ML19329E629

Responds to Interrogatories.Discusses Definition of Compliance W/Qa Regulations. Exhibits 1-14 & Certificate of Svc Encl

ML19329E629
Person / Time
Site:	Midland
Issue date:	05/21/1974
From:	Ferriss W, Gibbons W, Krout M BECHTEL GROUP, INC.
To:	Saginaw Intervenor
References
NUDOCS 8006160410
Download: ML19329E629 (104)

Text

36-389'S 4 UIIITED STATES OF AMERICA' ATOMIC EIIERGY COMMISSICII In the Matter of )

) Construction Permit COIISUIERS POWER COMPAllY ) Ilos. 81 and 82 (11IDLAND PLAUT, Units 1 & 2 )

ANSVERS OF BECHTEL PC'4ER CORPORATIOII

_AI!D BECHTtL ASSOCIATES PROFESSIOI!AL CORPORATIOII ("EECHTEL") TO SAGIIIAW IUTERROGATORIES Bechtel =akes the following ansvers to the Saginav Interrogatories served upon Bechtel.

It is to be noted that persons who have knowledge of the facts are numerous and thus the names of a representative number of persons are supplied in the interest of expediting the furnishing of these ansvers.

Similarly, the names of those preparing the interrogatory ansvers include only those who did so to a substantial extent, and excludes those with minimal participation, clericals, etc.

Interrogatory 1: Define the words " compliance with quality assurance regulations" as those words are employed and as you understand them in the Commission's Show Cause order in this proceeding. ,

Ansver: As used in the context of the Order to Show Cause, Bechtel's understanding of the words, " compliance with quality assurance regulations",

is the implementation of Bechtel's and Consumers' accepted quality assurance programs in accordance with the requirements of 10 CFR Part 50, Appendix B, including the establishment of necessary quality related procedures, the preparation and retention of documentation evidencing the implementation of the procedures, audits, follov-up of audit reports and management commit-ment to the quality program.

THIS DOCUMENT CONTAINS P00R QUAUTY PAGES 800616o fp

i Identification of representative. persons having knowledge of facts contained in this Answer or. participating substantially in the preparation of it:

1 S. A. Bernsen 27987 Via Ventana Los Alton Hills, California 94022 l

< W. S. Gibbons, Jr. 189 Varvich Avenue Sar ~ eandro, California 9h577 W. E. Ferriss 2762 S. State l.

Ann Arbor, Michigan h8104 J. I. Dotson' Tecumseh, Michigan 4810h D. R. Johnson 53 Wildvood Avenue

Piedmont, California 94610

i. M. M. Krout 1225 Astor Drive

Ann Arbor, Michigan h810h i

4 P. A. Martinez 32hh Bluett Ann Arbor, Michigan h8105 1

L. M. Scoville 1600 First Federal Building i Detroit, Michigan h8226 Interrogatorv 7: Identify in connection with each of Consuners Power Company facilities as set forth in the definitional section each docunent ever received or reviewed, each meeting you have had (include dates and names of attendees) and each physical structure you have reviewed in connection with your analysis of first compliance with quality assurance l regulations and second reasonable assurance of continuation with' compliance with quality assurance regulations.

Answer: Bechtel's overall quality assurance-program includes quality related activities performed by each of the following groups or departments: Quality Assurance; Quality Control; Engineering; Procurement Incpection; Materials, Fabrication and Quality Control Services; and Construction. As indicated in i

Bechtel's Objections to the Saginaw Interrogatories, each of these groups i

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or departments generates a large volume of documents during the course of the implementation and per formance of its quality requirements. The total of these documents is : ated to be in excess of one million pieces of paper.

' A number of Bechtel emp oyees, and Bechtel's counsel, have been reviewing these documents during the last three months in order to identify and collect the relevant documents. As indicated in Bechtel's Objections to Saginav's Request for an Extension of Time Regarding Motion for Production of Documents, the majority, if not all, of the documents for which identification is sought in Saginav's Interrogatories vill be promptly availabJe for inspection and copying and Bechtel vill make them available in lieu of listing each of them.

Additionally, in its Answer to Interrogatory 16, Bechtel identifies its various categories of quality related documents. The review of Bechtel's documents has been a monumental task. Accordingly, it is possible that some relevant documents vill, by inadvertence, not be offered for inspection, although Bechtel has made and continues to make a good faith effort to produce all relevant documents for which Saginav requested identification.

Using the term " meeting" in its broadest sense, there have been hundreds and probably thousands of meetings or conversations between two or more persons concerning substantially all quality assurance / quality control I

matters pertaining to the Midland Project. It is impossible to identify l each such meeting. Minutes of such meetings, to the extent they were prepared, vill be nade available for inspection and copying together with the documents referred to above, and generally include the names of attendees. Meetings or conversations for which minutes may or may not have been prepared include:

s

.some of the reports referred to in the Answer to Interrogatory 12(c); audit planning and audit exit intervieva; evaluations of vendors and subcontractors' QA Programs; items referred to in the QA Daily Log; management visits to th2 site; discussions with various AEC and client representatives; construc-tion, procurement and engineering procedures; quality assurance trends; i

quality assurance and quality control organization; cadwelding; resumption of construction after demobilization; ALAE-106 procedures; and the implemen-tation activities of each of Bechtel's groups having quality responsibilities which are discussed in the Answer to Interrogatory 10(i).

Bechtel interprets the term " physical structure" to include the structures, systems and components which prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public, upon which design or construction activities have begun.

A list of such structures is attached as Exhibit 7-1.

Identification of representative persons having knowledge of the facts contained in this Answer or participating substantially in the prepara-tion of it:

l M. M. Krout 1225 Astor Drive l Ann Arbor, Michigan 48104 l J. L. Hurley 2681 Hawks Avenue l

Ann Arbor, Michigan h810h l L. M. Scoville 1600 First Federal Building Detroit, Michigan 48226 Persons identified in meeting minutes 4

. 4-f .

- , -, - _ ,w. - -- . . . - - , - . - - - ,n- -

Interrogatorv 9: Define the words " reasonable assurance" as those words are used, and as you understand them in the Show Cause order in this proceeding. '

Answer: Bechtel's understanding of the term " reasonable assurance" is that under all of the human circu= stances and conditions involved in the design, procurement and construction of a nuclear power plant, a reasonable person, aware of applicable requirements and implementing programs and knowledgeable of nuclear design, procurement and construction vould believe that it was probable that the various elements of the overall quality assurance program vill be implemented as required by 10 CFR Part 50, Appendix B. See Answer to Interrogatory 1 for Identification of Persons.

Interrogatory 10(a): With reference to your " Petition to Intervene" filed in this proceeding state:

(a) Define and list in as much detail as possible the " broad experience" which you allege in paragraph 1; Answer: Bechtel entered the nuclear power industry over two decades ago and has participated in the engineering design and/or construction of many major nuclear plants in the United States and abroad. To date, more than a dozen units, on which Bechtel has had such involvement, have been licensed for operation. Nuclear News, a publication of the American Nuclear Society, in its " Buyers Guide Seventy-Four" Issue (mid-February,197h/Vol.17/no. 3) published a vorldwide list of the commercial nuclear power plants that were

operable, under construction, or on order (30 MWe and over) as of December 31, 1973 Bechtel is identified in this list as the architect engineer and/or constructor for 63 plants in four different countries.

i

Bechtel has experience with nearly all types of reactor design and pcVer concepts, working with major vorldwide suppliers of nuclear steam supply systems and turbine generators. This involvement has included the following nuclear systems: pressurized water reactor; boiling water reactor; sodium cooled reactor; sodium graphite reactor; liquid metal fast breeder reactor; high te=perature gas cooled reactor; pressurized heavy water reactor; boiling heavy water reactor; advanced gas cooled reactor; and steam generating heavy water reactor. Bechtel has participated in many projects involving advanced technological, design, and production milestones. Some highlights of this activity are:

Construction services for the world's first rea: tor facility to generate electricity from nuclear fuel.

Engineering, procurement and construction services for the world's first privately financed nuclear power generation facility.

Design and construction of the first large-capacity, privately financed nuclear power plant in the USA.

Comprehensive design and construction services for the first nuclear addition to a conventicnal steam plant.

Engineering, procurement and construction servf ees for the world's first commercial high temperature gas cooled reactor.

Engineering services for the first nuclear power unit with a pressure supp,ression containment.

Engineering, procurement and construction of the nation's first 450 MWe class conmercial power reactor.

Engineering, procurement and construction services for Asia's largest nuclear power plant when dedicated in 1970.

Development and construction of the first fully prestressed, post-tensioned concrete containment vessel.

Desig'n and construction services for the first nuclear power plant with a field fabricated. reactor vessel.

Engineering, procurement and construction management services for the largest fast flux test reactor in the USA.

Identification of representative persons having knowledge of the facts contained in this Answer or participating substantially in the prepara-tion of it:

J. L. Hurley 2681 Hawks Avenue y Ann' Arbor, Michigan h8104 L. M. Scoville 1600 First Federal Building Detroit, Michigan h8226 Interrogatory 10(b): With reference to your " Petition To Intervene" filed in this proceeding state:

(b) Describe in detail (and attach a copy) of the relevant

portions of your contract with Consumers Power Company setting forth your " direct responsiblity" as set forth in paragraph 1; Answer

Article 2 " Scope of Work," in Bechtel's contract with Consumers

Power Company states in pertinent part, "The scope of the work consists of all engineering, procurement and construction work and services required to

- construct and complete a two-unit nuclear power plant (hereinafter sometimes called the ' Midland Plant' or the ' Plant') to be located on Consumers Power's Midland -site near the City of Midland, Michigan."

Identification of representative persons having knowledge of facts contained in'this Answer or participating substantially in the preparation of it:

Not Applicable.

Interrogatory 10(f): With reference to your " Petition To Intervene" filed in this proceeding state:

(f)' Describe in detail each issue adverse to the continuation

. of Construction Permits. Nos. 81 and 82 as you use those terms in paragraph 3 of your petition;

_7_

Answer: Any proper issue within the scope of this proceeding and within the purview of the two issues stated in the Order to Show Cause, which is timely raised by the Atomic Safety and Licensing Board, the Regulatory Staff or the Saginaw Intervenors, and approved as a contested issue by the Atomic Safety and Licensing Board.

Identification of representative persons having knowledge of facts I

contained in this Answer or participating substantially in the preparation of it:

a Not Applicable.

Interrogatory 10(g): With reference to your " Petition To Intervene" filed

. in this proceeding state:

(g) Describe each fact upon which you base (and to which you make reference in) the last two sentences of the first paragraph of paragraph 4 of your petition; i

Answer: See the Order to Show Cause, and attachments thereto, together with the DRO Inspection Reports referred to therein and Bechtel's Answer 4

to Interrogatory 10(b).

Identification of representative persons having knowledge of facts contained in this Answer or F rticipating substantially in the preparation of this Answer:

Not Applicable.

Interrogatory 10(h): With reference to your " Petition To Intervene" filed in this proceeding state:

(h) . Set forth in detail each fact upon which you base the allegations in the second paragraph of paragraph h of your petition; l

. _ _ _ - - _ ,, - - , ~

Answer: 1. On March 26, 1973, the Atomic Safety and Licensing Appeal Board (hereinafter the " Appeal Board") entered its " Memorandum and Order" designated "ALAB-106", stating in Paragraph III:

". .. .We have found nothing which would cause us to overturn the Licensing Board's findings as to the consistency of the QA Program with the requirements of Appendix B. We have reviewed the QA Manuals for both the Applicant and its architect-engineer. Both of these manuals, as presently revised, appear to present a satisfactory overall program to meet the quality assurance criteria of Appendix B." (RAI-73-3 at 184 ).

2. Despite the Appeal Board's conclusion in ALAB-106 that the Licensee and its architect-engineer had satisfactory QA Programs, the Appeal ,

Board in affirming the issuance of the permits, modified the ASLB decision by imposing four conditions on the Licensee.

3 The Appeal Board expressly indicated that it imposed the four Conditions of ALAB-106 upon the Licensee, net as a " punitive" measure, but to re=edy any problem remaining due 'to lhs long shut-down in construction and to assure the quality of future construction [RAI-73-9 at p. 637 ( ALAB-lhT)).

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h. The principal problem to which the Appeal Board referred in

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ALAB-106 involved certain alleged nonconformancies in concrete work discovered during inspections by the DRO on September 29-October 1,1970. The Order to Show Cause states that these inspections " revealed several instances of Licensee's nonconformance with quality assurance program requirements involving concrete work" (Order to Shev Cause, p. 2). However, the "Urder to Show Cause" improperly relies upon these alleged nonconformances and ignored the recolution of the=.

1 The results of the inspection and resolution of all deficiencies are documented as follows:

(a) Alleged nonconformances as reported in CO Peport No. 329 and 330/70-6 (pp.1-2):

"1. Observation of concrete placement activities at the construction site revealed:

a. The use of vibrator to move concrete.

b. A lack of sufficient vibration penetration.

c. An absence of vibration action at recommended intervals.

The above items are in disagreement with ACI-301, Paragraph 803.d (II-A-1.a).

"2. The site testing laboratory was not taking aggregate gradation and organic tests at the frequencies stated in PSAR (II-A-1.a).

"3 The concrete sample obtained for the slump test at the point of transit truck discharge was not taken in accordance with the sampling instructions in ASTM-C-172 which require a representative sample (II-A-9.a).

"h. The QA and QC inspection personnel present at the concrete pour location did not pronptly identify and correct apparent deviations from the ACI-301 Standard regarding consolidation of concrete (II-A-9.b)."

(b) Subsequent to the issuance of C0 Report No. 329 and 330/70-6, the DRO noted the following in C0 Report No. 329 and 330/71-1:

"1. According to Messrs. N. Paige and B. Peck, corrective action by the applicant to improve the use of vibrators has been taken. Bechtel established a special crew of craft personnel to do the vibrator work. This crew has been trained in the proper use of vibrators.

"2. Regarding the taking of aggregate gradation and organic tests in accordance with the PSAR, Mr. Peck said that Consu=ers Power has reviewed the frequency of aggregate testing and, where necessary, more frequent tests will be made to comply with the PSAR.

"3 Mr. Peck stated that they have been taking concrete samples for slump in accordance with ASTM-C-172-Sh (Revised 1958) which requires only a single sample of concrete from stationary mixers. ASTM-C-172-68, which is a later edition, requires samples at two intervals during discharge of the middle portion of the batch. This difference in requirements has been brought to the attention of the applicant br telephone and will receive follow-up attention at the time concrete work resumes.

"h. Regarding the lack of prompt attention on the part of QC inspection staff to identify and correct apparent deviations, the applicant, (according to Peck) has requested that Bechtel upgrade the QC inspectipn force in the area of concrete placement. In this regard, Peck reported that Bechtel and Consumers Power (CP) have conducted reviews of the ACI-301 standard. Additionally, special inspector training sessions have been conducted for the site inspection force and Bechtel has assigned a full-time engineer to inspect all Q-list pours." (pp. 2-3)

No "Other Significant 1 tens" were noted in that Report. The Report .ilso indicates that the dates of the previous construction inspection vere September 29 and 30, 1970 and October 1, 1970, i.e., the dates referred I

to in C0 Report No. 329 and 339/70-6. Thus, it is evident that corrective 1 action was taken in a manner satisfactory to the DRO. However, C0 Report l No. 329 and 330/71-1 further indicates that all construction was shut down prior to that inspection. The shutdown occurred as a result of certain delays in obtaining Construction Permits and continued until the Appeal Board affirmed the ASLB's granting of the Construction Permit in 1973 Up on resumption.of construction, further corrective action was taken to prevent repetition of the four nonconformancies itemized in C0 Report No. 329 and 330/70-6, as follows:

Items #1 & #4 - An intensive indoctrination and train'.ng program was implemented for personnel involved in placing.and inspection of

1 concrete work. This program was developed and presented by San Francisco Bechtel Home Office Quality Control, the Project Field Engineer and the Project Field Quality Control Engineer, and contained, among other things , detailed instruc-tions in-the proper use of vibrators. Detailed inspection plans were developed and implemented. Explicit instructions were given by the Project Quality Assurance Engineer to quality assurance personnel to prenptly identify, and to take necessary actions to correct any discrepancies noted during concrete operations.

Item #2 - Pursuant to Field Inspection Manual G-1, (Rev. 8),

(July 16, 1973), Bechtel assi6ned a Quality Control representative to full time monitoring of test lab activities. Project Special Provisions Notice SF/ PSP #2, Rev. O, 7220, established additional requirements for indoctrination and training of Quality Control personnel at the Midland jobsite. (On December 28, 1973, General Technical Hotice #4 (SF/GT #4) was issued. SF/GT #4 supersedes SF/ PSP #2 and establishes a comprehensive program for the inioctrination, training and certification of quality control personnel. ) In addition, the requirements for frequencies of aggregate gradation and organic testing were reemphasized to quality assurance and quality control personnel.

Item #3 - Upon project reactivation, the Bechtel specifi-cation governing testing of concrete, Specification 7220-C-8, was superseded by -Specification 7220-C-208. The requirements and standards contained in  !

7220-C-208 vere updated to the latest revisions of the industry codes and standards which in the area of concrete sampling was the 1971 revision i of ASTM-C-172. That standard requires sampling of fresh concrete "at two l l

or in regularly specified intervals during discharge of the middle portions '

12 l

1

of the batch". In lieu of the previously assigned field engineer, Bechtel now has assigned a quality control representative to falliime functional technical direction of test lab activities. Prior to this proper instructions I

and directions to the field engineer in charge of the test lab resulted in correct sampling techniques as noted in RO Report No. 329 and 330/73-07 (c) Further, in " Applicant's Report on Quality Assurance Action Being Undertaken to Assure Satisfactory Condition of Work Already Per-formed and Materials Now on Site", May 25, 1973, filed with the Appeal Roard

- and the .DRO pursuant to ALA3-106, the Licensee submitted procedures for inspection, evaluation and remedial action to be undertaken in preparation for resumption of construction after shutdown and su=marized the results of.the intial inspections under these procedures. Subsequent reports were also filed with the Appeal Board and the parties stating in detail the infor-mation required.

(d) Subsequent to the reactivation of concrete placement activities, an unannounced audit was performed, on September 5-7, 1973, at the Midland site (R0 Report No. 329 and 330/73-07). The principal inspector, R. A.

