ML20077P400

Suppl to Motion to Reopen Record on Const QA Issue.New Documents Discovered Which Establish Existence of Widespread Deficiencies in Pullman QA Program from 1971 - Sept 1977. Certificate of Svc Encl

ML20077P400
Person / Time
Site:	Diablo Canyon
Issue date:	09/09/1983
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
ISSUANCES-OL, NUDOCS 8309130368
Download: ML20077P400 (75)

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OOCKETED USNRC UNITED STATES OF AMERICA ~ NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSING APPEAL BOARD ) In the Matter.of ) ) ' PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L. _) 50-323 0.L. (Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) ) ) ) JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE The Joint Intervenors to the above-entitled proceeding hereby supplement their pending motion to reopen the record on the issue of construction quality assurance ("CQA") with_the . attached documents containing significant new evidence directly relevant to the issue before this Appeal Board. The_ documents, only recently received and reviewed by the Joint Intervenors and their consultant, are ' (1) a proposal for an independent audit of Pullman Power Products-(" Pullman"), one'of PGandE's two principal construction contractors at Diablo Canyon, to be conducted by. Nuclear Services Corporation ("NSC"); and (2) the reportlof the audit itself, conducted by NSC and covering the period from 1971 through September 1977. To the best of our knowledge, the attached audit report has never been disclosed .8309130368 830909 PDR ADOCK 05000275 O PDR ~ 3>s63

7 by PGandE to this Board _or to'the parties.1/ As' appears below and in the_ report itself, the audit establishes the-existence of widespread deficiencies in Pullman's QA program'from 1971 through September'1977, ~ deficiencies which apparently went uncorrected at'least during the seven-year. period covered by the~ audit. .In so doing, it-provides significant'new evidence that directly contt dicts the

affidavits and testimony previously offered by.PGandE in opposition to.the-Joint Intervenors' and Governor Deukmejian's motions to reopen.' In support of PGandE's July 2, 1982 Response, for' example, Diablo Canyon' Station Construction Manager Bain attempted to. distinguish PGandE's construction QA l

_ program from its concededly' deficient design QA program as follows: i For the construction and installation of the building; equipment, and apparatus at Diablo Canyon, PGandE required that each contractor performing work at Diablo Canyon have a quality assurance program qualified to PGandE, E industry, and Nuclear. Regulatory Commission (Atomic Energy. Commission) quality assurance requirements. The contractor and any sub-tier 1/ Notably,.the audit was conducted in August and September 1977 just prior to the brief hearing on quality assurance before the. Licensing Board in mid-October 1977. 1 PGandE's witnesses made no mention of the adverse audit report 1 in their~ testimony to the Board.. Similarly, in none of their filings in opposition to the pending construction QA motions has PGandE mentioned the report or its findings. To the contrary, PGandE's witnesses have cited Pullman as a shining example of its construction contractors' adherence to QA requirements. See discussion infra. i -,-----r

contractor or supplier providing a service or material to be installed at Diablo Canyon adhered to these procedures in the performance of work at the site. (Bain Af fidavit, at 5.) Throughout the construction of DCPP well-defined QA/QC controls were required of the construction contractors. Strict requirements existed from the beginning and were enforced. (Id., at 14.) (Emphasis added.) More recently, at the " mini-hearing" on the motions in late July, PGandE witness Twiddy testified specifically with regard to Pullman's QA program: .1976 to recently -- we only had two major contractors, Pullman Power. Products and the H.P. Foley Company. The Pullman Power Product Company has an ASME N-stamp quality assurance program that's reviewed by the ASME survey team. They work more -- how shall I state this -- they just perform a better job when it comes tx) quality assurance. (Tr. 573-74.) Well, if you want to put it on a scale, I don't know how to answer your question, other than the fact that if I put a quality program on the scale of 1 to 10 and 8 is acceptable, I would say Pullman is a 10, and Foley is at 9, if that's clear enough. (Tr. 605.) (Emphasis added.) In striking contrast to PGandE's testimony, the new evidence offered herein as a supplement to the pending motions indicates a pervasive failure to adhere to the broad range of QA requirements in construction, suggesting the same lack of commitment to QA as has been established in design. The report is necessary, therefore, to set the record straight and cannot be ignored. As is evident from a reading of the report itself, _._

~ r e the deficiencies in Pullman's QA program were wideranging and substantial and included numerous violations of each of the applicable 10 C.F.R. Part 50, Appendix B criteria. The following summary listing of the principal deficiencies, with page citations to the audit report, is illustrative: -(a) lack of design interface and controls (pp. 7-8); (b) failure (1) to establish or describe a QA program in compliance with Appendix B or ANSI N45.2 or (2) to amend the contract to require such compliance (p. 10); (c) absence of management assessment (p. 10); (d) inadequate training and indoctrination of inspectors and workers (p. 10); (e) absence of design manual for preparation of isometrics and field drawings (p. 12); (f) absence of procedure to verify approved supplier (p. 13); (g) inadequate description of activities affecting quality (p. 14); (h) uncontrolled alteration of documents (e.g.., evidence of backdating of documents) (p. 16); (i) absence of procedures barring alteration of records (p. 16); (j) inadequate instructions for identification of Class I pipe supports (p. 20); (k) inadequate qualification and certification of inspection personnel (p. 21); -

(1) inadequate control of the welding process resulting in "no confidence that welding done prior to early 1974 was performed in accordance with welding specification, requirements" (pp. 22-25) (emphasis added); (m) failure to control special processes (i.e., heat trading and cleaning); (n) inadequate inspection processes (p. 27); (o) unaudir.able inspection process (p. 27); (p) inadequate control of testing (p. 29); (q) inadequate implementation of calibration program; (r) inadequate procedures for storage and handling (p. 32); (s) inadequate inspection procedures (e.g., " Field Process' Sheet") (p. 34); ( t) inadequate procedures for identifying nonconformances (p. 36); (u) lack of corrective action system (p. 37); (v) lack of procedures for filing, storing, and protecting quality assurance records (p. 38); (w) inadequate and ineffectual audits and procedures (p. 39). Based on these findings contained in Section IV of the report, NSC concluded as follows: Prior to early 1974,.there is little evidence available tx) verify the adequacy of the work performed. The available evidence indicates l,

_ ~ e that only a rudimentary quality control program existed and that control over the production ' organization was minimal, From early 1974 to late 1974, there is evidence available to verify the adequacy of the work performed. The available evidence. indicates that control was achieved of the materials control program and the welding control s -program. From late 1974 to the present, an increasing amount of documentation and records has been ..[j, generated to verify the adequacy of the work r" -performed..The available evidence demonstrates that an increasingly more stringent quality

program has been placed in effect and

increasingly greater control of the work offort has been achieved.

However, the present program and controls still do not meet 10 C.F.R. 50, Appendix B requirements in those areas as delineated in Section IV of the audit report. (P. 42) (Emphasis added.) By virtue of their breadth and number, these audit findings by an independent auditor establish a breakdown in the 4 Pullman QA program -- and, as the responsible applicant, in 1 PGandE's QA program as well -- throughout the period of peak plant construction, a breakdown analogous to that found by Roger 'Reedylin the area of design QA. It confirms, therefore, the evidence prov'iously offered by the Joint Intervenors and Governor Deukmejian in support of their motions suggesting that the' design QA' deficiencies conceded by PGandE extend to construction QA as well. Further, it undermines PGandE's confident assurances that its construction contractors strictly adhered to regulatory reuqirements and industry guidance. If, as PGandE's witness _Twiddy testified, Pullman's QA program is a "10 on a scale of 10," there is no basis upon which to conclude that any of the other construction contractors for Diablo Canyon had established and implemented an adequate QA program.,, _,, _. ~

o The new evidence submitted through this supplement provides further compelling evidence in support of the pending motions to reopen. Although the Joint Intervenors do not now know what corrective actions, if any, may have been taken by PGandE based on these audit findings, the report indicates that the period when the plant was substantially constructed was characterized not only by a breakdown in design QA practices but construction QA practices as well. Because this report and any PGandE response to it warrants close scrutiny by all parties and the Board, it demonstrates plainly the need for full evidentiary hearings to determine on the record the extent of QA noncompliance by Diablo Canyon construction contractors and the adequacy of any subsequent corrective action. The Joint Intervenors believe that the significance of this evidence is apparent from the audit report itself. If, however, the Board requests all parties to address.in greater detail the significance and implications of each of the cited deficiencies, the Joint Intervenors will certainly do so. '/// l /// l /// i I h _ _.~_

a o. For the reasons stated herein and in each of the documents previously filed in support of reopening the record, the Joint Intervenors respectfully submit that their motion to reopen-the record in this proceeding on the issue of construction quality assurance should be granted. DATED: September 9, 1983 Respectfully submitted, JOEL R. REYNOLDS, ESQ. JOHN R. PHILLIPS, ESQ. ERIC HAVIAN, ESQ. Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ. P. O. Box 1178 Oklahoma City, OK 73101 ~ By /OEL REYN050s Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION l CONFERENCE, INC. ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APPELBERG JOHN J. FORSTER l l l ~ w- ,m.w ---a n

e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of ) ) PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L. ) 50-323 0.L. (Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) ) ) ) CERTIFICATE OF SERVICE I hereby certify that on this 9th day of September, 1983, I have served copies of the foregoing JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE, mailing them through the U.S. mails, first class, postage prepaid.

• Thomas S. Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Cc : mission Conference, Inc.

Washington, D.C. 20555 4623 More Mesa Drive Santa Barbara, CA 93105

• Dr. W. Reed Johnson Atomic Safety & Licensing
• Malcolm H. Furbush, Esq.

Appeal Board Vice President & General U.S. Nuclear Regulatory Counsel Commission Philip A. Crane, Esq. Washington, D.C. 20555 Pacific Gas & Electric Company 77 Beale Street, Room 3135

• Dr. John H. Buck San Francisco, CA 94106 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 h

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• Docket and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
• Lawrence Chandler, Esq.

Office of the-Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission -Washington,ED.C. 20555 Janice 3. Kerr. Esq.

1. Lawrence Q. Garcia,.Esq.

J. Calvin Simpson, Esq. California Public Utilities Commisuion 5246 McAllister Street San ~ Francisco, CA-94102 John Van de Kaup, Attorney General -Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special. Counsel to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Loc Angeles, CA 90010 David S. Fleischaker, Esq. Post Office Box 1178 Oklahoma City, OK 73101 Richard Hubb'ard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose,- CA.95725 i Arthur C. Gehr, Esq. Snell & Wilmer 3100 Valley Center Phoenix, AZ 85073

• Bruce Norton Esq.-

Norton, Burke,. Berry & French, P.C. 2002 E. Osborn Phoenix, AZ 85016

• Maurice'Axelrad Esq Lowenstein, Newman, Reis & Axelrad, P.C.

