ML20079F720

Continuation of Const Plan

ML20079F720
Person / Time
Site:	Zimmer
Issue date:	12/31/1983
From:	CINCINNATI GAS & ELECTRIC CO.
To:
Shared Package
ML20079F717	List: ML20079F720
References
PROC-831231, NUDOCS 8401190182
Download: ML20079F720 (246)

Text

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THE CINCINNATI GAS & ELECTRIC COMPANY d --'

cincismariomio eze:

December 22, 1983 LOZ-83-0254 J, WILLIAME JR Docket No. 50-358 U.S. Nuclear Regulatory Commission Recion III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J.G. Keppler Regional Administrator Gentlemen:

RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 CONTINUATION OF CONSTRUCTION PLAN (CCP)

W.O. 57300, JOB E-5590, FILE NO. 956C Attached in accordance with Section IV.B (2) (b) of the Commission's November 12, 1982, " Order to Show Cause and Order I= mediately Suscending Construction," is the CG&E Construction Comolecion Plan (CCP) for the Zimmer Facility. The CCP contains resconses to cuestions contained in your letters dated October 28, 1983 and November 15, 1983, as they pertain to this program.

These responses reference the section within the CCP which provides a more detailed response.

As indicated in my letter dated November 23, 1983, the scope of the independent audit of the PVQC recuired by the Commission's order has been expanded to cover the QA/QC aspects of the CCP so that all QA/CC activities through completion of the plant are subject to independent audit.

Should you have any cuestions, please let me know.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANI

, By MN : # 7 j -

. WILLIAMS, JR.

SENIOR VICE PRESIDENT GCF/sfr 8401190182 840103 PDR ADOCK 05000358 PDR A

Mr. J.G. Keppler Regional Administrator December 22, 1983 LOZ-83-0254 Page 2 cc: NRC Office of Inspection & Enforcement -

Washington, D.C. 20555 NRC Resident Site Supervisor ATTN: W.M. Hill -

NRC Zimmer Project Inspector, Region III

.'sTTN : E. R. Schweibinz NRC Office of Nbclear Reactor Regulation ATTN: D.G. Eisenhut L.L. Kintner NRC Office of Executive Legal Director ATTN: Jim Lieberman A

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12/22/83 RESPONSES TO NRC QUESTIONS ON COA ROUND 1 (Reference NRC Letter J.G. Keppler to J4 Williams, Jr. Dated 10/28/83, Enclosure 3)

Does CG&E propose to resume work in an area or on a system for Question 1. which the PVQC has not been completed and unacceptable conditions resolved? If yes, how will the licensee insure that any work performed under this condition by the CCP will not have to be redone based on findings by the PVQCf

Response

Yes it is CG&E's intent to perform CCP work in an area or on a system prior to PVQC being completed. The Continuation of Construction Plan (CCP) specifies that the initiation of construction work will not commence until'the specific element of work (system, subsystem, coinponent, etc.) has been released by PVQC. In this manner CG&E can ensure that the construction work win not pre-empt the PVQC ef fort. Ref erence CCP, ,

Sections 1.4 and 7.2. Also, see answer to Question 8 of Round 2 attached.

Under any situation, win the group responsible for identifying Question 2. a nonconformance also be responsible for disposition of the acacenfcreance?

Response: Yes. The cognizant field engineers or QA/QC personnel may initiate an NCR. The field engineering group may identify the-disposition to correct the condition to comply withOther the engineering requireinents (i.e. rework or reject).

dispositions (i.e. use-as-is or repair) will be approved by l

Engineering. The disposition and the resultant work will be

' approved by QA/QC personnel. Refereme CCP Section 5.4 and Appendix.10. ,

Will an nonconformances be verified, and who win conduct this Question 3.

verification?

Response

Nonconformance reports win be validated by the cognizant QA/QC activity. Upon completion of the actions identified in the disposition instructions, reinspections will be performed as specified and recorded on the nonconformacce reports.

Reference CCP Section 5.4 and Appendix 10.

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Question 4. 'For each draft nonconformance which is not verified to be n  !

nonconforming condition, will a copy of the draf t be returned to the initiator with an explanation datailing the reason for lack of verification? -

Response Yes. Af ter each Nonconformance. Report (NCR) is written it will be signed by the initiator, logged, and forwarded to the applicable QA/QC activity for review and validation. Once an NCR has been logged, it cannot be voided. Should it become necessary to discontinue processing the NCR for reasons of redundance, erroneous reporting, or other similar conditions, the cognizant QA/QC activity will document the basis for the action and sign-off the appropriate block. NCRs that have been logged, but not validated, shall be maintained as a quality a

record with a qualifying statement as to why the NCR was not processed. If the NCR originator disagrees with the decision not to validate the NCR, he has the right of recourse to as high a level of management as necessary for resolution.

Reference CCP Appendix 10.

Question 5. If a design review is not performed on a particular system, how will the project director assure that the drawings provided to the constructor are acceptable for construction and include sufficient detail for that activity to be performed in an acceptable manner?

Response: Bechtel has the responsibility for managing work of those performing construction-related design, under the CCP and PVQC programs. In addition, there will be special desi p engineering assignments which Bechtel may be assiped to either manage or perform. The greatest part of all remaining construction will be performed directly by Bechtel.

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• Where Bechtel ascages others performing desip engineering, Bechtel will effect continuing surveillance of the work of the responsible design engineering organizations through Bechtel's on-site engineering group. This will include mohitoring the

- adequacy "of design techniques, design calculations and desip drawings for construction and will be assisted by direct feedback from Bechtel's constructioc and QC groups. In addition, Bechtel's quality groups will audit and otherwise j monitor work of the responsible design engineering organizations under the Bechtel quality program. Reference CCP Section 5.5.

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12/22/83 Page 3 Question 6. Will the Project Director generate any drawings to supplement S&L drawings? What is the nature of these drawings?

Response: At present, it is not planned that Bechtel will generate any design drawings for construction, to supplement the S&L drawings. However, Bechtel will have the capability of discharging special design engineering assignments which could involve drawings, but the nature of these is not now known. In addition, the Bechtel construction groups which win be directly performing construction, will develop sketches and other construction aids, but these will not be used to establish basic design requirements to which inspections may be made under the Bechtel quality program. Bechtel field engineers (part of the construction group) will probably develop designs within a limited scope, for installation of

- such items as small pipe and instrumentation tubing. These

. field engineering drawings will be prepared in acccedance with criteria provided by the responsible design engineering organizations and will be checked or approved in acccedance with accepted procedures.

Question 7. Why is Bechtel being made responsible for the review of CG&E's QA program?

Response: As part of the continuing effort to upgrade the Zimme QA Program, CG4E has requested Bechtel as part of thair Project Director's role to make a comprehensive review of the CG&E QA Program and make recommendations regarding any required improvements to the program. This review will take advantage c

of Bechtel's experience in the Nuclear Quality Assurance field and ensure compliance with Appendix B to 10CFR 50 and the QA commitments in the Safety Analysis Report, J

Question 8. Will work packages include QA/QC docunents/ records? If yes, who will control these packages prior to completion.-

Construction or Quality Assurance Department?

Response: The work packages will include or reference all documents necessary to acconplish and verify work covered by the package including inspection documents. Prior to completion these packages will be controlled by Construction Document Control in accordance with Quality Program requirements. QA/QC surveillance and monitoring will be performed to ensure the documents are controlled in accordance with the Quality Program requirements. Reference CCP Sections 3.7 and 7.3.

12/22/83 Page 4 I

Question 9. Will all records be reviewed for' completeness and technical adequacy prior tc transmittal to the records vault?

Response: During PVQC existing records will be reviewed for completeness and accuracy and PVQC documents will be generated to give evidence of those reviews and their results. The PiQC generated records will be reviewed and countersiped by QA/QC personnel. .

l During CCP, all Bechtel generated recceds will be reviewed for completeness and accuracy with a " bottom-line" si.pature

- applied. Other CCP records, S&L, GE and contractors, will be reviewed on a sampling basis by Eachtel QA/QC personnel. '

Reference CCP Section 3.7.2.

1 Question 10. Will a record be maintained by signature of the person l conducting this review? How will records currently in the i vault be controlled during the PVQC7 Response: Records reviewed will be signed or initialed by the reviewer on the record or on records traceable to the reviewed record.

(Ref. signature log). A PVQC records control group is being i

• established with appropriate procedures to support PVQC. This group will receive records to be reviewed by PVQC by

• transmittal from the central records control group. Procedures fer thsir operatien which will include all control elements necessary, comply with tihe Project QA program, and be reviewed and approved by Bechtel QC records management prior to implementation.

Question 11. During the PVQC, will the QC records / documents be reviewed by QC personnel in the same discipline as the document? If not ,

who will :onduct a review of these racceds? .

I Response Yes, the PVQC organization is established on a system or area discipline team concept. All field engineering and QA/QC reviews will be performed on a discipline oriented basis by

! personnel experienced in' that discipline.

. Question 12. Does control of interference between CCP on a system, i

sutdystem, or area and PVQC, require identification of all outstanding issues relative to PVQC prior to permitting construction to resume? Must the outstanding items be dispositioned prior to resumption of construction?

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12/22/83 Page 5 Response: In order to etisure tha't construction desa not interfere with or preempt the conduct of PVQC or implementation of potential rework on systems or areas for which PVQC has not been completed controls are established as outlined in the CCP.

Prior to commencing any construction work on a safety-related system, structure, or component, PVQC will release the work only if they are satisfied it will not interfere with the verification process. Outstanding issues relative to a system, structure or component will be identified and they will be dispositioned prior to physical work if the PVQC interface criteria would otherwise be violated. .

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RESPONSES TO NRC QUESTIONS ROUND 2  :

(Reference NRC Letter J.G. Kappler to J.' Williams', Jr. Dated 11/15/S3, -

Enclosure 2)

Question 8. CG&E plans to submit the CCP shortly af ter the submittal of the PVQC. The Bechtel Project Director plans to have the ,

organization unit conducting the PVQC be separate from the l organization unit conductirs the CCP in recopition of the need to ensure that the completion of construction does not

'i nterfere with or pre-empt the verification of quality. The proposed CCP is designed to proceed with construction of a safety-related system or area af ter it has been determined that such construction will not affect the verification of the

. quality of that system or area. Describe the planned method -

for resolving interferences between the sinultaneoi:s processes of verifying quality and completing construction. (Page 39, Volume I)

Easponse: Construction of a system, subsystem, or area will be controlled to, assure that construction does not interf are with or preempt th6 conduct of the PVQC or implementation of potential rework on systems or areas for which verification has not been completed. These controls, detailed in the Continuation of Construction Plan include measures such as:

o Specific training of construction personnel regardits PVQC interface restrictions.

o Surveillance of construction personnel to assure

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. compliance with the PVQC interface restrictions.

i o Fraquent schedule meetings to coordinate interface activities of PVQC and CCP personnel.

o Releases by PVQC based on evaluation and conclusion that a particular portion of CCP work will not interf ere with PVQC activities.

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TABLE OF CONTENTS Section' Title -

Pace GLOSSARY vii LIST OF ACRONYMS ix

, LIST OF APPENDICES ,

xi 1.0 OVERVIEW OF CONTINUATION OF CONSTRUCTION PLAN (CCP) 1 1.1 Background 1

1.2 Purpose and Scope

3 1.3 Dascription of CCP 3 1.3.1 Major Elements of CCP/ Correction of Programmatic Problems 5 21 1.3.2 Implementation of CCP 1.4 Interface with Plan to Verify the Cunlity of 2castruction (PVQC) 23 1.5 Program Results 25 2.0 ORGANIZATION AND PROJECT MANAGEMENT PLAN FOR REMAINING WORK 27 2.1 Project Management 27 i

2.1.1 Overall Management 31 2.1.2 Cincinnati Gas & Electric Company (CG&E) 36

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2.1.3 Bechtel Power Corporation (BECHTEL) 37 2.1.4 Sargent & Lundy ('S&L) 41 2.1.5 General Electric (GE) 42 2.2 Systems Completion Approach 42 f 2.3 Quality Assurance / Quality Control (QA/QC) Approach 45

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TABLE OF CONTENTS (continued)

Section Title Page s s 2.4 Organizational Results 48 .

3.0 GENERAL MANAGEMENT PROGRAM ELEMENTS -

50 3.1 General 50 3.2 Interfacing Document and Procedures Hierarchy 54 3.3 Prevention of Harassment of QA Personnel 56 3.4 Identification of CCP Safety-Related and Nonsafety-Related Work 58 3.4.1 Nonconformances and Incomplete Work on Safety-Related Systems, Structures, or Components (SSCs) from PVQC 58 3.4.2 Rework from Quality Confirmation Program 39 3.4.3 New Work from Continuing Design Analysis 59 l

3.4.4 Known Incomplete Work 59 3.4.5 Nonsafety-Related Work 59 3.5 Project Controls Program 59 3.5.1 Project Scope Definition 60 3.5.2 Project Scheduling 61 3.5.3 Project Cost 63 3.5.4 Project Budgets 63 3.5.5 Continuous Monitoring 63 3.5.6 Financa and' Accounting 65 3.5.7 Labor, Material, and Document Tracking (Project Data Base) 65 3.6 Management Progress Meetings / Reports 67

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c TABLE OF CONTENTS (continued)

Title Page Section' 3.6.1 Monthly Profect Progress Reports 6'8 3.6.2 Other Management Reports 69 3.7 Construction Documents and Records Management Program 71 3.7.1 Construction Document control 75 3.7.2 Construction Records Control 77 3.7.3 Construction Documents and Records Turnover 78 3.8 Tre.ining of CCP Personnel 78 Facilities 84 3.9 Avoidance of Past Generic Problems 85 3.10 3.11 Tracking of Future Nonconformances, Identification of Generic Problems, 87 and Corrective Actions Ganaral Manage =cnt Progr=" Results 89 3.12 92 4.0 QA PROGRAM ELEMENTS Program Overview 92 4.1 4.1.1 Program Hierarchy 92 4.1.2 Key Program Controls 94 Program Review and Approval 96 4.2 i

Division of Responsibility 96 4.3 CGEE 96 4.3.1 4.3.2 Bechtel 97 SEL - 98 4.3.3 Other Organizations 98 4.3.4 Major Program Elements 98 4.4

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TABLE OF CONTENTS (continued)

Section Title Page

%s 4.4.1 Proce,dures 99 4.4.2 Training and Qualification 100 4.4.3 Inspection 101 4.4.4 Nonconformance Reporting 103

4.4.5 Audit Program 103 4.4.6 Monitoring and Surveillance 106 4.4.7 Stop Work 106 4.4.8 Corrective Action and Deficiency Trending Program 107 4.4.9 Management Meetings 108 4.4.10 QA Management Reports 110

. 4.5 Construction-Related Considerations of the Program 111 4.5.1 QA Interface with Construction Related Activities- 111 4.5.2 Tracking Construction Related Quality 112 4.6 QA Program Results 113 5.0 ENGINEERING PROGRAM ELEMENTS 115 3.1 General 115 I

l 5.2 Engineering Procedures 118

( 5.3 Configuration and Design Change Control 121 l

5.4 Nonconformance Disposition Process 128 i 5.5 Control of Engineering Specifications and Drawings 129 l

5.6 Engineering Program Results 132 f

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p TABLE OF CONTENTS (continued)

Section Title Page 6 . ,0 PROCUREMENT AND MATERIAL CONTROL PROGRAM 133 ELEMENTS 6.1 Procedures 135 6.2 Onhand Materials 135 6.3 Inventory control 137 6.4 Storage and Issue of Material 137 6.5 Identification of Material Needed (Shortage Lists) . 138 6.6 Identification of Requirements and Completion of Requisitions 138 6.7 Purchasing 139 6.8 Source Surveillance and Audits 141 6.9 Expediting 142 6.10 Receiving and Receipt Inspection 143 6.11 Storage and Warehousing 145 6.12 Material Issue 146 ,

6.13 Procurement and Material Control Progran Results 148 l

7.0 CONSTRUCTION PROGRAM ELEMENTS 149 7.1 Construction Procedures Program 149 7.1.1 Administration 150 l

1 7.1.2 Construction Work Procedures 150 l

7.2 PVQC Interface . 151 7.3 Work Package Program 154 7.3.1 Definition and Scope 154

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TABLE OF CONTENTS (continued)

Section Title Page 7.342 Drawings, Specifications, and Initial Work Package Development 156 7*. 3 . 3 Material Requirements and

. Availability 157 7.3.4 Welding Requirements 157 7.3.5 QC Instructions, Inspection Requirements, and Hold Points 158 7.3.6 W'ork Package PVQC Interface 160 7.3.7 Construction Process 160 7.4 Nonsafety-Related Work 165 7.5 Welding Program 166 7.5.1 Procedures; 169 7.5.2 Training 171 .

7.5.3 Cualificat'icn and Testing 171 7.6 Contract Administration . ,

172 7.7 Construction Teating Program 173

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7.8 Preoperational Turnover Program 179 7.9 Post-Turnover Control Program 183 7.10 Pilot Program for Field Checkout of Safety-Related Work 185 7.11 Preventive Maintenance Program 186 7.12 Construction Program Results 187 8.0 IMPLEMENTATION OF CCP 190 9.0 SCHEDULE FOR CCP 194 APPENDICES N -

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.. -.._.a.~- . Ou. a n . . i_. .L _ . . L_ _. ~. ~1 GLOSSARY AS-CONSTRUCTED: The status of construction of safaty- l related systems, structures, and  !

components as currently construered CONTRACTOR: Any person or entity which has agreed by written undertaking with the. . Owners to furnish labor services only or a combination of materials, equipment, and/or goods and labor services for the Wm. H.

Zimmer Nuclear Power Station (Zimmer); provided, however, that the term " Contractor" does not include Bechtel, Architect /

Engineer, Constructor, or the suppliers of the turbine generator or NSSS CONSTRUCTOR: Bechtel Power Corporation or any other entity selected as prime contractor to peric,rm construction services for the Wm. H. Zimmer Nuclear Power Station (Zimmer)

CORPORATE MANAGEMENT: Management personnel responsible for the overall management of a

. . corporation or firm PROUECT MANAGEMENT: Management personnel directly assigned i to manage the Zimmer Project l CRITERIA IX: 10 CFR 50, Appendix B, Control of Special Processes, including welding, heat treating, and nondestructive testing PROJECT DATA BASE: The system (s) which provides for storage, retrieval, compilation

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and utilization of data such as tracking labor hours, material quantities, design documents, and deficiency document status

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GLOSSARY (Continued)

SAFETY-RELATED: Those SSCs riacessary to ensure 1) the

- integrity of the reactor coolant pressure boundary, 2) the capability to shut .down the reactor and maintain it in a safe ,

shutdown condition, or 3) the capability to prevent or mitigate the consequences of accidents ,

' that ' could result in potential offsite exposures comparable to those referred to in 10 CFR 100.11. As used in this CCP document, the term " safety-related" includes those SSCs that are not safety-related, but which have been designed as Seismic Category I or which are subject to FSAR commitments which expand the scope of the QA Program (e.g., Fire Protection)

NONSAFETY-RELATED: Not falling within the definition of safety-related TURNOVER: Transferring control of a system from construction to the CG&E startup group WORK-TO-GO LIST: A list identifying , design and/or

. construction work yet to be completed l

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LIST OF ACRONYMS AFR Audit Finding Report .

AI Authorized Inspector ANI Authorized Nuclear Inspector ANSI American National Standards Institute ASME American Society of Mechanical Engineers a

AVL Approved Vendor List BPM Bechtel Procedures Manual i BWR Boiling Water Reactor CAR Corrective Action Request CCP Continuation of Construction Plan CDDS Construction Document Distribution Schedule CG&E Cincinnati Gas & Electric COA Course of Action CESO Columbus & Southern Ohio Electric Company .

DCP Design Change Package DDB - Deficiency Data Base DDCN Design Document Change Notification

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DOR Division of Responsibilities DP&L Dayton Power'& Light EOTD Electric Operating Test Division EVP Evaluation Verification Package FDDR Field Deviation Disposition Request FDI Field Disposition Instruction FSAR Final Safety Analysis Report GE General Electric Co.

HJK Henry J. Kaiser Co. ,

MCAR Management Corrective Action Report

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LIST OF ACRONYMS (Continued)

NCR Nonconformance Report (Issued under the nonconformance program described in Appendix H of the PVQC)

NDE Nondestructive Examination NET NRC Evaluation Team NR Nonconformance Report (Icaued prior to implementation of the nonconformance program described in appendix H of the PVQC)

NRC U.S. Nuclear Regulatory Commission NQAM Nuclear Quality Assurance Manual NSSS Nuclear Steam Supply System 4

PCR Project Change Request e

PDB Project Data Base PDL Project Documents List PMDS Project Master Distribution Schedule ,

PQAM Project Quality Assurance Manual .

PVQC Plan to Ver'ify the Quality of Construction QA ' Quality Assurance .

QAM Quality Assurance Manual QC Quality Control QCIR Quality Control Inspection Report e

QCP Quality Confirmation Program QVIR Quality Verification Inspection Report SCO " Order to Show 'Cause and Order Immediately Suspending Construction" or Show Cause Order S&L Sargent & Lundy Engineers j SSC System, Structure, or Component ,

TPT Torrey Pines Technology (a Division of GA Technologies, Inc.)

ZOC Zimmer Oversight Committee ZPM Zimmer Procedures Manual

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i LIST OF APPENDICIES

. Appendix Number Title 1 Division of Responsibilities 2 Zimmer* Integrated Project Organization for FVQC and CCP 3 CG&E Organization for the Zimmer .

Project 4 Bechtel Project Management Organization 5 'Bechtel Construction Organization 6 CCP System Team Organization 7 Flow Sheet for Start of CCP Safety-Related Work 8 QA Program and. Procedural Document Relationship Hierarchy 9 Flow of Documents and Records for CCP 10 Description of Project Nonconformance Procedure 11 Major Design Change Control .

12 Procure 2ent and Material Control 13 Construction Procedures l

14 Work Package Preparation 15 Implementation of CCP Safety-Related Work i

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1.0 OVERVIEW OF CONTINUATION OF CONSTRUCTION PLAN (CCP)

1.1 BACKGROUND

On November 12, 1982, the Nuclear Regulatory Commission (NRC) issued an " Order to Show Cause and Order- Immediately Suspending Construction", Show Cause Order (SCO), regarding the Wm- H. Zimmer

. Nuclear Power Station (Zimmer). The FCO directed the licensee, Cincinnati Gas & Electric Co. (CG&E), to immediately suspend further safety-related construction activities.

The SCO stated that safety-related construction could not recommence until CGEE had completed four specific actions. Three of the required actions have been completed. They are:

o The independent review of Zimmer Project Management.

o Submittal to the NRC of a recommended Course of Action (COA).

o Submittal of a comprehensive Plan to 7erify the Quality of Construction (PVQC).

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The fourth action requires CGE.E , as licensee, to submit a comprehensive Continuation of Construction Plan (CCP) before restarting safety-related construction activities. The CCP reflects significant steps already taken by CGEE in staffing and planning f'or the construction restart with its strengthened project organization. As part of this strengthening, CGEE has retained Bechtel Power Corporation (Bechtel) as the Project Director and Constructor. Bechtel is , responsible, under CG&E direction, for managing the continuation of construction and other work as assigned.

