ML20078A508

Affidavit of RP Wischow Delineating Util & Pullman Actions Which Demonstrate Util QA Program Responsive to Applicable NRC Quality Requirements & That Pullman Had Effective Quality Program

ML20078A508
Person / Time
Site:	Diablo Canyon
Issue date:	09/21/1983
From:	Wischow R PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML20078A499	List: ML20078A496 ML20078A508
References
ISSUANCES-OL, NUDOCS 8309230295
Download: ML20078A508 (146)

Text

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 SEP 22 All:03 2 gr.rre .:. _

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. Before The Atomic Safety And Licensing AppealIBoardCl'g.,',,, . ,

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In the Matter of Pacific Gas ) Docket Nos. 50-275 O.L.

7 and Electric Company (Diablo ) 50-323 0.L.

Canyon Nuclear Power Plant, ) (Construction Quality 8 Units No. 1 and 2) ) Assurance)

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9 10 11 AFFIDAVIT OF RUSSELL P. WISCHOW 12 '

13 14 I, Russell P. Wischow, being duly sworn depose and 15 state as follows:

16 1. I am currently employed by Pacific Gas and 17 Electric Company, 77 Beale Street, San Francisco, 18 California; my title is Manager, Geysers P1 ject. During 19 the period from September 1, 1976 through January 31, 1978, 20 I was Director, Quality Assurance Department. A copy of my 21 professional qualifications is attached ( Attachment 1) . I 22 have read the Joint Intervenors' Supplement dated 23 September 9, 1983, and have the following comments.

24 2. In July 1977 PGandE requested Pullman Power 25 Products Corporation (Pullman) to have an independent audit 26 performed of the work Pullman had done at Diablo Canyon with 8309230295 830921 PDR ADOCK 05000275 O PDR s

1 particular attention to the adequacy of installed hardware.

2 Pullman is the principal piping contractor for Diablo Canyon 3 Units 1 and 2. Pullman was issued American Society of 4 Mechanical Engineers (ASME) Certificates of Authorization 5 (NPT and NA) in December 1972 which were renewed on 6 October 14, 1977 (Attachment 2). Pullman contracted with 7 NSC to have the audit done and PGandE concurred in that 8 selection. The audit was performed by NSC from August 22 9 through September 20, 1977 and the Report submitted to 10 Pullman by letter dated October 24,1977. ( Attachment 3. )

11 3. I testified at the October 1977 hearings in 12 San Luis Obispo as to the adequacy and content of the PGandE 13 QA program, procedures, policies, audits, and implementation 14 thereof. The NSC audit was not complete at that time and no 15 definitive results were provided for us to review and 16 evaluate prior to early 1978.

17 4. After receipt of the NSC audit report Pullman 18 conducted an internal review of the Report during the period 19 October 1977 through January 1978. Pullman determined that 20 the NSC had directed the audit primarily toward a review of 21 program, procedures and policies rather than to concentrate 22 .on the adequacy of the installed hardware as was intended by l

23 PGandE. Pullman also concluded that NSC performed the audit 24 of the 1971-77 Pullman QA program against the 1977 NRC 25 regulations and interpretive guidelines rather than against 26 the regulations and interpretive guidelines that were l

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1 applicable at the time that the work was done. Furthermore, 2 to some extent, the audit was also performed and evaluated 3 against NSC internal guidelines and opinions rather than 4 what was actually reqdired by the regulations, guidelines, 5 and applicable codes.

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5. In mid-February 1978, Pullman provided PGandE 7 with a draft of its review together with a copy of the NSC 8 report. Pullman formally forwarded its response and the NSC 9 Audit Report to PGandE on April 11, 1978. (Attachment 4.) ,

10 PGandE reviewed these documents in February-March 1978 and 11 held discussions with Pullman concerning the findings.

s 12 PGandE agreed that the NSC audit was misdirected in that the 13 hardware installed by Pullman had not been audited by NSC as 14 was intended. We concurred with Pullman that many of the 15 NSC opinions were not consistent with the QA requirements at 16 the time that the work was done and, in some instances, the 17 opinions were inconsistent with the then-current 1977 18 regulations and requirements. Regardless of this 19 misunderstanding, we required appropriate corrective actions 20 to be taken on the results of this audit in accordance with 21 the then current PGandE Corporate QA Program.

I 22 6. Furthermore, I established a special review 23 team, reporting directly to me, to review and evaluate the 24 NSC audit report and to perform an audit of what NSC was 25 supposed to have done; i.e., audit the Pullman physical work 26 at Diablo Canyon. This audit was specifically designed to:

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• Determine if the Pullman QA program met the 2 requirements cf the applicable regulations, codes and 3 standards at the time that the work was done; 4

• Determine if the NSC findings were valid; and 5

• Verify if the components and supports installed by 6 Pullman conformed to applicable specifications, 7 drawings, and quality standards.

8 7. The PGandE audit was conducted from April 2 9 through June 1, 1978 and a summary report submitted to Mr.

10 J. D. Worthington, Executive Vice President and the 11 applicable departments on June 13, 1978. In the cover 12 letter of this audit report, I concluded that the Pullman 13 Program met applicable requirements. (Attachment 5.} A 14 separate report which reviewed. the NSC audit findings in 15 detail was submitted to Mr. R. S. Bain, Manager, Station 16 Construction, on June 16, 1978. (Attachment 6.)

17 8. Corrective actions as a result of the PGandE 18 audit and revitw were identified as either Non-Conformance 19 Reports (NCR) or as Minor Variation Reports (MVR). The 20 PGandE QA department, through continuing on-site 21 surveillance efforts, assured that identified corrective 22 actions were tr. ken, results were evaluated and the 23 deficiencies or non-conformances were closed out in 24 accordance with the PGandE QA Program. (Attachment 7.)

25 9. This documentation was available both on site 26 and in the General Office for NRC inspection. An NRC

1 inspection was made during the time period after the audit 2 results were reported and :hile corrective actions were 3 being taken by PGandE and Pullman. (Attachment 8.)

4 10. The foregoing actions taken by both Pullman 5 and PGandE forcefully demonstrate that the PGandE QA program 6 was responsive to the applicable NRC quality requirements 7 and that Pullman had an effective quality program.

8 Deficiencies were identified and corrective actions were 9 taken in a prudent, prompt manner consistent with good 10 quality practices.

11 11. Attachments 2 through 8 to this affidavit are 12 true and correct copies of documents in official PGandE 13 files. ,

14 15 Dated: September 21, 1983 16 17 7

/ a*c4m 18 ' RUSSELL P. WISCHOW '

19 Subscribed and sworn to before me 20 this 21st day of September, 1983 ymmmumimmmmmumummuumume

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MC SAN FRANCISCO C. T. NEAL-MADISON nunummunu/umuuummununumumuis ornminior. Expires Dec 27,1985 g Notary Public in and for the 24 City and County of San Francisco, State of California.

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Professional Qualifications j

. of Russell P. Wischow l

Education .

Ph.D Chemistry, Vanderbilt University 1958 M.S. Chemistry, North Dakota State University 1952 B.S. Chemistry, North Dakota State University 1951 Registration Professional Engineer, Quality Engineering, State of California Professional Societie_s American Chemical Society Fellow, American Institute of Chemists Sigma Xi Project Management Institute Professional Experience September 1976 - Present

( Pacific Gas and Electric Company Director, Quality Assurance 9/76 - 11/78 Geysers Project Manager 12/78 present April 1970 - September 1976:

President, Nuclear Audit and Testing Company and Vice President, E. R. Johnson Associates, Inc., Washington, D.C.

! September 1967 - April 1970:

Director, Division of Nuclear Materials Safeguards, U. S. Atomic Energy l Commission, Washington, D.C.

! October 1965 - September 1967:

Assistant General Manager, Nuclear Fuel Services, Inc. , Washington, D.C.

April 1963 - October 1965:

1 Supervisor, Chemistry Department, Martin Company, Baltimore, Maryland 1

l June 1952 - April 1963:

l Senior Research Chemist, Callery Chemical Company Company l Group Leader, Union Carbide Nuclear Company Summa ry Over thirty years experience. Management positions were in regulatory, i government, research and development, chemical process, design, l construction, plant operations, and project management activities.

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Cert # ate of Authwizatim ;I' Number N . 592 2

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1 H.W. E N CO. DIV. OF PULLMAN, INC,

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Pacific Gu and Electric Co. Nuclear Station, Diablo Canyon, Cal. ,if f

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symbol of The American Society of Mechanical Eagineers for l ',

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Classes 1, 2, 3 4 HC Field Fabrication of l

' ' Nuclear Parts, Appurtenances, and Piping

,Subassevblies, 72 inches , maxie.na diameter, at Diablo Canyon site, Units 1 4 2 cnly.

' un accordance with the applicable rules of the boiler and Pressure T;

Yessel Code of The American Society of Mechanical Engineers.

y' The use of the Code symbol and the arbority granted by thh I

certificate of anthorizelion are subject to the frovs'sions of 164 ,

a sgreement set forth in the application. Any construction stamped V

with this symbol shall have been built strictly in accordance with 4

i the provinons of the Boiler ad Pressure Yessel Code of The g o

h American Society of Mechanical Engineers.

V THIS AUTHORl2ATION expires on Co918 tion of Contrac_t g i

Authorized on O'* C t th* T 18' 1912 for d THE AMERICAN SOCIETY OF MECHANICiI. ENGINEERS j hy the BOfLER AND PRESSURE YESSEL COMMTITEE ,

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THIS AUTHORIZATION expiret on Coesleti a mf Ce e ~ t }

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by she BOIIER AND PRESSURE VESSEL COMMITTEE i

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THIS IS TO CERTIFY thae THE M. W. ELLOGC Cot @ANYr ' l l

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.j THIS AUTHORIZATION expires on OCTOBER 14, 1980 ]

AEthorized. on DEC M ER 18, 1972 fpf

, H EEWED: OCTOBER 14, 1977 "

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THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS j p( 67the BOILER AND PRJSSURE VESSEL COMMITTEE l '

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h;} FIELD FABRICATION CLASS 1, 2, 3 6 HC CmPONENT PARTS & Q lh APPURTENANCES AND u S 1, 2 & 3 PIPING SUBASSEMBLIES AT { l l' f3 THE DIABLO CANYON NUCLEAR POWER STATIOti, Utf1TS fl & $2; i (

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THIS AUTHORIZATION expires on _ OCMER 14,19E,0 m

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Authorized on DLEMBER 18,_ 1972 9 for 4 I P '

RE NEWED: OCTOBE R 14, 1977 THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS hy the BOILER AND PRESSURE VESSEL COMMITTEE ) j H d

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TWF,91oS94141s October 24, 1977 NSC-QAS-KEL-003 JW-77-072 Mr. Edward F. Carwin Chief Engineer / Quality Assuranee Manager Pu11can Power Products Post Office Box 1007 Willia = sport, Pennsylvania 17701 ,

Subject:

Audit Report of Diablo Canven Effort

Dear Mr. Gerwin:

The audit, conducted under your cognizance, of the Diablo Canyon work ef-fort has been completed and is documented in the attached audit report.

Section VI, "Sunmary," of the audit report contains the audit team's over-all evaluation and conclusions concerning the work performed at Disblo

[' Canyon. To facilitate corrective actions, as much detail and as many

( 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 informatien to confirm the disposition of the audit findings by Pullman Power Products and eventually by Pacific Cas and Electric Co=pany will be transmitted to me. As.we discussed, a copy of the letter transmitting the audit report from Pullman Power Products to Pacific Cas 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 connit to requesting that Pacific Gas and Electric Company send me a copy of any official corzunications con-cerning their actions relative to the audit. I trust that you have been able to obtain Pacific Gas and Electric Company's. concurrence.

In behalf of the audit team, I would like to express my appreciation to all the Pullman Power Products personnel for~their cooperation and to you for your personal attention and involvemet.c in the audit.

Very truly yours, ack Weber G( (4)(br

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Audit Team Leader Attachment

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1 AUDIT REPORT PULLMAN POWER PRODUCTS WORK SCOPE AT THE .

o DIABLO CANYON SITE August 22 through September 20, 1977 l

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l. INTRODUCTION

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A. Audit Scope 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 Olabio 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.

l The scope of the audit included the following:

(1) The organizational arrangement and the independence of the quality organization.

(2) The qualifications and certifications of personnel performing the work.

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(3) The Quality Assurance Program, including the procedures and instructions by which the work is accompIlshed.

L (4) The implementation of the Quality As'surance Program.

(5) The systems by which deficiencies are found, reported, tracked, and corrected.

(6) The records and documentation system. ~

(7) The workmanship of the field-fabricated and Installed items.

(8) The status, adequacy, and effectiveness of receiving inspection, warehousing, installatio'n, wclding, heat treating, NDE, instalia-tion inspection, testing, and records functions for installed

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and erected piping, fleid-fabricated piping (;E 2-inch diameter),

pipirig 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 sampling those systems or programs

! until a conclusion could be reached concerning the adequacy or in-adequacy of that system or program.

The Pullman Power Products effort at Diablo Canyon was initiated in 1971, based on the contractual agreement of May 1970 between Pullman Power Products and Pacific Gas and Electric Company.

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

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audit 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 performed. When requirements are issued, there is always some room for interpretations concerning what is an acceptable method of satisfying these requirements. During the 1971 i to 1974 time period, a number of ANSI standards were promulgated to define acceptable methods of satisfying 10 CFR 50, Appendix 8. It Is required that organizations revise their quality programs to sat-l isfy present interpretations. In areas requiring Interpretation, the quality of the work effort at Diablo Canyon was measured against the current ANSI standards and Regulatory Culdes, accepted today as valid interpretations of regulatory requirements. The long time span and the specific time Interval during which the work effort was conducted

! should be considered when reading this audit report.

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- 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 111. " Entrance Interview";

Section IV, " Audit Findings";Section V, " Exit Intervied'; and Section VI, " Summary." Corrective actions will be determined by the appropriate Pullman Power Products personnel upon receipt and review of this audit report.

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b II. AUDIT PRE'PARATION A series of meetings were held in which the following tentatife schedule was established:

o Preparation of checksheets .

e Receipt and review of Pullman Power Products Quality Program documents and contractual commitments to Pacific Gas and Electric Company o Finalization of checksheets e Entrance interview e Audit of Organization, Personnel Qualif! cation and Certification Program, Document Control, Nonconformance Program, Auditing Program o Feedwater Systems, Unit I and Unit 2 (f e Main Steam System, Unit 1 e Chemical and Volume Control System, Unit 2 e Residual Heat Removal System, Unit i .

e Safety inspection System, Unit 1 e Containment Spray System, Unit 1 e Component Cooling Water 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.

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'( lit. ENTRANCE INTERVIEW

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An entrance interview was held August 16, 1977, et the Diablo 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 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 Fleid quality Assurance Manager John Ryan Pullman Power Products Resident Construction Manager

'f Mike Tressler Pacific Gas & Electric Co.

Station Superintendent Jack Weber Nuclear Services Corporation Audit Team Leader j 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 11 above.

Mr. J. P. Runyan, Field Quality Assurance Kanager, Pullman Power Products, and his staff were designated as the audit team contacts.

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( IV. AUDIT FINDINGS The audit findings are divided into the 18 sections consistent with ,

10 CFR 50, Appendix B. The audit findings are given to present the status of the program and, therefore, include both the acceptable and unacceptable areas detected during the audit.

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7 I Criterion I. Organization

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1. A current organizational chart does exist. . ,

2. Procedures KFP-1 and KFPS-1 do describe the quality organization, as well as some of the functional responsibilities of the quality organization.

3 The Field Quality Assarance Organization has performcd functions other than those described in KFP-1 and KFPS-1; and some functions were outside the quality responsibility, i.e., writing an,d approving .

Engineering Specifications, performing welding engineering functions, approving engineering changes. These activities raise the question i of the qealification of quality Assurance personnel to perform these functions and the problem of requiring the Field Quality Assurance l

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 Fleid Engineering Organization. The responsib!Ilties of the other Field Construction Organizations are not described, nor are the full responsibilities of the Field Engineering Organization described.

S. The descr.iptions of Individual position responsibilities are in-l adequate. Some elements of position descriptions exist in the KFP and rFPS procedures, and job descriptions exist for inspection and inspection technician positions. No position descriptions exist for any of the upper-level site personnel.

6. The description and controls of the interfaelal relationship between Pullman Power Products and Pacific Gas and Electric Company are inadequate. The contract and some Engineering Specifications do 4

describe some interfaces and mechanisms. However, for the greatest scope of the work effort, there is little to describe how the inter-

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• face will be managed and controlled. Some of the activities that g

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~, require Interface control are hydrostatic testing, nonconformance reporting, meetings, work on pipe rupture restraints, wcIrk on -

hangers, document control, reporting of deficiencies, responses to Pacific Gas and Electric Company audits, Interfaces with other ,

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Pacific Gas and Electric Company contractors that impact Pullman Power Products work, etc.

7. The description and the controls of the Interfacial relationship i between Pullman Power Products Field Organization and the other Pullman Power Products organizations involved in the Diablo Canyon effort are in&dequate. 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 y 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 Manager is not described; the interface between Field quality Assurance and Corporate Quality Assurance is not described with respect to fleid purchases and Corporate quality Assurance auditing of those suppliers.

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 Manual 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 1sometric, hangers, and restraint document packages; welders logs; and control of the weld-Ing process are not described.

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!( 9 The stop work authority for the Fleid Quality Assurance Organization is not adequate. Procedure ESD-240 does describe' the stop work ,

authority for Hold Tags, but there are no mechanisms described or authority addressed for the circumstances when the Construction O'rganization elects to proceed through'a Hold Tag stop.

10. The Field Quality Assurance Organization does report to a sufficiently high level of management.

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d I Criterion 11. Program

1. The contract between Pullman Power Products and P'acific 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 vere requirements for the Pullman Power Prodacts wrk effort. Work was not initiated on the Diablo Canyon site until late 1971, when Appendix B had become a requirement [ Appendix B was added to 10 CFR 50 on June 17, 1970, effective July 27, 197J (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 ANSI 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 the findings.

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2. There is no description of the overall quality Assurance Program.

1 Special Quality Assurance instructions s're not described; the rela-

' tionship and purposes of the KFPS, KFP, and ESD procedures are not

- described; the Pipe Support Quality Assurance Manual is not described; and the relationship of the Pipe Support Quality Assurance Manual to

, - the balance of the Quality Assurance Program is not documented.

3 Procedures KFP-1 and KFPS-1 do provide a broad and generalized description of the scope and applicability of the quality Assurance

- Program. These procedures also reference the contract between-1 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 as'sociated with anchor bolts are not adequately described.

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4. There is no evidence that upper management has performed scheduled

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reviews of nonconformance reports, personnel qualifications, and corrective actions.

I 5 There is evidence that uppe. management has performed reviews of audit reports generated by Pullman Power Products and Pacific Gas and Electric Company.

6. The indoctrination and training program requirements for personnel involved in inspection activities are adequate. Procedures KFP-2, KFP-3, KFPS-2, and KFPS-3 require training of NDE personn'el; 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 personnel, warehousing personnel, etc.

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

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. (, . Criterion III. Design Control

l. There is no design manual for the preparation of Isometgles 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 Quality Assurance / Quality Control Manager review field changes to 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 Powtr Products drawings. However, this mechanism is not described li; a written procedure. Documentation of the implementation of this informal procedure does exist.

!(t, 5 The isometrics and fleid fabrication drawings do indicate the i classification of systems.

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

7. The changes to isometric drawings and fleid fabrication drawings are Indicated on the documents, as well as the reason for the change.

Procedure KFP-9 establishes a mechanism to permit tracking of all revisions, i.e., the Chief Field Engineer is required to maintain j a copy of all volded drawings. ,

l 8. Procedure KFPS-8 requires the Chief Field Support Engineer to assure that all supports are fabricated to the latest drawing revision. No mechanism exists to comply with this requirement.

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Criterion IV. Procurement Document Control

1. Procedures KFP-6 and KFPS-5 adequately describe the responsiblitties -

associated with field purchase order processing.

2. Procedure ESD-226 adequately describes the quality requtrements for purchase specifications of the usual Pullman Power Products scope of purchased materials.

3. Procedures KFP-6 and KFPS-5 do not require that the purchase order state that Pul' aman Power Products is given the right to gudit the subcontractor shop.

4. No written procedure permits verification of the selected supplier as one identified on the Pullman Power Produc'ts corporate-approved vendors list.

There is no mechanism by which Pullman Power Products Corporate is q' 5 informed of the procurement of safety-related parts, components, l equipment, and material to assure thsc the selected supplier is placed on the Corporate audit schedule.

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Criterion V. Instructions, Procedures, and Drawings 7g

1. There is no requirement that activities 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-i nance of Field quality inspector Daily Logs.

3 Many activities 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 Weekly qualified-Velders Lists, and auditing.

4. The present orocedures are generally inadequate for providing direction to those performing the work. The procedures do not follow the flow of the work; many procedures are very long (over

( 10 pages); insufficient information is given; important information is not provided or referenced in the procedure. ,

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Criterion VI. Document Control

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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 f or control of ESD procedures.

4. There is no procedure for control of Special Quality Ass 0rance Instructions.

5 The Pullman Power Products review of completed packages relative to . ,

hangers and pipe restraints is not detailed in a procedure, nor is ESD-254 complete as to what is actually done for the isometric package.

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

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

is maintained in a nonpermanent manner. The log is filled out in pencil; and when the number of revisions er.ceeds the available space, the early revisions are erased to accomdodate the new revision.

7 No mechanism assures that the Pacific Gas and Electric Company drawings being used as the reference drawings are the latest-Issued revision. Audits are frequently performed to determi'ne that Pullman Power Products has the latest Pacific Gas and Electric Company draw-Ings. However, the audit mechanism is not satisfactory when l't is the only mechanism.

