ML16340E193

Audit Rept:Pullman Power Products Work Scope at Diablo Canyon Site 770822-0920

ML16340E193
Person / Time
Site:	Diablo Canyon
Issue date:	09/20/1977
From:	Larsen G, Tonya Newman, Weber J PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML16340E194	List: ML16340E193 ML17083B245 ML17083B247 ML20086F497 ML20086F500 ML20086F664
References
NUDOCS 8403080281
Download: ML16340E193 (84)

Text

AUDIT REPORT PULLNAH POWER PRODUCTS WORK SCOPE AT THE DIAHLO CAHYOII SITE August 22 through Septer".ber 20; 1977

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)NTRODUCTION A.

Audit Scope and Purpose A quality assurance audit was performed on the Pul)man Power Products

.'work scope at the Diablo Canyon site.

The purpose of the audit was to'valuate the performance of the Pu))man Power Products Diablo Canyon Site Organization with respect to the Qua.lity Program and contract requirements.

The audit was performed under the cognizance of Hr. E. F. Gerwin, General Manager, Quality Assurance, Pullman Power Products

and, as such, was an independent, internal audit of the Pullman Power Products Diablo Canyon work scope.

The scope of the audit inc)uded the following.'1)

The organizational arrangement and the independence of the quality organization.

(2)

The qualifications and certifications of personne) performing the work;

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(3)

The Qual i ty Assurance

Program, including the procedures and instructions by which the work. )s.accomp) ished.

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The implementat'ion of the Qual ity.Assurance Program.

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(5)

The systems by which deficiencies"are'found,

reported, tracked, and corrected

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The workmanship of the field<<fabricated and installed items.

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The status,

adequacy, and effectiveness of receiv'ing inspection, C,

warehousing, ins al)ation, fielding, heat treating, NDE, instal la" tion inspection,

testing, and records functions for installed a

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. and erected piping, field-fabricated piping

(< 2-inch diameter),

piping supports, piping snubbers, piping restraints, weld rod, and material (excluding the Primary Coolant System) examined by nondestructive

testing, as appropriate.

The audit was performed by identifying each sys em or program that is used to control the work effor. and sampling those systems or programs until a conclusion could be reached concerning the adequacy or in" adequacy of that system or program.

The Pullman Power Products effort at Diablo Canyon was initiated in

1971, based on the contractual agreement of May 1970 between Pullman Power Products and Pacific Gas and Electric Company.

During the time period of 1971 to the present, the requirements relative to the Pullman Power Products work scope have changed.

The audit scope and purpose were to evaluate the Pullr.en.Power Products I

work effort against the codes and standards in effect at the particular time that the work was being performed.

@hen requirem nts are issued, there ls always some room for interpretation's concerning what is an acceptable method of satisfying these requirements.

,During. the 1971 to 1974 time period, a number of AMSist'a'n'da'rds" w'ere promulgated to

.-::::.,define acceptable methods of satisfying

10. CFR 50,'ppendix B.

lt is required that organizations revise th ir quality programs to sat-isfy present interpretations.

In areas requ~.ring interpretation, the quality of.the work effort at Diablo Canyon was measured against the curt ent AHSl standards and Reg'ulatory Guides, accepted today as valid

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Interpretations of regulatory requirements..

The long time span and the s'pecific time Interval during which the work effort.was conducted should be considered.

when reading.this audit report.

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c B.

Audit Team The'audit team consisted of the following Nuclear Services Corporation personnel:

Jack Weber, Audit Team Leader G. J. Larsen T. C.

Newman (part-time)

G.

W.

Rowe C.

Audit Resort The audit report is divided into six parts:

Section I, "Introduction";

Section II, "Audit Preparation";

Section lll, "Entrance Interview"',

Section IV, "Audit Findfngs";Section V, "Exit Interview"', and Section VI, "Sunmary."

Corrective actions will be determined by the appropriate Pullman Power Products personnel upon receipt and review of this audit report.

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AUDlT PREPARATIOH I

A series oF m ctlngs werc hei'd in which the Following tcntativc schedu)e was established:

o Preparation of checksh~cts o Receipt and review of Pullraan Power Products Quality Proaram documents and contractual co'mitments to Pacific Gas and Electric Company o Finali"ation of check hccts o Entrance interview e Audit of Organization, Personnel Qualification and Certification

Program, Document Control, Nonconformance

Progran, Auditing Prog. am c

o Feedwatcr

Systems, Unit 1

and Unit 2 o Hain Steam

System, Uni-1 e Chemical and Volume Control System; Unit 2

~ Residual Heat Removal

System, Unit 1

~ Safety Inspection

System, Unit 1

o Contairnent Spray

System, Unit 1

o Component Cool ing 'later Sys cm, Unit 1

The schcdulc was changed to meet thc progress and findings of thc audit, but thc Frrl 1 scope of. the audit was achieved.

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EHTRAHCE -INTERVIEW An entrance interview was held August, 16,

1977, a" the Diablo Canyon

'site to introduce the audit team.

In attendance at the entrance interview were:

Jerry Arnold Pacific Gas 5 Electric Co.

Diablo Canyon Site Quality Assurance Coordination A 1 hack Pullman Power Products Quality Engineer, Centra I Staff

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Rick Etzler Pacific Gas I Electric Co.

Lead Mechanical Engineer

.Gerry Larsen Nuclear Services Corporation Auditor Bill Rowe Hucl ear Services Corporation Auditor Pete Runyan John Ryan Pul lman Power Products Pullman Power Products Field Quality Assurance Manager Resident Construction Manager Hike Tressler Pacific Gas c EIectric Co.

Station Sup rintendent Jack Meber Nuclear Services Corporation Audit Team Leader During the entrance interview, a discussion was held of the progress

-.and problems associated with the Pullman Power Products effort and the present status of the ~rk effort.

