ML20042C751
| ML20042C751 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/01/1982 |
| From: | Bain R PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20042C752 | List: |
| References | |
| NUDOCS 8207140401 | |
| Download: ML20042C751 (34) | |
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION e
3 4
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 7
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)
8 In the Matte tof.____,.
)
Docket No. 50-275
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9 PACIFIC GAS AND ELECTRIC
)
COMPANY
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(Low Power Proceeding) 10
)
(Diablo Canyon Nuclear Power
)
11 Plant, Unit No. 1
)
)
12 13 14 AFFIDAVIT OF RICHARD S. BAIN 15 16 STATE OF CALIFORNIA
)
)
ss.
17 CITY AND COUNTY OF SAN
)
FRANCISCO
)
18 19 20 21 The above being duly sworn, deposes and says:
22 23 1.
My name is Richard G.
Bain.
I have been Manager of Station Construction and have had responsibility 24 25 for the construction of Diablo Canyon Nuclear Power Plant 26 since 1975.
Prior to my appointment as Mt. nager, Station "n7140401 820707 r u..
DOCK 05000275 C
1 Construction, I was the Station Construction Superintendent 2
at PGandE's San Francisco General Offices, and was assigned direct supervision of all construction activities, including 3
4 supervision of construction contracts for Diablo Canyon from 5
its inception.
A summary of my experience and responsibili-6 ties is contained in Attachment A.
7 2.
I have carefully read the affidavit-of Mr.
8 Richard B.
Hubbard dated May 24, 1982 filed with Joint 9
Intervenors Motion dated June 8, 1982.
I will address my 10 comments specifically to Mr. Hubbard's allegations of an 11 inferred " breakdown" of quality assurance and quality 12 control in the construction and installation of equipment 13 and apparatus at Diablo Canyon.
As I will comment 14 hereinafter, PGandE had in place a comprehensive and 15 vigorous on-site construction quality assurance / quality 16 control program.
This program was subjected to numerous 17 internal and NRC (AEC) audits during construction activity 18 at Diablo Canyon.
No such " breakdown" occurred.
19 3.
There were three types of on-site procedures 20 and instructions that were developed and applied at Diablo 21 Canyon to provide the requisite direction for these actions 22 and activities necessary to assure design and quality 23 requirements being in conformity with the Quality Assurance 24 Program.
They consist of:
25 a.
Quality control procedures to establish the s
26 control, direction and methods for acceptance of.
1 physical work performed by PGandE personnel and as 2
required by the Senior Site Representative to 3
control project activities affecting quality.
4 b.
Preoperational and startup test procedures to 5
assure that systems and components meet design 6
requirements.
To the extent feasible, test 7
procedures incorporate approved plant operating 8
procedures and provide for testing of items under
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9 simulated operating conditions.
10 c.
Field instructions developed by the Resident 11 Engineers (Civil, Electrical, Mechanical, and 12 Start-up) to provide the Project Superintendent 13 with supervisory support for the on-site 14 activities through Resident Engineers, Field 15 Engineers and Field Inspectors.
With respect to 16 quality control, the responsibilities of the 17 Resident Engineers include:
(1) preparation of 18 quality control plans for site-related activities, 19 (2) direction of quality control activities, (3) 20 review and approval of field contractors' f
21 individual quality assurance procedures, (4) 22 supervision of Field Engineers and Inspectors, (5) 23 review of site-related, quality assurance 24 Procedures, and (6) preoperational testing and 25 startup.
s 26
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1 4.
PGandE has always recognized the importance 2
of supervisory surveillance and inspection during construc-3 tion activity.
Even prior to the promulgation of 10 C.F.R. 4 Part 50, Appendix B and the formalization of quality 5
assurance requirements, PGandE had procedures for cleaning 6
and flushing; shipping, receiving, storage and handling; 7
housekeeping; dimensional checking and quality testing in P ace at Diablo Canyon.
l 8
_ _ ~........
9 5.
The first on-site Quality Control Engineer 10 was appointed in June 1969.
This position has been 11 continuously maintained by a succession of engineers since 12 that first appointment.
The purpose of the on-site Quality 13 Control Engineer was to assist the Project Superintendent 14 and resident engineers in implementing the quality program, 15 Provide guidance to the contractors quality groups, and 16 inspect and audit for compliance to PGandE quality program.
17 This inspection / audit was conducted in addition to and 18 supplemental to the quality control inspections and audits.
19 The on-site quality engineer has remained independent of 20 direct responsibility for the scheduling,
- cost, or 21 Performance of construction.
22 6.
Quality Control Procedures and Departmental 23 Instructions were developed at Diablo Canyon as early as 24 October 1969 to implement the requirements of the PSAR and 25 Proposed 10 C.F.R. Part 50, Appendix B and PGandE's PSAR.
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26
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1 7.
For the construction and installation of the 2
building, equipment, and apparatus at Diablo Canyon, PGandE 3
required that each contractor performing work at Diablo 4
Canyon have a quality assurance program qualified to PGandE, 5
industry, and Nuclear Regulatory Commission (Atomic Energy 6
Commission) quality assurance requirements.
The contractor 7
and any sub-tier contractor or supplier providing a service 8
or materia 1 to be installed at Diablo Canyon adhered to 9
these procedures in the performance of work at the site or 10 any other location affecting materials or products 11 ultimately destined for Diablo Canyon.
These programs were 12
- reviewed, approved, and audited by PGandE.
(See 13 Attachments 1, 2,
3 and 4 for illustrative examples.)
l 14 8.
Quality procedures, work practices, personnel l
l 15 qualifications, forms, etc.,
prepared by contractors were 16 submitted to PGandE General Construction, Quality Assurance, 17 and other departments for review and approval.
The same 18 rigid experience requirements established for Company field l
19 engineers and inspectors were also required of contractors.
20 9.
Quality control at the Diablo Canyon site was 21 a multi-tiered operation.
As a requirement of all bid 22 specifications, each contractor was required to prepare and 23 staff a site quality assurance /quali,ty control organization 24 adequate to inspect the quality of work performed.
PGandE t
25 field engineers and inspectors reinspected this work for l
a 26 compliance with the applicable design documents and l l
l
1 specifications.
The General Construction quality control 2
on-site group was then directly involved in the verification 3
of the adequacy and effectiveness of the contractors' 4
quality assurance program and the Company's following 5
inspections.
Finally, Corporate on-site quality assurance 6
engineers verified the adequacy and effectiveness of the 7
entire process.
8 10.
The complementing ratio of Company field 9
engineers and inspectors overseeing the contractors' work 10 varied from a maximum of 18 workers to 1 inspector to a 11 minimum of 8 workers to 1 inspector, and averaged 13.5 12 workers to 1 inspector.
13 11.
The first construction QC audit was conducted 14 on February 11, 1970, and from that date there have been 707 15 such audits.
In every instance any discrepant condition was 16 corrected.
In every instance of a contractor QA/QC 17 identified discrepancy a Company discrepancy report was also 18 filed to be certain that the condition was properly 19 processed.
This duality of documentation established a 20 double-check for satisfactory resolution of the discrepancy 21
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l 23
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1 l
24 25 s
26,
1 in accordance with quality assurance / quality control 2
procedure, engineering design and specification.
3 4
Dated:
July 1, 1982 5
6 L
t b
7 Richard S. Bain 8
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9 10 Subscribed and sworn to before 11 me this 1st day of July, 1982 12 13 N6ncy J.
L6 master, 14 Notary Public in and for the City and County of San Francisco, 15 State of California.
My commission expires April.14, 1986.
16 17 18 19 20 21 22 23 24 25 s
26 1
PROFESSIONAL QUALIFICATIONS OF 2
RICHARD S. BAIN 3
4 5
My name is Richard S.
Bain.
I am Manager of 6
Station Construction in the General Construction Department 7
in the Pacific Gas and Electric Company.
I have held this 8
position _si_n,ce 1975.
I am responsible for the 9
administrative, technical, and physical services necessary 10 to ass.emble, install, test, and make operable (1) plant and 11 auxiliaries of electric generating stations; (2) 12 transmission and distribution electrical stations; (3) 13 communication systems; (4) gas pipeline compressor and 14 metering stations as assigned by Gas Construction; and (5) 15 water treatment facilities as assigned by Civil-Hydro 16 Construction I am responsible for assuring the established 17 conditions and specifications are met within acceptable 18 schedules, and providing manpower and equipment for 19 maintenance and repair of facilities.
20 Prior to my duties as Manager, I was Station 21 Construction Superintendent with the General Construction 1
22 Department in'the Pacific Gas and Electric Company beginning
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23 in 1953.
I was responsible for providing prompt, effective, 24 and safe construction services for power plant facilities in 25 accordance with engineering specifications.
During that is assigned the responsibilit" for the construction 26 time I was l
s
1 of Diablo Canyon Power Plant with its inception in 1966.
My 2
responsibilities included also the the planning and 3
supervision of construction work related to the Humboldt Bay 4
Power Plant and other planned nuclear power stations.
5 I
am a member of the American Society of 6
Mechanical Engineers Committee on Nuclear Quality Assurance 7
and have been involved in the preparation of ANSI' N45 8
industry nucle _ar codes and standards.
9 My educational background includes a BS in 10 Industrial Engineering from Stanford University in 1947.
11 12 13 14 15 16 17 18 19 20 21 l
22 i
23 24 25 g
26 __.-
i PACIFIC CAS AND ELECTRIC COMPANY SUPPLEMENTARY SPECIFICATION FOR MANUFACTURER'S QUALITY CONTROL SYSTEMS REQUIREMEhTS 1.0 SCOPE This Supplementary Specification establishes requirements for the manuf acturer's systems for control of quality during manufacture, including inspection plans. Should this Supplementary Specification conflict with the Specific Conditions, the latter shall govern. Items required to comply with certain codes or standards by the Specific Conditions may have additional requirements such as found in Paragraph N-832 of Section III, Nuclear Vessels, ASME Boiler and Pressure Vessel Code.
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2.0 SYSTEM REQUIREMENTS The manufacturer shall establish and maintain a system for the control of quality during the order that shall assure that all supplies and services,~
including subcontracted items, meet all drawing and order requirements.
2.1 Drawings and Changes:
The manufacturer's system shall provide procedures which will assure that the latest applicable drawings, specifica-tions, and instructions required by the contract or purchase order as well as authorized changes thereto are used for manufacture, inspection, and testing.
2.2 Description of Procedures:
The manufacturer shall maintain a written description of procedures for control of quality and inspection show-ing in detail the implementation of the quality requirements of the contract or purchase order and the requirements of this Supplementary Specification.
In addition, the procedures shall include (but not be limited to) quality control measures governing:
2.21 Qualification of processes, equipment, personnel, and laboratories.
2.22 Receiving inspection.
2.23 Certification of material used and final product.
2.24 Quality audits.
s April 1968 BAIN Attachment 1 9
5
Suppl. Sp3c.
Quality Contral Systems 2.3 Management Review:
The manufacturer's quality system shall provide for the identification and evaluation of significant or recurring discrep-ancies and for alerting the manufacturer's cognizant management to the need for corrective action. Corrective action shall be reviewed by the manufac-turer for effectiveness and the need for further action.
3.0 PROCESS PROCEDURES The manufacturer shall operate under a controlled manufacturing system such as process sheets, shop procedures, travelers, etc.
Special controlled
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processes such as welding, heat treating, nondestructive testing, and inspec-tion techniques shall be a part..of and included in the system.
3.1 Procedure Revisions: There may be a need to revise or eliminate a previously approved inspection procedure. When this occurs, the change to (or elimination of) inspection procedures shall require Purchaser's approval.
3.2 Inspection Plans:
Inspection planning for~this order shall be completed in writing by the manufacturer, covering subcontracted work as well as his own, to the following minimum requirements:
3.21 All inspection operations through shipment shall be listed and referenced to the manufacturer's/ subcontractor's manufacturing procedures.
This Inspection Check List shall be submitted to Purchaser for approval in advance of fabrication.
3.22 Characteristics specified by the order and its referenced drawings and specifications shall appear on the check lists under the appropriate inspection operation.
Space shall be provided for a nota-tion of the document number and revision to which the inspection was made and for the inspector's signature or stamp.
Each characteristic so listed shall be inepected (using approved procedures wherever these are required) and t'.te result recorded.
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3.23 When a combined manufacturing and inspection plan meets the requirements above, a separate check list of special format is not required.
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4.0 NONCONFORMING COMPONENTS OR MATERIAL All nonconforming material and components shall be kept identified and recorded to prevent intermingling with conforming material. Material or components that fail to meet acceptance standards shall bd disposed of as g
(
follows:
s April 1968
Suppl. Sp2c.
Quelity Control Systems 4.1 Components or material that do not meet specifications may be sub-mitted for possible acceptance in accordance with the purchase order.
4? The manufacturer shall be responsible for establishing and control-ling __, ir procedures. He shall obtain written approval from Purchaser of any repair procedure which utilizes operations not performed in the normal manufacturing process.
Each repair shall be recorded.
4.3 When the manufacturer elects to scrap the defective material or component, adequate records shall be maintained to verify that the rejected l
material or component has not been used.
i 5.0 QUALITY CONTROL RECORDS 5.1 The manufacturer shall maintain a complete file of all records for material and items manufactured. This shall include chemical and physical properties of materials, inspection, test, and analysis data taken before, during, and af ter manufacture as required, the manufacturing and inspection procedures, specifications, and drawings used.
The records shall include all closely related data such as qualifications of personnel, procedures, and equipment, and data on nonconforming material.
5.2 Purchaser shall be provided access to records on special request l
as needed for engineering studies. However, copies of all data specifically requested in Purchaser's specification or purchase order shall be submitted to Purchaser as required.
The manufacturer shall maintain a record file for a minimum of 5 years after order completion, after which time he shall either request disposition instructions from Purchaser or continue to maintain the records.
6.0 CONTROL AND IDENTIFICATION OF MATERIAL The manufacturer shall maintain a system of material control adequate to assure identity of all material used and that it meets the applicable specifications, prior to-start of manufacturing operation.
Identification of all material shall be maintained throughout all operations by heat number (or any other suitable means traceable to the heat number) and recorded on inspec-tion data records for each component.
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April 1968 8
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Suppl. Spac.
Qun11ty Control Systems k
8.2 Where applicable, the manufacturer's control charts and other sta-tistical data shall be made available for inspection to Purchaser and shall be maintained as a record substantiating the acceptability of the components or material.
9.0 HANDLING AND STORACE 9.1 The quality program shall require the use of handling procedures and equipment inspection with a monitoring program established to-prevent handling damage to the product. The equipment inspections shall include any,
load bearing devices (hooks, shaf ts, slings, etc.) the failure of which could result in product damage.
9.2 The manufacturer shall provide adequate work and inspection instructions for storage, preservation, packaging, and shipping to protect the products and/or supplies from damage, loss deterioration, degradation, or substitution of product or supplies. Any special handling instructions during shipping and storage shall be prominently displayed on the shipping package.
4 4
i April 1968
mat SPECIFICATION N07 8831-X 0
G.M. NO.
162027 SPECIFICATION FOR FURNISH AND ERECT CONTAINMENT STRUCTURE LINER FOR UNIT 1 DIABLO CANYON SITE FOR THE
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PACIFIC GAS AND ELECTRIC COMPANY SAN' FRANCISCO, CALIFORNIA
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Department of Engineering Comprising Specific Conditions Appendix 0
ror-er rroPo 1 Insurance Questionnaire l
I
,':c APPROVED BY J. J. McCann/ATL(NLT/DBN)
BIDDER - SIGN HERE TO INDICATE THIS B. W. Shackelford/RVB(EPW/SP)
HAS BEEN USE I
PREPARING PROPOSAL
/
D. V. Kelly /JOS(WJL)
FIRM SIe b M*A N/$
BY 5$$$ /
b-/ 7-/o d DATE O
DATE February 25, 1969 BAIN Attachment 2 s
l s
5.
8831-X Quality Assurance 18-1 SECTION 18 QUALITY ASSURANCE 1.0 DEFINITIONS 1.1 Quality assurance comprises all those planned and systematic pro-grams necessary to establish confidence that a material, component, or system will perform satisfactorily in service.
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1.2 Quality control comprises those quality assurance actions which provide a means to control the quality of the material, component, to predetermined requirements.
or system i
1.3 Product includes material, components, devices, equipment, systems, i
structures, services, and other items furnished by Contractor under other sec-tions of this Specification.
Product may consist of individual items, assemblies of items, or items in any state of fabrication.
l 2.0 SCOPE 2.1
_ Quality assurance requirements shall apply to all activities affecting the quality of products that are important to nuclear safety and to the prevention of accidents or to the mitigation of their consequences.
l All products provided under this Specification shall be considered as within j
the above category unless specifically exempted in writing.
l 2.2 Activities subject to quality assurance requirements include 1
designing, purchasing, fabricating, handling, shipping, storing, maintain-I ing, constructing, inspecting, testing, repairing, modifying, and documenting.
l 2.3 Contractor is responsible for performance of all quality assur-ance activities necessary to assure that products furnished by him are complete and in accordance with design and specification.
2.4. Contractor shall submit with his proposal a description of his proposed quality assurance program (bid Item 500).
l l
Not later than May 20, 1969, Contractor shall prepare in detail and suNsit to Specification No. 8831 Contractor for submittal to Constructor for approval eighteen copies of his quality assurance program which shall define the program and designate the qualifications, functions, and number of personnel necessary to assure com-pliance with the Specification.
The program and methods used to implement i
these requirements shall be developed by Contractor based on the outline g
)
provided in Paragraph 3.0 of this Section. Contractor shall revise all or any portion of the quality assurance program where, in Company's judgment, it does not satisfy requirements. Such corrections shall be made prior to start of work.
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8831-X Quality Assurance
{
l 18-2 2.5 Contractor shall be fully accountable for scheduling his work so as to permit adequate time for compliance with the quality assurance require-ments of this Specification.
3.0 QUALITY ASSURANCE REQUIRDIENTS
3.1 Organization
Contractor's quality assurance organization shall have clearly defined responsibility and authority for implementation of a
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comprehensive quality assurance program.
Contractor shall require his sup-pliers and subcontractors to establish adequate quality assurance organizations.
Quality assurance personnel shall be independent of manufacturing, fabrication, and construction forces and shall not perform functions other than those of quality assurance. Quality assurance personnel shall have sufficient and well defined responsibility, authority, and organizational freedom to identify and eval 6 ate quality problems and to require implementation of approved solutions.
Contractor shall provide with his detailed quality assurance program as required in Paragraph 2.4 a description of his suppliers' and subcontractors' quality assurance organizations.
