ML20090K036
| ML20090K036 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/05/1983 |
| From: | Grier G DUKE POWER CO. |
| To: | |
| References | |
| A-002, A-2, NUDOCS 8405230583 | |
| Download: ML20090K036 (88) | |
Text
-h Applicants' Exhibit k,,
/0 UNITED STATES OF AMERICA T
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%,3 NUCLEAR REGULATORY COMMISSION g-i be N:
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BEFORE THE ATOMIC SAFETY AND LICENSING ARD cD "blR,3 '3.194 p
r In the Matter of
{
G DUKE POWER COMPANY, et al. )
Docket Nos.
50 - :D
)
50-4G (Catawba Nuclear Station,
)
Units 1 and 2)
)
TESTIMONY OF G. W. GRIER 4
1 PART I 2
Q.
STATE YOUR NAME AND BUSINESS ADDRESS.
3 A.
George William Grier, III 4
Duke Power Company 5
P. O. BOX 33189 6
Charlotte, NC 28242 7
Q.
STATE YOUR PRESENT JOB POSITION WITH DUKE POWER 8
COMPANY AND DESCRIBE THE NATURE OF YOUR JOB.
9 A.
My present position is Corporate Quality Assurance Manager. I am 10 responsible for the management of the Duke Power Company Quality 11 Assurance Department.
I report to Company management regarding 12 the - proper conduct of our Quality Assurance Program.
This 13 involves assuring that certain activities are carried out in 14 accordance with Quality Assurance procedures developed to 15 implement Nuclear Regulatory Commission (NRC) regulations, and 16 various industry codes and standards.
17 Q.
DESCRIBE YOUR PROFESSIONAL EXPERIENCE
-AND 18 QUALIFICATIONS,- INCLUDING YOUR PRIOR POSITIONS HELD 19 WITH DUKE POWER.
O 8405230583 831005 PDR ADOCK 05000413 Q
4 1
A.
I received a Bachelor of Science Degree in Physics in 1964 from the 2
George Institute of Technology.
I am a registered professional 3
engineer in the State of North Carolina.
I served for five years in 4
the United States Navy as a Commissioned Officer.
I attended 5
Nuclear Power School, Prototype Reactor Training and Submarine 6
School.
I served for three years aboard a Polaris Submarine and 7
was qualified as an Engineering Watch Officer on an S5W Nuclear 8
Power Plant.
At various times I held the position of Sonar Division 9
Officer, Communications Officer, Electrical Division Officer and i
10 Supply Officer.
11 After leaving the Navy in May of 1969, I joined Duke Power 12 Company in the Construction Department at the Oconee Nuclear 13 Station.
My duties there included supervision of welding 14 inspectors, radiographers and other non-destructive examination 15 (NDE) inspectors.
I was certified by the company as a Level III, 16 non-destructive examination inspector in liquid penetration 17 inspection (PT), magnetic particle inspection (MT), radiography 18 (RT), and ultrasonic testing (UT) in accordance with requirements 19 of the American Society of Non-Destructive Testing Document 20 ASNT-TC-1 A.
I was also responsible for development and 21 maintenance of welding procedures, as well as review of welding l
22 inspection documentation.
l 23 In May of 1971, I was transferred to the McGuire Nuclear l-
-24 Station as Senior Construction Engineer.
In that role I supervised 25 the Construction Technical Support Organization, which included 26 Quality Control inspectors, and the ' Construction Planning. and-27 Scheduling Section.
I. was also responsible for developing.the 28 procedures and recommending organization modifications necessary '
l l'
to bring the Quality Assurance Program into conformity with the f-2 then recently published 18 point criteria set forth in 10CFR50, 3
Appendix B.
4 In May of 1974, concurrent with the formation of the Quality
)
5 Assurance Department, my title was changed to Project Engineer.
6 At that time the Quality Control inspectors were placed in a 7
separate organization within the Construction Department project 8
organization reporting to me.
9 In May of 1980, I was transferred to the Catawba Nuclear 10 Station as Planning Manager.
My duties were to develop and 11 maintain the construction schedule for Catawba.
In October of 12 1981, I was transferred to the Oconee Nuclear Station as Manager of 13 the Station Support Division.
In this role I was responsible for all Q
14 construction activities conducted at the Oconee Nuclear Station. On O
15 February 1,
1982 I was. appointed Corporate Quality Assurance 16 Manager.
17 Q.
DESCRIBE THE ORGANI7ATION OF THE QUALITY ASSURANCE 18 DEPARTMENT.
19 A.
The Quality Assurance Department is currently organized into six 20 divisions, each of which is headed by a Manager reporting to me.
21 The six divisions are Administrative Services, Operations, Technical 22
- Services, Audit, - Vendor, and Projects.
I have attached an 23 organizational chart to my testimony as Attachment 1 which reflects 24 the Department organization.
25 The Administrative Services Division is responsible for training 26 and certification of all inspectors and for the technical and
(
27 developmental training for. all members of. the department.
28 Administrative Services is also responsible for all ' personnel l I t
.,m 1
administration and for long term maintenance of Quality Assurance 2
records.
3 The Operations Division is responsible for carrying out the 4
Quality Assurance program at our operating nuclear stations.
5 There are currently four groups in this division, the QA groups at 6
Oconee, McGuire and Catawba, and a General Office Group 7
responsible for In-service Inspection Planning and Contract 8
Administration.
9 The Technical Services Division is responsible for development 10 and maintenance of all quality assurance procedures, surveillance of 11 Design Engineering activities, review of vendor quality assurance 12 doctunentation, interpretation of quality assurance requirements in 13
- codes, standards,
and design specifications, and trending of 14 non-conforming item reports (NCI's).
15 The Vendor Division is responsible for the audit and approval 16 of supplier quality assurance programs.
They maintain a list of
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17 currently qualified suppliers.
18 The Audit Division is responsible for the internal auditing of 19 our Quality Assurance Program.
Th'ey audit the activities of other i
20 divisions in the Quality Assurance Department as well as other 21 departments who are responsible for carrying out the requirements l
l 22 of the Quality Assurance Program.
These audit activities include l
23 certification that the procedures meet the requirements of the 24 codes, standards, specifications and NRC regulations which we are 25 committed to meet.
In addition, these activities verify the proper 26 implementation of these approved procedures.
Periodic reports are A
27 made to management on the effectiveness of the QA Program.
- l l.
I s
-l' The Projects Division is responsible for the Quality Assurance b
2 Program during construction at the Catawba Nuclear Station and at 3
Cherckee.
This division includes the quality assurance engineers l
4-and technicians who are responsible for reviewing construction 5
procedures and documents for conformity with QA requirements, for 6
determining specific inspections required to carry out the program, 7
and for. developing and approving corrective action instructions.
i 8
The Projects Division also includes Quality Control inspectors who 9
implement inspection procedures, Quality Assurance Technicians and 4
10 Clerks who review completed quality assurance inspection 11 documentation, and a
surveillance group which reviews the 12 implementation of the Quality Assurance Program by both the 13 Construction Department and the Quality Assurance Department.
14 Q.
DOES THIS DEPARTMENTAL ORGANIZATION DIFFER IN ANY O*
15 SIGNIFICANT MANNER FROM THE ORGANIZATION IN 1981?
16 A.
The organization is essentially the same now as it was during the 17 major part of 1981.
One significant change was the transfer of the 18 Quality Control inspectors from the Construction Department to the 19 Quality Assurance Department in February 1981, and the elimination 20 of the Projects QA Organization at the McGuire Nuclear Station 21 because of completion of construction.
22 Q.
DESCRIBE THE INTERFACE BETWEEN THE QA DEPARTMENT AND 23 THE CONSTRUCTION DEPARTMENT-ON THE CORPORATE LEVEL.
24 A.
The Vice President of the Construction Department, R. L. Dick, 25 and I regularly attend staff meetings conducted by Mr. Owen.
Any l
26 matters which affect both departments is ' reviewed during these t
27 regular staff meetings.
In addition, we attend regular project
,28 review meetings at which all phases of the Catawba Nuclear Station.
l I
are discussed.
Trend reports which analyze the corrective action O
2 program are regularly reviewed by Construction and Quality 3
Assurance mana',ement.
The results of internal audits performed 4
by the Audit Division are discussed during exit meetings with 5
Construction management.
The review and approval of quality 6
assurance procedures contained in the Duke Power Company 7
Construction Department Quality Assurance Manual involve both 8
Construction and Quality Assurance Management.
The results of 9
NRC inspection visits as well as inspections by organizations such 10 as ASME are jointly reviewed by Quality Assurance and 11 Construction management.
12 Q.
DESCRIBE THE INTERFACE BETWEEN THE QA DEPARTMENT AND 13 TIIE DESIGN ENGINEERING DEPARTMENT AT THE CORPORATE 14 LEVEL.
15 A.
The interface between QA and Design Engineerir.g is very similar to 16 the interface with Construction.
The Vice President of the Design 17 Engineering Department, L. C. Dail, also attends the regular staff 18 meetings held by Mr. Owen.
Any matters which affect both 19 departments are reviewed during these meetings.
We also attend 20 periodic project review meetings with Construction to review the 21 status of construction of the Catawba Nuclear Station.
Trend t
22 reports of non-conformance and variation notices are developed and
[
23 submitted to the management of both Quality Assurance and Design 24 Engineering for review. Design Engineering management attend exit 25 meetings conducted by the Audit Division after internal audits of l
26 the Design Engineering Quality Assurance Program, and there is 27 frequent contact between Quality Assurance personnel and Design
1 Engineering personnel in the course of review of specifications and 2
3 Q.
HOW DO YOU DEFINE QUALITY ASSURANCE?
4 A.
Quality Assurance is a planned management program designed to 5
assure that activities are carried out in accordance with i
i 6
procedures,' and result in the end product that meet certain 4
7 specifications and standards.
For the design and construction 8
phase of Catawba, the Quality Assurance Program assures that 9
design and construction are carried out in accordance with 2
10
. procedures which assure that. the completed plant meets the t
11 established specifications and standards.
12 Q.
HOW DOES QUALITY ASSURANCE DIFFER FROM QUALITY 13 CONTROL?
14 A.
Quality Control is those specific inspection activities designed to 15 determine the physical characteristics of work.
These physical j
16 characteristics are compared to specific criteria to determine if the 17 work is acceptable or must be -reworked or discarded.
Quality
]
18 Assurance encompasses Quality Control, as well as the programs 19 designed to guide the actual work activities of craftsmen,
20 technicians, engineers and others engaged in activities covered by 21 the Quality Assurance Program.
22 Q.
IS THERE A SET OF CRITERIA OR STANDARDS GOVERNING THE 23 DUKE POWER QUALITY ASSURANCE PROGRAM?
24 A.
Yes.
The Duke Power ' Company Quality Assurance Program is 1
25 governed by NRC regulations, including 10CFR Part50, Appendix 26 B.
The program must also encompass elements of the Final Safety 27 Analysis Report which specifies certain codes and standards.
1 Q.
WHAT IS REQUIRED BY APPENDIX B?
s 2
A.
Appendix B
has eighteen specific criteria that our Quality 3
Assurance Program must comply with.
These criteria include 4
management commitment, organizational requirements,
and 5
requirements for certain activities such as design control, document 6
control, procurement control, inspections, control of measurement 7
and test equipment, corrective active plan requirements, and 8
audits.
9 Q.
DOES THE DUKE POWER QA PROGRAM SATISFY THE "18 POINT 10 CRITERIA" REQUIRED BY APPENDIX B?
11 A.
Yes.
The Duke QA Program has satisfied the Appendix B criteria 12 since they were adopted by the NRC.
The QA Program as 1
13 described in the Topical Report was submitted to the NRC in 1974 14 and was approved.
Each subsequent amendment to the - Topical 15 Report has also been approved by NRC.
16 Q.
DESCRIBE HOW THE DUKE POWER QA PROGRAM SATISFIES EACH 17 CRITERION REQUIRED BY APPENDIX B,
STARTING WITH 18 ESTABLISHMENT OF THE QA ORGANIZATION.
19 A.
Duke Power Company is responsible for the design, construction, 20 operation and quality assurance of its nuclear power plants, as well 21 as its other operating plants.-
Individuals engaged in these 22 activities are employees of Duke ' Power Company.
The Corporate 23 Quality Assurance Manager directs the Quality Assurance 24 Department and has the sole responsibility for the development,
'25 management, and implementation of the company's Quality Assurance 26 Program.
The Corporate Quality Assurance Manager reports 27 directly to the Executive Vice President, Engineering and 28 Construction.
I have attached an organizational chart as b
1 Attachment. 2 to my testimony which reflects this relationship. Each 2
individual in the Quality Assurance Department, including the I
3 Quality Control Inspectors who report to successive levels of 4
supervision in the Quality Assurance Department, is independent of 5
any other department in the company.
Members of the Quality 6
Assurance Department have the full authority to execute the Quality F
7 Assurance Program, including the authority and responsibility to 8
stop ' work when the continuation of the work would produce results 9
adverse to quality.
The organizational responsibilities of each of 10 these departments is set forth in the Duke Power Company Topical 11 Report (Duke 1. A.).
12 The Executive Vice President, Engineering and Construction, 13 Mr. Owen, is the Corporate Executive responsible for Quality i
14 Assurance.
The Design Engineering Department, the Construction O'
15 Department and the Quality Assurance Department all report to Mr.
1 j
16 Owen.
The activities of the Design Engineering and Construction -
17 Departments affecting nuclear safety related work are delineated in l
18' procedures which are reviewed and approved by the Quality 19 Assurance Department.
The Quality Assurance Department i
20 maintains control over the safety related work through these l
21 procedures, 22 Q.
HOW DOES DUKE POWER SATISFY THE APPENDIX B
23 REQUIREMENTS WITH RESPECT TO ESTABLISHMENT OF A QA 24 PROGRAM?'
25 A.
Program manuals for the Design Engineering Department, the 26 Construction Department and the Quality Assurance Department l
-27 have been written. These manuals contain procedures which control 28 the activities of these three departments.
Similar_ procedures are l l
l
1 written which control the activities of quality assurance personnel V
2 and Nuclear Production Department personnel during the start-up 3
and operating phase of the plant.
