ML20080K266

Responds to 780208 Immediate Action Ltr Re Concerns, Including Use of Outside Audit Team & Establishment of Effective Contract Spec Control Sys.Mods to Sys Listed. Related Info Encl

ML20080K266
Person / Time
Site:	Perry
Issue date:	05/01/1978
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20079G896	List: ML20080K266 ML20080K277 ML20080K281 ML20080K287 ML20080K302 ML20080K318 ML20080K332 ML20080K342 ML20080K357 ML20080K361 ML20080K422 ML20080K457 ML20080K461
References
FOIA-83-199 NUDOCS 8309290080
Download: ML20080K266 (20)

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5 THE CLEVELAND ELECTP,1C ILLUMIN ATING C016PANY ettumaims stoc. . rusue sovant . ettvataNo. omo anoi . titer,.oN ami sn.use . ud soc,ntss e.o sox sooo Serving The Best Location in the Natyn Dahyyn R. Davidson

• vaCl PAtsIDINT

• enc 8NIERING

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- May 1, 15ff8 _ i -

4 Mr. James G. Keppler, Director U.S. Nuclear Regulatory Co ission Region III Office of Inspection and Enforcement 793 Roosevelt Road Glen Ellyn, niinois 600137

Dear Mr. Keppler:

This letter is our response to your Icmediate Action letter of yebmary 8, 1978. The Imediate Action Ietter addressed eight areas of concern.

Tne first five ite=s have been resolved with the members of your staff, as a result of inspections on site and review of the actions taken on our part. In order that this letter be co:plete, I have attaebe5 as Appendix 1 a brief su-y of the first five itecs and resolution status.

Vith respect to Items 6, 'l and 8 of your letter, a thorcrash review was uniertaken both interns.ny and s-ith the use of an cratside auditing team, it crder for us to aSdress these concerns.

Ite- 6 of the 7ebruary B,1978 Tr: mediate Action letter in part identifies tu teed to establish an effective contract specificLtionr control syste=.

It response to this concern, the syste= vas reviewed including auditing er t.11 project and sr.fety-related contractors files.

It the audit of the existing files deficiencies which vere ferand, have beer. corrected and au files updated including control copies. The

" Specifications" include attachment Specificatiens, Engineering Change Estices, and Field Varis,nce Autberizations. .

The system was then reviewed and several rodifications vere made. In

• Eeneral these consisted of the :follcuing: ,

A. The syste= nw utilizes a control number distribution with l return receipts required. All distribution responsibilities l are nw at the Site Document Control Centar.

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2. The specifications status system is in part monitored on a

> (7 ' '/ T co:Puterited/ ten.inal system identified as EEWSPEC. Field i Variance Authorizations are presently monitond manuaHy.

A maintenance system was established which centralizes the responsibility for inputting of all new or change in-

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formation through the Site Document Control Center. The 8309290080 830622 PDR FOIA HIATT83-199 PDR .

6 Mr. James G. Keppler May 1, 1978 i:

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system provides for continuous monitoring of specification <;

status, bovever, periodically, at a minimam quarterly a status reviev vill be conducted as spelled out in a pr,oject procedure. In addition, audits by Site Quality Assurance - a vill be performed to verify correctness.

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C. The project and contractor files were updated including elimination of xerox copies.

D. Procedures were developed to define the syste= and spell crat the me banics to operats it. In addition, instructions have been developed for personnel operating the system.

E. All project and construction personnel received training and indoctrination presentations. Included were the familiarization with the procedures and scoping of responsibilities.

With the implementation of the above ve consider we have in place an effective syste= for assuring the timely and controlled distribution of specifications. All safety-related construction contracts are included and non-safety and equipment contracts vill follow.