The descriptions shall include the duties, responsibilities, numbers, and basic qualifications of key personnel to be assigned to these activities. The above shall include a chart indicating responsibility and lines of authority between Contractor, Contractor's con-struction supervision, suppliers and subcontractors, and quality assurance personnel.
3.2 Procedures and Plans: Contractor shall review the requirements of the Specification and prepare written procedures and plans for the following:
3.21 Proposed sequence of shop and field fabrication and construc-tion activities in detail and including and identifying those operations specifically related to quality.
l 3.22 Honitoring, inspecting, testing, and control of shop and field fabrication processes, test equipment, fixtures, tooling, and per-sonnel skills required to assure the product quality.
3.23 All nonfabrication work affecting quality, including but not limited to designing, detailing, purchasing, handling, inspecting, test-ing, and shipping.
3.3 Approval of Procedures:
Procedures shall be submitted to Construc-tor for approval prior to initiation of the work. Work shall not proceed until written approval of the corresponding procedure has been obtained 3.4 Hold Points:
Company may indicate mandatory inspection hold points
- which shall require witnessing or inspecting by Company. Work shall not pro-ceed beyond these hold points prior to such witnessing or inspection.
R 8831-X Quality Assurance 18-3
3.5 Records
Contractor shall prepare, use, and maintain adequate records to attest to and document the quality of the product. Such a set of records shall include, as a minimum, material analyses, design checks, inspec-tions, tests, workmanship, and procedures; qualifications of equipment, procedures, and shop, field, and technical personnel; and nonconformances and subsequent corrective actions.
Inspection and test records shall indicate the nature of observations and type of nonconformances found. Records of work performance shall indicate acceptability of the work and/or material or necessary corrective action in cases of nonconformances. All records and l
documents must be preserved for ultimate use by Company for a minimum of ten l
years. Until such time as they may be transferred to Company, the records and documents shall be available for inspection and review by Company and regulatory agencies at any time.
Contractor shall submit his record proce-dure to Constructor for review and approval prior to beginning fabrication or ins tallation. activity.. Contractor's procedure shall include a system for identifying the inspection status of products. This may be accomplished by stamps, tickets, or tags.
3.6 Corrective Action: The quality assurance program shall provide a system for prompt detection, identification, and correction of conditions having an adverse affect on quality. Any factor of Contractor's operations which has had or could reasonably be expected to have an adverse effect on product quality shall be identified and corrected. The program shall require effective use of all data regarding defects which will not be limited to product items, but shall include methods, processes, and facilities. All conditions adverse to quality shall be documented and brought to the atten-t tion of Constructor and Contractor's supervision and management for aralysis, evaluation, and prompt corrective action.
3.7 Specification. Drawing. Documentation, and Change Control: Con-tractor shall prepare, maintain, and use a procedure for assuring that specifications, drawings, procedures, instructions, authorized changes, and other documentation, which deal with activities affecting quality, are cur-rent, adequate, and available for use in fabrication, construction, inspection, and testing. The procedure shall stipulate that obsolete documentation be removed from point of use.
3.8 Measuring and Testing Equipment: Contractor shall prepare, maintoin, and use a procedure for the maintenance and periodic calibration of measuring.And testing equipment used to determine product conformance.
All measuring, and testing equipment shall be calibrated against certified measurement standards which have known valid relationships to national standards i
e 3.9 In Process and Final Inspection: Contractor's quality assurance program shall assure that work is accomplished under controlled conditions which include documented work instructions and test procedures, adequate equipment, and any special environments that may be required.
Inspection g
personnel shall be qualified in their specific area of responsibility and knowledge. Documented work instructions shall include criteria for accept-able and unacceptable conditions including workmanship. Physical examination,
8831-X Quality Assurance 18-4 I
I measurements, and/or tests shall be performed as required during product processing at appropriate points so as to assure quality of the end product.
Contractor shall maintain close coordination with Company to facilitate inspection or witnessing of tests by Company.
3.10 Product Control: All products subject to quality control require-ments which have been approved for use shall be identified and segregated to assure that only these products are used in the work.
3.11 Nonconforming Products: Contractor's quality assurance program shall require that products which fail to meet requirements are identified and segregated and removed from work site or from areas designated for approved material.
3.12 Handling and Storage: Contractor's quality assurance program shall provide and use adequate procedures to assure that all necessary meas-ures are taken to prevent damage or deterioration of products during handling or storage.
3.13 Special Protection. Packing, and Packaging: Contractor's quality 5,
assurance program shall provide and use adequate procedures to assure that i
products requiring special protection, packing, or packaging shall be given
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appropriate consideration and treatment.
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3.l'4 Cleanliness: Contractor's quality assurance program shall provide adequate procedures to assure that products are provided and maintained in an appropriate state of cleanliness.
3.15 Audit: A procedure for a system of audits shall be established and used to assure compliance with all aspects of the quality assurance pro-gram and to determine its effectiveness. Audits shall be made on a planned i
periodic basis.
Contractor chall include as a requirement of his purchase i
orders and subcontracts a statement essentially as follows: " Contractor and/or Company shall have the right to conduct qua'ity assurance audits and inspections at any time during production and testing as may be deemed f
necessary."
4.0 CONTROL OF WORK 4.1 Company will perform a continuing audit of Contractor's quality assurance program. This is in addition to the audit by Contractor described in Paragraph 3.13.
4
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t 8831-X Quality Azcurcnce 18-5 4.2 Company will stop or reject work which, in his opinion, is below
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specified quality standards. Work shall not be resumed until acceptable f
corrective measures are adopted by Contractor.
Exercise of this authority shall be by written directive describing the work in question and reason for its suspension.
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PACIFIC GAS AND ELECTRIC COMPANY
.g S AN FRANCISCO, CALIFORNI A DEPARTMENT OF ENGINEERING i
ACCOUNTING DATA ACT WIM %
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orco 27 18 Various Various 40 p
p GM Project File Number 30.70 I
SPECIFIC ATION FOR
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INSTALLATION OF THE NUCLEAR STEAM SUPPLY SYSTEMS FOR UNITS 1 AND 2 - DIABLO CANYON SITE _
l COMPRISING Specific Conditions General Conditions Proposal Form J
Insurance Questionnaire Appendix l
I O
s i
APPROVED BY J. J. McCann (ATL)(EDC/ MPH)
D. V. Kelly (HJG/RML/AGW/NLZ)
HAS BEEN USED IN PREPARING PROPOSAL g
T. A. Bettersworth (JWC/DN)
FLRM R. V. Bettinger (EPW/VJG)
W. J. Lindblad DATE G. V. Richards DATE May 3, 1972 BAIN Attachment 3
4 I
I 8752
[
General
.g 1-1 I
5 i
SPECIFIC CONDITIONS SECTION 1 CENERAL l
1.0 SCOPE OF WORK l
1.1 General
This Specification covers the installation of the nuclear steam supply systems at Company's Units 1 and 2 - Diablo Canyon Site. The nuclear steam supply systems are Westinghouse Electric Corpo-ration four-loop pressurized water reactors. The material, equipment.
l and components to be-installed are Company furnished and comprise a major portion of the primary or reactor coolant system. The items to be installed for Unit 1 are itemized and described in Section 2 of this Specification, and the accompanying drawings show and locate the Unit 1 c
system and equipment.
Unit 2 will be similar, except opposite hand.
Contractor shall provide all labor, supervision, inspection, material, I
supplies, equipment, tools, and facilities required to complete the l
installation of the items furnished. All work performed under this i
Specification shall be to the satisfaction of the Constructor, but this shall not be construed as to relieve Contractor of the responsibility to complete and guarantee the work as specified.
l 1.2 Heavy Equipment Handling: Company has contracted with others l
for receiving, transporting, storing, and lif ting the heavy equipment and components to be installed under this Specification. Refer to Sec-tion 2 for the heavy items which will be handled by others. Contractor will not have to handle these items, except as noted in Section 2.
1.3 Installation Procedures: Contractor shall prepare detailed written installation and erection procedures and instructions for all work to be performed under this Specification.
Company and the nuclear steam supply system supplier, Westinghouse, will provide the technical data and information necessary to develop these instructions. Refer to Section 3 for installation procedure requirements.
1.4 Quality Assurance: Work activities affecting structures, systems, equipment and components, that are essential to the nuclear safety of the plant and to the prevention of accidents or to the miti-gation of their consequences shall be performed and documented by a quality assurance program.
All the structures, systems, equipment and components for the Diablo Canyon Site that require quality assurance measures are categorized as " Design Class I."
With a few exceptions, the material, equipment, and components installed under this Specifica-tion are Design Class I, and are specifically noted as such in the descriptions of Section 2.
Contractor shall implement a quality assur-g ance program for all work performed and material supplied for Design Class I items.
Refer to Section 4 for Contractor's Quality Assurance Program requirements.
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8752 Quality As uranc3 4-1 SECTION 4 CONTRACTOR'S QUALITY ASSURANCE PROGRAM 1.0 GENERAL 1.1 This Section establishes the requirements for Contractor's quality assurance program for the control of quality of material supplied and work performed under this Specification.
1.2 Contractor's quality assurance program shall apply to all material supplied for and work performed on Design Class I structures, systems, and components, including equipment and accessories. Design Class I items are identified in other sections of this Specification.
1.3 Contractor's quality assurance program shall include the following activities: preparing drawings, purchasing, fabricating, receiving, handling, shipping, storing, maintaining, installing, erect '
ing, assembling, constructing, inspecting, testing, repairing, modifying, recording, documenting, and ' auditing.
1.4 Contractor shall schedule his work to permit adequate time for implementation of the quality assurance program.
1.5 Contractor shall assure that his suppliers and subcontractors conform to all requirements of the quality assurance program.
2.0 DEFINITIONS 2.1 Quality assurance comprises all those planned and systematic i
actions necessary to establish confidence that the equipment and systems will perform satisfactorily in service.
2.2 Quality control comprises those quality assurance activities related to the physical characteristics of a material or work which providgs a means to determine and control the quality of the material j
supplied and work performed to predetermined requirements.
2.3 Material includes components, devices, equipment, systems, structures, and other items. furnished by Contractor to complete the
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requirements of this Specification. Material may consist of individual items, assemblies of items, or items in any state of fabrication.
2.4 Work includes all activities by Contractor to complete the g
requirements of this Specification.
8752 Quality Assurance 4-2 3.0 SUBMITTALS 3.1 Bidder shall submit with his his proposed quality assurance program, proposal a brief description of (1) quality assurance organization, including details or samples of his :
(2) quality assurance proce-dures manual, and (3) quality assurance inspection and test plans.
3.2 Within 30 days following the award of contract, Contractor shall submit to Constructor for approval six copies of (1) his quality assurance organization description, designating qualifications, respon-sibilities, and numbers of personnel, in accordance with Paragraph 4.2 of this Section; and (2) his quality assurance procedures manual, includ-ing all the procedures necessary to assure compliance with the require-ments of Paragraph 4.3 of this Section.
Contractor shall revise all or any portion of his quality assurance organization and quality assurance manual where -in Company's judgment, they are not satisfactory. When Company approves of Contractor's quality assurance organization and quality assurance procedure manual, nineteen copies of the approved organization and manual shall be submitted to Constructor.
Ccatractor's quality assurance organization and quality assurance procedures manual shall be approved prior to the start of any work.
3.3 At least 21 calendar days prior to the start of work on a,ny Design Class I structure, system, or component, including equipment and accessories, Contractor shall prepare and submit to Constructor for approval six copies of a specific inspection and test plan for that work.
This plan shall be in accordance with the requirements of Paragraph 4.4 of this Section.
Contractor shall revise all or any part of the plan where, in Company's judgment, it is not satisfactory. When Company approves the inspection and test plan, nineteen copies of the approved inspection and test plan shall be submitted to the Constructor, and it shall be used for documenting and recording all inspections and tests performed on that Design Class I item.
Inspection and test plans shall be approved prior to the start of any work on Design Class 1 items.
Upon completion of the installation and upon Company acceptance of the equipment, nineteen copies of the completed inspection and test plan shall be forwarded to Conatructor, i
4.0 QUALITY ASSURANCE PROGRAM REQUIREMENTS 4.1 Quality Assurance Program:
4.11 Contractor's quality assurance program shall consist of a quality assurance organization, a quality assurance precedures manual, and quality assurance inspection and test plans in 1 5 accordance with the following paragraphs.
I l
8752 Quality Assurancc j
4-3 1
4.2 Organization
4.21 Contractor's quality assurance organization shall have clearly defined responsibility and authority for implementation of a comprehensive quality assurance program. The organization shall require quality control personnel:
(1) to have sufficient and well defined responsibility, authority, qualifications, and organiza-tional freedom to identify and evaluate quality problems and, when necessary, to require implementation of approved corrective actions, and (2) to be generally independent of procurement, manufacturing, fabrication, scheduling, and construction forces.
4.22 Contractor shall require his suppliers and subcontractors to establish adequate quality assurance organizations. Contractor shall provide with his detailed quality assurance program submittal (as required in~ Paragraph"3.2 of this Section) a description of his suppliers ' and subcontractors ' quality assurance organizations,
including qualifications, responsibilities, and numbers of personnel, and a chart indicating responsibilities and lines of authority between Contractor, Contractor's construction supervision, suppliers i
and subcontractors, and quality control personnel.
4.3 Procedures Manual:
Contractor's quality assurance procedures manual shall detail the methods used by Contractor to control the quality of material supplied and work performed under this Specification. Con-I tractor shall conduct his work in accordance with the procedures therein.
The manual shall include the following procedures as a minimum:
j 4.31 Design Control: Contractor developed designs for structures, systems, and components shall be reviewed for complete-ness, design adequacy, material compatibility, code conformance, currentness, and other similar items.
Reviews of design adequacy shall consist of checking the design with alternate or simplified calculation methods, by performance of a testing program which is approved by Company, or by conducting a complete design review.
Control measures for design changes shall be commensurate with those t
applied to the original design.
4.32 Document Control:
Contractor shall assure that specifications, drawings, procedures, instructions, inspection and test plans, and any other quality related documents, as well as authorized changes, used in work performed under this Specification are current, properly completed, approved by authorized personnel, and distributed for use.
The procedure shall assure that obsolete documentation be removed from use.
I i
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8752 Quality Assurance 4-4 4.33 Material and Work Procurement Control: Contractor shall assure that all material and work furnished by suppliers or sub-4 contractors under this Specification conform to the applicable 2
^
requirements of the procurement documents such as drawings, speci-fications, and codes. Contractor procurement control includes evaluation and selection of qualified suppliers and subcontractors, the transmission of applicable design and quality requirements to suppliers and subcontractors, the assurance that supplier and sub-contractor quality assurance programs are consistent.with this Specification, and source inspection by Contractor at the supplier or subcontractor. This procedure shall not include Company fur-nished material until delivered to Contractor.
4.34 Receipt Inspection of Material: Contractor shall inspe_c_t,,to the extent necessary all material delivered into his custody to assure conformance to specifications, drawings, purchase orders, and other technical requirements.
Receipt inspection may vary as to amount and type depending on the item and supplier.
Company furnished material need only be inspected for completeness and damage during handling if Company specifically identifies and i
exempts the equipment in writing.
4.35 Identification, control, and Status of Material:
Contractor shall develop measures to maintain identity and trace-I ability of material to assure that prescribed inspections and tests have been performed, to identify nonconforming material, and to pre-vent the use of incorrect or defective material.
Suitable means of marking or recording material, such as stamps, tags, labels, or i
routing cards shall be employed.
Contractor shall submit his l
proposed method of identification marking for approval.
l 4.36 Handling, Storage, Packaging, Shipping, and Preservation i
of Material:
Contractor shall assure that all necessary measures are taken to prevent damage, loss, or deterioration of material during handling, storage, packaging, shipping, receiving, preserving, installing, erecting, and maintaining until acceptance by Construc-tor. Material requiring special protection, preserving, or packaging shall be given appropriate consideration and t reatment. This will include, when necessary, the es tablishment and perf a " e verification of protective environments, such as inert gas, moisture content, r id temperature levels.
4.37 Nonconforming Material Control:
Cont ractor shall assure that material which fails to meet requirements of this Specification are identified, segregated..and then removed from areas designated for approval material. Nonconforming items shall be reviewed, l
accepted, rejected, repaired, or reworked in accordance with proce-dures requiring designer review.
If Company furnished material is nonconforming, Contractor st.all notify Constructor.
If Contractor n
proposes to use any material which does not meet the requirements of this Specification, a written report shall be prepared for Engi-neer's approval.
Company will furnish Contractor with instructions for submitting nonconforming material reports.
I i
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e s
8752 Quality Assurcnce I
4-5 4.38 Qualification o'f Processes and Personnel: Contractor I
shall assure that special processes, such as welding, heat treating,
(
and nondestructive testing, are controlled in accordance with appli-(
icable codes, standards, specifications, etc.
Special processes shall be accomplished by qualified personnel using qualified procedures.
(
4.39 Calibration of Measurement and Test Equipment:
Contractor shall assure the maintenance and periodic calibration of measuring and testing equipment used. All measuring and testing equipment
}
shall be calibrated against certified measurement standards which have known valid correlation to national standards.
4.310 Corrective Action:
Contractor shall assure that all l'
malfunctions, -deficiencies r deviations, defective items, and noncon-conditions which adversely affect quality and tend to cause failures, formances are promptly identified, reported, and corrected to pre-clude repetition.
Contractor shall maintain records on all conditions which adversely affect quality. These records shall indicate each condition, the cause of the condition, and the corrective action taken. A copy of these records shall be forwarded to both the Con-structor and the Contractor's supervision and management for analysis, evaluation, and review.
4.311 Records:
Contractor shall use, collect, and maintain records and data essential to document the quality of material
-~
supplied and work performed under this Specification.
Records are considered one of the principal forms of objective evidence of qual-ity, and procedures shall assure that records are complete and reli-able.
Records collected shall include, as a minimum, the following:
drawings, specifications, purchase orders, work orders, inspection reports, test reports, work performance records, work procedures, qualification records for procedures, equipment and personnel, non-conformance reports, corrective action records, and audit records.
Inspection and test reports shall indicate the nature of observa-tions or test, the acceptable limits of observations or tests, the results, the type of nonconformances observed, and the identity and signature of the observing personnel. Work performance records shall indicate acceptability of the work and/or material or necessary corrective action in cases of nonconformances. All records shall be j
collected and filed in one hour rated fireproof cabinets at one loca-tion a't suppliers' and subcontractors ' shops or at the work site.