Rohrbacher, made .the following findings:

(1) With reference to the prior problem of C0 Report No. 329 and 330/70-6 (September 29-October 1,1970) regarding the alleged improper use of vibrators during concrete placement:

"During this inspection, activities associated with the use of vibrators during concrete placement were .

observed. Through discussions with site personnel, review of records, and observation of concrete placement activities in progress, it was determined that the use of vibrators during concrete placement met applicable requirements ( ACI-301). This matter is considered resolved. However, periodic inspection of concrete activities, including use of vibrators, are to be made during subsequent inspections." (R0 Report No. 329 and 330/73-07 [Septe=ber 5-7,1973]

p. 2)

(2) Relat..e to concrete production and placement:

"The Unit 2 tendon gallery outer vall placement area was inspected prior to concrete placement. It was observed that the for=vork was solid, clean, tight, and adequately braced. The rebar was free from loose rust, properly spaced, and adequately held in place. Adequate transporting and handling equipment, vibrators, and crev vere on hand prior to placement. Adequate personnel, as well as sampling and test equipment, were available at the placement site, and Bechtel QA, QC, and field engineers were present to observe and inspect operations in progress.

"Through observation of QA and QC activities at the time of concrete placement and from discussion with the QA and QC engineers present, it was deter-mined that these engineers were qualified to monitor and audit concrete activities. A representative of CP stated that CP had reemphasized the need for adequate engineering surveillance and QC coverage by Bechtel during placement of all Class I pours.

"It was observed that concrete handling and vibrator usage were in accordance with applicable requirements.

Two vibrator crews were observed at four areas of the pour during placement. Through discussions with site personnel and review of records, it was verified that instruction in the use of vibrators took place on August 27, 1973 Demonstration and practice included use of vibrators in fresh concrete.

About 27 attende'd this Bechtel training session, including ten laborers , three foremen', and fourteen engineers (field, QA, and QC).

"During placement, it was observed that truck transit tickets were received and reviewed upon truck arrival and that sampling and testing was done properly and the results recorded. The inspector observed that the first load of concrete received for this pour was rejected at the placement location, due to improper slump. Methods used to take slump and air entrainment measurements met applicable requirements. It was observed that sampling and testing frequency was more frequent than required at the placement location and that samples were taken in a manner to obtain representative samples. A Bechtel QA engineer, among other engineers, was at the pour location verifying that sampling and testing requirements were met.

The inspector did not identify any deviations frca applicable requirements during observation of concrete placement activities.

"During observation of batch plant operations, it was noted that the required mix was being batched and that sampling and testing met applicable requirements." (R0 Report Ho. 329 and 330/73-07

[Septe=ber 5-7, 1973], pp. 10-11).

(3) With reference to the alleged failure in 1970 to take aggregate gradation and organic tests of sand in accordance with applicable requirements:

" Discussions with site personnel during the current inspection, review of records, and observations of batch plant operation provided information to estab-lish that the required frequency of the subject testing was maintained. However, this matter remains open pending further re'c ord review and observations during further concrete production." (R0 Report Ho.

329.and 330/73-07 [ September 5-7, 1973], p. 3).

(h) With reference to the failure to take slump tests in accordance with sampling instructions, and the failure of inspectors to pro =ptly identify apparent deviations from the ACI-301 Standard regarding consolidation

of concrete, R0 Report Ho. 329 and 330/70-6, see the comments of the principal l

inspector quoted at subparagraph (2) hereof.

5 The Order to Show Cause referred to violations of 10 CFR Part 50, Appendix B, Criteria II and V, involving design engineering inspections on September 10 and 11, 1973, and the DRO's discussion of its findings on ceptember 27, 1973. The Order.to Show Cause states:

" Inspections conducted on September 10, 11, and 27, 1973, revealed several additional violations of 10 CFR Part 50, Appendix B, Criteria II and V, involving inadequate record keeping procedures relating to quality assurance and unavailability of certain quality assurance records".

(Order to Show Cause, p. 2).

An examination of the specific findings of this Report (R0 Report No. 329 and 330/73-08) and the responses of the Licensee discloses:

(a) The DRO report of its inspection of project engineering states:

"[T]he Bechtel Corporation Nuclear Quality Assurance Manual does not include a requirement for retention of records common to activities affecting quality.

Furthermore, other quality assurance program documen-tation dealing with record retention requirements was unavailable during the course of the inspection."

(R0 Report No. 329 and 330/73-08, p. 2)

It should first be noted that Bechtel's QA group had previously identified this matter and initiated corrective action.

The fundamental document for ~Bechtel's Quality Assurance Program is Eechtel's Nuclear Quality Assurance Manual (NQAM). Criteria II and XVII of 10 CFR Part 50, Appendix B require that record retention require-ments be established but do not specify where record retention requirements are to be found. At the time of the inspection referenced in the aforesaid report, the NQM4 did not incorporate ' record retention requirements. The following 16-

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-m.. .

Bechtel standards and procedures then in existence did provide certain record retention requirements for project engineering:

1. Bechtel Engineering Standards , Volume G. " General".

2. Bechtel Internal Procedures Manual Midland Units 1 & 2.

Moreover, the actual records affecting quality which are required to be main-tained pursuant to Criteria II and XVII, have been maintained and are available.

Therefore, the deficiency was merely in not having sufficiently specific written procedures for record retention available, not in the non-existence of the records .

However, it was the position of the DRO report that record retention requirements for activities affecting quality should either be con-tained in the NQAM, or incorporated by reference thereto, since the UQAM is Bechtel's fundamental document relative to quality assurance.

-In an inter-office memorandum from the Manager of Engineering, dated November 2, 1973, project personnel were directed to comply with the requirenents contained in the Corporate Record Retention Schedule, dated October 30, 1973 Additional controlled copies of Bechtel Engineering Standards, Volume G, were requested for project personnel and the applicable requirements therein vere simultaneously emphasised to project supervisory personnel.

i As an interim measure, to comply with the DRO position, a project ' amendment to' the NQAM vhich specifically incorporated record retention I requirements for Engineering was issued on December 17, 1973 e

During its inspection of January 10 and 11,1974, DRO reviewed the commitments made by the Licensee to incorporate record retention requirements. In RO Inspection Report No. 329 and 330/74-01, DRO stated:

"A review of records and discussion with the Licensee's representative established that substantive progress had been made in that the proposed revision of the hQAM has been issued for review and comment. . . .

"A review of records and discussion with the Licensee established that an interim procedure for controlling records, common to activities affecting quality, was issued by December 17, 1973 Based on a review of these procedures, associated instructions, and the Bechtel Internal Procedures Manual, it is apparent that proper implementation of the interim procedure vill assure that all such records vill be controlled and retained in a manner consistent with 10 CFR Part 50, Appendix B, Criteria II and XVII requirements."

(pp. 7-8)

Finally, Bechtel's UQAM was amended February 11, 1974, l

i to specifically incorporate requirements for retention of records common to activities affecting quality for all project records.

1 .

(b) R0 Report No. 329 and 330/73-08 alleges with respect to project engineering, that, contrary to the requirements of 10 CFR Part 50, 4

Appendix B, Criterion V, Bechtel's Internal Procedure Manual for Midland Units No.1 and 2, Section 7 5, which requires that the current revision of each drawing be maintained in the stick files, was not being implemented because some stick files were not current. The DRO Report acknowledged that Bechtel QA had previously noted this matter and prescribed corrective action.

On September 18, 1973, measures were taken by Quality Engineering to review all project engineering stick files. All stick files have been updated in accordance with the Midland Drawing Control Log.

', As a further corrective measure, Section 7 5 of the Midland Internal Procedures Manual was revised to read in part: "It is the responsibility of each group to update and maintain its own stick file".

The Project Engineer directed that all supervisory personnel require that this procedure be performed on a regular basis.

4 Finally, the Project Quality Engineer and his staff have been and are performing a monthly surveillance of the project record print file and the discipline sti$k files to assure adherence to the latest Midland Drawing Control Register.

In RO Inspection Report 329 and 330/74-01 the Region III inspector stated:

"A review of records (procedures and instructions) and discussion with the Licensee's representatives confirmed that all of the above commitments were presently in force at the . . . Ann Arbor Engineering Office, and were being properly implemented." (pp. 8-9)

(c) R0 Report No. 329 and 330/73-08 alleged, with respect to Project Engineering, that contrary to Criterion V,10 CFR Part 50, Appendix B, which states, in relevant pr.-t:

" Activities affecting quality shall be prescribed by documented instruction =, procedures, or drawings of a type appropriate to the circumstances. . ."

l the following procedures were not available for review by the inspector at the time of the inspection:

1 1

_1g_ '

(1) Procedures to prescribe control of interface activities between design groups; and (2) Procedures to prescribe control, issuance, and changes to the Bechtel Corporation Internal Procedures Manual

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for Midland Units No.1 and No. 2.

The Report acknowledged that Bechtel QA had previously noted and prescribed corrective action in regard to all of these deficiencies (pp. 10-13). In response to the allegations, a review has indicated:

Item 1. Requirements regarding design office interface activities are now provided in the HQAM,Section II, Procedure No. 9 At the time of the inspection detailed interface requirements for Project Engineering personnel vere contained in the Divisional Engineering Standards (Volume G),

Sections 1 3 and G-200, and in the individual Discipline Eagineering Standards.

The requirements contained in those documents to the extent that they related to interface activities between design discipline groups were. incorporated by reference in Engineering Department Instruction ("EDI") 3 55.1, icsued December 17, 1973 Subsequently, EDI 3 55.1 was superseded by Engineering Department Project Instructions ("EDPI") h.25.1. i Item 2. The Bechtel Internal Procedures Manual for Midland Units 1 & 2, Revision #1 now has control serial nu=bers. Distribution is con-  !

trolled by a formal control lict for assignments of the Manual showing appli-cable serial numbers and assignments of the manual by recipients name. A

-revision block with date and approvals has also been provided. The Internal

Procedures Manual was revised and reissued in accordance with these controls on October 19, 1973 All superseded Manuals have been withdrawn from use.

The Project Quality Engineer and his staff have performed and vill continue J

to perform periodic surveillance and spot checks to insure that only Internal Procedures Manuals with the latest revisions are in use.

With reference to Items 1 and 2 above, the Region III inspector stated in RO Inspection Report 329 and 330/74-01, at p.10:

" Project amendment for Job Ho. 7220 (design inter-face) dated December 17, 1973,Section II, was revie. ed. Dagineering Department Instruction Ho.

3.55.1 (Design Interface Control, Revision 0) was issued on December 17, 1973, and becomes mandator / on February 15,197h. The interin Enendment provides documentation of the current interface control procedures. The Internal Proce-dures Manual, issued to a Bechtel employee, was observed to have a document control number and had been assigned according to procedures. A document showing the assignment of all manuals was reviewed. Docunented evidence showing the distribation and retrieval of all superseded internal procedures manuals was reviewed."

i (d) 10 CFR Part 50, Appendix B, Criterion V, states, in part:

" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures , or drawings."

RO Report No. 329 and 330/73-08 alleged, with respect to Project Engineering, that although "the Bechtel Corporation Nuclear Quality .

Assurance Manual (UQAM),Section III, Procedure No. h, specified the use of Exhibits 3.6A.1, 3.6A.2, and 3.6A.3 for vendor control," Quality Assurance 4

t z- - . - , . . - - _ . , - - - - - - - - ,

Specifications No. 7220 G-20, No. 7220 G-21, and No. 7220 G-22 were being used to accomplish this activity despite the absence of an approved change j to .the NQAM authorizing the use of these specifications. .

Once again, Bechtel Quality Assurance had previously 4

identified this discrepancy and directed that corrective action undertaken. ,

As discussed with the DRO, action to amend the UQAM had been taken by Bechtel prior to the DRO's inspection, approval of the use of Specifications No. 7220-G-20, 21 and 22 had.been granted by Quality Assur.tnce Management and the mechanics for change of the HQAM had been set in motion (R0 Report No. 329 and 330/73-08, p.13). To preclude repetition of the discrepancy, the NQAM was amended on Decenber 15, 1973, to provide Midland Project Engineering with the flexibility to respond to evolving QA requirements via specification changes with proper Quality Assurance approval and without requiring changes to the UQAM.

In RO Inspection Report 050-329 and 330/7h-01, p. 10, the AEC Inspector confirmed that the above corrective action had been completed.

6. With respect to the inspections conducted on November 6-8, 1973, the Order to Show Cause alleges deficiencies associated with Cadweld splicing of concrete reinforcing bars.

A. Specifically, RO Inspection Report 329 and 330/73-10 alleged that the procedures for installation and inspection of splices were inadequate

l because they did not provide adequate instructions for performing Cadweld splicing nor for inspection of completed splices, and becauce instructions and {

procedures were not being implemented to assure that Cadweld preheating require-ments were properly accomplished.

On November 6,1973, the effective specification for Cadweld splices was Bechtel Spec. No. 7220-C-231, Rev. 2. Paragraph 10.0 thereof, l

and all subparagraphs thereto, referred to " Mechanical Splices of Reinforcing Bars". These paragraphs dealt with the entire Cadweld process and referred to such specifications as the qualifications of the splicing crew, the care and handling of splicing kits and equipment, preparation for splicing, and inspection. In addition to this specification, the Bulletin of the manufacturer, ERICO Products, Inc. , was available to each operator. The Bulletin contains 36 pages of detailed instructions, including pictures, to facilitate the completion of a successful splice. The "ERICO Manual" contained referenced ,

inspection criteria. Finally, a QC inspection plan had been prepared and issued for use and a check list was prepared by the field engineers. Therefore, there were instructions and forms for installation and inspection of splices, as required by Criteria V of Appendix B.

On Novecher 9, 1973 Bechtel Spec. No. 7220-C-231 was amended to clarify Para.10.11.5 (relating to the measuring of " voids").

Specifically, the intent of the general formula for measuring voids was clarified and an example of a more precise method for measuring the void area was added. ERICO Products, Inc. , concurred in this revision by letter dated November 21, 1973. .

j I

On December 5,1973, QC Procedure Ilo. C-231-1 (Rev. 6),

i

" Inspection of Cadweld !&chanical Splicing of Concrete Reinforcing Steel" Y

]. was issued for use by inspectors, and "Cadweld Rebar Splicing Instructions for a>

the Operator" was issued as a work procedure for operators.

4 The 'Cadweld operators and inspectors were thoroughly re-trained, qualified and tested regarding the procedures to be utilized prior to resump-i tion of work, as detailed hereinafter. ERICO Bulletin states:

1 1

Generally, the Cadweld Rebar Splice is a mechanical means (not ,

i a, veldment) of butt splicing deformed bars that produces a joint with basically the same mechanical properties as those of an unspliced bar. Two reinforcing bars are joined at the ends within a splice sleeve. After the rebars are I

cleaned and properly located within the sleeve, filler metal is melted in an apparatus adjacent to the splice sleeve. Filler metal flows through a guide tube l t

and invades the space between the reinforcing bars and the internal surface of the splice sleeve, thereby interlocking the bar deformations and the annular I

grooves of the splice sleeve. I The apparatus is then disassembled, the asbestos packing removed, and the splice visually inspected for excessive " void" area, porosity,' centering, blow-out and slag. A void area measurement is used to determine the approximate area, in square inches, of unfilled space at the end of the sleeve following a Cadweld splice. The void area is the area not filled by filler metal after allowance of a '3/16 inch normal void area i

about the bar perimeter which was filled by the asbestos packing.

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. _. .__ ._u__ - _ . , _ . _.-__ ___

ERICO designed the Cadweld sleeve conservatively. It has advised that for the sine of bar in question (#18), splices with six (6) square inches of void area per end have successfully met tensile test standards. Nevertheless, Bechtel has specified that if the void area is equal to or less than 3 square inches for a single end of a splice sleeve, the splice is satisfactory.

B. DRO allegation 1.c. is that inspections of completed splices were being perforned by personnel lacking knowledge of applicable inspection-acceptance criteria and/or by personnel using inspection-acceptance methods, which could lead to the acceptance of finished Cadwelds which did not meet acceptance criteria relative to established Cadweld void limits (R0 Inspec-tion Report No. 329 and 330/73-10, p. 3).

During the Hovember 6-8, 1973, inspection DRO alleged that at least one Cadweld rebar splice had a void measurement exceeding the allowable 3.0 square inches. DRO Inspector determined the area of the void by multiplying the width of the void at its videst point by the depth of the void at its deepest point after allowance of the 3/16 inch void area about the bar perimeter. A review of the matter was it=ediately undertaken.

As a result of the review, it was concluded that the method as interpreted by the DRO, set forth in the ERICO Manual, was quite conservative. It vas decided that a more precise method which more realistically approximated the actual void area ray be c= ployed as the measurement method for such void areas. That method is the " profile Method" and consists of sectionalising the void area to produce a measurement which vill more closely approxinate the

actual void area. Bechtel Specification 7220-C-231, Section 10.11 5, was accordingly revised (Rev. 3, November 9,1973) to reflect this decision.

ERICO agreed that this method was satisfactory. Utilizing this method, on November 10-11, 1973, a co=plete reinspection was made by field engineering of all the completed Cadweld splices in Unit 2. Results indicate that out of the 320 splices rechecked for Containment Unit #2, there were 8 splices preliminarily found to have void areas in excess of the maximum allovable.

Subsequently, a second complete reexamination of all splices was performed by QC personnel using the Profile Method. As a result of this reexamination, which co==enced on November 14, 1973, the QC engineers found that 2 of the 8 splices previously found to be unacceptable by field engineering were acceptable, but added to the remaining six, three additional possible unacceptable splices due to excessive void area. The result was 9 possible unacceptable splices due to excessive void ar as. These 9 void areas were then presented to the field engineering staff for evaluation. The measurements from the field were plotted and a planimeter was utilized to calculate the exact area within the plotted figure. The results of the plani-meter tests indicated that none of the nine splice ends previously believed to have excess void areas, had a void area exceeding the prescribed limit of 3.0 square inches.

Two Cadwelds were rejected for high porosity. These two Cadwelds were cut out and subjected to pull tests to determine their strength. Both rejected Cadwelds exceeded the minimum strength requirements.

