.- . * . PUBLIC SERVICE INDIANA March 6, 1980 S. W. Shields Vice President - Electric System Mr. Harold R. Denton, Director Docket Nos.: STN 50-546 Office of Nuclear Reactor Regulation STN 50-547 U.S. Nuclear Regulatory Commission Construction Permit Nos.: Washington, D.C. 20555 CPPR-170 CPPR-171 Dear Mr. Denton: Public Service Company of Indiana, Inc. (PSI) has been requested to provide your office with information regarding changes in the context and organizational elements of its Quality Assurance Program. The following information is intended to fulfill this regt:est. I. ORGANIZATION OVERVIEW The Vice President-Electric System (who reports directly to the President of PSI) is charged with the overall responsibility for the Marble Hill Project Quality Assurance Program. The Marble Hill Project Quality Assurance Manager reports directly to the Vice President-Electric System and is organizationally independent of cost and schedule considerations as shown on Figure 1. The Quality Assurance Manager has the authority and responsibility to implement the necessary controls to assure that the Marble Hill Project Quality Assurance Program meets all NRC requirements. The only significant changes made to the Quality Assurance Organization are the clarification and augmentation of Stop Work authority, the simplification of documentation of nonconforming situations and the reorganization and g upgrading of personnel experience levels. y O ty \ ~ % ) 6< 60 d7 v 8008070 I) SE 'S 1000 East Main Street, Plainfield, Indiana 46168 317. 839 .9611 . , _ . --as.e . . - = ma, . --
Transcript
.- .
*.
PUBLICSERVICEINDIANA March 6, 1980
S. W. ShieldsVice President - Electric System
Mr. Harold R. Denton, Director Docket Nos.: STN 50-546Office of Nuclear Reactor Regulation STN 50-547U.S. Nuclear Regulatory Commission Construction Permit Nos.:Washington, D.C. 20555 CPPR-170
CPPR-171
Dear Mr. Denton:
Public Service Company of Indiana, Inc. (PSI) has beenrequested to provide your office with information regardingchanges in the context and organizational elements of itsQuality Assurance Program. The following information isintended to fulfill this regt:est.
I. ORGANIZATION OVERVIEW
The Vice President-Electric System (who reports directly tothe President of PSI) is charged with the overallresponsibility for the Marble Hill Project QualityAssurance Program. The Marble Hill Project QualityAssurance Manager reports directly to the VicePresident-Electric System and is organizationallyindependent of cost and schedule considerations as shown onFigure 1. The Quality Assurance Manager has the authorityand responsibility to implement the necessary controls toassure that the Marble Hill Project Quality AssuranceProgram meets all NRC requirements.
The only significant changes made to the Quality AssuranceOrganization are the clarification and augmentation of StopWork authority, the simplification of documentation ofnonconforming situations and the reorganization and gupgrading of personnel experience levels. y
O ty \~ % )
6<60 d7v
8008070 I) SE 'S1000 East Main Street, Plainfield, Indiana 46168 317. 839 .9611
., _ . --as.e . . - = ma, . --
.
.
Mr. Harold R. Denton -2- March 6, 1980PUBUCSERVICEINOlANA
II. DETAILED PROJECT ORGANIZATION
A. Proiect Diree''r
The Project Director, reporting to the VicePresident-Electric System, is responsible for direction andcoordination of the efforts of PSI organizationsparticipating in the Marble Hill Project and the following:
1. Interface with the Vice President-Engineering, theVice President-Construction and the Quality AssuranceManager to assure adequate manpower and resources areavailable in support of the project.
2. Direction of the Construction Manager, ProjectEngineering Manager, Project Control Manager andProject Administrator in the design, procurement,construction, testing and equipment control of theproject.
The Project Director will direct and coordinate the work ofthe NSSS vendor, the Architect-Engineer, Sargent & LundyEngineers (S&L), PSI organizations, consultants and otherassociated company functions as required to provide a safe,reliable facility. His responsibilities include theimplementation and execution of effective design reviewsboth within PSI organizations and in S&L's staff, theanalysis of bids, purchase recommendations, budgetaryanalysis, schedule preparation, progress reports andlicensing contacts with the NRC Project Manager.