The scope and schedule of the audit were discussed, and agreement was reached to perform the audit in accordance with.the schedule presented in Section II above.

Hr. J.

P.

Runyan, Field Qual ity Assurance

Manaaer, Pul lman Power

.'roducts, and his staff were 'designated as the audit team contacts.

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I IV.. AUDIT FINDINGS r

The audit findings are divided into the 18 sections consistent with 10 CFR 50, Appendix B.

The, audit findings are given to present the status of the program and, therefore, include both the acceptable and unacceptable areas detected during the audit.

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Criterion I.

Orcanization l.

A current organizational chart does exist.

2.

Procedures KFP-I and KFPS-I do describe the quality organization, as well as sor of the functional responsibilities of the quality organization.

3.

The Field Quality Assurance Organiza"ion has performed functions other than those described in KFP-I and KFPS-1;'and some functions were outside the quality responsibility, i.e., writing and approving Engineering Specifications, performing welding engineering functions, approving engineeri'ng changes.

These activities raise the question of the qualification of equality Assurance personnel to perform these functions and the problem of requiring the Field Qual,ity Assurance Organization to audit its own performance.

4.

5.

Procedures KFP-4, KFPS-4, KFP-6, KFPS-5, KFP-8, KFPS-7, KFP-9, and KFPS"8 do describe some of the responsibilities of the Field EngIneering Organization.

The responsibilities of the other Field Construction Organizations are not described, nor are the full responslbilitjes of the Field Fngineering Organi"ation described.

The descriptions of individual position responsibilities are in-adequate..

So.-..e lcmcnts of position descriptions exis.

in he KFP and KFPS procedures, and job..descriptions exist for inspection and inspection technician positions.

No position descriptions exist for any of the upper"level site personnel.

6.

The description and controls of the interfacial relationship between

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.Pullman Power Products and Pacific Gas and Electric Company are inadequate.

The contract and some Engineering Specifications do describe some interfaces and mechanisms.

However, for the greatest scope of the work effort, there is little to describe how the inter-face will be managed and controlled.

Some of the activities that

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require in!crfacc control are hydrostatic testing, nonconformance reporting, me tings, work on pipe rvpture restraints, work on

hangers, aocum<.nt. control, reporting of deficiencies, responses to Pacific Cas and Electric Company audits, interfaces with other Pacific Gas and Electric Company contractors that impact Pullman Power Produc s work, etc.

7.

The description and the controls of the interfacial relationship between Pullman Power Products Field Organization and he other Pullman Power Products organizations involved in the Diablo Canyon effort are inadequate.

The Qva lity Assurance Hanual does d scribe some qvality interfaces between the Field and Corporate Office

However, there are no requirements for periodic reporting from the Field Quality Assurance Organization to the Corporate Quality Assurance Organization; there are no requirements For an upper-management review of corrective action reports, nonconforr an e

reports, and personnel qualifications; the interface 'between the Field Organization and the Parar,;ount shop is not described; the interface between the Resident Construction Hanager and the Corpo-rate Construction Hanager is not described; the interface b tween Field Quality Assurance and Corporate Quality Assurance is not described with respect to field purchases and Corporate Qva'lity A "urance auditing of those suppliers.

8.

The description and the controls of the interfacial relationship between the Pullman Power Products Field Quality Assurance Organiza-t ion and the other Pul lman Power Products Field Orcani "at i ons are inadequate.

The Qual ity Assvrance Ha'nual and many of the Engineering Specification dc cribc interfaces nd mechanisms.

However, the interfaces relative to the construe ion and engineering efforts in regard to drawing approval; review o isometric,

hangers, and restraint document packages;

~elder logs; and cortrol of thc wcld-ing process are not described.

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9.

The stop work authority for the Field Quality Assurance Organization ls not adequate.

Procedure ESD-240 does describe the stop work authority for Hold Tags, but there are no mechanisms described or authority addressed for the circumstances when the Construction Organization elects to proceed through a Hold Tag stop.

10.

The Field Quality Assurance Organi"ation does report to a suf iciently high level of management.

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Criterion II.

Program 1.

The contract between Pullman Power'roducts and Pacific Gas and Electric Company was signed in Hay 1970, prior to.the enforcement of 10 CFR 50, Appendix B.

The contract did contain certain quality aspects that were requirements for the Pullman Power Products work effort.

Work was not initiated on the Diablo Canyon site until late

1971, when Appendix 8 had become a requiremen-Appendix 8 was added to 10 CFR 50 on June 17.

1970, effective July 27, 1970 (35 FR 10498),

and amended September ll, 1971, effective October ll, 1971 (36 FR 18301)j.

Even though the contract was not amended by Pacific Gas and Electric Company to include Appendix 8 as a requirement, Pullman Power ~

I Products was obligated to conform ta Appendix B requirements; and the total quality program was evaluated against Appendix B and ANSI N45.2.

Mhile a written Quality Assurance Program exists, the program does not meet the requirements of 10 CFR 50, Appendix B or ANSI N45.2.

The specific inadequacies of the program are descr.ibed throughout the findings.

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There is no description of the overall Quality Assurance Program.

0 Special Qual ity Assurance Instructions are not described; the rela-tionship and purposes of the

KFPS, KFP, and ESD procedures are not described; the Pipe Support Quality 'Assur'ance Hanual is not described; and the relationship of the Pipe Support Quality Assurance Hanual to the balance of the Quality Assurance Program is not documented.

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Procedures KFP-1 and KFPS-1 do provide a broad and generalized description of the scope and applicability of the Qual ity Assurance Program.

These procedures also reference the contract between Pullman Power Products and Pacific Gas and Electric Company.

Ho~ever, the total scope and applicability of the Quality Assurance Program are not adequately described.

The efforts relative'to pipe rupture restraints, receiving and control of materials and components other than Pullman Power Products-procured, and the work associated with anchor bol ts are not adequately described.