An evaluation was perfomed to deter =ine the acceptability of the concrete batched by Fational Hobile Co=pany to a superseded design specification during the time period from August 5,1977 to Tetruary,1978. roe result of this evaluation by the cognizant design engineer concluded that the concrete produced to revision VI of EP-14-45hn-CXXO vill satitty the.

design recrairements. Each of the 31 notifications that were cade in revision VII of SP-lh-h5h9-0000, vere evaluated. These modificationc vere in the following general e.rer.r:

1. Expansion and clarification to rcrovt redundencies and resolve conflicts.

2. Fodification of certain procedural changet that do not affect quality.

3 Modification of certain requiremente to facilitate field conditions withcrat sacrificing quality.

Most of these modifications incorporated into revision VII had been previously issued as ECN's applicable to revision VI. It is our opinion and that of the responsible design engineer, that production of quality concrete at the Perry Plant vac not affected by any re-vision of the specification being held by the batch plant contractor.

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• Mr. Jattes G. Keppler -

3- May 1, 1978 ,

d s -i Item 7A. An evaluation of the indoctrination and trainirig program

<f was made. It was concluSed that the program needs improvement.

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Accordingly CEI will restructure the indoctrination and training program to include a unifom appromeh to indoctrination w25 training - .

for various organizations, including contractors. Outlines sill be ccc:pleted by mid-May and the schedule for implementing training sessions vill be co=pleted by the third week of May. Regular in- ,

doctrination sessions vill be started during May and vill continue on a regular basis as defined in the indoctrination and training outline.

Item 73. Daring our evaluation it was determined that the noncon-formance reporting system as implemented on the site, is an effective system. There have been occasions however vbere documents other than nonconformance reports have been used to note problem areas. Effective imediately, a policy statement has been issued that only noncon-fomance reports will be utilized in defining nonconfoming conditions.

Item B. To evaluate our program effectiveness, a special quality Assurance Task Force was established consisting of representatives from Gilbert Associates, Inc., Kaiser Engineers, CEI and an independent QA consultant Mr. J. P. Jackson of Management Analysis Company. The Epecial QA Task Force has performed a thorough evaluation including on-site and off-site audits.

This Task Force issued an Interim and a Final Report evaluating the overall effectiveness of our program. Tne methodology of the Task Force was to conduct indepth interviews with all key project personnel plus audit selected contractors and site elemen's (CQA, CQO and FCbD),

and the home office departments (NED, Purchasing, and KQAD).

Tne Tash Force then evaluated the results of these audits end interviews with respect to the effectiveness of the progrs=. This translated into specific findings relative to the appropriate 100TR50, Appendix 3 criteria and the FHFp PSAR Chapter 17 cc.__itseents.

Recoc=,endations vere provided and a plan has been established based on these findinge in order of priority which addressed relative significance to the action necessary to improve our progran effectiveness. The priorities themselves were based on:

a. Those items which were critical to the overall corrective action progra= and required top canagement priori.ty,

b. Those actions which vere required for QA program implementation,

c. Those actions required for improves'ent to the QA program.

The following conditions were identified as a result of crar evaluations as those that have contributed to the causes of the items identified I

as Items 1 through 6 in the Immediate Action Letter.

'J Mr. James G. Keppler -%- May 1, 1978 '

A. The CEI QA Program is de' fined in many different manuals. 7 There is no single nanual that defines critical controls necessary to implement the QA program on a corporate basis. This lack of definition as to vbo is responsibla ,

bas resulted in confusion as to primary responsib,ility in implementing the program.

2. The techniques for resolution of conflicts has not provided timely response to noted problem areas. Additionally, the degree of r.anagement involved in resolving problem areas within the CEI QA program has ncrt been co=:ensurate with the need for resolution of QA program issues.

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The reorganization of 1977 vbich merged the Site QA/QC .

activities, created voids in certain areas of the QA pro-gram vbich should have included redefinition of responsibilities, particularly in the area of surveillance / inspection and audits.

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Each contractor is held totally responsible for total QA pro-gram, with: rat consideration for the integration of CEI QA/QC functions with those of those contractors.

Comensurate with the priority of the recomendations CEI bas acco:plished those items vbich were identified as critical to the overall corrective action program and required top r.anecesent priority. Tne following su=arines the changes initiated and co=pletti.

Item 1 -- The M/QO organization at the site has been re-organized to unify it under tbt direction of a Ge:ertl Supervising Evinee:. 1:. oddition the, assignments be.ve been revised so as to provide

e. single rer;casible quality engineer for each contrLeter.

