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W DRAFT PROJECT 2485 f*
INDEPENDENT CONSTRUCTION REVIEW OF MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 DiD 2
SUMMARY
REf0RT TASK A - EVALUATION OF QA ORGANIZATION AND MANAGEMENT POLICIES 'IWARD QUALITY ASSURANCE August 5,1983 T. R. Colandrea I?oll0050703
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. 1.
INTRODUCTION The purpose of this report is to summarize the work performed in Task A of Project 2485, and to provide a single reference source for docmentation of the work.
Bis smmary report is called for in Subtask A8 of the Program Plan.
Task A is designed to evaluate the organizational status of QA on the Marble Hill Project and to review PSI management policies which affect QA and assess the degree to which those policies help to assure an effective QA program.
In carrying out this task, the work focused on (a) interviews of selected PSI personnel and (b) review of PSI manuals, procedures and supporting decments, which, taken together, provided the basis for making the evaluation.
He information in this report is presented in seven sections.
Be first section presents an introduction to the report and describes the objective of Task A.
The second section samarizes the results of each Task A subtask. he third section presents the conclusions regarding the adequacy of PSI's QA organization and management policies towards quality assurance.
The fourth section lists the personnel who worked on the task.
Be fifth section presents the list of the personnel contacted during Task A.
The sixth section provides a list of the manuals, procedures and supporting documents reviewed during Task A.
he seventh section presents a smmary of the PFRs generated under Task A.
2.
SUMARY OF WORK 2.1 Subtask A1 The first subtask required preparation of a procedure and checklists needed to accomplish the Task A evaluation.
This procedure was issued as 2485-PD-1 on July 12, 1983.
Checklists, audit points requirements to determine that relevant QA program policies have been put into practice, were also,;repared.
2.2 Subtask A2 This subtask involved interviewing selected PSI personnel (see Section 5 of this report) to gather information required for Subtasks A3 through A7 as well as to identify relevant manuals, procedures and supporting docments used in the Task A evaluation (see Section 6 of this report).
2.3 Subtask A3 j
This subtask consisted of an evaluation of the organization level and status of the PSI QA Department to determine if the level, status and staffing are consistent with that required for an effective QA progrm. The following topics were addressed during the evaluation:
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' QA Department staffing
- PSI criteria for detennining adequacy
- Level as evidenced by QA Department effectiveness
- Management response to requests for staffing QA Department budget Reporting level of QA Manager /QA Department Title of QA Manager compared to peers Perceived attitudes of QA people regarding stature of QA Department / people QA salary levels versus counterparts QA salary levels versus outside organizations Organizational independence of QA verifiers fran work itself Training / qualifications of QA verifiers Freedom of QA Manager and his staff from cost and schedule pressures Freedom of QA Manager and his staff from non-QA and non-Marble Hill responsibilities May 1983 resignation of PSI QA officer.
While there are no formal staffing criteria, the staffing level in Quality Assurance Department is based on management experience and knowledge of what it takes to get the job done plus the status of the work itself.
All indications are that the QA staffing level is quite adequate to do an effective job.
Based on the evidence examined, it appears that each QA Department request for staffing increases has been granted.
There is extensive budget analysis, forecasting and tracking of QA staffing and other budgetary needs. It appears that the QA Department has adequate independence and sufficient budgetary control to assure that the necessary manpower and supporting services are planned, obtained and controlled.
The Executive Director of the QA Department, C. Beckham, reports to the Senior Vice President of the Nuclear Division and is on a comparable organizational level with the heads of counterpart organizations.
Beckham's title is Executive Director of Nuclear Quality Assurance. Others in the Senior Vice President's organization
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-4 have the same or lower title with the exception of the Vice President of Nuclear Services, W. Petro.
This is satisfactory considering the fact that Construction and Engineering report to the Vice President of Nuclear Services, although strong consideration should be given to making C.
Beckham the QA Officer (a Corporate Officer) in a manner similar to his predecessor, L. Ramsett.