The Zimmer team, under the direction of CG&E Project Management, is proceeding to modify existing programs, install new programs, review and modify existing procedures, and pr'epare new procedures as

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required. A restructuring of the Quality Assurance / Quality Control (QA/QC) Programs for all contractors is also underway, thereby providing the foundation for implementation of the CCP.

The Independent Auditor of the PVQC will also audit ,

the QA/QC aspects of the CCP such that all QA/QC actiivities through completion of the plant are subject to' independent audit. The " Protocol Governing Communications Between CGEE and Independent I Organizations Conducting Reviews or Audits Under the i

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Commiss. ion's Order," as prescribed by the NRC, will be utilized to ensure an " arm's length" relationship between CGEE, Bechtel and the Independent Auditor.

The following sections describe the major elements of the CCP and describe how these elements are integrated to achieve an efficient, controlled process to complete construction of Zimmer.

1.2 PURPOSE AND SCOPE ,

The Continuation of Construction Plan (CCP) provides a program to complete the remaining work at Zimmer, including correction of nonconforming conditions on safety-related systems, structureu, and components (SSCs), in accordance with appropriate regulations and in a controlled manner.

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1.3 DESCRIPTION

OF CCP The CCP is a comprehensive program designed to assemble the management organization and systems required to control completion of Zimmer construction and plant system turnover to CG&E. The plan provides for a team consisting of' CG&E as Project Manager (licensee), Bechtel as Project Director and

Constructor, Sargent & Lundy (S&L) as Architect /

, Engineer, and General Electric (GE) as the Nuclear t

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The members of the team have defined responsibilities and will use approved work plans and procedures to control work . processes. The work plans and procedures emphasize quality and control and are based on proven methods which have been used by other owners and Bechtel on other power plants.

Bechtel, as Project Director and Constructor, will manage the completion of the project using competent and experienced management at all levels and provide the overall program within which S&L, GE, and contractors will complete their respective functions.

The CCP is specifically structured to provide a strong management and technical foundation for the completion of the engineering, procurement, and construction activities at Zimmer.

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Fundamentally, the CCP is a two-phase program consisting of a preparatory stage in which the prerequisite programs are developed and an

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implementation phase during which actual construction is undertaken in accordance with the prerequisite programs and appropriate Nuclear Regulatory Commissi~on (NRC) approvals.

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1.3.1 ' Major Elements , Of .

CCP/ Correction Of Programmatic Problems In order to achieve the control and correction of programmatic problems necessary to complete engineering, procurement, construction, -and testing in accordance with the applicable regulations and the NRC construction permit, it is essential that key

. elements of the CCP be in place prior to continuation .

of construction. The following paragraphs summarize the major elements of the CCP that CG&E and Bechtel will implement, as required, prior to continuing ccastruction.

o ORGANIZATION CGEE has established a restructured and markedly

- strengthened management team consisting of a highly experienced and motivated senior management staff dedicated to quality in the construction, startup, maintenance, and operation of a safe and reliable nuclear power facility. As part of the restructuring, CGEE has provided a clearer definition of the responsibilities and interfaces of all organizations. CGEE has more than doubled its staff to support this augmented management organization, has engaged the services of Bechtel to act as the Project Director and Constructor reporting directly

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to CGEE senior management, and has engaged the services of a firm not previously associated with Zimmer activities to independently audit the PVQC and QA/QC activities of the CCP.

Retention of Bechtel as the Project Director and Constructor adds to the project an experienced constructor 'and architect / engineer to manage, as directed by CGEE, the engineering and coristruction activities. Bechtel has designed and constructed numerous nuclear plants and has assumed the role of Project Director and/or Constructor on other plants after the projincts were partially completed. As Project Director, Bechtel is responsible for QA/QC surveillance of S&L, G'E , and contractors; for project scheduling, 'and

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controls such as planning, cost control; and for providing project direction to S&L, GE, and contractor organizations.

3 As Constructor, Bechtel is directly responsible for l the accomplishment of the remaining construction as assigned by CGEE.

Henry J. Kaiser Company's (HJK) role as the former Constructor is limited to those activities necessary to provide the data required to certify the status of and

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the ASME, Section III, systems, structures, components (SSC) for which HJK has code l

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. responsibility. -

This activity will be performed as -

described in the PVQC and in accordance with detailed agreement for the transfer of code responsibilities.

S&L has substantially increased the number of its resident engineers at Zimmer. Necessary organizational changes with appropriate assignment of responsibilities will enable S&L to maintain greater control over design changes initiated in the field, provide more effective resolution of nonconformances, and pr6 vide more effective guidance for construction.

o PROCEDURES A Zimmer Procedures Manual is being prepared which addresses all interface activities involving more than one department or organization. A comprehensive set of procedures is being prepared and will be used to integrate, coordinate, and control the activities of all organizations. Each organization is preparing procedures which will conform to the requirements of the Zimmer Procedures Manual. Each contractor, in l addition to administrative procedures, will establish l

l procedures to control work processes. These procedures will reflect Bechtel's role as Project Director and Constructor.

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S&L's, GE's, and contrac' tors ' Z'immer quality-related procedures will be reviewed and. approved by Bechtel.  !

The consolidation of the project procedures and i instructions will enable management to maintain the work controls essential to completing Zimmer in a deliberate and controlled manner.

o PROJECT CONTROL SNSTEMS As Project Director, Bechtel is establishing ?nd will maintain a complete Project Control System including plans, schedules, budgets, manpower requir ements',

cost control,. and financa and accounting. The Project Control System is supported by a Project Data Base.

As Project Director, Bechtel will also prepare and issue reports to management including monthly 2 4

progress reports; project trend reports, QA management reports, and cost and schedule forecasts.

These reports will keep all levels of management informed of status and problems, and they will allow management to take corrective action as required.

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o CONSTRUCTION DOCUMENT CONTROL E, RECORDS MANAGEMENT A construction documents and records control sy' stem under Bechtel's direction will control drawings, specifications, and other controlled documents and records until turnover of completed SSCs and associated records to CGEE at which time they will be stored in the CGEE records vault. The system will provide the needed support to engineering, procurement, construction, and inspection activities as well as the turnover of required records (completed documents) to the permanent plant records system. Controlled documents such as instructions, specifications, procedures, drawings, and applicable revisions will be controlled and distributed in accordance with the Project Master Di'stribution Schedule to assure the latest applicable revisions are used.

o TRAINING A Master Training Plan will be prepared in accordance with the CGEE site directive and approved by CGEE.

CCP personnel will be given general orientation and will be trained in the requirements of the procedures and work plans required for the performance of their specific tasks. Each organization will perform ,

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_10 training as defined in the Master Training Plan. In addition to performing assigned training, Bechtel as the Project Director will monitor and approve S&L's, GE's, and contractors' training activities.

o QUALITY PROGRAM CGEE has- responsibility for the overall Quality Program. The QA Program strengthening includes addition of competent, experienced, and qualified QA personnel headed by a new CGEE Assistant Vice President, Quality Assurance; strong management ,

support; effective OA procedures; clear communications with upper-level management; and provisions for ensuring . involvement of project management.

The CGEE QA Organization will approve and oversee all site. Quality Programs. The QA Programs of CG&E, S&L, GE, and Zimmer contractore performing safety-related work are being reviewed and restructured to assure I programmatic adequacy and functional ability to meet requirements. In addition,, the independent audit of the PVQC has been expanded to cover the QA/QC aspects i

of the CCP such that all QA/QC activities through completion of the plant are subject to independent e f*

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audit.' The QA Programs 'of S&L'l GE, and contractors will be closely monitored by Bechtel.

The QA/QC Programs of all of:ganizations will address general and specific problems previously identified.

Quality will be stressed at' every level in all organizations. All personnel will be informed that any form of harassment of QA/QC personnel will not be tolerated.

Reports of quality concerns will be prepared and promptly forwarded to CGEE management. Inter-organizational QA Managers meetings and Senior Vice 74;asident, Nuclear Operatiens, noetings will be held on a regular basis.

o CORRECTIVE ACTION PROGRAM i-l The Project Corrective Action Program assures that l

l audit findings, , NRC findings, NCRs, Corrective Action ,

Requests, and programmatic deficiencies are analyzed,

, tracked, and expedited to assure timely and correct disposition, completion, and closecut. Analyses of these items will be cond,ucted to identify quality

. trends and to determine whether a generic or programmatic deficiency exists. This information c I i

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is used to determine- if *the levels of inspection / surveillance are adequate. This will help i

ensure that corrective action, which both corrects the specific deficiencies and prevents recurrence of  !

similar deficiencies, is taken. Trends will be analyzed against historical records to continuously

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test the effectiveness ' of the new programs against past performance. Significant conditions adverse to quality will be investigated to identify root causes. This will permit senior management to take measures to avoid recurrence of significant conditions adverse to quality.

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o NONCON?OPJ!ANO23 The Project Nonconformance Program provides definitive procedures for reporting, processing, controlling, and dispositioning. The system will be l centrally controlled and managed by Bechtel. All dispositions and closeouts of nonconformances will,be ,

documented using a nonconformance report (NCR) to provide the quality records needed for turnover to plant operations. NCRs will be tracked to ensure timely disposition and corrective action for nonconforming items. ,Information regarding the status of NCRs will be readily available to the l -- - - . .- -. _ __ _

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. originators of the documents and a mechanism for the originators to disagree with or appeal the actions s

'being taken will be procedurally described.

, , o PREVENTION OF dARASSMENT OF QA PERSONNEL

~

CG&E and Bechtel have issued to all site employses statements of the companies' policies which prohibit harassment and intimidation of QA personnel. The statements also provide formal channels for handling

. quality concerns and complaints of harassment. A formal project-wide program will be establishsd to further the goals of the policy statements. All Zimmer personnel will be throughly indoctrinated concerning the importance of QA on the project and the implications resulting from harassme'nt of QA personnel.

o CONFIGURATION'AND DESIGN CHANGE CONTROL Revisions to safety-related design documents and i

! field-requested design changes will be subject to l

! equivalent reviews and approvals to thoae for the original design. All approved design change documents will be tracked and controlled through a

., centralized project system to ensure that affected base design documents are identified.

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This process will ensure, that -design changes are processed and dispositioned in a timely manner.  %

As the system turnover date approaches, design changes will be packaged to ensure that configuration control is maintained. Field requests for design

. changes will not be used to bring existing construction into conformance with design.

Nonconforming items will be documented on nonconformance reports.

o PROCUREMENT / MATERIAL CONTROL The Procurement and Materiah Control Programs and procedures have been strengthened to control requisitioning, purchasing, contracting, expediting, source survrillance e and audits, shipping, receipt ,

inspection, storage, and issue of materials and components. The Procurement Program will assure that

' procurement and material control activities are accomplished in accordance with the applicable regulations and requirements. Particular attention will be placed on activities which affect quality such as inspections, documentation, storage, material control, and traceability of materials.

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o WELDING /SPECIAL PROCESSES The project program for control of welding and special processes has received special attention and ,

upgrading. Existing procedures will be reviewed, retired, revised or new procedures prepared as required to ensure that they correctly address design and code requirements. Bechtel will keep the number of welding procedures to a minimum and ke'ep them up to date and controlled in accordance with the QA Program.

All personriel performing welding or other special processes will be qualified in accordance with the Q

requirements of the ASME Code or Standards applicable to the process prior to performance of the activity.

Qualification testing of personnel will be witnessed by QC personnel from the affected organizations to at least the same level as would be required during the production process to assure compliance to the procedures and accuracy of the test documentation and reports.

The Project Data Base will contain the current qualifications of site welding procedures, individual welder qualifications, and personnel training N

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i recordsa This information will . assist in assuring that welds are properly made by qualified welders caing correct procedures.

o PILOT PROGRAM

'A Pilot Program is being established in which the programs, procedures, and inspection requirements for safety-related work are applied to selected nonsafety-related SSCs. Use of the Pilot Program allows evaluation of processes, programs, and procedures and their modification or .developmer.t of new procedures as required.

o WORK PACKAGE PROGRAM Work packages are the primary means of controlling the construction work. Work pack <ges consist of the design drawings, construction inspection plan, instructions, checklists, construction aids, procedures, restrictions, precautions, and other pertinent documents or information required to

- complete a specific scope of work.

Work packages are planned and prepared using input

' status, from PVQC which identifies current nonconformances, and incomplete work in safety-related SSca. Identified rework and new work l

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resulting from design changes or new design also are s

, inputs to the preparation of work packages. All documents in the work package are kept current in accordance with approved procedurea. Procedures for the preparation, updating, and control of work packages are being prepared and the implementation of these procedures is the responsibility of Bechtel.-

Work packages are assigned to System Teams responsible for monitoring and completing the work.

t No work will be conducted without a release from PVQC .

indicating concurrence that the work will ,neither interfere with nor preempt the conduct of the PVQC.

I

• o CONSTRUCTION TESTING / TURNOVER .

The Project Test Program is being completely reviewed and upgraded. Test specifications and construction l

testing procedures are being reviewed and modified as l

necessary. Test sequences are being defined which l

! will establish construction completion priorities, i

Upon completion of construction and construction l

i testing, the systems, structures, or components (SSCs) will be turned over "to CGEE under an improved jurisdictional turnover procedure. Upon acceptance of an SSC by CGEE, a Post-Turnover Controls

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A Program will be ir.stituted to assure that no work is conducted on turned over 'SSCs unless authorized by CG&E.

o PROGRAM FOR THE CONTROL OF ACTIVITIES THROUGH INSTRUCTIONS, PROCEDURES, AND DRAWINGS A project program for control of activities through instructions, procedures, and drawings will be implemented. Activitfies affecting quality will be prescribed by documented instructions, procedures, or drawings, including revisions to existing documents.

Construction a' ids /1 sketches will identify governing design specifications and drawings and will be controlled where required, by project procedures.

Construction and inspection personnel are required to use only engineering approved drawings and specifications in the performance of construction and inspec' tion activities. The implementation of this program is integrated with several other CCP Programs including' the Work Package Program, the Document and Records Control Program, and the Project Procedures Program.

~

o INSPECTIONS Inspection programs are being restructured to assure that inspections are more closely coordinated with M

-19 construction activities which ,

will improve the s:onitoring of activitles af fecting quality.

l Hold points and witness points will be established to assist in assuring that required inspections or witnessing of activities are performed as required.

Additional redundant inspections and random i

surveillances will be performed as necessary to provide added verification of and confidence in the quality of work. Detailed planning will provide inspectors with the information necessary to perform comprehensive and complete inspection activities, o AUDIT PROGRAM l The Senior Vice, President - 'Nucl' ear Operations will have an independent audit performed at least annually by an outside organization to assess the effectiveness of the Project QA Program. The Senior Vice President will direct corrective action be taken on identified deficiencies and report the audit's findings to the ZOC and Owners Review Committee.

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This wi11 ensure that tho' adequacy of the Project QA Program will be periodically verified by an outside organization.

The Project Audit Program is being enhanced by -

expanding the independent audit of the PVQC to cover the QA/QC aspects of the CCP. CGEE will conduct audits to assess the adequacy and implementation of the QA Programs of all site organizations affecting I safety-related quality activities. Bechtel will conduct audits of its safety-related quality activities and of S&L, GE, and contractors under its direction. S&i., GE, and contractors will conduct audits of their organizations' safety-related quality activities. Audit Program requirements for all audits conducted by the aforelisted organizations (CGEE, Bechtel,. S&L, GE, and contractors) will provide for immediate reporting of nonconformances, noncompliances, and other deficiencies to Quality Program requirements, and identify remedial and corrective action (s) necessary to preclude recurrence of these conditions.

Audit emphasis will be placed, as a minimum, on ,

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Training Program, Corrective Action Program, Document Control Program, and Inspection Program activities.

Audit plans an.1 schedules will ensure that applicable c,

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aspects' of the Project Qua.lity ' Assurance Program are audited at least annually or during the life of the activity, whichever is shorter.

1.3.2* Implementation Of CCP

. The CCP will be implemented by' CG&E as Project Manager, Bechtel as Project Director and Constructor, S&L as Architect / Engineer, GE as NSSS supplier and fabricator, and contractors as necessary.

No safety-related construction will be performed

. until the applicable CCP programs, pro'cedures , and

~

training procrus are approved and in place.

Construction of safety-related SSCs will proceed, in accordance with the CCP, after it has been determined that such construction does not affect the conduct of the PVQC and that applicable procedures and QA programs are in place, as follows:

o Proceed, prior to lifting of the SCO, on approval by the NRC Regional Administrator in each case, with safety-related construction .

. rework which has already been defined and which can be done without impact on the conduct of the PVQC. Examples of such rework l

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are removal of coatings from containment steel and concrete, and correction of structural steel-bolted connections.

o Proceed, prior ,to lifting of the SCO, on approval of the NRC Regional Administrator in each case, with safety-related construction involving new work which can be done without impact on the conduct of the PVQC. 8ew work identified to date which may be in this category includes: installation of pipe supports, installation of support structure for the centrol rod drive .

mechanisms, and induction heating stress improvement of reactor coolant piping not previously treated. .

o When the information being gathered by the PVQC is ' completed for a system, subsystem, or area, a report of the results will be sent to the NRC Regional Administrator. A l

plan will be submitted , to the NRC Regional Administrator for approval to proceed with i

the construction work or rework identified by the PVQC, provided it does not conflict ,

1 with other PVQC activities.

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-e eLA e m_, - Qw 4 The safety-reU2ted work identified above is to be accomplished under the new and approved QA/QC Program.. To* the extent that the above-mentioned construction requires a relaxation ~ of the SCO pursuant to Section IV.B.(3) of thre order, CGEE will

! submit a request for relaxation when it seeks

, approval of specific construction activities.

Construction of nonsafety-related SSCs will continue as permitted by the SCO provided it does iot '

interfere with conduct of the PVQC. When the SCO is lifted, all construction will proceed in accordance with provisions of the CCP.

Work from the categories mentioned above is centrolled by preparing and using the Work Package Program, an essential element in the control of construction activity.

l l

1.4 INTERFACE WITH PLAN TO VERIFY THE QUALITY OF CONSTRUCTION (PVQC)

The PVQC process will identify work which must be l .

accomplished under the CCP including A3 complete work and work identified as a result of nonconforming conditions.

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l Construction of a system, subsystem, or area will be ,

controlled to assure that construction does not interfere with or preempt the conduct of the PVQC or impienentation of potential rework on systems or 4

areas for which verification has not been completed.

These controls, detailed in Section 7.2, include measures such as:

o Specific training of construction personnel

, regarding PVQC i,nterface restrictions.

o Surveillance of construction personnel to assure compliance with the PVQC interface restrictions.

o Frequent schedule meetings to coordinate interface activities of PVQC and CCP

) personnel.

o PVQC releasing specific portions of CCP. work based on evaluation and conclusion that a particular portion of CCP work will not t

interfere with PVQC activities.

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- Bechtel, as Project Director, has structured its organization to provide for separate management of activities under the PVQC and CCP. In short, Bechtel will devote sufficient manpower and management 1

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resources to the execution.. of b'oth the PVQC and the CCP to assure that each receives the degree of attention necessary for its successful execution.

1.5 PROGRAM RESULTS The CCP, under a fully defined and implemented QA Program, will result in the followings o Assurance that each nonconformance is -

dispositioned and appropriate corrective action is implemented.

o Assurance that needed rework, repair, or replacement of nonconforming SSCs is performed in accordance with approved design -

and procedures and with approved material.

t o Assurance that incomplete work is completed in accordance with approved designs, l

approved procedures, and with approved materials.

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o Provision for documentation of activities needed to complete work on SSCs and to repair, rework, or replace nonconforming SSCs.

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Accomplishment o of n'ew work, including nonsafety-related construction in accordance with approved design, approved procedures, and with approved material.

o Provision for requisite QA/QC records to CG&E to enable startup testing of the plant in compliance with regulations.

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2.0 ORGANIZATION AND PROJECT MANAGEMENT _

PLAN FOR REMAINING WORK 2.1 PROJECT MANAGEMENT Cincinnati Gas & Electric Co. (CG&E) management is committed to completing the Wm. H. Zimmer Nuclear .

Power Station (Zimmer) project in a manner which will provide a safe and reliable nuclear power plant constructed to high standards of quality, engineering

~

and construction, and in accordance with all applicable codes and regulations. To implement this commitment to quality. CGEE management is taking the following acticas i

j o Restructuring and strengthening CGEE's nuclear operations through a centralized

. Project organization with strengthened management and technical personnel.

o Previding for an independent audit of PVOC.

o Improving the- monitoring of the imple-mentation of the QA Programs by extending the duties of the PVQC Independent Auditor to include the QA/QC activities of the CCP.

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t, o Employing an experienced architect / engineer and constructor as project director and constructor to manage and. complete the remaining work, o Establishing a first-rate Quality Assurance

. (QA) Program.

o Develop!ng and implementing detailed plans for the completion of the work [ Plan to Verify the Quality of , Construction (PVQC) and Continuation of Construction Plan (CCP)3 o Providing for an independent design review.

l o Providing for the functioning- of the Zimmer Oversight Committee (ZOC) whose purpose is to l

provide the CGtaE Board of Directors with an f

indep,endent source of information and an l

i l' overview of all activities and operations associated with the completion of construction and transition to operation of the Wm. H.

Zimmer Nuclear Pcwer Station and on the basis of such overvir,w, "to advise the Board on policy matters affacting such activities and operations of the Zimmer project, and to ascertain that such policy is carried out e

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. and tnat adequate information is being provided to the' Board.

o Providing for the functioning of the Owners Review Committee (ORC) consisting of the Chief Executive Officers of Cincinnati Gas &

i Electric Company (CGEE), Columbus & Southern Ohio Electric Company (CESO), Dayton Power &

Light (DP&L), one purpose of which is to provide a source of advice and counsel to the Senior Vice President, Nuclear Operations in all matters materially affecting the project.

The Course of Action provides a well-defined division

- of responsibility (DOR) for the PVQC and CCP. (See Appendix 1.) The DOR was designed to maximize the ,

strengths of the major corporate participants with a restructured CGEE organization performing as Project i

Manager. The organizational structure, as depicted l

in Appendix 2, provides clear lines of communication and reporting relationships to senior CGEE management. This allows CG&E to provide strong

. leadership and exercise overall control and management of the project.

Management by objectives will be utilized with detail planning, monitoring, and control emphasized, and accountability strictly enforced. Achievement of e

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quality is the ' primary goal., Cost and schedule objectives are secondary to project quality. The Project ' Data Base (PDB) w'ill be used to monitor and track critical project activi.ty. Problems will be .

identified through the Project Control System and -

corrective action taken quickly.

o PRCUECT MANAGEMENT COMMUNICATION AND VISIBILITY Project management is to be kept cognizant of the status and progress of the project through review and approval of specified detailed plans, continuous involvement in construction, and a continuous review of quality, schedule, and cost. A =onthly review '

will address pertinent project , activities in progress, and a Monthly Progress Report to Corporate

- Management wi 1 be prepared following the review.

The Monthly Progress Report to Corporate Management i

will typically include a summary of project activities, a review of progress against the approved plan, and an analysis of problems detailing corrective actions, enacted or planne'd.

Project Management will meet periodically with the oversight and review groups listed in Section 2.1.1

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to review project activities and obtain the benefits of their counsel.

