ML20134B243

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Confirmatory Action Ltr Re Problems Identified During 830124-28 Special Insp Concerning safety-related Electrical Work at Facilities.Discussions Lack Continuation of Stop Work Order Encompass Electrical Auxiliary Steel
ML20134B243
Person / Time
Site: 05000000, Marble Hill
Issue date: 02/02/1983
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Shields S
PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
Shared Package
ML20132B505 List:
References
FOIA-84-293 CAL, NUDOCS 8508150560
Download: ML20134B243 (22)
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%.....J FEF " 1933 Docket No. 50-546 Docket No. 50-547 Public Service Indiana ATTN: Mr. S. W. Shields Senior Vice President Nuclear Division Post Office Box 190 New Washington, IN 47162 Gentlemen:

This refers to problems identified during the special inspection conducted January 24-28, 1983, in the area of safety-related electrical work at the Marble Hill facilities. The findings from this inspection resulted in your voluntary stop work in the electrical area. Based on discussions between Mr. R. C. Knop of the Region III staff and Mr. L. Ramsett of your staff on February 2, 1983, with respect to the electrical stop work, it is our under-standing that you will:

1. Continue the stop work order as specified in Public Service Indiana letter te Commonwealth-Lord Joint Venture number COE-0:E3-E3, dated January 25, 1963, with the following clarification: the step work encompasses fabrication and installation of electrical auxiliary steel; cable tray and conduit hangers; and cable tray and exposed conduit.
2. Review all CARS, MCARs, NCRs, and inspection reports as related to Itam 1 above, and verify that all nonconforming conditions are doc-umented as part of the NCR system and control (tag) all nonconforming items identified.
3. Review and revise electrical contractor procedures (CVPs, QWPs, QCPs, etc.) as necessary to ensure that all Regulatory, SAR, specification, and code and standard requirements are addressed.
4. Develop an adequate system for inprocess and final work activities that includes as a minimum: completion of verification and hold points and other required signoffs prior to the item being considered complete; referencing or attaching NCRs, deficiency reports and other related documents; and listing calibrated tools or instruments utilized in the work / inspection activity. Review the closed traveler packages C

_. 9 kheh CONFIRMATORY ACTION LETTER

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  • f f CONTIEMATOEY ACTION LETTEE Public Service Indiana -:- pgg ; g33 and identify all open items. Convert the e>:isting open travelers and closed travelers with open ite=s into the revised system. Levelop a system for determining the status of inspections, tests, and final acceptance of work activities performed by the electrica? contractor.
5. Provide documented evidence of personnel training (angineering, quality and construction, including craft) prior to implementing the revised procedures.
6. Audit all aspects of the corrective action taken by your electrical contractor to correct and prevent recurrence of the items identified by the NRC, PSI, and the electrical contractor.

We further understand that the stop work order will remain in ef fect until your program for improved control over the electrical construction program as set forth above, is approved by the Region III office.

Partial work releases in areas defined by the licensee are permitted with the concurrence of Region III, provided that the prerequisites, as outlined above, are completed for that sequence of work.

Please let us know immediately if your understanding differs from that set forth above.

Sincerely,

,2 3_7 /h ,

James G. Keppler Regional Administrator cc:

W. M. Petro, Executive Director ruclear Project Management DMB/ Document Control Desk (RIDS)

Resicant Inspectdr, RIII LeBoeuf, Lamb, Leiby & MacRae Lave Martin, Office of Attorney General John R. Galloway, Staff Director Environment, Energy and Natural Resources Subcommittee .

E. P. Martin, Wabash Valley Power l

Association Thomas M. Dattilo, Save the Valley J. Axelrad, ELD l E. Jordan, DEQA J. Taylor, DRP

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CVERVIEW This cocument covers the activities tnat will ce acccmplished in order to address and resclve all items identified in the NRC Confirmatory Action Letter regarding the stop work order in effect en the CLJV Construction Program. The listing of these activitics constitutes the action plan itself and d:es not ccnstitute any attempt to establish policies or philcscphies relati.g to the final resclution of these matters.