A random survey of PSI QA staff members showed that 9 of the 18 people contacted felt that others at Marble Hill had negative feelings toward the QA Department /QA people (for example, QA interferes with produc-tion, necessary evil, policeman, only here because it is required, is too picky, required headache, delay organization, religious fanatic, while the other nine were quite positive in their unreasonable), how others view the QA Department /QA people (gets along thoughts as to well, generally respected, good working relationship, important part of the project, cooperate completely with QA, pretty well accepted team member). While overall it appears that QA Department / people have adequate stature as far as that required for an effective QA program, sme image building and role definition would be helpful in order to gain greater acceptance of the QA Department and people at Marble Hill.
The salary levels of PSI QA personnel were the same as those for others of counterpart positions in other PSI departments.
'Ihe PSI QA salary levels also appeared to be competitive with other companies.
QA Department personnel at PSI appeared to be organizational 1y independent frm the work being controlled and verified.
Lead auditors were qualified to ANSI N45.2.23 and inspection / test personnel were qualified to ANSI N45.2.6.
i QA Department personnel appeared to be substantially free frm excessive cost and schedule pressures.
A review of the minutes of 20 Executive Review meetings showed involvement and interest at the highest corporate level in assuring a proper balance between quality, cost, and schedule.
There was no evidence of QA personnel involved in non-QA or non-Marble Hill responsibilities.
It appears that the QA Officer, Lauren Ramsett, resigned because he and the Vice President, of Nuclear Services could no longer work together.
'Ihey evidently had philosophical and personality differences to the point where Ramsett did not want to continue in his present role and such that the two of the became polarized.
'Ihere was no indication of a specific quality problem or detrimental impact on the quality program that resulted frm their differences which caused Ramsett to leave.
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. Details of this subtask are contained in the completed checklists which are available in the project files for Project 2485. There were no PFRs written on this subtask.
2.4 Subtask A4 This subtask consisted of a review of job descriptions and procedures relevant to defining authority and responsibility of key PSI QA personnel.
hese documents were evaluated to determine if the identified responsibilities and authorities were commensurate with those required fcr an effective QA program. The follo41ng topics were addressed during this review:
QA Manager position description and qualifications Key QA personnel position descriptions and qualifications Authority delegated by upper management to QA Manager Other vehicles / procedures which define QA authority Freedom in QA Department's use of stop work authority A review of job / position descriptions for four randomly selected QA Managers and five other key QA personnel indicates that the duties and responsibilities of each position examined are adequately defined.
Mcwever, difficulty was encountered in attempting to verify that the current incumbents meet the minimm qualification requirements for their respective positions.
Current " position descriptions" contain no minimm qualifications for education, experience, skills, etc.
New " job descriptions" have been developed but not yet approved to replace the position descriptions.
These job descriptions do contain minimm qualifications.
However, a sample comparison of the qualifications of four current QA Managers against their respective proposed job descriptions indicates that three of them appear not to meet the minimm education requirments.
The problem lies in the fact that the job descripticns provide no equivalency criteria which may be desirable.
PFR 2485:006 was written to address this area.
This PFR has not been dispositioned by the Findings Review Committee as of the time of this summary report.
A review of several manuals, procedures and statements of authority indicated that the authority and responsibility of the QA organization are well defined and appropriate.
It appears that the QA Officer is assigned adequate authority and responsibility for implementation of the QA program.
QA authority is principally defined in the PQAM and AQAM.
e
- The QA Department appears to have free use of stop work authority without hinderance frm others.
That is, all personnel performing QA functions can limit or control further processing or installation of an item.
The Senior Vice President has a responsibility to assure that the work is stopped immediately and he cannot modify the Stop Work Order.
The signatures of both the Senior Vice President and the QA Officer are required to lift the Stop Work Order.
Details of this subtask are contained in the completed checklists and in a July 22, 1983 mmorands frm B. L. Coleman to T. R. Colandrea which are available in the project files for Project 2485.