All records shall be preserved by Contractor for use by Company for ten years.
If Company has not requested custody of the records and documents before the end of the ten-year period, Contractor shall request disposition instructions from Company.
Until such time as they may be transferred to Company, the records and documents shall be available for inspection and review by Company and regulatory agencies. Upon request, duplicate copies of records and documents for specific items shall be provided promptly by Contractor to j
Constructor.
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I 8752 Quality Assurance 4-6
- 4.312 Audits:
Contractor shall establish a system of audits to assure compliance with all aspects of the quality assurance program and to determine its effectiveness. Audits shall be made on a planned periodic basis.
Follow-up action, including reaudits, shall be taken where necessary.
and forwarded to Constructor for review. Audit results shall be 4.4 Inspection and 'fest Plans: Contractor's quality assurance inspection and test plans shall identify the specific inspection and test requirements for the construction, erection, and installation of i
structures, systems, equipment, and components under this Specification.
Contractor shall review the drawings, specifications, purchase orders, codes, manufacturers' instruction manuals, and other doctanents pertainin;
~,
to structures, systems, equipment, and components under this Specifica-tion and prepare written inspection and test plans. The inspection and test plans will establish the initial, in-process, and final inspections and tests that are performed to assure quality.
Inspection and test plans shal'l-includs receipt inspection, storage inspection, dimension
~
inspections, visual inspection, cleanliness inspections, fit-up inspec-tions, weld inspections, nondestructive tes ts, materials tests, electri-cal circuit continuity tests, hydrostatic tests, operating tests, or any other inspections and tests required by this Specification.
The plans shall be in accordance with the following:
4.41 Plans shall be specific for structures, systems,.
equipment, and components, as specified in other sections of this Specification.
4.42 Plans shall follow the sequence of construction i
activities, from the receipt of material, components, or equipment to the completion of work.
4.43 Plans shall itemize inspection and test points, l
indicating in the sequence of construction activities when the inspection or test. point occurs.
l 4.44 Plans shall itemize characteristics to be inspected or tested at each inspection and test point.
4.45 Plans shall describe or reference acceptance ' riteria c
for each inspection and test point.
4.46 Plans shall designate inspection and test results to be recorded, data to be collected, and the identity and signature of the observing personnel.
Plans shall be filled out and completed as work is performed and progresses.
s
l as 8752 Quality Assurance 4-7 4.47 Plans shall indicate inspection hold points for Company's witnessing and review of the inspection or test, as required by I
other sections of this Specification. Work shall not proceed beyond g
these points without Company approval.
j 1
4.48 Plans shall list the records, forms, or documentation I
used and collected at each point. Sample forms shall accompany the plans., In approving the plan, Company will designate the specific forms to be retained by Contractor and those to be submitted to 3,
Company.
ino 4.49 Plan changes shall be approved by Company.
4.410 Upon Company acceptance of structures, equipment, systems, or components, nineteen copies of the completed inspection g,
and tes t pla~n 'shall be " forwarded to Cons tructor.
The original shall be retained by Contractor in accordance with Paragraph 4.311 of this Section.
L=
if 5.0 CONPANY INSPECTION AND AUDITS
{
5.1 Company will perform a continuing audit of Contractor's quality assurance program. This is in addition to the audits performed by Contractor.
5.2 Company will reject material and/or stop work which in its opinion is below specified quality levels or not in accordance with Con-I tractor's quality assurance program as approved. Work shall not be l
resumed until acceptable corrective measures are adopted by Contractor.
Contractor will be notified by written directive describing the work in question and reason for its suspension.
5.3 Company will perform off-site shop inspection on Contractor and his subcontractors and suppliers. Subcontracts and purchase orders shall include the following statement:
"All work on this contract / order is subject to inspection and, test by PG&E at all times (including the period of perform-ance) and places; and as a minimum final inspections and tests will be observed prior to shipment. The PG&E representative who normally services your plant shall be dotified forty-eight (48) hours in advance of the time material or work is ready for inspection or test."
s
PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CALIFORNIA Department of Engineering ACCOUNTING DATA SPECIFICATION NO. 8828 CM 167027 & 169972 Rev. No. 4 Loc. Div. 18 Project File No. 131.10 Account 61 Plant Strutture Activity Item 30 Safety Related:
No Location and/or Item 40
\\-
i SPECIFICATION FOR ARCHITECTURAL FINISH WORK k
UNITS 1 AND 2 DIABLO CANYON SITE.
N h
l l
l f1[hj CONTRACTOR GIGN HERE TO INDICATE APPROVED BY 7
THAT THIS REVISION IS ACCEPTABLE J. J. McCann/
(NL 8kPP) (EDC)
Be ttinger/g ger>25-g' (y*
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Firu IN S/FMG/GPB)
R. V.
By M
D.~ V. Kel y Date g/
C.' V. Richard /CER i
s ACCEPTED BY.
JB#/#
J.-B. Hoch s
l DATE June 1, 1978 EkINAttachment4 bb1I
l 8828 Ravisien 4 Pega 1 SPECIFICATION FOR FIELD CONTRACTOR'S QUALITY ASSURANCE PROGRAM (FOR SPECIFICATION 8828) 1 CENERAL 1.1 This Specification establishes the requirements for contractor's Quality Assurance Program to assure quality during the procurement and installation of components or equipment and the performance of work for those components identified in the attached Supplement, which ar'e to be l
constructed after the issuance of this Specification change.
l
])*1.2 Contractor's Quality Assurance Program shall apply to all activities affecting the quality of material supplied and work performed including:
Purchasing, Receiving, Handling, Constructing, Erecting, Maintaining Storing, Documenting, Inspecting and Testing.
1.3 Contractor shall also assure compliance with all quality requirements contained in the contract that are not described in this Specification.
1.4 This Specification shall be used in conjunction with the specified codes or standards (N.F.P. A., U.L., A.S.T.M., A.W.S., etc.) in order that l
activities not included in the codes or standards will be provided for.
l 2
DOCUMENTS FOR SUBMISSION 2.1 Contractor shall submit, to Company for approval, information which fully describes the Quality Assurance Program demonstrating that work will be performed under a controlled program conforming to the requirements of Paragraph 3 below.
l 2.2 Eight (8) controlled copies of final, approved Quality Assurance Programs shall be submitted to the Company by Contractor for approval.
3] QUALITY" ASSURANCE PROCRAM 1
l-3.1 Contractor's Quality Assurance Program shall describe in detail the procedures and methods used by Contractor to assure that all supplies l
purchased and work performed satisfy all contract requirements. The l
Program shall describe the methods of implementation of the following requirements:
g, i
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8828 Ravision 4 Page 2
3.1.1 Organization
The Contractor shall assign and identify personnel who will be responsible for implementing the Quality Assurance Program and such assigned personnel shall have direct access to such levels of management as necessary to achieve effective implementation of the Contractor's QA program.
I 3.1.2 Procurement Document Control: Contractor shall assure that applicable requirements and specifications necessary to assure adequate quality are included or referenced in Qontractor's, pro-curement documents. Changes shall be subject to the same degree of control utilized in the preparation of original procurement s
documents.
3.1.3 Instructions, Procedures, and Drawings: Contractor shall assure that-all activities affecting quality are prescribed by documented instructions, procedures, or drawings.
Such instructions, procedures, or drawings shall include quantitative or qualitative criteria for determining that activities affecting quality have been accomplished satisfactorily. Quantitative criteria, such as dimensions, tolerances, and test limits, and qualitative criteria, such as comparative workmanship samples, shall be specified, when appropriate, for determining acceptable work performance and quality compliance.
Procurement Control: Contractor shall perform receipt 3.1.4 inspection on all material and equipment delivered into his custody to assure conformance to the procurement requirements. Company-furnished materials and equipment need only be inspected for completeness and damage during handling if Company specifically identifies and exempts the equipment in writing.
Contractor shall assure that documentary evidence that items conform to the procurement requirements is available to the company prior to the installation or use of such items. Documentary evidence shall I
be sufficient to identify the specific procurement requirements that Where not n~ecluded by other procurement requirements, have been met.
written certifications of conformance which identify the procurement requirements that have been met may be used as documentary evidence, providing means are available to verify the validity of such certifications.
Measures shall be established and documented Document Control:
3'5 to assure that all quality-related documents are reviewed for adequacy, approved for, release by authorized personnel, and properly distributed.
Changes to documents shall receive the same degree of review and approval as the original documents.
Written procedures governing document control shall provide for the i
identification of individuals or organizations responsible for pre-paring, reviewing, approving, and issuing documents and changes These procedures shall preclude the possibility of use of thereto.
superseded, obsolete, or void documents.
^ '
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8828 R2 vision 4 Pcga 3 3.1.6 Identification and Control of Material and Equipment:
Contractor shall establish and document measures to identify and control material and equipment. These measures shall prevent the use of incorrect or defective material.
Traceability when required by Specification for material and equip-ment shall be maintained with records and markings. When identi-fication marking is used, the marking shall be clear, unambiguous, 2
and indelible, and the method of marking shall not affect the function of the material or equipment.
- 3.1.7 Control of Measuring and Test Equipment: Contractor shall assure that all tools, gages, instruments, and other measuring and test equipment used in activities affecting quality are of.the proper range, type, and accuracy to verify conformance to established requirements.
- 3.1.8 Inspection: Contractor shall assure that activities affect-ing quality are inspected for conformance to the documented instruc-i tions, procedures, and drawings used in the accomplishment of the activity.
Written procedures shall require that inspections are performed according to written instructions or checklists which are based on the instructions, procedures, and drawings used in accomplishment of the activity being inspected. Inspection procedures shall also require the documentation of the qualitative or quantitative results 4
of the specific parameters being inspected.
- 3.1.9 Test Control: Contractor shall assure that a test program will be established which identifies and documents all testing required to demonstrate that an item will perform satisfactorily in service. Written procedures shall require that all testing be performed in accordance with written test procedures which incor-porate all requirements and test limits specified in the design document s.
Test procedures shall assure that prerequisites, such as calibrated instrumentation, appropriate equipment and environ-mental conditions, and trained personnel, are met.
Test require-ments, results, and acceptance criteria shall be documented and evaluated by authorized personnel to assure that all requirements have been satisfied.
- 3.1.10 Inspection Plan or Procedures:
Contractor shall perform l
required inspections in accordance with a written inspection plan or procedure.
The Contractor shall assure that all inspections required by the attached Supplement are, identified in the inspection plan or proc'edure. The plan or procedure shall be developed in accordance with the following:
l The plan or procedures shall identify the characteristics to be inspected.
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8828 R2 vision 4 j
Page 4 l
The plan or prccedures shall dercribe the inspection instructions or procedures to be used.
The plan shall list the records, forms, or other documentation used.
- The plan or procedure' shall indicate all inspection hold points for Company witnessing and review of the inspection or test, as required by the attached Supplement. The plan shall provide for adequate advance notice to Company's inspector. Work shall not proceed beyond inspection hold points until such points have been witnessed or inspected by the Inspector.
Records shall be kept of all tests and inspections including nonconformances observed and the identity and signature of the inspection and test personnel.
i
- 3.1.11 Inspec't'lon~a~n'd " Operating Status :
Contractor shall establish
~
and document measures to identify inspection status of items and work.
l Such measures shall provide means for assuring that required inspec-tions are performed and that the acceptability of items or work with regard to inspections is known at all times. Written procedures shall provide for the status of inspections through the use of indicators such as tags, markings, stamps, or records.
The procedures shall assure that only items, or portions of ' work, that have passed requir,ed inspections are accepted and that nonconforming items are clearly i
}
identified.
- 3.1.12 Nonconforming Material Control:
Contractor shall assure that material, equipment, services, or activities which do not conform to requirements are identified, documented, segregated, evaluated, and accepted, rejected, reworked, or repaired in accordance with documented procedures.
If Company-furnished material is found to be nonconforming, Contractor shall notify Constructor.
Written procedures controlling nonconformances shall define the responsibility and authority for the disposition of nonconformances.
Such procedures shall provide for the reinspection of all repairs or rework in accordance with applicable procedures.
If Contractor proposes to use any special procedures or materials for repair or rework, a written description of Contractor's proposal shall be submitted for Constructor's approval. When Contractor elects to accept a nonconformance as is records shall document the basis for acceptability. When Contractor elects to scrap a nonconformance, adequate records shall be maintained to verify that the nonconformance has not been used.
3.1.13 Handling, Storage, and Shipping:
Contractor shall establish and document measures to control handling, storage, and shipping, including cleaning, packaging, and preservation of material and equipment in accordance with instructions, procedures, or drawings, to prevent damage, deterioration, and loss.
r -- - - - - -
8828 Ravision 4 Page 5 7
- 3.1.14 Corrective Action:
Contractor shall assure that all condi-tions which are adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material, and nonconformances are promptly identified and corrected as soon as practical. Correc-tive action shall be sufficiently comprehensive to intercept and correct all items affected by the adverse conditions.
In the case of significant conditions adverse to quality, written procedures shall require that the caus~e of the conditions be determined and appropriate corrective action taken to minimize the possibility of repetition.
Contractor shall maintain records on all conditions which adversely affect quality. These records shall identify each condition, the cause of the condition, and the corrective action taken, and shall be forwarded to both Constructor and Contractor management levels for review.,~~~ '-
~"
- 3.1.15 Records:
Contractor shall use, collect, and maintain records and documents sufficient to furnish documentary evidence of the i
quality of material supplied and work performed. Written procedures shall identify all records which are to be retained, and shati prescribe the retention period, storage location, and assignment of responsibility.
Records co!!ected shall include, as a minimum, the following: drawings, specifications, purchase orders, work orders, material certifications, work procedures, personnel and equipment qualification records, nonconformance reports, corrective action records. Work performance records shall indicate acceptability of the work and/or material or necessary corrective action in cases of nonconfo rmance s.
Requirements and responsibilities for record transmittal, retention, and maintenance subsequent to completion of work shall be established and documented consistent with procurement documents.
In general, records which identify the as-built condition of materials or equipment shall be maintained for a minimum of ten years. At the end of the ten year period, Contractor shall request disposition instructions from the Company for all documents which Company has not requested custody of.
These records shall be indexed, filed, and maintained in facilities that provide suitable environment to minimize deterioration or damage and to prevent loss. Until such time as they may be transferred to Company, all records shall be available for h
inspection and review by Company and regulatory agencies.
3.1.16 Audits:
Contractor shall establish a system of audits to assure compliance with all aspects of the quality assurance program and to determine its effectiveness. Personnel performing audits shall not have direct responsibilities in the areas being audited.
Follow-up action, including reaudit, shall be taken when necessary.
g Audit results shall be documented and forwarded to Contractor's management for' review.
3
l 8828 R2 vision 4 Page 6 Written procedures which govern the audit program shall assign responsibilities for the audit program; establish the frequency of audits, prescribe the minimum qualifications for auditors and their independence from the area being audited; and prescribe the format for documenting audit results. The procedure shall prescribe the mechanism for submitting audit results to appropriate levels of management and also the criteria for determining when follow-up action is required.
~
4 COMPANY INSPECTION AND AUDITS 4.1 TheCompanyw[1'1perfoE1nperiodicauditsaswellascontinuous
~
~
inspection of Contractor's activities throughout all work performed.
- 4.2 The Company will reject material and/or stop work which, in its opinion, is not in accordance with the quality assurance requirements herein. Work shall not be resumed until corrective measures, which are approved by the Company, have been adopted by Contractor.
0 4
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7 9
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1
___ft_________
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1 UNITED STATES OF AMERICA 'f..
2 NUCLEAR REGULATORY COMMISSION- - p/#
3 2
4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 7
)
8 In the Matter of
)
Docket No. 50-275
)
~~- - -
9 PACIFIC GAS AND ELECTRIC
)
COMPANY
)
(Low Power Proceeding) 10
)
(Diablo Canyon Nuclear Power
)
11 Plant, Unit No. 1
)
)
12 13 14 AFFIDAVIT OF WARREN A. RAYMOND, CHARLES W. DICK, AND MICHAEL J.
JACOBSON 15 16 STATE OF CALIFORNIA
)
17
)
ss.
CITY AND COUNTY OF SAN
)
18 FRANCISCO
)
l 19 20 21 22 The above being duly sworn, depose and say:
23 i
24 The purpose of this affidavit is not to establish 25 the absence of deficiencies in the implementation of the
=
26 PGandE Quality Assurance Program.
Obviously deficiencies h$0 g b 3 4 ((
~*~
l
t l
o 4
1 did exist; however, those associated with the implementation 2
of QA/QC procedures for design activities are being 3
generically addressed by the Independent Design Verification 4
Program (IDVP) established by the NRC Order Suspending 5
License, CLI-81-30 (November 19, 1981).
This affidavit will 6
establish that the construction work is not similarly 7
affected because of:
the_ difference between construction and design work 8
9 process 10 construction work history 11 surveillance activities by regulatory agencies, 12 Quality Assurance / Quality Control groups, and "other 13 groups" 14 This affidavit will also demonstrate that Mr. Hubbard 15 mischaracterized and/or misstated many of the facts set 16 forth in his affidavit concerning alleged " breakdowns" in 17 the Diablo Canyon Quality Assurance Program.
(The Hubbard 18 affidavit dated May 24, 1982 will be hereafter cited as 19 "Hubbard aff. at
")
20 21 1.
HISTORICAL DEVELOPMENT OF QUALITY ASSURANCE AT DIABLO CANYON.
22 In. order to place the QA/QC issue in perspective, 23 24 it is useful to briefly describe the quality assurance 25 Program which has evolved over the past 16 years at DCPP.
s 26
/// 4
1 The Diablo Canyon project study started in 1964 2
and resulted in the issuance of a contract for the Nuclear 3
Steam Supply System (NSSS) in November 1966 -- approximately 4
2-1/2 years before the proposed Appendix B to 10 C.F.R. Part 5
50
(" Appendix B") was issued for comment.
The Unit 1 PSAR 6
was submitted in January 1967, prior to the identification 7
of formal quality assurance requirements, and thus'the 8
requirements were not specifically addressed.
Supplement 5 g
to the Unit 1 PSAR was submitted in November 1967 and 10 described a quality program for the primary system.
The 11 Construction Permit for Unit 1 was issued in April 1968 (one 12 year prior to publication of the proposed Appendix B), and 13 construction of the major buildings commenced in June 1969.
14 At this time the seismic design for Unit 1 was essentially 15 complete.
Two months prior to the start of major 16 construction on Unit 1, the proposed Appendix B was 17 published for comment.
