Hangers o
Cable Installation _and Terminations o
Conduit 56pport o
I&C Installation Prepurchace & Inactive Contrac_t_ss o
Components and Valves o
Cable o
Structural Steel o
Concrete, Resteel and Cadwelds o
Cranes and Hoists o
Piping and Hangers o
Mechanical and Electrical Equipment o
Soil Compaction o
Instrumentation Specail Tasks o
Design Change Documentation o
Personnel Qualifications o
Receiving Inspections o
Grout Further, many other review, reinspection and evaluation activities serve to comprise the totality of WNP-2 construction verification:
TECHNICAL AUDIT ASSOCIATES. INC.
- B.23 -
"0THER" VERIFICATION ACTIVITIES Secrificial Shield Wall Evaluation and Repair Program o
o PWR Review and Repair Program o
WBG' Documentation Completion Program o
Restart Program Elements o
Weld Radiograph Review o
Concrete Anchor Evaluation Program o
. Backfill Testing Program o
Structural Steel Bolting Drywell Steel Inspection o
Special Inspections and Audits by Corporate or Project QA o
o Hanger Retrofit Program Piping and Hanger As-Built Programs o
TSU's Component Verification Program o
o Pre-Service Inspection o
Coating Rework o
Bechtel QA Program Elements We believe the root cause of the RHR heat exchanger support deficiency is a construction coordination problem which occurred during the transfer of responsibility from WBG to Bechtel for completing the installations.
The resulting vulnerability to potential deficien-cies is limited to contract 215, as no other such transfer of This issue responsibility between contractors has taken place.
is being appropriately addressed as described in our response to Finding 15.
In conclusion, the Quality Verification program is soundly based on our comprehensive assessment of.the construction work in place prior to the s'topwork, and our careful cohsideration of that work for possible reinspection.
No further appraisal of the QVP scope is necessary.
done T 617M TAA Finding No. 16 j
In view of the gap in the QVP inspection program identified in Finding No.15, we believe there should be a fresh, systematic appraisal of the QVP scope to determine if there are other significant areas which are not covered by it.
Supply System Response Our discussion with TAA representatives on April 29,1983, may have unintentionally left the impression that equipment installations are not being verified.
The Bechtel Reverification Group (BRG)
TECHNICAL AUDIT ASSOCIATES. INC,
- B.24 -
was performing an eval.uation of Project programs which address Contract 215 equipment installation at the time of TAA's visit.
This evaluation will be included in the Contract 215 reverification report.
At our April 29th meeting, we responded to TAA's questions on the RHR heat exchanger mounting by taking action to investigate whether or not the missing shim; should have been discovered by QVP reinspections. At the receipt of this audit finding (5/19/83) we were concluding a part of our investigation which has revealed that Contract 215 equipment installations were not completed prior to July 1980, and are therefore outside the scope of QVP (Re:
response to finding No. 15).
To clear the path for understanding the completeness of QVP's exanination of Contract 215's work scope, not only to determine the total quantity o.f hardware to be reinspected but to identify specific items to be selected for reinspection, you may need to be aware that WBG's computer control lists were used as the basis for cstcolishing the QVP scope. These lists provide an identification of work packages for piping, hangers, structural items and equipment; the only substantive categories of work in the contract..The coverage of QVP reinspections, including Contract 215, is typified in the following lists:
QVP ELEb1ENTS Systems Completion I
~
i o
Piping and Hangers o
Structural Steel o
Equipment Installation o
Ductworr and Hangers o
Cable Installation and Terminations o
Conduit Support o
lac Installation Prepurchase & Inactive Contracts o
Components and Valves o
Cable o
Structural Steel o
Concrete, Resteel and Cadwelds o
Cranes and Hoists o
Piping and Hangers o
Mechanical and Electrical Equipment o
Soil Compaction o
Instrumentation TECHNICAL AUDIT ASSOCIATES. INC.
~
l '.