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b o CORP, ORATE MANAGEMENT COMMUNICATION AND VISIBILITY Corporate management will become cognizant of the-status and progress of the project through reports, meetings, and audits. They will attend project review meetings on a periodic basis. CG&E's Corporate Management also interfaces with the oversight and review groups listed in Section 2.1.1 to assure the effectiveness of the quality-related activities of Zimmer.

2.1.1 Overall Management I

CG&E establishes ' policy through its new management organization and provides overall management direction and overview of the entire project. The CG&E senior management organization is depicted in

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Appendix 3. CGEE establishes the policy and fundamental organizational structure which provides overall management and overviek of the' entire project.

A Zimmer Oversight Committee (ZOC) established by the CGEE Seard of Directors consisting of five members of the Board serves to provide to the Board, generally, independent oversight of kctivities at the Zimmer i

Project and to assist the Boar'd in the formulation of policy.

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The ZOC will: ,

o Provide to the Board an independent source of information and an overview for the, Board of all activities and operations associated with the completion of construction and transition to operation of the Wm. H. Zimmer Nuclear Power Station; and o Cn the basis of such overview, to advise the Board on policy matters affccting such activities and operations of the Zimmer Project, and to ascertain that such policy is carried out and that adequate infernation is being provided to the Board.

The ZOC will retain an advisory staff of professional technical advisors and at least 3 respected members of the community.

The primary function of the advisory staff, is to provide to the ZOC a high level of appraisal of the professional and technical aspects of the Zimmer Project, including the implementation of the Plan to Verify the Quality of Construction (PVQC) and the f Continuation of Construction Plan (CCP).

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The basic authority of the advisory staff is to review and recommend. It will take direction from and report to the ZOC and perform other related duties which the ZOC may direct. It shall have no .

authority to direct or require action. It will carry out its responsibility by making reports and recommendations to the ZOC.

The advisory staff shall meet once each month, or

, more often at the call of the Staff Director. The Senior Vice President, Nuclear Operations, or his designator, shall meet with the advisory staff monthly for the purpose of reporting en the pr0greer ,

and status of the Zimmer Project.

All reports and recommendations to the ZOC must be l i

presented to the ZOC in writing. The advisory staff is expected to reach consensus on all important issues.

• The Senior Vice President, Nuclear Operations, if the 1

I ZOC directs, wi1,1 respond formally to all recommendations. made by the advisory staff by informing the ZOC what action, if any, was taken, or l

explaining why a particular recommendation was not adopted.

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' An Owners Review Committ.ee consisting of the Chie,f Executive Officers of the ' Cincinnati Gas & Electric Company, Columbus & Southern Ohio Electric Company, and Dayton Power & Light, or their designees, normally will meet monthly at the Zina a' site. This committee will serve as a vahicle for obtaining and providing the owners . with information regarding the project. The committee has no responsibility for directing any project activity. The Senior Vice President, Nuclear Operations f rom time-to-time seeks the advice and counsel of the committee in matters materially affecting the project; informs the committee ,of the status of construction ,and of

( problems and other developments at the project site; and meets with the committee at such times as the committee may request. ,

work Independent Auditor, The scope of of the

' retained by CG&E to audit the conduct of the PVQC, has been expanded to include the OA/QC aspects of the CCP such that all QA/QC activities through completion of the plant are subject to independent audit.

An Independent Design Review of sufficient scope to evaluate Zimmer plant design will be performed ,by an organization different from the PVQC and CCP Independent. Auditor. The design review will be of sufficient depth to permit the reviewer to determine k.

if tho' design features under re' view meet the license application requirements. All Zimmer ceganizations

- will cooperate with the Zimmer ov.ersight Committee, owners Review Committee, the PVQC and CCP Independent ,

Auditor, and the Independent Design Review organization as required. .

Bechtel, as Project Director, manages Sargent &

Lundy's (S&L), General Electric's (GE) and contractors' CCP efforts related to Zimmer. Bechtel oversees the planning and performance of PVQC and CCP activities. Bechtel also assists CGEE in developing Quality Assurance / Quality Control (QA/QC) policies

. and procedures t and . monitors implementatien of the policies and procedures by S&L, GE, and contractors.

All of Bechtel's duties under the CCP are set forth in a comprehensive contract with the owners.

The organizations, management responsibilities, scopes of effort, and interfaces are defined between CGEE, Bechtel, S&L, GE, and contractors. Direct lines of communication will be established and maintained at management and working levels, thus

! assisting in the coordination and control of engineering and construction processes.

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2.1.2 Cincinnati Gas & Electric Company (CGEE)

The CGEE organization provides management control ,

from the Senior Vice President, Nuc' lear Operations through the Assistant Vice President, Nuclear

• Projects to Bechtel. The Manager of the Nuclear Construction Department, the Manager of Nuclear Project Controls, and the Manager of PVQC and Nuclear Prisject Support Services report to the Assistant Vice

President, Nuclear Projects. The three managers mentioned above, and their staffs, form the main i'nterface with their counterpart managers in

' Sechtel's organization.

CGEE will exercise continuous oversight of Bechtel as well as S&L, GE, and contractors. CGEE has the authority and the responsibility for setting policy for the project and for overall project management i

and direction. Bechtel will report directly to the Assistant Vice President, Nuclear Projects (CGEE Project Manager) for day-to-day resolution of problems and direction / guidance with direct access to l

the CGEE Senior Vice President for Nuclear Operations f

for prompt resolution of* differences that arise.

CGEE through its restructured QA, Construction, and l

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! Engineering Departments - will evaluate and oversee the performance of Bechtel to ensure that it is properly

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b and . professionally executing. its contractual responsibilities in accordance with CG&E's standards ,

and policies. Although management direction is as described, information contacts are not limited to

'the described chain of responsibility. .

2.1.3 Bechtel Power Corporatidn (Bechtel)

Under CG&E management control, Brachtel provides management, direction, and coordination to S&L, General Electric (GE), contractors, and vendors and will per form construction work as directed by CGEE.

. Bechtel's Site Project Director and Deputy Project Director provida direction to the Assistant Project Director for PVQC, Assistant Project Director for CCP/ the Manager of Engineering and Licensing, the Construction Manager, and the Manager of Controls and Services. Bechtel's Site Project Director will coordinate QA/QC activities through the Bechtel Manager of Quality. (See Appendix 4.)

These line managers are supported by the fdllowing groups:

i l

a. Project Engineering i b. Quality Assurance

c. Que.lity Control

d. Quality Engineering l

1 .

h .

e. Construction Supervision

f. Field Engineering

g. Schedule Control and Reporting

h. Cost Control and Reporting

i. Training

j. Personnel

k. Safety

1. Finance and Accounting

m. Procure'ent m

n. Contract Administration Bechtel's organization provides for the separate management of PVQC and CCP activities and takes adequate measures to prevent interference of the CCP l

with the PVQC. In addition, personnel assigned to

. perform the PVQC will have no other major responsibilities during the period in which they are working on the PVQC.

The Bechtel Manager of Engineering and Licensing, through Bechtel project engineers and their staffs, I

will manage completi,on of design engineering by S&L j

and contractors. Inter. faces will be provided between Bechtel and S&L, as required, to monitor and l

manage the design and design change processes covering all areas Cincluding the nuclear steam supply system (NSSS), and mechanical, electrical, and civil engineering disciplines]. Specific monitoring l .. -

.~ . _ _ _ __ _ _ _ . - _ _ _

l b of licensing requirements and configuration control will be provided.

Bechtel's Construction Manager, assisted by the Field Construction Manager. and staff, direct construction and manage contractors' construction activities.

(See Appendix 5.) The Field Construction Manager's staff consists of a Project Superintendent (CCP),

, responsible for the satisfactory completion of all construction activities, and a Project Field Engineering Manager, responsible for all field engineering activities. Also reporting to the Field Construction Manager are the Project Superintendent (services) and the Labor Relations Representative.

The Project Superintendent's (CCP) staff consists of a Project Systems Superintendent, a Field Superintendent, a Project' Field Engineer (CCP), and a Contraces Supervisor.

r The Project Systems Superintendent is responsible for managing the completion of systems, structures, or components utilizing teams as further described in Section 2.2. The Field Superintandent and staff are responsible for the overa5.1- supervision of the i crafts. The Project Field Engineer (CCP) 1.s responsible for the overall supervision of the field engineering activities associated with the CCP. The

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Project Field Engineer (CCP) reports to the Project Superintendent (CCP) for project direction and to the Project Field Engineering Manager for administrative and technical direction. The contracts Supervisor is responsible for the administration of contracts with other contractors.

1 e '

Project control responsibilities are provided by the Bechtel Manager of Controls and Services. Cost and schedule preparation, monitoring, and reporting engineering and construction progress is ,the responsibility of the Controls Group. The management of the Project Data Base is a primary responsibility of the controls Group. Interface with CGEE, S&L, Bechtel, and contractors by the Bechtel Controls ,

Group occurs at numerous levels of the respective l

l organizations. The data maintained by the Controls l

l- Group is used to support engineering, construction, and miscellaneous support groups.

QA, QC, and Quality Engineering (QE) functions are managed by the Bechtel , Manager of Quality who interfaces, through staf f members, with S&L, GE, and contractors' QA/QC managers and' staffs.

As Project Director, Bechtel manages and directs primary support functions which service total project t r *-- - ---rw----e.w-,-e

needs, such as the operation and maintenance of the Project D'ata Base, document control, scheduling, and cost reporting.

2.1.4 Sargent & Lundy (S&L)

• S&L's design engineering responsibility is discharged by the S&L Project Director. Supporting S&L's

- Project Director are S&L's Site Project Manager and QA Coordinator. The Bechtel Manager of Engineering and Licensing provides the S&L Project Director with direction for the design engineering effort in

.s support of the PVQC and CCP through turnover.

CGEE, through the Assistant Vice President, Nuclear Engineering, provides direction to the S&L Project Director for . . engineering activities other than PVOC and CCP.

Reporting to the S&L Project Director are the S&L Project Manager, assisted by the S&L Field Project Manager. S&L's Project Manager is responsible for providing the design criteria and translation of these criteria to design drawings and specifi-l cations. S&L's Field Project Manager prov. ides design clarification and design engineering support at the jobsite for the CCP. The S&L field organization will approve the disposition of nonconformances as

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required, resolve construction interferences, and providg resolutions to constructability problems as they arise. S&L field staff at the jobsite will .

provide timely responses for CCP and will interface with the S&L Home Office as required.

2.1.5 General Electric"(GE) .

tJnder Bechtel management direction, GE is responsible for the design and fabrication, including QA activities, of the NSSS. GE is represented at the jobsite by .the Resident Site Manager who reports to the GE Zimmer Project Manager in San Jose, l - California. Supporting the GE Recident Site Manager are a Site Electrical Engineer and a Site QA Engineer.

GE's primary interfaces are with the Bechtel Manager f of Enginmering and Licensing and S&L's Site Project l

f Manager. Coordination and communication interfaces l

l are maintained by GE's Resident Site Manager with the Bechtel Construction Manager.

l 9

2.2 SYST:MS COMPLETION APPROACH The Zimmer CCP will use , a systems completion approach under the direction of the Bechtel Project Systems Superint enden't. (See Appendix 6.) This management technique organizes the offort to complete remaining N-m------ w -%, , - . , . . _ _ _ , _ ,

work on a system, structure, or component. All elements required to support the turnovet of a plant N

system, structure, or component (SSC) are brought together under a System Team. Each System Team is made up of personnel from Bechtel, S&L, GE, and contractors as required.

The System . Team Leader under the direction of the ,

Bechtel Project System Superintendent organizes crafts, supervision, field engineering, scheduling,

. procurement, and construction testing resources into a team to schedule the remaining work, determine material needs, and track their procurement. The team also must determine and expedite necessary i

design req'uirements , expedite the resolutions of 1

nonconformances, and any other items required to complete the remaining worio. QC engineers are assigned to interface with the team to provide and coordinate timely inspections and documentation.

Members of a System Team are supported by discipline-

! oriented groups within the supervisory and field engineering areas to provide the numbers and mix of technical personnel required for a given system. A team may be responsible for several systems or areas. The assignment of systems and the makeup of the teams will be monitored and revised as necessary by construction management to comply with

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,,m 44-the project completion and tese.ing schedule dates.

The Project Data Base provides the , status ,of

remaining work, 'the availability of materials, and .

tracks the progress during the course of the work.

i l

. The System Team approach provides for interface between construction and engineering to support system turnovers. Working-level meetings to review progress on the completion of systems will include, as a minimum, Bechtel, StiL, and GE. This assures that project schedule needs are understood and are being addressed as required by all participants.

h Daily meetings will be conducted by the System Team Leader to identify probles Areas and schedule completion of outstanding work items. During the meeting, action items will be defined and individuals assigned responsibility for resolution. This meeting will coordi'nate all interface activities, identify j construction, procedural, material, design, and l

l documentation problems needing immediata attention.

These daily reviews will measure detailed Level IV

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Schedule contaitments against actual progress to ensure the proper resources are brought to bear on problem areas.

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As. -Project Directo g Bechtel interfaces with and surveys. all contractor activities to assure compliance with procedures 'and provide- support as required.

2.3 -QUALITY ASSURANCE / QUALITY CONTROL (QA/QC) ,

, , APPROACH ~

The' QA/QC approach provides a strengthened QA/QC organization.. Overall- responsibility for QA rests J

with CG&E. Under . the management of Bechtel and the .

oversight of CG&E, all construction organizacions are responsible for quality, compliance with regulations and commitments, and maintaining. a highly

. professional quality assurance atmosphere free of harassment or intimidation.

i Construction , turnover and - startup activities - will be performed by trained and qualified personnel to meet predefined acceptance criteria as set forth in g

approved procedures. Completed quality-related work will be inspected by the , performing organization's l

! QA/QC department. Turnover processes will be audited l

by Bechtel's and CG&E's Quality Assurance organizations.

l

_ ,.. _ _.___ . . . - _- _u . . _ _ _ - . _ _ _ _ . _ _ _ _ - - . . _ . . _ _ _ _ _ . . . _ . _ .

-46 .

The CG&E Assistant V ce President, QA reports directly to the CGEE Senior View President, Nuclear Operations and has a line of communication to the President and Chief Executive Officer of CGEE. The CGEE Manager of QA reports to the Assistant Vice

~

[

. President, QA. Reporting to the Manager of QA are staff groups responsible for quality engineering, inspections, audits, surveillance, corrective action and trending program, and operations. The CG&E QA organization sets the QA policies for the project and maintains surveillance and oversight of the QA activities of Bechtel, S&L, GE, and contractors.

The Bechtel Manager of Quality reports directly to the. Ann Arbor Power Division's Manager .o f Quality Assurance. Bechtel's Deputy Manager of Quality, the

. Project QA Engineer, the Project QC Manager, the Project Quality Engineer, the Procurement Supplier Quality Manager, and their staffs report to the Manager of Quality'. Bechtel's Manager of Qualitiy is responsible for Bechtel quality activities and coordinates them with Bechtel's P.roject Director.

The Manager of Quality is also responsible for the l surveillance, oversight, monitoring, and auditing of engineering, procurement, construction, and quality activities of S&L, GE, and all contractors.

l l

S&L's QA Coordinator has the responsibility for S&L's quality activities, receives direction from the S&L -

~

• Corporate Manager of QA, and coordinates S&L quality activities with the SEL Project Manager.

The QA managers of all project entities are responsible for adherence- to the CGEE QA policies

< established for the project. The site organizations as described in this section provide for a clear division of responsibilities among the organizations and within each organization. The QA managers have lines of communication between each other and coordinate their activities .with' eadh other. They will interface with each otner on a day-to-day basis r.t all levels. Interorganizat.ional QA Manager and Vice-Presidential level meetings will be held to discuss quality problems and program status.

All QA/QC personnel will be trained, qualified, and certified as required by relevant ANSI standards. - -

They and the construction' personnel will be made fully aware of the program to prevent harassment and intimidation of QA/QC personnel.

As additional assurance to CGEE management that the continuation of construction will proceed in accordance with the requisite QA/QC standards, the

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4 scope of work for the Independent Auditor for PVQC has been expanded to include the QA/QC aspects of CCP.

2.4 ORGANIZATIONAL RESULTS The organizational spproach for project management, system completion, and QA/QC will result in:

o A restructured management team consisting of a highly experienced and motivated senior management staff.

o The addition of Bechtel as Project Director -

and Constructor providing additional nuclear power plant construction experience.

o A clear definition of the r,esponsibilities an'd interfaces of all project organizations, o Complete control of the complction of systems, structures, and components by utilizing system teams.

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! o Resolution of interface problems between the l

l implementing activities permitting a more I

concentrated effort to be applied.

i o Management support of the QA/QC program.

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o Clear QA/QC communications with upper-level management and ensured greater iavolvement of Project Management in QA/QC matterra. -

o Strengthened QA/QC organizations.

o An independent audit of CCP QA/QC activities.

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5 9

3.0 GENERAL MANAGEMENT PROGRAM ELEMENTS 3.1 GENERAL This section describes' the major General Management Program Elements that must be met prior to continuing construction on safety-related work at the Wm. H.

Zimmer Nuclear Power Station ( Zirmer) . (See Appendix 7.)

The basic activities required to be completed prior to the restart of construction on safety-related work ares o Development of applicable programs and procedures required to control the continuation of construction such as the Plan to Verify the Quality of . Construction (PVCC) l Interface and Work Package Programs.

o Completion of any pertinent prerequisites and accomplishment of required corrective actions.

o Satisfactory completion of the Pilot Program.

(See Section 7.10.)

o Nuclear Regulatory Commission (NRC) approval to proceed with safety-related work.

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The following Continuation of Construction Plan (CCP) major elements must be implemented, as appropriate, prior to implementing the Pilot Program, preparing work packages, or continuing constructions o ' organization, including a substantially

- strengthened staff.

o Procedures and interfacing documents.

o Quality Assurance / Quality Control -(QA/QC)

Program.

o Training, qualification, and certification programs..

o Document and Records Management Program.

l f o Project Control Systems.

l o Configuration and Design Change Control

- Program, o Nonconformance Report (NCR) Program.

l o Corrective Action Program.

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o Work Package Program.

! o Welding /Special Processes-Program.

o Procurement and Material Control Programs, o Prevention of Harassment of QA Personnel Program.

, o Construction Testing Program.

o PVQC Interface Program.

o Pilot Program Definition.

o . Project Audit Program.

A Pilot Program (outlined in Section 7.10), using nonsafety-related systems, will be implemented to demonstrate that the CCP is effective in ensuring that safety-related work will be accomplished in conformance with design and regulatory requirements.

Prior to the commencement of each Pilot Program, the CCP major elements, programs, and procedures will be reviewed and a list developed and approv.ed of those elements required as prerequisites to commencing each i specific Pilot Program. All CCP elements are not applicable to each Pilot Program.

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The Pilot Program will exercire the programs, procedures, and control systems required for safety-related work including preparation of work packages, the training of personnel, the performance of physical work in accordance with approved procedures, and the performance of QC inspection in accordance with the Project Quality Program. *All work will be performed as if it were safety-related. ,

Audits and surveillances of the entire process will be conducted . in accordance with the Project Quality Program.

After the appropriate CCP major elements are in place, .work packages will be prepared, based on approved design documents, for incomplete ' work, new work, or work resulting from PVQC. The work packages

. will be reviewed to ensure that performance of the .

work will not interfere with or preempt the conduct of the PVQC or implementation of potential rework.

After submittal of the CCP to the NRC and the completion of the necessary CCP major elements, a j request will be made to the NRC to approve the' resumption of safety-related work which will not l impact che conduct of PVQC activity. Sources of work are:

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o Incomplete work . which is already a matter of record. .

o New work.

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o Rework previously identified.

o Work iden'tified by PVQC, Prior to complete implementation of the CCP, other specific safety-related work may proceed upon the successful completion of the Pilot Program, the availab,ility of the work packages, the eqmpletion of applicable prerequisites, and the approval of the NRC.

~3.2 INTERFACING DOCUMENT AND PROCEDURES HIERARCHY CGEE with assistance from Bechtel is developing and will issue a Zimmer Procedures Manual (ZPM) containing procedures for major functional processes i such as design control, procurement, construction, inspection, and quality assurance. The procedures will address the responsibilities and interfaces between CGEE, Bechtel, and major Zimmer contractors. .

Bechtel will provide a Bechtel Procedures Manual (BPM) for CGEE approval which will utilize the ZPM procedures directly wherever possible and provide

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1 additional details to define Bechtel-'s respon-sibilities. It will also supplement the ZPM description of the interface relationships between .

Bechtel and other p$oject entities.

Each contractor will develop procedures, including detailed work procedures, as required to fulfill their assigned responsibilities using elements of the ZPM and BPM. All procedures will meet the

• requirements of site hierarchical documents [e.g.,

CG&E's Final Safety Analysis Report (FSAR), CGEE's Project Quality Assurance Manual (PQAM), Bechtel's Nuclear Quality Assurance Manual (NOAM)], applicable regulatory guides, codes, standards, and other commitments. Bechtel is assessing adequacy and implementation of the procedures.

Bechtel, as Project Director, is managing a comprehensive Centralized Procedures Development

' Program which is based on experience at other nuclear projects, knowledge of nuclear QA programs, and regulatory requirements. This program will provide I identification of hierarchical relationships between procedures. (See Appendix 8. ) The program will also provide a method for maintaining commitssnt and hierrrchical control on a continuing basis and an administrative process for preparing, reviewing, and issuing procedures.

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A Procedures Development ' Group has been established ,

to organize the review and development process, analyze existing procedures, and identify new ,

procedures r.. quired to support the continuation of construction. Representatives from each major project organizEtion for each functional area (e.g.,

QA, construction, project controls) will perform review and stat'tsing functions for their respective area. Administrative support, technical support, and planning functions will be the responsibility of the Procedures Development Group.

l l

! A procedures data base will be the principal tool used by the project to ensure that procedures are maintained current with commitment and policy requirements.

i )

This program will provide an integrated, l

comprehensive management tool for assuring that the procedures carry out

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the commitments and policies established for the CCP.

3.3 PREVENTION OF HARASSMENT OF QA PERSONNEL I

l A formal, site-wide progra's is being established to prevent har'assment and intimidation of QA personnel and other personnel having quality concerns.

Harassment of personnel will not be tolerated at l

k 1

Zimmer. All QA organizations will report incidents of harassment to senior management within their respective companies. This includes CGEE, Bechtel, S&L, GE, and contractors. Personnel will be assured that they are free to perform their functions without fear of reprisals. All personnel have been or will be advised in writing o f, the antiharassment policy and the penalties regarding harassment of personnel.

These measures are described in training programs.

Any suspected or reported i:ase of harassment will be promptly investigated .;2 appropriately resolved.

Appropriate sanctions or disciplinary actions will be taken against those individuals engaging in harassment or intimidation.

Personnel who believe that they are the victim of harassment have an obligation to immediately report concerns about harassment to their supervisor, their company QA Department management, the CGEE QA Department management, or the Assistant Vice President, QA. If such concerns are not resolved, the individual should inform successively higher levels of managment, including the Senior Vice President, Nuclear Operations or 'the President of CGEE. The individual may also bring any harassment concerns to the attention of the NRC or its Resident Inspector.