2.5 Subtask A5 This subtask consisted of an evaluation of PSI QA Department's access to upper management to determine if the QA program status and problems can be, and have been brought to the attention of upper management and acted upon, as appropriate, in a timely manner.
The following topics were addressed during the evaluation.
Methods for QA Manager reporting of QA program adequacy and effectiveness to management Other vehicles for informing management of quality status / problems /
trends
- corrective action requests
- nonconformance reports
- progress reports
- audit reports
- memos
- trend reports
- other reports Distribution of contractor audit reports, trend reports, etc. to PSI management Contractor reporting of problems to PSI management Management response to reports and QA program status /proble information received Perceived attitudes of QA people regarding "open door" policy for reporting program status and problems to management QA Manager's attendance at upper management meetings Extent, if any, of filtering / sanitizing of infonnation on problems as reports proceed up the management chain.
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It was found that the QA Department has good access to upper management, and that QA program status and probles are regularly brought to upper management's attention.
Re QA Executive Director attends the monthly Executive Review meetings, which are also attended by all division upper management through the Senior Vice President, and the PSI President and CEO.
As evidenced by the meeting minutes, these meetings have provided a formal mechanisn for QA matters to be brought to the attention of top management at PSI.
In addition, the QA Executive Director is in close daily contact with the Senior Vice President, Nuclear Divinion, thus assuring excellent access and good connunication on QA matters.
De QA Executive Director attends other project meetings, including the Senior Vice President's bi-monthly staff meetings, which provide further assurance that QA does have access to all levels of management.
Re President of PSI is also generally in attendance at the Senior VP's staff meetings.
Quarterly Quality ^
Trend Reports provide another mechanisn for informing management of quality trends and status.
Rese reports are distributed to management levels up to the Senior Vice President, Nuclear Division.
A random survey of QA and Nuclear Services PSI staff members showed that the vast majority of personnel felt that PSI did, indeed, have an "open door" policy for reporting problems to management and that PSI management has, in fact, been responsive in acting on problems in a timely manner.
There were no PFRs written on this subtask.
Details of this subtask are contained in the completed checklists and in a July 29, 1983 menorandtrn from S. D. Bresnick to T. R. Colandrea which are available in the Project files for Project 2485.
2.6 Subtask A6 This subtask consisted of an evaluation of the PSI QA Department's involvenent in project activities to determine if the QA Department was sufficiently involved to help assure adequate QA control and cognizance of the project. The following topics were addressed during the evaluation:
PSI QA Departnent reviews and audits of contractors for adequacy, implementaticn and effectiveness of their QA program Timeliness and extent of PSI QA Department surveillance of construction l
- PSI QA Department review of contractor inspection planning i
- PSI QA Department identification and use of witness and holo points I
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. - PSI review of contractor docmentation 1
- PSI QA Department involvenent in reinspection of contractor work on a sampling basis Interface of PSI QA Department with contractors and NRC on matters of urgency PSI QA Department involvenent in responses to NRC 1
PSI inspection on equipnent turnover PSI QA Department involvenent in scheduling and status meetings PSI QA Department involvenent in problen-solving meetings PSI QA Department concurrence on quality-related procedures including engineering and construction procedures.
An examination of the site annual audit schedule and supplier annual audit schedule verified that the site contractors and suppliers were audited on a regular basis to appropriate criteria.
Selected audit reports of site contractors were reviewed which showed that their QA programs had been evaluated by PSI QA for adequacy and effectiveness and, as necessary, corrective action had been taken on shortcomings reported during the audit.
A review of PSI QA Department's mandatory hold point logs and con-struction surveillance reports with related docmentation indicated that PSI QA reviews contractor inspection planning and procedures for the purpose of establishing witness and hold points.
The necessary controls appear to be in place to asure that the hold points were adhered to.
A review of the Corrective Action Requests, PSI /
contractor / supplier nonconformance reports, requests for evaluation subnitted to the Safety Committee and other problem-reporting docmen-tation verified that PSI QA interfaces with contractors and the NRC on matters of urgency (for
- example, reporting of significant deficiencies).