(
B.25 -
Special Tasks o
Design Change Documentation o
Personnel Qualifications o
Receiving Inspections o
Grout Further, many other review, reinspection and evaluation activities serve to comprise the totality of WNP-2 construction verification:
"0THER" VERIFICATION ACTIVITIES Secrificial Shield Wall Evaluation and Repair Program o
o PWR Review and Repair Progran o
WBG Documentation Completion Program o'
Restart Program Elements o
Weld Radiograph Review o
Concrete Anchor Evaluation Program o
Backfill Testing Program o
Structural Steel Bolting o
Drywell Steel Inspection Special Inspections and Audits by Corporate or Project QA o
o Hanger Retrofit Program Piping and Hanger As-Built Programs o
TSU's Component Verification Program o
o Pre-Service Inspection o
Coating Rework o
Bechtel QA Program Elements We believe the root cause of the RHR heat exchanger support deficiency is a construction coordination problem which occurred during the transfer of responsibility from WBG to Bechtel for completing the installations.
The resulting vulnerability to potential defi-ciencies is limited to Contract 215, as no other such transfer of responsibility between contractors lias taken place.
This issue is being appropriately addressed as described in our response to Finding 15.
In conclusion, the Quality Verification Program is soundly based on our comprehensive assessment of the construction work in place prior to the stop work, and our careful consideration of that work for possible reinspection.
No further appraisal of the QVP scope is necessary.
)
TECHNICAL AUDIT ASSOCIATES. INC.
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Observation No. 2 We believe that dealing with the uncertainties of turbine disc cracking requires a total systems evaluation, including water chemistry, turbine operation, and condenser leakage.
In its turbine planning, the S.S.
should determine as exactly as possible the conditions obtaining in other turbines on which it is relying for l
its strategic planning model, and compare those conditions with the conditions which can realistically be maintained for the WNP-2 turbine.
Until this has been done and the d:sta analyzed, the S.S. should be cautious about assuming three years of satisfactory service.
l Observation No. 5 For the purpose of deciding whether or not to extend
.the sample size, tray and conduit supports which,do not' conform to design plans, but are found acceptable as is, I
should be analyzed.
It is important to determine if the same deviations might be unacceptable in other tray and conduit support situations.
If so, such " acceptable as is" items should be counted as deviations for sample size For Supply System 's response to j
Observation #5 please refer 1:o Volume III; Report of Audit
- 3; May 16,1983; Attachment D, second from last page.
TECHNICAL AUO'T ASSOCIATES. INC.
APPENDIX C LIST OF PERSONS INTERVIEWED BY TAA i
TECHNICAL AUDIT ASSOCIATES. INC.
APPENDIX C LIST OF PERSONS INTERVIEWED by TAA C.
Anderson, QVP Program, S.S.
G.K. Afflerbach, Test and Startup Manager, WNP-2, S.S.
T.
Arch, Bechtel J.S. Ayers, Member HPCS Team, S.S.
R.J. Barbee, Member FRC, S.S.
W.C. Bibb, Director of Power Generation, S.S.
D.M. Bosi, Design Reverification, System Interaction, S.S.
T.
Bostrom, Bechtel Project Engineering Staff G.D. Bouchey, Technical Assistant to Managing Director, Chairman FRC, S.S.
H.R. Canter, Burns and hoe Engineering C.S. Carlisle, WNP-2 Program Director, S.S.
J.R. Cole, HPCS & RHR Team Member, Technology, S.S.
J.
Cooney, Fire Hazard Evaluation, Westinghouse K.D. Cowan, Technical Manager, WNP-2 Operations, S.S.
H.A. Crisp, Construction Manager, WNP-2 Project, S.S.
J.M. Curren, Member RFW Team, S.S.
A.I. Cyglecan, Manager Site Engineering, Burns and Roe B.E.
Ebboson, Systems Interactive Design Reverification, Stone
& Webster W.A. Eberly, Systems Interactive Design Reverification, Stone &
Webster W.I. Edwards, Member RHR Team, Westinghouse D.T.
