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5 PROGRAM PLAN INDEPENDENT CONSTRUCTION REVIEW OF MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 AND 2 l
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PUBLIC SERVICE INDIANA JUNE 1983 J& lENY TECHNOLOGY F01A- @ 4 9 8508150367 850703
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G A-C17143 PROGRAM PLAN INDEPENDENT CONSTRUCTION REVIEW OF MARBLE HILL NUCLEAR GENERATING STATION UNITS 1 AND 2 1
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1 SECTION TITLE PAGE 1
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Summary...............................................
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II Cons truc tion Review P rogram...........................
4 Task A Evaluation of QA Organization and Management.. 5 - sftw(
Policies Toward Quality Assurance. 8to u d m-c M
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Walkdown Feature Splection..(............
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C2 Walkdown Procedures.
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Task D Testing......................................
22 D1 ASME Piping Weld Inspection..............
22 CT' h Concrete Inspection...................... 23 d %, i [s Task E Construction D.ocument Review................. 26 E1 ASME Piping Material Certification Review 26 E2 Concrete Test and Inspection Review...... 27 tb E3 Welder Qualification Records.............
28 E4 Safety-Related Equipment Maintenance..... 29 L'.y ed..-
and Storage Task F Potential Finding Processing.................
33 Task G Administration and Reports...................
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SUMMARY
A program plan has been developed to conduct an independent review of the construction of the Marble Hill Nuclear Power Station.
The program will
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also provide an insight into the management effectiveness of the quality assurance program for the construction of the plant. This program will be performed by GA Technologies Inc. (GA) through its engineering services division, Torrey Pines Technology.
The program presented herein has been structured to provide a discerning basis for judging the adequacy of the construction of the Marble Hill power plant.
This is accomplished by reviewing the construction design control system and its implementation, by reviewing inspection and fabrication records for safety-related items, and by inspecting constructed items in the field.
The items selected for inspection will be representative of j
various levels of complexity, types of hardware, interface relationships, and will include safety-related mechanical components, piping, and struc-tures. The program will also review the Quality Assurance organization and management policies toward quality assurance.
A seven element approach to construction review constitutes the planned program:
Task A QA Organization and Management Policies Toward Quality Assurance Task B Construction Design Control Task C Physical Inspection - Walkdown Task D Testing Task E Construction Document Review Task F Potential Finding Processing Task G Administration and Reports Torrey Pines Technology (TPT), is eminently qualified to perform this evaluation for Public Service Indiana (PSI).
TPT is experienced in conducting such programs as evidenced by the recently completed independent reviews for verification of the San Onofre seismic design for Southern - _ _ _ - _ _ _ _ _
California Edison, construction verification of Shoreham for Long Island Lighting Company, quality assurance evaluation of Palo Verde for Arizona Public Service Company, and system design review of Waterford 3 for Louisiana Power and Light. TPT is currently performing a management review of Zimer for Cincinnati Gas & Electric. TPT also operates under the first NRC-approved quality assurance program.
GA Technologies Inc. has not had significant involvement with Public Service Indiana and the Marble Hill Nuclear Power Station in the last two years. The individuals assigned to this project will be free from conflict of interest.
The independent construction review is scheduled to be completed in September 1983 as shown in the overall schedule of Figure. 1.
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CONSTRUCTION REVIEW PROGRAM The purpose of this program is to conduct an independent review of the construction of the Marble Hill Nuclear Power Station to evaluate compli-ance with approved design documents for systems hardware and structures and to document that review in a final report.
This effort will include a review of the Quality Assurance organization and management policies toward quality assurance.
The program is structured to verify that the construction process converted design document requirements into the completed features and that quality assurance is receiving adequate management attention. This will be accom-plished by reviewing the QA organization and management policies toward l
quality assurance (Task A), by reviewing the construction design control system and its implementation (Task B), by physically inspecting features of the plant (Tasks C and D), and by reviewing selected construction documents (Task E).
Safety of the public will be given primary considera-tion in the selection of plant features to be reviewed.
Any discrepancy that is identified during this process that could potentially have signifi-cant impact on the quality of the plant is documented and reviewed (Task l
F).
Status reports and a final report on the adequacy of the Marble Hill plant construction will be prepared and issued (Task G).
Detailed descriptions of the tasks included in this program are contained in the following subsections.
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TASK &
ETALUATION OF QA ORGANIZATION AND MANAGEMENT POLICIES TOWARD QUALITY ASSURANCE In the context used herein, the term " quality assurance" includes control measures implemented by all persons performing quality-related activities
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and is not limited to activities of the QA Department.
OBJECTIVE
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To evaluate the organizational status of QA on the Marble Hill project and
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to review PSI management policies which affect QA and assess the degree to I
which those policies help to assure an effective QA program.
I SUBTASES
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A1 Prepare a procedure, and checklists as appropriate, to accomplish the j
evaluation described below.
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A2 Meet with PSI personnel to discuss this task, identify and interview appropriate personnel and obtain relevant manuals, procedures and f
supporting documents.
A3 Evaluate the organization level and status of the PSI QA Department to I
determine if the level, status and staffing are consistent with that required for an effective QA program.
A4 Review job descriptions and procedures relevant to defining authority.
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and responsibility of key QA personnel.
Evaluate these documents to F
determine if the responsibilities and authorities so defined are com-mensurate with that required for an effective QA program.
AS Evaluate PSI QA Department's access to upper management to determine if QA program status and problems can be, and have been, brought to the attention of upper management and acted upon, as appropriate, in a timely manner.
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A6 Evaluate the PSI QA Department's involvement in project activities to determine if the QA Department was sufficiently involved to help assure adequate QA control and cognizance over the project.
A7 Evaluate management's involvement in QA activities to determine if management was sufficiently involved to provide an appropriate level of support and status to the QA program. Evaluation will include organi-zational level of QA with relation to line and site managers respons-ible for activities affecting quality, communications channels between QA and other senior management positions, distribution of QA reports to management, QA and project meeting attendance and PSI policy statements regarding QA.
A8 Prepare a summary report on the work in Task A.
MILEST0llES A1 Procedure and checklists 6/24 7!/ f-- Y A2 Interviews, document collection 7/22 mr Level and status of QA Department 7/22 h Authority and responsibility of QA personnel 7/22 h QA Department access to management 7/22 h QA Department involvement in project activities 7/22 Management involvement in QA activities 7/23r-A8 Issue summary report 8/5
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TASK B - CONSTRUCTION DESIGN CONTROL OBJECTIVE To review and evaluate the (PSI) Marble Hill system for control of approved design documents, Sargent & Lundy-initiated design changes, and field-initiated design changes; and to evaluate implementation of the system and its effectiveness in assuring that safety-related components are con-structed in accordance with the approved design.
SUBTASKS B1 Prepare a procedure to define how the work described herein will be accomplished.
B2 Review and evaluate the (PSI) Marble Hill system and procedures for control and issuance of approved design documents, design changes and field design changes.
The system will be evaluated against applicable requirements in 10CFR50 Appendix B and ANSI N45.2.11, and for effec-
' pl tiveness in assuring that the plant is constructed in accordance with 6
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B3 Select a sample of design documents, change notices and field change d
documents and evaluate these and any associated logs or control
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T records, for compliance with procedures evaluated in B2 above.
Docu-E Vments for evaluation will be selected from components and systems
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B3 Evaluate implementation 7/20 B4 Issue summary report 7/27 O
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TASK C PHYSICAL INSPECTION - WALKDOWN OBJECTIVE To determine if the physical installation and construction of selected portions of safety systems and structures at Marble Hill conform to the requirements of the design documents, f
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WW C1 Walkdown Feature Selection pf Odst b-C1-1 Selection Criteria Preliminary criteria for choosing features for physical verifica-tion are listed below.
These criteria will be refined for pur-poses of final selection of features to be reviewed.
Features to be selected for inspection will be determined by applying the following criteria:
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Features supplied, installed, or constructed by major contrac-a.
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tors (Westinghouse,~Newberg, Cherne) will be included. Other i/
organizations will be included if significant.
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A range of sophistication in construction methods will be covered.
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Installed safety systems will be walked down in their entirety i
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utilizing flow (or P&I) diagrams to ensure that the systems f
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Features (specific components or portions 'of systems)lof each
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system will be selected for detailed construction review, based on importance to safety, and will include:
o at least one safety-related mechanical / structural component o
at least one major NSSS component o
a wide range of equipment, structural types and complexity will be chosen to provide balance in the review.
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Portions of the systems will include safety related mechanical components, piping, pipe supports, and an electrical raceway or conduit (if already installed).
Features which are. encompassed.withid' one or more identified,
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concerns.of the NRC will.be considered,for review. 4%gd-:
50.65e),15 juf C1-2 Feature Selection A,
The following system and structural features will be identified during the selection process considering the selection criteria in Subtask C1-1.
a.
Structural-Inspection' 1.
Portions of major safety structures will be selected for inspection to determine if they' have been constructed in accordance with the struc'tural plans, drawings, and specifications. Representative structures to be inspected will encompass reinforced concrete,l prestressed coneyte, masonry walls,jand structural steel.l Important structural components such as reinforcing steel and mechanical splices, post-tensioning ' tendon ducts and anchorage b'
systems, anchor plates, concrete anchors, structural frame O
members, containment liner, and connections will be
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The inspection will cover completed structures and structures under construction.
2.
A subset of structural components will be selected for in-spection to determine if:
concrete placement'and resulting quality, meet' cons'truc-t o
ction specification requirements
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o structural steel components (beams, columns, anchor plates and connections) location, orientation, and configuration conform to installation drawings and specifications.
I o reinforcing steel and splice sizes, location, and configuration conform to installation drawings and specifications Design and construction documents used to establish the requirement will include structural detail drawings, installation drawings and specifications, concrete con-struction specifications and procedures, and reinforcing steel placement drawings and procedures.
3 Portions of structural compon,ents,will be selected for a more detailed inspection, which will include:
o detailed dimensional _ checks of structural members,
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3 detailed dimensionat checus of reinforcing steel and o
splices, material, cadwelds, bends, etc.
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o detailed review of concrete construction records,
control cylinder strength data, placement sequence, and construction joint preparation.
b.
Mechanical Walkdown 1.
Installed major safety systems or important portions of major safety systems will be selected for walkdown to determine if mechanical components and piping have been installed in the proper sequence, are properly identified, and that there are no system components which do not l
appear on the drawings.
The major design documents which will be used to perform this work are process flow (or P&I) drawings.
2.
A subset of systems will be selected for walkdown to determine if:
i o pipe diameter conforms to requirements o pipe routing of large bore pipe conforms to area drawings and piping isometrics o pipe and equipment support locations and orientations conform to piping isometric and pipe support drawings o _ equipment nameplate data corresponds to equipment specification requirements o equipment tag numbers match equipment list designa-tions.
These subsets will cover piping isometrics and include but are not limited to representative pipes, valves, pipe supports, cable tray supports and major components such as pumps and heat exchangers. Design documents which will be used to establish requirements include isometric drawings,
piping drawings, pipe support drawings, equipment lists, component installation drawings, equipment specifications, and piping specifications.
3 Portions of the system subsets (or different system portions, if necessary) will be selected for more detailed review.
The walkdown of these portions will include detailed dimensional checks of pipe and component supports including materials, welds, and connections to supporting structures.
The structural and mechanical walkdown will primarily be on Unit 1.
Approximately 25% of the same features will be walked down on Unit 2.
Representative candidates for review are given in Table C-1.
Final selection of specific system and structural features to be reviewed will occur in June.
MILESTONES C1-1 Complete definition of feature selection criteria 6/15 C1-2 Complete systems / structures features selection 6/17
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TABLE C-1 REPRESENTATIVE CANDIDATES FOR REVIEW STRUCTURES Reactor Containment and Internal Structures Auxiliary Building REACTOR COOLANT SYSTEM Reactor Vessel, Steam Generators, Pressurizers, Reactor Coolant Pumps, and Connecting Piping Feedwater and Steam Piping Safety Valve EMERGENCY CORE COOLING SYSTEM Accumulators Boron Injection Pump Safety Injection Pump Suction Check Valve CHEMICAL AND VOLUME CONTROL SYSTEM Letdown Heat Exchanger l
Charging Pump Boric Acid Filters i _ _ _ _ - _ _ _. __
TABLE C-1 (continued) l COMPONENT COOLING SYSTEM Component Cooling Pump Component System Piping and Pipe Supports Component Cooling Surge Tank RESIDUAL HEAT REMOVAL SYSTEM SYSTEM Residual Heat Exchangers Residual Heat Removal System Motor Operated Isolation Valve AUXILIARY FEEDWATER SYSTEM l
l Feedwater Pumps Motor and Turbine Drive Valves Piping and Pipe Supports l
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C2 WALKDOWN PROCEDURES Develop specific procedures for each unique type of walkdown or inspec-tion. Collectively these procedures will address the following as they apply to each feature:
Installation of selected safety systems is in accordance with flow a.
