ML20023C024

Self-Initiated Evaluation.

ML20023C024
Person / Time
Site:	Perry
Issue date:	10/31/1982
From:	CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20023C016	List: ML20023C021 ML20023C024
References
NUDOCS 8305090493
Download: ML20023C024 (213)

Text

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I TABLE OF CohTENTS SECTION PAGE INTRODUCTION i PURPOSE AND SCOPE 11 -

DETERMINATION 111 FORMAT iv

SUMMARY

OF GOOD PRACTICES AND FINDINGS v PERFORMANCE EVALUATION

SUMMARY

AND DETAIL SHEETS

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OA.1 ORGANIZATION STRUCTURE 1 OA.2 MANAGEMENT INVOLVEMENT AND COMMITMENT TO QUALITY 5 OA.3 THE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS 8 DC.1 DESIGN INPUTS 11 DC.2 DESIGN IhTERFACES 15 DC.3 DESIGN PROCESS 20 DC.4 DESIGN OUTPUT 24 DC.5 DESIGN CHANGES 27 CC.1 CONSTRUCTION ENGINEERING 33 CC.2 CONSTRUCTION FACILITIES AND EQUIPMENT 37 CC.3 MATERIAL CONTROL 40 CC.4 C0hTROL CF CONSTRUCTION PROCES3ES 52 CC.5 CONSTRUCTION QUALITY INSPECTIONS' 60 CC.6 ,

CONSTRUCTION CORRECTIVE ACTIONS 67 CC.7 TEST EQUIPMENT CONTROL 71 PS.1 INDUSTRIAL SAFETY 74 PS.2 PROJECT PLANNING 79 PS.3 PRQJECT CONTROL ,

82 PS.4 PROJECT PROCUREMENT PROCESS 85 PS.5 CONTRACT ADMINISTRATION 89 PS.6 DOCUMEST MANAGEMENT 93 TN.1 TRAINING MANAGEMENT SUPPORT 98 TN.2 TRAINING ORGANIZATION AND ADMINISTRATION 101 8305090493 8 gDRADOCK05 0

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TABLE OF CONTEhTS (Continued)

SECTION PERFORMANCE EVALUATION

SUMMARY

AND DETAIL SHEETS PAGE TN.3 GENERAL TRAINING AND QUALIFICATIONS 104 TN.4 TRAINING FACILITIES, EQUIPMEN"I, AND MATERIAL , 110 QP.1 QUALITY PROGRAMS 113 QP.2 PROGRAM IMPLEMENTATION 116 QP.3 INDEPENDENT ASSESSMEhTS 121 QP.4 CORRECTIVE ACTIONS 124 TC.1 TEST PROGRAM 127 TC.2 TEST GROUP ORGANIZATION AND STAFFING 130 TC.3 TEST PLAN 13S TC.4 SYSTEM TURNOVER FOR TEST 138 TC.S TEST PROCEDURES AND TEST DOCUMENTS 142 TC.6 SYSTEM STATUS CO.VTROLS 146 APPENDIX I TEAM ORGANIZATION CHART AND TEAM MEMBER RESUME'S I I-19 APPENDIX II ATTENDANCE LIST - EXIT MEETING II II-2 9

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INTRODUCTION ,

A Self-Initiated Evaluation, following Institute of Nuclear Power Operations (INPO) guidelines, was conducted for the Perry Nuclear Power PlantConstruction Project for Units #1 and #2 during the weeks of October 4 and 11, 1982. The Perry Plant is jointly owned by a group of five electric utilities--The Cleveland Electric Illuminating Company (CEI), Ohio Edison Company, Toledo Edison Company, Pennsylvania Power Company, and Duquesne Light Company. CEI is acting as the Owners' representative for the group.

The Perry Nuclear Power Plant is located 35 miles northeast of Cleveland, Ohio, in North Perry Village and Perry Township on the shore of Lake Erie.

The Perry Plant will consist of two 1205 MWE General Electric Boiler Water Reactor Units. At the time of this evaluation, Unit #1 (including common facilities) was approximately 87% complete and Unit #2 was approximately 45%

complete. Unit #1 is scheduled for commercial operation in 1984 and Unit #2 On 1988.

Overall management of the PNPP Project activities is the responsibility of CEI, referred to as the Owner throughout this summary. The Owner has dele-gated design responsibilities to both General Electric (NSSS) and Gilbert Associates, Inc. (A/E). Construction management assistance is provided by Raymond Kaiser Engineers,.Inc. Construction work is performed by a number of companies contracted by the Owner.

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PURPOSE AND SCOPE The ultimate objective of this Self-Initiated Evaluation is to ensure that the program in effect is meeting the performance goals intended. Specifically, '

the evaluation was performed to confirm that the plant is being built to the design requirements by identifying the existence and adequacy of controls for design, construction and other important activities. As a basis for.the evaluation, INPO developed performance objectives and criteria were used for

each of the seven performance categories examined. Conditions found in each

,' performance area were evaluated against the parformance criteria for that area, with good practices identified as well as findings requiring corrective 1 actions. The report includes these findings and the Project responses showing corrective actions planned. This evaluation was undertaken as part of an industry effort guided by INPO to examine the status of current Nuclear Con-struction Projects. Benefits are anticipated for both the Perry Project and the Nuclear Industry.

This Self-Initiated Evaluation was conducted at the Perry Site and at the Gilbert (A/E) Design Offices in Reading, Pennsylvania, to assess activites related to the design, construction, and preoperational testing of Units #1 and #2. The evaluation did not include the transmission station, fuel pro-curement, NSSS vendor, and some contractors with limited design responsibil-ities. However, interfaces with these areas were taken into account as part of the evaluation.

The evaluation examined the project organization and administration, corporate management support, design control, training, construction control, project support, quality programs, and test control activities as part of the overall assessment. Information was assembled by an evaluation team through discus-sions and interviews with Project and A/E personnel, observations of activi-ties, and reviews of procedures and documents. Interviews were held with key corporate officers of the Owner, the A/E, and the construction management consultant to assess the corporate support of the Project. Construction con-tractor activities also were included within the scope of this evaluation.

This evaluation was conducted by a team of 16 engineering and construction experts. Appendix II contains an organization chart for the team and the resumes of all team members. The team consisted of a Team Manager from the Owner's corporate office, a team leader and a liaison person from the Perry Project 0rganization, eight engineering management personnel from the Owner's corporate office, one from Toledo Edison, two consultants, and two engineering management personnel from Gilbert (A/.E) who are not associated with the Perry

Project. The team was supported by a representative from the INPO Self-Initiated Evaluation Task Force who had also participated in the three INPO pilot evaluations.

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l The evaluation team was formed in September 1982. Seven members of the team

] attended an INPO two-day workshop in preparation for the evaluation. The entire team spent two weeks at the site in training on the evaluation method-ology and in preparing work plans for the evaluation. In all, approximately '

1,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> were spent in training and preparation, and another 1,300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> were spent in performing the evaluation.

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n DETERMINATION

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Within the scope of this evaluation, the team determined that the Perry con-struction Project is under good control. This rating is based on the fact that all areas assessed were either'under good control or activities were underway to enhance existing controls.

In the process of conducting this -evaluation, the following strengths were noted: -

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1. The construction effort is being strongly supported, with all admin-istrative, quality, procurement, and engineering activities located at the site. This includes a large site design element working as an extension of the A/E design office.

2. The high level of involvement of the Owner's personnel and their leadership role in the construction support organization further emphasize tha commitment by the Owner to the Perry Project.

3. A high level of corporate management involvement and support by both the Owner and the A/E was evident.

4. Management has identified and is making the organizational changes

in a timely manner required for the transition from the construction ,

] phase to the construction / start-up/ operations phase.

S. The qualification and experience level in the overall construction organization was found to be noteworthy. This is further enhanced by the long tenure on this project of key members of the Owner's organizatica as well as those of the consultants.

. 6. The facilities and equipment to support construction were rated very good based on observations of various construction and testing activities.

7. The corporate goal of constructing a sa'fe, reliable plant is being '

actively pursued throughout the Project Organization. There was indication of high morale in many of the interviews, along with an eagerness to offer constructive suggestions.

< Through re' view of specific findings and concerns from this evaluation, some weaknesses were identified. In a number of cases those weaknesses had been recognized by the Owner with corrective measures underway, but results I observed during the evaluation did not appear sufficient to meet project objectives and will require increased management attention. These weaknesses are summarized as follows: ,

1. The document management program and the "As-Built" drawing program require a high level of effort in the near term to assure meeting Project requirements.

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2. The Preoperational Test Program, including Turnover methods, re-quires increased training at the working level as soon as possible to ensure a smooth transition from construction to test and test to operations.

3. There needs to be increased emphasis on training by Supervision to assure that existing procedures are known and followed by all Project Organization and contractor personnel.

4. In view of recent organization changes, additional specific job descriptions and position responsibility guides need to be developed for the Project Organization to assure that individuals have a good understanding of their authorities and responsibilities.

5. Storage of equipment and materials and field maintenance activities need to be upgraded.

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FORMAT The body of the report is organized as follows:

1) Seven performance categories Organization Structure Design Control Construction Control Project Support Training Quality Programs Test Control

2) Each performance category is subdivided into additional specific performance areas.

3) Each area is subdivided as follows:

A. Performance Evaluation Summary

1. Performance Objective

2. Scope of Evaluation

3. Conclusion

4. Areas of Weakness and Corrective Action; Good Practices B. Performance Evaluation Details

1. Supporting Details

2. Evidence of Scope Not Associated with Specific Findings e

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SUMMARY

OF GOOD PRACTICES.AND FINDINGS .

As discussed above, the evaluation dealt with saven specific performance ,

categories, with several performance areas in each category. Following is a summary of each category evaluation, with a brief statement of Good Practices and Findings for each area.

- Organization and Administration Th's organizational structure is in place and functioning effectively to ensure a high level of management control and the accomplishment of corporate quality commitments for the Perry Project.

0A.1 Organization Structure Finding Summary a Page OA.1-1 Good Practice: Owner's technical and support 2 -

personnel located on site.

0A.1-2 Good Practice: Integrated Project Team 2 combines strengths of several erganizations.

0A.1-3 Good Practica: Owner has formed an on-site 2 design team.

OA.2 Management Involvement and Commitment to Quality Findina Summary Page OA.2-1 Good practice: Owner requires each group to 6 submit monthly a Performance Analysis Report, which provides in-depth insight to Management.

0A.3 Role of First Line Supervisors and Middle Managers Finding Summary Page OA.3-1 Job descriptions are not available for some 9 Owner personnel.

0A.3-2 In some Sections, subtier organization charts 9 need to be developed or updated.

Desian Control

-The design control effort is generally well performed. The Construction Engineering area in particular appears to be strong as a result of having highly experienced people with long tenure on the project. There were

, few findings in the design control area and these were related primarily to lack of knowledge of procedures and vagueness in some of the proca-dures.

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DC.1 Design Inputs

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Finding Summary Page

, DC.1-1 Required A/E design input form is not used in 12 some cases.

DC.1-2 A/E Home Office Layout Department is not 12 requesting constructability reviews for layouts per procedure.

DC.2 Design Interfaces Finding Summary Page DC.2-1 After the fact design overview is not always 16 being done by A/E Home Office.

DC.2-2 HVAC specification review and documentation is 16 not always done per procedure for some nonsafety contracts.

DC.3 Design Process Finding Summary Page DC.3-1 Improved interference checking during design 21 review could reduce installation problems.

DC.4 Design Output (No Findings)

DC.5 Design Changes Finding Summary Pag _e DC.5-1 Controls do not always exist to assure prompt 28 processing of design change documents.

DC.5-2 No procedures to ensure Unit i design changes 28 are reviewed for applicability to Unit 2.

DC.5-3 Procedural address to documentation of A/E home 29 office overview of design changes is incon-sistent.

Construction Control Construction Control activities appear to be well directed. The Project Organization has developed a system to identify, evaluate and prevent reoccurrence of construction problems. This system integrates all levels -

of supervision from all companies that make up the Project Organization vii r .-y- -_ -,rr -m -

which supports the construction effort. Controls have been provided for equipment storage and test, but more effective implementation will assure that completed constructio'n will meet design requirements. Overall control of the contrsetors is good, although some weaknesses were identified for correction in the areas of piping and electrical construction.

CC.1 Construction Engineering Findina Summary Page CC.1-1 Good Practice: Nuclear Construction Engineering 34 Section has a computerized valve information system.

CC.1-2 Some Nonconformance Reports were pending past 34 the 30-day requirement for disposition (Accord-ing to log).

CC.2 Construction Facilities and Equipment (No Findings).

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CC.3 Material Control Findina Summary Page CC.3-1 -Nonconformance Reports are not used for minor 41 discrepancies related to periodic maintenance requirements.

CC.3-2 Some equipment in Warehouse is moved but 41 documentation is not changed. Also, noncon-forming equipment awaiting disposition is not usually segregated.

1 CC.3-3 Equipment stored in Warehouse may not always 42 receive required maintenance.

CC.3-4 Review of contractors' material control opera- 43 tions revealed situations inconsistent with procedures.

4 CC.4 Control of Construction Processes Findina Summary Page CC.4-1 Hilti bolt installation procedures in some 53 instances were not followed by the responsible

, contractor.

CC.4-2 Electrical Contractor personnel were not 53 qualified to a written procedure (cutting .

and silver brazing of stainless steel conduit).

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Finding Summary Page CC.4-3 Electrical contractor has no procedure for 54 welding isolated phase bus duct (nonsafety).

CC.5 Construction Quality Inspection Finding Summary Page CC.5-1 Contractors' NDE procedures for liquid penetrant 61 examination do not specify maximum drying time.

CC.5-2 Contractors' procedures for NDE Practical Quali- 62 fication did not meet requirements of SNT-TC-1A.

CC.5-3 Project procedure for Review of Contractor 63 Procedures does not specify qualifications for reviewers.

CC.6 Construction Corrective Actions Finding Summary Page CC.6-1 Nonconformance procedures are not always 68 effective in achieving timely closeout of non-conformances. .

CC.7 Test Equipment Control Finding Summary Page CC.7-1 One contractor had no routine program for 72 calibrating welding machines.

Project Support The existing organization and management in the Porject Support area was found to be good. The Evaluation of Project Support included the areas of Industrial Safety; Overall Project Plans, Schedule and Work Plans;

• Procurement; Contract Administration; and Document Management.

Weaknesses were found in the activities to complete and fully implement (1) the status and plans relative to as-built drawings, (2) the identi-fication, development and processing of required records by fuel load and (3) additional training in the use of the project scheduling documents.

Management is aware of and had initiated prior action on some of the findings. However, the current level of effort in some areas is of con-cern, with possible impact on key Project milestones.

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1 PS.1 Industrial Safety

' . Finding Summary Pa,ge J ,

PS.1-1 Effectiveness of site safety and fire protection 75 systems could be improved with additional man-power.

i PS.1-2. Number of safety violations is not excessive 75 but improvements can be made.

) PS.2 Project Planning Finding Summary Page

! PS.2-1 Planning weaknesses were noted in Project 79 transition documents.

! PS.3 Project Control i

j Finding Summary P_aage PS.3-1 Complete system scheduling information is not 83 available to all Project personnel. ,

PS.3-2 Good Practice: " Operation Review Program" 83

. reviews the administration of all Construction

' Contracts.

PS.4 Project Procurement Process Findina Summary Page 4

l PS.4-1 No written criteria exist to categorize a 86 Perry Construction Work Authorization.

i 1S.4-2 There is no automatic followup procedure to 86 remind a contractor when his response to a

! Perry Construction Work Authorization is i overdue.

PS.5 Contract Administration Finding Summary Page

! PS.5-1 Contrac't Administration is not verifying time 90 sheets in a manner consistent with Contract i Administration guidelines on SP 33/34.

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PS.6 Documentation Management Finding Summary Page PS.6-1 The document management and control system does 94 not have the capacity to meet the volume of work expected prior to fuel load (November 1983).

Training The evaluation of the training area covered management support, organi-zation, the actual training and qualification of Project employees, and training facilities. Despite a few specific findings, employees in most instances are appropriately trained. Additional emphasis needs to be placed on procedural training and adherence to procedures. Strong management support was evident and a recent improvement to the training organization was noted. The new Training Center now under construction should alleviate facilities problems in the future.

TN.1 Training Management Support (No Findings)

TN.2 Training Organization and Administration -

(No Findings) t TN.3 General Training and Qualification Finding Summary Page TN.3-1 The major piping contractor does not have a 105 written training program. .

TN.3-2 The procedure for background checks on new 105 hires varies across the site.

TN.4. Training Facilities, Equipment and Material (No Findings)

Quality Programs The Quality Program scaluation oncentrated on the programmatic and organizational interface between the site and the A/E's home office, on the independen* ssessment of the QA program, on program implementation aspects, and on the effectiveness of corrective action. While overall the quality programs are operating effectively, findings were developed in connection with program implementation dets41s.

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QP.1 Quality Programs (No Findings)

QP.2 Program Implementation Finding Summary Page QP.2-1 The Electrical Contractor does not meet 117 his site QA staffing commitment.

QP.2-2 The Electrical Contractor did not impose 117 QA program requirements on a supplier.

QP.2-3 Project Internal Audit function is not always 118 effective in achieving corrective action.

QP.2-4 Good Practice: A three-phase pipe hanger in- 118 spection program is being used.

QP.3 Independent Assessments Finding Summary Page QP.3-1 Independence of Quality Assurance Advisory 122 Committee questioned.

QP.4 Corrective Actions Finding Summary Page QP.4-1 Follow-up is not producing timely corrective 125 actions.

Test Control A testing program has been established and implemented to assure that systems within the plant will operate as required. This program includes a staffing schedule, turnover schedule, testing quality control programs, goals, and the ability to monitor and report status. The program is a good one, but attitudes of personnel must continue to change from one of bulk construction to system completion and turnover. Turnover job definitions and responsibilities are not clear; therefore, more under-standing, training, and implementation emphasis are needed.

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TC.2 Test Group Organization and Staffing Finding Summary Page TC.2-1 Responsibilities and authorities of key 131 testing personnel not in writing.

Finding Summary Page TC.2-2 Orgnalzational charts are inaccurate. 131 TC.2-3 Nuclear Test Section Training Program does not 131 include System Team training.

TC.3 Test Plan (No Findings)

TC.4 System Turnover for Test Finding Summary Page TC.4-1 Nuclear Test Section to Perry Plant Department 139 turnover procedure not consistant with FSAR.

TC.5 Test Procedures and Test Documents Finding Summary Page TC.5-1 Chemistry Laboratory personnel weak in

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143 basic laboratory techniques.

TC.5-2 Good Practice: Efficient procedures are being 143 used for calibrating instruments.

TC.6 System Status Controls Finding Summary Page TC.6-1 Tracking of jurisdictional status of systems 147 needs to be improved.

TC.6-2 Jurisdictional tagging procedures are not 147 being followed in the control room.

The findings contained in this report were presented to the Project Organization at an exit meeting (attendance list in Appendix III) held on October 19, 1982. The Project Organization responded with the corrective actions which are included as part of this report. Based on the corrective actions planned, the weaknesses enumerated earlier should ,

be substantially resolved. Management will monitor all Corrective Actions and Concerns to assure that there is response and follow-up.

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PERFORMANCE EVALUATION

SUMMARY

AND DETAIL SHEETS O

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

. Perry Plant Performance Area Organizational Structure Objective No. OA-1 Evaluator (s) H. R. Porter, R. G. Schuerger I. Performance Obiective The owner's corporate organization and all other project organizations responsible for the design, engineering, planning, scheduling, licen-sing, construction, quality assurance, and testing of a nuclear plant should provide an organizational structure that ensures effective project management control.

II. Sccce of Evaluation The scope of evaluation in the Organizational Structure area included detail reviews of organization charts and documents, and numerous interviews with management personnel of the Owner, AE, and Construction Management Consultant. The range of management levels that addressed this subject extended from chief executive officers to lead engineers.

Approximately 25 manhours were expended on this evaluation.

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III. Conclusion The organization structures evaluated were found to provide the necessary means to ensure effective Project management control. The current Project Organization is judged to be strong and composed of the elements necessary to meet the identified

, ;aals and quality commitments of the Owner. Certain good practices relative to the Project Organization were noted. Changes in I responsibilities and interfaces resulting from recent reorganiza-tion and personnel assignments should be quickly defined.and made  :

known Project-wide to maintain continuity and organizational -

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PERFORMANCE EVALUATION SUMMRRY Construction Project Perry Plant Performance Area Organizational Structure Objective No. OA-1 Evaluator (s) H. R. Porter, R. G. Schuerger IV. Areas of weakness and corrective action: Good Practices Finding The following good practice was noted:

(OA.1-1) The location on the Site of technical, management and support personnel from the owner's organization

.and from all organizations significantly involved in the Plant Project uniquely provides the means for immediate and coordinated efforts of Site activities.

Finding The following good practice' 'was noted:

(OA.1-2) An integrated Project Team, comprised of experienced personnel of the owner and all organizations with major involvement in the Project, staff the on-site organization. This composite organization utilizes the combined strengths of several effectively organizations, and it serves as a means to increase and diversify the capabilities of the owner's personnel who retain the lead management and most supervisory positions.

Finding The following good practice was noted:

(OA.1-3) The recent formation of an Owner design group on-site, totally dedicated to Unit 1, will assure the presence of qualified and well prepared Owner engineers for start-up and plant operation.

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I PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Organizational Structure Objective No. OA-1 (title) Sheet A or z

2. Provide factual information that succorts the Performance Evaluation Summarv _

A. In a review of organization charts and documents relative to the on-site Project personnel, it was noted that an integrated Project Team is established consisting of people from Owner and several other companies. The integration exists in management, engineering, construction management, and various support activities. Owner personnel retain the lead in management and most supervisory positions. The September Project Progress Report shows.that the Owner Project Organiza-tion has a total of 1,199 people on-site. Of this total, the Owner has 528, with 216 of them in the Plant Department dedicated to plant operation efforts. The balance consists of 437 from Construction Management Consultant, 150 from the AE, 15 from NSSS Contractor and 69 from several consulting firms.

B. Interviews and discussions with many Project pefsonnel by all members of the Evaluation Team confirmed the team membership and the various company affiliations. The level of assignments and apparent capability of the individuals under the umbrella Owner management, and their tenure at the site, was found to be impressive.

C. Evidence of Scope Not Associated with Specific Findings

1. Some concerns relative to continuity and interfacing were noted in certain areas of the Project Organization during the evaluation that are considered attributable to recent organization changes.

a. A recent shift of engineering personnel from Nuclear Design & Analysis (ND&A) Section to the Nuclear Construction Engineering (NCE).Section who are responsible for Owner follow of AE' design was done in part. Not all responsible. engineers were transferred,

b. It was learned from AE engineers that as a result of the ND&A/NCE transfers, they now had to interface their engineering efforts with three separate Project groups at the Site.

PERFORMANC M 7ALUATION DETAILS Construction Project Perry Plant

1. Performance Area: nreani,ational Structure Objective No. OA-1 l (title) Sheet 2 of 2 )

2. Provide factual information that suceorts the Performance Evaluation Summarv _

c. In discussions with some management, supervisory, and lead engineering personnel by evaluation team members it was learned that specific responsibilities of some subtier groups and some key personnel have not as yet been defined and made known to the Project Organization.

CONCERN - AN AC, TION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP FOR ITEMS a, b, & c.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant MANAGEMENT INVOLVEMENT AND Performance Area cnMMTmurMm mn nttarTTv Objective No. nA_?

Evaluator (s) H. R. Porter, R. G. Schuerger I. Performance Obiective Senior and middle managers in the owner's corporate office, designer's office, and at the construction site who are assigned functional responsibility for matters relating to the nuclear project should exhibit, through personal interest, awareness, and knowledge, a direct involvement in significant decisions that could affect their responsi-bilities'.

II. Score of Evaluation Evaluations in this area took place in the Owner's Corporate Office, the offices of the Design Organization, and at the Construction Site. The information required to permit assess-ments and an overall evaluation was obtained from a significant number of interviews with middle and senior management.

Approximately 35 manhours were expended on'this phase of -

evaluation.

I III. Conclusion Management personnel with functional responsibilities related to the Project have exhibited a positive attitude toward their jobs, and an impressive degree of interest, knowledge, and direct involvement in activities and decisions related to their specific responsibilities and to identified Project objectives. The executive level of management displayed a high degree of knowledge  !

and awareness of Project Organization personnel, Project status, and an appropriate graded involvement.  :

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Management Involvement and Commitment Objective No. OA-2 uw w m. y '

H. R. Porter, R. G. Schuerger Evaluator (s)

IV. Areas of weakness and corrective action; Good Practices Finding -

The following good practice was noted:

(OA.2-1)

An Owner corporate policy requires that a Performance Analysis Report (PAR) be prepared and submitted monthly to Senior Management by each group. These reports supplement other means of communications and are designed to highlight significant problems, potential opportunities and anticipated actions.

The unique benefit provided by this PAR system is the insight that the Owner's senior management has to a greater depth within the organization than that normally realized within many large companies.

This is of particular importance on a nuclear constuction project. The PAR is considered to be a positive supplement to the normal reporting ,

means encountered on a project of this nature, made possible by having Owner personnel in manage-ment and most supervisory positions in the Site Project Organization.

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l PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Management Involvement and

1. Performance Area: Commitment to Quality Objective No. OA-2 (title)

2. Provide factual information that succorts the Performance Evaluation Summarv Evidence of Scope Not Associated with Specific Findings:

In discussions with executive management, the Owner's Performance Analysis Report System was discussed. The longstanding reporting system was cited as an excellent means for first-level supervisors and management to communicate upwards to senior management, who in turn remain well informed of both individual and work progress on the construction site.

(Ref. Perfor. Eval. Detail Sheets OA.1-OA.2)

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant The Role of First Line Supervisors Performance Area and Middle Managers Objective No. CA-3 Evaluator (s) H. R. Porter. R. G. Schuerger I. Performance Objective ,

The project first line supervisors and middle managers should be qualified by verified background and experience and have the necessary authority to carry out their functional area responsibilities.

II. Scoce of Evaluation The evaluation consisted of interviews conducted on-site and at the AE's offices, with mid-level managers, supervisors, and lead engineers.

Approximately 45 manhours were expended on this effort, i

III. Conclusien The individuals contacted showed good leadership qualities, without exception. A large percentage of the middle managers and supervisors have demonstrated background and experience to perform exceptionally well in carrying out their functional area responsi-bilities. There is an apparent need to concentrate more efforts on the development of job descriptions and subtier organization charts in some areas.

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, PERFORMANCE EVALUATION

SUMMARY

Conctruction Project Perry Plant Performance Area The Role of the First-Line Objective No. OA-3 Supervisors and Middle Managers Evaluator (s) H. R. Porter, R. G. Schuerger IV. Areas of weakness and corrective action; Good Practices Finding Job descriptions are not available for some of the

(OA.3-1) Owner's personnel who were contacted. The absence of these documents was noted in some of the long established groups as well as in some groups recently organized.

Corrective Management previously recognized the need to revise Action existing job descriptions and in some cases create (OA.3-1) new job descriptions listing Perry specific func-tional responsibilities and tasks. Tne Nuclear Project Training Section (NPTS) is currently work-ing with the Nuclear Quality Assurance Department in a pilot project to analyze the organizational QA structure and to develop functional position descriptions and corresponding training commit-ments. ,

This project will be expanded to include all ele-ments of the Project Organization on a priority basis. Action should be completed by April 30, 1983.

Each Section will be required to designate at least one individual to develop position descrip-tions and organization charts. NPTS will provide initial orientation and continuing guidance to I the designated individuals.

Based on the results of the pilot project, a Special Project plan will be developed by December 15, 1982, to include guidelines for development of functional position descriptions and provisions for revisions and annual reviews. NPTS is responsible for coordi-nating the above activities.

Finding Subtier organization. charts should be developed (OA.3-2) and/or updated in some sections.and distributed to i identify assigned responsibilities and interfaces.

f Corrective Development of subtier organization charts will be t Action addressed concurrently with position descriptions (OA.3-2) as detailed above.

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l PERFORMANC M VALUATION DETAILS Construction Project Perry Plant The Role of First-Line

1. Performance Area: Supervisors and Middle ManagersObjective No. OA-3 (title)

2. Provide factual information that succorts the Performance Evaluation Summarv _,

A. Details in Support of Finding OA.3-1 Interviews were conducted with managers and supervisors in several sections of the Nuclear Engineering and Nuclear Construction Departments. In several of the interviews it was determined that the individual had no written job description, and in some instances it was indicated that job descriptions did not exist for their subordinates. It was determined that an Owner corporate policy requires job descriptions for all employees.

B. Details in Support of Finding OA.3-2 It was found through discussions and review oh section organization charts that certain groups within the section show up as a long list o'f names. Comments made'by some individuals to Evaluation Team members indicated that a more visible means is needed to show assigned responsibilities, levels of authority, and interfaces, such as a subtier organization chart that is available to interfacing organizations.

C. Evidence of Scope Not Associated with Specific Findings:

It is not evident from a review of the major piping contractor's organization chart that there is any direct supervision of the Assistant Resident Construction Manager, who has direct responsibility for craft labor. Only an information line of communication exists between the Assistant Resident Construction Manager and the Resident Construction Manager. There is a concern that this condition could hamper proper construction management of the Project. Project management is aware of the situation and 6 is monitoring the situation to assure that there is adequate

! management control of' craft labor. CONCERN - AN ACTION

REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORFECE EVALUATION SU:01ARY Construction Project Perry Plant Performance Area Desien Incuts Objective No. nc 1 Evaluator (s) y aanknuev4 e n4rn_ n v411snveh I. Performance Obiective Inputs to the design process should be defined and controlled to achieve complete and quality designs.

II. Sce;e of Evaluation The evaluation of this area involved three evaluation team members. A total of approximately 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> was expended in interviews and follow-up document reviews. Interviews were -

conducted with the Owner's Site En'gi'neering, the A/E Site Engi-neering and the A/E Home Office personnel.

III. Conclusien .

Control of the majority of the activities in this area were well f -

defined, controlled and documented. The overall evaluation is satisfactory. There are some weaknesses which should be addressed.

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- , PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Design Input Objective No. DC-1 F. Jankowski, S. Biro, R. Villforth Sheet 1 of 2

• Evaluator (s)

IV. Areas of weakness and corrective action; Good Practices Finding The interviews and document reviews discovered (DC.1-1) several instances of lack of use of the required A/E design input form. This is true of both safety and non-safety calculations. The appli-cation of this form to non-safety calculations is not clearly spelled out in the A/E procedures.