1025 Connecticut Avenue, N.W. Washington, D.C.- 20036 Virginia and Gordon Bruno Pecho Ranch Post Otfice Box 6289 'Los Osos, CA 93402 9 + e +, -m w w w g w,--e--<3--- wwr-e--+,-- jy y e s. c,~--- ,e w r-e e a e-e ---ee--. + - -*--s-*-m-w-=-==s,-*rr N-*c= "v-~*-

Sandra and Gordon Silver 1760 Alisal Street . San Luis Obispo, CA 93401 Nancy Culver 192 Luneta San Luis Obispo, CA 93402 Carl Neiburger Telegram Tribune . Post Office Box 112 San Luis Obispo, CA 93402 Betsy Umhoffer 1493 Southwood San Luis Obispo, CA 93401 dAAr e e AMANDA VARONA

• Delivered via Express Mail
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.) 4 t). PROPOSAL FOR INDEPENDENT INTERNAL 2 AUDIT. OF PULLMAN KELLOGG'S EFFORTS AT DIABLO CANYON o Prepared for: .o.LMAN-KELLOGG NUCLEAR SERVICES CORPORATION <c 1700 ocll Avenue Campbei1, CA. 95003 July 28, 1977 PS-07277-605 (_~r f O

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N TABLE OF CONTENTS PAGE l.0- INTROCUCTION-1 2,0 SCOPE OF SERVICE 3_

1 3.0 QUALIFICATIONS AND EXPERIENCE 3 4,0 SCHEDULE 3 5.0 PRICE-3 6.0 TERMS AND. CONDITIONS 4 ATTACHMENT A: RESUMES ATTACHMENT 0: QUALITY AUDITING SERVICES PROVIDED CLIENTS OF NUCLEAR SEP. VICES CORPORATION 1 ~ 9 8 1 e 5 9 4 e k t o

s HUCERR GR.h'!!CCS C0lIPOMlil0D .m PROPOSAL FOR AN INDEPENDENT INTERNAL AUDIT OF PULLMAN-KELLOGG'S EFFORT AT DIABLO CANYON 'i.0 INTRODUCTION Nuclear Services Corporation is pleased to submi t this proposal to perform an independent internal audit of Pullman-Kellogg's efforts at Liablo Can' yon. This proposal delineates the scope of services, qualification, experience, and estimated cost for accomplishing the work requested. The scope of this proposal compiles with Pullman-Kellogg's inquiry. 2.0 SCOPE OF SERVICES The proposed independent internal audit would assess the status, adequacy, and ef fectiveness of the following functions for each of the items listed, as' appropriate: Functions items Piping (field fabricated (1) Receiving Inspection e 1 2" diameter) (2)- Warehousing + Piping Supports (3) Installation e Piping Snubbers and e (4) Welding Snubber Settings (5). Heat Treating Piping Restraints o .(6) NDE (7) Installation Inspection o Weld Rod Nondes'tructive-e (8) Testing Examined Material (9) Records (excluding Primary Coolant System) Fire Protection System e s* = + - -. s

e. flUCtCG SQMIMS CDEPCI$liiGil The audit scope. would include: s (1) Review of the overall adequacy of the existing quality assurance . program against current HRC rcquirements. (2)- Review of the implementation of the quali y assurance progra.n. t .(3) Review of the workmanship of ficid-fat.ricated and installed items. 9 The independent internal audit would consist of.the following: (1) Preparation of an audit plan and related checklists. ~ Pullman-Kellogg will make available all the necessary documents and an audit coordinator. 2 (2) Three auditors for three weeks (15 working days) at Diablo Canyon to perform the audit, including entrance and exit interviews. Time would be spent at-Diablo Canyon Power Station Unit #1. The audit would be performed jn accordance with the Nuclear Services Corporation and(Pacific Gas and Electric Company quali ty Assurance Programs) ##

• ^"4 M C4 87 "

(3) Exit -interview with Pullman-Kellogg's upper management to provide a summary overview of program effectiveness. (4) Preparation of the audit report at Campbell and submittal of the requested number of copies of the final report to -Pullman-Kellogg management. 2-6 ~, - -e,--,

o c RUCIEE sf,IMCG QFd!'bMT1Gil t3.0 QUALIFICATI'ONS AND EXPERIENCE .The personnel selected to perform the work for. Pullnen-Kellogg will-have' the full range of'exportise necessary to perform the audit. 1 Nuclear' Services Corporation's audit team leaders a.re qualified to LANSI N45.2.23 and AftSt N45.2.12. Auditors are selected depending 1 'upon the expertise requi red for the particular audi t. Resumes describing the background and experience of J. weber, W. Rcwe, and G. Larsen are contained in Attachment A. n' Nuclear Services Corporation has performad audits similar to the proposed work for.many corporations. The quality auditing services that we.have provided to our clients are listed in Attachment B. P - 4.0 SCHEDULE The Nuclear. Services Corporation planning ef fort for this audit could comme'n'ce in August 1977, with the audit conducted anytime during late August or'early September. The audit plan would be submitted to Pullman-Kellogg at least one week in advance of the s-audit. The final audit report woul6 be submitted to Pullman-Kellogg within three weeks after the' conclusion of the audit. 5.0. PRICE The estimated costs' of one individual for two weeks (audit preparation and. report writing) -and three individuals for three weeks (audi t activity) are $29,200. Nuclear Services Corporation performs engineering and consulting services on a -time and asterials basis,lai th expenses billed at actual cost as established by the' fee schedule and terms of this proposal.. Fees for the time of direct: applied personnel vary with ' the level of skill-required and are indicated on Nuclear Services ' ~

e 110C120R GWRCCS C0in'.0GiliM1 C,3 Corporation's Standard Fee Schedule. The fee schedule is subject s to annual review and adjustment, with any necessary changes in -{ ~ rates becoming effective on January 1 of each year. Nuclear Services Corporation's Fec Schedule for 1977 was used as' the basis for this proposal. The Fee Schedule for 1977 will be provided upon request. 6.0 TERMS AND ;0NDITIONS-Nuclear Services Corporation will invoice for services performed upon completion of the w6rk. Unles's other speci fic arrangenents are made prior to invoicing,.any amounts outstanding af ter thirt.y (30) days of receipt of invoice by the client will be subject to an interest penalty of one percent '(1%) p r month. e e a M a e 9 9 9 e

~. - NUCLEAR SERVICES CORPORATION Jack Weber, STAFF CONSULTANT' L r Mr. Weber has more than 18:. years' experience in - the development, fab-rication, production and; testing of nuclear power reactor con;ponents, incl'uding fuel" cladding, fuel' assemblies, and heat exchangers. His experiench includes materials and processes for development, fabrica-J' tion, and'testLof.a_prototyp6; sodium-water haat exchanger meeting ASME f .Coller and Pressure Vessel Ccdc requirements. .j ~ PROFESSIONAL EXPERIENCE Present cNuclear Services Corporation, Campbell, California. ^ Staff Consultant. Manager, quality Assurance and e Environmental Services Department. Responsible for-quality assurance programs:for utilities, including. audits of contractors and subcontractors, liaison with e federal regulatory agencies, training and education . sessions, and review of technical. documents. -Served as -(., .the acting' quality Assurance Manager for two utilities and has served as' audit team leader for.a number of audits to evaluate management, quality assurance, fuel, cost effectiveness, equipment status, and subcontractor evaluations. Presented seminars on quality. assurance and audit training... Has worked with overseas firms to establish quality. programs. '.1967'- 1970 Atomics International, Los Angeles, California. Project Manager. Engaged in materials and processes i .research for the development, fabrication, and testing ' of a prototype sodium-water heat exchanger for the Fast Breeder Reactor Program. The heat exchanger was con-q structed to~Section lil, Class A of the ASME Boiler and

Pressure Vessel Code; and a patent was granted for a tube-to-tube sheet welding process.

Formulated the quality assurance program and the material and process spec i fi c'a t ions. Responsible for technical direction; subcontract administration; vendor and customer liaison; coordination-with the design, inspection,'and manu-- facturing departments; liaison with AEC a'gencies; and ' development of fabrication processes. Also engaged in the-developmental effort associated with uranium carbid'e 7 fuel.for the Heavy Water Organic Cooled Reactor concept. -) 4 }. j

• Hr. J ck V:ber - Pcgn 2 I

1966 - 1967 Combustion Encineerino, Windsor Locks, Connecticut. C Project Engineer. Assigned as technical representative Q to Atomics international on the HWOCR Program. Con-ducted developirent programs for solid state bonding and the testing programs to evaluate the bonds. Responsible for the specifications and vendor evaluation of' uranium dioxide fuel pellets and zirconium cladding in support of the light water reactor effort. igg - 1966 Westinghouse Electric Cornoration. Pittsburgh, Pennsylvania. Project Engineer. Engaged in the development of fabri-cation procceses for manufacture of Zircaloy-clad PWR fuel elements. Responsibit for the technical quality of fuel elementr, for PWR Core 2, including the requirements for the seed and, blanket fuel wafers, the development end welding of Zircaloy spacer grids and fuel' clements, and material testing and studies related to oxidation of Zircaloy. EDUCATION M.S., Metallui. cal Engineering, Carnegie Institute of Technology, 1964 B.S., Metallurgical Engineering, Colorado School of Mines, 1958 PROFESSIONAL AFFILIATIONS Registered Professional Engineer, Metallurgical Engineering, No. 1689, California Registered Professional Engineer, quality Engineering, No. 1107, California Member, Professional Engineering Society Member, American Society for quali ty Control Member, American Nuclear Society Member, American Society for Metals PATENTS Patent awarded for tube-i.o-tube sheet welding head and fixture 12/17/76 b.

- 3..