8. There is no Weld Rod Requisition for one of the welders who partici-pated in FW-345 of Isometric' 04-500-139

9 There is evidence that documents have been backdated and changed to meet requirements without any substantiation of the information. ,

o 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: FW-1673 was perforv,cd te Revision 2 of the isometric, which did not show FW-1673 Revision 3 of the I;o-metric, which included the FW-1673, was generated approximately one week after completion of the weld. It is therefe,re concluded "

that FW-1673 was performed without the norrel controls of a Process Sheet, a weld procedure call-out, and a call-out of NDE requirements.

e 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 I 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 1

December 2, 1975, the entry on the Process Sheet for removal of dams was signed off and backdated. There is no proof that the

, dams had been removed.

e isometric 2-26-417: FW-144, -145. -196, and -197 were completed l

on May 14, 1976. The Weld Rod Requisition had been altered to add FW-197. Mcwever, the Weld Rod Requisition shows that 14 rods had been burned, which seemt. Improbable for the four welds.that were supposedly welded.

10. No procedure or requirement prohibits the changing or alteration of the records and documents that are necessary to track the work.

Field Process Sheets, Weld Rod Requisitions, inspection records, etc.,

should not be changed or should be changed only by Quality Assurance l ,

supervisory personnel and then signed and dated.

Procedures KFP-14, KFPS-12, ESD-239, and ESD-254 are adequate instruc-(( 11.

tions to assure that the correct documentation has been assembled

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the system is ready for turnover.

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-(. Criterion Vll. Control of Purchased Material,~ Equipment, and Services

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1. The Interface between the Pullman Power Products Fleid Srganization .

and the Pullman Power Products Corporate Crganization relative to 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 performance of receiving inspection.

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Criterion VIII. Identification and Control of Materials, Parts, and

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components

1. Identification and control of piping and val /es 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-11, and ESD-202.

3. Identification and control of backing gas dams are adequately speci-fled by Procedure ESD-214.

4. Procedures KFP-8 and KFPS-7 are adequate for specifying that the identification of parts and components is to be recorded on the Fleid Process Sheet. The implementation of this procedure is adequate.

5 The isometric drawings and field fabrication drawings are the major documents for recording the Identification of the parts, spools, ,

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

mechanism has been followed and is an excellent technique.

6. Identification of welds and welders is adequately described in Procedures ESD-203, -204, -221, and -243

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

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

8. Material control techniques for temporary pipe attachments are ade-quately described in Procedure ESD-232. ,

9 Procedure ESD-248 adequately describes tontrols f'or the repair of installed valves and for valve parts control.

10. Adequate control of snubbers,' plate, and other components is achieved by using Procedures ESD-200, ESD-201, KFP-8, KFPS-7, and the practices b associated with field drawing preparation. However, no procedures specifically address these items.

11. Procedure KFP-20 provides an adequate reechanism to control nuts,

• bolte, etc.

12. Procedure ESD-223 does not give adequate Instructions for the identi-fication and control of Class I Pipe Supports.

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

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Criterinn IX. Special Processes

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1. 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. Cawelti, G. P.

Keeler, K. E. Beck, L. Glass, W. R. Johnson, E. Stanton, C. B. Athay, R. G. Sears, D. S. Tutko, J. N. Shiromizu, V. J. Casey, J. A. Brasher, L. F. Myrick. S. R. Stanley, H. Guest D. E. Sentley, 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 k without fulfilling the specified requirements. The most prevalent discrepancies are: not completing the required training, not having proof of previous experience, insufficient time as Level I, unsigned tests, and insufficient background and experience.

4. NDE procedure qualification is adequately described in Procedures 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 Welding Engineer (Williamsport). .

7. Procedures KFP-15. KFPS-13, and ESD-216 are adequate for specifying welder qualifications.

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I The certificatiori of the following welders, by weld symbol, was fb 8.

U, AN, IH, Po, VD, QZ, NY, PD, JL,

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examined and found acceptable:

ET , HL , AY , Ho , TQ , I Q, PG , KP , XC , FC , and ZC .

9 The certification of welder U was not ' signed.

10. A number of procedures provide mechanisms for control of the weld-log process: ESD-203, -204, -215. -219, -221 -225, -227, -242, and

-243. 'However, the control of the welding process has been inade-l quate as follows:

• e Records of welder qualifications prior to 1972 are not available, o The Ninety-Day Welders' Log was not maintained from August 1972 i to December 1972. There is no Weekly qualified-Welders List for that time period to substantiate that the welders were actually qualified. .

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(-(( e The Ninety-Day Welders' Log is not sufficiently detailed to determine if the welder is qualified to perform certain proce-dures. The Ninety-Day Weiders' Log has been revised a number of times, and the detail has improved with each revision. Pre-vlous 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 procedure states what the Field Quality Assurance inspector uses as the primary means to determine welder qualification, the Ninety-Day Welders' Log, the Weekly Qualified-Welders List, or the Welder's Qualification Card.

l e No procedure specifies who is responsible for the Ninety-Day l

Welders' Log, the Weekly Quallfled-Velders List, or the Welder's Qualification Card; how the information is obtained; how the logs are used; to whom they are distributed; etc.

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( 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 actively 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 (V. Adair, 251) performed welding on FW-70, -72, -73,

-76, -77, -78, -100B, -132, and -133 in isometric package 21-7 and FW-88, -90, -91, -92. -134, -135, and -160s in isometric package 21-8. This welder was not quallfled for the thickness range; and the welds were reported on DRs 2536, 2538, 2539, and 2899 In accordance with Pacific Gas and Electric Company dis-position, some of the welds were radiographed and found accept-

• able; Welder BF was quallfled to the thickness range; and all the welds in question were accepted. This disposition is not permitted by B31.1, 831.7, and ASME,Section IX, which all specify that the welder must be qualified prior to making pro-duction welds.

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

, with the sampilng to be noted on the Fleid Process Sheets.

examining Field Process Sheets, it is obvious that the sampling by the area inspectors was not performed.

e Procedure ESD-219 requires periodic auditing by the Welding Auditor. These audits w.re not performed untti November 5, 1973; and Pullman Power Products was no: ,in compliance with this procedure for approximately 23 months.

e Procedure ESD-219 requires monitoring stainless steel welds for ferrite control. However, the Severin Cauges wer'e not on site until the beginning of 1973; and Pullman Power Products was not in compilance with this procedure for approximately 12 months.

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( e' Hangers are not welded in accordance with Pacific Gas and

- Electric Company requirements. Hangers 2023-IV and 2039-2V are two exampies of a number of hangers observed that are welded to the structural steel on the wrong side of the bracket.

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 those weldments is not clear; in addition, the requirements for addressing impact property requirements for Pullman Power Products field welds are r.ot clear. If impact properties are necessary, the acceptability of each weld that has been repaired and subjected to more than one stress relief is Indeterminate because of the time at tem-perature limitations within the qualified weld procedure.

i e Some welders do not receive sufficient training. Welders,

( fabricating the pipe rupture restraints within the contain-ment, are welding heavy plate. While these welders are quali-l fled by virtue of welding heavy wall pipe, the techniques are different. The welders who were already qualified to heavy l wall pipe were not given additional' training on plate.

' e There is no procedure for the preheating of weld joints.

e The initial results of the welding auditing (from November 5, I 1973, tc February 1974) Indicate that the following problems existed:

• The welders did not understand shielding and purging.

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• Tempil sticks were not used.

• Amperages were not within procedure limits (mainly root 4

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k 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 tims vs flew rate alternate technique was not used.

• Oven rod temperature control 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 welding audit reports and the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974

( was performed in accordance with welding specification require-

$. ments.

11. Welding procedures for carbon steel welding require preheat and Inter-pass temperatures for material that has a carbon content in excess of 0.30 percent and a thickness of one inch or more. There is no mechanism by which the welder can determine carbon content.

12. Procedure ESD-221 does provide adequate guidance on weld repairs.

13 Heat treating has been identified as a special process in the Pacific Gas and Electric Company co'ntract (as well as in Appendix B), but it has not been controlled as a special process by Pullman Power Products.

14. Procedures KFP-13 and ES0-218 provide controls of the post-weld heat treatment process. The imp 1, e mentation of Procedure ESD-218 is acceptable.

(* 15 Cleaning has not been identified as a special process.

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Procedures ESD-220, -224, -238, -242, -252 -258, -259, and -261 I( 16.

provide adequate guidance in cleaning and cleanliness of.the various ,

materials, parts, and components. .

17 Procedure ESD-231 provides some guidan'ce on hot and cold bending of small bore piping. The guidance is considered insufficient to assure that the bending is done properly to avoid high stresses and thinning of the wall.

18. Procedure ESD-238 provides adequate instruction in torquing of bolting for pipe flanges.

19 Procedure ESD-259 provides adequate Instruction for installing Grinnell Snubbers.

2O. Procedure ESD-224 provides excellent instruction for assembly and torquing of installed valves.

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21. Procedere ESD-260 provides adequate instruction for installation

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of Williams Rock Bolts.

22. Procedure ESD.230 provides 6ood instructions for entering an in-stalled line.

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[ Criterion X. Inspection i 1. Procedures KFP-5, -8, and -14 thoroughly describe the Int,erface .

between Pullman Power Products and the Authorized Inspector.

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2. Procedures KFP-8 and KFPS-7 provide the requirements for the Field Process Sheet, which specifies inspection points and inspector )

sign-off.

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The Fleid Process Sheet references procedures to which the work and i the inspections will be performed.

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-207,

4. The inspection procedures are detailed in Procedures ESD-206

-208, -209, -210, -211, -215, -219, -225, -233, -234, -236, -24),

-243, -244, -249, -250, -251, -255, -259, and -260. These procedures are, In general, broad descriptions of the inspection process for the total range of the work scope and are adequate for that purpose.

5 For all inspection processes, there is no mechanism to provide the

(. Inspector the particular characteristic to be inspected; the partic-ular acceptance criteria; the particular methods and equipment to e

be used; and provisions for recording results, other than acceptance for the particular inspection being made,. The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures that specify the use of particular equipment (such as some of the ultrasonic procedures).

6. The inspection process is generally not auditable. The practice of exhibiting an acceptance signature only does not permit auditing to determine if the Individual characteristics were examined, the correct criteria were used for acceptance, and the correct specific measuring devices were used.

- 7 A large number of welds in $ nit 2, system 14 (Fw-110, -111, and i

-112 in isometric package 2-14-31 a a examples) were accepted for

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visual examination and thereafter accepted based on surface NDE I

I inspection (MT er PT). Visual examination of those welds Indicates -

that the surface is not suitable for the performance of surface NDE Inspection.

- 8. Far FW-110 (isometric package 2-14-31), the Process Sheet indicates that MT was perforned; however, the inspection sheet for PT shows that weld number, and the inspection sheet for MT does not show that weld number.

S.

FW-83 (Isometric package 1-10-9) was repaired in accordance with 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.

10.

Isometric package 1-03-1 has a step that requires a Pullman Power Products inspector sign-off. This requirement was removed, and the

( step was accepted by a Pacific Gas and Electric Company employee.

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( Criterion XI. Test Control

' 1. Procedure ESD-229 adequately defines the methods'and Inspctions ,

relative to performing hydrostatic tests. ,

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2. There .ls no description of the respons'Ibilities of Pacific' Gas and Electric Company or of the Pullman Power Products / Pacific Gas and Electric Company interface relative to hydrostatic testing.

3 Procedure ESD-229 is not adequate for describing the flow and authorities relative to the individual hydrostatic test procedures '

to be perfo'rmed.

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4. Hydrostatic test packages 7-2, 7-2A, 8-12, 9-12, 106, 106A, 106B, and 64 were examined and found acceptable.

I 5 The B31.1 and B31.7 Codes require that all piping be leak-tested, f where practicable. Pullman Power Products is only leak-testing

(., Class A and 8 piping and that Class C piping specified by Pacific

( Gas and Electric Company. Classes D, E special,'and E pipAig is not being leak-tested. A letter from Pa'cific Gas and Electric Company (dated January 13,1976) does exist, which states that Pacific Gas and Electric Cor6pany will assume responsibility for the leak-testing of Class C piping. There is concern that Pullman Power Products is not discharging its contractual obligations (that specify compliance to 831.1 and 831.7) by not performing piping leak-testing to Code requirements for Classes C, D, E special, and E piping systems and, as a result, may be legally vulnerable.

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Criterion Xil . Measuring and Test Equipment

1. Procedures KFP-11, KFPS-10, and ESD-213 describe an adequate call -

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bration program.

2. The calibration program did not require recalfbration 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. .

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The calibration program has not been adequately implemented.

e Paragraph 11.5 of Procedure KFP-11 and Paragraph 10 5 of Pro-cedure KFPS-10 require reinspection of materials and components if the measuring and 'est equipment is found to be out-of-call-bration. Except for I;ydrostatic testing and heat treating, the Identity of measuring and test equipment is not related to the

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[ Inspections performed.

o Procedure ESD-213 does not contain a mechanism to report out-of-calibration measuring and test equipment to Pullman Power Products. Some forms used by the calibration subcontractors only contain provisions fo~ attesting to calibrating the equip-

- ment to appropriate standards and have no provisions for record-ing the actual values obtained.

l e The calibration records of recorders were confused by having two 1

j recorders identified on one record, and the acceptability of I

the records could rot be determined. -

o Severin Cau'ges 2947 and 2971 were received on the' site in January 1973 Initial calibration was August 29, 1373; and the next calibration was November 19, 1974, for gauge 2947 and January 23, l

1975, for gauge 2971. Procedure ESD-213 requires annual

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f 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.

e " Tong Test" ampmeter TT2527403 was out of calibration for the period December 12, 1976, to January 31, 1977 No D# has been written against that instrument.

e Storage requirements for Instruments are not specified.

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( Criterion Xill. Handling, Storage, and Shipping

( 1. Procedures ESD-202, -215 -217, -222, -223, -240, -259, and , -261 -

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provide some information relative to handling and storage of mate- -

rials, parts, and components for the total scope of the Pullman Power Products effort.

i Procedures for storage are generally inadequate. Procedures ESD-222, 2.

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" Control Valves," and ESD-202, " Weld Material Withdrcwal and Control,"

are specific and adequate. Procedure ESD-215, " Visual inspection,"

provides some guidance on storage. There is very little information *

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relative to how specific items are to be stored or the de11neation 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 how 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 strainers, which were stored in the Pullman Power Products storage area.

O 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. Procedure ESD-239 has excellent detait as to the handling of Grinnell Snubbers during installation. However, Procedure ESD-259 was issued January 27, 1977; and there is no assurance that materials, parts, and cceponents were properly handled during the period prior  ;

to January 27, 1977, when most of the installation activities were l occurring. l

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The present storage areas were found to be in excellent condition,

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with areas clearly defined, materials supported on adequate dunnage,

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and openings capped. .

7 Procedures KFP-19, KFPS-17, and ESD-222 provide for an adequate Prior to October 31, 1973, tiee sur-storage surveillance program.

ve111ance was performed using a checksheet that contained the stor-age requirements; after October 31, 1973, the checksheet was changed so that the storage requirements were not listed. While the sur-veillance program appears adequate, the checksheet used after October -

31, 1973, does not appear adequate.

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I Criterion'XIV. Inspection, Test, and Operating Status

(' 1. The major mechanism that exhibits the status of the work,Is the _

The Field Process Sheet provides for perfor-Fleid Process sheet.

mance status of some important fabrication steps and for inspection '

status. However, many important fabrication steps are not Indicated by the Fleid Process Sheet:

erection steps; cleaning prior to in-

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sta11ation of insulation; and some critical welding steps as pre-heating, checking gas flows, and checking for 0 2 content in the backing gas. The Field Process Sheet, as a mechanism to exhibit status, is considered inadequate. The inadequacy of the Field Proc-ess Sheet is considered a major weakness in the Pullman Power Products system.

2. The Hold Tag mechanism described in Procedure ESD-240 is an accept- f l

able method of exhibiting status when a defective or discrepant l

condition is noted.

The method of using the Fleid Process Sheet,'the Hold Tag, and the

([ 3 Discrepancy Report is an acceptable mechanism to track the status l cf a discrepant condition and the final dispos! tion of that condi-tion. However, the mechanism is not always utilized.

e DMR-604, dated February 14, 1973, fcLr isometric package 1-03-1 There required rework and reinspection of 14 Class 8 welds.

are no Fleid Process Sheets or Inspection Reports to demonstrate that the work had been performed.

e The Fleid Process Sheet for FW-347 states that the weld was cut out in accordance with a specified DR. The referenced DR Js not appilcable to cutting out FW-347

4. The method of indicating r,epair welds, as described in Procedures ESD-203 and -204,'and the notation of repair welding on the Field However, Process Sheet are acceptable for showing repair status.

FW-83 -(Isometric Package 1-10-9) and FW-348 (Isometric Package 04-500-I .

4 I

l( 139) were not stamped "R" to indicate repair.

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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 Indicating hydrostatic test status. l These mechanisms are acceptab's. Procedure ESD-229 should reference Procedure ESD-239 and require that the release be confirmed prior to i

Initiation of the testing.

6. Paragraph 8.12 of Procedure KFP-8 requires that the Field Process -

Sheet be maintained in the area where the line is being installed'.

This requirement has been interpreted as having the Field Process Sheet in the area inspectors' station and not as being available to the foremen and the people performing the work while the work is in progress. This practice causes the Field Process Sheet to become an inspection sign-off record, rather than a traveler that presents necessary Information to all Individuals involved in the performance of the work.

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7 Paragraph 7 2 of Procedure KFPS-7 requires that the foreman or pipe-fitter procure a drawing and Process Sheet prior to starting work and check off operations as completed. There was no evidence that this practice (which is in confilet with KFP-8) is observed.

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Criterion XV. Nonconforming Materials, Parts, or Components  ;

1. Procedures KFP-10, KFPS-9, and ESD-240 describe an adequgte system .

of identifying nonconformances. ,

2. Procedure ESD-240 does not adequately describe the actual process by which Nonconformance and Discrepancy Reports are processed.

3 The Pullman Power Products / Pacific Cas snd Electric Company inter- l face r'lative e to Discrepancy Reports Is not described.

4. Procedure ESD-240 does contain adequate information relative to disposition and close-out (use of logs) for Nonconformance and Discrepancy Reports.

5. Systems that circumvent the nonconformance system have been estab-Ilshed. Use of Note-0-Grams and Rejection Notices to denote dis-crepancies usually precludes their pick-up on a subsequent NR or DR.

f- The use of these alternate systems removes the controls and reviews

( that have been Integrated into the NR and DR system and also pre-vents information relative to the number and types of problems from being identified. These alternate systems are unacceptable.

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Criterion I. Corrective Action

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'( 1. 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 evaluation and tracking.

e Documentation of all discrepancies.

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-e inclusion of documented discrepancies in the NR and DR system,

• i.e., discrepancies reported in Note-0-Grams are not subsequently written as a NR or DR.

e Tracking of discrepancies to determine which discrepancies are recurritig.

e Analysis of discrepancies to determine programmatic problems.

( e Reporting of significant conditions adverse to quality and the corrective actions taken to appropriate levels of management.

2. Based on the results of this audit and the problems encountered in the past, it appears that a corrective action system has not been ,

operative.

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

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Criterion XVit. Quality Assurance Records f

(- 1. Procedures KTP-16 and KFPS-14 and most of the ESD procedures adequately identify the records to be retained. .

2. Procedures KFP-I4 and KFPS-12 provide adequate guidance and mechanisms Records that are not specified to assure collection of most records.

l in these two procedures (e.g., records on heat treatment, torquing.

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

3 There are no procedures for filing, storing, and protecting records, ,

1.e., no requirements for the vault, no method on how records other than isometric packages are identified, no instructions on how records are to be stored. However, the practices employed do provide for adequate Identification, retrieval, and fire protection.

4. Procedure ESD-212 does adequately describe a security system that

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' provider "out" cards for Identification of the record and the Indi-( vidual using the record and for the overall security of the records within the vault.

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l Criterion XVllt. Audits l l (.

Procedures KFP-18, -19, ~21; Procedures KFPS-16, 18; and

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1. '

Procedures ESD-219 and -222 describe an adequate audit program.

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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 Checksheets wgre employed.

performed approximately every six months.

Based on the results of this audit and the results of Pacific Gas and Electric Company audits, these management audits appear to have been ineffectual.

4. Procedure KFPS-16 does not require management audits.

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5 In response to KFP-18 and KFPS-16, internal a,udits were performed (Y every six months. Checksheets were not employed.

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6. There are no procedures for audit reports, audit responses, and time limitations on responses.

7 Procedures KFP-18 and KFPS-16 require that a copy of the audit report be transmitted to the Manager of quality Assurance.

8. There are no requirements that the Manager of Quality Assurance I track the audit reports or take any corrective actions when program-i matic or recurring deficiencies are noted.

9 There are no requirements for periodic, independent, internal audits I of the total quality program. ,

10.

One independent internal audit was performed in January 1976.

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[ V. EXIT INTERVIEV

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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: .

Vice President, Jack Bowes Pullman Power Products Production General Manager l Ed Gerwin Pullman Power Products Quality Assurance John Ryan Pullman Power Products Resident Construction Manager .

Field Quality Assur-Pete Runyan Pullman Power Products ance Manager Pullman Power Products Chief Field Engineer Chris Scannell Pullman Power Products Quality Engineer, Al Eck Central Staff Pullman Power Products Consultant John Mitchell Sherman Naymark Nuclear Service:, Corporation President i

Nuclear Services Corporation Audit Team Leader Jack Weber Bill Rowe Nuclear Services Corporation Auditor Gerry Larsen Nuclear Services Corporation Auditor 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, l.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

- - - - - - - - - . . - - - , - - - , - - - - - ,- - - - - , - - - ~,--r--- , , - , - , - . - -- , ,,n_.-- -m---.~ - - , - - <-,,.,--,v n--,,.- ,

b presentation of the audit findings, an overall sunnary of the findings I. was presented. , .

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VI.

SUMMARY

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

to the present.