Tne acticn plari is crcken ir.te five separcte areas re'.ated to tnt NRC Confirmater. Acticr Lette: ite r ;,2,4,- a r. d - .x pti".!s crCugn Up 1P O T.e '!E C E Xi *. Mieting CT C a r.u a r, 25, 1962, relatir.g tc the inspecticn per lon cf the meeting .1.1 ce addlessed in the final resolutlen to each item as applica'le. c Item 3 will 6ddress inspecticn points 1 and 3. Item 4 will address inspection point 2.

FotA-84-273

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(ITIM $ 2)

. PUR?CSE Review of MCAR's, CAR's, NCR's and Inspectica Checklists per-taintng to fabrication and installaticn cf cable tray, expesed conduit, caele tray hangers, conduit hangers a..d auxiliary steel. Verify that all nonconforming cond tiens are documented as part of the NCR system and tag all nonconforming items iden-tified.

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.i ~ . =..zn Al MCAR's CAR's Survatilance Repcrts

1) PSI Review and give status tc C*JV on all CAR 's and Surveillance Reports written against CLJV.

ii) Review MCAR's, CAR's, and Surveillance Reports to assure that ..cnconforming conditions are docu-mented as required by QCP-C10.

ilt) Initiate NCR's, as required, in acecrdance with latest revisicn of QC?-C10.

3) NCR's
1) Provide a status of all NCR's, i.e. locacica, state of completion.
11) Review NCR's o determine if hold tag / flag and werk release as;ing/f'.agging is required, refer-ence ;CP-C10 latest revision.

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illi Verif) that al. IAqs/ flags fOr Open NOF*$ Sre af,0';6 d ,

Wnere required, O r re=cve d if *.T.e NOF s cicsec.

j Ivi Revise NOR's, at neressa-), :: meet the requirement i stated in ter 3 aceva ,

i j C) Inspectior. Checklists

1) Review QA Records Log and determine Scope of Review.
11) Review to assure all nonconforming cond:tions are

) identified, properly referenced, and documented.

4 l iii) Review NCR's referenced on checklists and compare l nonconforming conditions with stated unsatisfactory condition on Inspection Checklist.

iv) Conditions which are not properly documented shall l be documented in accordance with QCP-C10 latest revision.

2) DOCUMENTATION REVIEWED BY A) Inspection Checklists, including referenced NCR's, shall be reviewed by a certified Level II or III Inspecter.

, El NOR's shall be reviewed by a cert:fied Leve' :: cr :::

! Inspec cr. Statusing 5:R's sna;l ce a::cmpl;snef c-/.

v tne QA Reccrds Grcup.

4 1

i C) MCAR's, CAR's and Surveillance Reports shall be reviewed by a Quality Essurance Engineer.

i 1 3) DOCUMENTATICN OF REVIEW i

,Tnis review shall be documented and shall contain the follcwing:

I A) Review document number.

B) Reference to specific instructions followed during the

, review as required by MCAR 017.

C) Deficiencies found and corrective action taken in accor-

dance with approved procedures. .

D) Signature, title, and level of person performing the review.

Documentation review sheets shall become part of MCAR 017. '

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i PCRPCSE PSI will develcp a Special Process Precedure (SPP-35) to address the review of all Cc=menwealth-Lord J.V. (CLJV) Ccr.s rue::.cn Work Procedures (CWPs), Quality Work Procedures (QWPs) and Quality Control Procedures (QCPs) to ensure that all Regulatory, ,

SAR, specification, and code and standard requirer.ents are j i

addressed.

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i 1. 57F-25 will be :,ssued by 2-9-52.

2; The rev:.ew of al'. CLJV CWP's, QWF's, and QCP's identified in SPP-25 will ce completed by 2-15-82.

2) All ecmments generated by SPP-25 will ce processed ar.d implemented enrcugh the PE: Procedure F.eview Scard.
4) CLJV will address and dispcsition all Gilbert /Ccecenweal h audit recommendations and ce ccepleted by 2-12-22. PSI will review and cc= cent before final acceptance. l CLJV has established a list (copy attached) cf procedures required 4

to restart specific activities of the Werk. The review conducted under SPP-35 will be prioritized based en CLJV's list.

