ML20102A195

Responds to 831101 Request for Comments Re Util Course of Action Presented at 831101 Meeting.Util Responded to All Detailed Recommendations.Many Responses Broad in Scope & Detailed Intent Cannot Be Judged

ML20102A195
Person / Time
Site:	Zimmer
Issue date:	11/16/1983
From:	Neylan A TORREY PINES TECHNOLOGY
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20102A048	List: ML20102A146 ML20102A164 ML20102A195 ML20102A256
References
FOIA-84-151, FOIA-84-176 NUDOCS 8502080188
Download: ML20102A195 (6)

Text

.

-, Sbaylk da 511 OW I

( i . 9st 3;7,f7 l

10RREY FINES TECHNOLOGY F 0 Er. tS63E Wg ';7{if@i

- g 3/RA tf Se* Dep: Cav on.a 9?13E ~~

leesem (E19; 4f 51E54 ' ~~

- b i M5F 4 De.c G A Technologies Inc. r y

5AI 4L Novecber 16, 1983 JNF ! IFile j g Project 2474 2474:092: 83 Mr. J. G. Eeppler BeEional Adcinistrator Nuclear Regulatory Commission Region III 799 Glen Ellyn, Illinois- 60137 -

Dear Mr. Eeppler:

The following is in response to your request for concents on CG&E's Course of Action as presented at the teetinE in Cincin- ,.

nati on November 1, 1983 In 7,P 7 ' s view, CG&E's proposed Course of Action restructures the Zitter Project organization generally as recommended by 7PT. Key new project personnel have been hired, an experienced architect / engineer / constructor-type organization is to be're-tained, staff levels are being increased, new policies and procedures to control the operation of this new orEanization are being prepared and unequivocal statements of CG&E's commit-cent to quality have been cade.

In 7FT's initial review of the CG&E document, we were concerned that the recoctended increased involvement and recognition of the responsibility of the CG&E Board was not evident. Bowever, ba, sed on the statements by Mr. Dickhoner at the public meeting, it it apparent that TPT's recocmendations in this area are also being fully addressed. A new director who has broad experience in the nuclear industry will be elected, the Board has orivill review and endorse, as appropriate, the credentials of all CG&E officert having direct line canagement responsibilities for Zitter and t h t- Board will become more involved and knowledge-abic reEarding key policy decisions al d the results of these policies.

We have only one significant remaining concern. The proposed Assistant Vice President for Quality Assurance and the Manager of the Quality Assurance Department are only marginally quali-fied for these positions. This opinion is based on the quali-fications presented in the Course of Action and the requirements of the ANSI / ANS 3 1. There is an apparent lack of a proven track record and experience in overall QA program management. We be-lieve this experience will prove critical to successful continua-tion of Ziccer activities. .

\

8502080188 840619 13 PDR FOIA CARPENT84-151 PDR NOV 211333

. . ( (.

Mr. J. G. Eeppler 2t7A:092: 53 There are several nominal organizational differences between TPT's recommendation and CG&E's proposed Course of Action at the detailed level. In TPT's view, these differences are Einor in nature and generally of the type where two ways are accepted and practiced in the nuclear industry, each having its own set of ad-

. vantages and disadvantages. In each case effort must be made to compensate for the disadvantages of the approach chosen. Some of ,

the more important examples of these are:

1.

TPT recommended formation of a central Administration Group. The major concern here was to integrate, standardize and centralize the functions of Program Planning and Sch'eduling, Management Idrormation Systems, and. Document Control. CG&E appears to have achieved this objective for two of these functions but has organizationally located them under the Nuclear Projects Group. However, the requirements for all records

' control are under. the Manager of Adcinistration and *<

Training (Iter 11-COA-Attachment 6) who reports to Mr.

Cruden. Construction Records Control will be centra-lized under the Nuclear Project Controls Department Manager who reports to Mr. Cole. This appears to be a division of responsibility in an area of extreme in-portance. There are advantages, as noted in the COA, to this arrangement. The disadvantaEes can be com-pensated for by having carefully assigned' areas of responsibility, coordinated document listings and consistent procedures and formats.

2. TPT recommended Licensing be combined under the Engi-neering Group. CG&E has created a separate osanization, at the department level, reporting to the Sr. Vice President. As stated at the zeeting, both forms of organizational structure are commonly and effectively utilized in the nuclear industry. There are advantages and disadvantages to'ench. The form proposed by CG&E allows more direct contact and overview by the Sr. Yice President, as acknowledEed by Mr. Williams at the Novem-ber 1 seeting. The disadvantages can be compensated-for by careful management attention to coordination and careful. technical review of all licensing actions and

. issues.

3 TPT recommended that the AE/C Project Manager (Bechtel) r'eport directly to the CG&E Zimmer Project Manager-(Williams). CG&E has elected to have the Bechtel ,

-Project Director report - to the Assistant Y1ce~ President

- Nuclear. Projects with an " access" organizational -line directly to Williams. We expect that, in practice, Mr. Williams, based on his statements, will take an n-

(s

. -f - \

- Mr. J. G. Eeppler 2474: Oc2:63

~ ' ~~ '

3 (continued) active role in Bechtel's project managecent activities, especially in relation to the quality verification program and the completion of construction. As such, TPT has no disagreement with the organizational arrange-ment selected, and given Williams' additional attention /

action believes it will be stronger than the relation-ship TPT recommended.