The findings indicate that there were three* distinct These findings'are:

periods as related to the quality of the work. vidence available to verify

' e Prior to early 1974, there is l'Ittle

~ the adequacy of the work performed. The available evidence Indicates that only a rudimentary quality control program existed and that con-trol over the production organization was minimal.

ify e From early 1974 to late 1974, there is evidence available to ver the adequacy of the work performed. The available evidence indicates that control was achieved of the materials control program and the welding. control program.

i e From late 1974 to the present, an increasing amount of documentat on and records has been generated to verify the adequacy of the work The available evidence demonstrates that an increasingly performed.

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

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However, the present program and controls still do not meet 10 CFR 50, Appendix B requirements in those areas as delfneated in Section IV the audit report.

d l 0 / W Ja6k Weber, Audit Team Leader n-_

. f /*f/h g y q #G. J. Larsen, Auditor f d' EfC ,

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Ib.IlS7 y' . 6 --

9 . T. C. Newman, Auditor 4-

' 1L Sg'.N U? Ci,A.'.CV,.y

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. W. Mowe, AucTitor

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-- - ~ . _ _ , _ ,,, _ ,9,- ___ "%'9hw,. # _ 'DN* Q g, _

Dvoon of W IncorporatoG I

P O Bom 3308. Reacn Road Whomeport. Pennsy%sn.a 17701 Toisphone (717) 323 9991 j Tenen 841416 coe% - -

Pullman Power Products M M  !

4l April 11, 1978 [/

RSS anamec<rs amas yp3 KM EM I90141978

• gyp g t'Wpt opet.

5 Pacific Gac & Electric Company >$aatka; 77 Beale Street y _ _ _

Room 2505 pg San Francisco, California 91405 Attention: Mr. R. Bain .

Subject:

Pacific Gas & Electric Company Diablo Canyon - Units 1 & 2 NSC Audit of August 22 through September 20 I

Dear Mr. Bain:

l Nuclear Services Corporation conducted an audit of the piping installation l Products, '

work at Diablo Canyon Units 1 & 2 at the request of Pullman Power Division of Pullman Incorporated.

f After receipt of the NSC Audit Report, we prepared a preliminary d site draft o proposed personnel.

responses and corrective actions for review by o sidered. d  ;

Attached for your review is the NSC Audit Report and our responses an proposed corrective action for each finding.

You will note in our Observations that we were not entirely satisfie with the direction of the audit.

personnel conduct in-depth audits These of the reports areinstallation filed at site. from ThereJanuary through March of this year.  ;

I were no significant findings. i After you have had an opportunity te review this report, ider we would be pleased to meet with you to cont.ider future actions you may cons necessary. -

l Sincer yours,

[ wa-Director of Quality Assurance i

EFC/kal l ( Att.

cc: E. Manning (Bone Office File) w/att.

J. P. Runyan (Site File) w/stt.

T. D. Landale f S. Bandler J. E. Bowes J. Ryan T. .

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PACIFIC GAS & ELECTRIC COMPANY DIABLO CANYON UNITS 1 & 2 AUDIT OF PULDfAN POWER PRODUCTS INSTALLATION WORK C

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l. INTRODUCTION As a result of a meeting between PG&E and Pullman Power Products representatives in early July,1977, an independent audit of the Pullman Power Products installation activities at Diablo Canyon'-

Units 1 & 2 was conducted.

The auditing was subcontracted by Pullman Power Products to Nuclear b Services Corporation of Campbell, California. Nuclear Services Corporation was selected by mutual agreement between PG&E and Pullman.

The purpose of the audit was to verify that the installation met all the requirements of the applicable contract specifications and drawings.

The audit was conducted during the period from August 22 through September 20, 1977.

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2. AUDIT RESULTS A copy of the NSC Audit Report was received by Pullman Power

• Products October 27, 1977. This report is attached as Appendix "B" to this document. .

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( 3. AUDIY RESPONSE The Pullman Power Products response is attached as Appendix t'A".

For each fi.tding, Pullman has reviewed the item in depth and pr'e-pared a suitable response. Where corrective action is required, a the corrective action which has been, or is to be taken, is defined.

I For ease of review, the audit finding from Appendix "B" has been copied verbatum. It is inunediately followed by the Pullman response and corrective action where applicable.

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4. OBUERVATIONS

( s. Although one of the major purposes of the audit was to verify the adequacy of the workmanship of field fabrication and * '

installation against the contractual obligations, very few of the findings cita discrepancies in this area. This cocid be interpreted as a vote of confidence in the physical ,

installation but NSC does not so state.  ;

g b. NSC points out that auditing is a sampling procedure sad that opinions are based on the number of deficiencies within the sample. Unfortunately, the sample sizes and numbers of discrepancies per sample are not reported. Neither is there any indication as to whether discrepancies noted are i

serious or minor. Both items of information would have helped in formulating an opinion regarding the physical installation.

c. Many findings make general statements that some procedure or control is not adequate. The specific reasons for the inadequacy are not listed, and frequently even specific procedures are not cited. Such lack of specificity askes it almost impossible to respond. Where possible, we have attempted to identify these areas to correct the alleged inadequacy. More often than not, one must conclude that personal opinion was involved.

( d. The major thrust of the audit was directed at the Pullman Quality Assurance Program. .

Our original Quality Assurance Program was written to reflect the Quality Assurance requirements of the 1968 Edition of the ASME Nuclear Pressure Vessel Code, as it applied to piping. This program was modified as requested by the State of California to reflect special State require-ments. It was accepted by the ASME as the site Q.A. Manual as a result of a site survey in February, 1971.

It must be borne in mind that 10CFR50 Appendix B was published sub-sequent to the contract date. The ANSI N45.2 documents and Regulatory Guidee which were issued as specific methods for fulfilling Appendix B requirements were published for the most part during 1973 and 1974 when most of the actual work was underway.

As part of our obligation to improve the quality of our Program as a result of our greater experience as well as greater sophistication in Quality Assurance resulting from the issuance of the. aforementioned documents, we revised our quality Assurance Manual and putilished scores of Engineering Specifications and quality Assurance Instructions to supplement it. No att ept was made to remodel the Manual to the Appendix j

-( o "B" format. All applicable points, however, are scattered throughout the Manual, Specifications, and Quality Instructions.

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No attempt was made to apply never requirements to work com-This is not required by the ,

plated to earlier requirements. l

( NRC or the Code. I We have been audited on numerous occasions (the text of boa response indicate 68 audits) by PG&E, the NRC, ASME, State Our of California, and one other independent auditing group.

program has been reviewed and our work monitored by both the State of California and Bartford Steam Boiler Wa Insurance recently g

Company, our Authorised Inspection Agencies.

underwent an ASME No audit one forhas renewal found of our ASME major fault withCertificates our with flying colors.

Quality Assurance Program.

e. NSC, on Page 2 of the Audit Report, rightfully points out that the work has taken place over the time period fror.1971 .

to present, and that the audit scope and purpose was to evaluate the work against Codes and standards in effect at the particular time the work was performed.

Unfortunately, in making their evaluation and conclusione, the audit team did not adhere to their own precautionary statement. The audit findings are profuse with instances where records, docunents, and procedures were judged against 1977 criteria instead of those in effect at the time the work was done. This, we feel, was a great disservice to Pullman and our customer.

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SUMMARY

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a.

The NSC audit failed in fulfilling one major pr.rpose, the

• verification of the adequacy of the installation. .

b.

Nowhere in this report is there any indication of a finding ,

which indicates an inadequacy in the installed work or an inadequacy in the documentation which constitutesThese two basic point b

evidence of compliance.

- omitted in the NSC Summary, but are most relevant in judging the quality of the installation.

We strongly disagree with the NSC Summary that prior to early 1974, there is little evidence available to verify All of the evidence exists in the adequacy of the work. form of documentation and other records which were i

by the Code and Quality Assurance requirements existing at the time the work was performed.

c.

The conclusions regarding the adequacy of as-installed work should be judged against the Codes specified in the contract Conclusions regarding adequacy of the Quality documents.

Assurance program should have been evaluated against Findingspractices 3 in effect at the time the work was accomplished.

relative to Quality Assurance appear to be judged against current (1977) criteria.

( The statement that the Quality Assurance Program does notIn our opinion, the d.

meet 10CFR50 Appendix B is an opinion only.-

program does adequately meet Appendix B.

e. The audit results were useful only in the sense that they pointed out areas where the current Quality Assurance (1977) requirements Program can be improved to suit currenteven though the work wa requirements.

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"A"

_ APPENDIX AUDIT RESPONSE CRGANIZATION

( CRITERION 1.  ;

A current organizational chart does exist.

FINDING 1. I No Corrective Action required.

Response: No comment.

' )

Procedures KFP-1 and EFPS-1 do describe the gus11ty organization.

FINDING 2_.

as well as some of the functional responsibility of the quality organization, b

g No conament.

No Corrective Action required.

Response

i The Field Quality Assurance Organization has performed functions FINDING 3_.

i.e., writing other than those described in KFP-1 and EFPS-1; an and approving Engineering Specifications, performing velding l engineering functions, approving engineering changes.' These l activities raise the question of the qualification of Quality Assurance personnel to perform these functions and the problem of requiring the Field Quality Assurance Organization to audit its own performance.

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Response

There is no evidence of deficient work as a result of the system I

sdescribed.

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Welding procedures were originally prepared by the Welding i d Engineer at Williamsport, however, Mr. R. Fink, Q.A. Manager, later rev se i

( some of these and prepared some additional procedu In all

' and Construction.

Where Q.A. personnel were involved in procedure preparation, Engineering input was solicited and incorporated where applicab Present policy requires Engineering to prepare and/or revise Engin-eering Procedures. Q.A. Department reviews and approves.

No further Corrective Action contemplated.

Procedures ETP-4, EFPS-4, EFP-6, EFPS-5, KFP-8, EFPS-7, KFP-FINDING 4.

and EFPS-8 do describe some of the responsibilities of t Engineering Organization.

Construction Organizations are not describe

Response

At the time our Quality Assurance Manual was written and imple-mented on this job, there were no requirement Assurance Department.

Corrective Revise the Q.A. Manus 1 Section EFP-1 to be

! Action: Department, and to clarify the responsibilities of the Q.A. Department.

(

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1 FINDING 5. The descriptions of individual position responsibilities are inadequate. Some elements of position descriptions exist

' ( in the KFP and EFPS procedures , and job descriptions exist for inspection and inspection technician positions. No  :

position descriptions exist for any of the upper-level site ,

personnel. .

Response: At the time our Q.A. Manual was written, it met the require- l ments of the Code and contract.

Carrective Corrective Action for Item 4 above will cover this finding.

Action:

FINDING 6. The description and controls of the interfacial relationship between Pullaan Power Products and Pacific Gas and Electric Company are inadequate. The contract and some Engineering Specifications do describe some interfaces and mechamians.

However, for the greatest scope of the work effort, there is little to describe how the interface will be managed and controlled. Some of the activities that require interface control are hydrostatic testing, nonconformance reporting, meetings, work on pipe rupture restraints, work on hangers, document centrc1, reporting of deficiencies, responses to Pacific Gas and Electrip Company audits, interfaces with other Pacific Gas and Electric Company contractors that impact i

Pullman Power Products work, etc.

Response: At the time of the contract, our Q.A. Manual addressed inter-faces between our site departments, but only with PG&E insofar as design changes were concerned. Subsequently, many specifications have been written which do cover inter-faces with PG&E in other areas. Interfacial activities are functioning properly, but are not necessarily docsaiented in written form.

The following addresses each item in Finding 6 specifically:

6a) Hydrostatic Testing: PG&E has a procedure for preparation of the Procedure for each Hydrostatic Test. These test requirements are transmitted to Pullman Power Products Chief Engineer. When the requirements are received from PG&E, Pullman Power l j

Prod" cts Chief Ent,ineer or designee prepares the < l i

specific Bydro test procedure in accordance with ESD-229. This system complies with the job specifications and code requirments.

6b) Wonconformances are reported on a Discrepancy Report (DR)in accordance with Pullman Power Products i

Procedure ESD-240'. DR's are transmitted to the PG&E's Resident Mechanical Engineer for disposition and/or approval. Following customer disposition

(~. the DR's are returned to Pullasa Power Products' QA Department. The QA Department then issues approved DR's to personnel responsible for per-forming the work. Work is performed and documented l

1

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We fail 6b) in accordance with approved p ocedures.

(Cont.)to understand why nonconformance reporting is con-

,f sidered inadequate by Audit Team. 1 i ~

6c)

Meetings are held twice weekly between PG&E and

• Pullman Power Products to maintain an open ,

communication tractor.

line between If major changes are the Utility and Con-In mo up-dates of work in progress.made, Official meeting these are handled via dr' tract change or field orders.

g minutes are not kept and distributed to attendees.

Each attendee notes items of concern within his area of responsibility.

6d) Work on pipe rupture restraints We , and hangers are scope of Pullman Power Products contract.

disagree with this finding.

Drawings, specifications, and 6e) Document Control:

contracts and their revisions are transmitted to Pullman Power Products via PG&E Drawing Cont Procedures.

Pullean Power Products in accordance with Pullman approved procedures.

6f) Reporting of deficiencies - see b - Nonconformances.

( PG&E audit 6g)

Responses to PG&E's company audits: reports h as any other audit report.

4 has determined the cause for noted discrepancy, b performed corrective in writing in action when required, es ar.d responded to PG&EPG&E has further reviewed the actions taken.

implemented corrective action to determine that the d steps taken were adequate and properly im 6h) Interfaces through the responsible with other PG&EPG&E resident contractors engineer aContractors nd are han prep d .

in weekly contractors meetings.and submit weekly sc among all act!ve contractors.

l to l Review allIf current practices with PG&E site p I

Corrective

~ Action: not, modify existing or prepare new relationships. I procedures as required.

, i

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The description and the controls of the interfacial relation- f FINDING 7_.

ship between Fullama Power Products Field Organisation d in the and j

( the other Pullman Power Products organizations involve The Quality Assurance

• Diablo Canyon effort are inadequate. Manual does descr Field and Corporate Offices.

ments for periodic reporting from the Field QualityAs i

i of

• there are no requirements for an upper-management rev ew corrective action reports, nonconformance reports, and g personnel qualifications; the interface between the Field Organization and the Faramount shop is not des Corporate Construction Manager is not described; the inter-fa'ce between Field Quality Assurance and Corporate Quality Assurance is not described with respect to field p Response _:

Although it is not documented in the site Q.A. Manual, a l corporate policy was established to require corporateThese cover requ l

' sudits on a semi-annual basis.for review of corrective Corporate or action, n qualification by upper management personnel. i management audits were conducted on a semi-annual dd bo sThere starting September, 1972.

management audits In on file indicating addition, the fieldfindir site gr and recommen e Quality corrective action.

(

Assurance Manager has beer. required since mid-1977 to forwa a monthly report to the Director of Quality Assurance in Williamsport citing these items.

The Paramount Shop is considered as a supplier to PG&E and all interfaces must come through PG&E, Interfaces between Field and Corporate Q.A. regarding purchasing is covered in the Q.A. Manual, Section KFP-6, Paragraph 6.3(g).

Corrective The Q A. Manual Section KFP-18 villNobe revised to in current practices of management audits and reviews.

Action: Corrective Action is required for the balance.

I Interfaces between the Resident Construction Manager and '

Corporate Construction Manager will be covered in thePurchasing I d

corrective with Field action and Corporate for Item 4 above. Q.A. will also be better define .

The :description and the controls of the interfacial relation-FINDING $_. ship between the Pullman Power Products Field Quality Assurance Organisation and theThe other Pullman Quality Assurance Power Products Field organisations are inadequate.

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FINDING 8_

Manual and many of the Engineering Specifications describeH interfaces and mechanisms. d to (Cont. ) to the construction and engineering efforts in regar p G drawings approval; review of isometric, hangera, and restraint ,

document packages; welders loss; and control of the welding

• process are not described.

h There are Engineering Specifications which describe tb3 itter-e R_rponse_: facial reistionship for the items listed. t As part of the review contemplated under Item 6 above, Carrectiv_e revisions will be made to procedures where necessary.

Action _:

The stop work authority for the Field Quality procedure ESD-240Assurance does FINDING 9.

Organization is not adequate.

describe the stop work authority for Bold Tags, fer but the there are no mechanians described or authority addre proceed through a Hold Tag stop.

Rerpense:

The Quality Assurance Manual as originally written did not specifically address the stop work authority Department. ance of the Q.A throughout the length of the job that the Quality Assur Manager had the right to.stop work at any time It has never been necessary on this project Assurance.

( for the site Q.A. Manager to exercise this prerogative.

A stop work authority statement will appear intive the revisions Corrective. to Section KTP-1 of the Q.A. Manual as part of correc

~ Action:

action described for Item 4 above.

The Field Quality Assurance Organization does report to a FINDING 10.__ sufficiently high level of managasent.

Response

This finding tends to suppcrt the stop work authority response to Itan 9 above.

No Corrective Action is required.

(

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CRITERION II. PROGRAM

( The contract between Pullman Power Products and Pacific Gas FINDING 1.

& Electric Company was signed in May,1970, prior to the

• enforcement of 10 CFR 50, Appendix B. The contract did con-tain certain quality aspects that were requirements for .the Work was not initiated Pullman Power Products work effect. .

on the Diablo Canyon site until late 1971, when Appendix B 5 had become a requirement. $ppendixBwasaddedto10CFR50 on June 17, 1970, effective July 27,1970 (35 FR 10498), and g amended September 11, 1971, effective October 11, 1971 (36 FR 18301%.) Even though the contract was not amended by Pacific Cas & Electric Company to include Appendix B as a l requirement, pullman Power Products was obligated to conform l to Appendix 3 requirements; and the total quality program was evaluated against Appendix B and ANSI N45.2. While a written Quality Assurance Program exists, the prograp does not meet the requirements of 10 CFR 50, Appendix B or ANSI N45.2.

The specific inadequacies of the program are described through-out the findings.

Response: Our Quality Assurance Program as accepted by PG&E and implemented on the site meet the contractual requirements.

It addresses Quality Assurance as required by ASME Section The manual was modified III Nuclear Vessel Code 1968 Edition.

to suit specific added requirements of the State of California and was accepted by the ASME as a result of a field site

( survey.

As noted in the findings, Appendix B did not become effective until af ter the program was implemented in the field. Most of the ANSI ?45 documents which gave specific direction for implementing Appendix "B" were not published until 1973 and 1974 when the bulk of the work was underway.

As the work progressed and experience dictated, we incor-ported many provisions of the above documents in our Quality Assurance Manual Engineering Specifications, and quality Assurance Instructions. Bowever, no attempt was made to address each specific requirement in one place. .

l The progras in effect at any given time complied with the l requirements of 10 CFR 50 Appendix B andAll implementing work was performed decuments which existed at the time. Therefore, the and docuented to the program in effect.

wrk is considered to have met the job requirements and was completed to the applicable quality level.

Ihmerous audits by PG&E, the NRC, the state, ASME, etc., have not fotnd any fault with our program from this point of view.

Other than Corrective Actions acted throughout the response Corrective to the audit as a whole, no corrective action is anticipated.

( Action:

4-

~

t

FINDING 2.

There is no description of the overall Quality Assurance .

Program. Special Quality Assurance instructions are not I

( described, the relationship and purposes of the KFPS, KFP, *!

and ESD procedures are not described; the Pipe Support -

Quality Assurance Manual is not described; and the salation-ship of the Pipe Support Quality Assurance Manual to the balance of the Quality Assurance Program is not docsmented. .

Response _: Our Quality Assurance Manual KFP-1 Paragraph 1.13 indicates that Engineering Specifications covering specific Quality Assurance functions would be prepared at site and approved by j These become part of the Q.A. Program.

Company Q.A. and PG&E. j The term " Engineering Specifications" was intended to cover '

all program supplements without the need forThe specific pipe support ider.tification as KFPS, KFP, or ESD's etc.

manual was added at a later date and served as an extension of the original manual. ,

No Corrective Action contemplated.

FINDING 3.

Procedures KFP-1 and KFPS-1 do provide a broad and generalized description of the scope and applicability of the Quality Assurance Program. These procedures also reference the contract between Pullman However, Power the total Products scope and Pacific and applicability of Gas &

Electric Co.

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.

Response

Efforts relative to receiving and control of materials and components other than Pullman procured are very adequately covered in KFP-7 Paragraph 7.2.

Efforts relative to pipe rupture restraints and anchor bolts are covered by the Pipe Support Manual although not specifically listed.

Rupture restraints and anchor bolts are covered by numerous 243, 259, 26 IDS's and Q.A. instructions. See ESD Q.A. Instructions 72, 95, 96, 97, 105, etc. .

No Corrective Action required.

There is no evidence that upper management has performed PINDING 4_.

scheduled ' reviews of, non-conformance reports, personnel qualifications, and corrective actions.

(

I l

l Response _: Corporate Management Audits have been performed on a regular l f

\ basis since 1972. (See response to Criterion I, Pinding 7.)

l Part of the auditing activity is to review non-conformance reports, personnel qualifications, and corrective action. .

Since mid-1977, all site Q.A. Managers are required to -

subait a monthly report which includes a review of non-i conformances, corrective actions, and personnel requirements.

No Corrective Action is required.

FINDING 5. There is evidence that upper management has performed reviews of audit reports generated by Pullman Power Products and Pacific Gas & Electric Co.

Rerpense: This finding corfirms existance of audit reports men,tioned in 4 above.

No Corrective Action required.

) The indoctrination and training program requirements for FINDING 6.

i personnel involved in inspection activities are adequate.

Procedures KFP-2, KFP-3, KTPS-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.

Rerponse: No ecument.

No Corrective Action required.

FINLING 7. The indoctrination and training program requirements for personnel involved in quality-related activities are inadequate. There is no requirement for indoctrination and trainine, of welders, foremen, engineering personnel, warehousirg personnel, etc.