Ite::. 2 -- Tne Sitt C atlity Enutls are it the process of being consoliitted reflecting the redefined responsibilities and procedures of the site @/QO organize. tion.

i Item 3 -- A QA Advisory ccrJ- ttee has been established to assist '

the CEI Nuclear Quality Assurance Department Manager with inputs and reco=endations to key program de-cisions, orientation of QA concepts and methods as well asaccessingoverallcorporatesupportbyCEI/GAI/EEI to the direction taken by the Nuclear Quality Assurance 1 Department Manager.

This committee vill te co= prised of Mr. M. R. Edelman,-

Manager of the Nuclear Quality Assurance Department, Mr. R. R. Barker, Manager of Construction QA at Gilbert Associates, Mr. E. V. Knox, Corporate QA Manager of l Kaiser Engineers. '

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, Mr. James G. Keppler May 1,1978 Item h -- The Nuclear Quality Assurance Department Manager 'I has established a plan thieb provides a schedule for completing modification to the QA program.

Weekly meetings have been scheduled to track and ,

report progress to upper management. ,

Additionally, the Nuclear Quality Assurance Depart-ment Manager has established a program of quarterly reviews to CEI top management to incorporate the inputs from the Advisory Co=ittee, as well as, re-view the QA program through evaluation of audits, corrective action reports and other management tools.

Item 5 -- ne nuclear Quauty Assurance Department has been reorganized to reflect the findings and reco=mendations of the Audit Task Force. Attachment 2 depicts the revised organization and lists the primary responsi-bilities of the key individuals involved.

Item 6 -- CEI has established a schedule for the restructuring of the audit program, both at the Site, our con-tractors and our QA agents.

Item 7 -- CEI has established and has started the i=plementation at the Site of an integrated inspection / surveillance progra=. The progra= includes witness points tied to contractors inspection planning documents and includes in-process surveillance inspections, as well as, surveillance inrpection of completed work, he surveillu.ce intpection planning vill be approved by a respontitle Quality Engineer. Co:plete i=ple entEtion is anticiptted by rid-Jun?..

Ite= 8 -- Tne receiving inspection program has been expanded beyond e. count and ds= age check and is nov based en input of quality engineering to deter =ine on a ca.se by case basis the necessary inspection required.

Implementation has been started with co=plete imple=entation anticipated by mid-June.

i Item 9 -- The NQAD Manager vill use the formal management chains to resolve conflicts, with the corporate QA program clearly indorsing his authority to resolye quality issues. The corporate quality assurance management co= ittee has been redefined as a communication vehicas.

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. i Mr. James G. Keppler

- 6 h y 1, 1978 ,

In addition, actions that were identified by the Task Force and deemed ,.

necessary, but not yet cotqpleted, are as fonows: ,

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CEI has strengthened our quality assurance program, by .

• co:qpleting the items described previously. In addition ve purpose to reissue our Corporate Raality Assurates htraal to reflect these improvements as ven as clearly define the interfaces between an departments performing quality related functions. This manual win reiterate the strong CEI co:r.itment to the @ program indicating that the u.anual wast be followed by au persons involved with respect to the Perry Project, and that changes will be considered and processed immediately if the situation varrants. The manual win clearly provide guidance on how CEI will address with liegulatory Guides identified in the PSAR. Sebeduled cecpletion date for issuance of this r.anual is August,1978.

2. CEI will evaluate the effectiveness and erpertise of pre-sently available in-house personnel, consistent with the revised departmental organization. CEI wi n e= ploy ex-perienced quality assurance personnel in the key supervisory roles as defined on the revised organization chart as shown in Attaebment ccepleted 2 1.

by June of this let.::. This evaluation vin be CEI vin continue to draw upon Gilbert '

Associates and Kaiser perro.nel fer support as deemed necessary by the Nuclear QA Department h*.tger.