Corrective The calculations identified in the finding will be Action retrofitted with the design input form by the site (DC.1-1) design team personnel responsible for the calcula-tions by 12-1-82. We evaluated the need to review calculations to retrofit the form for those calcu-lations performed since 6-30-82 (when the form be-came' applicable to Perry). It was determined that this review was not required because it did not add significantly to the engineering support for the design. To prevent recurrence, A-/E lead engi-neers were reindoctrinated on 10-26-82 of the requirement for the use of the form, where required, on safety-related calculations. A review of the Engineering Operations Manual indicated that the manual adequately addressed the procedure. An indoctrination to the requirements for nonsafety calculations will be conducted for site design team personnel by 12-1-82. A/E internal design control audits will be used to verify that the problem is not recurring.

Finding The A/E Home Office layout department is not (DC.1-2) requesting constructibility reviews for layouts per procedure DCP 1.15.

Corrective Original issues of Layout drawings and Structural Action drawings were reviewed for constructibility by (DC.1-2) A/E Home Office personnel and Construction Manage-men.t personnel. At this stage of the project, t

- , PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant

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Perfor: nance Area Design Input Objective No. DC-1 Sheet 2 of 2 Evaluator (s) F. Jankowski, S. Biro, R. Villforth IV. Areas of weakness and corrective action: Good Practices layout drawings are no longer undergoing major revisions which require a review for constructi-blility. DCP 1.15 will be evaluated by 12-15-82 to clarify the need of constructability reviews of layout drawings at this time.

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l PERFORMANCE EVALUATION DETAILS Construction Project  !

Perry Plant

1. Performance Area: Design Input Objective No. DC-1 (title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

A. Details in Support of Finding (DC.1-1)

(1) An interview was held with the A/E site mechanical design personnel. A random check of a specific cal-culation for safety-related welds produced the fact that three required A/E design input forms were not used, although the work itself was done correctly.

(2) An interview was conducted with an A/E engineer who works on nonsafety-related seismic clearance viola-tions. Document reviews revealed that the A/E design input form was not used per procedure. The procedures are actually unclear as to how this form is to be used on nonsafety calculations.

B. Details in Support of Finding (DC.1-2) -

- In all interviews with A/E design personnel, it was asked how constructability reviews were performed. Generally, the response was that the A/E layout group performed this function.

The A/E layout group stated that they did not request review of layouts by the A/E Construction Services Group. Document reviews discovered that the A/E DCP 1.15 requires this review.

C. Evidence of Scope Not Associated with Specific Findings:

The following activities were reviewed and no significant problems were discovered. These activities can be considered satisfactory:

l On-site Owner handling of NSSS Contractor documents.

l On-site Owner handling of NRC dictated cha'nges, such as ATWS.

A/E definition and control of design input.

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PERFORMANCE EVALUATICN

SUMMARY

Construction Project Perry Plant I

i Performance Area Design Interfaces Objective No. DC-2 i Evaluator (s) R. Villforth, F. Jankowski, S. Biro I. Performance Obiective Design organization external and internal interfaces should be identified an'd coordinated to ensure a final design that satisfies all input requirements.

II. Scoce.of Evaluation The evaluation of this objective involved primarily three members of the Evaluation Team. Approximately 33 manhours were expended in the interviewing of Nuclear Design and Analysis Section, Nuclear Construction Engineering Section and the A/E Home Office Associates Engineers. The evaluation also included review of documents and drawings. Interviews were conducted at the Engineer level and followed up by discussions at Project Management and Supervisory levels. _

I III. Conclusien

This performance objective'i;s being met satisfactorily. However, there are soma areas of improvement identified which could elimi-l nate future design, construction and operating problems.

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I PERFORMANCE EVALUATION

SUMMARY

Construction Project

. Perry Plant Performance Area Design Interfaces Objective No. DC-2 Evaluator (s) R. Vi11forth, F. Jahkowski, S. Biro Sheet 1 of 2 IV. Areas of weakness and corrective action; Good Practices Finding After the fact design overview is not always (DC.2-1) being done and documented by the A/E Home Office engineers for work performed by the A/E Site Team.

The Perry Project Manual calls for A/E home office overview of Field Variance Authorizations, Engineer-ing Change Notices and Nonconformance Reports.

Corrective Appendix P to the Perry Project Manual (PPM) will Action be revised to require the A/E Home Office Project (DC.2-1) Engineer or his designee to initial field Noncon-formance Reports (as is already required on ECN's and FVA's). This procedure will be placed in effect by memo from the Project Manager by Novem-ber 1, 1982, and a formal revision to the PPM will be issued by December 31, 1982.

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The Project Organization (P/0) distribution matrix has been revised to indicate the A/E Home Office on distribution for site NR's, effective Octo-ber 18, 1982.

For the period in question from December 1, 1980, to October 18, 1982, NR's were forwarded to the Home Office and have been overviewed and initialed. Prior to December 1, 1980, NR's were'being forwarded to j

the Home Office.

The project office will monitor this effort and assure its compliance.

The effectiveness of the implementation of the procedure revisions will be evaluated by the A/E Quality Assurance Division.

Finding - Although the specifications were generally being (DC.2-2) reviewed and comments documented by the mechanical disciplines of the Nuclear Design and Analysis l Section, the HVAC area specification review and comment documentation of some non-safety general I contracts is not always being carried out according to procedures.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance' Area Design Interfaces Objective No. DC-2 Evaluator (s) R. Villforth, F. Jankowski, S. Biro- Sheet 2 of 2 IV. Areas of weakness and corrective action: Good Practices Corrective The HVAC specification reviews were accomplished; Action however, the comment coordination was not in (DC.2-2) accordance with procedure with regard to routing

.of comments for some General Contracts on non-safety items. Addition.al indoctrination regard-ing the requirement was accomplished for the individuals involved.

This appears to be an isolated instance and, as such, no additional corrective action is required.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Design Interfaces Objective No.DC-2 (title) Sheet 1 of 2

2. Provide factual information that suoports the Performance Evaluation Summarv A. Details in Support of Finding DC.2-1

1. Copies of completed Nonconformance Reports have not been arriving at the A/E home office as required in Appendix P of the A/E Interfaces Manual.

2. No procedure exists to document or sign-off that an overview of field Nonconformance Reports by the A/E home office has been completed.

3. A procedure exists for sign-off that overview of field Engineering Change Notices (ECN) has been completed by the A/E home office. This procedure is not always being followed as has been identified in a QA audit the week of October 4. Responsible Engineers interviewed during the week of October 11 were still unaware of the ECN sign-off requirements.

B. Details in Support of Finding DC.2-2

1. Nuclear Design & Procurement Procedure 3-0606 states the procedure for reviewing and documenting comments on specifications prepared by the A/E. General specifica-tions for the Service Building, Training Center and Guard House include sections on HVAC. The HVAC comments were not always coordinated by the Responsible Engineer and for the most part, comments from the Owner HVAC

. discipline went directly to the A/E HVAC discipline in the home office by phone and without documentation.

C. Evidence of Scope Not Associated with Specific Findings

1. Activities of the Owner Nuclear Design and' Analysis Section's Mechanical Discipline were investigated through interviews and document review. Procedures were being followed and good engineering practice was in force. There appeared to be a movement toward the

. Owners' site team assuming more of the design functions in the non-safety related areas from the A/E Team.

There would appear to be no problems with this as long as procedures were thought out in advance to accommodate the activities relinquished by the A/E Team. In one instance the Owners' Team provided numbers for valves

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PERFORMANCE EVALUATION DETAILS Conctruction Project

- Perry Plant J

Performance Area: Design Interfaces Objective No. DC-2

1. Sheet 2 of 2 (title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

added to equipment by the Nuclear Test Section without involving the A/E Site Team. The A/E Team is currently responsible for adding as-built information to flow diagrams. The A/E Team discovered the valve numbers were not f.ollowing convention and the numbers had to be changed. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESOLUTION AND FOLLOW-UP.

2. The vendor instruction book approval activity was investigated and procedures for distribution and review of books were being followed. Generally the Responsible Equipment Engineer coordinates this activity. There is no specific requirement for review of instruction books by Responsible System Engineers' but there are situations where instructions affect system design, such as the need for special temporary strainers, cool-ing water, and temperature control. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESOLUTION AND FOLLOW-UP.

3. The integration of A/E home office and site procedures has been good. A concern, however, exists concerning 1

communications of changes in Project Administration Procedures which have secondary effects in the A/E home office. Recently the Project Administration Procedures were revised to show 30-day turnaround periods for the disposition and review of Nonconformance Reports. This change is not reflected in the A/E Design Control Procedures and is not known to all A/E Site or home office personnel. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Design Process Objective No. DC-3 Evaluator (s) S. Biro, F. Jankowski, R. Villforth I. Performance Obiective The management of the design process should result in designs that are safe, reliable, verifiable, and in compliance with the design requiremencs.

II. Scoce of Eva'luation The evaluation of this area involved the Owner's Nuclear Design &

Analysis Section, the A/E Desian Team on Site, and the A/E Design Home Office. Interviews and discussions were cQndyc.ted with Project engineerr,-"iead engineers, responsible engineers and supporting design documents personnel. In addition the Pro and records were reviewed. andject inspected manuals, procedures, Approximately 45 manhours were expended in this evaruation area.

III. Conclusion f

Control of the majority of activities evaluated under this performance objective can be rated good. A few areas of weakness, which are not considered to be significant in nature, are identified and steps should be taken to strengthen these areas.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Design Process Objective No. DC-3 Evaluator (s) S. Biro, F. Jankowski, R. Villforth IV. Areas of weakness and corrective action: Good Practices Finding Installation problems during construction could be (DC.3-1) reduced by improved interference checking during the design review process and by the use of more

. construction details on the installation drawings.

Corrective We agree that additional interference checking at the Action home office could have resulted in improved construc-(DC.3-1) tion interfaces, i.e., fewer field problems. The effects of cost and schedule were considered in the early design phases of the project and as a result, the site design team was formed in 1978, with an em-phasis on resolving interferences and accumulation of tolerances in the field. The site design team was supplemented'in 1979, in the case of electrical con-duit design'by an on-site detailing effort directed specifically at an optimum cost / benefit solution to interference problems, and to provide additional con-struction details on the installation drawings. Recog-nizing completeness of the design, no further correc-tive action is required. ,

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Design Process Objective No. DC-3 (title) Sheet 1 or e

2. Provide factual information that supports the Performance Evaluation Summary A. Details in Support of Finding DC.3-1 The A/E Site Design Team responsible electrical engineer reported that many Field Questions and problems are a result of the following:

1. There are many interferences identified on Site between pipe supports designed in the A/E's Home Office and electrical cable tray and conduit. A review of ECN and FQ files substantiated this fact.

2. Improvement could be made in the detailing on electrical design drawings as issued by the A/E, especially in the area of equipment mounting and physical connections to electrical equipment. ,

B. Evidence of Scope not Associated with Specific Findings

1. The following are some general observations that are minor concerns:

a. Both the A/E Site and Home Office engineers indicated there have been cases when responsibilities were

! not clearly defined between the two offices which resulted in duplication of effort.

b. The electrical design group in the A/E's home office manually develops their own barchart type schedules for controlling their work. They advised that no overall coordinated engineering schedule exists,

c. Review of revised Project procedures Is on an individual basis. There is no effort or plan to brief personnel on the specifics of the revisions.

d. The A/E Home Office electrical equipment responsible engineer indicated problems getting the diesel generator vendor to provide equipment qualification.

CONCERN - ACTION REQUESTS WERE ISSUED BY THE PROJECT FOR ITEMS a, b, c & d FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant 1.. Performance Area: Desian Process Objective No. DC-3 (title) Sheet 2 of 2

2. Provide factual information that succorts the Performance Evaluation Summarv _

2. The A/E electrical design team on Site is familiar with and utili.zes the same design criteria, codes, standards, and procedures as the Home Office. The majority of the Site team members are experienced personnel with long association with the Perry Project.

3. Discussions with the A/E Home Office Project Electrical Engineer indicated a good understanding and application of physical and electrical separation criteria in design.

4. Discussions with the A/E Home Office responsible engineer

. confirmed that loading conditions for the diesel generator units are continuously being reviewed and updated to incorporate current requirements. ,

5. Review of equipment qualification status in the A/E Home Office Instrument & Control Section indicated that a good program has been developed, is being utilized, I and is effective.

6. Interviews and discussions indicated that the A/E home office design engineers are well qualified, have a good understanding of their responsibilities and the applicable criteria and procedures. Groups are well organized and their activities are well controlled. Review of design documents indicates compliance with design requirements.

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, PERFORMANCE EVALUATION SUNiARY Construction Project Perry Plant Performance Area Design Output Objective No. DC-4 Evaluator (s) F. Jankowski, S. Biro, R. Villforth I. Performance Obiective Project design documents should specify constructable designs in terms of complete,' accurate, and understandable design requirements.

II. Sec=e of Evaluation The evaluation of this area involved three evaluation team members.

A total of approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> was expended in interviews and follow-up document reviews. Interviews were confidential with Owner?s Site Engineering, A/E Site Engineering, and A/E Home Office personnel.

1 I

III. Conclusion All of the observed activity in this area was found to be well defined ,

t , controlled and documented. The overall evaluation is good.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project e

Perry Plant ,

Design Output DC-4 Performance Area Objective No.

F. Jankowski, S. Biro, R. Villforth Evaluator (s)

IV. Areas of weakness and corrective action; Good Practices None.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Design Output Objective No. DC-4 (title)

2. Provide factual information that supports the Performance Evaluation Summary _

Evidence of Scope Not Associated With Specific Findings:

A. The following activities were reviewed and no significant events / findings were discovered. These activities were being carried out according to procedures.

- On-site Owner handling of vendor manuals.

- A/E handling of NSSS Contractor design documents.

- A/E handling of vendor designed package chemical systems.

B. During discussions with the A/E Home Office Engineer who is the A/E interface with the NSSS Contractor, it was discovered that a large number of NSSS Contractor drawings were still in the " Approved as Noted" or " Return for Correction" stage.

The engineer stated that he counted " hundreds" in this condition and some date back to 1977. The A/E procedure states that these drawings must be resubmitted with the comments incorporated for approval. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Design Changes Objective No. oc-5 S. Biro, F. Jankowski, R. Villforth I. Performance Obiective Changes to released project design documents should be controlled to ensure that constructed designs comply with the most recent' design requirements.

II. Scece of Evaluation The evaluation of this area involved the Owner's Nuclear Design &

Analysis section, the A/E Design Team on Site, and the A/E Design home office. Interviews and discussions were conducted with Project engineers, lead engineers, responsible engineers and supporting personnel. In addition, the Project manuals, applicable procedures, design documents, and records were reviewed and inspected.

Approximately 50 manhours were expended in this evaluation area.

t III. Conclusion r

Control of the majority of activities evaluated under this performance objective can be rated as good. Actions should be taken to strengthen those areas of weakness that are identified. .

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, PERFORMANCE EVALUATION

SUMMARY

Construction Project

, Perry Plant Performance Area Design Changes Objective No. DC-5 sheet 1 of 2 Evaluator (s) S. Biro, F. Jankowski, R. Villforth IV. Areas of weakness and corrective action: Good Practices Finding Controls do not alway's exist to assure prompt 1 (DC.5-1) processing of documents which comprise the design change control system.

Corrective The procedural address for prompt processing of design Action changes was evaluated. There is no evidence indicat-(DC.5-1) ing that construction scheduling needs or Quality re-quirements have been compromised because of delays in i processing known changes. The contract team concept utilizes good communication to ensure that all parties are aware of priorities. The Contract Administrator generally expedites processing of documents affecting construction and the Quality Engineer generally ex-pedites documents affecting quality. None of the dis-ciplines have a proceduralized system and the evalu-ation concluded that it would not improve the effec-tiveness of the Engineering effort.

It is recognized that some Field Questions and Noncon-formance Reports may take longer. than 30 days to re-solve. Some may involve extensive evaluation, vendor contacts, additional inspections, etc. The intent of

the 30 day requirement is to help expedite resolutions and avoid unnecessary delays. A revision will be initiated by Construction Engineering by November 30, 1982, to Procedure 3-1501 to clarify the engineering requirements for the 30 day resolution and address the need for justification of delays.

Finding There are no procedures that ensure that all (DC.5-2) -

design changes incorporated on Unit 1 are reviewed and implemented on Unit 2 if required.

Corrective Appendices N (ECN's), G (Drawing Changes) and X (DCN's)

Action to the PPM will be revised by the A/E Home Office by (DC.5-2) December 31, 1982. The revision will reflect that de-

sign changes for Unit 1 are reviewed and incorporated, when applicable, into Unit 2 design documents.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Design Changes Objective No. DC-5

• • O Evaluator (s) S. Biro, F. Jankowski, R. Villforth IV. Areas of weakness and corrective action; Good Practices This practice is currently in effect in most disci-plines at the A/E Home Office. For pipe supports, a 100% review of Unit i design changes is being imple-

.mented. The review will determine the applicability of the Unit 1 changes to Unit 2. Those determined to apply to Unit 2 will be incorporated.

The effectiveness of the implementation of the pro-cedure revisions will be evaluated by the A/E Quality Assurance Division.

Finding A/E home office overview of design changes (DC.5-3) authorized by the A/E Design Team on Site is required by the procedures which cover the design change control system. However, the procedures are inconsistent in addressing docu-mentation requirements of this overview.

Corrective Appendix P (Nonconformance Condition) to the PPM will Action be revised as indicated in response to finding DC 2-1.

(DC.5-3) This will provide consistency among all design changes.

Corrective action is as identified in the response to DC 2-1.

Appendix 0 (Field Questions) to the PPM will be re-vised by the A/E Home Office by December 31, 1982, to clarify the requirements for Field Questions.

The Field Question is not a design change document for safety-related designs, as specified in Section 2:02 of Appendix 0 to the PPM. Therefore, a documented overview of field questions is not required.

The effectiveness of the implementation of the pro-cedure revisions will be evaluated by the A/E Quality Assurance Division.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Design Changes Objective No. DC-5

1. Performance Area:

S,heet 1 or a (title)

2. Provide factual information that supports the Performance Evaluation Summarv A. Details in Support of Finding DC.5-1

1. Electrical Site engineers indicated that they use no procedure to follow-up on the processing of ECN's, FQ's, FVA's and NR's that have been sent to their group for action.

2. Status logs were reviewed that indicated some FQ's and NR's have been in the design groups for action for periods in excess of 30 days, which is contrary to NR procedure requirements.

3. No status logs were in evidence for ECN's or FVA's to be processed.

B. Details in Support of Finding DC.5-2

1. Review of the Site procedures that cover design changes indicated that there is only one instance when transfer of Unit 1 changes to Unit 2 is specifically mentioned. This is in Appendix G, Revision 17 of the Procedures Manual, Section 4.08, which only addresses electrical elementary and interconnection diagrams that have been transferred to the Site.

2. The A/E's engineers on Site indicated that it is their understanding that ECN's are automatically incorporated at the home office, but discussions at the home office do not substantiate this and the ECN procedure does not address it specifically.

C. Details in Support of Finding DC.5-3 The following inconsistencies exist in the procedures:

1. Procedures Manual, Appendix 0, " Processing Field Questions,"

requires that FQ's be sent to the responsible engineer and

- if he disagrees with the evaluation he notifies Site engineering to initiate a revision. The procedure does not make any provision for documenting this review.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Desian Chances Objective No. DC-5 (title) Sheet 2 of 3

2. Provide factual information that succorts the Performance Evaluation Summary

2. Procedures Manual, Appendix P, "Nonconformance Conditions," requires that responsible Project engi-neers. provide an "after-the-fact overview" of completed NR's, but makes no provisions to document that the overview has been done.

3. Procedures Manual, Appendix W, " Field Variance Authori-zation," was revised September 30, 1982, to include the provision that the responsible Project engineer initial the FVA to document his concurrence with the field engineer's decision.

4. Procedures Manual, Appendix N, " Engineering Change Notices," requires the Project engineer to initial

, field ECN's to indicated his concurrence. ,

D. Evidence of Scope not Associated with Specific Findings

1. The interviews conducted with engineers in the three design groups indicated a good understanding of design responsibilities and procedures. The groups are well organized and their activities are well controlled; and for the most part the engineers have had a long association with the Project and are well qualified.

Communication seems to be good among the three groups.

Review of completed documents indicates adherence to procedural requirements.

2. Some observations during the evaluation that are minor concerns are:

a. It takes from 10 days to 3 weeks from time of issue of a revised drawing by the A/E for it to be released to construction.

b. Figure W-1 of Appendix W of the Procedures Manual is not the latest revision of the FVA Form.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Design Changes Objective No. DC-5 (title) Sheet 3 or 3

2. Provide factual information that succorts the Performance Evaluation Summary

c. Project procedures are constantly changing and the engineers indicated difficulty in staying current with requirements.

d. There are no sessions to brief personnel on revi-sions to procedures. Individuals must read and acknowledge understanding.

CONCERN - ACTION REQUESTS WERE ISSUED BY THE PROJECT FOR ITEMS a, b, c & d FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATICN

SUMMARY

Construction Project Perry Plant Performance Area Construction Engineering Objective No. CC-1 Evaluator (s) S. Biro, R. Villforth, F. Jankowski, W. Tokarcik I. Performance Obiective Engineering and design performed under the authority of the construc-tion organization should be controlled as to consistency with the basic design criteria to ensure compliance with applicable codes, standards, and regulatory commitments.

II. Scoce of Evaluation The evaluation of this objective involved three members of the Design Control Team and some members of the Construction Control Team. The review teams interviewed support, engineering, pro-ject management, lead contract administrators, several con-tractor superintendents, and Perry Nuclear Power Plant (PNPP)

Project Organization supervisory personnel. The team also reviewed documents, drawings, records, organization charts, and procedures. Approximate 1.y 50 manhours were expehded in the evaluation.

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l III. Conclusion The performance in the Construction Engineering area was very good. It.was evident that the staff included highly experienced people with the lead persons having a minimum of six years tenure with the Perry Project. There is a good practice for listing i valves which is described in the details, along with some minor areas that could be improved.

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- PERFORMANCE EVALUATION SiiMMARY Construction Project Perry Plant Construction Engineering Objective No.

Performance Area '

Evaluator (s)

S. Biro, R. Villforth, F. Jankowski, W. Tokarcik IV. Areas of weakness and corrective action; Good Practices Finding The following good practice was noted:

(CC.1-1) The Nuclear Construction Engineering Section has developed a computerized valve information system which functions not only as a valve list, but also as a valve installed location, inventory, design verification, and start-up area identifica-tion program.

Finding The Nonconformance Report Log of the Site Design (CC.1-2) Team - Mechanical indicated that actions on some reports were pending beyond the 30-day turnaround requirements for disposition and review.

Corrective A review will be made by the site design team of Action the nonconformance report log to determine all (CC.1-2) violations of the applicable requirements of PAP '1502, para. 1.2.2. All violations will be cor-rected by the site design team engineer responsible for review of the nonconformance report by 11-1-82.

To prevent further recurrences of this problem, the A/E Perry Procedures Manual will be revised by 12-31-82 to add the requirements on timing of the review cycles and documenting reason for delay.

A review will be performed under the A/E Assistant Project Manager's direction in January 1983, to assure that the problem is not recurring.

Please note that the NR log maintained in the A/E site project office covers all disciplines; therefore, this corrective action will apply to all disciplines.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant l l

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1. Performance Area: Construction Engineering Objective No. CC-1 '

(title) Sheet 1 of 2 d

2. Provide factual information that sucports the Performance Evaluation Summary _

A. Details in Support of Finding CC.1-1

1. The Responsible Engineer for the site valve information system was interviewed as a result of commendations which were noted while evaluating the A/E Home Office Design Group. The system is a very sophisticated computerized system which offers a wide variety of i information, as well as performs some design and in-ventory control functions.

2. The actual valve printout was reviewed and demonstrated the wide usefulness and flexibility of the program.

! 3. The A/E Home Office Organization has a computer terminal which allows them to get up to the minute information concerning valve records, even though the Basic updating and administration of the program occurs at the site.

B. Details in Support of Finding CC.1-2

1. Review of logs indicated that the A/E Mechanical Site Team is not always following the Nonconformance Report Procedures. Procedure 1502, Revision 2, calls for ,

30-day disposition and 30-day review periods. The log showed NR's pending since 1981 without documentation of reasons for passing the deadlines, as required by procedures.

2. The 30-day NR deadline periods generally were not known to the A/E site people, since they are not indicated in the A/E Site Procedure Manuals.

C. Evidence of Scope not Associated with Specific F'indings

1. The following activities were reviewed, and no sig-niff. cant findings were discovered. The activities are satisfactory:

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PERFORMANCE E7ALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Engineering _

Objective No. CC-1 (title) Sheet 2 of 2

2. Provide factual information that succorts the Performance Evaluation Summary _

. On-site A/E design of small bore piping hangers.

. .On-site A/E resolution of seismic clearance criteria violations.

. On-site A/E interfacing design information for home office resolution of problems on safety and nonsafety large bore pipe hangers.

2. The filing and recording of the numerous reports and forms by the stenographers-clerks was very noteworthy in the A/E Mechanical Site Area. The people were proud of their work and very confident of its adherence to procedures.

3. Contractor superintendents were interviewe'd and generally could not present problems relating to the Construction Engineering activity.

4. The performance of safety-related calculations on site could become a problem. Not many calculations (only two or three) were performed, and they were generally completed per requirements, except that design inputs were vague. A recent procedure for documenting design input criteria-was not well known to the Mechanical Site Lead Engineer and his team. This procedure should be made clear to the people in the event that more safety-related calculations are done on site.

CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATION SUMJiARY Construction Project

, Perry Plant Construction Facilities Performance Area and Ecuierent Objective No. CC-2 Evaluator (s) n_ v4kav4m. c. nafe

.I. Performance Obiective Construction. facilities and equipment should be planned for, acquired, installed, and maintained consistent with project needs to support quality construction.

II. Sccce of Evaluaticn The evaluation of this area included an interview with the Site Crane Coordinator, an interview with the Site Facilities Engineer, and an interview and a Site inspection with the Lead civil contract Administrator. An inspection was also made of a contractor's storage area. Approximately 30 manhours were spent on this evaluation.

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III. Conclusion The control of activities evaluated under this performance objective '

can be rated as very good. No significant weaknesses were observed.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Construction Facilities and Equipment Objective No. CC-2 Evaluator (s) G. Fikaris, C. Daft IV. Areas of weakness and corrective action: Good Practices None.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Construction Facilities

1. Performance Area: and Ecuiement Objective No. CC-2 (title)

2. Provide factual informati~on that succorts the Performance Evaluation Su.mmarv A. Evidence of Scope Not Associated with Specific Findings:

1. An interview with the Site Crane Coordinator indicated that the Site crane scheduling is his responsibility and is done each day in a meeting with all contractors. He indicated that problems and priorities are usually worked out at that level and no problems or confusion exist in allocating crane time.

2. A review of the crane records and logs indicated that substantiation is available for backcharges to con-tractors when necessary, and to defend against claims.

3. An interview with the Site Facilities Engineer indicated.

that there is an adequate staff to support the Site needs' ~

for additional construction facilities.

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4. An interview with the Lead Civil Contract Administrator indicated that there are adequate facilities to support construction and that there is a contractor on Site responsible for the cleanup and maintenance of general construction facilities, including roadways.

5. An inspection of a contractor's storage facility indi-cated that the outdoor storage yards needed some atten-tion, namely weed control and sign repainting. CONCERN -

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. CORRECTIVE ACTION CC.3-4 ADDRESSES THIS ITEM.

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PERFORMANCE EVALUATICN

SUMMARY

Construction Project Perry Plant Performance Area Material Control Objective No. _gg-j Evaluator (s) G. Fikaris, W. Tokarcik H. Vyhnalek I. Performance Obiective Material and equipment should be inspected, controlled, and maintained i to ensure the final as-built condition meets design and operational i,

I requirements.

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II. Scope of Evaluation The evaluation involved three members of the team whose inspections,

' observations, and interviews were divided in three areas: namely, Site-controlled indoor storage, Site-controlled. outdoor storage, and field (contractor) warehousing under Site authority and .

directing, including materials and equipment already in place. A survey of documentation practices, storage , maintenance, and

, warehousing practices in general was made. Input from other team members associated with contractors' operations was also included.

The evaluation required 100 manhours. .

I III. Conclusion There appeared to be a generally satisfactory written program which had been developed for handling materials and equipment from receipt l to process completion. The program for storage maintenance requirement s l

as outlined in the Storage Maintenance Requirements (SMR), provides j the Project Organization with a precise set of. guidelines for the preservation of the quality of each item. There were some problems in the implementation of the program which should be improved. There were also some isolated weaknesses also noted in the contractors' storage practices. -

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Material Control Objective No. CC-3 Sheet 1 of 4

, Evaluator (s) G. Fikaris, W. Tokarcik, H. Vyhnalek Areas of weakness and corrective action: Good Practices

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IV.

Finding Project personnel responsible for Material and (CC.3-1) Equipment Maintenance and Inspection report noncon-forming conditions for major problems, using the

.Nonconformance Reports (NR's) per Procedure 7-1302; but do not use the Nonconformance Report for minor discrepancies related to periodic maintenance requirements. Instead, they use an informal notification method not addressed by approved procedures or instructions.

Corrective After evaluation it was concluded that the basic Action problems associated with the Maintenance Program (CC.3-1) (as implemented) consist of the following:

1. Failure of the program tc specify responsi-bilities for needed SMR revisions, when such necessary changes are attributed *to changing environmental conditions or installation progress.

2. Failure to specifically delineate actions required by Maintenance personnel when a routine maintenance frequency has been missed.

Both of the above deficiencies have been addressed by Action Requests issued by Nuclear Quality Assur-ance Department. All conditions identified needed correction but were not specifically nonconforming based on the evaluation.

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' Actions considered to be minor deficiencies were corrected in accordance with procedure (s). Actions requiring step (s) to preclude recurrence wi'.1 be 1982, by the accomplished on or before December 1, Supervisor, Operational Quality Control Unit.

Finding Warehouse receiving, in-house storage and issuing (CC.3-2) operations are generally good, but e problem does exist with traceability because equipment is moved I . - . - . -.

l PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Material control Objective No. CC-3 Sheet 2 of 4 Evaluator (s) G. Fikaris, W. Tokarcik. H. Vvhnalek

.i IV. Areas of weakness and corrective action: Good Practices l

and documentation is not chat.ged. Nonconforming equipment awaiting disposition is not usually segregated and could get mixed in with other '

equipment.