Furthermore, it appeared that the QA Department is involved in the preparation and/or subnittal of the responses to NRC inspection reports.
A review of the minutes and attendance of the Project and Construction Department status and problem solving meetings revealed that QA participates and plays an active role in these meetings.
An examination of a nmber of PSI project and engineering procedures, site contractor construction / installation and test procedures and PSI QA procedures indicated that the appropriate QA disciplines reviewed and approved the procedures.
1
. There were no PFRs written on this subtask.
Details of this subtask are contained in the completed checklists and in a July 22, 1983 menorandtzn from B.
L.
Coleman to T.
R.
Colandrea which are in the project files for Project 2485.
2.7 Subtask A7 This subtask consisted of an evaluation of PSI manage. ment's involvenent in QA activities to determine if management was sufficiently involved to provide an appropriate level of support and status to the QA program.
'Ihe following topics were addressed during the evaluation.
Management's awareness of problens Management's review of quality status reports Management response to quality-related requests for support Frequency of management's contact with QA progran status Management's stated policies regarding quality / quality assurance Management's statements expressing opinion on QA
- performance appraisals
- notes
- menos, letters
- conversations, speeches Management enphasis on " Quality is Everybody's Business" and "Do It Right the First Time" thenes QA audits and evaluations requested by management Bnployee's perception of management's policy on quality / quality assurance Onployee's perception of management's attitude toward and commitment to quality assurance The review showed that PSI's management is, in fact, closely involved with QA activities and does provide an appropriate level of support and status to the QA progran.
The Executive Review meetings involve PSI top management (Chainnan and President) on a monthly basis, and the Senior Vice President, Nuclear Division, is involved on a daily basis through his contacts with the QA Executive Director.
Interviews with QA personnel from line positions through middle and upper management all indicated strong support of the QA program by PSI management.
- A PSI policy statement in support of the QA program appears in the QA manual, signed by D. Menscer, President.
PSI training and indoctrination programs (Levels A and B) for riew employees stress that PSI management supports the QA program, and also stress the " Reporting Without Discrimination" policy.
l Management audits are called for in the Project QA Manual (PQAM) and the ASME QA Manual (AQAM).
Management audit files for the last three years were reviewed and it was confimed that two audits were performed each year (one for the IQAM and one for the AQAM). However, a review of the contents of these reports indicated that they were limited to implementation audits and did not evaluate effectiveness of the program or compliance with codes and standards.
PFR #2485-011 was written to cover this issue.
PSI is in the process of issuing written instructions for performing management audits (PMP 18-3, in draft form).
Prior to this, an uncontrolled docment signed by S. W. Shields entitled " Instructions
+
for Performance of Management Audits at Marble Hill Nuclear Generating Station, "
dated 11/05/81, apparently served as the governing procedure.
Although the management audit files did not always contain all the backup records required, this was considered minor as the basic reports and essential supporting records were available.
Interviews held with D.
V.
Menscer (President and Chief Operating Officer) and H. A. Barker (Chaiman and CEO) indicated a strong and sincere commitment to maintaining an effective QA program throughout the project.
Both Menscer and Barker believe that a strong QA program is essential for the succesful completion of the project and for the safe and reliable operation of Marble Hill.
'Ihey encourage reporting l
of any probles related to QA and the prm pt investigation and assessment of any allegations reported by site personnel.
In addition, they encourage prmpt, frank and open communication with the l
NRC inspector.
l A survey of the PSI QA and Nuclear Services staff showed that the vast I
majority of respondents felt that PSI management had a positive attitude toward, and strong commitment, to QA.
'IWo of the question-naire respondents expressed concern that schedule pressures might comprmise quality.
f Details of this subtask are contained in the completed checklists and in a July 29, 1983 memo frm S. D. Bresnick to T. R. Colandrea which are available in the Project files for Project 2485.
. 3.