3 CEI will restructure the t.uiit yrogra= and coordinate the audit review reports fro = all ele .setr . The audit program win cover all arpects of tbc prg :e including agents, design e.ctivities, construction e.etivities as well as internal CEI e.etivitie t . Tnis revised tudi, progra= vin . serve as the backbone f er the Nuclear Raality Assurance Depe.rtment Manager as e tool to e.ecess the effectiveness of cr.tr overe.11 E pro-crte . Tr.it iE anticipated to bt implemented by June 1.

h. CEI vin Irovide direct support to selected contractors in the QA/E t.rea vbere it is deterr.ined by the responsible quality engineer that such support is needed. This vin prevent der. suds on contractors to establish @ programs that are beyond their capabiMties to implement effectively.

This will be implemented on as needed basis. ,

5. Additional detailed reco==endations for improvement in the CEI QA Program based on the Special QA Task Force have been reviewed and win be included as aIpropriate in the revised QA Manual. These are anticipated to be completed by August 1,1978.

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• Mr. James G. Keppler May 1, 1978 ,

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In sumary the three month accessEent made of our program'by the out- <.

side auditing team plus our own evaluations as to our effectiveness ,

bave provided beneficial input to au parties involved. gignificant inprovements have been made and win continue to be made to make our - +

program overall more effective. I will provide close attentfon to the development of the revised QA Eanual and review the effectiveness of our overall quality assurance progrs=. With the co=itments that we have made and, the changes that have been i=plemented, we feel that our quality assurance progra= vill provide a effective means of controlling quality on the Ferry Project to insure the plant is built to applicable standards and designs.

Very truly y:rars,

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Dalvyn Davidson Vice President - Engineering DRD:ge Attachments m

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ATTAGOENT 1

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SU!FJJtY OF ACTION TA}ri ON IJCTDIfE ACTION IMR ITnG 1-5 RAC) GROUND Based on concerns noted in Iteu l-5 of the liRC Imediate Action 14tter of February 8,1978, numerous actions have been taken and these actions have received concurrance during various ERC' inspections. The following is provided as a su:r:utry of these activities. IrnC letter of March 31, 1978 Inspection Report 2io. 50-Wo/78-03, 50-M1/78-02 provide additional detail and liRO evaluation on these actions.

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.. Item.1 and 2. Safety-Related Piping Tabrication and Installation

' ' Deficiencies noted by the NRO, prompted CEI QA Elements to st.op work on Pullman Power Products in the areas of safety-related pipe fabrication, yard piping installation, and Plant piping. Several modifications to the specifications 't and the quality program requircents were initiated by CEI, GAI, and PPP. ibese measures included Pullman initiat-ing procedures for " Document Control" and " Design Control" ' -

vbich were sub:titted to and approved by the CQA Element.

Pullman fabrication and erection drawings have be'en submitted to GAI Design Ingineer for review and approval in accordance v' these procedures. Gilbert Engineering has issued an EU to SP-W vhich establishes the requircents for the Design Ingineer's review of contractor's piping drawings.

This area has been monitored by CQA to assure that these requirements are being met.

Pullman has implemented a procedure for "Pield Handling of Materials and Equipment" which was approved by the CQA

• Ilement. CQA has vitnessed Indoctrination and Training classes conducted by Pullman on QA Program Requirements. These

/ classes were documented and are to continue on a regular basis.

Pullman has since e= ployed a training officer on site to conduct these classes.

One hundred percent surveillance inspection was implemented by the GAI Resident Inspector at Pullman's Williamsport, Pennsylvania shop. On March 16, 1978, Mr. R. L. Spessard of ERO Region III approved the use of a sa=pling plz.n per MSP-033, Rev. 3, and CEI letter dated Mareb 9,1978.

CEI letter dated February 18, 1978 established the retaire-ment for the GAI Design Engineer to:

1. Review 10D% safety Clast I rpool drawingt.

2. Sa=pling per MSP-033, Part.. C.3d applied to spool dravings or.ly for refety Class II an".

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Subsequent KRO review of there corrective action mer.rares resulted in the release of P@n Power Products for safety-related work.

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Item 3. PBI Industries sarety-Related structural steel and Ibbeaments ,

The installation procedural controls on safety-related ested='ents and structural steel have been todified to assure co:pliance to AWS D.1.1-1972 prior to placement. The CQC element-bas superimposep an inspection program of 100% verification of the vendor's and our manufacturing assurance inspection programs.