Response: At the f.ine our Q.A. Manual was originally issued, there were ne requirements for training of quality related personnel outside of the Q.A. Department. We have conducted but not necessarily documented training sessions with Engineering personnel, General Foremen, welders, and other craft personnel. A full time welding sagineer has provided instructions and directions to weldern during original qualifications and during subsequent work. He has'monit'ored their activities. .

Corrective Add a requirement in the Q.A. Manual, Section KFP-1 to

(- Action:

cover a requirement that personnel in quality related functions are trained.

-S-K .

l 1

l l

There is no evidence that personnel have been trained to FINDING _8_.

assure their f amiliarity with the procedures they are

( responsible for implementing, except for welders, who have 5 been trained and qualified to specific weld procedures.

f l

Re sponse_:

Requirements for documented _ have We evidence of training conducted requirsidwas never addressed in our Q.A. Manual.

training for NDE and inspection personnel to the require-

/

5 ments of our procedures (See Item 6 above), very often Quality-related over and above contract requirements. q We have b

personnel were also trained (See Item 7 above).alw not necessarily documented it.

All future training will be documented.

Corrective Action: .

C e

d I

1

i -

4---- - - . . . _ _ _ _ _ , _ _ _ _ _

CRITERION III. DESIGN CONTROL

( FINDING 1. There is no design manual for the preparation of isometrics and field fabrication drawings. .

Response: Preparation of isometrics and field fabrication drawin'gs do not involve any type of design. They are merely transfer of customer requirements from orthographic projections to i j

more manageable documents . to pemit ease of installation 6,

and documentation of work performed. The Q.A. Manual l l

covers requirements for control and approval by Q.A.

Department of such drawings.

No Corrective Action required.

FINDING 2. Procedure KFPS-4 provides adequate control of the pipe support design effort.

Response: No Coment.

No Corrective Action required.

FINDING 3. Procedure KFP-4 requires that the Chief Field Engineer and the Field Quality Assurance / Quality Control Manzger review field changes to Pacific Gas & Electric Company -

( approved drawings and specifications for ASME Code com-pliance. No written procedure for this review exists.

Response: In order to assure that Code requirements are correctIy applied, our Q.A. Manager KFP-4 requires a review of PG&E initiated drawings and revisions by the Pullman Chief Field Engineer and Field Q.A. Manager. Both individuals were selected for this work because of experience and t.bility. They are well versed in applicable customer and Code requirements, and a written procedure for this review is not deemed necessary.

When drawing changes are requested by Pullman, a discre-pancy report is written and submitted to PG&E for approval prior to any work.

No Corrective Action is necessary.

FINDING 4. A mechanism does exist for checking and reviewing Pullman Power Products drawings. Bowever, this mechanism is not described,in a written procedure. Documentation of the inf lementation of this informal procedura does exist.

Response: Our Q.A. Manual Section KFF-4 outlines requirements for review

(- and checking of Pullman prepared documents. The finding,

' indicates: that implementation is acceptable. Mc. formal pro-cadure is deemed necessary.

I Wo Corrective Action is contemplated. l l

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1 FINDING 5_.

The isometries and field fabrication drawings do indicate the classification of systans.

(

Rarponse_: No comment.

i, No Corrective Action required. ,

Procedure ISD-205 does contain a classification of systems PINDING 6. and the requirements for each classification.

b Response: No comment.

No Corrective Action required.

FINDING 7_.

The changes to isometric drawings and field fabrication drawings are indicated on the documents, as well as 'the reason for the change. Procedure KFP-9 establishes i.e., the a

mechanism to permit tracking of all revisions, Chief Field Engineer is required to maintain a copy of all voided drawings.

Response: No comment.

No Corrective Action required.

C Procedure KFPS-8 requires che Chief Pield Support Engineer FINDING 8. to assure that all supports are fabricated to the latest No mechanisa exists to comply with this drawing revision.

requirement.

Q.A.

Response: Pipe supports are part of the total piping, system.

Manual KFP.4 Paragraph 4.3.7 requires the Chief Engineer to assure that all systems are built to latest drawing revision prior to test.

ESD-253 covers pipe support ESD 239 requires release from drawing control in detail.

support engineering before closeout.

No Corrective Action required.

e

(

l l

11 I

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CRITERION IV. PROCURDENT 'uoCUMENT CONTROL FINDING 1. Procedures KFP-6 and KFPS-5 adequately describe the respon-sibilities associated with field purchase order processing.

• Response: No comment. ,

No Corrective Action required.

NNDING 2. Procedure ESD-226 adequately describes the quality require-ments for purchase specifications of the usual Pullman Power Products scope of purchased materials.

Response: No comunent.

No Corrective Action required. .

FINDING 3. Procedures KFP-6 and KFPS-5 do not require that the purchase order state that Pullman Power Products is given the right to audit the subcontractor shop.

l Response: All vendors or subcontractors are placed on the Approved Vendor List as a result of successful surveys and yearly audits by the Q.A. Department, Williamsport. Field purchases must be made from the Approved Vendor List issued by Corporate Headquarters.

No Corrective Action required.

FINDING 4. No written procedure permits verification of the selected supplier as one identified on the Pullman Power Products corporate-approved vendors list.

{

Response: Q.A. Manual Section KFP-6, Paragraph 6.3.6 requirer that the Q.A. Manager review all requisitions to verify that the supplier is on the Approved Vendors List. A separate procedure is superfluores.

No Corrective Action required.

FINDING 5. There is no mechanism by which Pullman Power Products Corporate is informed of the procurement of safety-related parts, com-ponents, equipment, and material to assure that the selected supplier is placed on the Corporate audit schedule.

Response: As noted in 3 and 4 above, suppliers must appear on the Approved Vendor list prepared at Corporate Headquarters.

All suppliers are audited on a yearly basis.

Copies of all Field Purchase Orders are sent to the

( Construction Engineer in Williamsport.

No Corrective Action required.

i

CRITERION V. INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS

( There is no requirement that activities affecting quality FINDING 1.

shall be prescribed by documented instructions, procedures, .

and drawings.

Response: We disagree with this finding. The Q.A. Namai s in Sections KFP-1, Paragraph 1.13, KFP-8, and KFFS-1 all specifically require that activities affecting quality b be identified on the field process sheets by specific reference to the special process procedure by number.

Welding procedures by number, NDE procedures by number, ecc. Specific ESD's listed give the detailed instructions.

l No Corrective Action is required. 1

=

i FINDING 2. Many activities affecting quality are not described in procedures. Among those activities are: hanger package review, pre-heating for welding, use of Note-O-Grems, use of Rejection Notices, and maintenance of Field Quality Inspector Daily Logs.

Response: Ranger package review is covered by KFPS-12. ESD-253, describes hanger drawing control. A detailed check list for hanger review needs to be developed.

( Preheating for welding is covered in the Weld Procedure Specification. ESD-218 also describes preheat require-ments. Preheat temperature range is also listed on the process sheet. When specified, it was performed and documented on the appropriate process sheet.

Note-0-Grass, Rejection Notices, and Inspector Iags are internal working tools of the Q.A. Department primarily for status reporting and record. They are intended to make the system more fool-proof by reducing verbal coinnunication to a minimum. Special procedures for these appear to be superfluous..

Corrective Revise ESD-254 to include hanger sad restraint check list.

Action:

a l

FINDING 3. Many activities affecting quality are insufficiently described in procedures. Among those activities are:

isometric package review, post-welding heat treatment, nonconformance reporting, Ninety-Day Walders' Log and Weekly Qualified-Welders List, and auditing,

.k

[

Responre:

Iscatetric package review requirements are described in ESD-254. "

(

Post veld beat treatment is covered by ESD-218 and weld _

procedures. .

Non-conformance reporting is adequately covering in ESD-240. 4 b Ninety-Day Walders' Log and Weekly Qualified Walder Corporate Auditing is covered by our Q.A. Manual KFP-18.

audits are conducted by selected, qualified personnel from Williamsport Headquarters under a qualified lead auditor.

A copy of the Corporate Audit Procedure XVIII-1 is available from the site Q.A. Manager. ,

In the past, there have been 16 NRC audits, 2 ASME audits, 9 management audits,1 independent audit and 40 PG&E audits of Pullman for a total of 68, performed at this site to verify performance to applicable requirements.

No Corrective Action is required for any of the above items.

FINDING 4_.

The present procedures are generally inadeq$aate for providing f direction te those performing the work. The procedures do

\ not follow the flow of the work; many procedures are very long (over 10 pages); insufficient inforration is given; important information is not provided or referenced in the procedure.

Rerponse:

This is a very general statement which is impossible to track due to lack of specificity.

All procedures now in effect, have been reviewed and approved by PG&E.

A review of all procedures will take place under Corrective l Corrective Action for Criterion I, finding 6. I Actior.:

i

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CRITERION VI. DOCUMENT CONTROL

(

FINDING 1. Procedures IFP-9 and IFPS-8 are adequate for field drawing

• control, and Procedure ESD-253 is adequate for pipe-support l drawing control. .

l Responre: No comment.  ;

e No Corrective Action required.

i FINDING 2. Procedures KFP-17 and KFPS-15 are adequate for control of the KFP and KFPS procedures and are appropriately implemented.

Respon_s_e : No comment.

No Corrective Action required.

FINDING 3. There is no procedure for control of ESD procedures.

Response: ESD's have been controlled in the same manner as the Q.A. ,

Manual. Their control is not specifically governed by l vritten procedures.

Corr ective Revise Q.A. Manual KFP-17 to include control of ESD procedures.

{ Action:

7INDING 4. There is no procedure for control of Special Quality Assurance Instructions.

Response: Special Quality Assurance Instructions are used for clarification of ESD's.

I Corrective Corrective action of Item 3 above vill include definition and l Action: control of Special Q.A. Instructions.

l FINDING 5. The Fullaan Power Products review of completed packages relative f to hangers and pipe restraints is not detailed in a procedure, i

nor is ESD-254 complete as to what is actually done for the isometric package. Procedure ESD-254 does describe some . l aspects of " Piping Systen Doceentation Review".

Response: ESD-254 is intended to cover the entire piping system which incorporates hangers and restraints and the syste is l

working effectively. Specific hanger information is not covered on the check. lists.

Corrective Revise ESD-254 to include henger and restraint check list.

l

(-

4 Action:

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1 The Fullaan Power Products log, Drawing Control Index FINDING 6. (KTP-9 and KFPS-8), is maintained in a nonpermanent manner.

7 The los is filled out in pencil; and when the number of -

O revisions exceeds the available space, the early revisions .

are erased to accommodate the new revision.

Response: The purpose of the Drawing Control Index is to assure theit all site departments are working with the latest drawings.  ;

Once a drawing has become obsolete, the record of when it U was received has no meaning. Accordingly, we have not

L b

concerned ourselves with maintaining a record of obsolete drawings.

No Corrective Action anticipated.

FINDING 7_. No mechanism assures that the Pacific Gas & Electric Co.

drawings being used as the ref erence drawings are tMe latest issued revi, ion. Audits are frequently performed to determine that Pu1 M n Power Products Bovever, the hasaudit the latest Pacific Gas & Electric Co. drawings. I mechanism is not satisfactory when it is the only mechanism.

It is PG&E's obligation to assure that we receive the latest drawings. As they are received, they are logged in

Response

PG&E -

l the Drawing Control Index as outlined in KFP-9. Since" August,1977, J

personal regularly audit this document.PG&E has been forwarding, on a m

( latest drawings.

No Corrective Action required.

There is no Weld Rod Requisition for one of the welders FINDING 8. 04-500-139.

who participated in FW-345 of isometric

Response

W-345 was welded by several welders including welder "LB".

Rod requisitions are available for all but "LB".

Records indicate There that "LB" welded is a requisition for rods on on FW-345 FW-346and PW-346 on the same day.

Rod withdrawn for FW-346 is the same type for Welder "LB".

and heat number as that withdrawn by others for FW-345.

FW-345 and PW-346 are both welded in accordance with the

• same procedure.

to verify that proper ESD-215 requires the field inspectorBe was not necessarily required to verify veld rod was used.

requisition as it related to the specific weld number.

Since this incident, all requisitions are reviewed by the welding inspector for weld number, welding procedure,

(. electrode, and welder symbol.

No Corrective Action is required.

_i s.-

• e

FINDING 9. There is evidence that documents have been backdated and changed to meet requirements without any substantiation

( of the information.

(a) For Isometric 2-14-77: The Process sheet was

• changed to show the completion of m192 on

• April 10 and April 11, 1974, approximately 19 months af ter the work was done.

~

(b) Isometric 2-14-8: FW-1673 was performed to 6 Revision 2 of the isometric, which did not show W-1673. Revision 3 of the isometric, which included the W-1673, was generated approximately one week af ter completion of the weld. It is, therefore, concluded that FW-1673 was performed without the normal controls of a Process Sheet, a weld procedure call-out, and a call-out of .

NDE requirements.

(c) Isometric 2-14-53: FW-247 was completed February 20, 1975. Approximately December 1, 1975, the visual acceptance was signed off and back-dated; and the Weld Rod Requisition was changed to show that more than the original quantity of one had been burned.

(d) Isometric 2-14-59: FW-268 was completed February 5, 1975. On Dec eber 2, 1975, the

( entry on the Process Sheet for removal of daar was signed off and backdated. There is no proof that the dans had been removed.

(e) Isometric 2-26-417: FW-144, 145, 196, and 197 were completed on May 14, 1976. The Wald Rod Requisition had been altered to add FW-197. However, the Weld Rod Requisition shows that 14 rods had been burned, which seems improbable for the four welds that were supposedly welded.

Response: (a) For Isometric 2-14-47: The weld was completed but not exsmined by FT until 19 months later. It was then accepted.

(b) For Isometric 2-14-8: FW-1673 did not show on Revision 2 of the isometric. During the installation te the required Process Sheet, it was determined that an additional weld (FW-1673) was required. In the earlier days, Field Engineers, in conjunction with the Field Q.A. Inspectors, were permitted to initiate field proces's sheet revisions with the required information. The Engineers revised the process sheet and marked the working drawing with Field Q.A. Inspector approval. This information was

( transmitted to the office where the original iso-metric was revised. The Process Sheet and all required documentation for FW-1673 are in the Isometric Record Package.

~_

I i

Response: (b) Present procedures require that the need for added f (Cont.) welds be reported to the office where the original drawing is revised before a new process sheet is

!( prepared.

(c) For Isometric 2-14-53: During an in-house audit,,

the Pu11msn auditor noted that a visual inspection point for W -247 was not initialed by the Field Q.A.

Inspector. The inspector verified from his daily work log that he had completed the required inspection.

g He accordingly signed and dated the sheet as of the

- inspection date.

Records indicate that the requisition change was initiated by a Q. A. Inspector.

Current procedures require initials and date. I (d) For W-2-14-59: Records indicate that this was a Code class 3 veld made with a backing ring. No dans were used. The standard process sheet form requires verification of dam removal. Field Q.A. )

Inspector should have indicated "Not Applicable" rather than signing this point.

. (e) For W-2-26-417: Field weld numbers W -144-145-196 and 197 are 3/4" socket velds. The required fillet is approximately 1/4". Fourteen (14) rods are sufficient.

{ Field Process Sheets have provisions for more than one weld on a sheet although separate entries are required for each weld. Process sheets show that all welds were completed on the some day.

Procedures permit a single requisition for not more than four (4) socket velds at a time. The field Q.A.

Inspector noted that suf ficient rods were available to permit completion of W-197 and added this number tc the requisition. This precluded necessity of the welder returning unused rods and obtaining a new requisition and rod for one 3/4" socket veld solely for record.

No Corrective Actio2 required for any of the above. .

FINDING 10. No procedure or requirement prohibits the changing or alter-ation of the records and documents that are necessary to track the work. Field Process Sheets, Weld Rod Requisitions, inspection records, etc., should not be changed or should be changed only by Quality Assurance supervisory personnel and i

then signed and dated.

(: Response: A Pullman audit of December, 1975 pointed out the subject of changer without dating. The requirement for initials and date appear in ESD-254 on a check list.

I l

l Revise ESD-254 to specifically detail the need for initia o corrective _ and dates on record changes made by Q.A. personnel.

Action _: -

FINDING 11. Procedures KFP-14 KFPS-12, ESD-239, and E ,

assembled and the system is ready for turnover, Response _:

This statement seems to negate part of the statement on Item 5 regarding isometric packages. k:

l W No Corrective Action required.

8

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i 19-I '~ _ _ _ _ , _

*"7*-,_. , _

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l CONTROL OF PURCHASED MATERIAL, EQUIPMENT. AND SERVICES _ {

CRITERION VII. i

( ,, i FINDING 1. The interf ace between the Pullman Power Products Pield -

Organization and the Pullman Power Products Corpora $e Crganization relative to selection and monitoring of -

suppliers' fulfilling field purchase requisitions is inadequate.

This finding does not cite any specific supplier I Response: This or b purchase order which was found inadequate. Pullman conclusion is not justified by the evidence.

Power Products corporate organization through the Quality Assurance Department in Williamspert maintains the updated Approved Vendor List which is used throughout the Pullman Power Products organization (including Diablo Canyon) for use in procurement of materials from qualified suppliers. All suppliers are accepted on the basis *of appropriate ASME Certificates or a Pullman survey.(See also Criterion IV Vendors are audited annually.

Items 4 and 5).

All field purchased material is subject to field receiving inspection as outlined in KFP-7.

No Corrective Action is required.

( FINDING 2.

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

Response: No comment.

No Corrective Action required.

l I

4

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CRITERION VIII. IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS _ )

( p Identification and control of piping and valves are adequately -

FINDING 1_. .

spe-ified by Procedures ESD-200 and ESD-201. .

Response: No comment. . l No Correctiva Action required.

6 Identification and control of weld material are adequately FINDING 2_.

specified by Procedures KFP-12. KFPS-31, and ESD-202.

Response: No comment.

No Corrective Action required. ,

Identification and control of backing gas dans are adequately FINDING 3_.

specified by Procedure ISD-214.

Response _: No consnent.

No Corrective Action required.

Procedures KFP-8 and FIPS-7 are adequate for specifyingdthat

( FINDING 4. the identification of parts and components is to be recorde The implementation of this on the Field Process Sheet.

procedure is adequate.

Response: No ecument.

No Corrective Action taquired.

The isometric drawings and field fabrication drawings are the FINDING 5.

major documents for recording the identification of the parts,W spools, and components.

ment, this mechanism has been followed and is an excellent technique.

l ,

l Response: No comment.

l l

No Corrective Action required.

Identification of welds and welders is adequately described 71NDING 6. in Procedures ESD-203, 204, 221, and 243.

Response: No comment.

k No Corrective Action required.

i

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FINEING 7. Proper methods of marking ars specified in Procedures ESD-200, 201, 202, 203, 204, 221, 223, and 243.

(

Response: No causent. .

No Corrective Action required. .

EINDING 8_.

Material control techniques for temporary pipe attac}unents are adequately described in Procedure ESD-232.

b R'esponse: No comment.

No Corrective Action required.

FINDING 9.

Procedure ESD-248 adequately describes controls for the repair of installed valves and for valve parts control.

Response: No comment.

No Corrective Action required.

FINDING 10. Adequate control of snubbers, plate, and other components is achieved by using Procedures ESD-200, ESD-201, KFP-8, KTPS-7, and the practices associated with field drawing preparation.

However, no procedures specifically address these items.

Response: Snubbers, plates, and other components are covered in F9D-223, 243, 261.

No Corrective Action required.

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

Response: No comment.

No Corrective Action required.

i FINDING 12.

Procedure ESD-223 does not give adequate instructions for the identification and control of Class I Pipe Supports.

Response: We disagree. ESD-223 is adequate.

No Corrective Action required.

FINr.ING 13.

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

l Easponse: No comment.

No Corrective Action required.

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' CRITERION IX. SPECIAL FROCESSES

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FINDING 1.

Nondestructive namination has been properly specified as a -

special process. procedures KFP-3, KFPS-3 ESD-235,, an.1 ESD-256 adequately specify requirements for NDE personnel.

Respor.se: No consnent. .

No Corrective Action required.

b FINDING 2. The requirements for Field Quality Assurance Inspectors are adequately specified in Procedures ESD-237 and ESD-256.

Response: No commert.  :

No Corrective Action required. l FINDING 3. The qualification and certification program for NUE and The records of inspection personnel has been inadequate.D. R. Ceske, the following persornel were ammined:

T. L. Koch, J. E. Cavelti, G. p. Keeler, K. E. Beck, L. Glass, W. E. Johnson, E. Stanton, C. B. Athay, R. G. Sears, '

D. S. Tutko, J. N. Shironizu, V. J. Casey, J. A. Brasher, L. F. Myrick. S. R. Stanley, H. Guest, D. E. Bentley, R. D. Kincade, K. D. Guy, J. R. Bowlby, E. R. Jennings,

(- A. L. Newton, C. C. Lanzi, J. J. Sisk, L. G. Thomas, A. A. Conques, and R. L. Marks. In virtually all cases, the individuals began performing their duties without The most prevalent fulfilling the specified requirements.

discrepancies are: not completing the required training, not having proof of previous experience, insufficient time

as Level I, unsigned teste, and insufficient background and experience.

Response

The finding fails to diff,rentiate between NDE personnel and inspection personnel.

A review of the files (certificates and ewsminations) indieetes that all NDE personnel had completed the exam-inations specified by ASNT-TC-1A as required by our l original Q.A. Manual, before they were allowed to perform

• l any work. They were trained under the General Dynamics program but doceented evidence in terms of subject matter and hours spent is not available.

A review of the files indicate that all NDE personnel either had ree.uired experience and background to permit

, immediate qualification to Level II, or that they took l an esswination, worked the prescribed time as Level I and subsequently, passed a Level II examination before

(.

being allowed to work as Imvel II.