3. Project Encineerina
The Project Engineering Organization is headed by theProject Engineering Manager who reports to the ProjectDirector. The Project Engineering Organizational structureis shown on Figure 2. The Project Engineering organizationhas overall responsibility for direction and coordinationof design activities and performs reviews of technicaldocuments as well as assuring that technical reviews areaccomplished by other affected PSI organizations. TheProject Engineering Organization is also responsible forassuring control of design changes and consistency withPSAR/FSAR commitments. The Project EngineeringAdministrator, who reports to the Project EngineeringManager, is responsible for the control of design documentsat the Marble Hill site and for maintenance of a DocumentControl Center.
g go v . o __Ntf_
. .
.
1
Mr. Harold R. Denton -3- March 6, 1980PUBUCSERVICEINDANA
C. Construction
The Project Construction Organization is headed by theConstruction Manager, who reports to the Project Director.The Construction Organization is shown on Figure 3. TheConstruction Manager is responsible for the following:
1. Overall responsibility for coordination of the MarbleHill site construction and fabrication.
2. Monitoring Contractor performance to commitments andschedules.
3. Coordination of Contractor interfaces.
4. Direction of the Construction Test Program at the siteto assure tests required to verify the integrity ofthe construction work are performed and documented.
5. PSI contractual acceptance of structures and systemsfrcm Construction Contractors.
The Construction Area Managers report to the ConstructionManager and are responsible for day-to-day coordination ofsite construction activities within their respectiveareas. Within their areas, they are also responsible for:
1. Coordination of Construction Contractor access to workareas.
2. Reparting progress to the Construction Manager.
3. As;uring Contractors take action on nonconformancesfrom specified requirements identified by the QualityAssurance Department or other PSI organizations.
The Systems Turnover Manager reports to the ConstructionManager and has the following responsibilities:
1. Authorizing issuance and use of construction testprocedures prepared by either Construction Contractorsor PSI.
2. Coordinating Construction Contractor participation inthe Construction Test Program including testperformance, notifications to PSI and performance ofnecessary repairs or correction of deficiencies.
.- . .. ...
|
Mr. Harold R. Denton -4- March 6, 1980gSERVICEINDIANA
3. Coordinating acceptance of completed systems,structures and components from ConstructionContractors following successful completion ofapplicable construction testing.
4. Coordinating the distribution, review and commentactivities of Construction Testing Program documents.
5. Directing and coordinating support personnel andothers during performance of Construction Testsincluding appropriate interface with Station Operators.
The Resident Engineer reports to the Construction Managerand is responsible for providing field engineering servicesto the Construction Area Managers. The overall scope ofthese responsibilities includes:
1. Preparation of Field Design Change Requests based oninput from the Area Managers and/or Contractors.
2. Review of Contractor-prepared procedures.
3. Review and resolve nonconformances within guidelinesprovided by Project Engineering and Quality Assurance.
D. Proiect Control
The Project Control Organization is headed by the ProjectControl Manager, who reports to the Project Director. TheProject Control organizational structure is shown on Figure4. The Project Control Manager is responsible for thefollowing:
1. Development and statusing of project schedules.
2. Construction cost control.
3. Assurance that PSI purchased materials, parts andcomponents are adequately controlled during receipt,storage and handling until released to Contractors sothat traceability to supplier quality verificationre:ords is maintained and damage or deterioration isprtvented.
- The Manag?r Material Management reports to the ProjectControl Ma3ager and has the following responsibilities:
- - . . . .
. .
t
Mr. Harold R. Denton -5- March 6, 1980PUBUCSERVCEINDIANA
1. Assuring storage instructions are obtained for PSI andCentractor stored materials, parts and componentspurchased by PSI.