Q)NQ.USIONS Based upon the results of this evaluation, it is concluded that PSI manage-ment has done a good job of developing and implementing policies which are supportive of the Marble Hill QA progre. Overall, it appears that the PSI QA Department receives excellent support frcun management and, as a result, is adequately staffed and interfaces at an appropriate level with counter-part organizations. The QA Department is actively involved in the surveil-lance of the Marble Hill QA activities and appears to have sufficient authority to carry out their responsibilities.
A key element in the success of the Marble Hill project since 1980 is the extensive involvement and sincere interest in quality and the QA progra on the part of upper and top management.
4.
TASK & PERSONNEL The following personnel worked on the Task A effort:
S. D. Bresnick T. R. Colandrea B. L. Coleman 5.
PEPSONNEL C0fffACTED The following personnel were contacted during the course of this evalu-ation:
H. A. Barker N. Smith C. Beckh m W. Tyler J. Bott K. Hollon F. Carchedi S. Ellegood D. Dedrick P. Parrish C. Driskell J. Blanke S. Gordy F. Zoll H. Curry.
D. Smith T. Geyman J. Young E. Cannichael A. Burns A. Heestand C. Drickell J. Huffman G. Marcoux T. Kunze M. Robey M. Macy A. Ray D. Menscer P. Hilland R. Minnich L. Langh s B. Morrison C. Zehme S. W. Shields D. Jones J. Stivers J. Brannon W. Petro H. Lukins E. Aimone R. Kindler L. Rasett E. Leach J. Lefman M. Smith
- D. Albright D. Fuller W. Brazelton R. Cramer J. Barbara R. Hardison R. Kennedy K. Richards J. Davenport T. Carlock D. Downs R. Pinter R. Berry 6.
MANUALS, PROCEDURES AND SUPPORTING D00DENIS REVIDfED The following represents a list of the major manuals, procedures and supporting docments reviewed during the Task A evaluation:
Budgets for 1981,1982 and 1983 actual staffing levels frm Nov.1981 monthly to present 1983 QA Dept) Budget preparation sheets Manloading Charts for QA Dept, from Jan.1981 to present August 1981 budget estimate for QAD March 1982 budget estimate for QAD Budget Variance Reports: 1981, 1982, 1983 Organizational charts Various PSI organization charts Results of questionnaires 1983 Cepensation Adnin. Program 7/19/83 salary info from E. Aimone Training records Exec. Review Meeting Minutes Budget / staffing information PMP Sec.10 Job descriptions and resmes Qualification and training folders Project QA Manual (PQAM), Sec.1 Rev. 9, and Sec. 2, Rey, 10 ASME QA Manual Statement of Policy and Authority, dated 7/16/82 Test Methods Procedures Manual Calibration Procedures Manual Civil Inspection and Testing Service Manual AQAM Statement of Authority dated Oct. 22, 1982.
AQAM, Sec.1, Rev.11 AQAM, Sec. 2, Rev.10 PMP 2-3, Rev. 3 Stop Work Order Status Log All Stop Work Orders listed in SWO Status Log Quality Trend reports 1982 Quarterly reports - 5/16/82, 9/2/82,11/12/83, 3/18/83, first 0
'83-5/11/83 Project Mgnt. Manual - 16.2 Management CARS I-83-01, 02, 03, A-83-01, A-83-02 Contractor Trend Reports QE Monthly report 6/30/83 and weekly reports prior to that date Executive Review Meeting Minutes, January 1981 to June 1983
s s
v.,
Site Annual Audit Schedule first quaryter update 5/12/83 Supplier Annual Audit Schedule, first quarter update 5/10/83 Cherne (Site) audit #83-Cerne-01, completed Feb. 83 Quality Engineering-Mechanical Mandatory Hold Point Status Log for l '.
t Cherne Construction Surveillance Report #Cherne CC-083-0389, empleted 7/15/83 Construction Surveillance Report #Cherne CC-083-0393, completed 7/15/83 Cherne Procedure 15.4, Rev.