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There is no evidence that upper management has performed scheduled reviews of nonconformance

reports, personnel qualifications, and corrective actions.

5.

There is evidence that upper management has performed reviews of audit reports generated by Pullman Power Products and Pacific Gas.,

and Electric Company.

6.

The indoctrination and training program requirements for personnel involved in inspection activities are adequate.

Procedures KFP"2, KFP"3, KFPS-2, and KFPS-3 require training of NDE personnel; Procedure ESD-237 specifies a training program for the HDE personnel; Procedure ESD-237 also describes a training program for Quality Assurance Field inspectors.

70 The Indoctrination and training program requirements for personnel involved in quality"related activities are inadequate.

There is no requirement for indoctrination and training of welders,

foremen, engineering personnel, warehousing personnel, etc.

8.

There is no evidence that personnel have been trained to assure their familiarity with the procedures they are responsible for implementing, except for welders, who have been rained and qualified to specific

. weld procedures.

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C Criterion i/i.

Dcsinn Control 1,

There is no design manual for thc preparation of isometrics and field fabrication drawings.

2.

Procedure KFPS-0 provides adequate control of the pipe support design effort.

Procedure KFP-0 requires that thc Chief Field Fngineer and the Field Quality Assurance/Quality Control Nanag'er review field changes to Pacific Gas and Electric Company-approved drawings and specifications for ASHE Code compliance.

No writt n procedure for this review exists.

A mechanism does exist for checking and reviewing Pul)man Power Products drawings.

However, this mechanism is not described in a written procedure.

Documentation of the implementation of this informa1 procedure does exist.

3.

Thc isomc ries and field fabrication drawings do indicate the classification of systems.

6.

Procedure ESD-205 does contain a classification of systems and the requirements for each classification.

7.

Thc changes to isometric drawings and field fabrication drawings are indicated on the documents, as well as the reason for the change-Procedure KFP-9 establishes a mechanism o permit tracking of all revisions, i.c., the Chief Field Engineer is required to maintain a copy of all voidc.'.3wings.

8.

Procedure KFPS-8 requires the Chief Field Support Enginccr to assure that all supports arc fabricated to the latest drawing revision.

Wo mechanism exists to comply with this requirement.

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P rocurcm~ n t Documcn.

Cont ro 1

1.

Procedures KFP-6 and KFPS-5 adeqva c)y describ the responsibili:<es associated with fi<<ld purchase order proces ing.

2.

Procedure ESD-226 adequately dc cribcs the quality requirements for purchase specifications of the usual Pullman Power Prcduc:s scope of purchased materials.

3.

Proci'dures KFP-6 and KFPS-5 do no'equire that the purchase order state that Pullman Power Products is given the right to audit the subcontractor shop.

tlo writtcn procedure permi ts veri fication of the selected suppl i er as one identified on the Pullman Power Products corporate-approved vendors 1 i s t.

There is no mechanism by which Pvllman Power Prodvcts Corporate is informed of the procurement, of sa fety-rel a ted parts, components, equipment, and material to assure that the selected supplier is placed on the Corporate audit schcdvle.

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Criterion V.

Instructions

~ Prnccdurns, and Drnwlnrs l.

There Is no requirement

.that activities af ecting quality shall be prescribed by documented instructions, procedures, and drawings.

2.

Hany activities affecting quality are not described in procedures.

Among those activities are:

hang" r package review, pre-heating for wcIdlng y u

c of rotc-O-Grams, use of Rejection hotices, and mai nte" nance of Field equality Inspector Daily Logs.

3.

Hany activities affecting quality are Insufficiently described in procedures.

Among those activities are:'sometric p'-ckage review, post"welding heat treatment, nonconformance reporting, tHnety"Cay Welders'ogs and Meekly Qualified-Welders Lists, and auditing.

The present procedures are generally iradequate for providing direction to those performing the work.

The procedures do not follow the flow of the work; many procedures are very long (over 10 pages);

insufficient information is given; importint information is not provided or referenced in the procedure.

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Criterion Vl.

Document Control 1.

Procedures KFP"9 and KFPS-8 are adequa.e for field drawing control, and Procedure ESD"253 is adequate for pipe"support drawing control:

2.

Procedures KFP-17 and KFPS-15 are adequate for control of the KFP and KFPS procedures and are appropriately implemented.

3.

There is no procedure for control of ESD procedures.

There is'no procedure for control of Special Quality Assurance instructions.

5.

The Pullman Power Products review of completed packages relative to hangers and pipe restraints is not detailed in a procedure, nor is ESD-254 complete as to what is actually done for the isometric package.

Procedure ESD-254 does.describe some aspects of "Piping System Gocu-mentation Review."

6.

The Pullman Power Products log, Drawing Control index (KFP-9 and KFPS-8),

is maintained in a nonpermanent manner.

The log is. filled out in pencil; and when the number of revisions exceeds the available

space, the early revisions are erased to acconnodate the new revision.

7.

Ho mechanism assures that the Pacific Gas and Electric Company drawings being used as the reference drawings are the latest-issued revision.

Audits are frequently performed to determine that Pullman Power Products has the latest Pacific Gas and Electric Company draw-ings.

However, the audit mechanism is not satisfactory when it is the only mechanism.

8.

There is no Weld Rod Requisition for one of the welders who partici-pated in FW"345 of isometric'4-500-139.

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9.

There is evidence that docuncnts have been backdated and changed to r

meet requirements, without any substantiatron o

the rnformatron.

~ For Isometric 2-14-47:

Thc Process Shcct was changed to show the conplction of FW-192 on Apri I I 0 and April 1 1,

) 974, approx-

)mately 19 months after the work was done.

e Isometric 2-14-8:

FM-1673 was perforned to Revision 2 of the, isometric, which did not show FW-1673.

Revision 3 or the iso" metric, which included the FW-1573, was generated approxinate)y one week after comp)etion of the weld.