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CL."i Precedures Eecuiref ?:r Ees:trr Procedure No. Title i

CWP-C33 Fabricatien and Installati n cf ,

Elec:rical Suppcrts G7-C7 Reuting Se;rega:ic: & Identif:.ca:icn Label Installation r

Cb7-CSA Welding ?recedure (General)

G7-CS3 Welder Qualification G7-CSC Welder Filler Material Centrol CWP-CSD Welding Procedure (Specific)

G7-CSG Welding Procedure (Welded Stud Bolts)

CWP-C143 Seis=ic Cat. I Conduit System Installation Ck?-C16 Seismic Cat. I & II Concrece Expansion Anchor Installation

! CWP-C19 Control of Measuring & Testing of Equipment QL7-C2 Electrical Equipment Leca:ica Laycut QWP-Ca2 Electrical Installati:n Traveler QWP-C43 Training l QCP-C2 Cable Tray & Hanger Inspection QCP-C5 Inspection Checklist QCP-C9 Inspection of Cencrete Expansion Anchors ,

i QCP-CIO Nonconformance Reporting, Statusing ,

and Corrective Action QCP-C17 Exposed Conduit Installation Inspection QCP-C20 Visual Weld Inspection 1 1

QCP-C22 Inspection of Material Heat Code Traceability )

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1. Review cf precedures:
a. CZ?-C33, Rev. 4, 10/26/S2, Tabrica:1cn and installatien cf Ilee:rical

' Supports i (1) 4.2.3 - An "H" plate ccnnec:or, Std. I3-502, shall be installed J

on the cable pan general notes and installatien detail drawings.

Mr. Love suggested this be reworded.

(2) 4.2.9 - Indicates that no velding can be perf erned en the cable tray af ter cabling has been installed. Mr. Love suggested PSI censider developing a cable protec:1cn procedure for cases where raceway needs to be reworked af ter cables have been installed.

b. CW7-C4A, Rev. 3, 10/27/82, Docunent con:rol - no ec==ent.
c. CW?-C43. Rev. 2, 12/3/S2, Document Centrol (Correspendence) - no cen=ent.
d. CW?-C63, Kev. O, 9/2/90, Cable :ns:alla:ica and ernina:1cn Docunen:a:1ct (1) 4.2.1.1 and 4.2.2.2 - Ref erence CW?-CEA, which has -c been issued as cf this da:e.

(2) 4.2.2.4 and 4.2.2.6 - Mr. Icve suggested the additien of vcrds in these paragraphs about cable sidewall pressure calculations.

He noted that when sidevall calculattens have been addad in the installa tion procedure, it should carry over :o C63. .

e. CW?-C6C, Rev. 2, 7/23/82, Cable Ins:allation (1) 4.1.3 - States that QC inspe::s Category I insta11atiens, and Engineering inspects Category II, except these designated as par:ial pulls. Mr. Lcve felt this is incerrect.

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(:) 4.f.; - Mr. L:ve :a:ed :ha: In;;neerin; nee:t :: :s:er: na

'e-- sheave si:e e as ne: :: ey.:eed zinicu ben: radius and

=axi=u: sidewall pressure. ALsc see E -146, 7.1.2, zieu:

ins:alling additional pull bex. regarding stieva"." press.

(3) 4.5 - Mr. Lcve s:2:ed tha: again ve need sene v:rds en sideva11 calcula tien s .

1' (4) 4.9.19.1 - Pr:ble: vith 3 fee: ef reu:ing p:in: noted in precedure.

Mr. Love ques:icned if ::ay edge sof tness vill be qualified fcr -

. nuclear use.

1 (5) 4.9.29 - Mr. Love noted that this discusses separation be:veen II and 30P cables, but not redundan: cables.

(6) Mr. Love s:ated that when using black-jacketed cables the cables should be =arked every five f eet wi:h color coding per IEEE 354.

Color coding of support cables every 35 f eet in risers was not addressed.

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(7) 4.9.30 - Sta:ed soap was used as a cable pulling lube. This needs to be rewritten.

(8) 4.9.31 - Mr. Love asked hev PSI planned on certifying break links.