All of these procedures are 4
reviewed and approved by the Quality Assurance Department.
5 These procedures include requirements for training personnel 6
performing safety-related activities, and include requirements to 7
audit these activities regularly.
8 Q.
HOW DOES - THE DUKE POWER QA PROGRAM SATISFY THE 9
APPENDIX B REQUIREMENTS IN THE AREA OF DESIGN CONTROL?
10 A.
Quality Assurance Procedures govern the activities of the Design 11 Engineering and Quality Assurance Departments associated with the 12 design of safety-related systems, components and structures in each 13 nuclear power plant.
Design Engineering specifications are 14 developed by qualified individuals based on applicable codes, 15 standards and FSAR commitments.
These specifications are 16 independently reviewed by another qualified individual within 17 Design Engineering, and are reviewed by the Quality Assurance 18 Department to assure incorporation of the necessary quality 19 assurance information.
All Design Engineering drawings are 20 reviewed independently by a qualified individual who was not 21 responnible for producing the original drawing information.
Each 22 drawing is then approved by an individual authorized in writing the 23 Chief Engineer of the sponsoring division prior to release to 24 Construction.
In order to establish the proper interfaces within 25 Design Engineering, each des:gn drhwing and specification is l
26 reviewed by a designared engineer from the other divisions in l
27 Design Engineering.
Any field variation to the design is 28 documented and approved by the Design Engineering Department
! 1 i
I
1 prior to incorporation in the final design documents.
When (q:
2 inspections reveal as-built conditions different from design 3
documents, those conditions which are not corrected by 1
4 Construction are evaluated by Design Engineering under the 5
Non-Conforming Item Report Procedure.
Those conditions which are f
6 acceptable are documented in the final design documents to reflect 7
the as-built condition.
Those conditions which are not acceptable 8
are identified to Construction for correction. All design information f
9 is distributed using a writtcn control procedure.
Methods for 4
10 resolving non-conformances are incorporated in the Design 11 Engineering Quality Assurance Program.
12 Q.
WHAT ABOUT DOCUMENT CONTROL AND PROCUREMENT i
13 DOCUMENT CONTROL?
14 A.
Quality Assurance procedures, design drawings and specifications, i
15 and procurement documents, as well as any other procedures and 16 instructions relating to nuclear safety-related activities,
are 17 controlled by procedures in the Design Engineering and i
18 Construction Quality Assurance Manuals.
These procedures assure 19 that all documents, including changes and revisions, are adequately 20 reviewed and approved by authorized personnel, and assure that i
21 the documents are transmitted and received at appropriate locations.
22 A transmittal sheet is attached to documents.which must be signed 23 and returned to the sending location as a means of assuring proper 24 receipt.
Controlled document lists are generated which indicate the 25 latest revision of the document.
After documents are received at 26 the construction project it-is the responsibility of trained document 27 controllers to maintain and distribute controlled documents.
These 28-
. document controllers replace superseded or revised documents with -. -
I current documents, and maintain records of the distribution of 2
controlled documents.
Certified inspectors regularly check the 3
functioning of this document control system.
1 4
The majority of procurement documents are originated by
)
5 Design Engineering personnel, although some documents are 6
originated by engineers in Construction or Nuclear Production.
7 These engineers are responsible for the technical aspects of the 8
These technical aspects include conformity 9
with design specifications and required codes and standards.
10 Regulatory requirements, such as compliance with Appendix B, are 11 also included.
Each procurement document is independently 12 reviewed by a qualified individual other than the person who 13 prepared the
- document, and is approved by an individual 14 designated by the Chief Engineer or Project Manager.
All 15 procurement documents for nuclear safety-related items are reviewed 16 by the Quality Assurance Department to assure that quality 17 assurance requirements, such as documentation, non-destructive 18 examination tests and inspections, are included in the document.
19 This QA review also assures that vendors are on a current list of 20 approved vendors produced by the Quality Assurance personnel in 21 the Vendors Division.
Prior to being placed on this approved list 22 the vendor quality assurance programs are evaluated by the Quality 23 Assurance Vendors Division.
24 Mill Power Supply Company, the purchasing department.of 25 Duke Power
- Company, originates purchase orders in strict 26 accordance with the approved purchase requisition.
An 27 independent check for correct transferal of data from the _
~
1 requisition to the _ purchase order is performed by the Quality
\\")
2 Assurance Technical Services Division.
3 Q.
HOW DOES THE DUKE POWER QA PROGRAM SATISFY THE 4
APPENDIX B REQUICMENTS WITH RESPECT TO CONTROL OF 5
PURCHASED MATERIAL, EQUIPMENT, AND SERVICES?
6 A.
Control of purchased material, equipment and services begins with 7
the selection of' qualified vendors.
The Vendors Division of the 8
Quality Assurance Department audits prospective vendors to make 9
sure that their quality assurance programs comply with the 10 appropriate portions of Appendix B, as well as other QA program 11 requirements that might be specified in applicable codes and 12 standards.
If the Vendors Division approves a supplier or 13 contractor they are placed on a controlled Approved Suppliers List.
14 The control of the requisition and purchase order process has been 15 described in response to a prior question.
16 During manufacture of purchased material or equipment, or the 17 performance of purchased services there are frequent technical 18 reviews by Design Engineering or Ccnstruction, as well as 19 surveillance visits by the Vendors Division of the Quality Assurance 20 Department.
Prior to shipping material or equipment, our 21 purchasing department, Mill Power Supply Company, assures that 1
l 22 the requisitioning department, as well as Quality Assurance are 23 satisfied that the material can be shipped.
Shipping, packaging 24 and handling instructions which comply with the required standards 25 are given to the vendor on the purchase order. When the material 26 or equipment is received on site, a certified quality control 27 inspector checks the material to assure that it is the material j-28 described by the requisition and purchase order and checks to see -.
- - - - _~
1 that no shipping damage has occurred.
The Technical Services O
t 2
Division of Quality Assurance reviews the documentation associated 3
with material to assure that all specifications and standards have 4
been met.
5 Q.
HOW DOES THE DUKE POWER QA PROGRAM SATISFY THE l'
6 APPENDIX B REQUIREMENTS WITH RESPECT TO IDENTIFICATION f
7 AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS?
8 A.
Requisitions and purchase orders specify marking requirements 9
which the vendor must apply to the material, parts or components 4
t 10 prior to delivery.
During receipt inspection, certified quality i
11 control inspectors verify that the markings on the materials, parts
~
12 or components comply with the requirements of the purchase order i
13 and requisition. Approved quality assurance procedures control the i
'14 marking and identification of materials, parts and components in 15 storage and in use.
These procedures include requirements to i
16 transfer markings if construction activities would make them 17 inaccessible or if materials such as pipe or plate are divided.
18 Inspections points are put in procedures that require certified j
19 inspectors to check marking requirements during fabrication and 20 erection.
Procedures for handling non-conforming items include the i
21 requirement to mark these non-confcrming materials to clearly i
22 indicate they are not to be used and, where possible, to separate 1
23 them from materials, equipment ad components that may be used.
l 24 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B l
25 CRITERIA WITH RESPECT TO CONTROL OF SPECIAL PROCESSES?
26 A.
All special processes including, but not limited to,
- cleaning, 27 welding, pipe bending, heat - treating, non-destructive examination 28 and calibration, are accomplished by qualified personnel under ll:
1 controlled procedures approved under the QA Program.
The V
2 Vendors Division of Quality Assurance monitors special processes 3
being conducted by manufacturers and contractors.
They assure 4
that these manufacturers and contractors have documented programs 5
for control of all special" processes utilized.
6 Special processes used by the Construction Department are 7
controlled by procedures approved under the quality assurance 8
program.
Controls include requirements to certify the process and 9
the individuals involved in carrying out the process.
These 10 procedures also require that process control be developed and 11 approved by qualified individuals.
The process control sets forth 12 the step-by-step instructions to the craftsmen and identifies 13 inspection points.
All welders and welding processes are certified 14 to the requirements of the American Society of Mechanical Engineers 15 (ASME), Secticn IX.
All individuals conducting non-destructive 16 examination processes are certified to - the requirements of the 17 American Society of Non-Destructive Testing recommended practice 18 SNT-T-1 A.
19 Q.
HOW DOES THE QA PROGRAM SATISFY THE CRITERIA WITH 20 RESPECT TO INSPECTION OF ACTIVITIES AFFECTING QUALITY?
21 A.
All inspection activities are conducted in accordance with approved 22 quality assurance procedures.
Inspection activities of vendors are 23 conducted in accordance with their quality assurance program which 24 have been approved by the Vendors Division of Quality Assurance.
25 Vendor Division personnel review the conduct of the vendor 26 inspection program during surveillance visits, and have full 27 authority to stop work if conditions require such action.,
-,~
-r
k t
1 The inspection program at the construction site is conducted O
-2
. by certified Quality Control inspectors who report to the Project 3
Quality - Assurance Manager.
All Quality Control inspectors are
+
l 4
examined and certified in their particular area of responsibility.
5 These inspectors are independent from the Construction organization 6
which performs the work. Their activities are controlled by Quality 7
Assurance Procedures which are approved by the Quality Assurance i
8 Department.
These procedures include instructions for performing 9
the inspection, requirements for hold points which stop the work 10 until inspectors inspect a certain activity, acceptance criteria, and 11 documentation requirements.
The results of inspections are l
12 documented and include, as a minimum, the identity of the inspector 13-conducting the inspection and the results of the inspection.
All 14 inspectors have full authority and responsibility to stop work when 15 conditions adverse to quality affecting nuclear safety are detected.
16 Q.
HOW DOES THE QA PROGRAM SATISFY 1HE APPENDIX B 17 CRITERIA WITH RESPECT TO CONTROL OF TESTING?-
3 l
18 A.
Testing is. conducted in accordance with detailed procedures which 19 are reviewed and approved by the Quality Assurance Department.
l 20 These procedures include the instructions for carrying out the l
21 tests, including required conditions and required ten t equipment, 5!2 the acceptance criteria, and requirements for data collection. Only 23 properly calibrated equipment may be used.
The tests are 24 inspected and Ldocumented by certified inspectors reporting to the 25 Quality Assurance Department. The tests results are evaluated and 26
. approved by the Quality Assurance Department.
i
^
. ~
. ~.
f 1
1 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B O-2 CRITERIA WITH RESPECT TO CONTROL OF MEASURING AND TEST 3
EQUIPMENT?
4 A.
The program to control measuring and test equipment is S
described in written approved procedures in the Quality Assurance 6
Program.
These procedures require the unique identification of 7
each piece of measuring and test equipment, and describe the 8
calibration requirements, the intervals at which re-calibration is a
9 required, and the system used to recall equipment for calibration.
10 The procedures.contain the accuracy requirements and the 11 requirements for tracing the acceptance standards to nationally 12 recognized standards.
13 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B 14 CRITERIA WITH RESPECT TO CONTROL OF MATERIALS 15 HANDLING, STORAGE, AND SHIPPING?
I 16 A.
- Handling, storage and shipping requirements are placed on l
17 requisitions and purchase orders.
These "give instructions to the 18 vendor for shipping as well as to the receiving site for storage 19 requirements.
Special procedures are written when necessary to 20 give more detailed storage requirements.
Certified Quality Control 21 inspectors monitor the storage conditions of material to assure that 22 no deterioration takes place.
23 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B l
24 CRITERIA WITH RESPECT TO CONTROL OF INSPECTION, TEST 25.
AND OPERATING STATUS?
26 A.
Erection and inspection procedures require that the inspection, test
'27 and operating status be marked on documentation traceable to the 28 item and, as appropriate, by physical marking on the item itself. ;
-n.
r.- -., - -
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_.,,----,e
l 1
For example, each weld made is marked with a unique stencil (J
2 number by the welder who made it.
Prior to transfer of systems 3
from Construction to the Nuclear Production Department, detailed 4
packages of information showing the status of structures, systems, 5
and components is assembled.
Tags are used to indicate the actual 6
status of the system in the plant.
7 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B 8
CRITERIA WITH RESPECT TO CONTROL OF NONCONFORMING 9
MATERIALS, PARTS AND COMPONENTS?
10 A.
During the course of inspections, an inspector can indicate his 11 rejection of a certain item in several ways.
When a minor 12 discrepancy is identified, the inspector can inform a craftsman or a 13 craft supervisor that he is not accepting a certain item and indicate 14 to the craftsman that he should make corrections in accordance with 15 approved procedures.
In this case the inspector will not sign off 16 the documentation indicating that he has accepted the item.
The
^
17 documentation requir.d to be produced during the course of 18 inspections frequently has provisions to indicate what has been 19 rejected on the item.
For these types of forms the inspector will 20 mark the reject block or in some other approved manner indicate 21 that the item has been rejected, and state the reasons for the 22 rejection.
Subsequently, the inspector inspects the repair or 23 rework, and if acceptable, will sign the documentation indicating 24 the acceptance of the work activity.
25 When discrepancies are not minor, cannot be corrected in a 26 timely manner, and the applicable inspection procedure does not 27 offer a means to document the rejections and corrections of the i
28
- problem, the QA program provides other procedures for
1 identification and resolution of discrepancies such as Procedure
'b 2
R-2.
An inspector can use this procedure to describe the 3
identified discrepancies.
The form used to document these 4
discrepancies (Form R-2A) is reviewed by technical personnel in the 5
Construction Department to determine the appropriate corrective 6
action.
After this corrective action has been carried out, the 7
Quality Assurance Department will review that action to assure that 8
it was sufficient to correct the problem, that all required actions 9
and reinspections were performed, and that information on the form 10 is clear and complete.
11 Quality Assurance Procedure Q-1, Control of Non-Conforming 12 Items, is used to document discrepancies which fall into the 13 following categories:
14 1.
A discrepancy requiring design evaluation other than 15 interpretations, clarifications or editorial changes.
16 2.
A discrepancy representing a manufacturing deficiency 17 other than minor material deficiencies.
18 3.
A discrepancy which will require extensive rework.
19 4.
A discrepancy which represents a bypass inspection 20 holdpoint.
21 5.
