DCL-84-065, Forwards Util Response to Sser Item 57 Re NRC Questions About Qualification & Certification of HP Foley Co QC Inspectors.Info Re Qualification of Pullman Power Products QC Inspectors Will Be Provided in Near Future
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77 BEALE STREET. SAN FRANCISCO, CALIFORNI A 94106 * (415)781 4211
- TWx 910-3776587 J.O.SCHuYLER
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February 17, 1984 PGandE Letter No.:
DCL-84-065 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulhtory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 SSER 21 - Item 57 Inspector Qualification
Dear'Mr. Martin:
Enclosed is PGandE's response to item 57 described in SSER 21 pertaining to the qualification and certification of H. P. Foley quality control inspectors.
Information regarding qualification and certification of Pullman Power Products quality control inspectors is scheduled to be provided shortly.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerely, Phuy r Enclosure cc:
T. W. Bisho)
D. G. Eisen1ut H. E. Schierling Service List I'
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PGandE Letter No.: DCL-84-065 t
ENCLOSURE PGandE RESPONSE TO NRC QUESTIONS REGARDING CERTIFICATION OF FOLEY INSPECTORS Description of Concern On January 19, 1984, representatives of NRC Region Y noted that HP Foley Company (HPF) did not begin certification of inspector qualification in. strict compliance to ANSI N45.2.6 until 1982. PGandE was requested to provide a description of the methods and programs used to qualify inspectors prior to 1982. This request was not directed to nondestructive testing personnel qualifications since all'non-destructive testing personnel have always been qualffied and certiffed to the standards of ASTN-TC-1A.
Background
This item was examined in detaff by the NRC in March and April, 1983. The results were reported in I&E Inspection Report No. 50-275/83-13 Item Ed, page 6.
No items of noncompliance were noted.
Program Description From 1970 through April 1981, formal' certification was not required for HPF quality personnel at Diablo Canyon. However, requirements for qualification
_and responsibilities for training of quality personnel were in effect as specified by approved and documented programs. The HPF QA manual, then QCP-6 (1974) " Indoctrination and Training" Procedure described how the HPF QC personnel, when hired, were qualified and assigned inspection duties based on the QA Manager's review of their education and experience. Based on this initial revfew, inspectors were then trained to the applicable procedures 0301d -
and other inspection requirements. Additionally, newly-hired inspectors were assigned to experienced inspectors who provided them with the necessary on-the-job training. Documentation of this on-the-job training was not i
4 required but training records were kept. An inspector in training was not l
allowed to document work acceptance until he had received sufficient traf,ning E
' and had shown by performance that he was ready to perform his assigned i
duties.-
These requirements and their implementation were routinely reviewed by PGandE 1
QA audits and PGandE General Construction inspections.
In May,1981, the QCP-6 procedure was revised to require certification of inspector qualification. The essential requirements were as follows:
1.
Inspectors were evaluated and certified for specific type of 4
i inspection by the QA Manager.
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- 2.
Personnel certification was based upon an individual's education, training, and experience.
3.
Personnel certifications were documented and maintained in the HPF QA f
Department.
The qualification requirements for training, experience and education continued to meet the intent of ANSI N45.2.6. The ANSI requirement to I
establish inspector levels was not implemented. Each inspector's background and training was documented by discipline (such as civil, mechanical, or l
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0301d '
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electrical) but the qualification levels (such as I, II, or III) were not established.
(Level I is a trainee, Level II, an experienced inspector, and Level III, a supervisor.)
Individuals which would have met only Level I requirements were not allowed to perform acceptance inspectfons since inspectors in training were not allowed to accept work.
B In August 1982, the requirement for Foley to comply with ANSI N45.2.6 (1778) was established by the PGandE Quality Assurance Audit 20801, documented in Open Item Report (OIR 117-82), and the subsequent Minor Varfation Repo-t, (MVR E-2394). This audit was conducted in accordance with NRC Generic Letter 81-01. PGandE responded to Generic Letter 81-01 with a formal commitment to meet ANSI N45.2.6. HPF complied with this requirement by issuance and J
implementation of QCP-6A, Rev. O, on December 7, 1982.