(9) 4.9.36 - Procedure discusses "co:bing" cables to bring them below the top of the ::ay. Mr. Love suggested we censider training cables during installation. This is being done at Clint=n.

d Suggested trip to Clin:en by key persennel :o reviev this precess.

(10) 4.9.46 - Prc:edure sta:es craf: and QC :: enter badge u='ers. r t Mr. Leve asked if the sa:c badge nu: bars are ever reissued.

(11) 4.11 - Cable Re cval - Mr. Love questiened pre:ectics of cables l renaining in the raceway, and asked if tension is conitcred and recorded during pull-cut.

(12) 4.12.3 - Mr. Love sugges:ed we c:nsider using tve ropes or saddles

o support coiled cables. ,

I (13) Z3-146, 6.2.2 " Supports shall be dedicated to the same safety-

! related division or channel as the Class II circuits installed l l

in the respective conduit being supported." 30P cenduit installatten 4

crews, as well as S.R. crevs, should be aware of this require:ent.

f. QW?-C42, Rev. 2,12/29/S2 - Electrical Ins:1allatien Traveler 1 (1) 4.2.1 - Changes to Traveler by a yield Engineer - Need to take 1:

clear when a traveler has to go back thru reviev cycle.

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(2) 2.1 - no concent.

l (3) 4.4.4.1 - Traveler steps need not be performed in sequence; hevever, i each step cust be signed-of f before next can be star:ed.

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i g. OC?-C , Kev. 6. 11/4/S2 - Cable !rcy and Hanger inspec:ic (1) 2.1 - Needs to be expanded :: include Categcry : :n-saf e:y-reia:ed tray to hanger attach:ents and ::ay splice Sci:s. I (2) 4.4.2 - Lists hanger horicental :.e:ber clerance f er belted cannections as j, one-half inch; hewever, dces ne: address velded C Cnn ec tions'.

h. QC?-C4, Kev. 1, 7/23/81, Inspection Report - no c e=:en ts .
1. QC?-CS, Rev. 7, 11/S/S2. Inspection Checklist - n o c e ==en :s .
3. Procedure QC?-CIO, Rev. 5, 10/12/82 f 4.2.1 'Jhen an undocu ented nonconfer ance is de:ec:ed,1: shall be l docu=ented on the noncenf or:ance report fort....

l f 4.2.2 - All "ha rdware" ite=s a t the Marble Hill Nuclear Site that are

deter =1ned to be nonecnf or=ing shall.have ene or cre hold tags af fixad to or adjacent to the ....

4.2.3 - Docu=entatica or procedural nonconfer ances vill not be hcid

agged er segregated. Hevever, the ;hysical 1:ers affec:cd by do:uzen:ation er crs shall be cen::cIl-d as required by 4.2.2.

3.2 - Held Tag - A tag that may be af fixed to or adjacent to a ncnconfor=ing ite=, and unless rodified by a work release :ag, used to prevent nonconfor=ing ite:s f rc: being coved, further i

processed, installed, tes:ed or operated, j NCE 233, dated 6/1/82, indica:es that hold tags were not a:: ached to cable

ay hangers H003, H009, H050, and H097, auxiliary-steel. This auxiliary  !

j steel was identified as ncnecnf or=ing beca'use velding was being perfer ec vi:hou t a traveler being issued for the 1:e=s. This NCR vas closed '

6/2/82 en the basis that MCAR-004 was issued on 6/2/82. Mr. Love asked hev these it,ers were controlled to prevent further processing i NCR 392, 9/15/82 - No hold :ags. At:ach ent "A" added to cepy presented

o NRC 1/27/83.

30R's '331 and 396 - no ce==ent.

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i ACTION PLAN ::: RESPO::!I TO

! NRC CONF RMATORY ACTION *ETTIF .