18 Formal quality assurance requirements were first 19 addressed in Appendix G to the Unit 2 PSAR which was 20 submitted in July 1969.
That appendix addressed Appendix B 21 requirements as follows:
22 QUALITY ASSURANCE A comprehensive Quality Assurance Pro-23 gram for the design and cc.nstruction of Unit 2 at Diablo Canyon will be estab-24 lished by Pacific Gas and Electric Company in the discharge of its respon-25 sibility to build a safe and reliable nuclear power plant.
The program will 26 be an extension of the quality assurance.
l 1
program developed for Unit 1, and will benefit from the experience gained from 2
the earlier program.
3 This Appendix discusses the scope of the
- program, its organization and manage-4
- ment, and the. implementation of the technical and systems aspects of the 5
Program.
The organization of the material in this Appendix is based on 6
the divisions used in the proposed
" Appendix B - Quality Assurance Criteria 7
for Nuclear Power Plants",
issued for comment by the Atomic Energy Commission 8
on April 17, 1969.
Since there is
~sub'stantial - overlap in the material covered in the various
- headings, the 9
subject matter of an individual division 10 should not be considered separately but in relation to the entire Appendix.
11 12 PGandE established a Quality Engineering Department in November 1969 to implement this commitment to a Quality 13 14 Assurance Program, and two months later the Company issued a 15 Quality Assurance Manual for Design and Construction.
This manual was developed utilizing the proposed criteria (April 16 1969) since Appendix B was not formally published until June 17 18 1970.
Since that time PGandE has continually reviewed and 19 modified, as necessary, its Quality Assurance Plogram and 1
20 organizational structure in order to be responsive to the l
21 evolving regulatory guidance and industry standards.
l Erection of major piping systems for Unit 1 22 started in November 1970, approximately six months after 23 24 Appendix B was issued and four months before 10 C.F.R. Part 25 50, Appendix A was issued.
The NSSS installation began in et 26 September 1972, and Unit 1 construction was completed by i
l l
l l 1
1 November 1975 and a " Hot Functional Test" was satisfactorily 2
conducted.
One month later, Unit 1 was licensed to receive 3
and store fuel in preparation for fuel loading.
4 During this period, there were several concurrent 5
industry and NRC actions that had a significant impact on 6
the evolution of quality assurance requirements.
Appendix B 7
was issued with a minimum of definition as to the detail l
8 required for implementation.
In 1970, industry began to
- - ~
I 9
form technical groups to define Appendix B requirements.
10 This effort resulted in the development of the N45.2 series 11 of standards.
Even though these standards did much to 12 interpret and provide guidance on the application of the 13 Appendix B requirements, the NRC found it necessary to 14 conduct a series of meetings in the mid-1970s and to issue i
f 15 clarifications (Rainbow Books) to provide guidance in the i
l 16 establishment of industry quality assurance programs.
An
[
17 example of the difficulty encountered in developing a 18 meaningful interpretation of Quality Assurance requirements 19 was illustrated by the development of ANSI N45.2.13.
The I
20 work on this standard began in September 1971 and it was not 21 completed until 1976 when the standard was issued -- a l
22 period of approximately five years.
The NRC endorsed this 23 standard in July 1977 -- about six years after work on it 24 began.
25 In addition to the WASH documents (Rainbow Books),
s 26 the NRC has issued Regulatory Guides which affect the l
l l l
1 interpretation of Appendix B.
For example, the Standard Review Plan references 17 Quality Assurance Programmatic 2
3 Regulatory Guides which are applicable to present day design 4
and construction of nuclear power plants.
Many of these 5
Regulatory Guides were issued after Unit 1 construction was 6
complete but have had a significant effect on the current 7
interpretation of Appendix B.
8 The initial QA Manual including the section for control of construction activities was issued in January, 9
10 1970 and has been reviewed and updated on a continuing basis in order to be responsive to the evolving regulatory 11 12 guidelines and industry standards.
In 1980, the QA Manual 13 for control of all departmental activities was incorporated into a single corporate manual which controls all quality 14 related activities for PGandE.
Detailed implementing 15 16 procedures for control of construction activities were issued as a separate manual.
The DCPP site construction 17
~
18 departments (Mechanical, Electrical, Civil) started to issue 19 formal, controlled procedures to implement the requirements of the then proposed Appendix B requirements in October 20 21
- 1969, 8
months before Appendix B became a
formal 22 requirement.
I 23 PGandE started formal audits of construction t
24 activities in December, 1969.
Audits of construction 25 activities have been conducted on a regular basis since that
\\
s time in accordance with NRC regulations as described in the 26 1
l l :
l
1 QA Manual.
The corporate QA/ construction QC audits from 2
1969 through 1981 exceeded 1500.
This total does not 3
include the hundreds of audits conducted by the NRC and 4
contractors in accordance with their QA programs.
5 6
2.
INDEPENDENT DESIGN VERIFICATION PROGRAM 7
The IDVP was formally established in st'rict 8
accordance_wi.th the, November 19, 1981 Commission order and 9
the letter from Mr. Harold Denton of the same date.
The 10 IDVP is managed by Teledyne Engineering Services (TES) and 11 employs several consultants to review QA and the 12 safety-related design activities performed by PGandE and 13 consultants who contributed to the design effort.
14 It is important to recognize that QA programs are 15 only one means to the end of being sure that design 16 requirements are met.
When complete, the IDVP and QA 17 Programs are not in themselves a total solution to all 18 Problems.
The IDVP is designed to provide assurance that 19 design meets criteria and other requirements, and in doing 20 so will more than compensate for any past QA deficiencies.
21 This concept is well expressed in the TES Interim Technical i
22 Rep 5rt for DCPP, dated June 23, 1982, and is quoted below.
23 Although one purpose of the QA Audit and 24 Review is to provide certain information in direct response to the NRC Order, l
25 another purpose is to obtain background g
information which impacts the review of 26 the design process.
The QA reviews 1
indicate trends in activities such as design control, document control, and 2
test control as they existed during the design process.
Although these trends 3
may indicate the level of consistency in a given area of design, good QA cannot 4
guaranty good. design nor does poor QA necessarily indicate bad design.
There-5 fore, the QA audits and reviews are not in themselves an indicator of design verification or the absence thereof.
6 Instead, the results of the QA audits and reviews may affect the extent of 7
verification of the design process.
A g
QA Finding reveals the potential for a low ~ level "of consistency and indicates 9
the possible need for additional verifi-cation.
10 11 The IDVP was specifically developed to provide 12 assurance that design activities were accomplished in a 13 manner consistent with the license application and does not 14 depend on the effective implementation of the original QA 15 Program.
The quality assurance review associated with the 16 IDVP provided input to the independent review process to 17 identify those areas which might, require additional review 18 over and above that originally anticipated.
19 The Commission Order also included a requirement 20 for an independent review of the QA Programs of PGandE and 21 its design consultants.
R.
F. Reedy, Inc. ("RFR") performed this review for the IDVP and submitted a Report dated 22 23 March 8, 1982.(" Reedy Report").
The RFR effort had as an 24 objective the identification of design areas where the IDVP 25 could most effectively concentrate its efforts.
(TES Inter-im Technical Report dated June 23, 1982.)
To accomplish 26 4
1 this objective Reedy used present day interpretations and 2
understandings of Appendix B in place of the differing 3
interpretations and understandings applicable at the time 4
work was done.
This approach established a low threshold 5
for the reporting of non-conformances in the area of Quality 6
Assurance.
7 The Hubbard Affidavit relies heavily on-the 8
findings of the Reedy Report both in his general 9
condemnation of the PGandE Quality Assurance program and his 10 inference of " breakdowns" in the QA/QC program as applied to 11 construction work.
The Reedy effort was directed at quality 12 assurance in the area of seismic design and did not involve 13 site or QA for construction activities.
The Reedy Report 14 was thoroughly discussed at the NRC meeting of April 1, 1982 15 where Mr. Reedy himself stated that:
16 "I
have to agree with you that the strict interpretation that we use[d] was 17 completely unfair.
The order to me did not seem to be fair to begin with, and I 18 made a comment at the time that the l
evaluation should be done to the criter-19 ia that was in use at the time this pro-gram was accepted by the NRC and audited 20 by the NRC, but we did not go back and say we will accept what the NRC audited 21 and what they accepted.
We will use the l
criteria in the order.
Now I
don't 22 think that is fair, but that is what we did."
(Tr. pp. 32 & 33.)
23 i
24 Following that meeting PGandE responded to the Reedy Report 25 on April 15, 1982.
That response is attached to this s
i 26 affidavit as verified by Mr. Warren Raymond, Manager of l
_g_
l
1 Quality Assurance for PGandE.
It is incorporated herein by 2
this reference.
That response evidences, contrary to the 3
conclusions drawn by Mr. Hubbard, that PGandE did institute 4
QA/QC program control measures.
5 6
3.
CONSTRUCTION QUALITY ASSURANCE 7
The Hubbard affidavit asserts that because of 8
quality assurance deficiencies in the area of design, one is
" led to believe" that deficiencies exist in the area of 9
10 construction.
PGandE QA reviews and NRC inspections (Diablo 11 Canyon Reverification Study, Transcript February 17, 1982, 12 P. 31 and Commission Briefing, Transcript November 9, 1981, 13 P.
23), confirm that there is no evidence of comparable 14 difficulties in construction activities.
15 There are various reasons why program deficiencies in the area of design QA should not be indicative of the 16 l
17 quality of construction or the effe'ctiveness of a i
18 construction QA/QC program.
19 QA programs for design and construction activities 20 function in significantly different ways.
In construction, l
21 one deals with a product (structures,
- systems, and 22 components) wh'ich permits hands-on type verification, such 23 as inspection.and test.
In design, one deals with a " paper" 24 Product and verification must be accomplished by measures 25 such as checking, design reviews, approvals, and/or limited 26 testing.
It is no accident that design quality has a L
1 historically relied more heavily on professional judgment, 2
and less on QA/QC controls, than has construction.
One 3
important reason for this has been the difficulty of 4
developing methods for design verification opposed to 5
construction verification.
6 For example, in applying the relevant criteria of 7
Appendix B there are differences between design and 8
construction in organizational structures and 9
responsibilities, verification approaches for assuring 10 design adequacy and product conformance, knowledge and 11 skills required for QA/QC personnel, appropriate remedial s
12 and corrective actions, and, most important, the process of l
l 13 verifying adequacy and detecting deficiencies.
Contrary to 14 Hubbard's assertion (Hubbard aff. at 92), PGandE recognized 15 these differences in the organization of the original QA 16 Manual.
It was written to specifically address the special l
17 requirements of the various departments associated with l
18 nuclear activities.
For instance, one section of the QA 19 Manual prescribed engineering requirements (PRE); another l
20 section related to construction work (PRC); and another section related to procurement of materials (PRP).
Other 21 l
22 job ~ specific items were described in separate sections of 1
23 the manual.
Thus, the PGandE QA maqual incorporated a set 24 of separate requirements for engineering, procurement and construction.
25 s
26
///
l i
1 With regard to controls and verification methods, 2
nuclear construction work has been subject to inspection, 3
testing, and other verification programs since the inception 4
of the nuclear power program.
All construction work at DCPP 5
was performed by independent contractors with clearly 6
defined work scope and controls.
The necessary interfaces 7
for construction work were specifically designated in l
8 contract d,ocuments related to the product.
- Thus, 9
responsibilities were clearly defined and information flow 10 more easily controlled for construction work.
11 The historical time span covered by formal 12 construction verification programs for DCPP has been longer, 13 and the programs are more detailed than in design.
14 Construction controls were easier to develop and implement 15 than design controls.
For example, it was not until 1971 16 that ANSI N45.2 was issued, and 1974 for ANSI N45.2.11 (the 17 basis for Regulatory Guide 1.64).
These constituted the 18 first industry wide standards for design control QA 19 requirements; and Regulatory Guide 1.64 was the first on 20 design control issued by the NRC.
As late as June, 1976, 21 Regulatory Guide 1.64, Revision 2, was issued, further i
evolving the design control guidance issued by the NRC to 22 23 interpret Appendix B, Criteria III.
Previously, other 24 requirements existed in codes and other standards, or drafts 25 thereof, but these were relatively specialized and were not 1
s 26 directed toward mangagement programs for quality. n
1 In contrast, for construction activities at Diablo 2
Canyon, " quality assurance" requirements were an integral 3
Part of every contract specification for construction, even 4
those issued prior to the time Appendix B was issued for 5
comment in 1969.
(See Bain affidavit attached to PGandE 6
Response to Motion to Reopen.)
These requirements covered 7
the areas of testing, material procurement, inspection, 8
reporting, personnel qualification, etc., either directly or 9
by reference to detailed codes and standards.
These 10 requirements were further supplemented by the ASME
'N' Stamp 11 Program used by contractors working on the project.
When 12 formal QA programs became a requirement for future nuclear 13 work, the changes for construction contractors at DCPP were 14 significantly less than the changes and additions required 15 for design activities.
This was not unique to PGandE, but 16 was characteristic of the situation throughout the nuclear 17 industry.
18 For construction activities, the quality program 19 required multiple tiers of verification.
Initial 20 verification of each contractor's work through first-line 21 inspection by contractor inspectors was performed.
For the 22 Reactor Coolant System an additional inspection was 23 conducted by Westinghouse, the suppljer of the Nuclear Steam 24 Supply System.
Also verification was performed on a P anned, routine basis, by PGandE's field engineering and l
25 s
26 inspection personnel by continuous reinspection of I u
1 contractor work.
In addition, quality control and quality 2
assurance included this activity in their scheduled audits 3
and continuous monitoring.
This verification included not 4
only reinspections but witnessing of tests by contractors, 5
ongoing work of the contractors, and user tests of 6
materials, plus preoperational and startup testing of 7
systems.
This verification was in addition to procedural 8
and other management controls.
- - ~ ~.....
9 Throughout the construction of DCPP well-defined 10 QA/QC controls were required of the construction 11 contractors.
Strict requirements existed from the beginning 12 and were enforced.
QA programs of the contractors were 13 routinely reviewed at the time of audit.
PGandE also 14 provided its own force of field engineers and inspectors to 15 assure compliance; and the AEC (now NRC) provided 16 inspectors.
At the peak of construction the ratio of 17 inspectors (excluding NRC) to workers was approximately 1:8.
18 Further, other inspectors, (e.g.,
State of California, 19 Hartford Steam Boiler, and ASME) were much in evidence.
With regard to the general concept of audits, 20 i
21 PGandE required that routine (Program) audits be conducted l
22 to assure the programmatic implementation of QA requirements and activity audits be conducted to provide reviews of 23 24 compliance to implementing procedures.
These audits also 25 reviewed all records concerning:
26
///,
F
1 Nonconformance reports.
Minor variation reports.
2 Design change notices.
3 4
Equipment inspections.
5 Inspector qualifications.
6 Drawing control.
7 Some findings and deficiencies resulted from NRC 8
inspections _a,n_d PGan,dE QA audits.
This is to be expected 9
for any nuclear power plant construction QA program.
It is 10 also. indicative that the programs were performing their 11 intended function.
Despite a rigorous audit and inspection 12 Program, there have been no findings to indicate serious 13 deficiencies related to the construction QA/QC program at 14 DCPP.
15 The Hubbard affidavit cites only four discrepan-l 16 cies that could even remotely be considered to involve work 17 activities under the purview of the construction QA/QC l
18 Program.
Alleged " errors" IV.J.
IV.Q, IV.R. and IV.T are i
19 arguably associated with the construction QA/QC program, and 20 these dwell heavily on the issue of problems with as-built 21 drawings.
(Hubbard aff. pp. 14-32.)
In fact, IV.J and IV.T are"the same irsue.
22 23 The. assertion is made thats discrepancies between 24 as-built drawings and as-built construction reflect poor l
25 construction.
This argument is simply erroneous.
The g
l l
26 appropriate question should be whether the as-built drawings l.
l
\\
1 1
accurately reflect construction, not vice-versa.
In point 2
of fact, as-built drawings are made after construction work 3
is complete.
But the real test of construction quality is whether the construction accurately reflects the approved 4
5 design including approved field changes.
6 4.
OTHER MISCHARACTERIZATIONS AND/OR 7
MISSTATEMENTS IN HUBBARD AFFIDAVIT.
8 9
In alleging that the PGandE QA Program was defi-10 cient, Mr. Hubbard has made a number of erroneous statements and mischaracterizations in his affidavit.
Some further 11 12 examples of these are described below.
Item 112 In referring to 10,000 anchor bolt 13 installations, reference is presumably made to 14 additional bolts installed as a result of the 15 16 Bulletin 02 program, and if so the statement is in error.
It is true a large number of additional anchor 17 bolts were installed but this was the result of a 18 cost-benefit decision which concluded it would be less l
19 20 costly to add the larger number of bolts than to l
perform reanalysis to justify existing installations.
21 If the reanalysis had been conducted, the number of 22 bolt modifications would have been minimal.
This 23 problem was reflective of an industry-wide concern over 24 anchor bolt capacities.
25 s
///
26 S i
1 Item IV.V The affidavit concludes that, 2
based on the 24 design errors cited earlier in Section 3
IV and the additional discrepancies identified by 4
PGandE and the independent auditors in the semi-monthly 5
reports, a series of QA/QC " breakdowns" and associated 6
regulatory violations of NRC Regulations have occurred.
7 8
- Howev_er, a substantial portion of the " errors" and 9
" discrepancies" referred to have no demonstrable 10 relationship to Hubbard's alleged QA/QC " breakdowns."
11 Many of the " additional discrepancies" are differences 12 in calculated results that exceed the 15% reporting 13 threshold established by the IDVP.
These differences 14 can be due to many factors such as the use of different 15 assumptions or calculational methods.
The mere 16 existence of a difference in results does not indicate 17 a violation of regulatory requirements or a QA/QC 18
" breakdown."
Compliance of the original design work 19 with applicable QA/QC requirements and procedures can l
20 not be called into question by differences in results l
21 of this nature.
This distinction becomes significant l
l 22 when it is recognized that the affidavit repeatedly l
23 characterizes the same items (3.e. those reported in 24 the semi-monthly reports) as associated with "QA/QC 25 breakdowns" and uses clear differences in terminology g
26 to describe them.
Examples are: - -
one hundred and eighty-five 1
a.
pages 14 2
(185) additional design and construction 3
discrepancies have subsequently been disclosed in 4
biweekly status reports 5
b.
page 25 the independent design 6
verificaton program has identified one hundred 7
fifty-six (156) potential errors in the Error and 8
Open Item (EOI) reports.
