ML20052F162
| ML20052F162 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/06/1982 |
| From: | Reedy R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20052F140 | List: |
| References | |
| NUDOCS 8205120184 | |
| Download: ML20052F162 (39) | |
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. o, 09%' ' ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'm ,.
' l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
1 In the Matter of )
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY, -et al. ) 50-446 l
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(Comanche Peak Steam Electric ) (Application for l Station, Units 1 and 2) ) Operating Licenses)
AFFIDAVIT OF ROGER F. REEDY REGARDING ASME SURVEY OF BROWN & ROOT AT COMANCHE PEAK l
I, Roger F. Reedy, being first duly sworn, do depose and state: I perform Engineering consulting services with the firm Reedy, Herbert, Gibbons & Associates in the area of ASME Code requirements and application of those requirements to nuclear power plant construction. As a consultant for Texas Utilities Generating Company, I have examined the Brown & Root records pertaining to the ASME Certificates of Authorization issued to Brown & Root, Inc. for the Comanche Peak project. In this role, I have also examined the find-ings reported by the ASME Survey Team at the October 12-14, i 1981 Survey and January 18-20, 1982 Resurvey of the Brown &
I Root Quality Assurance Program at Comanche Peak, and the responses to those findings taken by Brown & Root, and conclude that Brown & Root has demonstrated to the proper l
8205120184 820510 PDR ADOCK 05000445 G PDR I
i y authorities implementation of a OA Program which satisfies ASME Code requirements. A statement of my educational and professionr.1 qualifications is attached hereto as Attachment 1.
I. ASME NUCLEAR CODE The American Society of Mechanical Engineers ("ASME")
writes and publishes a set of Engineering Safety Standards known as the ASME Boiler and Pressure Vessel Code. Section III of that Code, known as the ASME Nuclear Code, provides rules for the design and construction of pressure vessels, piping, pumps, valves and storage tanks used in nuclear power plants. The Nuclear Code presents a set of minimum requirements developed to assure the integrity and safety of the pressure containing equipment and systems in the nuclear power plant.
The ASME Nuclear Code provides requirements for the construction of nuclear components. These requirements are-applicable to projects which are being constructed in jurisdictions which have adopted the ASME Code for that purpose. In addition, the Nuclear Regulatory Commission regulations require that for nuclear power plants with construction permits docketed prior to 1982, such as Comanche Peak, the systems and components of those plants be designed, fabricated, installed, tested and inspected in accordance with generally recognized codes and standards, such as the requirements of the ASME Nuclear Code. 10 C.F.R. } 50.55a.
e r II. ASME CERTIFICATES OF AUTHORIZATION All work performed pursuant to the ASME Nuclear Code must be certified by a Certificate Holder as complying with the applicable requirements of the Code. This certification is authorized by issuance of Certificates of Authorization which permit the stamping of the item with an ASME Code Symbol Stamp following completion. These stamps are issued only upon a demonstration to the ASME that an acceptable Quality Assurance ("QA") program exists for the work to be performed pursuant to the requested authority.
Before authorizing an organization to apply the ASME Code Symbol Stamp to any code item, an ASME Survey Team must review the facilities of the Certificate Holder and assure that the Quality Assurance Manual and related procedures comply with the applicable requirements of the ASME Nuclear Code. The Survey Team then audits performance to verify implementation of the QA program. The verification includes review of work in progress and appropriate records, including records of already completed Code work, and interviewing personnel. Once this verification has been made, the Certificates of Authorization and applicable Code Symbol Stamp will be issued to the organization upon the recommenda-l l tion of the Survey Team and with the concurrence of the ASME
Subcommittee on Nuclear Accreditation. The Certificates of Authorization allow the organization to apply the ASME Code Symbol Stamp to components. This authorization is valid for a period of three years.
There are three types of ASME Code Symbol Stamps.
The "N" Symbol Stamp is the stamp which signifies that all requirements for design and construction have been met and accepted. The N Symbol Stamp is used by the organization which accepts overall responsibility for the completed work. The "NPT" Stamp for parts of ASME Code components signifies that the designated work has been accomplished. An NPT Stamp does not include responsibility for the design. The "NA" Symbol Stamp is a stamp which indicates that the equipment has been installed or assembled to Code requirements. At Comanche Peak, Brown & Root, Inc.
i has been issued both the NA and NPT Stamps.
l III. INSPECTION ASME Third-Party Inspections of Nuclear Construction A fundamental controlling principle of the ASME Boiler and Pressure Vessel Code is that a component must receive l
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" third-party authorized inspection" during construcslon to assure compliance with all Code requirements. The signature l
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-S-of an Authorized Nuclear Inspector on an ASME Data Report, verifying that the component has been constructed in accordance with all applicable Code requirements, is a key element in the ASME accreditation system.
The third-party inspection is performed by the Authorized Nuclear Inspector who is generally employed by an insurance company which underwrites insurance for the type of equipment being constructed. At Comanche Peak, the Authorized Nuclear Inspector is employed by the Hartford Steam Boiler Inspection and Insurance Company. The insurance company inspector is independent of the manufacturer and the user of the equipment and has interest in safety becaase of the financial obligation of the insurance company on the equipment.
The National Board of Boiler and Pressure Vessel Inspectors is a professional group composed of the Chief Inspectors of each of the States which have adopted ASME Code rules. The National Board trains inspectors, prepares and administers examinations and certifies the qualifications of the Authorized Inspectors. The National Board assists the ASME by participating on the Survey Teams who review and qualify manufacturers and installers of both nuclear components and other ASME pressure vessel and boiler construc-tion. The National Board has an obligation to review the i
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effectiveness of the Authorized Inspectors program to assure that they are performing their inspection duties in accordance with the requirements of the National Board and the ASME Code rules.
IV. CONSTRUCTION PERFORMED IN THE ABSENCE OF EFFECTIVE CERTIFICATES OF AUTHORIZATION Before construction activities on a nuclear component can be initiated, it is necessary for the organization doing the work to have an agreement with an Authorized Inspection Agency for providing their services and those of Authorized Nuclear Inspectors. The Authorized Inspection Agency must review and accept the Quality Assurance Manual of the organization and determine that the organization is capable of properly implementing the QA Manual.
Once these activities have been accomplished, it is acceptable for the organization to begin ASME Code work on the item which is to be Code Stamped with the concurrence of the Authorized Nuclear Inspector. That ASME Code work may include Code design and construction activities engaged in prior to receiving a certificate of Authorization from ASME. Published ASME interpretations of the Nuclear Code l
l establish such practice as acceptable u.d permissible under l Code rules. Attachment 2 is a copy of such interpretations.
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All Code work performed during this time is subject to review during the ASME Survey Team's review and audit of the QA Program. It is an accepted practice for organizations to begin work in this way, in order that the ASME Survey Tean can verify implementation of the QA Program when the survey is performed.