. . _ _ _ _ _ . _ . __ _ _ . . .. ._=

1' 1

4 The_ problem concerning void area measurement stemmed from the simplistic example originally used in the specification, the installation 4

procedure, and in the manufacturer's directions. The intent of all methods used in the inspections was to approximate the actual void area. The specifi-cations have been clarified by an example which reiterates the initial for=ula i

used and provides a more precise method which considers both shallow and deep i'

voids by sectionalizing. The planimeter may be used to more precisely approximate 3

the actual void area. While the proper measurement technique was in questicn, i

i it should be emphasized that all interpretations were conservative as verified 1

by .more precise measuring methods used in evaluating the sleeve ends in question.

Although the inspectors had received training prior to the inspec-tion of cadwelding, to assure adequate reinspection of the splices and to inten-sify the training of inspectors, reinstruction and retraining sessions were held on the mornings of November 9 and 13,1973, and the afternoons of november 13 and 19, 1973 The inspector's prior training had included examination of Eechtel Specification 7220-C-231, the ERICO Bulletin, and a prepared field checklist for inspection.

1 C. R0 Report No. 329 and 330/73-10, p.19, states that the requirements of the PSAR and Bechtel Specifications, while establishing Cadwelding qualification requirements, do not specify the conditions which would disqualify a Cadwelder, nor establish the requirements for requalification of disqualified Cadwelders.

In response, paragraph 10.8.2 was added to Specification 7220-C-t 231, on- November 1h,1973, to provide:

, I l

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. - , , - , -- r - - - -,,,,,.r. y ., .-g . , .,-. .-~ ,- ,

"If the tensile test failures accumulated from all splicing crews exceed the rate of one for each 15 consecutive test sanples, or if splices are consis-tently failing to pass visual inspection, or if there is a question of a crew's ability, the splicing work shall be reviewed and evaluated to determine corree-tive action."

It is also provided that if a menber of a splicing crew has not used a specific splice position for a period of three months, that member shall be requalified in accordance witn the provisions of Specification 7220-C-231, 10.8.

D. The DRO found that packing material and slag in one sleeve obscured proper visual examination of the splice (R0 Report 329 and 330/73-10,

p. 10). The presence of asbestos packing does not necessarily mean that an inspection was not undertaken since small amouats of asbestos may " float" between the sleeve and rebar. However, if all packing and slag is not removed, proper inspection is precluded. Therefore, removal of all packing was and is a requirement of inspection.

To preclude recurrence of this item, operators and QC Engineers were reinstructed in the importance of removing packing and slag to allow for proper visual inspection of the filler metal. Additionally, new procedural instructions were issued which require that:

(1) the operator is responsible for removal of the packing; (2) the quality control engineer is responsible for inspection, final acceptance and verification of the quality of the splice.

e E. Another allegation made in the DRO Report was that the procedure for documenting required quality parameters was inadequate with respect to the cleaning of the rebar ends before a splice is co=pleted.

As part of the training program, operators and inspectors are taught to clean the rebar ends. However, documentation of the cleaning of rebar ends was previously not required under QC-CS, the Cadveld inspection and test report form. Instead, an in-process check was used to veriff that cleaning was performed, even though failure to completely clean each rebar end does not necessarily preclude an acceptable Cadweld splice. Cleaning is used to prevent " blowouts" a-d porosity, which would be visible at the completion of the Cadweld and would require that the Cadweld be rejected.

Visual inspection and verification of rebar cleanliness is now a specific requirement of the new "Cadweld Inspection and Test Report", QC Cadweld Form. Column 16 requires the QC Engineer to " visually inspect for evidence of cleanliness to confirm the bar ends were properly cleaned in the splice sleeve" and provides a space to document his acceptance. The new QC Cadweld Form was issued for use on November 29, 1973 On April 2, 1974, this form was revised to require quality control signatures for all activities l

covered thereby.  !

It is noteworthy that the new "Cadweld Inspection and Test Report," used to support the Master Inspection Plan C-231-1 (Cadweld),

is an effort to simplify the reporting and documentation of the various inspections regarding the entire Cadweld splicing procedure. On a single sheet of paper, the QC Engineer can note all proper inspection results regarding the particular splice.

The installation and inspection of cadwelds were the subject of MCAR #2 dated December 11, 1973 As part of the close out of this report Project Engineering analized the deficiencies and concluded that there were no safety implications.

F. The alleged deficiencies regarding inadequate material control stem from two alleged incidents. First, a splicing sleeve was found unwrapped; and, second, miscellaneous materials were discovered atop a box in the storage trailer.

10 CFR Part 50, Appendix B, Criterion XIII does not require a

" procedure" for storage of Cadweld materials, but merely requires that "teasures" be established. Specification C-231, which was in use and available at the time of the November 6-8, 1973 DRO Inspection, instructed that splice kits be i stored in a clean, dry, temperature-controlled area. Accordingly, teasures were in existence and available at that time.

Regarding the unwrapped sleeve, procedures were implemented to more adequately insure proper storage. As a practical matter, all sleeves had been inspected prior to use as specified in QC Procedure C-231, Section 10 9 3, which prevents a dirty, vet or corroded sleeve from being used.

Regarding the materials atop a box, there is no requirement that access to the Cadweld material storage facilities be controlled, although only operators and inspectors were instructed to utilize the area. However, I 1

1 steps have been taken to insure the proper separate storage of all materials j used on the jobsite and to keep other foreign materials away from stored materials.

I

1 G. On November 9,1973, a nonconformance Report with respect to the Cadwelding problem was issued by Consumers. This NCR required the stoppage of all Cadvelding and concrete pours involving Cadwelds until the list of problem areas were resolved. Ho such concrete work was scheduled until February 1,197h, so that there vould have been no problem in examining i

all Cadvelds in Unit 2 and correcting any deficiencies even if neither stop i

order had been issued. Subsequently, as set forth hereinabove, each of the

, problem areas listed in the UCR was resolved and Consumers lifted its stop work order on Decedber 6,1973 In this connection, it is important to note that Bechtel's Quality Assurance Engineer identified a problem with Cadvelding inspection prior to the Novedber 6-8, 1973, inspection. The matter was not determined to be serious at the time because of the long time available for reinspection before concrete pours were scheduled to begin.

I H. All alleged " violations" have been resolved by the Licensee and its engineer-constructor in a manner acceptable to the DRO. It was stated I

in RO Inspection Report 339 and 330/7h-03, at p. 2, that:

"It has been determined that appropriate corrective action has been taken by the Licensee to apparent violations identified in R0 Inspection Reports No. 050-329/73-08 and No. 050-330/73-08, no. 050-329/73-10 and no. 050-330/73-10, no. 050-329/74-01 and no. 050-330/74-01."

lui examination of the DRO Reports clearly shows the corrective 4

i i

activity taken on the ite=s identified by DRO and the committment to proper i

implementation of quality assurance requirements. The engineering and 1

5.

- - . . . . -. . . . = _ .

constructing of nuclear power plants requires the efforts of hundreds, if not thousands, of people, each of whom brings to the job a different skill, background and personality. Laborers, craftsmen, engineers, managers, specialists, clericals, i draftsmen and all of the other skilled groups of people necessary to perform the required work are brought together as an ever changing team depending upon the vork requirements at any given time.

l It would be unrealistic to approach an examination of the effectiveness of a quality assurance program, without an initial uhderstanding of the' fact that such people and the new relationships and interrelationships created between them gives rise to errors and conflicts.

4 Bechtel has recognised this fact for many years. Through education and training programs Bechtel has tried to keep such problems to a minimum. In addition, Bechtel has exerted ever increasing efforts to promulgate systems, procedures and programs as part of its quality assurance program, which, in turn, is designed to minimise adverse consequences of a human failure. i Rather than being insensitive to quality assurance requirements, Bechtel has been in the forefront of the development and implementation of quality requirements such as ANSI Hb5.2, as evidenced by Bechtel personnel j participating as members and chairmen of cammittees for ASME, ASTM and ANSI i 1

codes and standards development with full support and encouragement from 1 l

Bechtel management. '

1 In this connection, it is to be again emphasised that inter-pretation of nuclear quality requirements are ever changing and continually ,

_- = . - - , - - ._ -_

evolving. Such evolution has not stopped with the promulgation of Appendix B to 10 CFR Part 50. That document, not unlike the Constitution, is extremely broad and is susceptible to new interpretations as new situations and new technology'are encountered. Thus, proper implementation of Quality Assurance is extremely important and the subject of continued upgrading and development by both the Licensee and its engineer-constructor.

Bechtel has viable Quality Assurance and Quality Control 3

organizations which are continually acting to create new procedures, techniques and for=a to satisfy the evolving interpretations of the requirements of 10 i

CFR Part 50, Appendix B. While human error cannot always be prevented, the QA and QC organizations have at all times attempted to identify all possible sources of error, whether intentional, random or systematic. The DRO allega-tions and the resolution of them by the Licensee and its engineer-constructor

, evidence an attenpt to develop a systematic approach of avoiding possible further problem areas. The discussions occurring among the Licensee, its engineer-constructor and the DRO at various exit interviews demonstrate a villingness to discuss problem areas and work toward the best solution. The fact that the DRO finds areas of concern is evidence that the DRO is performing its statutory function, just as the Quality Assurance and Quality Control organizations of the Licensee and its engineer-constructor are performing their functions when they discover problem areas.

Identification of representative persons having knowledge of facts contained in this Answer or participating substantially in the prepara-tion of it:

i

T. C. Valenzano hh11 Swede Road Midland, Michigan 48640 R. A. Grote 3301. Garland Midland, Michigan h8640 J. P. Connolly 3313 Birchfield Midland, Michigan h86h0 L. R. Albert 3219 Milford Midland, Michigan 48640 C. E. Kinney 1932 Poseyville, Rte. #10 Midland, Michigan h86h0 B. J. Stockton 319 Park Drive Alma, Michigan J. I. Dotson Tecumseh, Michigan i

P. A. Martine: 324h Bluett Ann Arbor, Michigan h8105 F. Plutchak 5730 Del Trigo Concord, California 9h521 Interrogatory 10(i): yith reference to your " Petition To Intervene" filed in this proceeding state:

(i) State each fact upon which you base the allegations in the third paragraph of paragraph h of your petition including

, without limitation an identification of the various Bechtel quality-assurance, quality-control progra=s , how they have been implemented in accordance with evolving AEC codes and identification of such codes, regulations and interpretations to which you refer, and definition of " reasonable assurance" (including all facts which support such a definition) as you use those terms in your petition; Answer: For Bechtel's understanding of " reasonable assurance", see Answer to Interrogatory 9 Bechtel's quality assurance and quality control programs, sometimes referred to in the singular as " quality assurance program", for i

4 engineering, construction and procurement of the Midland facility are contained '

l in the following: the Midland PSAR, Nuclear Quality Assurance Manual (NQ/d4), l l

Field Inspection Manual (FIM) and Quality Control Notices Manual (QCNM), Procure-ment Inspection Department Manual (PIDM), Bechtel Quality Control Manual - ASME III (BQCM-ASME III), and quality related portions of Project Procedures Manual

, (PPM), Internal Procedures Manual (IPM), Engineering Department Procedures Manual (EDPM), Procurement Procedures Manual (Ann Arbor), and various Bechtel 4

approved Suppliers Quality Assurance Manuals. The NQAM has previously been supplied to the Intervenors. The supplementary manuals vill shortly be available for inspection and/or copying.

The following are the evolving AEC regulations, codes and some of the interpretations thereof to which Bechtel's quality assurance pro 3 ram responds:

10 CFR Part 50, Appendix B ALAB-1kT and 152 1

1 ANSI Nk5.2 I

] With respect to the above, it should also be pointed out that Bechtel has responded to the interpretations of various regulations and codes as handed

down by Region III inspectors despite the fact that the General Accounting Office (B-16h105) recognized that the Appendix B criteria are subject to considerable subjective interpretations

"We analyzed the 18 criteria (set forth in title 10, parb 50, appendix B of the Code of Federal Regulations, effective July,1970) and found that 21 terms, in our t

opinion, are subject to considerable subjective interpre-tation.

"We believe that AEC, to insure that all matters considered necessary to AEC management will be covered by inspectors, needs to provide its inspectors with (1) more guidance on what constitutes an effective and working quality assurance program and (2) a well-defined, minimum scope of inspection.

l l

l l

l "Without more thorough guidance to inspectors, it appears, likely that decisions about the acceptability of licensees' quality assurance progra=s and the depth.of inspections necessary to make such decisions vill be made more on the basis of individual judgnent than ~ on the basis of established criteria.

As changes in interpretations of AEC regulations become known they are assessed to determine the necessity for amending the appropriate manuals, specifications, procedures, etc. If it is determined that a new interpretation or code requires that Bechtel's quality assurance program be amended in order to be responsive to that interpretation or code, implementing procedures are undertaken to revise or a=end the HQN4.

Since the Midland project began, the HQAM has been revised or amended on sixteen (16) different occasions either to incorporate evolving codes, regulatien or interpretations as part of Bechtel's quality assurance program, or as a result of Bechtel's continuing effort to revice and upgrade its quality assurance program:

DATES / CHANGES REASON FOR CHANGE A. Project Amendments:

1. July 15, 1973 Response to the AEC's position /

Section III, No. 4 interpretation of " documentation Section III, No. 5 at the site" requirements of Section III, No. 6 Criterion VII, Appendix B.

2. December 15, 1973 Section III, No. h Response'to RO Inspection Section III, No. 5 Report No. 050-329 and 330/73-08 Section III, No. 6 finding that conflicts existed in Section III, No. 7 Bechtel's vendor QA Program requirements.

3 January 15, 1974 Section II, No. 2 Response to R0 Inspection Report Section II, No. 3 No. 050-329 and 330/73-08 finding Section II, No. 4 that there were no procedures

~Section II, No. 5 available for record retention or Section II, No. 6 design interface control.

Section II, No. 7 Section II, No. 8 Section II, No. 9

4. January 31, 1974 Section I, No'. 1 Response to ALA3s 147 and 152.

Section IV, No.1 Additionally, ANSI Nh5 2.9 wasSection IV, No. h .

adopted.

]

Section IV, No. 5

.Section V, No. 7 Section V, No. Ik 5 March 11, 1974 Section I, No. 1 Response to a corporate Section I, No. k directive ordering that QA Section I, No. 5 and QC be separated from project management.

B. Revisions :

1. February 15, 1970 Exhibit 10 This Exhibit to the 1969 NQAM

-outlined general vendor require-I ments.

2. March 3, 1972 Section I, No.10 (Rev.1) Added Procurement Inspection

Department to the quality assurance program.

3. July 12, 1972 At reactivation of the Midland facilities, the 1972 version of the HQAM was in effect. The nev

format (1972 1/2 UQAM) provided 4

for greater ease of referral and facilitates additions, deletions or revisions.

4. October 1, 1972 Section V, No. 6 Incorporated training and indoctrina-tion provisions of engineering and field personnel.

5. December 1, 1972 Section I, No. 11 Clarified the duties and respon-Section II, No. 6 sibilities of M&FQCS. Revised

, Section III, No. 8 Management Corrective Action to

Section III, No. 11 respond to new requirements regarding I Section IV, No. k notification to the Client as to the Section V, Ilo.10 AEC; documentation required.

6. January 5, 1973 Introduction Qualified the relationship between Section I, No. 11 Section III, No. 8 the BQCM-ASME III and the HQAM.

Clarified the M&FQCS relationship Section IV, No. h with QA Management Audits.

Section V, No. 10 Bulletin 16 -

7 Fet mary 15, 1973 bection II, No. 7 Corrected minor changes from Section III, No. 1 previous revisions.

Section III, No. 2 Section IV, No. 6 Section V, No. 5 Section V, No. 6 Section V, No. 7 Section V, No. 8

Section V, No. 9 Section V, No. 11 Section VI, No. 6

8. July 15, 1973 Section V, No.1 (Rev.1)

Section V, No. 2 (Rev. 0)

Reorganization. Added clarifica-tion of the amendment processSection V, No. 3 (Rev. 0) and QA group responsibilities.

Section V, No. h (Rev.1) 9 September 11, 1973 Bulletin 18 Clarification of the use of all Appendix C forms.

10. November 30, 1973 Section V, No. 11 (Rev. 2) Gave stop work authority to Section'V, No. 12 (Rev. 0) engineering and procurement.

Introduced communication control as a new procedure applicable  ;

to all functional groups.  ;

11. March 1, 197h 4-Section II, No. 2 Incorporated the Midland Project Section II, No. 3  ;

Amendments approved on January 15,Section II, No. k 1974.

0 i

)

,1

11. March 1, 197h Con.

Section ll, No. 5 Section II, No. 6 Section II, No. 7 Section II, No. 8 Section II, No. 9

12. April 12, 1974 -

Figures Clarification of the PQAE's Appendix A function in regard to QA Bulletin 20 Activity Reports.

When formally approved by the ASMZ Council, ASME Boiler and Pressure Vessel Code ('i3ME Code") revisions are published semi-annually as Su=mer and Winter addenda for the purposes of incorporating ASME C0de cases and clarifying or revising the Code rules or interpretations thereto. The revisions may be implemented at any time af'ter the date of issuance and become mandatory six months after the date of issuance except for components and/or installations contracted for prior to the end of the six month period.

Mandatory Code requirements are implemented in the BQCM-ASME III i

in accordance with the procedures detailed in Section 1. There is no require-ment that the BQCM-ASME III be revised to adopt the ASME Code revisions since the Manual, as written, provides for the implementation of evolving ASME Code requirements. Amendments to the BQCM-ASME III for the Midland , job have been submitted to the authorized inspection agency for review and approval prior to implementation. The amendments when adopted vill alter the quality control verification responsibilities according to the dictates of ALAB-lh7 (RAI-73-9,

p. 636).

The various groups or departments implement the changes to the HQAM or BQCM-ASME III by, first, amending or revising the supplementary manuals

t' to coordinate with the changes to the IlQAM or BQCM-ASME III, and, second, by implementing any procedures or other necessary actions required to effectuate those changes. The following are summaries of the activities of the various functional groups at Midland. These summaries deal, in a general way, with the implementation of quality related requirements which are set forth in greater detail in the respective manuals, procedures, etc.