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_ . _ . . _ _ _ _ _ _ _ . _ . . _ _ . _ . . - . . . _ . _ . _ _ . . - . . _ . . . _ _ _ . _ _ , _ . . _ _ . . - . . . _ . _ _ , . _ , . . , _ _ , _ , _l

i

====4 nations were graded but l

Response: Records indicate that some NDE There are no requirements (Cor.c. ) not signed by the Q.A. Manager.

( for this. The Q.A. Manager did sign the Certificates and j identification cards as evidence that satisfactory test .

[ results were attained for the Level an==ined. .

i t

All current inspectors have been qualified by test as *  !

j

• outlined in ESD-237. -I Requirements for qualification and certification of field b inspectors were added in ESD-237 on September 25, 1973 to reflect the requirements of ANSI N45.2.6 just published.

! Persons hired before this time were not necessarily tested l

at time of hire. Subsequent to 1973, the records indicate l that all inspection personnel received required training and examination.

No Corrective Action is required.

1

FINDING 4. NDE procedure qualification is adequately described in Procedures KFP-2 and KFPS-2 as being the responsibility l

• of the Manager of Quality Assurance, Williamsport

' Headquarters, i

Response: No comment.

1 No Corrective Action required.

l i

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1' 1

TINDING 5. Welding has been properly specified as a special process.

i I, Rerpor.se : No come.nt.

!' No Corrective Action required.

[i h

FINDING 6. Welding procedure qualifications are adequately described l in Procedure KFP-15 as being the responsibility of the Welding l Engineer (Williamsport).

l Response: No coment.

i

! No Corrective Action required.

I.

t FINDING 7_.

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

Response: No coment. .

No Corrective Action required. I

( l 1

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FINDING 8. The certification of the follow 1ng welders, by weld symbol,

( was eFamined and found acceptable: U, AN, IB, PO, VD, QZ, HY, PD, JL, ET, HL, AY, MO. TQ IQ, PG, KP, IC, PC, and ZC.

Response: No comment. ..

No Corrective Action required.

FINDING 9. The certification of welder U was not signed.

Response: The qualification records indicate that velder "U" was successfully qualified. The velding engineer failed to sign the certification at the time.

Corrective Field Q.A. Manager has reviewed the qualification record and Action: will attest in writing on the certificate that velder "U"

records indicate he was properly qualified.

FINDING 10. A number of procedures provide nachanisms for control of the velding process: ESD-203, 204, 215, 219, 221, 225, 242, and 243. However, the control of the welding process has been inadequate as follows:

C loa) Records of welder qualification prior to 1972 are not available.

Response: The first job weld was done on December 28, 1971. A record of the welders qualification for this first veld is dated December, 1971. No other welding in 1971.

10b) The Ninety-Day Welders' Log was not maintained from August, 1972 to December, 1972. There is no weekly Qualified-Welders List for that time period to sub-stantiate that the welders were actually qualified.

Respense: There is a void in the 90 day weld log from August,1972 to December,1972.

By reviewing welding records, a qualification status for this period has been reconstructed. All welders were found to be within the 90-day requalification period. Records' are sva11able for review.

No further Corrective Action is required.

loc) The Ninety-Day Welders' Log is not sufficiently detailed to determine if the welder is qualified to perform certain procedures. The Ninety-Day Welders' log has been revised

(-

a a number of times, and the detail has improved with each revision. Previous to the latest revision Giovember, 1974),

the log was very poor in giving precise information relative to procedure and thickness ranges to which the welder was qualified.

l l

. =

loc) Cent. The 90 day Walder Status 143 was modified and improved on Response _:

several occasions. It is intsaded to assure the welder remains qualified by process. The Code requires requal-

{ ification in the event the welder did not use a process within 90 days. Specific welding procedures or specific ,

thicknens range of qualification are not part of this -

i'orn . They appear on each qualification certificate.,

I No Corrective Action is required.

5 10d) No procedure states what the Field Quality Assurance Inspector uses as the primary means to determine welder qualification, the Ninety-Day Walders' I43, the Week.ly Qualified-Welders List, or the Walder's Qualification Card.

Response: The Q.A. Manual Section KFP-15 Paragraph 15.2.c indicates that the qualification status of each welder is kept on the 90 day Welders Status Log. The Inspection Supervisor prepares the Weekly Qualified Status List from the 90 day log and distributes it to the foreman and Welding Q.A.

Inspectors.

No Corrective Action required.

10e) Ne procedure gpecifies who is responsible for the Ninety-Day Welders' Log, the Weekly Qualified-Welders List, or C- the Welder's qualification Card; how the information is obtained; how the loss are used; to whom they are dis-tributed; etc.

Response: Q.A. Manual Section KFP-15, Paragraph 15.2 states that a field Q.A. Inspector appointed by the Q.A. Manager is responsible for velder qualification. This would include collection of qualification results, use of logs, and distribution of logs.

Cc rrective Requirements for qualification results, use of logs, and Action: distribution wilt be added to ESD-216.

10f) Procedure EFPS-13 differs from KFP-15 in that it does not permit a six-month extension of welder qualifications if )

i the welder has been actively welding on some other welding process. Procedure TFPS-13 requires the S welder

• to use the specific welding process within a t ree-month period or be requalified. There is no evidence of adherence to this requirement for pipe support welding.

Rasponse: EFPS-13 did not incorporate the option to permit extension of welder qualification to 6 months when employed on other welding processes. This is not a deviation, but merely I an omission. EFPS-13 has been revised accordingly.

(

No Corrective Action is required.

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I 1

l 10g) Walder BF (W. Adair, 251) performed welding on FW-70, 72,

( 73, 76, 77, 78,1005,132, aad 133 in isometric package 21-7 and FW-88, 90, 92, 134, 135, and 1608 in isometric paekage 21-8. This welder was act qualified for the

• thickness range; and the welds were reported on DR% 2536, I 2538, 2539, and 2899. In accordance with Facific Gas &  !

Electric Company disposition, some of the welds were radio-graphed and found acceptable; welder RF was qualified to

• the thickness range; and all the welds in questic,a'were accepted. This disposition is not permitted by 531.1, 4 ~B31.7 and ASME Section IX, which all specify that the velder must be qualified prior to making production welds.

Response: The deviation cited was found by pullman Quality Assurance and renorted to PG&E on appropriate deviation records.

Reference to DR-2536 is incorrect.

The auditor is completely incorrect in indicating that ASME Section IX, 331.1 and B31.7 do not permit welding prior to qualification. No such prohibitions exist.

DR-2538 Rev. 1 & DR-2539, Rev. I dated July, 1975 report 2-2" butt velds in Diesel Fuel 011 (1605 and 1008) made 12/17/73. Walder was not qualified for maall diameter (3" and undet) until 2/18/74.

Both DR's use the option to qualify the welder by radio- l 3raphy (see 1971 Section II Winter 71 Addendum - Paragraph

{ Q2 (a)) . Both production welds (1605 and 1005) were radiographed and found acceptable. PG&E accepted qualification on this basis.

DR-2899 dated August, 1975 reported 14 butt welds made prior to 2/18/74. Investigation shows these were 2 "

pipe size. Prior qualification by DR-2538 Rev. I and DR-2539 Rev. 1 covers qualification cf these seams.

No further NDE required.PG&E accepted seams on this basis.

10h) Procedure ESD-219 requisas random sampling of in-process welding, with the esspling to be noted on the Field Process Sheets. In aummining Field Process Sheets, it is obvious that the sampling by the area inspectors was not performed.

Response: ESD-219 requires random sempling of in-process welding,.

There is no requirement for recording on the process ,

sheet. Each welder is audited to a specific weld procedure on a production weld at least once every six weeks per ESD-219. The completed check sheet serves to verify this in-process check. There is evidence of sampling of in-process welding indicated either on process sheets or recorded 'in Inspectors Daily Loss.

Corrective Revise ESD-219 to permit recording of random sampling

(,' Action: checks, either on the process sheet, Inspectors Daily Log,

- or Wald Check List.

7

i dic auditing by the Weldingil November 5, f Procedure ESD-219 requires perioaudits were with not performed untt in comp 101) These

• Auditor.

1973; and Pullman Power ly 23Products months. was no ,

this procedure for approximate February, 1973 It was ,

i te auditing of welders.

ESD-219 was originally written in All welds, Rvponsej

~

revised in September,1973 to init awere begun in November, 1973d k

3 Audit reportsincluding those performed prior to auand required NDE to verif process, final inspections 6 acceptability.

No Corrective Action required.

i g stainless steel welds l I

10j)

Procedure ESD-219 requires monitor nHowever, the Severin Gauges 1973; and Pullman Power for ferrite control. i h this procedure for on site until the beginning ofPrMucts was not in comp approximately 12 months.

ll stainless steel filler From the outset of the project, a5 to 15% ferrite requirement.

Responsej material was purchased with a respond to the intentwere Severin gauges ESD-219 was issued February, 1972.

1973 to of Safety Guide 1.31 issued August, monitoring of complete receipt of Severin on site in early 1973 to implement d rior to These A sampling of completed welds ta e :preceipt of gauges. Welds made

{ gauges were checked subsequent ide 1.31.with ESD-219. ferrite per Safe toacceptable indicate after receipt of gauges were al No Corrective Action required. with Pacific Gas & Electric Bangers are not welded in accordanceRangers welded 2023-IV and 2039-2 10k) observed that are Company requirements. h examples of a number of hangerswrong to the structural steel on t eeviewed Bangers No. 2023-IV re welded in accordance Responre: Pullman and 2039-2V and found that they we Inspection personnel have rThis was pointed but NSC with customer drawings. Pullman asked that they reinspect, .

exit interview.

declined. eported.

No other hanger discrepancies were r No Corrective Action required.

suppliers' parts and 101) The interf ace of weldingts. to otherWelding The ascessity is done to joir components is not clear. ts for those bouse and Paramount parts and componenfo ents for Pullman Power

( voldoents is not clear; in ad If impact properties addressing impact property requiremf each weld that has be Products are necessary, fieldthewelds are not acceptability o clear.

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

101) repaired and subjected to more than one stress relief is Cont. indeterminate because of the time at temperature limitations (t within the qualified weld procedure.

l Response: Review of contract reveals that impact testing of welding .

l procedure qualifications was not required. Requireisen,ts for impact testing of procedure qualifications when required by customer specifications does not appear in 531.7 until 1972. Present procedures are acceptable.

E No Corrective Action required.

4 10m) Some welders do not receive sufficient training. Welders, fabricating the pipe rupture restraints within the contain-ment, are welding heavy plate. While these welders are qualified by virtue of welding heavy wall pipe, the techniques are difforent. The welders who were already qualified to heavy wall pipe were not given additional training on plate.

Response: Welders receive written instructions when qualified. These include rod requisitions, use of WPS, notification of Q.A. prior to welding, etc. All welders are qualified on pipe in required positions. The auditors seen to feel there is a difference in welding pipe and plate. There is, plate is easier. Note that ASME Section IX Paragraph OW303 indicates that for 1G and 2G positionr., qualification may be

(, made on pipe or plate interchangeably. In the SG and 6G positions qualification on pipe qualifies on plate but not vice-versa. We feel no added training is required.

No Corrective Action required.

lon) There is no procedure for the preheating of weld joints.

Response: Requirements for preheat temperature are given in each i

Welding Procedure Specifi. stion and shown on the Process ,

Sheet. , \

For pressure retaining materials. ESD-218 outlines the .)

provisions for installing resistance coils, blankets, These ,l thermocouples for post veld heat treatment. q l requirements apply equally for preheat, since preheat, weld l and g.st heat are carried on as one continuous process. -

i Corrective Reference to preheat will be added to title with specific Action: requirements in Paragraph 5.2 of ESD-218.

loo) The initial results of the welding auditing (from November 5, 1973 to February, 1974) indicate that the following problems existed:

(

em t K '

t

t loo) (1) The welders did not understand shielding f

\ Cont. and purging.

(2) Tempil sticks were not used. ,

(3) Asperages were not within procedure limits (mainly root welds and tack welds).

• (4) Wald procedures were not available, and 6

many velders did not know where to obtain them.

(5) The oxygen analyzer was not available or not operative. Also, the time vs. flow rate alternate technique was not used.

(6) Oven rod temperature control was not monitored i

by the welders.

(7) Many welders did not understand their duties and responsibilities.

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

(, welding specification requirements.

Response: The following is a response to each individual finding:

(1) Welders do undet stand shielding and purging.

During welder audits, it was found on few occasions that the welders were act operating within the criteria established. Findings indicated that welders were using higher flow rates than was permitted by the procedure. This is a non-essential variabic of the ASME Section IX Code. If there were problems associated with excessive flow rate, the resulting indications would have been porosity. This did not occur since velds were subsequently found acceptable by visual and nondestructive examination. 4 (2) In cases where welders were noted without Tempil Sticks in Internal Audit Findings, there was no indicatica on the " Welders Audit Sheet" that the interpass temperature was too high. It is, therefore, concluded that weld quality was not affected. Ferrite checks of welds where tempil sticks were not used show acceptable results.

(  :

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1 1

(3) Review of weld audit sheets revealed a small number of welders welding outside the pre-( scribed procedure superage range. Asperage is a nonessential variable and visual inspection l

and NDE examination indicates welds were acceptable.

i (4) Wald procedures are available. Each foreman,

general foreman, and QA inspector has copies of procedures. The welders are issued a b -

synopsis of weld procedures giving voltage and

' saperage range, and rod type and size for each procedure. Review of audit report indicates a small number of this type procedure deviation occurred.

(5) The inavailability of an oxygen analyzer at time of internal audit does not indicate that the veld was not purged. Accepteble NDE is an indication that purge was satisfactory. There appears to be no basis for the statement that the Time vs. Flowrate techniques were not impimented.

(6) The veld rod control procedure permits the exposure of weld rod without the use of an oven up to four (4) hours. In those cases CI where we noted oven temperatures to be less than that required by the procedures, we also noted that rod had been issued for less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. It was determined that weld quality

' was not adversely ef fected. The welders were required to have ovens repaired or replaced in each case.

(7) Walders were tested and met the Qualification Requirements of ASME Section II. They were issued written instructions indicating the requirements for securing weld rod, inter-pass temperature control, proper voltage /

amperage range settings. Their supervisor has also issued instructions to the welders on a daily basis as deemed necessary.

All the findings recorded above were derived from Pullman Field Audit per ESD-219. In each case, Corrective Action l was immediately taken. If it was determined by the Pullman l

Welding Auditor that the finding would result in defective i l welding,' further action in the form of discrepency report l- would have been initiated.- The items listed are ASME  ;

i Section IX Non-Essential Variables and do not necessarily i l inf er def ective welding. All welds were subjected to l fit-up, and finel visual inspection and NDE and found to l

t b- be acceptable.

a . _ _ _

FINDING 11. Welding procedures for carbon steel welding require pre-heat and interpass temperatures for material that has a

( carbon content in excess of 0.30 percent and a thickness of one inch or more. There is no mechanian by which the welder can determine carbon content. ,

I Response: It is not the welder's prerogative to determine the carbon content of any particular material. This is a requirement of the Engineering Department and the process sheet writer 5 will indicate the required preheat and interpass tesperature as a result of his review of the minimur specified carbon s content of the materials being joined. The welder need only follow the requiresents of the process sheet.

' No Corrective Action is required.

FINDING 12. Procedure ESD-221 does provide adequate guidance on weld repairs.

Response: No comment.

No Corrective Action required.

FINDING 13. Heat treating has been identified as a special process in the Pacific Gas & Electric Company contract (as well as in Appendix B), but it has not been controlled as a special

( process by Pullman Power Products.

Finding 14 below indicat.as that EFP-13 and ESD-218 do

Response

provide adequate controls for proper post veld heat treatment. We can only assume that the finding points out that we do not identify heat treatment as a special process in our Q.A. Manual. Beat treatment has been controlled as a special process, including operator training, and evidence of satisfactory performance is on file.

No Corrective Action required.

FINDING 14. Procedures EFP-13 and ESD-218 do provide controls of the post veld heat treatment process. The implesentation of Procedure ESD-218 is acceptable. .

I Response: See item 13 above.

No Corrective Action required.

FINDING 15. Cleaning has not been identified as a special process.

Cleaning is act identified in 10 CFR 50 Appendix "B" g

( Response:

as a special process.

Cleaning of components prior to installation and cleaning of surfaces to assure freedom free halogens are performed l

by Pullman to various ESD's, see Item 16 below. )

l

- .79p . , _ _ -

_ _ - , __O __

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by Cisaning of the systant prior to st:rtup is performed Respons_e: FG&E Co.

~

(Cont.)

No Corrective Action required. .

261 f

FINDING 16_. Procedures ESD-220, 224, 238, 242, 252, 2  ;

I the various materials, parts, and components.

E Rebonse: See Item 15 above.

No Corrective Action required.

ld Procedure ESD-231 provides some guidance on hot and coThe FINDING 17_. l bending of small bore piping. insufficient ll. to assure that the be to avoid high stresses and thinning of the wa All stainless is 2 inch and maaller.

Response: All piping field bent That inside the containment was steel was cold bent. solution heat treated, pickled, and passivated to eliminate any stress corrosion problem.All of this conforms containment was installed as bent.

to PG&E specifications.

( _ Corrective A sampling of bends has been measured for Action: Results indicate all are above the required minimum wall.

ESD-231 has been revised tc require UT thickness check on future bends.

Procedure ESD-238 provides adequate instruction in

~

FINDING 18. torquing of bolting for pipe flanges.

Response: No comment.

No Corrective Action required.

Procedure ESD-259 provides adequate instruction for FINDING 19. installing Grinnel Snubbers.

Response _: No coment.

No Corrective Action is required.

l Procedure ESD-224 provides excellent instruction for PINDING 20. assembly and torquing of installed valves.

Response _: No comment.

No Corrective Action is required.

~~.

_ _ . _ _ _ _ _ _ _ _ - . _ _ . - _ ___ _ _ _ _ _ _ _ . ~ - _ _ - . - . _ _ ,- _ _ __ ._._ _ _ . _ . . _ - _ _ . _ . _ . . _ - . - - _

( FINDING 21. Procedure ESD-260 provides adeeuate instructions for installation of Williams Rock Bolts.

Response: No comment. .

No Corrective Action is required.

L FINDING 22.. Procedure ESD-230 provides good instructions for entering an installed line.

Response: No comunent.

I No Corrective Action is required. ,

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CRITERION X. INSPECTION FINDING 1. Procedures KFP-5, 8, and 14 thoroughly describe the interface between Pullman Power Products and the . .

Authorized Inspector.

Response: No comment.

L No Corrective Action required.

FINDING 2. Procedures KFP-8 and KFPS-7 provide the requirements for the Field Process Sheet, which specifies inspection points and inspector sign-off.

Response: No comment.

No Corrective Action required.

FINDING 3. The Field Process Sheet references procedures to which the work and the inspections will be performed.

Response: No comment.

No Corrective Action required.

FINDING 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, 249, and 260. These procedures sra, in general, broad descriptions of the inspection process for the total range of the work scope and are adequate for that purpose.

Response: No cosmnent.

No Corrective Action required.

FINDING 5. For all inspection processes, there is no mechanism to provide the inspector the particular characteristic to ,

be inspected; the particular acceptance criteria; the particular methods and equipment to be used; and r provisions for recording results, other than acceptance for the particular inspection being made. The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures i that specify the use of particular equipment (such as i some of the ultrasonic procedures).  !

Response

The process sheet indicates each point where an inspection or aramination is required and references the appropriate procedure number. Each procedure defines the inspection requirements, equipment, and accept-reject criteria.

No Corrective Action required.

- - - - , ,-.n - r - - .-.- ---e- - . - - - rn., ,, . - , . - - - - . - - - - - - - - - , - . , .

The FINDING 6.

The inspection process is generally not auditable.

{. practice of exhibiting an acceptance signature only does not permit auditing to determine if the individual .

characteristics were e===4ned, the correct criter,ia were )

used for acceptance, and the correct specific measur,ing devices werc used.

An acceptance signature indicates that the requirements of the referenced procedure were met. We have had audits Response _:

by ASME, by the NRC, PG&E, by Hartford Steam Boiler, and k the State of California, and our own independent auditing Had the companies, as well as Pullman Power Products.

inspection process not been acceptable or auditable, these other agencies would have brought this to our attention long ago.

No Corrective Action required.

FINDING 7.

A large number of welds in Unit 2, System 14 (W -110, 111, and 112 in isometric package 2-14-31 are examples) were accepted for visual examination and thereaf ter accepted based on surface NDE inspection (MT or PT).

Visual examination of tipse welds indicates that the surface is not suitable for the performance of surface NDE inspection.

t Records indicate that W-110 was penetrant examined.

Response

W-111 was mag particle examined, FW-112 and a repair was was mag pa- icle subsequently penetrant examined.

examined.

When these items were called to our attention, paint was removed from the welds and all welds wereFW-110, visually inspected and penetrant examined.

W-112, and the repaired area of W-111 were effectively examined. FW-111 (originally M.T.) had some interbead crevices which contained residual paint. The paint produced several broad indications which were notVisual esamination considered relevant.

could be offactively mas particle esamined.

Welds cited appear to be the worst cases from the group*

I reviewed.

No further Corrective Action is required.

For N-110 (isometric package 2-14-31), the Process Sheet FINDING 8. indicates that NT was performed; however, the inspection sheet for PT shows that weld ausber, and the inspection sheet for NT does not show that veld number.

(

PT or NT are equally acceptable methods for inspecting

Response

this weld.

• Recording indicates PT. -

Process Sheet called for MT. Inspector signed Inspection Po .

Sheet revised to indicate PT.

A review of all Process Sheets was made DRto was verify that Corrective actual process used is on the Process Sheet.

_ Action:

k issued to cover those items found in error.

g No further Corrective Action needed.

j W-83 (isometric package The1-10-9) radiograph was of FW-83repaired does in accordance FINDING 9. inked onto with a valid Process Sheet.

not exhibit the required R1 symbol, but R1 wasThere is a sur the radiograph. i questionable for acceptance to visual standards.