• ~

NUCLEAR SERVICES CORPORATION G. William Rowe SCHIOR CONSULTANT Mr.. P. owe has.over sixteen years of construction ~ expertence, with special competence in project management for both the nuclear and industrial s' . construction industries.- His positions included those of field engineer - thru construction manager on varied and complex Industrial and commercial @ jects ranging in cost'from one hundred thousand to ever five hundred ~ - million dollars.- PROFESSidNAl. EXPERIENCE Nuclear Services Corporation, Campbell California. -Present Manager, Construction Services. Presently assigned to the River Bend Nuclear Project (Twin 1100 MW(e) BWR's) .for Gulf States Utilities. Provides construction renagement. assistance to.the _ utility's site staf f and is in charge of the construction engineering department which coordinates all A/E engineering activities, temporary facilities, (; security, subcontract evaluation,-and performs construction .f Inspection. Addltionally,'the construction engineering. department provides construction program and schedule evaluation, subcontractor. progress. payment approval, and preparation of site progress reports to management. 1974 - 1975 General Atomic Company, San Diego, California. S ta f f Construction Engineer. Designated as Site Manager for' the proposed Sun Desert Nuclear Pcwer Plant Project for San Diego Gas t, Electric Company. Responsible for architect / engineer coordina.lon on piping. installation; steam generator installation and removal methods; con-struction erection sequencing; review / evaluation of engineer / constructor studies; CPM schedule analysis for an 1100 MW(e) HTGR nuclear power plant. ~ 1973 - 1974 Ralph M. Parsnns Company, P'asadena,-California. Chief Mechani i Engincer, Enrico Fermi il Nuclear Power Plant (1100 MW(e) BWR) for. the Detroit Edison Company. Responsible for the supervision and direction of piping, welding, mechanical equipment installation, small piping design cffort, team leader for ASME "N" stamp prepara-tion and.audi:s. e..

c (.. William Rowe - Page 2 1969 1972 Dechtel' Corporation, San Francisco, California. Senior Fictd Engineer, Ouane Arnold Nuclear: Power Plant (550Mw(e) swr) for towa Electric. Responsible for pipe inst'allation scheduling, mechanical equipment installa-tion, intake structure craf t supervision (acting field superintendent) and. monitoring hydro-testing efforts. 1965 - 1969 Daniel Construction Company, Greenville, South Carolina.. Assistant Project Manager, aluminum reduction plant. Responsible to the Prcject Manager for field engineering, purchasing, scheduling, cost and subcontract management. 1960 - 1965_ Lockheed Missiles and Space Corporation, Sunnyvale, California. - Manager - Facilitiss Engineering. Responalble for ths coordination of construction activities of subcontractors involved in the expansion of Lockheed fa:Ilities in Sunnyvale, California. EDUCATION Mechanical Engineering, University of Vermont (2 years). B.A., industrial Management, University of Vermont, 1960. PROFESSIONAL AFFILIATIONS Associate Member, American Nuclear Society License, General Engineering Contractor - State of California License, General Building Contractor - State of California Associate Member, American Society of Mechanical Engineers .5/19/77 e (L,.:

^ NUCLE 5R S5RUIC55 CORPORhtiON 'Gercid J. Larser,- j

• 1 l

x" ] ,s 1 -SENIOR CONSULTANT 'wC-i Hr. Larsen has' over twenty yeces of mechanical and ele'ctrical engineering experience, with sixteen years broad spectrum of experience in commercial nuclear = power plant design, engineering, construction, test, operation and maintenance.. He is certified Level ill to supervise,~-direct, and perform engineering, construction, operational testing, operational support services, and NDE technical Inspection and administration. PROFESSICNAL EX?ERIENCE 4 Present Nuclear Services Corporation, Campbell, California. Manager of Operating Plant Services. Directs and supervises utility operational. support services and management of 30 to 40 engineers and technicians including maintenance, ncndestructive examination, technical inspection services, including; refueling, plant betterment, and related construction for BWR and PWR applications. (,,', 1961'- 1976 General Electric Comoany, Nuclear Energy Olvision, San 1 Jose, California. 1972 - 1976 Senior Project Engineer - Nuclear Projects Department. Overall technical and engineering direction on Perry 1 and 2 (BWR-6, MK-Ill) Nuclear Power Plant.

Develop, administer, and evaluate GE and Customer /AE component and systems to ensure ccmpletion of the proper design objectives and final project unique requirements for optimum safety, operations and conformance to construction requirements.

Develop specific plant designs to assist AE/ constructor in optimization of overall plant operations. Ensure compliance to quality control requirements of NRC, ASME, ASTM, ASTN, ANSI, OSHA, and local regulatory requirements. Integrate AE/ Customer /NRC requirements to project. 1970 - 1972 Warranty Service Engineer 1 - Atomic Power Equipment Department. Project management of " turned-over" operating nuclear power plants and customer liaison for product service, plant betterment, modifications and ove.rall plant operation. Planned, scheduled, supervised, 8 .m,. ,_,._,_,._.m,.__.,,

( * ' Gerald J. Lorsan ~ - Pcga 2 ~ and performed refueling, maintenance, inspection, and 4 repair outages. _ Designed special equipment and tools i /^ for numerous operations. Supervised GE personnel assigned to field' construction, testing, and systems operational . problems. Managed and_ coordinated the on-site activities (30-40 engineers) of. the Tsuruga Nuclear _ S.tation (Japan) Ist refueling and maintenance outage. Performed fuel-sipping and related inspections. Division Radiation Safety ~ Representative. Developed and integrated AE/Conscructor - work'on total. plant.- Developed working relationships with Inter-department:and intra-company responsibilities. Participated in marketing activities with potential: customers and developed proposal engineering data. 1969 - 1970 Superintendent of Testing - TOP 0 - Nuclenor (Spain) Project. Responsible for coordinating and performing construction and operational testing and adequacy of nuclear steam supply system and balance of plant systems.

Planned, supervised, and scheduled construction activities and testing program with site-assigned GE personnel, Ebasco (AE) personnel, customer technical staff, and vendor representatives.

Planned engineering requirements and supervised hydrostatic tests, nondestructive examination, and flushing ;~ reactor systems. ' ('m 1967 - 1969 Project Engineer / Reactor Operator - IGE Tarapur (india) Project. Assigned as APED engineering representative. Installation. inspection and functional testing of reactor. servicing equipment and core components. Supervised and trained customer and GE personnel for new fuel inspection and' installation, removal, disassembly and inspection of control rod drive mechanisms. Supervised and performed construction and pre-operational verification of condensate demineralizer, make-up water, off gas, nitrogen make-up and radwaste-systems. Supervised and performed QC/QA-NDE of the stress-corrosion repair program (retubing) of the secondary steam generators involving GE, customer, AE, and vendor personnel. Reactor Operations Shift Supervisor passed AEC equivalent Reactor Operators examination. 1966 - 1967 Operating Plant Engineer, Field Engineering, APED Engineering representative for Big Rock Point (Michigan) and KRB (Germany) nuclear power stations. Provided engineering direction for resolvement of plant operating, maintenance, testing, system and component problems. Responsible for, and supervised on-site activities, including: construction, testing, troubleshooting, system betterment repair programs, (L.- O W69W ep,.-

~ '~~ ~ Gerald J.1.arsgn

Paga 3' refueling and maintenance outages, irradiated fuel inspection, ultrasonic,-penetrant testing, and other nondestructive test y

it inspections, failed fuel sipping and miscellaneous field problems. 1965 - 1966 ~ Field Construction Engineer - KRB '(Germany) Project. ~Provided guidance to customer for establishing long-term maintenance program planning. Supervised construction, Installation and pre-operational testing of plant process and control systems. Supervised maintenance instructions and procedures for control rod drive mechanisms and reactor ~ tools and servicing equipment. Performed nondestructive test inspections. e. 1961 - 1965-Engineering - Atomic Power Equipment Department. Prepared operating procedures for JPDR _(Japan) reactor 4 - (on-s i te). Participated in new fuel inspection and reactor components, inspection, testing, and installation. -Descloped various construction, operating and maintenance instructions, radiation control procedures and standards - for reactors, including JPDR, PR&E Humbolt Bay, Lowell Tech OPR, EVESR, etc.; provided on-site guidance to customer operating and maintenance personnel at the GKN (Netherlands) reactor. (" 1960 --1961 H. t.. Yoh Comoany, Palo Alto, California. Production Manager. Supervised design engineering and construction requirements for miscellaneous electro / mechanical projects. Developed QA/QC programs and testing criteria for systems and-components. Developed sales and marketing efforts for engineering services. ~ 1959 -'1960-Admiral Corporation, Project Engineer. Performed laboratory design work.cf solid-state decoding equipment and field installation testing, and trouble-shooting for aircraf t-controller transponder operations. Developed quality Control procedures and methods to military specification require-ments. 1957 - 1959 Sylvania Electric Comoany, Technical-Development Engineer. Designed and fabricated laboratory test equipment-for traveling wave tubes. Supervised construction. Installation, and testing of various microwave t ut equipment installation. . g. e

Y 1 erald J. Lorstn - Pcg2 4 G 1954 - 1957 Ford Motor Company.. ^ Plant Engineer. Performed construction, installation .and troubleshooting of electro / mechanical conveyor and process systems. Developed maintenance program for operating plant _ equipment.. Performed nondestructive . testing of Installed equipment. Coordinated construction, installation, and'startup of vendor-supplied automatic paint system. 1950 -1954 U.S. Air Force, Senior Armament Specialist (Airborne). Combat crew member on RB-29 and RB-36 tactical aircraft. Provided in-flight instruction on systems to SAC pilots and Member of crew team for liaison and qualification gunners. acceptance testing of new aircraft. EDUCATION ~AA-SE,. San Jose / College, 1958 Other courses and training completed: Nuclear Reactor Technology Nuclear Instrumentation ' Construction Management-Radiation Protection Nondestructive. Testing Process Control s Thermodynamics quality: Control Courses and Seminars "(--; Professional-Business Management Courses j. and Seminars-PROFESSIONAL RECOGNITION Registered Professional Engineer (Nuclear N-310), California 1/28/77 1~ e ~

= w;y. { :. - i .flUCtta! JWDCCS COUPGliAT10ft I-i QUALITY AUDITING SERVICCS PROVIDED CCIENTS OF NUCLEAR SERVICES CORPORATION Client Activity . Anchor / Darling Valve Company Perform Audits of QA Program per ASME Requirements . 's -l1 Boston Edison Company Perform Vendor Auditing and Surveillance

1-Pilgrim Nuclear ~ Power Station Activities

'l Carolina Power and Light Company; Perform Audits of QA Program per i ASME Requirements i Central Nuclear'de Valdecaballeros Perform Project Auditing Services - (Spain)- Perform Program Audits of Major . Participants-i Commercial Contracting Corporation Perform Audits of QA Program per [ ASME Requirements !DeLaval Enterprise Division Perform QA Program Evaluation .f. m Duquesne L1ght Company Perform Records System Audit X Establish and implement a Site Auditing Program Exxon. Nuclear Company Provide Fuel Fabrication QA/QC ! ~ Fuel Fabrication. Plant Auditing Freese and Nichols Perform Internal Audits Gulf-States Utilities Perform Internal Audits Perform Project Management Audits Perform 0A Audits of A/E and NSSS Helwa-Stect and Iron Products Perform Audits.of QA Program per Jompany, Ltd. (Japan) ASME Requirements [. Hirata Valve' Industry Company Ltd. Perform Audits of QA Program per C .[ (Japan) ASME Requirements ~H.' S. Wright Construction Company ' Perform Pre-AEC Audit and Consultation b . lllinoi s Power Company Perform Audits of all Major Participants Perform Internal Audits Perform Project Management Audits Perform Audits of Site QA Program y h*f i i 1

~ 1 DUCLEM SC!!YICCS CODP0lt3T10D )' Indiana and Michigan Electric Company Develop Audit Procedures ITT-Ea rton Perform Audits of QA Program per ASME Requi rements Jersey Central Power & Light Company Perform Management Audit Kernkraf twerk 1.elbstadt AG Perform Audits of Suppliers (Elektrowatt), (Swl tzer1and) Kubota, Ltd. (Japan) Perform Audits of QA Program per l ASME Requirements Hason-Johnston and Associates, Inc. ' Perform Internal Audi ts Nakakita Seisakusho Co. (Japan) Perform Audits of QA Program per ASME Requirements ' Hippon Denkan Kogyo Co., Ltd. Perform Audits of QA Program per (Japan) ASME Requi rements 'Haneda Factory Kiryu Factory Yabuzuka Factory Osaka Factory Northern States Pcwer Company Perform Audits of Construction Monticello Nuclear Power Plant and Operating QA Programs Omaha Public Power District Perform Records System Audit Pennsylvania Power and Light Company Perform Vendor Auditing and Surveillance Susquehanna Steam Electric Station Perform Audits of Utility QA Program Perform Project Management Audits l Potomac Electric Power Company Perform Vendor Auditing in Japan l Perform Audits of Utility QA Activitics Perform QA Audits of A/E and NSSS l R.E.C. Corporation Perform Vendor Auditing in Japan Remco Hydraulics Division Perform Audits of QA Program per Stanray Corporation ASME Requi rements Rochester Gas and Electric Company Perform Management Audits Perform Operating QA Program Audits Sacramento Municipal Utility District Perform Records System Audi t B-2 h..

i I1UCLE.9R SERVICES CDRPORAT108 g.