2. Maintenance of records of materials, parts andcomponents stored by PSI.
3. Protection, maintenance and preservation of materials,parts and components stored by PSI.
4. Maintaining records of materials, parts and componentsreleased by PSI to Contractors.
5. Assuring Suppliers and Contractors provide OromptDispositions, or Corrective Actions when required, fornonconforming conditions related to receipt andstorage of itcas and materials.
E. Proiect Administration
The Project Administration Organization is headed by theProject Administrator, who reports to the ProjectDirector. The Project Administrator is responsible for thefollowing:
1. Processing Procurement Change Orders.
2. Maintenance of PSI warehouses and storage areas.
3. Interfacing with the Operations Organization for theadministration of Construction Site Security.
4. Control and issuance of Project Management Manual.
F. Quality Assurance Decartment
The Quality Assurance Organization is headed by the QualityAssurance Manager who reports directly to the VicePresident-Electric System. The Quality Assuranceorganizational structure is shown on Figure 5.
The PSI Quality Assurance Organization is assignedresponsibility for checking, auditing, inspecting orotherwise verifying that quality-related activities are
- correctly performed. The Quality Assurance Manager is theindividual responsible for managing the PSI QualityAssurance Program and for directing and controlling theorganization's conformance to quality requirements. The
.
i
Mr. Harold R. Denton -6- March 6, 1980PUBUCSERVICEINotANA
Marble Hill Project Quality Assurance Manual (FJAM)designates specific quality assurance functions to beaccomplished by the Quality Assurance Organization andthereby delegates corporate authority for performance ofthese functions. Specific quality assurance functionsinclude:
1. identifying quality problems;
2. initiating, recommending or providing solutions; and
3. verifying implementation of solutions.*
The PSI corporate structure is such that the QualityAssurance Manager reports to the vice president level ofexecutive management (specifically, the VicePresident-Electric System). This reporting level is thesame as that of the highest line manager directlyresponsible for performance of quality-affectingactivities. The Quality Assurance Organization istherefore independent of undue influences andresponsibilities for schedules and costs an'd has sufficientorganizational freedom to perform quality assurancefunctions. The reporting structure also affords directquality assurance access to PSI executive management, whichassures the availability of support as required to carryout quality assurance responsibilities.
The Quality Assurance Organization is divided into threefunctional organizations: Quality Engineering, Inspectionand Quality Systems.
The Quality Assurance Manager is responsible for:
1. The adequacy of the Quality Assurance Program,interpretation of Quality Assurance requirements andeffectiveness of the Program's implementation.
2. The use of appropriate techniques to assureconformance of all activities affecting quality to theProgram's requirements.
3. Assuring the adequacy, clarity and appropriateness ofall PSI Quality Assurance oriented communications andcommitments directed to Regulatory Agencies,Contractors end Suppliers.
_ _ . _ _ __
. .
s
Mr. Harold R. Denton -7- March 6, 1980PODUCSERVICEINDIANA
4. Assuring that actions such as Quality AssuranceProgram review, surveillance and audits are taken torequire Contractors and Suppliers to comply withapplicable Quality Assurance commitments.
5. Appropriately exercising the authority vested in theQuality Assurance Organization to cause the acceptanceor rejection of work, materials and equipment based onconformance to engineering requiremenes or failure tomeet procurement requirements.
6. Apprising tha Vice President-Electric System andProject Director of the project quality status byperiodic reporting on quality activities, trends andproblems through implementation of a corrective actionsystem.
7. Coordinating applicable activities of RegulatoryAgencies such as audits, inspections or investigationcwith the affected organization manager (s).
8. Appropriately exercising authority to stopnonconforming work.
9. Developing and maintaining current the PSI project andASME Quality Assurance Programs and Manuals (PQAM andAQAM) .
10. Maintaining staff of a sufficient size andqualification to support required audit, surveillanceand program development activities.
The Manager-Quality Engineering reports to the QualityAssurance Manager and is responsible for:
1. Supervision, coordination and direction of the variousdiscipline Superintendents Quality Engineering toassure adequate organization and control of theQuality Engineering function.