(or P&I) diagrams.
b.
Installation of components is in accordance with design documents.
Installation of piping and pipe supports is in accordance with c.
drawings and isometric sketches.
d.
Installation of reinforcing steel and mechanical splices is in 1
accordance with structural drawings.
Placement and quality of concrete meet construction specifications.
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Equipment part numbers / tag numbers comply with source documents.
The above procedures will incorporate to the extent practical the marking up of prints of applicable drawings of the systems, structures, components, or items inspected.
Checklists and walkdown packages will be developed to
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facilitate the construction review.
Photographs will be used where needed for clarification of details.
MILESTONES C2 Complete walkdown procedures 6/17
C3 FIELD WALKDOWN The field walkdown of system and structural features selected in Subtask C1 l
will be performed to determine if the system and structural features are in accordance with the design documents.
Each walkdown will review a feature l
to a specified degree of detail as defined in Subtask C1.
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The structural inspection will visually verify that selected portions of
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major structures have been constructed in accordance with structural plans and drawings.
Selected structural components will be inspected and dimen-sionally checked for location, orientation, and configuration.
In addi-l tion, specific portions of structural components will be subjected to a detailed inspection for such details as material, sizes, welds, anchors, and connections.
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The system walkdown will visually verify that components and piping have l
been installed in proper relative positions.
A piping isometric or cable tray walkdown will dimensionally review routing and support locations as well as general support arrangement.
Selected components, pipe and cable tray supports, etc., will be checked dimensionally and inspected fer such details as material, sizes, welds, fasteners, and attachments to the structure.
A walkdown documentation package will accompany procedures for conducting the walkdown.
The documentation package format will generally be the same for each feature; the exact scope of the walkdown for the feature will be provid ed.
The documentation package will also include the applicable design documents which contain the size, shape, material, quantity, and equipment vendor data required to accomplish the required review of the l
feature.
l The design documents will be marked up in the field to record the actual installation in the field.
Any field hardware that is not in conformance with the design documentation will be identified and recorded. _-__
Quality Assurance personnel will audit walkdown document packages and will perform a limited reverification of randomly selected walkdown inspections.
l In conducting the walkdown, TPT personnel will generally be operating in teams of two. One person will examine the hardware while the other records appropriate data.
Where equipment and systems are not accessible, such as behind shield walls, that portion of the design documentation will be so marked.
PSI or craft assistance will be requested to provide access to
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equipment where necessary.
No disassembly of component or structure will be required to perform inspections.
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A report will be prepared summarizing the results of the construction verification.
MILESTORES C3-1 start walkdown 6/20 c3-2 complete walkdown 7/29 c3-3 Issue summary report 8/19 M REY J
I4NES TECHN0lDGY PROJECT REPORT PAGE OF o w e GA Technologees Inc.
10N TASK C PHYSICAL INSPECTION - WALKDOWN DT 6/R/83 F. S. OPLE INDEPENDENT REVIEW 0F MARBLE HILL CONSTRUCTION PROJECT MANAGER PROJECT TITLE U
A" WO RK ITEM / ACTIVITY COMMENTS
- FEATURE SFLECTION C1 U
C1-1 PREPARE SELECTION CRITERIA U
Cl-2 SELECT SYSTEM /
STRUCTURE FEATURES C? PREPARE WALKDOWN
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PROCEDURES b C3 FIELD WALKDOWN C3-1 START WALKDOWN T7 C3-2 WALKDOWN ACTIVITIES l
U C3-3
SUMMARY
REPORT l
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G A 17b7 (Rev. 4/83)
TASK D TESTING Tests on features selected by the criteria of Subtask C1 will be performed.
The following subtasks represent currently planned tests.
SUBTASK D1 - ASME PIPING WELD INSPECTION OBJECTIVE i
To verify acceptability of ASME piping welds by review of inspection records and witnessing of inspection activities.
SUBTASKS D1-1 Prepare procedure and checklists to perform the inspections described herein.
D1-2 Obtain and review relevant to Marble Hill procedure (s) and supporting documentation for weld inspection.
D1-3 Identify specific welds for inspection.
The welds will be selected from the piping segments selected for walkdown in Subtask C1.
D1-4 Perform visual inspection of selected welds using the methods and criteria required in the original inspection.
Record results on inspection data form.
Compare results with that of the original inspection. Record and resolve any differences.
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D1-5 Obtain inspection records and radiographic films for selected welds.
Review inspection records and inspect films for compliance with specification requirements.
Compare film inspection results with that of the original inspection. Record and resolve any differences.
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s D1-7 Prepare a summary report on the work in Subtask D1.
MILESTONES D1-1 Issue procedure and checklist 6/17 D1-2 Identify, obtain and review relevant procedures 6/17 D1-3 Identify welds for inspection 6/24 l
f D1-4 Complete visual inspection 6/30 l
3 D1-5 Evaluate radiographic films and records g8
)b D1-6 Observe in-process inspection 7/8 D1-7 Issue Summary Report 7/15 4
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3 SUBTASK D2 - CONCRETE INSPECTION
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F OBJECTIVE Inspect concrete in nuclear safety-related concrete structures using visual inspection and rebound hammer techniques. Verify that the structures have no major defects and that the compressive strength of concrete meets specifications.
SUBTASKS D2-1 Obtain and calibrate rebound hammer.
Provide documented calibration report.
D2-2 Prepare procedure to accomplish the evaluations described below.
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D2-3 Review cylinder strength data, construction drawing (s), and access to nuclear safety-related concrete structures and select structures and areas to be inspected and tested.
Conduct visual inspection and rebound hammer tests (per ASTM C 805). Evaluate results for compli-ance with construction specifications for concrete defects and compressive strength.
D2-4 Prepare a summary report on the work in Subtask D2.
MILESTONES D2-1 Obtain and calibrate hammer 6/10 D2-2 Complete procedure 6/10 D2-3 Complete inspection and test 6/26 D2-4 Issue Summary Report 6/30 b
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I4NES nom PROJECT REPORT PAGE OF a o c e GA Technologies Inc.
TASK D TESTING DATE 6/8/83 INDEPENDENT REVIEW 0F MARBLE HILL CONSTRUCTION PROJECT MANAGER F. S. OPLE PROJECT TITLE
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WORK ITEM / ACTIVITY COMMENTS D1 ASME PIPING WELD INSPECTION s,
Dl-1 PREPARE PROCEDURE D1-2 REVIEW PSI PROCEDURES D1-3 IDENTIFY WELDS
__._/
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D1-4 VISUAL INSPECTION D1-5 EVALUATE RECORDS
_I D1-6 IN-PROCESS INSPECTION D1-7
SUMMARY
REPORT D_2 CONCRETE INSPECTION D2-1 OBTAIN & CALIBRATE HAMMER D2-2 PREPARE PROCEDURE D2-3 CONDUCT TESTS
.s D2-4
SUMMARY
REPORT i
TASK E CONSTRUCTION DOCUMENT REVIEW Construction documents related to the features selected in Subtask C1 will be reviewed. The following subtasks present current phnned reviews.
I l
SUBTASK E1 - ASME PIPING MATERIAL CERTIFICATION REVIEW I
OBJECTIVE To review piping and weld filler material vendors' certified test data for compliance with the applicable specification requirements.
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El-1 Prepare a procedure that defines how the work herein will be per-formed. The procedure will describe: (1) the method for selection of the pipe spool documents to be inspected and verified, (b) the use of checklists to record the pertinent information obtained from the examination of the material certificates.
El-2 Select a sample of pipe spools for which the material certificates will be reviewed.
A list of the selected piping will be generated, and will include pipe in both large and small sizes, as applicable.
l El-3 Obtain and review the piping and weld filler material vendors' l
certified test data reports for each of the selected pipe spools.
The review will include determining whether the certified test data I
complies with the applicable ASME Code and Marble Hill specification requirements. All appropriate data will be recorded on checklists to fully identify the piping spool represented, the material specifica-tion number, material heat number, etc.
E1-4 Prepare a summary report on the work in Subtask E1.
l.
MILESTONES El-1 Complete procedure 6/10 E1-2 Piping Sample List 6/22 E1-3 Review Materials Certifications 7/8 El-4 Issue Summary Report 7/15 SUBTASK E2 - CONCRETE TEST AND INSPECTION REVIEW OBJECTIVE To review testing and inspection records associated with construction of nuclear safety-related concrete structures for compliance with code and construction specification requirements.
SUBTASES E2-1 Prepare procedure and checklists to carry out work described herein.
E2-2 Review construction drawings and select structures to be investi-gated.
Identify and locate testing and inspection records for structures selected for the investigation.
Identify and obtain applicable codes and construction specifications for these struc-tures.
E2-3 Sclect a sample of the testing and inspection records.
The records will include (a) chemical and physical properties for cement, aggregate, concrete and reinforcing steel; (b) records of batching, mixing, placing and consolidating concrete; (c) records of reinforc-ing steel placement; (d) records of splicing for reinforcing steel (fabrication, inspection, welder and process qualification).
E2-4 Review the records for compliance with applicable codes and construc-tion specifications.
Review and evaluate the disposition of any nonconformances and deviations from codes and construction specifica-tions to ensure that the structural integrity of the structures is not degraded by any such deviation.
Document results of the review on the checklist.
E2-5 Prepare a summary report on the work in Subtask E2.
MILESTONES E2-1 Complete procedure and checklists 6/17 E2-2 Select structures 6/24 E2-3 Identify records 6/30 E2-4 Complete review 7/8 E2-5 Issue Summary Rt; port 7/13 SUBTASK E3 - WELDER QUALIFICATION RECORDS
[
OBaEC m E To review welder qualification records for ASME piping welds for compliance with code requirements.
SUBTASKS E3-1 Prepare procedure and checklists to perform the review described herein.
E3-2 Select welds for which welder qualification records will be reviewed.
E3-3 Obtain welders names (I.D. numbers, etc.) from construction records for the selected welds.
l E3-4 Review qualification records for each individual identified in E3-3 for compliance with ASME Code and Marble Hill specification require-ments.
E3-5 Prepare a summary report on the work in Subtask E3 MILESTONES E3-1 Issue procedure and checklists 6/17 E3-2 Select welds 6/24 E3-3 Obtain welder names 6/24 E3-4 complete review of records 6/29 E3-5 Issue Summary Report 7/6 SUBTASK E4 - SAFETY-RELATED EQUIPMElff MAINTENANCE AND STORAGE OBJECTIVE To review maintenance and storage procedures for safety-related equipment for compliance with requirements.
SUBTASKS E4-1 Prepare procedure and checklists to perform the review described herein.
E4-2 Review PSI procedures for maintenance of installed items and for storage of equipment on site.
I E4-3 Inspect status of stored items and installed equipment for compliance with procedures.
E4-4 Prepare a summary report on the work in Subtask E4.
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BELESi w E4-1 Issue' procedure and checklists 6/17 E4-2 Complete procedure review 6/24 E4-3 Complete inspection 6/29 4
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imey INNIS WHNY PROJECT REPORT PAGE OF a w w GA Technologies k REVISION LTR TASK E CONSTRUCTION DOCUMENT REVIEW (Continued)
DATE 6/8/83 NDNDENT EW 0F WBK HM COMUGION F.
.OM PROJECT TITLE PROJECT MAN AGER WO RK ITEM / ACTIVITY COMMENTS E3 WELDER QUALIFICATION REVIEW E3-1 PREPARE PROCEDURE E3-2 SELECT WELDS E3-3 IDENTIFY WELDERS E3-4 REVIEW RECORDS E3-5 SUW1ARY REPORT g
y E4 EQUIPMENT MAINTENANCE AND STORAGE E4-1 PREPARE PROCEDURE E4-2 REVIEW PSI PROCEDURES E 4-3 INSPECT FOR COMPLI ANCE E 4-4
SUMMARY
REPORT G A 17b7 (Rev. 4/83)
TASK F POTElfrIAL FINDIIIG PROCESSIlOG OBJECTIVE To review and document all Potential Findings identified during the review and classify each Potential Finding.