-.m 9
c.
page 82 - "
the nearly 200 design and 10 construction deficiencies identifed to date, and 11 summarized herein in Section IV, had as a 12 significant root cause the failure of PGandE to 13 implement the required and committed to QA/QC 14 Program."
15 d.
page 99
. nearly 200 examples have been set 16 forth herein which document PGandE's failure to 17 Provide a QA/QC program.
18 Item V.A The Staff, PGandE, and ACRS did not 19 rely on the QA/QC program to allow reduced safety 20 margins.
Mr. Hubbard cites his own earlier opinion in 21 Attachment V of his affidavit, but fails to cite any 22 factual evidence 'to support that conclusion.
The 23 statements quoted by Mr. Hubbard simply do not support 24 his conclusion and to our knowledge neither does the 25 licensing record.
In fact, to reduce margins because s
26 of expectations of better quality performance is not 4
1 technical capability.
Quality assurance is not a 2
factor.
3 Mr. Hubbard has misrepresented the use and 4
purpose of the lists included in attachments G, H and 5
I.
The list in attachment G is the Qualified Suppliers 6
List which was required until 1979 by QA Procedure 7
PRP5.
Quality Assurance procedures prior to 1979 did 8
not require Contractors for Services (Consultants) to
- - ~
9 be listed as a qualified supplier.
Contracts for 10 Consultant work were processed and issued by the 11 Engineering Department in accordance with the 12 department's internal procedures.
These procedures did 13 not require that a formal list be developed.
PGandE 14 discontinued mandatory use of the Qualified Suppliers 15 List in 1979; however, PGandE still retains all the 16 requirements for establishing a qualified supplier.
(
17 The requirement for publishing a " List" was deleted 1
18 from the program due to the inordinate amount of work 19 required to maintain qualifications of the suppliers
(
listed.
Infrequent use of particular suppliers 20 21 subjected them to unnecessary audits and more 22 importantly, wasted valuable QA resources which could 23 be used to better advantage in, the surveillance of 24 other company safety-related activities.
25 Attachment H is a list developed for infor-26 mation used only in order to perform a selection of !
1 safety related contractors who would be subject to a 2
Quality Assurance review according to IDVP. ~It was not 3
and is not intended to represent a-' formal listing of 4
approved contractors, and therefore Consultants that 5
appear in attachment H would not necessarily appear in Attachment G for the reason described in the preceding 6
7 paragraph.
The list included in Attachment I is a 8
9 special list developed for environmental qualification 10 of equipment only.
All suppliers listed or, inferred were qualified by PGandE Quality Assurance or were 11 12 subsuppliers to the supplier of the major component.
13 These subsuppliers were qualified under the provisions 14 of the procurement requirements required of the primary 15 supplier quality assurance program.
Item VII.F The assertion is made that PGandE 16 failed to conduct adequate design reviews in a timely 17 fashion and that audits of the design review process 18 19 did not result in appropriate follow-up action to cor-20 rect conditions adverse to quality.
This assertion is based on the results of three PGandE audits perfoimed 21 at various times.
However, Hubbard's assertion is 22 based on.mischaracterizations of the audit results he 23 24 presents.
Some examples of the mischaracterizations are as follows:
25 26
/// 4
1 a.
Paragraph 80, concerning an Audit performed in 2
April 1977, states that PGandE auditors once again 3
concluded that compliance with design review 4
measures was inadequate.
Review of the report 5
itself (Attachment N to Hubbard's affidavit) 6 yields the opposite conclusion.
Section 2.0 of 7
Audit No. 77016 states in part:
g The designs of all the selected
-structures, systems and components 9
have been reviewed.
These reviews comply with the requirements of 10' Procedure PRE-6 except that (1) some apparent design deficiencies 11 identified by the reviews have not been resolved and (2) several de-12 sign review reports lack required approvals.
13 14 Section 3.0 of the same report states in part:
15 The activities reported as incom-plete and the resolutions consider-16 ed open~ to question could not be considered as infractions or defi-17 ciencies until after the deadline for completion of the design 18 reviews.
l 1
19 It is clear from the foregoing that the auditors l
l 20 recognized and identified an item which would have 21 to be completed.
It is not unusual for this 22 condition to exist during the conduct of an audit, 23 and it provides proof tha', there was an active, 1
functioning design review program in place.
24 25
///
e, 26
///
1
.s y
s 1
The second quotation (regarding ANSI N45.2.117 by
[
i l
2 Hubbard from this audit does not reflect any 3
deficiency.
The. statement is a recommendation from the audit team.
4 5
s on record 6
There is additional,information 7
indicating the ~yresence of an adequate design K
s review program durdng the 1977 period.s.See 8
.s 9, p. 13 (response to the Reed'y Repor't) 10 which states in part:
w 11 At this same time, the NRC reviewed
^
PGandE's procedureT PRE-6, "Compre-hensive Design Reviews, and found l
12 that it provided adquate guidance for the conduct and approval of-
[
13 comprehensive design revi'ews (NRC' 14 Report 50-275/77-12).
Subsequent
's NRC inspections and PGandE quality l
15 Assurance audits of these compre 4
l hensive design reviews confirmed.
~
that the reviews.were completed in s
16 accordance with the requirements of
~
17 this procedures 18 b.
Paragraph 81, concerning an Audit in February 19
- 1979, states that PGandE auditors identified 20 significant deficiencies in the PGandE design verification.
Again, review of the report yields 21 a
different picture.
The cover letter 22 characterizes _the audit' results as follows:
23 The attached audit report concludes 24 that completed design verification conforms to requirements but that 25 much of thTs work is still in prog-s 26 ress.
s
1 The cover letter specifically characterizes the 2
four. discrepancies noted as less significant than 3
"nonconformances" which, in the PGandE program, 4
would be the. classification for significant 5
conditions adverse to quality.
As before, this 6
audit report indicates the presence of an active, l
7 functioning design review program.
a
///
9
///
s 10
///
11 1
12 13 l
14 i
15 l
16 17 18 19 20 l
21 22 23 5
24 25 s
26 l
l '
i u-
1 2
Since the audits cited above do not, when taken as 3
a whole, indicate failure to conduct design 4
reviews in a timely manner, the basis for claiming 5
a " breakdown" in th QA/QC program is not apparent.
6 7
Dated:
July 2, 1982 8
9 10 (N
Warren A.
Raym Charles W. Dic V 11 b'
12 Michael J. Jacobs'tFd 13 14 15 Subscribed and sworn to before 16 me this 2nd day of July, 1982 i
17 18 SEAL 3(ncy J'.
- Lemaster, 19 Notary Public in and for the City and County of San Francisco, State of California.
20 My commission expires April 14, 1986.
21 22 23 24 25 g
26 l
' a
1 PROFESSIONAL QUALIFICAiiONS OF 2
WARREN A. RAYMOND 3
4 5
My name is Warren A. Raymond.
I am the manager of r
l 6
Quality Assurance for Pacific Gas and Electric Company and l
i,
7 have the responsibility of implementing a Corporate-Quality l
8 Assurance Program in the areas of engineering, construction, 9
procurement, and operation.
10 My educational background is as follows:
l 11 University of Minnesota - BS in Electrical Engineering, l
12 1950.
13 Atomic Power Equipment Department (GE) - Dresden Technology 14 Course, 1957.
Radioactivity and Nuclear 15 University of California 16 Structure, 1958.
17 University of Idaho - Public Utility Executive Course, 1964.
18 I joined PGandE in 1950 as an engineer in power 19 plant operation with responsibility for equipment 20 performance and instrument maintenance.
In 1957 I was 21 assigned the position of Plant Superintendent at the 22 Vallecitos Boiling Water Reactor Facility in Pleasanton, l
23 California.
From that position, ip 1961 I assumed the 24 position of Start-up Coordinator for Humboldt Bay Power 1
25 Plant Unit 3 (nuclear unit) and in 1971 became Plant s
26
///
1 Superintendent.
I was a licensed Reactor Operator from 1958 2
to 1963 and a Senior Reactor Operator from 1963 to 1979.
3 In 1979 I transferred to my present position of 4
- Manager, Quality Assurance (previously Director), with 5
overall management responsibility for the implementation of 6
the Corporate Quality Assurance Program.
I have 29 years of 7
power plant experience involving all aspects of operation.
8 I have been a member of the ANS Committee for the 9
Development of Simulators for Use for Reactor Operator 10 Training, and am presently a member of the ASME Steering 11 Committee for Owners Certification.
12 13 14 15 16 17 18 19 20 21 l
22 23 l
24 l
25 g
26
, l s
(
1 PROFESSIONAL QUALIFICATIONS OF 2
CHARLES W. DICK 3
4 5
My name is Charles W.
Dick.
I am. a project 6
manager and a member of the project management team of the 7
Diablo Canyon Project consisting of the integrated 8
organization of Bechtel Power Corporation and Pacific Gas 9
and Electric Company, and with responsibilities which 10 include quality assurance.
I am a Licensed Professional 11 Engineer in the states of California, New York, and 12 Pennsylvania.
13 My education background is as follows:
BS in Electrical 14 California Institute of Technology 15 Engineering, 1946.
16 Stanford University - MS in Electrical Engineering, 1948.
17 I have also had additional training through 18 Advanced Engineering Programs, in Business Administration, 19 and from various technical and business courses.
20 Prior to my recent assignment to the Diablo Canyon l
l 21 Project, I was been Manager of Division Quality Assurance 22 Di ision at the Bechtel Power Corporation from 1980-1982.
23 My responsibilities included formul. ting the QA programs for 24 implementing such programs, and training QA personnel for 25 some 14 nuclear projects.
s 26
///._
I joined Bechtel Power Corporation in 1965 and w rked as a project engineer on various nuclear and 2
f ssil-fuel projects.
I was responsible for project 3
engineering work for a number of different types of power 4
Projects and studies, for nuclear standards development and 5
for licensing.
Beginning in 1973, I became an Engineering Manager and
.ubsequently Manager of Engineering,.with 7
overall management responsibility for the project g
engineering work on more than 20 power plant projects.
g Prior to my employment at Bechtel, I was engaged g
as an engineer with the General Electric Company beginning in 1948.
During that time, I was involved in marketing and application engineering related to nuclear power facilities.
13 Prior to that I was assigned as an electric utility applications engineer and provided consultation services 15 involving heavy electrical apparatus.
I am a senior member of IEEE and a member of the r
17 American Society for Quality Control.
I was also a member of the industry ' working group for development of ANSI g
l Standard N45.2.ll (Quality Assurance Standards for Design of 20 Nuclear Power Plants).
1 22 23 24 25 g
26 I
l l
1 PROFESSIONAL QUALIFICATIONS OF 2
MICHAEL J. JACOBSON 3
4 5
6 My name is Michael J. Jacobson.
I am the Project 7
Quality Assurance (QA) Engineer for the Diablo Canyon a
Project consisting of the integrated organization of Bechtel Power Cohoration a d Pacific Gas and Electric Company.
I 9
10 am a Registered Professional Quality Engineer in the State 11 of California.
12 My educational background is as follows:
13 Sacramento State College - BS in Civil Engineering, 1970.
14 Golden Gate University'- Business Management Certificate in 15 Management, 1979.
16 I joined Bechtel Power Corporation in 1970 as a 17 quality assurance engineer responsible for various aspects 18 of design phase quality assurance on a nuclear power plant i
19 Project.
I was subsequently responsible for performing l
l 20 structural design and seismic analysis activities on the 21 project.
Later, I was assigned as Project Quality Assurance 22 Engineer responsible for supervising project QA activities, 23 including direction of quality audits of construction 24 activities.
l 25 Subsequently, I was assigned Project QA Engineer s
26 on various other nuclear power plants, where I was i
s d
1 responsible for directing project QA programs.
I was 2
responsible for ensuring that project construction and site 3
activities, as well as quality control aspects, met 4
applicable QA and regulatory requirements.
5 I was assigned to the Diablo Canyon Project in 6
1982 to direct and control the QA program for this project.
7 8
9 10 11 12 13 14 l
l 15 16 17 18 l
i 19 20 l
21 1
22 23 24 25 s
26
4/15/82 ss tq, ei t-01-2:
JUL 1c EC2' COMMENTSONTHER.F. REEDY,INC.,QUALITYASSURANCE{
Omce of the S1 AUDIT REPORT ON SAFETY-RELATED ACTIVITIES Og gy * (^L.
Q3
/
PERFORMED BY PG&E PRIOR TO JUNE 1978 Ny' l
~
I.
INTRODUCTION At the April 1, 1982beeti$gwiththeNRC,PacificGasandElectricCompany (PG&E) committed to submit a formal response to the R. F. Reedy, Inc., Quality Assurance Audit Report (Report) within two weeks.
At this meeting it was confirmed the audit was based on a 1982 interpretation of 10CFR50 Appendix B, as well as guidance from ANSI N45.2.11 (Design Control), and applied to the work performed prior to June 1978.
For this reason we believe that comments on the Report are appropriate.to place the findings in proper perspective, to correct certain inaccuracie's or omissions, to describe the historical development and refinement of the PG&E Quality Assurance Program, and to
(
present some different conclusions.
Important factors regarding our quality programs were presented in the November 19, 1981 statement of our Mr. G. A. Maneatis to the Subco==ittee on Interior and Insular Af f airs of the U.S. House of Representatives (Attach-ment 1).
In that statement, evidence was provided as to the dedication of PG&E to formulating and implementing an effective quality assurance program.
We believe this presents a much more quality-conscious image than that obtained from the Report.
PG&E did provide controls for the work performed, consistent with our commitments to regulatory requirements and their interpretations in existence at the time the work was accomplished; however, our engineering activities were not documented by 1982 Quality Assurance standards.
It is also important that the past work is being further confirmed by comprehensive design verification activities being performed by independent consultants,
by PG&E, and by certain design contractors.
The key to understanding our position is to recognize that Diablo Canyon is a project mostly designed and built to quality standards of the late 1960s and early 1970s.
It is now 16 years since the first =ajor project commitments were made.
During this time, the NRC (AEC) regulations requiring quality assurance programs were first issued, interpretative standards were developed, and enforcement practices evolved.
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PG&E's Quality Assurance effort evolved fro = the preliminary proposed statement of the 18 Criteria in early 1969 to the comprehensive regulatory scheme of 1982.
During this period, the NRC inspection effort has also evolved from an inspector's individual inspection plan in the early 1970s to a sophisticated co=puter-controlled inspection program in 1982.
The Report spans almost this entire period; however, no acknowledgment is made of the many interpretations and changes implemented by Regulatory Guides, Appendices to existing regula-tions, or experience gained as a result of evaluation of the construction and operation of nuclear power plants.
This evolutionary process should be kept in mind in reviewing the following brief outline of significant milestones of
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the design and construction of Diablo Canyon as referenced to the development of NRC Quality Assurance guidance.
We recognize the dile==a-faced by R. F. Reedy, Inc., in attempting to go back and remember what the interpretation of Appendix B was in the 1972 era before issuance of the subsequent interpretative ANSI Standards and Regulatory Guides.
We agree with Mr. Reedy that to do so would be impractical, if not impossible.
(Tr. p 14)* As a result, it is extremely difficult to achieve meaningful results from this type of audit, where the history is so extensive and quality assurance requirements were evolving as project work proceeded.
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- Refers to Transcript of April 1,1982, NRC " Meeting With Pacific Gas and Electric Company to Discuss Seismic Design Review, Diablo Canyon Unit 1."
II.
HISTORY The Diablo Canyon project study started in 1964 and resulted in the issuance of a contract for the Nuclear Steam Supply System (NSSS) in November 1966 -
approxi=ately 2 1/2 years before the proposed Appendix B to 10CFR50 was issued for comment.
The Unit 1 PSAR was submitted in January 1967, prior to the l
identification of formal quality assurance requirements, and thus the require-ments were not specifically addressed.
Supplement 5 to the Unit 1 PSAR was submitted in November 1967 and described a quality program for the primary l
system.
The Construction Permit for Unit I was issued in April 1968 (one year prior to publication of the proposed Appendix B to 10CFR50), and construction of the major buildings commenced in June 1969. At this time the seismic design for Unit I was essentially complete.
Two months prior to the start of major construction on Unit 1, the proposed 10CFR50 Appendix B was published for
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Comment.
Formal quality assur'ance reqdirements were first addressed in Appendix G to the Unit 2 PSAR which was submitted in July 1969.
That appendix addressed 10CFR50 Appendix B requirements a's follows:
QUALITY ASSURANCE A comprehensive Qualit.y Assurance Program for the design and construction of Unit 2 at Diablo Canyon will be established by Pacific Gas and Electric Company in the discharge of its
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responsibility to build a safe and reliable nuclear power plant.
The program will be an extension of the quality assurance program developed for Unit 1, and will benefit from the experience gained from the earlier program.
its This Appendix discusses the scope of the program, organization and management, and the implementation of the technical and syste=s aspects of the program.
The organi-zation of the material in this Appendix is based on the divisions used in the proposed " Appendix B - Quality Assurance Criteria for Nuclear Power Plants", issued for comment by the Atomic Energy Commission on April 17, 1969.
Since there is substantial overlap in the material covered in the various headings, the subject matter of an individual l
division should not be considered separately but in relation to the entire Appendix.
PG&E established a Quality Engineering Department in November 1969 to implement this com=itment to a Quality Assurance Program, and two months later the This Company issued a Quality Assurance Manual for Design and Construction.
manual was developed utilizing the proposed criteria (April 1969) since 10CFR50 Appendix B was not formally published until June 1970.
Since that time PG&E 2.
has continually reviewed and modified, as necessary, its Quality Assurance Program and organizational structure in order to be responsive to the evolving regulatory guidance and industry standards.
d Erection of major piping systems for Unit 1 started in November 1970, approximately six months after Appendix B was issued and four months before 10CFR50 Appendix A was issued.
It has been estimated that design at that time was about half complete.
The NSSS installation began in September 1972, and Unit I construction was completed by November 1975 and a " Hot Functional Test" was conducted.
One month later, Unit I was licensed to receive and store fuel in. preparation for fuel loading.
During this period,'there were several concurrent industry and NRC actions that had a significant impact on the evolution of quality assurance require-ments.
Appendix B to 10CFR50 was issued with a minimum of definition as to the detail required for implementation.
In 1970, industry began to form technical groups to define Appendix B requirements.
This effort resulted in the development of the N45.2 series of standards.
Even though these standards did much to interpret an_d provi,de guidance on the application of the Appendix B requirements, the NRC four.d it necessary to conduct a series of meetings in the mid-1970s and to issue clarifications (Rainbow Books) to provide guidance in the establishment of industry quality assurance programs.