These additional inspection measures include 100% recei'ving in-spection of au new embedments and structural steel delivered to the site,10$ inspection of all e. bed:ents and structural steel currently in inventory prior to their issuance to contractors, and for those ite=s previourly issued,100% inspection of all e= bed =ents and structural steel prior to their placement.

These currently established zeacures have been reviewed and found acceptable by 23C inspectors as indicated in the March 31, 1978 report (50-40/78-03,50-W1/78-02).

To establish cocpliance at the vendor's facilities the CEI vendor assurance progra= bas been increased to include 100% surveillance of all e= bed =ents and structural steel being fabricated. Finally, the vendor's inspection program has been altered to include the additional detailed acceptance criteria provided by the Design Engineer.

' When FBI and its subsidiaries are released to resume shi Irnents, and all existing inventory has been inspected, an evaluation shall be performed to deterrine the future procedural controls for assuring co plience to AWS D.1.1-1972. This evaluation and reco= ended course of action sban be discussed with the NRO prior to being i=plemented.

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Item h. ' O. B. Connon Nuclear Coatings As a result, of the deficiencies noted by the NRC, C@ issued a Stop Work Notice and Corrective Action Request (CAR) to 0. B. Cannon.

ne CAR identified five deficient conditions in their E program 't and inplementing procedures in the areas of verification of r.aterials prior to use, qualifications of personnel, and performance of audits.

De contractor's response to the Corrective Action Request , included .

(1) the correction of coating applicators' qualification l records in accordance with 0. B. Cannon procedures; (2) the inspection status tagging of all cans and cartons of coating raterials in the storage area; (3) the r.issing physical ex- '

ar.ination record was returned to 0. B. Cannon's site QC file; (4) the O. B. Cannon QC manual was revised to include the re-view and approval of manufacturers' material certification; and (5) the contractor's first internal project audit was perfonned. -

ne contractor's implementation of these corrective actions was verified by CM and a partial stop work release for Class II coating work (non-safety related) was issued.

D en February 18, 1978, the NRC reviewed O. 3. Cannon's E program and procedural improve =ents and observed the corrective actions taken.

As a result of this review and observation, the NRC inspector concluded that safety-related coating work could be pemitted to rer.nne. - Sub-sequentially, a full stop work release was e.pproved and issued by CM. -

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's Item 5. Safety-Related Concrete Placement '

prior to resuming safety-related concrete placement by each of our four placement contractors, several QA program adjustment's were made. V These changes included a new slump testing procedure Wich requires, upon detection the higb/ low slump, the suspension of placement and the sagling of each truck until slump is back within specified limits. ~

An indoctrination and training meeting was held with contractor's vibrator operators and a proce$ ural requireaent was added to rebrief and provide attestation of vibration operator training prior to each placement.

The CQO detailed procedures and inspection plans were re-vised to reflect ireplementation of 100% CQO inspection of contractor preplace ent inspection activities. CQA performed detailed program audits of each contractor and CEI r.anagement met with contractor ranagement to e=phasize their contractural obligations with respect to quality control. t I

t Upon co=pletion of these activitieg and the review and inspection lof preplacements by KRO inspectors, contractors were individually released to place safety-related concrete. Th;n,inadditiontocontinued100%

i CQO inspection, CQA performed audits of preplacement and placement activities by both the contractor and CQO on all safety-related pours.

A subsequent CQA evaluation of these audits was reviewed by and agreed to by the ERO on April 14, 1978 and the CQA audit freguency on two of i the contractors (National Engineering and Great Iakes) vas reduced to one audit per week.

t As of this response date, the other two contractors (S & M and MCK ___ _

Corporation) shall continue under the CQA audit of every placement progra: until several pours can be made by each organization and a level of confidence is established.

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ATTACHMENT _2 OR3ANI7ATIONAL RESPONSIBILITIES 4 i

'i (A) Construction Quality Section - GSE " -

1. Coordinate all site quality functions 2.

Primary contact Nuclear Regulatory Ccc:::ission inspections ,

3 Responsible for all line supervisory functions (3) Raality Ingineering (Construction Qaality Section)

1. Contractor quality assurance programs

2. Establishing inspection requirements Coordination and disposition of nonconformance reports 3 -

h. Obtain correction action 5

Contractor; procedure review

6. Receiving inspection plan 7.

Audit contractors / site organization B. Review procurement documents 9 Analysis Establish and reports trends site quality assurance records require =ent 10.