Summary From,the beginning of construction until 1981, the number of HPF fnspectors on site varied from three to ten. Since the numbers of inspectors were small, the performance of inspectors was easily monitored by the HPF QA management.
This overview provided assurance that inspections were satisfactorfly HPF performed although the program did not meet all ANSI N45.6 requirements.
has always had approved procedures and training programs in place to assure appropriate inspections. Even though the earlier HPF program did not meet the l
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requirements of ANSI N45.2.6 the level of training and documentation of
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inspector qualification met the ifcensing commitments of PGandE and was consistent with the intent of industry standards and requirements.
Improvements have been made over time as has been done elsewhere in the industry, and today the program for Quality Control inspector qualification and certification is in complete compliance with ANSI N45.2.6.
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% Tz-ey PACIFIC GAS AND E LE C T RIC C O MPAN FGwIE n SERE STREET. SAN FRANCISCO CAUFORNIA 94106. WSM814Mt. TWX 910M6587 0 c. scnuvbese February 17, 1984 PGandE Letter No.: DCL-84-066
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I Mr. John B. Martin, Regional Administratcr C
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U. S. Nuclear Regulatory Commission, Region V
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1450 Maria Lane, Suite 210 6
Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76
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Y Docket No. 50-323
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Diablo Canyon Units 1 and 2 Control Room Ventilation and Pressurization SMsten Q'..
Dear Mr. Martin:
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In PGandE Letter No. DCL-84-045, dated February 7,1984, it was stated that approximately 80 feet of cable required replacement to resolve a traceability concern identified in Contractor Nonconformance Report (CNCR) No. 8802-1015.
The generation of the CNCR and the question of traceability was due to an error made in documenting the cable reel number from which the cable was taken. The correct Class 1E color-coded cable had been used but exact reference to the reet which it came from was lost.
The cable in question has been replaced with traceable cable and the CNCR has been closed.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed, addressed envelope.
i Sincer c
ter cc: Service List G. W. Knighton
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- FAC1'IC GAS AND ELEC'* tlc CO
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Mr. Itabert L. 'Dadesco Assistant Director ftr Licensing Division of Licensing
- o. s. mei-r negulatory m w w h shington, DC 20555 Mas Den:fust No. 50-275 Docket m. 50-323 Diablo Cmqycn Dnits 1 mui 2 i
subject: Jd11tional Infammatim - Diablo Canyon tksits 1 mui 2 r
Daar Mr. 'Mesan
'fhis.y.".s to your 1sttar datmi October 7,1980 rugunsting additional information m ths quality aneuranos pegrusa at Diablo Canycn.
WN11y, you ruguestal clariffnetion of the h% descri%i in Sectim 17.2 of the FSML, as pewided in Junen& runt 85 to the Diablo Canyon license agplication. 'Iba attached rer,unnae is in the sans format as your request. 'Ihn informatim in this response will be i m.W into the Psut.
Eindly acknowla6ge receipt of.this material cm the erv w copy of this latter armi return it to as in the enciceed a&*::==-9 amulope.
M truly yours, Philip A. Crane, Jr.
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bec w/atta:hnent: Bart Buckley, NPC NPO. LICENSING bbec w/ attachment:
Diablo Distribution LOG NUM3ER
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Respor.** to NIC Imttar of October 7,1990 7
Requesting Additional Information on FSAR
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260.1 He fully cruply with all of the Regulatory Guides listed with specific clarifications and exceptions on the following:
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Regulatory Guide 1.8, February 1979, endorses ANSI /ANS 3.1~- 1979.
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Our Diablo Canyon draft ' Itch. Specs. refer to ANSI N18.1 - 1971.
We can ccuply with the acre stringent requirements of ANSI /ANS 3.1 - 1979 after three years of crzmarcial operation.
b.
Design and construction of Diablo Canyon Power Plant started g?
in 1965 and nost of the work cannot ccuply with the specific requirements of Regulatory Guide 1.26, February 1976. The intent of the Regulatory Guide has been followed as shown by crrparing the Regulatory Guide with Tables 3.2-2 and 3.2-3 in the FSAR.
c.