Similarly, work performed during a time when no certificate of Authorization is in effect, as occurred at Comanche Peak following expiration of the Brown & Root Certificates on January 8, 1982 and prior to their reissuance on March 15, 1982, is treated in the same manner as work performed by a contractor prior to the initial ASME Survey.
The acceptance of the work performed during this period of time is at the discretion of the Authorized Nuclear Inspector and his Supervisor.
As discussed below, the Brown & Root ASME Code work at Comanche Peak meets the requirements of the ASME Code in that (1) Code procedures have been followed for all work, including that performed during this open period, and the work has been accepted or is subject to acceptance by the Authorized Nuclear Inspector and (2) all findings by the ASME Survey Team during the accreditation process have been addressed and the activities evaluated to determine that work performed satisfied ASME Code requirements.
V. ASME SURVEY OF BROWN a ROOT ASME QA PROGRAM AT COMANCHE PEAK In general, the purpose of a Quality Assurance Program is to establish an organizational plan for performing and assuring that the work on a project is accomplished in accordance with applicable design, fabrication and installa-tion requirements. The Guality Assurance Manual describes the essential features of the QA Program by detailing the responsibilities of personnel and controls needed for the work performed. ASME Code Section III, NCA-4134. 2(c) 1/
The QA Manual, in conjunction with the necessary supple-mentary implementing procedures, provides the specific details for control and documentation of the work. ASME Code Section III, NCA-4134.2(a) and NCA-4134.5. Some QA personnel prefer that the controls be outlined in the QA Manual with specific details being described in procedures.
Others prefer that the specific details be described in the
- QA Manual with less reliance on implementing procedures.
t In the ASME Code, it is a requirement that the QA Manual describe the essential controls of the Quality Assurance system. The Code permits the QA Manual to
- be supplemented by procedures. The principal reason
~1/ All references to the ASME Code are to the 1980 Edition.
through the Winter 1981 Addenda. All Code provisions cited herein are attached in Attachment 3.
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that essential controls are required to be in the QA Manual, rather than in the procedures, is that revisions of the ASME QA Manual require more approvals than revisions to procedures, thus providing additional controls to the QA Program. ASME Code Section III, NCA-4134.2(d).
In performing a review of an ASME QA Program, an ASME Survey Team will first examine in detail the subject QA Manual. After the QA Manual has been reviewed, the Survey Team must establish that the work is being carried out in accordance with the provisions of the Manual. In commenting on the Brown & Root QA Program for Comanche Peak, the ASME Survey Team identified details where they required changes to the QA Manual and in certain practices in order to more clearly control the implementation of activities as they are described in the Manual. Comments on the ASME QA Program for Comanche Peak are discussed in the ASME i
letter of November 23, 1982. Attached to Affidavit of R.J.
Vurpillat as Attachment 2.
Below.I describe the meaning of each comment made by the l I ASME Survey ( Team and describe the significance of each comment e
with respett to Brown & Root ASME Code work at Comanche Peak.
l Also, baseil on my review of the affidavit of Ray Vurpillat s
regarding[heresponsesofBrown& Root to those comments, I l
believe th)t the ASME Code work performed by Brown & Root at the Comancf;e Peak site was done in accordance with applicable ASME Code lequirements.
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VI. BROWN & ROOT ASME QUALITY ASSURANCE MANUAL FOR COMANCHE PEAK A. ASME Comment The manual was vague, failed to establish required controls, responsibilities, or provide for objective evidence that required activities were satisfactorily performed.
Applicable ASME Code Requirements The ASME Code requires that a QA Manual self-contain the essential elements of control for the QA Program. ASME Code Section III, NCA-4134.2(c). The Manual may be supplemented by the implementing procedures. When an ASME Survey Team determines (by judgment) that the Manual should be more detailed, it is common practice to require reiteration of some of the detailed procedure controls in the Manual.
As long as the QA Program (Manual plus implementing procedures) adequately addresses the Code requirements, there is no technical violation of the Code. However, the Manual may be required to be made more detailed for work performed after the ASME Survey.
Analysis and Conclusion As stated in the affidavit of Ray Vurpillat, the QA Manual which was reviewed by the ASME Survey Team had been revised by Brown & Root several months before the ASME Survey.
These revisions had been approved by the Authorized Nuclear Inspector. When making these changes, some of the essential
features that had been described both in the original QA Manual and the implementing procedures were taken out of the QA Manual, although they remain in the procedures.
The Survey Team indicated that this revision left the QA Manual too vague. This was corrected by later revising the QA Manual to include the details which had remained in the procedures. Affidavit of R.J. Vurpillat at 2-3.
Because the essential control features were still a part of the Brown & Root QA Program, the technical requirements of the ASME Code were met during this period. Based upon the findings of the Survey Team with regard to Brown & Root implementation, Code work was not adversely affected by the revisions to the QA Manual.
B. ASME Comment The manual established the Summer 1974 Addenda
- for piping and the Winter 1974 Addenda for component supports as the Code effectivity. The manual addressed activities only permitted by later Code addenda; such as NX-2610, NA-3867.4 (f) and supply of material - NCA-3520(e), without any
, identification of the applicability of these provisions.
Applicable ASME Code Requirements The provisions of the ASME Edition and Addenda specified by the Owner must be follcwed. ASME Code Section III, NCA-ll40(a).
The only time new alternative provisions in later Code Addenda may be used is when detailed in the design documents.
ASME Code Section, III NCA-1140(b).
Analysis and Conclusion The comment states that Brown & Root used specific ASME Code provisions from later Code Addenda than the Addenda I
specified for the work being performed. In other words, later changes to the Code which provided for acceptable alternative methods of meeting Code requirements were used by Brown & Root. This is permitted by the rules of the ASME Code. ASME Code Section III, NCA-ll40(b). The Code does not specifically require that use of later Addenda paragraphs be documented in the QA Manual. In fact, as noted in the Affidavit of R.J. Vurpillat at 3, Brown & Root has documented evidence in their design documents that the use of these later Addenda paragraphs was permitted, and ASME has been so advised. Accordingly, this means that the technical require-ments of the ASME Code were satisfied.
C. ASME Comment The manual control system did not contain the exhibits displayed in the manual or any manual approval method.
Applicable ASME Code Requirements Record forms used to document or control work may be included as typical exhibits in the QA Manual. ASME Code Section III NCA-4134.2(c).
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat at 4, it is true that the documents used to control and transmit the QA Manual were not included in the QA Manual exhibits.
However, the control documents were part of the Quality Assurance program and the QA Manual approval and transmittal was performed in accordance with the program detailed in the implementing procedures. After the ASME Survey, the trans-mittal forms were added to the Manual as exhibits.
While the addition of these exhibits clarified the system of Manual approval and transmittal, the earlier approach did not adversely impact the Quality Assurance i
program in effect at the time. Accordingly, the technical requirements of the Code were satisfied.