Transmit Findings to PSI or other major Marble Hill contractor (S&L, Westinghouse, Newberg, Cherne).
OVERVIEW Tasks A, B, C, D, and E will identify differences between the constructed plant and the requirements, deficiencies in construction records or other conditions requiring disposition. These conditions will be documented in a Potential Finding Report (PFR).
Following the filing of a PFR it is reviewed by the appropriate task leader. The purpose of this review is to determine if the PFR is valid, that is, if it is accurate (satisfied the criteria in the review procedure), well defined and traceable to a specific requirement and if it has an impact on the safety of the plant.
The original design organization (ODO) constitutes the next level of review.
The PFR is sent to the appropriate organization for the same type of accuracy review as was conducted by the task leader. At the same time a copy of the PFR is sent to the PSI representative.
When the PFR is returned from the original design organization it is sent back to the initiator and the task leader.
Based on the information supplied by this organization the initiator may modify the PFR or just comment on the organization's response.
The task leader can only add his comments.
Following this review, an impact assessment for the Potential Finding is prepared to define the potential for impact on the safety of the plant.
The impact assessment and the PFR re then submitted to the Find-ings Review Committee for evaluation.,
This committee is comprised of five senior technical people at GA who have extensive experience and broad knowledge of the design and construction of nuclear power plants and associated quality assurance practices. It is the purpose of this committee to evaluate each PFR and classify it according to established criteria.
A Potential Finding is classified as invalid if after the above-described review, the initiator and the task leader agree that the Potential Finding is inaccurate.
In addition, Potential Findings can be classified as invalid if one of the above-identified two reviewers conclude that the Potential Finding is invalid and the Findings Review Committee also decides it lacks validity.
The review procedure will contain criteria for classifying a valid Poten,-
tial Finding as either a Finding or an Observation.
Basically, if a Potential Finding is a deviation that could result in a substantial safety hazard, or if there is an indication of a repetitive or generic deviation that could create a substantial safety hazard, the Potential Finding is classified as a Finding.
Potential Findings that are valid, but that do not satisfy the above criteria for a Finding, are classified as Obser-vations.
The classification of the Potential Finding is reviewed by the Project Manager to determine if the correct procedures have been followed. Subse-quently, the Observations and Findings are sent to the PSI representative for resolution. In the case of Findings, a Corrective Action Plan (CAP) is prepared by PSI and returned for review.
This review is to determine if the Corrective Action Plan satisfies the concern expressed in the Finding.
j Each Corrective Action Plan is reviewed by the initiator of the Finding, l
the task leader, the Findings Review Committee and the GA project manager.
i In each step of this review process the comments and information that are added become a permanent part of the PFR. All PFRs will be included in the final program report that is transmitted to PSI and to the NRC.
SUBTASES F1 Establish a Findings Review Committee. This committee will be composed of senior technical personnel with broad experience in construction, design, technical management and quality assurance.
F2 Establish, by the Committee, specific criteria for determining the degree of impact that Potential Findings have on the construction adequacy of the Marble Hill Nuclear Power Station.
F3 Establish a detailed procedure to process Potential Findings.
This procedure will assure that PSI and the appropriate major plant contrac-tor have verified the definition and accuracy of the Potential Finding.
The basic process is shown in Figure F-1.
MILESTONES F1 Establish committee 6/17 F2 Define criteria 6/24 F3 Establish specific procedure 7/1 F4 Complete PFR reviews 8/26 1
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TASK G ADMINISTRATION AND REPORTS OBJECTIVE Provide administrative and management support for the project.
Prepare bi-weekly stacus reports, and a final report on Findings and conclusions with respect to adequacy of the construction of the Marble Hill Nuclear Power Station.
i SUBTASES G1 Provide management of the construction review program and accumulate cost and schedule data and prepare bi-weekly status reports on progress of the review effort.
G2 Compile all Potential Finding Reports, results of the Findings Review Committee, Observations and Findings.
G3 Assess the adequacy of the construction of the safety-related systems and features inspected.
1 G4 Prepare a final report compiling all Potential Findings, Observations, and Findings, including their description, comments, assessment of impact, the results of the Findings Review Committee, the results of the review of PSI corrective action plans, and the final assessment of the construction adequacy of the inspected items of the Marble Hill Nuclear Power Station.
l MILESTONES l
G1 Complete bi-weekly status reports (see schedule)
G2 Complete compilation 8/24 G3 Complete assessment 8/31 G4 Complete final report draft 9/7 l
G5 Issue final report 9/16 l
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a PINES 8
TECHNOLOGY A ov$on of GA Technologies Inc.
PO Bon 85608 San Dega, Cahfornia 92138 J
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GA-C17173 INDEPENDENT REVIEW 0F i
ZIMMER-PROJECT MANAGEMENT l
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FINAL REPORT k
VOLUME 1
- EXECUTIVE
SUMMARY
PREPARED FOR CINCINNATI GAS AND ELECTRIC COMPANY l
l' GA PROJECT NO. 2474 AUGUST 1983
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3.
TORREY J
PINES TECHNOLOGY a o.v>oa of GA Technologies Inc. ummmmmmme Y'W
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FOREWORD The final report on the Independent Review of Zimmer Project Manage-ment, done by Torrey Pines Technology under contract to the Cincinnati Gas
& Electric Company, is presentsd in two volumes.
Volume 1,
the Executive. Summary, presents a top level summary of the work done, results, observaticus, conclusions, and recommendations.
Volume 2, the Discussioc Volume, presents a more detailed description of the review and evaluation tasks, the information obtained and analyzed, and detailed observations, conclusions, and recommendations.
am j
l 111
6 3
ACRONYMS AND ABBREVIATIONS AE Architect-Engineer AEC Atomic Energy Commission, later the Nuclear Regulatory Commission (NRC)
AE/C Architect Engineer / Constructor AFR Audit Finding Report ANI Authorized Nuclear Inspector ANSI American National Standards Institute ASME American Scciety of Mechanical Engineers ASTM American Society for Testing Materials AVL Approved Vendor List AWS American Welding Society BOP Balance of Plant B&PV Boiler and Pressure Vessel i
BPC Bechtel Power Corporation BWR Boiling Water Reactor C of C Certificates of Compliance CAR Corrective Action Report CASE Coalition for Affordable Safe Energy CEO Chief Executive Officer CER Condition Evaluation Request CG&E Cincinnati Gas & Electric Company CI Catalytic, Incorporated CM Configuration Management
(
CMTR Certified Material Test Report CPM Critical Path Method CRD Control Rod Drive C&SO Columbus and Southern Ohio Electric Company CWAR Construction Work Approval Request DDC Design Document Change DP&L Dayton Power and Light ECR Engineering Change Request EOTD Engineering Operating Test Department V
=.
4.
e EPD Energy Production Department FCP Field Construction Procedure FDDR Field Deviation Disposition Request FDI Field Disposition Instruction FSAR Final Safety Analysis Report FWO Field Work order GA GA Technologies Inc.
GAP Government Accountability Project GCD Generation Construction Department 4
GE General Electric Company GED General Engineering Department i
EJK.
Henry J. Kaiser Company (formerly Kaiser Engineers Incorporated (KEI)]
IAL Immediate Action Letter I&C Instrumentation and Control I&E NRC Inspection Report IIDR In-Process Inspection Deficiency Report IR Inspection Report ISK '
~-
Isometric Piping Drawing KEI Kaiser Engineers Incorporated (later Henry J. Kaiser Company (EJK)]
LEAD Licensing and Environmental Affairs Department LOCA Loss-of-Coolant Accident MAA Management Assessment Audits i
MCAR Management Corrective Action Request i
MR3 Materials Review Board l
MRP Material Requirements Planning NDE Nondestructive Examination NED Nuclear Engineering Department NPD Nuclear Production Department NPS Nuclear Power Station NR Nonconformance Report
)
NRC U.S. Nuclear Regulatory Commission NSD Nuclear Services Department NSSS Nuclear Steam Supply System
Owner's Project Procedures OPP PMS Performance Measurement Systems Purchase Order PO Purchase Request PR PSAR Preliminary Safety Analysis Report QA&S Quality Assurance and Standards QA Quality Assurance Quality Assurance Department QAD QAP QA Procedure or QA Program QC Quality Control QC?
Quality Confirmation Program QCPP Quality Confirmation Program Procedure Quality Verification Program QVP RCI Reactor Controls, Incorporated RO Reactor Operator RPV Reactor Pressure Vessel S&L Sargent & Lundy Engineers SAI.
Science Applications, Incorporated S&W Stone and Webster Order to Show Cause (Order Immediately Suspending Construction SCO (to CG&E from NRC), dated November 12, 1982]
SLC Special Litigation Committee SRO Senior Reactor Operator SWO Stop Work Order Torrey Pines Technology (A Division of GA Technologies Inc.)
TPT Wallinger-Young and Bertke l
WY&B ZOC Zimmer Oversight Committee I
Zimmer Nuclear Power (Station) l ZNP ZPM Zimmer Project Manager or Zimmer Project Management ZPOC Zimmer Project Oversight Committee vil a
s VOLUME 1 - EXECUTIVE
SUMMARY
TABLE OF C0! TENTS FOREWORD.
iii ACRONYMS AND ABBREVIATIONS.
v 1.
INTRODUCTION I
2.
GENERAL OBSERVATIONS 3
2.1.
CG&E's Past Record 3
2.2.
Lack of Prior Nuclear Experience 4
2.3.
Fiscal Policy.....................
4 2.4.
NRC Attention.
5 2.5..
Mark,II Containment Design 5
2.6.
Effects of Three Mile Island 6
3.
REVIEW RESULTS 6
3.1.
Project Management Organization..
6 3.2.
Management Policies Toward Quality Assurance 9
3.3.
Management of the Quality Assurance Program..
10 3.4.
Quality Confirmation Program 13 3.5.
Project Management Interfaces with Maj or Subcontractors...............
14 3.6.
Planned Transition from Plant Construction to Operations.
19 3.7.
Case Studies 20 4.
OVERALL CONSIDERATIONS.
21 4.1.
Work Scope 22 4.2.
Policy Toward Quality Assurance.
23 4.3.
The Quality Verification Program 24 4.4 Staff Availability and Role of an Archit ect-Engineer / Constructor 25
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5.
EVALUATION OF ALTERNATIVE ORGANIZATIONS.
25 5.1.
Alternatives Evaluated 25 5.2.
Methodology.,...........
28 5.3.
Results........................
29 6.
RECOMMENDED ORGANIZATION 33 6.1.
Construction 39 6.2.
Engineering......................
40 6.3.
Quality Assurance.
42 6.4.
Operations 44 6.5.
Administration 45 7.
THIRD PARTY REVIEW 46 i
FIGURE 1.
Recommended Zimmer project management organization..
34 TABLES 1.
MU3T criteria 30 2.
WANT criteria 31 4
T e
X
VOLUME 1 - EXECUTIVE
SUMMARY
1.
INTRODUCTION Torrey Pines Technology (TPT) was retained by the Cincinnati Gas and Electric Company (CG&E) in response to Section IV.B.1. of the Nuclear Regu-
, latory Commission (NRC) Show Cause Order (SCO) deced November 1982, to con-duct an independent review of CG&E's management of the W. H. Zimmer Unit 1 Nuclear Power Station (NP3) project, including its quality assurance pro-gram (QAP) and its quality confirmation program (QCP), to determine the organizational changes needed to ensure that construction of the Zimmer 1 plant can.be completed in conformance with NRC regulations and the con-struction pe'rmit.
TPT reviewed the organizational structure, policies and procedures, and Quality Assurance (QA) activities of CG&E; including its interfaces with' Sar' gent' and Lundy (S&L), Henry J.
Kaiser Company (HJK), General Electric Company (GE), Catalytic Incorporated (CI), and Reactor Controls, Inc.
(RCI).
The evaluation covered the management of the Zimmer project from its inception to the present.
The review was divided into four periods:
(1) project inception to the assumption of increased construction responsibilities by CG&E in 1976, (2) from 1976 to the Immediate Action Letter (IAL) in early 1981, (3) from the IAL to the Show Cause Order (SCO) in November 1982, and (4) since the SCO.
The basic approach used in the review was to separately examine key characteristics and aspects of the Zimmer project management and QA pro-grams.
As a cross-check, selected " case studies" were also examined to assess the collective role and behavior of management in response to specific problems and/or series of events.