. (ITEM =O l,

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P'JRPCS E To develop an adequate system for inprocess and final work activities that will, as a minimum, address the following l

areas: Ccepletion of verification and hold points and otner required signoffs prior to the item being considered cceplete, P

l referencing or attaching NCR's deficiency reports and other j related documents, list calibrated tools or instruments utilized  !

i j in the work / inspection activity. The system will centrol d:cu-ents: en generation and flow fr:m :ne pein: Of assae te p: n:

! cf completion and turncver to PSI. The sys:em will aise nave the capability to status inspections, tests, and final accep-i

) tance of work activities perfermed by CLJV. All existing travelers, both cpen and closed, will be reviewed and deftciencies will ,

be identified. Conversion of existing travelers into cne new system will be accomplished as necessary.

SCOPE 1

1) Develop list of all specific types of physical ccnstruction i

< work activities done by CLJV and prioritize for review.

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2) Review each work activity and define how the documentation

( generated for installation / inspection will be tied to PSI's i area / subsystem turnovers outlined in TPAP 103.

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3) Determine all existing procedures that are applicaole to each work activity.

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4) PS: develop pro]ect petitlen on status. :n-prccess and trace-

. acility requirements for the system. l i

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5) Review existine pro:edures ft: earn a-crk a:::v:t3 :: determ:ne i

applicability to requirements stated in ';E0 00nfirmatery i Letter Item 84 and criteria er:arlished ir. Stept *2 and

s4 a ove.
6) Begin revising procedures for prioritized activities, inclu-  !

ding comments from the SPP-35 program, to meet criteria addressed in Step #5 above and all QA Program requirements, i including: Completion of verification and hcid peinte j and other required signoffs prior to items being considered complete, referencing NCR's deficiency reports and other related documents, and listing calibrated tools or instru-ments utilized in the work / inspection activity.

The revision shall include a comprehensive descriptien cf 4 requirements for documentation generation, flow and control f from point of issue to point of completion. The revision shall also contain a comprehensive description of a system to status inspections, test, and final acceptance of work activities performed by the Electrical Contractor.

7) For work activities that will not require any special docu-mentation " traveler" system, write a comprehensive statement  ;

on new pregram require.,ents are met and the rtatement snall 4

include necessary revisiens t: encse applica:16 prc:tdurer.

The statement shall include all QA program requirements, including: Completion of verification and nold points and  ;

all required singoffs prior to the item being considered complete, referencing NCR's, deficiency reports and related

documents, and listing calibrated tools or instruments q utilized in the work and inspection activity. The statement j shall also describe the system for determining the status j of inspections, tests, and final accepta,nce of these work j activities performed by the electrical contractor. Tne ,

! statement shall also contain all necessary decisions for [

procedurally describing the statusing system.

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8) CLJV review and resolve any problem areas on each procedure.
9) Call for PRB meeting on each procedure resulting in approval
of procedure.

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10) Institute training on each procedure (Item #5) l
11) In parallel with Steps 1 through 7 above, review all existing 9 travelers (NCR 1377/1402 for closed travelers, NCR 1390

] for open travelers) and identify deficiencies, i

. 12) Review converting existing travelers into revised system resulting from Steps 1 through 8. The QC Inspection Check-l list will be attached to each traveler.

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a. 2L-;Y vaul: c:;1es :f : aveler ;t::.a;es f: ha gers I-:--2:U.H'.11.

I-1-20f1H011 and MC12. ;:esente: as c:=p'.e:ed pa:k. ages:

I (1) HC2S l (a) No QC sign-cf f f or ca:erial verifica:icn and f e: hanger cc:ple:ed. Traveler had been signed of f as being cc ;1e:e and acceptable by Cons truc tien, In;ine ering , and Quality Assurance.

I (b) Procedure states that if a block (under QC sign-cf f) is N/A, the inspector shalt initial and date :he N/A. Mr. Love stated he did not rece=ber seeing an N/A initialed and dated.

(c) Mr. Leve asked when auxiliary steel and hanger veld would be painted. ,

(d) Heat / lot nu=ber of filler esterial listed.'

Certificaricas f or this rod were satisf actory.

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(2) E011 (a) Heat / lot nunbers were tissing. Referenced to MCAR 013, dated 12/21/82. Review of MCAA 013 indica:ed that hanger H011 is not included in the attached NCR's.

(b) Ranger traveler signed of f at bet:c=. No NCR's were listed en ::aveler. Eack-up docu=entation ref erenced NCK-392; h vever, hanger H011 not lis:ed en copy of NCE ;resen:ed.