11. Coordinator off site quality infort:.ation requests (C)

Quality Administration (Construction Raality Section)

1. Audit tracking

2. Indoctrinatica and training 3 Quauty manual control

k. Quality assurance records 5

Eonconfomance Report controa. ,

(D)

Inspection (Construction Quality Section)

1. Surveillance inspection

2. Receipt inspections 3 I)o:a=entation of inspections

h. Prepare Konconfomance Reports (E) Program Quality Section - GSE 1.

Coordinate all design, procure =ent, manufacturing activities Primarily

2. Resp,onsible for agents quality assurance efforts, inc.

GAI/QA Program

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3 Responsible for all line supervisory functions t

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F Quality Engineering (Program Quality Section)  ;

Review of contracts

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2. Vendor preavard meetings '

3. support audit program

4. Quality engineering support to Nuclear Engineering Department '

5. Quality engineering support to Purchasing '

6. Safety Analysis Report reviews *

(G) Quality Assurance Administration (Program Quality Section)

1. Audits

2. Indoctrination and training

3. Procedures

4. Records ,

5. Sebeduling and expediting .

, (B) Operational Quality Assurance (Program Quality Section)

1. Operations " quality assurance progrs= planning

2. Startup and Test quality assurance support (I) Quality Assurance Advisory Co=:ittee _

1. Input on quality assurance progra= policy

2. Input on quality atsurance methods and techniques 3 Quality assurance 2:anagement for GAI/KEI support G

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Nuclear Q.u;2t1 As'suranca Program 020CI Page 3 of 4 1Rev. _M_ Effective _7/ 7 /

% 1.4 . Management Review and Evaluation

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l Overall assessment of the scope, implementation and adequacy of the Quality Ass'urance Program shall be made by the QA Advisory Committee. This commit-tee consists of the CEI Nuclear QA Department Manager as chairman with QA management representatives from Kaiser Engineers, Gilbert Associates, an-d other agents, as approved by the chairman. This committee is chartered to perform quarterly reviews of the program and to report the results through the QA Department Manager, to top CEI management through corporate reporting channels. These reviews shall be documented and shall incorporate the Input

. provided by:

.a. The personal assessments of QA agent representatives on the.committei.

b. Audit trend analysis provided by PQS Quality Administration.

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c. Nonconformance trend analysis provided by CQS Quality Engineering.

d. Corrective Action Request evaluations providsd by PQS and CQS General Supervising Engineers.

e. Evaluations provided by outside audit groups or QA Task Forces which may be organized by the QA Advisory Committee to provide specialized ,

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f. Conventional management appraisal and analysis techniques. /

1.5 Resolution of Program Impasses Disputes arising from the interpretation of the Nuclear Quality Assurance Program shall be resolved at the lowest possible level. '

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,The hierarchy of each project department provides for squa4 interfaces from

' department specialists through various levels of supervision. This organi-

' zational consistency should provide ample opportunities for problem resolu-tion through simple escalation. /

V Those conflicts which cannot be resolved at lower levels shall be referreck to the NQA Department Manager. The Nuclear QA Department Manager shall attempt to resolve the problem with the Manager of the other concerned ^

department, or, if ::= % escalate to the executive level, using the advice of his QA Advisory Committee as appropriate.

1.6 Indoctrination and Training .

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,. Procedures shall be established tc assure that personnel performing quality

.. related activities are suitably trained and qualified to perform their' work.

, Each project Department is'. responsible for organizing, implementing, and

, f/ documenting appropriate training measures necessary for their project 7' functions.