Information was obtained by interviewing Zimmer project management staff (CC&E), representatives of subcontractor organizations (HJK, S&L, GE, CI, RCI,) and representatives of related organisations such as the NRC, 1
National Board of Inspectors, and Intervenor Groups.
The interviews included past and present management and other individuals having information pertinent to this review.
Selected records and files were examined to obtain relevant documents /information to supplement and verify the information obtained in the interviews.
The interviewees and the supplemental documents were selected on the basis of TPT's professional judgement.
Information received, in whatever form, was taken in good f aith by TPT.
TPT personnel involved in the research in support of the study were not expert in investigative techniques that might be used in cases of pur-poseful deception.
Although TPT has no right of discovery in the legal
- sense, all records and files requested by 1PT were made readily available.
TPT personnel did not uncover anything that might lead credence to the possible suspicion that they were being provided with incorrect information or were intentionally deceived.
The total program effort was approximately 60 manmouths; over.3200
- documents. were reviewed; and approximately 100 people were interviewed, several more than once.
Evaluations _were made of the advantages and disadvantages of: (1) the alternative organizational structures identified by NRC in the SCO, (2) organizational changes that have been implemented and/or proposed by CG&E since the SCO, (3) the organizational recommendation made by Bechtel Power Corporation (BPC),
and (4) various alternative organizational structures conceived by TPT.
TPT's recommendations for an appropriate organization to satisf actor-ily complete the Zimmer project, in accordance with NRC regulations, were formulated independently based on the data obtained and an evaluation of the alternative organizations.
- The investigation did not include any technical review or evaluation of the adequacy of the Zimmer plant design and construction.
No physical inspection of the plant was performed.
2
r
~.
2.
GENERAL OBSERVATIONS Construction of the Zimmer nuclear plant is approximately 97". com-plete. From external appearances, the plant appears to have been construc-ted in an efficient and workmanlike manner.
However, a comprehensive verification program (QVP) is required to determine the true quality of the design and construction.
It is TPT's opinion that the management short-comings which resulted in the issuance of the SCO.have been, or can be, corrected by CG&E and that, if the management changes recommended by TPT are made, future work at the Zimmer plant can be completed in conformance with the NRC regulations and construction permit.
In performing this investigation, TPT made the following additional observations regarding the background, external factors, and corporate man-agement practices that contributed to the present situation at the Zimmer project.
2.1.
CG&E'S PAST RECORD CG&E's performance record for the construction of coal-fired plants has been very good.
Construction schedules on fossil fuel plants were generally met, costs were kept under control, and results for consumers and stockholders were correspondingly satisfactory.
This successful record was achieved using a management style that relied on a small, tightly knit group of individuals who communicated informally and who controlled per-formance by contractual and fiscal constraints on subcontractors.
These methods were the essence of CG&E's style and were adopted by all levels of management.
When applied to Zimmer, this style of management resulted initially in significant accomplishments, in terms of schedule and construction comple-tion dates, despite extensive design changes and backfits on the Mark II Boiling Water Reactor (BWR) containment (which were no fault of CG&E).
In
- fact, until the late 1970's, CG&E was leading the nation in the construc-tion of this type of plant and was at the forefront in paving the way in licensing and defining solutions to design problems.
Even by November 3
t e
1982, the date of the SCO, the Zimmer power station compared very f avorably in terms of cost and schedule with contemporary nuclear plants of the same type.
2.2 LACK OF PRIOR NUCLEAR EXPERIENCE CG&E, and to a large extent its constructor HJK, lacked prior experi-ence in its assigned roles in this nuclear power plant project.
Although in the early 1970's numerous other utilities also lacked prior nuclear experience, the constructor (HJK) of the Zimmer project was unique from the standpoint that it did not have, nor did it later obtain, any additional commercial nuclear power plant prime construction contracts.
Consequently, it appears that neither CG&E nor HJK had sufficient experience or the external interactions necessary in order to respond in a timely and effec-tive manner to the rapidly evolving, more stringent interpretations of NRC
. requirements.
As a result, it was not recognized until very far along in the Zimmer proj ect ' hat a much more formalized, rigorous approach was
- needed to. control and document the quality of the design and construction of a nuclear plant than that required for the design and construction of a fossil fuel plant. This was probably the single, most significant factor contributing to the present situation at the Zimmer plant.
2.3.
FISCAL POLICY CG&E had a corporate fiscal policy that minimized expenditures.
Such a policy, taken in the proper perspective, benefits both the ratepayers and the stockholders of the Company. However, this erf-tsis completely domin-ated other important priorities such as quality and quality assurance.
Cost reduction and schedule maintenance was encouraged to the extent that construction forces worked only to compliance with the minimum NRC stan-dards and regulations.
This approach, combined with the rapidly evolving and more stringent interpretation of these regulations over the years, con-tributed significantly to'the current problems at the Zimmer project.
l 4
t 2.4.
NRC ATTENTION Quality problems existed during the early stages of construction which remained uncorrected during that period due, in part, to a lack of attention and follow-through on a corrective action course by the NRC.
Although CG&E QA was generally responsive to NRC concerns, these concerns were neither extensively nor aggressively.
pursued by the NRC.
Consequently, CG&E management failed to recognize the underlying message in the Inspection Reports (irs) relating to the problems that existed at Zimmer.
As a result, corrective action was not taken in an effective or timely manner.
CG&E was allowed to continue constructior. while being lulled into a false sense of satisfactory performance until the late 1970's and early 1980's.
2.5.
MARK II CONTAINMENT DESIGN As previously mentioned, CG&E had to cope with major design changes and..backfits;.affecting the Mark II containment of the GE Series 5 BWR when the original design was found to be deficient.
As the leading plant under construction, design options and the flexibility for backfits were more limited at Zimmer than for plants in earlier stages of construction.
The extensive changes and backfits that were required'were not conducive to high morale on the construction project.
In this environment the Zimmer project engineering staff, in addition to their normal construction duties, were also required to be active participants in the utility Owners' Group that was addressing the BWR problems.
It is not evident that GE took a strong role in support of the Zimmer problems, as opposed to the generic problem of the BWR.
5
t' 2.6.
EFFECTS OF THREE MILE ISLAND In the a'ftermath of the Three Mile Island incident, the NRC became increasingly more active and concerned about potential shortcomings at the Zimmer proj ect.
With a concurrently increasing public concern regarding nuclear power in general, and allegations about Zimmer in particular, CG&E was unsuccessful in its attempts to convince critics that the plant had not been constructed improperly. Even allowing for the fact it may have been difficult to distinguish between malcontents, antinuclear activists, and genuinely concerned individuals, CG&E reacted to particular issues in a symptomatic manner rather than trying to determine and correct the under-lying causes.
Although not all the criticism of CG&E appears justified, societal attitudes deteriorated to the point where CG&E is now presumed guilty until it can prove its innocence.
3.
REVIEW RESULTS
.The. following is a summary of the main conclusions in each area of Zimmer project management investigated by TPT:
3.1.
PROJECT MANAGEMENT ORGANIZATION In this area, the objective was to evaluate the CG&E project manage-ment organization to determine whether deficiencies existing in its struc-
- ture, staffing, policies, and/or procedures might have kept the project from meeting the high standards required for nuclear power plant design, procurement, and construction.
TFT concluded that:
CG&E attempted to use a project management approach at Zimmer that had been previously used successfully in the' construction of fossil fuel plants. The approach, which was not unusual at that time, was to rely I
6
small, dedicated management team using relatively informal man-on a agement systems and techniques.
The emphasis was on getting the plant built on schedule, at the minimum cost. CG&E was not prepared for the complexity of the proj ect requirements that evolved throughout the 1970's.
Even so, based on their approach, the Zimmer project manage-ment functioned effectively (although generally informally),
in attaining their cost and schedule goals.
In retrospect, a number of deficiencies have existed (and some continue to exist) in the project management organization structure staffing, policies, and/or proce-
~
dures that are inappropriate in the management of a complex project such as Zimmer.
CG&E established an Owners Project Procedures (OPP) Manual for the Zimmer Proj ect in 1972 which delineated the project organization, including reporting lines within CG&E, for the major subcontractors
( RJ).,
S&L, GE);
defined the responsibilities and authority of the various positions; and named the personnel who would act in those
. positions., These formal overall project policies concerning responsi-bility and authority over the functions at Zimmer Project appear to have been adequate, but they were not implemented adequately by proj-eet personnel.
CG&E did not have an integrated, comprehensive set of project manage-ment procedures documented and implemented to ensure that all elements of the proj ect (e.g., Construction, Engineering, Quality Assurance, Licensing, Cost, Scheduling, etc.) were coordinated.
This impaired communication between departments and, in some instances, resulted in conflicting requirements and/or a duplication of effort.
In comparison with other nuclear utility companies, staffing of both CG&E and the subcontractor organizations was inadequate throughout the 1970's.
The CG&E management and professional staff was of inadequate size and had insufficient experience and training in the design and construction of nuclear power plants.
After the IAL in April 1981, I
l l
l
additional staff was recruited including a large proportion of temporary employees, some in management positions. A small number of CG&E personnel with prior nuclear experience has been added to the staff since the SCO, but it still remains understaffed and this situa-tion needs to be corrected.
CG&E's project management and control systems, including performance measurement and document control, were inadequate. The systems util-ized did not integrate the planning and scheduling of various project management activities such as construction; QA; engineering; and, sub-sequently, the transition to operations. Management reporting systems were also poor.
Key managers and professional staff were not dedicated solely to the Zimmer project.
Several key managers had conflicting responsibilitien that detracted from their management overview of Zimmer. Except for short periods of time, the CG&E manager responsible for the entire
.Zimmer project was not located at the site.
These conditions, coupled with the lack of an integrated project management system, contributed to the creation of informal autonomous organizations within the proj-eet with lines of communication that were not always consistent with the published proj ect organization charts.
Also, there was a too-heavy reliance on contractors for project management and control. The CG&E policy of delegating the responsibility of major elements of the work to reputable experienced contractors is not inconsistent with the approach taken by other utilities in the construction of nuclear power plants. However, CG&E does not have the management system, implement-1 ing procedures, and staff required to control the work performed by its subcontractors. The net result was to impair the visibility of the project to CG&E top management.
e 8
3.2.
MANAGEMENT POLICIES TOWARD QUALITT ASSURANCE In this area, the objective was to evaluate the CG&E project manage-ment policies affecting QA, and to assess whether management's involvement and commitment towards quality was adequate to ensure an effective program.
TFT concluded that:
Management at Zimmer had not done an adequate job in highlighting the QA program as one of the key elements in the successful construction of a nuclear power plant, or in providing the appropriate level of support that would ensure effective program implementation.
The level and status of the CG&E QA organization through the years was generally inadequate to provide an effective nuclear QA program.
The major shortcomings in this area are the small and inexperienced CG&E QA staff, cost and schedule pressures on the QA organi=ations, and failure to, effectively correct and prevent recurrence of problems.
CG&E management generally did not establish definitive policies, verbal or written, concerning QA at Zimmer and no strong message by CG&E management in support of quality and quality assurance was evident.
Instead, CG&E management policy insisted that all concerned (CG&E and subcontractors) minimize the time and money spent on QA programs.
CG&E top management appeared to lack an adequate degree of involvement in, and commitment toward, QA at Zimmer.
Up until 1981, the President of CG&E appeared to be insulated from an accurate picture of the status and inadequacies of the Zimmer QA program.
The CG&E project organization provided minimal executive summary information to manage-ment on overall quality problems,
- status, and QA program effee-tiveness.
Executive reports generally addressed details and high-lighted " brush-fires" rather than providing a management perspective.
9
a The Zimmer proj ect management, up to the Vice Presidential level appeared to have been sufficiently involved in the QA program to have had an awareness of the many shortcomings and problems at Zimmer throughout the years.
However, corrective action to prevent recur-rence of these problems was generally not taken.
Problems continued to surface repetitively and eventually played a prominent role in the issuing of the IAL, the $200,000 fine, and the SCO.
While CG&E QA was involved in the Zimmer project activities over the
- years, there were several significant shortcomings in the management of this function which limited their perception and control of the status of thu project.
Their review and audits of subcontractor work for the adequacy, implementation, and effectiveness of related QA pro-grams did not include sufficient depth, follow-tp, or timely imple-mentation of corrective action.
3.3.
MANAGEMENT OF THE QUALITY ASSURANCE PROGRAM In this area, the objective was to evaluate CG&E's management of the QA Program to determine if adequate systems, procedures, and techniques have been established and, if so, are being implemented effectively.