- --- ~-. _

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concerns confidentially and CGEE will treat these There will give then . urgent, careful consideration.

be no reprisals, penalties, or discriminatory action for bringing forth such towar'd any individual concerns. ,

o 3.4 IDENTIFICATION OF CCP SAFETY-RELATED AND_

NONSAFETY-RELATED WORK both safety-related and The CCP will include nonsafety-related work.

and Incomplete Work on 3.4.1 Nonconformances Structures, or Safety-Related Systems, Components (SSCs) from PVQC The PVQC will identify discrepancies and incomplete work through the inspection of installed work and material receipt, storage, review of procurement, Any installation, and other related documentation.

nonconformances found will be documented on an NCR.

I The disposition of the NCR, any work (administrative -

from that disposition, and or physical) resulting by the PVQC will be incomplete work identified performed during the CCP.

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3.4.2 ' Rework Frce Quality Confirination Program Rework already identified by the Quality Confirmation Program (QCP) will be per for: sed during the CCP subject to the requirements ' established by PVQC, 3.4.3 New Work from Continuing Design' Analysis Work resulting from a continuing design analysis will be identified and performed during the CCP phase.

3.4.4 Known Incomplete Work Incomplete work which. is already a matter of raccrd will be performed during the CCP subject to the requirements established by PVQC.

3.4.5 Nonsafety-Related Work s

A list of nonsafety-related work will be prepared using various sources of information, such as records, inspections of existing , installations , and a review of design changes and new design requirements. -

3.5 PROJECT CONTRO5S PROGRAM Under CGEE's overall project management and direction, Bechtel will develop and implement a

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Projecti Controls Program.' . This program will consist of. a Project Plan, a process for monitoring and

- statusing progress relative to the plan, the identification of cost and schedule changes / trends, and a system to report that- status' to the project's management.

The Project Plan is outlined in the project forecast scope of the project, the which identifies the to-date and to-go costs, and the schedule for completion of the project. The Project Plan will be the framework for developing detailed project control systems once the project forecast has been reviewed and approved.

3.5.1 Project Scope Definition The detailed project scope is described by the design drawings, specifications, programs, and procedures in the project procedures manuals. A described forecast of remaining work on the project has been identified in the project forecast which Bechtel prepared. This completion forecast includes a cost estimate and' schedule which establishes the budget

'for remaining work. The technical scope evaluation an of incomplete work, was based on assessment N

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remaining design effort, expected new design requirements, and an ectimate of work required as a result of PVQC.

3.5.2 Project Scheduling l

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'The Project Schedule Program consists of a hierarchy of schedules. It makes the Project Plan clearly visible to the various levels of the site organization. The prcgram serves as a basis for monitoring progress against the Project Plan. This hierarchy of schedules consists of four levels.

The Level I, Milestone Schedule, establishes- major project milestones which form the basic schedule l framework for planning and integrating project engineering, procurement, construction, startup, and quality activities. This schedule will be reviewed and approve,d by CGEE's and Bechtel's senior managements and cannot be changed without their concurrence.

The Level II, Projec,t Summary Schedule, is an

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l integrated project summary, schedule of engineering, procurement, contruction, startup, and quality activities which expands the detail of the Level I t

I Schedule. The Level II Schedule will be placed on the Project Data Base and rescurce loaded as required.

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The Level III, Interm'ediate Schedule, will be developed wichin th6 framework of the Level II .

Schedule. The Level III Schedules will be bar charts, and/or time- or nontime-scaled-logic diag' rams. They will be resource or quantity loaded, if required: they form the framework for the more detailed daily work plans. The content and complexity of a Level III Schedule is determined by the associated scope of work which is typically a specific task, startup system, structure, or component.

' The Level IV, Working Schedule, will be the schedule used by project personnel to plan and perform work en a day-by-day basis. It is the most detailed schedule within the project schedule hierarchy and may take the form of bar charts or punchlists. The Level IV Schedule is a five-week schedule, updated weekly, which shows detailed work activities. The previous week,' current week, and upcoming three weeks are included.

Each of the schedule levels within the hierarchy provides a basis of progress review and reperting.

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3.5.3 Project Cost ,

The Project Completion Forecast, completed by Bechtel in October 1983, is an assessment of the project cost and schedule and provides a basis for all detailed l

budgets and controls including engineering costs, construction labor, nonmanual effort, quantities, equipment, material, con' tract, and CGEE costs.

3.5.4 Project Budgets The Project Budgets for scope, schedule, and cost provide a project management tool for tracking progress and monitoring the cost and schsdule performance of the project. ,

The budget defines, an expenditure and resource distribution plan for remaining work. The budget defines quantities, unit manhours, costs, total l ,

manhours, total dollars, and total time required to complete the project.

3.5.5 Continuous Monitoring

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j Management control through early corrective action is provided for by a program designed to allow a continuous monitoring of the scope, schedule, and l cost budgets.

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The remaining physical scope (quantities such as linear feet of pipe, number of connections, etc) is a key element in measuring progress. Installation of .

these quantities will be monitored on a facility and system basis.

l Inspection, verification, and ,

disposition of nonconforming condi.tions is another key factor in establishing the remaining scope. These processes ,

will also be tracked to assist in the evaluation of project status.

Tools for monitoring scope include the engineering control system. It divides engineering design activities into individual tasks and- monitors expenditures and progress against the plan.

The Project Data Base allows management to monitor scope changes by quantity tracking. Commodities to be tracked and statured' include structural steel, large and small pipes, instruments, hangers, pipe welds, cable footage and terminations, and raceways.

Commodities will be added to the Project Data Base

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for tracking as required.

The Project Data Base will also provide information on various key documents.

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l, 3.5.6 Finance and Accounting Actual ' project costs are incurred based on 'the .

expenditure of labor manhours, the purchase of material, and incurrence of other liabilities. The project Finance and Accounting Organization receives invoices, prepares payrolls, and dispenses checks.

'Bechtel will perform these activi. ties in a controlled manner and will provide information to the project Cast and Scheduling Organization for use in project monitoring and forecasting.

3.5.7 Labor, Material, and Document Tracking (Project Data Base)

As Project director, Bechtel will implement a Project Data Base (PDB). The PDB provides for tracking labor, material, documents, and statusing the integrated schedule. .

The document portion will be tracked in accordance with Sections 3.7.1, Construction Document Control, I

and 3.7.2, Construction ,

Records Control. Document tracking is accomplished using the tracking f'

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capabilities discussed in Section 3.5.5.

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L Material will be tracked' through the project in Sections 5.0, Engineerir g, 6.0, accordance with Procurement, and 7.0, Construction. Material tracking will be accomplished using the quantity tracking capabilities of the PDB.

o METHODOLOGY OF PROJECT DATA BASE DEVELOPMENT for successful operation of the The key element Project Control Program is the establishment and maintenance of the PDB. To be useful to all project entities, the data collected in the data base must be comprehensive, accurate, and timely. Project entities are being surveyed to determine th ir data '

requirements. These needs will be compared with the

• l requirements of the CCP, interfaces with other project entities, and the PDB's overall capability.

the determination of the project data After requirements, the Project Data Base will be developed and implemented. .

l l

0 MAINTENANCE OF THE PDB l

Once the PDB is in place, the responsibility for maintenance will be assigned to the originators and I users of the data. Data accuracy and quality will be I

! maintained by placing responsibility at its source I

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and holding each entity strictly accountable for the accuracy and timeliness of that information.

The project will use the Project Data lase to provide timely information on quality, scope, and schedule status. This will assist in the planning, performance, and control of the work associated with the project completion effort.

3.6 MANAGEMENT PROGRESS MEETINGS / REPORTS Effective project management is dependent on a system of timely communication of accurate project information which enables appropriate decision maning and necessary correct'ive action.

A Monthly Progress Meeting will be held to formally review project status. In addition, Project Management will meet whenever required to address project issues requiring action.

l A system of reports will use information from the 1

l management control systems and the PDB to provide CGEE's and Bechtel's managements with the information required to manage the completion of the project in an efficient and cost-effective manner while assuring that quality remains as the primary objective.

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3.6.1 Monthly Project Progress Re'p orts The primary management report for communicating the status of the project to CGEE management is the Monthly Project Progress Report.

The Monthly Progress Report addresses construction progress, quality of work, cost and schedule performance against budget and forecast levels, and provides identification of problems and proposed corrective action for effective completion of the plant.

' The Monthly Project Progress heport contains an executive summary with a project overview, a summary of quality activities, and a comparison of cost and schedule performance against the ' Continuation of Construction Plan.

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The summary is followed by a detailed presentation of the activities of the project entities including f

QA/QC, PVOC, CCP, Engineering and Licensing, Procurement, Cost and Schedule, Startup, and I Operations. ,

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These sections typically includes o An assessment of quality program status, trends, effectiveness, and audit results.

o A discussion of program status and current work activities.

o A discussion of problem areas and proposed corrective actions.

o Progress statistics to reflect current work activity such as nonconformance dispositions, e change control activity, work package activity, purchase orders and- quality verification inspection reports.

o Analysis of integrated project schedule progress and problem areas, cost analyses, and productivity assessment.

,3.6.2 Other Management Reports Other reports submitted periodically to CG&E will include:

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o The Project Trend' Repor - consolidates all identified cost and schedule trends against the project budgeted scope, cchedule, and cost.

o The Quarterly Update of the Project Milestone and Project Summary Schedules (Level I and II)

- provides visibility of schedule status on an ongoing basis.

o The Project Forecast - periodically reetaluates the total project cost and schedule, and results in an update of the budget.

(

o The Monthly Critical Items Action Report' identifies the critical areas on the project requiring management attention and assigns responsibilities for corrective action.

The reports listed above and the information l

contained therein provide the visibility required 'by i

CGEE's and Bechtel's managements to effectively manage the Zimmer project to construction completion, -

orderly turnover to CGEE, ar>d operation.

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3.7 CONSTRUCTION DOCUMENTS AND R5 CORDS MANAGEMENT PROGRAM o GENERAL The Construction Documents and Records Management Program defines all documents and recordt generated and/or used in the construction of Zimmer, describes i

the type of control required for these documents and 1

records during construction, ensures that the required level of control is maintained, and conducts ,

timely and orderly turnover of these documents and records in accordance with CGEE directives.

I.

A document is defined' as any written or pictorial information that may or may not be quality-affecting.

l A quality assurance document is an inprocess document that furnishes evidence of the . quality of items or a

activities affecting quality. A quality assurance record is a completed quality assurance document. It is considered complete when it has been processed and accepted by QA. A record is a document or correspondence retained specifically for proof or verification of an activity, usually stored or controlled for-future reference.

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a This Document and Records Management Program is established to:

o Create and maintain the Construction Records Control . System, which will include Construction Document Control and a Quality Records Vault.

o Conduct an inventory of construction documents and records.

o Establish a Project Documents List (PDL) by document category, o Maintain the Project Documents List (PDL) current as new documents are added.

o Identify and collect those documents and

records to be controlled in the Construction Records Control System.

o Provide consistent processing of all project documents and records.

o Utilize the Project Data Base for document and record tracking.

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i o Coordinate construction document .and record  !

control functions 'With bGEE plant operations to ensure smooth turnover of documents and records and transition of control activities. ,

o Ensure complete, controlled, and timely distribution of construction documents and records.

o Ensure that the document and records management procedures incorporate the requirements of applicable NRC Regulatory Guides and ANSI Standards.

o RESPONSIBILITY CGEE is responsible for o Providing an overview of the Documents and Records Management Program.

o Providing input for the development of the PDL.

o Defining the. documents and records turnover requirementc.

I o Providing documents and records as required for the continuation of construction.

• • -9M m,a we.M s 4 MQ9

As Project Director, Bechtel is responsible for managing: ,

o The development and maintenance of a PDL in coordination with CGEE, S&L, HJK, GE, and contractors.

o In conjunction with CG&E determine the organizations responsible for controlling categories of documents and records identified on the PDL.

o The establishment and maintenance of Construction Document Control.

o- The development ' and maintenance. of a Construction Document Distribution Schedule (CDDS). y S&L, HJF, GE, and contractors are responsible fort o Providing input for the development of the PDL.

o Providing documents and records as required

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for the continuation of construction.

' Participating the establishment of o in Construction Document Control.

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., j o CONSTRUCTION DOCUMENTS AND RECORDS CONTROL SYSTEMS The Project Document List (PDL) identifies all categories of documents and records such as location, originating company / department, approximate volume, quality- or nonquality-related, the group responsible for control, the scope and interval of documents and records turnover, and the final repository of documents and records after turnover.

The PDL identifies which documents are controlled in Construction Document Control, the Quality Records Vault, or those maintained and controlled by the originating companies / departments. A Document and Records Turnover Schedule will be developed based on the. System / Area Turnover Schedule and on PDL categories.

A Construction Document Distribution Schedule (CDDS) will be developed which defines the current required .

distribution of controlled documents.

3.7.1 Construction Document Control

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Documents are processed through Construction Document Control where they are formally received, registered, reproduced / distributed, filed, and surveyed as requircd.

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During receipt, every document is reviewed for legibil'ity and administrati've accuracy and ccepleteness. If incomplete or inaccurate, the document is returned to the originator for correction and resubmittal.

Each document or package of documents is registered to unsure retrievability and action item control.

Standard reports, which show the current status of documents and any outstanding actions, are pro,duced and distributed to the project.

For reproduction / distribution control, the CDDS is prepared and maintained by Construction Document Control. Construction Document Control is the control point for reproducing and d.istributing documents. The documents are distributed in accordance with the CDDS. Copies of documents are distributed to work packages and stick files. As new revisions are received, superseded revisions are physically removed from applicable work packages and stick files; they are replaced with the current applicable document.

Documents are filed by type of document. Access to document control files is limited to protect against loss or damage.

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Construction Document Control files are surveyed to

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ensure completeness a nd. . accuracy of files.

Appropriate action is taken to correct any discrepancies. Stick files and work packages, as well as other controlled documents, are surveyed by Construction Document Control and QA/QC personnel.

3.7.2 Construction Records Control The quality records are processed into a Quality Records Vault in accordance with procedures.

Procedural steps include receipt, indexing, distribution, filing, and storage.

Newly received records- will be reviewed for

! completeness and legibility. Incomplete records will be returned to the originator or responsible party

> for correction and resubmittal.

• indexed to ensure prompt Every record received is retrievability. The index is revised as necessary to reflect additions and deletions in the records files. This list of construction records will be maintained by Bechtel and turned over to CGEE control j upon final turnover of the SSC.

Distribution of record files is controlled, and distribution is limited to a published list.

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Records are filed in accordance with the record index and with ' detailed instructions. Records will be stored in accordance with ANSI N45.2.9 as endorsed by Regulatory Guide 1.38, Rev. 2 and amended by the FSAR, Appendix C.

3.7.3 Construction Documents and Records Turnover Bechtel turns over construction documents or records to CG&E in accordance with project requirements.

CG&E reviews and accepts or rejects the documents in writing. Acceptance is based on criteria established between CGEE, Bechtol, and contractors. Documents accepted by CG&E are sent to the appropriate repository.

3.8 TRAINING OF CCP PERSONNEL o GENERAL i

CG&E is issuing a directive to define the scope of all site training, including construction training activities. Training will be performed in accordance with this directive. It will address the training of project personnel including construction, operations, engineering, licensing, and QA/QC personnel, and will s

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identify the division of responsibilities between CG&E, Bechtel, SEL, GE, and ~ contractors for all areas ,

of training.

The directive defines:

o Requirements for the training programs for personnel at all levels.

i employee training, including o General indoctrination requirements for quality work.

o Responsibility for the preparation and implementation of the required programs,

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o Techniques for the development and selection of content of the required training programs.

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o Requirements for the development and selection I of content of the required training programs.

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establishment of o Requirements for the standards for instructor qualifications.

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establishment of o Requirements for the standards for training documentation and record retention.

k o Working relationships among organizations

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conducting training'activit'ies.

• This directive constitutes the basis upon which the Master Training Plan for the Zimmer project is being developed. The Master Training Plan provides an overview of all the training activities which must be accomplished to support key evolutions, events, or milestones in the construction and operation of the Zimmer project. .

CG&E will perform an in-depth review and analysis of the various Zimmer training programs and ensure that appropriate corrective actions are implemented to correct identified problems. CG&E will also monitor the overall training programs.

Bechtel will provide schedules of construction phase training for inclusion in the Master Training Plan, perform training as specified in the Master Training Plan, and approve and monitor the training programs of S&L, GE, and contractors. CG&E also monitors all construction site training.

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k o CCP PERSONNEL TRAINING Personnel assigned to the continuation of construction work will receive indoctrination and specific training commensurate with their assigned duties. This includes general training common to all personnel such as an historical review of the pr,oject; explanation of the unique requirements associated with construction of nuclear power plants, especially in the area of QA; emphasis on the importance which Project Management places on QA; an overview of the Project QA Program; a description of Project Management's position on harassment and intimidation and an explanation of procedures for reporting incidents of harassment and intimidation; and a description of procedures for reportable deficiencies pursuant to 10 CFR 50.55(e) and 10 CFR Part 21.

Upon assignment to the continuation of construction work, . employees will be notified of the required specific training applicable to their positions. The employee will be required to satisfactorily complete prerequisite training requirements prior to performing applicable CCP work. Training is provided according to discipline and job function. Training focuses on assuring knowledge of applicable procedures and proficiency in performing job I

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activities. Additionally, it emphasizes that the individual performing an &ctivith is responsible for the quality of the activity and that the individual has satisfied their responsibility for quality.

Centralized training will be ' performed when possible to eliminate duplication and possible confusion.

The CCP Training Program includes the following elements:

o Project personnel indoctrinated in Quality Program requirements prior to performing work.

o Training of each employee in current applicable manuals, standards, procedures, and associated requirements as specified by Bechtel, o Training performed to improve proficiency in areas identified in audits, trends, etc, as needing improvement.

1 o Training may, when required, consist of reading applicable " documents followed by written documentation that the employee hae l .

read and understands the documents.

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o Training may, when required, cousist of

'eading r applicable .docuNents followed by a documented review with the instructor or supervisor.

o Formal training classes, when required, conducted in compliance with a written lesson plan. The training classes may use lectures, video or cassette / slide presentations, or a combination thereof.

o Documentation of training.

o Mandatory periodic retraining and requalificaton of personnel. Revisions to procedures reviewed by the , approving 4

organization who recommends additional training as appropriate.

l Management and supervisory personnel are required t'o undergo appropriate training in procedures, job l proficiency skills, and management skills. This training provides managers and supervisors with methods and techniques to encourage communication and reporting of employee concerns related to the quality and safety of Zimmer and emphasizes the significance of individual employee contribution to site quality l

( and safety.

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A procedure is being developed that establishes require'ments for a training ]Isrogram evaluation by examinations, monitoring, and periodic evaluations.

Training Program materials are available for examination by the NRC.

3.9 FACILITIES An additional 160,000 square feet of construction and engineering office space is under construction to provide adequate support to PVOC and CCP activities.

Parking facilities are being enlarged and relocated in combination with a revised site access plan. A new craft change house and relocated brass alley (time office) are planned to further enhance jobsite facilities.

These additional facilities will result in less l

l congestion in the work areas, centralized support activities, and increased efficiency of operations.

The overall benefit of these facility and infrastructure improvements will be improved l coordination and communications between onsite i

! organizations charged with - the responsibility for the continuation of construction.

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\\ -85 3.10 AVOIDANCE OF PAST GENERIC PROBLEMS To avoid past generic problems, actions are continuing to o Identify past generic problems.

o List and analyze these problems for corrective action.

o Verify that the corrective action is effective and that the generic problem should not recur.

The methods.used to establish the program include: ,

o Analyses are being conducted of historical generic problems as documented in the SCO, NRC Evaluation Team Reports, reports of the

" National Board of Boiler and Pressure Vessel Inspectors, NRC Inspection Reports, Corrective

- Action Reports (CARS), Management Corrective Action Reports (MCARs), 50.55(e) Reports, and the COA. An historical generic problems list of the generic probl' ems is being developed and the problems identified to the applicable SSC or work activity and the root cause or program g

deficiency.

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o Allegations of past unsatisfactory workmanship will continue to b'e assessed, and action taken

'to address valid concerns.

o A licensing commitment list and the historical generic problems list, which includes identi- -

fication of programmatic improvements that must be incorporated into the implementing procedures, will serve as reference tools to help restructure the QA program and retrain project personnsl.

o These lists provide verification of the effectiveness of past corrective action to these generic problems, and are used to identify incomplete or indeterminate corrective action for further investigation / correction in the CCP.

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o In addition to the analysis and quantification

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• of software / system / generic problems, an analysis and verification of NRs that have been written against SSCs is being performed, with the corrective action verified through PVQC. This data 'will be included in the Deficiency Data Base (DDB) to permit tracking ,

and ev,aluation of future nonconformances according to past problems.

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3.11 TRACKING OF FUTURE NONCONFORH5NCES,

• IDENTIFICATION OF GENERIC PROBLEMS, AND CORRECTIVE ACTIONS Nonconformance Control System, A jobsite standard and Deficiency Trending Corrective Action System, System will be used to correct nonconforming work, identify gener'ic problems, and accomplish remedial or A description of these systems corrective action.

follows:

o The basic Nonconformance Control System will and implemented be established in the ZPM SEL's, GE's, and utilizing

• CG&E's , Bechtel's, procedures. These procedures contractors' implement a standard nonconformance form with standard data entries. Computer sorts will be used to track the status of nonconformances through verification and closecut.

i

• o The Corrective Action System ' wi1l be S&L's, GE's, documented in CGEE's, Bechtel's, and contractors' implementing procedures.

l This system will assure that deficiencies l .

\. identified in audit findings, CARS, and MCARs Corrective action will be are corrected.

L by QA personnel. For significant verified conditions adverse to quality, the corrective

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action will identify the cause and document the action taken to prevent recurrence. This cause will be checked against known generic problems to determine i f , they are recurring.

Nonconformances" will be screened for

. significant deficiencies, and where necessary, corrective action requests' will be initiated.

Potentially reportable deficiencies will ,

be reviewed according to the criteria established in 10 CFR 50.55(e) and 10 CFR Part 21 and as documented in CGEE's, Bechtel's, S&L's, GE's, and contractors' procedures. Any reportable conditions will be reported to the NRC by CGEE, as licensee, or its contractors, if eppropriate. Existing lists of 50.55(e) conditions will serve as reference tools to determine if previously reported conditions are recurring.

o The Deficiency Trending System requires review of applicable nonconformances for deficiency trends and the need for corrective action. If l corrective action is required for significant trends, it will be identified on standard forma and tracked .through completion and verification. Trend reports will be developed and submitted through Bechtel to CG&E management. These reports will provide CGEE

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7 management visibility of the Zimmer QA

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'P rogram's stattis 'and adequacyr the reports will also identify the status of generic

, problems. Trend Reports, NCR Punchlists, and Open-Item Lists serve as tracking ' mechanisms to assure that problems are corrected in a timely, effective manner.

3.12 GENERAL MANAGEMENT PROGRAM RESULTS Implementation of the General Management Program Elements, outlined in Section 3.0, that are required for the continuation of construction of safety-related work, will result int o Providing an integrated, comprehensive management system to assure that the

~

procedures are configured to the commitments and policies established for CCP.

Implementation will also provide substantially upgraded procedures to integrate, coordinate, and control the activities of all organizations.

o Ensuring that any quality-related concerns are brought to the attention of the proper level in the project organization without fear of reprisal.