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D. ASME Comment The program elements of process control, nonconformity control and document control required significant changes.
Applicable ASME Code Requirements The Code requires that the essential elements of control be addressed in the QA Manual. ASME Code Section III f NCA-4134.2(c).
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat at 4-5, these elements of control were part of the Brown & Root '
Quality Assurance system but were detailed in the QA implemen-tation procedures rather than in the QA Manual. The correc-tion was to add more clarifying detail to the QA Manual, which was later done.
This situation does not adversely reflect on the implementation of any QA functions by Brown & Root. There was no need for any corrective action of the part of Brown &
Root other than to include more detail in the QA Manual itself. Accordingly, the technical requirements of the Code were satisfied.
E. ASME Comment The design control element (control of field change design information and feed back of construction information to the Owner) was nissing from the manual.
Applicable ASME Code Requirements The Code requires that the essential elements of control be addressed in the QA Manual. ASME Code Section III,NCA-4134.2(c).
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat at 5, Brown & Root has always had implementing procedures on how field change information is controlled from the design stage forward. The corrective action taken to address the ASME comment was to add these controls to the QA Manual. There was no required change in the features of control. Accordingly, the technical requirements of the Code were satisfied.
F. ASME Comment All elements required changes to provide definitive information since few auditable controls were included.
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Applicable ASME Code Requirements l
The Code requires that the essential elements of control be addressed in the QA Manual. ASME Code Section
( III,NCA-4134.2(c).
Analysis and Conclusion By this comment the Survey Team requested that the specific details of controlling work, which were in the Brown & Root implementing procedures, also be described in the QA Manual. As stated by R.J. Vurpillat in his affidavit at 5, the QA Manual was revised by Brown & Root to accomp.lish this. This is a further elaboration of Item A above and does not signify improper implementation of any QA functions performed by Brown & Root at Comanche Peak.
VII. IMPLEMENTATION OF BROWN & ROOT ASME QA PROGRAM AT COMANCHE PEAK For each of the following items, Sections VII A-I,
- it is an ASME Code requirement that the specific requirements l
of the QA Manual be verified by the Survey Team as to being adequately implemented. ASME Code Section III,NCA-8161.
I The ASME Comments provide the views of the Survey Team on implementation of the Brown & Root Quality Assurance Program.
A. ASME Comment Document Control - The Manual requires that the File Custodians in each department maintain a log of design changes received from the Owner.
The File Custodian is to mark the involved docu-i ment to indicate that a design change had been I
' received and then the document user checks the log to find the applicable design change (s) .
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s The log being maintained by the QA Department File Custodian contained numerous mistakes and missing information. Three of three design packages, checked by the team, contained design changes not properly identified in the log.
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat at 6, the File Custodians have each reviewed their design change logs to verify that the documents which were the subject of this comment are now all correctly updated. Thi.s verification of documents assures that all ASME Code requirements have been met in this regard. Therefore, the technical requirements of the ASME Code were satisfied.
Further, as stated in the affidavit of R.J. Vurpillat at 6-7, the Survey Team was describing a situation encountered with the QA Department File Custodian. This File Custodian was reviewing each completed document package to assure that all the editorial work, required signatures, and other specifics were. properly documented prior to placing these document packages in storage files. For the three design packages that were reviewed by th9 Survey Team, the document
! review had not yet been accomplished although the records were in the File Custodian's hands. The problem was the timeliness in performing the review, not that the records were not being properly reviewed.
Also, the documents being reviewed were not working documents (i.e., not used for field work) but merely documents that were to be reviewed after construction and prior to final storage of records. The resolution of the problem was that the timeliness of the reviews was to be Lmproved.
This situation does not involve any violation of the technical requirements in the ASME Code.
B. ASME Comment Instructions, Procedures, and Drawings - The Brown & Root Construction Procedure 6.9G, reviewed by the site OA Manager, was in direct conflict with the OA Manual and the Code (NA-5241) in that it stated that the ANI would sign a blank process sheet and then Brown & Root would add the ANI hold points. The AIA representative stated that this procedure was not honored by them and that they had requested the procedure be revised. The procedure had not been revised.
The purpose of the Site QA Manager's review is to assure that the procedure complies with the Code and the QA Manual.
Analysis and Conclusion The Code requires that the Authorized Nuclear Inspector
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l ("ANI") establish " hold points" on Code activities being performed. ASME Code Section III, NCA-4134.8(c), NCA-4134.9(b) c ad NCA-4134.10(c) . As stated in the affidavit of R.J.
i l Vurpillat at 8, the ANI on site used the procedure described above in order to establish " generic" hold points. As long I
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s as these generic " hold points" were established by the ANI, the requirements of the Code were met.
The Survey Team felt that the ANI should not sign blank process sheets to establish hold points. Consequently, the method of establishing " hold points" was changed in the
. procedure and the Inspector established his own method of documenting hold points. See affidavit of R.J. Vurpillat at 8.
There was never a problem in implementation because the Inspector did establish the hold points he felt necessary.
The problem was that the Brown & Root procedure did not accurately describe the " hold point" system actually used.
The technical requirements of the Code were met both with regard to the Inspector and the establishment of hold points.
C. ASME Comment Control of Purchased Materials, Items and Services Vendor Control - Brown & Root procured material from a vendor that they had surveyed and qualified as a Material Supplier of bolting and plate materials. The material furnished had been formed into a saddle configuration by this vendor. The Brown & Root survey and qualification of this vendor did not address review of any operation relative to forming and the Brown & Root purchase order did not define the forming process or procedure.
s 4 8 Analysis and Conclusion Brown & Root should have reviewed the procedure used by the plate material supplier prior to placing them on their Approved Vendors list. As stated in the affidavit of R.J. Vurpillat at 9, the correction of this item was carried out by subsequent review of the procedure, and it was subsequently verified that the procedure was properly used for the plate material which had been formed by the vendor.
Further, the method of placing vendors on the Approved Vendors List was amended by Brown & Root to assure that procedures of this nature would be reviewed prior to approval of the vendor. Consequently, there was no violation of ASME Code technical requirements because the procedure was, in fact, properly qualified and demonstrated that the forming procedure used did not adversely affect the material.
D. ASME Comment Control of Purchased Materials, Items I and Services The same matet a1 addressed in [ Item C] was observed in the production shop with work in process. This material had not been receipt inspected in noncompliance with the OA Manual and the material was not identi-l fled as required by the Brown & Root purchase order. Brown & Root had divided l the material and transferred the material l
identification incorrectly. Brown & Root does not verify the transfer of material identification, and during the review of the manual stated that this verification was unnecessary.
i Analysis and Conclusion As described in the affidavit of R.J. Vurpillat at 10, the ASME Survey Team apparently did not fully understand this vendor's system of identifying heat numbers on material.