It is cur position that the Safe Shutacun Earthquake (SSE) for j' \\
the plant, as defined in 107R100, Appendix A, and referred to in Regulatory Guide 1.29, Septaber 19* 3, is the Double Design Earthquake (CCE). The ASI2 has decided that the Hoagri event is.
SSE.
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- i. We will-cxzply'with this Regulatory Guide and ANSI N45.2.6 - 1973 as applicable to nondestructive testing and Quality Control inspection persennel. Our plant Quality Ctmtrol Ingss, however, will not have the three levels of qualifications described i
in the ANSI Standard. As specified in the NRC Interpretation of
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Regulatory maide 1.58, issued April 1,1977, personnel perfoming l
inspection, examination, and testing functions aserr.inted with ncemal operations of the plant, such as surveillance tasting,.
maintenance, and certain technical reviews mily assigned to
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the plant staff, will be qualified to ANSI N18.1 - 1971.
y We will cxmply with this Regulatory Guide SEspt for the 4D g
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fire rating requirement for the records storage facility which g
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.harwt r---- "= trw. 1 hie on-site records.stcrage N
. facility will meet the 2-hour fire rating outlined in Section 5.6 i
(ofANSIN45.2.9-1979, issued.7uly 15, 1_979.
Our ocupliance with BIP ASP 9.5-1 has been the subject of a r.
thorough review by the NRC Staff. '!he results of this review are decamented in Supplanants 8 and 9 to the Staff's Diablo Canycn Safety Evaluation Report. 'the Staff concludes in
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S g plement 9 that "All matters relating to the fire protection j
program have now been resolved."
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NPO LICENSING LOG NlHiGEa l
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ATTACHMENT TO HPF/NCR 8802-824, REV. 1 Disposition Accomplished Summary as requested by the NRC i
1.
Employment verification was performed and documented on all currently employed QC Inspectors. The following methods were used:
A) Record of telephone verification.
B) Verification by letter.
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C) When verification was not' feasible, personnel interviews were conducted to determine if the individual had the knowledge one would expect him to have in the p^sition they held.
D) When previous experience was not exclusively in Quality, a statement documenting a percentage of time spent performing Quality related activities was prepared.
E) Tri-State Investigative Services was employed by Cataract to perform background verification on their personnel.
2.
Previous experience and education was evaluated to detemine the appropriate level of certification. ANSI N45.2.6-1978 was used as a guideline. Inspectors determined to be certifiable were issued new certifications by discipline. Inspectors detemined to be un-certifiable were reinspected in accordance with Item 3.
3.
A 10% reinspection of work of Inspectors who could not be certified was conducted and documented. Inspectors who worked in the Civil /
Structural discipline were 100% reinspected under the HPF/NCR 8833XR-74 series NCR's.
4.
Interviews were conducted with inspection supervision to detemine competence and performance level. The supervisors were asked to i
come on line stating they evaluated the inspectors'. performance level and that the inspectors were cognizant of the codes, standards and procedural requirements applicable to this project.
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H.P. Foley QCP-6A, REV. 1, paragraph 4.3 has been revised to indicate t
l capabilities of Level I and I,evel II personnel.
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6.
Screening of potential inspectors is performed by H.P. Foley QA prior j
to in-hire. Verification of education and previous experience is perfomed and documented prior to certification and release to begin l
inspection activities.
FOR INFORMATION ONLY l
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INSPECTION CLASSIFICATIONS 1
Electrical Inspection:
Inspections relating to raceways, and associate t supports, cables, wirepulling, terminations, junction and terminal boxes, sol. ring, concrete anchors, and. equipment installation.
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Mechanical Inspection:
Inspections relating to H.V. A.C., supports, cor crete anchors, plan't '
rotating equipment, and equipment and valve maintenance.
Instrumentation Inspection:
Inspections relating to tubing, small bore pip'ng, pnematic testing, test witnessing, brar.ing, and related instruments.
Civil Inspection (Structur,al):
l Inspections relating to fabrication, installation, and bolting of structural steel, including concrete anchors.
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cca_ : ;_:: Civil Inspection _(Concrete):
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Inspections relating to concrete, reinforcing steel, grouting, and plastering.