An example of i
the difficulty encountered in developing a meaningful interpretation of Quality Assurance requirements was illustrated by the development of ANSI N45.2.13.
The work on this standard began in September 1971 and it was not completed until 1976 when the standard yas issued - a period of approximately five years.
The NRC endorsed this standard in July 1977 - about six years after work on the standard was started.
By that time Diablo Canyon had completed construction, hot functional testing, and was ready to load fuel.
Since that time, PG&E has been involved in the Hosgri investigation, redesign for the postulated Hosgri event, and the TMI-related backfits.
l In addition to the WASH documents (Rainbow Books), the NRC has issued Regulatory Guides which affect the interpretation of 10CFR50 Appendix B.
For example, the Standard Review Plan references 17 Quality Assurance Progra==atic Regulatory Guides which are applicable to present day design and construction of nuclear power plants.
Many of these Regulatory Guides were issued af ter Unit 1 construction was complete but have had a significant effect on the current interpretation of 10CFR50 Appendix B.
In order to place the significant events involving Diablo Canyon in pirspective, we are attaching a chronology of significant milestones of Unit I design and construction referenced to NRC regulations, industry standards, and Regulatory Guides.
(Attachment 2) 4
III.
APPLICATION OF AUDIT CRITERIA A principal concern which was discussed and acknowledged at the April 1, 1982 meeting is that the Report was compiled utilizing "today's" understanding of the 10CFR50 Appendix B criteria for evaluating the ad,equacy of the PG&E quality assurance program during the pre-June 1978 period.
In our. view, the use of current interpretations of requirements as criteria for a historical audit of a quality assurance program over the past four to twelve years has created an erroneous and misleading perspective regarding the relative effectiveness of the PG&E quality assurance program.
In our meeting on April 1, 1982, Mr. Reedy stated that the Report did not consider the PG&E quality assurance program as committed to in the PSAR.
(Tr. p 12) We strongly believe that the PSAR information would have been the proper base f~'E~t'he develbpment of audit criteria.
o The fact that the Report used current interpretations of 10CFR50 Appendix B criteria was made quite evident several times during said meeting.
(Tr. pp 13 & 14)
It is important to note that the use of "today's" interpretation of Appendix B arose from the R. F. Reedy, Inc., interpretation of the Order, and further, that Mr. Reedy was not in agreement with that approach, but felt it was the k
only avenue available.
(Tr. p 14) x Even more important, Mr. Reedy apparently agrees with our position when in response to a question from the NRC Staff regarding his feeling about the strictness of the criteria used to make the statements made in the Report, Mr. Reedy stated:
"I have to agree with you that the strict interpretation that we use was completely unfair.
The order to me did not seem to be fair to begin with, and I made a comment at the time that the evaluation should be done to the criteria that was in use at the time this program was accepted by the NRC and j
audited by the NRC, but we did not go back and say we will accept what the NRC audited and what they accepted. We will use the criteria in the order. Now I don' t think that is fair, but that is what we did."
(Tr. pp 32 & 33)
When 10CFR50 Appendix B was issued in 1970, there immediately arose many questions of interpretation. The industry, through the American National Standards Institute (ANSI) and the NRC (AEC) recognized the need for further
" guidance" on the interpretation of Appendix B.
Beginning in August 1970 with g
establish =ent of the ANSI N45 subco==ittee, N45-3 and through the present time, i
there has been an evolving set of Standards and Regulatory Guides that continue to refine, define, and in some cases redefine, the requirements of Appendix B.
Mr. Reedy succinctly covered this issue when he stated that:
"I think it is important to understand that the QA as written in the original 1970 Appendix B has had a lot of inter-pretations that were put out in safety guides and then in regulatory guides and then in adapting or adopting various -
the rainbow books, for example, the N45.2 series as an educational progression of changing standards in QA, and this occurred starting about 1970 and went on to the present time so you have a knowledge increase as to what is required in QA as interpreted by the NRC, but we were not taking that into account because the criteria established in the order was take 10'CVR'50,'Appehdix B, and I think that is the comment
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that John Hoch brought out earlier, that this is a strict criteria when you use the end result to compare to the learning curves that goes on over a period of twelve years."
(Tr. pp 12-13)
The NRC Staff appeared to be in general agreement with this opinion.
(Tr. p 41)
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An example of the impact of the use of today's strict interpretation of Appendix B is evidenced by the general issue of documentation.
The Report implies that procedures did not exist or reviews were not held.
The Report goes on to admit that many procedures and documents were in fact reviewed but that many of the documents were not " controlled" in accordance with today's standards, and hence no credit was given.
In response to a staff question regarding the general philosophy given to audit team members, Mr. Reedy replied:
"The primary consideration was, we will consider the document if it's a controlled document.
In other words, we felt that our work could be audited by anybody and the only way you could audit what we did and conclusions that we drew
'was on the basis of controlled documented evidence. A piece of paper pulled out of someone's file that shows a certain bit of information to me is not a cont;olled document, and we based our conclusions and things in the report on those documents that were officially controlled."
(Tr. pp 29 & 30) s
_s In our view, these observations should have been noted in the Report to ensure that credit was given for these quality assurance type controls that in fact existed.
This would enable any reviewer of the Report to obtain a more comprehensive understanding of the overall quality of the product rather than the more restrictive view given in the Report.
In summary, it is significant to note that the Staff expressed appreciation for the interpretive insight into the Report received at the meeting, because it altered the impressions received from initial reading of the Report.
(Tr. pp 36, 43, 102) We certainly agree with the Staff's response that when you take these observations into account you certainly get a diff,erent impression regarding the PG&E Quality Assurance Program during the pre-1978 period.
With the foregoing thoughts in mind, we now turn to our specific comments on the Report's conclusions.
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IV.
REVIEW OF REPORT CONCLUSIONS The Report draws three conclusions, presumably developed from a review of the findings, to which we have the following response:
Conclusion 1:
"The PG&E Quality Assurance program for design work was not adequate in areas of policy, procedures and implementation.
The Quality Assurance organization had insufficient program responsibility."
Co= ment:
The Report appears.to.. iew the. PG&E Quality Assurance Department as synonymous v
to the Quality Assurance Program.
This viewpoint disregards the wording in 10CFR50 Appendix 3 that states:
" Quality Assurance includes quality control, which comprises those quality assurance actions related to the physical characteristics of a material, structure, component or system which provides a means to control the quality of the material, structure, component or system to predetermined requirements."
PG&E's present Quality Assurance Program includes not only the Quality Assurance Department but also the Quality Control groups located in each
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department associated with nuclear activities.
The Quality Assurance Depart-and the Quality Control groups collectively monitor implementation of j
ment the Quality Assurance Program with the Quality Assurance Department performing l
an overview function.
While the PG&E Quality Assurance Program is structured so that the audit l
function of the Quality Assurance Department is highly visible, the Quality Assurance Department has always had, and executed, the responsibility for Quality Assurance Program definition and for assuring that an appropriate l
program is established.
This is discussed further under Programmatic Finding 1.
Conclusion 2:
"A general weakness existed in internal and external interface and docu=ent controls.
This questions whether appropriate design information was being exchanged and utilized by design groups and consultants.
One concern is if the latest l
Hosgri seismic data was inputtedifor design analysis."
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Comment:
On page 3 of the Report it is stated, "Where procedural coverage was not in place, the design documentation was used for determining if positive though informal controls were practiced." There is no discussion in the Report which indicates'what conclusions were reached when design documentation was reviewed.
The Report does not clarify that many documents were reviewed such as memos, instructions, and interdiscipline letters which were issued to further implement and supplement Quality Assurance Manual procedures.
These documents provide evidence that PG&E did indeed exercise controls for internal design documents.
This is discussed further under Programmatic Finding 3.
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Conclusion 3:
"The design verification program was not formalized and was inconsistently implemented and documented.
Thrs~ included major gaps in design overviews of the design approach for mechanical and other equipment."
Com=ent:
Contrary to the conclusion, PG6E's design verification program was formalized in Quality Assurance Procedure PRE-6 issued in 1970.
The Report concludes that there were major gaps in the design verification based on a "three element" definition which we believe goes beyond even present standards in some respects.
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We submit that this definition is not appropriate criteria for this audit.
The Report on page 2 clearly states under Evaluation Criteria that selected I
parts of ANSI N45.2.11 were considered for guidance in the quality assurance l
program review.
The application of these criteria was inappropriate and apparently resulted from a misinterpretation of Attachment 1 to the November 19, 1981 order, paragraph 1(a)(4) which intended that the criteria for the design verification program consider the relevant guidance in ANSI N45.2.11.
This is discussed further under Programmatic Finding 4.
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V.
FINDINGS Programmatic Finding 1:
" Quality Assurance as defined in the QA Manual was essentially an audit role.
The Quality Assurance group was not assigned a primary role in determining QA requirements."
Comment:
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The Quality Assurance Department, including its predecessor, Quality Engineering Department, has been responsible for the development and issuance of corporate policies and. procedures since the first issuance of the Quality Assurance Manual in 1970.
Implementation authority and responsibility for the Quality Assurance Program is assigned to the Manager, Quality Assurance (previously Director, Quality Assurance).
Revisions to the Policy Sections of the Quality Assurance Manual have always been reviewed and approved by senior management of PG&E and by the Manager, Quality Assurance.
These revisions have always been developed by the Quality Assurance Department with due consideration to comments received from other affected departments.
The Checklist on page 37 states:
"Until March 1972 Quality Engineering, which had responsibility for total quality program.
." This statement supports our comment that the Quality Assuranca Department is responsible for developing, issuing, and auditing implementation of the program.
If we interpret these Checklist comments as " deficiencies" against Appendix B requirements for independence of Quality Assurance, we are confident in asserting that for the 1970-72 period such an organizational arrangement was not unusual, but was probably typical and in conformity with accepted practice in the industry.
Progra=matic Finding 2:
"PG&E had no procedure for assuring the completeness of the QA program to address the requirements of 10CFR50, Appendix B."
Comment:
We disagree that a procedure is required to dr.monstrate a one-to-one correlation of the Quality Assurance Program with the elements of Appendix B.
On page 47 of the transcript, Mr. Reedy stated when asked if PG&E had any procedure which was intended to accomplish this activity:
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"No.
There was no procedure and I don't know that a procedure is really required."
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The finding implies that PG&E's Quality Assurance Program did not completely address NRC requirements.
PG&E committed to develop a program consistent with the proposed requirements of 10CFR50 Appendix B in the Unit 2 PSAR Appendix G in 1970:
"The organization of the material in this Appendix is based on the divisions used in the proposed
" Appendix B - Quality Assurance Criteria for Nuclear Power Plants", issued for comment by the Atomic Energy Commission on April 17, 1969.
Since there is substantial overlap in the material covered in the various headings, the subject matter of an individual division should not be considered separately but in relation to the entire Appendix."
This commitment is further emphasized in the Letter of Authorization for the Quality Assurance Manual signed by J. F. Bonner in 1970:
. the PG&E... Diablo Canyon Site, will be designed and constructed in full compliance witn the Quality Assurance Program developed from the plan described in Appehdix G of the Preliminary Safety Analysis Report
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From the foregoing and a review of the manual, it can be seen that the Revision 0 Quality Assurance Manual was based on the best available guidance from the NRC (AEC) at the time; e.g., the then draft version of 10CFR50, Appendix B.
The Policy Section of the Quality Assurance Manual in Section 2.1.2 states:
"The Director, Quality Assurance.... His responsibility is to review continually the Quality Assurance Program and to report on its adequacy and the extent to which it is being carried out."
This Policy Section was issued in 1970.
Programmatic Finding 3:
"There were no provisions for document control of correspondence and design documents."
Com=ent:
There were programmatic requirement provisions in the Quality Assurance Manual for document control of correspondence and design documents.
There were controls which described internal design interfaces and responsibilities for document control; however, these controls were contained in the work procedures and the implementation assigned to the Responsible Engineer.
(Examples are given in Attachment 3.) A specific procedure concerning these items only was not issued at that time. The Checklist, page 27, refers to Quality Assurance Manual, Revision 0, Section 3.2.3, Infor=ation Control, which states:
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" Written procedures are required to control correspondence, drawings, specifications, manufacturers' information, etc., in order to assure that the engineers and designers involved in the design (1) receive the necessary information to develop the design, and (2) are kept informed of the design being developed by other interfacing design organizations.
These procedures provide for the review, approval, release, distribution, and revision of design documents."
Also, during the exit interview it was stated that problems found with consultants had not been found to exist with equipment suppliers. ~'
This finding on document. cont,rol is discussed again in the Report as Finding 5 under " Implementation Deficiencies."
Implementation Finding 5:
"There was no effective document control ystem established."
Com=ent:
These controls were inplemented in project instructions, Engineering discipline memos, and departmental procedures and were not part of a formal system of procedure control such as we have today.
Page 39 of the Checklist states that coordination activities were controlled by memoranda, but the memoranda were not part of a formally controlled system.
Page 24 of the Checklist notes that drawing control procedures were acceptable for PG&E drawings.
Page 66 of the Checklist states that " evidence exists to verify that correspondence was reviewed but no formal procedures were used."
These statements all support our comment that controls did exist.
The Report implies that the overall drawing control system was. inadequate.
This conclusion is apparently based upon reviewing five or six pipe support drawings (see page 87 of the Checklist).
It is not appropriate to attempt a conclusion based on only a review of the pipe support drawings.
PG&E recognized the control of pipe support drawings involved problems due to the number of~ supports and the number of revisions required.
This was documented in a 1978 Nonconfor=ance Report in which special procedures were written to control support drawings and changes, i
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Programmatic Finding 4:
"During Phase I, there were no controlled procedures for design control, design interfaces and design responsibilities.
PRE-9 and PRE-10 on these subjects were released in 1979 and are to be audited during Phase II."
Comment:
There were existing controlled procedures in the Quality Assurance Manual covering these program elements.
The Checklist, particularly on pages 17 through 24, indicates these were reviewed and in many cases found to be acceptable. These requirements were addressed in Section III of the Quality Assurance Manual Policy and the following procedures:
PRE 2 - Design Development PRE 3 - Drawing Preparation, Review and Approval PRE 4 - Specifications
. PRE 6 - Comprehensive Design Reviews In addition to these, there were " uncontrolled" implementing procedures (Attachment 3) as noted by Mr'., Reedy.
(Tr. p 54)
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It should be noted that during this period, PG&E's use of consultants for
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engineering services was limited since a very significant amount of Phase I design work was done in-house and was completed prior to June 1970 when 10CFR50 Appendix B was issued.
l As we stated at the November 3,1981 meeting, the NRC and PG&E, in 1977, recognized that comprehensive design reviews needed to be completed on all licensee designated Class I structures, systems, and components prior to fuel loading.
PG&E agreed to perform the design reviews.
Also in report No. 50-275/77-12 issued in 1977, the NRC stated that PG&E Procedure PRE-6 provided adequate guidance for the conduct and approval of comprehensive design reviews.
l This finding on design controls is directly related to Finding 4 discussed in the Report under " Implementation Deficiencies."
Implementation Finding 4:
"PG&E design verification on in-house activities and suppliers was unstructured and applied inconsistently.
We consider that design verification consists of the l
following three elements:
"1) Design overview for design approach, methods, design input selection, and assumptions.
s "2)
Detailed checking of design steps and completed design documents.
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_14 "3) Verification of approved "As Built" condition against approved design.
" Activities for element 3 were not initiated until 1979 and are to be reviewed during Phase II.
Documentation showed detailed checks to be. performed on PG&E work with design overviews being performed on a selective basis. Most of what PG&E refers to as Design Reviews consists of element 2."
Comment:
As stated above, PG&E's design verification process was structured in Quality Assurance Precedure PRE-6 and-was" reviewed and found acceptable by the NRC in report No. 50-275/77-12.
Further, the three elements together are not appropriate because:
- Elements 1 and 2 can be acceptable methods for design verification even when used individually.
They are not consistent with the Commission order dated November 19, 1981 even for applying today's f
I criteria.
- Element 3 is not required for design verification by applicable quality assurance requirements.
The Report draws the conclusion that most of PG&E's design reviews consisted i
of element 2 which in itself is consistent with N45.2.11.
While listed as an implementation deficiency, it appears to draw the conclusion that this is a programmatic deficiency also. PG&E submits that in the 1970-74 time frame, element 2 was generally accepted industrywide (until N45.2.11 and Regulatory Guide 1.64 were issued for additional supplemental guidance).
Regarding element 3, it clearly has merit for some situations, but it is neither required nor implied by current Regulatory Guides, ANSI Standards, or 10CFR50.
PG&E has always maintained and has always had procedures and requirements for as-builting, and has never considered as-builting as an aspect of design verification.
Simply stated, a design requirement is considered "as-built" when the construction or installation is verified as,being within the tolerance, configuration, etc., of the design document.
PG&E has always maintained a construction inspection engineering staff to assure that the plant l
1s buiit as designed; and when deviations are encountered, they are as-built and returned to the Engineering Depart =ent for approval.
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Programmatic Finding 5:
"PG&E did not require design consultants to implement.
Quality Assurance requirements."
Comment:
PG&E concedes that during the Phase I period, the program did not formally require design consultants to implement Quality Assurance program requirements.
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Guidance on control of procurement of items and services was widely interpreted, j
and we submit that it was neither uniformly understood nor typical industry practice to impose such requirements specifically on design consultants during essentially all of the Phase I period.
Evolution of the PG&E Quality Assurance program as previously discussed in Secticn II was consistent with the rest of the industry.
This finding on quality assurance requirements for design consultants is also discussed in the Report as Finding 3 under " Implementation Deficiencies."
Implementation l
Finding 3:
" Design consultants were not required to implement Quality Assurance Programs."
i Comment:
This finding does not clarify that PG&E began reviewing the quality assurance programs of seismic consultants in 1977 and that all consultants were required to submit a Quality Assurance Program starting in mid-to-late 1977 and were reviewed and qualified by mid-1978. As indicated on page 46 of the Checklist, two consultants implemented a Quality Assurance Program prior to mid-1978 one in 1974 and the other in 1977.
In addition, PG&E utilized a Responsible Engineer in residence for seismic testing.
(Tr. p 89) 1 1
Programmatic j
Finding 6:
" Corrective action provisions were not addressed except with respect to audit deficiencies and deficiencies at the site."
Comment:
The Transcript clarifies that the Report only applies to safety-related seismic design activities.
Looking at this finding with that viewpoint, this finding is correct.
However, the Report does not clarify that this program =atic l
deficiency was corrected in late 1975.