A discrepancy discovered during other than a preplanned 22 activity which would have no subsequent required 23 inspection planned which would check for that type of 24 discrepancy.
25 Each R-2A form is reviewed by Construction and QA using l
l 26 these criteria to determine if it should be handled using Procedure 27 Q-1.
This is the review of form R-2A for upgrading to an NCI.
l
-w-l
1 In a situation where any of these five criteria are applicable, 2
an inspector or other individual would write a Non-Conforming Item 3
Report (NCI), Form Q-1A.
The originator of the non-conforming 4
item will obtain a sequential serial number and place it on the form.
5 A designated QA Engineering Supervisor would then review the NCI 6
to assure that the item is non-conforming and requires processing 7
under Q-1.
That person will also assure that all information needed 8
to describe the item and to perform the evaluation is provided. If 9
it is determined that an NCI is unnecessary the reason is explained 10 on the report and a copy provided to the originator. These voided 11 non-conforming items reports are filed and maintained.
In the i
12 past, it was not always a QA Program requirement to file and 13 maintain copies of voided non-conforming item reports, although the 14 other steps of this review process applied.
15 The actual item which is non-conforming will be tagged to 16 indicate its status, and if physically possible, will be segregated 17 from acceptable items.
The non-conforming item report will be 18 processed as follows:
19 A technical review is performed by qualified engineers or 20 technicians in Design Engineering, Construction, or QA to 21 determine if the item can be reworked or must be scrapped.
The 1
22 proposed disposition is reviewed by a second qualified engineer or 23 technician within the organization originating the disposition.
24 There is a Qh approval of this disposition.
Qualified engineers or 25 technicians will also provide corrective action instructions to 26 implement this disposition.
This corrective action is reviewed by I
/'
27-QA for adequacy and. for designation of required reinspection.
\\
I
l 1
The non-conforming item is also reviewed by designated QA 2
Engineering Supervisors to determine if the situation is potentially 3
reportable under 10CFR, Part 21 or $50.55(e).
There is also a 4
separate evaluation by designated QA Engineering Supervisors to 5
determine if significant corrective action needs to be considered.
6 Significant corrective action would involve actions which would 7
extend beyond the scope of correction of the specific item which 8
was non-conforming.
All documentation concerned with 9
non-conforming item reports are reviewed by Quality Assurance and 10 filed in the permanent Quality Assurance records files, 11 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B j
j 12 CRITERIA WITH RESPECT TO ESTABLISHMENT OF MEASURES TO 13 INSURE CORRECTIVE ACTION?
14 A.
Quality Assurance procedures that control work activities and i
15 inspections contain instructions for corrective action.
These i
16 instructions include methods to identify and document discrepancies 1
17 as well as instructions for carrying out corrective action.
More 18 significant~ discrepancies are recorded on Non-Conforming item 19 Reports, Form Q-1A.
Each non-conforming item report is reviewed 20 to determine if significant corrective action needs to be considered.
21 The corrective action required to bring the specific item into 22 compliance is recorded on the non-conforming item report.
If there 23 is a need for significant corrective action, then the provisions of 24 Procedure R-6, Significant Corrective Action, are carried out.
25 Under the R-6 procedure, a designated individual in Quality 26 Assurance, Design Engineering and Construction is responsible for 27 determining' the required corrective action. The items considered in l
28
'this evaluation include whether the condition is significant; what
- l. i
-,-c.-
1 1
1 the root cause of the problem is; what corrective action is required 7
2 to prevent recurrence; whether there are possible Duke or industry 4
3 generic implications; whether the condition is repetitive to the 4
extent that generic corrective action should be implemented; and 5
whether the condition needs to be investigated at other Duke sites.
6 The results of this evaluation are recorded on Fonn R-6A and 7
corrective actio'ns required are documented.
After the corrective 8
action is carried out there is a final review of the document by 9
Quality Assurance.
10 Quality Assurance procedures require analysis of trends in 11 discrepancies documented on Non-Conforming Item Reports, Form 12 Q-1A and Discrepancy Reports, Form R-2A.
These trends are 13 provided to the appropriate management in Design Engineering, 14 Construction and Quality Assurance.
These trends allow 15 management to assess the effectiveness of the corrective action 16 program.
17 Q.
HOW DOES THE QA. PROGRAM SATISFY THE APPENDIX B 18 CRITERIA WITH RESPECT TO CONTROL OF INSTRUCTIONS, 19 PROCEDURES, AND DRAWINGS?
20 A.
-The development and revision of quality assurance procedures is l!
21 carried out in accordance with a controlled program. This program 22 requires review and approval of these procedures by
- designated-l 23 individuals in
-Quality Assurance, Design Engineering and 24 Construction.
These procedures are distributed in a controlled 25' manner, as previously described, which assures that up-to-date 26 copies are available.
Instructions and drawings produced by 27 Design Engineering, Construction, and Quality Assurance are 28 controlled in.accordance with quality assurance procedures.
QA... -.
J 1
Program procedures require the appropriate review and approval of 2
these documents as well as appropriate distribution control.
~
'3 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B 4
CRITERIA WITH RESPECT TO MAINTENANCE OF SUFFICIENT 5
QUALITY ASSURANCE RECORDS?
6 A.
The Quality Assurance Department has overall responsibility for 7
maintenance of quality assurance records, and procedures have 8
been established to control the review and storage of all quality i
9 assurance records.
These procedures melude the administrative 10 control of records as well as physical storage requirements. Record 11 storage facilities are constructed,
- located, and secured in 12 accordance with ANSI Standard N45.2.9.
Each quality assurance 13 record has a designated retention period.
14 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B i
15 CRITERIA WITH RESPECT TO PLANNED, PERIODIC AUDITS TO i
16 VERIFY THE QUALITY ASSURANCE PROGRAM?
17 A.
The Managers of the Quality Assurance Department's Projects, 18 Technical Services, Operations and Vendor Divisions are responsible 19 for surveillance of activities under the - cognizance of their 20 respective divisions.
The Manager of the Audits Division is 21 responsible for audits of all-departments performing nuclear safety 22 related work.
The Executive Vice President-Engineering and 23 Construction is responsible for the Corporate Audit performed of l
24 the Quality Assurance Department.
i 25 Personnel' performing audits - are not responsible for the work 26 in the area being. audited.
The surveillance activities consist of 27 checking documents, records and work in progress to determine 28 that the Quality Assurance procedures are being properly -,. _ _ _. _ _..
y y..
}
4
/
t 1
implemented. > These surveillance-groups develop and maintain hg' 2
_ schedub for ' periodic surveillances and review each new Quality N
3 Assurance procedure within three months of its efhetive date to 4
determine its effective implementation.
Copies i of surveillance
's 5
reports with deficiencies are provided to the appropriate Quality
+*
6 Assurance DivisFF Manager and to management responsible for the i
7 area subject to surveillance.
Action taken to correct deficiencies is reviewed by the Quality Assurance Department.,
8 i
p 9
The QA - Manager of the Audits Division is responsible for s,
10 conducting the independent audits of the Quality Assurance Program 11
' implementation.
Each audit team has a lead auditor who directs the 12 audit team in developing check lists, instructions or plans and a
13 directs the team while performing the audit.
Ea'ch. audit is
(
x 14 thorcughly documented in a report which sets forth identified O,
15 discrepancies.
The report is reviewed by responsible management 16 f
of the area audited who must respond in writing within thirty days
)
indicating 17
- action that will be t? ken to correct discrspancies,
^'
t 18 including the date when the action will be complete. The response i
19 is reviewed by the Audit Division to determine if it is adequate. A 20 re-audit of corrective action may be conducted.
The Audh Division 21 mdifttains files of audits,
including documentation; conc.erning 22 completion of corrective action.
23 The Executive Vice President, Engineering and Construction, 24 Mr. Owen, directs an independent audit of. the Quality Assurance 25 Department at least annually.
The - Executive Vice President l
26 appoints the hudit team which consists of at least three qualified 27 individuals who do not work within the Quality - Assurance w
28
' Department.
Duke Power : Company is ~ currently a member of the g 4
h qisW
,1 Joint Utilities Management Audit Group (JUMA).
Through JUMA,
-2 QusRty Assurance personnel from other utilities are available to foEn the audit team for the Corporate Audit.
3 i
This team conducts 1
4 the audit in the same manner that internal audits are conducted by 5
the Audit Division of the Quality Assurance Department.
These 6
corporate audits are conducted in accordance with approved 7
checklists, and reports are generated and submitted to the 8
Executive Vice President.
The Executive Vice President then I
9 assigns; appropriate individuals to determine needed corrective 10 action and reviews the results of this corrective action.
All 11, correspondence, checklists and reports related to the Corporate 12 I
Audit' are maintained in the Quality Assurance files.
13 Q.
HOW DOES THE QA PROGRAM SATISFY THE APPENDIX B 14 REQUIREMENT OF INDEPENDENCE FROM SCHEDULE AND
/n\\
15 O
CONSTRUCTION PRESSURES?
16 A.
Thb0Quality Assurance Department is responsible for all quality 17 assurance activities related to Duke's nuclear stations.
The t 18' I department is directed by the Corporate Quality Assurance Manager 19 who reports to Mr.
Owen,
the Executive Vice President,
, 20 Engineering and Construction.
The Corporate Quality Assurance 21 Manager reports to the same executive level as the Vice Presidents 22 of Design Engineering and Construction.
Mr. Owen has given the 23 Corporate Quality Assurance Manager the freedom and independence f'
24 to implement the Quality Assurance Program without constraining 25 influence in regards to schedules and costs.
Personnel within the 26 Construction Department and Design Engineering Department clearly 27 understand the Quality Assurance Department's independent role.
p) q a 28 v
Working relationships between Quality Assurance and Construction
,,.,u
,....,.~..-,.
)
l/
3 and Design Engineering era built on this principal of indspendence.
1 2
Mutual awareness of this principal allows smooth working a
, C while still allowing Quality relationships between the departments, 3
4 Assurance to make decisions independent of schedules and cost improper pressure being exerted by Construction or 5
without any Design Engineering personnel.
6 ARE THERE ANY MANUALS OR PUBLICATIONS W 7
Q.
THE DESIGN AND CONSTRUCTION PHASE OF THE 8
These manuals are the Duke Power Company Topical Report 9
A.
Yes.
DUKE-1A,
the Design Engineering 10 for Quality Assurance, Department Quality Assurance Manual, the Construction Departm 11 12 Quality Assurance Manual, Quality Assurance Department Quali 13 Assurance Manual, Quality Assurance Department NDE Program l
and the Quality Assurance Manual for ASME Code Work.
14
- Manual, 15 Q.
DESCRIBE HOW EACH OF THESE MANUALS IS USED TO l
IMPLEMENT THE QA PROGRAM.
16 The Topical Report provides a detailed organizational description o i
17 A.
18 those individuals and groups involved in carrying out activities It also delineates the required by the Quality Assurance Program.
19 responsibilities and authority of those organizational units.
20 duties,
the measures used to carry out the Duke The Topical describes 21 22 Power Company Quality Assurance Program and describes how 23 applicable requirements of Appendix B are satisfied by the This administration and implementation of the program described.
f 24 program was first submitted to the NRC in March 1974 and has 25 The latest approved as each subsequent amendment has been filed.
26 amendment, No. 6, was approved by the NRC on February 3,1983 27 9
1.
^
O) establishes the method of collection and storage of design 1
's 2
quality assurance records.
3 The Duke Power Company Construction Department Quality 4
Assurance Manual (Construction QA Manual) contains the procedures 5
which govern the quality assurance aspects of the construction 6
process. The Construction QA Manual establishes:
7
. requirements for the preparation, approval, revision and 8
control of construction quality assurance program procedures; 9
provides procedural requirements for auditing the vendors 10 supplying materials and' services to the field and for the 11 control of the procurement process and procurement 12 documents; 13 describes methods of preparing and obtaining approval of
' repared in the field, describes how 14 installation procedures p
15 hold points are specified, and describes the requirements for 16 documentation of process control instructions; 17 contains procedures that assure that only current and-18 properly released drawings, specifications, procedures manuals 19 and supplements are used by craftsmen, engineers and 20 inspectors; 21 establishes the requirements for the control and 22 identification of materials and components used in the 23 construction of structures and systems; 24 establishes the certification program for personnel i
25 performing special processes such as welding and mechanical 26 splicing of reinforcing steel; l -
l
/3 1
establishes the requirements for controlling special V
2 processes such as welding, heat treating, non-destructive 3
examination and cleaning; 4
establishes requirements for inspection of site work to I
5.
assure conformance with applicable designs, codes, standards 6
and specifications; 7
establishes the requirements for conducting and 8
documenting the tests of systems and structures during 9
construction; 10 establishes the requirements for the calibration of 11 measurement and test equipment used in construction activities 12 and for the documentation of those calibration activities; 13 establishes the methods for receipt inspection, proper 14 storage and field issue of equipment and materials which affect 15 quality; 16 establishes methods for identification, documentation and 17 resolution of items that do not conform to specifications, 18 drawings or procedures; establishes the methods to stop any work that is creating 19 20 a condition adverse to quality, establishes procedures to 21 correct a condition adverse to quality, and also establishes the 22 method for controlling and pennitting variations to design 23 drawings and specifications; and, defines the methods for establishing system or structure 24 25 boundaries,
tabulating items within these boundaries, 26 accumulating and filing QA documentation and for transferring i
27 systems or structures from the Construction Departz:,ent to the 28 Nuclear Production Department. _
l'
' The ~ Quality Assurance Department Quality Assurance Manual 2
(QA Department Manual):
3 establishes the requirements for the preparation, 4
- approval, and control of quality assurance procedures, 5
establishes training and qualification requirements for 6
department personnel, training requirements for auditors,
.7
- training, and certification requirements for inspectors, I
8 requirements for trend analysis,
and requirements for
)
9 regulatory reporting; i'
10 establishes the requirements for the department 11 independent audit program; 12 establishes the requirements for review of specifications 13 and procurement records and for surveillance of the 14 Engineering Department activities; 15 establishes the requirements for surveillance of Operations I
16 Division activities and Nuclear Production Department 17 activities,
includes procedures for the review of station l-18 procedures, quality assurance and quality control records, 19 inspection procedures, procurement documents and station 20 modifications; and, 21-establishes the requirements for evaluation of vendors, 22 including the requirements for audits and surveillance - of 23 vendors, and for the approved vendors list.