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SNUPPS Perform Audits of Various Major and Member Utilities Participants Kansas Gas and Electric Company teorthein States Power Company {- Rochester Gas and Electric Company Union Electric Company Southern California Edison Perform Audits of QA Program per ASME Requirements Stone and Webster Engineering Perform Management Audits Corporation Toa Valve Company, Ltd. (Japan) Perform Audits of QA Frogram per ASME Requirements Toledo Edison Company Perform Records System Audit Utsue Valve Company, Ltd. (Japan) Perform Audits of QA Program per ASME Requirements l Yankee Rowe Perform Records System Audit f a t I I e h h S 1 6 ,, - + - - .-,-.,-r ,,.~

lGlM.CO' S7!MCC$ CM&.!WOUM-l fv' ' AUDIT Pl.Atl F0ll' Art INDEPE!! DEI'IT IllTEPJ!AL AUDIT Ol' PULLIMfi-KELLOGG'S DIABLO CAtlY0il PROJECT 1.0 This audit plan describes tiie agenda for review and audit of the Pullman Power Products Corporation (the Contractor) Project efforts at Diablo Canyon (!uclear Units 1 and 2. i l '.1 -The purpose of this audit is to detcrmine through investigation-the adequacy of the Contractors performance of its functions ~ as defined in the " Description of Work" contract document, quality. assurance program description, codes, standards, and other related requirements especially appropriate to current-. practices and ' state-of-art. .l.2 Thr. audit is intended to encompass the Contractors efforts from (- ' contract initiation to the present and will include investigation of the items discussed in the following paragraphs. e -Initiation of the Contractors-Quality Assurance Program, modifications and revisions to the QA program, and the adequacy of the current QA program. o Investigation and evaluation.of the Contractors organization; ~ personnel qualifications; instructions, procedurcs, and drawings; document control; purchased material control and identification; special process control,. nonconforming reporting and closc-out; corrective action; quality assurance records including inspection, nonconforming materials, ~ discrepancies and corrective action; audits. .g f 4 -l-

^ ~. .x e IlUdfdC ~71'R3.MS Cfi!st'l8MBf]!El [N-Investigation and... evaluation of implementation of the A,j - o Contractors functional application of selected work

including representative sampling of systems from cach unit.

2.0 ' Activitics expected to be audited will be in accordance.vith the following General Audit time schedule. August 15,17, and 18 . Review of pullman-Kellogg documents. ~ August 16 -- Entrance Interview at Diablo Canyon with pullman-Kellogg, PG&E, and HSC audit team. August 22-24 -- Organization,' personnel qualification and certi-fication programs, software systems -(document control, nonconfonnances, etc.) gnd abditing program. August 25 and 26 -- Feedwater System Unit #1. August 29 asQ-e Feedwater System Unit #2. 30 S * 'O ' .{, August 31 and September 1 -- CVCS System Unit #2. Sep.tember 2 -- PJiR System Unit #1. ' September 6 and 7 - Safety Injection System Unit #1. th September @ corning of the' 9 -- Containment Spray System Unit f[ g'/ [y,, # c and Component Cooling Water System Unit #/. 'l The systems review will include physical inspection and verification of installed components, welds, attachments, restraints, and the following aspects: ~ a. Procurement Specifications. b. Receiving inspection of items including piping spoo! pieces, hangers, snubbers, anchors, valves, and support components, inspecting consumabics such -as film, dye penetrant, and NDE equipment, welding materials. w v.

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c. - Storage of components, materials, consumables.

d. Installation', erection, fit-up, welding, cleaning, inspection, and testing. At the end of cach day, the audit team will discuss the-findings of th'at day and the schedule for the following day. A formal th exit interview will be held the afternoon of September 9 Th'e above identified schedule and activities may be revised 'o -. depending on the. find.,s of the audit team. September 12, thru 30 -- Compilation and submission of formal audit report. e i. e I f l l ~ -. - -,, - +, n ,-,,-....-,,n- --...~w, g,,.., -a,,. ., -,,,,.y,

.1. ri$r5 b [CO3- } O ' Ig2f gg@,3pgg 'f n a m u vi~u.c c^=cu. cAu==^ ss== numaem -na ~ LCORP0HGUM1 Twx 910 590 u38 L ~ October 24, 1977 NS,C-QAS-KEL-003 JW-77-072 Ifr. ' Edward F. Cervin Chief Engineer / Quality Assurance Manager Pullman Power Products . Post Office ~ Box 1007 Williamsport, Pennsylvania 17701

Subject:

. Audit Reoort of Diablo Canyon Effort

Dear Mr. Cervin:

The audit, conducted under your cognizance, of the Diablo Canyon work af-fort has been~ccepleted and is documented in the attached audit report. 9 ~ Section VI,! Sume.ary," of the audit report contains the audit team's over- .(- Canyon. To facilitate corrective acticus, as much detail and es many_ all' evaluation and conclusions concerning the work performed at Diablo specifics as 'possible have been included in the audit report, which ac-counts for the length of the report. If any additional details are re-quired, do not hesitate to call.me.- It'is my understanding that _information' to confirm the disposition of the audit findings by Pullman Power Products and eventually by Pacific' Cas and Electric Company will be transmitted to me. As we discussed, a copy of the letter transmitting the audit report from Pullman Power Products to Pacific Gas and Electric Company will be sufficient to confirm your dispo-sition. The precise method of verifying Pacific Gas and Electric Company disposition was not defined, but you did commit to requesting that Pacific Cas and Electric' Company' send me a copy of any. official co=munications con-cerning their actions relative to the audit. I trust that you have been able to obtain Pacific Gas and Elect!ric Company's concurrence. , In behalf of the audit team, I would like.to express my appreciation to .all the Pullman Power Prcducts' personnel for their cooperation and to you for your personal attention and involvement in the audit. Very truly yours, S l Jack Weber Audit Team. Leader s Attachment l -e++ y-. ,_,,_,y.,4 .m.,_,- ,,,.,_,_,,,g,

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F I 'L) 1. INTRODUCTION A. Audit Scooe and Purpose A quality assurance audit was performed on the Pullman Power Products work scope at the Diablo Canyon site. The purpose of the audit was to' evaluate the performance of the Pullman Power Products Diablo Canyon Site Organization with respect to the quality Program and contract requirements. The audit was performed under the cognizance of Mr. E. F. Gerwin, General Manager, quality Assurance, Pullman Power Products and, as such, was an independent, internal audit of the Pullman Power Products Diablo Canyon work scope. The scope of the audit included the following: (1) The organizational arrangement and the independence of the quality organization. ,. t. (2) The qualifications and certifications of p' rsonnel performing 'e.-." e the work'.' - (3) The Quality Assuranc'e Program, including the procedures and +~- .c..".:..9;.. - -- instructions by which the work-Is accompt ished. ~....e - t -~' ~,, * - - A ii k.~.: '. e.:+.j. - ~; 'h... ',. ? ' (4) The implemenGtion of the Quality. Assurance Program. YS"' .. ' ^* .:..\\.'.;'..' .**.=.z 7 ' " ~ ~ (5) The syste'ms by which dcficienciesare fdsnd, reported, tracked, . ;. u.-...v... and correc'ted. > ' ::. J.

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I ~ d I and erected piping, field-fabricated piping (<_2-inch diameter), piping supports, piping snubbers, piping restraints, weld rod, and material (excluding the Primary Coolant System) examined by nondestructive testing, as appropriate. The audit was performed by identifying each system or program that is used to control the work effort and samp1Ing those systems or programs untII a conclusion could be reached concerning the adequacy or in-adequacy of that system or program. The Pullman Power Products effort at Diablo Canyon was initiated in 1971, based on the contractual agreement of May 1970 between Pullman Power Products and Pacific Gas and Electric Company.' During the time period of 1971 to the present, the requirements relative to the Pullm.an Power Products work scope have changed. The audi; scope and purpose were to evaluate the Pullman., Power Products work effort against the codes and standards in effect at the particular time that the work was being p'erformed. When requirements are issued, there is always some room for interpretati,ons concerning what.Is an { acceptable method of satisfying these requirements. During-the 1971 -[ to 1374 time peri,od, a number o'f ANSl;'st'a~nda'rifs~w~ere promu'1 gated to l..'k_[4. d.._. . define acceptable methods of satisfying 10. CFR 50,' Appendix B. It .. ~ yj is required that organizations revi.se, thel.r quality programs to sat-Isfy present interpretations. In areas. req 0i. ring Interpretation, the quality.of,the work effort at Di~abig Canyon.Fas mea'sured against the current A..NSI. standards and Regulatory Guides, accepted today as valid )

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iniierpretations of' regulatory requirements.. 'The long time span and ~ the s'ecific time l nterval during which the work effort was conducted p should be considered when reading.this audit report. 9. m O 4

. ) 8. Audit Team The' audit team consisted of the following Nuclear Services Corporation personnel: Jack Weber, Audit Team Leader G. J. Larsen T. C. Newman (part-time) G. W. Rowe C. Audit Report The audit report is divided into.six parts: Section I, " Introduction"; ~ Section 11, " Audit Preparation"; Section ill, " Entrance Interview"; Section IV, " Audit Findings"; Section V, " Exit Interview"; and Section VI, " Summary." Corrective actioni, will be determined by the appropriate Pullman Power Products personnel upon receipt and review of-this audit report. .[. .c... l.. .~.. :. ~ . ;.. s. ~ ~ ~ E'-

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~ \\l} -A serics of meetings were heid in which the following tcntative scheduie was established: e Preparation,of check.chacts e Receipt and review of Pullman Power Products Quality Program documents and contr' actual commitments to Pacific Gas and Electric Company e Finalization of checksheets e Entrance interview e Audit of Organization, Personnel qualification and Certification Program, Document Control, Nonconformance Program, Auditing Program e Feedwater Systems, Unit _i and Unit 2 e Main Steam System, Unit 1 e Chemical and Volume Control Systemi Unit'2 e Resideal-Heat Removal System, Unit 1 o Safety inspection System, Unit 1 e Containment Spray System, Unit I e Component Cooling tlater System, Unit 1 The schedule was changed to meet the progress and findings of the audit, but the full scope of the audit was achieved. f g ^ : e L

C lit. - ENTRANCE. INTERVIEW An entrance interview was held August 16, 1977, at the Jiablo Canyon site to introduce the audit team..in attendance at the entrance Interview were?.'- ~ Jerry Arnold Pacific Gas & Electric Co. Diablo Canyon Site quality Assurance Coordination 1. .u Al Eck Pullman Power Products quality Engineer, Central Staff Rick Etzler Pacific Gas & Electric Co. Lead Mechanical Engineer Gerry Larsen Nuclear Services Corporation Auditor Bill Rowe Nuclear Services Corporation Auditor Pete Runyan Pullman Power Products Field quality Assurance Manager John Ryan Pullman Power Products Re.sident Construction Manager Mike Tressler Pacific Gas & Electric Co. Station Superintendent Jack Weber Nuc' lear Services Corporation Audit [eamLeader During the entrance interview, a discussion was held of the progress ~ ..and problems associated with the Pullman. Power Products effort and ^ the present status of the work effort. The scope 'and schedule of the .. audit were discussed. and agreement was reached to perform the audit , ~. in accordance with.the schedule presented in Section il above. Mr. J. P. Runyan, Fleid quality Assurance Manager, Pullman Power ' T Products, and his staff were designated as the audit team contacts. [ P., i : a :.