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The Quality Assurance Manual for Operating Nuclear Power Plants issued for trial use in March 1975 contained a preli=inary version of Quality Assurance Procedure (QAP) No. 8.1, "Nonconformances." Page 52 of the Checklist states under Audit Instruction, " Prior to issuance of PRM-3 (2/1/78), what measures were established to identify and control conditions adverse tjl quality and obtain corrective action to prevent recurrence?" The implication here is that PRM-3 was a satisf actory procedure.
It should be noted here that PRM-3 was developed for the Design and Construction Quality Assurance Manual from QAP 8.1.
The Report did not identify the existence of QAP 8.1, presumably because it was contained in the Quality Assurance Manual for Operating Nuclear Power Plants.
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Although contained in the Operating Quality Assurance Manual, QAP 8.1 was
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applicable to Diablo Canyon Power Plant work at the time it was issued as evidenced by the following statements from the September 26, 1975 cover letter issuing the manual:
"With this letter the revised Manual is being distributed.
The new version has been approved and signed by the President and the Senior Vice President.
It is important that any aspects of the quality assurance program which may not yet be fully in effect be implemented without delay."
" Inspectors from Region V, Nuclear Regulatory Commission, have been reviewing the Manual and have begun inspections to evaluate our implementation of the program.
By the early part of November we will need to demonstrate to the NRC inspectors a fully implemented quality assurance program at Diablo Canyon or run a risk of delaying the operating license."
"The Quality Assurance Department will be conducting l
audits in the near future to evaluate the effectiveness l
of the program."
QAP 8.1 contained the following pacagraph under Section 2.0, APPLICATION:
"2.1 The Plant Superintendent, Manager, Station Construction, and Project Engineer are responsible for seeing that non-confor=ances occurring in work under their control are promptly disposed of in accordance with this Procedure."
This paragraph clearly describes the Project Engineer's responsibility to disposition deficiencies found in design activities in accordance with QAP 8.1.
QAP 8.1 was developed during the review of the corporate program which took g
l place for the Operating Quality Assurance Manual in anticipation of Unit 1 l
t going into operation in late 1975 or early 1976.
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This finding on corrective action provisions for design deficiencies is
~ directly related to Finding 2 discussed in the Report under " Implementation Deficiencies."
Implementation Finding 2:
"The PG&E audit system and corrective action system were not effective."
Comment:
It is inaccurate to imply that the overall audit and corrective action ~ systems were not effective.
All of the substatements made for this finding apply to the pre-1976 period.___As dis.cu,ssed above, QAP 8.1 was issued in September 1975 to correct this programmatic deficiency.
Page 53 of the Checklist shows aspects of the PG&E audit program that were found acceptable.
Page 31 of the Checklist shows the portions of the Quality Assurance Program covering corrective action for suppliers, contractors, on-site discrepancies, and audit results, all of which were found acceptable.
In the audits conducted in the Engineering Department between 1969 and 1978, deficiencies were identified and corrective actions were specified.
All audit reports were distributed to senior management.
We would also note that Mr. Reedy clarified that he did not intend to imply that corrective action was not taken; rather, he did not see a corrective action document that he was accustomed to seeing.
(Tr. p 84)
The third subparagraph of this finding, which states:
" Corrective action verification was by re-audit only" apparently finds verification by reaudit to be a deficiency.
This practice was an acceptable technique recognized by the NRC (AEC) guidance document WASH 1283 (Revision 1, May 24,1974), which contains Draf t 3, Revision 4, of ANSI N45.2.12.
Section 4.5.2 thereof states (for the auditing organization):
" Followup action may be accomplished through written communication, reaudit, or othe,r appropriate means."
[ Underline added.]
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- Program =atic Finding 7:
" Indoctrination and training were not addressed in the QA Manual or procedures."
Comment:
The 1970 Quality Assurance Manual, Revision 0, contains Appendices which are bound into and made a part of the manual.
Appendix 3 thereto, page B-6 states:
" Personnel involved in the Quality Assurance Progras will be trained and qualified in their respective fields.- Fersonnel performing non-destructive examina-tions must meet the qualification requirements of appropriate Codes and Standards.
Proficiencies will be monitored and training activity taken when necessary."
This topic is discussed in the Transcript on pages 47 and 48:
MR. REEDY:
"... There was a statement in the program 7
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that there would be training and indoctrination but nothing as to how it would be done.
That you will do this.
Each manager will do that, et cetera. We put l
down this as a programmatic deficiency in the respect that no detail -- just addressing it as an overall thing -- it wasn't provided, but other people could make a different interpretation of that.
The fact that it did address it could be interpreted differently."
MR. BISHOP:
"So you concluded there was no indoctrination or training?"
i MR. REEDY:
"It wasn't formalized and documented to the extent that you had controlled documents showing who received.what training when, on what subject."
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i Programmatic Finding 8:
"The QA Manual contained no provisions for PG&E management review of the QA program for status and adequacy."
C$ ament:
The requirement in Appendix B is:
,v "The applicant shall regularly review the status and adequecy of the quality assurance program.
Management of other_ organizations participating in the quality assurance program 'sh511 regularly review the status and adequacy of that part of the quality assurance program which they are executing."
We believe the process described below constitutes a review by management and satisfies the intent of the Appendix B requirement.
As noted in our comments on Programmatic Finding 1, all program policy
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changes have been reviewed and approved by senior management for authorization.
This review compared the revisions with Appendix B requirements. We have always considered that a revision to a procedure constitutes a review of that procedure.
Between 1970 and 1978, there were at least five revisions made to each individual section in the Policy Section of the Quality Assurance Manual.
Further, audit reports have been distributed to senior management as verified on page 35 of the Checklist.
NRC I&E Reports received the same distribution as PG&E Quality Assurance audit reports.
This topic is discussed on page 47 of the Transcript:
MR. REEDY:
"For example, there has been an awful lot of discussion about Item 8 which is management review of the QA program; and there was management review of all the changes at the program.
There was management review of all the audits, but the verification of that was extremely difficult to find.
It wasn't documented that we could pull out as a controlled thing that yes, this occurred.
It occurred because you might see a signature on someone's revision to the program but..."
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f -
s -
Further, on page 65:
x s
MR. REEDY:
"Now, there was QS or review on the part s.
of management of audits.
There was certainly review of program changes, so there was a management involvement in that, but we were trying to hone in specifically on theactivitytoverifytheeffectivenessofthe[ program,'
and to me a review of audits doesn't tell you'how "
effective the auditors are doing their work.
It tells you what they found but not were they really effective auditors, and that is the intent of my statement."
'i MR. BISHOP:
"What do you expect to see to have a positive finding on that type?"
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MR. REED.Y.:_.",I wou_1_d,. expect that someone would go in on-a periodic basis to see if they are arriving at similar N
conclusions to what the auditors would be " finding, the internal PG&E auditors, finding out if they are effec-tive.
In other words, do you concur with the type of' findings that they are coming up with?"
s MR. BISHOP:
"The third pa'rty?"
MR. REEDY:
" Third party, accompanying people,1 but just i
doing the same function again."
s We observe that only in recent experience has the NRC encobraged use of third party auditors, or has the industry regarded them as useful[.
In addition, page 68:
1 l
MR. HAASS:
"Was there implementation deficiencies tist.
q in with any use of stricter QA requirements than one would read in Appendix B?"
f' MR. REEDY:
"I think it would be easy for people going back to 1970 to say our manage =ent involvement in x
assessing our program and having discussions with QA
'i managers and looking at audit reports and talking to people was adequate to fulfill that requirementsin 1970, That type of activity in my mind was the type ofJ activity that was carried on in 1970.
It was certainly carried on there, but now when you are looking~for how is that documented as to what occurred?' Where are the minutes? They weren't there.
Again this is a very strict interpretation of today's requirement. What you would look for today. You would look for some kind of minutes of the meeting of what occurred.
So I'm not a
saying =anagement was not. involved.
That is not the intent of that statement."
7
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This finding on management review is discussed again in the Report as Finding 1 under " Implementation Deficiencies."
laplementation Finding 1:
"PG&E management did not review and assess.the effectiveness of the Quality Assurance Program."
Comment:
PG&E's senior management has always received and reviewed copies of audit reports.
By-this process the overall Quality Assurance Program has been continually assessed using both Quality Assurance Department and NRC reports as input.
As discuss.ed_a.bove, changes to the Policy Section of the Quality Assurance Manual required the review and approval of senior management.
Further, oral reports regarding the status of the Quality Assurance Program were given by the Quality Assurance Director to the Executive Vice President.
The Report mentions a program review by Energy Inc. (December 22, 1975).
Ve. submit that the Energy Inc. review is an important example of where senior management review and assessment were functioning.
The Energy Inc. review was commissioned by PG&E management and results acted upon.
Indeed, major changes in the PG&E Quality Assurance / Quality Control Program occurred following the
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Energy Inc. report.
For example, the Engineering Quality Control Department was established in 1976 and charged with the responsibility of developing and issuing a manual controlling Engineering Department activities. Additionally, a new Director of Quality Assurance was hired from outside the Company to provide aggressive and experienced leadership in the Quality Assurance Program.
This documented evidence refutes a finding that there was no management review and assessment of the program. While they may not have been documented, they, in fact, did take place and along with the other evidence noted above support r
a conclusion that manage =ent was indeed assessing the effectiveness of the Quality Assurance Program activities.
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___.._______1__.___._____.____
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- VI.
CONCLUSION In conclusion PG&E submits that:
Standing alone, the Report gives an erroneous impression of the pre-1978 PG&E Quality Assurance Program.
The use of 1982 interpretation of 10CFR30 Appendix B for a historical audit of pre-1978 activities is inappropriate; however, PG&E recognizes the impracticality, if not the impossibility, of attempting to reconstruct acceptable interpretations of Appendix B during that time frame.
The April 1, 1982 meeting did much to clarify these issues of concern to-PG&E-regarding the Report.
The foregoing comments provide further clarification of our concerns.
Finally, we believe that the Report, supplemented by these com=ents and the Transcript, provides an adequate basis for Teledyne Engineering Services to assess adequacy of the work performed by R. F. Reedy, Inc., and the implications of his work as they may impact upon the remainder of the Independent Verification Program.
t 4L
ATTACHMENT 1 1
STATEMENT 2
by 4
3 George A. Maneatis 4
Senior Vice President - Facilities Development 5
Pacific Gas and Electric Company 6
-before the 7
Subcommittee on Energy and Environment 8
Committee on Interior and Insular Affairs 9
U.S. House of, Representatives
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10 November 19, 1981 11 12 13 Good morning.
My name is George A. Maneatis and I am the 14 Senior Vice President - Facilities Development for Pacific. Gas
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15 ar.d Electric Company.
I am here today to discuss our Quality 16 Assurance Program in the context of the recently identified 17 errors in the seismic design for our Diablo Canyon Nuclear 18 Power Plant and to give our views on the implications of 19 these errors relative to quality assurance for reactors 20 under construction.
21 22 First, let me state that PGandE is committed to construct and 23 operate the Diablo Canyon Nuclear Power Plant in a manner that 24 will assure the public health and safety.
Paramount to this 25 commitment is the development and implementation of a Quality 26 Assurance Program.
The purpose of PGandE's Quality Assurance 27 Program is to provide policies, procedures, controls, and
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1 l
I mechanisms to meet 2he requirements of 10 CFR 50, Appendix B, 2
" Quality Assurance Criteria for Nuclear Power Plants and Fuel 3
Reprocessing Plants."
Such a program in addition to other 4
practices provides confidence that the designed and constructed 5
Diablo Canyon Nuclear. Power Plant will operate safely and 6
perform satisfactorily.
Quality Assurance is a management 7
and administrative tool which prescribes controls to detect 8
and correct errors in the design, construction, and operation 9
of nuclear facilities and, hen,ce, should minimize the proba-10 bility of-undetected errors.
However, Quality Assurance 11 cannot, in all cases, prevent errors from.being made*nor can 12 it guarantee that all errors will be detected.
It should be
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13 emphasized that Quality Assurance is only one of many factort 14 which contribute t'o the overall safety of a nuclear power plant.'
15 Conservative design and the redundancy and diversity of equip-16 ment and systems important to safety are other factors which 17 contribute to safety.
18 19 20 PGandE OUALITY ASSURANCE 21 To put Quality Assurance at PGandE in historical perspective, 22 t
23 a construction permit for the Diablo Canyon Nuclear Unit I was 24 issued by the Atomic Energy Commission (AEC) on April 23, 1968.
25 During the initial design and construction stages of the plant, Quality Assurance criteria were being formulated by the AEC 26 s
27 and were formally adopted and issued as Appendix B to 10 CFR 50 k
2
.e 1
in June 1970.
Thes,e Quality Assurance criteria became
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2 requirements for both Diablo Canyon units.
3 In anticipation of these requirements, PGandE organized a
.4 5
Quality Engineering Section (now called Quality Assurance 5
Department) in Novembe'r 1969 and assigned it responsibilities 7
for assuring that the design and construction of nuclear power 8
plants complied with applicable policies and procedures.
In 9
January 1970, PGandE developed and issued a Quality Assurance 10 Manual tv govern a'udits of construction and engineering 11 activities.
Since that time, PGandE has continually reviewed 12 and' modified, as necessary, its Quality Assurance Program 13 and organizational structure in order to be responsive to 14 evolving regulatory guidance and industry standards.
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15 16 When the Quality Engineering Section was first established 17 it consisted of three engineers.
Currently we have a total 18 of 47 Quality Assurance / Quality Control engineers to assure 19 implementation of the Qual *ity Assurance Program.
At the peak 20 of construction activity at the Diablo Canyon Power Plant, 21 the Quality Assurance / Quality Control personnel involved on 22 the project (including contractor personnel) numbered 298 or 23 about one Quality Assurance / Quality Control person for every 24 ten craftsmen.
25 26 s
27
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3
1 A further step in the evolution and improvement of PGandE's 2
Quality Assurance Program was the consolidation and updating 3
of the Engineering Department procedures into an Engineering 4
Manual.
5 6
Since 1969, over 1400 internal Quality Assurance audits have.
7 been conducted of which about 230 were of Engineering Department 8
activities.
Deficiencies identified during these audits were 9
reported to senior management and corrective actions were specified. 'Thesea'c'tions have either been or will be imple-
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10 11 mented and verified in accord'ance with Quality Assurance 12 requirements.
Additionally, throughout plant design and 13 construction, the NRC has continually made reviews of the 14 audits conducted by' our Quality Assurance Department and
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15 performed independent inspections of various design, 16 construction, and operating activities.
17 18 As an example of the NRC review process, the NRC and PGandE 19 determined in June 1977 thEt the existing design control 20 activities needed stronger controls.
At that time, PGandE 21 agreed to complete comprehensive design reviews on licensee-22 designed Class I components, structures, and systems to verify 23 correctness of design.
At this same time, the NRC reviewed 24 PGandE's Procedure PRE-6, "Compreheisive Design Reviews,"
25 and found that it provided adsquate guidance for the conduct 26 and approval of comprehensive design reviews (NRC Report s
27 50-275/77-12).
Subsequent NRC inspections and PGandE Quality
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4
Assurance audits of these comprehensive design reviews confirmed 1
2 that the reviews were completed in accordance with the require-3 ments of this procedure.
The NRC affirmed the overall adequacy 4.
of the PGandE program in testimony before the ASLB in October 5
1977.
6 7
8
. IDENTIFICATION AND REPORT OF ERROR 9
10 On September'2T,~1981,"we determined that an error had occurred 11 which potentially affected the plant's seismic design.
As 12 a result, we immediately suspended scheduled fuel loading 13 operations and informed the NRC.
14 35 We immediately assembled a team of engineers to analyze the 16 matter thoroughly and hired an independent consultant to conduct 17 a separate and independent review and analysis.
The Quality 18 Assurance Department also immediately initiated an investigation 19 of the error to determine its cause and extent and cooperated 20' fully in the NRC's independent investigation.
We presented our 21 findings to the NRC Staff in formal public briefings held on 22 October 9,1981 and November 3,1981.
Additionally we met with 23 the staff and intervenors in lengthy public work :essions during 24 the week of October 12, 1981.
The staff has proposed, and 25 PGandE has agreed in principle, to a f ar-ranging reverification 26 program to review and confirm the adequacy and accuracy of work s
27 performed for PGandE by its service-related contractors.
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5 5
1 Our findings indicate that although PGandE's Quality Assurance
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2 Program hau ' ten in overall compliance with NRC requirements, 3
a deficiency in its implementation occurred in 1977 which 4
involved the informal exchange of design information between 5
PGandE and one of our seismic consultants during the seismic 6'
reanalysis for the Hosgri event.
In this particular case, 7
inaccurate weights for equipment and piping in a limited area 8
of the containment structure were prepared and furnished the
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9 consultant on an incorrectly or,iented diagram.
This informal 10 informat-ion-exchange did not conform to Company practices 11' and Quality Assurance procedures which required the checking 12 of design calculations.
Had these procedures been followed, 13 we believe that th,e errors would have been detected at that 14 time.
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(l 15 16 As it turned out, the error was not identified until a piping
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17 design engineer in PGandE's Department of Mechanical and Nuclear 18 Engineering who was reviewing Unit 2 piping systems raised 19 questions about the correctness of the diagram.
20' 21 During our investigation we also identified a failure of 22 Company personnel to use revised 1977 seismic data for check-23
,ing the adequacy of the design of conduit and cable tray 24 supports.
t 25 26 s
27
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6 i
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1 This error involved a failure to follow established Quality 2
Assurance procedures which require formal distribution of 3
design data.
Again, had these procedures been followed, 4
we believe that this error would also have been detected 5
at that time.
6' 7
To avoid such errors in the future and to assure that past 8
- errors have not affected plant design margins, the Company is
[
9 embarking on a two-phase progra,m.
The first phase involves 10 establishhenf~of~a'r'etraining program for engineering personnel 11 which emphasizes the 6dherence to quality procedures.
The 12 second phase involves the retention of a consultant to carry 13 out a reverification of the existing design and to report 14 any deficiencies without restriction.
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15 16 Notwithstanding the occurrences of these errors, as well as 17 several other minor errors found during the investigation, we 18 continue to believe that because of the original conservative 19 design and the rather large' margins of safety associated 20 with the affected systems, th'ere would have been no safety 21 consequences even if the errors had not been detected and 22 the plant had gone into operation.
23 24 25 26 s
27
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7 4
1 IMPLICATIONS FOR PLANTS UNDER CONSTRUCTION 2
3 The errors which have been identified at Diablo Canyon resulted 4
from a failure to follow the requirements of our Quality 5
Assurance Program.