SU?CIARY OF TIIE QUALITY ASSUPAliCE ACTIVITIES FOR TI!E MIDLAIID PLAIIT The Midland Quality Assurance Prgram is coordinated by the Project

! Quality Assurance Engineer (PQAE), who was assigned to the project by and receives technical and administrative direction from the Divisional QA Manager through a QA Supervisor. The PQAE's functions include: reviewing project plans and schedules for quality related activities to assure the timely and effective implementation of the Quality Assurance Program for the project; providing surveillance of the project Quality Assurance program and coordina-tion of the Quality Assurance program interfaces between Engineering, Procurement, and Construction; monitoring and auditing to determine conformance to the the QA Supervisor and the Project Manager informed of the status and adequacy of Quality Assurance program implementation; identifying problem areas, recom-mending corrective action; coordinating and verifying implementation of correc-tive actions;' and assuring that there is established and maintained effec-tive systems for controlled storage and retrieval of quality documentation.

l The PQAE is currently assisted by five field and office Quality Assurance Engineers who insure that the QA program is properly being implemented. QA has 140- .

"stop work" authority which cannot be countermanded. Project QA is charged with the responsibility of preparing periodic reports to the Division QA Manager and to the Project Manager evaluating the status and adequacy of the prcject quality assurance program. In addition, QA prepares activity reports, discre-pancy reports (QADR's), Audit Findings (QAF's) and Management Corrective Action Reports (MCAR's) when required.

SUMMARY

OF QUALITY COIrfROL ACTIVITIES FOR THE MIDLAIID PROJECT The Chief Field Quality Control Engineer ("CFQCE") supervises the Quality Control Program. He is responsible for training and admf nistrative and technical direction of the Project Field Quality Control Engineer ("PFQCE")

and the Quality Control Engineers at the jobsite. Administrati re responsibility is exercised through and upon the recommendations of the Ann Arbor Quality Control Supervisor and the Project Field Quality Control Engineer. The CFQCE provides technical direction through Master Inspection Plans. The Ann Arbor Quality Control Supervisor coordinates quality control activities with engineering and construction personnel, and provides technical support to and monitors the performance of the Project Field Quality Control Engineer. The Project Field Quality Control Engineer is responsible for supervision of the Quality Control Program at the Midland jobsite to assure that the work falling under the scope of the program is properly inspected and documented. The Project Field Quality Control Engineer has authority to stop work being performed by Bechtel ]

and jobsite contractors. This authority, co= uaicated through the Project Superintendent, requires immediate stoppage of work operations and other construction activities determined to be improperly controlled or otherwise l

kl-

in nonconformance with quality requirements of the applicable design specifica-tions, drawings and other program criteria, or if a designated quality control inspection, examination or test operation is bypassed to the point where the work is no longer capable of bei.ng properly inspected. Stop work orders issued by the PFQCE cannot be countermanded by the Project Sup:rintendent.

Superimposed upon the stop work authority of Bechtel Quality Control are stop work authorities exercised by Bechtel Quality Assurance and Consumers f

Power Company. Surveillance over in-process work operations is pe'rformed by Quality Control Engineers to verify that construction and installation activities are performed in accordance with specified quality requirements.

They are also responsible for performance of the inspections and tests required for quality verification of construction and installation activities. These in-process surveillance and verification inspections are pre-determined and identified on Master Inspection Plans prepared by hona office Quality Control Engineers and approved by the Chief Field Quality Control Eagineer. Exa=ples of in-process surveillance and verification inspections are:

A) Visual inspections of structural steel, rotating equipment, pressure vessels, tanks, heat exchanges, heating, ventilating and air conditioning equipment, raceways, conduits, cables and associated electrical equipment, l

l B) Liquid penetrant, or magnetic particle of velds or structural steel and vacuum box testing of liner plate velds, and other associated material or components.

-h2- ,

C) Calibration control of measuring and testing equipment.

D) Monitoring of field design. document control measures.

The Project Field Quality Control Engineer supervises the quality verification function. He reviews inspection reports, processes non-conformances, coordinates training and supervises Quality Control Engineers performing receiving and in-process inspection assignments, monitors testing laboratories, provides surveillance of subcontractor quality control programs, reviews field purchase orders for Q-List items, and is responsible for the maintenance of the field quality control files. The PFQCE receives tecnnical and administrative direction from the CFQCE.

Quality Control Engineers and Technicians carry out inspection assignments in accordance with procedures and directions as. developed by the Project Field Quality Control Engineer and in accordance with the Field Inspection Manuals. The number of Quality Control Engineers and Technicians assigned to the site depends on the work load and nature of the work. Currently there are 25 Quality Control Engineers and Technicians who have responsibilities for the Midland Project. This vill increase substantially during peak construc-tion periods.

SE!ARY OF THE PROCUREMENT INSPECTION DEPARTME:iTS ACTIVITIES FOR THE MIDLARD PLANT The Procurement Inspection Department plays an active role in the acquisition and manufacture of material and components for the Pldland facility. Procurement Inspection Department activities include either pre-bid or pre-award supplier surveys to evaluate a potential supplier's manufacturing,

P quality control and quality assurance capabilities; both pre- and post-award meetings with potential suppliers to assist in clarifying Bechtel's position regarding enforcement of specifications, codes, and 3echtel's vendor quality assurance program requirements; pre-fabrication meetings to determine the 4

vitness and hold points for in-process inspection and testing; in-process j surveillance inspection to assure the quality of material and equipment being manufactured; post-avard supplier quality program audits to evaluate the supplier's implementation of its Eechtel approved quality control and quality assurance programs. Finally, materials requiring shop inspection receive a pre-shipment in-shop inspection and' documentation review prior to release for shipment to the jobsite

SUMMARY

OF ENGINEERING QUALITY ACTIVITIES FOR THE MIDLAND PLANT ,

Quality related activities of engineering are the responsibility of the Engineering Department. Technical verification of design work is the responsibility of the Project Engineering team, the Chief Engineers and their technical staffs.

The Engineering Department has established and maintains e Quality Engineering function to define Quality practices, coordinate and insure the i

establishment of quality requirements in engineering documents, and coordinate the design verification program.

Quality Engineers, reporting to the Project Engineer, are assigned to the Midland Project, in accordance with project work load. One Quality Engineer is designated as the Project Quality Engineer (PQE) and is responsible l

1

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{

for day-to-day supervision of the Project Quality Engineering Group which currently consists of approximately 6 quality. engineers.

The Project Quality Engineer is responsible for coordination of project Quality Engineering functions. With the assistance of Quality Engineers the PQE directs the planning, organization, and implementation of the Project Quality Engineering Program, including assistance and guidelines in the evaluation of vendor quality assurance progrs=s. Each principle discipline on the project is assigned one engineer who is responsible for coordinating Project Quality Engineering functions within his discipline.

The quality engineers advise and assist the technical discipline on quality matters, monitor project engineering operations for conformance to standards and procedures, and assure that the Project Engineer is aware of the inplementation of the overall quality program.

SUINARY OF CONSTRUCTION QUALITY ACTIVITIES FOR THE MIDLAND PLANT The use of plans, drawings and specifications to erect and install materials and equipment into a nuclear power plant is the prime function of the Midland Construction Team. The erection and installation of items to the specified requirements is the quality aspect of construction.

Construction involvement with quality begins with site prepara-tion and terminates with the acceptance of the facilities and structures by the Client. Field quality control measures continue in force throu6h j receiving, handling, storage, installation, inspection / test and final turn-

. . I over to the Client. j

-h5-

The Project Superintendent is responsible for all construction activities at the jobsite for which Bechtel is contractually obligated including field engineering and field procurement. While the Project Superintendent is responsible for the overall quality of the work, he is not responsible for the quality control function. The Project Superintendent is assisted by the Project Field Engineer, the Field Superintendent and a 1

staff of Superintendents.

, The Project Field Engineer assists the Project Superintendent with engineering decisions which do not affect basic design, recommends action to the Project Engineer on engineering proble=s where basic design is affected and reviews all reports of nonconformances.

SUMMARY

OF THE MATERIALS, FABRICATION AND QUALITY CORTROL SERVICES DEPARTMENT ACTIVITIES FOR THE MIDLAND PLAUT Materials, Fabrication and Quality Control Services Department (MF&QCS) supports engineering and construction activities by providing specialized services consisting of engineers and technicians experienced in metallurgy, corrosion control, metal fabrication techniques, and welding and nondestructive examination. Through the supervision of the !F&QCS Manager the following areas of support have been provided to the Midland facility:

consulting services en the properties of materials, material selection and corrosion investigation; preparation of periodic " Materials and Fabrication Guidelines" which provide technical guidance and suggestions for avoiding problems in materials selection, velding, fabrication and quality control; review of welding, fabrication, nondestructive examination and Codes and I

., l Standards portion of iroject specifications for specific components to insure up-to-date technical esntent; review of technical portions of bid packages prior to release to bidders and assistance to. Engineering and/or Procurement in the evaluation of supplier's bids; consulting services to Engineering on velding, veld design, fabrication, metallurgical, structural, nondestructive examination, heat treating and pressure testing; preparation, revision and maintenance of the Bechtel Quality Control Manuals for ASME Co=ponents by coordinating the i Manual content, including preparation of amendments for specific requirements of the project; organization of plant site audits for ASHE components and welding in coordination with Quality Assurance and/or Engineering; assigning metallurgical, velding and NDE personnel to assist Procurement Inspection Department in conducting supplier audits; and review of field velding and nondestructive examination procedures submitted by Bechtel subcontractors.

Identification of representative persons having knowledge of facts contained in this Answer or participating substantially in the preparation of this Answer:

W. S. Gibbons, Jr. 189 Warwick Avenue San Leandro, California 9h577 M. M. Krout 1225 Astor Drive Ann Arbor, Michigan h8104 J. I. Dotson Tecumseh,Fuchigan D. R. Johnson 53 Wildwood Avenue Piedmont, California 9h610 Z. Tucker lh2h Astor Drive Ann Arbor, Michigan h8104 W. E. Ferriss 2762 S. State 1

Ann Arbor, Michigan h8104 *

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J. L. Southard 1456 Keuhule Ann Arbor, Michigan 48103.

P. A. Martinez 3244.Bluett Ann Arbor, Michigan h8105 T. C. Valenzano kh11 Swede Road Midland, Michigan 486h0 R. C. So=merfield 6039 Ann Arbor Road Saline, Michigan 48176 L. M. Scoville 1600 First Federal Building Detroit, FEchigan 48226 Interrogatory 11: List each decision which you have taken or failed to take in connection with quality-assurance and quality-control at the Midland facility which action, or failure to act, was based in any part upon the expenditure of funds. This Interrogatory is intended to solicit your answer as to what role the cost of providing quality-assurance and quality-control play in the quality-assurance and quality-control activi-i ties you recommend or implement.

Answer: Cost is a minor consideration in virtually every decision recommended or implemented by Bechtel in connection with providing Quality Assurance and Quality Control activities for the Midland Plant. However, even to the extent that cost is a consideration, the primary and overriding consideration is the relationship between cost, need for and efficient use and availability of adequately qualified personnel and procedures. In this sense, cost has not been a factor in the staffing and training of Quality Assurance and Quality Control personnel. Nor has cost been a factor in implementing the Quality Assurance and Quality Control programs and activities. Bechtel's policy is to assure that potential solutions or options adequately provide for the implementation of Quality Assurance and Quality Control, with a choice then i

being made from such solutions or options which takes economic impact into consideration. To the best of our knowledge, there has been no instance where Bechtel made a decision or recom=endation regarding the staffing and/or training

l of the Quality Assurance and Quality Control groups and the implementation of their activities for Midland which resulted in a degradation of Quality Assurance and Quality Control activities through efforts to minimi:e costs. Accordingly, it is impossible to list each instance where cost was a factor in connection .

With staffing and training of the Quality Assurance and Quality Control groups for the Midland ' Plant and the implementation of their activities.

In this connection, however, it is to be re-emphasized that decisions as to staffing and training of the Quality Assurance and Quality Control groups for Midland as well as the implementation of their activities are supervised and coordinated by the Quality Assurance and Quality Control Managers and Super-visors, respectively, through the Project Quality Assurance Engineer and the Project Field Quality Control Engineer, who do not have responsibility for project costs and schedules and are properly independent of those who do.

Examples of decisions which have been made and may have resulted in increased costs:

(a) Revisions of the nuclear quality assurance manual, including project revisions pending changes in the basic manual; (b) Revisions of the Field Inspection Manual and project special provisions within the Quality Control Notices Manual; (c ) Increasing of the project QA staff to 2 man-years above the estimate; t,

(d) Increasing the project quality control staff to its current level;

.. - . ._ --. _ .. . -- - - . - - _ - . .=- - . -

(e) Increasing the nu=ber of Bechtel. QA managenent units for the Midland Pro. ject; (f) The formulation and implementation of various procedures; ,

J 1

(g) Providing a quality assurance supervisor and a quality control supervisor for Bechtel's Ann Arbor office; (h) Providing for the certification of quality control engineers.

Identification of representative persons having knowledge of facts I

contained in the Answer or participating substantially in the preparation of it:

1 W. S. Gibbons, Jr. 189 Warwick Avenue San Leandro, California 94577 S. A. Bernsen 27987 Via Ventana Los Alton Hills, California 94022 W. E. Ferriss 2762 S. State Ann Arbor, Michigan 4810h J. I. Dotson Tecumseh, Michigan

, M. M. Krout 1225 Astor Drive Ann Arbor, Michigan h8104 D. R. Johnson 53 Wildvood Avenue Piedmont, California 9h610 Z. G. Tucker lh24 Astor Drive Ann Arbor, Michigan 4810h J. P. Connolly 3313 Birchfield Drive Midland, Michigan 486h0 W. F. Holub 712 Peninsula Court Ann Arbor, Michigan h8105 L. M.' Scoville, Jr. 1600 First Federal Building Detroit, Michigan h8226 ere,-- . - - - - -

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Interrogatories 12(b) and 12(c): With respect to each of the nuclear facilities as to which you have been a contractor or subcontractor, state:

(a) List each Quality Assurance / Quality Control violation which has occurred at each site and include whether the violstion was reported to AEC officials.

(c) List each Quality Assurance / Quality Control incident which was not reported to AEC or which was not considered a violatio. but as to which discussion was had whether it was a violation.

Answer: The attached list (Exhibits 12(b) and (c)-1) identifies all issued Management Corrective Action Reports, Nonconformance Reports, Quality Audit Finding Reports, and Quality Assurance Discrepancy Reports. Of them only one, MCAR-2, was identified as reportable pursuant to 10 CFR Part 50 55e.

While " discussions" may or may not have taken place in any given instance, all Bechtel generated Management Corrective Action Reports, Nonconformance Reports and Quality Audit Finding Reports which identify none=,aformances or conditions adverse to quality are reviewed for reporta-bility pursuant to 10 CFR Part 50 55e prior to or concurrent with their cransmittal to Consu=ers Power Company. Bechtel provides a recommendation as to reportability to Consumers Power Company, and does not make a direct report of reportable items to the AEC.

Identification of representative persons having knowledge of facts contained in the Answer or participating substantially in the preparation of it:

W. S. Gibbons, Jr. 189 Warwick Avenue San Leandro, California 94577 W. E. Ferriss 2762 S. State Ann Arbor, Michigan h810h

J. I. Dotson Tecumseh, Michigan W. F. Holub 712' Peninsula Court Ann Arbor, Michigan 48105 J. Milandin 9 Fleetwood Court Orlando, California 94563 J. P. Connolly 3313 Birchfield Road Midland, Michigan h860h P. A. Martine: 32h4 Bluett Ann Arbor, Michigan h8105.

L. M. Scoville, Jr. 1600 First Federal Building Detroit, Michigan h8226 J

Additional persons with knowledge of the facts are identified on the reports themselves which vill be made available for inspection and copying.

Interrogatory 1h(a): With respect to your Midland facility quality-assurance state:

(a) Do you agree with the allegations set forth in the Show Cause order and the referenced documents? If not, state each allegation with which you do not agree and explain why:

Ancver: No. See answer to Interrogatory 10(h).

Interrogatory 1h(b): With respect to the Midland facility quality-assurance state: .

(b) As a result of the Show Cause order, have you recommended or taken any action to change your role or Consumers' role at the Midland facility? If not, state why not, and if yes, explain such changes in implementations and recommendations in detail.

Answer: Bechtel has not recommended or taken any action to change its role or Consumers' role at the Midland facility aJ a result of the Order to Shov l

l l

l

Cause. Bechtel has made adjustments and improvements in the implementation of its quality-assurance program both prior to and subsequent to the Order to Show Cause, and has expanded management, supervisory and senior personnel involvement, as indicated by the following:

1. A. P. Yates, Vice-President, Bechtel, sent a letter to S. H.

Howell, Vice-President, Consumers Power, dated December 19, 1973, cutlining a program for renewed emphasis upon areas of quality assurance / quality control, (Exhibit 1h(b)-1).

i 2.- On January 3, 1974, Mr. P. R. Cassidy,-Vice-President and Ann Arbor Area Office Manager issued a memorandum to all responsible supervisory personnel for the Midland job, re-e=phasizing the importance of QA/QC activities, (Exhibit 1h(b)-2).

3. On December 14, 1973, Mr. H. O. Reinsch, Executive Vice-President /

General Manager, issued a letter to management personnel involved with the Midland porject requiring increased reporting of important quality issues,

(. Exhibit 14(b)-3).

h. On February h, 1974, Mr. H. O. Reinsch, Executive Vice-President /

General Manager, issued a letter to all management personnel describing the

, organizational changes in QA/QC to 'oe implemented on Bechtel projects, (Exhibit 1h (b )-h ) .

5 On December 14, 1973, Mr. J. T. Marvin, Manager of Construction, outlined measures to be undertaken to improve QA/QC procedures and attitudes at Midland, (Exhibit 1h(b)-5).

6. On December 19, 1973, Mr. J. T. Marvin, Manager of Conatruction, further defined measures being taken to improve procedures and reenphasized positive attitudes concerning the QA/QC progrn=s at Midland, (Exhibit 14(b)-6).

See Answer to Interrogatory 10(i) for identification of changes to the Bechtel UQAM which refined the implementation of Bechtel's quality assurance program.