It is therefore concluded that FM-1673 was performed without the noma) controls of a Process

Sheet, a weld procedure'call-out, and a call-out of HOG requirements.

~ Isometric 2"l4-53:

rA"247 was completed February 20, l975.

Approximately December 1,

1975, the visua) ace ptarce was signed off and backdated; and

<<hc Weld Rod Requisition was char.g'ed to show that morc than the origiral quantity of one had be n burned.

o Isometric 2"14-59:

FV"268 was completed Febl'uary 5,. 1975.

On December 2,

1975, the entry on the Process Sheet for removal of dams was signed off and backdated.

There is no proo-tla. the dams had been removed.

~ Isometric 2-26-417:

FW-)44, -)45, "196, and.-)97 were ccr.".pleted on Hay )4,

)976.

Thc Weld Rod Requisition had been altered to add FM-197.

However, thc Weld Rod Requisition'hows that 14 rods had been

burned, which seems improbab)e for the four welds that were supposedly welded.

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Ilo prcccdurc or rcqu ircment pr ohibi

<<" the chang ing or a)tera ion of thc records and docuncnts that arc necessary to track the work.

Fic)d Process

Sheets, Weld Rosl Requisitions, inspection

records, etc.,

should not bc cliangcd or,should bc changed only by Qual ity Assurance supervisor'y personnel and then signed and dated.

ll.

Procedures KFP>>14, KFPS" 12, ESD-239, and ESD"254 are adequate instruc-tions to assure that the correct documentation has been assembled and the systen ls ready for turnover.

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Criterion V11.

Control of Purchased

Haterial, Equipment.

and Services 1.

The interface between the Pullman Power Products Field Organization and the Pullman Power Products Corporate Organization.relative to "selection and monitoring of suppliers'ulfilling field purchase requisitions is inadequate.

2.

Procedures KFP-7, KFPS-6, ESD-217, ESD-226, and ESD-261 are adequate for the performance of receiving inspection.

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Criterion VII'.

Identification and Control'of I;a.eria1s,

Parts, and

'omoonen ts l.

Identification and control of piping and valves are adequately specified by Procedures ESD-200 and ESD-201.

2.

Identification and control of weld material are adequately specified by Procedures KFP-12, KFPS-I I, and ESD-202.

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'." 5-Identification and control of backing gas dams are adequately speci-fied by Procedure ESD-214.

Procedures KFP-8 and KFPS-7 are adequate for specifying that the identification of parts and'components is to be recorded on the Field Process Sheet.

The implementation of this procedure is adequate.

The isometric drawings and field fabrication drawings are the major documents for recording the identification of the parts,

spools, and components.

Phile there is no procedural requirement, this mechanism has been fol'lowed and is an excellent technique..

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!dentification of welds and welders is adequately described in Procedures ESD-203,

-204, "221, and -243.

Proper methods of marking are specified in Procedures ESD-200, -201,

-202, "203, -204, "221, -223, and -243.

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Procedure ESD-248 adequately describes controls for the repair of

'nstalled, valves and for valve parts control.

N 10.

Adequate control of snubbers,

plate, and other components is achieved by using Procedures ESD-200, ESD-201, KFP-S, KFPS-7, and the practices associated with field drawing preparation.

However, no procedures specifically address these items.

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Procedure KFP-20 provides an adequate mechanism to control nuts, bolts, etc.

12.

Procedure ESD-223 does not give adequate instructions for the identi" fication and control of Class l Pipe Supports.

13.

Procedure ESD"228 does provide adequate guidance for the marking of tools used in grinding stainless and carbon steel welds.

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Criterion IX.

Special Processes i.

Hondestructive examination has been properly specified as a special process.

Procedures KFP-.3, KFPS-3, ESD-235, and ESD-256 adequately specify requirements for NDE personnel.

2.

The requirements for Field Quality Assurance Inspectors are adequately specified in Procedures ESO"237 and ESD-256.

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The qualification and certification program for. NDE and inspection personnel has been inadequate.

- The records of the following person-nel were examined:

D.

R. Geske, T. L. Koch, J.

E. Cawelti, G.

P-

Keeler,

'K. E. Beck, L. Glass, W. R. Johnson, E. Stanton, C.

B. Athay, R.

G. Sears, D. S. Tutko, J.

N. Shiromizu, V. J.

Casey, J. A. Brasher, L.'F. hayrick. S.

R

Stanley, H. Guest, D. E. Bentley, R. D. Kincade, K. D. Guy, J.

R. Bowlby, E.

R. Jennings, A. L. Newton, C.

C. Lenzi, J

J. Sisk, L. G. Thomas, A. A. Conques, and R.

L. Barks.

In vir-tually ail cases, the individuals began performing their duties without fulfiliing the specified requirements.

The most prevalent discrepancies are:

not completing the required training, not having proof of previous experience, insufficient time as Level I, unsigned

tests, and insufficient background and experience.

HDE procedure qual.ification is adequately described in Procedures KFP"2 and KFPS-2 as being the responsibility of the Hanager of Qual" Ity Assurance, Williamsport Headquarters.

Melding has been properly specified as a special process.

6.

Melding procedure qualifications are adequately described in Proce-dure KFP"15 as being the responsibility of the Welding Engineer (Williamsport).

7.

Procedures KFP-15, KFPS" 13, and ESO-216 are adequate for specifying welder 'qualifications.

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8.

The ccrti fication of thc fol)owing wc)dcrs, by weld synbol, was examined and found acccptablc:

U, AH, IH, PO, VO, QZ, HY, PO, JL, ET) HL) A<) HO) TQ)

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C) FC ~ and ZC 9. The certification of .)der U was not sign d. .10. A number oF proccdurcs provi de meehan i sms For control of,,the weld-ing process: ESD-203, -204, -2)5, -219, -221, -225, -227, -242, and -243.