Sometimes heat numbers and other identification of materials will be on two separate lines. Although the original material in question had its identification marking on two lines, when the identification was transferred to the cut material, the numbers were placed on one line. This caused confusion and gave the appearance that all of the heat number information was not being transferred. This method of identification and the subsequent reverification of all cut material, as described in the affidavit of R.J. Vurpillat at 10, demonstrates that all required material identification was properly transferred and that the requirements of the ASME Code were met.
E. ASME Comment l
l Control of Construction Processes 1
Process sheets were observed in production that had not been reviewed with the ANI for establishment of hold points in noncompliance with the B & R QA Manual and NA-5241 of the
, Code. The process sheets CC-068-002-S33R and l AF-035-023-S33A are included in this finding although numerous such process sheets are in l production. (See B above) 1
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat, at 11-12, this matter arose because of differences of opinion between two ANIS regarding the review of process sheets to establish hold points. The first ANI on site did not wish to review all process sheets for pipe hangers. He felt that his inspection of the installation of the pipe hangers would satisfy his requirements for inspections. A subsequent ANI felt that it was necessary to establish hold points on the process sheets. Some hold points were bypassed because of the inconsistency between the two ANIS approaches. After the ASME Survey was completed, the ANI reviewed all the process sheets to establish new hold points in the manner which he felt was necessary to respond to the concerns of the Survey Team. All process sheets for installed hangers will be reviewed with the ANI to assure all Code requirements have been met. Because each ANI has inspected work as he felt necessary, the ASME Code requirements were satisfied.
F. ASME Comment Control of Construction Processes Welding Procedure Specification 11012 for welding with impact test requirements did not specify the travel speed but instead controlled the heat input by Volt / amp
range and maximum bead width for a given electrode diameter. The procedure qualification record 010AB127 for this WPS recorded a bead width greater than allowed by the WPS.
Analysis and Conclusion The Survey Team was concerned that the procedure qualification record used did not address the higher heat input of the Welding Procedure Specification and therefore was not a qualification for the worst case conditions.
As stated in the affidavit of R.J. Vurpillat at 12-13, the problem was resolved by subsequent additional procedure qualifications which tested all the worst case heat input conditions which might exist during welding. The test results of these new welding procedure qualifications meet the requirements of the Code. ASME Code Section III, NB-4331 and Section IX, QW-409.l(a) and (b). This removes any question regarding the acceptability and adequacy of welding with this procedure. Also, as stated in the affidavit l
of R.J. Vurpillat at 12-13, all other similar welding procedure qualification records were reviewed for adequacy.
Thus, no further question exists as to coupliance with ASME Code requirements. The welding qualification performed by Brown & Root subsequent to the survey assures that Code requirements have been satisfied.
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G. ASME Comments Nonconformity Control Nonconformity Control Report (NCR) M-2592 reported that a spool piece had been welded into the system backwards. Brown & Root QA determined the disposition to be rework and not repair and thereby the disposition to cut the spool piece out and reweld it in the correct configuration was not reviewed by welding engineering, as would have been required by a repair designation. There appeared to be no consideration of the heat input effect on the material, etc. as would be expected with this type of nonconformance.
Analysis and Conclusion The matter commented upon by the ASME Survey Team arose because the system used and described in the welding control procedures was not adequately described in the QA Manual. Therefore, there was confusion on the part of the Survey Team regarding the welding review by the Welding Engineer. As described in the affidavit of R.J. Vurpillat at 13-14, Brown & Root's determination that the Welding Engineer had, in fact, reviewed both those items to be l
repaired and those to be reworked, and that heat input effects on the n4terial were considered by the Welding Engineer, demonstrates that applicable Code requirements were met. In addition, the material was carbon steel less l than 5/8" thick which was not required to be impact tested, and therefore no heat input problem existed. ASME Code i
! Section III, NB-2311(a)(1) and (4). Thus, Code requirements were met in this regard also.
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l H. ASME Comment Identification and Control of Material and Items Component Supports are procured as stamped items by the Owner. The Code Data Report does not list Code Case N-225. The Component Support is supplied to B & R with only the Code Data Report by the Owner. B & R then cuts the component support, removing the welds, and uses the material to fabricate other component supports. B& R does not have the Certificate of Compliance (C of C) for the material.
Analysis and Conclusion As stated in the affidavit of R.J. Vurpillat at 15-16, the resolution of this item is that all docu-mentation for material and component supports has been sent by the component support manufacturers to the site. An extensive review is being carried out to assure that all material documentation at the site is adequate and that material which does not meet the requirements of the Code 4
will not be used. When the review is completed, any necessary j remedial actions should be taken, and the requirements of the Code regarding material documentation will have been l
met.
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I. ASME Comment Authorized Nuclear Inspector Involvement -
The ANI hold points on process sheets have been bypassed on numerous occasions. The ANI logbook documents these conditions and the volume would indicate a significant breakdown of the program and interface between B & R and the Authorized Inspection Agency personnel (See B and D-1 above).
Analysis and Conclusion The Authorized Nuclear Inspector's " hold points" should not be by-passed. However, if this should occur, the Inspector can still make the required inspections at a later point, place new hold points or require work to be reperformed in order to witness whatever inspection he feels is required.
ASME Code Section III, NCA-4134.10(c). The Inspector is obliged to make sufficient inspections in order to assure himself that the item meets the require.aents of the Code.
ASME Code Section III, NCA-5290. By accepting the work, the Inspector has acknowledged that he is satisfied that Code requirements have been met. ASME Code Section III, NCA-5290.
Brown and Root has acknowledged this ASME comment and taken the necessary action to correct it. Documentation for all past " hold points" is in order and has been reconciled by Brown and Root and the Authorized Nuclear Inspector.
Affidavit of R.J. Vurpillat at 16-17. As long as the Inspector is satisfied that Code requirements are met, there is no violation of the technical requirements of the Code.
VIII. ASME RESURVEY OF BROWN
& ROOT ASME QA PROGRAM As discussed in the affidavit of R.J. Vurpillat at 17, the ASME Survey Team performed a resurvey of the Brown &
Root QA Program for ASME Code work on January 18-20, 1982.
That resurvey resulted in a recommendation by the ASME Survey Team to the ASME Subcommittee on Nuclear Accreditation, that the B&R Certificates of Authorization be renewed.
This recommendation was contingent upon the completion of three actions and verification of such completion by the Authorized Huclear Inspection Supervisor.
On February 8, 1982, the Authorized Inspection Agency
("AIA") for Brown & Root at Comanche Peak, Hartford Steam Boiler Inspection and Insurance Company, transmitted to the ASME verification that action for those three items had been verified as complete. Affidavit of R.J. Vurpillat at 17.
These matters, together with their resolution as stated in the AIA letter, evidence satisfaction of the technical requirements of the ASME Code and pose no concern that work performed prior to or since their resolution does not meet Code standards.