24 The Quality Assurance Department NDE Program Manual 25 establishes the requirements for qualification and training of NDE 26 inspectors.
It also provides procedures and acceptance criteria for
- 27.
..a-
~.
)
1 The Duke Power Company Quality Assurance Manual for ASME
[
.2 Code Work contains those specific requirements which implement the
-3 quality assurance program requirements of the ASME Boiler and 4
4 Pressure Code Section III.
5 Q.
DESCRIBE THE EVALUATIONS OR AUDITS PERFORMED ON THE
)
6-DUKE -QA PROGRAM BY ANY INTERNAL OR EXTERNAL GROUPS?
.7 A.
There are a number of different internal and external groups which 8
perform audits of the Quality Assurance Program.
Surveillance 9
activities are conducted by the Technical Services Group, primarily 10 directed at the Design Engineering Department Quality Assurance 11 activities.
The Operations Division and Projects Division conduct 12 surveillances of QA Program activities carried out by Quality 13 Assurance, Construction, and the. Nuclear Production Department.
I 14 These surveillances are documented and any discrepancies - are 15 reported to the appropriate management for corrective action.
16 The Audits Division of the Quality Assurance Department 17 conducts audits of all groups within Duke Power Company who i
18 perform activities covered by the Quality Assurance Program.
19 These audits are conducted by qualified lead auditors using 20 prepared checklists.
The audit reports are distributed to the 21 appropriate levels of management for any necessary corrective j
22 action.
The corrective action proposed is reviewed by the Audits i
23 Division then follow-up audits are conducted to assure that all 24 discrepancies have been properly resolved.
l 25 An. independent Corporate Quality Assurance Audit is 26 conducted at least annually by members of other quality assurance l
d 27 organizations and utilities which are part of the Joint Utilities 28 Management Audit Group.
These audits are conducted at the,
1 direction of the Executive Vice President Engineering and
]
2 Construction, who reviews these audit reports.
The Institute for 3
Nuclear Power Operations (INPO) will also be conducting 4
independent evaluations of the construction and design of the 5
Catawba Nuclear Station.
This evaluation will include aspects of 6
the Quality Assurance Program.
In October of 1982 a team of 7
personnel from Duke Power Company and the Tennessee Valley 8
Authority conducted a self-initiated evaluation using INPO criteria.
9 Duke Power Company is authorized to design and construct 10 nuclear power plant components under the authorization of the 11 American Society of Mechanical Engineers.
This requires that the 12 American Society of Mechanical Engineers conduct a survey of the 13 activities governed by the Duke Power Company Quality Assurance 14 Manual for ASME Code work. These surveys are conducted at least 15 every three years.
Resident Authorized Nuclear Inspectors (ANIS) 16 who are employees of the Hartford Steam Boiler and Insurance 17 Company are on the Catawba site and constantly audit the 18 implementation of the Quality Assurance Program as it relates to 19 ASME Section III activities.
In addition, there are resident NRC 20 inspectors at Catawba who review the implementation of the QA 21 program.
The efforts of the NRC resident inspectors are 22 frequently supplemented by inspectors from the regional office.
23 Discrepancies discovered by any of these methods of audit are
(
.24 promptly reviewed by appropriate levels of management and 25 corrective action plans are developed.
These plans include dates 26 for the implementation of the corrective action.
l l -
1 Q.
HAVE ANY OF THESE INTERNAL OR EXTERNAL AUDITS 2
CONCLUDED THAT THE QA PROGRAMS AT THE CATAWBA SITE 3
SUFFERED FROM SYSTEMATIC DEFICIENCIES OR SUFFERED A 4
PROCEDURAL BREAKDOWN WHICH MIGHT ADVERSELY AFFECT 5
THE IMPLEMENTATION OF THE QA PROGRAM?
6 A.
Many of these audits have pointed out areas where quality 7
assurance procedures are not being properly implemented and did 8
not contain requirements which were clear and precise enough.
In 9
previous positions I have held, I have been well aware of the 10 results of audits and evaluations of the Quality Assurance Program.
11 This program is of such a large scope and detailed nature that it is 12 not unusual to find deficiencies in program content and i
13 implementation.
It has been my experience with Duke Power 14 Company that these deficiencies have been of a nature that could be 15 corrected without major changes to the program.
I am not aware of 16 any audit that has indicated a breakdown of the QA Program of the 17 nature that would preclude the program working to assure that our r
18 plants are safely built and operated.
These audits and evaluations 19 have served to strengthen the QA program.
In all cases the 20 appropriate management personnel have reviewed the discrepancies 1
l 21 and developed corrective action plans.
This corrective action has 22 been properly carried out and has included the consideration for i
~
23
.needed corrective action on previously completed work and on work 24 locations other than the nuclear station where the discrepancy was l
25 discovered.
Many of these discrepancies have been identified by l
L O p
1 Quality Assurance personnel in the course of implementing the QA 2
Program.
Rather than demonstrating a breakdown of the program 3
this, in fact, demonstrates that the program is working.
4 Q.
ARE YOU FAMILIAR WITH THE 1981 SALP REPORT?
f 5
A.
I have seen the report.
This report covers the periods of
,o 6
construction of Catawba from September 1979 through August of 7
1980.
During that period of time I was assigned to the 8
Construction Department at the McGuire Nuclear Station and after 9
May of 1980 as Planning Manager of the Catawba Nuclear Station.
10 In those roles I was not specifically involved with the Quality 11 Assurance activities at the Catawba Nuclear Station.
12 Q.
THE SALP REPORT RATES THE CATAWBA PROJECT "BELOW 13 AVERAGE", BASES IN PART ON CRITICISM OF TIIE QA PROGRAM.
14 IN YOUR VIEW, DOES THIS SALP REPORT INDICATE THAT THERE 15 ARE SIGNIFICANT OR SYSTEMATIC DEFICIENCIES IN THE DESIGN 16 OR CONSTRUCTION OF CATAWBA?
17 A.
No.
My understanding of the way the NRC produced the SALP 18 Report in 1981 was to consider an unweighted numeration of 19 deficiencies.
This system gave little credit of the volume of work 20 being done.
It is also relevant that as each deficiency had been 21 presented to Duke by the
- NRC, the deficiency had been 22 satisfactorily investigated and corrective action performed.
The 23 NRC followed up on inspection of this corrective action and was 24 satisfied with the action in every case.
25 Q.
DOES IT INDICATE THAT THERE ARE SIGNIFICANT OR 26 SYSTEMATIC DEFICIENCIES IN THE QA PROGRAM?
O i
4 1
A.
No.
In the course of the design or construction of Catawba, each 2'
' deficiency was addressed at the time issued and was cleared to the 3
satisfaction of both Duke Power Company and the NRC.
4 Q.
WHAT IS THE BASIS FOR YOUR VIEW THAT THE SALP REPORT 5
DOES NOT INDICATE THAT THERE ARE SYSTEMATIC 6
DEFICIENCIES IN DESIGN AND CONSTRUCTION OR IN THE QA 7
PROGRAM?
8 A.
My view is based on the fact that as deficiencies were presented 9
they were cleared to the satisfaction of Duke Power Company and 10 the NRC.
Subsequent SALP Reports have not rated the Catawba i
11 Nuclear Station below average.
In fact, the 1983 SALP gives the 12 Quality Assurance Program the highest rating.
13 Q.
ARE YOU FAMILIAR WITH THE ACTIONS TAK".N BY DUKE POWER 14 IN RESPONSE TO THE VIOLATIONS THAT WERE THE BASIS FOR O
15 THE SALP EVALUATION?
16 A.
I know that in every case the violations were answered when 17 presented. After the SALP report was issued this was reverified to 18 the satisfaction of Duke Power Management.
In every case as the 19 violation was presented to Duke Power Company by the NRC l
20 corrective action plans were sent to the NRC and after corrective 21 action had been taken the NRC re-examined the area and closed the 22 issue.
Thus, the violations were resolved to the satisfaction of 23 both Duke Power Company and the NRC.
24 Q.
ARE THERE QA PROCEDURES UNDER WHICH EMPLOYEES MAY 25 RAISE CONCERNS OR OBTAIN MANAGEMENT REVIEW OF I
26 DECISIONS THEY DISAGREE WITH?
O
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1 A.
Yes, we have procedures in place in the QA Department to enable 2
employees to raise concerns of any kind, and obtain management 3
review of decisions they disagree with.
The philosophy of the i
4 Quality Assurance Department is that employee concerns should 5
receive thorough consideration and be addressed promptly.
The 6
first step in addressing an employee concern is usually discussion 7
between the employee and - his supervisor.
We encourage that
}
8 discussion, but recognize that it will not always resolve the 1
9 employee's concerns.
Therefore, a
number of management 10 procedures have been developed to allow the employee access to all 11 levels of management. within the Company to resolve his concerns.
12 In May of 1979, a company procedure covering employee i
13 recourse was implemented.
This procedure allowed an employee to 14 express concerns through successive levels of management to the 15 President of Duke Power Company.
In July of 1982 a supplementing i
16 recourse procedure was developed for Quality Assurance personnel.
17 In February 1981 the company implemented a management 18 procedure dealing with harassment of employees.
This new 19 procedure indicated how an employee should report incidents which 20 he believed to be harassment, and set forth how the facts would be 21 investigated.
In July 1982 the Quality Assurance department l
22 implemented a supplementing procedure.
The harassment procedure 23 could be invoked by an inspector or any employee, who was fearful 24 of carrying out his duties.
The Quality Assurance Procedure 25 outlines the investigation process that will be used when harassment 26 is reported or suspected.
It also contains disciplinary actions 27 which will be taken if prohibited conduct has occurred. Depending (
. =_
h 1
on the severity of the conduct amounting to harassment, there are i
V 2
progressive levels of discipline, up to and including dismissal.
3 There are times when arguments between employees are investigated 4
under the harassment procedure.
Arguments, which at times, could 5
become very heated are not within the scope of the harassment 6
procedure.
However, the Quality Assurance Department does not j
i 7
condone arguments and pursues the investigation to determine the 8
best way to prevent the situation from happening again in the 9
future.
We urge employees to -use these avenues of recourse if i
10 their concerns are not resolved with their supervision and will 11 assist an employee who desires to carry his concerns to levels of 12 management above the Quality Assurance Department.
13 The Construction Department instituted a
" Harassment i
14 Procedure" in September 1980.'
This procedure is very similar to 15 the one adopted by the QA Department in 1982.
Since the Quality i
16 Control Inspectors were part of the Construction Department in 1980 17 this construction procedure applied to them.
Prior to that time i
18 there was no specific harassment procedure which applied to the QC 19 inspectors.
The Construction Department had issued " Rules of 20 Conduct" in 1977 which spelled out actions and activities that were 21 not acceptable, including harassment.
22 Q.
WHAT RECOURSE PROCESS WAS AVAILABLE TO INSPECTORS 23 PRIOR TO IMPLEMENTATION OF THE 1979 COMPANY RECOURSE 1'
24 PROCEDURE?
25 A.
In 1977 the unwritten policy of recourse without reprisal was put in 26 writing in the Construction Department Personnel Policy and d
27 Practices Manual.
At that time, QC inspectors were in the i
l
-,.. -. _,,,,.. _ - - -,,,.,.,. ~,,, -. -,,
O 1-Construction Department.
Each supervisor was provided with a O
2 copy of this manual which was available for referencing use by his 3
-crew.
Since the quality control inspectors were members of the 4
Construction Department during this period this manual applied to i
5 them.
The Employee Relations Section of this manual contained the 6
procedure for informal and formal pursuit of concerns and 7
disagreements that an employee may have.
The informal approach 8
directed supervisors to make every effort to hear employees 9
promptly and attempt to clear up any misunderstandings that might 10 have arisen.
If a discussion with the supervisor did not promptly 11 resolve the problem the employee could pursue it to a higher level 12 of supervision.
If the problem was not resolved to the employee's 13 satisfaction by that approach he could :ik the Project Employee l
14 Relations Supervisor to help with a resolution to the problem.
If 15 resolution was not reached to the employee's satisfaction by that i
16 informal approach the employee could use a formal procedure which l
I 17
- included the provision to submit in writing the concerns to the i
1 l
l 18 Project Manager who would render a decision within 15 days.
If i
19 the employee was not satisfied with the decision at that t.tep the 20 complaint would be referred to the Vice President of Construction 21-for final determination and a decision would be given to the 22 employee in writing within 30 days after receipt of the complaint.
f l
23 Q.
WHAT IS THE QUALITY ASSURANCE DEPARTMENT'S POLICY AND 24 PRACTICE WITH RESPECT TO EMPLOYEE'S ACCESS TO THE NRC 25 TO EXPRESS ' CONCERNS OR RAISE TECHNICAL QUESTIONS.
26 A.
It has always been Duke Power's policy that all personnel have l
27 access to the NRC.
In April 1977, R. L. Dick, Vice President of 28 Construction,. posted a notice on bulletin boards which indicated >
- _ _, _ _ _. _ _ _. - _ _,. _..,. _,. _ _ _ _ _ _ _,. _,. _. ~. _
4 l
-1 that Duke Power Company expected employees to express any 2
concerns they might have about the quality of work to their i
3 supervisors and any level of company management.
In addition, the 4
notice directed any employee who has concerns or questions about 5
the nuclear safety of any facility to bring those matters to the l
6 attention of the NRC inspector or the nearest NRC Regional Office 1
l 7
if the concerns could not be resolved directly with the company.
l 8
In
- addition, NRC Form-3 is posted at prominent locations 4
9 throughout the project.
J l
10
.The offices of the NRC Resident Inspector on site are clearly 11 marked and are easily accessible to employees.
The office is 12 adjacent to the Unit II turbine building and can be entered from 13 the construction yard without first going through any company 14 reception.
15 In July
- 1981, the company implemented a
Management I
16 Procedure entitle
" Resolution of Technical Matters Involving 17 Differences of Opinion".