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IV.. AUDIT FINDINGS A The audit findings are divided into the 18 sections consistent with 10 CFR 50, Appendix B. The audit findings are given to present the status of the program and, therefore, include both the acceptable and unacceptable areas detected during the audit. e G 9 O O 6 9 0 e m e 4 e 4

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) Criterion 1. Organ'!zation 1. A current organizational chart does exict. 2. Procedures 1KFP-1 and KFPS-1 do describe the quality organization, as well as soes of the functional responsibilities of the quality orgar.ization. 3 The Field quality Assurance Organization has performed functions other than those described in KFP-1 and KFPS-1;'and some functions were outside the quality responsibility, i.e., writing and approving Engineering Specifications, performing welding engineering functions, approving engineering changes. These activities raise the question of the qualification of quality Assurance personnel to perform these functions and the problem of requiring the Fleid quality Assurance Organization to. audit its own performance. 4. Procedures'KFP-4, KFPS-4' KFP-6, KFPS-5, KFP-8, KFPS-7, KFP-9, and KFPS-8.do describe some of the responsibilities of the Field Engineering Organization. The responsibilities of the other Field _, Construction Organizations are not described, nor.are~ the full i responsibilities of the Field Engineering Organization described. + . r, 5., The descriptions of Individu.at position responsibilities are in-- ,,, adequate.. Some elements of' position' descriptions exist in the KFP and KFPS procedures, and Job descriptions exist for Inspection and ,e

, Inspection technician positions. No position descriptions exist a

.. '..-for any of tne upper-level si te personnel. ~ 6. The description and controls of the Interfacial relationship between ..,, Pullman Power Products and Pacific Gas and Electric Company are Inadequate. The contract and some Engineering Specifications do describe some interfaces and mechanisms. However, for the greatest scope of the work effort, there is little to describe how the inter-(,,j face will be managed and controlled. Scme of the activities that 7-e _.,i- ..,v-.-.-- .--.------ - -- - - ----------- - -M

require interface control are hydrostatic testing, nonconformance reporting, meetings, work on pipe rupture restraints, work on hanscrs, document control, reporting of deficiencies, responses to Pacific Gas and Electric Company audits, interfaces with other PacificGasandElectricCompanyconchactorsthat impact Pullman Power Products work, etc. 7 The description and the controls of the interfacial relationship between Pullman Power Products Field Organization and the other Pullman Power Products organizations involved in the Diablo Canyon effort are inadequate. The Quality Assurance Manual does describe some quality interfaces between the Field and Corporate Offices. However, there are no requirements for periodic reporting from the Field' Quality Assurance Organization to the Corporate Quality Assurance Organization; there are no requirements for an upper-management. review of corrective action reports, nonconformance reports, and personnel qualifications; the interface between the Field Organization and the Paramount shop is not described; the Interface between-the Resident Construction Manager and the Corpo-rate Construction Hanager is not described; the interface between field Quality Assurance and Corporate quality Assurance is not described with respect to field purchases and Corporate quality Assurance auditing of those supplicrs. 8. The description and the controls of the interfacial relationship ~ between the Pullman Power Products Field Quality Assurance Organiza-tion and the other Pullman Power Products Field Organizations are inadequate. The quality Assurance Ma'nual and many of the Engineering Specifications describe interfaces and mechanisms. However, the interfaces relative to the construction and engineering efforts in regard to drawings approval; review of isometric, hangers, and restraint document packages; welders logs; and control of the weld- / ing process are not described. (.. 4 '

s 9 The stop work authority for the Field quality Assurance Organization d. Is not adequate. Procedure ESD-240 does describe the stop work authority for Hold Tags, but there are no mechanisms described or aukhorityaddressedforthecircumstanceswhentheConstruction Organization elects to proceed. through a Hold Tag stiop.

10. The Field quality Assurance Organizatiori does report to a-sufficiently liigh level of management.

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) Criterion" 11. Procram 1. The contract between Pullman Power Products and Pacific Gas and Electric Company was signed in May 1970, prior to the enforcement of 10 CFR 50, Appendix B. The contract did contain certain quality aspects that were requirements for the Pullman Power Pro'ucts work d effort. W'rk was not initiated on the Diablo Canyon site until late o 1971, when Appendix B had become a requirement [ Appendix B was added to 10 CFR 50 on June 17. 1970, effective July 27,1970 (35 FR 10498), and amended September 11, 1971, effective October 11,1971 (36 FR 18301)]. Even though the contract was not amended by Pacific Gas and Electric Company to include Appendix B as a requirement, Pullman Power Products was obligated to conform to Appendix B requirements; and the total quality program was evaluated against Appendix B and ANSl N45 2. While a written Quality Assurance Program exists, the program does not meet the requirements of 10 CFR 50, Appendix B or ANSI N45 2. The specific Inadequacies of the program are described throughout w the findings. 2. There is no description of the overall quality Assurance Program. Special quality Assurance instructions are not d'escribed; the rela-T1-tionship and purposes of the KFPS, KFP, and ESD procedures are not described; the Pipe Support quality 'Assuranc'e'Hanual is not described; g-and the' relationship of the Pipe Support quality Assurance Manual to the balance of the quality Assurance Progr.am.is not documented. . t.,

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._3 Procedures KFP-1 and KFPS-1 do prov'Jde a bro ~ad and generalized description of the scope and applicability of the quality Assurance Program. These procedures also reference the contract between ~ Pullman Power Products and Pacific Gas and Electric Company. However, the total scope and applicability of the quality Assurance Program are not adequately described. The efforts relative to pipe rupture restraints, receiving,and control of materials and components other than Pullman Power Products procured,and the work associated with anchor bolts are not adequately described. . ~, ,. - _, _. ~ _

~ 4. There is no evidence that upper management has performed scheduled reviews o'f nonconformance reports, personnel qualifications, and corrective actions. 5. There is evidence that upper management has performed reviews of audit repo.ts generated by Pullman Power Products and Pacific Gas and Electric Company. 6. The Indoctrination and training program requirems.nts for personnel involved in inspection activities are adequate. Procedures KFP-2, KFP-3, KFPS-2, and KFPS-3 require training of NDE personnel; Procedure ESD-237 specifies a training program for the NDE personnel; Procedure ESD-237 also describes a training program for Quality Assurance Field Inspectors. 7. The Indoctrination and training program requirements for personnel involved in quality-related activities are inadequate. There is no requirement for indoctrination and training of welders, foremen, engineering personrel, warehousing personnel, etc. 8. There is no evidence that personnel have been trained to assure their familiarity with the procedures they are responsible for implementing, except for welders, who have been trained and qualified to specific ._ weld procedures. + l-s: s O O a 11 -

t v Des' inn Control -) - Criterion ^ lit. ~2 ' ' l. There is no design manual for the preparation of isometrics and field fabrication drawings. 2. Procedure KFPS-4 provides adequate control of the pipe support design effort. ~ 3 Procedure KFP-4 requires that the Chief Field Engineer and the Field o Quality Assurance / Quality Control Manag*er review field changes to j. Pacific Gas and Electric Company-approved drawings and specifications for ASME Code compliance. No written procedure for_this review exists. 4. A_ mechanism does exist for checking and reviewing Pullman Power . Products drawings. However, this mechanism is not described in a written procedure. Documentation of the implementation of this informal procedure does exist. ,og e ' f< 5 The isometrics and field fab,rication drawings do indicate the clas,ification of systems. 6. Procedure E50-205 does contain a classification of systems.and the requirements for each classification. 7. -The chang'es to. isometric drawings _ and field fabrication drawings are indicated on the documents, as well as the reason for the change. Procedure KFP-3 establishes a mechanism to permit tracking of all ~ i.e., the Chief Field Engineer is required to maintain revisions, a copy of all voide.: "rawings. 8. Procedure KFPS-8 requires the Chief Field Support Engineer to assure No that all. supports are fabricated to the latest drawing revision. mechanism exists to conply with this requirement. .r .a - - ~.. -.. _. -_.. _.....,. ,--.-..-..._,..,,I

n ~. sj .' s l 4, i Criterion IV. Procurement Document Control l. Procedurcs_KFP-6 and KFPS-5 adequately describe the responsibilities ] associated with field purchase order processing. I ~ 2. Procedure ESD-226 adequately describes the quality requirements for purchase specifications of the usual Pullman Power Products scope of purchased materials.. -j i e 3 Procedures KFP-6 and KFPS-5 do not require that the purchase order f state that Pullman Power Products is given the right to audit the subcontractor shop. J 4. No written procedure permits verification of the selected supplier { as one identified on the Pullman Power Products corporate-approved 4 i vendors list. j (,I m 5. There is no mechanism by which Pullman Power Products Corporate is informed of the procurement,of safety-related parts, components, L j equipment, and material to assure that the selected supplier is i 5 placed on the Corporate audit schedule. l 1 l 1 l ^} e l r* t I 's J I 9 l l '[ l e i 13 - ~., .n.-w.,