Mr. Leve s:sted :ha: they fina*.ly f ound listing in clesed NCR 2*7.

(c) Mr. Love questiened the painting of velds.

(3) 5012 - sa:e as H011.

Mr. ~ eve noted that fre: inf ormatien ob:ained, no hold :ags were

- attached to indicate tha: hangets were en hold.

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b. Reviewed 25 travelers in Auxiliary 3uilding, 426' elevation, I-0-3051 series.

(1) Torque viench used by craf t not identified.

(2) No sign-off space on ::aveler for torqu,ing of tray splice bolts.

! (3) H034 appeared to be in blue ink; however, could not read =any of the entries as they were smeared. Ite: lined out with no initial or date. -

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(4)' During initial review of travelers, FE, Superintendent, and

' Quality not dating their review.

(5) H016 - Auxiliary steel caterial listed, quantities were deleted.

Hanger naterial quantities dele:ed. Mr. Levo questiened what l

=

natorial was used.

c. Eeviewed 30 ::avelers in :he Auxiliary Iuilding 439' eleva:icn.

E-0-3062 series:

4 (1) H002, 9/14/S2 - T. ree changes =sie in ref eren:e d::uzen: ::1u=n en 1/17/53 by MC, ::avelcr net revised and sen: ta:k :hrru;h the

raveler review cycle.

(2) H004, 9/14/S2, =cdified 1/1 /S3 - MC - ne revision.

(3) H006, 9/14/82, :odified 1/17/83 - MC - no revisien.

(4) HOOS, 9/14/82, =odified 1/17/83 - MC - no revisien. ,

i (5) H022, 9/14/82. TCK" #E-5623 added - no initials date, revision.

i (6) H02S, 9/15/82, =odified 1/17/S3 and 1/18/82 - MC - no revision.

4 4 (7) Nine additional travelers checked - same problems.

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! (8) Same type ite=s identified with E-1-3061 series travelers.

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d. Sa:e :ype ite=s identified vi:h E-203002 series travelers in Auxiliary Building, 346 ' eleva tion.

(1) H517 was revised per TCR-E-5321 on 12/8/82 (Rev.1). Revisica 2 was issued 1/21/83. FCR's I-5307 and $275 added; no ini:dal, date, revisien. ,

(2) H511, 10/25/52.

(a) Ranger fit-up signed of f by Construc:icn 11/3/E2.

(b) Note at ached to traveler stated: "Can't co:plete fit-up un:11 A12 panels arrive, cut A-12 pla:es."

e. Auxiliary Building 383' E-2-3002 series travelers.

4 l (1) H027 (a) Revork supple:ent added to traveler because QC had identified a veld overlap probles.

J (b) Revork'vas cespleted 1/11/83. QC signed of f the rework on 1/14/53, but f ailed to note an inspectten report nu ber or discrepancy nu:bar in space provided. Mr. Love j

sta:ed'he was unable to de'terzine if accep:ed or rejec ted.

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Mr. Love asked the folleving question: "Per the CL-JV procedures,

' if two violations are allowed bef ore an NCR is prepa red, hev is this trended?"

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AC":CN ?~AN IN RESPONEE TO 4

NRC CONF:RMATOEY ACTICN LETTEE (ITEM *S)

. PURPCSE To develop a' training program that would be applicable to all 3

CLJV personnel (QA/QC, Engineering and Construction). This program will address the formulation of supervisory and other CLJV personnel as qualified instructors for training class presentations. This program will be documented and be traceable i to the vault. This program will address and establish all aspects necessary for successful and effective implementation s

of a raintng prtgrac :ncluding lesscn plans, lessen guides, training schedules, training matrices, and documentation require-l ments.

i SCOPE

1) Deletion of CWP-C43, Rev. O, tra'ining procedure, after -

approval of CWP-C43.

2) Write GWP-C43 training procedure.

A) This precedure has been written and is in approval cycle. (should be 3 days max to final approval).

3) Revise QCP-C1, Rev. 3.

A) This precedure is now under revision - to define training department responsibilities and training department control. (should be 7 day max to final approval).