Receivingkaspeption:
Inspections relating to receiving and storage of materials.
Visual Welding:
Inspections relating to visual examinations of welds and welder qualifications.
Visual Welding (Structural):-
Inspections relating to structural steel M O h ~-5 MM.
Visual Welding (Electrical)/
Inspections relating to electrical supports, and ground pads.
Visual Welding (Mechanical):
metal.
Inspections relating to mechanical supports, piping and sheet Visual Welding (Instrumentation):
Inspections relatinz to instrurentation and piping, including brazing.
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BASIS USED FOR CERTIFICATION
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LEVEL I
-(l) Two years of reisted experience in equivalent inspection activities.
(2) High school-graduate and six cienths of related experience in equivalent inspection activities.
(3) Associate Degree plus 3 months'of related experience in equivalent inspection activities.
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- LEVEL II~
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- 41) One year of satisfactory performance as a Level I in equivalent inspection activities i
(2) High school' graduate plus three years of related j
experience in equivalent inspection activities.
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(3) Associate Degree plus one year of relate'd experience
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in equivalent inspection activities.
(4) BachelofDegreeplussixmonthsofrelatedexperiekce in equivalent inspection activities. /
u CENERAL STATEMENTS A.
Indoctrination to the requirements of 10CFR50 Appendix B and The Howard P. Foley Quality Assurance Program.-
B.
The probationary period has been vaived based upon verified previous experience.
r-C.
The probationary period has been waived based upon additional documented training, and verified previous experience.
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d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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.at BEFORE THE ATOMIC SAFETY AND LICENdING APPEAL BOARD i
T-D In the Matter of
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PACIFIC CAS.AND ELECTRIC
)
Docket No. 50-275 COMPANY, Diablo Canyon
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Nuclear Plant, Unit No. 1
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AFFIDAVIT OF JOHN D. CARLSON STATE OF CALIFORNIA
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COUNTY OF CONTRA COSTA
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- 1. John D. Carlson", being duly sworn do depose and state as follows:
1.
I an employed by the U.S. Nuclear Regulatory Commission in the Region V Office, Division of Resident Reactor Projects and Engineering Programs. A statement of my professional qualifications is attached hereto as Exhibit A-and incorporated herein by reference.
2.
I as the Senior Resident Inspector at Diablo Canyon and have had g
responsibility for inspection of the Diablo Canyon preoperational testing program. I as also responsible for the inspection of power ascension testing and plant operations. My inspection effort is in addition to the effort of the regional inspectors and supplements their work.
- 3.. I have personally conducted inspections of the Diablo Canyon facility since August 1981. I have specifically inspected activities related to the concerna expressed by the former H. P. Foley Company employees in their testimony to the NRC, dated March 25, 1983, and the State of California, dated April 5, 1983. The findings of this inspection effort are included in NRC Inspection Report No. 50-275/83-13, attached hereto as Exhibit B and incorporated herein by reference.
a 4.
I have read the document entitled " Joint Intervenors' Motion to Reopen the Record on the Issue of Construction Quality Assurance," dated May 10, i
l 1983, as well as the affidavits of Richard B. Hubbard entitled " Joint Intervenors' Motion to Reopen the Record," dated June 7, 1982, and " Supple-i mental Affidavit of Richard B. Hubbard Concerning Breakdowns in the Diablo Canyon Quality Assurance Prograa," dated March 29, 1983.
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- 5. The purpose of this affidavit is to address the matters raised in the l
above notat'd Joint Intervenors' Motion and Mr. Hubbard's supplemental affidavit, insofar as they relate to the concerns expressed by the former employees of ' the H. P. Foley Company. The areas of concern i
(1) qualifications of Foley Company QC inspectors. (2) inadequate ares ratios of QC inspectors to craft workers (3) failure to document I
or control acaconformances. '(A) failure to implement a adequate QA/QC program, (5) Anadequate QA/QC organisational independence, (6) excessive
. productiog pressure and harassment, and (7) absence of design drawings for a
installation of instrument tubing. These concerns and my knowledge of their 7
relevancy',to the issue before the board are addressed in the following 1
detailed tAragraphs:
p A.