The purpose of this procedure is to give 18 due consideration to differing views of employees on technical l.
19 matters.
An employee can direct his concern in writing to his i
i 20 department head, who shall appoint a group of not less than three 1.
technically qualified individuals to review the issue.
The group 21 22 shall gather data, review the concerns, and made recommendations 23 leading to a resolution.
A written answer will be provided to the i
24 questioning employee.
If the employee is not satisfied he can take 25 his concern to the Executive Vice President, Engineering and 26 Construction.
In July 1982, the Quality Assurance Department O
l 27 implemented a supplementing procedure entitled "QA Department j
28 Quality Recourse Procedure".
The purpose of this procedure is to i '
i
. ~.. _.. _. _ _.... _.
f I
give employees within Quality Assurance an avenue to express 2
concerns about quality and technical concerns.
This procedure 3
enables an employee to take his technical concerns through 4
successive levels of management within the Quality Assurance 5
Department and if not satisfied, allows recourse to the Executive 6
Vice President.
7 Q.
DESCRIBE WHAT AN INSPECTOR DOES WHEN HE IDENTIFIES 8
WORKMANSHIP THAT DOES NOT CONFORM TO DUKE POWER QA f
9 PROCEDURES.
10 A.
If during a preplanned inspection an inspector finds workmanship 4
11 that does not conform to standards he withholds his acceptance of 12 that workmanship.
If the discrepancy is minor and can be readily 13 corrected he may inform a craftsmen or a craft supervisor of the 14 discrepancy.
After the craftsman corrects - the discrepancy the l
15 inspector reinspects the workmanship, and if acceptable, the 16 inspector accepts the workmanship and documents his acceptance in i
17 accordance with the' procedure he is using for the inspection.
I j
18 Some procedures have forms that contain both accept and i
19 reject sign-off points.
In this case, an inspector can use the 20 reject-block to identify workmanship that doesn't conform to 21 required acceptance standards.
Some procedures contain separate 22 discrepancy report forms which the inspector can use to record l
23 discrepancies. -
24 Quality Assurance Procedure R-2, Identification and Resolution i
25.
of Discrepancies, is used to identify discrepancies where governing 26 procedures do not offer a means to correct the problem.
In this 27 case the inspector will document the discrepancy on Form R-2A, the 28 discrepancy report.
40 l
!t
/
1 In situations where an inspector discovers unacceptable 2
workmanship at times other than during preplanned inspection, and 3
when no other inspection is planned which would identify the 4
discrepancy, then procedure Q-1, Control of Non-Conforming Items, 5
would be used to document the discrepancy.
6 In every situation I have described, after the discrepancy has l
7 been corrected a reinspection will be performed to assure that the 8
work conforms to required standards.
i 9
Q.
DESCRIBE THE ROLE OF QC AND QA SUPERVISION IN THE 10 RESOLUTION OF NONCONFORMING ITEMS.
11 A.
After the inspector has completed the description of the 12 non-conforming item and has obtained a serial number, he will j
13 present the non-conforming item report to a designated QA
- 14 Engineering Supervisor.
This individual will review the information 15 to be sure that the item is non-conforming, based on applicable 16.
procedures and therefore, requires processing under the Procedure 17 Q-1.
If the NCI is detennined to be unnecessary or improperly i
18 initiated, the reason shall be explained on the report and a copy 19 provided to the inspector.
The NCI is filed in the Quality i
20 Assurance Reports fues.
21 In the past, Quality Assurance Procedure Q-1 did not require 22 that unnecessary non-conforming reports be retained.
23 Nevertheless, the review was done by supervision in the same 24 manner as now required.
25 Q.
IS THERE ANYTHING IMPROPER OR INCONSISTENT WITH A 26 SOUND QUALITY ASSURANCE PROGRAM FOR A SUPERVISOR TO
_ l
1
. REVIEW AN NCI WRITTEN BY AN INSPECTOR AND VOID THE NCI i
l-2 BECAUSE IN THE SUPERVISOR'S JUDGEMENT, THE NCI SHOULD l
3 NOT 'HAVE BEEN WRITTEN?
4 A.,
There is no inconsistency with a sound QA Program for a
}
5 supervisor to void an NCI.that, in his judgment, is improperly i
6 initiated.
It is the role of a supervisor to interpret the quality
?
7 assurance procedures and make judgements in regards to acceptance 8
criteria.
Prior to clarification of the use of non-conforming items in 9
1982, non-confonning item reports were at times used to ask i
10 questions in regards to the acceptability of workmanship.
For i
j 11 example, there are times when the acceptance criteria is not clear i
12 in -its application to some specific workmanship.
There have been 13 cases where the inspectors have used a non-conforming item report 14, to obtain the necessary clarification, rather than pursue the
)
15 question through the proper organizational contacts.
This is an i
16 improper use of the non-conforming item report.
At times j
17 supervision would determine that these NCI's should not have been i
j_
18 written; at other times NCI's were written by inspectors who 19 misinterpreted the intent of procedures.
In these cases supervision t
20 was carrying out their responsibility in determining that NCI's i
21 should not be written.
They were using. their judgement to l
22 determine the proper. intent of quality assurance procedures.
Due j
23 to the general nature of some code acceptance requirements, Quality 1
I 24 Assurance procedures are written in.a conservative manner.
This 25 generally results in Quality Assurance procedure acceptance criteria 26 which exceeds code acceptance criteria.
This is particularly true 27 when code acceptance criteria are not numerical in nature.
These 1
28
- are generally the areas where supervision must exercise the 1
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1 responsibility to interpret the intent of acceptance criteria as 2
reflected in Quality Assurance procedures.
Audits conducted by 3.
the Audit Division of the Quality Assurance Department determine if 4
quality assurance procedures are being correctly implemented.
This 5
serves as a check to determine if supervisors are directing the 4
6 proper implementation of procedures.
7 Q.
WHAT OPTIONS ARE AVAILABLE TO A WELDING INSPECTOR WHO 8
BELIEVES THAT A SUPERVISOR HAS MADE AN INCORRECT 9
JUDGEMENT IN INSTRUCTING HIM TO VOID AN NCI7 10 A.
The Welding Inspector's first step is to discuss the matter with his 11 supervisor and explain to his supervisor why he believes that 12 supervision, has made an incorrect judgement.
The supervisor 13 should then discuss the matter with his supervision and determine I
14 if the judgement is correct.
The outcome of this discussion is 15 discussed with the inspector.
If this means of resolving the issue 16 is not successful the inspector should then use the Quality i
17 Assurance Procedure for Quality Recourses.
This will allow the i
18 disagreement to be put in writing and answers to be developed and 19 documented.
i 20 If the matter is not resolved prior to its reaching the 21 Corporate Quality Assurance Manager as outlined in the Recourse 22 procedure, then a review team of at least three qualified individuals 23 will be named by the Corporate Quality Assurance Manager.
This 24 team will thoroughly investigate the problem and document the i
]
25 results, which will be discussed with the inspector.
If this does 26 not resolve the issue then the inspector can take his concern to the i
27 Executive Vice President for final resolution.
If this pursuit of
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technical recourse through the company is. not successful the G
2 inspector should take the matter to the resident NRC Inspector or 3
call the Regional Office.
4 Q.
HAVE YOU BEEN INVOLVED IN THE PROCESS WHICH SETS THE 5
PAY CLASSIFICATION FOR INSPECTORS?
6 A.
Yes.
I was on a Non-Exempt Evaluation Team formed in 1977 to do l
7 the initial evaluation of all non-craft non-exempt jobs in the 8
Construction Department.
This included the inspectors who at that 9
time were part of the Construction Department.
I was also on a 10 Non-Exempt Evaluation Team formed in 1980 which reviewed the 11 evaluation of certain construction jobs including certain inspection j
12 jobs.
13 Q.
DESCRIBE WHAT HAS OCCURRED OVER THE YEARS WITH 14 RESPECT TO THE PAY CLASSIFICATION OF WELDING INSPECTORS 15 A.
Prior to February 1980 when a formal Construction Department 16 Non-Craft Wage Program was established, the wage rates for 17 specific inspection classifications were determined by site 18 management.
In February of 1980, a Non-Craft Non-Exempt Pay 19 Program was implemented with pay ranges based on the evaluation 20 of jobs using the Hay Associates evaluation method.
When this 21 program was implemented the welding inspectors pay was set at pay 22 grade 11.
In 1980 a new Non-Exempt Evaluation Committee was 23 formed.
This committee evaluated new and revised jobs using the 24 Hay Associates method.
In the summer of 1980, the committee 25 reviewed and evaluated a revised position analysis for welding 26 inspectors.
This review determined that both the know-how points j
27 and the problem solving points should be reduced.
The know-how 28 points were - reduced because of the position analysis no longer.
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I required that a welding inspector have at least two years of prior 2
welding or welding inspection experience.
The problem solving 3
points were reduced because the team determined that the thinking 4
challenge should be designated as selective memory rather than 5
interpolative.
This is consistent with an inspector's role which 6
requires that solutions to problems be bounded by the limits of the i
7 procedures which govern the inspector's actions.
This doesn't i
8 allow the inspectors to search out new solutions to problems. The 9
rating established for welding inspectors in 1977 was 320 points.
10 The 1980 rating for the Welding Inspector A position was 281 11 points.
This re-evaluation resulted in the movement in the pay 12 grade for Welding Inspectors from Grade 11 to Grade 10.
There 13 were other jobs in the Quality Assurance Department which were 14 affected by this evaluation process.
The Film Reader ' position was j
15 reevaluated from 341 points to 299 points.
This resulted in a pay 16 grade reduction from Grade 12 to Grade 11.
The Mechanical 17 Inspector A position was reevaluated from 225 points to 262 points, 18 which resulted in a pay grade increase from Grade 9 to Grade 10.
19 The Electrical Inspector A position was reevaluated from 228 points j
20 to 262 points, which resulted in a pay grade increase from Grade 9 21 to Grade 10.
These changes in pay grade were implemented at the 22 time of the July 1981 general salary increase.
At that time welding 23 inspectors, and film readers received one-half the general increase 24 to begin the process of moving their compensation to the proper 25 grade.
This process was completed after the general salary 26 increase of 1982.
O -.I
(Q 1
Q.
DID THE CHANGE IN THE REQUIREMENT FOR TWO YEARS V
2 WELDING OR WELDING INSPECTION EXPERIENCE FOR WELDING 3
INSPECTORS RESULT IN LESS QUALIFIED WELDING INSPECTORS?
4 A.
No.
The training, qualification, and certification requirements 5
remained the same.
6 Q.
WHEN DID YOU FIRST BECOME AWARE OF THE QUALITY OR 7
SAFETY CONCERNS EXPRESSED BY WELDING INSPECTORS AT 8
CATAWBA?
9 A.
I believe I first became aware of those concerns in January of 1982 J
10 at a staff meeting conducted by R. L. Dick.
At that time I was on 11 Mr. Dick's staff as Manager of the Oconee Station Support Division.
12 I believe that in the course of a staff meeting there was some 13 discussion of concerns being expressed by welding inspectors at 14 Catawba.
i i
i O
1 PART II U
2 Q.
WERE YOU INVOLVED IN THE MANAGEMENT DECISIONS TO 3
INITIATE THE VARIOUS TASK FORCE INVESTIGATIONS?
4 A.
The only task force that I was involved with at the initiation stage 5
was the Non-Technical Task Force.
6 Q.
DESCRIBE YOUR INVOLVEMENT WITH THE INITIAL TASK FORCE, 7
WHAT IS NOW REFERRED TO AS TASK FORCE I.
8 A.
I was not involved with members of the initial task force as they 9
carried out their duties.
This task force completed its work in 10 December 1981, prior to my transfer to the Quality Assurance 11 Department.
12 Q.
DESCRIBE YOUR INVOLVEMENT WITH THE TECHNICAL TASK 13 FORCE.
14 A.
My initial involvement was to assure that a good working interface
{
15 was established between the task force and personnel within the l
16 Quality Assurance Department.
After the task force determined its 1
17 course of action I was involved with Parks Cobb, the Task Force l
18 Leader, in meetings with welding inspectors and other supervision 4
j 19 at Catawba Quality Assurance to present the planned course of i
20 action that the task force would undertake.
21 Q.
DESCRIBE YOUR INVOLVEMENT WITH LEWIS ZWISSLER OF 22 MANAGEMENT ANALYSIS COMPANY.
i 23 A.
As Lewis Zwissler carried out his duties of independently monitoring 24 the work of the Technical Task Force, he reviewed the status of
- 5 his investigation with me.
I made sure that Mr. Zwissler had free 26 access to all individuals within the Quality. Assurance Department in 27 order to allow him to. conduct his investigation in a thorough and 28 proper manner.
Mr. Zwissler made some recommendations during
i l
1 the period of his investigation.
For example, he recommended that 2
we approve a procedure which would allow prompt changes to 3
Quality Assurance Procedures where the intent of the procedure is 4
unclear.
He based this recommendation on interviews he conducted 5
with inspectors and supervisors,
having determined that our 6
inability to make changes to procedures promptly or expeditiously 7
was causing inspectors problems in the field.
As a result of that 8
recommendation by Mr. Zwissler, we approved a Quality Assurance 9
Procedure that allows the Corporate Quality Assurance Manager to 10 make a supplemental change to Quality Assurance Procedures very 11 quickly.
12 After the Mar,agement Implementation Plan had been developed 13 and we had substantially completed implementation of the Technical 14 Task Force' recommendation, I requested that Mr. Zwissler review 15 our implementation efforts.
Mr. Zwissler reviewed our work and 16 submitted a brief report in August of 1982.
This report contained 17 recommendations which were considered for follow up.
18 Q.
DESCRIBE YOUR INVOLVEMENT WITH THE NONTECHNICAL TASK 19 FORCE.
20 A.
After the Technical Task Force determined that some concerns were 21 of an administrative nature, I determined that someone with a 22 personnel administration background would be better suited to 23 investigate those concerns.
I asked C. N. Alexander, who at that 24 time was Personnel Manager for the Mount Holly Station Support 25 Division of the Construction Department, and D. L. Powell who was 26 the Supervisor of Employee Relations for the Construction 27 Department at the Catawba Nuclear Station, to serve as a Task 28 Force to investigate the non-technical concerns of welding -
4
./
1-inspectors.