IX. CONCLUSION Based upon the foregoing, I conclude that Brown & Root has satisfactorily demonstrated, pursuant to the requirements of the ASME Code, that ASME Code work performed by it at the Comanche Peak site, which was the subject of the ASME Survey and Resurvey, satisfies all pertinent ASME Code requirements.
All matters raised by the ASME Survey Team at both the October 1981 Survey and the January 1982 Resurvey were resolved by Brown & Root and appropriate reverification has been completed or is now being undertaken. Specifically, Brown & Root has demonstrated to the proper authorities implementation of an appropriate OA program for ASME Code work completed at Comanche Peak up to the present time.
Accordingly, no serious safety issues were raised during the survey and recertification process, and the matters which were raised have been resolved satisfactorily.
Y -
Do
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V oger't.VReedj
.w Sworn to before me this O day of May 1982.
,Y \
Notary Public Q g q r ~~ E S ~ \ b 'Ok 9% Q
ATTACHMENT 1 ROGER F. REEDY STATEMENT OF EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS CURRENT PCSITION: President, R.F. REEDY, INC.
Partner, REEDY, HERBERT, GIBBONS &
ASSOCIATES FORMAL EDUCATION: Bachelor Science, Civil Engineering, Illinois Institute of Technology, June 1953 Postgraduate study, Structural Engineering Illinois Institute of Technology 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> credit September 1956 - June 1959 EXPERIENCE:
1981 - Present R.F. REEDY, INC., President REEDY, HERBERT, GIBBONS & ASSOCIATES, Partner - Advise client companies on QA, design, fabrication, construction and licensing.
1976 - 1981 NUTECH, Enginearing Manager and Chief Consultant - Code consultant to engineers and clients. Served as Director of the Quality Assurance Group and consulted with clients in developing QA programs.
1956 - 1976 CHICAGO BRIDGE & IRON, Design Engineer, Engineering Manager, and Senior Engineer.
Served as designer, staff engineer, project engineer and design manager. Ultimately served as senior engineer reporting to the Vice President of Engineering. Duties included design of pressure vessels and consulting on quality assurance.
PROFESSIONAL AFFILIATIONS:
ASME Boiler and Pressure Vessel Committee Chairman,Section III (Nuclear Components)
Member - Executive Committee Member - Main Committee Subgroup on Containments (former Chairman)
Subgroup on Fabrication and Examination (former member)
International Standards Institute Chairman, Working Group on Containment ASME Pressure Vessel and Piping Division -
Past Chairman
ATTACHMENT 1 1
Professional Affiliations:
(cont.)
Registered Professional Engineer in the States of Illinois, Michigan, Wisconsin, Indiana and California Registered Structural Engineer in the State of Illinois Member - American Society of Civil Engineers (ASCE)
Fellow - American Society of Mechanical Engineers (ASME)
Member - National Society of Professional Engineers (NSPE) l l
r i
I ._. - _ - ._ ,, ._
ATTACIEENT 2 111 1 79'199 Interpretation: 111 1 79-199
Subject:
Section III, Division 1, Subsection NCA Owner's Activities Date Issued: November 29,1979 File: NI 79 248 Question (1): What requirements must be met for an Owner to furnish materials to his on-site sub-contractors?
Reply (1): In order to fumish materials to his on site subcontractors, the Owner must have an N Type Certificate of Authorization,or have a written program that conforms to NCA 3861(b) and NCA-3866.3 and this written program has been surveyed and accepted by ASME or the N Type Certificate Holder
[NCA 3820(b)] who uses the material.
Question (2): May an Owner furnish Code stamped items to his on site subcontractor for installation?
Reply (2): The Owner may fumish Code stamped items to on-site subcontractors for installation at the Nuclear Power P! ant site provided those on-site subcomractors are holders of the appropriate N-Type Certificate of Authorization.
Question (3): If any Owner retains and keeps on file in his facility all Code required documentation for the material and Code items described in (1) and (2) above, may he then advise subcontracted N Type Certificate Holders that the documents are available to them and their Authorized Nuclear Inspectors for review if they wish to visit the Owner's facility?
Reply (3): When the Owner procures Code stamped items for installation at the Nuclear Power Plant site, the records required by NCA4134.17(e) need not be maintained at the Nuclear Power Plant site as permitted by NCA4134.17(d). However, the Authorized Nuclear Inspector performing inspection of the installation at the Nuclear Power Plant site shall have available to him the documentation required for him to perform the duties described in NCA 5220.
Question (4): May the Owner who furnishes materials to subcontracted N-Type Certificate Holders refuse to submit Certificated Material Test Reports and Certificates of Conformance to the subcontracted N Type Certificate Holder?
I Reply (4): When authorized to furnish material, the Owner shall furnish all Code required documen-tation, including Certified Material Test Reports and Certificate of Conformance, as applicable, for the material that is furnished to the N-Type Certificate Holder receiving the material to permit the N Type Certificate Holder to determine that the requirements of the Code have been met.
Question (5): Is it permissible for the Owner to put all documents relating to Code material and stamped items on microfiche and destroy original documents?
Reply (5): Yes. NCA4134.17(b) states that records may be either the original or a reproduced
- les
- ible copy. In addition, NCA4134.17(c) provides requirements for the microfilming of radiographs.
l l Question (6): Is it permissible for the Owner to perform the activities of an N-Type Certificate l Holder prior to having a written " inspection" agreement with an Authorized Inspection Agency?
i Reply (6): An Owner is not permitted to perform any work which requires witnessing for verification by the Authorized Nuclear Inspector at the time it is performed without having an agreement with an I
L -
Attachment 2 111 1 79-199 e a Authorized Inspection Agenc/. However, an Owner is permitted to perform those activities which, after being performed, are verifiable by an Authorized Nuclear Inspector subsequent to an agreement with an Authorized Inspection Agency. Those activities performed prior to having an agreement with an Authorized Inspection are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
Question (7): Is it permissible for the Owner to perform the activities of an N-Type Certificate Holder prior to an Authorized Inspector being assigned to witness or verify the Code activities?
Reply (7): An Owner is not permitted to perform any work which requires witnessing for verifica-f tion by the Authorized Nuclear Inspector at the time it is performed. However,an Owner is permitted to perform those activities that are verifiable by the Authorized Nuclear Inspector subsequent to the Authoriz.
- ed Nuclear Inspector being assigned to the site.Those activities performed prior to the Authorized Nuclear i
Inspector being assigned to the site are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
Question (8): Is it permissible for the Owner to perform the activities of an N Certificate Holder, without a Quality Assurance Program meeting the NCA4000 requirements?
Reply (8): No. The activities of an N Certificate Holder must be performed under a Quality As-surance Program meeting the requirements of the Code applicable to these activities.