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o Identifying the remaining work so that it can be" properly planned, control'l'ed, and completed.

o . Adding a Project Data Base to maintain project information and an integrated planning and scheduling process.

o Initiating comprehensive management reports that provide the required visibility of essential information to al.1 levels of management.

o Implementing additional controls for project elements such as budgets, plans, schedules, manpower, costs, finances,.and accounting.

o Centralizing the management of documents and records, identifying controlled documents in a document register, and distributing controlled documents and revisions in accordance with the Construction Master Distribution Schedule, o Timely and accurate distribution of documents to stick files and work packages to assure that construction work is planned and performed in accordance with the most recent issue of design documents.

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o Timely reproduction and turnaround of documents required of'r const'ruction.

o complete and accurate files containing current documents and all outstanding changes.

o, Providing personnel training programs, with partigular emphasis on the quality requirements of Zimmer.

o Improving the management and control of training.

o Training of personnel in their specialized areas with particular emphasis on management and supervisory training.

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l o Increasing the level of knowledge and l competency of personnel associated with the l

CCP.

o Ensuring that past generic problems are identified, corrective actions implemented, i

and that such actions are effective.

o Providing improved means to identify future t

generic problems, track trends, and ensure j timely corrective actions.

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4.0 QA PROGRAM ELEMENTS NOTE: THIS SECTION DOES NOT APPLY TO THE INDEPENDENT AUDITOR PERFORMING THE AUDITING OF THE QA/QC ASPECTS OF THE CCP. AS PREVIOUSLY STATED IN SECTION 1.1 THE INDEPENDENT AUDITOR OF THE PVQC WILL ALSO AUDIT THE QA/QC ASPECTS OF THE CCP SUCH THAT ALL QA/QC ACTIVITIES THROUGH COMPLETION OF THE PLANT ARE SUBJECT TO INDEPENDENT AUDIT. THE " PROTOCOL GOVERNING COMMUNICATIONS BETWEEN CGEE AND INDEPENDENT

, ORGANIZATIONS CONDUCTING REVIEWS OR AUDITS UNDER THE COMMISSION'S ORDER" AS PRESCRIBED BY THE NRC WILL BE UTILIZED TO ENSURE AN " ARM'S LENGTH" RELATIONSHIP BETWEEN CGEE, BECHTEL, AND THE INDEPENDENT AUDITOR.

4.1 PROGRAM OVERVIEW 4 .1.1 - Program Hierarchy All CCP quality-affecting activities shall be performed in accordance with QA programs approved by CG&E. These programs implement the criteria of 10 CFR 50, Appendix B, ANSI N45.2, as endorsed by Regulatory Guide 1.28, Rev 2 and amended by FSAR,

- Appendix C, and other applicable regulatory l

requirements.

The CCP QA program also implements Chapter 17.1 of

. the Zimmer Final Safety Analysis Report (FSAR) and the commitments in the Course of Action (COA), as follows:

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o Chapter 17.1 of the'FSAR provides the overall commitments which CGEE, Bechtel, and contractors are implementing to meet Appendix B to 10 CFR 50, and other regulatory requirements (ANSI N45.2, as endorsed by Regulatory Guide 1.28, Rev 2 and amended by FSAR, Appendix C, and applicable regulatory guides).

e o CGEE has established in the PQAM the project policy direction which CGEE, Bechtel, and contractors will implement in their programs and implementing procedures.

o .Bechtel's NOAM provides programmatic requirements which Bechtel must include in its implementing procedures to perform its -

quality-relat'ed tasks and further delineates requirements for other implementing organir.ations.

t o The ZPM provides standard project procedures regarding nonconformance control, training, O

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.. audits, and other processes which esch implementing organlzation (CGEE, Bechtel, S&L, GE, and contractors) must use in providing further details in their implementing procedures as required.

o Project implementing procedures provide the detailed descriptions of the work activities

. and the responsible personnel for performing all quality-related tasks.

4.1.2 Key Program Controls The following key controls are being implemented at all levels of the program prior to continuation of construction:

o Documented descriptions of the duties and authorities of all organizations and groups performing activities affecting quality.

o Prerequisite qualification training of project personnel performing activities affecting quality. Inspection and audit personnel

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qualified and certified as required by applicable codes and standards.

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o Adequate detailed . . procedures providing for

' implementation of activitius affecting quality.

.o Project procedures for reviewing and documenting potentially reportable conditions.

o Qualified procedures and personnel for controlling applicable special processes.

o Standard nonconformance reporting and processing system.

o Standard corrective action programs which assure implementation of appropriate and timely corrective action for significant conditions adverse to quality.

> o Management information systems to permit assessment of the adequacy and effectiveness of quality programs.

o Standard audit procedures and reporting practices to assure thorough and effective coverage of quality-related activities.

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4.2 PROGRAM REVIEvi AND APPROVAL ' -

CGLE reviews and approves the QA programs for contractors, Bechtel,- S&L and GE. As Project Director, Bechtel will be responsible for assuring implementation of the QA programs of S&L, GE, and contractors. Bechtel reviews, requests changes as required, and recommends acceptance to CGEE of S&L's, GE's, and contractors' QA programs. In addition, Bechtel reviews and recommends changes, as necessary, to CGEE's QA Program. CG&E approves Bechtel's QA Program implementing procedures and Bechtel approves contractors', SEL's and GE's QA Program implementing

. procedures.

.l 4.3 DIVISION OF RESPONSIBILITY The assignment of responsibility between organizations participating in the total quality program for ~ Zimmer has been established in the Division of Responsibility (DOR) (See Appendix 1).

Responsibilities are further described in QA program manuals. A summary of responsibilities follows.

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4.3.1 CGEE CG&E has described its QA Program responsibilities l and those of other implementing organizations in its l

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PQAM. CGLE has overall responsibility for QA activities at Zimmer from _an owner-licensee overview .

standpoint. These responsibilities are depicted in the DOR. Procedures will describe the overall interface responsibilities of the various CG&E

, internal organizations -and other project organizations. CGEE has the authority to direct specific actions to strengthen the contractor's QA programs at all levels.

4.3.2 Bechtel Bechtel has described the QA responsibilities of its various departments in its Nuclear QA Manual (NOAM).

Bechtel has responsibility for:

o Management of S&L, GE, and all contractors performing activities in accordance with the y CGEE approved QA Program.

. o Conducting its own activities in accordance l

with approved procedures.

o Review of the QA Program policy manuals of S&L, GE, and all contractors, making

! recommendations to CGEE regarding approval.

[

Bechtel approves S&L's, GE's and contractors' implementing procedures.

4.3.3 S&L As the Architect / Engineer, S&L has described the QA responsibilities of its various organizations in the S&L Quality Assurance Manual (QAM). S&L has the responsibility for performing its design activities ,

at Zimmer in accordance with its QAM and implementing ,

procedures. These procedures are approved by Bechtel prior to use during the continuation of construction.

4.3.4 other Organizations The Nuclear Steam Supply System (NSSS) supplier, GE, will implement their quality and all contractors responsibilities as appropriate to their scope of work end assigned activities in accordance with policy manuals and site procedures approved by l

Bechtel.

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I' 4.4 MAJOR PROGRAM ELEMENTS

! The CCP QA Program provides' the necessary provisions implementing organizations' manuals and in the

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procedures to comply with each of the applicable elements of Appendix B to 10 CFR 5b'.

The program is described in detail in Chapter 17.1 of the FSAR and the other program documents listed in Section 4.1.

The following elements characterize the CCP QA program at each level:

4.4.1 Procedures Implementing procedures will include elements such as the followings o- Mandatory requirements and, where feasible, standardized formats for the administrative and operational QA/QC controle and reporting mechanisms.

b o Controls for such activities as NCRs, CARS, MCARs, training, qualification, certification, trending, and reporting, o Controls for operati$ns such as installation, inspection, testing, storage and handling,

! material issue, auditing, and surveillance.

1

. . . . . _ . . . . . , _ . . . _ - .~ . . _ . . . . . _ . _ _ . . . _ _ . . _ _

-100-o Basic requirements of the - project QA Pr.ogram

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in terms of witness ' and hold points, checklists, and standards of compliance.

o Details of internal activities and controls necessary to ensure compliance to QA Program requirements by others, o Provisions for approval by Bechtel's QA organization of Bechtel's, S&L's, GE's, and contractor's quality-related procedures prior to their implementation.

4.4.2 Training and Qualification The coordination and management of .all site indoctrination, training, and qualification is included in a comprehensive training plan for Zimmer as described in Section 3.8. This plan, as it relates to the QA Program, includes items such ar. the following:

l o General project indoctrination and training to provide an overall knowledge of the project QA Program to ensure "that personnel performing quality-related activities are cogn.zant of

-101-the total ,

project commitments and the programmatic requirements.

o Training programs established by each CCP QA organization to ensure proper personnel ,

training in the requirements of the CCP procedures and their own detailed procedures.

o Qualification of inspection, surveillance, and audit personnel in accordance with applicable NRC regulatory guide commitments listed in FSAR, Appendix C, o Qualification of percannel performing special processes such as welding and NDE in accordance with applicable codes, standards, and programmatic requirements such as Society of Nondestructive Testing TC-1A, and The American Society of Mechanical Engineers s

j (ASME)Section IX.

4.4.3 Inspection

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Inspections shall be performed according to approved l: procedures and checklistr. Each organization I

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-102-performing safety-related work activities shall provide- QA/QC surveillance.. and monitoring of those work activities. Inspection shall be performed by personnel qualified and certified in accordance with ANSI N45.2.6 as endorsed by Regulatory Guide 1.58, Rev 1 and amended by FSAR, Appendix C.

The following further describes the Inspection Program:

o As the responsible construction organization on the project, Bechtel performs verification inspections of its construction activities according .to specification and procedure requirements.

o Bechtel performs surveillance and overview inspections of S&L's, GE's, and contractors' work to determine, from an adequate sample of work activities, that CCP work is accompliched according to documented requirements.

o CG&E performs random surveillance and redundant inspections of overall project activities to assure 'that all project entities are complying with their QA programs.

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-103-o Inspection procedures and checklists contain or reference the acc'eptance criteria, witness and hold points, and indicate inspections f required.

4.4.4 Nonconformance Reportirig A standard jobsite Nonconformance Reporting System is being implemented. This system includes a standard nonconformance form, proper disposition of nonconformances, and the tracking and statusing of NCRs through the entire lifecycle of the nonconformance. (See Appendix 10.)

4.4.5 Audit Program The Project Audit Program includes audits to assess the effectiveness of the Project QA Program. The overall Project Audit Program will be implemented, in part, by each QA organir.ation.,

of all quality-related activities will be Audits performed according to a Project Master Audit Plan.

This plan will cover the 18 criteria of Appendix B to 10 CFR 50, Appendix B, and other program requirements as follows:

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-104-o Audit plans and schedules will be consistent wi'th the size and complekity of the audit units and will consider the results of outside audits and items identified by the Corrective Action Program.

o CG&E will conduct audits to assess the adequacy and implementation of the QA programs.

o Bechtel will conduct audits of itself, S&L, GE, and contractors under its direction to verify compliance with QA Program requirements.

o S&L, GE, and contractors will audit their activities in a manner similar to Bechtel.

o All audits will be performed according to approved procedures and checklists.

o Auditors will be qualified and certified to ANSI N45*.2.23 as endorsed by Regulatory Guide l 1.146, Rev 0.

o Audit. findings will be followed up to assure

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-105-o Audits conducted by CG&E, Bechtel, S&L, GE, and contractors will provide for immediate reporting of nonconformances, noncompliance and other deficiencies ' to Quality Program

. requirements and identify remedial corrective action (s) necessary to preclude recurrence of noncompliance conditions.

o The Audit Program will include periodic verification that the criteria of the working level quality-related procedures conform to the PGt ? w.t.uitments and the ZPM. Audit emphasis will be placed, as a minimum, on Training Programs, Corrective Action Programs, Document Control Programs, and Inspection Program activities, o Audit Plans and Schedules assure that all aspects of the Project QA Program are audited at least annually or during the life of the activity, whichever is shorter.

o Audit Reports will be distributed to management up to the CGEE Vice . Presidential level. The Audit Program will include criteria to assure timely responses to the Audit Finding Report.

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-106-4.4.6 Monitoring and Surve,illance, CGEE and Bechtel will conduct preplanned and selective monitoring and surveillance of their internal programs and contractor program activities to provide an added level of asscrance of compliance with- QA program implementation. These monitoring activities will be conducted on selected construction activities and will be documented according to approved procedures. Special emphasis will be placed on known generic problem areas which have been identified in generic deficiency reports.

4.4.7 Stop Work l-l The CG&E Assistant Vice President for QA and the CG&E .

Manager, Quality Assurance Department have the authority and responsibility to stop nonconforming activities and the further processing of deficient materials or itsms. They have been assigned the authority and have organizational freedom from direct i

pressures of cost / schedule necessary to fulfill their responsibilities with no conflict of interest.

, The Zimmer Stop Work procedures further allow for limited stop work authority as assigned by the

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-107-Manager - Quality Assurance Department for inspection ,

personnel on the specific task or activity being inspected in accordance with project procedures.

Supervisors and directors may then stop work on an entire task or activity based upon evaluation of the inspector's findings.

Stop work authority for other construction related organizations is provided in the Bechtel program and procedures.

Corrective Action and Deficiency Trending 4.4.8 Program d

A separate group in CGEE's Quality Assurance Department has been established to perform evaluation, tracking, and trend analysis of deficiencies and corrective action.

Corrective Acti,on Program will be f An overall I

implemented by all organizations to: 1) identify and document conditior.s adverse' to quality, 2) correct significant- conditions adverse to quality to preclude recurrence, 3) report to the NRC significant reportable in accordance with 10 CFR conditions 50.55(e) and 10 CFR Part 21, and 4) to identify and correct generic problems.

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-108-The program is summarized as follows: . ,

o The tracking and control of corrective actions for conditions adverse to quality will be effected by the use of corrective action documents such as CARS and MCARs.

. o Corrective action forms provide for the documentation of the deficiency, the identification of its cause, and the corrective action to preclude recurrence.

o These docilments are issued to Bechtel and CGEsE management as appropriate, and are " summarized in management reports.- .

. o Deficiency codes will be used to assist in the computerized tracking, statusing, and trending of nonconformances and corrective action documents.-

4.4.9 Management Meetings .

QA. Management Meetings will "be conducted to naaintain high visibility of the adequacy and effectiveness of the QA Program. These includes

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-109-o Inter-organizational QA managers' meetings will be held at least once before any major multi-organizational activity starts, at least weekly during the program planning / development stages and at least monthly af ter the start of the activity, o Monthly meetings between the Senior Vice President -

Nuclear Operations and his Lasistant Vice Presidents will be held to discuss quality problems and program status.

m o Periodic meetings within SEL's, GE's, and ,

contractors' organizations to review quality status.

o Periodic koetings between CGEE Senior Vice President, Nuclear Operations and QA and Project Management of CGGE and Bechtel.

o Periodic meetings between Bechtel and the Assistant Vice President, Nde. ear Projects.

o Verbal presentation' of CGtaE Annual Management to the President, CGhE, Audit status

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-110-4.4.10 QA Management Reports -

QA Management Reports will be generated to provide management with an overview of significant activities, major problems,- and the general visibility of the status, adequacy, and effectiver.ess of the QA Program. All contractors will develop internal reports and will provide summary status reports to the next higher level for input into CG&E reports. The following are typical of these reports:

o Reports addressing the status of items such as NCRs, inspection reports, CARS, MCARs, significant audit finding reports and 50.55(e) reports to management up to the level of President, CG&E. These will elso address, where appropriate, root caases and actions to preclude recurrence.

o Executive Summary reports to upper management of the adequacy of the Quality Program f implementation including open major i deficiencies, trends, results of audits, and timeliness of processing and resolving deficiency documents. These shall also direct attention to areas requiring management attention.

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-111-o Reports of trends of ..significant or recurring nonconformances ' including determinations of need for action to preclude recurrence.

4.5 CONSTRUCTION RELATED CONSIDERATIONS OF THE PROGRAM 4.5.1 QA Interface with Construction Related Activities .

To assure timely implementation of the QA requirements, it is essential that the construction related activities interfacing with QA be clearly defined. The QA organizations of CGEE, Bechtel,.S&L, ,

GE, and contractors will coordinate activities with construction and maintain awareness of construction related activities by:

o Reviewing preparation of safety-related construction work packages to assure that the applicable QA Program witness / hold points are incorporated within the work packages.

o Surveillance of construction related activities and routine discussions between QA,

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112-engineerinrJ, procurement, and'~ construction personnel. .

o Frequent " meetings to' coordinate QA with construction related activities.

l o Establishing witness / hold points as necessary to monitor and survey construction related activities at critical points of the engineering, procurement, and' construction process.

4.5.2 Tracking Construction Related Quality The project quality organizations maintain control and keep cognizant of construction related quality by

' the following measures:

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o Direct inspection by Bechtel's, S&L's, GE's, and contractors' quality organiza, tion for the work performed by that organization.

o Sele.cted redundant inspections and surveillance of the implementation of- S&L's, GE's, and contractor's quality programs by Bechtel.

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-113-o QA* audits of construction related activities.

o QA audits, surveillances, and redundant inspections by CG&E of some of Bechtel's activities as Project Director and Constructor.

o Audits by CG&E of all Zimmer organizations.

o Re' view of NCRs, trehding reports, and audit reports.

o Review of progress and status reports.

4.6 QA PROGRAM RESULTS

, The elements and benefits of the CCP QA Program include: )

o An effective, quality organizational structure l .

using appropriately trained and qualified l

personnel who will work from comprehensive procedures. These constitute the primary means for achieving the QA Program objectives and commitments.

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-114-o Controls being exercised at the CG&E management level to monitor overall QA Program implementation and advise CGEE top management of the status and adequacy of the program.

.l o Effective management support of the QA Program and clear management ccamunications.

o Coordination of QA and construction activities.

o An accurate verification of the quality of the l

work.

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-115-5.0 ENGINEERING PROGRAM ELEMENTS 5.1 GENERAL The purpose of the Engineering Program is to provide a system for overall management and control of the engineering process for the CCP. Each responsible design engineering organization will contr,o1 'i ts internal documentation; compliance with codes, standards, and regulatory commitments; the quality

'and design criteria of its work; and all other .,

aspects of its engineering and design process. The activities of design engineering organizations related to the CCP will be managed by Bechtel as the E'oject Director.

The Engineering Program will be developed so that:

o codes, standards, regulatory, and other design requirements are identified and properly implemented.

l o Engineering procedures are formulated, developed, and implemented to- adequately accomplish design and design control s,

requirements.

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-116-o Nonconformances are resolved in a manner consistent with the primary project objective of quality.

o Engineering activities are performed in. a controlled,, efficient, and timely manner.

o Design documents prepared' for construction are both complete and timely, to meet project needs.

o Configuration and design change control is maintained thoroughout the preparation of

' design documents.

o Engineering activities are monitored and audited for quality and conformance to requirements.

These objectives will be achieved through:

o Strengthening management of design engineering.

o Providing improved management systems involving all project entities in the areas of configuration and design change control.

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-117- 1 o Providing project-wide management systems to

. process and disposition NCRs, including requirements for prompt action on those conditions considered reportable.

o Preparation and monitoring of engineering work Litns that identify ths tasks and schedules of design engineering organizations.

o Supplying timely reports on the engineering program, and provi, ding regular reviews of the program to senior management.

o Providing a isignificantly increased engineering staff that is commensurate with the requirements for timely support of the construction activities, including i

cenfiguration and design change control.

Specifically, the SsiL site organization will be staffed with personnel of appropriate skill levels and authority to effectively process and approve construction related design changes.

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,o CENERAL The Engineeri,ng Procedures Program will provide procedures to support those engineering tasks required for continuation of construction and turnover of plant systems and documentation. These engineering-related procedures will comply with project requirements including tho following: .

i l o Applicable codes, standards, FSAR, nuclear licensing, other regulatory requirements, and ,

CGEE design criteria.

o The Project Quality Program including the PQAM and NQAM.

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o Zimmer Procedures Manual (ZPM).

o Bechtel Procedures Manual (BPM).

o S&L Procedures.

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-119-o RESPONSIBILITIES CGEE is responsible fort ,

o Issuing the ZPM.

o Reviewing and approving the Bechtel Procedures Manual (BPM).

o Assuring that CG&E engineering activities are conducted in accordance with the approved procedures.

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. o Monitoring the engineering activities of

.Bechtel, S&L, GE , and other design engineering organizations for compliance. with project procedures.

1 o Approval of design modifications as desdribed t

. in Section 5.3.

Bechtel engineering,is responsible for l

o Assir, ting in the development of the engineering portions of the ZPM.

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-120-o Developing the engineering portions of the BPM for CG&E approval.

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o Reviewing, approving, and monitoring the implementation and control procedures of the design engineering organizations for compliance with the ZPM and BPM, including interface requirements.

o Monitoring. engineering quality criteria for compliance with required codes, regulations, standards, and overall project objectives.

o Managing the planning and execution of the engineering work by design engineering organizations and requiring that the - work be performed in accordance with project procedures and, controls and in a timely manner to meet project needs.

Other design engineering organizations (S&L, GE, and others) are responsible for o Reviewing and revising, as necessary, their implementation procedures for compliance and consistency with the approved ZPM and BPM, and for defining interfaces with other project organizations.

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o Revising their impi mentation procedures and instructions as required to strengthen their internal control. .

o Ensuring that their procedures and instructions define the quality criteria of the work, within their area of responsibility.

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l o Ensuring that their engineering activities, interface communications with other project organizations, and work planning are conducted .

in a timely manner in accordance with the approved implementation procedures and instructions.

5.3 CONFIGURATIOh AND DESIGN CHANGE CONTROL ,

l l o GENERAL -

t The primary objective of the configuration control l

l process is to provide an effective system for tracking, retrieving, and statusing documentation and its related hardware. The process will support the completion and turnover of plant systems, preoperational testing, and startup. Tracking and l

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-122-control of documentation and hardware, including changes, will be accomplished:

o To support and manage an orderly completion of construction.

i o To support scheduled turnover of systems, subsystems, or components (SSCs) and related documents to CGEE for preoperational testing Tnd startup in accordance with design requirements.

l o To assure that the status of constructed ,SSCs relative to design requirements is known in order to maintain control and assure consistency of construction with design.

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The primary objective of the design change control

. process is to control the decisions and actions related to design changes. The approval of changes will be based on' engineering evaluation of their impact on the project's quality, technical, and operational objectives and criteria. Actions taken will be properly controlled and documented from inception through implementation.