This task force began its work early in February of 2
1982.
3 Q.
HOW WERE THE NON-TECHNICAL CONCERNS DIS".'INGUISHED 4
FROM.THE TECHNICAL CONCERNS?
5
'A.
The members of the non-technical task force reviewed the concerns 6
.-written by the inspectors.
Any concerns expressed that were 7
not tied to a piece of physical work in the plant, the resolution of 8
an NCI, or the implementation of a QA procedure were considered 9
to be non-technical.
Some specific-concerns were dealt with 10 individually, while most non-technical concerns were placed in one f
11 of several general categories.
12 Q.
WERE YOU INVOLVED IN THE IMPLEMENTATION OF 13 RECOMMENDATION ISSUES BY ANY OF THE TASK FORCES?
4 14 A.
Yes.
I was involved 'in the implementation of recommendations of 15 the Technical Task Force and the Non-Technical Task Force.
I 16 Q.
DESCRIBE YOUR ROLE IN IMPLEMENTING THE RECOMMENDATION 17 OF THE TECHNICAL TASK FORCE, INCLUDING YOUR ROLE IN 18 THE DEVELOPMENT OF THE MANAGEMENT IMPLEMENTATION PLAN 19 USED TO IMPLEMENT THE RECOMMENDATION OF THE TECHNICAL 20 TASK FORCE.
l 21 A.
After the task force had developed their recommendations, they were submitted to me for my review.
A Management Implementation 22 23 Plan was developed. by me and 'several QA Department Division l
'24 Managers.
A copy of the plan is Attachment 3 to my testimony.
i 25-This plan included appointment of an Implementation Coordinator i
i 26 and. a ' number of implementation objectives which covered the 27 programmatic and general recommendations of the task force.
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1 This implementation plan was reviewed with Mr. Owen and the V
2 Vice Presidents of Construction and Design Engineering.
Mr. W.
3 H.
Bradley was named Plan Implementation Coordinator.
He 4
developed a documentation format for each action to be performed.
5 The assignment for each specific action recommendation was placed 6
on a separate documentation sheet.
A specific individual in the 7
Quality Assurance Department, Construction Department, or Design 8
Engineering Department was assigned to carry out the action.
This 9
individual documented the action that was carried out and submitted 10 it to the responsible Department Head for approval.
As Corporate 11 Quality Assurance Manager, I reviewed the action carried out on 12 each of these specific action recommendations.
The Implementation 13 Coordinator, Mr.
- Bradley, verified that each specific action 14 recommendation had, in fact, been implemented.
This Management 15 Implementation Plan was communicated to all inspectors who raised 16 concerns and to supervision in the Catawba Quality Assurance 17 organization.
18 Q.
DESCRIBE THE IMPLEMENTATION OBJECTIVES DEVELOPED TO 19 IMPLEMENT THE TECHNICAL TASK FORCE RECOMMEND ATIONS.
20 A.
The Technical Task Force submitted programmatic recommendations 21 in various areas such as process control, welding inspection, NCI 22 resolution, design drawings and material control.
There were 15 23 implementation objectives developed to carry out the implementation 24 of these programmatic recommendations.
These implementation 25 objectives can be categorized as follows:
26 1.
Clarify policy procedures or methods.
Examples are:
Ah 27 clarify the policy concerning verbal and written instructions and 28 resolution of disagreements; clarify the policy on handling process - - - - _
1 control discrepancies; and clarify the method of handling NCI's that 2
have resolutions that are questioned.
3 2.
Review or verify the adequacy or effectiveness of 4
methods and procedures.
Examples are:
consider the adequacy of 5
the documentation checking process; assure all marking 6
requirements are valid; and determine the most effective use of 7
workmanship samples.
8 3.
Training.
Examples are:
continued training on proper 9
NCI resolutions; training of QA and QC personnel on the roles of f
10 supervisors, inspectors and QA technical support personnel in 11 regards to writing and reviewing NCI's ; and training of QC 12 personnel in the roles of supervisors and inspectors in general 13 inspection duties.
14 4.
Miscellaneous items.
Examples are:
assuring that QA IS supervision is involved in the review of inspection procedure 16 change proposals; and investigation of the standardization of weld 17 symbols in des'ign documents.
18 As previously noted this implementation plan is attached to my 19 testimony as Attachment 3.
4 20 Q.
DESCRIBE THE ACTIONS TAKEN TO IMPLEMENT THESE 21 OBJECTIVES.
22 A.
The actions taken can best be summarized by looking at the t
23 categories of programmatic recommendations made by the Task 24 Force.
25 In the area of process control, a thorough review of process l
l 26 control procedures and practices was carried out.
This review 27 concluded that generally the process control procedures are very 28 adequate and the process in well understood by those individuals _
i 1
responsible for implementing those procedures.
Implementation 2
objectives in this area did result in the establishment of periodic 3
meetings between individual disciplines within QA, Crafts and 4
Construction Technical Support for the purpose of reviewing 5
problems in using process control procedures.
These meetings are 6
held at least every six months and include inspection supervision.
7 In the area of welding inspection, the implementation objectives 8
resulted in a number of enhancements to our program.
A program 9
within the Technical Services Division of Quality Assurance called 10
" Train the Trainer" was implemented.
The essence of this program 11 is that the individual with the Technical Services Division 12 responsible for incorporating comments into a
proposed QA 13 procedure revision will conduct a training session with supervision 14 who will be implementing the procedure.
This training session will i
15 cover the intent of the procedure revision.
This program has 4
16 worked very well and allows supervisors to answer many questions 17 their employees have about procedure revisions and procedure 18 intent.
We also developed a policy on how questions would be 19 answered by supervisors concerning procedure inte tn.
This l
20 included the method of documenting answers received from 21 appropriate individuals in Quality Assurance, Design Engineering or 22 Construction.
Workmanship samples had been made up to assist 23 welding inspectors and supervisors in visualizing the acceptance l
24 criteria cannot easily be described in words.
A video tape, "The 25 Inspector," which explained the roles of supervisors and inspectors 26 in carrying out their duties was produced.
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'In the.ar,e'a of NCI resolutions Procedure Q-1 was revised to 1
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make the handling of voided NCI's very clear.
This change 3-required the filing of any voided NCI's.
4 In the area of design drawings, training was conducted by 5
Design Engineering to highlight the importance of good drafting 6
techniques to eliminate drawing clarity problems.
4 7
In the area of material control Quality Assurance Procedures 8
H-4 and H-5 which cover the marking requirements for structural 9
steel and piping materials, were revised to reflect their applicability 10 to QA Condition 1 and QA Condition 4 work only.
11 I have included in my testimony as attachment 4 a complete 12 summary of actions taken on the Technical Task Force Programmatic 13 Recommendations.
I 14 Q.
THE TECHNICAL TASK FORCE IDENTIFIED 24 POTENTIAL 15 TECHNICAL INADEQUACIES.
WERE TifESE
' POTENTIAL 16 INADEQUACIES EVALUATED?
17 A.
Each of these potential technical inadequacies was investigated in 18 the course of carrying out the specific action recommendations.
j Welds and other work identified as concerns by welding inspectors 19 20 were rechecked.
In all cases the existing work was found to meet 21 Design Engineering requirements.
In one case the initial resolution 22 of a wall thickness concern was resolved by adding weld material.
23 This was done as a cost effective method of resolving the particular 24 concern.
Design Engineering later evaluated the concern and 25 determined that the 29/1000 reduction in wall thickness that
(
26 originally existed would not have been of any nuclear safety or 27 structural significance, and need not have been repaired.
The.
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1 conclusion to each potential technical inadequacy was that no 2
technical inadequacy existed.
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3.
Q.
DESCRIBE THE ACTIONS TAKEN TO IMPLEMENT Tile 4
RECOMMENDATIONS OF THE NON-TECHNICAL TASK FORCE.
5 A.
. Specific action recommendations were carried out by Mr. Neal i,
6 Alexander, the Non-Technical Task Force Implementation 7
Coordinator and completed in April of 1982.
8 The following actions were taken as a result of general 9
recommend'ations of the Non-Technical Task Force.
In the area of 10 -
work direction, a vide; tape, "The Inspector" was produced which 11 explained the role of the inspectors and the supervisors in carrying 12 out their duties.
A number of items designed to develop a 13 teamwork spirit in the department were carried out.
These 14 included a ctandardized hardhat color for all Quality Assurance 15 personnel and a department logo which is displayed on the hardhat.
16; A department newsletter was begun, a Quality Circle Program was 17 started, and an Employee Forum Program was started, which allows 18 employees to per.odically get together with their second line 19 supervision to discuss any issue that they would care to.
20 In the area of recourse, in July of 1982, departmental 21 procedures supplementing company procedures were implemented to i
22 cover administrative recourse,. quality recourse and harassment.
23 In the area of qualifications, the video tape described under c24 L work direction contained guidance to the inspectors -as to the kind
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p 25 of instructions that they can properly give Craft personnel.
26 Finally,. in. the area. of communications, all QA supervisors at-27 Catawba were. trained in effective communications skills.,
1 Q.
HOW WOULD YOU DESCRIBE THE PRIMARY CONCERN OF THE 2
WELDING INSPECTORS?
3 A.
I believe that the primary concern of the welding inspectors was 4
their ability to carrycut their job correctly as they understood their 5
responsibility.
A practice had developed at the Catawba ' Nuclear 6
Station which involved interpreting Quality Assurance Procedures, 7
as well as other procedures, quite literally.
The procedures as 8
written could not cover every specific situation that would arise in 9
the course of inspection activities.
This is not an unusual 1
10 situation.
National standards and codes, such as the American 11 Society of Mechanical Engineers Boiler and Pressure Vessel Codes, 12 contain standards that require interpretation.
The inspectors were 13 uncomfortable with the interpretations of procedures made by 14 supervision.
Management had not done a good of explaining to supervision the necessity of being very clear when explaining their 15 16 judgement to inspectors who raised questions.
In some cases the 17 supervisor reached his conclusion about a question and instructed i
18 the inspector to accept a certain situation.
The supervisor did not 19 pursue the matter strongly enough with the inspector to determine 20 if the inspector agreed with the conclusion.
In these cases the 21 inspector felt that he was being asked to accept something that ne 22 didn't fully agree with.
The concerns expressed by the inspectors 23 have allowed us to examine our methods of communicating the intent 24 of procedures to supervisors and inspectors.
That interface has 25 been strengthened and communications are being carried on in. a 26 more positive manner.
The supervisor is now vey careful to 27-explain his judgement to the inspector, and in particular not ask an
. 28
. inspector to sign off anything that the inspector does not agree. -, -. -,.. -
1 (3
1 with.
If an inspector is not satisfied with his supervisor's V
2 judgement the supervisor is to assist the inspector with a resolution 3
of that concern.
4 QA Department management recognizes the potential for conflict 5
between craftsmen and inspectors in the course of carrying out 6
their duties.
On occasion there will be disagreements between the 7
inspectors and craftsmen which can result in arguments.
We have 8
provided training and guidance to inspectors and QC supervisors on 9
how to handle these kinds of situations. Further training in human 10 relations skills is planned in the future.
We do not expect to 11 eliminate the potential for these confrontations, but rather to 12 instruct inspectors and their supervisors on the proper way to 13 handle confrontations when they occur. A key part of this training O
deals with how an inspector can maintain a firm position and not be 14 15 drawn into an argument that may result in any intimidating action 16 by the craftsmen or by the inspector.
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Q.
ARE YOU AWARE OF ANY OTHER GENERAL CONCERNS OF THE U
2 WELDING INSPECTORS?
3 A.
Yes, some of them have alleged that the lack of opportunity for 4
promotion or transfer is a concern.
5 Q.
IS THIS A SOUND ALLEGATION?
6 A.
No.
Promotions in, and transfer out, of the welding inspecting 7
organization have not been very frequent.
With respect to 8
promotions, this is because many of the inspectors have been with 9
us for a long time and thus have reached the top of their pay 10 classification.
Newer members of the organization progress up the 11 pay - scale at a rate similar to inspectors in other areas of the QA 12 Department.
Due to Duke's present construction plans, promotional 13 opportunities are very limited.
With respect to transfers, present 14 work level essentially precludes making inspectors available for 15 transfer.
16 Q.
THE CONCERNS EXPRESSED BY THE WELDING INSPECTOR WERE 17 INITIALLY CHARACTERIZED AS CONCERNS AFFECTING THE 18 QUALITY OF WORK OR THE SAFETY OF THE CATAWBA PLANT.
19 IN YOUR VIEW, DID THE CONCERNS EXPRESSED BY THE WELDING 20 INSPECTORS AFFECT THE QUALITY OR THE SAFETY OF THE 21 CATAWBA PLANT.
l l
22 A.
After investigation of the concerns, I can clearly conclude that 23 none of the concerns, in my view, bring into question the quality 24 of construction and the ability of the Catawba Nuclear Station to 25 operate in a saf e manner. In each instance where an inspector was l
26 concerned with a specific physical characteristic of the plant, the
1-I concern was investigated, and it was determined that each physical 2
characteristic fell within the applicable design requirements.
I 3
Q.
IN YOUR VIEW, DID THIS EXPRESSION OF CONCERNS BY THE g
4 WELDING INSPECTOR INDICATE THAT THERE WAS A BREAKDOWN 5
IN THE QA PROGRAM AT CATAWBA OR THAT THE QA PROGRAM 6
WAS NO LONGER WORKING AT CATAWBA?
7 A.
No.
The QA program has continued to work throughout the 8
construction phase of the Catawba Nuclear Station.
It is very l
9 evident that welding inspectors, as well as other inspectors, have 10 continued to carryout their responsibilities of inspecting designated 11 workmanship to assure that it meets required standards.
The 12 concerns did indicate a need to clarify procedures, a need to 13 assure better communications was taking place between supervision 14 and inspectors, and the need to explain more fully answers that O
15 were given to inspectors in response to questions that they have 16 raised.
