ML20093M442

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Rev 2 to Record Verification Program Plan
ML20093M442
Person / Time
Site: Clinton Constellation icon.png
Issue date: 09/24/1984
From: Campbell R, Connell W, Hall D
ILLINOIS POWER CO.
To:
Shared Package
ML20093M413 List:
References
PROC-840924, NUDOCS 8410220128
Download: ML20093M442 (19)


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ILLINOIS POWER COMPANY CLINTON POWER STATION RECORD VERIFICATION PROGRAM PLAN REVISION 2 PREPARED BY: '

T_ f # DATE: J///f R. E. CampEcl;., Director Quality Systems & Audits REVIEWED BY: /]M h./M DATE: [I/!f! ,

W. nnell, Manager IP uality Assurance APPROVED BY: DATE: [ [

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D. P. Hall, Vice President 8410220128 840926 PDRADOCK05000g

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' TABLE OF CONTENTS SECTION~ TITLE l:

i' TABLE OF CONTENTS 1.0 OBJECTIVE 2.0- SCOPE-g, 13.0 DEFINITIONS 4.0 TASK DESCRIPTION e.

5.0 RESPONSIBILITIES 6.0- RESOURCE REQUIREMENTS 7.0 ATTACHMENTS

, Attachment 1 - Baldwin Associates Document Review Group Organization Chart Attachment 2 - Site Records Management Interface Structure Attachment 3 - IPQA Record Review Group Organization Chart

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1.0 OBJECTIVE The purpose of this Illinois Power Company program is to verify the acceptability of QA records applicable to the Clinton Power Station.

NOTE These records may be in the custody of either IP or BA organizations.

2.0 SCOPE The main features (clements), of the QA Records Verification Program are described in this section, while the organization and responsibilities are covered in Section 5.0.

2.1 The Records Verification Program (hereafter referred to as the " program") will apply to QA records for safety-related, fire protection, and augmented class D systems or structures as follows:

Baldwin Associates' construction / fabrication / installation work documentation packages Site generated or maintained purchase order documentation packages, including associated receiving inspection and vendor data packages.

2.2 IPC QA will conduct n QA records surveillance program to verify the adequacy of the BA program. IPC QA will use the same criteria as BA uses in conducting their review program.

2.3 Description of BA QA Documentation Final Review Program.

, 2.3.1 Reviews will be scheduled and conducted in time frames to support scheduled hardware turnovers. However, if necessary, reviews and resolution of deficiencies may proceed beyond the hardware turnover date.

2.3.2 The Startup organization will provide lists of equipment and travelers included in each turrover.

2.3.3 The BA Senior QA Engineer (Document Reviewer) will request the documents be transmitted from the BA vault to the BA QA/DRG for review.

2.3.4 Records will be itemized and logged out of the BA vault for use by the QA/DRG in their work aren. While in this area, when not being reviewed, the records will be stored in locked firo-proof file cabinctn.

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V l 2.3.5 Each record, record package, or traveler will be assigned to an appropriate Quality Assurance Engineer (QAE) for review according to the QAE's area of expertise.

2.3.6 Each type of record package such as purchase order or l traveler will be reviewed using applicable final review checklists.

2.3.7 A computer generated Record Status Repcrt will be maintained to reflect the current status of records in the review cycle. .

2.3.8 Installed equipment will be field checked on a surveillance basis to determine if the equipment is traceable back to the documentation. This may be performed under a separate plan (e.g., IP Overinspection).

2.3.9 Documentation review and the equipment field checks for traceability will be performed by personnel who are l trained and qualified in the required specialities.

2.3.10 Record deficiencies found during the review process will be documented and routed to the appropriate discipline for action. Records that have been corrected will be <

routed back to QA/DRG for re-review. Documentation l !

probleus that remain unresolved will be added to the turnover exception list and tracked as part of the Plant Startup punchlist. The BA/DRG will trend deficiencies utilizing an inhouse computerized system. The system will be eble to provide a printout of resolved and unresolved items to ensure total accountability.