Question (9): May an Owner perform the activities of an N-Type Certificate Holder prior to a review by ASME7 8
Reply (9): It is permissible for an Owner to perform the activities of an N-Type Certificate Holder
- prior to review by ASME for an N-Type Certificate of Authorization, provided these activities are perform-i ed in accordance with a written Quality Assurance Program (NCA4000). Activities performed prior to ac-ceptance of the Quality Assurance Program by ASME and the issuance of the N Type Certificate of Authorization by ASME are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
A1TENTION The foregoing interpretation has been further considered and the following corrected interpretation sent to the inquirer.
Correction Issued: January 11,1980 Question (1): What requirements must be met for an Owner to fumish materials to his on-site subcontractors?
Reply (1): In order to furnish materials to his on-site subcontractors, the Owner must have an N-Type Certificate of Authorization, or have a written program that conforms to NCA-3861 (b) and NCA-l 3866.3 and this written program has been surveyed and accepted by ASME or the N Type Certificate
^
i Holder [NCA 3820(b)] who use's the material.
Question (2): May an Owner furnish Code stamped items to his on site subcontractor for installation?
Reply (2): The Owner may fumish Code stamped items to on-site subcontractors forinstallation at the Nuclear Power Plant site provided those on site subcontractors are holders of the appropriate N Type Certificate of Authorization.
1
Attachment 2 111 1 79-199 1
Question (3): If any Owner retains and keeps on file in his facility all Code required documentation for the Code stamped items described in (2)above, may he then advise subcontracted N Type Certificate Holders that the documents are available to them and their Authorized Nuclear Inspectors for reviewif they wish to visit the Owner's facility?
Reply (3): When the Owner procures Code stamped items forinstallation at the Nuclear Power Plant site, the records required by NCA4134.17(e) need not be maintained at the Nuclear Power Plant site as permitted by Nt'A4134.17(d);the required Data Reports shall be furnished to the subcontracted N Type Certificate Holder.However,the Authorized Nuclear Inspector performinginspection of the installation at the Nuclear Power Plant site shall have available to him the documentation required for him to perform the duties described in NCA 5220.
Question (4): May the Owner who supplies materials to subcontracted N-Type Certificate Holders refuse to submit Certified Material Test Reports or Certificates of Compliance to the subcontracted N-Type Certificate Holder?
Reply (4): When authorized to supply material, the Owner shall fumish all Code required documenta-tion, including Certified Material Test Reports or Certificates of Compliance, for the material that is sup-plied to the N Type Certificate Holder receiving the material to permit the N-Type Certificate Holder to determine that the requirements of the Code have been met.
Question (5): Is it permissible for the Owner to put all documents relating to Code material and stamped items on microfiche and destroy original documents?
Reply (5): NCA4134.17(b) permits records to be either the original or a reproduced legible copy.
In addition, NCA4134.17(c) provides requirements for the microfilming and retention of specifically designated radiographs.
Question (6): Is it permissible for the Owner to perform the activities of an N Type Certificate Holder prior to having a written " inspection" agreement with an Authorized Inspection Agency?
Reply (6): An Owner is not permitted to perform any work which may require witnessing by the Authorized Nucler.r Inspector at the time it is performed (NCA 5200) without having an agreement with an Authorized Inspection Agency. An Owner is not prohibited from performing those activities which, after being performed, are verifiable by an Authorized Nuclear Inspector subsequent to an agreement with an Authorized Inspection Agency;however, those activities performed prior to having an agreement with an Authorized Inspection Agency are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
Question (7): Is it permissible for the Owner to perform the activities of an N Type Certificate Holder prior to an Authorized Nuclear Inspector being assigned to witness or verify the Code activities?
Reply (7): An Owner is not permitted to perform any work which may require witnessing by :he Authorized Nuclear Inspector at the time it is performed (NCA 5200). An Owner is not prohibited from perfornung those activities that are verifiable by the Authorized Nuclear Inspector subsequent to his being assigned;however, those activities performed prior to the Authorized Nuclear Inspector being assigned to the site are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
Question (8): Is it permissible to perform the activities of an N Certificate Holder,without having a Quality Assurance Program meeting the NCA4000 requirements?
Reply (8): The activities of an N Certificate Holder must be performed under a Quality Assurance Program meeting the requirements of the Code applicable to these activities. Activities performed prior to
Attachment 2 1
111 1 79 199,111 1 79 200 acceptance of the Quality Assurance Program by ASME and the issuance of the N Type Certificate of Authorization by ASME are performed at the risk of not being acceptable to the Authorized Nuclear Inspector.
Question (9): Is it permissible to perform the activities of an N-Type Certificate Holder prior to a survey by ASME?
Reply (9): An organization is not prohibited from performing the activities of an N-Type Certificate fioider prior to a survey by ASME for an N Type Certificate of Authorization,provided these activities are performed in accordance with a written Quality Assurance Program (NCA-4000). Activities performed prior to acceptance of the Quality Assurance Program by ASME and the issuance of the N Type Certificate of Authorization by ASME are performed at the risk of not being acceptable to the Authorized Nuclear Inspector-
ATTACHMENT 3 ASME CODE SECTION III (4) austenitic stainless steels; NS2MO FRACTURE TOUGiINESS gj ,ng,y,,,
ILEQUIREMENTS FOR G) Drop weight tests are not required for the MATERIAL rnartensitic high alloy chromium (Series 4XX) steels
. NB.2310 MATERIAL TO BE IMPACT and precipitation hardening steels listed in Appendix i TESTED L He Ehe requirements of NB 2332 apply for these steels. For nominal wa!! thicknesses greater than 2%
NB.231I Material for Wbleh Itspact Testing Is in. (64 mm), the required %y V.M vdm shdl Required be 40 mils (10.20 mm) Integl expansion.
- (a) Fressure retaining material and rnate:ial welded thereto shall be impact tested in secordance with the reauirements of this subart* ele, except that the material listed in (1) through (7) below is not to be impa:t tested as a requirement of this Sub>ection: .
(1) material with a nominal section thickness of l % in. (16 mm) and less where the thickncues shall be
! taken as defined in (a) through (c) belon. NB 4330 GENERAL REQUIREMENTS FOR (a) for pumps, valves, and 6ttings, use the WELDING PROCEDURE lar$est nominal pipe wall thickness of the connecting QUALIFICATION TESTS
' PPI 8; NB 4331 Conformance to Section IX W81 l (b) for vessels and tanks, use the nocninal
'9"'**"
thickness of the sbcIl or head, as applicable; (c) for nordes or parts udded to vessels, use All welding procedure quali5 cation tests shall be in the lesser of the vessel shell thickness to which the accordance with the requirements of Section IX as item is wddM or the mn~ mum radial thickness 01 the supplemented or modified by the requirements of this item exclusw of integral shell butt welding projec- Article.
tions; (d) for flat heads, tubesheets, or flanges, use the maximum sh:Il thickness associated with the butt wc1 ding hub; (c) for integral 6Itings ustd to attach process pirin vesselto the use nozde, antain==t v=d the largee or
- thickness nommal cat =1==Je'o NCA.u4o uSE OF CooE EorrioNS, -
p2pe conne:tions; ,
(2) bolting, including studs, outs, and bolts, mith (a)(1) Under the rules of this Section, the Owner 8
^
a p reminal size of 1 10. (25 mm) and hes; or his designee7 shall establish the Code Edition and l (3) bars'with a bominal cross-sectiond ma of Addenda to be included in the Design Specifications.