17 Q.
DID CONCERNS EXPRESSED BY WELDING INSPECTORS INDICATE 18 COMPANY PRESSURE TO APPROVE FAULTY WORKMANSHIP?
19 A.
Concerns expressed by the Welding Inspectors indicate that on 20 occasion they were told to sign-off work which they did not feel 21 fully complied with specifications.
We have dealc with this issue 22 and have made it clear to supervisors that they are not to ask any 23 inspectors to sign-off any work which they do not view as totally 24 ceceptable.
This - situation does not indicate any pressure by the 25 company to approve faulty. workmanship. All examples of welds and 26 other work sited by inspectors were investigated and.no work was found to be faulty.
This indicates that supervisors' judgements.
27
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28 were ' correct!in. directing inspectors to accept certain items.
The l
29
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1 guidance given to supervisors and inspectors should elinunate 2
misunderstandings of this type in the future.
3 4
5 6
I hereby certify that I have read and understand this document, and 7
believe it to be my true, accurate and com ete testimony.
1
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11 G. W. GYier
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12 13 14 Sworn to and subscribed before me 15 this J3 day of September,1983.
9 r6t1~D w o
19 Notary Public 20 My Commission Expires Sept. 24,1985 21 Commission Expires O..
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- ' ICE PMSIDENT VICE PRES 80ENT VICE PRESIDEN T 900ft T HE RN CENTRAL WESTERN Of'a TRied TIOst illANSMISSION
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. Attachment 3
/O 9.0 MANAGEMENT IMPLEMENTATION PLAN G
The following implementation steps will be taken:
(1) Assign an implementation coordinator with the following duties:
a.
Assure that all specific action recomendations are assigned to appropriate individuals and have target dates for completion.
j i
b.
Assure that all implementation objectives are assigned to appropriate individuals and have completion dates for final-izing implementation detaiis and for completing action.
c.
Collect documentation of all implementation action.
(2) The recomendations of the Task Force are based solely on specific concerns of individuals.
Those persons assigned to carry out this implementation plan must be sure that specific recommendations are reviewed for action based on the specific concerns. They must also determine how general and programatic recomendations relate to needs broader than the individual concern raised.
(3) General recommendations and programmatic recommendations that are implemented will be based on the following objectives:
O a.
Clarify policy covering:
V 1.
Verbal instructions and inquiries 2.
Written instruction and inquiries 3.
Resolution of disagreements, including signoff responsibility 4.
Recourse for quality concerns This objective speaks to Process Control Recommendations no.1 and no. 5 and Welding Inspection Recommendations no. 2, no. 3 and no. 5.
b.
Consider adequacy of documentation checking process.
This speaks to Process Control Recomendation no. 2.
c.
Clarify policy on handling process control discrepancies.
l This speaks to Process Control Recomendations no. 2 and no. 5.
d.
Put in place an appropriate discrepancy tracking and feedback program.
Including review sessions for non-NCIR discrepancies.
l This speaks to Process Control Recomendations no. 3 and no. 4.
e.
Continue emphasis in training on proper method of NCI resolutions.
(3 (m)
This speaks to NCIR Resolution Recomendations no.1 and no. 3.
f.
Train QA and QC personnel on roles of supervisors, inspectors and QA technical support personnel in writing and reviewing NCI's for clarity of statement and validity as well as general inspection duties.
^
^
A 9.0 MANAGEMENT IMPLEMENTATION PLAN (continued)
This speaks to NCIR Resolution Recomendation no. 2 and Welding Inspection no. 6.
g.
Clarify method of handling NCI's that have resolutions that i
_are questioned.
This speaks to NCIR Resolution Recomendation no. 3G.
h.
Assure that QC supervision is involved in inspection procedure change review.
This speaks to Welding Inspection Recomendation no.1.
i.
Clarify methods for review of inquiry responses for use in training and in procedure review.
This speaks to Welding Inspection Recommendation no. 1 and Material Control Recommendation no. 2.
j.
Detemine most effective use of workmanship samples.
This speaks to Welding Inspection Recomendation no. 4.
l k.
Assure all marking requirements are valid.
This speaks to Material Control Recomendation no.1.
1.
Review methods for handling material marking discrepancies.
This speaks to Material Control Recomendations,no.1 and no. 2.
m.
Standardi::e welding symbols in design documents.
This speaks to Design Drawing Recomendation no.1.
n.
Assure that adequate training and incentives are in place for Crafts to do quality work.
This speaks to Process Control Recomendation no. 6.
o.
Investigate simplifying, including the separation of administrative direction from, certain QA procedures such as F-9, M-4, and M-51 This speaks to general recomendations no.1 and no. 2 (4)
Implementation action will be reviewed for completenes's by s
Department Heads.
{.
- Attachment It e
l ACTION TAKEN QN l
WELDING INSPECTOR TASK FORCE PROGRAMATIC - RECOMMENDATION'S l
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PROCESS CON 1ROL RECOMMENDATION #PC-1 RECOMENDATION ACTION 1)
Review existing Process Control procedures to insure adequacy for resolving Process Control conflicts, for noting when Process Control is not required, and for noting when verbal instructions are acceptable.
- Also, insure adequacy for unusual work situations.
Review existing Processing Control procedures to QA Procedures F-9, M-51, M-19 were reviewed.
Each insure adequacy for resolving Process Control procedure contains instructions for making conflicts, corrections to process control documents (minor or major).
for noting when Process Control is not required, The procedures specify when process control is required.
If process control is not required for a particular case the procedure would specify; however, no cases could be identified that need clarification.
and for noting when verbal instructions are Instructed inspectors not to accept verbal instruction if he felt they were wrong or violated acceptable.
t procedures, t
- Also, insure adequacy for unusual work These QA procedures provide a mechanism (in the s i tuat. ions.
form of F-9B or M-19C) for specifying unusual process control requirements.
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9 91 4-
i-1 PROCESS CONTROL RECOMMENDATION #PC-2 RECOM4ENDATION ACTION l
2)
Review existing Process Control documentation to l
insure specific instructions are provided on how l
to complete forms and that procedures for handling discrepancies on forms are clear and specific.
Consider whether present written methods for documenting and reconciling documentation discrepancies are adequate.
Consider the use of examples of documentation discrepancies and how they should be resolved.
Insure that guidance is provided to indicate when
}
discrepancies are acceptable.
Consider
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additional training of personnel in resolving discrepancies with documentation.
Review adequacy of documentation checking process.
Review existing Process Control documentation to Construction procedures contain specific insure specific instructions are provided on how instructions for completing forms.
Refer to CP-42, i
to complete forms 427, 351, 144, 17, 432, 313.
i and that procedures for handling discrepancies on QA procedures F-9, M-51, M-19 contain clear j
forms are clear and specific.
instructions.
Refer to QAP F-9, par. 5.2.H QAP M-51, par. 4.2.2 l
QAP M-19, par. 4.3.C l
Consider whether present written methods for Discrepancies are documented in accordance with QA documenting Procedures R-2 or Q-1 unless the concern is a question which is handled verbally, and reconciling documentation discrepancies are Discrepancies are reconciled through use of QA i
adequate.
Procedures R-2 or Q-1.
When discrepancies are
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identified verbally the reconciliation is by means of qualified personnel revising the process control instruction IAW F-9, M-51, M-19.
9 O2 4
n, u a.
P:ge 2 REC 0t#1ENDATION ACTION Consider the use of examples of documentation Discussions with site personnel indicated a high discrepancies and how they should be resolved.
level of understanding of the QA procedure requirements.
No need for examples was indicated.
Insure that guidance is provided to indicate when There is no provision for acceptable discrepancies.
discrepancies are acceptable.
The discrepancies identified are resolved through provisions of the QA procedures referenced above.
Consider additional training of personnel in Instructions ad implementation of instructions are resolving discrepancies with documentation.
considered adequate.
Need for training is continually monitored through trending of R-2As, QA-1A, and by HRC resident inspections.
Review adequacy of documentation checking An extensive analysis of the process control system process.
at Catawba was undertaken.
The results of this analysis showed the system to be adequate with supporting procedures giving accurate information, process control issuers and Seckers adequately trained and motivated to perform their jobs adequately.
O Oa 0
PROCESS CONTROL RECOMENDATION #PC-3 i
RECOMENDATION ACTION l
3)
Review the adequacy of tracking methods for l
monitoring Process Control procedural and documentation problems.
Review methods for feeding back results from such monitoring into procedures and personnel performance evaluations.
Consider whether present methods for documenting this activity are adequate.
Review the adequacy of tracking methods for All process control discrepancies are recorded as monitoring Process Control procedural and R-2A's or NCI's.
This method is considered documentation problems.
adequate.
Review methods for feeding back results from such All R-2A's and NCI's are reviewed for adverse monitoring into procedures
- trends, which may require procedure revision.
and personnel performance evaluations.
All R-2A's and NCI's are reviewed for adverse trends.
Such trends may require personnel action.
Consider whether present methods for documenting The present methods are considered adequate.
this activity are adequate.
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e
l PROCESS CONTROL RECOMENDATION #PC-4 l
t RECOMENDATION ACTION 4)
Review adequacy of any existing, periodic review programs held with Construction and QA personnel for purposes of reviewing problems and progress in using Process Control procedures. Consider I
using such sessions to emphasize the importance of closely following procedures.
Review adequacy of any existing, periodic review Reviewed this area and found no review programs programs held with Construction and QA personnel existed.
for purposes of reviewlog problems and progress in using Process Control procedures.
Consider using such sessions to emphasize the Action was taken to establish periodic meetings by importance of closely following procedures.
discipline with QA, Crafts and Construction Technical Support for a period of 6 months for the purpose of reviewing problems in using Process Control procedures.
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PROCESS CONTROL REC 0ffiENDATION #PC-5 RECOMMENDATION ACTION 5)
Review with appropriate site personnel (QA and Construction) the organizational responsibilities and authority for resolving Process Control
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conflicts, discrepancies, and omissions.
Insure functional adequacy of in place procedures.
Review with appropriate site personnel (QA and Through discussions with site personnel, and review Construction) the organizational and individual of QAP's F-9, M-51, and M-19 it was clear that responsibilities and authority for resolving these responsibilities were well understood.
Process Control conflicts, discrepancies, Same.
and omissions.
Same.
Insure functional adequacy of in place Construction procedures and QA procedures are procedures.
adequate in this regard, any discrepancies are resolved in accordance with QA procedures R-2 or Q-1.
PROCESS CONTROL RECOMMENDATION #PC-6 RECOW4ENDATION ACTION 6)
Construction supervision should consider use of stronger incentives to insure craf t adherence to procedures.
Also, consider review and adequacy of V-1 training program.
Construction supervision should consider use of Policy was instituted where procedural violations stronger incentives to insure craft adherence to are reviewed for possible disciplinary action.
procedures.
i Also, consider review of adequacy of V-1 training An outside consultant has been hired to determine
- program, training needs.
This study has been completed and recommendations will be implemented - beginning January 1983.
9 97 9
WEtDING INSPECTION #WI-1 l
RECOMMENDATION ACTION I
1)
Review the present process used to review changes to QA Procedures before they are implemented.
Consider adequacy of present communication of intent as well as specific instructions.
Insure that technical terms are defined in procedures and training sessions.
Consider adoption of a written commentary as part of certain procedures to insure clarity and for later reference on intent.
Insure appropriate review by QA, Technical Support and Craft personnel.
Review the present process used to review changes Process requires changes to be sent to each site to QA Procedures before they are implemented (both QA and Construction management) unless jointly agreed by Vice President Construction and Corporate QA Manager.
Consider adequacy of present communication of In some cases intent was not adequately intent as well as specific instructions.
communicated.
We have undertaken a program where procedures writers brief trainers on intent and then review implementation of the procedure to ensure intent is understood.
Insure that technical terms are defined in Technical terms are defined in procedures when procedures and training sessions.
necessary and training sessions include definitions.
Consider adoption of a written commentary as part Briefings described above will result in " minutes" of certain procedures to insure clarity which will be distributed to trainers.
and for later reference on intent.
These minutes will be kept in procedure history file in QATS.
Procedures are sent to Projects for review.
Site Construction and QA Managers distribute for comments as they see fit.
8
- WI-1 Pcge 2 RECOMMENDATION ACTION Insure appropriate review by QA, Technical Required routing of all proposed procedure Support and Craft personnel.
revisions to appropriate inspection supervisors for review and conment. All proposed revisions to QA procedures have traditionally been routed to Tech-nical Support for review and consnent.
If Technical Support feels that craft input is desirable is sought from appropriate craft supervision.
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WELDING INSPECTION #WI-2 RECOMENDATION ACTION 2)
Review with inspector supervisors their responsibilities and practices in providing verbal response to inspectors on technical questions and issues.
Insure that verbal responses are provided for the proper scope of work in that the basis for responses is clearly communicated.
Such basis should include reference to specific existing procedures, specifications, or other basis for decisions.
Use of judgement should be limited to those areas not specifically addressed in procedures.
Review with inspector supervisors their Instructed supervisors as to when they could give responsibilities and practices in providing verbal instruction and how to determine if they verbal response to inspectors on technical shq,uld give answer or refer it to others.
questions and issues.
Insure that verbal responses are provided for the All supervisors were instructed in training proper scope of work in that the basis for sessions.
response is clearly communicated.
Such basis should include reference to specific All supervisors were instructed in training existing procedures, specifications, or other sessions.
basis for decisions.
I l
Use of judgement should be limited to those areas All supervisors were instructed in training not specifically addressed in procedures, sessions.
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WELDING INSPECTION #WI-3 REC 0691ENDATION ACTION 3)
Review with inspectors their responsibilities and practices in signing off work.
Insure clear understanding that they are responsible once work has been signed off and that items which are not acceptable should not be signed of f, regardless -
of opinions of others.
Review appropriate and inappropriate methods for documenting input of others.
Insure understanding of acceptable methods and personnel from which assistance and guidance should be obtained.
Insure adequate use of available alternative inspection techniques for questionable items.
Review with inspectors their responsibilities and All inspectors were instructed when not to sign -
practices signing off work.
when they felt it wasn't right regardless of verbal instructions.