2. Maintaining communication and coordination between thevarious discipline Superintendents Quality Engineeringand other PSI and Contractor organizations.
The Superintendents of Quality Engineering (Electrical,Mechanical, Welding /NDE and Civil) all report to theManager Quality Engineering and are responsible for QualityAssurance matters within their discipline, including:
i
ff Mr. Harold R. Denton -8- March 6, 1980PUBUCSERVCS6NDIANA
1. Review of selected Engineering Documents to verify theappropriateness of and conformance to applicablequality requirements.
2. Review of selected Supplier and Contractor Documentsto verify the adequacy and conformance withquality-related. requirements.
3. Preparation, review and approval of PSI initiatedinspection / surveillance plans and procedures orchecklista which contain acceptance criteria to assurethe adequacy and appropriateness of conformanceverification requirements.
3. Review of the effectiveness of the practices, adequacyand performance of Marble Hill Contractors' andSuppliers' Quality Assurance Programs.
5. Review of Nonconformance Reports (NCRs) generatedduring design, construction and testing to verify thatappropriate quality considerations are applied to thedispositioning and reselution of the identifiedJeficiencies.
6. Maintaining awareness of inspections performed by theNuclear Regulatory Commission (NRC) and to assist thecocrdination of efforts by affected organizations.
7. Verifying that design, construction and testingactivities are controlled by suitable writtenprocedutes and instructions to ensure proper planningand accomplishment of work in an organized maTner; andverifying that such planning takes into accountequipment and service availability, weather protectionand housekeeping.
The Superintendent Procurement Quality Assurance reports tothe Manager Quality Engineering and is responsible for:
1. Coordinating procurement related interfaces betweenthe discipline Quality Ermineering and InspectionSuperintendents, and Suppliers or Contractors toassure that:
a. Preaward surveys are performed as necessary,
b. Quality Assurance records requirements aredefined and provided.
.....
.
;
'P Mr. Harold R. Denton -9- March 6, 1980
PUBUCSERVICEINDIANA
c. A witness and hold point program is determined byQuality Engineering and provided to theSuperintendent Inspection.
d. Surveillance and receipt inspection checklistsare prepared consistent with the schedules formanufacture or construction.
2. Maintaining the Approved Supplier and Contractor List.
3. Reviewing of Supplier and Contractor quality trendsand recommending necessary corrective action to theQuality Assurance Manager.
The Superintendent Inspection reports to the QualityAssurance Manager and is responsible for:
1. The supervision of PSI activities related to theperformance of supplier surveillance, receivinginspection and Contractor surveillance.
2. Assuring that inspection and surveillance activitiesare performed by trained and qualified personnel inaccordance with regulatory requirements.
3. Assuring that inspection records resulting frominspection and surveillance functions are properlycompleted, legible and authenticated.
4. Verification of the as-built condition of Marble Hillstructures and systems.
The Superintendent Quality Systems reports to the QualityAssurance Manager and is responsible for:
1. Developing and maintaining the Project and ASMEQuality Assurance Manuals (PQAM and AQAM) andsupporting quality procedures.
2. Providing quality-related inputs to changes affectingthe PSAR/FSAR.
3. Determining the need for, providing or arranging forand documenting Quality Assurance training ofpersonnel.
4. Scheduling and coordinating the PSI Quality AssuranceAudit Program.
i
I Mr. Harold R. Denton -10- March 6, 1980PUBUCSERV!CEINDIANA
5. Assuring retrieval of and maintaining Supplier andContractor quality verification records.
6. Coordinating NRC inspection activities and follow-upto assure correct resolution and prompt closecut ofinspection findings.
7. Performing and coordinating long-range planning andorganization studies to establish requirements fortransition from construction to operations.
8. Determining and coordinating Quality Assurancestart-up responsibilities.
9. Establishing a Quality Assurance trending program to7rovide a management tool for tracking and trending of.tonconformances.