4) The following forms for training documentation purposes have ceen developed er censolidated into a single form,
as attachments to the new training procedures i

A) CLJV Cualified Instructor Certification.

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. . . . . =: . t re .

B) CLJV M/H Lesson Guide.

C) Quality Training Attendance Reccrd.

D) CLJV Training Department Examination.

E)

CLJV New Hire Indoctrination Record Sheet.

5) Procedure Lesson Guides have been developed for all current CLJV Procedures - QAP 's , QCP 's , QWP 's and CWP 's . Procedure Lesson Guides will be revised, as necessary, to follow any revisions resulting from Item e4, Steps 5, 6 and 7.

i

6) An Individual Required Procedure / Document Reading Program is now implemented for all CLJV personnel down to the foreman level and is operating smoothly in respect to traceable documentation. The Required Reading Program consists of the following:

A) Individual Required Reading Matrix, which is submitted to supervisors for their input to the training department, showing what procedure / documents their personnel are required to read in what priority - 1st Issue, 2nd Issue, and so on.

B) Three folders were developed for eacn :ncividual:

i) Felder "A"

- was transmitted to the vault, for filing completed reading notification acknowledgements and associated Document Quiz.

ii) Tolder "3"

- is kept in the training department files containing a Required Reading Record, which tracks the doeurents on Issue to the individual, the date documents are issued, date completed and date tested. This folder contains Issues of all documents that have been established by priority and quantity by the individual's supervisor, iii) Folder "C" i

- is a folder that travels between the individual '

and the training department. This folder contains a letter of introduction to the " Required Reading Program," an Individual Required Reading Notification, a copy of each document on the Notification, a Document Qui: and Instructions for completion and return.

4 ..1

7) New Mare Ind0ctrtnatien - has been revised under the new QWF-043 procedure :: estaolish sur:e:t naterial :: ce cevered tn ths Indcetrination and is d:cume..ted - tracea 1e to the vault.
8) Instructors a preliminary list of CLJV instruercrs has been established and teaching sessions will be assigned according to subject that the instructor is certified /

qualified in.

9) Training schedules will be established under the new QWP-C43 training procedure provisions to be preventative training, tracking the construction schedule and be traceable to

, the vault.

10) Training files - due to the revised previsions of QWP-C"3 can now be maintained and be traceable to the vault.

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(ITEM #6)

AUDITS CLJV will assign an auditor to audit all aspects of the corrective action taken to correct and prevent recurrence of items identified by the NRC, PSI, and CLJV as related to all work perfcrmed addressing items 2,3,4, and 5 in the NRC Confirmatory Letter. PSI will conduct surveillances as necessary to ascist CLJV during the develcpment and completion of actions to address items 2,3,4, and 5 in the NRC Confirmatory Letter. After completion of all work relating to all items addressed in the NRC Cc.. firma: cry Le::er, ?S: -111 cenduct a ecmprehensive audit prior to close-cut of PS! CAR-0CE.

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i OBalfelle 376-4908 February 8, 1983 f!r. Ken C. Carroll EG&G Idaho, Inc.

P.O. Box 1625 Idaho Falls, ID 83415

Dear Ken:

Attached is my appraisal of the fiarble Hill project engineering /

design / purchasing activities based on the 20 key indicators. I also added a numerical rating for each indicator that I could assess.

I am very interested in how all our appraisals fit together.

I'll try to complete a similar appraisal for Diablo Canyon soon.

Sincerely, -

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aioY'dHarty'W(b

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/

e'nior Staff Engineer '

HH:nb c: 11. D. Al tman - f1RC Hg Richard Kleckner - Kist & Associates M. G. Patrick - BCL S.11. Heaberlin - PNL l

foiA-84-2 93 g toa  !

EVALUATION OF GENERIC KEY INDICATORS FOR PROJECT ENGINEERING / DESIGN / PROCUREMENT ACTIVITIES AT MARBLE HILL NUCLEAR POWER STATION

1. The organization is fully committed to a program for assurance of quality.

Senior management are actively engaged in assuring that adequate quality is built into the plant. They have backed up their intent with time (in site visits and meetings on quality) and funds (by providing adequate levels of staffing). Management works with QA/QC staff to improve their approach to decision making. Rated 5.