In addition to those identified above as senders or addressees of the referenced letters or memoranda, the following are representative persons having knowledge of facts contained in the Answer or participating substantially in the preparation of this Answer:

S. A. Bernsen 1595 Uright Avenue l Sunnyvale, California 94087 l l

W. S. Gibbons, Jr. 189 Uarwick Avenue i San Leandro, California 94577 I

W. E. Ferriss 2762 S. State Ann Arbor, Michigan h8104 J. I. Dotson Tecumseh, Michigan M. M. Krout 1225 Astor Drive Ann Arbor, FEchigan 4810h D. R. Johnson 53 Wildwood Avenue Piedmont, California 9h610 Z. G. Tucker 1h24 Astor Drive Ann Arbor, Michigan 48105 J. P. Connolly 3313 Birchfield Drive Midland, Michigan 486h0 W. F. Holub 712 Peninsula Court Ann Arbor, Michigan h8105 P. A. Martinez 32hh Bluett .

Ann Arbor, Michigan h8105 L. M. Scoville, Jr. 1600 First Federal Building Detroit, Michigan h8226

Interrogatory 16: Describe in detail each classification or category of document (as defined herein) which you maintain in connection with quality-assurance quality-control r.egarding the Midland site, whether maintained at the Midland site or elsewhere. This Interrogatory is intended to solicit information for a motion to produce and is intended to have you describe documents whether of a formal or informal nature, and whether or not they are documents wh'ich are or are not disclosed to someone other than persons in your Co=pany.

Answer: In general, the classifications or categories of documents maintained in connection with Quality Assurance or Quality Control for the Midland Plant are the following:

, (a) Desiga Criteria - Standards, codes, regulations and/or client requirements used as a basis for the design of the Midland facilities.

(b) Systems Descriptions - Written summaries describing the specific functions, design and intent and major features of a system. In the context of power plant design, a system is a grouping of components assembled to perform a specific function.

i (c) Specifications - Specific descriptions, requirements and instruc-tions for components, materials, manufacturing and field processes and required supplier analyses involved in the design and/or construction of the Midland Plant.

(d) Drawings - Visual informations, graphical presentations, or lists of design information into a format of instruction and/or information for the user.

(e) Design Calculations - A su= nary of the mathematical or other approaches used to establish a design parameter.

(f) Purchase Orders and Subcontracts - Commercial agreements entered into with other organizations for the supply of services and/or commodities necessary for construction of the Midland facilities.

(g) Vendor Quality Assurance Manuals - The quality assurance program supplied by a vendor of Q-listed coc=odities or services to Bechtel for acceptance. The quality assurance program describes the planned and systematic measures that are used to assure that structures, systems, and components vill meet the requirements of the procurement department.

(h) Vendor Engineering Documents - Procedures, drawings, specifica-tions, prototype qualification test reports, and other similar documents that require project engineering approval prior to fabrication, or prior to use of the design or fabrication process.

They also include price lists, and instructional docu=ents for handling, storage, maintenance, etc.

(i) Vendor Quality Verification Documents - Material test reports, heat treatment charts, velding records, NDE results, performance test reports, etc. , which demonstrate or certify conformance to the technical ~ or inspection requirements of the procurement documents.

(j ) Correspondence Files - All project internal and external communi-cations relative to the construction, engineering, and procure-ment, and quality activities for the Midland facilities. Corres-pondence files are maintained by the following groups: QA, QC, Engineering,IF&QCS. Procurement Inspection and Construction.

Meeting minutes are contained in these files.

(k) SAR Change Notices - Documented records of changes to design commitments proposed and/or adopted in the Midland SAR.

(1) Construction Documentation - Field and Subcontract Engineer's reports and other forms and docu=ents utilized to record information and data.

(m) Construction Procedures and Instructions - Documents establishing methods and sequences of performing construction work not neces-sarily covered by engineering specifications.

(n) Procurement Inspection Reports, Surveys, and Audit Reports -

Documentary evidence of off-site Procurement Inspection Depart-ment activities relative to the Midland facilities' commodities.

(o) Inspection Assignments - Document packages made up for all purchase orders or subcontracts requiring shop inspection. The packages contain copies of the purchase order or subcontract, all applicable specifications, inpsection plans, and inspection reports.

(p) Materials, Fabrication and Quality Control Services Documentation -

These documents including supplier review documentation, qualifica-tion and training records of NDE personnel, and welding procedure qualification records.

(q) Quality Control docu=entation - Those documents that provide visibility for specific quality related activities:

Material Receiving Reports Vendor Certifications Receiving Inspection Plans Field Inpsection Plans and Reports Welding and Non-Destructive Examination Records, Personnel Qualifications, and Reports Quality Control Records Logs Non-Conformance Reports and Logs Field Inspection Logs Material Receiving Instructions Quality Control Procedures Training and Qualification Records of QC Personnel Field Quality Verification Drawings (r) Quality Assurance documen+ation - Those documents that pro dde visibility for specific quality related activities:

. Quality Audit Findings Quality Assurance Discrepancy Reports Daily Log Sheets Management Corrective Action Reports Bi-monthly Activity Reports Work Plans Quality Assurance Audit Checklists 4

(s) Quality Engineering documentation - Those documents that provide visibility for specific quality related activities:

Bidder Quality Program Ibnual Evaluation Su- ary Supplier QA Checklist Project Survey Reports Identification of representative persons having knowledge of facts cor.tained in the Answer or participating substantially in the preparation of it:

J. I. Dotson Tecumseh, Michigan J. P. Connolly 3313 Birchfield Drive Midland, Michigan 48640 T. C. Valenzano kh11 Swede Road Midland, Michigan 486h0 J. L. Hurley 2681 Hawks Road Ann Arbor, Michigan h810h J. L. Southard 1h56 Kuehule Ann Arbor, Michigan h8103 R. C. Sonnerfield 6039 Ann Arbor Road Saline, luchigan 48176 L. 11. Scoville, Jr. 1600 First Federal Building Detroit, Michgigan 48226 Interrogatory 17:

Please list the name and address of each vitness whose testimony you intend to offer at the proceeding. Include with your answer a summary of the scope of each witness's testimony. In the event that you do not presently knov who your witnesses will be, please list the areas of evidence or testimony which you presently believe you vill introduce. If you cannot answer this Interrogatory, please explain in detail why you cannot.

1 l

Answer: Bechtel has not determined who its vitnesses may be because that determination depends upon the scope of the hearing in this matter, the ' required specification of issues and the testimony offered by other parties to this proceeding. It is presently believed that areas of evidence offered by Bechtel vitnesses vill include:

The continuing evolution of Bechtel's overall quality program; The implementation of Bechtel's quality requirements on the Midland Project by those Bechtel groups responsible therefor, including Engineering; Construction; Quality Control; Procurement Inspection; Materials, Fabrication and Quality Control Services and Quality Assurance; and Bechtel's commitment to quality requirements.

Identification of representative persons having knowledge of facts contained in the Answer or participating substantially in the prepara-tion of this Answer:

L. M. Scoville, Jr. 1600 First Federal Building Detroit, Michigan h8226 Interrogatory 18: Please list all of the documentary evidence which you presently plan to introduce at the proceeding. If you are not in a position to presently state what documentary evidence you will intro-duce, please ' state what categories of documentary evidence you vill introduce. If you are not in a position to answer this Interrogatory, please explain why not.

Answer: With the exemption of the Quality Assurance Program Manuals identified in the Answer to Interrogatory 10(i), Bechtel has not determined what documentary evidence it vill introduce at the hearing on this matter.

That determination depends upon the scope of the hearing, the required specification of issues and the testimony and documentary evidence offered by o~ther parties to this proceeding. See the Answer to Interrogatory #17 for areas of evidence which Bechtel presently believes it will address.

Identification of representative persons having knowledge of facts contained in the Answer or participating substantially in the prepara-of it:

L. M. Scoville, Jr. 1600 First Federal Building Detroit, Michigan h8226

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Laurence M. Scoville, Jr. y/

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S STATE OF MICHIGAN )

) ss COUNTY OF WASHTENAW )

M. M. KROUT, being first duly sworn, deposes and says that he is Project Manager for Bechtel Power Corporation with such responsibility for the Consumers Power Company Midland Plant, Units 1 & 2; that he has authority to sign the foregoing Interrogatories on behalf of Bechtel Power Corporation; that he has read the foregoing Answers and subscribed the same; that said Answers were prepared with the assistance and advice of employees of Bechtel Power C,orporation and Bechtel Associates Professional Corporation and counsel, upon whose advice he has relied; that said Answers, subject to inadvertent or undiscovered errors, are based on and limited by records and information in existence, presently recollected and thus far discovered in the course of the preparation of these Answers, and that subject to the foregoing limitations, the said Answers are true to the best of his knowledge, information and belief.

1 kl k M.f.KROUT' f 'f i

Subscribed and sworn to before me, a Notary Public, in and for said County and State, this J// day of '// v,,

A.D., 1974. g'

/

Cl / . c s: ,

( .. ?) t n k (br_ e '

/

Notary Public, Washtenaw County, Michigan My Commission Expires: A h , / / M / ef 7

I l

1 STATE OF MICHIGAN )

) ss COUNTY OF WASHTENAW )

P. A. MARTINEZ, being first duly sworn, deposes and says that he is Project Engineer for Bechtel Associates Professional Corporation with such responsibility for the Consumers Power Company Midland Plant, Units 1 & 2; that he has authority to sign the foregoing Interrogatories on behalf of Bechtel Associates Professional Corporation; that he has read the foregoing Answers and subscribed the same; that said Answers were prepared with the assistance and advice of employees of Bechtel Power Corporation and Bechtel Associates Professional Corporation and counsel, upon whose advice he has relied; that .said Answers, subject to inadvertent or undiscovered errors, are based on and limited by records and information in existence, presently recollected and thus far discovered in the course of the preparation of these Answers, and that subject to the foregoing limitations, the said Answers are true to the best of his knowledge, information and belief.

e

! / ,

P. A. MARTINEZ Subscribed and sworn to before me, a Notary Public, in and for said County and State, this < Q / day o f 9? 'es, ,

A.D., 1974. #

• a ,te,i < n

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Notary Public, Washtenaw County, Michigan ,

My Commission Expires: //M / 4'] /Y7

[l.

• EXHIBIT 7-1

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QUALITY ASSUllANCE PROGRAM l l5, , j ,')3;4 PROJECT

SUMMARY

Q LIST FORM

%.':,4 MIDLAND LHITS 1 & 2 Job No. .__Z2.2_0 ARCHITECTURAL Page 1 of 1 iTEMI,,Tg' ,D EfiTITY l REV. ITEM / DESCRIPTION EQ UIP DWG SPEC NO. j PORCHASER NO. NO. NO.

t .

f2.1 i

Reactor Containment Bldg. Coating s A-15 2.2 Class I Masonry A-13 (Includes ALL Masonry Construction for Areas Catitaining Class I Equipreent) l l 2.3 Flood Control "atertight Doors A-17 and Airtight Docrs 2.4 Control Room Sust ended Ceiling A-19

2.5 Reactor Containment Bldg. B&W G-3 Equipment Coatings (Partial) m l

l l l j

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0 i O I i H l  ! I

[;kt 6/t/7 Rt " !::c-1 m ..! re !!

• ts -I by D.\PC Utn.il) </, k g [ [ h 0 - /' 7 3 ff' 4 ,

-u.__.-

j *

{

fl 10/lW 70 "' '

-) j REV* ' PROJ. ENG. DATE CHIEP gg' DATE RE ASON f OR IrJUE NUC. I;NG._;i_. DATE i

ISSUED BY APPROVEli HY

} ' . l . y .,. , -

v j QUALITY ASSURANCE. PROGRAM

'l.i.hdd.

'A

' "c '

PROJECT

SUMMARY

Q LIST FORM

?!IDI AND UNITS 1 & 2 Job fio. 7"n P 1d 2 CIVIL / STRUCTURAL

'!TEH EQUIP. DWG. SPEC.

ICEt;0.

• .!!iY l ITEM /DESCRIFTI0tl PURCHASER tt 0. NO. fl0 .

EM,-

11 Prestressed & Reinforced Concrete 1.11 R.aintorcing Steed C-39 3 1. 13 1 Cadwelds

• C-255 3 1.12 Concrete

• C-230 C-231 3 1.121 Natcr Stop

• C-232 1.13 Post-Tensioning C-2 l

1.13l Corrosion Protection Fill er C-49 3 1.14 Aux. Eldg. Pipe Tunnel

• C-23 12 Contaianent Structure _

1.21 Liner Plate C-50 A 1.211 1/4" and thickened liner plate C-50 A 1.212 Penetration assenblies (including pipe sleeves and wall' stiffeners) C-50 A 1.213 Leak chase channel system. C-50 A 1.22 Locks and llatch Door C-500 3 1.23 Crane Supports C-50 A 3 1.24 Paints and Coatings (Including C-50A,B equip ent conting systens)

Fuel Storage root u tuel transter 3

Canat 1.31 Fuci Rachs (new & spent fuel) C-41 C-42 1.32 Stainless Steel Liner Plate C-43 1.33 Fuel Pool Cates C-44 O .

O l IL\ l -

/h './1 k' n. v ine.1 auti l'o is s ueil by BAPC (final) /fb d ~/ ~ 7 7 -

I "'

/9/73lP.eviacil and reissued b. RAPc(Preliminar .

DROJ. Et,u. ..E un. ,,.. a [ .[ F

-r-

-.. 1 n .f * '

. OAit REASON FOR 15!UE j ISSUED BY A F F ' 0 '.' E 3 E (  ;

1

.. .....,. J

U '. ' .5 2 QUALITY ASSURANCE PRCGRAM i ' i l'M PROJECT SUt: MARY Q, LIST FORM b',

a u p'. /

i HIDI.A::D (MI'rs 1 & 2

CIVIL /STRUCTURAI.

Jt) u. 7220 ,,,, 7 ,, 9

.f , ,

'I II E" g g g.;T ITY

+

7EV. 7, g , PURCHASER EOUIP.fic. DWG.NO. SPEC. NO.

c .; 3 .

j 1.34 Fuel Transfer Tube C-46 1.4 Structural Steel l

I 3 1.41 Reactor iluilding Structural i Steel C-37 1.42 Au>:lliary Building Strue. C-36A S t.cel C-363 I

3 1.43 Emergency Generator Building

+ Structural steel C-37  ;

i

! 3 1.44 Service Unter Pump Structure Structural Steel C-37 1.45 Miscellaneous Iron-E abcdded

• C-33 j

(Sole plates under stcaa gener-

ators and reactor vessels, all l i embedded steel in reacter

! building foundations, all anchor l 1 bolts and threaded rods.) l I

j 3 1.3 Emergency Reservoir

3 8

1 1.51 Backfill Adjacent to C-210 l Emergency Reservoir i

3 1.52 Pipeline #

I j 3 1.53 Service Water S tructure Sluice -

g j Gates t

i

h. l

3 1.8 coi.mac ted unckfill

• C-210 i 1.9 Field Erected Tanks l

q 1.91 Borated 0:ater Stora3e Tank c_Is l I! {

!9 l 1

j

• Sein:dc Cat e;;ory I portions only.

j # Specificatiens will be added at later date.

i AA-102672 1

11 .- .

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,r.... "

v1 $,5 ,

ljh . f QUALITY ASSUllANCE PROGRAM PROJECT

SUMMARY

O LIST FORM 4;_'/

!!IDLAND UNIT 1 & 2 Job No. 7220 _

CONTROL SYSTDIS Page 1 of '

TiEP.1I j~DE5TITY REV.

_NO. f,, NO. I Ef.1,'OEERIPTION NRCHASER EQUIP. DWG. SPEC.

NO. NO. NO.

1 Instrunents

'; 5.1 Controllers / Transmitters l J-204 5.2 Radiation !!initoring Equipment J-211 f 5.3 Level Controllers J-216

, 5.4 Temperature Regulators J-217 5.5 Flow Tubcs J-222 l l5.6 Orffice Plates J-223 5.7 Flow Switches J-224 5.8 Sight Flow Glasses 1 .

J-225 5.9 Level Switches J-226 5.10 Gage Glasses O 5.11 J-227 Pressure and Temperature Switches J-228 l 5.12, Thermocouples, RID's and Thermo -

1

' Wells I

i J-229 5.13 Dial Thermometers

- J-230 i

i 5.14 Control Valves i

J-255 1 5.15 Solenoid Valves

!' J-256 1 4 ,

I i

) 3 l5.16 Non-Nuclear Instrumentation B&W i M-1.35 i (CS 1048)

I Q-listed instruments for all of the categories above are identi-fied in the Instrument Index.

f

_:3'.fillULHerised and Reinsued hv napc (rf n,11 k$-4,k k d 6 - b D '< C/ 7 /; :' i p 11--5-: 0 ..,

i ' ,

(,a i i 1 -

l. l l HEV.

,, DATEjl REASON FOR ISSUE PROJ. ENG. DATE CliitF NUC. ENG. DATE L _m i i ISSUED BY l APPROVED BY

-+se.... . _ _ _ . ,

_.u-m. __

<~'D 1 s' .. OllALITY ASStjitANCE PROGRAM j!lM! -('39 ) PIIOJECT StJMMARY Q LIST FOR'M I .t --.' .' !'

!!IDLAND UNIT 1 & 2

. fob rJe ._ _7220 Pagelor_2 2

~

' ' ~

CONTROL SYSTDIS ITET lhEfUiiv

~

HEV. g g' PURCHASER EQUIP. NO.

"* DWG.NO. SPEC. fJO.

Equipment i

3 i 5.17 ' Itain control neards (Seis:nic ca t.n;ory I Only) J-201 I i  !

3 5.18 lLocalControlr.:nels i j (Seismic (~'a '.. nory I Only) J-202 t

.! 3 5.19 Local Instronent Rocks

); i (Seismic Category I Only) J-203 3 5.20 Nuclear InaLcon entation and B&W 11-1.31

.f Reactor Protection Systems (C S-2-18)

I 3  ! 5.21 Engineereil S.:Ccty Features

.! l Actuation Systeas

• J-207 i i I l t

i j  !

• ECCAS by n & W 11-1.32 I.

4 I

i I.

I i

i i

I f

6

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I l  !

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l ' - -

l' 7e ,k  :

CUALITY ASSURANCE PROGRAM l~ilj.'j#; )

PROJECT

SUMMARY

Q LIST FORM MLDLAD UNITS 1 and 2 Job f;o. EI.ECTPsICAL Page i of'_4 __

7??n_

! Y E st ggg.7;7y Eggip. Dys.