However, the contro) oF thc we)ding process has been inade-quate as follows:

~ Records of welder qualifications prior to 1972 are not available. ~ The Hin ty-Oay Welders'og was not maintained from Augus-1 72 to December 1972. There is no Weekly Qualified-Welders List For that time period to substantiate that the welders were actually qualified. ~ Thc Hinety Day Welders'og is not 'sufficiently'detailed to determine i f the welder i s qual i fied to perforn certain proce" dures. The Hinety-Day Welders'og has.been revised a number of times, and the detai) has improved with each revision. Pre-vious to the latest revision (November )974), the lcg was very poor in giving precise inforration relative to procedure and 'hickness ranges to which thc welder was qualified. o Ho procedure states what thc Fie)d Quality Assurance Inspector uses as the primary means to determine welder qualification, the Hinety"Day Welders'og, the Weekly Qualified-Welders List, or the Wcldcr'ualification Card. e Ho 'procedure specifics who is responsible for the Ninety-Day Welders'.og, the Weekly Qualified-We)ders List, or the Welder' Qualification Card; how thc information is obtained; how the logs arc used; to whom they are distributed; ctc. - 22 " e Procedure KFPS-13 differs from KFP-15 in that it does not permit a six-month extension of welder qualifications if the welder has been act.ively welding on some other welding process. Procedure KFPS-13 requires the welder to use the specific welding process within a three-month period or be requalified. There Is no evi-. dence of adherence.to this requirement for pipe support welding. l ~ Melder, BF (M. Adair, 251)'erformed welding on FM-70, -72, -73, -76, -77, -78, "1008, -132, and -133 in isometric package 21-7 and FM-88, -90, -91, -92, -134, -135, and -1608 in isometric package 21-8. This welder was not qualified for the thickness range; and the welds were reported on DRs 2536,

2538, 2539, and 2899.

In accordance with Pacific Gas and'Electric Company dis"

position, some of the welds were radiographed and found accept-able; Melder BF was quaii,fied to the thickness range; and all the welds in question were accepted.

This disposition is not permitted by 831.1, B31.7, and ASHE,Section IX, which all specify that the ~elder must be qualified prior to making pro-duction welds. Procedure, ES D-2 1 9 requires random samp 1 I ng of I np roc es s we ) d Ing ) with the sampling to be 'noted on the Field Process Sheets. I n examining Field Process S hee t s, it I s obvious 'hat the samp 1 i ng by the area i ns pecto rs wa s not performed. r ~ ~ ~ ~ Procedure ESD"219 requires periodic auditing by the Melding Auditor. These audits were not performed until November 5,'973; and Pullman Po~er Products. was not in compl iance with this procedure for approximately 23 months. ~ Procedure ESD"219 requires monitoring stainless steel welds for ferrite control.

However, the Severin Gauges were not on site until the beginning of 1973; and Pullman Power Products was not

~ ~ In-compliance with this procedure for approximately 12 months. 23 I ~ I r e Hangers are not welded in accordance with Pacific Gas and Electric Company requirements. Hangers 2023<<1V and 2039"2V are two examples. of, a number of hangers observed that are welded to th'e structural steel on.the wrong side of the br'acket. o The interface of welding to,other suppliers'arts and compo-nents is not clear. Melding is done to join Mestinghouse and Paramount parts and components. The necessity for addressing impact property requirements for those weldments is not clear; ln addition, the requirements for addressing impact property requirements for Pullman Power Products Field welds are not clear. lf impact properties are necessary,'the acceptability of each weld that has been repaired and subjected to more than one stress relief is indeterminate because of the time at tem-perature limitations wi hin the qualified weld procedure. o Some ~elders do not receive sufficient training.

Vclders, fabricating the pipe rupture restraints within the contain-ment, are welding heavy plate. 'hi le these welders are quali-fied by virtue of welding heavy wall pipe, the techniques are different.

The welders who were already qualified to heavy wall pipe were not given adcfitional training on plate. o There is no procedure for the preheating of weld joints. ~ - The initial results of the welding audi ing (from Hovember 5,

1973, to February 1974) indicate that-the following prob)ems ex l s ted:

'he welders did not understand shielding and purging. 'Templl sticks were not used. 'mperages were not within procedure limits (mainly root 0 a I ~ ~ A 4 a > A ~ ' welds and tack welds. Meld procedures were not available, and many welders did not know where to obtain them. The oxygen analyzer was not available or not operative. Also, the time vs flow rate alte'mate technique was not used. 'ven rod temperature control was not monitored by the welders.. Hany welders did not understand their duties and responsi-bilities. 1 II t Sased on a review of the Pullman Power Products welding audit reports and the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requi're-ments. ~ ~ t ~g Melcfing procedures for carbon steel welding require'reheat and inter-pass temperatures for material that has a carbon content in excess of 0.30 percent and a thickness of one inch or mor. There is no mechanism by which the welder can determine carbon content. 12. 13. Procedure ESD-221 does provide adequate guidance on weld repairs. Heat treating has been identified as a special process in the Pacific Gas and Electric Company contract (as well as in Appendix S), but i" has not been controlled as a special process by Pullman Po~er Products. Procedures KFP"13 and ESD-218 provide controls of the post-weld heat treatment process. The implementation of Procedure ESD"218 is acceptable. 15. Cleaning has not been ldenti.fied as a special process. ~ ~l 16. Procedures ESD-220, -224, -238, -242, -252, -258, -259, and -.261 provide adequate guidance in cleaning and 'cleanliness of the various materials,

parts, and components.

lj. Procedure ESD-231 provides some guidance on hot and cold'ending of small bore piping. The guidance is considered insufficient to assure that the bending is done properly to avoid high stresses and thinning of the wall. 18. Procedure ESD-238 provides adequate instruction in torquing of bolting for pipe flang'es. 19." Procedure ESD"259 provides adequate instruction for in'stalling Grinnell Snubbers. 20. Procedure ESD-224 provides excel lent instruction for assembly and torquing of installed valves. 21. Procedure ESO-260 provides adequate instruction for instal lat ion of Vi 1 l Iams Rock Bo 1 ts. 22. Procedure ESD-230.provides good instructions for entering an in-stalled )Ine. I P MM P.F pPz Criterion X. Inspection l. Procedures KFP"5, -8, and -)4 thoroughly describe the interface between Pullman Power Products and the Authorized Inspector. 2. Procedures KFP-5 and KFPS-7 provide the requirements for the Field 0 . Process

Sheet, which specifies Inspection points and inspector sign-off.