- Evans, S.S.
TECHNICAL AUDIT ASSOCIATES. INC.
- C.2 -
R.A. Ferguson, Managing Director WPPSS J.A. Forrest, Burns and Roe, WNP-2 Project Director, Richland R.
Friis, General Electric G.L. Gelhaus, Manager Systems Design Technology, S.S.
R.B. Glasscock, Director Licensing and Assurance, S.S.
J.F. Gorman, HPCS Team Member, Technology, S.S.
L.T. Harrold, Assistant Director, WNP-2 Engineering, Burns and Roe R.L.
Heid, RFW Team Leader, S.S.
B.A. Holmberg, Engineering Manager WNP-2, S.S.
J.R. Honekamp, Technical Assistant to Managing Director, S.S.
A.G.
Hosler, Member FRC, S.S.
T.J. Houchins, Manager of Audits and Surveillance, Corporate QA, S.S.
D.
Johnson, Bechtel QA Manager, WNP-1 and 2.
R.T. Johnson, Manager of WNP-2 Project QA, S.S.
T.H. Keheley, HPCS Team Member, Technology, S.S.
A.D.
Kohler, Deputy Director Technology, S.,S.
R.L. Knawa, Manager, Quality Verification Program, S.S.
M.N. Leach, Bechtel Supervisor, Quality Verification Program P.J. Macbeth, HPCS Team Leader, Technology, S.S.
F.
MacLean, General Electric T.A. Mangelsdorf, Bechtel WNP-2 Project Manager F.J. Markowski, RHR Team Leader, S.S.
J.D. Martin, WNP-2 Operations Manager, S.S.
S.
Mather, General Electric i
TECHNICAL AUDIT ASSOCIATES, INC.
- C.3 -
R.G. Matlock, Director WNP-2 Program, S.S.
D.W. Mazur, Managing Director, S.S.
A.
Mcdonald, Plant Manager, Hanforc/Packwood Generation, S.S.
C.H. McGilton, Manager WNP-2 Nuclear Safety, Member FRC, S.S.
M.A. Mihalic, Member RHR Team, S.S.
J.C. Mowery, S.S.
D.M. Myers, Supervison.WNP-2 Site System Engineering, S.S.
R.
Nelson, Licensing Manager, WNP-2 Project L.C.
Oakes, Member FRC, S.S.
C.C.
Patel, Member RFW Team, S.S.
J.T.
Person, Member RHR Team, S.S.
D.W. Porter, Manager Plant Engineering 6 Construction, S.S.
N.S.
Porter, Member FRC, S.S C.M.
Powers, WNP-2 Plant Staff, S.S.
A.B. Rafer, HPCS Team Member, Technology, S.S.
R.
Ramsgate, QVP Program, S.S.
D.L. Renberger, Deputy Director, Technology, S.S.
W.E. Schulz, Prepurchased Instrument Rack Reverification, Stone
& Webster P.K.
Shen, Director Technology, S.S.
A.
Squire, Deputy Managing Director WPPSS G.C. Sorenson, Manager Licensing Progt:ams, Member FRC, S.S.
D.T.
Thonn, Member HPCS Team, Technology, S.S.
D.C. Timmins, Technical Assistant, WNP-2 Project Manager, S.S.
l TECHNICAL AUDIT ASSOCIATES. !NC
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J.
Verderber, Burns and Roe, NY Office E.
Vogeding, Systems Interactive Design, Westinghouse J.M. Walker, QA Audit, S.S.
I G.L. Walkoetter, Member RFW Team, S.S.
D.L. Whitcomb, Reverification Lead Engineer, S.S.
D.F. Winters, Member HPCS Team, Consultant J.M. Yatabe, Assistant Director Systems Engineering, Technology, S.S.
J.R.
Zimmerschied, QA Audit, S.S.
E.