~ r" Criterion V. Instructions. Prncedures, and Drawinns l L 4 ># 1. There is no requirement.that activitics affecting quality shall be prescribed by documented instructions, procedures, and drawings. 2. Many activities affecting quality are not described in procedures. Among those-activities are: hanger package review, pre-heating for welding, use of Note-0-Grams, use of Rejection Notices, and mainte-nance of Fleid Quality inspector Daily Logs. e 3 Many activitics affecting quality' are insufficiently described in procedures. Among those activities are: Isometric package review, post-welding heat treatment, nonconformance reporting, Ninety-Day Welders' Logs and Veckly qualified-Welders Lists, and auditing. 4. The present procedures are ge'nerally inadequate for providing direction to those performing the work. The procedures do not follow the flow of the work; caany procedures are very long (over 10 pages); insufficient information is given; important information .s is not provided or referenced in the procedure. O 6 e 9 e e j ,. ~

m Criterion VI. Document Control 1. Procedures KFP-9 and KFPS-8 are adequate for field drawing control, and Procedure ESD-253 is adequate for pipe-support drawing control. 2. Procedures KFP-17 and KFPS-15 are adequate for control of the KFP and KFPS procedures and are appropriately implemented. 3. There is no procedure for control of ESD procedures. 4. There is'no procedure for control of Special quality Assurance Instructions. 5 The Puliman Power Products review of completed packages relative to hangers and pipe restraints is not detailed in a procedure, nor is ESD-254 complete as to what.Is actually done for the isometric package. ( Procedure ESD-254 does describe some aspects of " Piping System Docu-mentation Review." 'a e.ce: The Pullman Power Products '1og, Drawing Control Index (KFP-9 and KFPS-8), 6. is maintained in a nonpermanent manner. The log is. filled out in pencil; and when the number of revisions exceeds the available space, the early revisions are erased to accommodate the new revision. , No mechanism assures that the Pacific Gas anU Electric Company 7. , drawings being used as the reference drawings are the latest-issued l revision. Audits are frequently performed to determine that Pullman Power Products has the latest Pacific Gas and Electric Company draw-. Ings. However, the audit mechanism is not sa'tisfactory when it is .the only mechanism.. 8. There is no Weld Rod Requisition for one of the welders who partici-pated in FV-345 of isometric 04-500-139 n. - + -,, -.., -

1 J .4" ..,e' ,l There is evidence that documents _have been backdated and changed to 9.- racet requirements withou't any substantiation of the information. e For isometric 2-14-47: The Process Sheet was changed to show the completion of FW-192 on April.10 and April 11, 1974,_ approx- ~ .imately 19 months after the work was done. e isometric 2-14-8: FV-1673 was performed to Revision 2 of the-isometric, which did not show FW-1673. Revision 3 of the iso- ~ 0 metric, which included the FW'-1673, was generated approximately one week after completion of the weld. It is therefore concluded that FV-1673 was performed without the normal controls of a Process Sheet, a weld procedure call-out, and a call-out of NDE ~ requirements. o Isometric 2-14-53: FW-247 was' completed February 20, 1975 Approximately December 1,1975,_ the visual acceptance was signed ( ~ ' off and backdated; and the Weld Rod Requisition was changed to-show that more than the original quantity of one had been burned. e isometric 2-14-59: FW-268 was completed February 5, 1975 On December 2,1975, the entry on the Process Sheet for removal of daos was signed off and backdated. There is no proof that the dams had been removed. e Isometric 2-26-417: FV-144, -145, -196, and.-197 were completed on May 14,,1976. The Weld Rod Requisition had been altered to However, the Veld Rod Requisit on shows that 14 rods i add FW-197 had _bcen burned,-which seems improbable for the. four welds that were supposedly welded. No procedure.or requirement piohibits the changing or alteration of 10. the records and documents that arc necessary to track the work. Fictd-Process Sheets, Vcid-Rod Rcquisitions, ir.spection records, etc., .- ( e ,f-should not be changed or should be changed only-by quality Assurance g supervisory personnel and then signed and dated. 16 -

=. - - < -. s Proc'edures KFP-14, KFPS-12, ESD-239, and ESD-254 are adequate instruc- \\G 11. tions to assure that the correct documentation has been assembled and the system is ready for turnover. r- \\g C . 4';% '.t

e.

~

s-e

.,vy( ',Qa .i.'.d -- 1 ..e - ~ - t ! *.T .s.. w . g;, e e e. + s I s 1 *-- ..Z. 17 - ~.. -

- r \\ ( Criterion Vlf. Control of ' Purchised'Haterial', ' Equioment; 'and Serv' ices t 1. The interface between the Pullman Power Products Field Organization and the~ Pullman Power Products Corporate Organization relative to l selection and monitoring of suppliers'.. fulfilling field purchase requisitions is inadequate. j 2. Procedures KFP-7, KFPS-6, ESD-217, ESD-226, and ESD-261 are adequate for the per'ormance of, receiving inspection. f l t .j i i. t i l t ? y , 4; n.[ . n e, t C+

r. -

• .a-.

t. l .1 g-s l 5:* t ~ l l 4 4 9 e 18 - e

( ,g ' Criterion Vill. identification and Control'of Materials, Parts, and ' Components 1. Identification and control of pipi,ng and valves are adequately specified'by Procedures ESD-200 and ESD-201. 2. Identification and control of weld material are adequately specified by Procedures KFP-12, KFPS-li, and ESD-202. e 'l - 3. Identification and control of backing gas dams'are adequately speci-fled by Procedure ESD-214. i k 4. Procedures K7P-8 and KFPS-7 are adequate for specifying that the o }l Identification of parts and' components is to be recorded on the 1 Field Process Sheet. The implementation of this procedure is adequate. ? = ~ .-q 5. The isometric drawings and field fabrication drawi gs are the major

g. f documents for recording the Identification of the parts, spools, g

f. and components. While there is no procedural requirement, this

+

e

mechanism has been followed and is an excellent technique. FLi w. ~ g 6. Identification of welds and welders is adequately described in ,n 'I Q Procedures ESD-203, -204, -221, and -243. I eA s 7. Proper methods of marking are specified in Procedures ESD-200, -201, k -202, -203, -204 -221, -223, and -243 8. Material control technique:s for temporary pipe attachments are ade-Ijf quately described in Proceddre ESD-232. ,9 Procedure ESD-248 adequately describes controls for the repair of

• 5 "-

Installed valves and for valve parts control. 1

10. Adequate control of sn'ubbers,' plate,' and other components is achieved by using Procedures ESD-200, ESD-201, KFP-8, KFPS-7, and the practices,

y associated with field drawing preparation. However, no procedures specifically address these items. i. e

0 C ~

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

12. Procedure ESD-223 does not'give adequate instructions for the identi-fication and control of'Q1 ass i Pipe Supports.

13. Procedure E50-228 does provide adequate guidance for the marking of tools used in grinding stainless and carbon steel welds.

e h* W b 2 I.* i. /. w f 1' 1 ) 3, 'a','. h.*hl (c o.,; { r* I.+; ', ~ .de iJ g gj t g l g: v-7,; l 7':1 ,-w t 1 } f l t e t. g l s. s 20 - l t ,-,n n--

i e Criterion IX. Special Processes I. Nondestructive examination has been properly specified as a special process. Procedures KFP-3, KFPS-3, ESD-235, and ESD-256 adequately specify requirements for NDE personnel. ~ 2. The requirements for Field quality Assurance inspectors are adequately ~ specified in Procedures ESD-237 and ESD-256. 3 The qualification and certification program for.NDE and Inspection personnel has been inadequate. The records of the following person-nel were examined: D. R. Geske, T. L. Koch, J. E. Cawel ti, G. P. Keeler, K. E. Beck, L. Glass, V. R. Johnson, E. Stanton, C. B. Athay, R. G. Sears, D. S. Tutko, J. N. Shiromizu, V.' J. Casey, J. A. Brasher, L. F. Myrick. S. R. Stanley, H. Guest, D. E. Bentiey, R. D. Kincade, K. D. Guy, J. R. Bowlby, E. R. Jennings, A, L. Newton, C. C, Lenzi, J. J. Sisk, L. G. Thomas, A. A. Conques, and R. L. Marks. In vir-tually all cases, the individuals began performing their duties j e without fulfilling th'e specified requirements. The most prevalent disc.'epancies are: not completing the required t' raining, not having l[ } proof of previous experience, insufficient time as Level 1, unsigned aJ g ',; tests, and insufficient background and experience. rg U 4. NDE procedure qualification is adequately describ~ed in Procedures m{ KFP-2 and KFPS-2 as being the responsibility of the Manager of qual-Ity Assurance, Williamsport Headquarters. 5 Welding has been properly specified as a special process. 6. Welding procedure qualifications are adequately described in Proce-dure KFP-15 as being the responsibility of the Velding Engineer (Williamsport). 7 Procedures KFP-15, KFPS-13, and ESD-216 are adequate for speci fying . -.Q weider quaiifications. e

8. The certificotton of the following weiders, by weld symbol, was j) examined and found acceptable: U, AN, IH, P0, VD, QZ, HY, PD, JL, - ET, HL, AY, MO, TQ,' IQ, PG, KP, XC, FC, and ZC. 9 .The certification of elder U was not si,gned. A number of procedures provide mechanisms for control of the weld- .10. ESD-203, -204, -215, -2is, -221, -225. -227, -242, and ing process: -243 However, the con, trol of the welding process has been inade-e quate as follows: e Records of welder qualifications prior to 1972 are not available. e The Ninety-Day Velders' Log was not maintained from August 1972 to December 1972. There is no Veckly qualified-Velders List for that time period to substantiate that the welders were actually qualified. (; e The Ninety-Day Velders' Log is not suffic!cntly " detailed to determine-if the welder is qualified to perform certain proce-dures. The Ninety-Day Velders' Log has.been revised a number of times, and the detail has improved with each revision. Pre-v.lous to the latest revision (November 1974), the log was very poor in giving precise-information relative to procedure and thickness ranges to which the welder was qualified. e No proced'ure states what the Field Quality Assurance inspector r uses as the primary means to determine welder qualification, the Ninety-Day Welders' Log, the Weekly qualified-Velders List, or the Welder's Qualification Card. o No procedure specifies who is responsible for the Ninety-Day Welders' Log, the Weekly Qualified-Welders List, or the Velder's Qualification Card; how the information is obtained; how the ~ ') logs are used; to whom they are distributed; etc. -,n ,-.. -. -, -..., ~. - +

o s 's e Procedure KFPS-13 differs from KFP-15 in that it does not permit a six-month extension of welder qualifications if the welder has been act.Ively welding on some other welding process. Procedure KFPS-13 requires the welder to use the specific welding process within a three-month period or be requallfled. There is no evi-dence of adherence.to this requirement for pipe support welding. e Welder BF (W. Adair, 251) performed welding on FW-70, -72, -73, -76, -77, -78, -1008, -132, and -133 in Isom' etric package 21-7 and FW-88, -90, -91, -92, -134, -135, and -160s in isometric package 21-8. This welder was not qualified for the thickness range; and the welds wer'e reported on DRs 2535, 2538, 2539, and 2899 In'accordance with Pacific Gas and' Electric Company dis-3 position, some of the welds were radiographed and found accept-able; Welder BF was quallfled to the thickness range; and all. .j the welds in question were accepted. This disposition is not P O1 permitted by B31:1, 831.7, and ASME, Section IX, which all ' l specify that the welder must be qualified prior to making pro-4.a 5 duction welds. og t y