' SPEC.

R, .

., g ,  ! T E/ D E S C R I P T 10'4 PURCHASER *; 0 .

30 .

__3_.1 ;witchgent, Encr. Safecuards 3 3.101 4.16kV Swgr. Buses IA95 & E-5 E-29 2A05 E-6 t 3 3.102 4.1 R'.' St:g r . Cn e s 1A06 & E-5 E-29 i 2A06 E-6 i S t ation Pe .c r ir:mr. . . Digr.

3.11 Safemtards l

3.111 4160-430V Trans. 750 kVA 1X17 & E-ll 2X17 E-15 E-6 3.112 4160-480V Trans. 750 kVA 1X18 E-ll 2X18 E-15 E-6 3 3.113 4160-480V Trans. 500 kVA 1X15 E-ll 2x15 E-15 E-6 3.12 Load Centers , En:*r. Safeguards 3.121 480V' Load Center Euses- 1B17 & E-ll 2B17 E-15 E-6 3.122 480V Load Center Buses 1B18 & E-ll 2B18 E-15 E-6 3 3.123 480V Load Center Buses 1815 E-ll 2B15 E-15 E-6 Motor Control Center 3.13 Engr., Safeo,uards 3.131 Motor Control Centers 1B23 & E-11 2B23 E-15 E-7 6

3.132 Motor Control Centers 1824 & E Il 2B24 E-15 E- 7 3.133 Motor Control Centers 1B25 & E-11 l 2B25 E-15 E- 7 L\

7y-

, I 17 1 l / .'.

f ,_/[h, >/1/ 7 , nev! <ed and ':c issue.! (Fina!) Jb b ~ /-73 ['k'. a e !' l

.h._ 11/3/?0

' P R O.' . E ?.G . Pall ..hr r.

t .. 9 ?. r E Rr A s o!. rop ! s e tlE '

! *: ' o r p r. -  ;

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+ *

.' d QUALITY ASSU.~ANCE PROGRAM l l :';. sdN[.3 PROJECT SUf';1ARY Q LIST FORM l .~.'u.Y  !!!DLA!:n ti:HIS 1 and 2 i ELI:CTRICAL s,.

7220 p a s e _._2 of 4 1

I C E ,* T l iY '3 PURCHASER E C U I P . *;0. 0 W G . fi0. SPEC. rl0.

. 0.

3.134 Motor Control Centers 1B39 & E-11 2n39 E-15 E-7 3.2 Switchboards .s Panels i 3.241 120V Preferred ac Panels lYll & E-23

.I 2Y11 E-24 E-15 1 3.'a2 120V Preferred ac Panels ,1Y12 & E-23 I l 2Y12 E-24 E- l 'i 1

3 . ' ': 3 12CV Preferred ac Panels lY13 & E-23 e 2Y13 E-24 E-15 l

I

' 3.244 E-23

120V Preferred ac Panels 1Y14 &

2Y14 E-24 E-15 3.3 Raceeays Asneciated uith Enar. Safecunrds ( T R F711ation) 3.31 Conduit- (installation only)

E-42 Field 3.32 Cable Tray (installation only) E-42 Field g

3... Cabic Assoc ia t.el wi th Lngr.

Ri f e nua rdr.

1 i

l 3 . '+ 1 1 Tr ias

T ':t re vnt. C.>hle t_23

!j 3 . '. i 2 Coa >: . t i,.: t , nn,,n t ra til E- 2 '3

l l! 7.4!3 sh i e t ,ted Tr tr.nent C.iblo E-23 ll; y--- . . . - - -

• O

{I.N I, '] (UALITY ASSURA:tCE PROGRAM

l. .ilgjiU).3. .

i PROJECT

SUMMARY

Q L.IST FORM I ' :. .  !!IDLAND UNITS 1 and 2 7220 ELECTRICAL

,,9, 3 ,, __ 3

! E." IDENTITY ')

SPEC. t10.

,y-no. PURCHASER EQU I P . fic . DW G . fiO .

.l .

3.414 Thermocouple Extension Wires E- 23 3.42 600V Control Cable E-22 3.43 600V Power cable E-22 3.44 SRV Power Cable E-21 3.5 DC Emiinuent f3 I

3.51 125V Station Datteries ,0t;02A & E-20 OD02B E-21 E-12 l

3.R Battery Chargers 3.521 Battery Chargers 1D12A & E-20 2D12A E-21 E-ll 3.522 Battery Chargers 1D12B & E-20 2D12B E-21 E-ll.

3.53 AG InverrtTs 3.531 Inverter Channel #1 OY01A E-20 E-ll 3.532 Inver.ter Channel #2 OYO1B E-20 E-11 3.533 Inverter Channel #3 OYOlC E-21 E-11 3.534 Inverter Channel #4 OYOID E-21 E-11 3,54 DC Buses 3 125V de Bus 3.541 1D21 & E-20 2D21 E 21 E-13

3 3.542 125V de Bus 1D22 & E-20 2D22 E-21 E-13 )

3.55 125V de Distribution Panels

! 3.551 125V de Diste. Panel ID31 &

3 ~

E-20 3

. 2D31 E-21 E-13 l 6

l 3.552 125V de Distr. Panel ID32 & E-20

.; 2032 1:-21 E-13 3.6 Miscellaneous Elect. Ecufp.

iA 10,* f U 1 l

- -o - ..

~

f :j.] ' QUALITY ASSURAtlCE PROGRAM PROJECT SUMitARY Q L1ST FORM

, 2 2 '- 3j 'i;.I.;/

o -.

!!IDIMD U!iLTS I and 2 ELECTRICAL Pan 4 M. 4

. 3 s,. 72?O

..z '

ICENTIM PURCHASER EQUI P . fic . D W G . t:0. SPEC. FIO.

{ -} ,

.i0.

12" Penetrations for Pcuer E-20 l 3.611 .

\

3.612 12" Penetrations for Control E-20

3.613 12" Penetrations for Instrumen-tation E-20 a

1 i

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I I*

t .

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j

, ,' d g 'j). :! .3 QUALITY ASSUllANCE PROGRAM i

'{p

[N.' . #

-) PROJECT

SUMMARY

Q LIST FORM MIDLMD U!IITS 162

J.m No __7220 MECI!ANICAL/ PLANT DESIGN Page 1 of 14

[ I T E *AI. IbE NTITY

-)  ; ntv. ITEP.UDEZRIPTION EQUlP. DWG. SPEC.

. . O. PURCHASER g j.f;0-  !

N O. N O. N O.

4 i '

l3 400 ' !!iscellaneous Equipment I

- l'  ; 40011151  ! Reactor Building Crane (S) 11151 M-92

.j  !

i 40021151 Reactor Euildinn Crane (S) 1 . I 21151 M-92 l  !.00G!!52 3.us:f.liary Building Cranc (S) 0 II 52 M-93 i, 3 4001M12 I Ilydrogen Recombiners 1M12 A,B

. A !. L M-169 i

3 ;4002M12 11ydrogen Recombiners 2M12 A,B '!- 1 ' -

1 A&B 1 -

-! 3 i4001010 Emergency Diesel Generators jA&B 1G10 A,B M-18

!l!

l l

!! 3 l4002C10 Emergency Diesel Generators l 2G10 A,B M-18 lA&B l

i p3  !

l 40001.! Fuel' Transfer Tube Isolation Valves DCCL 3l Reactor Euilding Isolation System -

t (all penetration components not l addressed under other systems) l 3 I 400011 Reactor Building Isolation Valves 3 4000Q Reactor Building Penetration Piping 3 }4000Z Reactor Euilding Penetration Flued

[

g I? cads l

3 4000M Reactor Building Penetration  !

Supports & 11ani;ers 4

401 Reactor Coolant and Pressure I Control System, Unit 1 I.

4 i

,l '

i --

l. _ _ .l '

i

-l,..b_ .l 1 l i i ,1  !

! - { l

- . (mv. - ; - -

' l  !

l - l ,

f.i_[6/,l/73 RevisedandReiss_ued_by__B.A.P.C(Finali a' ll E V.

k. 'II-'SI[.1" _

_ f _ e. . . y tio. DATE REASOff FOR ISSUE PROJ. ENG. l DATE PJU C.I:in

. .al DATE

-.~ . . . . ~ .

ISSUED BY '

ArrnqvEn ny

~

,(.J.til<.. b[

(f. QUALITY ASSUR/ MCE PROGRAM PROJECT

SUMMARY

Q FIST FORM N}

' m u. 7220 , p.g. 2 e r, 14

/ IUf f PURCHASER EQUIP.NO. 0 W G . fl0. SPEC. fl0.

• o .

4011T51 Reactor vessel and IIcad B&W 1 T 51 , M-1.1 3 4011:193 Fuel Assemblies and Neutron Sources B&W l M 98 N/A 8

1 3 4011M51A Control Rod Assemblies B&W 1 !! 51A M-1.3 3 4011:151B A:cini rever Sheping, Rod Assemblies B&W 1 M 51B.  !!-1. 3

! 3 4011M51C Orifice Rod essemblies B&W 1 M 51C M-1.3 3 4011::31D Lumped Surnable Poison Rod 1 M51D Assemblies B&W M-1.3 1

!1*:'2 Control Rod Drive Pressure Tube B&W 1 M 52 M-1.A 4011E51 Steam Generators B&W 1E51 A,B M-1.6 A&B

i i 3 4011P51 Reactor Coolant Pump B&W 1 P 51  !!-1.7

A,B,C,D A,B,C,D l

! 3 4011FM51 Reactor Coolant Pump Motor Flywheel B&W Part of M-1.8 A,B,C,D PM51A,B,C, D

! 4011T52 Pressuri::er B&W 1 T 52 M-1.10 l3 r 4011Q Pipitig*^ B&W(Partial ) M-1.9 i DCCL l 3 4011W Valves ** B&W(Partial ) II-7.23 l M-1.11, ,

DCCL  ;

! 1 l

I 3 4011M Supports & 11 angers */ M-106 .  ;

402 Reactor Coolant and Pressure l _ Control Svste s Unit 2 4022T51 Reactor Vessel and I!ead B&W 2 T 51 11-1.1 l I

3 4022::98 Fuel Assemblics and 'eutron Sourcer B&W 2 M 98 t;/A I 4022:151 A Centrol Rod Assemblies B&W 2 !! 51 A M-1.3 3 4022:!51$ A::ial rouer Shapint; Uod Assemblies B&W 2 M 51 r M-1.3 i

i3 4022:151C Orifice 201 Assent: lies B&W 2 M 51 C M-1.3 I

4022:151D Lumped turnable Poison Road 2 M 51 r l1

Assemblies B&W M-1.3

l

,' 5.. .gj

• QUALITY' ASSURANCE PROGRAM r.i j ;':1 j PROJECT

SUMMARY

Q LIST FORM

. . _ .. s 1,

p.,, 3 ,, 14

.3 w. 7220 l -

, 10 m PURCHASER EQUIP.ic. 0WG . fl0. SPEC. *i 0 .

so.

4022M52 Control Rod DtIve Pressure Tube B&W 2 !! 52 M-1.4 4022E51 Steam Cencrators B&W 2E51 A,B M-1.6 A&B 4022P51 Reactor Coolant Pump B&W 2 P 51 M-1.7, A,B,C,D A,B,C,D l

j 3 Reactor Coolant Pump Flywheel B&W M-1.8 l

l 4022T52 Pressuri::er B&W 2 T 52 M-1.10 i

3 4022Q Piping ** B&W M-1.9 (Partial) DCCL 3 4022U Valves ** B&W DCCL

! . (Partial) M-1.27 3

3 4022:1 Supports & IIangers** M-106

~

1 l

j 403 Makeup and Purification System, i Unit 1*

2 h 4031T58 Makeup Tank B&W l T 58 M-1.15 t

' M-1.16 3 4031P5S  ?!akeup Pur.ps & fotors B&W 1P58 A,B,C A,B,C

, 3 4031E57 Letdown Heat E:-:citangers (tube side i B&W lE57 A,B M-1.13

! A&B I

j 3 4031Q Piping ** DCCL 3 40317 Valves ** DCCL 1

3 4031:t Supports & liangers** M-106 3 40317. Reactor Building Penetration Flued l M-lll IIcads 404 flakeup and Puri.f ication System, Unit 2*

4042T53  ::aheup Tank B&W 2 T 58 . it-1.15 l . ,

3 4042P58 Makeup Pumps & Motors B&W 2P58 A,B,C  !!-1.16 '

A,B,C

7 .

t

,71.3 QUALITY ASSURANCE' PROGRAM

• pil!.I[j] f PROJECT

SUMMARY

Q LIST FORM

~'

s:. :s zee .. 7220_ p.s. 4 o, 14 ITES '

l.

IU,; [!TV PURCHASER EQUIP.NO. D W G . fl0. SPEC. NO.

3 4042E57 Letdeun !! cat Exchangers (tube side.l B&W 2E57 A,B M-1.13 3 4042Q Pipinp** DCCL f 3 4 042h' Valven** DCCL l' 3. 4042?! Sup; orts & II. nnersi'- M-106 L

3 4042Z Reactor Building Penetration Flued

!! cads M-lll 406 Reactor Coolant Sample System

• 3 4060Q neactor Du11 ding Penetration Pipin;;

3 4060'? Reactor Building Isolation valves' I

3 4960'I Supports & !!anner

• M-106 3 4060Z Reactor Building Penetration Flued llead s - -

M-lll 407 Liquid Waste Management System

• 3 4070Q Reac~ tor Building Penetration Pipin: ,

3 4070') Reactor Building Isolation Valves 3 4070.'t Supports & flangers ** M-106 3 4070Z neactor Building Penetration Flued IIcads11-110,111 409 Waste Gas System

• 3 4090T9S Radwaste Gas Surge Tank 0 T 98 M-26 4090To9 Radwaste Gas Decay Tanks 0 T 99 M-26 A,n,c,n,t P -

A,n,c.n, E,

' ' ' ' ~

p_ ~ ~ - -

_ . _ _ _ _ _ _ _ _ _ . _ _ ~

.aen.

.i 1 !qh QUALITY ASSURANCE PROGRAM dN;, PROJECT

SUMMARY

Q LIST FORM rh i Q'/}'

rae, 5 e e _1_4__

n 'io. 7'20 _

PURCHASER EQUIP.NO. DW G . fl0. SPEC. f:0 .

no. '

3 4090Q Piping

• DCCL Valves ** - '

l 3 4090W DCCL 3 4090:1 Supports & It in2crs ** M-106 l

3 4000u .c.;,,ctor Building Penetration Flued M-111 He a J .;

410 Docav iteat Removal and Emergency Core Coolinn Svs tet,. Unit 1 410l P60 Decay Heat Removal Pumps & Motors B&W IP60 A,B  ? !- 1.17 3

) A&B l 410lE60 Decay Heat Removal Heat Exchangers B&W lE60 A,B St- 1.18

! A & 11 A

j 4101T63 Core Flooding Tanks B&W 1T63 A,B fi-1.19

! A & 11 i

3 4101Q Piping * :DCCL 4101W Valves *" DGCL f 3 3

4101M Supports & IInngers ** .M-106 l,

' 3 4101Z Reactor Building Penetration Flued M-lll itcads 411 Decay llent Removal and Emergency Core Cooline Svstem, Unit 2 4112P60 Deca:, Heat Removal Pwps & Motors B&W 2P60 A,Ti .t-1.17 A&B  !

4112E60 Decay IIcat Removal I! cat Exchangers B&W 2E60 A,B  : t-1.18 A&B l 4112T63 Core Flooding Tanks B&W 2T63 A,B :1-1.19 i A&B l i

1 l 3 4112Q Pipinc,* DCCL l 3 A 112'! Valves ** DCCL 3 4112:-! Supports & Ilangers ** M-106 3 4112Z nesctor Building Penetration Flued '!!-111 8 '!c ad s 412 Reactor Building Spray System, Unit 1 ,

f 4121P64 Reactor M tilding Spray Pumps & Potois IP64 A,B ' t - 5 !.

, A5M i

4121T71 Sodium Hydroxide Storar,c Tank B&W 1T71 'l-1.74

. 4121T72 Sodium Thiosul f ate Storage Tank B&W 1T72 '!-1.74 i*

41211' 7 L Sod ium lIydroxide Injec tion Pumps & B&W 1P71 A,B 71-1.74 A&B fia to rs

QUALITY ASSURANCE, PROGRAM g';hd -

PROJECT

SUMMARY

Q LIST FORM 640 he we. 7220 6 14 or ITEP P.E V , 10E? ITY NO. "* PURCHASER EQUIP.NO. DWG.MO. SPEC. NO.

4121P72 Sodium Tliiosulf ate Injection Pumps B&W i IP72 A,B -

?1-1.74 A&B & Ilotors 3 4121M64 Reactor Bitilding Spray liozzles :t-1.74 B&W IM64 A,B A&B 3 4121Q Piping **

DCCL 3 4121!! Valves ** DCCI, 3 412111 Supports & 11anners ** ;1-10c, 3

4121Z Reactor Building Penetration Flued 't-111 ficads 413 Reactor BuildlIig Spray System, Unit 2 4132P64 Reactor Building Spray Pumps & Moto.r s 'l-54 2P64 A,B A&B 4132T71 Sodiun Ilydroxide Sterage Tank B&W 2T71 ' ! - 1 7

l 4132T72 Sodium Thiosul fate S.torage Tank B&W 2T72 :t- 1. 74 4132P71 Sod ium. Ilyd roxide Injection Pumps B&W 2P71 A,B M-1 74 A&B & Ifotors .

4132P72 Soditm Thiosul Ente Injection B&W 2P72 A,B El-1 70 A&B Pump & !!otors j3 4132M64 Reactor Building Spray Nozzles B&W 4 2M64 A,B :t-1. 74 i A&D 3 4132Q Piping **

ncct:

3 413211 Valves **

DCCI.'