Qualifications of Foley Company Quality Control Inspectors Paragraph 5.d of the attached report (Exhibit B) specifically addresses the concern regarding the qualifi:ation program for the Foley Company quality control (QC) inspectors and quality assurance (QA) auditors.
In the report, the evolution of the qualification program is described and was reviewed for compliance with the licensee's cot:=itments to the NRC. Prior to December 1982, the Foley Company was only required, consistent with 10 CFR Part 50 Appendix B, to perform an on-the-job training program to qualify QC inspectors. Starting in 1983. Foley Company QC inspectors have been subjected to the qualification standards of ANSI N45.2.6.
Based on my examination of the qualification programs I consider that the programs are consistent with licensee commitments, are adequately descrfbed by procedures and, based upon records examined, the inspectors are properly qualified.
B.
Inadequate Ratio of QC Inspectors to Craft Workers (a)
Paragraph 5.s o the attached report addresses the ratio of QC inspectors to craft workers n detail for the period prior to 1974.
In addition, for the period af r 1974 I also verified that the inspector-to-worker ratios for the Fole Company were within the range consistent with a
' national survey.
I of the opinion that the current ratios do not represent a condition uch that the workload of the QC organization is excessive.
C.
Failure to Document or Ade ustely Control Nonconformances Paragraphs 5.b, 5.f. 5.g. an\\d'.n of the attached report addresses the concerns expressed in the forme Foley Company employees testimony regarding the handling of nonconf ance reports (NCRs) and the inspection activities conducted in sponse to the concerns. The inspection team examined all NCRs ass cisted with the Fuel Handling BuildingmodificationsforthemonthsoffebruaryandMarch1983,and verified in the field, on a sampling basis N he handling of " Red Hold Tags" associated with the NCRs. Although thia ~ concern was substantiated in part as evidenced by the item of noncompliancbde(cribed in Appendix A to the cover letter of the attached report,'thea roblems identified in the testimony are, in my opinion, isolated cas h f w indiiiduals failing to fully follow established procedures and do not represent a major breakdown of the licensee's QA program.
D.
Failure to Implement an Adequate QA/QC Program J~.h
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Paragraphs 5.c and 5.q of the attached report detail the history and
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evolution of both the licensee and Foley Company QA programs.
I determined
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_3 from an examination of these programs that the progras received the apptapriate review by NRC in the case of the licensee's QA program, and by,
the licensee for the Foley Company QA program. The NRC conducted implemen7 tation inspections of the licensee and Foley Company QA programa as j
documented by greater than 50 NRC inspection reports since 1970 contained -H within the Diablo Canyon docket file. During the course of the recent
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special inspection, two violations of 10 CFR 50, Appendix B requirements relating to velder qualification and requalification were identified as shown in Exhibit B.
These items appear to be isolated, low severity level violations. Based on my review of the above noted documentation I*am of the opinion that the licensee's and Foley Company's QA programs were ade-quate and in compliance with NRC requirements applicable during that period of time as set forth in 10 CFR 50, Appendix B.
E.
Inadequate QA/QC Independence Paragraph 5.m pf he attached report provides details of the Foley Company's organization inc1 ing QA/QC. Based on my examination of the QA program, associated procedu s, and organization charts for the Foley Company, I consider that the Q QC department has had in the past and does have at present adequate ind endence to perform its function in accordance with 10 CFR 50, Appendix B, Regulatory Guide 1.28, and ANSI N45.2-1971 requirements.
F.
Excessive Production Pr sure and Harassment of QC Inspectors V)
A Paragraph 5.a of the atta ed report addresses the issue of excessive production pressure and ha,assment of QC inspectors. The inspection team, led by myself, conducted numerous interviews encompassing both production and quality assurance /contro personnel. The results of these interviews, in my opinion, do not indica that any excessive pressure, intimidation, or harassment of QA/QC person 1 existed to expedite production at the expense of quality, or to bypas procedural requirements.
C.
Absence of Design Drawings for Inktallation of Instrumentation Tubing
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Paragraph 5.1 of the attached repork addresses field routing of instrumentation tubing and placement f electrical conduit supports. The inspection team, led by myself, did n find any safety concerns relating to installation of instrumentation tub g.