Corrective Warehouse personnel are performing an inventory Action of all items in storage to ensure accurate storage (CC.3-2) location records and correct discrepancies. Action will be completed by December 31, 1982, under direc-tion of the Assistant Warehouse Superintendent.

The Warehouse Composite Crew has been directed to i

inform the Assistant Warehouse Superintendent when-ever items are not stored in the intended location or are moved to a different location. Procurement Quality Unit will perform a monthly surveillance to sample items in storage per a checklist to be developed by the Supervisor, Procurement Quality Unit by December 15, 1982.

An area is being established by the Assistant Warehouse Superintendent to segregate material awaiting receipt inspection. All incoming mater-ial, size permitting, will be stored in this area.

After inspection, satisfactory items will be moved to their identified storage locations and noncon-forming items will be documented on Nonconformance Reports, tagged, and stored in a segregated area when possible. The segregated area will be estab-lished by December 15, 1982.

Finding Equipment stored in the Warehouse may not always l (CC.3-3) receive the required maintenance. Files of storage maintenance requirement records are not well organized to ensure that all warehouse in storage equipment is properly maintained and in a timely fashion. There were indications that SMR's were not maintained to agree with their current storage levels.

Corrective A program has been developed by the Maintenance Action Coordinator in Nuclear Construction Engineering (CC.3-3) Section, the Assistant warehouse Superintendent 1

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Material Control '

Objective No. CC-3 Sheet 3 of 4 Evaluator (s) G. Fikaris, W. Tokarcik, H. Vyhnalek IV. Areas of weakness and corrective action: Good Practices in Nuclear Construction Administration Section, and the Procurement Quality Unit Supervisor of Training / Administration Section to increase effectiveness of equipment maintenance in the Warehouse. Program Revision Notices are being issued to address the necessary changes in exist-ing procedures and instructions. All actions are scheduled for completion by January 31, 1983, under overall direction of the Assistant Warehouse Superintendent.

The program developed includes revision to Instruc-tion 53-1302 to describe use of the Maintenance Job Tickets an inventory of all equipment in the Warehouse to identify items without Storage Main-tenance Requirements (SMR) forms; monthly sur-veillance of SMRs in the Warehouse by- Nuclear Quality Assurance Department; revision of Pro-cedure 5-0802 to address credit tickets and material returned from Contractors; a review of Procedure 3-1301 to identify possible improve-ment in. updating and maintaining SMRs; and improv-ing the SMR filing and tickler system.

Finding Review of the contractors' material control (CC.3-4) operations revealed situations inconsistent with procedures. Lack of controlled access to storage areas containing safety-related material, trace-ability and housekeeping appeared to be the major problems. The survey, however, also revealed. good storage practice by some contractors.

CorrSctive The Major Electrical, Major Piping and HVAC Con-Action tractors have each established plans for upgrad .

(CC.3-4) ing the material control activities in their areas.

Their plans include additional training for per-sonnel, increased segregation of safety-related materials along with increased emphasis on. limit-ing access to the areas of safety-related equip-ment improved housekeeping and increased attention l

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Material Control Objective No. CC-3 Sheet 4 of 4 Evaluator (s) G. Fikaris, W. Tokarcik, H. Vyhnalek

. IV. Areas of weakness and corrective action; Good Practices along with procedure revisions for' disbursement of materials. These corrective measures are to be completed by November 26, 1982. The Construction Quality Section will issue Action Requests (AR's) to the specific Contractors to track and verify completion of the corrective items. It should be noted that none of the finding details resulted in any hardware deficiencies which would require corrective action.

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PERFORMANCE EVALUATION DETAILS Construction Project

't Perry Plant

1. Performance Area: Material Control Objective No. CC-3 (title) Sheet 1 of 7 ,

2. Provide factual information that succorts the Performance Evaluation Summary A. Details Supporting Finding CC.3-1

1. Auxiliary Building #1, Room 07, 575'-0" elevation; high pressure core spray pump and motor, 1E22-C001 HPCS; SMR required plywood housing has been removed and has not been replaced. A Nonconformance Report was not written.

2. Reactor Building #1, 568' elevation; control rod drive housing room had two housing ends uncovered and not protected. A Nonconformance Report was not written.

3. During an interview, the PMA maintenance coordinator stated that if maintenance required by the responsible maintenance engineer could not be completed during the required intervals, that it could be postponed without a Nonconformance Report being written.

4. In the above facts, the OQC inspector and the PMA maintenance coordinator stated that they would not write a Nonconformance Report. A job ticket would be issued the next week to complete required work and would only be reported on the weekly report back to the responsible maintenance engineer. Their statements included that the responsible maintenance engineer might write the NR, but they were not sure, nor did they follow up to make sure. The responsible

maintenance engineer stated that he did not write the NR or noncompleted maintenance.

5. Outdoor storage of heat exchangers required the maintenance of a nitrogen purge of 5 to 15 psi to be checked on a four-month interval. Inspection of the records showed that there was compliance with the interval requirement, but the records also showed at least 21 instances where purge pressures below 4 psi were noted without DR's or NR's being written.

6. Implementation of two SMR's was observed in the field.

Four 125 V batteries (R42-S002, S003) were in place, but SMR form was only attached to one. Panels 1H51-P142 i

and P143 were not completely protected by a tarp in accordance with SMR.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Material Control Objective No. CC-3 (title) Sheet 2 of 7

2. Provide factual information that suceorts the Performance Evaluation Summary _

B. Details Supporting Finding CC.3-2

1. An interview with the maintenance coordinator and a ,

walk through the warehouse brought out a traceability problem. Tracing down several pieces of equipment for maintenance checks revealed that they were relocated from their documented location. The maintenance coordinator said that this was a problem.

2. In an interview with the assistant warehouse supervisor, he admitted too much equipment was stored on the floor and that he was getting shelving con-structed to correct this. He also said that to his knowledge, nonconforming equipment was not, roped off and could get mixed in with other equipment by mistake.

The maintenance coordinator also said the same thing.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Material control Objective No. cc-3 (title) Sheet 3 of 7

2. Provide factual information that supports the Performance Evaluation Summary

( C. Details Supporting Finding CC.3-3

1. A spot check of maintenance records on equipment showed that, in general, proper maintenance was being performed.

However, several instances were noted where records were not attached to equipment, and several pieces of equipment had missed a yearly maintenance.

2. A review of the master SMR file indicated that there was no method of initiating maintenance in a timely fashion. The maintenance coordinator indicated that he is in the process of instituting a tickler file to help him in getting maintenance done. This is a manual method, as opposed to a computerized maintenance file used by plant operations for in place equipment main-tenance.

3. Storage Maintenance Requirement records (SMR) for several in storage sump pumps inspected were found to be missing from the master file. There were no main-tenance records available. The maintenance coordinator said that he was correcting this. These pumps were not safety-related and did not require Nonconformance

, Reports to be written. However, he could not be sure how bad this situation is and is in the process of reviewing this.

4. Inspection of the maintenance coordinator's list of items under his ~ surveillance revealed equipment without ,

an MR, but having an SMR. It was explained that this equipment belonged to a contractor, but was under Site maintenance. There.was no definite procedure which could be located to explain the handling of this situation. Inspection of the equipment revealed that nonsafety sluice gates were-involved. The attached SMR indicated that this equipment required- UI (Unheated l Inside) storage. It was stored outdoors under a tarp.

No DR or NR was located covering this nonconformance.

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PERFORMAN.CE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Areas Material Control Objective No. CC-3 (title) Sheet 4 or 7

2. Provide factual information that succorts the Performance Evaluation Summarv _

5. The preparation of SMR's, Storage Maintenance Requirements, was discussed with the electrical equipment responsible engineer and the following was noted:

a. He identified the procedure he was using as Nuclear Design and Procurement Procedure 3-1031, Revision 2, dated August 29, 1980. Later review of the procedure manual indicated that Revision 4 of this procedure exists, and he was, therefore, not using the latest revision.

b. Review of the " Master File" of SMR's revealed the following:

1) Copies of previous revisions, not voided, were included in the file.

2) Photocopies, not originals, are in the file, and some of them are not clear copies.

3) Procedure requires that forms be signed and dated. Not all SMR's are so identified.

4) Procedure requires that when SMR's are revised, these points of change shall be '

identified. Most revisions were not identified.

D. Details Supporting Finding CC.3-4 The inspection of contractors' storage practices revealed the following practices inconsistent with procedure:

1. Major Electrical Contractor l

a. Warehouse was dusty, due to ongoing construction activities in this area. However, no sensitive equipment was located in this area.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant -

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1. Performance Area: Material Control Objective No. CC-3 (title) Shest s of 7

2. Provide factual information that succorts the Performance Evaluation Summary

b. The safety-related storage area, located upstairs in the Warehouse, was not locked with access l

controlled. This area was not manned. Access control is required by ANSI N45.2.2.

c. The storeroom foreman controlled access to the ground level storeroom. However, he was only concerned with those union personnel reporting to him. An access list, approved by Contractor management, was not located in this area, and the foreman was not aware of such a list. Access control is required by ANSI N45.2.2.

d. Cable tray brackets were found stored outside the warehouse, as well as inside the warehouse, but outside the safety-related storage area. Con-sequently, access to these material was not controlled.

2. Major Piping Contractor

a. Outside storage areas (south storage) had numerous weeds growing within them; material was stored on dunnage and kept in outside storage areas. Ropes

' designating outside storage areas were, in many cases, sagging and laying on the ground,

b. Small hanger material, including several. spring hangers, were stored inside a quonset hut covered with a visquine type material. The material within the hut was very rusty.

c '. A hanger base plate with other materiS1 was stored in the Intermediate Building, Elevation 599'. The responsible field engineer was able to readily determine the storage location of the base plate from his records.

d. Weld rod in disbursement areas was usually stored in hold ovens at a temperature of approximately 250*F. On occasion, they are maintained in portable ovens over night.

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PERFORMAN C VALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Material Control Objective,No. cc-3 (title) Sheet 6 of 7

2. Provide factual information that supcorts the Performance Evaluation Summary __

3. Major HVAC Contractor (Weld Rod Storage Area)

a. . Weld rod, as received, is stored in the QC manager's office.

b. Disbursement of weld rod was controlled and witnessed by QC. However, QC'did'not witness the return of weld rod.

4. Major Instrumentation Contractor

a. Nonconforming materials were either in a roped-off area or stored in a locked storage area. Material is not tagged with an " Accept" tag. However, no~

evidence that unacceptable material was used in the field could be located. It was, therefore, ,

concluded that this system was acceptable.

b. Quality documentation was readily available for the material installed in the field. Quality documentation is stored by Purchase Order. The Owner should ensure that heat number / purchase order cross-reference log maintained by the Contractor's receipt inspector is turned over to the Owner'at the end of the Project.

c. Safety-related piping has end caps installed.

Nonsafety-related stainless steel pipe and tubing did not have end caps and was stored on carbon steel racks.

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4 PERFORMANCE EVALUATION DETAILS Construction Project i

. Perry Plant

1. Perfo'mance r Area: Material Control Objectiva No. CC-3 (title) Sheet 7 of 7

2. Provide factual information that supports the Performance Evaluation Summarv

5. Nuclear Coatings Contractor i The paint storage trailers are temperature controlled and carefully monitored. When questioned about the control that is exercised during the time the material left the factory, records and comments revealed that water-based paints were not used during the past winter despite the manufacturer's research indicating that they would tolerate five freeze / thaw cycles without affecting their quality. Solvent-based paints were picked up by the Contractor's personnel, minimizing I transit time (Cleveland from Buffalo).

Evidence of Scope Not Associated with Specific Findings  ;

F.

The Contractor responsible for the physical labor which maintained equipment storage in place was changed while this evaluation was in progress. The decision was based on normal rebidding of the work when their contract expired and the new contractor was commercially more acceptable. The

Contract Administrator was also changed. During the past three years, the preceding Contractor's work was directed by l five different maintenance coordinators and four different maintenance engineers.

The new Contractor was ab1e to employ one-half of the craf tsmen released by the previous Contractor / but the new superintendent l had not been fully trained, nor had his qualifications been i accepted by the Contract Administrator at this time.

CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR EEPUNNE AND FOLLOW-UP. - -

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PERFOR.%NCE EVALUATION

SUMMARY

Construction Project

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. Perry Plant Performance Area Control of Construction Processes Objective No. CC-4 Evaluator (s) , ,

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I. Performance Obiective The construction organization should monitor and control all construc-tion processes to ensure the project is completed to design requirements and that a high level of quality is achieved.

II. Scoce of Evaluati2n, The evaluation of this area involved essentially the entire Construction Control Group. Approximately 175 manhours were expended in interviews, inspections and observations of work practices at various locations on the Project. Both safety-related and nonsafety-related areas of work were involved.

Jrocedures, specifications, qualifications, records.and other documents were reviewed to evaluate the entire performance area.

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l III. Conclusien

, The~ majority of the act.ivities evaluated under this performance objective were satisfactory. However, some isolated areas of concern were noted which need to be addressed.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

. Perry Plant Performance Area Control of Construction Processes Objecgfgp Np. ;CC-4

• Evaluator (s) W. J. Tokarcik and Various Team Members IV. Areas of weakness and corrective action; Good Practices Finding The Contractor responsible for installation of l (CC.4-1) safety-related instrumentation did not follow procedures during some aspects of hilti bolt installation and grouting of abandoned holes.

Corrective The Instrumentation and Control (I&C) Contractor Action has been directed to establish hold / witness points, (CC.4-1) on all future patching of " abandoned" hilti bolt ,

holes. These hold / witness points will be in effect until such time as a level of confidence can be gained to give assurance that the concern identified by the INPO Inspector is not a generic

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problem. In addition, the I&C Contractor has been instructed to establish a training session for all personnel involved with hilti bolt installation.

This training session will be monitored and docu-mented by the Civil / Structural Unit of Construction Quality Section (CQS). This training will be done by October 29, 1982.

In addition to the above actions, the Supervisor of the Civil / Structural Unit of CQS (a Level III civil inspector as well as a lead auditor) will lead an in-process audit of "all" contractor's presently installed hilti bolts. The results of these audits will determine if this finding is '

. generic in nature or simply an isolated case.

The I&C Contractor has'been~ instructed to provide a map of all hilti bolt installations in the area where the obse'rvation for this finding occurred.

This map will be analyzed to identify any abandoned bolt holes which fall within the stress cone area

_ _ _ _ of installed hilti bolts. Any abandoned holes that fall within the stress cone area will be sample inspected in accordance with Mil Standard 105.D to establish the structural integrity of abandoned bolt holes.

Fi'nding Electrical Cont'ractor personnel were not qualified (CC.4-2) to a written procedure in the performance of cutting and silver brazing of safety-related stainless steel conduit.

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, PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Control of Construction Processes Objective No. CC-4 Sheet 2 of a .

Evaluator (s) W. J. Tokarcik and Various Team Members l l

IV. Areas of weakness and corrective action: Good Practices Corrective' The current procedure for brazing of flex conduit Action provides for training of personnel performing this (CC.4-2) activity. The Electrical contractor will reviso this procedure to include qualification of brazing personnel. It should be recognized that this opera-tion does not affect the safety function of the system nor does the brazing technique lend itself to normal qualification procedures.

A random 20% sample of in-process brazed ends was performed by the contractor's inspection personnel and found acceptabic. The results of this inspec-tion were documented on the contractor's Form No. 131. No,further prior work inspections are planned in view of these results and the fact that the brazing of the conduit was being done merely to facilitate the next construction step of installing the conduit fitting.

Nuclear Construction Engineering and Construction Quality Sections will review revisions to the above procedure and verify that work is performed per procedures.

The above actions will be accomplished by Decem-ber 15, 1982.

. Finding Electrical Contractor responsible for welding (CC.4-3) isolated phase bus duct (nonsafety-related) does not have a procedure for this activity.

Corrective ~

Contracts Administration will direct the Major

Action Electrica1' Contractor by letter to furnish a proce-(CC.4-3) dure and instructions for the field welding of

, aluminum Isolated Phase Bus duct by November 10, -

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m PERFORMANCE EVALUATION

SUMMARY

Construction Project s

Perry Plant Performance Area Control'of Construction Processes Objective No. CC-4 Sheet 3 of a .

Evaluator (s) W. J. Tokarcik' and Various Team Members IV. Areas of weakness and corrective action Good Practices Project Engineering will evaluate the past aluminum welding on the Isolated Phase Bus duct, including the inspections performed to date, and the rework performed under Deficiency Report #1304, to ascer-tain compliance with the riajor Electrical Con-tractor's approved procedure. This evaluation for compliance will be done after issuance of the approved procedure.

The Project Construction Quality Section will ver-ify, through inspections to the approved procedure, that work is being performed in compliance with the procedure.

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4 1 i PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Control of Construction Processes Objective No. CC-4 (title) Sheet A of 4

2. Provide factual information that supoorts the Performance Evaluation Summarv _

A. Details in Support of Finding CC.4-1

1. Documentation and procedures for hilti bolt installation were available at the work site.

2. Craftsmen drilled holes with care to procedure requirements.

3. Grouting of abandoned holes was inconsistent and procedures for mixing grout were not followed.

4. Contractor QC Inspectors did not inspect abandoned holes for cleanliness prior to grouting.

5. -During and after grouring operations, the holes were not inspected to see that they were filled to full -

depth.

B. Details in Support of Finding CC.4-2

1. This activity is considered safety-related by admission of the Contractor's QC Inspector.

2. Contractor QC Inspector indicated that the Contractor had a procedure for installation, but not for qualifying personnel to perform a work activity of this nature. ,

3. The Contractor welding engineer indicated that he has observed silver brazing operations and found them acceptable.

4. Work was performed in the Contractor's fabrication shop under Contractor quality control inspection..

5. Contractor QC Inspectors did not have an acceptance criteria to approve the completed operation.'

C. Details in Support of Finding CC.4-3 Other nonsafety-related welding activities were being 1.

done to AWS procedures as required by Specification 34-4549-00.

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PERFORMANCE EVALUATION DETAILS Construction Project l

I Perry Plant

l. Performance Area: Control of Construction ProcessoGbjective No. CC-4 (title) Sheet 2 of 4

2. Provide factual information that suceerts the Performance Evaluation Summarv _

2. The specification (SP-34) requires a procedure for welding and special processes.

3. No approved procedure could be produced for the welding of aluminum Isolated Phase Bus which was being done by the Electrical Contractor.

D. Evidence of Scope Not Associated with Specific Findings:

1. Observation, inspection and interviews of the installa-tion of NSSS mechanical equipment and installation of mechanical equipment installed in the nuclear island other than NSSS group revealed:

a. The Contract Administrator was well informed on problem areas encountered by the Contractor. Tracking Systems are used to follow the status of NR's and Travelers Bi-Weekly Meetings are held to review the status of work and problem area identification.

b. Travelers containing procedures are prepared by the contractor, submitted and approved by Project Organization Engineering and QA before work begins.

2. An observation-and inspection of installation of nonsafety-related instrumentation and installation of safety-related instrumentation revealed:

a. The Contractor's QA Manual was revised in March 1982 to delete the use of " Accept Tag." However, procedures still require its use. Revision of procedures to meet QA Manual criteria.is in progress.

CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

b. Welding procedures were in order. Interviews with three welders demonstrated their knowledge of welding requirements,

c. Inspection procedures were of current revision and

- were carried by the inspectors.

PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant t

1. Performance Area: Control of Construction Processesbjective No. CC-4 (title) Sheet 3 of 4

2. Provide factual information that sucocrts the Performance Evaluation Summarv _

d. Verification was made on welding procedures and NDE procedures (PT),

e. Verification was made on in process traveler packages.

f. Weld areas were inspected and found to meet all requirements.

3. Observation, inspection and interviews on the Contractor involved in installing HVAC in areas other than the nuclear island and installation of HVAC in'the nuclear island revealed:

a. Welders were knowledgeable and followed welding -

procedure requirements.

b. Welding procedures were prequalified and welders observed were qualified for the work in process.

c. Certification of weld rod filler material was available to the evaluator.

4. An observation was performed on the safety-related electr'ical installation which revealed:

Installation of expansion anchor bolts to relocate a conduit bracket in R3 #1, 620'-0" elevation at the 195*

interval was performed according to the contractor's procedure and was inspected by the Contractor's QC Inspector.

5. During expansion anchor bolt installationb 'y the Electrical Contractor, it was observed,that Contractor QC Inspectors did not follow good documentation practices. The Contractor's QC Inspectors took notes of observations, then went back to the office to fill out the Quality Documentation and Acceptance Report. This may be a source of error in the' documentation of the operation, especially when several inspections are completed before data is recorded on the quality record.

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I PERFORMANCE l"7ALUATION DETAILS Construction Project

, Perry Plant

1. Performance Area: Control of Construction Processesbjective No. CC-4 (title) Sheet 4 of 4

2. Provide factual information that succorts the Performance Evaluation Summarv _

(Location: RB #1, 620' elevation, 195* interval)

CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

6. In general the Project Organization's flush unit of NTS displayed an excellent knowledge of the process and the details of the procedures. However, two areas of concern were noted during the observation of the flushing of a nonsafety system:

a. The operator displayed carelessness in handling the " pillowcase" which is used to evaluate the quality of the flushed water. The pillowcase was removed from the plastic container and laid on a packing crate in the work area. This activity subjected the pillowcase to area cont' amination.

The collected particulates are used to evaluate the cleanliness of the line. This breach of good practice might cause false indications which could require further unnecessary flushing.

b. Procedures were ignored during the f!"sh which may have altered the results. The procedure required a three-pump operation during an observation; only two pumps were operating. The Test System Engineer in charge authorized this procedural change while flush was in progress. This change in procedure was not documented but later was accepted by a high level review.

CONCERN - ACTION REQUESTS WERE ISSUED BY THE PROJECT FOR ITEMS a & b FOR RESPONSE AND FOLLOW-UP, 453A/Z/8/rd

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant  !

Performance Area Construction Quality Inscections Objective No. CC-5 Evaluator (s) B. H. Grier, C. Daft I. Performance Obiective Construction. inspections should verify and document that the final product meets the design and quality requirements.

II. Scope of Evaluation Evaluation of this performance area was based on interviews with appropriate Project and contractor personnel, observations of construction activities, and related inspections and examination of procedures and records. Approximately 55 manhours were expended on this evaluation.

III. Conclusion

. The majority of activities evaluated in this performance area were found to be satisfactory. It appears that increased atten-tion should be given to the review of contractor NDE inspection procedures and to procedures for qualifying contractor NDE personnel.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

' Perry Plant Performance Area Construction Quality Inspections Objective No. CC-5 Sheet 1 of 3 Evaluator (s)

IV,. Areas of weakness and corrective actiont Good Practices Finding The Major Piping and Electrical Contractors and (CC.5-1) NDE procedures for liquid penetrant examination do not specify the maximum drying time between

' penetrant removal and developer application as required by the ASME Code,Section V, Article 6.

In the Major Piping Contractors case, it was

_ __ observed that an NDE inspector performing.a liquid penetrant examination in the contractor's fabrication shop on site did not adhere to a maximum time between penetrant removal and developer application.

Corrective The major piping Contractor was issued an Observa-Action tion Action Request on October 13, 1982, stating (CC.5-1) that removal and application of the developer had not been addressed procedurally. This finding can be closed upon receipt of an acceptable procedure

- revision from the Contractor. (This requirement was established during procedure qualification.)

A follow-up audit will be performed 30 days after the procedure revision.

Identification of past deficiencies is not appli-cable. The material manufacturer recommends a drying time of 5 to 30 minutes. Past monitoring by the-Construction Quality Section (CQS) revealed no problems with excessive drying. CQS will con-tinue to include this area in their daily sur-veillance inspection activities.

The Major Electrical Contractor's liquid penetrant procedure will be revised not later than Novem-ber 30, 1982, to specify maximum drying time be-tween penetrant removal and developer application.

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A Project Action Request has been issued to ensure l

this action item is tracked to completion.

No action to identify past deficiencies is re-quired because this Contractor has not performed any P.7. on site.

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- PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Construction Quality Inspections Objective No. CC-5 Sheet 2 of 3 Evaluator (s) B. H. Grier IV. Areas of weakness and corrective action; Good Practices Finding The Major Piping and Electrical Contractors pro-(CC.5-2) cedures for NDE Practice Qualification used to qualify liquid penetrant inspectors did not meet the requirements of SNT-TC-1A. In addition, the documented evidence that the work experience of two piping liquid penetrant inspectors met the qualification requirements of SNT-TC-1A for Level I and/or Level II was not complete.

Corrective A complete review of personnel records was immedi-

Action ately conducted by the Major Piping Contractor.

(CC.5-2) Four individuals identified as being incorrectly certified were retested under the direct supervi-sion of the NDE Level III examiner using a test object with known indications. All four passed y

the re-examination and documentation attesting to the retest is acceptable and on file. All individuals in question appear to have been fully qualified. The Project Organization NDE Element retests welds using either Liquid Penetrant Tests

, or ultrasonic tests as part of its surveillance i program-and its Pre-Service Inspection respec-

! tively. Because of these factors, no further action on previous examinations is considered necessary. .

l The Project Construction Quality Section (CQS) l is reviewing all NDE personnel certifications, with completion expected by November 12, 1982.

Any problems id.entified will be handled on a case by case basis. Al'1 future certifications will be closely monitored and evaluated by CQS.

, Although no requirement exists for the Contractor to map out and document the know indications of his test specimens, this was recommended during the evaluation as a good practice. The Major Piping Contractor has incorporated this sugges-tion into their program.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Construction Quality Inspections Objective No. CC-5 Sheet 3 of 3 Evaluator (s) B. H. Grier IV. Areas of weakness and corrective action; Good Practices The Major Electrical Contractor's NDE Practice Qualification procedure will be revised not later than November 30, 1982, to include the SNT-TC-1A requirements that a test piece with known indica-tions be utilized and that examinees be required to identify 90% of those indications during par-ticle examination. A Project Action Request will be issued by CQS to ensure this item is tracked to resolution.

All Major Electrical Contractor personnel holding P.7. certifications will be retested to the re-vised procedure. No action to identify past pro-cedures is required because this Contractor has not performed any P.7. on site.

Finding The project procedure for the Review of Con-(CC.5-3) tractor Procedures (2-0504), which is applicable to the Construction Quality Section (CQS), does not specify the qualification requirements for the individual who reviews and approves contractor procedures. CQS is assigned the prime responsi-bility for review of NDE procedures. (While it may be inferred that this finding contributed to CC.5-1 and CC.5-2, that fact was not established.)

I Corrective Current procedures are being revised and combined Action into a new Project Administration Procedure which (CC.5-3) will requira reviewers to be certified in accor-dance with ANSI N45.2.6 (1972). The General Supervisor, Construction Quality Section (CQS) will assure the revised procedure is forwarded l

to the Procedures and Records Unit by November 15, i

1982, for processing, training and issuance.

The Unit Supervisor, CQS Program and Records Unit, will ensure a review of all active NDE procedures by November 15, 1982, to determine if the original reviews were performed by qualified reviewers.

Any procedure found not to have been reviewed by a person qualified in accordance with ANSI N45.2.6 and/or ASNT-7C-1A will be re-reviewed by a quali-fied reviewer.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Quality Inspections Objective No. CC-5 (title) Sheet 1 of 3

2. Provide factual information that supeorts the Performance Evaluation Summarv _

A. Details in Support of Finding CC.5-1

1. The Major Piping Contractor's Liquid Penetrant Procedure (IX-PT-1-N75) does not specify the maximum drying time between excess penetrant removal and application of the developer.Section V of the ASME Code requires that this time not exceed that established during the procedure qualification. In addition, liquid penetrant examination personnel in the field indicated that there was no maximum time between excess penetrant removal and developer application.

2. The Major Electrical Contractor's Liquid Penetrant Procedure (4.7.5) does not specify the maximum drying time between excess penetrant removal and application of the developer.Section V of the ASME C6de requires that this time not exceed that established during the procedure qualification.

B. Details in Support of Finding CC.5-2

1. Reviewed the Major Piping Contractor NDE Level II Liquid Penetrant. Personnel Qualifications.

a. Four individuals were qualified on either a fabrication piece or a test piece with no indications during the practical portion of their qualification examination. This appears contrary to SNT-TC-1A which requires the individual to identify 90% of the known indi-cations during the practical examination.

b. For the test piece in which there are indi-cations, the contractor has not mapped out the piece to document the known indications.

2. Reviewed the Major Electrical Contractor's NDE Level II Personnel Qualification Practices.

Revealed that personnel utilized fabrication pieces during the practical portion of the qual-ification examination. This is contrary to SNT-TC-1A which requires individuals being tested to identify 90% of the known indications during the practical examination.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Quality Inspections Objective No. CC-5 (title) Sheet 2 of 3

2. Provide factual information that supeorts the Performance Evaluation Summarv _

i

3. SNT-TC-1A specifies the work experience necessary prior to qualification to Level I or Level II.

For at least two Major Piping Contractor's liquid penetrant examiners, documented evidence of work experience met the qualification requirements of SNT-TC-1A for certification to Level I and/or Level II was not complete.

C. Details in Support of Finding CC.5-3

1. A review of Procedure 2-0504 shows that the qualifica-tion requirements for the individual who reviews and approves contractor procedures is not specified.

Qualification requirements for reviewers are specified in other project procedures. ,

2. A review of a recent audit report (PIA 82-12) indicates that the above item was identified as an item of con-

, cern. The audit report also identifies several

cases in which the qualification of the individual who reviewed contractor NDE procedures could not be established.

3. A review, on October 13, 1982, of an initial draft of the procedure being developed to replace 2-0504 indicated that the item of concern had not been resolved.

D. Evidence of Scope not Associated with Specific Findings

1. Discussions with Quality Engineers and review of project procedures indicate that the construction inspection.

program being carried out by the Construction Quality Section is clearly defined and well organized. The individual responsibilities are documented. Detailed, Surveillance / Inspection Plans are developed for inspec-tion of individual contractors. Plans include in-process audits as well as the use of hold points and witness points. Checklists are used to report results of surveillance inspections.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Quality Insoections Objective No. CC-5 (title) Sheet 3 or 3

2. Provide factual information that succorts the Performance Evaluation Summarv

2. During the evaluation period, the evaluator was escorted by several Quality Engineers and Quality Control In-spectors. Generally, it was felt that these individuals were knowledgeable in their assignments and were .

interested in ensuring that a quality job was performed.

3. Inspected several welds in the Major Piping Contractor.'s laydown areas for good workmanship practices during off site fabrication. No deficiencies were noted.