( 1 sq in. (645 mm8 ) andless; All items of a nuclear power plant may be constructed i (f) all thicknesses of material for pa,pe, tube. to a single Code Edition and Addenda, or each item l
Ettings, pumps, and valves with a nominal pipe size 6 may be constructed to individually specified Code l
in.diameler and smaller; Editions and Addends.
(5) material for pumps. valn:s and Sctings with (21 In no case shall the Code Edition and all pipe connections of % in. (16 mm) nominal wall Addenda dates established in the Design Specifications thidness and less;
'See NCA-3210 for deimtion of Owner.
i
! 'As usal throughout this Section the word designee refers to any orgamzation that performs speeded activities at the request of the Owner. The Owner retains the responsibility for the activity as performed by the designee.
l
- Attach:nent 3 Page 2 be earlier than three years prior to the date that the the quality assurance functions have this required nuclear power plant construction permit apphcation :s authority and organizational freedom. Irrespective of docketed. the crganizational structure, the individual (s) assigned (b) Code Editions and Addenda later than those the responsibility for assuring effective execution of established by (a) above may be used by mutual any portion of the Quality Assurance Program at any consent of the Owner or his designee and Certificate location where activities subject to this Section are Holder.' For Division 2 design and construction, the being performed shall have direct access to such levels consent of the Designer shall also be obtained. Specific of management as may be necessary to perform this provisions within an Edition or Addenda later than function.
those established in the Design Specifications may be used provided that all related requirements are met. NCA-4134.2 Quality Assurance Program (c) A Holder of a Certificate of Authorization shall have a Quality Assurance Program for the control of the quality of specific items which he designs and constructs, or for the other work which he performs.
The Program shall define the organizational structure NCA-4134 N, NV, NPT, and NA Certifieste within which the Quality Assurance Program is Holders for Class 1, 2, 3, MC, CS, implemented and shall clearly delineate the responsi-CB, and CC Construction bilities, levels of authorities, and lines of communica-tion for the various individuals, groups, and subcon-NCA-4134.1 Ormintion tractors involved. The Quality Assurance Manual (a) The authority and responsibility of those per- shall include a statement of policy and authority sons and organizations performing activities afecting indicating management support. He Quality Assur-quality shall be clearly established and documented. ance Program shall be documented by written policies, These activities include both the performing activities procedures, and instructions and shall be based on of attammg quality objectives and the quality assur- consideration of the design and construction aspects of ance functions. the scope of work. The quality of all items and (b) The quality assurance functions within the services, whether constructed, manufactured, or per-Quality Assurance Program are those of assuring that formed at the Certificate Holder's facilities or obtained an appropriate Quality Assurance Program is estab- from an outside supplier, shall be controlled at all lished and effectively implemented, and verifying, such points na-y to assure conformance with the as checking, auditing, or inspecting, that activities requirements of this Section and the Cernficate Hold-l afecting quality have been correctly performed. Per- er's Quality Assurance Manual. He Program shall I sons and organizations performing quality assurance provide for the accomplishment of activities affecting l functions shall have suf5cient authority and orgamza- quality under suitably controlled conditions. Con-tional freedom to: trolled conditions include the use of appropriate (1) identify quality problems; ' equipment, suitable environmental conditions for ac-(2) initiate, recommend, or provide solutions; complishing the activity, and assurance that prerequi-(3) verify implementations of solutions; sites for the activity have been satisfied. The Program (4) and limit or control further processing, deliv- shall take into account the need for special controls,
, cry, or installation of a ennconforming item or processes, test equipment, tools, and skills to attain the i
unsatisfactory condition until proper dispositioning required quality and need for verification of quality by has occurred. enmmation, inspection, and test. The Program shall Such penons and organizations performing quality provide for ready detection of nonconforming material assurance functions shall report to a management level and ite=s and for timely and positive corrective so that this required authority and orgnintional actions. Management shall regularly review the status i freedom, including sufficient indep ndence from cost and adequacy of the Program. De specific responsibil-and schedule considerations, are provided. Because of ities of the quality assurance organization of the the many variables involved, such as the number of Certificate Holder shall include the review of written personnel, the type of activity being performed, and procedures and monitoring of all activities concerned the location or !ccations where activities are per. with the Quality Assurance Program as covered in this formed, the organi:stional structure for executing the A:icle.
Quality Assurance Program may take various forms (b) ne Program shall provide for indoctrination provided that the persons and organirntions assigned and training of personnel performing activities 1
Attachment 3 Page 3 affecting quality as necessary to assure that suitable NCA-4134.8 Identification and Control of Material pro 5ciency is achieved and maintained. It shall be the and Items responsibility of the Certi5cate Holder to assure that (a) Measures shall be established for identi5 cation all personnel performing quality functions within the and control of material and items, including partially scope of this Section, including personnel of subcon- fabricated assemblies. These measures shall assure that tracted services, are quali5ed as specided in this identi5 cation is maintained either on the material or Section. The assignment of qualided personnel shall be item or on records traceable to the material or item at the discretion of the Certi5cate Holder. throughout construction. These measures shall be (c) The Program shall be documented in detail in a designed to prevent the use of incorrect or defective Quality Assurance Manual The Program need not be items, and those which have not received the required in the same format or sequential arrangement as the examinations, tests, or inspections.
requirernents in this Article, as long as all applicable (b) Permanent or temporary unit identi5 cation requirements of this Article have been covered. ne marks shall be applied using methods and materials Manual shall have been accepted by the Society prior which are legible and not detrimental to the item to the issuance of a Certidcate of Authorization. A involved. Such identi5 cation shall be located in areas copy, including all changes that are made, shall be that will not interfere with the function or quality made available to the Inspector. He Manual shall be aspects of the item. Welding and brazing materials for the Inspector's guide for monitoring the Cerudcate all classes of construction shall be controlled.