TPT concluded that:
Management did not establish adequate mechanisms to ensure that QA program commitments in the Preliminary Safety Analysis Reports (PSARs) and Final Safety Analysis Reports (FSARs) were implemented in CG&E (and subcontractor) quality procedures in a timely manner.
CG&E's control of the process of developing, maintaining, and implementing subtier procedures, instructions for work, and inspec-tions that affect quality has been less than effective from the start of construction to the present. There are many instances of inade-quate control over design documents, design document changes, welding 10
O
- forms, inspection methods / procedures, documentation of work acco=-
plished, conformance to work procedures, and QA procedures.
i l
It was generally found that the QA training program was a reactionary
- process, increasing in scope and depth as problems were identified.
Little evidence of planning for training, or systematic appraisal of training requirements in advance of specifie work commencement, was found.
Comprehensive qualification and certification c:f QA personnel, for the most part, was act accomplished until af ter the major construction was completed.
An apparent lack of a clear-cut delineation of the different CG4E and EJK responsibilities and authorities in the area of procurement con-trol [ coupled with ongoing differences of opinion between CG&E and HJK over the scheduling of surveys / audits / inspections,
on vendor. data requirements, and on the development of an Approved Vendor List (A7L)]
have contributed to a number of procurement problems. Attempts at j
corrective action appear to have been ineffective.
Up to 1981, CG&E lacked effective control over the design function.
More audit emphasis should have been placed by CG&E on field design control procedures.
This could have helped to identify and correct, in a timely manner, the design control problems experienced at Zimmer.
CG&E initiated an intensive effort af ter the SCO to get this system back on track.
CG&E did not provide sufficient direction and support for the estab-lishment of a comprehensive audit program executed in accordance with the requirements and intent of 10CFR50, Appendix B. Consequently, the CG&E QA audit program appeared to be ineffective.
Individual problems 11
a were attacked, but the magnitude and extent of problems apparently remained largely undetected.
Many noncompliances detected by outside audit groups should have been found by the CG&E QA audit group.
There exists no effective assurance that documents to be maintained as records are complete, accurate, valid, or readily retrievable.
It would also appear that management did not take effective action early enough in the construction project to ensure the validity and avail-ability of these documents. A centralized records center was set up after the IAL, and the turnover of documents from other site locations is in progress. However, progress is slow and it is 'not being accom-plished in a thorough manner.
From the beginning of construction until the present, the corrective action system was generally not effective in assuring that identified discrepancies in material / systems / procedures were investigated in a
, timely manner, analyzed to determine root causes, and corrected by priority actions to prevent recurrence.- Standard management tools to collect reirvant data, analyze the data relating to the problem, pro-i pose alternatives on the basis of analyzed data and the operating environment, and select solutions were available but were apparently not utilized or, at the least, were not effective.
In addition there is little evidence to indicate that management established an effec-tive system to track "open" items to assure their completion.
l There were extremes in the degree and kinds of interaction between.the QA Department and its subcontractor organizations.
On one hand, the CG&E QA interface with S&L QA and GE QA has been minimal but suffi-cient in relation to contractual responsibilities.
On the other hand, CG&E QA's interface with RJK QA increased over the years to the point that the association became less than amicable and developed into an adversarial relationship.
The controls and interfaces which CG&E QA applied to the activities of RCI also appear to have been minimal even though information provided from CG&E Management Assessment Audits 12
o 1
(MAAs) indicated that problems existed.
It appears that the obscurity of CI's work scope; the lack of CI/Zimmer interfacing procedures; and the CG&'. QA audits which appear to have been programmatic, rather than technical, contributed to the concerns of the NRC.
3.4.
QUALITY CONFIRMATION PROGRAM In this area, the objective was to evaluate CG&E's management of the QCP to determine its adequacy and effectiveness in achieving the objectives i
and the commitments of the program.
i TPT concluded that:
During the initial stages of TPT's management review of the QCP it became increasingly evident that the assignment to the program of the present Director signaled a significant turning point in the history of the QCP.
The present QCP appears to have a reasonable organizational structure including adequately defined responsibilities and authorities. A high degree of management skill particularly in the administrative area, as opposed to the technical area is displayed by QCP management.
J i
- However, in spite of improved management there is still an inadequate 1
definition to the QCP itself.
While some tasks show good progress, others appear to be bogged down for one reason or another.
In parti-
- cular, the treating of audits, audit findings, root cause identi-
- fication, corrective action, and the overall management assessment of the QCP through audits have been generally ineffective.
l CG&E recognizes that a Quality Verification Program (QVP) is required, which vill be more comprehensive than the present QCP, and involve disciplines and skills not now required of the QCP.
Although the QVP I
13
O organization would require personnel with different levels of exper-tise than those presently involved in the QCP, TPT believes the present QCP management and organization have a role in QVP (i.e.,
individual personnel appear well qualified to perform certain tasks).
l Such skills are not evident in several areas of the Zimmer project management.
The overall magnitude of.the QVP indicates the need not only for management with high administrative skills, but also with extensive technical and prior experience in setting up, implementing.
l and successfully completing nuclear programs at other plants.
Additional experiencid staff and/or,the services of an experienced external organization will be required to satisfactorily complete the QVP.
An independence from involvement in prior activities would provide greater credibility.
i 3.5. PROJECT MANAGEMENT IhTERFACES WITH MAJOR SUBCONTRACTORS In this area, the objective was to evaluate the adequacy of CG&E's
~ project 'shnagement methods for: (1) administration and control of the work of maj or subcontractors and suppliers and (2) managing changes to their j
work and contracts to ensure effective control of performance.
The evalu-ation included CG&E interfaces with S&L, HJK, GE, CI, and RCI.
l TPT found that CG4E's original philosophy regarding procedures for projects was to j
allow major subcontractors to develop and use their own procedures, with the OPP as an umbrella document.
The concept was good, but the implementation and control are inadequate in the case of the Zimmer m
project.
The original OPP, issued in 1972, was a very broad but brief i
document that covered only the outline of how CG&E was to interact i
with the major contractors.
This OPP was inadequate as a basis for developing and recording engineering / construction records and writing procedures, and for controlling software and design documents; i
especially design drawings and design document changes (DDCs).
14 l
The OPP has been rewritten since the IAL and now appears to be an ade-quate base upon which to establish final, detailed project procedures.
A maj or effort is still required to prepare and naintain a comprehensive set of working-level project procedures.
The present Nuclear Engineering Department (NED), formerly the Mechan-ical Engineering Section of the General Engineering Department (GED),
had a formal charter to perform project engineering tasks such as monitoring S&L and GE activities, development of cost accounting on purchase orders (Pos),
cash flow proj ections,
engineering change request (ECR) reviews, DDC reviews, making design changes, keeping up with codes and standards, and providing licensing support. However, in actual practice, NED has had little or no influence on the acti-vities of S&L and GE.
Although NED was the receiver and reviewer of engineering information it has been understaffed, limiting its effec-tiveness as a monitor of S&L and GE.
NED has been in a reactive m' de of operation.
Its time has been rather than an anticipative o
.. consumed, in detail work, reviewing procedures and previously written
- DDCs, rather than in monitoring the engineering activities of others.
]
Thus its oversight
- charter has not been made meaningful.
In about l
1961 or 1982, NED tried to become more actively involved but support by senior management is required before NED's influence can increase.
The relationship of GE to CG&E was that of a vendor providing nuclear equipment to a buyer. GE interacted with CG&E primarily through the GE Zimmer Project Manager (ZFM) stationed in San Jose, California.
GE did no site construction or inspection.
GE has had very little direct influence on CG&E in the technical decisions made at Zimmer as CG&E relied upon S&L to make decisions regarding GE equipment. GE's role has been one of assuring that changes made by S&L affecting GE equipment are reviewed,
approved, and properly documented in the GE drawing system universally used on all of GE's BWR projects.
l l
15
l e
The relationship of trust between S&L and CG&E was well-established.
It was based on past experiences in the construction of coal-fired plants (22 different proj ects) over a period of 75 years.
It is conceivable that this trust enabled CG&E senior management to feel it was unnecessary to monitor and control S&L's activities and that merely holding them accountable, under their contractual obligation to perform all engineering at Zimmer, was adequate. When attempts were made to exercise greater control and influence over S&L activities, senior management would admonish the Zimmer project personnel to let S&L alone to do their job.
In this way, the monitoring and auditing of S&L activities was minimized.
For the majority of the time spent on the Zimmer contract, S&L con-ducted their engineering functions (including. the processing of engi-neering changes, the incorporation of DDCs into drawings and speci-fications, analyses, and report writing) from the Chicago offices.
S&L had a minimal site representation at Zimmer until after the IAL, f
when,they did assign a large staff to the site to try and deal more directly with field engineering problems.
Engineering changes were not well-controlled until a unified procedure was established in 1981.
An extensive backlog of DDCs remains to be incorporated into design documents.
' G&E did exercise significant control and overview of HJK. CG&E C
initially delegated construction and QA responsibilities to RJK, yet tightly controlled the purse strings, limiting the number of staff employed and dictating the scope of activity in selected areas.
CG4E's confidence in RJK decreased and their relationship with RJK had apparently deteriorated significantly by about 1976.
On that date, CG&E took over the project management responsibility for construction and began to exercise greater ove rview and control, resulting in increased adversarial relationships between CG&E and RJK personnel with KJK assuming a more defensive posture in later years.
Management policies and procedures clearly defining the management roles of both 16
e CG&E and HJK (including their chains of command, limits.of authority on both sides, and supervision rights) were inadequate.
Catalytic, Inc.
(CI), working primarily for the Nuclear Production Department (NPD), was hired in mid-1980 mainly to work on punch 11st items.
They also performed other work for the GCD such ass (1) upgrading of structural steel to accommodate seismic loads and (2) removal and replacement of fuel pool heat exchangers.
CG&E QA had direct contact with CI, and the CI QA Manager, through:
(1) audits of CI's work, (2) review and approval of C1 work procedures, (3) review and approval of CI controlled work packages, and (4) participation at periodic project review meetings.
Due to the number of procedures that CI developed and routed through CG&E QA for review, CI work on hardware did not actually start until the surser of 1982.
In
. eneral, CI was found to perform well in the punchlist or systems-g oriented phase of construction although the definition and control of their work sometimes appears questionable.
Various concerns regarding CG&E's control of CI's work included such items ass (1) inadequate control of work assignments to CI, (2) incomplete work packages and weld inspection records, (3) lack of in process CG&E inspection hold points, and (4) inadequate CG&E audits of CI.
i Reactor Controls, Inc.
(RCI) was contracted to provide design anal-
- ysis, construction activities, and QA/QC to an S&L design specification.
Since RJK was not part of the work effort, it was CC&E's QA responsibility to perform audits and surveillance of RCI.
CG&E did not provide definitive directions to RCI regarding the criteria and procedures needed to conduct work at Zimmer.
l I
j 17 L
e CG&E QA reviewed and approved the RCI OA manual prior to start of work and also made subsequent revisions to the manual. Apparently, a survey of. RCI was not performed to verify QA Program implementation.
QA performed periodic audits of RCI work. However, CG&E did not audit RCI to all the criteria of 10CFR50, Appendix B, applicable to RCI~
. work. Considering the major RCI problems that were revealed later, it appears that the CG&E audits were not only insufficient in number but also ineffective.
Problems that were subsequently identified included welding workmanship deficiencies, questionable welder qualifications, and inaccurate drawings.
These are typical examples of deficiencies that are ordinarily detected by QA audits.
The audits were also ineffective because the non-QA participants (that is, the CG&E project engineering personnel) were inadequately trained in auditing procedures and requirements and did not have sufficient time to prepare and execute the audits.
CG&E has taken appropriate corrective action by hiring other subcon-tractors to inspect the reactor internals, define any deficiencies,
~
and' take the corrective actions needed. -
In general, review of subcontractors' activities appears to have occurred aggressively only between CG&E and HJK.
There is little evidence that S&L, RCI, or CI activities were effectively reviewed, monitored,
- audited, or critiqued by CG&E.
This CG&E policy of delegating the responsibility for major elements of the work to reputable experienced contractors is not inconsistent with the approach taken by other utilities for the construction of nuclear power plants.
However, CG&E does not have the management system, implementing procedures, and staff required to control the work performed by their subcontractors.
Project planning and scheduling programs, and management information
- systems, appear to be available. However, their development, inte-gration, understanding, and utilization by CG&E and the major sub-18
O' s
\\
contractors have many shortcomings.