Zisman, Burns and Roe, Oradell Present as observers only in some meetings:
W.
Chin, Bonneville Power Authority R.A. Feil, NRC B.
Reusche, Bonneville Power Authority A.D. Toth, NRC 117-3422 TECHNICAL AUDIT ASSOCIATES. INC.
i APPENDIX D TAA/ SUPPLY SYSTEM /NRC - VISITS /M EETINGS
}
1 TECHNICAL AUDIT ASSOCIATES. INC.
APPENDIX D TAA/ SUPPLY SYSTEM /NRC - VISITS / MEETINGS DATE LOCATION PURPOSE ATTENDEES 4/15-16/82 NYC Administrative / Planning Laney; Jewett, Honekamp 4/26-29/82 On-Site Review Panel, Phase I Laney, Levy, Roddis, Jheets, Jewett l
5/24-27/82 On-Site Review Panel, Phase I Laney, Levy, Roddis, Sheets, Jewett 6/25/d2 NYC Review Panel, Phase I
~Laney, Levy, Roddis, Sheets, Jewett 8/8-11/82 On-Site Chairman Visit Laney 9/21-24/82 On-Site Chairman Visit Laney 11/10/82 W DC SS/NRC Presentation Laney 11/18-23/82 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Jewett, Miller l
12/13/82 W DC NRC Follow-up Laney 1/5/83 NYC Review Panel, Phase II Laney, Roddis, Sheets, Jewett 1/19/83 On-Site FRC Meeting Miller 1/26-28/83 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Jewett, Miller l
2/8/83 On-Site FRC Meeting Miller 2/11/83 NYC Review Panel, Phase II Laney, Roddis, Sheets, Jewett 2/22/83 On-Site FRC Meeting Miller 3/7-9/83 On-Site Chairman Visit Laney 3/7/83 On-Site FRC Meeting Laney, Miller 3/18/83 On-Site FRC Meeting Miller Technical Audit Associates, Inc.
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DATE LOCATION PURPOSE ATTENDEES 4/1/83 On-Site FRC Meeting Miller 4/4/83 On-Site PRC Meeting Miller 4/8/83 On-Site FRC Meeting Miller 4/20/83 W DC S.S./NRC Up-date Laney 4/27-29/83 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Lewett, Miller 4/28/83 On-Site FRC Meeting Laney, Levy, Roddis, Sheets, Jewett, Miller 5/13/83 On-Site FRC Meeting Miller 6/3/83 On-Site FRC Meeting Miller 6/15/83 On-Site FRC Meeting Miller 6/28-7/1/83 On-Site Chairman Visit Laney 7/15/83 On-Site FRC Meeting Miller 7/19-23/83 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Jewett, Miller 7/29/93 On-Site FRC Meeting Miller 8/4/83 On-Site FRC Meeting Miller 8/5/83 On-Site FRC Meeting Miller 8/22-23/83 On-Site Chairman Visit Laney 8/22/83 On-Site PRC Meeting Laney 8/25/83 NYC Review Panel, QVP Laney, Roddis, Sheets, Jewett 9/1/83 OnSite PRC Meeting Miller 9/12/83 NYC Review Panel, QVP, DRP Laney, Roddis, Sheets, Jewett, Miller 9/27-28/83 NYC Review Panel, QVP, DRP Laney, Roddis, Sheets, Jewett Plus 3 Supply System & 1 Burns and Roe 117-3354 Technical Audit Associates, Inc.