It is my opinion that controls consistent with NRC requirements existe and were implemented covering the installation of instrumentation tubing a electreial conduit supports.
6.
Although, during the course of the special napection three items of noncompliance were identified as discussed i paragraph C and D above, I do not consider them to be indicative of a ignificant breakdown of the cons {ruction quality assurance programs of eit er the licensee or Foley Company. As for the concerns expressed or impi gd, some of the concerns were substantiated or substaniated in part; however, fg is my opi.nion that the items vere isolated instances of failure to comply \\with requirements and q
do not have significant generic implications as related to the implementation gj of the construction quality assurance programs.
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" Guidance on Quality Assurance Requirements During th Construction Phase of Nuclear Power Plants." This complies with our position on the implementation of guidance in quality assurance programs and is, the fore,-
acceptable.
Based on cur evaluation as described in the Sai y Evaluation Report and supplemented in this rep t, we now 4
conclude that the Diablo Canyon Quality Assur ce Program-has the necessary controls to comply with t requirements of Appendix B to 10 CFR Part 50 and is, th efore,_
l acceptable for controlling the operationa phase of Diablo Canyon, Units 1 and 2."
Pacific Gas and Electric Company, in Chapt 3, paragraph 3.2.1, of the final Safety Analysis Repor (FSAR), state,s that:
" Appendix B to 10 CFR 50, " Quality ssurance Criteria for Nuclear Power Plants and Fuel Repr cessing Plants,"
regsires that structures, systems and components t
important to safety be designed ad constructed in accordance with the quality ass rance requirements described in Appendix B.
Ther fore, as described in Chapter 17 of the FSAR, the quirements of the Diablo Canyon Quality Assurance Pr ran apply to all structures, i
systems, and components ela sified as Design Class I, this l
assures that plant featured important to safety have met the requirements of Appendix B."
f Chapter 17, of the FSAR st es in paragraph 17.1.2 that:
" Pacific Gas and El ctric Company's Quality Assurance Program requires that all contractors and suppliers of Design Class I it4ms establish and maintain in effect l
quality assurant/e programs appropriate to the importance of.their activ ties important to safety. Requirements for contractors' ad suppliers' quality assurance programs are prescribed design specifications. Specified requirene s are based on 10 CFR 50, Appendix B.
Contract s and suppliers are not permitted to proceed with th r work until they have submitted a quality assur ce manual describing their quality' assurance pro e and have received approval from PG&E."
Based on the above it.is apparent that the H. P. Foley Comp y was required to implement a Quality Assurance Pro an as required by 10 CFR 50, Appendix B.
N items of noncompliance or deviations were identified.
I d.
Concern: The concern was expressed or implied that H. P. Foley quality control inspectors and quality assurance auditors were not qualified in accordance with ANSI N45.2.6, " Qualifications
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of Inspection,' Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants", and ANSI N45.2.23,
" Qualification of Quality Assurance Program Audit Personnel for Wuclear Power Plants", respectively.
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NRC Findinas: This concern was not substantiated.
To' address this concern the inspectors reviewed the qualification program for quality personnel working for the Howard P. Foley Company. This examination indicated that the program for qualification of personnel'was specified and controlled by H. P. Foley Quality Control procedure QCP-6
" Indoctrination and Training," Revision 5.0, prior to December 1982.
This procedure;specified the indoctrination process and job-related training requirements leading to certification as a fully qualified inspector. However, this program did not specify levels of qualifications and educational requirements, as required by ANSI N45.2.6, for quality control inspectors, and ANSI N45.2.23, for quality assurance auditors. The inspector reviewed the licensee's quality assurance program that was in effect at the time (before December 1982) and determined that ANSI N45.2.6 and N45.2.23, were not a commitment of the licensee's program and thus were never imposed on the contractors. On May 4, 1981, the NRC issued generic letter 81-01 which required all licensees of cperating plants and holders of construction permits to endorse ANSI N45.2.6 for quality control inspectors and ANSI N45.2.23 for quality assurance auditors. The licensee responded in a letter, dated July 14, 1981,. and committed to implement the above standards with minor exceptions prior to full power
' licensing of Unit No. 1.