4. Reviewed the major Instrumentation Contractor as '

follows:

Welders interviewed felt inspectors were knowledgeable in the performance of their duties and that their inspections were timely to support the con'struction activities. Verified that inspection procedures were of a current revision and were coded by the inspectors. Veri-fied that weld process sheets (travelers) were available at each work location, had been reviewed for hold points by Instrumentation and Control Contractor, the Owner and the ANI, and that these hold points had been adhered to.

5. Reviewed the major HVAC Contractor as follows:

a. The contractor's mandatory hold points, such as final visual inspections, are called out in produc-

, tion procedures. Remaining inspections are on a l surveillance basis. There is no established sur-veillance schedule. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSp AND FOLLOW-UP.

b. Interviews with welders indicated they were familiar l with mandatory QC hold points, as established in

. procedures. Although not reviewed by ANSI N45.2.6 or contractor procedures, contractor gave tests to QC inspectors to demonstrate their knowledge of visual weld inspection requirements, 10CFR50, Appendix B, and ANSI N45.2.

453B/C/7/rd

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PERFORMANCE EVALUAT ON

SUMMARY

Construction Project

• Perry Plant i

Performance Area Construction Corrective Actions Objective No. CC-6 Evaluator (s) B. H. Grier

.I. Performance Obiective

The construction organization should evaluate audits, inspections, o

and surveillances; proce.ss replies and follow-up; and take corrective action to prevent recurrence of similar problems.

II. Scdce of Evaluation Evaluation of this performance area was based on interviews with appropriate Project personnel and examination of related procedures and reports.

Approximately 30 manhours were expended on this evaluation area.

III. Conclusion i

The control of activities evaluated in this performance are.a was

! found to be satisfactory. The attention recently given to the

! nonconformance system should be continued to ensure that changes l made are effective in achieving the desired improvements.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project I

1 Perry Plant j Parformance Area Construction Corrective Actions Objective No. CC-6 Evaluator (s)- B. H. Grier IV. Areas of weakness and corrective action; Good Practices Finding (CC 6-1) The procedures which have been in place for identi-fying, tracking and resolving nonconformances have

.not always been effective in achieving timely close-out of the nonconformances identified.

Corrective The Contract Administrators will' increase their NR Action closeout efforts with the specific Contractors.

(CC.6-1) The CA's will take the necessary steps immediately to identify to the Contractor and Scheduling Area Teams the workable NR's in their Contractor.'s pre-sent work areas. The Contractors will be directed to implement those NR's that are workable / closeable in a timely manner prior to dehobilization from that particular area. ,

The Contract Administration Administrdtive Assis-tant will continue to provide the necessary NR information to the Contract Administrators so that outstanding NR closecut can continue. A monthly update of NR's by specifications is provided to the respective CA to have his Contractor work on.

This system was initiated within the past six months in the Contracts Group.

The various Project Managers will periodically review NR closecut progress to ensure effective-ness of the program.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Corrective Actions Objective No. CC-6 (title) Sheet 1 o: 2

2. Provide factual information that supcorts the Performance Evaluation Summarv _

d A. Details in Support of Finding CC.6-1 A review of the current status report of open Nonconformance Reports (NR's) shows a total of approximately 1,000 open Many of these have been NR s in the NR tracking system.

open for more than a year and some for nearly three years.

A review of the trend analysis for the last six months shows .

the number of open NR's is continuing to increase.

Changes in the nonconformance procedures have recently been made based on the results of comprehensive assessment of the

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nonconformance system conducted early this year. Extensive training of personnel involved in using the system has 1

recently been completed. There is insufficient data at this time to evaluate the effectiveness of improvements in the -

system.

B. Evidence of Scope not Associated with Specific Findings

1. An extensive assessment of the NR System was conducted early in 1982 as a part of the QA Program Evaluation.

The Task Force conducting the assessment made a number of recommendations for improving the NR System. Action on these recommendations has been carried out over the past several months.

2. A detailed training program on the NR system was developed for all involved Project personnel. This training program has been completed.

3. The Project procedures for nonconformance control (PAP 1502) was revised and issued effective September 15, 1982. Changes were made in the procedure to respond to recommendations of the 101 Assessment Task Force. The revised procedure clearly defines respon-sibilities and establishes time periods within which action must be taken in processing trend analyses.

4. .A computer tracking system is in place and being used .

to track NR's. Various programs are available for performing trend analyses.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Construction Corrective Actions Objective No. CC-6 (title) Sheet e or e

2. Provide factual information that succorts the Performance Evaluation Summarv

5. Weekly reports on the status of open NR's are prepared and distributed. These reports identify the organiza-tional element responsible for the next NR action.

Reports are also prepared showing NR activity by contractor.

6. Further ef forts to develop capability for additional trending analysis to improve usefulness of the system' are reported to be underway.

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453A/B/4/ba 1

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PERFORMANCE EVALUATION SUW1ARY Construction Project Perry Plant Performance Area Test Ecuiement Control Objective No. CC-7 H. J. Vyhnalek, W. Powell, P. Solanics, C. Daft Evaluator (s)

I. Performance Obiective Measuring and test equipment should be controlled to support construction' testing effectively.

II. Scoce of Evaluation Interviews and obser'v ations were conducted to evaluate the efficiency of the Site Instrument Calibration Program.

One team member conducted the evaluation although all members were alerted to inspect test equipment employed in their areas for calibration information.

Approximately 5 manhours were devoted to this evaluation area.

III. Conclusion There appeared to be an excellent program of control for equip-ment under Project Organization responsibility; however, there was a concern with one of the six contractors who were revierad. ,

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- PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Test Equipment Control Objective No. CC-7 Evaluator (s) H. J. Vyhnalek, W. Powell, P. Solanics, C. Daft IV. Areas of weakness and corrective action; Good Practices Finding The Instrumentation and Control contractor had no (CC.7-1) routine program for calibrating welding machines.

Corrective The Instrumentation and Control (I&C) Contractor Action will revise their Measuring and Test Equipment (CC.7-1) Procedure, and the Project will review QAS-1006,

" Welding Procedure and Performance Qualification" by November 30, 1982. CQS generated a Project Organization Action Request to ensure that the actions are effectively implemented with appro-priate follow-up.

. The I&C Contractor Quality Control inspects 100%

of all safety-related welds, and the Project Con-struction Quality Section (CQS) inspects approxi-mately 10% of all welds inspected by the I&C Con-tractor. Based on successful results'in these inspections, there currently is no reason to suspect the acceptability of any previous welds.

Therefore, no re-inspection prograss is proposed.

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PERFORMANCE E7ALUATION DETAILS Construction Project e

Perry Plant

1. Performance Area: Test Eauipment Control Objective No. CC-7 (title)

2. Provide factual information that succorts the Performance Evaluation Summary

( A. Details in Support of Finding CC.7-1 The Instrumentation and Control Contractor does not calibrate their welding machines; however, current output is periodically checked through QC Surveillance. The claim was made that calibration is not required by the Contractor's procedures.

This was the only contractor of six who had not complied to the requirement of SP-709-4549-00, Revision 4, 5/24/79.

1:05,11.which states that the contractor is responsible for this calibration.

'B. Evidence of Scope not Associated with Specific Findings:

1. Interviewed the' technician responsible for the super-vision of the Project Organization Calibra~ tion Lab and found the following:

. Good Training Program - All technicians must pass a fairly rigorous test and are requalified every two years. Program is described in Instruction 61-0201.

. . Facilities - Rather cramped since they are temporary. The calibrating equipment appeared to be of excellent caliber. All were traceable back to the Bureau of Standards.

. Documentation - All instruments having an MPL number which require calibrations are computerized.

Weekly printouts are reviewed and instruments requiring calibration are noted and re. calibrated.

Two instruments were picked at random from the total list and were easily traced through the files for their complete calibration history.

2. All test equipment in use that was noted by members of the Evaluation Team were reported to be properly labeled. All instruments were in compliance with the calibration interval limits.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Perfo=mance Area Industrial Safetv Objective No. PS-1 Evaluator (s) G. Fikaris and various team members I. Performance Obiective The construction site industrial safety program should achieve

[ a high degree of personnel safety.

II. Scoce of Evaluation -

.The evaluation of this area included interviews with the Site Industrial Relations Manager, the Site Safety Supervisor, and personnel in both fire protection and industrial safety areas of responsibility. An observation of site safety surveillance was made and an inspection of fire fighting and medical response equipment was conducted. Other team members contributed to this evaluation through their various observations.

. Approximately 22 manhours were spent in this evaluation.

l III. Conclusion The site fire protection and medical response activities were

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found to be satisfactory. However, although the site safety record has been good, several areas for improvement were identified.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Industrial Safety Objective No. PS-1 Sheet 1 of 4 .

Evaluator (s) G. S. Fikaris and various team members IV. Areas of weakness and corrective action; Good Practices S-Finding The effectiveness of site safety and fire (PS.1-1) protection systems may be jeopardized by the lack of sufficient personnel. The number of safety surveillances completed by Site safety personnel have recently been reduced due to the loss of l personnel. Site personnel are showing concern l

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over near accidents. Untrained maintenance

' personnel are being utilized to check fire .

protection systems.

Corrective The primary responsibility related to safety and Action fire protection for all site contracts lies with the (PS.1-1) Contractors. The site reviews of their activities and the performance record of the project indicates

- the Contractors are effectively meeting their responsibilities.

The Project Organization responsibility is to pro-vide an overview and coordination with the Contrac-tors' programs. The following are the plans of the Project Organization to maintain its effective overview function. .

A new Project Fire Chief has recently been appointed in the Fire Protection Unit. Based on this recent transition, a new person will be provided to assume the Chief's former responsibilities. Also,.an overall evaluation of personnel requirements for Safety and fire protection is currently in progress.

Target date for completion of the review and any

. necessary manpower adjustments is December 1, 1982.

The comment that the site is using untrained maintenance personnel should be clarified. The

~ ~ ~ - people referred to are three plant maintenance personnel who are on a rotation of assignment, with one being rotated every 30 days. These

. people are trained prior to or during inspections and are used to do only basic fire prevention checks, such as: .

1. Fire extinguisher checks i

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Industrial Safety Objecgve 9. PS-1 Evaluator (s) G. S. Fikaris and various team members IV. Areas of weakness and corrective action: Good Practices

2. Routine maintenance checks of site protection systems Finding Sito safety violations were observed in various (PS.1-2) areas of the construction Site. While the number of violations observed were low for a project this size, improvement can be made in a number of areas. Each contractor has the prime r.e,sponsibility' for safety in their work areas.

Corrective Existing contract clauses and day-to-day communica-Action tions will continue to emphasize that the first-(Ps.1-2) line responsibility for safety rests with con-tractors. A designated safety representative is

- provided by all major contractors to assure that safety programs are enforced.

The Project 0 ganization Safety Unit is continually striving for improvements in the Contractor's safety progrcms. The Safety Unit provides an over-view of contractor programs with identified problems being reported to the contractors v.ia the Contractor Administration using " Notice of Safety Violations"

. and " Safety Inspection Memorandum." The Safety Unit is not the only source of input for identifying problems and/or concerns. Safety issues are also reported by the Area Teams, Contract Administrators, and outside inspectors (State of Ohio, American Nuclear Insurers, and the Pre-Operational Inspection and Safety Evaluations (POISE Team).

The safety program will be reviewed with those con-tractors where violations were noted by December 31, 1982, under the direction of the General Supervising Engineer of the Nuclear Construction Administration Section.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Industrial Safety Objective No. PS-1 (title) Sheet 1 of 2

2. Provide factual information that supoorts the Performance Evaluation Summary Details in Support of Finding PS.1-1 A. An interview with the Site Safety Supervisor brought out

that he has been in his present' job for about six months.

i He also indicated that he had just lost some of his key people. He identified on individual responsible for safety and one for fire protection and prevention.

B. The scheduled safety walk through and survaillance with the Safety representative was postponed twice because he had to perform more pressing duties. He indicated to me that his safety surveillance suffers when other things come up, like requested follow-ups on hazardous conditions identified by craft personnel.

C. Interview with the fire protection representati've indicated that he also checks for safety violations in his walkdowns for fire prevention and extinguisher location checks.

D. It was stated that lack of manpower limits visual checks of the permanent fire protection systems. To compensate for this lack of manpower, Plant maintenance personnel assigned for maintenance are doing fire hydtant and PIV valve checks.

[ It could not be shown that instruction in this task had been provided to enable the maintenance personnel to do a complete job.

E. Other responsibilities of the Safety representative include air sample checks on request, accident investigations, fire investigations, and responding to ambulance calls which leave little time for accident prevention surveillance.

Details in Support of Finding PS.1-2 .

The following safety violations were observed by team members at various locations in the construction area:

A. Electrical panels 1R42-5033CEF (120 volts) were energized

. and had no covers. These were located in the Turbine Complex El. 624'~, Col. TB-81, with no personnel working on the panels.

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PERFORMANCE EVALUATION DETAILS Construction Project j l'

Perry Plant

1. Performance Area: Tndustrial safetv Objective No. ps-1 (title) ~ Sheet 2 of 2

2. Provide factual information that supeorts the Performance Evaluation Summarv _

B. At the 620' elevation west of the Diesel Generator Building, an excavation for a pipe had been dug. The opening is approximately 5' deep by 30' long. A 2x10 plank has been placed across the excavation to cross from one side to the other.

C. On October 6, in the Emergency Service Water Pumphouse, at elevation 537', access hatches to lower areas have been removed to allow the diver access. These openings were not covered nor barricaded.

D. Electrical panel 1H51-P236 (120 volts) was energized and cover was not on. This was located in the Control Complex at El. 638' with no personnel working on the panels.

E. Several team members observed workmen not weari'ng hard hats in the construction area.

F. On three separate occasions in a walkthrough with the Site Safety Representative, grinding operations were observed that did not have grinding shields. The safety representa-tive suggested to workmen that they get them before proceeding.

Evidence of Scope Not Associated with Specific Findings

(

The fire protection response team and the medical response team who man the fire truck and the ambulance are members of the Security Force who are trained in both fire fighting and medical first aid. An inspection of the fire truck and the ambulance indicated that they were well equipped and adequately maintained.

A review with the Safety Supervisor indicated that good cooperation exists with the local fire chiefs and adequate off-site support will be available, if needed.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant h

I Performance Area Proieet Plannino

• Objective No. PS-2 Evaluator (s) H. R. Porter I. Performance Obiective l, Project plans.should ensure completion of the project to the highest industry standards by indentifying, interrelating, and sequencing the tasks of the project organizations.

II. Scoce of Evaluation ,

All members of the evaluation team were involved in discussions with personnel relative to project plans. A composite of the information obtained forms the basis for this evaluation.

Approximately 25 manhours were expended on this evaluation.

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l III. Conclusion The necessary elements, systems, and experienced personnel l are in place to ensure that the Project plans will result in the completion of the Project to the highest industry standards. The Project is now making a transition from construction to start-up. Planning documents

, being modified reflect the changing emphasis. Techniques being used for plan development / updating show unique good practices. A fully updated plan is.to be implemented within the next few months. Transition documents cur-rently being used are not always effective in some areas, while excellent

. use is realized in others. Weaknesses resulting from thi.s transition 8

should be corrected and a revised plan issued to the entire Project,  !

with proper indoctrination, as soon as possible. j l

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PERFORMANCE 2 VALUATION

SUMMARY

Construction Project Perry Plant Performance Area Project Plenning Objective No. PS-2 Evaluator (s) H. R. Porter IV. Areas of weakness and corrective action; Good Practices Finding Some planning weaknesses were noted in the (PS.2-1) Project transition documents. Currently a transition document labeled "The Top Ten" is being used to establish system priorities.

This document is not being used in a consistent manner throughout the Project. Also, planning

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for and sequencing of tasks are not always compatible with existing conditions.

Corrective The " Top Ten" is a manual extraction from the Action existing Project Schedule. To ensure consistent (PS.2-1) utilization and understanding of the " Top Ten" and other existing schedule documents, a formal Train-ing Program will be initiated within Nuclear Con-ctruction Administration, Nuclear Construction Engineering, and Nuclear Test Section's. The necessary indoctrination and training will be completed by the three responsible Section's -

General Supervising Engineers by December 1, 1982.

A description of the program and resulting action will be. documented in each Section's Performance

' Analysis Report (PAR) for December, 1982.

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PERFORMANCE EVALUATION DETAILS Construction Project ,

I

• Perry Plant 4

1. Performance Areas Project Planning Objective No. PS-2 (title)

2. Provide factual information that supeorts the Performance Evaluation Summarv _

i A. Details in Support of Finding PS.2-1 In interviews with Project personnel by several members of the evaluation team, it was learned that several types of schedules were being used in planning and conducting assign-ments. In most instances the schedules were tied to a priority system, or Level IV; but not all were in agreement.

Attention was called to certain test schedules not interfacing with construction schedule.

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PERFORMA.CE N EVALUATION SU}e1ARY Construction Project Perry Plant Performance Area Project Control Objective No. PS-3 Evaluator (s) o, p, 7;;g;;

I. ' Performance Obiective .

Project scheduling and work planning and coordination should ensure that the objectives of the project plan are met through effective and efficient use of project resources.

II. Scope of Evaluation The evaluation in the project control area included the review of reports and control documents, and interviews with personnel responsible for the development, implementation, and assessment of their adequacy.

Approximately 30 manhours were expended on'this evaluation.

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III. Ccnclusion Effective and efficient' use of project resources is being realized. A continuing dedicated effort to further improve current performance has been generally noted in contacts with management and super-visory personnel. A planning and scheduling system to address the transi-tion from construction to start-up has been developed that is an apparent significant improvement over past systems. The participation of management j from all major contributors to the project efforts in its development, implementation and use should result in better coordination of efforts and :

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overall improved performance. It was noted that the systems schedules weret

'not available and in use in.some areas, and lack of understanding of Top 10' l ' and Level IV schedules exists with some personnel. j l

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PEPJORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Proiect Control Objective No. PS-3 Evaluator (s) H. R. Porter IV' . Areas of weakness and corrective action: Good Practices ,

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Finding Complete and comprehensive system scheduling (PS.3-1) information is not yet available to all project personnel. In certain instances, full and effective use of what is available is not being realized due to continuing use of interim schedules and some that have been personalized.

~~ Lack of firm and clear communication of the system scheduling plan and its intended and mandatory use has been noted in some contacts.

Corrective The existing distribution of the Project Schedule Action or portions thereof is based on established (PS.3-1) matrices. These existing matrices will be' reviewed by the responsible Section's General Supervisor to assure adequate dissemination of schedule infor-mation in their respective areas. T, hey will initiate any required changes by December 1, 1982.

See response to Finding PS.2-1 for address of the necessary indoctrination and training for effected personnel on utilization and understanding of schedule information.

Finding The following good practice was noted:

(PS.3-2)

An " Operational Review Program" has been instituted by the Owner to review the administration of all Construction Contracts. These reviews cover the areas of Contract Administration, Purchasing and Accounts Payable related to the specific contracts.

The frequency of the reviews is related to the size of the contract.

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9 PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

l. Performance Area: Project Control Objective No. PS-3 (title)

2. Provide factual information that succorts the Performance Evaluation ,

Summarv _

A. Details in Support of Finding PS.3-1 In discussions with planning and scheduling personnel, the intent to use Level IV schedules as a working-management tool was stated. This was verified by other project managers that indicated their support. In interviews with some supervisors and their subordinate personnel, a range of schedule types were found to be in use, including Level IV's. Additionally, comments were expressed by some j individuals that indicated they were not fully aware of the Level IV schedules being used in part and the intent to use them exclusively when they are completed, and

others thought of them as a punch list. Communication

of the details of the Level IV schedules and the intent for their use appears to be lacking.'

B. Details in Support of Good Practice Finding PS.3-2 A review was made of the construction contract audits per-formed by the Project and it was found that an " Operational Review Program" has been established. All construction con-tracts are reviewed in the areas of Contract Administration, l .,

Purchasing and Accounts Payable on the following basis:

1. All contracts at least once (while active).

2. Contracts over $20,000,000 are performed on an annual basis.

3. Any contract per special management request.

4. Upon special request of a Buyer or Contract Administrator, a review is done 3 months prior to completion of a contract.

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SUMMARY

Construction Project Perry Plant Performance Area Proiect Procurement Process Objective No. ps-4 Evaluator (s) R. Demchak

'I. Performance Obiective The project procurement process should ensure that equipment, materials, and services furnished by suppliers or contractors meet project requirements.

II. Scoce of Evaluation The evaluation of this area was limited to the Construction Buying Section and involved discussions and interviews with working level personnel and supervision, and filer and records review with the responsible clerks.

Included were reviews of correspondence files, insurance files, Qualified Bidders' List, buyer trhining, equipment expediting, contract scope changes and claims resolution. Not included were the technical specification and vendor QA and source inspection activities handled by NSSS Contractor and the A/E.

Approximately 35 manhours were expended in this evaluation.

1 III. Conclusion l There is good control of activities evaluated under this l performance objective. The weaknesses identified should be strengthened, but are not considered of a substantial nature.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Project Procurement Process Objective No. PS-4 Evaluator (s) R. Demchak IV. Areas of weakness and corrective action; Good Practices Finding No management controls exist and no written (PS.4-1) criteria exist to categorize a Perry Construction Work Authorization (PCWA) as per the following:

a. QA Urgent

b. Schedule Urgent (i.e. Work Before Price)

c. Price Before Work

d. No Cost / Transmittal Of special concern are the definitions of Schedule Urgent and Price Before Work, as they impact cost control.

Corrective Procedure 3-0350 will be revised to provide defini-Action tions and criteria for QA Urgent, Schedule Urgent, (PS.4-1) Price Before Work and No Cost / Transmittal. This revision will be mutually prepared by Nuclear Con-struction Engineering and the Construction Buying Sections under the responsibility of the General Supervising Engineer, Nuclear Construction Engi-neering Section. The target date for completing this revision is February 1, 1983.

No backfit considerations are applicable.

Finding There is no automatic follow-up procedure to (PS.4-2) remind a contractor when his response to a Perry Construction Work Authorization (PCWA) is overdue.

- Timely follow-up of contract changes is consistent with good contract cost control.

l Corrective A modification to the present computer program is Action in progress to provide a printout of overdue PCWA's (PS.4-2) by specification number. The General Supervisor

' of the Construction Buying Section will take the necessary steps to initiate action within the l

Buying Section for expediting contractor response I to PCWA's. The revised expediting practices will be in place by January 31, 1983.

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PERFORMANCE EVALUATION DETAILS Construction Project d Perry Plant i 1 1. Performance Area: Proiect Procurement Process Objective No. PS-4 (title) Sheet 1 of 2

2. Provide factual information that supports the Performance Evaluation Summary -

i (a) Details In Support of Finding PS.4-1:

The Perry. Construction Work Authorization (PCWA) is the form used to transmit to the contractor changes and specific change documents affecting the existing construction con-tract. The PCWA is initiated by the Nuclear Engineering Department (NED) who categorize the PCWA as QA Urgent, Schedule Urgent (i.e. , work before price), Price Before Work, or No Cost Transmittal. No criteria for making this categorization are included in the applicable procedures.

Three construction buyers and two responsible engineers interviewed were not aware of such criteria being documented anywhere.

(b) Details In Support of Finding PS.4-2: .

When new PCWA's are received in Purchasing, they are recorded, '

logged into* tie computer, assigned a bid due date and mailed to the contractor. The bid due dates are defined as follows:

30 days - Price Before Work PCWA's 7 days - Work Before Price PCWA's j

A review of overdue PCWA's with the Purchasing General Supervisor has revealed:

4 (1) The general supervisor confirms that no automatic

. system exists reminding contractors that their PCWA response is overdue.

'(2) Currently, a monthly computer printout indicates to the Buyer when a PCWA response is late.

(3) The general supervisor has previously recognized the need for an automatic reminder system and that future development of the PCWA control program should include that feature.

PERFORMANCE EVALUATION DETAILS Construction Project e Perry Plant i

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1. Performance Area Proiect Procurement Process Objective No. PS-4 (title) Sheet 2 of 2

2. Provide factual information that succorts the Performance Evaluation Summarv .

(c) Evidence of Scope Not Associated with Specific Findings:

(1) The following activities were reviewed and no signifi-cant events / findings were discovered. These activities can be considered satisfactory.

Contract files and maintenance Insurance files and maintenance Qualified Bidders' List / files and maintenance PCWA indexing and computer printout Expediting (equipment) area Buyer Training (2) Discussed the contract changes activity (PCWA) with the

, General Supervisor of Construction Buying and can -

report the fc .;owing facts:

The number of PCWA's " received" is steadily increasing with the current monthly level at 650 to 700.

The PCWA backlog has steadily decreased from a peak number of 3700 in March, 1980 to 1600 in August, 1982.

(3) Discussed the contract claims activity with the General Supervisor of Construction Buying and can report the following facts:

- The 12-month trailing average of'" claims received",

as measured in dollars, has been a steady l

$10,000,000 per month since early 1981.

- The total number of "pending" claims has been

. steadily decreasing from 94 in April, 1981 to 24 in September, 1982.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

. Perry Plant Performance Area . Contract Administration Objective No. PS-5 Evaluator (s) R. J. Demchak I. Perfobmance Objective Methods for administering and controlling contractors and suppliers and for managing changes to their contracts should ensure effective control of performance.

II. Scoce of Evaluation The scope of this evaluation was limited to interviews with lead contract administrators, a walkthrough of a contractor's on-site office facilities, an inspection of a contractor's records vault, and a review of contract administration files.

Approximately 20 manhours were expended on.this evaluation.

i Op

(

III. Conclusion The activities evaluated under this performance objective are

- considered to be good. Some weaknesses were observed which appear to be isolated cases and do not suggest problems of a generic nature. These weaknesses, however, should be addressed l

and strengthened.

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- PERFORMANCE EVALUATION

SUMMARY

Construction Project l Perry Plant Performance Area Contract Administration Objective No. PS-5 Evaluator (s) R. J. Demchak IV., Areas of weakness and corrective action; Good Practices FINDING Contract Administration is not verifying time (PS.5-1) sheets for work performed in the Control Room on SP-33/34 in a complete manner consistent with Contract Administration guidelines. They are, however, approving and signing the time sheets, thereby delegating the responsibility that they are correct, factual and represent the actual work done to the System Test Engineer. This delegation of responsibility is not documented in any manner.

Corrective Contract Administration Procedure 5-0701 will be Action revised to reflect the Nuclear Test Section Control Room System Test Engineer's responsibility for directing the Contractor and verifying manhours expended on that work. The Program Revision Notice (PRN) to 5-0701 will be written by December 1, 1982, by the Nuclear Cons'truction Administration Section General Supervisor.

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l PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Contract Administration Objective No. PS-5 (title) Sheet 1 of 2

2. Provide factual information that suceerts the Performance Evaluation Summarv _

A. Details in Support of Finding PS.5-1:

1. The activity in the Control Room appears to have developed into a special case regarding administration of the work. The System Test Engineer seems to be assuming some of Contract Administration's responsi-bilities by directing the contractor and by verifying the work done, without the proper authority.

2. In an interview with a lead contract administrator, daily time sheets from the electrical contractor who is working in the Control Room on SP-33/34 were reviewed.

3. In this area of work only (Control Room), the Lead Contract Administrator (LCA) does not perform a normal review of the time sheets, but casually observes if anything on that time sheet appears unusual (i.e.,

extremely excessive hours, description of work out of contractor's responsibilities). If no highly unusual entry exists, he signs the time sheets.

B. Evidence of Scope Not Associated with Specific Findings:

1. A Contract Administration log book was reviewed (SP-33/34) and it was observed that some of the entries did not appear to conrorm with criteria established in Procedure S1-0503. Specifically, the entries observed did not address the areas of work, the contractor progress, the number of men working and what equipment and material may have been used. The Correspondence Log Sheet appeared to have some deficiencies in the recording of dates. CONCERN - AN ACTION REQUEST WAS ISSUED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Contract Administration Objective No. PS-5 (title) Sheet 2 of 2

2. Provide factual information that succorts the Performance Evaluation Summarv _

2. A weekly contractor meeting was observed. This meeting was attended by the contractor, Quality Assurance, Engineering and Contract Administration. This meeting was informal and loosely structured, but good information was exchanged and current problems seemed to be getting prompt and positive attention.

3. The following activities were reviewed and can be considered satisfactory:

- Procedural Knowledge

- Company Interface Relationships

- Contractor Interface Relationship

- PCWA and EW Processing and Knowledge

- Claims Training l

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PERFOPP.ANCE EVALUATICN

SUMMARY

Construction Project

- Perry Plant Performance Area Documentation Manacement Objective No. PS-6 Evaluator (s) , , ,___w,.,

I. Performance Obiective The management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /information requirements of the plant's operational phase.

II. Sccce of Ev0luation The evaluation of this area was limited to discussions and interviews with supervisors and senior personnel involved with the identifi-cation, collection, review and processing of records. Also, the facilities used in the processing and storage of records were inspected.

Approximately 40 manhours were expended in this evaluation. ,

III. Conclusion The activities evaluated under this performance objective can be rated conditionally satisfactory based on the plans currently underway to expand and strengthen the system. A concern is noted on the subject of "As-Built Drawings". .

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PERFORMANCE EVALUATION

SUMMARY

Construction Project e Perry Plant Performance Area Documentation Management Objective No. PS-6

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avaluator(s)

IV. Areas of weakness and corrective action: Good Practices Finding The existing document management and control (PS.6-1) system does not appear to have the capacity to meet the volume of work expected prior to the scheduled fuel load of November, 1983.

Corrective The Project has recognized the large volume of Action documents that must be put into the System in the (PS.6-1) time indicated. A response to this need is already underway. Development of sufficient document l management and control capacity to meet the volume of work will be accomplished by:

a. A Special Project Plan is being developed to better organize and prioritize required record identification, review and turn-over. The plan will be developed by the Records Management Unit by November 15, 1982.

b. Additional staff, including consultants, are being added to the Records Management Unit with planned additions to be in place by November 15, 1982.

c. Controls to monitor the quantities and to qualify the records are being refined.

Improved record tracking controls will be developed by the Administrative and Special Projects Supervisor by Novem-ber 15, 1982.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Documentation Management Objective No. PS-6 (tatle) Sheet 1 of a

2. Provide factual information that succorts the Performance Evaluation Summary Details in Support of Finding PS.6-1 a) Interviews were conducted with the Records Management Super-

. visor, the Records Control Supervisor, the Construction Analyst in charge of the Quality Records Vault (QRV), the Program and Records Supervisor, the Senior Staff Engineer responsible for Enginsering Records and the AE As-Built Drawing Coordinator. These discussions indicated the pro-ject is in the process of expanding their document manage-ment system which will be needed shortly based on the following observations:

, 1) An accepted industry standard for the total quantity of records expected for a single unit and common is 25,000,000 documents. Presently, 2,000,000 documents have been received by the Project. 1,000;000 have been reviewed and processed and 1,000,000 awaiting review.