HJK appears to have had sinimal J
involvement in, input to, and use of these information systems.
Schedules and planning documents are not used to establish priorities or work plans at monthly subcontractor meetings.
Engineering, quality assurance,
construction, and planned testing activities are inadequately integrated.
TPT concludes that a centralized planning organization would be desirable in order to integrate the planning work of the operations group into a single reference source.
3.6.
PLANNED TRANSITION FROM PLANT CONSTRUCTION TO OPERATIONS In this area, the original objective was to review existing procedures and the methods by which these procedures are to be implemented in the I
transition of the plant from the construction phase to the operations phase.
From TPT's investigation, it is clear that the preoperational test program, qui originally conceived and carried out, was unsatisf actory due to
~
the significant design changes imposed during the program compounded by the decision to allow the release of systems prior to the completion of con-struction.
The disorder evident in the original test program resulted, in
- part, from turnover of systems to NPD which were in no condition to be meaningfully tested due to incomplete construction, known system changes which had yet to be physically implemented, and the large number (about 11,000) of outstanding DDCs which had not been incorporated in the design documents. Added to this was the large number of outstanding ECRs awaiting resolution and the large number of NRs resulting from the QCP.
This shortcoming has been realized, and the corrective action provided is to return the program, in effect, to its beginning by returning all essential systems to GCD jurisdiction.
The project would then be committed to completing all construction activities and repeating the entire preoper-ational test program. Judgments as to the adequacy of this approach must remain tentativc at this time since details of how the transition from the 19
construction phase to the operation phase will actually be implemented have not yet been finalized.
At the close of the original transition program, NPD had a staff of some 35 teat engineers, two-thirds of whom were CG&E employees.
It would be expected that this staff, experienced in the operating functions of the Zimmer plant, would be adequate to support the revised test program-The situation with NED is less clear.
As of May 1983, the department had a total engineering staff of only nine engineers who were assigned responsi-bilities f or the Nuclear Steam Supply System (NSSS) and/or Balance of Plant (BOP) syrtems.
Considering the backlog of outstanding ECRs, and the un-doubtedly large number of additional ECRs that will be generated in the course of renewed testing, it would be expected that the staff will have to be enlarged.
The proposed team concept, wherein representatives of all affected CG&E departments are assigned to a group having the responsibility for coordinating all needed work to successfully complete the preoperational testing of a specific system / subsystem, promises to supply the coordination of effort that appeared to be lacking in the initial program. As of this
- date, procedures have not been prepared to establish the number of teams, each team's responsibility and membership, and the amount of authority each team will have to set work priorities for the various CG&E departments and subcontractors involved in construction rework, QA documentation, and resolution of the deficiencies uncovered in testing.
Thus, the ef ficiency of the team concept could not be evaluated by TPT.
However, TPT believes that, when properly covered by the appropriate procedures, this will be.an effective program.
3.7.
CASE STUDIES In this
- area, the objective was to assess the role and behavior of CG&E management in response to selected specific problems and/or series of ev ents, using the case study approach as a cross-check on the observations 20
and conclusions reached separately in each of the other tasks in this independent review project.-
TPT found that:
In each of the case studies, similar management deficiencies existed which were consistent with problems found in the other tasks in this report.
For example, the other tasks in this review cited examples of CG&E management's lack of experience in nuclear construction, lack of emphasis on quality commitment, lack of procedurns and records
- control, and, fundamentally, lack of understanding of the importance of the thorough documentation required in the ccnstruction of a nuclear plant.
In each case study, the particular problems or deficiencies identified are presently being adequately addressed by CG&E.
The ;overall conclusion common to all case studies, which was also corroborated by observations in all other tasks, was that (since the SCO) there has been a significant change in approach toward project management and, in particular, the attitude toward quality.
As CG&E strengthens the Zimmer project organization by hiring experienced external personnel, this improvement in management attitude is expected to continue.
4 OVERALL CONSIDERATIONS In TPT'S opinion, the future major goals of the Zimmer Project must be to establish corporate credibility with the public and with regulatory authorities, to verify the quality of the design and construction to date, to rectify any deficiencies, and then to complete construction and start-up fully in accordance with regulatory requirements.
21
It is with this background, and based on the investigation of CG&E management (including its QA Program), that TPT recommends the management organizational changes discussed in Section 6 of this report.
Before specific organizational arrangements and responsibilities are discussed, some overall considerations deemed appropriate to the antici-pated continuation of the Zimmar project are presented.
4.1.
WORK SCOPE In order to recommend an appropriate organization, the major taska' that need to be performed must first be identified.
Key among these tasks are:
1.
Defining and completing a comprehensive QVP to verify the quality of the design and construction of the Zimmer Plant from start of construction to the present date.
The QVP should include: (1) an independent design review to determine if the design for Zimmer has been properly exe cuted and documented, (2) a construction
- walkdown, and selected nondestructive testing to confirm compli-ance between the actual construction and the design documents, and (3) a comprehensive records collation and review to ensure compliance with QA documentation requirements.
2.
Rectifying any deficiencies found in the QVP, including any needed modification of hardware in order to ensure compliance with design requirements and the reworking or replacement of areas where the quality is inadequate or indeterminate.
3.
Completion of remaining construction including: (1) outstanding design modifications, (2) final construction checkout, (3) pre-operational testing and start-up testing performed fully in 22 i
s accordance with NRC regulations and, finally, after start-up, (4) the ongoing operation of the plant.
4.
Confirmation of operator selection, training, and qualifications in preparation for plant start-up and operation.
5.
The development of a comprehensive and integrated program plan schedule and management information system to effectively plan and control the work.
6.
The establishment of an effective QA and audit program to ensure that all activities are performed in accordance with the appro-priate regulatory requirements and standards.
This program should include not only the audits but the actions to be taken in a timely manner in order to identify and correct problems and their root causes.
4.2.
POLICY TOWARD QUALITT ASSURANCE A key consideration in completing the Zimmer project is the policy and attitude of management towards QA.
Quality assurance must start with the top executive of the company and permeate the actions and responses of everyone and everything that is done.
This across-the-board commitment to quality and QA should not be made under duress or because CG&E is forced to do so.
The commitment should be made because it is good business and good management.
As will be noted in the following section, part of TPT's recommenda-tion is to centralize and elevate the status of the QA management.
How-ev e r,
all management functions must accept the responsibility and commit-ment to perform work of fully acceptable quality.
The QA group should not (as perhaps has been the situation in the past at Zimmer) be regarded as e
the organization controlling the work and assuring that it is right.
The connitment to quality, and the basic control of and responsibility for the 23
- work, is fairly and squarely in the hands of the construction, operations and engineering groups.
QA must be independent and provide assurance through the inspection, surveillance, and audit functions that quality is built into the product; but the a priori responsibility for quality is with the performing organization.
In addition to holding the performing organi-
)
zation responsible and accountable for the quality of the work done, upper management must get timely feedback on how well the work is done from a QA standpoint.
4.3.
THE QUALITY VERIFICATION PRGORAM The QVP is seen as the next project phase for the Zimmer plant.
This QVP is seen as considerably broader in scope than the existing QCP.
It affords CG&E the opportunity to make its QA objet.tives evident.
The immediate effort should include the planning and scheduling of activities,
- staffing, procedures preparation, organizing of related documentation, and the execution of inspection activities (including walkdowns) to check com-
.pliance
.be. tween actual construction and design document requirements.
An independent design review should be initiated immediately.
Implementation of hardware changes during this project phase would be initiated only as required to satisfy the QVP and would be completed prior to commencing the additional work necessary to complete construction, plant checkout, and preoperational testing.
l From the initial definition of its scope to its eventual successful l
completion, he QVP will require the support of every organization involved l
in the Zimmer project.
The day-to-day. leadership of QVP activity must be clearly defined as the responsibility of a single organization but the overall responsibility for the QVP is placed squarely with the senior executive having overall management responsibility for the Zimmer plant, as it is with any other project phase.
In this context, various elements of the QVP may have conflicting demands on available CG&E resources. A strong commitment on the part of CG&E management is required to coordinate, 1
i 24 t
- schedule, and monitor QVP activities (and to maintain staff morale) in order to achieve the successful completion of this program.
4.4.
STAFF AVAILABILITY AND ROLE OF AN ARCHITECT-ENGINEER / CONSTRUCTOR Another overall consideration must be the practicality of quickly obtaining the right type, quality, and quantity of management and support staff considered necessary to complete Zimmer in accordance with regulatory
- requirements. To mitigate this problem, TPT recommends that the most real-iscic approach is to retain the services of a fully qualified and experi-enced architect-engineer / constructor (A-E/C) type of company to provide the quality and quantAty of temporary staff required to manage construction and provide an overview of the QVP.
5.
EVALUATION OF ALTERNATIVE ORGANI7.ATIONS Various alternative organizations to accomplish the tasks identified above were evaluated by IPT.
In all alternatives sufficient authority, resources, management experience, and capability at all levels must be available to perform the activities required to complete Zimmer in accord-ance with design requirements and the NRC regulations.
5.1.
ALTERNATIVES EVALUATED Sixteen alternative project management organizations, as listed below, were evaluated.
Alternatives specified by the NRC for evaluation were:
1.
Strengthening the present CG&E organization.
25
2.
An organizational structure in which the construction management of the project is conducted by an experienced outside organiza-tion reporting to the Chief Executive Officer (CEO) of CG&E.
3.
An organizational structure in which the Quality Assurance pro-gram is conducted by an experienced outside organization report-ing to the CEO of CG&E.
4.
An organizational structure in which both Quality Assurance and construction management of the project are conducted by an experienced outside organization reporting to the CEO of CG6E.
Each' of these first four alternatives could be effected in conjunction with the CG&E organization that was in place at the date of the SCO, or with the CG&E organization as revised since the SCO.
The latter case pro-vides four additional alternatives (IA, 2A, 3A, 4A) for evaluation. _
, Alternatives suggested by TPT 5.
Creation of a new company organized and owned by the present owners (CG&E, Dayton Power and Light Co. (DP&L), and Columbus and Southern Oh;, Electric Co. (C&SO)), which would function virtually autonomously to complete and subsequently operate the Zimmer plant.
6.
Strenthening and reorganizing the Zimmer project organization within CG&E, whereby all aspects related to the Zimmer project are directed by an experienced senior officer of the company
[ effectively, the Zimmer Proj ect Manager (ZPM)], who had an involvement with Zimmer prior to the SCO.
In addition, con-struction management, and management of the QVP, are performed by an experienced outside organization reporting to the senior 2
officer responsible for the Zimmer project.
26
s 4
7.
Creation of an organizational structure whereby an experienced outside organization co-manages the proj ect with CG&E and assigns personnel to all key management positions.
The initial responsibility for Zimmer activities would rest with the outside organization, with a gradual transition to CG&E of the prime responsibility as progress was made and CG&E staff became more capable.
8.
Delegation of all activities on the Zimmer project to an experi-enced outside organization on a turnkey basis.
9.
Establishment of a Zimmer Project Oversight Committee (ZPOC) with a maj ority of the members having no prior Zimmer line management involvement.
The ZPOC would report to the Board of directors.
The organizational structure discussed in Altern-ative 6,
including the ZPM, would report directly to the ZPOC.
The ZPM would have a line of communication directly to the CEO of CG&E in reporting progress and status.
- 10. Establishment of a ZPOC reporting to the Board of Directors of CG&E as in Alternative 9.
The organizational structure dis-cussed in Alternative 6, including the ZPM, would report to the CEO of CG&E and have a Line of communication to the ZPOC to report progress and status (i.e., the reverse relationship to Alternative 9).
Alternative proposed by CG&E:
11.
Strengthening and reorganizing the CG&E Zimmer project organi-
- zatica, whereby all aspects related to Zimmer are the responsi-bility of the Senior Vice President, Nuclear Operations (who had no involvement with Zimmer prior to the SCO).
Bechtel Power Corp.
(BPC) as an experienced external organistion, will be responsible for management of the QVP and construction.
BPC's 27
e proposed scope of activity and responsibility is not yet final-ized.
BPL will report to a CG&E Vice President under the Senior Vice President.
CG&E co-managers are planned for all BPC proj-ect management positions.
(Note that this is similar to TPT's Alternative 6,
except for some differences in detail at the lower levels of the organization.)
Alternative proposed by Bechtel Power Corporation (BPC):
- 12. BPC proposed a fif th alternative to the four concepts suggested by the NRC.