R1 symbol was inadvertently omitted Response _: PW-83 was repaired.from radiograph (R1 was inked on) and weld su by Alleged surfece defect was inspes.*ed independently ble.

two Level III personnel and found a be accepta R1 symbol has been added to weld.

Corrective

( _ Action _:

llman Isometric package 1-03-1 has a step that requires a PuThis requi FINDING 10. &

Power Products inspector sign-off. removed, and the Electric Company employee.

i The inspection in question There is was a clean and no requirement that fit-up this operat on.

Rtsponre: "C". This is an isolated It was Code Class operation be witnessed r d signed off.This procedure has not problem which occurred in 1972.

been permitted since that time.

No further Corrective Action required.

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CRITERION XI. TEST CONTROL

(

FINDING 1. Procedure ESD-229 adequately defines the methods and ,

inspections relative to performing hydrostatic tests.

~

Response: No comment.

[ No Corrective Action required, b

FINDING 2. There is no description of the responsibilities of Pacific Cas & Electric Company or of the Pullman Power Products / Pacific Gas & Electric Company interface to hydrostatic testing.

Response: A complete description of the extent of each hydr.otest is prepared by PC&E and given to Pullman. Pullman personnel performs the test under guidance of PG&E employees and to their specific requirements. All records are complete and acceptable. Clarification cf interfacial relationships will be covered in response to Criterion I, Finding 6.

FINDING 3. Procedure ESD-229 is not adequate foz describing the (f flow and authorities relative to the individual hydro-static test procedures to be performed.

Response: ESD-229 is a general procedure for conducting pressure tests. Specific test limits, requirements, authority, are all furnished by PG&E in a written procedure for each test. See response for Finding 2 above.

No Corrective Action required.

FINDING 4. Hydrostatic test packages 7-2, 7-2A, 8-12, 9-12, 106, 106A,106B, and 64 were examined and found acceptable.

Response: No comment.

No Corrective Action required.

FINDING 5. The B31.1 and B31.7 Codes require that all piping is leak-tested, where practicable. Pullman Power Products is only leak-testing Class A and B piping and that l Class C piping sp,ecified by Pacific Gas & Electric Company. Classes D E special, and E piping is not being leak-tested. A letter from Pacific Gas &

Electric Company (dated Jamaa:y 13, 1976) does exist,

{' which states that Pacific Gas & Electric Company will assume responsibility for the leak-testing of Class C piping. There is concern that Pullman Power Products is not discharging its contractual obligations (that

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l yINDING 5_ specify compliance to B31.1 and 331.7) by not performing

,f piping leak-testing to Code requirements for Classes C,

!1 (Cont.) D, E special, and E piping systems and, as a result, .

ti may be legally vulnerable. *

')

Response

Pullman is hydrostatically testing Class A & B piping '

l -

to the Code. I' I

There is a letter on file from PG&E which relieves I' Pullman of respontibility for Code compliance on In 6 Class C (331.7 Class III) relative to hydrotest.

some cases, testing is performed at less than Code B31.7 requirements because of limiting components.

' paragraph 737.4 permits an upper limit of hydrostat Balance 1.25 design pressure exceeds component limits.

of systems are given an initial service leak systems test as are permitted by Code. None of the Class "C" Code stamped if hydrotest is not per Code.

There is no Class "D" piping.

Class "E" and Class "E Special" are B31.1 Systems.

I Most are tr.sted per Code, some at less than Code because of limiting components and others are given initial service leak tests as permitted by the Code.

In our opinion, the owner, PG&E is ultimately respon-sible te the NRC for the suitability of the system.

In following their instructions, we are fulfilling our contractual obligations.

No Corrective Action is required.

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CRITERION III. MEASURING AND TEST EQUIPMENT Procedures KFP-11. KFPS-10, and ESD-213 describe. an -

l FINDING 1.

adequate calibration program.

• 1 Reeponse: No comment.

5 No Corrective Action required. I b

The calibration program did not require recalibration FINDINC 2_.

of thermocouples until June 16, 1976. Therefore, there is no ar surance of the accuracy of thermocouples used for and post-velding heat treatment prior to June 16, AW 6. Newly purchased thermocouples were However , ,

required to be calibrated by the manufacturer.

the manufacturer's calibration does not assure tfiat the thermocouples have not been damaged during handling and shipping.

All chermoccuples have been and are purchased with calibration. Prior to June,1976, there were no require-

Response

When the ments of recalibration of thermocouples.

program was initiated, all existing thermocouples were .

11041200 Code requires heat treatment in the range of which is f airly wide. In addition, each weld joint has Any thermocouple with more than one thermocouple.

significant deviation would show as widely divergent

~from the others on the charts.

No Corrective Action required.

The calibration program has not been adequately implemented.

FINDING 3.

3a)

Paragraph 11.5 of Procedure KFP-11 and Paragraph 10.5 of 2 Procedure KFPS-10 require reinspection of materf als and components if the measuring Except and for testhydrostatic equipmenttesting is found to be out-of-calibration.

and heat treating, the identity of measuring and test equipment is not related to the inspections performed.,

Response

The system now in effect requires recording of the instru-ment serial missber used on each inspection, thus permitting reinspection of work if instrument is found to be out of calibration. .

As noted, Eydrot'est sages and Beat Trastaant Recorders were found to be satisfactory.

(

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Response: Torque wrenches were used for the most part on rupture restraints to AISC requirements which required daily Accordingly,

/ (Cont.) calibration of each wrench prior to use. ,

1 the wrenches were calibrated but the serial number of .

the wrench used was not recorded. Some bolted pressure joints were torquod with calibrated wrenches, bu't serial numbers were not recorded. Any leakage would-tava been detected in hydrotest.

PG&E has reviewed previous records and finds no out-I b of-tolerance condition which would result in over-

~ stress of bolting.

Tong Testers are used only to monitor welding emperage Due to which is a non-essential variable in welding.

the wide range of amperage permitted, a deviation on the Tong Tester would not be detrimental. .

Correc tive The procedures have been revised to require recording of instrument serial number on inspection or audit

_ Action:

sheets.

l A 100% review of all torque records were made to assure l that correct torque was applied.

A program of random verification of torque loads is l underway.

i

b 3b) Procedure ESD-213 does not contain a mechanian to report out-of-calibratica measuring and test equipment to Some forms used by the calibration Pullman Power Products.

subcontractors only contain provisions for attesting to calibrating the equipment to appropriate standards and have no provisions for recording the actual values obtained.

Response

The only items for which calibration is subcontracted are tong testers and potentiometers.

For tong testers, see response in prior finding.

l Unless a potentiometer were badly out of calibration, the very wide range of heat treatment temperature permitted A badly out-of-range by the Code would not be violated.

potentiometer would have been called to our attention by the subcontractor.

Procedures now require vendors to report actual values Corrective of deviation before recalibrating equipment to permit ,

Action:

review. of any previous' work.

7. ,

3c) The calibration records of recorders were confused by having two recorders identified on one record and the

( acceptability of the records could not be determined.

Response: There are separate calibration certificates for each ,

recorder'on file attesting to their acceptability.

The Calibration Inspector recorded both instruments on one card.

l torrective Separate record cards for each instrument are prepared and now on file. This has no effect on work performed. l sction: \

l 1

Severin Gauges 2947 and 2971 were received on the site l 3d )

fn January, 1973. Initial calibration was August 29, 1973; and the next calibration was November 19, 1974 for gauge

• 2947 and January 23, 1975 for gauge 2971. Procedure ESD-213 requires annual calibration.

Response: There was a strike during the period June,1974 to November, 1974. Calibrations were allowed to lapse.

Both were recalibrated as soon as needed.

No Correccive Action required.

3e) Magnetic Particle Test Equipment T-6 has no documentation

(' to verify calibration.

Response: Magnetic Particle Equipment consists of yoke type ~

equipment. Calibration consists in determining whether yoke is capable of lifting a 10 lb. weight. No tolerance is involved. A card is on file which indicates the yoke capacity was checked as required.

No Corrective Action required.

i 3f ) There is no documentation available to verify calibration of " Tong Test" asp meters.

l Rerponse: There are calibration certificates from the subcontractor and cards in the calibration file atter. ting to the docu-mentation.

No Corrective Action required.

33) " Tong Test" o p seter TI2527403 was out of calibration for the pe'riod December 12, 1976 to January 31, 1977. No DR has been written against that tastrument.

It is rarely

(; Response: Tong Tester mentioned is of the 0-1000 range.

- used. It was not used in the December 1976 to January 1977 period and so noted on the calibration card file.

No Corrective Action required.

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Storage requirements for instrraents are not specified.

Response

There are no specific requireaants for construction equipment storage and consequently no written instructions ,

{

were prepared. I Tong Testers, micrometers, hydrotest sages, and small, torque wrenches are stored in locked file cabinets in the Q.A. office.

h

' Temperature recorders are normally in use, but when stored,

[ are in a heated warehouse. Large torque wrenches are stored in a heated warehouse.

ESD-213 environmental control indicates that each Q.A.

Inspector is responsible for calibrated tools in his area. .

No Corrective Action required.

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f CRITERION IIII. HANDLING, STORA_G,E,, AND SHIPPING

(

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FINDING 1. Procedures ESD-202, 215, 217, 222, 223, 240, 25%, and l

261 provide some information relative to handling and storage of materials, parts, and components for the total scope of the Pullman Power Products effort. *

I No comment.

B.esponse:

No Corrective Action required.

FINDING 2. Procedures for storage are generally inadequate.

Procedures ESD-222 " Control Valves" and ESD-202,

" Weld Material Withdrawal and Control" 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 of storage areas reistive to the protection each area provides. l Response: In genera 3, storage conforms to N452.2. All large pipe materials are stored outside on dunnage in drained areas and were properly closed to prevent intrusion of dirt, etc. Valves and other items were

(' stored in warehouses. Weld material was properly stored as indicated in ES-202. Please note Pinding 6 below.

No Corrective Action is contemplated.

FINDING 3. Procedure ESD-240 requires a segregated storage area for " scrap" asterial, and Procedure ESD-215 requires separate areas for asterial with Bold Tags and for P1 P8 asterial separation. These procedures are adequate. However, they do not relay unsch information on how these segregated areas are to be established and maintained segregated.

Response: It is significant to note that the auditors found the storage areas in excellent condition. (See Finding 6 below). The main concern is that proper, segregated ,

storage is used. There are a variety of ways this can he accomplished, i.e., roped off areas, separate storage bins, pallets, etc. We use any or all of these procedures depending on the specific circumstsaces.

No Corrective Action contemplated.

FINDING 4. There are no procedures or asaufacturers' instructions (I for the storage of flow indicators and strainers, which were stored in the Pullman Power Products storage area.

AA-

Response _: These items are stored on the same fashion as valves.

{' We fail to see why any special instructions are ,.

required.

No Corrective Action required. .

Handling procedures do not exist; and the only handling FINDING 5. I instructions i.re contained in ESD-222 and a number of cther procedures, which contain a caution against the k Pro-use of carbon steel in handling stainless steel.

cedure ESD-259 has excellent detail as to the handling However, of Crinnell Snubbers during installation. 27, 1977; and there Procedure ESD-259 was issued Jancary is no assurance that materials, parts, and components were properly handled during the period prior towhen most of the installat

' January 27, 1977, activities were occurring.

Response

Materials, parts, components, valves, etc. were handled in accordance with ESD-215 issued Septanber,1971 and We also point out that ESD-222 issued February,1972.

cur Quality Assurance Manual KFD-19 which was part of our program from the beginning, requires maintenance and surveillance of spools, hangers, valves, etc. on a monthly basis. Quality Assurance Instruction 94 and

f. PG&E Specification 8711 also give requirements for b handling and storage.

Our Pipe Support Manual Section KFPS-6 describes storage and handling, and KFPS-17 describes maintenance Prior tc issuance of ESD-259, and surveillance.

Grinnell Snubbers were controlled under ESD-215.

All Crinnell Snubbers have been reinspected and tested in accordance with ESD-259 procedure on both units.

No Corrective Action contempleted.

FINDING 6. The present storage areas were found to be in excellent on adequate dunnage, and openings espped.

This finding confirms proper storage is implemented despite

Response

alleged inadequate instructions in the above findings.

No Corrective Action required.

Procedures KFF-19 EFPS-17, and ESD-222 provide Prior for an to October FINDING 7_.

adequate 31, 1973, storage surveillmace program.the surveillance was perfomed u

(\ sheet that contained the storage requirements; af ter the checksheet was changed so that the

• October 31, 1973, While the sur-etorage requirements were not listed.

ve111ance program appears adequate, the checksheet used after October 31, 1973 does not appear adequate.

Rvponse: The criginal checklitt cyplied to valyco in ,wticular during the period cf tin 3 when valves vera o cignificant I

part of the storage.

(/ After October 31, 1973 when valve storage was significantly J reduced, surveillance of valves was incorporated in with other materials. ,

l We feel the original checklist is too detailed and,the current one is satisfactory.

No Corrective Action required.

b.

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INSPECTION. TEST. AND OPERATING STATUS.

_ CRITERION IIV. f the ..

The major mechanism that exhibita the statustant oThe Field Process FINDING 1.

' work is the Field Process Sheet. Sheet Bowever, provides for perform dierted by many important erection fabrication steps steps; cleaningcritical are not infabrica

, the Field Process Sheet: flows, and E

, prior to installation of insulation; and some The b welding steps ascontentpreheating, in the checking backing gas. gas checking for 07 Field Process sheet, The as inadequacy a mechanism of the to in exhibit status, is considered inadequate.

Field Process Sheet is considered a major weaxness .

the Pullesn Power Products system.

l the Steps Response: The Field Process requirements Sheetinisparticular.not for field welding intended necessarilyto fulfil taken to erect a piping sub-assembly are They need not quality related, and are quite obvious.

be indicated on the Process Sheet. is a Cleaning prior to installation of insulation basis and does s t lled by totally separate operation on a systemnot appear on special procedure.

h Critical welding steps such as preheat, f thegas flow, oxygen centent of backing gas are all part l they o Welding Procedure Specification and it is fe t need not be repeated on each process sheet. tions The Process Sheets give the required specific instruc for veld fitup and inspection as required by Code.  !

Recent revisions to the Process Sheet include more specific procedure requirements.

No further Corrective Action required.

D 240 -

The Mold Tag mechanism describedh inaProcedure ES -

FINDINC 2. is an acceptable method of exhibiting status w en defective or discrepent condition is noted.

Response: No comment.

No Corrective Action required.

Bold The method of using the Field Process Sheet, the

( FINDING 3.

Tag, and the Discrepancy Report is an a ndition Bowever, i

' and the final disposition of that condition.

the mechanism is not alvsys utilised.

W e.

[

3a. DMR-604, dated February 14, 1973, for isometric package 1-03-1 required rework and reinspection of  ;

j

%' 14 Class B welds. There are no Field Process Sheets l or Inspection Reports to dumonstrate that the work '

had been performed. l I

DMF-604 for isometric 1-03-1, response: Comument is incorrect.

has no Class B attaclamenta indicated. There are ClasTC attaclaments which are documented and inspected '

in accordance with the DMR.

b 3b. The Field Process Sheet for W-347 states that the

( weld was cut out in accordance with a specified DR.

' The referenced DR is not applicable tc cutting out W-347.

f

Response

DR-1247 was written to cover rerouting of the line and the addition of W~347. This DR is referenced on the original process shaet.

W-347 vas cut Reveld out andisrevelded to facilitate complete and correctlyinstallation documented.

of other work.

The as-built condition is documented.

No Correct.1ve Action required.

FINDING The method of indicating repair welds, as described in

(( 4_.

Procedures ESD-203 and 204, and the netation of repair welding on the Field Process Sheet are acceptable for showing repair status. Bowever, W-83 (Isometric Psekage are 1-10-9) and W-348 (1sometric Package 04-500-N-83) not stamped "R" to indicate repair.

Response

See Criterion X, Finding 9, the same response applies to W-348.

The Corrective Action taken applies also.

Procedures EFP-8 and ESD-239 do present some information FINDING 5. relative to the release of the systems for hydrostatic testing. Procedure ESD-229 does contain a method of indicating hydrostatic test status. These mechanisms

• are acceptable. Procedure ESD-229 should reference Procedure ESD-239 and require that the release be confirmed prior to initiation of the testing.

Response

This again applies to procedures not to the quality of the installation work.

Corrective ESD-229 will be r'avised to cross reference ESD-239.

Action:

([

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. ~ . - . . . , . - -, -,,I

Paragraph 8.12 of Procedure KFP-8 requires that the FINDING 6.

7 Field Process Sheet be maintained in has This requirement the area where 3 3/ the line is being installed. .

been interpreted as having the Field l ile Process She! i to the foremen and the people performing This practice thethe causes work wh l the work is in process.

Field Process Sheet to become an inspection sign 4ff g record, rather than a traveler that presents necessary information to all individuals involved in the b

performance of the work. I This is a requirement of our original Q.A. program.

Response

The inspection station' serves as a focal point forw individual inspector. Process sheets and other requirements are reviewed with the foreman and we*1ders prior to the work. The Process Sheet is available at all times.

Since the Process Sheet is a permanent record needed fcr final documentation, it was decided to retainDistribution directly them at the inspector station.

to the foreran might result in loss This or danage which procedure

' would destroy prior records. .

. furnished control required.

C No Corrective Action required.

Paragraph 7.2 of Procedure KFPS-7 requirer that the FINDING 7_. foreman or pipefitter procure a drawing and Process Sheet prior tostarting work and checkof f operatiour.

as completed. There was no evidence that this practice (which is in conflict with KFP-8) is observed.

apread out and loss of process Response: Since hangers are moresheets for hangers were not cor.sidered as c those for pressure welds, the procedure of dKFPS-7 Process; was established in 1973.

with each hanger drawing and are completed as require These drawings and process as work progresses.

sheets are on file in Q.A. vault for all completed and accepted work.

No Corrective Action is required.

Mh" L'- - - . _ - - - ~ ~ ^ - - - - - - . . . _ , , _ ' , *NW'Mww .w _

l CRITERION XV. NONCONFORMING MATERIALS. PARTS, OR CCMPONENTS I

(/

j FINDING 1. Procedures KFP-10 KFPS-9 and ESD-240 describe an .

adequate system of identifying nonconformance. ,

i Rerponse: No comment.

No Corrective Action required. .

b FINDING 2. Procedure ESD-240 does not adequately describe the i J

actual process by which Nonconformance and Discrepancy Reports are processed.

Response: We disagree ESD-240 does adequately describe process.

If specifics were listed, we could better evaluate this finding. No Corrective Action contemplated *at present.

FINDING 3. The Pullman Power Products / Pacific Gas & Electric Co.

interface relative to Discrepancy Reports is not described.

Response: ESD-240 requires approval of all DR's and NCR's by PG&E.

Specific individuals contacted are not mentioned. This will be corrected under Criterion I, Pinding 6.

((

No further Corrective Action required.

FINDING 4. Procedure ESD-240 does contain adequate information relative to disposition and close-out (use of logs) for Nonconformance and Discrepancy Reports.

Response: No comment.

No Corrective Action required.

FINDING 5. Systems that circumvent the nonconformance system have been established. Use of Note-O-Grams and Rejection Fotices to denote discrepancies usually precludes their

• pickup on a subsequent RN or DR. The use of these alternate systems removes the controls and reviews that have been integrated into the RN and DR system and also prevents information relative to the number and types of problems from being identified. These alternate '

systems are unacceptable. <

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Rerponse_: DR's are written to cover deviations which are found af ter an its has been completed and presented _ for .

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inspection. O

' During the course of a job, it is necessary to call attention to status of items still_in progress, but not yet presented for inspection. Note-O-Grama are an internal type of communication regarding the work in progress. They were introduced to reduce the risk

' . associated with verbal communication.

b l Rejection Notices were also introduced to call l attention to conditions which must be corrected

^

before presenting for final inspection. They ars also written to preclude six-up associated with rerbal comununication. They are similar to the weld repair

orders used when unacceptable indications are found

• by

! RT, PT, or MP.

Once again, we must emphasize that deviations or non-

! conformances are defined as unacceptable itens found f af ter the item is considered complete and has_ been a

presented for inspection.

No Corrective Action required.

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l CRITIRION XVI. CORRECTIVE ACTION

/ Procedures KFF-10, KFPS-9, and ESD-240 describe a FINDING 1. corrective action system. The corrective action -

system is inadequate in that it does not require:

a. Categorization of reported discrepencias to permit evaluation and tracking.

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- b. Doc u entation of all discrepancies.

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c.

Inclusion of documented discrepancias in the RN and DR system, i.e., discrepancies reported in Note-0-Grams are not subsequently written as a RN or DR.

d. Tracking of discrepancies to determine which, discrepancies are recurring.

e. Analysis of discrepncies to determine programmatic problems.

f. Reporting of significant conditions adverse to quality and the corrective actions taken to approptiste levels of management.

Response

At the time of the contract, Corrective Action require-(I ments meet the requirements of the Contract and Codes.

a. Lack of a procedure for categorization may have resulted in repeated deficiencies, however, each discrepancy as defined by the Q.A. Manual was reported on a DR. Appropriate disposition was made and steps were taken to prevent reoccurence.

Current Corporate Procedures do cover this situation.

! b. Docusentation of all discrepancies are reported Discre-as required by KFP-10 of Q.A. Manual.

pancies that can be corrected in the normal course of construction are not required to be reported on a DR.

Items written on Note M ass to expedite incor.

c.

plate work, is not considered a discrepancy and is not subsequently reported on a DR.

4

d. Tracking of Discrepancies - see response to Item 1 of Finding 1.

a. Analysis of discrepencies to determine programmatic problems - see response to Item 1 of Finding 1.

i f f. Reporting of significant conditions adverse to I I

j: quality are reported via a monthly Q.A. Report and copies of all significant DR's are ser.t to Director of Qualit) Assurance for evaluation and recommendations, i

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l No Corrective Action is required.