2) The ANSI Standard that must be met for, licensing is N45.2.9, paragraph 6.2. This paragraph addresses

" Accessibility" and states: " Storage systems shall provide for the accurate retrieval of information without undue delay".

3) The svaluation recognizes that not all 25,000,000 docoments wil; be necessary to meet licensing criteria, however, two basic facts remain:

1) Which records and how many records will be required for licensing is as of yet unidentified.

i l ii) All records will have to be addressed and indexed l in some manner to comply with the redrievability

' criteria or to be available for future processing.

4) The first step towards meeting the records criteria is collection. Presently, the QRV, the collection point of document packages, is not procedurally included in the transfer plan,s of document packages from the contractors. Also, some contracts / specifications indicate that the turnover of documents should occur at contract completion rather than in a more timely fashion to support system turnover and testing.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant i

1

'1. Performance Area: Documentation Management Objective No. PS-6  !

(title) Sheet 2 or a

2. Provide factual information that succorts the Performance Evaluation Summary

5) Although the QRV is the collection point for all document packages, their physical space limitation is about their present capacity which is 1,000,000 documents and their capability for performing the clerical review has been estimated at 200,000 documents / month. In September, 1982, the QRV processed 70,000 documents.

6) The quality and technical review is the next process toward document acceptance and the volume of records anticipated should severely test the reviewing elements.

The present capability of "as-built" drawing reviews has evidenced that of approximately 20,000 drawings submitted, only about 3,000 are approved. It is estimated that a total of 100,000 contractor drawings and 10,000 Nuclear Test Section drawings would have to be processed by Unit #1 fuel load. When the AE as-built drawing coordinator was asked as to how he would accomplish this volume of work. he said he didn't know. Further, a new Project Administration Procedure, 1705, requires that non-quality related cons'truction packages will be reviewed by the responsible engineers. These packages will be collected and stored by the Quality Assurance Group until the engineering review is completed.

7) Finally, the processing of document packages by the Records Control must be done. The present capacity of the Records Control element for microfilming and index-ing is 140,000 documents / month. At a level of 200,000 documents / month, additional processing equipment would be necessary.

Project Management has recognized the need to streng.then the document management program as evidenced by the recent creation of a Record Management Unit, by some organizational changes and procedural reviews within the document review areas, and by

agreeing to utilize a consultant experienced in record management.

These steps appear to be in a positive direction as the scheduled fuel load date of November 1983 will impose significant additional pressures upon the existing document management system.

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PERFORMANCE T7ALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Docunantation Manacement Objective No. PS-6 (title) Sheet 3 of 3

2. Provide factual information that succorts the Performance Evaluation Summary A. Evidence of Scope Not Associated with Specific Findings:

The subject of "as-built drawings" appecn to be an issue of significant concern in various areas cr she project. Although this is not a finding at this time because of the status of the project, it has the potential to become a major project problem. Some items of concern which surfaced in the review of other areas are as follows:

1. Current contracts do not require the contractors to submit as-built drawings in a timely manner.

f

2. A Project Administration Procedure for as-built drawings l is being prepared, but no schedule exists for its com- 4 pletion or of the various sub-tier procedures which then

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must be prepared.

3. The procedure under development and review requires a computer program to be in place for status and tracking.

Although the program is being developed, it has no l

l scheduled completion date.

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- 4. The scope of work for "as-built drawing" review that is part of the records management program may be larger than the current capacity, but no schedule of document package reviews, based on system schedule needs, is available to confirm this.

5. The subject of "As-Built drawings" is one that impac'ts all elements of the Project Organization, but no one i

element seems to be in charge of making sure the work is completed in time to support the project needs.

l CONCERN - ACTION REQUESTS WERE ISSUED BY THE PROJECT FOR RESOLUTION AND FOLLOW-UP OF ITEMS 1 THROUGH 5.

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PERFOILMANCE EVALUATION

SUMMARY

Construction Project l l

Perry Plant i Performance Area Trainine Manacement succort Objective No. TN-1 Evaluator (s) o a crhunegar I. Performance Obiective Management should ensure that an effective program exists for indoctri-nation, training, and qualification of personnel involved in the project.

II. Scoce of Evaluation This objective was evaluated by observing the existence of requirements for indoctrination training and qualification, and existence of the actual programs. Interviews at the vice president and manager level were also employed.

Approximately 5 manhours were devoted to this evaluation area. .

I III. Conclusien

[ Strong Management support of training does exist.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Training Management Support Objective No. TN-1 Evaluator (s) R. G. Schuerger IV. Areas of weakness and corrective action: Good Practices None.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Training Management Support Objective No. TN-1 (title)

2. Provide factual information that supeorts the Performance Evaluation Summarv _

Evidence of Scope Not Associated with Specific Findings:

l

a. The Perry. Plant Department, recognizing the need for the

training of licensed and non-licensed operators and other plant personnel, has had comprehensive training programs for some time.

b. The need for a unified comprehensive training program for the Project Organization (non-plant) has been recognized with the recent establishment of the Nuclear Project Training Section.

c. Under construction is a new building which will include a Training Center with a simulator, classrooms and training laboratories adequate for future needs. .

d. Interviews with the Vice President-System Engineering and

, Construction, the Vite' President-Administrative Services, and the Manager-Perry Project Services Department confirmed their commitment to and support of the Perry Project training programs.

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PERFORMANCE EVALUATION St.',W1ARY Construction Project Perry Plant Training Organizatien Performan.:e Area and Administ r h _ Objective No. m Evaluator (s) R. G. Schuerger I. Performance Obiective The training' organization and a_2:aistration should ensure effective control and implementation of training activities.

II. Score of Evaluation This area was evaluated by interviewing the General Supervisor, Nuclear Project Training Section and the Training Supervisor, Perry Plant . Department.

Approximately 10 manhours were devoted to this evaluation area.

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III. Cenclusion Two clearly identified training organizations exist, one for all l' plant employees, and one for all Project Organization employees.

The former is in an advanced state of development and should I achieve required fuel-load objectives. The Project Organization

! program is in an early stage of development, but is showing favorable progress. The two organizations will be merged by fuel-load. Previously the Project Organization training was the  !

responsibility of the individua.1 sections without an overall l coordination effort.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant

- IralnAng vrgaalenciva and Performance Area Administration Objective No. TN-2 Evaluator (s) R. G. Schuerger IV. Areas of weakness and corrective action: Good Practices None.

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l PERFORMANCT'" EVALUATION DETAILS Construction Project Perry Plant Training Organization and

1. Performance Area: Aamininerneinn Objective No. TM-2 (title)

2. Provide factual information that suoports the Performance Evaluation Summarv A. Evidence of Scope Not Associated with Specific Findings:

1. The following subjects were discussed with the Perry Plant Department's training supervisor: scope of the PPD training program under his directions, the status of his training plan, the structure of the plan, present and future staffing needs, method of evaluation of training effectiveness, and other feedback mechanisms.

This aspect of training, which covers licensed and non-licensed operators and other plant personnel, seemed to be under control, although project fuel load requirements impose a substantial workload for the next year.

2. The General Supervisor, Nuclear Project T aining Section was interviewed as to his activities in the development and implementation of a project-wide training program.

The program is still in the process of development, but documents were reviewed that indicated substantial progress including:

the organization chart for the Training Sec. tion

- a complete set of Responsibility Guides and Quali-fication sheets for the Training Section staff a description of proposed mission, goals, objec-tives and current activities a training needs questionnaire

- a report on position description development

- the current issue of the monthly training schedule

a. While implementation of this training. program for .

Project Organization (construction, engineering, and quality assurance personnel) 1s in an early stage of development, program development pr6gress to date indicates that the outlook is positive.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area General Trainine and Qualification Objective No. TN-3 R. G. Schuerger, B. Grier, F. Jankowski, W. Tokarcik Evaluator (s)

I. Performance Obiective The training. program should ensure that all employees receive indoctrination and training required to perform effectively, and that employees are qualified as appropriate to their assigned responsibilities.

II. Scoce of Evaluation This area was investigated by looking for the existence of proce-dures and compliance with procedures, looking for the existence of training programs, and by interviewing individuals as to the

. extent of their knowledge.

Approximately 25 manhours were devoted to this evaluation area.

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l III. Conclusien .

While a comprehensive training plan is being developed for the Project Organization, cara must be taken to assure that employees l F l receive essential training in the interim, especially in the area of procedures. The knowledge of procedures was found to be generally satisfactory in the Project Organization, although some

! areas of weakness were observed. At least one contractor needs to formalize his training of craft personnel. Verification of l employment and educational backgrounds is not done on a consistent  !

, basis.

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PERFORMANCE EVALUATION

SUMMARY

Construction Projcct Perry Plant General Training and Qualification ObjecggggNg.g T -3 Porformance Area

• R. G. Schuerger, B. Grier, F. Jankowski, W. Tokarcik Evaluator (s)

IV. Areas of weakness and corrective action; Good Practices Finding The major piping contractor does not have a (TN.3-1) written training program for craft personnel.

Corrective' Although this contractor's program did not formally Action address training, the following training was being (TN-3-1) implemented. Each worker's employer is responsible for ensuring that the individual is properly trained and qualified to perform his assigned work.

Prior to joining the Project, all craft personnel receive apprenticeship training for theirTraining discipline areas through their union affiliations.

and qualification is based on discipline areas j

and revolves around work procedures applicable to a given area. For most disciplines other than quality assurance and welding, there are no formal industry training certification standards. Craft supervisors are responsible in the first instance for assuring that workers are properly trained and l qualified in the procedures goverring their work.

In addition, the QA/QC program reviews and verifies the adequacy of worker performance through physical inspection of both work in progress and resulting installation.

1 In the welding area, workers are qualified by employers in accordance with American Welding Society

'( AWS ) Section D1.1 or American Society of Mechanical Engineers (ASME)Section IX code requirements.

Quality control inspectors are governed by the American National Standards Institute (ANSI) N45.2 standards and American Society of Nondestructive Testing (ASNT) SNT-TC-1A standard and ANSI N45.2.6 (1973) governs qualification, trainingIn and certifi-addition, cation of quality control inspectors.

the contractor has had extensive supplemental train-ing to address specific areas for emphasis. The contractor's QA program will be revised to formally recognize the training program in place by Decem-

' ber 31, 1982.

Finding The procedure for checking out employment and (TN.3-2) educational backgrounds for new hires varies across the range of site employers.

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j PERFORMANCE EVALUATION

SUMMARY

Construction Project i

i

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• Perry Plant Performance Area General Trainino and Oualification Objective No. TN-3

. . Sheet 2 of 2 -

Evaluator (s) R. G. Schuercer. B. Grier. F. Jankowski, W. Tokareik IV. Areas of weakness and corrective action: Good Practices Corrective The responsible Construction Quality Engineers

. Action have been requested to evaluate their respective (TN.3-2) contractors' procedures for checking out previous employment and educational backgrounds for new hires into engineering, testing and quality assurance / quality control positions. If defi-I ciencies are identified in a contractor's hiring procadure, resolution will be made on a case-by-case basis, including verification of currently employed personnel if not previously accomplished.

The General Supervisor, Construction Quality Section will assure that the appropriate evaluation is performed for each contractor responsible for safety-related work.

An evaluation of hiring procedures us'ed by consul-tants employed by the Project Organization will be accomplished under the direction of the General Supervisor, Nuclear Project Training Section.

Hiring practices for consultant personnel in engi-l neering; testing and quality assurance / quality control positions will be evaluated to assure consistency and meet the Owner's requirements, including verification of previous employment and educational backgrounds for currently employed personnel if necessary. ,

. The evaluation of contractor and consultant hiring practices and resolution of any deficiences will be completed by December 31, 1982.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant General Training and -

1. Performance Area: Ou'alification Objective No. TN-3 (title) (Sheet 1 of 3)

2. Provide factual information that supoorts the Performance Evaluation Summary A. Details in Support of Finding (TN.3-1):

Quality specification 709 requires a written quality program which includes the indoctrination and training of personnel performing activities affecting quality. The trainer for the major piping contractor stated that the only training new craft personnel receive is a one-hour video tape program on 10CFR50, Appendix B, except for the production welders who after passing their certification receive more training.

Safety and housekeeping are covered in weekly " tailgate" safety meetings which may not have a written agenda: The trainer trains lower tier supervisors who in turn are supposed to train about 500 craft personnel in addition to the one-hour video tape. He is unsure whether his supervision training reaches the craft level. Subsequent training is on an irregular basis and may not include formal instruction.

Site QA and NRC findings are not transmitted to the trainer so that he can create training to inform the workers.

B. Details in Support of Finding (TN.3-2):

(1) The electrical contractor has a written corporate procedure which allows only clerical, drafting and conduit detailers to be site hired. Conduit detailer employment record is phone checked back to the previous job. All QC/QA personnel are hired out of the main office and employment and education confirmation is made there.

(2) The major piping contractor has no written corporate or site procedures on verification of education or employ-ment for QC/QA. Verification might be made by telephone but not consistently.

(3) The instrumentation and control installation contractor has a written' corporate procedure that requires QC/QA site hires to have the last employer contacted and

, college degrees verified for senior designers; the last employer must be checked, but not necessarily the educational record. Checking tor junior designers is erratic.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

,. General Training and

1. Performance Area: nualification Objective No. TN-3 (title) (Sheet 2 of 3) 3

2. Provide factual information that suooorts the Performance Evaluation Summary , _

l (4) The HVAC contractor has no written corporate or site procedure for verification. QA/QC site hires have job

^ references checked back to the last job. School and educational background is not checked. QA/QC hires must have approval of home office QA Manager. The extent of checking is not known.

i (5) The construction management consultant has no written corporate or site procedure. The practice is that all clerks are checksd for the past five years and all education is verified. Above the clerical level all information is verified to the full extent in writing.

(6) The owners' procedure is presently being reviewed for the verification of application information when a person is hired. No other procedure exist's.

As a rule

! all applicants are 100% checked on experience and education.

C. Evidence of Scope Not Associated with Specific Findings:

(1) The Nuclear Construction Administration Section has an up-to-date continuing employee training program, which covers general skills, specific skills, and off-site training assignments.

(2) The Manager, Nuclear Engineering Department has initiated action to bring the qualifications and training of his l

people up-to-date_ in the interim period while the I overall project training program is being developed.

I During interviews with an individual engineer (4 months experience), he did not have complete comprehension of procedures he had recently signed off as having read.

CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT l

FOR SESPONSE AND FOLLOW-UP.

(3) The Mechanical / Piping unit of the Construction Quality Section holds sessions every Friday for the training of Unit personnel on procedure changes. Field Variance Authorizations (FVA's) and Engineering Change Notices (ECN's). Records of attendance at these training sessions are maintained.

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PERFORMANCE EVALUATION DETAILS Construction Project L

Perry Plant

^

General Training and

1. Performance Area: n,,,34,4-o4nn

~ ~

Ob],ective No. TN-3 (title) (Sheet 3 of 3)

2. Provide factual information that succorts the Performance Evaluation Summary ,

(4) Instrumentation contractor welders were interviewed and were found to be familiar with welding procedure require-

. ments. This implies effective training. During the performance of a PT by the contractor, a trainer was assisting the Level II Technician.

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l PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Training Facilities, Equipment Performance Area and Material Objective No. TN-4 Evaluator (s) R. G. Schuerger I.' Performance Obiective The training . facilities, equipment, and material should support and enhance training activities.

II. Scoce of Evaluation Information on existing conditions was gathered in the process of investigating other objectives. The capabilities of the new Training Center were reviewed with the General Supervisor of Nuclear Project Training Section.

Approximately 4 manhours were devoted to this evaluation area.

I III.. . Conclusion Based on a very limited sample, some facilities problems exist at j this time. However, completion of the Training Center now under construction should relieve this condition for the Project I Organization. One contractor was found to have less than ideal

! training space, but the extent of this condition is not known.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant IraAnAny revAAAuAus, Equipmous Performance Area and Material Objective No. TN-4

~

Evaluator (s) R. G. Schuerger W. Areas of weakness and corrective action; Good Practices None.

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PERFORMAN G ALUATION DETAILS Construction Project Perry Plant Training Facilities, Equipment

1. Performance Area: and Material -Objective No. TM-4

, (tit?e)

2. Provide factual information that succorts the Performance Evaluation Summary A. Evidence of Scope Not Associated with Specific Findings:

1. On one occasion a training instructor reported that the conference room that he was using for a classroom did not'have enough tables to meet his needs. CONCERN -

AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

2. Upon entering the major piping contractor's Training Coordinator's office, it was noted that a new employee was reading procedures. In the same area four other persons were either conducting other business or socializing. When asked about this situation, the training coordinator stated that these individuals had just arrived and that he had no quiet facilities to allow new employees to complete their training assignments. CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

3. The new Training Center, which will be located in a building now under construction which will also house the Emergency Operating Facility, is scheduled for completion in 1983. The Center will have eight classrooms: an operator training simulator; I&C, health physics and other laboratories, and instructors' offices.

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PERFORMANCE EVALUATION SUsiARY Construction Project Perry Plant Performance Area Quality Programs Objective No. OP-1 Evaluator (s) R. G. Schuerger I. Performance Obiective The quality assurance program scope, content, and applicability should

be appropriate, defined clearly, and understood.

l l

II. Scope of Evaluation This evaluation concentrated on the interface between the quality assurance activities at the site and at the A/E's offices, and to a lesser degree on the contractor audit program and the con-struction inspection program.

Approximately 25 manhours were expended on'this evaluation.

III. Conclusien The division of responsibility and authority between the site l

l* and A/E's. offices is clearly documented, and clearly understood at the management level. Owner A/E and Construction Management Consultant employees are fully integrated in the site Nuclear QA Department, a contractor audit program is established, as is the  !

construction inspection program.

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PERFORMANCE EVALUATION' SDMMARY Construction Project Perry Plant Performance Area Quality Program Objective No. OP-1 Evaluator (s) R. G. Schuerger IV. Areas of weakness and corrective action; Good Practices None.

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PERFORMAN G ALUATION DETAILS Construction Project Perry Plant 4

1. Performance Area: Ouality Procram Objective No. 09-1 (title)

2. Provide factual information that succorts the Performance Evaluation Summarv _

A. Evidence of Scope not Associated with Specific Findings:

1. The quality program and the quality organizations were reviewed with the Manager-Nuclear Quality Assurance Department at the site and his key people, and with the A/E Vice President - Quality Assurance Division and his Perry Project Manager at A/E's offices. Particular attention was paid to the interfaces between the site and A/E office in both the program area and the organi-zational areas. The managers at each location displayed consistent understanding of these issues, which were also clearly identified in program and other management documents.

2. A contractor audit (#722) exit meeting was observed, and the three-phase pipe hanger program was discussed in detail and an inspection was observed.

3. Reports of several recent reviews of the Perry QA program were examined, including the NRC's Comprehensive Assessment Team (CAT) Report, quarterly QA Program Effectiveness Reports, and the comprehensive 1982 QA Program Evaluation conducted by the Nuclear QA Department.

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PERFORMANCE EVALUATION SUNiARY Construction Project Perry Plant Performance Area Program Implementation Objective No. QP-2 Evaluator (s) R. Schuerger, B. Grier, C. Daft' I. Performance Obiective Quality assurance and quality control functions should be performed in a manner t'o support and control the quality of the project activities.

II. Scoce of Evaluation Evaluations of compliance with this objective was carried out by interviewing quality program personnel at all levels of the organizations, by the examination of appropriate documents, and by the observation of audit and inspection activities.

Approximately 30 manhours were devoted to this evaluation area.

l III. Conclusion overall implementation of the quality program is satisfactory, g, although some weaknesses were identified.

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, PERFORMANCE. EVALUATION

SUMMARY

Construction Project

. Perry Plant Performance Area Program Implementation }

ObjecggggNg.;QP-2 Evaluator (s) R. Schuerger, B. Grier, C. Daft IV. Areas of weakness and corrective action; Good Practices Finding The Electrical Contractor does not meet their cur-(QP.2-1) rent commitment for Site QA staffing. Also, the absence of an on-site QA Manager seems to detract from the effectiveness of their QA Program.

Corrective The Project Organization and the Electrical Con-Action tractor have agreed that increased emphasis is (QP.2-1) needed in addressing Quality Assurance problems.

Construction Quality Section has monitored and will continue to monitor the performance of QA functions and their effectiveness through audits. These audits are scheduled on a monthly basis.

Currently the Electrical Contractor has one Quality Engineer on site performing QA functions. A second Quality Engineer has been hired and is com-mitted to report to the site on November 15, 1992.

The Contractor's QA function is managed and directed from Corporate Headquarters. The Owner will con-tinue to assess that the increased, staffing is adequate based on the above organizational arrange-ment.

Finding The Electrical Contractor's purchase order for (QP.2-2) supplier's materials (cable tray, fittings, etc.)

did not impose QA program requirements on the supplier.

Corrective This finding was previo'usly identified by Project Action Organization as a result of an audit by NCAD in (QP.2-2) May of 1982. Subsequently the Electrical Contractor has conducted and documented training classes on their QA/QC Procedure 4.4.1 " Procurement Document Review."

The Electrical Contractor's QC and Engineering have completed a review of all past Purchase Orders to assure that proper QA requirements were imposed

, on vendors via the procurement documents. This review has been completed with some concerns regarding lack of documentation. The Electrical Contractor has committed to resolve these concerns by December 15, 1982.

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i PERFORMANCE EVALUATION

SUMMARY

Construction Project I i

I I

Perry Plant s

Performance Area Program Implementation Objective No. QP-2 Evaluator (s) R. Schuerger, B. Grier, C. Daft IV. Areas of weakness and corrective action: Good Practices An AR has been issued as a result of the afore-mentioned audit. Due to the extensiveness of the review and corrective action, this AR remains open; however, the Electrical Contractor continues to work toward completion. The Owner's Construction Quality Section will verify the effectiveness of corrective and preventative actions at the time of close-out.

Finding The Project Internal Audit function is not always (QP.2-3) effective in achieving corrective action.

Corrective Further definition of an " Action Request" versus a Action " Concern" will be developed and included in revi-(QP.2-3) sions to procedures 1602, " Corrective Action,",and 1-1806, " Audits." A review of all Project Internal Audit reports from 1980 to the present will be per-formed to identify all concerns, and follow-up on all concerns will be accomplished on future audits to insure close-out of each concern. All future concerns identified will require responses, follow-up and close-out by Nuclear Quality Assur-ance Department. To assure consistent use of concerns and Action Requests by all auditors, the Audit Coordinator, Training / Administration Section will provide a review of all Project Internal Audit reports for consistency in identification of deficiencies. These actions will be implemented by December 1, 1982 under direction of the Audit Coordinator, Training / Administration Section.

Finding The following good practice was noted:

(QP.2-4)

A three-phase pipe hanger inspection program.is

! being used.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant l

1. Performance Areas Procram Implementation Objective No. QP-2 l (title) Sheet 1 of 2  !

I

2. Provide factual information that supports the Performance Evaluation i Summary l A. Details in Support of Finding QP.2-1 At the exit meeting for Contractor Audit #722 on October 6, 1982, it was observed that there was no Electrical Contractor QA manager present. Discussions with the Manager, NQAD; the Supervisor, Construction Quality Auditing; and General Supervisor, Construction Quality Section indicated the Contractor does not have a site QA manager assigned, and that the regional QA manager position is not filled. The corporate QA manager, who has been overseeing this function, was not at the exit meeting. There is a QC supervisor on Site. The QA function appears to be attended to by a single quality engineer. Contractor has committed to assign a second QE but has not yet done so. ,

B. Details in Support of Finding QP.2-2 A review of the purchase order issued by the electrical contractor to the supplier.for conduit, tray, fittings, etc., did not impose QA program requirements on the Supplier.

This is contrary to the requirements of ANSI N45.2.13. This finding was previously identified during an audit by NQAD in May 1982, but corrective action has not yet been accomplished.

C. Details in Support of Finding QP.2-3 Audit reports are transmitted from a lead auditor or the audit coordinator to responsible General Supervising Engineers.

Findings are listed as Action Requests (AR's) or items of concern. AR's require response, but items of concern do not. The differentiation between AR's and items of concern is not clear. The overview of the findings is by the Audit Coordinator. For example, audit # PIA 82-12, Audit of Control of Contractor Procedures, identified one item of concern which should have been an AR. Procedure 2-0504 does not specify qualifications for the procedure reviewer as required by ANSI N45.2.6 and SNT-TC-1A. Action to resolve this item

- of concern was not apparent.

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PERFORMANCE EVALUATION DETAILS Construction Prnject ,

l Perry Project

1. Performance Area: procram Tmn1,m ntation

~

Objective No. OP-2 (title) Sheet 2 of 2

2. Provide factual information that succorts the Performance Evaluation Summary D. Details in Support of Finding QP.2-4:

In mid-1982 in response to a cuggestion by an NRC Inspector, the Project adopted a three-phase pipe hanger inspection program based on the program used at the Clinton Project.

The three phases are: 1) verification of pipe and anchor location prior to the initiation of hanger installation;

2) inspection after completion of installations; and 3) a recheck for clearances, damage, etc., after hydro and just prior to turnover. This three-phase approach is judged by the Project to be cost-effective; higher inspection costs are expected to be outweighed by lower rework and delay penalties.

E. Evidence of Scope Not Associated with Specific Findings:

• Time limitations did not permit detailed investigation, but it is suggested that the relationship of the vendor inspec-tions and receiving inspections programs be reviewed by the Project to assure'that underlap does not exist. A receiving inspection was observed and the program was discussed with the Lead Inspector. CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFOR N CE EVALUATION SUIciARY Construction Project

- Perry Plant Performance Area Tndependent Assessments Objective No. OP-3 Evaluator (s) n_ c_ gch,,.vg,v I. Performance Obiective Management sh.ould provide an effective, independent asses; ment of project activities affecting the quality of the project.

II. Sccee cf Evaluation This area was evaluated by investigating the Quality Assurance Advisory Committee (QAAC) and its operation. This was done by attending a Committee meeting, by reviewing appropriate documents, including the QAAC Charter, the memorandum appointing the current members, a meeting agenda, and the minutes of recent meetings.

Discussions were also held with various people, including the Vice President, System Engineering and Construction; the Manager, Nuclear Quality Assurance Department; and two members of the Committee.

Approximately 10 manhours were devoted to evaluation of this area.

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l III. Cenclusion

! The Quality Assurance Advisory Committee Charter establishes an adequate basic program for providing review and evaluation of the Perry Quality Assurance Program. One discrepancy was noted with the Charter for the Committee.

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, PERFORMANCE EVALUATION

SUMMARY

Construction Project l Perry Plant l

Performance Area Independent Assessment Objective No. O~

Evaluator (s) R. G. Schuerger lIV. Areas of weakness and corrective action: Good Practices Finding The degree of independence of the Quality (QP.3-1) Assurance Advisory Committee is questioned, in view of its Charter and the QA Program document.

Corrective By November 15, 1982, the Nuclear Quality Assurance Action Department Manager will review the Corporate Nuclear

(QP.3-1) Quality Assurance Program 0200, Rev. 4, and the l Charter of the Quality Assurance Advisory Com-mittee.

The concern will be addressed either by changing the Charter and CNQAP 0200 to more closely describe the Committee's role or by restructuring the Com-mittee membership itself. This task will be com-pleted by November 30, 1982.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Independent Assessment Objective No. QP-3 (title)

2. Provide factual inftsrmation that supports the Performance Evaluation Summary A. Details in Support of Finding QP.3-l' The Corporate Nuclear Quality Assurance Program 0200, Revision 4, effective September 15, 1982, in Section 1.4, Management Assessment, characterizes the Quality Assurance Advisory l

Committee (QAAC) as an independent group, as does the QAAC l

Charter, dated June 3, 1982. The current QAAC membership of l seven is made up of: three Perry Project Managers, the 1 Manager of the Nuclear Quality Assurance Department, who l also chairs the Committee, one each QA executive from the l

A/E, one from the Construction Management Consultant, and an outside consultant.

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PERFORMANCE EVALUATICN SUmiARY Construction Project

,, Perry Plant Performance Area Corrective Actions Objective No. OP-4 Evaluator (s) C. Daft, B. Grier, R'. Schuerger I. Performance Obiective Conditions requiring corrections or improvements should be resolved in an effective and timely manner.

II. Scoce of Evaluation This evaluation was carried out by reviewing the Nonconformance Reports tracking system and its output reports, by observation of the Contractor audit process, and by a separate review of Contractor l records.

l

( Approximately 10 manhours were devoted to this evaluation area.

i III. Conclusion The program for corrective action is in place and operating but needs improvement in resolving items in a timely manner. Several examples of slow corrective action were noted and are reported as l l findings in Performance Areas previously reported.

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, PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Corrective Action Objective No. QP-4 Evaluator (s) C. Daft, B. Grier, R. Schuerger IV. Areas of weakness and corrective action; Good Practices Finding Follow-up is not always successful in achieving (QP.4-1) timely corrective actions.

Corrective Management continues to actively address the needs Action for assuring timely follow-up to corrective actions.

(QP.4-1) Earlier this year a number of management controls

" ~ ~ - were instituted for this purpose. The INPO evalua-tion occurred close enough to institution of the controls that the effects may not have been fully demonstrated.

Among the actions taken for improved response are:

a. Open Corrective Action Requests are now identified to management on a monthly basis for follow-up action.

b. The position of NR Coordinator was estab-lished to provide enhanced tracking, trending and follow-up of Nonconformance .

Reports.

c. The position of AR Coordinator was expanded to provide increased follow-up emphasis.

d. The reports generated by NR & AR Coordi-nators are reviewed by management to assure increased attention to problems.

A review of progress and evaluation of effective-ness of these program enhancements will be addressed as an agenda item of the Quality Assurance Advisory

___ Committee meetings during 1983.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Corrective Action Objective No. QP-4 (title)

2. Provide factual information that succorts the Performance Evaluation Summary Details to Support Finding QP.4-1 Several examples of nontimely corrective actions were noted and were reported as findings under other Evaluation Objectives.

References:

1. Finding The subject Findings were identified by an (QP.2-1 & audit by the Owner's QA Department in May 1982, QP.2-2) but corrective actions had not been completed at the time of the INPO evaluation.

2. Finding The procedures which have been in place for (CC.6-1) identifying, tracking and resolving nonconformances

. have not always been effective in achieving .

timely closeout of the nonconformances identified.