III. QUALITY ASSURANCE PROGRAM MODIFICATIONS
The PSI Marble Hill Quality Assurance Program descriptionhas been reorganized and now is contained in the ProjectQuality Assurance Manual (PQAM). This reorganizeddescription of the Program did not alter PSI's previouscommitments to meet 10 CFR 50, Appendix B and relatedguides and standards. The Program is still mandatory andapplies to those activities which affect the quality ofnuclear safety-related items, material and systems asfurther described in Project Management Procedures. TheProgram includes Contractor and Supplier activities andservices affecting quality or safety.
Table 1 designates the PQAM sections which providecompliance with each 10 CFR 50, Appendix B, criterion.
Activities relating to the ASME Section III Code pipingsystems are conducted in accordance with the ASME QualityAssurance Manual ( AQ AM) . The AQAM complies with therequirements of the ASME Boiler and Pressure Vessel Code,Section III, and, by reference, is part of and not inconflict with the PQAM.
The Marble Hill PQAM and AQAM and changes thereto, areapproved by the Quality Assurance Manager, Project Directorand Vice President-Electric System.
PSI has also more clearly defined the authority of the PS~Quality Assurance Organization to stop nonconforming work
-_ -_
;
Mr. Harold R. Denton -11- March 6, 1980
PUBUCSERVICEINDANA or processes. The PSI Quality Assurance Organization has
full authority to stop further processing of items ormaterials by PSI or its Suppliers and Contractors; toidentify quality problems; to initiate, recommend, orprovide solutions; and to verify implementation ofsolutions. The individual stopping further processing isresponsible for documenting the nonconforming condition ona Nonconformance Report or Corrective Action Request asappropriate. Once further processing has been stopped, theorganization responsible for the activity which was stoppedshall not resume this activity until the conditions of theNonconformance Report or Corrective Action Request havebeen corrected or dispositioned and the PSI QualityAssurance Manager has provided documented authorization toresume processing.
The Quality Assurance Manager has the full authority tostop work of any PSI Contractor or Supplier organizationwhich, in his judgment, must be stopped in order to correctpoor quality trends or performance. This Stop WorkAuthority includes such things as a single prccess andbroader scope activities such as entire design activitiesof an organization, installation activities of a Contractorand fabrication or processing of PSI purchased materials oritems. The Quality Assurance Manager is responsible fororally stopping the work by notifying appropriatemanagement in the affected organization. The stop work isdocumented on a Stop Work Order which is signed by theQuality Assurance Manager. Documentation of the Stop WorkOrder includes conditions or actions required prior torestart of the work. Once the conditions requiringcorrection have been acted upon and have been verified tobe acceptable by the Quality Assurance Manager, he removesthe Stcp Work Order by signing the release portion of theStop Work Order. Completed Stop Work Orders are retainedas Quality Verification Records.
The Vice President-Electric System is responsible forreviewing and evaluating the status and effectiveness ofthe PSI Quality Assurance Program. The primary elements ofmanagement participation are by review of Quality AssuranceReports and establishment of a Quality Assurance ReviewCommittee (QARC), which holds meetings to review qualityAssurance Program activities. An annual independent auditshall be performed at the direction of the VicePresident-Electric System which assesses the scope,implementation and effectiveness of the Quality AssuranceProgram to assure that the program is meaningful,
I Mr. Harold R. Denton -12- March 6, 1980PUBUCSERVICEINDIANA
effectively complies with applicable codes, standards andregulatory guides and effectively implements all elementsof the Quality Assurance Program as stated in the PQAM.Reports containing the results of the audit shall bereviewed and appropriate action taken as directed by theVice President-Electric System.
The information above describes the programmatic andorganization changes instituted in PSI's Quality AssuranceProgram and is intended to fulfill the NRC's request forupdated information.
Please advise if you have questions concerning this material.
Sinc e y, y
S. W. Shields
SW5:ka
cc: J. G. KepplerE. R. Schweibinz, P. E.J. J. Harrison