The fifth alternative, proposed by BPC, was substantially the same as TPT's Alternative 8.
However, BPC interpreted NRC's Alternative 1, " Strengthening the present CG&E organization" differently than TPT. Their interp:: station is, in
- fact, co-management by an experienced outside organization and is similar to TPT's Alternative 7.
-5.2.. METHODOLOGY The organizational alternatives were evaluated using a modified Kepner-Tregoe type of analysis with criteria developed by TPT.
This decision making methodology involves defining primary (or MUST) criteria
(
and secondary (or WANT) criteria against which the alternatives are evalu-ated.
The MUST criteria selected were:
(1) all legal requirements and relationships to the PUC and nuclear licenses with NRC must maintained, (2) the organization must overcome all prior deficiencies in order to facilitate completion of construction in accordance with all NRC regula-tions and requirements, and (3) the organization must provide a credible basis for a comprehensive quality verification of all prior construction.
1 All alternatives which meet the MUST criteria are further evaluated j
against the secondary or WANT criteria. The alternatives are ranked using weighted figures of merit against the WANT criteria.
The WANT criteria selected were:
(1) external credibility, (2) soundness of organizational 28
characteristics, (3) practicality of implementation, (4) ease of transition from construction to operations, and (5) project continuity.
5.3.
RESULTS l
The results indicate that strengthening CG&E management, combined with involving an experienced external organization, is the basic element of the three front-running candidates.
Combining this basis with an independent
- Zimmer Project Oversight Committee (ZPOC) provides a considerable increase in the perceived credibility of the organization.
The practicality and credibility of having this ZPOC act in an advisory committee to the Board, rather than a controlling mode, is favored.
Consequently, Alternative 10 is the organization preferred by TPT.
A summary of the evaluation, including a brlef discussion of the relative merits of various alternativ as,
is provided below.
A more extensive discussion of Alternative 10, the recommended organization, is provided in Section 6.
The evaluation of the MUST criteria is presented in Table 1.
A number of alternatives met all the MUST criteria only weakly, particularly in the l
area of correcting prior deficiencies.
However, the benefit of the doubt was accorded to all alternatives on the basis that, provided the overall project organization was fundamentally improved, additional strengthening in selected areas could be effected to correct prior project deficiencies in that area.
The alternatives which met the MUST criteria (with qualifi-cations) are noted in parentheses in Table 1.
The evaluations in Table 2 of the L' ANT attributes for each alternative reflect relative judgments, not absolute ones, using a scale of from one to Each criterion was taken separately and evaluated based on experience ten.
and careful reflection of the best data available.
The weighted figure of 29
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J merit for each alternative indicates its the relative preference, in TPT's opinion.
Additional consideration was then given to developing the struc-ture of the front-running alternative (10) to address and correct the defi-ciencies observed in prior Zimmer project management.
Some of the key reasons for differentiating between the alternatives are summarized below:
At the operational level, the recommended Alternative 10 is quite similar to alternatives 5, 6, 9, 10, and 11.
Each, if properly struc-tured at the lower levels, should rectify the prior deficiencies noted in the Zimmer project management. The key difference between Alterna-tives 9 and 10 and Alternatives 5, 6, and 11 is the appointment of the ZPOC (at the Board of Directors level) to provide an independent advisory body.
The senior executive officer responsible for Zimmer must convince this committee that the policies and progress at Zimmer are satisfactory, consistent with NRC regulations, and in the best
. interests of the stockholders of CG&E. Using this committee in an operational mode, as in Alternative - 9, is considered impractical.
Establishing an autonomous new company, as in Alternative 5, would provide greater independence and even more external credibility but it is judged to be the most difficult, potentially expensive, and time-consuming to set up.
Legal issues on the transfer of NRC permits and licenses would require considerable further time and evaluation, the benefits of which are not consistent with the expense that would be incurred.
Alternatives 1, 2, 3, and 4 all suffer the same type of shortcomings.
Each would correct deficiencies in particular areas of the Zimmer i
proj ect management but, in TPT's opinion, the deficiencies extend l
across all functions within the complete project and also involve senior management.
- Clearly, Alternatives 1A thru 4A are variants l
which are better than their counterparts 1 through 4, but still suffer shortcomings in respect to the correction of functional deficiencies.
l 32 l
1 I
TPT doubts whether simply strengthening the CG&E organization (Alter-native 1),
interpreted to mean the replacement of or the hiring of additional staff, is satisfactory.
Involving an experienced external organization clearly enhances CG&E's credibility and provides an important resource to the project.
Alternatives 7 and 8 overcame the functicual deficiencies perceived by
- TPT, in that they apply across the complete project.
However, Alter-native 7, the establishment of co-managers at all key management posi-tions is perceived as highly impractical (involving a difficult division of responsibility and authority). At the working level, this choice would foster a persistent questien as to who was in charge and whose orders were to be followed.
The maj e r shortcoming in Alternative 8 is the lack of involvement of CG&E management and staff, who must be prepared to take over and operate the plant.
In addition, the relationship of all alternatives
.to CG&E. cop management must be carefully viewed to ensure sufficient external credibility.
Only Alternatives 5, 9, and 10 provide this characteristic to a satisfactory degree in TFT's opinion.
As noted
- above, in TPT's view, Alternative 10 is superior in that it is the most practical and credible of the three.
6.
RECOMMENDED ORGANIZATION The following summary of TPT's recommendation for an organizational structure is an expansion of Alternative 10.
It is presented (by group function) in the context of completing the work scope, particularly the QVP discussed in Section 4, Overall Considerations.
The organizational structure is depicted in Figure 1.
The foundation of any public-held stock company is the Board of Dirac-tors.
These directors represent the stockholders and their interests.
!?T 33
J J
CG&E BOARD OF DIRECTORS I
I l
I CG&E PRESIDENT OVERSlGHT AND CEO COMMITTEE
~
I I i
l !
J l
l I
I EXECUTIVE I
VICE PRESIDENT I
ZIMMER PROJECT I
MANAGER I
I
! THIRO PARTY l
l REVIEW / AUDIT l
1 1
MANAGER MANAGER MANAGER MANAGER MANAGER ENGINEERING QUALITY CONSTRUCTION OPERATIONS ADMINISTRATION
& LICENSING ASSURANCE
& QVP TEAMS
-S&L
- HJK
-GE
-QVP
- EXPERIENCED EXTERNAL O R GANIZATION.
C-17173 Fig. 1.
Recommended Zimmer project management organization 34
9 believes that (for a smooth functioning, efficient organization) the direc-tors must retain full responsibility and that it should not be diluted in any fashion.
TFT believes that the Cincinnati Gas & Electric Board of Directors should become more involved and knowledgeable regarding key policy decisions and the key results of those policies.
The Board, as a
- whole, should be perceptive enough to identify flaws and undesirable over-all results from key management policies.
These directors should bring business expertise and technical expertise applic'able to, if not directly related to, the nuclear industry and community concerns.
To assist in the fulfillment of this responsibility, TPT recommends the election of a direc-tor by the stockholders who is, and has been, independent of the Zimmer proj ect and who has broal experience in the nuclear industry from a busi-ness viewpoint, a project management viewpoint, and from a QA viewpoint.
TFT further recommends that the board, recognizing its responsibili-
- ties, carefully evaluate the capabilities and credentials of all CG&E officers having direct line management responsibilities for Zimmer, and, on the. basi.s of,the evaluation, if appropriate, issue endorsement of those officers.
To further assist the Board in fulfilling its responsibilities to the stockholders, in order for the Board of Directors to demonstrate its comaitment to integrity in all activities related to Zi=mer and, at the same time, achieve the maximum credibility in the eyes of its critics a Zimmer Proj ect Oversight Committee (ZPOC) should be appointed.
This committee should be constituted from existing CG&E directors (supplemented by new members, if required) so that the majority of members have had no prior involvement in Zimmer line management.
These directors should have business and technical expertise applicable to, if not directly related l
- with, the nuclear industry, and community awareness.
The ZPOC would be similar in constitution and independence to the recently formed Special Litigation Committee (SLC) formed by the CG&E Board to address the Bell Zfros Derivative Action Complaint.
35
4 e.
4 The capabilities of the ZPOC should be supplemented by a permanent, though not necessarily full-time, staff of advisors.
These advisors should provide technical and business expertise, and community awareness.
Included should be technical expertise in all phases of a nuclear project.
including engineering, construction, and quality assurance.
A member who belongs to such organizations as The American Nuclear Society, The American Society of Mechanical Engineers, or The American Society for Quality Control would be appropriate.
Also included should be a respected leader from the Cincinnati community.
Representatives of the two partners in the Zimmer project should also be included.
The ZPOC would provide an overview and source of information and analysis of Zimmer operations, for the Board of Directors that would be independent from the views of the line management.
This strategy would ensure the highest corporate visibility for Zimmer.
The ZPOC should have full access to any documents and records of the Zimmer project. The senior i
executive responsible for Zimmer would report periodically to this
-~ committee regarding progress and status.
The ZPOC would not make policy decisions but would act as an Advisory Group to the Board of Directors on policy matters, providing insights into the results of policy decisions.
The Chief Executive Officer (CEO) and President of Cincinnati Gas &
Electric has the full responsibility for the management of Zimmer, as well as all aspects of CG&E business, and also for the implementation of policy l
decisions from the Board of Directors. Any other organizational structure that might weaken the CE0's position would be counterproductive and would increase the cost of operation of CG&E, including Zimmer, to the stock-holders and therefore, ultimately, also increase the cost of electricity to i
I I
the ratepayers without any counterbalancing benefit.
Therefore, in this recommended organization, the CEO is left with the full responsibility for Zimmer.
As such, he must be involved in all policy decisions including the i
relative priority of quality, quality assurance, cost, and schedule; basic approach to regulatory requirements; and the organizational reaction to I
36 l
l
~
e whistle-blowers.
He must also be knowledgeable regarding the results of these policies and the continuing general direction of the project.
Obviously, he should not be involved in the day-to-day operation of the project but he must be sensitive to, and perceptive of, the basic direction of the project and its major problems.
Furthermore, TPT has concluded that the President of CG&E is capable of completing the job, notwithstanding the errors of the past and the widespread criticism of CG&E and its management.
This conclusion applies specifically with respect to the current President, Mr. W. H. Dickhoner.
In this reorganization, all activities related to Zimmer should be concentrated exclusively in a single senior executive who has had no direct association or involvement in the project prior to the SCO.
This senior executive would report to the President and CEO of CG&E.
He should have the authority and resources necessary to implement all measures needed to complete the Zimmer proj ect successfully and in accordance with the NRC regulations.
, He will also be responsible for previding complete, timely reports to the ZPOC concerning progress, policies, and any major problems at the Zimmer project.
He will also provide infornation to the ZPOC that is requested by the Committee itself or by its group of advisors.
This senior executive should have a proven track record in the suc-cessful management of major nuclear projects.
He should have demonstrable knowledge of all phases of the completion of a nuclear project including engineering, construction, quality assurance, and regulatory relations.
For the purposes of this discussion, he is referred to on the organization chart (Fig.
1) as the Executive Vice President, Zimmer Project Manager (ZPM), but numerous other titles would be appropriate.
TFT recognizes that CG&E has hired Mr. J. Williams, Jr. as Senior Vice President, Nuclear Operations, since the SCO, and that his sole responsi-bility is to manage the Zimper project.
In TPT's view, Mr. Willya=s is an appropriate selection to manage current activities at the Zidber plant.
37
4 His background and experience meet the requirements specified by TPT.
His words and actions since being in office have underscored his commitment to q'uality and his intention to do whatever is necessary to perform a compre-hensive QVP and to complete the Zimmer station fully in accordance with NRC regulations and the construction permit.
TFT also notes that Mr. Williams has hired three well qualified per-sons to head various functions at the Zimmer plant.
TPT has had no contact with these individuals as they have recently joined the project.
There-fore, TPT can observe only that their qualifications and experience fully meet, in TFT's judgment, the requirements of these positions.
The major activities identified in the previous section of this report should be addressed collectively by organizational units elevated in status to report directly to the Executive Vice President, Zimmer Project Manager, as indicated in Fig. 1.
Each organizational function should be headed by an individual of proven ability, having the qualifications and prior
.. experience, commensurate with the position.
An experienced, external A-E/C organization would be hired to perform necessary construction management and to manage the leadership of the day-to-day activities of the QVP in the context of the overall project commit-ments discussed previously.