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PERFORMANCO EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Test Program Objective No. TC-1 Evaluator (s) w onuoll I. Performance Obiective The test program should verify the plant's full capability to operate as intended by testing the plant's systems functionally.

4 II. Scoce of Evaluation The evaluation involved approximately 35 manhours. This included interviews with Nuclear Test Section personnel, review of procedures

- - - and documentation, and observation of a Nuclear Test Section

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III. Conclusion The activities within the Test Program objective can be rated as good. There were no specific findings associated with this objective.

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PERFORbfANCE EVAZ.UATION

SUMMARY

Construction Project Perry Plant Performance Area Test Program Objective No. TC-1 Evaluator (s) W. Powell IV. Areas of weakness and corrective action; Good Practices None.

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• PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Test Program Objective No. TC-1 (title)

2. Provide factual information that supports the Performance Evaluation Summarv _

Evidence of Scope Not Associated with Specific Findings:

The evaluation involved discussions with Nuclear Test Section personnel, observation of a Test Procedure Review Committee meeting, and review of the following:

Chapter 14 FSAR

- Nuclear Test Section Procedures

- Test Specification for P64 System

- Test Procedures Master Deficiency List for P45 and P49 Systems No weaknesses in the test program were discovered; however, it should be noted that the test program is in the early stages and the majority of testing activity is associated with individual components. Therefore, no actual system testing activities were observed.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project

, Perry Plant Test Group Organization Performance Area and Staffing Objective No. TC-2 Evaluator (s) P. A. Solanics

.I. Performance Obiective The test group organi.ation and staffing should ensure effective implementation of the test program.

II. Scoce of Evaluation The Scope of Evaluation included interviews with testing personnel, review of organizational documents and observation of testing activities. The evaluation was centered at the Nuclear Test Section Lead Test Engineer level and below, and concentrated on the effective implementation of the test program. Approximately 35 manhours were expended on this ev,aluation.

I III. Conclusion The majority of activities evaluated under this performance objective were generally satisfactory. However, due to the changing nature and structure of the test organization, there are needs to strengthen the documentation of individual and functional responsibilities and to reinforce the procedural training program in order to insure effective implementation of the test  :

program. .

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, PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Test Group Organization & Staffing Objective N

• TC-2 Page 1 of 2 .

Evaluator (s) P. A. Solanics IV. Areas of weakness and corrective action; Good Practices Finding Responsibilities and authorities of key testing (TC.2-1) personnel are not always described in writing, resulting in indeterminate responsibility and authority within the Test Organization.

Corrective The Nuclear Test Section General Supervisor will Action develop a document defining the functional respon-(TC.2-1) sibilities for the Section and personnel. Along with this, the lower tier organization will also be identified. This document will be made available to all Section personnel by November 15, 1982.

Similarly, a review will be made by all Project Organization Supervisors to assure that the same functional organization and personnel responsi-bility information is available to their personnel.

The Project effort will be completed by December 15, 1982. These steps are considered as an interim measure prior to completion of the Project Organi-zation plan to develop complete position descriptions for the organization by April 30, 1983. (See Cor-rective Action OA.3-1)

Finding The Nuclear Test Section (NTS) organization charts

, (TC.2-2) do not accurately depict the NTS Organization and reporting structure below the Lead Test Engineer level. This causes confusion among organizations which interface with NTS and within the NTS Section itself.

Corrective The response to TC.2-1 will address TC.2-2 finding j Action as well.

(TC.2-2)

Finding The NTS Training Program should be reinforced to (TC.2-3) include System Team training. Lack of understanding on how to obtain and verify latest print revisions, interpretations of print details, and interaction with other Project elements were noted in several

, observations.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant erformance Area Pant Groue Oroanization & Staffino Objective No. TC-2 Page 2 of 2 -

i Evaluator (s) p. n_ gnlanien 3

I IV. Areas of weakness and corrective action; Good Practices

~

Corrective The System Responsibility Matrix identifying the Action overall interaction of members of the Project (TC.2-3) System Teams will be updated by the Nuclear Test Section (NTS) by December 15, 1982. A training program to present this functional operating plan for System Teams will be developed by NTS with support from Nuclear Project Training Section by January 15, 1983. Training for System Teams will be accomplished by February 15, 1983.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Testing Group Organization

1. Performance Area: t e* fr4nn Objective No. Tc-2 (t'ltle ) Sheet 1 of 2

2. Provide factual informatier. that support's the Performance Evaluation Summary A. Details in Support of Finding TC.2-1

1. FSAR, Chapter 14, Initial Test Program, Section 14.2.2, Organization and Staffing, does not reflect the latest NTS organization. Specifically, the roles and functions of the Senior Project Engineers are not defined.

i

2. Interviews were held with four Lead Test personnel.

Three of the four did not have a written responsibility guide for their positions. One of the four referred the interviewer to the one paragraph description in Chapter 14 of the FSAR.

3. An interview with the Control Room Coordinator indicates that his actual activities were in conflict with those verbally communicated by his Lead Test Engineer.

B. Details in Support of Finding TC.2-2 During interviews with Lead Test personnel, two produced documents (one was created during the interview and the other was for his personal use) indicating a reporting j structure based on activities with subordinate people responsible for these activities. .

C. Details in Support of Finding TC.2-3

1. Testing personnel were not using latest print revisions for verification of air-manifold installations. The method of obtaining latest print revisions was not clear to test personnel. (Refer to Observation of Air Manifold Installations.)

2. Perry Plant personnel had applied metal tags to an air-manifold in the Water Treatment Building per an as-built drawing which had not been design reviewed and was found to be incorrect.

3. Testing personnel were testing air lines to pneumatic control valves and conveyed information to another testing element by valve number. Prints were deemed wrong because air line terminations were indicated to solenoid control valves which had a different number

( designation.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant 1

Testing Group Organization j

1. Performance Area: & Staffina Objective No. TC-2 1 (title) Sheet 2 of 2 1 1

2. Provide factual information that supcorts the Performance Evaluation Summarv _

l 4. Interviews with various test personnel indicated that, in general, understanding and training on Project procedures is the individual's responsibility. Due to interaction with other Project elements, the need for a more' formalized program was indicated by several personnel.

D. Evidence of Scope Not Associated with Specific Findings Current staffing levels and projected staffing levels were investigated in some detail. Current staffing levels appear adequate to handle the existing and near-term workload.

Interaction between Perry Plant testing personnel and NTS personnel is good, with Perry Plant personnel assisting NTS on systems which have been turned over to NTS. Plans for future staffing are questionable; however, enou'gh factual data could not be gathered, due to uncertainty on a'long-term schedule," to formulate a finding. CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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PERFORM,WCE EVALUATION

SUMMARY

Construction Project Perry Plant Performance Area Test Plan Objective No. TC-3 Evaluator (s) G. Fikaris.

I. Performance Obiective

, The test organization should prepare a plan and a schedule that I describe the' sequence of system or component testing to support major schedule milestones.

II. Scoce of Evaluation The evaluation of this area included interviews with the Senior Engineer, Scheduling; Senior Project Engineer, System Test; and Senior Project Engineer, Test Support; all from the Nuclear Test l

Section. In conjunction with this, an interview was conducted l with the Electrical / Instrumentation Contracts Administration Manager.

Approximately 15 manhours were spent on this evaluatron area.

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i III. Conclusion l

The control of activities evaluated under this performance g objective was found to be good and no significant weaknesses .

were observed.

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PERFORMANCE EVALUATION

SUMMARY

Construction Project Perry Plant

'a Perfor: nance Area Test Plan Objective No. TC-3 Evaluator (s) G. Fikaris IV. Areas of weakness and corrective action; Good Practices None.

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PERFORMANClONALUATION DETAILS Construction Project i

Perry Plant

1. Performance Areas Test Plan Objective No. TC-3 (title)

2. Provide factual information that suceorts the Performance Evaluation Summary A. Evidence of Scope Not Associated with Specific Findings:

1

1. An interview with the Nuclear Test Section's Senior Engineer for Scheduling indicated that an overall test plan exists. This was seen in the form of a master diagram called the " Sequence Document."

2. Although a viable integrated Construction and Test 5

, Schedule does not now exist, it is in the development stage and will soon be operational.

3. A " top ten" priority systems schedule now exists (explained as a temporary measure) to assure that critical systems meet key milestones. Construction and Engineering elements respond to this schedule. ,

4. Systems are adequately defined by the system " Scoping Package" that outlines all prerequisites and defines boundaries. This package is prepared by the System

< Test Engineer and is reviewed by Engineering and Construction.

5. Walkdowns are used to monitor construction progress and weekly meetings are used to communicate problems to elements involved and to assure that schedule dates are met.

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I PERFORMANCE' EVALUATION SUM 1ARY Construction Project Perry Plant Performance Area System Turnover for Test Objective No. TC-4 Evaluator (s) u em 11 I. Performance Obiective The construction testing and turnover process should be controlled effectively to ensure that program objectives are met.

II. Scoce of Evaluation ,

The evaluation involved approximately 30 manhours. This included procedure and documentation review, observation of turnover walkdowns, and discussions with supervisory personnel in the Nuclear Engineering, Nuclear Construction, Nuclear Quality Assurance, and Perry Plant Departments.

l III. Conclusion Controls for system turnover are currently being put in place and

! are generally good. There is one area identified which requires improvement. .

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PERFORMANCE EVAI,UATION

SUMMARY

Construction Project Perry Plant i

P0rformance Area System Turnover for Test Objective No. TC-4 Evaluator (s) W. Powell  ;

l IV. Areas of weakness and corrective action; Good Practices Finding The current Nuclear Test Section (NTS) to Perry (TC.4-1) Plant Department (PPD) turnover procedure is not consistent with FSAR, Chapter 14. This chapter of the FSAR addresses involvement of the Plant Operations Review Committee (PORC) in turnover. Current

'rocedures do not include any involvement of PORC in turnover.

Corrective An amendment to the FSAR has been submitted to Action delete PORC involvement in turnover. In place of (TC.4-1) PORC involvement the responsible General Supervisor will review and approve turnovers from Nuclear Test Section to Perry Plant Department. The Senior Licensing Engineer is responsible for assuring the change is included in the next FSAR amendment.

Amendment 10 to the FSAR is expected to be filed in November 1982. -

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: System Turnover for . Test Objective No. TC-4 (title) Sheet 1 of 2

2. Provide factual information that succorts the Performance Evaluation Summary _

A. Details in Support of Finding TC.4-1

1. Chapter 14, Section 14.2.2.14, of the FSAR states the Plant Operations Review Committee (PORC) " responsibility incl'udes the review and recommendation for approval or rejection of safety-related systems to be turned over to the Perry Plant Department. . . " Section 14.2.2 of the FSAR also addresses PORC involvement in turnover.

2. Existing and proposed turnover procedures do not address PORC involvement in turnover.

3. In a discussion with the Senior Licensing Engineer, he stated the FSAR wording related to PORC came from Perry Plant Department. .

4. In an interview with the Perry Plant Department (PPD) person responsible for writing the turnover procedures, .

he stated he was not aware of the wording in the FSAR.

He said a current revision of the Nuclear Test Section (NTS) to Perry Plant Department (PPD) turnover procedure was in review. He stated the draft procedures do not address PORC. He agreed'there was a discrepancy between the FSAR and the procedures for turnover. He later stated he had put discussion of this discrepancy on the agenda for the next PORC meeting.

B. Evidence of Scope Not Associated with Specific Findings Procedures, FSAR requirements and turnover documentation were reviewed. Supervisory personnel in the Nuclear Construction, Nuclear Quality Assurance and Perry Plant Departments were interviewed. Observations of two walkdowns of safety-related systems by System Test Engineers were conducted. Two areas of concern were identified.

1. There were no significant problems observed on one system walkdown. The other system walkdown resulted in the following concerns:

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- Some nonconforming items were removed from the Master Deficiency List (MDL) by the System Test

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1 PERFORMANCE svaLUATION DETAILS Construction Project i

Perry Plant

1. Performance Area: System Turnover for Test Objective No. TC-4 i

(title) Sheet 2 o: 2 1

2. Provide factual information that supoorts the Performance Evaluation Summarv  !

Engineer without field verification of completion of the corrective action. He relied on a noncon-

.formance tracking report which was inaccurate.  ;

Nonconformance Hold Tags remained on items long after the Nonconformance Report was closed out.

Two had been closed out for over two years. The

, System Test Engineer was aware of this but did not take action to notify the appropriate quality control element to remove the Hold Tags.

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A review of five Nonconformance Reports on system i

components indicated one nonconformance Hold Tag was placed on the wrong component.

It appears System Test Engineers should put more emphasis i on tracking and closeout of nonconformances within i their system. Evidence was inconclusive to formulate a finding based on only two safety-related system walkdowns with insufficient details to determine generic problems. <

CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

2. Development of adequate procedures for turnover of systems and components from Nuclear Test Section to Perry Plant Department are required to support start-up testing in a timely manner.

4

In discussions with the Turnover Lead Engineer, Nuclear Test Section and General Supervising Engineer, Program Quality section, they stated procedures for safety-

related turnovers from NTS to PPD are not adequate due to lack of clear procedure and documentation requirements.

The General Supervising Engineer, Program Quality Section stated a new procedure is currently under review. He stated that after the new procedure was in place, safety-related turnovers from NTS to PPD would be evaluated on

. an individual basis. Turnover would depend on procedures PPD had in place to maintain and operate the system or equipment being turned over. Since safety-related turn-over procedures are not required at this time, there is no evidence for a finding. CONCERN - AN ACTION REQUEST WAS INITIATED BY THE PROJECT FOR RESPONSE AND FOLLOW-UP.

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1 PERFORMANCE EVALUATION SUWiARY Construction Project Perry Plant de Test Procedures and

, Performance Area Test Documents .

Objective No. TC-5 g, g ,)

P. A. Solanics, H.'J. Vyhnalek I. Performance Obiective Test procedur.es and test documents should provide appropriate direction and should be used effectively to verify operational and design features of respective systems.

II. Scoce of Evaluation -

The Scope of Evaluation included interviews with testing per-sonnel, review of test procedures and observations of testing activities. The evaluation was centered on the Nuclear Test Section and Perry Plant Department test personnel and concen- '

trated on the development of test procedures, utilization of test procedures on systems that have been turned over to the Nuclear Test Section and test support by the Plant, Chemistry Laboratory. Approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> were expended in the evalu-ation of these areas.

l III. Conclusion l The majority of activities evaluated under this perfc mance objective were very good. One area of weakness is identified.

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PERFORMANCE EVALUATION StiMMARY Construction Project Perry Plant' Performance Area Test Procedures an'd Test Documents Objective No. TC-5 Evaluator (s) P. A '. Solanics, H. J. Vyhnalek IV. Areas of weakness and corrective actient Good Practices Finding Performance of Ch'emistry Laboratory personnel (TC.5-1) reflected weakness in training in basic laboratory techniques.

Corrective The Chemistry Unit Supervisor of Perry Plant Action Department will issue a Chemistry Administrative (TC.5-1) _

Instruction covering basic laboratory techniques by 12/1/82. All Chemistry Analysts will be trained to this Instruction after issue. Analysts will be monitored periodically by Supervision to ensure good techniques and adherence to Instructions.

Finding .The following good practice was noted: Developing (TC.5-2) initial instrument calibration procedures in conjunction with working on the instrument results in an efficient procedure and early identification of discrepancies with manufacturer's technical specifications.

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Test Procedures and

1. Performance Area: Test Documents Objective No. TC-5 (title) Sheet 1 of 2

2. Provide factual information that supports the Performance Evk'uation Summary A. Details in Support of Finding TC.5-1

1. Practically no data is recorded. A determination of chloride in demineralized water was run and the result was inconsistent with previous data. The technician was unable to check where the problem was since he

, had not recorded data. Review of previous analyses also failed to produce data other than the final answer.

2. The pipette used for sampling was allowed to lay on the table and it was rinsed by reverse flow directly from the reagent water supply bottle. This is not good lab practice and could cause cross contamination.

3. Two standard solutions were used in the dne analysis.

There was no record of the credibility of these solu-tions.

4. The standard solutions used were well outside the range of the material being analyzed. The water was below 0.05 ppm, while the standards were 10 ppm and 100 ppm.

5. A great dependence was placed on laboratory instrument manufacturer procedures, which were at times extended beyond the intent for which they were written.

i B. Details in Support of Finding TC.5-2 1

1. While developing an Initial Calibration Procedure for a Source Range Monitor in the Unit 1 Control Room, several discrepancies were noted with the. technical specification in GEK 736635. These discrepancies were forwarded to the Control Room Coordinator to obtain resolutions from GE (San Jose). Several pre-cautions were also noted in the procedures (i.e.,

Test Point 4- very sensitive to adjustment). (Refer to observation on Control Room Instrument Calibration.)

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PERFORMANCE EVALUATION DETAILS Construction Project Perry Plant Test Procedures and

1. Performance Area: Test Documents Objective No. TC-5 (title) Sheet 2 of 2

2. Provide factual information that supeorts the Performance Evaluation Summary

2. Interviews with lead test personnel indicated that as a general practice, initial calibration procedures are. developed in conjunction with working with the' specific device. This practice is contingent on equirment and manpower availability.

C. Evidence of Scope not Associated with Specific Findings

, A review was conducted on the various t'ypes of test pro-

! cedures (generic and initial) as to clarity, source docu-ments, and technical content. An observation was made on the utilization of a generic test procedure to a safety-related 125-V de cubicle. The test procedure policy for safety vs. nonsafety equipment was reviewed and discussed ~

with various Lead Test Engineers. All the above investiga-tion revealed no apparent problems.

It was noted that Perry Plant Department and Nuclear Test Section personnel work closely together on the development of initial calibration procedures and have apparently established good lines of communications and cooperation.

In one instance, a calibration procedure that would

normally be done by NTS personnel was being developed by PPD personnel, since they were more familiar with the l devices.

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PERFORMANCE EVALUATION SUNiARY Construction Project Pe'rry Plant Perfosmance Area System Status Controls Objective No. TC-6 Evaluator (s)

I. Performance Obiective A method should exist to identify the status of each system or component and the organization holding control or jurisdiction over that system or component to prevent interference and ensure equipment and personnel safety.

II. Scope of Evaluation The evaluation of this area primarily involved interviews with supervisory personnel in the Nuclear Test'Section of Nuclear Construction Department and the Program Quality Section of Nuclear Quality Assurance. A review of procedures and logs and observations of testing were conducted. Approximately 40 man-hours were spent in evaluation of this objective.

I III. Conclusion The System Status Controls are generally satisfactory, but there were two areas identified which require improvement.

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- PERFORMANCE EVALUATION

SUMMARY

Conctructicn Project Perry Plant Performance Area System Status Controls Objective No. TC-6 -

Evaluator (s) W. Powell j l

IV. Areas of weakness and corrective action; Good Practices 7nal Finding The present method of tracking the jurisdic (TC.6-1) status of systems needs to be improved. Separate tracking records now being maintained by dif-ferent organizations lead to. confusion. The current published status report does not adequately address component turnovers or turn-backs. Quality Assurance is planning to install a centralized computer tracking system. This system, if implemented in a timely manner and -

properly maintained, should resolve this weakness.

Corrective Nuclear Test Section is implementing a centralized Action Computer System Status Tracking Program. The (TC.6-1) stated program will be written and completed approximately December 1, 1982. Two additional months to backfit all records to date will be

required. By February 1, 1983, the system will be completely functional. The Nuclear Test Section Turnover Lead Engineer is responsible for implementation.

I Finding Jurisdictional tagging procedures are not being (TC.6-2) followed in the control room. Unauthorized juris-dictional tagging methods are currently being -

used for control room benchboard switches within the jurisdiction of Perry Plant Department..

Corrective A Program Revision Notice (PRN) has been initiated Action to PA-1104 " Project Safety, Jurisdictional, and (TC.6-2) Special Purpose Tagging" which clarifies and resolves the situation regarding tags and labels.

The PRN will be effective by December 1, 1982.

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Inappropriate labels on breakers were removed at l

the time of the finding.

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PERFORMANCE EVALUATION DETAILS Construction Project

,, Perry Plant

1. Performance Area: system status controls- Objective No. TC-6 (tithe) Sheet 1 of 2

2. Provide factual information that succorts the Performance Evaluation Summary A. Details in Support of Finding TC.6-1

1. An interview was conducted with the Senior Project Engineer for Turnover Coordination in the Nuclear Test Section. He stated there is a list of system status' published on an as needed basis. The listing

" System Turnover Jurisdiction" does not indicate when systems or subsystems are turned back for correction to. Nuclear Construction Administration Section.

2. The Supervisor of Turnover Coordination Unit in the Prog' ram Quality Section was interviewed. He stated there is no one source for accurate tracking of system or component jurisdictional ststus. He stated that ~

the Nuclear Test Section and System Quality Engi-neering Unit keep separate jurisdictional tracking records which are not always consistent. He said jurisdictional confusion had occurred in turnover of electrical cables.

He stated these problems had been presented to Nuclear Quality Assurance Department management along with a recommendation for a computer program to track system and component ~ jurisdictional status.

3. In a discussion held with the Program Quality Section General Supervising Engineer, he said a Nuclear Quality Assurance Department management decision had been made to establish a computer program for jurisdictional status tracking.

B. Details in Support of Finding TC.6-2 l

l 1. Control switches in the Unit 1 Control Reom are marked with green circular labels.

( 2. Several Control Room personnel, including the Project Tagging Coordinator, were asked th,e purpose of the green labels. They indicated the green label's were an indication of Perry Plant jurisdictional status.

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PERFORMANCE"" EVALUATION DETAILS Construction Project Perry Plant

1. Performance Area: Svntem status Controls Objective No. TC-6 (title) Sheet 2 of 2 S

2. Provide factual information that supports the Performance Evaluation Summary

3. Project Administration Procedure 1104, " Project Safety, Jurisdictional and Special Purpose Tagging" does not address the use'of labels for Perry Plant Department tagging.

4. ' Green circular labels similar to those used in the control Room were observed on the following switchgear which had Nuclear Test jurisdictiohal tags attached:

1R23 5001 Breaker F1A03 1R23 5005 Breaker F1E03 1R23 5003 Breaker F1C03 1R23 5041 Breaker F1B05 1R23 5006 Breaker FIF03 It appeared these labels were being used for purposes other than jurisdictionsl tagging. ,

C. Evidence of Scope not Associated with Specific Findings:

Members of Nuclear Test Section, Nuclear Quality Assurance and Perry Plant Departments were interviewed. Items reviewed included:

Turnover procedures Turnover documentation packages

• t Tagging procedures Safety tagging log Lifted lead and jumper log Testing activities An interview was conducted with the Project Tagging Coordi-nator. He stated safety tagging procedures should be revised prior to fuel load. Under the current procedures, devices with " Limited Operation" tags and "Out of Service" tags may be operated by anyone authorized by the job super-visor. He said a licensed person must operate a device which controls reactivity. He stated that before fuel load, further clarification or controls in the procedure will y be required to prevent unauthorized personnel from operating Since these controls a

are device that affects not necessary at this reactivity'this time, is not a basis for a finding. However, project personnel are aware that a proce-l dure revision is required.

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• APPENDIX I TEAM ORGANIZATION CHART AND TEAM MEMBER RESUMES I

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, ORGANIZATION CHART OF .STRUCTION EVALUATION TEAM , ,

PROJECT MANAGER l

A. Kaplan I

TEAM LEADER C. Shuster i

R. Vondrasek/J. Sevier (INPO)

DESIGN CONTROL CONSTRUCTION CONTROL ORCANIZATION & PROJECT SUPPORT I

S. Biro W. Tokarcik R. Porter

-F. Jankowski - B. Grier -R. Schuerger (Nech./Huclear)

-R. Villforth -G. Fikaris -R. Denchak (Struct./ Safety)

-P. Solanics j (I & C)

! -W. Powell (Elect.)

-H. Vyhnalek (Coatings / Flushing / Welding)

-C. Daf t (Welding) .

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A MR. ALVIN KAPLAN, Manager, Plant & Substation Engineering Department of CEI, is a 1964 graduate of Tenn . College of Cleveland State University with a B.E.

degree in Electrical Engineering, and a 1970 graduate of Cleveland State University with.a B.E. degree in Mechanical Engineering. He completed a course on the Davis-Besse pressurized water reactor presented by Babcock and Wilcox Company and a BWR design orientation course presented by General Elec-tric Company, He started his employment with CEI in the Plant & Substation Engineering Department in 1956. He has worked on the electrical engineering and start-up of three 250 W units installed at the Ashtabula, Avon and Lakeshore Plants between 1956 and 1962. During 1963 and 1964, he was the electrical mainte-4 nance foreman responsible for 1-250 W and 4-40 W units at the Ashtabula Plant. He was the Electrical Project Engineer responsible for the design and start-up of a 650 W unit put in service at the Avon Plant in 1970. From 1970 to 1975, Mr. Kaplan was the electrical project engineer for the Perry Project (2-1200 W nuclear' units). H'e was the General Supervising Engineer, Design Section, responsible for all engineering on the Perry Project from 1975 to 1978. From 1978 to 1980, he was the General Supervising Engineer, Construc-tion Section, responsible for all construction on the Perry Project. Cur-rently, he is the Manager of the Plant & Substation Engineering Department which is responsible for all engineering on the company's fossil fueled power l plants, transmission stations and substations.

Mr. Kaplan is a member of the Institute of Electrical and Electronic Engi-neers. He was a member of the IEEE. Nuclear Power Engineering Committee (NPEC) from 1970 to 1977, and during 1978 and 1977, was Chairman of the Equipment Qualification Subcommittee. He is also a registered Professional Engineer in the State of Ohio.

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, MR. CYRIL M. SHUSTER, General Supervising Engineer, Nuclear Project Training Section of CEI, is a 1954 graduate of Case Institute of Technology with a B.S.

degree in Electrical Engineering, and a 1963 graduate of Casa Institute of

, Technology with an M.S. do,ree in Engineering Administration.  !

He joined CEI in 1954 as an Engineering Assistant, in the System Planning Department. He was later assigned to the position of Associate Engineer.

In 1962, he was appointed Engineer, where he was responsible for designing ,

protection systems for the electrical power system. In 1963,- he served for '

eight months as Electrical Test Foreman, (on Rotation of Assignment) where he was responsible for the testing and maintenance of electrical control and relay equipment.

In 1967, he was assigned to the position of Senior Engineer. He was respon-sible for the direction and design of protection plans for power system app 11-cations. He participated in a series of Rotation of Assignments from 1975 to 1977, as General Supervisor of Customer Engineering responsible for the design of the facilities required for Commercial and Industrial customers. As General Supervising Engineer for Electrical Projects Engineering, he was responsible for the overall design of all company transmission and distribu-tion stations. He served as Acting Manager of Plant Substation Engineering Department responsible for the design of all company transmission and distri-bution substations and all plant electrical facilities.

In 1977, he was assigned to General Supervising Engineer, System Protection Section, responsible for automatic protection systems and automatic control systems for application on the Electrical Power System.

Concurrent with his other responsibilities, Mr. Shuster served as Engineering Training Coordinator from 1968 to 1976. He was responsible for coordinating the training program for new engineering personnel to provide broad training on power system design methods.

. In 1982, he was named to his present position of General Supervising Engineer, Nuclear Project Training Section. He is responsible for directing the devel-opment and coordination of training to assure that the Perry Plant is staffed

, with trained, qualified individuals capable of supporting, maintaining and operating the Perry Plant.

Mr. Shuster is a registered professional engineer and holds professional memberships in the following organizations: The Electric Power Research Institute, Institute of Electrical and Electronic Engineers, and the Cleveland Engineering Society. In addition, he is the CEI representative on. the Power System Planning and Operations Task Force. He is Chairman of Underfrequency Protection Working Group of Power Relay Committee.

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ROBERT L. VONDRASEK, General Supervising Engineer, Program Quality Section cf CEI, is a 1975 graduate of Cleveland State University with a B.S. degree in Engineering, and a 1981 graduate of Cleveland State University with an M.B.A.

From 1964 to 1968 he served in the U.S. Air horce as Nuclear Weapons Member, Nuclear Weapons Crew ChLef, Nuclear Quality Control Inspector, and Nuclear Maintenance Member of base Disaster Control Team. He started his employment with CEI as a junior engineering aid in the Plant and Substation Engineering D:partment in 1968. From 1968 through 1978 he held various positions in the Plant and Substation Engineering Department. As Electrical Project Engineer, he was responsible for plant and transmission substation design and equipment cpplications.

In July, 1978, he joined the Nuclear Quality Assurance Department as a Quality Engineer in the Program Quality Section. In October 1978, he was named Direc- ,

ter of Training, responsible for the development of the indoctrination and training' program dttring the construction phase of the Perry Nuclear Plant. In April 1979, he was named Supervisor, Construction Quality Engineering Unit, whnre he was responsible for quality assurance support of all construction functions. In September 1980, he assumed the position of General Supervising Engineer, Training / Administration Section. He was responsible for indoctri-n: tion and training, quality records, coordination of activities involving the Nuclear Regulatory Commission during the construction phase, and general' administration functions. He assumed his present position of General Super-vining Engineer, Program Quality Section, in April 1981. Mr. Vondrasek is recponsible for planning and directing the quality assurance activities in-

.ving procurement, program development and quality control for the start-up and operation of the Perry Nuclear Plant. He reports directly to the Manager, Nuclear Quality Assurance Department.

Mr. Vondrasek is a member of the American Nuclear Society and the Institute of Electrical and Electronic Engineers.

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i MR. CHARLES DAFT, Quality Assurance Director, Toledo Edison Company, is a 1971 graduate of Ohio State University with a Bachelor of Welding Engineering degree. He is a Certified Audit Team Leader in accordance with the require-ments of AMSE N45.2.23.

From 1971 to 1974 Mr. Daft served in the U.S. Navy aboard a destroyer tender with specific assignments in the repair of electrical motors and components and the welding of piping and ship structures. In 1974, Mr. Daft joined Toledo Edison as a Field Quality Assurance Engineer assigned to the Davis-Besse Nuclear Power Station. In this assignment, he was responsible for reviewing procedures and auditing the piping installation contractor and the Inservice Inspection Contractor. In 1976, he was promoted to Quality Control Supervisor. In this capacity, he was responsible for the independent inspec-tion activities associated with the maintenance, pre-operational testing, and operation of Davis-Besse. Mr. Daft became Operations Quality Assistance Manager in 1978, and was responsible for Quality Control and-Quality Assurance activities associated with the operation and maintenance of Davis-Besse. From 1980 to present, Mr. Daft has served as Quality Assurance Director and is responsible for the development and implementation of Toledo Edison's Quality Assurance Program.