/

Response: -

• i (Cont. ) .

FINDING 2. Based on the results of this audit and the problem .

action system has not been operative.  ;

,. Each time a dis- I This is a very general statement.

Rarponse_:

crepancy is found, Corrective Action was taken toin requiresents.  ;

It is recognized that there were scee problems in the It should be noted that these problems were detected and dispositioned. Corrective actions . vere past.

implemented in the form of revised procedures, i further training of field inspectors and additional inspect on Examples of these are; rewritten procedure Icints.

for hanger installation and inspection, inspection points established for installation of concrete anchors, established a requirement that all radiographs be re-or second reviewed by a Level III We have perf 6rmed an internal review to determine ifNo additiona Corrective other quality deficiencies exist.

_ Action:

ciencies were noted.

There is no procedure for reporting 50.55(e)

FINDING 3_.

deficiencies.

10 CFR 50.55(e) requires the holder of the permit

Response

(PG&E) to notify the comunission of each fault inOur DR Syst design and construction. It is his obligation such deficiencies to the owner. l t to report any he determines may adversely effect p an 1

safety if uncorrected.

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_ CRITERION XVII. QUALITY ASSURANCE RECORDS (r FINDING 1. Procedures KFP-16 and EFPS-14 and most of the ESD procedures adequately identify the records to be retained. . .

Response _: No comment. ,

No Corrective Action required. .

b Procedures KFP-14 and KFPS-12 provide adequate guidance FINDING 2.

and mechanisms to assure collection of most records.

Records that are not specified in these two procedures (e.g., records on heat treatment, torquing, pipe rupture restraints) do not have any documented mechanisms for  ;

collection, but are adequatnly assembled and retained.  !

Response: No consnent.

No Corrective Action required.

FINDING 3. There are no procedures for filing, storing, and protecting records, i.e., no requirements for the vault, no method on how records other than isometric packages are identified, no instructions on how records are to be stored. However, the practices (I employed do provide for adequate identification, retrieval, and fire protection.

Response: The finding notes adequate systems, but wants spec' ic instructions. Some are included in ESD-212.

Corrective Revise ESD-212 to more specifically reference storage Action: methods.

FINDING 4. Procedure ESD-212 does adequately describe a security system that provides "out" cards for identification of the record and the individual using the record and j

for the overall security of the records within the vault.

Response: No comment.

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No Corrective Action required.

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CRITERION XVIII. AUDITS

(/ Procedures KFP-18, 19, 21; Proceduras IFPS-16, 17, 18; FINDING 1.

and Procedures ESD-219 and 222 describe an adequate audit -

program. .

Response: No comment. .

I No Corrective Action required.

b FINDING 2. The audit program does not require the use of checksheets or procedures to delineate the scope and extent of the audit, nor does it require that the audit teensisader be qualified.

Response: At the time the audit program was instituted, audit reports were made in narrative form. See Q.A. Manual KFP-18, Paragraph 18.4.

When preliminary issues of N45.2.12 and N45.2.23 were first available in 1975, Corporate Quality Assurance prepared necessary auditing procedures and qualified audit temn leaders as required, to perform the auditing l

required at 6 month intervals of the site by Central Staff personnel. This is all outlined in Corporate i

Procedure XVIII-1 available from the site Q.A. Manager.

{

Corporate procedures do use check sheets but Internal Audits by field Q.A. do not necessarily require their use.

Corrective Use of checksheets has been incorporated as a requirement Action:

when internal audits by site Q.A. personnel are performed. ]

FINDING 3. In response to KFP-18, Paragraph 18.2.1, management ,

audits were performed approximately every six months.

Check sheets were set.oyed. Based on the results of l

this audit and the results of Pacific Gas & Electric l Company audits, these management audits appear to have been ineffectual.

Response: Managment audits of the Diablo facility were started 9/19/72 and have been conducted at periodic intervals since t, hat time. There is a record of nine management audits on file from the time period of 9/19/72 through 6/21/77.

These audits clearly detect and define areas of deficiencies, and are followed by recommended corrective l action for impimentation. Verification of the adequacy of the impimentation of corrective action was verified

~

on subsequent audits conducted by managment personnel. ,

We disagree with the statement in audit findings that

(, these management audits appear to have been ineffectual.

N No Corrective Action required.

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FINDING 4. Procedure KFPS-16 does not require t,anagement audits.

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Response: The ASME approved Q.A. Enual requires managment audits. It covers the entire scope on site including .

hangers. KFPS was written only to supplement it. .

No Corrective Action required.

F kNDING5. In response to KFP-18 and KFPS-16, internal audits were performed every six months. Check sheets were not employed.

Response: KTP-18 and KFPS-16 specifically reference narrative reports and use of check sheets was not required.

See Corrective Action audit Finding 2 above.

FINDING 6. There are no procedures for sudit reports, audit responses, and time limitations on responses.

Response: Corporate procedure XVIII-l covers all there require-ments and is available at job site.

No Corrective Action required.

t FINDING 7. Procedures KFP-18 and KFPS-16 require that a copy of

(/ '

the audit report be transmitted to the Manager of Quality Assurance.

Response: No comment.

No Corrective Action required.

FINDING 8. There are no requirtuents that the Manager of Quality Assurance track the .udit reports or take any corrective actions w? en programastic or recurring deficiencies are noted.

Response: Q.A. Meausi KFP-18 require that audit findings be reviewed by the Q.A. Manager. He must assure corrective action has been taken. This requirment covers pro-

• grammatic or recurring deficiencies. Corporste Procedure KV-2 for non-conformance requires evaluation of non-conformances to determine whether they are programmatic or recurring. and outlines required steps to do so.

No Cohrective Ac. tion required.

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2 skE:2l l 2% T-There are no requirements for periodic, independent, -! T l FINDING 9.

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internal audits of the total quality program. ES'

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{ There are no Regulatory Code or Customer requirementsUse

[o Response: * *- -

for independent audits. .

a mechanism used by Pullman to review the adequacy Independent groups have been . . of -

M their work and program. g employed on occasion to obtain alternate views.,: ,3 3, - ~

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No Corrective Action required.  !

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i, One independent internal audit was performed in FINDING 10._

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January, 1976.

v Response: No comment. ,

No Corrective Action required.

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( *:: = ;", Qan. m ASSm a Cz cs Lm:= or sa m set Fu11mma Power Products '

Quality Assurance Program j

. Audit No. 80422  ;

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/ June 13, 1978 )

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I MR. J. D. WORTHINGTON:

Attached is the report of an audit conducted by the of the Quality Assurance', Department to determine the adequacy, Power quality assurance program implemented at Diablo Canyon Plant by Pullman Power Products. The report concludes that, in general, the Fullmas program meets applicable requirements.

Bowever, three programmatic deficiencies and three deficiencias in the implementation of established procedures were noted.

( Two Nonconformance Reports and four Minor Variation Reports were initiated by the General Construction Department.

General Construction personnel are working closely with Pullman's management in correcting the deficiencies identified. Resolution

~

of these deficiencies will be verified by the Quality Assurance Department. .

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- JCCarroll J0Schuyler FAcrane, Jr. CBSedan JEBoch EWShackelford DVKally -

MRTres,ler

!. FCMarks EWWhite FFNautz

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Audit h 80422

. Iccue Dato: 6/13/78 Pasa 1 cf 12 PACIFIC GAS AND ELECTRIC CmfFANY QUALITY ASSURANCE DEPARTMENT Fullman Power Products Quality Assurance Frogram ygg2,: ,

Audited Organization /

Tccility:

Fullman Power Products at Diablo Canyon Power Plant M. E. Leppke (Lead Auditor)

Auditors': '

C. L. Eldridge

• R. W. Taylor April 2 - June 1. 1978 Dates Performed:

l 1.0 Scope This audit was performed with three objectives in mind. They were:

(a) Verify that the Pullman Power Produ::ts Quality Assurance Program implemented at the site meets contract requirements and the require-ments of applicable regulations, codes, and standards.

(b) Review objective evidence to determine the validity of the findings ,

( of an audit performed by Nuclear Services Corporation (NSC) in 1977 and determine if Fullman's responses were accurate and appropriate.

(c) Observe the as-installed condition of components and support -

fabricated and installed by Fullman to verify adherence to applicable specifications, design drawings, and quality standards.

2.0 Conclusions and Exit Interviews 2.1 Conclusions The Fullman Power Products Corporate QA Program and the impleman-tation thereof were reviewed in light of the audit performed by Nuclear Services Corporation. Additional audit activities included a review of the installed hardware. The primary conclusions are given below with additional details set forth in Appendix A.

(a) Adequacy of the Fullman Power Products QA Program The Quality Assurance Program implemented by Fullman Power

- . Products essentially fulfills contract requirements and meets requirements.of the ASME Boiler and Pressure Vessel Code, 1971 edition. Bovaver, three program deficiencies were identified 8

and three deficiencies in the implementation of established procedural requirements were noted. Tneo Nonconformance

(. Reports and four Minor Variation Reports were initiated by General Construction. Areas were also identified where it appears.to be'to Pacific Gas and Electric Company's advantage to ups'ade r pro' gram elements though no violations of applicable regulations, standards, or the contract are apparent.

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x F Audit No. 804 W I

Pago 2 ef 12 i es Audit of Pullman Powerw.

• i; (b) Nwaluation Products QA program _

of the Nuclear Serv c byion ,

work performed ficiencies inified tions by the General Constructwere direct Several apparently generic de Additionally, i P,ullaan were As apreviously ident reinspec result, extensive ept-a

. Department. l Construction Department.verall evaluation of the a or performed by the Generawas onents andasked to perform suppo:ces(NSC) did not an wasO ccatracted by Pu Pullman l

[ ability of the installed compNuclear Nowever, Services the resulting Corporation ry littleauditC concentrated party, to per form this evaluation. main objective in that work.

NS 6

achieve its on Pullman's Quality Assuranc e Program and inspected ' program vedetermine t of the installed hardware ajor to portionsh of Pullman in srequirements audit findings allege that mto understand t e It is essential lace the NSC audit findingsSC states that require-NSC's sources:

are inadequate.

which NSC audited against to pThe audit checklist used by Nextracted Perspective.ments for the NSC )audit were 18 Criteri& (10CFR50 Appendix B on Quality Assurance a)

Grey Book (UASH.1283d" Procurement Guidance Phase of Nuclear b) Requirements During Design an Power Plants") .

c) ANSI Standards (internal guidelines)

Chapter Nuclear Services Corporation dix B are applicable. i d) l Safety Analysisf Report 10CFR50 comm ts The 18 criteria of 10CFR$0 Appen ME Boiler 17.1 of the Diablo Canyon ogramFina seating the intent oalso commits to the assurance to a quality assurance prFullman's programDE),1971 edition for qualityi h Appendix B.and Pressure Vessel Code (COThe 1971 Code is consi Chapter 17 requirements.

of 10CFR50 Appendix B. Book) is not applicable. kes no commitment The WASH 1283 document l Safety Analysis Report maDiablo Canyon. W of the Diablo Canyon Fina ign and (Greyconstruction of d i ble to WASHANSI 1283 71 for the and word ANSI that it is N45.2 not appl series caANSI N45.2standar s.

endorses M45.2, 19 des with the Code.they are intended ANSI N45.2 states in itsthatforework performed in accor under " Scope" to stand.:ris state with ANSI M45.2, 1971 series for use in conjunction licable for the same reasons The ANSI Standards are not app i s sapressed for WASH 1283.i s only represent the'opin on i ements.

Internal NSC corporate guidel neinterpreted by PG

( .

of the auditors and are not .

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4

_ _ - = . . . . . . .

- Audit No. 80422 Paga 3 cf 12

( Many NSC audit findings state that elements of Pullman's program are inadequate but specific deficiencies and references for .

requirements are not identified. Some actual deficiencies were identified by the NSC auditors but many of their findings appear to represent the an:titor's opinions with no bases in applicable regulations, codes, or standards.

The audit performed by the PGandE QA Department essentially

. Deficiencies identified

.i retraced the steps of the NSC auditors.Other alleged deficiencias stated by are listed in Appendix A.

NSC do not appear to be supported by objective evidence or do not appear to be based on applicable codes, regulations standards.

Pullman's responses to the NSC audit findings in general appear to be correct. However, to place the NSC sudit findings in proper perspective Pullman should have assessed the applicability of requirements which NSC alleged that Pullman violated. ,

(c) Evaluation of the Pullman Power Products Corporate Audit of the Unit 2 Hardware Installed by Pullman Power Products Corporation In February 1978 Pullman's corporate office performed an audit to verify that Unit 2 hardware items were installed One hundred in accordance twenty-two vith design drawings and specifications.

( hangers, restraints, and snubbers and seventy-seven isometric drawing packages were inspected; no discrepancies were noted by the Pullman Power Products auditors.

Approximately half of the items inspected by the Pullman audit team were reinspected by PGandE during this audit; several discrepancies were noted. In light of the number of discrepancies noted, it is apparent that the Pullman audit did not effectively evaluate the quality of their work.

Most of the discrepancies noted appear to be minor in nature.

Similar problems identified by reinspections in other areas have generally been "acceptad as is" by the PGandE Engineering Department. However, an overall assessment of the situation still should be done to determine whether additional Pullman's reinspections management should be performed and the scope thereof.

25, 1978, to send additional agreed, during a meeting held on May qualified staff to the site to perfors'the required evaluation.

General Construction plans to direct the performance of the Pullman evaluation.

M n M-3725 and M-3726 were initiated by General Construction to document and provide for resolution of the noted discrepancies.

(

- ;udir No. 90d22 dcsa 4 cf 12

'( , -

2.2 Exit Interviews Two preliminary meetings and a final exit meeting were held to discuss ^

the audit findings and to establish the recounded corrective actions.

(a) Freliminary Exit Meetina (May 10, 1978)

A meeting was held on May 10, 1978 to discuss the results and l .

preliminary findings of the audit of the Pullman Quality Assurance Program and of the overall pipe and pipe support inspections. The following personnel attended:

General Construction Quality Assurance Ensineerina C. K. Maxfield R. F. Wischow J. B. Roch t

M. R. Trasler V. L. Killpack R. Etzler M. E. Lappke G. Arnold C. L. Eldridge ,

R. W. Taylor (b) Freliminary Exit Meetina (May 25, 19781 A meeting was held on May'25, 1978 to discuss corrective actions with General Construction and Pullman Power Froducts. The General Construction Department directed Fullman Power Froducts to (I perform the required corrective actions. Those in attendance were:

~

Fullman Power Froducts Quality Assurance General Construction M. Evans V. L. Killpack C. K. Maxfield F. Runyan M. E. Leppke M. R. Tresler J. Ryan R. Italer A. Eck (c; Final Exit Meetina (June 1.1978) .

A final exit interview was held on June 1, 1978. Audit findings and agreed-upon corrective actions were summarized. All deficiencies identified during the audit had been documented prior to the exit interview by General Construction on Nonconformance Reports or Minor Variation Reports. Those in attendance were:

Quality Assurance General Construction C. K. Maxfield R. F. Wischow V. L. K111 pack M. R. Tresler ,

M. E. Leppke R. Etaler - C. L. Eldridge C. Arnold

(

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Audit No. 80422 l- Pass 5 cf 12 ..

l

)

(

As a result of this audit the following Nonconformance Raports OsCRs) and Minor Variation Reports (MVRs) were written by the -

General Construction Department to resolve the problems identified: ,

Description

• WCR Documents the lack of program DC-78-EM-004 definition and lack of detailed audit schedule.

The relative responsibilities of  :

DC-78-RM-005 (S and production are not clearly established.

Description ,,

MVR ,,

Pullman Corporate Management audits M-3723 were not performed,at the scheduled frequency.

M- 3724 Bold points were bypassed.

Bardwhre discrepancies were noted.

1 M-3725 Discrepancies concerning isometric k( M-3726 drawing packages were noted.

Corrective actions were agreed upon; the QA Department will verify the resolution of these nonconformances and deficiencies.

Prepared by: 'M E bV? Xt- .1 ((St

N. E.'Leppke i

'C. L4Eldridge

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- 1 1 Approved by:

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' - V. L. K111 pack

~ O C R. F. Wisdow / "

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- Audit No. 80422 Faga 6 ef 12

• . .~ .

AFFgNDIX A g'

.. g In this section, the deficiencies which were identified as a result of'the audit cra discussed. The problem in each instance is identified to a specific Noncon-formance Report- (NCR) or Minor Variation Report (MVR) that was initiated by the Gensral Construction Department.

Incdditio$,non-mandatorysuggestionsandrecommendationsofprogramimprowe-ments are given for consideration.

j 1.0 Program Deficiencies ,

1 i

Two Nonconformance Reports were initiated for the three identified i deficiencies.

• i f (a) Nonconformance Report No. DC-78-EM-004 1 This NCR is comprised of two parts as follows:

J .

) (1) The Fullman Power Products Quality Assurance Program is not l

adequately defined. The ASME Boiler and Pressure Vessel Code,

' Section III, paragraph NA4140 of the 1971 edition requires that the Quality Assurance Program be documented in detail in a

, f- manual consisting of written policies, procedures, and instrue-j \g j- tions. Corporate Procedure No. XVIII-1 is presently being used for the performance of management audits of field activities.

l l

Corporate Procedure No. VII-1 is being used for qualifying I

vendors for the Approved Vendors List. These procedures implement Quality Assurance requirements of the contract but

) i are not identified as part of the program and revisions are not controlled by the program.

The program is required to be approved by the ASME, and changes

' to the manual are co be approved by the Authorized Inspection Agency. EFP-1, paragraph 1.13 states that Engineering Specifi-cations (ESDs) shall'se part of the program. Most ESDs appear to be imp 1==*nHar proemduras, but some define actual program elements. For example, ESD-240 establishes the Noncompliance Report (NCR) system. No evidence could be found to indicate that ESD-240 has been reviewed and approved by the ASME or the Authorized Inspection Agency.

i It is not clear which manuals and procedures are applicable to specific activities. The pipe support manual is considered The by site personnel to be a supplement to the piping manual.

piping manual is approved by Fullman's Vice President but the Nowever, support manual is only approved by the field QA Manager.

I the front page of each manual indicates that it establishes the quality requirements for work performed under that manual. The

(,

\ defined scope of each manual indicates that the two apply to '

different construction activities.

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- L dit do. 80422

- - Fago 7 of 12

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(- Engineering Specifications appear to supplement one or both manuals or independently establish quality assurance program requirements. Special QA instructions are dritten to supple-ment and clarify Engineering Specifications or procedures in l

' one or both manuals.

I Recommended Corrective Action

,/ (a) Write a program description which clearly identifies the documents that are to be considered part of the total quality assurance program and establish the hierarchy of the documents 6 ' (where necessary obtain approval by the proper authority).

(b) Define approval requirements for the above documents and for revisions and obtain approvals where necessary. (For example, approval requirements are not provided for special QA instructions).

(c) Clearly define the scope of work to which the above documents t

are applicable. (For example, do requirements of the piping manual apply to pipe support work?)

(d) Review the program to insure that supplementary procedures -

do not include requirements which conflict with requirements Several KFP procedures of the procedures they supplement. Corresponding KFPS l(y require the involvement of the AI.

procedures allow work to be done without AI involvement.

KFPS procedures clearly cannot supplement KFP procedures without revising the KFP procedures to allow waiving AI (Example: KFP-7 and KTPS-6).

involvement on non-Code work.

(2) FGandE Specification 8711 and the 1971 Code,Section III, paragraph l MA4700 require a comprehensive system of planned and periodic

audits to be carried out to assure compliance with all aspects of the Quality Assurance Frogram.

Procedure KFP-18 states in its scope that it sstablishes such a system. However, two types of audits, The management audits and procedure does not establish internal audits, are described.

the scope of either type of audit and no detailed schedule has been developed to show that all aspects of the program are being l

audited. Furthermore, audit records at the site do Records not indicate do that all aspects of the program are being audited.

not indicate that management audits have been performed on pipe l support work.. An unofficial, unapproved internal audit schedule ..... ...

exists, but it has not been followed consistently and few ESDs

.. . . .. . A March 1977 internal audit erroneously appear on the schedule. and -14 pre not to be audited as they states that EFP-3, -5, -9, do not apply to Diablo Canyon. Internal audit schedules for i

October, November, and December.1977 and January 1978 were not met.

9

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~~~ &ndit No!' 804S2' ~ ~ ~~  !

Pass 8 of 12

(. ,

Recommended Corrective Action _ -

Establish and implement a detailed audit schedule to assure compliance with Specification 8711 and the Code. '

(b) Bonco'nformance Report No. DC-78-RM-005 PCandE Specification 8711. Section 4, paragraph 3.11 requires that l t}uality Control personnel perform only quality control functions and that they be free of scheduling and production pressures.

6

• A review of procedures and work in progress indicates that Quality Control inspectors' independence from schedulingProcedures and production pressures is not assured by the program as written.do not responsibility to read and use the process sheet insuring that steps are performed in the required sequence and hold points are observed.

During the course of this audit, it was noted that two hold points were bypassed on FW #362 (see Section 2.2 below).

Discussions with individuals involved indicated that the Quality l

Control inspector was expected to follow the work and ensure l

that inspections were performed at hold points indicated on i ((. the traveler.

and was unaware that hold points existed.

A QC inspector should not be responsible for directing the course of construction to ensure that hold points are observed, particularly if he also signs off these hold points.

Fu11 man's procedures identify the Field QA/QC Manager as respons for ensuring that most Quality Assurance Program fu'letions are Field QA personnel had already determined that some lities performed.

procedures needed to be revised to clarify or redefine d to responsibi to ensure that production responsibilities are not assigneThe A QA/QC personnel. revisions to three pipe support manual procedures a others to determine whether revisions are needed.

Reccmmended Corrective Action _

(a)

Revise EFP-8 and EFFS-7 to clearly state that production is '

responsible for following the traveler and ensuring th points are observed. ,

or audit. j t '

( (b)

Review procedures and practices to verify that QC is neither ,

( procedurally nor functionally placed in situations where theirR independence may be compromised.