3. The Field Process Sheet references procedures to which the work and . the inspections will be performed. The inspection procedures are detailed in Procedures ESD-206, "207, -208, -209, -210, -211, "215, -219, -225, -233, -234, -236) -241, I -243, -244, "249, -250, -251, -255, "259, and -260. These procedures

are, in general, broad descrip ions.of the inspection process for the total range of the work. scope and are adequate for that purpose.

. For all Inspection processes, there is no mechanism to provide the inspector the particular characteristic to be inspected; the partic-ular acceptance criteria; the particular methods and equipment o be used; and provisions for, recording results, other than acceptance for the particul,ar inspection.being. rude. .The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures that specify the use of. particular equipment (such as some of the ultrasoni.c procedures). 6. The inspection process is generally not auditab)e. The practice of exhibiting an acceptance signature on)y does..not permit auditing to determine if the lndividua) characteristics were, examined, the corrt.,: criteria were used for acceptance, and the correct specific measuring devices were used. 7. A large number of welds in Unit 2, System 14 (Rl-))0, -11), and -112 in isometric package 2-14-31 are examples) were accepted for 27 a c vl "ual examination and thereafter accepted based on surface HDE inspection (NT or PT). Visual examination of those welds indicates that the surface is not suitable for the pcrf'ormancc oF su o F ur face t!DE inspection. 8. For FM-110 (isor.-etric package 2-14>>31), the Process Sheet indicates that HT was pcrforr,".ed; however, the inspection sheet for Pi shows that weld number, and the inspection sheet for ki does not show thac weld number. FM-83 (isometric package 1-10-9) was repaired in accordance with a valid Process Sheet. The radiograph of PM-83 does not exhibit th required.Rl symbol, but Rl was inkcd onto tl..e radiograph. There is a surface defect that is questionable for acceptance to visual standards. 10. Isometric. package 1-03-1 has a step that requires a Pullr.:an Power Products inspec'.or sign"off. This requirement was remo e v d and the step was accepted by a Pacific Gas and Electric Company employe ~ I P I ~I Criterion XI. Test Control 1. Procedure ESD"229 adequately defines the methods and inspections relative to performing hydrostatic tests. 2. There is no description of the responsibilities of Pacific Gas and Electric Company or of the Pullman Power Products/Pacific Gas and Electric Company interface relative to hydrostatic testing. 3. Procedure ESD-229 is not adequate for describing the flow and authorities relative to the individual hydrostat,ic test procedures to be performed.. Hydrostatic test'ackages 7-2, 7-2A, 8-12, 9"12,

106, 106A,

106B, and 64 were examined and found acceptable.

5. The B31.1 and B31.7 Codes require that all piping be leak-tested, where practicable. Pullman Power Products is only leak-testing Class A and B piping and that Class C piping specified by Pacific Gas and Electric Company. Classes D, E special, and E piping is not being leak"tested. A letter from Pacific Gas and Electric Company (dated. January 13,. 1976) does exist, which statnes that Pacific Gas 'and"Electric Company will assume responsibility"for 'he leak"tesiing of Class C piping. 'There is concern tha. Pullman'ower Produ'its'Ret not di'scharging its contractual obligations (that specify compliance to 831.1 and B31.7) by not performing piping leak-testl rip to Code requirements for Classes', D, E spatial, atnd E piping systems

and, as a result, may be legally vulnerable.

~ e ~ ~ ~ r 29 'I ) ) ) ~ Criterion Xl f. Heasurina and Test Equipment 1. Procedures KFP-ll, KFPS-10, and ESD-213 describe an adequate caii-bration program. 2. The calibration program did not require reca libration of thermo-couples until June 16, 1976. Therefore, there is no assurance of the accuracy of thermocouples used for pre-and post-welding

heat, treatment prior to June 16, l976.

Hewly purchased thermocoupies were required to be cal.ibrated by the manufacturer. However, the manufacturer's calibration does not assure that the thermocouples have not been damaged during handling and shipping. 3. The calibration program has not been adequately implemented. ~ Paragraph 11.5 of Procedure KFP-11 and Paragraph 10.5 of Pro-cedure KFPS-10 require reinspection of materials and components lf the measuring and test equlpmen is found to be out-of-cali" bration. Except for hydrostatic testing and heat treating, the identity of measuring and test equipment is not re1ated to the inspections performed. ~ ~ ~ y ~ 0 ~ ~ ~ i 4 ~ 0 ~ ~ Procedure ESD-213 does not conta-in a,mechani~-.to <eport. out".-. of-calibration measuring and test, equipmeot ta.PQ lman Power Products.. Some forms used by.the cal.ibrat~an subcontractors... on 1 y con ta l n provisions for. at test leg, co.ca ldb rat 1 ng the equip-ment to appropriate standards and;have eo gray~:sions for record-ing the actual values obtained. we ~ 4 ~ ~ o The calibration records. of recorders were.confused by, having two recorders identified on one record, and the. acceptability of the records could not be determined.. 1 Severin Gauges 2947 and 2971 were received on the site in January 1973. initial cal ibration was August 29, 1973; and he next calibration was Hovember l9, 1974, for gauge 2947 and January 23, ~ ~ ~ g e 1975, for gauge 2971. Procedure CSO-213 requires annual ca 1 ibci1t i on. o Hagnetic Particle Test Equipment Y-6 has no documentation to veri fy cal ibrat ion. a There is no documentation available to verify calibration of "Tong Test" ampmeters. ~ "Tong Test" Qmpmcter TT2527403 was out of cal ibration for the period December 12,

1976, to January 31, 1977.