2.3.11 As records are reviewed and found acceptable, they will be stamped accordingly.

2.3.12 After final review has been completed, IP will be notified that the records are available for their review.

2.3.13 The final step in the BA QA documentation review program is to return the records to the DA vault for storage and subsequent transfer to IPC, or to transfer recordo directly to IP.

2.3.14 The BA/DRG will interface with the BA Field Verification Group for field verification. The purpose of the interface is to assure that field verification is performed in conjunction with the ongoing overinspection activity, i 2.4 Description of IPC QA Records Surveillance Program.

2.4.1 After QA records have been reviewed and accepted by the ,

BA/DRG, they will be reviewed by IP QA on a surveillance basis.

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s 2.4.2 The purpose of this review is to evaluate the adequacy of the BA QA Documentation Final Review Program independently on a continuing. basis.

2.4.3 The QA records will be reviewed using the same criteria, as delineated in the BA final review checklists.

Additional criteria may be used to assess BA/DRG adherence to their governing procedures.

2.4.4 The IPC QA surveillance program will consist of approximately twenty (20) percent of all quality documentation reviewed by Baldwin Associates. A trend analysis program will determine the need to increase or decrease the percentage of records reviewed by IPC.

2.4.5 The IPC QA surveillance program will be conducted by personnel who are trained and qualified. The training program will be formalized and documented.

3.0 DEFINITIONS 3.1 Acceptability - The records as presented are legible, completely filled out and identifiable to the item involved.

Requirements identified in the aurchase specification and applicabic codes and standards invc been met. All documentation discrepancies have been resolved and the records are ready for transfer to Illinois Power Company.

3.2 Accountability - The process of verifying that documentation required by codes, specifications and procedures is identifiable and retrievabic, 3.3 Documents - Collective term used to describe all written or pictorial information that provides evidence of what and how an activity uns accomplished.

3.4 Documents Repository - An area designated for the protective storage (lockable f;.re-proof cabinets with a rating of I hour at 350') of BA records while in the QA rinal review status. The Document Reponitory shall function as an extension of the BA Vault, and the otorage, control of and access to records shall be in accordance with applicabic procedures.

3.5 Field Verification - The process of verifying documentation against the equipment actually installed in the field.

3.6 Final Review Checklints - Detailed lists of requirementa used to asuint 6c' reviewer to determine the acceptability

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of the different types of QA records and record packages.

The checklists also define the kind of QA recorda required by applicabic procedures, codes, standardo, and desi,n specifications for each type of equipment installed .n safety related, fire protection and augmented class D sys cms.

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3.7 QA Document Review Group (QA/DRG) - A staff of technically qualified personnel who perform the BA QA final review of records.

3' 8 :QA/DRG Handbook - A compilation of information to assist the QA final review personnel to perform their assigned tasks.

3.9 LAT - A lesson plan consisting of lesson objectives, references, instructional aids, lesson outline and additional information.

3.10 Quality Assurance (QA) Record - Those completed documents which durnish documentary evidence of the quality of items and of activities affecting quality.

3.11 Record Deficiency - Any record which contains a nonconformance or departure of a characteristic from specified requirements.

3.12 Surveillance - A scheduled or unschcduled review or observation of an activity, process, or product and associated objective evidence to verify that certain actions have been or are being accomplished in accordance with applicable requirements.

3.13 Training Qualification Requirements (TQR) - A specific listing of training /tnstruction requirements, practical demonstration requirements, examination requirements and other requirements for a given job assignment.

3.14 Traveler Packet (" traveler") - A group of documents in packet form containing individual traveler forms, inspection reports and information sheets which document Construction, Quality Control, and Technical Services activities for a defined portion of fabrication and/or installation.

4.0 TASK DESCRIPTIONS 4.1 The BA 'uocumentation Final Review Program.

The initial implementation was completed through Baldwin QA procedures and a series of instructions, (BQAls). These Lnstructions, which were described in Revision 1 of this plan, have been incorporated into Baldwin Associates

?rocedures (BAPs).