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DATE LOCATION PURPOSE ATTENDEES l
4/1/83 On-Site FRC Meeting Miller 4/4/83 On-Site FRC Meeting Miller 4/8/83 On-Site FRC Meeting Miller 4/20/83 W DC S.S./NRC Up-date Laney 4/27-29/83 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Jewett, Miller 4/28/83 On-Site FRC Meeting Laney, Levy, Roddis, Sheets, Jewett, Miller 5/13/83 On-Site FRC Meeting Miller 6/3/83 On-Site PRC Meeting Miller 6/15/83 On-Site FRC Meeting Miller 6/28-7/1/83 On-Site Chairman Visit Laney 7/15/83 On-Site FRC Meeting Miller 7/19-23/83 On-Site Review Panel, Phase II Laney, Levy, Roddis, Sheets, Jewett, Miller i
7/29/93 On-Site FRC Meeting Miller 8/4/83 On-Site FRC Meeting Miller 8/5/83 On-Site FRC Meeting Miller 8/22-23/83 On-Site Chairman Visit Laney 8/22/83 On-Site FRC Meeting Laney 8/25/83 NYC Review Panel, QVP Laney, Roddis, Sheets, Jewett 9/1/83 OnSite FRC Meeting Miller 9/12/83 NYC Review Panel, QVP, DRP Laney, Roddis, Sheets, Jewett, Miller 9/21/83 OnSite Discussion of questions Miller 9/27-28/83 NYC Review Panel, QVP, DRP Laney, Roddis, Sheets, Jewett Plus 3. Supply System & 1 Burns and Roe 117-3354 Technical Au'dit Associates, Inc.
APPENDIX E Technical Audit Associates, Inc.
Plant Verification Program Plan Evaluation Team For WPPSS/WNP-2 BIOGRAPHICAL INFORMATION e
TECHNICAL AUDIT ASSOCIATES. INC.
r APPENDIX E Technical Audit Associates, Inc.
Plant Verification Program Plan Evaluation Team For WPPSS/WNP-2 BIOGRAPHICAL INFORMATION Frank B.
Jewett, Jr., Assignment Manager:
Founder & President of TAA, Member Technical Audit Board.
Assignment Director:
Indian Point-2 Containment Flooding Accident Audit, Nine Mile Point-2 Cost to Complete Audit.
Fermer: President and Chief Executive Officer, Vitro Corporation of America; Director of Engineering Research and Development, General Mills, Inc. &
Vice President Mechanical Division; Vice President & Manager Vacuum Equipment Division, National Research Corporation.
Former member President's Council, Cal Tech.
Member: of the Corporation, Woods Hole Oceanographic Institute; NY Academy of Sciences; Life Member ASME and member ASME Safety Committee.
Merit Citation, Crusade for Freedom.
Registered Professional Engineer, Minnesota.
BS, California Institute of Technology; MBA (mcl) Harvard University.
Robert V.
Laney, Chairman of the Review Panel:
Vice President of TAA, Member Technical Audit Board, Review Panel Nine Mile -2 Cost to Complete Audit.
Former Deputy Director, Argonne Na-tional Laboratory; Vice President and General Manager, Quincy Shipyard Division, General Dynamics; Techical Repesentative of AEC at Westinghouse Bettis Atomic Power Lab; Project Manager, Naval Reactor Program AEC & Bu Ships.
Ch. Engineering Review Team, Wash State Public Power Supply System.
Member, GPU &
Commonwealth Edison Ad Hoc Advisory Committees on Three Mile TECHNICAL AUDIT ASSOCIATES. INC.
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j Island; Member Presidential Board on National Breeder Reactor Policy.
Consultant:
Department of Energy; Argonne National Laboratory; MA Attorney General; Commonwealth Edison; State of Illinois.
BS, US Naval Academy; MS, MIT; MBA, U of Chicago.
Dr. Salomon Levy, Consultant to the Review Panel:
Consultant.
Member TAA Technical Audit Board.
Twenty Four years General Electric Co, San Jose, CA: General Manager Boiling Water Reac-tor Operations; General Manager BWR System Dept; Manager Des.
Engr. Atomic Pwr. Equip. Dept.; Manager System Engineer, At.
Pwr. Equip. Dept.; Manager Heat Trans
& Reactor Progam, APED.
Former: Member AEC Task Force, Emergency Core Cooling; Ch. ASME Heat Trans. Division; Member Argonne National Laboratory Review Committe, Reactor Safety; Industrial Advisory Board, TMI-2 ac-cident.