Ho OR has been writ ten aga ins - tha t i ns trument. ~ Storage requirements for instruments are not specified. ~ ~I Criterion XIII. IIandllnn . Storanc, and Shinninr. 1. Procedures ESD-Z02, -Zly, -2l7, -222, "223, -240, -259, and -261 provide some information relative to handling and storage of mate" rials, parts, and components ,or thc total scope of the Pullman Power Products effort. Procedures for storage are generally inadcquntc. Procedures ESD-222, "Control Valves," and ESD-202, "Weld Haterial Withdrawal and Control," are specific and adequate. Procedure ES0-215, "Visual Inspection," provides some guidance on storage. There is very little information relative to how specific items are to be stored or the delineation of storage areas rclativc to the protection each area provides. 3. Procedure ESD"200 requires a segregated storage area for "scrap" material, and Procedure ESO-215 requires separate areas for material with Hold Tags and for Pl and P8 material separation. These proce-dures are adequate.

However, they do not relay much information on how these segregated areas are to be establ ished and raintained segregated.

There'rc no procedures or manufacturers'nstructions for the storage of flow indicators and s'trainers, which ware stored in the Pullman Power Products storage area.; 'andling procedures do not exist; and the only handling instructions are conta.ined in ESO-222 and a number of other procedures, which ron-tain a caution against the use of carbon steel in hand)ing stainless steal. Procedure ESD-239 has excellent detail as to thc handling of Grinncll Snubbcrs during installation.

However, Procedure ESD-259 was issued January 27, 1977; and thcrc is no assurance that materials, part and components were properly handled during thc period prior to 'January 27, 1 77, when rc.t of hc insta llaticn activi ics were occurring.

I I I e 6." The present storage areas were found to be in excel lent condition, h areas clearly defined, materials supported on adequate

dunnage, and openings capped.

7. Procedures KFP-19, KFPS-17, and'ESD"222 provide for an adequate storage surveillance program. Prior to October 3 1,

1973, the sur" velllance was performed using a checksheet tha contained the stor" age requirem nts; after October '31, 1973, the checksheet was changed so that the storage requirements were not listed.

While the sur-velllance program appears

adequate, the checksheet used after October 31,

1973, does not appear adequate.

~ C 'E "33- (0 Criterion XlV.'nspection, Test, and Oneratin, Status ~ ~ \\ The major mechanism that exhibits the status of the work is the Field Process Sheet. The Field Process Sheet provides for perfor" mance status of some important fabrication steps and for inspection status.

However, many important fabrication steps are not indicated by the Field Process Sheet:

erection steps; cleaning prior to in-stallation of insulation; and some critical welding steps as pre"

heating, checking gas flows, and checking for 02 content in the backing gas.

The Field Process

Sheet, as a mechanism to exhibit

status, is considered inadequate.

The inadequacy of the Field Proc-ess Sheet is considered a major weakness in the Pullman Power Produc s systems I 2. The Hold Tag mechanism described in Procedure ESD-240 is an accept-able method of exhibiting status when a defective or discrepant condition is noted. ~ ~ , 54 ~ '4 3. The method of using the Field Process

Sheet, the Hold Tag, and the Discrepancy Report is an acceptable mechanism to track the status of a discrepant condition and the Final disposition of that condi-tion.

However, the mechanism is not always utilized.

o DHR-604, dated February 14, 1973, for isometric package 1-03-1 required rework and reinspection of 14 Class B welds. There are. no Field Process Sheets or inspection Reports to demonstrate that the work had been performed. Vy ~ ' ~ ~ ~ The Field Process Sheet for FM-347 states that the weld was cut ~ out in accordance with a specified DR. The referenced DR is not applicable to cutting out FM-347. e 4. The method of 1ndicating repair welds, as described in Procedures ESD-203 and "204, and the notation of repair welding on the Field Process Sheet are acceptable for showing repair status.

However, FV-83 {Isometric Package 1-10-9) and FW-348 {isometric Package 04-500-34

c I j I ) ~ 'O' \\I-Hr vr 4 ~'

• re II M rrvr vs Irv

'. 139) were not stamped "R" to indicate repair. Procedures KFP-8 and ESD-239 do present some information relative to the release of the systems-for hydrostatic testing. Procedure ESD-229 does contain a method of indicating'ydrostatic test status. These mechanisms are acceptable. Procedure ESD-229 should reference Procedure ESD-239 and require that the release be confirmed prior to initiation of the testing. ~, ~ j ~ ~ V 6. Paragraph-8.12 of Procedure KFP"8 requires that the Field Process Sheet be maintained in the area where the line is being installed. This requirement has been interpreted as having the Field Process Sheet.in the area inspectors'tation and not as being available to the foremen and the people perf'orming the work while the work 1s in progress. This practice causes the Field Process Sheet to become an inspection sign-off record, rather than a traveler that presents necessary information to all 1ndividuals involved in the performance of the work. ~ ~ r Paragraph 7.2 of Procedure KFPS-7 requires that the foreman or pipe-fitter procure.a'drawing and Process Sheet prior to star ing work and check off operations as completed. There was no evidence that this practice (which is in, conflict with KFP"8) is observed. ~ ~ ,.INC- ~ ~ . ~ I ~ A ~ V ~ " 35- ~ ~ r ( Crl terion XV. Nonconforming Haterial s

Parts, or Components l.