4.1.1 Qualification and Certification of QA Documentation Final Review Personnel.

Documentation review personnel will be trained as Level I, II, and III QA Engineers and certified to the requirements Page 4 of 14 Rev. 2 L

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of the BA QA Training Manual. The requirements discus ed below were formerly described in BQA 184.

l The three levels of qualification for QA Engineers (Final l Document Review) are as follows: )

I Level I A high school graduate (or GED equivalent) and six (6) months of quality-related experience, or Completion of college level work leading to an Associate Degree in a related discipline plus three months of quality-related experience.

Level II High school graduate (or GED equivalent) plus one (1) year of satisfactory performance as Level I in the examination of documents to applicable codes, standards, and procedures, or High school graduation (or GED equivalent) plus three (3) years of quality-related experience, or Completion of college level work leading to an Associate Degree in a related discipline plus one (1) year of quality-related experience, or Four-year college graduation plus six months of quality-related experience.

Level III High school graduate (or GED equivalent) plus six (6)  ;

years of satisfactory performance as a Level II in the I examination of documents to applicable codes, l standards, and procedures, or  !

High school graduation (or GED equivalent) plus ten j (10) years of quality-related experience, or high school graduation plus eight (8) years of i quality-related experience, with at least two (2) years I as Level II, and with at least two (2) years associated with nuclear facilities-or if not, at least sufficient training to be acquainted with the relevent quality ,

assurance aspects of a nuclear facility, or Completion of college level work Icading to an '

Associate Degree and seven (7) years of quality-related experience, with at least two (2) years of this experience associated with nuclear facilities-or if not, at least sufficient training to be acquainted with the relevant quality assurance aspects of a nucicar l facility, or Page 5 of 14 Rev. 2 e I

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Four-year (4) college graduation plus five (5) years of quality-related experience, with at least two (2) years of this experience associated with nuclear facilities-or if not, at least sufficient training to be acquainted with the relevant quality assurance '

aspects of a nuclear facility.

-Qualification of document review personnel will be determined by written examination, and practical demonstration. The examination and practical demonstration will be documented.

Training of document review personnel will consist of periodic and supplemental training conducted by the Lead QAE, on-the-job training, and mandatory reading and will be documented.

General and specific examinations will be administered for certification purposes. A Proficiency and Performance  !

Evaluation Record will be completed prior to Level I and i II certifications. QA/DRG personnel will have a '

- performance appraisal and will be re-examined and re-certified biennially.

4.1.2 .The BA QA final review will be conducted using checklists derived from applicable procedures, instructions, codes, i standards and specifications.

The total number of checklists and categories of checklists may increase or decrease as the needs are better defined.

4.1.3 The organizational structure for the BA/DRG is as shown in Attachment 1.

4.1.4 Job descriptions for the BA/DRG positions are as follows:

a. Lead Quality Assurance Engineer (Document Review) Level III l

Duties: j

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  • Address and evaluate problems and discrepancies outside QAE's range of responsibility or expertise.

Assist and coordinate efforts of methodology of evaluation of travelers and/or documents and establish base line requirements of acceptability.

Interface with other disciplines concerning documentation discrepancies for resolution in a  ;

timely and orderly manner. l Page 6 of 14 Rev. 2 w_

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Perform traveler and/or document review.

Supervise those personnel assigned by the Senior QA Engineer (Document Review).

Responsible for the thorough and accurate documentation review performed by those persons under his/her, supervision.

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  • Assist Senior QA Engineer (Document Review) as 1

d.tected.

Qualification Required:

l -Education / Experience Requirements L Must meet applicable standards for certification as defined in BA QA Training Manual, plus prior supervisory experience in a similar work related field.

b. Quality Assurance Engineer (Documentation) Level II Under general supervision of Lead QAE (Document Review), Level III, responsible for performing final review of safety related documentation for nuclear-power plant construction.