12,
" Installation of Mechanical Equipnent" Quality Engineering-Electrical Mandatory Hold Point Log for Commonwealth-Lord Various QE Electrical letters to C-L establishing MHPs PHP 7-7, Rev.1 PMP 10-2, Rev. 2 CAR 282 PSI 0047, dated 2/25/82 RFE S82-04 dated 2/25/82 Safety Review Committee meeting minutes #409 dated 2/26/82 Suspected Trend Investigation Report (STIR) dated 2/8/83 CAR 283 PSI 0040 dated 3/7/83 RFE S-83-09 dated 3/9/83 Cwmonwealth-Lord NCR #54LB CAR 282 PSI 220 PQAM, Sec.15, Rev. 9 PQAM, Sec.16, Rev. 8 PMP 16-3, Rev. 2 PMP 2-4, Rev. 0 NRC Audit #81-22, dated April 13, 1982 (Docket No. 50-546,50-547)
Several other NRC audit folders Project Review Meeting notification mmo and agenda for 5/16/83 Project Review Meeting agenda for May 25, 1983 Critical Items List meeting notification mmo and action item sheets for July 8,1983.
Project Management Manual, Volunes 1 and 2; PPM Policy Statement PHP 5-3, Rev. 3 PMP 5-4, Rev.1 PMP 5-6, Rev.1 Several contractor procedures:
CONAM Proc. 59-Mr-023 Newberg Proc. QAP 9.01 Pullman Proc. IMP 2.2 Cmmonwealth-Lord Proc. QWP-Cll I
Cherne Proc. 11.1 l
S&L Proj. Inst. PI-Mi-004, Rev. K l
QCP-5, Rev.12 TMP-15, Rev. 5 CAL-12 6/30/83, Morrison to Beckham, QE Monthly Report I
IQAM Policy Statement 7/16/82, 7/27/81, 6/4/80, 1/22/80 l
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r 1.'
,. Level A Orientation Lesson Plan, Rev. 3 Level B Indoctrination, Rev. 3 Management Audits 1980-1983 11/8/81 " Introduction for Performance of Management Audits..." by Shields 83-mMfAUD-01 (ASME) 3/83 82-E MfAUD-02 12/82 82-EMfAUD-01 (ASME) 5/82 NUS-3950 12/81 81-EMfAUD-01 (ASME) 5/81 16-E NTAUD-01 (ASME) 16-mMfAUD-02 (NUS) 3/81 Rev.1/81 Critical Items List meeting notification and Action Items.
Approved Position Description for " Supt - Quality Administration" Approved Position Description for " Audits Manager" Job Description for " Operations Quality Assurance Supervisor" Job Description for " Senior Operations QA Engineer" Job Description for " Operations QA Engineer" Job Description for " Senior QA Engineer" Job Description for " Quality Administration Supervisor" Job Description for " Quality Engineering Manager" Job Description for " Senior Doctanent Inspector Level III" Job Description for " Senior Quality Engineer" Job Description for " Quality Engineering Surveillance (Lead)"
Job Description for " Quality Engineer" Job Description for " Quality Assurance Receipt Inspector Supervisor" Job Description for " Quality Records Verification Manager" Job Description for " Discipline Quality Engineeing Manager" Job Description for "" Supplier Audit Supervisor" Job Description for
" Senior Supplier Quality Engineering Representative" Job Description for " Supplier Quality Engineering Representative" Job Description for " Site Audit Supervisor" Job Description for " Audit Manager" Job Description for
" Senior Quality Assurance Engineer (Lead Auditor)"
Job Description for "Startup Quality Assurance Engineer" Job Description for "Startup Quality Assurance Manager" Job Description for " Senior Startup QA Engineer" 7
POTDrfIAL FINDIIE REPORTS
'No Potential Finding Reports were initiated under Task A.
These are stenarized belcw:
PFR 3 Subject Classification 2485-006 QA Job /Fosition Descriptions Not Available 2485-011 PSI Management Audits Not Available