Holder's continued compliance with the accepted (c) All characteristics required to be reported by Quality Assurance Program. The Certificate Holder the material speci5 cations and by this Section shall shall make available to the Inspector such drawings appear on checklists and each such characteristic shall and process sheets as are necessary to make the be examined by accepted procedures as required and Quality Assurance Program intelligible. the results recorded. Characteristics included on (d) Tne Certi5cate Holder shall be responsible for Certi5ed Material Test Reports or Certi5 cates of advising its Authorized Inspection Agency of any Compliance need not be duplicated in the checklists.
signi5 cant changes which are proposed to be made t Checklists shall provide for a record that the Certified the Quality Assurance Manual, and shall have accep-Material Test Reports and Certi5 cates of Compliance tance of the Authorized Inspection Agency's Inspec-have been received, reviewed, and found acceptable.
tion Spectahsts before putting such changes into effect.
When the results of the examination or test procedure The Certi5cate Holder shall be responsible for conducted by the Certi5cate Holder are necessary to promptly notifying the Inspector of such accepted show compliance with material speci5 cation or other
, changes, m, eludmg evidence of acceptance by the Authorized Inspecton Agency, and for simultane- requirements, the checklists shall show the required j
I ously reconciling copies of the Quality Assurance range of values. The checklists shallinclude spaces for Manual. inclusion of document number and revision to which examination or tests were made, for a signature, initials, or stamp and date of the examination per-formed by the Certi5cate Holder's representative, and fr an Inspector's signature, initials, or stamp and date for those activities which he witnesses.
I NCA-4134.5 Instructions, Procedures, and Draw.
Ings. Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be l accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative and qualitative criteria for determining that important
- activities have been satisfactorily accomplished. Cop-I les of these procedures shall be readily available for l vse by design and construction personnel and for use by the Inspector.
i
Attachment 3 Page 4
< . r NCA-4134.9 Control of Construction Processes (c) Mandatory hold points at which witnessing is (c) Tne Certi5cate Holder shall operate under a required by the Certi5cate Holdefs representative or controlled system ruch as process sheets, shop proce. the Inspector shall be indicated in the controlling dures, checklists, travelers, or equivalent procedures. documents (NCA-4134.9). Work shall not proceed Measures shall be established to assure that processes, beyond mandatory hold points without the censent of such as welding, heat treating, and concrete place. the Certi5cate Holder's representative or the Inspe:-
ment, are controlled in accordance with the tules of tor, as appropriate.
this Section and are accomplished by qualided person-nel using quali5ed procedures.
(b) Process sheets, checklists, shop procedures, travelers or equivalent documentation shall be pre-pared, including the document numbers and revisions NCA-5290 CERTIFICATION OF DATA to which the process conforms, with space provided REPORTS AND CONSTRUCTION for reporting results of completion of specific opera. ORTS tions at checkpoints of fabrication, manufacture, or installation. These documents shall include spaces for (a) The appropriate Data Reports prepared by the the signature, initials, or stamp of the representative of Certificate Holder shall be certified by the Inspector the Certincate Holder and date, and for the signature, only after they have been certified by a responsible initials or stamp of the Inspector, and date for those representative of the Certificate Holder and after he activities which he witnesses. has satisfied himself that all requirements of this (c) The Program shall provide for the accomplish- Secti n have been met and that each Data Report ment of activities afecting quality under suitably .
certined is a comet record. For D, visioni 2 items, controlled conditions. Controlled conditions include certification by the Designer is also required prior to the use of appropriate equipment, suitable environ- certification by the Inspector, mental conditions for accomplishing the activity, and (b) The Inspector shall review and separately cer-assurance that prerequisites for the given activity have .
tify that the mformation contained in the Construction W satis 5ed. Report for Division 2 construction is valid and NCA-4134.10 unminations, Tests, and Inspections corresponds to the requirements of Division 2 and that (a) In-process and final examinations and tests shall the Designer's review and certification of the Con-be established to assure conformance with spec- struction Report has taken account of all requirements ifications, drawings, instructions, and procedures of this Section.
which incorporate or reference the requirements and (c) The N 3 Data Report Form (NCA 3220) shall acceptance limits contained in applicable design docu- be certified by the Inspector only after:
ments. Examination activities to verify the quality of (I) it has been certified by the Owner; work shall be performed by persons other than those
' (2) the Inspector has reviewed the N 3 Form and who performed the activity being examined. Such verified that the Data Reports referenced on the N 3 persons shall not report directly to the immediate Form are on file and that such Data Reports verify supervisors who are responsible for the work being Code compliance of all components, parts, appurte-inspected.
nances, component supports, and core support struc-(b) Process sheets, travelers, or checklists shall be tures incorporated into the nuclear power system or prepared, including the document numbers and revi.
that portion of the system covered by the N 3 Form:
sion to which the examination or test is to be (3) the Inspector has verified that required docu-( performed, with space provided for recording results ments for overpressure protection exist and are prop-of examinations and tests. The documents shall erly filed for that portion of the system covered by the include space for a signature, initials. or stamp and date that the activity was performed by the Certificate N 3 Form.
Holders representative and for the Inspector's signa-ture, : itials, or stamp and date for those activities which he witnesses. The emunation checklist for construction of ite=s shall be 511ed in and completed by the Certi5cate Holder who applies the appropriate Code symbol stamp to the item.
Attachment 3 e ..
Pace 5 NCA-S!60 SURVEY OP APPLICAhT CA S161 AppUesst for a CertiEcate of Authorizatio::
(of Appli:ar,ts for a new or renewed CertiS:ste of Authoritation for Cass I, 2, 3, CS, CB, CC, or MC construction require a sunry of their shop or field facilities. The purp>se of the survey is to eveJunte the appH ant's Qality Assurance Manual and theimple-mentation of the Quably Assurance Program.
(t>) Authorizatioa to app!y a Code Symbol Stamp to an item will be gre.nted o:Jy after a survey by the Society has satisfactorily dernonstrated the adequacy of the Qanlity Assurano: Program. '
(c) The calcot of the survey will be determined by the Sxiety basad os a resiew of the appUcant's intended work scope. The axeptance by the Sxiet) of the Quality Assuran:e Pro; ram shall not be inter-preted to mean endorsement of technical capability to perfo.m design work sueb as syv.em d: sign or stress analysis. Su:b eepability is imp 5:4 for the speciS composent invohrd by the certiSeation of Desisu Repana (NCA 3300, NCA-3555) by a Registered Professionn)Ensin:cr.
ASME CODE SECTION IX l QW-409 Th*ical Clasmincteristics QW-409.1 A change in the type of current or polanty, or an increase in heat input, or an incrusse in volume c( weid metal MM per unit length c(
.id, o,er that pru n 3,cr:3.e ==r be men-sared by citherof the following:
(a/ Heatinput(J/in.)
,,voie ee w w x6o Traved speed (m./ min) i (b) Vohame of Weld Metal == An Increase in bend size, or a h in length c( weld bead per unit length c( cicctrode or, alte.a-L1d i, a decrease in travel speed.
l De r@ a fa measurms the best input or vehmae of y- U weld =rhl t$oes not apply when the WPS is q -W with a grain refining sust. ' g -
! best tr~~t after welding.
l
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