/// Procedure $and Records sevrew p abost t ITs aud eh opNw;; eld /MocSSS1-of trainin o.u gw ,

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Corporate Nuclear Qutlity Assur:nca Progrca 0200 Rev. 1 Effective n/JQ88 Page 3 of 4 1.4 Management Review and Evaluation Overall assessment of the scope, implementation and adequacy of the Quality Assurance Program'shall be made by the QA Advisory Committee. This commit-tee consists of the CEI Nuclear QA Department Manager as chairman with QA management representatives from Kaiser Engineers, Gilbert Associates, and other agents, as approved by the chairman. This committee is chartered to perform quarterly reviews of the program and to report the results through the QA Department Manager, to top CEI management through corporate reporting channels. These reviews shall be documented and shall incorporate the input provided by:

a. The personal assessments of QA agent representatives on the committee.

b. Audit trend analysis provided by PQS Quality Administration.

c. Nonconformance trend analysis provided by CQS Quality Engineering,

d. Corrective Action Request evaluations provided by PQS and CQS General Supervising Engineers.

p. Evaluations provided by odtside audit groups or QA Task Forces which may be organized by the QA Advisory Committee to provide specialized input.

f. Conventional management appraisal and analysis techniques. ,

e' l.5 Eesolution of Program Impasses f pisputes arising from the interpretation of the Nuclear Quality Assurance rogram shall be resolved at the lowest possible level.

The hierarchy of each project department provides for. interfaces from department specialists through various levels of supervision. This organi-pational consistency should provide ample opportunities,for problem resolu-pion through simple escalation. -

r Those conflicts which cannot be resolved at lowe'rvlevels shall be referred to the NQA Department Manager. The Nuclear QA Depa tment Manager shall attempt to resolve the problem with the Manager of the other concerned department, or escalate to the executive level, using the advice of his QA Advisory Committee as appropriate.

1.6 Indoctrination and Training

,, Procedures shall be established to assure that personnel performing quality related activities are suitably trained and qualified to perform their work.

Each project Department is responsible for organi' zing, implementing, and i documenting appropriate training measures necessary for their project l functions. Procedures and Records through its review process of training l

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1 Corporata Nuclear Quality I

Assurance Program 0200 Rev. 2 Effective 11/5 7 79 Page 3 of 4 All procedures and instructions shall be approved and established, with training accomplished, prior to the start of the activities being con-trolled. Issuance, distribution, and revisions shall be controlled to

• preclude the use of obsolete documents.

Reference indexes, demonstrating the Quality Assurance program's address i with respect to the guidelines provided by Quality Program Regulatory l j Guides and American National Standards (ANSI) are presented in Appendix I.

1.4 Manaaement Review and Evaluation O'jrall assessment of the scope, implementation and adequacy of the Quality Assurance Program shall be made by the QA Advisory Committee.

This committee consists of the Manager, NQAD, as chairman with QA management representatives from Kaiser Engineers, Gilbert Associates, and other agents, as approved by the chairman. This committee is chartered to perform quarterly reviews of the program and to report the t

' results through the Manager, NQAD, to top CEI management through corpo-rate reporting channels. These reviews shall be documented and shall incorporate the input provided by:

a. The personal assessments of QA agent representatives on the committee.

b. Audit trend analysis provided by the Program Quality Section (PQS) Quality Administration.

c. Nonconformance trend analysis provided by~ the Construction Quality Section (CQS) Quality Engineering.

d. Corrective Action Request evaluations provided by the General Supervising Engineers, PQS and CQS.

e. , Evaluations provided by outside audit groups or QA Task Forces which may be organized by the QA Advisory Committee to provi e

$specializedinput. ... ' e

~

f.

. Conventional management appraisal and analysis p tecN,gue((,.'(

1.5 Resolution of Program Impasses

• C i v ,.s[j.-

Disputes arising from the interpretation of th uclear Quality Assurance

Program shall be resolved at the lowest possibl -revel.

The hierarchy of each project department provides for interfaces from 4

department specialists through various levels of supervision. This

. ,. organizational consistency should provide ample opportunities for problem resolution through simple escalation.

i i

Those conflicts which cannot be resolved at lower levels shall be referred to the Manager, NQAD. The Manager, NQAD shall attempt to resolve the problem with the Manager of the other concerned department, or escalate to the executive level, using the advice of the QA Advisory Committee as appropriate.