Cons.: Kemeny Commission; NRC Advisory Code Commis-sion; World Bank on Nuclear Safety in Korea. Member National Academy of Engineering; Fellow ASME.
Adjunct Professor, Uni-versity of California at Los Angeles.
ASME Heat Trans. Memo-rial and Conf. Award.
BS, MS, PhD, University California, Berkley.
Charles 0. Miller, On-site Consultant to the Review Panel:
Registered Professional Engineer.
Eight years United Engineers
&. Constructors; Dep. Proj. Mgr., WPPSS Unit 1; Asst. Ch. Power Eng., including supervision and management of power projects
[
and studies involving mechanical, nuclear, piping, process dis-ciplines; standards development, tech. des. guides, design re-views; tech. support and direction to various major power pro-jects, including seven nuclear plants; supervised design cri-teria reverification Seabrook Nuclear Units 1 & 2; Sup. Eng.
for preliminary design of five standard nuclear plants, includ-ing GE. Nuc. Steam Supply. System.
Seven years USN, including TECHNICAL AUDIT ASSOCIATES. INC.
(
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. operation, testing, maintenance of diesel-electric and nuclear submarines during new construction, overhaul, and operation.
B.S. Mech. Eng. and Math., U.S. Naval Academy; M.S. Applied Mech., Stanford University; Juris Doctor, Rutgers University.
Louin H.
Roddis, Jr., Member of Review Panel:
Consulting Eng-ineer.
Member TAA Technical Audit Board.
Chairman Energy Re-search Advisory Board of US Department of Energy.
Director:
Detroit Edison, Co.; Hammermill Paper Co.; Gould Inc.; Research
- Cottrell Inc.
Former President & CEO, John K. McMullen Asso-ciates; President & V. Ch., Consolidated Edison Company of New York; Chairman & President, Penna Electric Co.; Deputy Director Reactor Development,'USAEC; Project Officer Power Plant Devel-opment Nuclear Subs NAUTILUS and SEAWOLF, USN; Task Force I, Bikini atom weapons tests.
Fellow:
Royal Institute of Naval Architects, ASME, AAAS, American Nuclear Society.
Member E VC US National Committee CIGRE.
Member: SNE,'ASME, IEEE, ASEE, NSPE, HFS, ASHAE.
Registered Professional Engineer, NY, NJ, PA, DC, SC, Chartered Engineer UK.
Member National Academy of Engineering.
Outstanding Service Award USAEC.
Dr. Herman E.
Sheets, Member of Review Panel:
Director of TAA, Member Technical Audit Board.
Member Review Panel and Expert r
4 Witness, Indian Point-2 Containment Flooding-Audit; Review Pan-el Nine Mile Point-2 Cost to Complete Audit.
Director of Engi-neering, Analysis and Technology, Inc.
Former Chairman and Professor, Ocean Engineering Department, University of Rhode Island; sixteen years, Vice President, Engineering and Re-search, Electric Boat Division, General Dynamics Corporation; Engineer Manager, Goodyear Aircraft; Progam Manager, Elliott Co.; Director Research, St. Paul Engineer & Manufacturing Cor-poration; Chief Engineer, Chamberlain Res. Corp.; Design Engi-TECHNICAL AUDIT ASSOCIATES. INC.
j
i
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neer, Erste Bruenner Maschinen Fabrik. Cit. Sec. War, Manhattan Project.
Member:
National Academy of Engineering, New Yark Academy of Sciences.
Fellow ASME, AAAS; Member: ASME, ASNE, SNA & ME. Associate Fellow, AIAA.
Dipl. Ing. (1st in class),
-f,'
Technical Inststitute, Dresden; Dr. Technical Science, (award y
A for excellence) Technical University, Prague.
I E
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f 117-3441 i
TECHNICAL AUDIT ASSOCIATES. INC.
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