During construction completion and turnover of systems to CGEE, and during preoperational testing

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i -123-and startup, strict configuration and design change management - will be enforced. As , Project Director, Bechtel will be responsible for management of the Configuration Control, Design Change Control, and

, Turnover Programs. As part of ' this management responsibility, Bechtel will make recommendations to CGEE for engineering staffing levels which will be commensurate with the schedule requirements.

o CONFIGURATION CONTROL configuration control is the process for ensuring that the configuration (documentation and hardware) of the plant is known and traceable at all times and .

that the design, construction,. and startup system scoping. documents are " consistent. Configuration

' control will be ensured by implementing required design, construction, startup, and quality procedures. The Project Data Base (PDB) will be used as a communication and reference tool for identifying configuration status and will provide the tool by which design drawings and documents, design I revisions, nonconformance reports, and other related quality documents will be tracked and identities such as cross-referenced to hardware system, structure or component. Those sntities e

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-124-responsible for the origin or revision of the data will maintain the data current and accurate for use by engineering, PVQC, . construction, construction

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testing / turnover, and CG&E preoperational testing and etartup. Exception reports for management will

, provide an overview of key, activities and will i

display trends of potential emerging problems, such

• t as changes delayed in processing, or dispositioning, and as-built drawing backlogs.

o DESIGN CHANGE CONTROL Changes can originate from new design requirements, z

dispositioning of nonconformances, and the process of implementing the remaining design requiromants.

Revision's to the design documents and constructor requested design changes will be subject to the same I review and approval authority as the original design.

The control of proposed changes to design documents is achieved using tne-following basic processes.

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l o Project Change Requests (PCRs) - Major changes shall be proposed, documented, and controlled using PCRs. These ' constitute changes in design criteria, or changes which require

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-125-either the addition or modification of a piece 4

of equipment, or affect basic system performance and/or functional logic, or change essential requirements, or change .

configuration of structures. All other changes are considered minor. (See DDCN below.) A PCR can be initiated by any cognizant project entity and will be submitted to S&L for conceptual evaluation, with a copy to CGEE. This conceptual evaluation will include a review of the technical and quality

. requirements and the resulting project impact. The results of the conceptual evaluation will be reviewed for concurrence by Bechtel and approved by CG&E. Af ter , approval, the responsible design organizations will and

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proceed with detailed design required document revisions. GE will review and evaluate those changes which have potential effect on tne NSSS. (See Appendix 11.)

Construction is not authorized to proceed until detailed design has been completed and approved, except as specified in CGEE approved procedures.

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o Design Document Change Notices (DDCNs) - Minor changes shall be proposed, documented, and s

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-126-controlled using DDCNs. These constitute all

. other changes which are not classified as major changes (PCRs). A DDCN may be initiated ,

by any cognizant project entity and will be submitted to S&L for determination that the change is properly the subject of a DDCN and does not require a PCR, and for review / approval. The associated design documents will be revised when required. GE will review and evaluate those changes having potential effect on the NSSS. Construction is not authorized to proceed until detailed design has been completed and approved, except as specified in CG&E approved procedures.

o Design Change Packages (DCPs) -

In order to

- . facilitate implementation of late changes and to maintain configuration control, CGEE, with a recommendation from Bechtel, will institute the Design Change Package Program as the system turnover 'date approaches. The DCP will contain all documents and data required for the complete change and will provide the basis for the associated construction work package (s). Generally, those changes which will potentially impact, or be impacted by, the turnover schedule will be packaged into a

, DCP. CGEE and Bechtel will review the change

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-127-4 to determine when i,t should be performed and whether the change should be packaged as a DCP or processed as a normal change. At CG&E's option, installation of the change may be deferred beyond turnover. Configurr. tion control is assured as design documents are issued with the Design Change Package. To support this process, related data is

, maintained on the PDB. These control techniques have been sucessfully used on other projects and are a primary tool in the overall Configuration and Change Control Program.

(See Appendix 11.)

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o.. Field Disposition Instructions (FDIs) and Field Deviation Disposition Requests (FDDRs) -

FDIs are initiated by GE *(home office) and FDDRs are issued by GE (field). They are used to document proposed changes affecting the NSSS systems. The proposed changes will be integrated in the project change control system as a part of the PCR,or DDCN process, depending on the nature of the change.

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-128-

$.4 NONCONFORMANCE DISPOSITION PROCESS

,A single, project-wide procedure will ccntrol and document nonconformances. This ,

procedure will require NCRs to be 'dispositioned as REWORK, REJECT, REPAIR, or USE-AS-IS.

REPAIR and USE-AS-IS dispositions require approval by the ' responsible engineering organization. Approved dispositions will require either a design change or a determination that the as-constructed condition meets design requirements. Unapproved dispositions will be returned to the originating organization.

REWORK and REJECT dispositions shall be provided by the cognizant field engineering organization with disposition concurrence provided by their designated quality entity. The cognizant field engineering organization may also recommend REPAIR and USE-AS-IS dispositions to the responsible engineering organization for approval.

Nonconformance disposition analyses will be documented in accordance With project procedures.

NCRs will also be reviewed for potential reportability as required by 10 CFR 50.55(e) and l -

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-129-10 CFR Part 21. NCRs dispositioned by the responsible engineering, organization will be monitored by Bachtel. Bechtel may require reconsideration of the disposition by the responsibis design engineer. .

Dispositions requiring rework or repair in gccordance with design requirements will be directed to the responsible construction organization in accordance ,

with project procedures. (See Appendix 10 for an overview of the NCR process.)

5.5. CONTROL OF ENGINEERING SPECIFICATIONS

• AND DRAWINGS .

Project procedures define the responsibilities for the control of the project engineering design ,

specifications and drawings. They address the transfer of documents from the responsible engineering organization to the Constructor and contractors, engineering reviews and approvals, the control of engineering documents during systems completion, and as-built drawings.

CGEE will oversee the process of control of engineering specifications and drawings.

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As Project Director, Bechtel is responsible for managing the following engineering activities, with all engineering and design organizations responsible ,

for implementation'of the requirements delineated:

o ENGINEERING DOCUMENT FLOW l The engineering document flow process requirements and responsibilities for the interfaces between CGEE, Bechtel, S&L, and contractors will .be managed by Bechtel. Procedures covering the review and approval process, flow and distribution of design and supplier documents and construction aids will. require that the mo. :. racant applicatia design infornation is available for use by the project in a controlled manner. The Project Data Base will referance the effective revisions of the document. '

o ENGINEERING REVIEWS l

l The review and approval of document revision and l

updating will be performed in accordance .with project procedures. , This process, under Bechtel surveillance, will require that approved changes are incorporated into the basic design ' documents, and l

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-131-that system, structure, or , component (SSC) configuration is in conformance with design drawings and specifications.

The primary objectives of the review and approval process of design documents, procedures, and supplier documents will be quality and conformance to project requirements.

for the preparation of design The procedure documents, including reviews and approvals, will provide the basis for Bechtel surveillance and audit $

applicable codes, and will require conformance to standards, FSAR, and regulatory requirements.

o DESIGN COMPLETION AND SYSTEM TURNOVER INTERFACE During design completion and system turnover, Bechtel remaining sngineering work for will monitor the and timely close out of design and completeness As turnover of a SSC documentation activities.

approaches, Bechtel will perform a detailed review of open engineering items and require corrective actions l

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-132-5.6 ENGINEERING PROGRAM RESULTS 1

. l The overall Engineering Program for the Continuation l of Construction Plan (Section 5.0) will result in ,

improvements in: ,

o configuration and design change control. .

o Resolution of NCRs. through a process that requires documentation of engineering decisions. -

o Performance of the administrative aspects 'of angi.. caring in : c:::ntrclled annner.

o Design control of engineering documents from design criteria through implementation. .

o completion of design, final documentation of design, and turnover of documents to CGEE in the as-built configuration.

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-133-l 6.0 PROCUREMENT AND MATERIAL CONTROL PROGRAM ELEMENTS

-o GENZRAL Procurement includes requisitioning, purchasing, expediting (onsite and in ' the manufacturer's shop),

source surveillance and audits, warehousing (receiving, r'eceipt inspection, storage, maintenance, issue, material control), and related interfacing functions (cons'truction equipment, tool control, preventative maintenance).

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Material control consists of systems and processes used to control and track material, including inventory management.

Installed components .and materials for safety-related systems will be supported by the proper documentation and approoriate traceability. The processes used to purchase and control these items, both before shipment and after they arrive on the site, will be controlled and monitored as necessary to ensure conformance by all organizations and individuals.

All procurement and material control functions will be implemented in accordance with the program described hereinafter and as shown in Appendix 12.

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-134- l o PURPOSE The purpose of this program is to assure that material , acquisition, receipt, storage and issue processes that meet the' requirements for nuclear l

power plant . construction and operation are in place prior to the performance of related activities in the CCP.

o RESPONSIBILITIES CGEE will manage the overall procurement functions .

and perform procurement services.

Bechtel, as Project Director, will manage construction and S&L, GE and contractor / subcontractor procurement services, perform procurement services as requested by CGEE, review the existing purchase and material control program (s), and assure that necessary program changes are implemented.

Contractors will perform procurement services as

! required by contract / subcontract or as requested by i

CGEE.

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S&L will provide technical and quality support to procurement functions, in'cluding' review of vendor documents and the preparation of technicii and quality documents required to' purchase and control items.

6.1 PROCEDURES Existing procurement-related procedures and methods are being reviewed by Bechtel to determins adequacy.

These procedures will be modified or replaced, as required, by the responsible organization, to ensure that an adequate program is. implemented. New or modified procedures will be approved by the responsible organization's (i.e., CG&E's, Bechtel's, SEL's, GE's, or contractors') technical and QA/QC functions. Final approval will be obtained from Bechtel and/or CGEE, as required, inc.uding technical' and QA/QC review. Procedures will be issued and training / instruction given to all participating and interfacing organizations and individuals before program implementation.

6.2 ONHAND MATERIALS ,

The PVQC will review the documentation of safety-related equipment and material in storage to determine whether the purchased material meets the t y-e.% my,y _

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-136- .

requirements of the design drawings, specifications, and documentation requirements. As defined in the PVQC Program, where the purchase documentation

. reviews indicate the material on hand meets the requirements, material will be inspected or tested as appropriate to confirm the documentation is correct.

The physical ites will be reviewed against the applicable documents to determine if P.he onhand materia'Is are acceptable. If the physical item is in good condition, appropriately traceable, obtained from an acceptable source, and supported with the proper documentation, the item will be so identified in accordance with the applicable procedure. This entire process will be performed under the project Quality Program.

Questionable items (items which may or may not be acceptable) will be identified and segregated in accordance with project procedures. Unacceptable l

items will be identified with a clearly identifiable marking and processed as required. Segregation in storage will be provided to minimize inadvertent issue. Suitable inside and . outside hold areas will be established, clearly identified, and controlled by QA/QC. ASME items will be separated from non-ASME items.

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-137-6.3 INVENTORY CONTROL Present inYentory control systems wil'1 be reviewed to determine the adequacy of control and information on file. The system will be modified or replaced, as approved by CG&E, to assure data quality and timeliness are obtained and controlled. After implementation of system improvements, the material status from Section 6.2 will be entered into the system.

Past information from the original system is being .

reviewed and, upon determination of accuracy, will be entered into the inventory control system for historical purposes. Past records will be retained in inactive storage for historical purposes.

6.4 STORAGE AND ISSUE OF MATERIAL Storage methods and facilities are being reviewed to determine their adequacy in providing segregated,

. controlled storage which is environmentally suitable for the type of items stored. Issue methods will be reviewed to determine if . issue is controlled satisfactorily by the installing and warehousing organization and to assure that the proper item is i -

issued for the desired installation . Procedures are being modified or added to assure that proper l

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-138-storage and issuance' is occurring at each location.

~..

Facilities will be modified or added to provide -

'- proper skorage.

. 6.5 gyNTIFICATIOtt OF MATERIAL NEEDED (SHORTAGE LISTS)

Existing CGEE,. S&L, HJK, and contractor reports and lists are being reviewed to identify required materials and equipment, including presently identified repair or replacement items. A list of remaining materials required (material s,tatus report) is being developed. The inventory developed pursuant to the qualifications activity in PVQC and the resultant disposition of the material, combined with the list of remaining material requirements, will be used to develop lists of items needed for an adequate -

inventory. (See Section 6.2.)

l 6.6 IDENTIFICATION OF REQUIREMENTS AND COMPLETION OF REQUISITIONS l

l Upon determination of the need for an item for permanent plant installation, including calibrated t

tools, the 'i nstalling or designing organization prepares a requisition with ' supporting I

l

-139-specifications, drawings, shop inspection requirements, documentation requirements, and receipt inspection requirements. Originating engineering and

'QA/QC organizations review the requisition, as appropriate, for conformance to engineering specification and quality requirements.

Preparation cf requisitions will be performed and/or monitored by Bechtel. This review includes technical and QA/QC reviews to assure the item being requested is correct and to the proper quality class. All requisitions determined to be incorrect will be returned to the originator, corrected, and subjected to the same approvals as the original.

4 Bechtel monitors the preparation program (s) and prescribes corrective action to asstkre that organizations initiating requisitions - completely incorporate the technical and quality requirements.

s 6.7 PURCHASING .

Purchasing, gives final approval of the requisition after review for accuracy and completeness, check of

!- the existing inventory, and . rate of usage. Questions i

are resolved through Enginaering and Quality l

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-140-organizations as appropriate. If changes to the requisition are required, it,will be returned to the originator and subjected to the same. approvals as the original. After all questions are resolved, purchasing will proceed.

Upon receipt of quotations, purchasing will obtain engineering, QA/QC, and construction review as necessary to ensure the item being purchased meets technical and quality requirements. When the evaluation process is complete, purchasing- will prepare the purchase order for award and obtain QA/QC

^

approval, as required, before placement of the order.

t l

Vendors supplying material, components, equipment, or services for safety re, lated SSCs will have a QA program which has been reviewed and approved by CG&E and will be audited and surveyed by CG r.E or the ,

contractor responsible for the activity. Objective l' evidence of qualification by an independent organization (i.e., ASME certification or audit repcrt from CASE) may be accepted in lieu of the qualification survey, but ,does not relieve the requirement for audits during performance of the l

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-141-activity. , Qualification of vendors will be in accordance with the requirements of ANSI N45.2.13 and Regulatory Guide 1.123.

Be"chtel will monitor the purchasing process to assure that appropriate procedures are followed.

6.8 SOURCE SURVEILLANCE AND AUDITS The need for source surveillance and audits will be determined to assure that the item is supplied to project requirements. This determination will be based on QA technical, documentation and schedule requirements, and manufacturing capability and performance. Criteria for source surveill'ance and audits, will be based upon the. technical needs of the project, typical standards for similar items, and manufacturer performance. ,

Inspection and witness points will be established and documented for the activities being performed by vendors commensurate with the degree of complexity and the importance to safety. of the item or service being provided. Inspections or surveillances will be performed at these times by qualified personnel from CG&E or organizations acting as agents for CG&E.

P e . . . s . . . . .

-142-Requisitions and pQrchase orders will include source surveillance and audit requirements requested by engineering and reviewed by QA. Source surveillance and audits are being performed by organizations and individuals qualified to perform the service.

Appropriate surveillance and audit re' ports are being sent to the applicable project organization. Audits of this program will be performed by QA.

As Project Director, Bechtel monitors this program to verify conformance to the criteria established, the qualifications of personnel, and that the program achieves the desired results.

6.9 EXPEDITING All requisitions and purchase orders are assigned a .

site need-date. Expediters ensure that items and associated required documentation arrive in accordance with committed shipment dates and/or with project site need-dates. Expediters expedite internal and external organizations and individuals as necessary until the item (s) are received at the project. This may include expediting of the design, requisitioning, purchasing, manufacturing, and shipping.

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-143-Expeditors input to and prioritize *their activities using the material status report and other schedule-ind.icating ' ,

documents. A Procurement critical Items Report will be published indicating schedule and work activity impacting items and will be distributed to all project- organizations for

.' information and action as appropriate.

6.10 RECEIVING AND RECEIPT INSPECTION Three types of acceptance criteria will be developed for use. They are commercial criteria by procurement, technical criteria by engineering, and quality criteria by engineering and QA/QC.

Procurement performs commercial and ' technical inspection as required to ascertain that the item recei.ved is what was purchased, that it was.

manufactured ir. accordance with industry standards

! acceptable to the, project, and that no damag.e was incurred in transit or handling. If required, engineering assists in the technical inspection.

QA/QC performs technical and, quality inspections for safety-related items, including a review of the l

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-144-

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documentation and' a comparison

'-of the documentation , l l

to the physical item. If necessary, assistance will l be obtained from engineering.

All safety-related ' items will be inspected including unique identifications, examination of heat numbers, heat codes, part or catalog numbers, nameplate data and tags to assure that all items received are properly identified and traceable.

Handling during receipt will be in accordance with t

handling instructions developed from the t

l manufacturer's recommendations, engineering -

requirements, and indistry practice. ,

i Upon receipt, items are placed in a receiving area, stored to the proper level, with safety-related items removed only upon release by QA/QC. Items may be stored in other appropriate areas if properly l

identified regarding their receipt inspection status. . .

If during the receiving process an item cannot be accepted because of missing documentation or a i

noaconforming condition, th+ item is tagged on QA/QC l hold and moved to the hold area, if necessary, to l

preclude its inadvertent use.

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-145-6.11 STORAGE AND WAREHOUSING A site system for material control is being established to control all material, equipment, a,nd components during warehousing, transfer, and installation. CG&E monitors compliance with this program by all site organizations. This program provides for identification and traceability of the ,

item to the installation and certification documents for the item and to the purchase order or vendor in accordance with requirements.

Items will be stored in accordance with engineering requirements, the proper levels of housekeeping, fire ,

protection, and security and segregated to the extent necessary to preclude inadvertent issue. Hold areas will be established for controlled storage of items and location identification established for all i

inside and outside stored items to accurately locate items for inventory control purposes. QA/QC monitors storage of safety-related materials and items identified as nonconforming during the storage process are tagged by QA/QC and moved to a hold area, as necessary, to preclude inadvertent use. Items on

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-146-  !

hold can be released o'ly by QA/QC. Items requiring separatio'n during storage are separated under a controlled procedure with QA/QC surveillance. A controlled process is used to ensure required identification is maintained when material is divided.

6.12 MATERIAL ISSUE Materials will be issued only upon receipt of a properly and completely filled out withdrawal slip.

All withdrawal slips must contain the signature and construction organization of the person requesting the item (s) and approval of the engineer responsible for the work. Withdrawal slips must- also contain the following information as a minimum: quantity desired, size and description, material composition a'nd grade, quality class, location where material is to be installed, and system' and location to which the item is to be delivered. Identification to the associated work package is included where required.

Upon receipt of the withdrawal slip at the storage area, the item is issued only after the withdrawal slip is reviewed for adequacy and accuracy and approved by warehouse supervision.

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-147-Issue personnel will obtain the item from inventory, transcribe unique identifications such as heat number or code to the withdrawal slip, and sign it. The Person receiving the item also signs the withdrawal slip.

m In instances where upgrading of material for use in safety-related applications is determined to be required, material is inspected and tested, in accordance with an approved upgraded program, meeting the requirements of ANSI N45.2.13, to confirm the acceptability of material for .the application. The upgrades of such material in a safety-related application will be approved by CG&E QA to ensure that a proper. level of control has been established.

The construction organization to whom safety-related material is issned is responsible for identification and control of the material from issue through installation, in accordance with appropriately approved procedures which are compatible and consistent with the centralized standard material identification and control system.

QA/QC monitors the. Issue Program on safety-related items.

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-148-

• l 6.13 PROCUREME?JT AND MATERIAL CONTROL PROGRAM RESULTS The Procurement and Material Control Program will result in: ,

- j o Effective procurement procedures and controls, o A controlled Requisitioning and Purchasing Program.

o Purchase sources that are qualified and monitored.

o Proper receipt, storage, and issue control.

o Attention to schedules and priorities. .

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o Traceability of safety-related items to the l

point of origin.

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-149-7.0 CONSTRUCTION PROGRAM ELEMENTS The Construction Program is designed to ensure that Zimmer is built in accordance with the applicable codes and regulations, NRC regulatory guides and standards, drawings, and specifications. Programs covered by this portion of the CCP include:

Construction Procedures Program, the Work Package Program, the Welding Program, the Construction Testing Program, the Preoperation Turnover Program, j l

the Post-Turnover Control Program, and a Pilot l . Program for checkout of organizations, programs, and procedures prior to restart of safety-related work.

7.1 CONSTRUC" ION PROCEDURES PROGRAM i '

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Administrative and construction procedures will be l

developed for each major work activity (e.g., work l l

package control, pipe hanger installation, weld i l

inspection) assuring that programmatic and technical l l

requirements are incorporated. (See Appendix 13.) 1 Procedures will be developed in accordance with the Zimmer Procedures Manual (ZPM) and the Bechtel l Procedures Manual (BPM). -

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-150-7.1.1 Administration ,

The Construction Procedures Program as required by the ZPM and the BPM will be administered by Bechtal.

These procedures will be developed and approved by CGEE, Bechtel, S&L, GE, and contractors as required.

will be approved by Bechtel, the The procedures cognizant quality organizations and, if required, CG&E, S&L, and GE . As Project Director, Bechtel will review, surveil, and audit the implementation of these procedures to verify that the procedures meet the applicable requirements.

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7.1.2 Construction Work Procedures Construction work procedures are being developed based on the requirements of the ZPM, BPM, Quality I

~

Program, applicable S&L design requirements, good construction practice, and the requirements of codes and standards. These procedures are used to perform and control the remaining activities on the project.

The types of construction work procedures required inclu'de general work precedures, specific work procr.dures (by discipline, commodity, or work operation), and special process procedures.

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7. .- - . . . .

-151-Examples of construction work procedures are: pipe installation, hanger , installation, electric cable installation, equipment alignment, and hydrostatic testing.

7.2 PVQC INTERFACE l The PVQC process will identify work which must be accomplished during the continuation of construction, r 8

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including incomplete work and work identified as a result of nonconforming conditions.

1 Construction of a system, subsystem, or area is controlled to ensure that construction does not interfere with or preempt the conduct of the PVQC or implementation of potential rework on systems or areas for which verification has not been completed.

These controls include measures such as l identification of specific items which are subject only to construction activities, identification of specific items which are not subject to construction activities, and where appropriate, identification of specific items which should not be used for physical support of construction personnel or' otherwise contacted physically. These controls also provide for specific training of construction personnel in

. the above restrictions and surveillance of

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-152-construction personnel to, assure. compliance with the above restrictions. Should it become necessary, the controls may include restricting access of

• construction personnel to certain sectors of the plant.

Specific controls of the interface with PVQC consist of the following: .

e o Continuous interfacing of PVQC and CCP personnel to determine current status and priorities.

, o Frequent meetings to coordinate interface ,

activities of PVQC and CCP personnel.,

3o Utilizing integrated PVOC and CCP schedules reflecting the work plans of each group.

o PVQC releasing specific portions of CCP work based on evaluation and conclusion that they will not interfere with PVQC activities. This r'elease will be based on appropriate evaluations to assure that the determination has been made in a controlled manner.

C If a generic deficiency is identified after construction has resumed on certain systems,

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-153-subsystems or areas, ,

its , applicability to or areas construction on such systems, subsystems, will be determined. If the generic deficiency is determined to be applicable,- CG&E takes whatever action may be necessary, up to and. including a stop work order, to identify and segregate existing items that may be deficient and to prevent propagation of additional deficiencies in new construction pending determination of appropriate corrective action. CGEE l

promptly informs the NRC of the existence of any such generic deficiency and the actions taken in response to its discovery.