In August 1982, the licensee conducted a quality assurance audit (PG&E Audit No. 20801) of
,1 the H. P. Foley Quality Assurance Program and an audit finding was written ' gainst the H. P. Foley Quality Control / Quality a
Assurance Training Program for inspectors and auditors.
In response to the audit findings, H. P. Foley generated a new procedure (QCP-6A) for qualification and certification of quality control inspectors and supervisors that follows the guidelines of ANSI N45.2.6.
In addition, a new procedure has been drafted addressing the qualification of quality assurance auditors in accordance with ANSI N45.2.23.
The inspector reviewed t'he M. P. Foley qualification records for the Quality Control Manager, Quality Control Inspectors, Supervisors, Quality Assurance Auditors, Lead Auditors and the Quality Assurance Manager. Under the requirements of H. P.
Foley Quality Control Procedure QCP-6, in effect at that time, the qualification records were satisfactory. However, a problem with implementing the new certification process required by the new procedure (QCP-6A) was identified by the licensee. In late December 1982, the H. P. Foley Company contracted with Cataract Engineering Company to supply 1
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additional quality control personnel'. These personnel were certified to a certain level by Cataract based on experience and verified by an investigative service. However, the resumes of the individuals, in some cases, did not support the certifications in some areas. This problem was identified by licensee Quality Assurance Audit No. 83043A, performed in February 1983, and further documented on Nonconformance Report No. 8802-824, dated March 17, 1983. Currently the licensee.
the M. P. Foley Company, and Cataract' Engineering Company are.
resolving the problem by verifying past employment of the personnel in question. In the interiais, personnel with a potential resume problem are not being used in the field as quality contral inspectors. This nonconformance report (NCR No. 8802-024) also notes that between December 7,1982 and March 10, 1983, I.evel I inspection did not require a I.evel II co-signature, and further notes that, "This nonconformance encompasses both H.-P. Foley direct inspection personnel and sub-contracted, Cataract Engineering Company personnel." The resolution of these licensee audit findings will be examined during a future inspection. (50-275/23-13-01) hio items of noncompliance or devia'tions were identified.
e.
Concern: The concern was expressed or implied that as'a result of increased construction activity starting in September 1982 and the accelerated hiring of craf t personnel, welders hired during this period might not be properly certified.
NRC Findinas: The specific concern that welders hired since September 1982 might not be properly certified was not substantiated, however an apparent item of noncompliance with welder certification was identified during this examination and is detailed below.
To address this concern the inspectors examined H. P. Foley's Quality Cont'rol Procedure for Welder and Brazer Qualifications and the. Qualifications,of Welding and Brazing Procedures (QCP-5, Revision 8, dated 1/28/82) and determined that the procedure provides a system for qualifying welders and maintaining a continuous record of qualification status of all l
welders. The procedure references and appears to comply with the latest edition of the AWS DI.1, Structural Welding Code, l
for documenting test results and describes the: steps necessary to qualify a' procedure and a welder in accordance with Code i
requirements.
An examination of the qdalification records for seventeen welders (ironworkers, pipefitters, and electrical welders) established that all of the welders certified since September 1982 had been properly certified and monitored in accordance with requirements of QCP-5. However, the inspector noted that j
one electrical welder (symbol "JX"), initially certified on February 27, 1980 to an AWS D1.1 Shield Metal Arc Welding (SMAW) Process, had last been monitored by Quality Control on i
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weldina Inspector Qualifications The inspector reviewed the qualification records of four welding quality control inspectors authorized by the contractor to sign-off on process sheets. The inspectors' approval signifies that code and procedural requirements have been complied with, thus assuring a sound weld joint. The following qualifications ~were reviewed: education and training, knowledge of welding, inspectron experience, and good vision.
The welding inspectors appeared to be competent and have the necessary qualifications to make the inspections for the type of structures to be inspected.
No items of noncompliance or deviations were identified.
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Nanagement Meeting On March 4,.1983, the inspectors met with licensee representatives i
denoted in paragraph 1.
The scope of the inspection, the observations, and the findings of the inspectors were discussed.
4 The licensee acknowledged the concerns and the apparent item of noncompliance identified in this report.
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