Procedures KFP-10, KFPS-CI, and ESD-240 describe a'n adequate system of ldent ify i ng noncon formances. 2, Procedure ESD"290 does not adequately describe the actual process by which Nonconformance and Discrepancy Reports are processed. 3. The Pullman Power Products/Pacific Gas and Electric Company inter-face relative to Discrepancy Reports is not described. Procedure ESD-240 does contain adequate.information relative to disposition and close-out (use of logs) for Nonconformance and Discrepancy Reports. Wk'4 ~ 1J 2 5 Systems that circumvent the nonconformance system have been estab-lished. Use of Note-.O-Grams and Rejection Notices to denote dis-crepancies usually precl.udes their pick-up on a subsequent NR or DR. The useof these alternate systems removes the controls and reviews that have been integrated Into the NR and DR system and also pre-vents information relative to the number and types of problems from being Identified. These alternate systems are unacceptable. t' g "( " Iilc ~ ' Oa

r. '

~ ~ ~.. r ~ ~ II If 0 ~ ~ Qfg V~ Criterion XVI. Corrective Action 1. Procedures KFP-10, KFPS-9, and system. The corrective action ESD-240 describe a corrective action system is inadequate in that it does not require: o Categorlz~tion of reported discrepancies to permit evaluation and tracking. o Documentation of ail discrepancies. e inclusion of documented discrepancies in the MR and DR system, I e., discrepancies reported In Mote-0-Grams are not subsequently xritten as a NR or DR. o Tracking of discrepancies to determine xhich discrepancies are recurring. ~ Analysis of'discrepancies to determine programmatic problems. 2e 3 0 ~ Reporting of significant conditions adverse to quality and the corrective actions taken to appropriate levels of management. ~ I ~ ~ ~ 0 ~ Sased on the results of this audit and the problems encountered in .the past, it appears that a corrective action system has not been ~ I~ ~ ~ ".operative. ~ ~ 1

There is no procedure for reporting 50.55(e) deficiencies.

~ W ~ \\ ~ .el C ~ ~ ~ ~ ~ ~ 37 ~ ~ ~ ~ ~ 'I gi Criterion XVII. Qua it Assurance Records 1. Procedures KFP-16 and KFPS"14 and most of the ESD procecures adequately identify the records to be retained. 2. Procedures KFP-14 and KFPS-12 provide adequate guidance and mechanisms to assure collection of most records. Records that are-not specified In these two procedures (e.g., records on heat treatment,

torquing, pipe rupture restraints) do not have any documented mechanisms for collection, but are adequately assembled and retained.

3. There are no procedures for filing, storing, and protecting records, I.e., no requirements for the vault, no method on how records other than isometric packages are identified, no Instructions on how records are to be stored.

However, the practices employed do provide for adequate Identification, retrieval, and fire protection.

t, g, ~ r Procedure ESD-212 does adequately describe a security. system tha provides "out" cards for iderrtification of the record and the indi-vidual using the record and for the overall security of the records within the vault. ~ L 0 ~ 8 4 '~ V1 ~'ll . ~ '8 ~ I ~ ~ ~ 4 J ~ ~ j.<< ) (,3 K ( <<v <<4 W <<<<~ <<<<<<v(4M,hA t. \\ 1 <<Q<<4 ~ (4<<<<<<<<<<i <<e Tll ~ V. EXIT INTERVIBl The exit interview was conducted on September 20, 1977, at the Pullman Power Products offices at Diablo Canyon. In attendance at the exit ~ 'nterview were: Jack Bowes Pu1lman Power Products Vice President, Production Ed Gerwin John Ryan Pul lman Power Products Pullman Power Products General Hanager Quality Assurance Resident Construction Hanager Pete Runyan Pullman Power Products Field Quality Assur" ance Hanager Chris Scannel 1 Al Eck Pul lman Power Products Pul lman Power Products Chief Field Engineer Quality Engineer, Central Staf John Hitchell Pullman Power Products Consultan't Sherman Naymark Nuclear Services Corporation President t, Jack Meber Nuclear Services Corporation Audi,t Team Leader ~ >r c. I.- a: Bill Rowe . Nuclear Servi ces Corporat ion Auditor Gerry Larsen Nuclear Services Corporation, Auditor ~ ~ ~ +' The exit interview was initiated.by Hr. Meber's s~arizing of the purpose and scope oF the audit, the basis against which the Pullr an Power Products effort was measured, and the purpose of the exit intervie~. Additionally, a discussion was held on the fundamentals of auditing, i.e., an audit is a sampling technique, that enough samples are taken from each program or system to draw a conclusion, and that the conclusion is then applied to the adequacy of that program or system. Each audit finding was presented,. and discussions were held to clarify or refute the findings. Some findings were modified, based on additional evidence presented by Pullman Power Products..Upon completion of thc ~ I e I presentat'ion of the audit findings, an overal l sundry of the findings was presented. ~ 0 ~ ~ ~ ~ ~ ~ ~ r \\ + ~ t +r ( ~ ~ C ~ ~ ~ o ~ ~ ~ ~ 4 ~ ~ ~ ~ 4 ~ ~ Y1.

SUMMARY

~ +

The Pullman Power Products Diablo Canyon effort has extended from 1971 to the present.

The findings indicate that there were three distinc.

periods as related to the quality of the work.

These findings are:

~ Prior to early 1974, there is 1'ittle evidence available to verify the adequacy of the work per!ormed.'he available evidence indicates that only a rudimentary quality control. program existed and that con-.

trol over the produc"ion organization was minimal.

o Fiom early 1974 to late

1974, there is evidence available to verify the adequacy of the work performed.

The available evidence indicates that control was achieved of the materials control program and the

~ welding. control program.

~ From late 1974 to the present, an increasing amount of documentation and records has been generated to ver.ify the adequacy of the work performed.

The available evidence demonstrates that an increasingly more stringent quality program has been placed into effect and in-creasingly greater control of the work effort has been achieved.

However, the present program and contro'ls still do not meet 10 CFR 50, Appendix B requirements in those areas as delineated in Section IV of

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