As described in the PVQC, individuals assigned to perform PVQC under the Project Director, Bechtel, are dedicated full time- to the PVQC and will have no responsibility. Furthermore, Bechtel as the other >

Project Director has structured its organization to provide for separate management .of activities utider the PVQC and the CCP. In short, sufficient panpower and management resources are being devoted te the execution of both the PVQC and the CCP to ensure that ,

each receives the degree of attention necessary for each program's successful execution. .

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-154-l 7.3 WORK PACKAGE PROGRAM '

The Work Package Program is the primary method for controlling both safety-related and nonsafety-related construction to assure that specified units of work are completed in conformance with the latest applicable procedures, drawings, and specifications.

Work packages also help control the required inspections and associated documentation and provida a basis for scheduling woric.

Work packages will be .kept current with the most recent applicable information and/or documents.

Bechtel vill prepara and monitor the Work ' Package 7

Program for its work and will monitor the preparation and implementation of the Work Package Program of contractors so that procedural requirements are enforced and the program is controlled. A flow diagram of the process for preparing work packages is, detailed in Appendix 14.

7.3.1 Definition and Scope -

All work defined in Section 3.4 is divided into discrete items for the purpose of planning and performing remaining project work efficiently. A work package is prepared consisting of information required to complete the work item. It also assists

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-155-in assuring that the necessa'ry inspections and i d;cuments are completed. Sections 7.3.2 through 7.3.6 describe activities performed during the development of the work package. Section 7.3.7 describes how the work package is used in the construction process.

The scope of a work package varies by SSC and plant area. For some SSCs or areas, the work package scope is an individual component such as a single large pipe hanger, piece of equipment, or concrete placeae.nt. In some instances, the work package scope i

is a group of components such as all small pipe, fittings, and supports associated with a small pipe t isometric or a group of terminations in .a certain i

panel. In other cases, it will reflect a defined scope of work in a certain area such as coating application in the drywell or all of the conduit in a certain area. The scope of a work package can vary due to di*fferences in complexity, criticality, PVQC interface constraints, or requirements to assign work to several crews. Bechtel is establishing work package guidelines by discipline and commodity.

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-156-7.3.2 Drawings, Specifications, anii~ Initial Work Package Development Work package development is started as soon as remaining work is identified, as described in Section 3.4. Work package development and based on the PVQC, implementation is being construction, and test schedules. (See Appendix 14.)

For each work package, a checklist is completed in accordance with applicable procedures. The checklist defines requirements for the work package including i

the quality classification, special instructions, testing requirements, material availability, and list of documents included in the package. The current applicable revision of the required documents (drawings, DDCNs, DCPs, NCRs, etc) is placed in a work package. Any special precautions or restrictions pertaining to the work, such as those required by PVQC, will be included in the work j

package.

In addition to the work package procedures, specific guidelines will be developed on a commodity-by-j commodity basis to provide assistance to work package assemblers regarding possible interface problems and potential situations that should be checked during constructcbility reviews.

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-157-4 An initial evaluation of planned work is performed by personnel familiar with the plant area in question to identify potential problems and special requirements.

Existing work packages will be reviewed by Bechtel prior to their use to assure that they possess all the necessary CCP attributes.

7.3.3 Material Requirements and Availability Material requirements and availability are determined during work package ,

development. Requisitions are prepared to obtain material not on order or available on site. In general, work packages are not released until all required material is identified and i available. Exceptions can be made if major portions of the work package can be cc'mpleted pending receipt of required material. Material will be purchased,

- received, and_ issued as described in Section 6.0.

7.3.4 Welding Requirements During preparation of work packages requiring welding, the welding engineers determine the welding requirements from the current design documents. The

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welding engineers identify and prepare the necessary welding instructions. The instructions will specify

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-158-requirements such as the weld procedure; preweld and postweld heat 'treatmehts; filler material requirements; and inspection requirements. These documents are placed in the work package. The work

. package is reviewed' by QA/QC and/or other entities such as the Authorized Nuclear Inspector (ANI), as required, for the establishment of witness or ~ hold points.

Pertinent weld documents are retained in the' worl package during construction. Work package preparation, inprocess work, filler material control, and associated documentation will be under the surveillance of Bechtel's welding engineers and QC personnel. (See Section 7.5 for more information on welding.)

7.3.5 QC , Instructions, Inspection Requirements, and 3 Hold Points Quality-related work packages are reviewed by the originator's QC organization. QC prepares, using input from others, a Construction Inspection Plan including , or, referencing quality control instructions, inspection requirements, inspection records, and hold points. The plan will be developed in accordance with the QC Program and work package procedural requirements.

~ - -, .- _.

-159-Witness and hold points are established by the and as appropriate, the AI, the ANI, Contractor Bechtel, and CGEE to ensure that inprecess inspections are performed as required. . Witness points are points in the work process at which the contractor must advise the applicable field engineering, QC organizations, and ANI (if required) that the witness point has been reached, so that they may witness the subsequent work operations. The contractor may proceed with work following notification. Hold points are critical points in the work process at which the contractor must notify the applicable field engineering, QC organizations, and

.ANI (if required), that the hold point has been reached, so that they can witness the operation or conduct an inspection. The contractor may not proceed past the hold point without written permission of the organization which established the hold point.

Incorporation or referencing of quality-related documents into work packages is accomplished by Q0 and field engineering per'sonnel. Indoctrination,

~

training, qualification, and certification, as required, of project personnel preparing work packages will be accomplished prior to the start of work package preparation.

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-160-7.3.6 Work Package PVQC Interface Woric packaget, will not be issued unless PVQC concurs that the work as described in the work package will not interfere with or preempt the conduct of the PVQC or potential rework. (See Section 7.2 for further information 'on the methods to be used to control the PVQC interface.)

7.3.7 Construction Process o RELEASE FOR CONSTRUCTON When _the preparation of the work package has been completed, including a final check of the package to ensure that all required documents are included and current, it is released for construction. The status of the work package will be entered into the Project Data Base. When a controlled document is revised, all work packages containing a copy of the revised document will be updated, with the most recent -

applicable revision and change information.

o CONSTRUCTABILITY REVIEW

~

After receipt of the work package, the work element will b'e reviewed or walked down by the field engineer, supervisor, or craft foreman, for

W

-161-constructability. If the work package is it is then scheduled by the satisfactory, constructing organization for implementation. If it is unsatisfactory, field 6sgineering/ supervision returns the package to the originator with problems identified in writing.

o SCHEDULE THE WORK PACKAGE Because each work element is completely identified a work packager constructability, material within equipment requirements, area craft availability, manning, scheduling, and statusing can te-density, determined prior to the start of the work. The work activity is scheduled in accordance with the Level project requirements.

III schedules for overall Day-to-day coordination and planning is accomplished Level IV Schedules and the area through the (See Section 3.5 for additional coordinators.

information on scheduling.) The schedule information is entered into the Project Data Base. _

o ASSIGN WORK CREWS Work crews will be assigned by the contractor's craft after verifying that the crew personnel supervisor trained, qualified, and certified as have been

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-162-required to perform the work defined in the work package. QA/QC will oversee and monitor the assignment of work crews to assure that the work is assigned to properly trained, qualified, and certified personnel. CG&E and Bechtel also monitor this process. (See Section~ 3.8 for more information on training.)

o EXECUTE-PERFORM WORK Work is accomplished by the contractors and Bechtel, as the Constructor. As the Project Director, Bechtel will provide overall management o.f the work while being monitored by CGEE. Organizations assign personnel as required to ' support the System Teams.

(See Section 2.0 for description of System Teams.)

These teams are accountable for the work. Witness and hold points identified in the work package assist .

in assuring that in-process inspections are accomplished as required. The work status is be entered into the Project Data Base. ,

o QC INSPECTION QC inspections are performed and documented by trained, qualified, and certified QC personnel.

Witness and hold points are established prior to

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-163-the start of work to ensure that required inprocess inspections are performed.

QC inspections, designed to ensure that the work is accomplished in accordance with the project requirements, are performed by the contractor responsible for the activity. Surveillance, monitoring, and auditing of CCP act,ivities will be performed by Bechtel's QA/QC personnel. Additional surveillance, redundant inspections, monitoring, and auditing will be performed by CG&E QA/QC personnel. -

. The status of QC inspections are entered into the Project Data Base.

o FINAL ACCEPTANCE OF WORK The field engineer determines that 'the work was completed by examination of the wor 4c against current, applicable drawings and documents. If the work is not in accordance with requirements, it is returned to supervision for rework and subsequent reinspection.

When the work is judged aceeptable, field engineering notifies QC that the work is ready for final inspection.

QC personnel inspect and accept or reject the work, using the current drawings and documentation. Each 5 _ - __ -- _ ___----- T _ . _ _ _ _ __

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-164-contractor involved in CCP is be responsible for the necessary inspections, testing", and process controls, including QC acceptance of their installations and activities. Upon acceptance by the contractor, l Bechtal's QC personnel are notified as required.

Bechtel QA/QC personnel, notify the responsible contractor of any deficiencies and/or deviations found during their inspections. CGEE QA/QC personnel finding deficiencies and/or deviations during their inspections notify the appropriate . Bechtel supervisor. The notified responsible. CCP contractor documents and corrects the deficiencies and l

, deviations in accordance with CCP requirements and notify CGEE and Bechtel QA/QC personnel when corrections are completed. CG&E, Bechtel, and contractor QA/QC personnel verify the corrections as required. The status of the work package is entered I into the Project Data Base.

o WORK PACKAGE CLOSEOUT l' .

After construction completion and satisfactory completion of all QC inspection; and documentation, the contractor transmits all quality documents to Bechtel for review, acceptance, and storage in accordance with the applicable procedures. (See

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-165- -

Section 3.7.2.) Nonquality documents are retained as .

requireii by the contractor, Bechtel, and CG&E.

7.4 NONSAFETY-RELATED WORK The construction program for nonsafety-related work has the same basic construction controls as ,

safety-related work. Although nonsafety related. work will not be- accomplished under the strict QA/QC requirements for safety-related work, the requisite quality will be issued throtagh measures such as: .

l o Work packages developed and reviewed for acceptability to the required codes and standards applicable to nonsafety-related' work.

o Acceptance of work documented by field engineering, with an overview by Bechtel.

- o Special requirements may dictate involvement by QA/QC and in such cases, the special

- requirements will be documented.

j.

o As defined in the CGEE FSAR, certain nonsafety-related systems important to safety, such as fire protection, have been selected for inclusion in the QA Program.

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-166-o CGEE monitoring and field engineering walkdowns of the nonsafety-related .SSCs will ,,

be conducted the same as for safety-related SSCs.

o Additional QA coverage for nonsafety-related SSCs important to plant operation may be specified by CGEE.

Nonsaf ety-related . work is evaluated by PVQC prior to release to the field to assure that performance of this work will not interfere ~ with the PVQC program.

.(See Section 7.2. )

7.5 WELDING PROGRAM The Welding Program is being structured to ensure compliance with all requirements of the applicable codes and standards. Particular attention is being given to weld procedure qualification, filler material control and traceability, welder and inspector qualification, weld documentation, and inspection. Witness points, hold points, inspections, monitoring of the welding, and audits are employed to ensure compliance to procedures.

Bechtel prepares procedures for its own work and as Project Director, Bechtel will review, rewrite (if

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. ,167-necessary), and approve contractors' applicable procedures. Qualification of procedures will be ,

accomplished in accordance with applicable codes.

CGEE, Bechtel and contractor personnel will be trained, qualified, and certified as required. Weld requirements are identified and documented in the work package, and approved as described in Section Qualified '. welders will make welds using

( 7.3.4.

l controlled weld filler material and in accordance with qualified procedures. Welds will be inspected

\

l - by field engineering and QC personnel.

Completed weld documentatien is transmitted as l described for quality documents in Section 7.3.7 l

l under Wcrk Package Closeout.

I Bechtel, as the Constructor, 3&L, GE, and contractors are individually responsible for:

o Procurement of properly qualified and certified weld filler material.

o Preparing and qualifying welding procedures.

o Procedural training, qualification, and l

I i

certification of welders..

. - - - _ ~ _ _ _ . . . _ _ _ _ _ _ _ _ . __ _____ _ . - _ . ._, __,

- 168-o Maintaining welder qualifications.

o Filler material control.

o Performing the work using the current approved procedure and welders qualified to the procedures.

o Training and certifying QC personnel.

o Required inspections.

o Notifying the responsible inspection

. organizations when work progresses to a witness or hold point.

o Preparing and maintaining weld documentation.

o Coordinating and directing nondestructive examinations (NDE).

l o Certifying personnel performing NDE. ,

o Reviewing / approving- nondestructive examination i (NDE) results. .

l l

I o Documenting repairs.

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-169-o Documenting base material weld repairs.

o Statusing the Project Data Base.

Ac Project Director, Bechtel is responsible for:

o Reviewing and approving all site welding procedures.

o Detailed CA/QC surveillance, monitoring, and auditing of all welding activities described above.

o - Selective redundant inspections. -

CG&E overviews the entire process including surveillance, audits, and selective redundant 3

inspections.

7.5.1 Procedures

. All welding and NDE procedures are being reviewed prior to implementation of the Welding Program, and

approved by Bechtel and the responsible engineering organization. Existing procedures are being rewritten, by Bechtel, GE, and contractors, as required. Procedures requiring qualification will be

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-170-qualified by. Bechtel, GE, and contractors in accordance with applicable codes. CG&E and Bechtel monitor the process of qualifying welding procedures.

The procedures will cover but not be limited to o Weld processes.

o Procedural training of welders, welding engineers and QA/QC personnel.

o Walder qualification and testing.

o . Control of weld filler material including purchasing, handling, and issuing.

o Preparation and maintenance of inprocess l welding records.

l o NDE processes and procedures.

i l

l .

o Qualification of NDE procedures.

o certification of' NDE personnel and maintenance of qualifications.

i f __.

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-171-o Postweld heat treatment.

o General administration of welding program.

The procedures require that welding activities be inspected to verify that the work is in accordance with applicable drawings, specifications, and procedures.

7.5.2 Training S & L*, GE, contractor and Bechtel personnel will be trained in accordance with the program detailed in Section 3.8. ' Welding engineers and QC personnel will be trained, . qualified, and certified, as required, on specific work procedures, requirements, and inspections prior to performing CCP work. Crafts will be trained "to procedural and specific requirements. This training is under the overall

surveillance of Bechtel.

7.5.3 Qualification and Testing Welders will be qualified by physical welding tests for specific welding procedures and the tests conducted by qualified personnel and managed by Bechtel. The physical welding tests are to be

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172-witnessed as required' by Bechtel's qualified welding personnel. ,

The PDB will. contain the current status of all welding procedures, individual welder qualifications, and personnel training records. The PDB will assist in assuring that:

~

o Only properly qualified and approved procedures are used.

o Welder testing and qualification is performed by qualified personnel.

o Only properly trained, qualified, and certified personnel are allowed to we.1d.

l

, o Training, qualification, and certification, as ,

required, is current.

7.6 CONTRACT ADMINISTRATION l

CG&E administers all aspects of its contract with Bechtel. As Project Director, Bechtel will administer CGEE's contracts with S&L, GE, and contractors pertaining to CCP activities and such other tasks as may be designated by CG&E. These

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-173-contracts will be administered in accordance with the project procedures. Bechtel coordinates and performs selecti've inspections, reviews, and audits of the work of S&L, GE, and contractors to ascertain that l such work complies with applicable regulatory and l

I contractual requirements. CGEE retains responsibility for ;dministration of the commercial aspects of the contracts.

Bechtel, S&L, GE, and cc'ntractors' are responsible for the administration and control of their subcontracts l in compliance with applicable , provisions of their i

contracts with CGEE.

7.7 CONSTRUCTION TESTING PROGRAM i .

Construction testing consists of a series of tests and verifications performed by construction on

, installed SSCs prior to . preoperation turnover of the SSCs to CGEE. -

o RESPONSIBILITIES .

l CG&E has overall responr.ibility for the conduct and I

administration of the overall testing program. As Project Director, Bechtel is responsible for:

l -

. y .

I

-174-o Performing a comprehensive review of the present project construction test procedures and acceptance criteria and those prerequisite test procedures and acceptance criteria designated by CGEE, submitting to CGEE any

. recommendations.

o Performing a comprehensive review of previously completed construction testing activities.

o Identifying the construction tests and associ. Led precedures  :: quired for each i syst em, structure, or component for CG&E's approval.

o Developing and maintaining the overall l

schedule and reviewing / approving the detailed schedules for the construction tests.

o Reviewing and providing for CGEE's approval construction test procedures as requested by l

CGEE. -

l l-Managing the performance of mechanical, o

electrical, and instrumentation construction tests.

u__ _ _ _ _ _ . . _ . _

-175-Providing CGEE reasonable advance notice of o

performance of all construction tests so the CG&E Representatives may be present. Tests with designated hold points shall not be performed until the CGEE Representative is present.

~

Reviewing and recommending CGEE approval of o

construction test results.

o Resolving all testing-related deficiencies

- expeditiously.

o Coordinating the jurisdictional transfer (system turnover) of the plant systems to CGEE.

and CGEE are each responsible for The contractors training test personnel, preparing procedures, documenting tests, scheduling, performing tests, statusing the PDB, and preparing requirements as appropriate for their individual work scopes.

o TESTING REQUIREMENTS comprthensive review of construction testing A

requirements is being conducted. This review includes the testing requirements of CGEE, Bechtel,

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- - ~ ~ . - - - _ . . . _

k

-176-S&L, contractors, the Zimmer Final Safety Analysis Report (FSAR), and the Nuclear Regulat'ory Commission (NRC).

Specific requirements to be evaluated for inclusion in the construction testing program include:

o SSCs requiring testing.

o Tests to be performed on each SSC.

o Acceptance criteria for each test.

o Evaluation and documentation of test results.

o Qualifications of test personnel. .

o Quality involvement.

o System scope documentation.

o Administrat.ive and test procedures.

o Measurement and test equipment program.

o Safety precautions.

k

-177-o PREVIOUS CONSTRUCTION TESTING After requirements of the Construction Testing Program have been determined, a comprehensive review of previously . completed construction testing

~

~

activities will be conduct'ed to determine their acceptability. As appropriate, this review includes:

o Construction test procedures used.

o Qualifications of test personnel.

o Measurement and test equipment program.

o Evaluation and documentation / retention of results. .

o Proper performance and completeness of the tests.

o Quality involvement.

o Effact of post-testing SSC . history on the integrity of the test results (e.g.,

construction and d'esign changes, equipment maintenance, and operational status).

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-178-o Effect on the integrity of the test results for systems turned back to' construction.

o Action required to render the remainder acceptable.

4 o CONSTRUCTION TESTING PROCEDURES o Construction testing procedures will be written by either the performing organization or by Bechtel.

In either case, CG&E has final approval authority e

over procedures, to assure that they meet all requirements.

o CONSTRUCTION TESTING PERFORMANCE Construction tests will be performed and documented by Bechtel, contractors, or CGEE. Bechtel will manage and monitor all construction testing. The safety-related construction tests are inspected, witnessed, and audited by the appropriate quality organizations and other organizations, as required by i

the test procedure or Qualitp Program.

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b

-179-7.8 PREOPERATIONAL TURNOVER PROGRAM i

o GENERAL l

l The Preoperational Turnover Program defines the responsibilities and procedures for turnover of the project systems, structures, or components (SSCs).

i Preoperational turnover is defined a.s the process of transferring the SSC jurisdiction from Bechtel to CGEE. An SSC will be turned over to CG&E as complete as possible following the guidelines set forth in the requirements for preoperational turnover of a SSC.

Procurement, installation, and QC documentation is not transferred to CGEE at the time of turnover, but is verified as complete and available for review.

The transfer of jurisdiction from Bechtel to CGEE occurs when the preoperational turnover is accepted by CGEE.

• CG&E is responsible for the following:

l l

I l o scoping startup systems. ,

l-l l

o Reviewing and dispositioning DCPs.

o Accepting or rejecting the preoperational turnover from the construction organization.

7 . ..

b

-180-o Administering the jurisdictional tagging, safety tagging, and the clearance program for post-turnover work.

Director, Bechtel is responsible for As Project managing:

completion of installation and o The construction testing.

o The orderly turnover of systems.

assembling of preoperational turnover o The packages.

The documentation of exceptions.

o

~

o The completion of turnover exception work.

o Concurrence with readiness for turnover.

o The appropriate jurisdictional tagging of SSCs prior to preoperational turnover.

o TURNOVER UNIT SCOPE The scope of each testable turnover unit is provided by CG&E on marked-up drawings describing the turnover

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\,

-181-unit boundaries and components. .,Bechtel reviews and

. make recommendations on scoped drawings . The scope

- of each nontestable unit (facility) will consist of a detailed turnover unit description and identification numbers.

Bechtel manages the compilation of detailed turnover scope drawings, lists, and tabulations developed from the scoping drawings provided by CG&E.

o CONSTRUCTION COMPLETION SSC completion and turnover is being planned in accordance with the turnover schedule. Once the scope of the SSC has been defined, completion progress will be monitored and controlled as'follows:

o The CCP System Team prepares a discipline worklist, schedules are prepared, and construction completed.

o As the system turnover date approaches, design changes will be controlled through the use of design change packag,es (DCPS). The DCPs will be forwarded to CG&E to determine when the design changes will be completed.

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h

-182-s .

o As the ' system turnover date comes closer, the

~

Team issues" a detailed list of System outstanding items and , conducts an initial

~

walkdown with CG&E. New items are system included on the list of outstanding items arid the items are scheduled for completion.

o Just prior to the scheduled turnovar, the System Team and CG&E' personnel conduct a final system. walkdown of the turnover unit. Each open item is reviewed to determine whether it will be completed prior to turnover. A list of the items to be completed after turnover is prepared and included as part of the turnover package.

o PREOPERATIONAL TURNOVER When the installation and construction testing is complete, a notice of completion is prepared, reviewed by QC and QA (for safety-related, Seismic I and ASME, Section III, items only), and sent to CG&E. The procurement and installation inspection documents are certified to be complete and available for review.

D 4 e-

-183-Acceptan,ce of an SSC turnover is indicated by CG&'E's written notification. After acceptance of the SSC, CG&E implements the jurisdicational tagging procedure to adequately identify items within the turnover boundary.

f-After acceptance, CGEE assumes sole responsibility for preoperational testing, operations, and maintenance of the SSC. No work is performed on the SSC unless it is approved and controlled by CG&E. .

o FINAL DOCUMENT TURNOVER After the enrpletien of the preeperational turnover of SSCs and the close out of open items, the final document / record turnover transfers all

• remaining documents / records to CG&E.

7.9 POST-TURNOVER CONTROL PROGRAM o GENERAL The Post-Turnove.sr Control Program controls how work is accomplished and completed after SSCs have been turned over to CGEE. This program ensures that no work is undertaken on turned-over SSCs unless properly authorized by CG&E. Retesting of work previously tested is performed as necessary.

-184-In some cases a SSC may be accepted by CG&E with work items remaining. These items will be designated.on a work included in the turnover list of incomplete s

work may result from corrective package. Other a

maintenance or repairs needed after turnover. Work may also result from design modifications determined j

testing, from engineering i.