• e Procedure ESD-219 requires random sampling of inprocess welding,

.4 . with the sampling to be'noted on the Field Process Sheets.. In l p,j examining Field Process Sheets,.It is obvious that the sampilng l E5 by the area inspectors was not performed. f% j .3 _ F ~ e Procedure ESD-219 requires periodic auditing by the Welding l Auditor. These audits were not performed until November 5, I 1973; and Pullman Power' Products was not in compliance with this procedure for approximately 23 months. i e Procedure ESD-219 requires monitoring stainless steel welds for l ferrite control., Heweve,r, the Severin Gauges were not on site until the beginning of 1973; and Pullman Power Products was not In compliance with this procedure for approximately 12 months. l - 4 L

e Hangers are act welded in accordance with Pacific Gas and Electric Company requirements. Hangers 2023-IV and 2039-2V are two examples of a number of hangers observed that are welded to the structural steel en the wrong side of the bracket. I e The interface of welding to other suppliers' parts and compo-nents is not clear. Welding is done to Join Westinghouse and Paramount parts and components. The necessity for addressing impact property requirements for t. hose weldments is not clear; in addition, the requirements for addressing impact property requirements for Pullman Power Products field welds are not clear. If Ir.ipact properties are necessary, the acceptability of each weld that has been repaired and subjected to more than i. one stress relief is indeterminate because of the time at tem-I k perature limitations within the qualified weld procedure. g e Some welders do not receive sufficient training.' Welders, i [,. fabricating the pipe rupture restraints within the contain-

7. j ment, are welding heavy plate. While these welders are quali-1 s fled by virtue of welding heavy wall pipe, the techniques are.

b. ;f.

different'. The welders who were already qualified to heavy WJ,1 wall pipe were not given additional training.on plate. i b p' t o There is no procedure for the preheating of weld Joints. 1 e The Initial results of the welding auditing (from November 5, 7 1973, to February 1974) indicate that the following problems existed:

• The welders did not understand shielding and purging.

l

• Templi sticks were not used.

l , Amperages were not within procedure limits (mainly root 24 f 1 L

= -. m -.-. _m____. (' welds and tack welds.

• Weld procedures were not available, and many welders did not know where to obtain them.
• The oxygen analyzer, was not available or not operative.

Also, the time vs flow rate alte'rnate technique was not used.

• Oven rod temperature con' trol was not monitored by the welders..
• Many welders did not understand their duties and responsi-bilities.

Based on a review of the Pullman Power Products weldi'ng audit i reports and the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974 f was performed in 'accordance with welding specification require-

n" 5.

~ V f 1 ments. -;pj 9 11. Welding procedures for carbon steel welding require preheat and inter-n,a ] pass temperatures for material that has a carbon content in excess fj.$ - of 0 30 percent and a thickness of one inch or more. There is no TU mechanism by which the welder can determine carbon centent, yu c1 E 12. Procedure ESD-221 does provide adequate guidance on weld repairs. 13 Heat treating has been identifled as a special process in the Pacific Gas and Electric Company contract (cs well as in Appendix B), but it has not been controlled as a special p'rocess by Pullman Power Products. 14. Procedures KFP-13 and ESD-218 provide controls of the post-weld heat .he impi,ementation of Precedure ESD-218 is T treatment process. acceptable. 15. cleaning has not been identified as a special' process.

= . 1 f' I (L,p 16. Procedures ESD-220, -224, -238, -242, -252, -258, -259, and -261 ~ provide adequate guidance in cleani.ng and cleanliness of the various l materials, parts, and components. 17 P'rocedure ESD-231 provid'es some guidance on hot and cold bending l of small bore piping. The guidance is considered insufficient to assure that the' bending is done properl to avoid high stresses and I thinning of the wall. 18. Precedure ESD-238 provides 'dequate instruction in torquing of a c i l bolting for pipe flanges. 1 l I ( l 19 Procedure ESD-259 provides adequate instruction for installing Grinnell Snubbers. i 1 20. Procedure ESD-224 provides excellent instruction for assembly and torquing of Installed valves. c { 21. Procedure ESD-260 pr'ovides adequate instruction for installation l of Williams P.ock Bolts. i 22. Procedure ESD-230.provides good. instruct,lons for entering an in-stalled line. - r-( I i e D e m

4 k( Criterion X. Inspection x. 1. Procedures KFP-5, -8, and -14 thoroughly describe the interface between Pullman. Power Products and the. Authorized Inspector. 2. Pr'ocedures KFP-8 and KFPS-7 provide the requirements for the Field Process Sheet, which specifies inspection points and inspector sign-off. [ 3 The Field Process Sheet references procedures to which the work and the inspections w!!! be performed. l 4. The inspection procedures are detailed in Procedures ESD-206, -207, -208,--209, -210, -211, -215 -219, -225, -233, -234. -236, -241, -243, -244, -249, -250, -251, -255, -259, and -260. These procedures are, in general, broad descriptions.of the inspection process for l the total range of the work. scope and are adequate for that purpose. l 5. For all Inspection processes, there is no mechanism to provide the ~ i inspector the particular characteristic to be inspected; the partic-ular acceptance criteria; the particular' methods and equipment to be used; and, provisions, for recording results, other than ac:eptance for the particular Inspection.being made. ;The exceptions to this statement are ra.diography, where the reader sheet allows the recording I of results, and those procedures that specify the use of particular equipment _ (such as some of the ultrasonic procedures). The inspection process is generally not auditabl.e. The practice of 6 exhibiting an acceptance, signature only doesanot permit auditing to. determine if the Individual character!stics were examined, the corrc a criteria were used for acceptance, and the correct specific measuring devices were used. 7 A large number of welds in Unit 2, System 14 (FW-110 -111, and -112 in isometric package 2-14-31 are examples) were accepted for l '

visual examinntion and thereafter accepted based on surface NDE inspection (MT or PT). yisual examination of'those welds indicates that the surface is not suitable for the performance of surface NDE Inspection. For FV-Il0 (isometric package 2-14-31), the Proces's Sheet Indicates 8. ' that MT was performed; however, the inspection sheet for PT shows -that weld' number, and the inspection sheet for MT does not show that weld number. FV-83 (Isometric package 1-10-9) was repaired in accordance with 9.. The radiograph of FW-83 does not exhibit a valid Process Sheet. the required,R1 symbol, but R1 was Inked onto the radiograph. There is a surface defect that is questionable for acceptance to visual standards. Isometric package 1-03-1 has a step that requires a Pullman Power 10. ~ Products inspec~ tor sign-of f. This requirement was removed, and the step was accepted by a Pacific Gas and Electric Company employee. 1 I I i

CrIEerionXI. Test Control 1. Procedure E50-229 adequately defines the methods and inspections relative to perform.Ing hydrostatic tests. 2. T'here is no description of the responsibilities of Pacific Gas and Electric Company or of the Pul.lman Power Products / Pacific Gas and Electric Company interface relative to hydrostatic testing. 3 Procedure ESD-229 is not adequate for describing the flow and authorities relative to the Individual hydrostatic test procedures to be performed. 4. Hydr'os,tatic test' packages 7-2, 7-2A, 8-12, 9-12, 106, 106A, 1068, and 64 were examined and found acceptable. 5. The B31.l and 831.7 Codes require that all piping be leak-tested, (%dM where practicable. Pullman Power Products is only leak-testing Class A and B piping and that Class C piping specified by Pacific Gas and Electric Company. Classes D, E special, and E piping is not being leak-tested. A le'tter from Pacific Gas and Electric se,-- Compahy l(datei aWuary13,.1970) does exist, which states that l Pacific Gas ind E1Ectrii Company will assume responsibility-for ~ ' ~ the leak-testing o'f' Cla(s;s:.C piping. in t.worde - :: There is concern that Pu11 man' Power P66du' cts':4st' ot ifFsch'arging its contractual obligations n (that specify compliance to B31.1 and 831.7) by not performing FIND 1N.1 ' piping Tiak-testins to' Code requirements for Classes ~ C, D, E special, V^and,Epih..u,.-n'g', s'ysums' and, as a result, may be legally vulnerable.

• • • !$~

= s... e e ~ - .r

t . ~ _.. _. . ~. _. -... _ ~., ..n C Criterion XII. Measuring and Test Equipment 1. Procedures KFP-11, KFPS-10, and ESD-213 describe an adequate cali-bration program. 2. The calibration program did not. require recalibration of thermo-couples until June 16, 1976. Therefore, there is no assurance of the accuracy of thermocouples used for pre-and post-welding heat treatment prior to June 16, 1976. Newly purchased thermocouples were required to be calibrated by the manufacturer. However, the manufacturer's calibration does not assure that the thermocouples have not been damaged during handling and shipping. 3 The calibration program has not been adequately implemented. e Paragraph 11.5 of Procedure KFP-II.and Paragraph 10.5 of Pro-cedure KFPS-10 require reinspection of materials and, components If the measuring and test equipment is found,to be out-of-cali-( b ra t !'on'.' Except for hyd'rostatic testing and heat treat'ing, the g Identity of measuring and test equipment,;l:s,no,t related to the inspections performed. .......c,..,

t :- r::. :.::

t-vt. 7 -

e. Procedure ESD-213 does not contain a:m,echa,ni;sm,po. report,out,c.

~ t {,. of-calibration measuring an.d. test. equipment.tp..Pu-11 man.P.ower -.! ? Products. Some forms used by.th.e ca1.Iprat.!pn, spbcontractor;s... h: g - only contain provisions. for%at. testing.$or.ca;1ri, brat,Ing the equ_ip-W ment to appropriate standard.s and hav.e po.prpy4s,lons for record-Ing the actual values obtained.- h n.c..~:. . 7 :e..: :- e The calibration records of. recor,ders we.r.e.confqsed by;. having two ' recorders identified on one record,.and the.ac.ce.ptability of, the records could not be determined.. r. e Severin Gauges 2947 and 2971 were received on the site in January 1973 Initial calibration was hugust 29, 1973; and the next calibration was November 19,1974, for. gauge 2947 and January 23, - ~.....,.

m e a .i I 1975, ror ga'uge 2971. -Procedure Eso-213 requires annual calibration. e Magnetic. Particle Test' Equipment Y-6 has no documentation to -verify-calibration. ~ e There is no documentation available to verify calibration of " Tong Test" ampmeters. . " Tong Test" ampmeter TT2527403 was out of calibration for the. period _ December 12, 1976, to January 31, 1977.. No DR has been written against that instrument. . Storage requirements for instruments are not specified. k 1

~ 0 l B Cri terion X1 t l. Handling. Storanc. and Chipning l. Procedures ESD-202, -215, -217, -222, -223, -240, -259, and -261 provide some information rclative to handling and storage of mate-rials, parts, and components for the total' scope of the Pullman P'ower Produ' ts ef'for t'. c , 2. Procedures for storage are general 1y inadequate. Procedures ESD-222, " Control Valves," and ESD-202, " Weld Material Withdrawal and Control," e are specific and adequate. Procedure ESD-215, " Visual Inspection," provides some guidance on storage. There is very little information relative to how specific items are to be stored or the delineation I of storage areas relative to the protection each area provides. 3 Procedure ESD-240 requires a segregated storage area for " scrap" material,and Procedure ESD-215 requires separate areas for material with Hold Tags and for P1 and P8 material separation. These proce-(. dures are adequate. However, they do not relay much information on h6w these segregated areas are to be established and maintained segregated. 4. There' are no procedures or manufacturers' instructions for the storage of flow Indicators and s^ trainers, which were stored in the Pullman Power Products storage area. 5 Handling procedures do not exist; and the only handling instructions are contained in ESD-222 and a number of other procedures, which con-tain a caution against the use of carbon steel in handling stainless steel. Procedurc ESD-239 has excellent detail as to the handling of Crinnell Snubbers during installation. However, Procedure ESD-259 was issued January 27, 1977; and there is no assurance that materials, parts, and components were properly ' handled during the period prior to January 27, 1977, when most of the-installation activitics were occurring. (2: - .g.