3 4132tl Supports & llannor3* *

't-106 3 4132Z Reactor Building Penetration Flued

.;_113 Ileads A l4 Fuel Pool Cooling and Purification 1 l Svntem*

3 4140Q Reacter Building Penetration Piping 3 4 t40N Reactor Building Isolation Valves

3 4140M Suprorts & Ilangers *

• 11-106 l3 41407. Reactor Building Penetration Flued ~M-lll lleads-416 Component Cooling Water System, Unit in 4161P73 Component Cooling Unter Pumps 1P73 A,B '1-52 A&D & Motors 4161E73 Component Caoling Water IIcat lE73 A,B 11-51 A & B-

- - - - =

Exchangers

l

[ .hj] QUALITY ASSURANCE PROGRAM l

PROJECT

SUMMARY

Q LIST FORM i- <j

( ~.ij?*.jild i ),

l

n ao . _,7._2_2 0 ,,,, 7 ,, 14 l

IiE" ICENTITY CWG.NO. SPEC. NO.

"EY. EQUIP.NO.

"0*

,, PURCHASER

! FO.

4161T73 Component Cecif og Water Surge Tanks M-26 1T73 A,B A&B 3 4161Q Pipin ' DCCL 3 4161U va l . " ne '. DCCL 3 4161:1 surports & II: ngers i  !!-106 1 4161~ "cactor Ruf1 ding Penetrotton Flued licads l

417 Com .inent Coalio/ "a'.er System, 1 Itnit 26 4172P73 Component Cooling Water Pumps 2P73 A,B M-52 A&B & Motors 4172E73 Component Cooling Water Heat 2E73 A,B M-51 s A&B Er. change rs j

1 4172T73 Component Cooling Water Surge Tanks 2T73 A,B M-26 A&B -

3 4172Q Piping *- DCCL 3 41722 Val.ves** DCCL 3 4172M Supports & llangers** M-106 3 4172Z Reactor Building Penetration Flued M-lll Heads.

4 13 Service Water Sy stem Cooling Tower and Poms*

4180P75 Service Water Pumps & Motors OP75 M-75 A,B,C,D,E A,B,C,D,E 3 4130F7> Service Water Strai.nors OP75 M-181 j

A,B,C,D,E A,B,C,D,E l 3 4130Q Piping ** DCCL 4

3 41802 Valves * 'DCCL l

l 3 41SO:t Supports & llangers ** it-lon

, 3 M-111 g 4180Z Reactor Building Penetration Flued a

licads 419 Service Water Systen Reactor and Auxiliary P.ci Id :n:; and Emergency Dierel cen.rntor, t

1 3 4190Q P i p int- .

DCCL 1

~

3 4190U Valves '

DCCL 3 4190:1 Supports & llangers

• M-106 3 4190% neactor Bui.1 ding Pene tration Flued . !!- 111 Ileads m.__

. . - - - = ~ -- - . . . = - -- . . . . . . _ . __ ..-

[.a'*,. QUALITY ASSUPANCE PROGRAM s

' ,pj!I.; {}'

PROJECT

SUMMARY

Q LIST FORM x ,, s-

3 .. 7220 8 en, or 14 IIE" REV.

ICENTITY t,0 . NO*

~

PURCHASER EQUIP.NO. C'4G.NO. SPEC. NO.

421- Reactor Eutidi.ng Penetration

, Prencuri::at.!"n .ind Seal Injection i Sys t er.s , '.'n i t ! ' i

! 4211141 3 Pre;surized Storage T. ink 1T41 3 4211T42 P.*nctration Pr w:;urtned Air 1T42 l'eceiver 3

4211Q Piping ** DCCL

, 3 4211'l Valves ** DCCL i 3 4211M Supports & IIangers ** M-106 l

?

422 Reactor Building Penetration Pressurination and Seal Injection Sys tem, 1: nit 22

a 4222T41 Pressurized Storac,e Tanle 2T41 3 4222T42 Penetration Pressurized Air 2T42

} Receiver l '

l 3 4222Q Piping ** DCCL.

i 3 4222U Valves ** - CCL i 3 4222M Supports & Hangers *

• i M-10.6 3

i

}

i 431 Main Sten:1 an.1 Turbine Steam j System, Unit 1 (frem Steam Gen.

thru R.B. Isolation Valves)*

3 4311Q Piping ':*

DCCL l3 4311W Valves ^*

PZL i

I 1 '111W

+

Safety Val.ven B&W 'i- I . ! '

,I 3 4311M Supports & llannern *f " 106

~

1 illl ?. Reactor Buildiun Penetration Flte d " l'l Head::

' ,N3D

.) QUALITY ASSURANCG PROGRAM

,j g.l;ld .J[.!

PROJECT

SUMMARY

Q LIST FORM r i. . e

,o w. 7220

. . . . _g o, _ i t> __

I l.

PURCHASER EQUIP.NO. DWG.NO. SPEC. NO.

!i i 43' "ain S can and Turbitic Stean

~l Systen, l'ni t 2 (Cron Steam Gen.

?

,th,r u R . S . Inclation Valves)*

.l 3 4322Q Pip Ing ** DCCL

! 3 4322'i Vc.1ve.4 *

• DCCL

.1 J

l -

3 4322W SaCety Valves B&W M-1.12 3 4322M Supports & IIant,ers * *

, 4t-106 3 4322% Reactor Building Penetration Flued M-111

^l. Ilcads .

i l 4J3 Au;;iliary Steart Sy;5 Leu, talt 1

) (frem Main Steam IIcaders thru ,

i Aux. F.W. Puno Turbines)*

1 j 3 4331Q Piping **

DCCII 3 4331W Valves ** DCCL 3 4331M Supports & !! angers ^* .M-106 f 434 Auxiliary Steam System, Unit 2

.j (f rom Main Stream llenders to Aux.

{ F.W. Pump Turbines)*

1 1

3 Piping **

4342Q 'DCCL 3 43'i?N Valves ** 'DCCL-1 l

3 4352'i Supports & I! angers"

• M-106 t

l l

1 l l' 43S Feed'. ater and condensate Sys tem

' i Unit 1 ('t:lin F.U. Piping it.~i l

Steam Cen, to R.i!. Iselatica l Valves , Aux. F.U. Piping 6 Piping l fron Service Water Svs. to Aux.

I F.tl. Pump Suetlon)_^

n-~ --

m_ __ __ -

s e.. .

,b.ifi] QUAL 1TY ASSURAtlCE, PROGRAM PROJECT

SUMMARY

Q LIST FORM bl.cf./

I pia, 10 er 14

!:o 3. 7220 ,

IIIE" IDENTITY

') EQU!P.NO. DWG.NO. SPEC. NO.

Pl!RCH AS E R

!?EV. NO*

! *. 3 . _

1 4381P05 Auxiliary Fecdwater Pumps & Drivers , 1P05 A,B

• M-14 j A & P. (Turbine and Electrical) 1 DCCL

3 4381Q Piping **

l, DCCL 3 4381U Valves **

Supports & I!ancers^t M-106

!3 43SIM

,i

', 3 4331Z Pcacter Buildine Penetration Flued Heads M-111 439 reedwater and Conlenaate System l'nft 2 (Main F.U. Pipin;; f rom jl Steam Cen. to R.B. Isolation Valves, Aux. P.U. Piping & Piping j

from Service U. Iter Sys. to Aux.

F.W. Purn Suetion)*

'i 4392P05 Auxiliary Feedwater Pumps 5 Drivers 2P05 A,B M-14

A&B i

Piping ** DCCL f 3 4392Q Valves ** DCCL 3 4392W I 3 4392M Supports & IIangers** M-106 3 4392Z Reactor Euilding Penetration Flued Heads M-111 452 Emergency Diesel Fuel Oil System 3 4521T77 A3 Emergency Diesel Oil Day Tanks 1T77 A,3 M-26

'S22T77 i A,! Emergency Diesel Oil Day Tanks 2T77 A,P, M-26

!' , 3 3 '.521T78 A,1 Emergency Diesel Oil Storage Tanks 1T78 A,D 'f-71 4

3 4322T78 A,I Emergency Diesel 011 Storage Tanks 2T78 A,B !i-t 3 iS21P78 A,1 Diesel 011 Trancfor Pumps IP78 A,3 M-24 I

,3 iS22P78 A,1 Diesel 011 Transfer P' imps 2P78 A,B M-24 j

PCC f.

3 4320Q P i p i ng,*

• 3 4520W Valves ** DCCL f

1 4520:1 Supports & Panr.ers** M-lim 1

I . __ -- _ . - .

~~

L

, ' ' ' .- .,M QUALITY ASSURANCE PROGRAM ygJrl PROJECT

SUMMARY

Q LIST FORM r- ... -

n se. 7220 *

,y, 11 ,, 14

';

• PURCHASER EQUIP.?;0. Ok'0. tio . SPEC. NO.

'. 0 .

453 Reactor lilde. Ventf altion System

• 4331VM56 Reactor n111 ding Cooling Units IV!!56 M-163 A.B,C,D A,B,C,D 4531U57 Reactor Building Cooling Unit Fans IVV57 M-157 A,B,C,0 A,B,C,D 4532VM56 Reactor Building Cooling Units 2VM56 M-163 A,ll,0.D A,B,C,D 4532VV57 Reactor Building Cooling Unit Fans 2VV57 M-157 i A,B,C,D A,D,C,D 3 4531VV55 Reactor Eutiding flydrogen Vent Fan IVV55 M-157 3 4532VV55 Reactor Building Ilydrogen Vent Fan 2VV55 M-157 4531VF60 Reactor Building.Ilydrogen Vent Pre-Filter ,, IVF60 M-162 4532VF60 Reactor Building Ilydrogen Vent Pre-Filter 2VF60 M-162 4531VF61 Reactor Building flydrogen Vent ilEPA Filter IVF61 M-162 4532VF61 Reactor Building flydrogen Vent ilEPA Filter 2VF61 M-162 4531VF62 Reactor Building Ilydrogen Vent Cliarcoal Filter IVF62 M-162 4532VF62 Reactor Building !!ydrogen Vent Charcoal Filter 2VF62 M-162 3 4531VE51 Reactor Building flydrogen Vent licating Coil IVE51 M-166 4 3 4532VE51 Reactor nuilding liydregen Vent Ileating coil 2VE51 M-166 3 4531VD Reactor Unilding Daupers** tt-151 1

3 4532VD Reactor thiilding D.wpern**

!!-151 3 4531VD Reactor IIuild f ug Doctwork and i

Supportul*- M-151 l 3 4532VD Reactor nullding. Ductteork and l

Supportai*  !!- I " 1

~. .

..} f ..

..*!,. QUALITY ASSUFAt4Cd PROGRAM g;:'d!I;j,]

P  !.. 5 PROJECT SUt* MARY Q LIST FORM

• W ha' - 17 o' _14_

__ -70 2 0-s.

't .

I0fp PURCHASER E QU I P . te 0. DW G . t:0. SPEC. f,C.

• S 4531U Reactor Building Purgc Valves **  !!-168 4532U Reactor Building Purge Valves **  !!-168 454 Auxiliary liutiding Ventilation System

• 4540t!01 OVitol tt-160 A&B Control Roon Air llandling Units *** A, B 4540VV03 OVV03  !!-159 A&B Control Roem Surely Fans *** A, B 4540VF01 '

OVF01  ?!-162 A&B Control Root Supply Pre-Filters *** A, B 3 45407F02 Control Room Supply Prc-Filters *** OVF02  !!-162 4540VF63 Control Roem Supply llEPA, Filter *** OVF63  !!-162 4540VF51 Control Room Supply Charcoal OVFS1 FI-162 Filter ***

4540Vi!52 Conponent Cooling Unter Pump Room OVitS2 FI-160 Air liandling Unit 4541Vil52 Component Cooling Water Pump Room IV1152 FI-160 A&B Air llandling linit A, B 4542V:tS2 Cerponent Cooling Uater Pump Room 2V:152  ?!-160 A & P. Air IInndling I' nits A, B -

3 4541V 154 Auxiliary Feod. tater Pump Room IV:tS4 it-160 A&B Air llandling 1' nits A, B 3 4542V:!54 Auxiliary Fecdw tcr Pump Room 2VII54 FI-160 A&B Air llandling Units A, B 4541V:!55 1:ngineered Safeguards rump Room 1VitS5  !!-160 A&B Air llandling Units 4 5',2V 155 Engineered Safecuards Pune Room 2VitS5 it-160 A&B Air llandlint, l'ults 4540VV53 Dicsci Cenerator Room 1:xhaust Fans OVV53 tt-165 A,B,C,D A,B,C,D 4541V~ Battery Room Exhaust Fans t!-165 4542V Unttery Roort Exhaust Fans  ?!-165

• • * =c___ -p .,

J ' , ,, -

. ;! ) QUALITY ASSURANCd PROGRAM PROJECT

SUMMARY

Q , LIST FORM J n Ns. 7220,

,, 7 _.1 3 _,, __14 ITEM 10 E f1 T ! TY

, 'f - t;o , PURCHASER E00!r.t:0. DW G . rt o . SPEC. flo.

3 4541V!:05 Switch Cear Roon Alr llandling Units IVM05 . of-160 A&B AR 3 4542Vt105 Suitch Gear Roon Air llandling Units 2VM05 ot-160 A&B A, B 3 4540V?t02 Cable Spreadinn Roon Air IIandling OVM02 it-160 Unit 3 4540Vit03 Cable Spreading roon Air Handling OVM03 71-160 Unit 3 Service Water Punp Structure Sf-165 Exhaust Fans 3 Diesel Generator Room Dampers ** 't-151 1 Service Water Pump Structure Dampers ** PI-151 3 Diesel Generator Rona Ductuork

& Supports ** -

' t-151-3 Service Water Pomp Structure Ductwork & SuProrts** :1-151 457 Chilled Water System

• 45 70VP02 Auxiliary Building Chilled Water OVP02 T1-154 A&B Pumps *** A, B 3 4570Vf159 Auxiliary Build tug train Chiller *** OVil59 ft-155 A&B A,' B 3 4570Q Piping ** DCCL 3 4 570'.1 Valves ** DCCL 3 4570t! Supports & llangers** .f t-106 3 4570Z Reactor Building Penetration Flued 11-111 lleads NOTES:

3

• Seismic Class I Portions 3 ** Actual _Q-valven, dmnpers and lines

..33 ~,,..,, _ - -

s-

,I ' o .' e QUALITY ASSURANCE PROGRAM s :gi:l!{jj.)

f PROJECT SUMitARY Q i.IST FORM

):

f* .. M20 y

,,g, 14 ,,

r !_.

i; l ," '*I .l,"10Er4T!TV t;0. PURCHASER E 0V ! P . f;0. D WG . !10. SPEC. .*;0.

I -

1

} (NOTES Con't.)

, i j will 1 c indicated on the synten 8

Pt.TD and ripine Clar.s Sunmary Sheets.

,!' 3 *** Only cssured for Control Room Energency ventil stica.

3 DCCL Bechtel Desic,n Control check List.

h' hen indictted in " Spec No."

colurn the DCCL should be used in conjunctinn with the appropriate PLID to datermine which piping or valve specificatien applies. ,

(S) Seismic I for Structural Integrity only.

e e

% ~

~, ,

• EXHIBIT 12 (b) and 12 (c) - 1 DOCUMENT CODE DATE DOCUMENT CODE DATE NCR C-1-1 7-12-73 NCR C-47 C-2 1-21-74 9-7-73 C-48 1-21-74 C-3 9-12-73 C-49 C-4 1-21-74 9-28-73 C-50 (R.1) 1-24-74 C-5 9-28-73 C-6 C-51 (R.1) 2-8-74 1 0-4-73 C-52 2-8-74 C-7 1 0-8-73 C-53 1-29-74 C-8 10-8-73 C-9 C-54 (R.1) 2-4-74 10-29-73 C-55 1-28-74 C-10 10-29-73 C-56 2-4-74 C-ll 11-8-73 C-57 2-4-74 C-12 11-2-73 C-58 C-13 2-13-74 11-19-73 C-59 2-13-74 C-14 11-16-73 C-60 C-15 2-14-74 11-16-73 C-61 2-14-74 C-16 11-16-73 C-62 C-17 2-14-74 11-21-73 C-63 2-14-74 C-18 11-23-73 C-64 C-19 2-18-74 11-29-73 C-65 2-18-74 C-20 11-29-73 C-66 C-21 2-21-74 11-28-73 C-67  ?-21-74 C-22 11-29-73 C-68 C-23 74 11-30-73 C-69 2-22-74 C-24 11-30-74 C-70 C-25 2-22-74 12-3-73 C-71 375-74 C-26. 12-5-73 C-72 C-27 3-4-74 12-5-73 C-73 3-6-74 C-28 12-5-73 C-74 C-29 3-11-74 12r12-73 C-75 3-11-74 C-30 12-12-73 C-76 C-31 3-14-74 12-12-73 C-77 3-18-74 C-32 12-14-73 C-78 C-33 3-19-74 12-12-73 C-79 3-20-74 C-34 12-18-73 C-80 C-35 3-20-74 12-19-73 C-81 3-22-74 C-36 12-31-73 C-82 C-37 3-27-74 12-20-73 C-83 3-28-74 C-38(A) 1-9-74 C-84 4-5-74 C-39 12-18-73 C-85 C-40 4-5-74 1-3-74 C-86 4-11-74 C-41 12-20-73 C-87

~

C-42 4-18-74 12-20-73 C-88 4-17-74 C-43 1-4-74 C-89 C-44 4-24-74 1-15-74 C-90 4-25-74 C-45 1-19-74 C-91 C-46 4-30-74 1-21-74 C-92 5-8-74 C-93 5-10-74

"." DOCUMENT CODE DATE DOCUMENT CODE DATE MCAR-1 9-11-73 QAF E-2-9 9-5-73 2 12-11-73 10 9-5-73 3 12-7-73 11 9-5-73 4 12-10-73 12 9-5-73 5 2-5-74 13 9-5-73 6 5-2-74 14 9-5-73 15 9-5-73 16 9-5-73 CNCR-QF-1 11-9-73 17 9-5-73 QF-2 12-6-73 18 9-5-73 QF-3 1-16-74 QAF E-3-1 11-5-73 QF-4 1-16-74 2 11-5-73 QF-5 1-25-74 3 11-5-73 QF-6 1-23-74 4 11-5-73 QF-7 2-6-74 5 11-5-73 QF-8 2-19-74 6 11-5-73 QF-9 3-5-74 7 11-5-73 QF-10 3-28-74 8 11-5-73 QF-11 4-74 9 11-5-73 QF-12 4-1-74 10 11-5-73 11 11-5-73 12 11-5-73 QAF E-1A 001 5-14-73 QAF E-4-1 2-28-74 002 5-14-74 2 2-28-74 003 5-14-74 3 2-28-74 004 5-14-74 4 2-28-74 005 5-14-74 5 2-28-74 006 5-14-74 6 2-28-74 007 5-14-74 7 2-28-74 008 5-14-74 QAF C-1 001 7-17-73 009 5-14-74 002 7-17-73 010 5-14-74 003 7-17-73 011 5-14-74 004 7-17-73 012 5-14-74 005 7-17-73 QAF E-1B 001 5-14-74 006 7-18-73 002 5-14-74 007 7-18-73 003 5-14-74 008 7-16-73 004 5-14-74 009 7-17-73 005 5-14-74 010 7-17-73 006 5-14-74 011 7-16-73 007 5-14-74 012 7-17-73 008 5-14-74 013 7-17-73 009 5-14-74 014 7-16-73 QAF E-2-1 9-5-73 .