Mr. Daft is a member of the American Welding Society. He is an American Welding Society Certified Welding Inspector. He is also a registered pro-fessional engineer in the State of Ohio and the State of California.

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MR. ROBERT J. DEMCHAK, Engineer, Plant & Substation Engineering Department of CEI, is a 1972 graduate of Cleveland State University with a Bachelor of Electrical Engineering degree.

He started his employment with CEI in the Transmission & Distribution Depart-ment in 1966 and pursued his engineering degree through CEI's - cooperative education program. He worked as a distribution feeder planner from 1972 until 1977, when he transferred to the Purchasing Department. In Purchasing, he worked as a General Buyer responsible for all labor and major equipment con-tracts involving all air and water pollution projects. During his stay in Purchasing, electrostatic precipitators were installed at Avon Lake, Eastlake, Ashtabula "A&B", and Ashtabula "C" plants, and water pollution control systems were installed at Avon Lake, Eastlake, Ashtabula "A&B", Ashtabula "C", Lake-shore and Canal Road Plants.

In February 1982, Mr. Demchak transferred to tho' Plant Electrical Engineer-ing S.ection of Plant & Substation Engineering Department where he is currently working as an engineer.

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MR. GEORGE S. FIKARIS, General Supervising Engineer, Substation Engineering Section of CEI, Plant and Substation Engineering Department, is a 1954 gradu-ate of Fenn College of Cleveland State University with a B.S. degree in Civil Engineering. He completed a cour,se on the Davis-Besse pressurized water reactor presented by Babcock and Wilcox Company.

He started his employment with CEI in the Civil Engineering Department in 1956. He worked on the structural design of three 250 MW units installed at Ashtabula, Avon Lake and Lakeshore Plants between 1956 and 1960. From 1958 to 1960, he was assigned to the construction of the Avon Lake Unit #8 as construc-tion inspector of various contracts including the main electrical contract.

He was also assigned as contract inspector to the 345 kV Canton to Cleveland transmission tie line from 1962 to 1964. From 1965 to 1978, Mr. Fikaris was a Unit Supervisor in the Costs and Record Department responsible for the con-struction cost estimating and cost accounting of all CEI construction costs of power plants substations, service centers and transmission lines. Currently, he is the General Supervising Engineer of the Substation Engineering Section ,

which is responsible for all of the engineering of Company distribution sub-stations.

Mr. Fikaris is a member of the American Society of Civil Engineers and a registered Professional Engineer in the State of Ohio.

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MR. BOYCE GRIER, Consultant with Gilbert Associates, Inc., it a 1946 graduate of the U.S. Naval Academy with a B.S. degree in Engineering and a 1950 gradu-ate of Erskine College with a B. A. degree in Mathematics and Chemistry. He completed one year of graduate work in Physics at the University of Virginia in 1951.

. Following active duty with the U.S. Navy, he was employed as a reactor physi-cist by DuPont at the Savannah River Plant from 1955 to 1960. During this

, period, he was assigned to the Reactor Technology Section which provided ,

technical support to the production reactor operations. In 1960, he joined

, the Atomic Energy Commission as a reactor inspector in the Division of Compli-ance at AEC Noadquarters and was involved in the inspection of reactors under construction and in operation until 1963. In 1963, he was assigned responsi-bility for providing technical direction of the AEC reactor inspection program for licensed reactors. In. 1967, he was named Regional Director for AEC Region III in Chicago where he was responsible for directing the program for inspection of AEC licensees in eight midwestern states. In 1973, he, returned to AEC Headquarters as Assistant Director for Construction and Operation in the Directorate of Regulatory Operations. In 1975, with the formation of the NRC, he was named Director of the Division of Reactor Inspection Programs in the Office of Inspection and Enforcement. In these positions, he was respon-sible for directing the development of the reactor inspection program and for providing support for resolution of technical issues identified during inspec-tions and investigations. During this period, he served ,as the Inspection and Enforcement representative on the Interoffice QA Task Force. He also served as the U.S. Representative on the IAEA Technical Review . Committee on Safe Operation, a part of the IAEA program to develop safety codes and guides. In 1977, he was named Regional Dixector for NRC Region I in Philadelphia where he was responsible for directing the inspection and enforcement program for NRC I

licensees in eleven northeastern states.

I Mr. Grier retired from NRC in 1981. He is currently under contract with Gilbert Associates, Inc., Reading, Pennsylvania as a consultant in the Quality Assurance Division.

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l MR. FRANK D. JANK0WSKI, Engineer, huclear Engineering Department of CEI, is a 1969 graduate of Ohio University with a B.S. degree in Mechanical Engineering, and a 1980 graduate of Cleveland State University with a M.S. In Mechanical Engineering. He is currently completing a MBA at Case Western Reserve Univer-sity.

He started his employment with Babcock & Wilcox in ths Nuclear Navy Component design group in 1969. He worked on functional design of reactor vessels,

- steam generators and pressurizers. He also worked as a Proposal Engineer and l was responsible for writing up the engineering portion of proposals submitted to the Navy. l He joined Stone & Webster Engineering in 1971, in the Mechanical Design Sec- l tion. He was responsible for designing ASME Section VIII tanks and vessels for various nuclear projects. He completed a seven-month field assignment at Beaver Valley where he was NSSS Installation Engineer. In the field, he was ,

the engineering representative of the S&W Boston office for the rough set and I installation of the neutron shield tank, reactor vessel, pdlar crane, pressur-izer, and three steam generators. He was involved in the writing and review-ing of installation procedures,for these components while in the field.

He joined Toledo Edison's System Planning Group in 1973, in the Generation f Planning Secti6n. He was responsible for running studies which analyzed the current and future capacity addition plans for Toledo Edison.

He rejoined Stone & Webster in 1974, as a Systems Engineer on the Montague Units 1 & 2 project. This was a BWR6, Mark III containment nuclear plant. He was responsible for the licensing and design of systems such as RWCU, CRD and the fuel pool cooling and cleanup system. These units were subsequently cancelled in late 1975.

He joined H. K. Ferguson in 1975, as an Engineer. He worked on various pro-jects including Anheuser Busch breweries. He also spent one year as a Subcon-tract Administrator handling contrccts for insulation, piping installation, j tanks and acid proof brick. ,

He joined CEI in 1977, as an Associate Engineer on the Perry Nuclear Power Plant. He worked in the NSSS Section and during that time, completed a one-year rotat; ion of assignment as a Buyer in Purchasing. While in Purchasing, he was responsible for the NSSS, turbine-generator, and valve procurement con-

' tracts. While in the NSSS group, he handled the condenser and NSSS installa-tion contracts. He handled design & licensing of various NSSS systems as well as special projects such as cladding of the recirculation system. He was assigned full time in 1980 to the Future Generation Study as the Project Mechanical Engineer where he handles the architect-engineer portion of .the study.

Mr. Jankowski is a member of the American Society of Mechanical Engineers and is a Registered Professional Engineer in the State of Ohio.

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4 MR.' HARRY R. PORTER, Director, Research and Pisaning, Gilbert / Commonwealth

, International, Inc., is a 1959 graduate of Oklahoma State University with a B.S. degree in Mechanical Engineering. Mr. Porter's graduate study in Engi-neering was at the Carnegie Institute of Technology. He attended several industrial technical and management courses during his employment with West-inghouse Electric Corporation.

Mr. Porter was Iead Design Engineer, Advanced Nuclear Reactor Design from 1959 to 1963, and Resident Engineer, Structural and Assembly Engineering from 1963 to 1965, at the Westinghouse Bettis Atomic Power Laboratory. He served as the Westinghouse Project Engineer on the Virginia Electric Power Company's Surry Nuclear Power Project to 1969, with responsibility for the Technical, Adminis-trative, Licensing, and Coordination aspects of the nuclear steam supply system and turbine generators in the Commercial Nuclear Energy Systems Divi-sion. Mr. Porter was Projects Manager,1969, to November.1971, with respon-sibilitles for the overall efforts of providing NSSS and certain Balance of Plant Engineering and Equipment to utility customers for concurrent nuclear power station projects. The projects were Duquesne Light Beaver Valley Units

1. 1 and #2, South Carolina Electric and Gas Company V.C. Summer Station, and Northwest Utility Service Company's PWR Four Loop station. Since 1971, Mr. Porter has beed employed by Gilbert Associates, Inc., an Engineering and Consulting firm. From 1971 to 1974, he was Engineering Manager with respon-sibi,11 ties for the management of the Structural and Architectural Engineering Departments and multiple foreign and domestic nuclear power plant projects.

Department and project personnel reported directly to the Engineering Manager.

In 1974, he was appointed Manager of Projects with responsibility for all foreign nuclear projects and the domestic Perry Nuclear Power Station. The foreign projects included OHI Units #1 and #2 (Japan), KORI I (South Korea),

and KRSK0 (Yugoslavia). From June 1979 to May 1981, Mr. Porter was Director of International Business Development, and is currently Director, Research and i Planning in the Gilbert Associates International Company.

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MR. WAYNE POWELL, Senior Engineer, Plant & Substation Engineering Department of CEI, is a 1969 graduate of Tenn College of Cleveland State University with a Bachelor of Electrical Engineering degree and a 1971 graduate of Cleveland State University with a Master of Science .in Electrical Engineering. He completed a BWR design orientation course at CEI.

He began his employment with CEI as a Scholastic Awards Student in the Opera-tions Services Section in 1965. In 1969, he joined the Plant & Substation Engineering Department. He worked on the electrical design and start-up of various fossil unit retrofit and upgrade projects. In 1976, he joined the Nuclear Engineering Department as planning coordinator. In this capacity he was responsible for directing the planning and scheduling efforts of the Perry Nuclear Power Plant Project. From 1978 to 1982, Mr. Powell was responsible engineer for the instrumentation and control contracts for the Perry Project.

Currently, he is a Senior Engineer in the Environmental and Control Section of the Plant & Substation Engineering Department. He is responsible for instru-mentation and control engineering on the company's fossil fueled power plants, transmission stations and substations.'

Mr. Powell is a member of the Institute of Electrical and Electronics Engi-neers. He is a registered Professional Engineer in the State of Ohio.

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! . MR. RICHARD G. SCHUERGER, Principal Nuclear Operations Engineer for CEI, is a 1949 graduate of Case Institute of Technology with a B.S. Degree in Mechanical Engineering. He also earned an M.S. degree in Mechanical Engineering from  ;

l Case Institute in 1953. He began employment with CEI in 1948, where he worked i

for the summer between his junior and senior years at ' Case. He began full-2 time employment la 1949, in what is now known as the Production Engineering Unit. From 1949 to 1956, he held various engineering positions and worked on .

a number of assignments involving the start-up and testing of fossil-fired steam electric generating plants. In 1956, he was assigned for two years to the Atomic Power Development Associates in Detroit, Michigan. While at APDA, he was responsible for the design of mechanical components for the Enrico l

Fermi fast breeder reactor project, including the control rod drives and the fuel handling equipment. In 1958, he returned to CEI as General Supervising Engineer of what is now the Engineering Services Section of the Production Engineering Department. In this capacity he had overall responsibility for the operation of the Chemical Laboratory. Work carried out by these elements during that period of time included support for the start-up and testing of three 250 MW generating units, one of which was Avon Lake No. 8, an early .

i supercritical pressure unit.

In 1962, he was made Manager - Civil and Mechanical Enginesing Department. In this capacity he was responsible for the design, construction, start-up and ,

testing of the Seneca pumped-hydro generating plant (commercial 1970), and the Eastlake No. 5 650 MW unit (commercial 1972). Other principal responsibili-ties included air and water quality planning and implementation, plant support

engineering, and generating plant operating and maintenance economics.

As Manager of Civil and Mechanical Engineering, Mr. Schuerger was responsible for the engineering and licensing functions for the Perry Nuclear Power Plant project from its inception in mid-1971, until an organization change estab-lished the CEI Nuclear Engineering Department in October 1975. From October 1975, to April 1977, as Manager of Civil and Mechanical Engineering, he was responsible for developing and implementing major environmental and mainte-nance programs for the existing CEI coal-fired generating plants. With the elevation of the Quality Assurance function to CEI Department status in April 1977, Mr. Schuerger was appointed to the position of Manager. In April 1978, he was assigned as Principal Nuclear Operations Engineer.

Since his assignment to the Fermi I project in 1956, Mr. Schuerger has been more or less continuously involved with nuclear power, except for the 1975-1977 period in fossil plant work. After his return from the Fermi assignment, he was the part-time company representative to several nuclear activities, including APDA, and the East Central Nuclear Group. From 1968 to 1975, he was responsible for CEI engineering liaison with Toledo Edison on the design and construction of Davis-Besse No. 1. In his present assignment, Mr. Schuerger represents -CEI interests in the operation and construction of the jointly owned CAPCO nuclear units operated by other companies: Davis-Besse No. 1

. (Toledo Edison) and Beaver Valley No. 2 (Duquesne Light).

Mr. Schuerger has taken undergraduate courses in nuclear engineering at Case

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Institute of Technology and the University of Michigan; he has participated in a number of seminars offered by nuclear steam. supply system vendors. He

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• Page 2 served on various committees of the Atomic Power Development Associates and the East Central Nuclear Group (ECNG). He is a member of the American Society of Mechanical Engineers American Nudlear Society, and the Cleveland Engineer-ing Soiety, and is a registered Professional Engineer in the State of Ohio.

He was a member of the Prime Movers Committee of the Edison Electric Institute for 15 years and held positions in its Environmental and Research Projects

. Subcommittees, including chairmanship of the former. He served on the Envi-ronment Task Force of the Electric Power Research Institute (EPRI) in 1974 and 1975.

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MR. JOSEPH T. SEVIER, a Senior Program Manager of Gilbert Associates, Inc. in Reading, PA., is a 1956 graduate of Nottb, Carolina State with a B.S. in Mech-anical Engineering. He has done graduate work in Nuclear Engineering and was instruantal in.ths development and teact ing of courses for the certification of start-up tejt engineera for the U.S. Navy's S5W reactor plants while en-ployed'e Electric Boat. '

, s After= a ;three-yaer tour of duty as a Ship ' Repair Superintendent at Norfolk Naval Shipysyd, he went to work at Electric Boat. He held several positions there, ranging from a -- test engineer to Chief Design Engineer for the S5W submarine reactor plant. While Westinghouse was responsible for the systems engineering of the S5W plant, his group was responsible for the selection and procurement'of practically all of the materials and equipment, development of the plant arrangement, production of the detailed construction drawings, specification .of the'wonstruction and testing processes, and directing the fabrication and construction of the plants. This also included design and analysis for flow, thermal Atress, external shock, radiation shielding, heat and pass transfer and balanca, and for noise reduction, He also directed several special studies, fpr ' component standardization, constructibility and maintainability.

From 1964 to 1974, he was employed by NUS Corporation as a consultant and project manager. Here he managed modification of the offgas system for NSP's Monticello (BWR) Plant. , This' project converted the plant from the original

. thirty-minuta delayed release -of main condenser offgas to a system for recom-bining the radiolytic hydrogen'and oxygen and then compressing and storing the remaining gases so .as to achieve an average decay period of several days. As a consultant 7 he was. involved in studies associated with nuclear powered ice-breakers and combinedsdesalination-power generation barges. He also directed capital cost projection stWies for commercial nuclear power plants which proved to be the most accurate in the industry. For several years he provided l assistance ~ to Oak Ridge National Laboratories for their computerization of reactor safety information (CHORDS) program and their equipment design stan-

! dardization programs.

At Gilbert Associates, he has served as Manager of the Quality Assurance Technical and Specialty Services Section and as a Socior Program Manager. He was instrumental in developing GAI's Operations - Quality Assurance program.

Since March of ,1982, he has been assigned to the Institute of Nuclear Power Operations Construction Program Evaluation Team as CEI's, representative on the i program. ,

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MR. PETER A. SOLANICS, Gene:al Supervising Engineer of the System Protection Section of the System Planning Engineering Department of CEI, is a 1964 gradu-ate of Baldwin-Wallace College with a B.A. degree, a 1964 graduate of Carnegie Institute of Technology with a B.S.E.E. degree, and a 1967 graduate of Case Institute of Technology with a M.S.E. A. degree. He completed the nine-month General Electric Power System Engineering Course conducted in Schenectady, New York in 1969.

He started his employment with CEI in the System Planning Engineering Depart-ment in 1964. From 1964 to 1977, he worked in the Relay Activity of the System Protection Section and was responsible for developing protective relay plans for system facilities, developing relay settings, analyzing system trouble events and conducting system stability studies. From 1977 to 1980, he was the Senior Protection Engineer and was responsible for directing and coordinating the work of the Relay Activity. From 1980 to 1982, he was the  !

Senior Engineer responsible for organizing and administering the Instrument &

Control Activity of the newly formed Environmental & Control Section of the

. Plant & Substation Engineer.ing Department. Curr.eptly, he is General Supervi-sing Engineer of the System Protection Section which is responsible for plan-ning of the system protective relay and communications facilities and power system computer & analytical applications.

Mr. Solanics - is a' member of the Institute of Electrical & Electronics Engi-

- neers and the Cleveland Engineering Society. He is a registered Professional Engineer in the State of Ohio.

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MR. WILLIAM J. TOKARCIK, General Supervisor, Contract Administration Section, Production Engineering Department of CEI, is a 1978 graduate of Cleveland State University with a B.S. degree in Civil Engineering' Technology. He l c attended John Carroll University,

• School of Business Administration, from i 1968 until 1971 and received an A.S. degree in Building Construction '

Technology from Cuyahoga Community College.

, . Mr. Tokarcik started his employment with CEI in 1971 in the Contract Construc-tion Department. He has been responsible for the inspection and acceptance of all piping and mechanical equipment setting, and high and low voltage electri-cal installations at a 1200 megawatt facility of nine fossil units and thir-teen boilers. During 1973 to 1978, he was the contract administrator of civil projects at the Perry Nuclear Power Plant for the construction efforts of two natural-draft cooling towers, fabrication and erection of safety and non-safety-related structural steel, several erchitectural packages and the con-struction of the pump houses, radwaste, and control complexes. He also coor-

• dinated the contractor's efforts in the placement of large electrical and mechanical equipment in related areas'. From 1978 to 1979, Mr. Tokarcik was the Lead Civil Contract Administrator supervising nine civil contract adminis-trators at the Perry Nuclear Power Plant. Mr. Tokarcik was responsible for directing all civil construction contracts, claims, schedules, budget consi-derations, engineering efforts, and contractor coordination. Additional responsibilities included all civil discipline-related material placement, testing, and the mechanical and electrical equipment setting. From 1979 to 1982, he was Supervisor, Major Construction Projects, Production Engineering Department, directing supervision of field inspectors located at five major fossil power plant sites and two fossil steam generating facilities. He was also a member of a new unit study investigating the feasibility and construct-ability of a new six-hundred megawatt fossil unit. Currently, he is General Supervisor, Contract Administration Section, Production Engineering Depart-ment, with the responsibility for supervising the management of major and general contracted construction' and maintenance projects in the areas of electrical, civil, structural, and instrumentation.

Mr. Tokarcik is a member of the American Institute of Constructors, Cleveland Chapter. He was the Vice Chairman of the Construction Division of the Cleve-land Engineering Society during 1979 to 1980. From 1980 to 1981, he was the Chairman of the Construction Division of the Cleveland Engineering Society.

He has received OSHA Supervisors Safety Training and Level II Nuclear Inspec-tor Training for Civil Engineers and has attained license as a structural steel 'and reinforced concrete inspector for the City of Cleveland.

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l MR. RICHARD VILIJORTH, Manager of Projects, Gilbert Associates, Inc., is a )

1950 graduate of Bucknell University with a B.S. in Mechanical Engineering.

He completed the following additional courses: Introduction to Environmental Protection, G/C, 1973, Management Development Program, Pennsylvania State University, 1974, Comprehensive Communications Skills, Learning Achievements Inc., 1975, Managing for Motivation', G/C,1976, and Principles of Law for the Engineer, G/C,1979.

He started his employment with Gilbert / Commonwealth as a Mechanical Engineer in 1950. He war, responsible for the engineering and design of mechanical equipment, preparation of specifications, flow diagrams, and heat balar.ces for power generating units ranging in size from 100 MW to 350 MW.

He was a Project Mechanical Engineer from 1960 to 1968. He was responsible for the supervision of mechanical engineering and design and start-up of mechanical systems for The Kansai Electric Power Company of Japan, Himeji Station, Units 2 and 4, 325 MW and 450 MW oil fired units.

He served as Assistant Project Manager from 1968 to 1969 and was responsible for the coordination of all engineering departments and the maintenance of schedule commitments for engineering and drafting for Florida Power Corpora-tion's Crystal River Nuclear Station, Unit 3, 855 MW.

From 1969 to 1981, he served as Project Manager. He was responsible for the administration of projects including coordination .of all engineering and drafting departments, maintenance of the required production schedule, mainte-nance of contracted scope of work, review of manpower effort, and liaison with the client and ultimate customer for the following Westinghouse Electric Corporation pressurized water reactor nuclear power plants:

Kansa: Electric Power Co. , Inc. , Takahoma Station, Unit 1, 826 MW Korea Electric Power Co. , Kori Station, Units 1 and 2, 600 MW Yugoslavia, Krsko Station, 630 MW .

In 1981, Mr. Villforth assumed his present position of Manager of Projects.

He is responsible for overseeing all G/C activities with assigned clients including Commonwealth Edisen, GPUNC, Westinghouse Electric Corporation and Brown Boveri Companies of- West Germany. Activities include supervision and assistance in the planning and management of projects, supervision and assis-tance in the preparation and presentation of proposals, participation in marketing activities and contract negotiations.

Mr. Villforth is a registered professional engineer, with thirty-two years of professional experience on major and fossil power generating facilities includ-ing project management and administration of engineering design and start-up of mechanical systems. He is a member of the American Society of Mechanical Engineers.

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I t MR. HENRY J. VYHNALEK, a graduate of Case Institute of Technology in Chemical i Engineering; has recently retired from his position as General

• Supervising j Engineer, Engineering Services Section of the Cleveland Electric Illuminating Company. Mr. Vyhnalek's work activities have been devoted to water technology since 1945. He was responsible for the direction of activities associated with the chemical, mechanical, and metallurgical engineering aspects of fossil fired generating plants with emphasis on improving availability and effici-ency.

i He was actively engaged in the early chemical engineering design of the Perry Nuclear Power Plant. He was environmental project engineer during PSAR period. He attended the Babcock and Wilcox and the General Electric Training Programs for their respective nuclear units.

4 Mr. Vyhnalek has been associated with the design and operation of the chemical engineering phase of more than 22 fossil fuel generating units, and the early design work on two 1200 MW BWR units. His scope of activities included waste water control, metallurgy, corrosion control and other water-oriented disci- ,

plines. In the environmental area, his work included the direction of design and operation of air and waste water control equipment required to back fit existing fossil generating units, and providing information to regulatory agencies on the suitability of solid waste disposal associated with these coal-fired units.

He was a member of the Edison Electric Institute's Power Station Chemistry Subcommittee (Chairman 1964-1967); is a member and former Chairman (1976-1978) of ASME Research Committee on Water in Thermal Power Systems. He has also held membership on the EEI Piping and Metallurgical Task Force, ASME Internal Corrosion by High Temperature Water Research - Steering Committee, EEI Stress Corrosion Research Steering Committee, Governor Gilligan's (Ohio) Task Force on the Environment (1971), ASTM D-19 Committee on Indurtrial Water, EPRI Nuclear Systems and Materials Task Group, and the EEI Energy and Environment Committee. He is a registered Professional Engineer in the State of Ohio.

i He has authored various papers on power plant chemical engineering activities which were presented at the American Power Conference, the International Water Conference and other technical meetings and symposiums.

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APPENDIX II ATTENDANCE LIST EXIT MEETING October 19, 1982 1:30-3:30 p.m.

, CEI TITLE FUNCTION D. R. Davidson Vice President M. R. Edelman System Engineering & Construction Division Manager Nuclear Engineering & Construction F. R. Stead Manager M. J. Titas Manager Nuclear Engineering Department J. J. Waldron ' Manager Perry Project _ Services Department J. M. Lastovka Perry Plant Department General Supervising Nuclear Construction Engineering

. Engineer Section 4

R. P. Jadachew General Supervising Engineer Nuclear Construction Administration B. L. Barkley Section General Supervising Nuclear Test Section Engineer E. Riley General Supervisor J. H. Bellack Constraction Quality Section General Supervising Nuclear Design & Analysis Section Engineer

• GA TITLE FUNCTION T. Demers Vice President, Division Staff General Manager F. Moreadith Manager of Engineering, Administration Power Division P."Gudikunst Project Manager J. Mehaffey Project Management Program Manager Quality Assurance Division W. Sailer Manager of Division Program Management EVALUATION TEAM TITLE FUNCTION A. Kaplan Manager-Plant & Substation Engineering Department, CEI C. M. Shuster General Supervising Engineer Nuclear Project Training Section, R. L. Vondrasek Perry Project Services Department, CEI General Supervising Program Quality Section, Nuclear Enginegr H. R. Porter Director, Research & Quality Assurance Department, CEI Gilbert Associates, Inc.

• Planning S. Biro Sr. Engineer Plant & Substation Engineering Department, CEI W. Tokarcik General Supervisor C. Daft Quality Assurance Contract Administration Section Toledo Edison Company Director II - 1

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EVALUATION TEAM TITLE FUNCTION (Continued)

R. Schuerger Principal Nuclear Operations Engineer W. Powell Sr. Engineer Plant & Substation Engineering Department, CEI R. Deschak Engineer Plant & Substation Engineering-Department, CEI P. Solanics General Supervising System Planning Department, CEI Engineer J. Sevier Sr. Program Manager Gilbert Associates, Inc.

. E TITLE FUNCTION B. Brown Accounting Manager Project Management / Field Construction Administration NRC TITLE FUNCTION M. Gildner Construction Resident Nuclear Regulatory Commission Inspector i

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466/D/2/rd II - 2

OBSERVATIONS S

'f. age Chem Lab Operations (#1) 2 Chem Lab Operation (#2) 4 Control Room Instrument Calibration S Coating Activities 7 Storage Maintenance Requirements 9 Meeting of the Quality Assurance Advisory Committee (QAAC) 10 Instrument Installation 11 System Walkdown 13 Inspection of Pipe Hangers 14 Material Handling 15 Outside Storage 16 Instrumentation Contractor Welding Practices 17 QC Receipt Inspections 18 Welding a Hanger 19 Expansion Anchor Bolt Installation by the 20 Instrumentation Contractor (#1)

Expansion Anchor Bolt Installation by the 22 Instrumentation Contractor (#2)

Expansion Anchor Bolt .The Major Electrical Contractor 23 Air Manifold Installation 24 Flushing Operation , 25 Instrumentation Contractor's Wald Rod Control 26 CQS Inspection at a Hold Point 27 Pipe Hanger Weld Inspection 28 Pipe Hanger Rod Rework . 29 466/C/2/rd

, OBSERVATION #1 0F CHEMICAL LAB OPERATIONS i

1 I. SCOPE  ;

Conducted a review of chemical laboratory operations in conjunction with I its role in assuring the proper quality of flush water.

II. OBSERVATIONS A. Supervisor informed me of the organizational status of his seven laboratory technicians and their quslifications.

B. A temporary lab was in use until the permanent facilities are available.

Technicians did comment on the cramped quarters.

C. Domineralized water was being analyzed for chloride content. A specific ion electrode coupled to a computerized voltmeter with digital readout was being used. The technician was relatively new and referred to the instrument manufacturer's manual frequently.

The method involved the use of two standards to tell the relationship and it then computes the chloride 'ontent c of the sample.

D. The technician used 10 and 100 ppe,CL as standards, although he was measuring water in the 0-20 ppb range. It was later pointed out that the instrument was linear in the 10-100 ppm range and, therefore, that is why it was used. The technician did not know how the standards were prepared or if they were certified by a secondary method.

E. After the analysis, the value produced (0.57 ppm) seemed out of line with what would be expected. I asked the technician to check his data to see how that compared with previous data. I was informed that no data is recorded except the final answer which is read from the instrument. A rerun produced a reasonable result.

F. The operator rinsed the pipette by inserting the tip into the delivery tube of the reagent water supply; he also Isid the pipette on the lab

• table amidst a variety of solutions and equipment; each of these could lead to cross-contamination and a subsequent incorrect result.

G. The Instrument Manual did not specify the lower sensitivity of the method they were using, but a senior technician who set up the

. procedure assured me that the data was available justifying use of the procedure at that low level'. .

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~ OBSERVATION OF ^

CHEMICAL IAB OPERATIONS Page 2 III. CONCLUSION A. There appears to be a good knowledge of instrument p_ocedures, but there is weaknes.s in basic laboratory techniques. There is no

, continuity of recordkeeping for traceability. Standardization

. credibility was not apparent.

NOTE: These conclusions are based on the observation of only one type of determination and one rather inexperienced technician.

REFERENCE:

This Observation is, in support of Finding TC.5-1.

S 453B/K/2/rd

OBSERVATION #2 ,

OF CHEMICAL LAB OPERATIONS 1,

I. SCOPE This is the second review of this type. It included a more seasoned technician and different analysis.

II. OBSERVATIONS A. Raw, coagulated, and filtered water were analyzed for pH, conductivity, turbidity and free chlorine.

B. The instruments used were all essentially of the field type, portable nature with direct readout. All had been calibrated and properly tagged.

C. The technician measured pH using the Owner's manual as reference and followed those procedures religiously. She had a problem with one sample getting a stable reading as the method required. I asked her why she didn't take another portion of the same sample as most pH procedures require. She said the procedure did not require taking another sample increment.

D. No individual data was taken. As noted in my first observation, only the final answer was listed on a report sheet. No individual j data books are kept.

E. Interviewed the first and second line supervision and indicated my concerns. They admitted that the one method observed did not have proper background data for credibility. They are now in the process of developing this credibility. They also feel that once they move into their permanent quarters where more room and equipment are available, most of the concerns would be taken care of. They felt that the Owner's methods manual did conform with ASTM and EPA methods; however, when we looked up the pH method in ASTM and EPA manuals, some points of variation were pointed out.

4 III. CONCLUSIONS i

This second observation of Chemical Lab Operations verified the conclusions obtained previously. While most of these concerns are now being studied.

they seem to be' of a generic nature.

REFERENCE:

This Observation is in support of Finding TC.5-1.