QAE will perform reviews of records in accordance with checklists derived from project requirements documents. Results of review will be documented on the document exception list, signed / initialed by the

-QAE, and incorporated into the document as part of the final record.

Work is subject to review by Lead QAE (Document

~ Review), however the QAE in expected to work independently and must be familiar with documentation re uirements for a variety of disci lines including pi ing, supports, welding, electric 1, ci il/ structural, and associated components.

The QAd must meet applicable standards for certification as defined in BA QA Training Manual.

c. Quality Assurance Engineer (Documentation) Level I Under close supervision of QAE, Level II, a Level I QAE will assist in performing final documentation review of safety related records for nuclear power plant' construction.

_The Level I QAE will review records in accordance with checklists derived from project requirements documents.

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A Level I QAE will refer non-conforming cond?tions or documentation discrepancies to a Level II QAE for interpretation when required. Results of review will be documented on checklists and/or exception reports, signed or initicled by the QAE, and incorporated in the document as part of the final record.

The QAE must meet applicable standards for certification to QAE Level I as defined in the BA QA Training Manual.

d. QA/DRG Technical Assistant Duties:

Assigned to QA for purpose of providing technical assistance to QA Engineers performing final review of hardware and software (documents, records, drawings) prior to turnover to the owner.

Technical assistants are expected to have a working knowledge of applicable regulations and procedures.

Duties will include but are not limited to the following:

Performs initial review of Travelers and/or documents for readiness to review.

Prepares and inserts review forms.

Evaluates QA Final Review Document Exception List (DEL FORM) for the complete review.

  • Maintain control over records, including Travelers, and other documents to insure preservation and protection in accordance with applicable procedures and instruction while undergoing final documentation review.

Assists QAEs as directed / required.

Qualifications:

High school graduate or equivalent plus two years related experience, or Two years college plus six (6) months related experience

o. Senior QA Engineer (Document Review)
  • Senior QA Engineer (Document Review) reports directly to the Assistant QA Hanager for program direction and operation.

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Responsible for development and implementation of final documentation review program.

Recruit and train required staff of Quality Assurance Engineers (Document Review) Technical Assistants, and clerical support personnel needed to perform the job, Develop qualification standards, establish OJT and other training plans and provide for examination and testing of personnel as a prerequisite for certification to perform assigned duties.

Develop necessary procedures to establish the program, and work instructions, including forms, checklists, handbooks, and reinted matters to accomplish the specific tasks neccanary so that the final review process will assure satisfactory results.

Will assure that accean to, and correction, or addition to the records in in full compliance uith opplicable records management and records control procedures.

Su erviscs Lead QAE and staff of Quality Annurance En inecrn (Document Review), Technical Assistants, an clerical personnels evaluates performance, approven Icave and overtime requirements, and adjusts working houra as required.

Responsible for planning scheduling, and organizing the works and,for coordinating with other departments auch as Engineering, Quality control, Technical Services, and Illinois Power Company.

Identify and report any and all documentation discrepancien, and coordinate with appropriate organizations / disciplines for their resolution.

4.1.5 Recruiting of personnel for the DA/DRG in ongoing. A discussion of renourcen appearn in section 6.0.

4.1.6 The BA Senior Engineer (Document Review) will prepare schedulen for final review of vaulted and in-proccan records.

4.2 Tank Description- IPQA Record Surveillance Program 4.2.1 Dencription of IP QA Record Surveillanco Proceduro, QAP-117.02 pnge 9 of 14 Rev. 2 s

4.2.1.1 The surveillance program will coincide with the completion of reviews by BA/DRG on an ongoing basis and will support project schedules.

4.2.1.2 Record surveillance will consist of an <pproximate twenty percent sample of records reviewcu by BA/DRC.

Random sampling techniques will be used.

4.2.1.3 Record surveillance will be performed by record reviewers trained, qualified and certified to specified requirementa.