015 7-16-73 2 9-5-73 QAF C-2-1 10-25-73 3 9-5-73 _ 2 10-25-73 4 9-5-73 3 10-25-73 5 9-5-73 4 10-25-73 6 9-5-73 5 10-25-73 7 9-5-73 6 . 10-25-73 8 9-5-73 *7 10-25-73

- 1.

r l

DOCUMENT CODE DATE DOCUMENT CODE DATE QAF C-2-8 10-25-73' QADR CVN-7 5-2-74 9 10-25-73 CA-5 5-20-74 10 10-25-73 11 10-25-73 12 10-25-73 13 10-25-73 14 10-25-73 15 10-25-73 16 10-25-73 17 10-25-73 18 10-25-73 19 10-25-73 20 10-25-73 21 10-25-73 22 10-25-73 23 10-25-73 24 10-25-73 25 10-25-73 QAF C-3-1 1-28-74 2 1-28-74 3 1-28-74 QAF C-4-1 2-20-74 2 2420-74 3 2-20-74 QAF C-5-1 5-1-74 2 5-1-74 3 4-30-74 4 5-1-74 5 5-2-74 6 5-2-74 7 5-1-74 QADR 001 2-5-74 002 2-5-74 003 2-5-74 004 2-6-74 005 2-13-74 006 2-25-74 007 3-28-74 008 4-29-74 QADR CA-1 3-18-74 CA-2 3-20-74 CA-3 3-21-74 CA-4 3-21-74 CVN-1 4-9-74 CVN-2 4-10-74 CVN-3 4-11-74 CVN-4 4-15-74 CVN-5 4-30-74 CVN-6 5-2-74

DOCUMEIR CODE DATE DOCUMETE CODE DATE NCR 0001 9-14-70 NcR 0045 10-23-70 0002 9-14-70 0046 10-23-70 0003 9-14-70 0047 10-27-70 0004 9-14-70 0048 10-27-70 0o05 9-14-70 0049 11-6-70 0006 9-18-70 0050 11-5-70 0007 9-19-70 0051 10-19-70 0008 9-24-70 0052 10-26-70 0009 9-25-70 0053 11-9-70 0010 9-26-70 , ooy4 11-16-70 0011 9-28 0055 11-24-70 0012 9-28-70 0056 11-25-70 0o13 9-29-70 0057 11-25-70 0014 10-2-70 0058 11-27-70 0o15 10-2-70 0059 12-2-70 0016 10-5-70 0060 12-2-70 0017 10-5-70 0061 12-2-70 0018 10-5-70 0062 12-7-70 0o19 10-5-70 0063 12-7-70 0020 10-5-70 0064 12-7-70 0021 10-6-70 0065 12-8-70 0022 10-8-70 0066 12-8-70 0023 10-12-70 0067 12-14-70 0024 10-20-70 0068 12-14-70 0025 10-27-70 0069 12-14-70

0026 10-27-70 0070 12-14-70 0027 '

11-2-70 0071 12-15-70 0028 11-2-70 0072 12-16-70 0029 11-2-70 0o73 12-16-70 0030 11-2-70 0o74 12-18-70 0031 10-27-70 0075 Not Issued 0032 10-27-70 0076 Not Issued 0033 10-27-70 0077 Not Issued 0034 10-27-70 0078 Not Issued 0035 10-27-70 0079 12-21-70 0036 10-27-70 0080 12-21-70 0037 10-27-70 0081 12-21-70 0038 11-2-70 0082 12-21-70 0039 11-2-70 0083 12-22-70 0040 11-2-70 0084 12-22-70 0041 10-24-70 0085 12-22-70 0042 10-28-70 0043 10-30-70 0044 10-27-70

o ,.

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[. Inter-office Memoran ' ' '

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To Ann Arbor Office Staff Feeting Attendees p

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Sub;cct ~F p, g,;Cg331dj i, QA/QC .'!,,,

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! t'  ;[..'__.'.L' C00'es to R. D. Allen .

Ia' --Ann ~A'rbor Office A. P. Yates l J. Morowski E. J. O'Connell

H. O. Reinsch I

i It is not possible to sufficiently emphasize the importance of QA/QC in all of our nuclear work.

We have been accused of " foot-dragging" by the AEC and the Client in the case of the Midland Job. Below listed are steps that must be taken so that our lj QA/QC program is effective.

3 (1) Provide Immediate Response It is imperative that an immediate response be made to each and every QA finding. The response may be a complete response or it i may be a promise to take corrective measures by a given time. It is very important that we can produce the paper that shows that we have immediately acknowledged the problem and have a program for I correcting it.

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! (2) Seek Help in Responding n

j The Quality Assurance Department is available and prepared to help 8 any of our people who are not certain as to how to correctly respond f to any quality related findings coming from auditing groups (i.e.,

Bechtel, /sEC, Client).

4[ 1 (3) Follow-l'p

( As a correlary to the above. it is important that each department 1 have a foolproof follow-up system that will insure that corrective measures are taken within the tirac f race specified.

f tj Proper performance of our QA/QE/QC responsibilities is the most critical subject

- facing us this year. It is important that this message be transmitted to O Bechtel people roughout our projects.

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, EXHIBIT 14(b)-)

( , , Bechtel PowerCorporation R. D. Allen / ,

interoffice Memorandum R.D.A.

I. R. Caraco ~ '

g to C. D. Statton om December 14, 1973 7g saya Reporting Important QA/QC From H. O. R einsch -

Problems

• I of Thermal Power Management

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cen io H. F. B rush .W. E. Ferris s At 50 Beale Street R. M. Collins W. S. Gibbons ll/B-7 Ext. 6204 W. K. Davis R. T. Hamilton K. O. Taylor Ib Ibsen J. B. Loth ,

T. I. McHugh L. E. Stromberg G. B. Grable J. M. Varela The growing awareness and rapid dissemination of Quality Program problems detected by AEC and others makes it increasingly important for us to keep Management advised of important issues as soon as they a re identified. The following instructions will become a part of TPO Quality Program Policies and should be placed into effect immediately.

Wheneve r a significant QA/QC problem is detected by A EG, nccht el Client, or Bechtel personnel concerning Bechtel, Bechtel Subcontractor -

or Supplier, a brief written report shall be submitted b'y the Project Manager or his designee to the cognizant Division Manager. Informa-tion copies shall be sent to the cognizant Manager of Projects, Department Manager, QA Manager, and the Manager of Quality Assurance-TPO. This report shall describe the problem; how it was discovered and by whom; indicate other documents that may report the problem, such as reports to or by AEC or press releases; and indicate the immediate remedial action underway or planned. A schedule for completing this remedial action and a description of the types for formal reports to be prepared shall be included. The report shall be submitted no later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after discovery of the condition.

The Manager of Quality Assurance, Thermal. Power Organization, should be advised by telephone as soon as possible'whenever the occurrence may have serious adverse affects on relations with the AEC, Pnblic, or Client.

When considered necessary, the Project Manager should-also advise the -

cognizant. Manager of Projects by telephone.,

p.

- '..ie Auurvasees b8L. .ai;i r'OWef Corporation December 14, 1973 8 Page 2 4

d The Manager of Quality Assurance, Thermal Power Organi::ation, will be responsible for advising appropriate TPO Management.of these problems as necessary.

)bbn y H. O. Romsch HOR:SAB:mm I

. ._ - - -- ~.

' EXHIBJT 14(b)-4 Bechtel Power Corporation i t

Interoffice Memorandum a

'o Distribution om. Februa ry 4, 1974

, sueci QA/QC Organization from H. O. Reinsch of Thermal Po ver Management cmes i, M 50 Beale 11-B/7 Eochtel has consistently required that personnei performing Quality Assurance and Quality Control functions have sufficient authority and independence to carry out these functions and assure a quality job. We have also recognized the need for teamwork and close coordination on projects and for effective use of persnnnel.

In the past few years, a number of organizational relationships have been empioyed by our Divisi,ons to achieve these goals.

While many of these have been effective, including those currently in use, we have determined that a single, uniform approach, unless

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specifically e':empted, must be adopted and incorporated in all work performed by the Power Divisions for projects in the United State s. .

The key elements of this standard approach are:

1.

Quality assurance administrative personngl on projects shall receige supervision and technical direction through the Division Quality Assurance Manager.

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2. Quality Control personnel on projects shall receive admini-strative supervision and technical direction through the Division Chief Field Quality Control Engineer.

j 3. The relationship between Project Managers and Project

) Quality Assurance Engineers shall be defined as Coordination.

Project Managers will not direct project Quality Assurance pe rs onnel.

I 1 Administrative supervision includes hiring, assignment, and salary administration.

2 Technical direction includes positive mandatory direction prescribing the procedures and practices to be followed.'

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w Distribution Feb rua ry 4, 1974 i

/ 4. The relationship between Project Field Constructi*on Managers (or Project Superintendents) and Project Field Quality Control Engineers shall be defined as Coordination. Project Field Constructiun Managers will act direct project Field Quality Control personnel.

} 5. Organization charts will illustrate that the relationship of QA and QC to the Project Managers and Project Construction Managers is different than that for other personnel.

Effective within 30 days, all projects unless specifically exempted by the Division Manager shall meet the requirements of this memo.

Projects exempted will be individually reviewed by Division Manage-ment and the Manager of Quality Assurance to determine whether some of these requirements shodld be incorporated.

The Bechtel Topical Report on Quality Assurance will be revised to show these relationships.

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EXHistT W(b)~5 '

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9 9 Bechtel F otuer Corporation Inter-office Memorandum IMtc December L4, 1973 To E. E. Felton QA/QC - Midland Project 7220 r enm J.T. Marvin ats;. ci Of Construction Cepesto A. P. YatCs A: Ann Arbor P. R. Cassidy M. M. Krout Further to several telephone conversations uith you on December 10, 11, 12 and 13 concerning measures we must take to improve our proccdures and atti-tudes concerning QA/QC on the Midland project, listed belou arc improvements to be made ittediately if they are not already made:

1. Provide procedures (instructions or work plans) in addition to the field inspection plans for selected processes. Plans needed t.'ill be agreed upon uith Consumers Power Company prior to their impic-mentation.

2. Additional emphasis on pre-planning of quality requirements of selected work processes. Pre-planning to identi fy and prepare the required procedurcs, instruction, inspection plans, specifi-cations, drawings, etc., to be used in the work operation.

3. Although our inspectors are qualified by constructica training programs, past work history and education, certification of these inspectors will be performed.

4. Intensify efforts in the training of field quality control personnel, field engineers and craftsmen.

5. Implement an action program to provice timely and adequate response to Quality Assurance / Quality Control findings.

6. Establish a written reporting system to apprise management of quality operations.

7. Added quality assurance personnel at the project site to assist in the interpretatian of the quality asuurance requirements.

8. Additional management and supervisory personnel attention until the foregoing items have been accomplished.

l.

- Bechtt,, Power Corporation

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. JDI to El:P 12/14/73 .

As you kncu, Construction Methods in Ann Arbor han been workinr, since December ILon a plan to implement a pror. ram which covers Iten 2 above.

In addition. I have revietted certain instructions and work plans in San Francisco ubicis may be implemented on selected proces.scs ns defined in Iten 1.

These, of course, as well as other selected itenn will be im-ple mented at Midland with the concurrence of the client.

On December 19 I will be vis,iting your project for two specific reasons: .

(1) to confirm that you and your pernonnel have a complete understanding of the measures described herein and (2) to revicu chose additional pro-cedures as outlined in this letter that you have or arc implementing.

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E . E . 11.1 Lon deh 72?O flidland Project r,..., J. 1. !L.r in QA/4C l'iciland !! nits 1 f. 2 g, Con!. t rin. L inn c., c , , , A. Yates e' Ann Arline

p. Cassidy ti. Kroul .

Subsequent to my c:cn:orair.iuui to you da tcd Doct; n r l ?. , l 'i / 3, o ' m. i n :

mecsui cs un are t a!.ing to Nprou.. procn'h:v es and alti tu. <ini -

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the fjl',/CC progre:'.'. nn the liidlar.d Pi oject. T h i . f.:  :: r, m . i' i:

' . i t.o identify and clarify those iLeas thal require :.pacia1 cnj w .Linui: '

cons ide ra ti on .

(1) Soecial '.'ori: Processes A 'aore forinalized progcc:q .till be ins ti tu t I in

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re,,Jirv:?nts for spcc ial uoch pencenc.s. lhi< pn -

coas t.i tui.es t he basic pre-plennin<j of i:ny 'i; yr '. i c i till it . . . ,

the req'lired procedures, ins truction- cc ..ork pic i , i n:., .i.: n plans, specificc tions and drcuin<:s rc.psirc.' Fo r ...: c , t h i ', '.. _

planning opera t. ion vill assis t in i6nii f >ir.u /i. ...'.o : c. '

specified requircnonts, as required by th eig 6.c n trit. -ic, ci 10CI R-50, /,ppendix 0, such as Field Ch:'np keim ;L . :i A) and l'on-Conformance Reports (i!CRs) . This pro: .-'

il i n';1 c a revie.. of all v;ork functions to d"t ar

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special t;ork processes. A lis t will be pr.'p:. red br revi by Con .uc:ers i'ouer C(,:':pa ny . Appreitriate .ork plar" ill tiro Le prepared and revie cd uith Conse 3r: Power Co. .p..r.; prior to proceeding uith t.he work.

(2) Ch.unied Inspeciion P,c .ponsibili tie: .

Previously, sm;c verificat. ion in vectionn ' ere pr r f oi . d by field em.lincers. l'au all jobr.i te (pul i: V er.u p ur ~i-fication in".poc tions ( for sa fc ty i ela t ..d

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only by qua1iLy control enginters. L.u,i l i ty "rifim'i' . i: - -

tion consis t.c of the uc.cl process th.it innure, th t th - >',+ N process is construc ted in accord.ince vi th the appl ic..hle p i m ' '. ,

docu':lents , speci f ica tions , al.d Codes , at:d incl uis the appru;n 4 a l e '

do CU;aen la t. i on .

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i.n . ni.i u ni u njy,..-inni E. E. Tel ton Deceinher 19, l'1/3 (3) pesjpnse_,to_qjpli ty Find ijgif.,

Implement an action progrm.: to provide n: ore timely response to quality assurance / quality cont.rol findings, unim) a reviscil procedure for identifyinn, reporting and resolving non-confni.:i. nces.

'Section G3 covering Hon-Cenformi:nces in 'the Cechtel field Inspe -

tionsManual is under revision. This revised precedui e provida for increased control over the precessing of non-confononces and inspection findings by quality control and quality assurance per-sonnel and for more timely and action oriented reporting of non-conformances to engineering and quality assurance personnel.

(4) Organizational Changes Organizational changes have been made to provide additional coverage for quality control operations. A Quality Control S01:ervisor, responsible for Ann Arbor quality centrol operations, Z. G. Tuchce, has been added to our Ann Arbor Difice. The forner Proicct Field Quality Control Engineer has been replaced by J. P. Connolly, t:i:o reports directly to Z. G. Tuckcr. This latter change was rcquired to support the increased quality control inspection responsibilitics described in Item 2. These new personnel, along with m mbers of the construction organization, have intensified efforis in ficid quality training. To insure the adequacy of training, a training sessions coordinator, L. R. Albert, has been assigned in the job site quality control organization.

, (5) I'nspectar Certification Although our inspectors are qualified by training proorms, past work history and education certificction of these inspectors uill be performed in accordance with a writi.cn proccdure ccvering the qualifications, indoctrination, training, testing and certifica-tion of quality control personnel to emet the require:,mnts of ANSI Standard N45.2.6 and the AEC Regulatory Guide 1.50.

On December 20, 1973, I will review the status of progress regarding the above items and work that Construction Methods in Ann Arbor has been doing since Decembe. 8,1973, with regard to item 1, Special 1.'ork Processes.

This review will be made with all of your I:cy project personnel. I would appreciate your scheduling this review meeting for the af ternoon of

~

December 20, 1973.

-fy.,,C J. T. Marvin JIM /jm

/

UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of )

)

CONSUMERS POWER C0:@ANY ) Construction Permit

) Nos. 81 and 82 (Midland Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the attached " Answers of Bechtel Power Corporation and Bechtel Associates Professional Corporation ('Bechtel')

to Saginaw Interrogatories" dated May 22, 1974 in the above captioned me.tter have been served on the following in person or by deposit in the United States mail, first-class, or airmail, this 22nd day of May, 1974:

Secretary (20) John G. Gleeson, Esq.

U.S. Atomic Energy Commission- Legal Department Attn: Chief, Public Proceedings The Dow Chemical Company Branch 2030 Dow Center Washington, DC 20545 Midland, MI 48640 James P. Murray, Jr. Michael I. Miller, Esq.

Chief Rulemaking and R. Rex Renfrow III, Esq.

Enforcement Counsel Isham, Lincoln & Beale U.S. Atomic Energy Commission One First National Plaza - 42nd Floor Washington, DC 20545 Chicago, IL 60670 Michael Glaser, Esq. .Lester Kornblith, Jr.

1150 17th Street, NW U.S. Atomic Energy Commission Washington, DC 20036 Washington, DC 20543 Dr. Emmeth A. Luebke Myron M. Cherry, Esq.

U. S. Atomic Energy Commission Jenner & Block Washington, DC 20545 One IBM Plaza Chicago, IL 60611 P.' Robert Brown, Jr. f I

.