However, a review of the numerous PGandE 6'
Quality Assurance and NRC~ audits shows that while deficiencies 7
occur, they are generally detected and resolved in a timely 8
. manner.
This incident vividly illustrates that no matter how 9
embarrassing or costly an error,may be, it will be reported and 10 promptly correctedr 'We believe that existing NRC and industry 11 quality assurance requirements when properl,y implemented are 12 adequate to safeguard the public health and safety.
- Also, 13 the industry record of identifying, reporting, and correcting 14 problems exemplifies a strong commitment to adhere to Quality 15 Assurance requirements.
16 17 We are confident that the errors identified at Diablo Canyon 18 do not represent a generic weakness in the Quality Assurance 19 regulations or in industry's responsibility to design plants 20 that will operate safely.
We believe the present program 21 of inspections by industry and the NRC is adequate to assure 22 a high degree of reliability in the detection and correction 23 of deficiencies.
24 s
25 26 s
27
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CLOSING REMARKS 2
3 In closing let me emphasize that:
4 PGandE voluntarily suspended fuel loading when 5
6-we discovered the e'rror and we immediately took 7
steps to notify the NRC and to correct the 8
error.
9 PGahdE 'is fi~rm'ly committed to design, 10 11 construct, and operate Diablo Canyon in a safe 12 manner.
In carrying out this commitment, we 13 have:
Assign 5d competent, experienced, and 14
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15 dedicated people to perform these 16 functions; Used and continue to use extreme con-17 18 servatism in the design and construction 19 of Diablo Canyo'n; Contracted with o'ne of the most qualified 20 21 consultants in the country to carry out an 22 independent reverification of the existing 23 design and to report any deficiencies 24 without restrictions.
Agreed to make any further changes that 25 26 are identified as a result of the s
27 reverification program; and kl 9
3
=
- Conducte.d ourselves and reported the 1
2 results professionally and forthrightly 3
even though it has been embarrassing 4
to the Company, to our engineers, and 5
to the nuclear industry.
6-I represent the highest level of PGandE 7
8 management in assuring this Committee, the NRC,
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9 and the public that we a,re totally committed
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10 to the-continued implementation of a sound and 11 effective Quality Assurance Program.and to 12 building nuclear power plants that are safe in 13 every respect.
14 15 16 17 18 19 20 21 22 23 24 4
25 26 27 10
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ATTACitd.Ehi 2 DESIGN AND CONSTRUCTION MILESTONES DATE DESIGN AND CONSTRUCTION STATUS COMMENTS NOVEMBER 1966
'NSSS CONTRACT AWARDED JANUARY 1967 UNIT'1 PSAR SUBMITTED JULY 1967 PROPOSED GENERAL DESIGN CRITERIA s
ISSUED (10CFR50 APPENDIX A)
APRIL 1968 UNIT 1 ONSTRUbTIONPERMIT AUGUST 1968 STARTED SITE PREP JUNE 1968 UNIT 2 PSAR SUBMITTED
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APRIL 1969 PROPOSED QA CRITERIA ISSUED FOR COMMENT (18 CRITERIA)
JUNE 1969 START CONSTRUCTION MAJOR SEISMIC DESIGN FOR BUILDINGS BUILDINGS COMPLETE JULY 1969 UNIT 2 PSAR APPENDIX G ADDED QUALITY ASSURANCE PROGRAM
' PROGRAM WILL BE AN EXTENSION DESCRIBED USING PROPOSED 10CFR50 0F THE QAP DEVELOPED FOR APPENDIX B UNIT 1..."
NOVEMBER 1969 PG&E FORMED QUALITY ENGINEERING DEPARTMEh7 JANUARY 1970 PG6E ISSUED RED QA MANUAL FOR DESIGN AND CONSTRUCTION JUNE 1970 10CFR50, APPENDIX B ISSUED NOVEMBER 1970 START ERECTION OF MMOR PIPING DESIGN ALMOST HALF COMPLETE DECEMBER 1970 UNIT 2 CONSTRUCTION PERMIT s
ISSUED 4
DATE DESIGN AND CONSTRUCTION STATUS COMMEh7S FEBRUARY 1971 10CFR50 APPENDIX A ISSUED g
OCTOBER 1971 N45.3.11 SUBCOMMITTEE ESTABLISHED (LATER RENAMED N45.2.11)
MARCH 19/2 PG&E FORMED QUALITY ASSURANCE DEPARTMENT JUNE 1972 SAFETY GUIDE 23 ISSUED (QAP DESIGN AND CONSTRUCTION)
ENDORSES ANSI N45.2-1971 SEPTEMBER 1972 START INSTALLATION NSSS NOVEMBER 1972 SAFETY GUIDE 33 ISSUED (OPERATING QAP)
ENDORSES ANSI N45.2-1971 JUNE 1973 GRAY BOOK ISSUED MAY 1974 GREEN BOOK ISSUED JUNE 1974 N45.2.11 ISSUED (QUALITY ASSURANCE REQUIREMENTS FOR THE DESIGN OF NUCLEAR POWER PLANTS)
(
FEBRUARY 1975 R.G.
1.64 ENDORSES ANSI N45.2.11-1974 AUGUST 1975 CONTAINMENT LEAK TEST SEPTEMBER 1975 SER #3 APPROVES FSAR NOVEMBER 1975 HOT FUNCTIONAL TEST DESIGN AND CONSTRUCTION COMPLETE FOR FUEL LOADING DECEMBER 1975 NRC ISSUES LICENSE TO RECEIVE AND STORE FUEL FEBRUARY 1976 N45.2.13 ISSUED (QUALITY ASSURANCE REQUIREMENTS FOR CONTROL OF PROCUREMENT...)
JULY 1977 R.G.
1.123 ENDORSES ANSI N45.2.13-1976 NOTE:
SINCE DECEMBER 1975, DIABLO CANYON WORK RAS BEEN CONCERNED WITH HOSGRI et INVESTIGATIONS, HOSGRI REDESIGN, TMI BACKFIT, AND REVERIFICATION OF DESIGN.
r U....
_.-S 1
..ss ATTACHMENT 3 c j U4p Fit t:
Nov;mbar 25, 1969 Mechanical Syste: Design Responsibilities For Class I Syste=s and Equipment Units 1 & 2 - Diablo Canven Site MEMORAh*DUM TO FILE:
The purpose of this ce=orandum is to confirm, update and clarify the mechanical system design responsibilities.
Each Engineer (Systec' Engineer) who has been assigned a system is responsible for the total system design including establishment of design criteria, overall design, piping size and instrumentation.
The Lead Engineer is responsible to see that the Engineer (s) assighed to the system carries out the foregoing function.
Generally, either the Lead Engineer or the Engineer is responsible for equipment procurement for this assigned system. Where the System Engineer doe s not procure the equipment, the equipment procurement responsibility is shown below.
The System Engineer, however, is still responsible for the equipment design criteria.
In addition to system responsibility as given above, Mr. G. A. Abbott is responsi-ble for the design of the lastrument systems based on the performance criteria
~
established by the System Engineer.
Mr. Abbott is also responsible for all con-trol valves.
)
In addition to system responsibility as given above, Mr. A. G. Walther is responsi-ble for the design of the piping for the various systems (except drainage piping) including hanging, valves and insulation.
The System Engineer is also responsible for furnishing the Mechanical Design Draf ting Section, Electrical Design Section and Civil Design Section the necessary criteria for the design of items done by the foregoing sections.
Organization With Prime PGEE Organization System or Maior Ecuiement Responsibility Lead Entineer Engineer Main Steam and Feedvater PG&E JBGegan AGWalther Steam Gen. Safety Valves RPFawcett Reactor Coolant Westinghouse JPFinney JPFinney Chemical Volume & Control JPFinney HJGormly Liquid Holdup Tanks
' PG&E JPDuffy Safety Injection Westinghouse' JPFinney JPFinney Residual Heat Keroval JPFinney NLZiemek Sampling Westinghouse GAAbbott GAAbbott i
a
_________._________o
ATTACIDfEh7 3 b l, Organization With Prime PG&E Organization Svstem er Maior Icutement Re scon sibility Lead Engineer
- Entineer Containment Spray Westinghouse /
JPFinney/
PG&E WJLindblad RWood Component Cooling PG&E JPFinney NLZiomek
[BGegan DOBrand Auxiliary Salt Water Fire Protection WJLindblad RPFawcett Diesel Fuel Oil JPFinney NLZiomek Auxiliary Building Ventilation WJLindblad RWood***
Emergency Air GAAbbott JJCarpenel'la Instrumentation & Control Westinghouse /
GAAbbott RWMiner PG&E Control Boards & Panels n
JVRocca Containment Ventilation PG&E WJLindblad RWo o d***
Containment Isolation Valves WJLindblad Main Steam & Feedwater AGWalther Containment Piping Penetration.
WJLindblad JPDuffy Diesel Generator Units (Mech.)
JPFinney NLZiocek Auxiliary Feedwater JBGegan RPFawcett Makeup Water JBGegan HJGormly**
Radioactive Waste Disposal HJGormly HJGormly Reactor Coolant Drain Tank JPDuffy Equipment Drain Receiver Tanks JPDuffy Gas Decay Tanks JPDuffy Piping Systems AGWalther JPDuffy WCHam 8 c
<w &
J. O. SCHUYT JOS: pac See attached distribution.
e s
Civil Engineering responsible for detail design of tanks.
Civil Engineering responsible for detail design of ventilation systems.
ANTACHMENT3e k
DISTRIBUTION Engineerine Services A. T. Lomas R. H. Spalding Elee. Distribution Engineering J. W. Colwell Civil Engineering
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R. V.- B'ettinger E. J. Ross Mechanical Engineering D. V. Kelly G. A. Abbott D. O. Brand J.*J. Carpenella J. P. Duffy R. P. Fawcett k'-
J. P. Finney J. B. Gegan H. J. Gormly W. C. Ham W. J. Lindblad R. W. Miner J. V. Rocca A. G. Walther R. W. Wood
~~
N. L. Ziecek
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wwv ATTACHMEhr 3 d
}EC11All1 CAL 6 lajCLT).R C;CU;EEPII:G 1.23 Drawing Questions Units 1 and 2-Diablo Canyon Site January 7,1975 MESSRS.
D,_NIELSTJ!
E. P. VOLIl.K Please have Diablo Canyon ECO's or drawings requiring coordination sent to the following engineers:
- 1. Turbine Duildirk John Sale r/
- 2. Auxilicry Buildics Richard Bacher V
- 3. Cenesin: ant Jesse Ante
- 4. Intake Structure Panos Antioch'os They will be responsible for our routing and returning them to you.
H. J. CORMLY JWSale/jm cc:
JAAnte PGAntiochos REBacher /
DLPolleyg/
JBGegan RMLaverty WJStracke AGWalther 4GL C
< },.eo - e n. o.m
- 2. OGT@
bkc.
ATTACHMENT 3 e RECflVED jag ron mrna -com'ANY uwa PROJECT ENGlHEER Owwnu on EPW DIActo cAnyou 5EN on anmcNr ELECTRIC DISTRIbtrrION ENGINEERING O
- etc No.
18.25 HJG JAN 151974 c LcTTcn cr' svanct Diablo Canyon Sito Units 1 and 2 DN Preparrtion of Design Reviews e fg~
For Class I Electric Systems f, f January 11, 1974
?!E!!ORAt;DLT.!:
This memorandum defines tht: Class I c1ccerical s> stems which will have design revicu and also describes the general requirements for these reviis3.~ The 'sp*ccific design revicus covered are those that are in the scope responsibility of the Electric Distribution Departec.nt.
Systems and equip =cnt by Ucstinghouse on the NSSS Contract are not included, and neither are those in the resp ~onsibility of the !!cchanical, Civil and Architectural Departments.
The design revicus shall be prepared as described in Quelity Assurance Procedure PR,E-6 for Diablo Canyon Site and also shc11 ep.; ply uith Part II T., " Design Control", of 10CFRSO, Appendix L.
Procedure
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PRE-6 generally is limited to systems in our case.
Design revicus shall be made for the following:
1,.
Each of[those Class I electric power systems:
a.
4160 volt, 60 hertz, Buscs F, G, and H.
b.
480 volt, 60 hertz, Buscs F, G, and H.
c.
115 volt, 60 hertz, instrument c.c. power system.
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d.
125 volt d.c. electric power sys. tem.
c.
125 volt d.c. cmergency lighting system.
2.
Class I cicctrical conductors for equipment inter-connections, including electrical penetrations of the containment.
3.
C1cos I cicetrical raceways.
/4 Class I heat tracing system.
5.
Class I ventilation control system.
6.
Settinan of electr'ic.al protective devices.
s 7.
Miner:11anews, as directed by the Supervicing Engir.wr, F
I (j
ATTACHMENT 3 f e
Mrmorandum Jcnuary 11, 1974 The design criteria selected for the cicctrical systems shall include those given in the PSAR and FSAR, and the AEC " General Design Criteria" listed in Appendix A of 10CRT50 to the extent of our con.mittment in the PSAR and FSARu, also included are the Westinghouse criteria, and those industry standards and Company practices in effect as the design progressed.
Carc should be taken to not include those, criteria or standards which have appocred since the design was committed and were not adopted for the project. ~
Design revieu means the critical review of the design in order to provide further assurance that the actions leading to the design output such as d auings, calculations, analysis, and specifi-cations have been satis;actorily performed and the information included in the design output is correct.
Established proc 6dures for design revieu shall be followed, results of the revieu docuacnted, and measuref_taken _to cnsure that the findings are impicmented, khether the review is conducted by one individual or an organization there are a number of basic questions that chould be addressed where applicable:
(1) Were the inputs correctly selected and incorporated into design?
(2)
If assumptions were neces:ary to perform the design
(?
activity are the basis of the assumptions adequately described and reasonable?
(3) Are the correct quality requirements.specified?
(4) Have the applicable codes, standards and regulatory requiremouts been met?
(5) Have the design interface requirements been satisfied?
(6) Was an appropriate design method used?
(7)
Is the output reasonabic compared to inputs?
(8) Are the specified parts, equipment, and procenses suitable for the required application?
(9) Are the specified materials cenpatibic with each other and the design environmental conditions to which the material uill be' exposed?
(10) Has adequate acc6csibility been provided to perform needed maintenance and repair?
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ATTACH}iENT 3 g Memorandum January 11, 1974 (11) Have adequate maintenance requirements been specified?
(12) Have acceptance criteria been delineated in the design documents, such as drawings,' instructions or other supporting documents which are sufficient to assure that adequate standards are maintained and that the activitics prescribed by the design documents have been satisfactorily accomplished?
The design review documentation shall be organized and completed to meet the requirements of PRE-6.
The review shall contain the following:
1.
A description of the system covered.
2.
A statement giving the objective and scope of the review.
3.
A summary giving the results and conclusions reached, and any design deficiencies formed not in accordance with the criteria or standards.
4 Any ex lanations, comments and recommendations.
k 5.
A list of the design criteria and the standards used in the revieu.
6.
The sigh.ature of the review and the Supervising Engineer and the date of completion.
7.
A set of attachments containing the material supporting the details developed by the results and conclusiens of the revieu.
Material should include the analyses and data developed by the revicuer and copics of documents pertinent to the review.
The complete review shall be assembled in a folder or set of folders, labelled with title of the review and then placed in the files of the design cection.
The status of the design review at this time are as follows:
1.
The electric power systcuc are partially complete, with much of the cystem analyses completed.
The design revice of the Class i motors has been completed.
8
p g.
ATTACHMENT 3 h (f
f,,
M:morandum January 11, 1974 2.
Design review of the electrical conductors for the contaitrnent fan coolers have been ecmpleted. The remainder has not been begun.
- 3., 4., 5.
Electrical raceways, heat tracing, venti-lation control, and relay settings have not been design revicwed.
A design review has been completed for the hydrogen 6.
releases in the battery rooms.
Persons assigned to perform and complete these design reviews will have access to any records that are available, and
~
are requested to make the review as independent as practical of the original design.
- i t 1.i'f W
1 DONALD NIEISEN D ::YG 4(
W e
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2 4
7 s
ATTACHMENT 3 i
/'
i./, /.,,.
.'.l... /) b.
1 July 2S, 1972 I
g.,
Doripn Chant;cr. to cnd Approvel I:{
of piping Schematics File No. 146.10
!T*nr a "r * "O '.T L T/J19 Cr.Yo:' "ECR',rIC/A T.::GI?:rERS :
1.s of neu, escontf r.lly all piping schc=stics are issued "/.pproved for Conserr-tion." '1his remernr. Cum will revise the control over changes to piping' scham:t;c.i and supersede the previous memo of July 29, 1972, on this subject.
Any rys to.r, responsible, instrument or piping enginacr may initiate a dcrign chany.e er revision to piping schematics.
Changes should be limited to caly tho e absolut ely necessary.
This will be done by an intra-compsny memorandum forn with or uithout sketches.
The memorandum shall be addressed to I. F. Hall and shaTl'b'e" routed"through:
~
1.
Responsible Engineer 2.
Piping Engineer 3.
Instrument Engineer 4.
J. V. Rocca Each will initial a*nd date his approval of the proposed change.
(f' Copiec will be kept as follows:
A m yellow - originator pink - mechanical file white - I. F. Hall Anyone wishing copies for their own file will use the Xerox.
Another area that requires a more formalized contrcl is the "Line Designation Table" (LDT). The LDT will be issued " Approved for Construction" after being reviewed and signed off by each system engineer. Af ter that, any changes in line nu=ber, flow, pressure or temperature must be processed through A. G. Walther/J. R. del Mazo on the attached format addressed to I. F. Hall.
Again, this should be routed through:
1.
Responsible Engineer 2.
Piping Engineer 3.
A. G. Walther/J. R. del Fb:o Each will initial and date his approval of the proposed change.
Copies will be the responsibility of each individual.
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H. J. Gormly JYPoccc/ja Attachment cc:
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I have read the foregoing 22 page document entitled
" Comments on the R.
F.
Reedy, Inc., Quality Assurance Audit Report on Safety-Related Activities Performed by PGandE Prior To June 1978" including Attachments 1 through 3j.
The contents of said document and attachments are true and correct to the best of my knowledge, information and belief.
June 24, 1982.
%[4 zc Warren A.
Raym Manager of Qu ity Assurance Pacific Gas d Electric Company Subscribed and sworn to before me this 24th day of June, 1982.
k J
Nancy J.
Ledaster, Notary Public in and for the City and County of San Francisco, State of California.
My Commission expires April 14, 1986.
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