Insure clear understanding that they are All inspectors were trained and understand this responsible once work has been signed off responsibility.
and that items which are not acceptable should All inspectors were specifically instructed in this not be signed off, regardless of opinions of regard.
Others.
Review appropriate and inappropriate methods for Instructed supervisors their input would be signing documenting input of others.
if qualified.
Also developed flow chart of getting answers or questions that covered how other input would be obtained and documented.
Insure understanding of acceptable methods All supervisors were trained on how to get information and how to use it.
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- WI-3 Page 2 REC 0fMENDATION ACTION and personnel from which assistance and guidance A
flow chart established how and from whom should be obtained.
assistance and guidance should be obtained and communicated and this was communicated to all inspectors.
Insure adequate use of available alternative Instructed supervisor to use alternative inspection inspection techniques for questionable items, techniques to help resolve questionable items.
l 9
9 9
12
4 WELDING INSPECTION #WI-4 RECOMMENDATION ACTION 4)
Consider the use of workmanship samples or pictures to illustrate the difference between acceptable and unacceptable work, especially on items which are somewhat judegemental or on which regular or periodic high volume of NCIR's occur.
Consider the use of workmanship samples or We are developing these samples in structural steel pictures to illustrate the difference between and piping welds.
Samples will be accompanied by acceptable and unacceptable work, especially on implementing procedure.
items which are somewhat judgemental or on which regular or periodic high volume of The samples will include these items as need is NCIR's occur.
identified, based on input from Construction.
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WELDING INSPECTION #WI-5 RECOMMENDATION ACTION 5)
Provide a
resource (example:
Level III Inspector) to resolve conflicts and discrepancies in welding inspection on the spot.
Provide means for appropriate documentation of his actions.
Provide a
resource (example:
Level III Since Duke has only 1 Level III in each discipline Inspector) to resolve conflicts and discrepancies and this is specifically done to avoid different in welding inspection on the spot.
methods because of multiple Level III's, and that multiple levet III's are not available; the approach taken was to clarify how the existing Level III should be utillized.
This was done through flow path development and training.
Provide means for appropriate documentation of Development of flow chart above did this along with his actions.
instructions to inspectors not to sign if they felt it was wrong.
Proper method for Level III to document his action would then be to sign himself for action if inspector disagreed.
Inspector then would have recourse right under the Technical Recourse procedure.
4 1
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WELDING INSPECTION #WI-6 RECOMENDATION ACTION 6)
Review with inspectors the scope of their responsibilities and the part they play in the overall process of insuring quality.
Insure that they understand that responsibility is shared with their supervision and upper management and does not totally rest with them.
Review with the inspectors the scope of their This item was specifically addressed in training responsibilities and the part they play in the sessions conducted in accordance with the overall process of insuring quality.
implementation objectives.
Insure that they understand that responsibility This item was specifically addressed in training is shared with their supervision and upper sessions conducted in accordance with the management and does not totally rest with them.
implementation objectives.
9 9 1s 9
NCIR RESOLUTION #NR-1 RECOMMENDATION ACTION 1)
Review adequacy of present requirements and controls for documenting technical resolutions, especially those by Design Engineering and Construction.
Insure that written resolutions are concisely stated, cite specific documentation as basis, and answer obvious questions.
Review adequacy of present requirements and Requirements were reviewed and necessary procedure controls for documenting technical resolutions, changes were isolemented to both Design and especially those by Design Engineering and Construction precedures.
Construction.
Insure that written resolutions are concisely Technical approval of Design pesolved NCI's is at
- stated, the Group llead or higher level cite specific documentation as basis Training was conducted to stress citing specific basis.
and answer obvious questions.
Training was conducted to insure that obvious questions are answered.in resolution of NCI's.
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NCIR RESOLUTION #NR-2 RECOMMENDATION ACTION 2)
Review the existing process for NCIR orgination by QA inspectors, especially as relates to interface with immediate supervisor.
Insure that no procedural steps, procedural interpretations, or personnel interfacing inhibits development of proposed NCIR's by inspectors.
Insure that inspector supervisor adequately dispositions proposed NCIR's to upgrade to NCIR r.tatus or degrade to invalid NCIR status in accordance with required procedures.
Pay special attention to adherence to documentation required for invalid NCIR's.
Insure that supervisor responsibilities and specific procedures are
- written, communicated, and understood including:
a)
Responsibility and criteria for review of all proposed NCIR's and determination of future disposition.
b)
Responsibility for insuring complete clarity of problem description for all proposed NCIR's that are elevated to NCIR status.
Insure that supervisors authority to require complete rewrite or to personally make minor editorial changes is understood and carried out.
Insure that adequate records are kept for future review of inspector
- and, supervisor performance.
c)
Responsibilities and procedures for documenting and filing rationale and specific justification for designating a proposed NCIR as invalid.
Insure that sufficient files are kept and regularly reviewed by upper supervision for adequacy of justifications, trend usage and inspector and supervisor performance and training
- NR-2 Page 2 RECOMMENDATION ACTION Review the existing process for NCIR origination Process was reviewed and procedure was revised as by QA inspectors, especially as relates to necessary.
interface with immediate supervisor.
Insure that no procedural
- steps, proced0ral No procedural steps or interpretation inhibit the interpretations, or personnel interfacing development of proposed NCIRs.
inhibits development of proposed NCIR's by inspectors.
Insure that inspector supervisor adequately Procedure is clear in this regard and training was dispositions proposed NCIR's to upgrade to NCIR conducted.
status or degrade to invalid NCIR status in accordance with required procedures.
Pay special attention to adherence to Procedure is clear in this requirement.
documentation required for invalid NCIR's.
Insure that supervisor responsibilities and specific procedures are written, communicated, and understood including:
a)
Responsibility and criteria for review of This item was addressed in specific training all proposed NCIR's and determination of sesrions.
future disposition.
b)
Responsibility for insuring complete clarity Procedure is clear in this respect.
of problem description for all proposed NCIR's that are elevated to NCIR status.
Insure that supervisors authority to require Procedure is clear in this respect and supervisors complete rewrite or to personally make minor do ur.derstand their authority.
editorial changes is understood and carried out.
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- NR-2 Pcge 3 RECOMMENDATION ACTION Insure that adequate records are kept for Adequate records are kept for review of personnel future review of inspector and supervisor performance.
performance.
c)
Responsibilities and procedures for Procedure is clear in this regard and supervision documenting and filing rationale and has been specifically trained.
specific justification for designating a proposed NCIR as invalid.
Insure that sufficient files are kept and A review team was appointed by management to review regularly reviewed by upper supervision for each NCI.
This team has functioned to improve the adequacy of justifications, trend usage and overall quality of NCI's, by reviewing each NCI for inspector and supervisor performance and justification, disposition and trends.
This team training input.
has also provided training input to all affected departments.
9 G
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NCIR RESOLUTION #NR-3 RECOMENDATION ACTION 3)
Review process for NCIR resolution by Construction and Design Engineering to insure adequacy of the following:
a)
Resolution documentation (See Item 2) b)
Adequate site inspection before resolution is issued.
c)
Workable repairs are issued for craft implementation.
d)
Any significant level of NCIR occurrences in specific areas is factored into procedure and performance reviews appropriately, e)
Any significant level of acceptance of "as is" conditions which do not meet Design or Construction original requirements are reviewed for procedure changes and personnel j
performance evaluation by appropriate management.
f)
Upper time limit for resolution of all NCIR's is adequately defined and enforced.
g)
Returned NCIR's which have resolutions that are problems are tracked in the same manner as normal NCIR's received for the first time.
Also insure that such returns are trended for procedure and performance evaluation purposes.
i Review process for NCIR resolution by Construction and Design Engineering to insure adequacy of the following:
a)
Resolution documentation (See Item 2)
Process
'was reviewed and procedures were appropriately revised.
b)
Adequate site inspection before resolution Design personnel appropriately review conditions
'i is issued.
prior to issuing a resolution.
20
QR-3 Prge 2 RECOPMENDATION ACTION c)
Workable repairs are issued for craft Repair instructions are reviewed by both Technical implementation.
Support and Quality Assurance.
d)
Any significant level of NCIR occurrences in Trend analysis is performed to identify specific-specific areas is factored into procedure problem areas.
and performa..ce reviews appropriately.
e)
Any significant level of acceptance of "as Trend analysis will identify needed procedure is" conditions which do not meet Design or changes.
Construction original requirements are reviewed for procedure changes and personnel performanance evaluation by Management takes whatever personnel action they appropriate management.
feel appropriate.
f)
Upper time limit for resolution of all
- None, item was addressed but not considered NCIR's is adequately defined and enforced.
desirable.
g)
Returned NCIR's which have resolutions that Construction Department NCI's returned to Design or are problems are tracked in the same manner QATS are tracke.1 the same as first time NCI's.
as normal NCIR's received for the first time.
Also insure ti.at such returns are trended Periodically, the site sends list of returned NCIs for procedure to QATS who reports results to management via NCI trend analysis, and performance evaluation purposes.
Management takes whatever actinn they feel appropriate.
9 9m G
DESIGN DRAWINGS #DD-1 RECOMMENDATION ACTION 1)
Review clarity of present standards used for weld callouts on drawings.
Consider using more general specification vs.
providing extensive joint geometry.
Review clarity of present standards used for weld Training was conducted by Engineering to highlight callouts on drawings.
in importance of good drafting to eliminate drawing clarity problems.
Consider using more general specification vs.
Engineering addressed this item in detail, the providing extensive joint geometry.
option of the joint geometrics is a decision of the designer and is exercised on some design drawings.
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MATERIAL CONTROL #MC-1 RECOMMENDATION ACTION 1)
Review clarity of procedures and craft isrplementation of procedures for material marking.
Insure instructions are speci fied.and that monitoring of craft compliance is sufficient.
Insure that procedure violations are dealt with in rigorous fashion as relates to disposition of scatcrial in question and as relates to personnel performance feedback.
a Review procedure scope limits.
Review clarity of procedures Material control procedures were reviewed and found unclear in some areas.
Procedures H-4 and H-5 were revised for clarification.
and craft implementation of procedures for Craft personnel receive training in Quality material marking.
Assurance procedures (both new and revised) as they are issued to the field.
Construction (generated at the site) are revi.ewed and
- revised, if necessary, to reflect the requirements of the new or revised QA procedures.
The craft personnel also receive training on the requirements in construction procedures.
There are programs which identify craf t non-compliance of procedures.
These programs are (1) procedure QA-300, " Construction Surveillance",
(2) procedure QA-150,
" Trend Analysis", and (3) the inspection program.
Each of these methods have the means to identify and document non-compliance with procedures.
Each also has a method to document corrective action taken to rectify the situation.
Therefore, the program is l
sufficient to verify craft implementation of the procedures.
O O,
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- MC-1
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Page 2 REcotNENDATION ACTION Insure instructions are specific As revisions are issued to the
- field, the construction procedures will be reviewed for conformance to the current Quality Assurance procedures.
Craft personnel will be trained in the procedure changes, both construction procedures and QA procedures.
and that monitoring of craft compliance is There are three methods used to help monitor craf t sufficient.
compliance of instructions.
These programs are (1) procedure QA-300, " Construction Surveillance", (2) procedure QA-150, " Trend Analysis", and (3) the inspection program Each program has a method to identify and document discrepancies as well as methods to perform corrective action.
Each of these programs are innlemented by a different group.
The Construction Surveillance program is implemented by Quality Assurance personnel at the site, the " Trend Analysis" program is implemented by Quality Assurance, Technical Services, and the inspection program is implemented by site Quality Control personnel.
The combination of these programs provide a constant monitoring system which is sufficient to identify craft compliance with instructions.
Insure that procedure violations are dealt with The fabrication and erection inspection procedures in rigorous fashion as relates to disposition of provide inspector checkpoints to verify correct material and question material.
These procedures provide corrective action guidelines.
Also Quality Assurance Procedure, Q-1, " Control of Non-Conforming Items" is used for violations of Quality Assurance procedures.
These methods are sufficient for determining the disposition of the materials used.
~9 9m 9
- MC-1 P ge 3 RECOMMENDATION ACTION and as relates to personnel performance feedback.
The performance of the craf t is constantly being viewed by means of (1) the Construction Surveillance program, (2) the non-conforming item Trend Analysis, and (3) the feedback from the inspectors on problems encountered in the field.
These methods have systems to provide feedback to the craft via their supervision.
These methods are sufficient to identify performance problems and provide the necessary corrective action.
i Review procedure scope limits.
Quality Assurance Procedures 11-4 and 11-5 have been revised to reflect applicability to QA Condition 1 and QA Condition 4 only.
0 4
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MATERIAL CONTROL #HC-2 RECOMMENDATIDH ACTION 2)
Review adequacy of methods for dealing with QA procedure violations, lack of procedures, and procedure extensions, to insure appropriate guidance exists.
Consider if sufficient avenues are available and are being used to rework some deficiencies without having them escalate to
+
status of a proposed NCIR's.
Review adequacy of methods for dealing with QA The purpose section of Quality Assurance Procedure procedure violations, Q-1, " Control of Non-conforming Items", identifies Quality Assurance procedure violations should be handled in accordance with this procedure.
- Also, some procedures allow the use of procedure R-2,
" Corrective Action", as an acceptable alternative to document discrepancies.
The program to deal with Quality Assurance procedure violations is sufficient.
lack of procedures, Quality Assurance Procedure A-1,
" Preparation and Issue of Quality Assurance Procedures", outlines the steps to take when a new Quality Assurance procedure or revision is needed.
Quality Assurance procedure F-1, " Construction Procedures", outlines the proper steps for the development of construction procedures.
and procedure extensions, Procedure QA-107 was developed to more closely control the method for issuing procedure extensions.
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NHC-2 P:ge 2 RECOW1ENDATION ACTION to insure appropriate guidance exists.
Consider if sufficient avenues are available The existing fabrication and erection inspection procedures outline acceptable metho.'s within the and are being used to rework some deficiencies procedure to document and correct deficiencies.
without having them escalated to status of a lhese procedures also identify other procedures proposed NCIR's.
such as Q-1 " Control of Non-Conforming Items" and R-2 " Corrective Action", which can be used to document discrepancies.
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