453B/K/3/rd 4

, OBSERVATION OF - i CONTROL ROOM INSTRUMENT CALIBRATION I. SCOPE Observed two Perry Plant Department technicians calibrating Channel D of a Source Range Monitor in the Unit 1 Control Room per an unofficial ICI calibration procedure that had been developed working with Channel A.

II. OBSERVATIONS A. Technicians ~ observed were from the Technical Section of the Perry Plant Department. They were working on the development of the ICI procedure (Perry Plant Procedure) since they had received substantial training in the device and were familiar with it.

B. A draft calibration document (OM8:ICI-C51-1, Rev. 0) was being used for calibration. This draft document had been developed from reference document GEK 73635, Source Range Monitor, 368x101BBG1,64, in conjunction with application to Channel A.

C. Several handwritten notes on OM-8 document indicated that GEK tolerances could not be met. These discrepancies were forwarded to the Control Room Coordinator to get resolution from the NSSS supplier.

D. The NTS ICP procedure was not available. Normally, the ICI procedure is developed from the ICP NTS procedure. However, due to PPD personnel '

familiarity with the device, the procedure would be reversed for this device.

E. Technician stated that the calibration procedure outlined in GEK would usually work, however, it may not be explicit enough and may not be the best and most efficient method to do calibration. By

. developing procedures in conjunction with working on the device, special precautions and pitfalls could be discovered and included in procedure (Ex. Test Point 4 - very sensitive to adjustment).

F. Calibration and functional checks were broken out separately because of testing periods.

G. Senior Plant Technician was knowledgeable regarding effects of EMI on instrumentation in Control Room. He did not know of any special

. precautions to be taken in Control Room to preclude use of radios or walkie-talkies.

OBSERVATION OF .

. CONTROL ROOM INSTRUMENT CALIBRATION Page 2 III. CONCLUSIONS A. Ih this instance, cooperation and communication between Perry Plant and NTS testing personnel resulted in the most experienced technician working on development of the required testing procedure.

B. (Good Practice) Developing the test procedure in conjunction with t.orking with the device results in an efficient test procedure and early identification of discrepancies with manufacturer's technical procedures.

REFERENCE:

This Observation is in support of Finding / Good Practice TC.5-2.

e 453B/K/5/rd

. . .- _ - - .L_______-.

l OBSERVATION

^

OF COATING ACTIVITIES I. SCOPE

. Conducted a review of three different activities in the coating category; concrete preparation, concrete coating and a rework by the coatings contractor.

~ II. OBSERVATIONS A. Two workmen were removing loose concrete and miscellaneous material from the " broom" finished floor (Room 01, El. 631, #1 Reactor Building) using needle guns and chipping hammers (10/6/82). The contractor's inspector reviewed the job and okayed it for coating on 10/7/82.

B. Met the contractor's inspector (10/7/82) who had already directed the workmen to make an additional cleaning of the floor (sweeping and vacuuming). Prep t nditions appeared to meet requirements.

C. The coating (110AA) was brought to the job site. Its " Pot Life" was clearly marked on the container. A measured amount of coating was distributed over a specific area and two workmen troweled this amount over the surface, frequently " wet gauging" for thickness (Specs. 1/8 i 1/32). This was also verified by the contractor's inspector.

D. Observed the application of the second coat on concrete wall (E1. 642, Rooms 04, 05, RB II). The contractor's inspector had previously directed an additional scraping of the wall prior to the application.

The workmen were just finishing that operation. The application

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of this material (114) is also by a blade. Its purpose is mainly to level the voids in the concrete. Thickness may vary from 1-10 mil; no wet-film measurements were observed during the time of inspection.

E. A " rework was observed at El. 689, A2, 248' to 271* of structural

, steel between the fuel pool wall and the drywell wall. This involved the power tool removal of rust or nonconforming zine primer. This involved the bolts and nuts of the I-beam junctions. The cleanup job was deemed excellent by the inspector who released it for coating.

No primer was to be applied. When I questioned this, I was referred to ECN #7433-64-44, Rev. A, Attachment I, 5:03.4.6, which allows for direct application of top coat on this rework.

F. On 10/8/82, I reviewed the inspector's reports on the three projects I observed on 10/7/82 and found them to be complete and accurate.

3 C. .

W'h ile making the above observations, I had the opportunity to witness several occasions where there were direct contacts between the coatings workmen and their supervisors and the inspector. During each of the encounters, there appeared to be a rather genuine air of cooperation and respect.

w - y.- g ,,y=- - -e

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OBSERVATION OF COATING ACTIVITIES Page 2 III. CONCLUSION

. A. These observations seemed to reflect good quality performance by the coatings contractor personnel.

REFERENCE:

This Observation is in support of Performance Area CC.4,

" Control of Construction Processes" and Performance Area CC.5,

" Construction Quality Inspections."

453B/K/7/rd 8-

OBSERVATION 0F STORAGE MAINTENANCE REQUIREMENTS I. SCOPE Observed the implementation of Storage Maintenance Requirements (SMR) on the 125V batteries and two transmitter panels.

II. OBSERVATIONS A. 125V Batteries

1. All batteries were in place in battery risoms.

2. A craftsman was in the process of preparing battery terminals.

His work was being carried out in accordance with requirements.

3. No special protection of terminals from physical damage, as required, was evident.

4. The SMR forms were attached to only one out of the eight sets of batteries.

B. Containment System Temperature Transmitter Panels

1. Panels were not permanently installed but were on temporary wood skids in the general area of future installation.

2. Both panels had the SMR forms attsched to the protective tarp covering.

3. Temporary electric lights were installed in each panel in accordance with SMR.

4. Protective plastic tarp was in place over both panels per the SMR; however, one panel was located adjacent to a metal con-

struction chest and opening of the chest lid loosened the tarp on one side.

III. CONCLUSIONS A. The storage and maintenance requirements are not always completely folloOed and observed, and damage to equipment could result.

REFERENCE:

This Observation is in support of " Details Supporting Finding

[' CC.3-1," Item #6.

453B/K/8/rd 1

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e OBSERVATION

, OF

, , MEETING OF THE QUALITY ASSURANCE ADVISORY COMMITTEE (QAAC)

I. SCOPE I

. The scheduled September 29, 1982, meeting of the QAAC was observed. The full roster of seven members was in attendance, chaired by the Nuclear Quality Assurance Department Manager. Three additional members are Project Managers; and three are from outside the Project, one each from the A/E and the Construction Management headquarters, and one is an independent consultant.

II. OBSERVATIdNS A. The meeting was run by the Chairman, who followed the written agenda that had been sent out in advance.

B. Two invited nonmembers made a presentation on the results of the two-week NRC inspection of July 19-30, 1982 (CAT Inspection), which was generally favorable.

C. Other agenda subjects were discussed with good interaction between .

the members.

D. The Committee decided to utilize the INPO Self-Initiated Evaluation in lieu of the normal annual GAI QA evaluation of the project.

E. The meeting minutes were issued promptly (October 5,1982) and included a clearly stated Action Items Summary.

I III. CONCLUSIONS A. The QAAC appears to be performing an effective and useful role as a top level advisory function.

t B. It is not clear that the QAAC is in fact independent as stated in its Charter and in the Project QA Program of QAP 0200, Rev. 4, Section 1.4.

REFERENCE:

This Observation is in support of Finding QP.3-1.

i d

453B/K/9/rd 4

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l OBSERVATION OF INSTRUMENT INSTALLATION I. SCOPE Documents and site installation were observed for a level control instrument on the RCIC Turbine-Steam Inlet Drain Pot.

II. OBSERVATIONS A. The instrumentation, contractor's personnel were welding connections to the drain pot and assembling seismic restraints.

B. Weld rod was being maintained at a temperature of 300*F.

C. Work was being performed from a drawing IE51 No. 37; Sheets 1, 2 and 3; approved by PNPP on September 10, 1982. An Engineering Change Notice (ECN) 8930-90-285, Rev. A, was written against the drawing.

The 3" long, 1" pipe and 1" SW cap at the test port called for in the ECN was added to the drawing. All the welds were designated and reported in the " weld status report" including Nos. 21'and 22 which were added as a result of the ECN.

D. Attitude of the tradesmen was excellent.

E. The work area was somewhat confined but relatively clear of unnecessary material.

F. Actual welding was not being performed and was not observed.

III. CONCLUSIONS

! A. The procedures for document use and recording were being followed.

B. The contractor's engineer following the work was conscientious, cooperative and appeared to be very capable.

C The particular instrument installation was proceeding toward the

, required design, installation and QA requirements.

REFERENCE:

This Observation is in support of " Evidence of Scope not Associated with Specific Findings," Item #4 in Performance

( Area CC-5.

O I l l

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POSTSCRIPT OBSERVATION OF INSTRUMENT INSTALLATION Page 2 I. SCOPE The installation by the instrumentation contraci:or of some stainless steel tubing for sensing pressures at the RHR heat exchanger was reviewed.

II. OBSERVATIONS A. Socket welding of the nominal 3/8" stainless steel tube was proceeding in'a confined area above the RHR heater.

B. A ladder of a rather shaky nature used to get to the top of the RHR heater was not secured.

C. TVo welders atop the heaters were being bothered with paint and solvent fumes and requested the engineer to use his radio to call their foreman to whom they complained about the situation.

III. CONCLUSION A. Industrial Safety should be stressed, i.e., tying down ladders and having proper ventilation.

REFERENCE:

This Observation is in support of Finding PS.1-2.

453B/K/11/rd l

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OBSERVATION OF SYSTEM WALKDOWN I. SCOPE Observe system test engineer walkdown of the P45 Emergency Service Water System.

II. OBSERVATION .

.i A. The test engineer had all appropriate documents (scoping package, deficiency list, system diagram) for the walkdown.

B. The engineer had a good working knowledge of his system status.

C. When asked if several nonconformance tagged items were on his deficiency list, the test engineer found they were not.

D. Further research determined that some of the nonconformances were closed out, but all tags had not been removed. In one case, research of the records indicated the nonconformance tag was on the wrong item. In another case, the noncohformance computer log had deleted the NR and the engineer had deleted it from the deficiency list without field verification. He had subsequently caught the error when the NR was replaced in the log and he was in the process of updating the deficiency list.

III. CONCLUSIONS .

A. More emphasis should be placed on field verification of nonconforming items.

B. Quality personnel La some cases are not removing nonconformance tags after closeout of the NR and some items are being incorrectly tagged.

REFERENCE:

This Observation is in support of " Evidence of Scope Not Associated with Specific Findings," in Performance Area TC.4.

8 e

453B/K/12/rd

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OBSERVATION OF INSPECTION OF PIPE HANGERS I. SCOPE Discussed the program for the inspection of the pipe hangers installed by the rajer piping contractor under SP-44 with the Lead Inspector of the assigned QC group, and with him observed the inspection of two hangers.

II. OBSERVATIONS A. The Lead Inspector stated that his inspectors are all qualified to Level II but was not aware of whether the contract surveyors who he uses were registered.

B. The Lead Inspector stated that he does not get work schedule information on hanger installation to use for planning inspection work, but rather, his inspectors respond to requests from the contractor.

C. The second hanger inspected (1G43H008) was found to have a defect and was not signed off. The hanger was actually a guide, and the clearance between the guide and the pipe was less than the allowable 1/32 inch on one side.

III. CONCLUSION A. The observed inspection was performed in accordance with applicable procedures. Rework may be necessary because of inadequate t

clearance. It was stated that the clearance was proper at fitup, so

! that a welding process or procedure may be at fault.

I

REFERENCE:

This Observation is in support of Performance Area CC.4,

" Control of Construction Processes" and Performance Area CC.5, " Construction Quality Inspections."

[ 453B/K/13/rd l

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OBSERVATION OF MATERIAL HANDLING I. SCOPE Conducted an observation of the outside storage to establish if the objectives of the Storage Maintenance Requirements are being met.

II. OBSERVATIONS A. The Warehouse Supervisor's alternate and the Lead Receiving Inspector reviewed the mechanisms of receiving and putting the material in storage. Both were knowledgeable and cooperative.

B. The whole Owner-managed storage area was inspected and all outside storage appeared to be in compliance with the Nuclear Design and Procurement Procedure 3-1302.

C. My guide pointed cut areas where added covered storage was supplied to accommodate the implementation of the plans.

D. When asked ab'out the rapidity of repair of pipe and equipment closures, he indicated that they respond as soon as they hear of an incident.

I mentioned that I saw several pipes which had ruptured caps the previous day. He seemed somewhat surprised and we hunted for them without success. He explained that they may have been in the contractor's storage.

III. CONCLUSION A. The preliminary conclusion is that present control of the outdoor storage function is being adequately handled.

REFERENCE:

This Observation is in support of Performance Area CC.3,

" Material Control."

453B/K/14/rd e

OBSERVATION '

0F i

OUTSIDE STORAGE I. SCOPE Conducted an observation of Owner-managed outside storage to evaluate the implementation of the Maintenance Program.

II. OBSERVATIONS l A. Inspection of materials stored inside (but not in the warehouse) and i inspection of equipment which was already in place indicated that l maintenance was being handled properly. The Storage Maintenance Requirements (SMR) were quite evident;. maintenance dates (such as replacement of desiccant) were marked and current.

B. Outside storage materials were almost completely devoid of SMR's.

It was explained that there was considerable difficulty in keeping these attached due to their availability to the general work force and the elements. There is no requirement to have this document on the equipment (Nuclear Design and Procurement 3-0102, 9/21/81), but it is done for the convenience of the inspectors.

C. We walked the . area trying to locate the 6" pipes which I found the previous day uncapped. . We could not find them. Either they had been recapped or removed from storage in the meantime or may have been in a contractor's storage area.

D. I inquired about the inspection control schedule and was Laformed that it is now up to data but had problems earlier. They now do audits more frequently than the schedule requires.

III. CONCLUSIONS i

l This cbservation of materials stored outdoors indicated that at the present time the program was being adequately implemented. However, subeequent analysis of warehouse SMR records showed some weakness in the effectiveness of the system.

l t

REFERENCE:

This Observation is in support of Finding CC.3-3.

453B/K/15/rd e

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OBSERVATION OF INSTRUMENTATION CONTRACTOR WELDING PRACTICES _ .

I. SCOPE i . Observed welding operations associated with three tubing /pipewelds.

II. OBSERVATIONS A. Welders' ID were vibroetched near the completed weld.

B. Pipe / heat numbers were vibroetched on the pipe / tubing.

i C. Welding procedures used were the current revision. Although welding procedures were kept in the foreman's office and not the work location, the welders were familiar with their requirements.

D, The welding operation met the welding procedure requirements.

E. _ Hold points had been previously established by the contractor, the Owner and the ANI and were being adhered to.

F. Cleanliness was maintained during the welding operation.

G. Socket welds were retracted 1/16 inch prior to making the tack welds.

H. Welds made appeared to be visually acceptable.

i I. QC Inspectors were readily available to support the welder.

J. Cleanliness, ' purge gas adequacy, and interpass temperature were checked on a ramdom basis by QC.

III. CONCLUSION A. The observed welding of pipe / tubing by the instrumentation contractor was acceptable.

REFERENCE:

This Observation is in support of " Evidence of Scope not Associated with Specific Findings," Item #4 in Performance Area CC.S.

l 453B/K/16/rd S

OBSERVATION OF QC RECEIPT INSPECTION I. SCOPE Observed a QC Inspector inspect a shipment of meters received from the NSSS supplier.

II. OBSERVATIONS A. The package was a cardboard box containing three smaller boxes.

B. The Inspector had a copy of the packing list and the quality document.

C. He first checked packing list for correct package number. He then opened the individual boxes, removed and visually inspected the meters that were inside, checked numbers on nameplates and repacked them in their boxes.

III. CONCLUSION A. Inspector knew what he was doing and performed the inspection according to Procedure 1-0730. .

REFERENCE:

This Observation is in support of " Evidence of Scope not Associated with Specific Findings" La Performanc'e Area QP-2.

453B/K/17/rd w -w a - _ _ - _ _ _ _ , . _ _ . _ _ _ _ _ _ - _ - - - - - -

OBSERVATION OF WELDING A HANGER I. SCOPE Observed the welding of a hanger by piping contractor.

II. OBSERVATIONS - -

A. The welder was knowledgeable of the welding procedure requirements.

He indicated his welding procedure was available at his foreman's office if he needed to reference the procedure.

B. Wald rod was maintained in a portable oven with stubs placed in a stub bucket. Weld rod withdrawal tickets were with the weld docu-mentation maintained at the weld location.

C. Process sheets had been reviewed by Perry Project QC, the con-tractor's QC, and the ANI for the inclusion of hold points prior to performing the weld. The hold points were being adhered to.

D. ' Observed the final inspection of base plate welds and the fit-up inspection of a bracket weld. The inspector appeared knowledgeable 4

in both the inspection requirement: and the ability to read drawings.

E. Welding was performed in accordance with the welding process require-ments.

l F. Low stress stamps were available for use by the welder. The welder's-ID was not stamped near the weld as welder traceability was maintained through the documentation.

G. Certification was available for the weld rod and base materials involved in the weld.

H. The weld appeared to be visually acceptable. After welding and

. prior to each pass, slag was removed. After welding, excess spacter

wcs also removed.

l I. The weld area was cleaned prior to welding.

J. The drawing used in the' fabrication was of the correct revision.

III. CONCLUSION A. The weld process was performed adequately.

l

REFERENCE:

This Observation is in support of Performance Area CC.4,-

" Control of Construction Processes" and Performance Area CC.5,

" Construction Quality Inspections."

453B/K/18/rd

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OBSERVATION #1 0F EXPANSION ANCHOR BOLT INSTALLATION BY THE INSTRUMENTATION CONTRACTOR I. SCOPE Observed expansion anchor bolt installations for control piping hangers on the Reactor Building structure. .

II. OBSERVATIONS A. Two craftsmen were drilling holes for a plate attachement. Hanger centerlines were laid out by contractor's surveymen and the craftsmen used these to lay out tha bolt holes.

B. Craftsmen used a hand level and square to keep the drill perpendicular to the surface. They used a folding rule to measure depth.

-C They knew the required minimum depth for the 1" diameter hole they were drilling.

D. I asked for and vas shown the A/E hanger drawing and the sign-off sheet for the anchor bolts. .

E. No QC inpsector was present.

F. Moved to another location on the same elevation of the Reactor Building and witnessed a craftsman filling a hole with grout.

G. He told me he was using #713 grout and dry packing the hole using a l wooden dowel to camp the grout in the hole. Dry pack was not tested j according to procedure.

H. Again, no QC inspector was present.

I. Observed the torquing and QC acceptance of an expansion anchor bolt attachment.

J. QC inspector had already signed off on grouting of holes, since plate was already in place and bolts snugged up.,

K. Torquing was' done according to procedure. Checked wrenches for calibration on a daily log anc found them in order.

L. QC inspector checked bearing of plate by using a thin 6" rule and trying to get it behind the plate.  ;

I M. He checked for skewness of bolts by checking the washers under the

! nuts for flatness. He said this was according to procedure. Checked the contractor's Procedure QAS-1102, Rev. 6, and found to be true.

l 1

OBSERVATION OF ANCHOR BOLT INSTALLATION BY  ;

THE INSTRUMENTATION CONTRACTOR '

Page 2 N. He did not check holes for cleanliness nor bolts for skewness, other than the above acceptance checks.

III. CONCLUSION A. Installation procedure requirements are not always being otserved for the installation and inspection of expansion anchor bolts.

REFERE' ICE: This Observation is in support of Finding CC.4-1.

e P

453B/K/20/rd 21 -

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OBSERVATION #2 0F EXPANSION ANCHOR BOLT INSTALLATION BY THE INSTRUMENTATION CONTRACTOR I. SCOPE Gbserved torquing of bolts for Hanger P-1043 #3, Dwg. #MK IH51-104-3, Rev. O, at El. 664 in the Unit 1 Reactor drywell outside wall at location N270*. The bolts had previously been drilled and installed and the plate fitted and nuts drawn tight and ready for torquing. The contractor's QC inspector was present, as well as a CQS inspector.

II. OBSERVATIONS A. Contractor's QC inspector was taking measurements to determine location of plate. He also made visual inspection of the plate and bolts and the welded angle bracket on the plate. Location is verified from survey points along the circular wall and elevations previously established by contractor's survey crew. Measurements are taken from these points to establish locations as shown on hanger drawing.

B. Torque wrench was set by craftsmen at 200 ft.lbs. and checked by QC.

Wrench #72-33 was, used. Allowable torque was reached when wrench clicked.

C. Inspector then checked for skewness by inspecting washers for plate bearing by inserting thin steel rule under plate and minimum imbedment by measuring bold exposure above nut.

j D. QC inspector signed off on the activity.

E. It seemed to me that the top bolt on the hanger may not have the minimum 4" imbed for 3/4" diameter bolt and I measured it. I came up with 4-1/2".

F. I did not check wrench calibration because the earlier checks I had

. made were good, and the CQS inspector said he was going to check m

this so'etime today.

III. CONCLUSION A. The expansion anchor bolt installations I have observed were according to procedures. The only concern is that there is no verification evident of complete grouting of unused holes.

REFERENCE:

This Observation is in support of Finding CC.4-1.

453B/K/21/rd

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i

, OBSERVATION i 0F EXPANSION ANCHOR SOLT THE MAJOR ELECTRICAL CONTRACTOR I. SCOPE Observed expansion anchor bolt reinstallation of a conduit bracket on the outer drywell wall in the Reactor Building, El. 620 at 195'.

II. OBSERVATIONS A. TWo craftsmen removed existing conduit on the bracket and unbolted the bracket.

B. Craftsmen relocated hanger per ECN #9544-33-2087, support drawing SS-215-005, Sheet 1B, Rev. H, Type 7 support.

C. Holes were drilled with 3/8" carbide drill and leveled by eyesight.

Holes were 5" deep and a depth gauge was used on the drill. Minimum depth requirement of 3/8" diameter bolt is 2-1/2".

D. The contractor's QC inspector was present and inspected the drilling procedure.

E. The bracket was aligned and the bolts were driven into the wall.

F. The bolts were torqued to 35 ft.lb. with Wrench #6-127 and checked by QC inspector with #6-203 wrench.

G. QC inspector checked bracket installation visually and marked the bolts with Torque Seal signifying acceptance.

H. QC inspector had copy of procedure and was taking notes. When I asked him where his checklist and acceptance sheet were, he said he will go back to che office and fill them out from his notes.

I. Also observed craftsmen grinding off original bolts, driving them into concrete and filling them with grout. This was in accordance with contractor's Procedure QAS-1102, 6/30/81, Rev. 6.

J. Verified the calibration of both torque wrenches at their shop.

III. CONCLUSION A. This operation was done in accordance with approved contractor procedure. However, the practice of the contractor QC inspector filling out the required quality documentation back at the shop from l notes of the inspection, may be a source of error.

REFERENCE:

This Observation is in support of " Evidence of Scope Not Associated with Specific Findings," Item #5 in Performance l Area CC-4.

453B/K/22/rd t ,

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OE3ERVATION OF AIR MANIFOLD INSTALLATION I. SCOPE Two Nuclear Test Section (NTS) personnel were attempting to field verify air manifold connections for an upcoming air supply test. Observed NTS personnel interacting with I&C Engineer and accompanied personnel to field v'erify air manifold connections.

II. OBSERVATIONS A. NTS personnel had visually checked several air manifold connections end found them in error. Furthe- checking indicated they were not working from the proper print revision.

B. Latest " Contractor Drawing Distribution List - Monthly Report" was used to verify proper "as-built" field revision which I&C Engineer had. NTS personnel were not aware of this list.

C. NTS personnel checked their visual inspection data with proper drawing revisions and still found discrepancies.

D*. hB Unit 1, El. 600', IP 52-J112 manifold was checked visually. NTS personnel stated they could not visually confirm routing due to inaccessibility and would have to use compressed air to trace pipe continuity.

E. IP 52-J112 was tagged with a blue tag for NTS. Observed loose clamp on copper tubing bundle (screw missing) and screw missing on upper left-hand strut.

F. Auxiliary Boiler House, El. 620', IP 52-Jll8 was visually checked.

Checked only 4th outlet on left supply which was supposed to be a l spare from print. Was connected to an instrument and did not agree with print. Was easy to visually check (run of approximately 20 ft.).

G. Inquired as to how long piping runs could be. Knew of no limitation in length. Stated that runs have been made between buildings.

III. CONCLUSIONS.

l i

A. The drawing had not been revised to indicate the actual installation which was installed on a " field route" basis.

B. In this instance, NTS personnel were not adequately trained on how to obtain latest print revisions.

REFERENCE:

This Observation is in support of Finding TC.2-3 and Details in Support of Finding TC.2-3.

453B/K/23/rd

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_k OBSERVATION OF FLUSHING OPERATION I. SCOPE Conducted an observation of the flush of Condensate Transfer and Storage System on September 28, 1982, a system which had previously been difficult to flush. It had been " pigged" as a result and was being given a final flush.

II. OBSERVATIONS A. The Test Support Engineer (TSE) who directed the program was well acquainted with the system; the support personnel were likewise well acquainted.

B. The TSE at times was somewhat careless with the " pillowcase" used to evaluate the efficiency of the flush. They were left uncovered on boxes, etc., in the plant atmosphere between tests. Despite this handling, the flush still passed inspection.

C. TSE did not always initial the activity being completed at the time

. of completion.

D. When asked why this syst'em had been so troublesome to clean, the operator indicated the piping was installed a relatively long time ago after what he felt was poor outside storage.

E. When the " pillowcase" tests showed the system to meet ANSI Class B cleanliness, the operator was asked if a layup procedure would be employed. He indicated no special layup was required since there was expected to be some work performed on the system. The procedure allows up to 45 days for this work. (The instructions - IP11A-F-026-M requires only draining of the system if work is expected within 45 days.)

F. .I asked about organic removal (such as overheated weld purge barriers) since this could not be evaluated by the " pillowcase." The operator indicated that there was a letter from Engineering excluding them from this evaluation. This was confirmed.

III. CONCLUSION A; This operation is under adequate control. Except for minor technique deficienices, it could be ccasidered a well handled process.

REFERENCE:

This Observation is in support of " Evidence of Scope Not Associated with Specific Findings," Item #6 in Performance Area CC.4.

453B/K/24/rd

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)

OBSERVATION OF INSTRUMENTATION CONTRACTOR'S WELD ROD CONTROL I. SCOPE Observed the return of filler metal to the instrumentation contractor's weld rod storage area.

II. OBSERVATIONS l ,

A. Filler metal issue tickets were used to document the quantity, type, and heat of material issued to each welder during the workshift.

B. Quantities of filler metal issued were appropriate to support a typical day's activities.

C. The original of the filler metal issue tickets issued for the day were laid out on a table to ensure that all material was returned at the end of the shift.

D. Unused filler metal and stubs were returned with the stub buckets at the end of the shift by the welder.

E. The storeroom attendant discarded stubs and placed acceptable electrodes and rod into their appropriate storage locations. He also completed the filler metal issue tickets to denote the quantity of acceptable material returned. Stubs were not coun'ted.

F. Filler metal was segregated by type, size, and heat.

G. The weld rod storage area was locked with controlled access.

H. Low hydrogen electrodes were warm upon their return at the end of the shift.

I. During plant tours weld rod stubs were not noted on the floor areas.

III. CONCLUSION A. The control of weld rod by the instrumentation contractor is acceptable.

REFERENCE:

This Observation is in support of " Evidence of Scope Not Associated with Specific Findings," Item #4 in Performance Area CC.S.

453B/K/25/rd

_ , _ _ . _ _ _ _ _ . _ , . ,, ._,______._,__,,,,y._, . _ . _ . _ , _ , , .. m . , _ ,m,,,, ,. _ , _ , , . ._.-m_.,,, 7,,

OBSERVATION OF -

CQS INSPECTION AT A HOLD POINT I. SCOPE Observed a Construction Quality Section (CQS) piping inspection of a hold point in' Reactor Building No. 2. A pipe sleeve had already been installed by others through the containment and the contractor personnel were installing a pipe assembly penetration per Work Process Sheet IT8A, Dwg. 2P113.

II. OBSERVATIONS The contractor QC personnel notified Construction Quality Section inspector th'at a hold point had been reached. A request was made for a CQS inspection.

The traveler package was complete; both the piping contractors and CQS inspectors were knowledgeable and experienced; the craftsmen were receptive.

The work area was well lit and safe. The drawings and procedure were of the latest issue and all weld rod issue tickets were attached.

III. CONCLUSION This inspection was conducted per procedures and no irregularities were found.

REFERENCE:

This Observation is in support of " Evidence of Scope Not Associated with Specific Findings," Item #2 in Performance Area CC-5.

i e

O 453B/K/26/rd

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OBSERVATION ^

OF PIPE HANGER WELD INSPECTION I. SCOPE

. Observed a Phase II weld inspection of a control rod drive tube strap support IC11-H186, approximately 636 E1. , 74 degrees.

II. OBSERVATIONS A. Review of the traveler package indicated that the weld had been first worked on in January 1982. All weld rod issue tickets were attached. The contractor's Drawing 303186, Rev. 2, was the latest issue.

B. Shims were added to a steel angle to bring the pipe strap out to the pipe as a bracket.

C. The major piping contractor's QC hanger inspector reviewed the traveler package and the weld. He concluded that the work was completed per the PPP drawings and procedure.

D. The Project Organization's Construction Quality Section inspector then inspected the weld and traveler package and also concluded all work was completed per specification.

E. All involved individuals had proper tools and worked efficiently.

III. CONCLUSION A. Repetition and experience have made this a routine job.

REFERENCE:

This Observation is in support of Performance Area CC.4,

" Control of Construction Processes" and Performance Area CC.5,

, " Construction Quality Inspections."

l l

l .

l 453B/K/27/rd l

OBSERVATION 0F PIPE HAN'GER ROD REWORK I. SCOPE Observed rework of a pipe hanger to shorten a rod to avoid an interference

' at 674 El., Control Complex, piping contractor's Drawing 356211 Hanger No. IP47-H211.

II. OBSERVATIONS A. Reviewed traveler package and viewed weld rod issue ticket, FVA, the contractor's drawing and procedure to remove a nut, cut stock from hanger and weld a nut to the hanger to receive a threaded rod.

B. The welder stopped work at a hold point and waited for the piping contractor's QC hanger inspector to approve the bevel prior to welding the nut on 'the upper sleeve.

C. The inspection was completed and accepted. The welder continued his work to completion and final PPP acceptance.

III. CONCLUSION

, A. Repetition and experience have made this a routine job.

REFERENCE:

This Observation is in support of Performance Area CC.4,

" Control of Construction Processes" and Performance Area CC.5,

" Construction Quality Inspections."

453B/K/28/rd i

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