4.2.1.4 Records selected for surveillance will be maintr '.ned and stored in a manner to preclude record deterioration.

4.2.1.5 A computerized tracking program will be utilized to reflect the status of records reviewed in the surveillance program. The system will be able to provide a printout of resolved and unresolved record deficiencies to ensure total accountability.

4.2.1.6 Record deficiencies found during the review process will be documented and routed to BA for resolution. Records that have been corrected will be routed back to the IP surveillance group for final acceptance.

4.2.1.7 Trending of record deficiencies will be conducted by IP QA using a computerized system.

4.2.1.8 IP QA Review stamas will be used to provide objective evidence within the record package that the surveillance review wan performed.

4.2.2 The IP record surveillance will be conducted using checklists derived from opplicable proceduren, instructions, codes, standards and specifications.

The total number, and categories, of checklists may increase or decrease as the necda nre better defined.

4.2.3 Description of IP Training and Qualification Program.

4.2.3.1 Record surveillance personnel will be trained, qualified and certified an Level I, Lovel II, and Lcyc1 Ill record reviewers.

4.2.3.2 Level III Record Reviewers require the followings

a. Iligh school grndunto (or GED equivalent) plun six (6) yocrn of antisfactory performance as a Level II Recordo Reviewer or equivalent, or
b. liigh school Produnto (or CED equivalent) plus ten (10) years of rointed documentation experiences or Page 10 of 14 Rev. 2

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high school graduate plus eight (8) years of related

, Edocumentation= experience, with-at.least two (2)

Lyears las a Level II . Records Reviewer, and with at ex.~ '

least two (2) years associated with nuclear-facilities - cnr if not, at least sufficient trainingL to,be: acquainted:with the relevant quality assurance

- l aspects of a nuclear facility, or

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c. (Completi'on ofteollege level work leading to an Associate. Degree plus seven (7)- years of. related

.~L documentation. experience, with at'least.two (2) years.:of'this' experience associated with nuclear.

facilities - or if not -at.least sufficient training tolbe acquainted with the relevant quality assurance aspects of la nuclear facility.

L4.2.3.'3-1 Level II1 requires the individuals to be a high school graduate s (or GED equivalent) and have one year,of

-satisfactory performance.as a Level 1 record reviewers

. Dor _high. school diploma (or GED. equivalent) and three

. years-related documentation experiences or completion of

' college' level work leading to an, associate Degree-in a related: discipline plus one year related documentation experiences or: four year college graduate plus six imonths of related. documentation experience.

14.2.3.4 ; Level _ I:: requires the individuals to have two years aof

related. documentation-revie<w or:high school diploma-(or 4

GED ' equivalent) - and . six months . related documentation

~ experience; or completionfof. college level work leading to an AssociateLdegree_in-a'related' discipline _plus three months related-documentation. experience.

'h ' L4i2.3.'5 . Qualification and training of record; review personnel

'willibe determined'by the training and qualification

, _ requirements (TQRs)'as established for' Levels.I,-II and-

.e , III ,.

E4s2(3.61 Training. of _ record. review : personnel will be documented.

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m. ' 4.2.3.7 ; Record review personnel will be~re-examined _and

~ 1G J re-certified- biennially.

.4.2.~4:: sThe' organizational structure:for the IP. Record r , iSurveillance' Group _is as shown.in Attachment 3.

K4.2."5, Position: titles and: responsibilities for the Records.

Review'.Groupjare as follows:

"a'. ~ Records? Coordinator-L(Level III Record Reviewer)

= Duties:

. Direct: record review personnel.

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Interface with other departments / disciplines to i resolve record deficiencies. l Develop-training and qualification requirements for record review personnel.  ;

CoordinateLreview of specifications,. procedures ~and code: documents for quality requirements and development of checklists.

Coordinate and update computer tracking programs.