6.[ The present storage areas were found to be in excellent condition, with areas clearly defined, materials supported on' adequate dunnage, and openings capped. 7 Procedures KFP-19, KFPS-17, and ESD-222 provide for an adequate storage surveillance program. Prior to October 31, 1973, the sur-veillance was performed using a checksheet that contained the stor-age requirements; af ter October 31, 1973, the checksheet was changed so that the storage requirements were not listed. While the sur-veillance program appears adeouate, the checksheet used after October 31, 1973,' does not appear adequate. i l t h b}. l '. r,. T t.., r. r - L'.:.; Q.. ] .k^d '!5*.k?.01'..*

6. l

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\\

e Criterion XIV.

Insp'ection, Test, and Operating Status 1. The major mechanism that exhibits the status of the work is the Field Process Sheet. The Field Process Sheet provides for.perfor-mance status of some important fabrication steps and for inspection Howeve[, many important fabricati.:n steps are not Indicated status. by the Field Process Slieet: erection steps; cleaning prior to in-stallation of Insulation; and some critical welding steps as pre-e ntent in the heating, checking gas flows, and checking for 02 backing gas. The Field Process Sheet, as a mechanism to exhibit status, is considered inadequate. The inadequacy of the Field Proc- ~ ess Sheet is considered a major weakness in the Pullman Power Products h,

• system.

I' 2. The Hold Tag mechanism described in Procedure ESD-240 is an accept-able method of exhibiting status when a defective or discrepant [.. .1 condition is noted. ( ';' ?} 3 The method of using the Field Process Sheet, the Hold Tag, and the ,y N,3 Discrepancy Report is an acceptable mechanism to track the status [:j of a discrepent condition and the final disposition of that condi-s a D tion. However, the mechanism is not always utilized. e DMR-604, dated Febi uary 14, 1973, for Isometric package 1-03-1 b required rework and reinspection of 14. Class B welds. There b.e - Q p are no Field Process Sheets or inspection Reports to demonstrate V-that the work had been performed. i t ::. .);

s. y.

ar. e The Fleid Process Sheet for FW-347 states that the weld was cut out in accordance with a specified DR. The referenced DR is not appilcable to cutting out FW-347 4. The method of indicating repair welds, as described in Procedures ESD-203 and -204, and the notation of repair welding on the Fleid Process Sheet are acceptable for showing repair status. However, FV-83 (Isometric Package 1-10-9) and FV-348 (Isometric Package 04-500-AV

.m..- m.

m...

./ g

1. 139) were not stamped "R" to indicate repair.

5 Procedures KFP-8 and ESD-239 do present some'information relative to the release of the systems for hydrostatic testing. Procedure ESD-229 does contain a method of indicatincJ hydrostatic test status. These mechanisms are acceptable. Procedure ESD-229 should reference Procedure ESD-23'9 and require that the release be confirmed prior to Initiation of the testing. 9 6. Paragraph.8.12 of Procedure KFP-8 requires that the Fleid Process Sheet be maintained in the area where the line is being Installed. This requirement has been interpreted as having the Field Process Sheet in the area inspectors' station and not as being available ( *'s to the foremen an'd the people performing the work while the work r

f. ' e.

~1 is in progress. This practice causes the Field Process Sheet to .;i become an inspection sign-off record, rather than a traveler that ( 1 713 u 9' presents necessary information to all individuals involved in the h performance of the work. 4-k r.% cd.. 7 Paragraph 7 2 of Procedur'e KFPS-7 requires that the foreman or pipe-5, ..j fitter procure.a' drawing and Process Sheet prior to starting work S$ and check off' operations as completed. There was no evidence that t ri:g/ this practice (which is in conflict with KFP-8) is observed. -n .; :;jf.0..l4 ' f. i.i W - i. ~ > { is ,t "iyr. ~ -' Ql *,. h = JWy .t - m . w.... w

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m.: _.._ Criterion XV. Nonconforming Materials, Parts, or Components -f3 1. Procedures KFP-10, KFPS-9, and ESD-240 describe a'n adequate system of identifying nonconformances. 2. Procedure ESD-240 does not adequately describe the actual process by which Nonconformance and Discrepancy Reports are processed. l 3 The Pullman Power Products / Pacific Gas and Electric Company inter-face relative to Discrepancy Reports is not described. J 4. Procedure ESD-240 does contain adequate.information relative to disposition and close-out (use of logs) for Nonconformance and \\ Discrepancy Reports. f 5. Systems that circumvent.the nonconformance system have been estab-r a .; M lished. Use of Note.0-Grams and Rejection Notices to denote dis-3 crepancies usually precludes their pick-up on a subsequent NR or DR. h The use of these alternate' systems removes the controls and reviews L-d that have been integrated into the NR and DR system and also pre-E! vents information relative to the number'and types of problems from Lw} being identified. 'These alternate systems are unacceptable. '.r [-g , -.;r?.U M.' # '.,. r. j

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=.. (F s Crlferion XVI. Corrective Action I. Procedures KFP-10, KFPS-9, and ESD-240 describe a' corrective action system. 'The corrective action system is inadequate in that it does not require: ~ o Categorization of reported discrepancies to permit eva'luation and tracking. e Documentation of all discrepancies. e inclusion of documented discrepancies in the NR and DR system, i.e., discrepancies reported in Hote-0-Grams are not subsequently written as a NR or DR. I' e Tracking of discrepancies to determine which discrepancies are o [ recurring.. f', C.99* e Analysis of discrepancies to determine programmatic probteras. O e Reporting of significant conditions adverse to quality and the i y, % L;;; , corrective actions taken to appropriate levels of management. '~:% -...:.11 s:.u. .j Based on the results of this,. audit and the problems encountered in -...n. j gf 2, f.X .the past, it appears t..at,a corrective action system has not' been >.4 a.ria.... i

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.s-Criterion XVII. Qua]Ity Assurance Records 1. Procedures KFP-16 and KFPS-14 and most of the ESD procedures adequately identify the records t'o be retained. l ~ 2. Procedures KFP-14 and KFPS-12 p'rovide adequate guldance an'd mechanisms to a::sure collection of most records. Records that are not specified in these two procedures (e.g., records on heat treatment, torquing, pipe rupture restraints) do not have'any documented mechanisms for l l collection, but are adequately assembled and retained. e 3 There are no procedures for filing, storing, and protecting records, i.e., no requirements for the vault, no method on how records oth,er,., than isometric packages are ' identified, no Iristructions on how records l are to be stored. However, the practices employed do provide for i adequate identification, retrieval, and fire protection. i l ( f. I \\ 4. Procedure ESD-212 does adequately describe a security system that provides "out" cards for identification of the record and the indi-pl vidua'l using the record and for the overall security of the records N within the vaul't c.t l 1 ~. i. A.L C:.a.:.

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A F f Criterion XVill. Audits ^ 1. Procedures KFP-18, 21; Procedures KFPS-16, -17, -18; and Procedures ESD-219 and -222 describe an adequate audit program. 2. The audit program does not require the use of checksheets or pro-cedures to delineate the scope and extent of the audit, nor does it require that the audit team leader be qualified. 3 In response to KFP-18, Paragraph 18.2.1, management audits were performed approximate.ly every six months. Checksheets were employed. Based on the results of this audit and the results of Pacific Gas l and Electric Company audits. these management audits appear to have been ineffectual. i l ( 4. Procedure KFPS-16 does not require management' audits. 1 4 5 In response to KFP-18 and KFP'S-16, internal audits were performed g every six months. Checksheets were not employed. ,b4

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There are no pr_ocedures for audit reports, audit responses, and time-l j m i r. e. limitations on responses. hj - .3Ner.c c pg 7 . Procedures KFP-18 and KFPS-16 require that a copy of the audit report P.I .betransmittedtSthiManagerofQualityAssurance. i i t: q - c;. 8,

There are no requirements that the Manager of Quality Assurance

. track the audit reports or take any corrective actions when program-i matic or recurring deficiencies are noted. l 9 There are no requiraments for periodic. Independent, internal audits of the total quality program. 10. One independent internal audit was performed in January 1976. 1 ( i I -

( V. EXIT INTERVIEW G The exit interview was conducted on September 20, 1977, at the Pullman Power Products offices at Diablo Canyon. In attendance at the exit Interview were: Jack Bowes Pullman Power Products Vice President, Production Ed Gerwin Pullman Power Products. General Manager quality Assurance John Ryan Pullman Power Products Resident Construction Manager Pete Runyan Pullman Power Products Field quality Assur-ance Manager Chris Scannell Pullman Power Products Chief Field Engineer Al Eck Pullman Power Products quality Engineer, Central Staff John Mitchell Pullman Power Products Consultant Sherman Naymark Nuclear Services Corporation President f d Jack Weber Nuclear Services Corporation Audit Team Leader L.: s I'.'i Bill Rowe Nuclear Services Corporation Auditor Ld 'mc ^ [4 Gerry Larsen . Nuclear Services Corporation Auditor f ' ' ' ; #- ', 1 (,q,:, The exit interview was initiated by Mr. Weber's summarizing of the purpose and scope of the audit, the basis against which the Pullman Power Products effort was measured, and the purpose of the exit interview. Additionally, a discussion was held on the fundamentals of auditing, i.e., an audit is a sampling technique, that enough samples are taken from each program or system to draw a conclusion, and that the conclusion is then applied to the adequacy of that program or system. Each audit finding was presented,.and discussions were held to clarify 'or refute the findings. Some findings were modified, based on additional evidence presented by Pullman Power Products..Upon completion of the

VI.

SUMMARY

The Pullman Power Products Diablo Canyon effort has extended from 1971 to the present. The findings Indicate that there w'ere three distinct periods as related to the quality of the work. These findings are: e Prior to early 1974, there is l'Ittle ividence available to verify the adequacy of the work performed. The avr.Ilable evidence indicates that only a rudimentary quality control. program existed and that con-trol over the production organization was minimal. e From early 1974 to late 1974, there is evidence available to verify the adequacy of the work performed. The available evidence indicates that control was achieved of the materials control program and the . welding. control program. e From late 1974 to the present, an increasing amount of documentation and records has been generated to verify the adequacy of the work performed. The available evidence demonstrates'that an increasingly (d

s. ore stringent quality program has been placed into effect and in-creasingly greater control of the work effort has' been achieved.

C However, the present program and controls still do net meet 10 CFR 50, ,,{ Appendix B requirements in those areas as delineated in Section IV of j ,the. audit report.-

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