7 Corporate Nuclear Quality Assurance Program 0200 Rev. 3 Effective 4/ -~~

6 /81 Page 3 of 4 References cre addressed in detail in the eighteen sections which comprise this Manual. The requirements of this program shall be implemented in accor-dance with detailed procedure and instruction manuals.

All procedures and instructions shall be approved and established, with training accomplished, prior to the start of the activities being con-trolled. Issuance, distribution, and revisions shall be controlled to preclude the use of obsolete documents. ,

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$$8h kh.YN$kh5EAE55h5N 1.t.krespectrJewethewgtritleMddW CMdawnMA=ANieusv4M1_?c'%ynagideddydydj.tMJpgram Regulator <

ifaaiMANSIL are pre $e' rite 713Yl%peIt. ,;p 1.4 MANAGEMENT REVIEW AND EVALUATION Overall assessment of the scope, implementation and adequacy of the Quality Assurance Program shall be made by the QA Advisory Committee.

This committee consists of the Manager, NQAD, as chairman, the Managers, Nuclear Engineering and Perry Plant Departments; with QA management representatives from Kaiser Engineers, Gilbert Associates, and other agents, as approved by the chairman. This committee is chartered to perform quarterly reviews of the program and to report the results through the Manager, NQAD, to top CEI c.anagement through corporate

' reporting channels. These reviews shall be documented and shall incorpqrate the input provided by: .K. .

t

a. The personal assessments of QA agent represen the p [.o e fve. .so committee.

b. Audit trend analysis provided by the Prog Quality Section (PQS) and Training / Administration Section.

c. 'lonconformance trend analysis provided by the Construction Quality i

Section (CQS), Training /Adminiatration Section and PrpRram Quality i 9ection-

~

l d. I Corrective Action Request evaluations provided by the General '

kSupervising Engineers, lqS and ] .

c. Evaluations provided by outside audit groups or QA Task Forces which may be organized by the QA Advisory Committee to provide specialized input.

"f. Conventional management appraisal and analysis techniques.

i 1.5 RESOLUTION OF PROGRAM IMPASSES Disputes arising from the interpretation of the Nuclear Quality Assurance Program shall be resolved at the lowest possible level.

I l

4 Corporate Nuclear Quality AssuranceProgramy00Ef Rev. 4

/_ fective _/_.L Page 3 of 4 References the corresponding safety-related activities are addressed in detail in the eighteen sections which comprise this Manual. The requirements of this program shall be implemented in accordance with detailed procedure and instruction manuals.

All procedures and instructions shall be approved and established, with training accomplished, prior to the start of the activities being con-trolled. Issuance, distribution, and revisions shall be controlled to preclude the use of obsolete documents.

Reference indexes demonstrating the Corporate Nuclear Quality Assurance Progra'm's address with respect to the guidelines provided by Regulatory Guides and American National Standards Institute (ANSI) are presented in Appendix I.

1.4 MANAGEMENT ASSESSMENT Management assessment of program effectiveness shall be through j regular and documented reporting channels on a month by month basis, 1 and through a Quality Assurance Quarterly Evaluation.

t In addition, a Quality Assurance Ar'visory Committee (QAAC) 'has been established as an independent group to conduct regular review and evaltyition of the QA Program for the Perry Nuclear Power Plant (PNPP).

) The committee shall advise the Vice President - System Engineering

) and Ccinstruction on the adequacy of scope, implementation and D effec;iveness of the PNPP QA Program, and on CEI QA policy matters

! as thEy relate to PNPP.

The QAAC shall have an approved charter addressing frequency, membepship, and responsibilities.

1.5 RESOLUTION OF PROGRAM IMPASSES Disputes arising from the interpretation of the Corporate Nuclear Quality Assurance Program shall be resolved at the lowest possible level.

The hierarchy of each project department provides for interfaces from department specialists through various levels of supervision. This organizational consistency should provide' ample opportunities for problem resolution through simple escalation.

<- Those conflicts which cannot be resolved at lower levels shall be referred to the Manager, NQAD. The Manager, NQAD shall attempt tc, resolve the problem with the manager of the other concerned department, or escalate to the executive level, using the advice of the QA Advisory Committee as appropriate.