2. Responsibility and authority appear to be clearly defined and properly impl emented. Procedures are in place governing responsibilities and authorities, and personnel are required to acknowledge in writing changes which pertain to them. There is an acceptance at the working level (nonsupervisory professionals) of the procedures. There is a significant involvement of QA personnel in the planning of the construction work.

" Whistle blowing" is actively encouraged. Rated 5.

3. A well-qualified professional engineering staff was assigned to Marble Hill. Most have significant experience appropriate to their present positions. Some are on the cutting edge of their technology (e.g., on cost and schedule monitoring). Not all personnel in key positions were PSI employees, however, so some projects strengths may be lost to the company as the plant becomes operational . Rated 5.
4. Instructions, procedures, and drawings were well controlled and appeared current. There was an effort to ensure a consistent approach to quality down to the craft / laborer level. Rated 5.

Having been burned badly in the matter of assurance of quality early-on 5.

in the project, evidences that might suggest a compromise of quality appear to be closely monitored. There is a management information system on quality of construction-related activities, but its usefulness to upper management was not determined. There is an attitude within the PSI project staff toward quality that is very positive, and which suggests that quality deficiencies are promptly identified and corrected properly. Rated 5.

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6. The corrective action program, to the extent observed, appeared effective.

The management, in particular, seemed tuned to root cause detection and/or eradication. Staff training in assurance of quality was an emphasis.

Rated 5.

7. Information on independent design reviews per se was not obtained. The PSI project engineering staff reviews all the " top level" drawings issued by Sargent and Lundy (S&L), but not "all 60,000 drawings and 210 (?)

specifications". Project engineering does review all design changes. Some type of design review may occur within S&L as a matter of course as the Byron design is replicated at fiarble Hill. Design changes resulting from field changes are all reviewed by Sargent and Lundy prior to release to the field for construction. S&L is increasing their staff at flarble Hill from about 20 to over 100 in early 1983 in recognition of the importance of processing change orders expeditiously without compromising design quality. Rated 4.

8. Infomation on control of design input data, per se, was not cbtained in detail. The design control process appeared to be adequate. However, there was concern that the " replication engineers" at S&L were not as knowledgeable of the background of the design as were the Byron engineers at S&L who did the original design. Rated 4.
9. The organizational structure was relatively straightfomard and appeared to be understood by those interviewed. The formation of construction management teams at llarble Hill appears to have removed much organizational ambiguity that had previously existed. Rated 5.
10. The planning, scheduling, and budgeting activities are excellent. Good coordination exists among construction, engineering, procurement, inspection, etc. The flarble Hill cost-schedule integration system is a cut above anything else that exists in the industry. Not only does it provide an estimate of job completion and cost to complete, but it also shows where there is a breakdown in productivity and changes in critical path scheduling.

Rated 5.

11 Not assessed in detail. See items 7 and 8.

12. Not assessed in detail. See items 7 and 8.

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13. All contracts are processed through a single organization at Marble Hill.

l S&L reviews technical specifications and quality aspects. The purchasing organization monitors the contract, change orders, and delivery. All information pertaining to the purchasing process is forwarded to the records canagement function for filing and storage. The purchasing function is audited twice a year by consultants. Rated 5.

14. Not assessed.
15. Not assessed.
16. Not assessed.
17. Not assessed.
18. The records control for Marble Hill is excellent with respect to control and distribution of' design drawings, specifications, and related project materials. All materials are logged in, photographed, distributed, and controlled from a control organization. Outdated material is retrieved and the process is documented. Records are stored in a fireproof vault.

Rated 5.

19. Audits appear to be made for many of the functions at Marble Hill, including purchasing (by outside consultants) and project engineering (internal, management QA, and NRC audits). Audits seemed to be quite common at NarbleHill. Rated 5.
20. Corrective action seems to be adequate. Cost and schedule are acknowledged as important considerations, but not as important as quality, at least at this time in the project history. There is no reluctance to inform

' management of needed changes and there appear to be ample opportunities to do so. Rated 5.

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