It is recommended that HJK be retained to perform all construction activities under the management of the new A-E/C.
Existing CG&E construc-tion staff would be utilized to the extent required in the QVP; specifi-cally, to provide continuity to prior activities and records.
It is important to preserve the A-E/C's corporate identity, responsi-
the knowledge, experience and records of existing 38
staff; and the prospect of the transition from construction to operations (which will ultimately be the licensee's responsibility).
In these circum-stances it is inappropriate to fully delegate accountability to a new A-E/C.
CG&E, appropriately reorganized and strengthened in the senior management functions, should remain actively involved in Zimmer project management and quality assurance in order to properly discharge corporate responsibilities.
In this organi=ational concept, the A-E/C would have a clearly-defined corporate role and scope under CG&E's overall management.
- The A-E/C would provide necessary program management resources primarily in construction activities and in leadership of the QVP teams mentioned previ-ously. The new A-E/C would manage RJK site activities in the completion of the QVP and, subsequently, in the completion of construction.
In addition, depending upon CG&E's ability to recruit appropriate people, the A-E/C may also provide temporary staff to be integrated (under CG&E's direction) in areas other than construction; for example, in engineer:.ng and/or the operations area.
As noted above, the A-E/C's project manager would report to, and receive directions from, the Executive Vice President, ZPM.
The scope and ft ction of each major organizational unit and the relationship to major subcontractors is described below.
6.1.
CONSTRUCTION The A-E/C would replace the present CG&E construction management group.
The responsibility of the A-E/C would be to direct and manage all construction activities, including the remedial work resulting from the QVP and the subsequent completion of construction at the Zimmer site.
All work is essentially hardware related, but includes all required and related doc-umentation.
I Also as noted abov e,
it is further recommended that the QVP should report organizationally through the Construction Group to the Executive Vice Pfasident, ZPM. A team approach is proposed for the implementation of the QVP.
Each QVP Team would be assigned to a system, a subsystem, or l
39
G other logical and existing subdivision of the plant.
These teams would consist of personnel from each Zimmer organization, representing all disciplines and functions necessary for that team's assignment except QA/QC*.
The number of active people on a team would vary from time to time depending on the status of completion and the particular requirements.
The-experienced external organization is perceived to have the technical and management capability, and the prior experience, to assume this duty and to provide the necessary qualified staff as team leaders.
In addition, as the membership of each the team comprises representation from all other groups, all organizational units must contribute resources to the extent required.
The A-E/C's activities and responsibilities are concluded when the
- QVP, the subsequent completion of construction, the construction checkout
- tests, and the rework identified during the preoperational and start-up tests are completed, and the level of effort can be handled by the permanent station maintenance crew. At this point, the A-E/C, as such, is terminated and responsibility is fully transferred to the Operations Group.
--Thereafter; ongoing hardware-related functional activities such as materials receiving, warehousing, and key craf t capabilities are retained maintenance support function for future operations.
Qualified staff as a are reassigned to operations and engineering to provide an essential carry-over of experience into those areas.
6.2.
ENGINEERING The responsibility of the Engineering Group is to direct and manage I
all engineering activities related to the Zimmer project.
All work is essentially software-and engineering-related.
l
- QA/QC would be independently performing its normal project function while reporting through an independent chain of command to Zimmer's top management.
=
40
i.
During the QVP phase of the project, the Group's primary activities will be to:
1.
Participate strongly and actively in the QVP Team activities pro-viding the necessary technical input and guidance.
2.
Provide the liaison to a third party's independent design revi2w which is seen as an essential requirement during the QVP.
3.
Continue to be the primary technical interface between the Zimmer project organizaton, the original plant designer (S&L), and the NSSS supplier (GE), and 4.
Implement design control procedures to bring the technical docu-mentation of the plant to the s:andard required.
The Group would provide a technical overview and needed resources to other organizations, as required.
The status and, requirements to complete the ASME Code N Stamp Reports on earlier HJK work is one area requiring such technical evaluation.
Other areas would be power system performance and safety system performance.
The Group would also be responsible for all Nuclear Safety, Licensing, and Environmental Affairs.
The Group would not, as in the past, provide the administrative service for the purchase of components and services.
That function would be administered separately under the Administrative Group, with technical review as required by Engineering.
The Head of the Engineering Group, and the majority of his key assist-acts, should be permanent CG&E professional staff who, after the coupletion of the Q7P and the construction will provide complete technical services (or conduits of services from external sources) to the Operations Group.
41
The Head of the Engineering Group should hold an appropriate engi-neering degree from an accredited national university and have extensive experience in the nuclear industry. He ihould have held an engineering management position with a nationally-recognized company actively involved in the design and construction of nuclear power plants.
Prior experience' with BWR reactors would be desirable.
It is clear that the existing CG&E staff must be supplemented by additional qurlified staff.
Also in the near-term, the number of staff
=
will be greater than when the plant is operational.
It would, therefore, be appropriate to contract for some supplemental staff temporarily from qualified external organizations.
6.3.
QUALITY ASSURANCE The Quality Assurance Group is responsible for establishing and implementing a Quality Assurance Program that covers all activities on the Zimmer proj ect.
The program must be structured to ensure that all
' Zimme'r-rela'ted activities comply with current-regulatory requirements.
All Zimmer-related QA activities will be centralized under this Group including those related to the QVP, construction completion, preoperational testing, start-up and operations.
The Group is expected to function in the conventionally-accepted role, verifying the quality of the work accomp-lished by the performing organization.
The Group's responsibilities would include all of CG&E's Zimmer-related QA/QC activities, including the effective auditing of subcontractor performance, and also the prime responsibility for all external relation-ships with Federal,
- State, and Regulatory Code Authorities regarding QA matters.
42
t The Head of the Group should have the same status as all other Group Heads and report directly to the Executive Vice President, ZPM. Group staff should have equality in level, status, and compensation with other functional groups.
The QA Group should have a clearly designated information-reporting line to the CG&E President.
The Head of the Quality Group, and his key assistants, should be per-manent CG&E employees who, after the QVP and the construction completion
- phase, will have similar responsibilities for the continuing operation of Zimmer.
The qualifications of the Head of Quality Assurarce must predominantly reflect a strong QA management background and experience in civilian nuclear power plant construction and operation.
The existing CG&E QA organization is understaffed and staff must be supplemented by additional qualified personnel.
Particularly during the QVP, additional subcontractor support will be required.
s As part of their QA activities,
the Quality Assurance Group must provide particular attention to the determination of actions which must be taken to identify and correct any existing shortcomings in the quality of l
the Zimmer plant.
Accordingly, it is important that the group perform l
trending analyses of quality problems, keep track of connitments, and make timely determinations of the root causes of problems and measures to pre-vent their recurrence.
Another key duty of the Quality Assurance Group is to verify that adequate documentation is being produced and properly i
l retained for all Zimmer safety-related QVP, construction, engineering, start up, and operations activities.
i Although individual groups may retain copies of their own records, a central file for all safety related documents, maintained by the Adminis-trative Group, under QA's technical overview and direction is considered essential.
l e
43 L
2 6.4.
OPERATIONS The Operations Group is responsible for all activities related to pre-operational testing, start-up tests and subsequent Nuclear Power Plant operations to ensure safe and efficient operation of the facilities in accordance with all federal, state, and local regulations.
The Group's responsibilities include plant maintenance (af ter takeover from Construction);
the retention of a proper inventory of spare parts; plant security; and the procurement, management, and efficient utilization of nuclear fuel supplies.
The Group's responsibilities also include the training and requalifiying as required, of nuclear plant operators.
During the QVP and the construction complet:sn phases of the Zimmer proj ect,
the Group would assign staff to the varius QVP Teams primarily to obcain exposure to the design and construction phases of the facility and to maximize the opportunity for experience carry-over.
Also during these
- phases, the plans and procedures for the effective transition' from
' cons'truction to operations will be finalized.
The currently proposed
' team' a'pproach being developed by NED should be utilized. Leadership of its start-up. teams should be the responsibility of the Operations Group.
Plans will also be formulated for operator training and qualification and the subsequent maintenance of these qualifications.
- Clearly, the Head of the Operations Group must be a permanent CG&E employee reporting to the Executive Vice President, ZPM, whose continuing responsibility is to provide the necessary management capability to direct the future safe and efficient operation of the facilities.
Eis responsi-bilities will entail the establishment and implementation of policies and procedures relating to all aspects of operating the nuclear facility.
He should have a demonstrated record of success in the professional management of nuclear power generating facilities and have played a significant role 44
i in the start-up of nuclear plant (s).
CG&E currently has sone capable sup-port staff in the plant operations and operator training areas.
This caps-bility should be enhanced by their involvement in the QVP and continuing involvement in other reactor programs.
6.5.
ADMINISTRATION TPT recommends that administrative activities be centrali=ed and standardized under a single manager to relieve the burden on the Executive Vice President, ZPM created by multiple, independently reporting organiza-tians.
Presumably, corporate CG&E resources would continue to be utilized for standard administrative functions such as Finance, Accounting, Legal, Con-tracts, Purchasing, and Personnel.
In these areas, specific individuals at CGJE's main office should be clearly designated as having Zimmer duties as their first priority.
They should be available, as required, by the Execu-tive Vice. President, ZPM and should, in any event, be coordinated through a
~
single senior individual manager (independent of other Groups) on the Zimmer proj ect staff, reporting to the Executive Vice President, ZPM.
In the case of Contracts and Purchasing, although standard administrative head office resources may be utilized, serious consideration should be given to locating the designated individual (s) at the Zimmer site depending on the level of activity.
Three functions that require special emphasis (and that should be centralized, standardized, and specific to (and located at) the Zimmer I
site]
are the areas of Program Planning and Scheduling, Management 4
Information Systems,and Document Control. Major shortcomings of the Zimmer proj ect in the past have been the lack of effective integrated planning of cons t ruction, QA and the transition to operations, the absence of comprehensive management information
- systems, and an inadequate documentation / records control system.
2 i
45
4 o
There is a major and urgent need to establish such capability.
In the areas of Program Planning and Management Information Systems some progress has been initiated by CG&E, particularly in operations.
A powerful computer code, and related sof tware systems, have been purchased but are not yet fully operational nor effectively utilized.
It is strongly recom-mended that this capability be established and applied to all future acti-
- vities, commencing with planning for the OVP, and al.to applied for all activities thereaf ter.
As noted previously some progress is being made in the area of documentation to identify and compile records at the central f acility at Zimmer.
However, progress is slow and this task is not icing accomplished in a thorough manner.
This activity should be elevated in priority and focused under a relativelv senior manager.
7.
THIRD PARTY REVIEW recommends that a qualified external organization (s), independent TPT from the A-E/C referred to previously, be retained to perform review / audits in three specific areas in conjunction with the following organisational recommendation.
These are:
1.
An Independent Design Review.
2.
An independent Audit of the implementation of the QVP.
3.
A Records Management Review.
These reviews and audits should be performed by a qualified outside organization, which did not perform the activity initially nor will be involved in performing the activity subsequent to the recommended reorgani-zation.
2 a6
r e
6
- l The primary incentive to perform independent third party reviews is to provide increased assurance to CG&E management that the resumption of activities at Zimme~r will proceed properly.
It is in the best interest of management, the stockholders and the ratepayers that everything reasonably possible be done to assure satisfactory completion of the project. A secondary incentive is the increased credibility that will be achieved with Congress, the NRC and the General Public.
The p'ttpose of the Independent Design Review is to determine that the design for Zimmer has been properly executed and documented.
Selected critical safety systems should be examined to ensure that original design configuration and calculations (including field modifications) are ade-quate, comply with the design bases, and meet Regulatory requirements.
The purpose of the Independent Audit of the QVP is to provide expert l
independent assurance that in addition the audit would include an indepen-dent review to verify that the construction and repair activities at Zimmer are. being. performed in an adequate and effective manner consistent with Regulatory requirements.
The depth and scope of the proposed QVP activi-ties including the related planning of the program are adequate.
Selected critical safety systems would be examined to confirm compliance between actual construction and the original design document and that this compli-ance can be demonstrated.
The purpose of the Records Management Review would be to ensure that i
l the appropriate records retention and retrieval systems are being assen-
{
- bled, as recommended, at Zimmer.
In addition to examining the overall records management system, the review would test the effectiveness of the system by tracing selected documentation from design through construction to operations, ensuring that all prerequisite identifications and controls have been applied and that such documentation is readily retrievable.
I 47
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