> during preoperational changes, and from new NRC requirements. Corrective maintenance and repairs are to be accomplished under

( .

the cognizance of the CGEE organization that has i

These design changes jurisdiction over the system.

t are controlled using a design change package fror S&L receive management review before which will inplementing changes. Cc plation of items from the any additional work is incomplete worklist and scheduled and assigned, as required, by CG&E.*

1

)

o METHOD OF IMPLEMENTATION I

Work af'ter turnover can be accomplished in one of the following ways:

can perform work on the o A contractor '

turned-over SSCs as requested by CG&E on a l

work request form. The construction Zimmer in this case, is responsible for contractor, f

! the work, including

-I the execution of l

l

~ . . - . _ _ , . , _ _ _ . . - _ _ _ _ . _ _ _ _ . . _ _ _ . , _ _ _ . , _ _ . . . _ _ , _ _ _ _ _ _ _ . _ _ , _ - .

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- _ .. . c .__ _ _ ~ . . . . _ . . ._ . _ _ _ . _ _ _ _ _ _ , _ . _ _.

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l.

-185-engineering, procurement, as requested, construction testing, QC, supervision, and crafts. CG&E is responsible for the scheduling, safety tagging, and work authorimstion s systems.

o Work on turned-over SSCs can be accomplished by CG&E.

o Contractors cdn furnish crafts and associated supervision to CG&E as requested. All functions other than craf t supervision and the furnishing of crafts is the responsibility of CG&E.

7.10 PILOT PROGRAM FOR FIELD CHECKOUT OF SAFETY-RELATED WORK o GENERAL A Pilot Program will be used to confirm that elements of the CCP have been properly conceived, that procedures are adequate, and that personnel are properly trained, qualified, and certified as required.

Representative nonsafety-related SSC work from each major discipline will be selected as considered

)

. - . .- -. ..~ _-.-- - . - . _ - . . - _ . . - . - . . - -- - . - - _ - -

s -186- -

-necessary and clearance given by PVQC prior to-starting the work to ensure that the

[

nonsafety-related work does not interfere with PVQC.

Prior to the commencement of each Pilot Program, the CCP major elements, programs, and procedures will be reviewed and a list developed and approved of those elements required as prerequisites to commencing each specific Pilot Program. All CCP elements are not applicable to each Pilot Program. Procedures will be ,

written, training performed, work packages prepared, construction performed, and inspections and documentation completed as if the work were safety =related. Bechtel's and contractor's, field engineering, design engineering, QA and QC persennel perform as if the Pilot Program were being applied to safety-related work. An analysis of problems encountered will be made and changes implemented as required, to assure that the same problems do not occur on the safety-related systems.

7.11 PREVENTIVE MAINTENANCE PROGRAM A Preventive Maintenance Program is being established to ensure that all plant SSCs are maintained and preserved at a level commensurate with their importance to safety and in an acceptable manner.

Preventive maintenance requirements are ectablished I 1

. . . _ _ - _. .___....L._._.____..

-187-by the CGEE Engineering Departasnt. Prior to preoperational turnover of SSCs, preventive maintenance will be the responsibility of the constructor and carried out in accordance with the program requirements as defined by CG&E engineering.

Post-operational turnover preventive maintenance will be the responsibility of the Nuclear Production Department, which may directly perform the required maintenance or may delegate the physical work to a contractor under a Work Request Program.

Responsibility for configuration control of SSCs rigidly maintained by the entity responsible as defined by the preoperational turnover process.'

7.12 CONSTRUCTION PROGRX4 RESULTS The construction programs (outlined in Section 7.0) required for the continuation of construction of safety-related work will result int o Effective administrative,. managerial, and technical procedures for construction activities.

o Establichment of a control system to ensure that the PVOC and construction interface is precisely defined and controlled.

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-188-l

o. Institution of a Work Package Program that provides an effective means for scheduling completion work, controlling work quality, and controlling the PVQC interface.

o An improved Welding Program that provides control of all welding functions, updated welding procedures including procedure ,

qualification, assurance that only properly qualified welders perform welding, controlled welder training- and qualification, and improved document control.

o Effective management of contracts in .

accordance with regulatory and contractual requirements and project procedures, o A clear definition of construction testing requirements and needs, controlled test procedures, complete control of test implementation, and assurance that quality l

l verification of testing is performed.

l l

f o A Turnover Program that will ensure an orderly turnover of jurisdiction from l.

construction to CG&E and a Post-Turnover

. Program that will provide complete system work control.

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-189-o Use of a Pilot Program to demonstrate the viablity of the 'CCP exlsts by performing initial construction ,

activities on nonsafety-related systems.

o An effective Preventi've Maintenance Program that will maintain and preserve all SSCs in accordance with the applicable requirements.

4

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-190- .

. t-8.0 IMPLEME!!TATION OF CCP_

showing the major steps A simplified flowchart required to perform safety-related work is shown in' the process as major steps of

' Appendix 15. The .

detailed on the flowchart are described belows o Prior to the start of safety-related work, as required to certain major prerequisites, support the scope of work, must be in place and functioning.

Appendix 15 lists some of the major prerequisites and the section of in which they are addressed.

this document .

t design drawings, o The preparation of specifications, and other design documents is as described in Section 5.0.

accomplished engineer's QA/QC organizations The design the design engineering monitor and audit

' activities.

o The remaining work is identified as described After the remaining work has in Section 3 4.

been identified, it is divided into discrete items of work, and work packages are prepared 7.3 through 7.6.

as described in Sections 6 @ gs.

- - ~ _ _ _ _ _ _ _ _ ___ -_-

. _ _ _ . .-._ - . . , . _ - . _ _ . . . . _ _ . . .. .__.- - - ~.._ _ . _ __.__

-191-The contractor's QC organization and the Authorized Nuclear' Inspector provide input, as required, into the work package. (See Section 7.3.5 for further details.) ,

o Requisitions for equipment and materials not.

yet purchased . are prepared. The equipment or materials are purchased, inspected, received, stored, and issued for use as described in Section 6.0. The purchaser's QC personnel will inspect the material upon receipt.

o After preparation of the work packages, satisfactory completion of the Pilot Program (Section 7.10), and the approval of the NRC safety-related work to proceed with the work package will be (Section 3.1),

issued and work will proceed as described in Section 7.3.7. The performance of the work will be inspected by QC as described in Section 4.0.

o Upon completion of the construction work, construction testing will be accomplished as described in Section 7.7. Construction tests inspected by QC or will be witnessed and qualified and certified test

• properly engineers, as applicable.

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-192-1 o After satisfactory completion of the c'onstruction and ' construction testing, the SSC will be jurisdictional 1y transferred from Bechtel to CG&E, as . described in Section 7.8. Work after turnover will be accomplished as described in Section 7.9.

o Quality records for turned-over SSCs are transferred to CGEE. Nonquality records are retained, as required by CG&E. (See Section 3.7.)

Bechtel's, S&L's, GE's, and each contractor's QA organisation audits and monitors the entire work process including the:

o Preparation of work packages.

o Completion of work as defined by work package.

c Construction testing.

o S3C turnover to CGEE.

o Post-turnover work.

t

^

-193-o Turnover of records to vault.

o Performance of QC.

As Project Director, Bechtel manages, audits, and monitors all activities performed by S&L, Bechtel, and contractors. .

CG&E manages Bechtel and monitors the entire project, including audits and surveillances as necessary.

The organization as described in Section 2.0, the CCP major elements as described in Section 3.0 through 7.0, and the implementation of these elements will result in an of fective and controlled continuation of construction assuring that work is completed in accordance with applicable requirements.

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-194-9.0 SCHEDULE FOR CCP As Project Director, Bechtel is developing and maintaining an integrated schedule for completi,on of the project., A milestene schedule based on the current forecast dates has been developed. (See following page.) It identifies milestone dates for completing prerequisites, starting, and ' completing ,

the Continuation of Construction Plan (CCP) work.

4 e

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s CCP IMPLEMENTATION SCHEDULE I  !

1983 1984 O N D J F M A M J J A S O '

t NRC I SilBMii APPROLAL COA . . t

! NRC

! SUBhiIl /.PPR0yjil i

} PVOC  ;

l SUBMIT l 1 F S AR 17.1 V l l l ,

INTEGRATED PROJECT SCHED WP I  !,

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FINALIZE O A PROGRAM I J g .- 6

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' SUHHli NRC AFPROVAL i CCP .

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!; PREREQUISITES O g gi I

i l I O # IO C0'1PLETI ON TRAINING g l

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l i PILOT PROGRAM  !

i l i IMPLEMENTATION 1 ' TO C0 1PLEil 0N 1

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I, I ll'i IINI PVQF ANI) FCP r . e. ,.. , ; .

filVISillN 11! Ill SPINSn..  ;

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11. PVOC -l gli Sa'lWSlill i I)RO.ANI / AI IIM NW,'

f t II( Altrill11 Cl- <.

~

l 11 t4 lit kuiv( f r.Al . Ill t Illt 1. F Nr.lNI I R Sill'I'l ll le 84 SI:llll'l tilN Annant An. ant

~Hil. Ann a nt Approve liersunmesul i n Osialit y fmif ormation Ps ewirnm (OCP) twpanninn fr.Al any ,

^l nerennary l j.

chswwy* Annant . Ann a nt Annant ,'

Appe nve, mdi- Prepare A Pieparril son of Plan for Verifical enn of util t o Nill' nedwest in 7

Onnlit y Canal ruct inn (PVOC) Of;Af Snpoly

'ageply reI l l Hannip. A 'nspply r esp pr*".1 e*a l

';ingil y Siipply eltw oment al inn input l}l recI i 1

lilent ify A Re spient Nrwie Iraan own Irnen omi traan all Irnin own perstwwwl persenwiel _ _ .

i Irnin PV00 perntwwiel peransww l perntwwml Sigiply pernewi. Nos u-4 Hrw ena to , el s - Siipply person- l Giappl y tw'l i n perform nel in perform I rect newt per-

'e V i mini iseilw'cl itwi pornosww= 1 ASME (Sec.) 3 f form Supply peason- New ee*

'nipply person-Supply Hannge, nel lo perform nel in perfoem ,

I

~

Phynical annpectinn perniwuiel elarcel A l 1.

petform ASME (Sec.) 3 Nm p*

in annant Supply person- Supply person-Snpply twer- Havinile, als- nel in perform tiel 10 perform Ikw inactil al smi Reviewn newniel t o rect A 7

perrnia ASME (Sec.) 3 Nnew-annist None None lleview Perform Nose-

-~ 11 St alian stel ermlunt. inn for civiformerwJ Perform Inr PerInrm for nonconforminq newf incomplele ilens Perform Perform GunIil y annorance nesti1.n newl norvr ilinnce rect iv al ics con- skict nct tvil eri tes con-by A/l n cluct cel by 11.1t( emptnyeen employees I

--a

, i Annant Annant Prepare A Annant f Approve, I PVOC report of remills mdinal to sides 1 to ~~~

til Cl;Af Provnlo re- Ps ow nld ~i NitC Preiv iele re-Ps ov iile re- spenni cal info qm nl o.1 i.sf .

fewel r:w l fort o ryseni c<l info t o nwls t or laulepe wl6nt omfit nf PVi3C prov iile re- qiwant eel inf i n nielii nr 18 in nmlefor in amielor tyeenl eet info i n nipla t or

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

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a

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N=2 E n= L6 1 6J L C. e L *I O. E 6.

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6

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DIVic.lpN 111 Itf SP. IlIlllS fnR PVOC AND CCP P: .

Vll. IIffN'ilNr. AND PfRHII SIIPPORI .

RI SPilNSillt I flRCANITAI 10N 1IlM OF blDRK art'lli IF 01 - NW.

08 AI. lli l'Illi i ll.IN NH. Of SCRIPlllIN INCINF F R SilPf'l Il_5 Annant Ann s e.1 Perform A Ann ni Ane. i nt 1 Renponnen in NRC or nlher requelnlory linsly ansmge Annant Appenvc A Annant Ainant Ans i il "

7 I SAR rhrwiry n sist em it Asnint A ;nini -

Annint Annist I nv irosunent al report supplcoent s Appenve A l

solim iI I'nop!y Cnapiy Onopty Compiy fnmpIy lifesel i v t 4 10 CfR 2I l'< wnp l y talent i fy A tilent ify A idesil Iy A

'. 1001 R

• 0.'e'i( c) annini CG40 nssist CGAE in assist CCA0 in annist l'G.!

in evnlin.it inq evalianting de- evalient irwl ele- evalientis=j '

ficiencies f aciesw-ics ficacew se-sleficiencies potentently gwil ent c a l l.

polcutinfly pot ent ially reiwirl nSle report ahle re.c rtable retwirl reiste 1

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FOR THE IIMMER PROJECT ,

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I C

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CCP SYSTEM TEAM ORGANIZATION t y

P'c,eII Fielt 'reje:1 gg. g.

E*i lete*IRG Constrwctior C* g., . ...

& Liteesimi manager manage-saaose' --

(.

. . . . . - . . . . . . - . - . . ..I .

l ,

Project ' ' ' C8 Test;-

Project Sweerintencent Pfe F d Q,- g ' '.

Eegineer CCP I"9 3 "I"9 E*93 nee' Manage-s I l l i i Pre; ct cC= :

I rieie ico;ect met *e.

I Sw:ecintenseat Syste- Fiele Engineer 5.c.-

Sweerietencent l - ,

i I a .

• I 1 5rste-L_! l Syste-l Test

. Tea- j E*9 s l Lesce's ;es.3 ate: .

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,----p------- q

.scissene Cratt ne g Sweervision go,,,og i g y e......,

' I i 1 I I I l

- 1 I l Crafts l l g I I l I

EECHTEL I' I

. . _ _ _ _ _ _ L _ _ _ _ p . . . . . _ _ _ _ _ _ _ _ _' .

l l OTHER CONTRACTORS l A/I Contractor's qa P 8C* $ woe rvi sion n,n,9,,

g , ,

I I l 8 l l 1 I I-- 7 i

• I  ! Discipline *

• Craft I l or qc Supervision l Comodity Engineers A/E l Engineer l Project Direction Coordination . -- .

Administrative &

Techni cal 0l rect i on -. == ..= = == . .

System Team Organization

• Personnel As Required g

To Support Te = APPENDIX 6 e

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l QA PROGRAM AND PROCEDUPAL l:

?

DOCUMENT RELATIONSHIP HIERARCHY

, F5AR j ' '.1 NOT[$

Smo cause order coswitments Zimer 4

corrective actions (ie-Problem matris) Organitation mu st ce addressed by all coc e nts & Regulations mummmmmmCA Program Direction * "*

! PqAn

' """""* Zlare r Qrgan! ationa1

& kegulations Direction e nseesesm ununnennuud g

-Zimer inter Campany Direction = 1 Zineer Proceoures manual (Inter-Coacan. & Inter CC&t P-Provice PvcC&CCP Comitments Departments Proceoures, to inoicatec Documents P E

Zlasner

,f intra- ._ _ _ _

• Departmental '

CCsf Proceoures a

PRCJECT &lR(CTCK g g[CnT[g 4' uqAP b _

Seentel Proceoures

'. Manual f

• PVCC Catail {

Procedures I

rp <

ll CCP D Detall  :

Proceoures

• \

QTnER itMnEA GAGAhl4ATIC% ' '

QAM 4 .

1

^

Detail -Z- -

Proceoures 10/5/83 ZG-0224-04 I

APPENDIX 8

, . . _ _ . . . . . - - ~ ~ - -

FLOW 0F DOCUMENTS & RECORDS FOR CCP I..._ -- E c .. .. . .. ,. . .

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CONF 80L *"' s

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' (,NillAL n.......

gangg,,,ggg ,

,8I A(C,O* tgly0% D.commen, Can,rel .'

Or Quelley Receed.

Vault

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APPENDIX 9 ' " ' a

l___._____. .___. - - - - - - - -- - -- - - ~ - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

L 10-1 i

APPENDIX 10 DESCRIPTION OF PROJECT NONCONFORMANCE PROCEDURE Existing project procedures for control of nonconformances were reviewed by a site interorganizational committee to determine whether the procedures and methods could be improved. As a result of the committee's review, it was determined that the procedures for documenting and controlling nonconformances and discrepancies should be replaced by a single, project-wide procedure.

A new proce. dure for controlling and documenting nonconformances is being developed. One prerequisite

~

is that all affected Zimmer projec- organizations will append this new procedure to their procedures manual to show the NCR flowpath through their system and to identify responsibility, by title, for activities in compliance with the new requirements.

These requirements comprise the following principal elements:

o Only one form, titled nonconformance report (NCR), shall be used to report, control, disposition, and complete nonconforming items.

t o A nonconformance is defined as a deficiency in characteristic, documentation, or procedure APPENDIX 10 1

l

10-2 that renders the quality of an item f '

unacceptable or indeterminate with respect to project requirements. Examples of

~

nonconformances include physical defects; test failures; incorrect or inadequate decurentation; and dev.iations from prescribed processing, inspection, or test procedures.

o other documents, such as the ex,isting reports (NRs), inprocess nonconformance discrepancy reports (IIDRs), and inspection requests for design change will no

' field longer be used to report nonconformances. NRs and IIDRs that were issued and validated prior inception of the new NCR procedure, if to found to be correct, will be transferred to CCP for processing. If it is determined these reports are incorrect as a result of PVQC, the NRs and IIDRs will be transferred to an NCR for clarification,and processing.

o NCRs shall be initiated by those individuals who are assigned the responsibility to perform inspections or verify quality. Typically, includes cognizant field engineers and this quality control personnel, t

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. ..-.. . .. - - - . . - . - - - .- - - - - - . - - - - ~ - - ~ -

10-3 s

o The cognizant field engineer or quality

~

control person sha.ll be notified by any person who observes or becomes aware of a nonconforming condition. Upon determination that an NCR is warranted, an NCR shall be written, signed, . logged, and forwarded to the applicable discipline QC for review and validation.

o Once an NCR has been logged, it cannot be voided. Should it become necessary to discontinue processing the NCR for reasons of redundance, erroneous reporting, or other

, similar conditions, Quality Control shall state the basis :cr the action and sign-off

( the appropriate block with the Bechtel t

l Project Quality Control Manager or the Bechtel Project Quality Control Engineer concurrence. No further action is required except for removal of hold tags, '

distribution, and filing.

o All nonconforming items shall be segregated, tagged, marked, or appropriately identified to prevent inadvertent use or installation.

Only quality control may remove hold tags or other identifiers from the nonconforming items. '

J . . -.~ 1 ..... .

10-4 o NCRs that have been logged, but not j validated, shall be ma,intained as a quality record with a qualifying statement as to why the NCR was not processed. If the NCR originator disagrees with the decision not to validate- the NCR, , he has the right of recourse to as high a level of management as l necessary to obtain satisfaction. A separats procedure will be issued to explain this method.

l l o All NCRs shall be reviewed by quality I

assurance to determine whether the nonconformance is possibly reportable under ,

10 CFR 50.3 (=) or 10 CFR Part 21 in l accordance with applicable procedures.

I

[ o During activities under the Plan to Verify 1

the Quality of Construction (PVQC), NCRs will be issued, validated, and trended.

, Dispositioning of NCRs is not included within the scope of PVOC activities; however, there l

may be instances where a generic condition is discovered in which a standard resolution can be used for , specific occurrences of applicable nonconformances.

1 10-5 s

I o Dispositioning and closure of NRs, IIDRs, and j' . NCRs that are, valid - As a result of PVOC shall begin with CCP. NCRs shall be dispositioned as REWORK, REJECT, REPAIR, and USE-AS-IS.

All dispositions shall be reviewed by the S cognizant quality entity for completeness, accuracy, and appropriate signatory approvals

~

prior to final concurrence.

o REPAIR and USE-AS-IS dispositions require

, approval by the responsible engineering G

] organization. Requisite changes to design or i

as-built criteria shall be provided by the responsible engineering organization. The Bechtel Project Quality Contrul Mar.og er or i

j Bechtel Project Quality Control Engineer t shall provide signatory concurrence for these dispositions.

o REWORK and REJECT dispositions shall be provided by the cognizant field enginee. ring, organization with disposition concurrence provided by their designated quality entity.

The cognizant field engineering organization may also recommend REPAIR and USE-AS-IS dispositions, which requires approval by the

. responsible engineering organization and concurrence from the Bechtel Project Quality

)

-~ ^" ~"

~ . - - .

i .=

10-6 Bechtel Project Quali.ty Control Manager or

' Control Engineer. -

dispositions of 1) conditional o Interim release for install-. tion or 2) investigation These may also be provided, as warranted.

approval by the dispositions require organization and responsible engineering Quality concurrence by Bechtel's Project Control Manager, Project Field Engineer, and Project Quality A.asurance Engineer prior to implementation. Work limitations encompassed within each of the above categories must be <

clearly defined and established.

o Approval of dispositions affecting ASME code items shall be obtained from the Authorized Nuclear Inspector (ANI) for ASME Division III from an Authorized Inspector (AI) items or for other ASME code items.

o Implementation of NCR dispositions shall be performed in compliance with the disposition Reinspections shall be instructions.

with the original performed in accordance methods, requirements or approved alternate t

10-7 providing they are at least equal to the original r equi rement s ".- The results of the reinspections shall be recorded on the NCR.

l l .

1 i

1 l

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1 l

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i I -

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l MAJOR DESIGN CHANGE CONTROL

( PROJECT CilANGE REQUEST - PCR )

i A/E Originate A/E g @. Design  !

, Request .

Evaluate m

, g Concept ,

Approval g Issue j t

l DDCN V

Reject ReleCg Reject 1 . *

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i I i

I "*-

Normal Change Flow (Prior To 180 Days From Turnover) 7 i g 1

), Design Change i, . Package A/E i

/ impi m nt (DCP) m Compile m DU

l. " "

Complete Review s Schedule Package; Installation  :

1

Mgt Review i CGEE Will Install After Turnover .

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4 PROCUREMENI' AND MATERIAL CONTROL  !

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identify Review i f ac ,*,g j gg,,,ggV us.D == Review Caast rwe t to. 4 . Requirement s

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it. 0119 e4 APPENDIX 12 Ii l lI

F E

. i CONSTRUCTION PROCEDURES  ;

E BECNTEL QAM PROCEDURES MANUAL 1 F 1 P QUALITY .

CONTROL m SPECIFIC A/E, Vender, WORK ,

Client DWGS.

PROCEDURES

' & Specs.

- Codes & STDS.

QUALITY ASSURANCE t

l 1 r MATERIAL - - QCIR CONTROL WORK PACKAGE l

l WELD CONFIG l

DOCUMENTS / f Co m 0L CONTROL

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APPENDIX 13 f

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WORK PACVKE PEPARATION ,

! l 1 1 l 1 t 1 Islen t i fy i Material

• Resna in ing Requirements '

i Work a .  !.

i r Scope Prepare identify Of Work Work Assemble Final Ready

, Required &

Package Package Package 4 Resolve

" 4 ro, Determined Documents Assed ly issue Check L l s t Problems s Review

. d b d bd L eview ConsIrn[I1hiIit onstructable Establish Hold >

Points i

,q , FE FWE QC ANI ,

finalire Constructinn inspection Plan Q.C. FE= Field Engr.

FWE= Field Welding Engr.

, QC=0naliiy Conarol ,

, AN1*Authori7eri Nuclear inspector '

l APPENDIX 14

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IWLEENTATION OF CCP SAFELY-ELATED WDRK I ,

t MAJOR PREREQUISITES l

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ORGANIZATION 20 - u i....

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PROCEDURES 32 rei, acimat i..

PROJECT CONTROL

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