Required Qualifications:

Education and experience requirements necessary to certify Level III to ANSI N45.2.6-1978.

b., Level II Record Reviewer Duties:

  • ' Review specifications, procedures and code documents for. quality requirements.

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Assist Level I record reviewers.

Develop checklista to be used for record surveillance.

. Identify record deficiencies'and follow through until closeout.-

Perform record reviews in accordance with checklist requirements.

Provide data for. update of record surveillance information on the computer-tracking system.

Required' Qualification:

Individual must meet applicable standards for certification as defined in ANSI N45.2.6-1978 for Level II. .

c. Level I Record-Reviewer Duties:

Perform record reviews in accordance with checklist requirements.'

-Identify record deficiencies and follow through until closeout.

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Provide data for update of record surveillance data in the computer tracking system.

Required Qualifications:

Individual must meet applicable standards for certification as defined in ANSI N45.2.6-1978 for Level I.

.d. . Records Engineer Duties:

Review specifications, procedures and code documents for quality requirements.

Assist Level I and Level II record reviewers.

Develop checklists to be used for record surveillance.

Expedite record problem closeouts.

Expedite development or improvement of computerized systems as required.

Required Qualifications:

Individual must meet applicable standards for certification as defined in ANSI N45.2.6-1978 for Level II.

5.0- RESPONSIBILITIES 5.1 .The IP Manager Quality Assurance has overall responsibility for the-development and implementation of the program.

5.2 -The BA Manager of Quality and Technical Services has the

~ responsibility for development and implementation of the program for BA.

5.3 The-IP Nuclear-Records Supervisor is responsible for coordinating and interfacing with the BA Document Records Center personnel, Sargent & Lundy, other IP organizations and IP contractors, as shown in Attachment 2, as necessary to support the needs of the program. The IP Nuclear Records Supervisor is also responsible for keeping upper management informed of status and problems that arise and propose corrective action.

6.0 RESOURCE REQUIREMENTS The~ resource requirements needed to implement the Records Verification-Progran have expanded to the following levels:

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-BA - 157Lpcople as of. August 1, 1984.

IP - 32 people as of August 1, 1984.

Needs' will-continue to be assessed and levels will change accordingly..

7.0 : ATTACHMENTS 7.1 Attachment 1 -'Baldwin Associates Document Review Group Organization Chart 17 . 2 Attachment 2 - Site Records Management Interface Structure.

7.3 Attachment 3 - IPQA-Record Review Group Organization Chart (MISC)

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~ Attachment 1

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Revision 2 BALDWIN' ASSOCIATES DOCUMENT REVIEW. GROUP BA Manager-Quality Assurance IP.N ecords Senior QA Engineer Technical Assistant (Document Review)

I Lead QAE (Document Review)

QAE-Procurement & Vendor Documentation QAE-Piping, Mechanical & HVAC Documentation QAE-Eler .rical & Instrumentation Documentation QAE-Civil Structural & Subcontracts

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.. . 1 Attachment 2 Page 1 of 1 '

Revision 2 SITE RECORDS MANAGEMENT INTERFACE STRUCTURE IP.VICE PRESIDENT DIRECTOR NUCLEAR SUPPORT SUPERVISOR SUPPORT SERVICES SUPERVISOR NUCLEAR RECORDS I

l g-- - - - g - - - - pL---- 7---

BA DOCUMENT IP BA RECORD REVIEW CPS RECORDS RECORDS STARTUP TURNOVER G2OUP COORDINATOR m

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Attacha nt 3' Page 1 of 1. '

Revision 2-IPQA RECORD REVIEW GROUP ORGANIZATION CHART -

4 IP MANAGER-QUALITY ASSURANCE t

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!, IPQA DIRECTOR QUALITY SYSTEMS & AUDITS r IP NUCLEAR RECORDS SUPERVISOR I

i I IPQA RECORDS COORDINATOR __.,______.]

i LEVEL III

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I I I DOCUMENT REVIEW LEADS RECORDS ENGINEER i

1 DOCUMENT REVIEWERS 1


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