4. TPT recommended that Start-up Testing be part of Opera-tions. CG&E put.this function under Engineering. There are valid arguments for either approach. The CG&E or .

- ganization raises the question of how operations will get full benefit from the experience gained during start-up testing. This concern can be alleviated by -

making sure that operations people are intimately in-volved in planning, managing and executing the start-up

. testing program.

5. TPT expressed concern that CG&E had previously not ade-quately monitored the technical activities of S&L and GE. CG&E's proposed Course of Action substantially increased their engineering staff in order to audit and .

p verify the design control meets project requirements with particular attention provided to the technical l activities of S&L and CE (Item 4 4-COA- Att. 6). However, the organizational relationship indicates project direc-tion from Bechtel (Fig. 1) with an " access" relationship between S&L, GE and CG&E Engineering. The relationship between CG&E Engineering and Bechtel in this area re-quires clarification, assuring that CG&E Engineering will be technically prepared to handle engineering

! responsibility when the plant goes into operation.

In the QA area, CG&E has been responsive to TPT's I 6.

l orEenizational recommendation thatall QA activities i

report to an overall QA manager at the same level and status as other functions ( Assistant Vice President).

The suborganizations, although named differently, cover essentially the same functions as recommended by TPT.

In general, CG&E responded to all TPT's detailed recommendations.

Although generally sa tis fa ct ory , sany of the responses were very broad in scope and.the detailed intent cannot be judged. TPT recommends that the NRC or other independent agency should audit / verify at some later date that the CG&E proposed action has been effectively implemented.

k

, (

Mr..J. G. 1:eppler 1, -

FA7A:09?:E3 CG&E has outlined a good ' Course of Acti'o'n in reAponse to our recommendations. Minor chanEes to accommodate our comments and continued stronE efforts to develop an excellent orEanization with appropriate policies and procedures will result in CG&E's being able to complete the project in accordance with all rcEulations

,a nd the construction permit.

Should you have any questions or require further review, p' lease call me or George Wessaan.

Sincerely,

' A. J. Neylan Project Manager

, w Copy: Mr. W. H. Dickhoner - CG&E i

4 e

i I

L w ,

MoY hr Ppg C ,

CORRESPONDENCE

..-.. .m.._ . _ _ _ . . . _ _ . . , , , _ , . . . . . _ _ , , , ,

I TO: File /I V

/I DATE: January 20, 1984 GFC-84-0035 FROM: G. F. Cole

SUBJECT:

INDEPENDENT AUDITOR OF THE PVOC The purpose of this Memo is to record a telephone con-versation from Mr. Bert Mazo of Ebasco on January 20, 1984.

Mr. Mazo said that the NRC has arranged to perform interviews of Senior Ebasco people proposed for the Independent Audit Contract. He said these interviews are to be held at the Zimmer site on January 24 and 25, 1984. Eight Ebasco employees will be interviewed. They are:

Larry Stinson Lou Borchardt Larry Bast V. Burgard -

P. Panchal A. Contino J. Gutierrez G. Mahan He asked that we make arrangements for these employees to have access to the site.

I. told Mr. Mazo that we were gearing our schedules so as to begin in-plant PVOC activities on February 24, 1984, and there would bG a number of activities started earlier in February leading to this. I said Ebasco should be formulating their plans accordingly and suggested that when their people are on site for.the interviews that discussions take place with the NRC and Bechtel on means of obtaining information to enable Ebasco'to support our PVQC schedule. Mr. R. W. Bass will coordinate this for CG&E.

GFC:jac f [

f G. F. Cole cc:- Messrs. J. Williams, Jr.

D. S. Cruden B. B. Scott G. E. Murphy E. J. Wagner H. Barjian '

R. W. Bass Ezusw11)r- NRC D. R.-Hyster G. B. Jones - Bechtel G. C. Ficke THE CINClHNATI GAS & ELECTRIC COMPANY The Union Light Heut and Power Company f

Lawrenceburg Gas Company

A-n>cacm. n p n n Not sr/ wt CORRESPONDENCE . . . . . .

TO: File DATE: January 11, 1984

~

FROM: R. W. Bass LAction/Rqview RSS M \

SUBJECT:

INDEPENDENT AUDITOR FOR THE PVOC SRT Mf f RI //"

RI .

FII.E DATE REC'D . dNN 1 1 j384_

On January 9, 1984, representatives from Ebasco, the NRC resident staff and CG&E met at Zimmer for the purpose of hearing Mr. Stinson of Ebasco preview his presentation prepared for the public meeting scheduled for January 11, 1984.

Drafting assistance was provided to Mr. Stinson in the preparation of view graphs and in reproducing these graphs.

While on the station, the Ebasco prospective resident manager of the independent audit was shown the facilities that will be assigned to Ebascc and arrangements were discussed regarding furniture, telephones and other office equipment.

ll R. W. Bass RWB:jac cc: G. E. Murphy H. Barjian,. . .,

M .,M . Hill---- NRC THE CIHClNHATI GAS & ELECTRIC COMPANY l$

The Union Light, Heat and Power Company Lawrenceburg Gas Company

[