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t (c) Perform the training necessary to ensure that produc' tion and QC ,

personnel fully understand their relationship and the functions they are expected to perform.

2.0 Deficiencies in Implementation of Procedures 3 _

72.?

• Q M-3725, and M-3726 Four Minor variation Reports QWR) or the identified carici.ou es.

were,/ initiated by General Construction (a) Minor Variation.Seport No. M-3723 Records. indicate that management audits have not been performed by Fullman Power Products Corporation at the specified frequency.

Management every six months.

audits are required by KFP-18 to be performed at leastSince at eight to ten month intervals. .

Recommended Corrective Action Conduct audits at required intervals or change the requirements.

(b) Minor variation Report No. M-3724-On April 25, 1978, work in progress was inspected to verify that the Field Process Sheet was being used as required by procedure

{( KTF-8.

It was noted that the repeir work on FW #362 had proceeded to step 4 on the Field Process Sheet. TheInspection Field Process Sheet was of the Field in the custody of the area QC Inspector.

Process Sheet indicated that, contrary to ETP-8, paragraph 8.4, work had proceeded beyond two hold points and the designated inspections had not been performed.

Corrective Action The Field QA/QC Manager issued Nonconformance Report #265 and agreed to write a procedure requiring The the issuance procedure is to of a Field clearly define Process Sheet to production.

responsibilities for using and completing process sheets.

(c) Minor Variation Report No. M-3725 Minor Variation Report M-3725 was initiated to docsmient the following hardware discrepancies, noted by the FCandE QA Depart-ment, to facilitate their resolution.

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Suppsrt er De"cription ef Dircrep^ncy Irometric .47-69R Vertieel clearance is'1/2" should be 1/16"

( '

Vertical clearance is 1/2" should be 1/16" l 47-70R  !

• 46-17R Clearance is 3/16" should be 1/16"- - \

Weld Item 2 to 1 not all around .

. 77-12SL Snubber installed on wront pipe .

• 77E14SL No torque seal 23-7V Location Item 7 is 5/8" should be 4" 23-8V Weld Item 9 to pipe not all around 23-5R Clearance Item 12 is 1/4" should be 1/8"23-12R Missing anchor bolts23-16R Crinder Couges 3/32" deep. .

• • Loose. bolt

• Clearance is 1/8" should be 1/16"

• 23-66R Clearance is 0" should be 1/16"

• 947-1R Weld Item 1 is not all around l

90-44R Wald Itsa 9 is not all around '

• 90-45R As-built does not reflect added shim ,

• 90-47R Weld Item 6 only tacked 90-48R As-built does not reflect added_ weld _

• 96-6V 5/8" rod used in lieu of 1/2" rod 90-46A Wald Item 2 is 5/16" should be 3/8" 72-195L Weld Item 4 not both sides

• 6-4R Weld on attaciument is 1/4" should be 3/8" 6-28R Fabrication of "t" shoe not to as-built

• 6-6V Dimension is 3'-1 1/2" should be 2'-11 11/16" l

6-8v Wo load on support, not tightened 2730-61 No Clearance "t" shoe to clip 2730-63 Broken stud i

' 2730-65 No clearance "t" shoe to clip 2730-66 No clearance "t" shoe to clip \

2730-42 Clamp loose, wrons location -

I l

shoe to clip l 2730-21 No clearance "t" l 935-23 Brace weld not all around 935-24 Brace is 45' should be 55' .

935-25 Confinuration opposite'to DWC.

t 935-27 Brace veld not all around *

• These items were accepted as-is b~ General.Cosotruction during the course of the audit. ,

f

• • Item was corrected during the course of the audit.

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- -- -~ __ __ _ __

q _. .

Audit No. 80422 Faga 11 cf 12 I

Minor Variation Report Wo, M-3726 l (d) t the i litate Minor Variation Report No. M-3726 was initiated their resolution: I

.; Support or De scription of Discrepancy Isometric ISO shows check valve as Spec 8729 Item 17 (Velan).

'. 2-3-18' Installed valve is Spec 2550 (Weston Hyd.)

2-3-19 Same as 'c-3-18 Line 1058; dimension shown as 2'-8" is l'-8".

2-4-418 2-9-478 F.W. 858 is etched on two velds _

F.W. 170 is stamped 176 be 2-3 2-12-5 Detail for FX263 refers to pump 2-1, should 2-14-14 are shown by the process l 2-3-418 F.W. 1390, 1391, & 1392 sheet to have been perfor ..

309 rod. Joints are all carbon.to carbon. l l

Documentation was determined to Note:

(( '

incorrect.

been used. l 3.0 Recommendations _ irements were presented i exit intervisvs and Several comments and recommendatios:s for prog are summarized as follows:

Schedule for laplementation of Commitments. ts should be (a) i A schedule for implementatten of the following comm tmen established: ' ,

Training program - added to KYP-1, 12/23/77. ses to NSC Use of internal audit checklists - made in draft respon audit. . d to Issue a procedura requiring a process sheet to be issue production. Commitment of'4/.25/78.

his audit.

Implementation of corrective' action resulting from t N*

- _ - . , _ . - . , , . . , , _ _ , _ ,, .,y__ , . . . . , _ . . _ , . . _

Audit No.- 80422 l' . Pag 2 12 ef 12 I

l Pullman Problem Reporting Procedures _ 7 (b)

Dese procedures should be revised to facilitate determining and .

verifying corrective actions.

The f6llowing changes are recosamended:

Issue internal audit findings as NCRs.

Expand the use of NCRs to cover all conditions adverse to quality 6

which are not covered by DRs. f Require the cause as well as the corrective action to prevent recurrence to be documented.

Establish a management review system for DRs and NCRs to identify trends.

(c) Inspector's Certificatiog The Pullman inspector's certification card should be amended to N45.2.6 eliminate the claim that inspectors are qualified to ANSI i nts.

or inspectors should be qualified in accordance with its requ reme I A review of ESD-237 and qualification records indicates that some

{ Fullman inspectors are not qualified to ANSI R45.2.6.

Description of Supervisory Responsibilities _

(d)

The KFPS (pipe support) manual assigns specific quality functions toT the " Hanger Engineering Supervisor".

of this position should be defined in the program.

(e) Special QA Instruction Index '

This index being An index for special QA instructions should be prepa addressed.

Update Pipe Support Procedure KFPS-7_

(f)

The process sheet shown The in KFPS-7 latest revision is Revision 7 and the proces of the process ld be removed shown in ESD-223 is Revision 8. sheet should be placed in KFP from the procedure..

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i samsev Review of Nuclear Services Corporation Audit Findings

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, June 16, 1978 I

1 MR. R. S. RAIN: -

I j

An audit of the Pullman Power Products quality assurance j program was conducted at Diablo Canyon Power Flant by Nuclear The Services Corporation (NSC) in August and September 1977.

'sttsched is a review conducted by the Quality Assurance Department of the NSC audit findings and Pullman's responses. Not all ,

finding,s are addressed; those NSC findings which are not addrsssed f in this review either stated that a program element was acceptable

( or only concerned insignificant, isolated discrepancies in documen-tation. .

From this review we conclude that the NSC audit was directed primarily at the programmatic aspects and did not address itself to the verification of the adequacy of the installed hardware.

The NSC audit was superficial with respect to the hardware As a result, the and very critical in the review of the QA program itself.

NSC audit is considered to represent an inadequate and inaccurate measure of the overall Pullman Fon r Products quality program.

If you have any specific questions or ased clarification of any point, please call either M. E. Leppke (69-1727) or C. L. Ildridge (3694), the Q& Department personnel who performed this review.

9

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. Pass 1 of 12 Criterion I - ,

Findina 3*

n e innetions listed are not outside the lly scope Qualityof Quality Cont ~

defined in Specification 8711.

is misleading since Engineering specifications are actuaEnginee g

Assurance procedures.

compliance with Code requirements. ld have been Quality Control personnel have performed d tion personnel. No. 80422.

functions which sho 6 performed by pro uc

• actions are outlined in Appendix A to QA audit report f mance were l dit No cases where Quality Assurancer has audiced its own identified. l report No. 80422 should insure that this will not occu .

• l l

Finding 4_

for the Construction l i f NSC's audit.

l Eesponsibilities and duties of keyibilities 30, 1977 to include responsjob descriptions for personnel and exce KFP-1 was revised on Decemberduties ofified. the Construction Supe

'{ each type of Quality Control Inspector. duties of Quality Co .

Finding 5_ i ents of Existing position descriptions appear to meet the requ rem Specification 8711 and the 1971 Code.

Finding 6_ et the Interface procedures for each activity Code. listedNo appear interface to me requirements of Specification 8711 and the 1971 procedure for holding meetings is required.

Finding I ' to send copies of r KFP 18 3.2 requires the Field Quality Assurance Manager internal audit reports to Corporate Quality Assurance. f mance reports, nted as Management Management reviews of corrective action reports, Auditsnoncon on a or and Audits.

personnel qualifications were performed and do semiannual basis are required by IFP-18, paragrap ,

8/22/72.

ld consult the NSC report

( -

• For azact wording of the NSC finding, the reader s ouSite", dated h

" Pullman Power Products Work Scope at Diablo Canyon October 20, 1977.. , .

~ #

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Prgo 2 cf 12 Criterion I -

Findina 7 (continued) 7 f The interface between the field and the Paramount .

(Rev. S/27/76). U Some functions performed by the corporate office at Details are described in Appendix A to audit report Procedares.

.No. 80422.

Finding 8, Interfaces appear to be adequately described as follows:

Drawing approval - IFP-4 and ETP-8.

Review of isometric, hanger, and restraint document packages - KFF-4, EFPS-7, and ESD-243 and -259, respectively.

Welders' logs - IFF-21. -

Control of welding process - EFP-12 and -15 Findint 9 No objective evidence could be found to indicate that the stop work authority of the Field C ality Assurance Organization is not adequate. Construe-ESD-240 requires a hold tag to be placed on discrepant items.

tion personnel are forbidden by the procedure to work through a hold tag.

No objective evidence 2he wasstopfound to indicate that a hold tag had been work authority described in ESD-240 latentionally bypassed.

appears to meet requirenants of the contract and 1971 Code.

i Criterion II Findint 1 Chapter 17.1 of the Diablo Canyon Final Safety Analysis Report couani implementing 10CF150, Appendiz 3.

a Quality Assurance program which seats the meeting the quality Assurance requirements The ofQuality Section III of the ASME Assurance Boiler and Pressure Yessel Code, 1971 adition.

regnirements of the 1971 Code were written to be consistent with the regnirements of 10CF150, appendix 3.

ANSI B45.2 etates in its foreword that it does not apply to work perform

( in accordance with the Code.

10CFt50.55a regnires that moelear power plant piping and components b constracted and inspected in accordance with the Code. .

P:33 3 of 12 1

% 2 Criterios II .

~

Findina 1_(continued) h Pullman Quality. **

d the 1971 edition of The documents ANSI N45.2 does not apply.

which establish requirements forg t l

the Codie. f Specification 8711 and tha A to audit report l

The Program appears to meet the requirements o19 Bo. 80422.

l

' Finding 2_ b r 23, 1977 to more f 1

Bevisions were made to the piping manual on Decem ly defined. See eThe revisions il clearly describe the program.

description, but the program is still not ils.adequate Appendix A to audit report No. 80422 for deta Fieding 3_ Bowever, the scope and See e clearly defined.

Fullman's response appears to be accurate.

applicability of the program 4 do need to be morApp Findina 4 include nonconformances, Bovever, implementation Corporate Management Audits were verified to i personnel qualifications, and corrective act on. detect trends is rec af a system for reviewing nonconformances to See Appendix A to audit report No. 80422.

Findina 7_ Procedure iningEFP-1 was revised on of all personnel Fullman's response appears to be correct.to require Quality Assuran December 23, 1977 involved in quality-related activities.

These Findina 8_ '

alification files.

Written esaminations are retained in inspector quiliarity lity with the req esaminations document the inspectors' famISD-237 is a detailed traini applicable procedures.Assarance and quality Control personnel. t Criteries III .

Findias 1_ riate.

'( -

Pn11 man's response appears to be accurate and approp

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Finoins 3 llman's review is simply to verify c

ges with original designNo violati It should be pointed out that PuReviews performed to reconcile cha .

compliance. rent.

requirteents and objectives are pe1971 Code or Spec A

' l entation.

71nding 4 iled enough to allow effective imp emNo violar. ion o ot appear necesssary.

,IFP-4 appears to be deta  !

more detailed procedure does n Code or contract is apparent.

EFP-4, however, may Finding 8_ drawing control. l ESD-253 See appears Appendix A to to adeguately coveraudit report No. 80422 act apply.

Criterion IV Finding 3 However, the Corporated as part rect.

has not been oficially identifie See Pullman's response appears to be cor procedure for qualifying vendorsd at Diablo Canyon Pow of the program audit to report be implemente No. 80422.

Appendix A to Finding 4_ rrect.

Pullman'a response appears to be co -

List.

Finding 5_ pear on the Qualified VendorsSee Appen Suppliers are not used unless they apCorporate procedures.

Vendor audits are controlled by audit report No. 80422.

Criterion Y However, l

Finding 1 h

pear in which the program.

they occur."

Field Process l the auditors' specific h words for doeachnot operation apEFP-8, orsignif operations and areinsputions required toand be referenced te i Frecedure numbers This effectively requires activit es inspection. controlled by written procedures.

'{ quality to be 3 .* ... . ~ - . .

. ' ' ' ' ' " ' ~ ~ + - . '

• v _

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Pass 5 sf 12 Criccrion V .

Finding 2 vered by proceduras Eanger package review and De preheating for weldinglisted other activities are codo. actf rm

- as azplained in Fullman's response.significantly affect quality a written procedures. k

. Finding 3_ described but do not The auditors state procedures are insufficientlyWithProgram appears to meet the exceptions lis

! reference requirements. report No.'80422, the Pullman Quality Assura the requirements of Specification 871 .

Finding 4_ k IFP-8 requires that Frocedures do appear to follow the flow of the wor .i h operations and insp process traveles identify the sequence in wh cThe response to Findin are to be performed.

appropriate.

Criterion VI Findings 3 and 4 l ESD procedurec .nd 23, 1977 to contro IFP-17 was revised on December Special Quality Assurance Instructions.

Finding 5_ 1 Finding 11 appears This Finding is directly contradicted by Finding 1 to be correct.

Finding 6_ i ts of applicable This Finding does not appear to be b,ased on requ remenThere is regulations or standards.

established practics.

Finding 7 Pt.Ilman receives the l PGandE's drawing control procedures ihd assure thatThe procedures. Fielddrawings are latest drawing changes. h they are using the Index and contro11ed'in accordance Engineers are required by proesdura to verify t atDrawing c with establ s e t

latest revisions.

violation of applicable requirements is apparen .

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. Pass 6 sf 12 e-Criterion VI Finding 10_

30, 1977. .

Corrective action was completed on December .

Criterion VII e'

Finding 1 The interface appears to be I See Appendix A to audit report No. 80422.

functioning adequately.  !

l i

Criterion VIII l Finding 10_

Applicable regulations and standards do not require specific procedures for these items. ,

Finding 12 ESD-223 appears to meet the requirements of Specification 8711 and the

(. 1971 Code.

i Criterion II Findint 3 SNT-TC-1A allows a person to be Pullman's response appears to be correct. certified directly as a In It was noted that sum of requirements for Level I a 1Bowever, Levelcompliance II. inspectors with other prior experience established in ANSI E45.2.6. Training and ANSI 545 2.6 is not required for this project. indoctrination guid been met.

Finding 10 Pn11=an's responses appear to.be correct.

Findings 11', 13, 15, 17 No violations of the Code or Pn11 man's responses appear to be correct.

Specification 8711 are apparent.

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Paga 7 cf 12 ,

(\ .

Criterion X .

Finding 5 .

l Agree with Pullman's response.

I .

~

Finding 6 f

Agree with Pullman's response. Inspection record sheets used reference -

- tbe inspection procedure and establish acceptance criteria. The inspector does not put a check mark by each acceptance criterion but signs Thisthe method form saying that all acceptance criteria specified have been met.

of performing and documenting inspections appears to meet the requirements of the contract and the 1971 Code.

Finding 8_

Records indicate that the proposed review was completed. No further corrective action is required.

Criterion II Finding 2 k EFP-8, paragraph 8.17, addresses this interface. ESD-229 describes the methods of performing hydrostatic tests. These procedures appear to meet all requirements of ANSI 331.1, ANSI 331.7, the contract, and the 1971 Boiler and Pressure vessel Code for work performed by Pullman.

Finding 3 Agree with Fu11 man's response.

Finding 5 Agree with Fu11 man's response.

In addition, it should be pointed out that all systems required to be code stamped are being hydrostatically tested in accordance with the Code and witnessed by the Authorized Inspection Agency.

Criterion III Finding 2 Agree with Pullman's response. Calibration system does not appear to violate contract requirements or requirements of 1971 Code.

t

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I -

Criterion XII .

Findias 3 e

In addition to Pullman's response, it should be pointed out that

, procedures le effect since 1972 appear to meet requirements of theI .

contrait and the 1971 Code.

had been identified, all items that could conceivably have been inspected by.the device could have been reinspected.

.; l The Code requires that measures be established toiassure be maintained that measuring '

,and test equipment used in activities affecting qual tyThe findings do not indicat within specified accuracy limits.

instruments that were outside specified accuracy limits were used in activities affecting quality.

Finding 3(g) contradicts Finding 3(f).

Finding 3(h) has no basis in the contract or the 1971 Code.

Criterion IIII .

Finding 2 Storage procedures appear to meet the requirements of the No corrective contract and ASE Boiler and Pressure Vessel Code,Section III, 1971.

action necessary.

Finding 3 Frocedures appear to meet the requirements of the contract and ASE Boiler and Pressure Tessel code, 1971.

Finding 4 No procedures required.

Finding 5 Procedures appear to meet the requirements of the contract and the 1971 Code.

Find {ns 7 Weltbar the procedure nor the checklist appear to violate requirements of the contract or the 1971 Code. . e

• enom * " *

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Page 9 of 12 l

Criterion XIV Finding 1 ,

I TM auditor appears to be saying that the" process traveler is inadequate for indfeating status since it is kept at an area inspector's station rather*than at the point where work is being performed.

There is no written requirement in applicable regulations or standards for

~ tfie process traveler to be attached to or adjacent to the work being performed. Bold tags and discrepancy reports are used to indicate the

, status when discrepant conditions exist. H e traveler is available to the person directly responsible for supervising the work.

Bowever, repair work in progress on main steam Field Weld #362 was checked and the process trav21er vaa reviewed. It was noted that two hold points had been bypassed. Discussions bet sen the assigned quality Control inspector and the foreman in charge of the work indicated that the foreman had not read the process traveler. In this particular case, the traveler did not accurately reflect the status of the work and was not effectively controlling the work. See Appendix A to audit report No. 80422.

There is no basis in app 14 cable regulations and standards for requiring  :

the process' traveler to include cleaning prior to installation of insulation, preheating, checking gas flows, or checking 02 content in the I backing gas. These are handled by established procedures.

Finding 5 Corrective action was completed by Inv. 12/30/77 of ISD-229.

Finding 6 Process sheets are available for foremen to read, but evidence indicates that they do not always read them (see Finding 1).

Finding 7 This practice has not been followed and is not required for work performed under the piping (EFP) ranual (see Finding 1). EFp-8 is vaguely written and the field's interpretation is less restrictive than the wording of It simply EFFS-7 for pipe supports. IFPS-7 does not conflict with EFP-8.

adds additional requirements.

Criterion IF -

Findina 2 ,

ESD-240 is a detailed procedure and appears to adequately implement Specification 8711 and 10CF150, Appendix 3 requirements. The procedure t.

does not specifically address routing to FCandE, but the D.R. form has a space for customer approval. A check of 20 completed D.R.s was performed and all were approved by PGandE. PGana approval is required by IFP-10.

Controls appear to be adagnate. .

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, Page 10 of 12

(/ Criterion IV .

Fladina 3 ~

. l EFP-10, paragraph 10.1.4 and ESD-240, paragraph 3.3 adequately describe the interface from the Pullman side. It is PGandE's responsibility NCRsto are designate PCandE personnel to perform such interface functions.

i not required to be approved by PGandE.

(See comment criterion IVI, '

Finding le)

Findins 5

.See casament,- Criterion IVI. Finding J.

criterion IYI  :

Finding 1_

The corrective action system meets the contract requirementsAand non-the 1971 requirements of the ASME Boiler and Pressure Yessel Code. IFP-10, conformance was defined as a deficiency in a hardware item.

EFPS-9, and ESD-240 require writing Discrepancy 4aports for all deficient hardware items.

BSD-240 also requires writing a Noncompliance Report for s's item or work

(( - process which deviates from a specified condition or requirement, butare They which can be corrected during the motsal construction process.

mot considered to be permanent docsmasats and are not presented to PCandE for review.

Deficiencies noted in internal audits are only required to be written up is narrative form in an audit report. They are not presented to PGandE for review.

Escommendation: - l Espand the use of Noncompliance Reports or establish a new reporting l system to cover deficiencies which are not associated with a specific  ;

item or component. Make them permanent documents and submit them to FGendE for review. (See Use comment themCriterion to docusent 171I1 findiwss Finding 3.) ofPerform 1 sternal audits ma appropriate.

periodic reviews of DRs and NCRs to determine trends or identify areas where practices might need improving.

Bete:

' FGena specification 8711, paragraph 3.28 states "All conditions "

adverse to goality, the cause, and coi'rective action shall be docu-i usated and forwarded to the Constructor and Contractor's supervision and management for analysis, evalu'atles, and review." Today's

' accepted definition of " conditions adverse to goality" is not restricted to hardware items only. ,

. t .; - ,

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Fa3311 cf 12 critcrion IVI Finding 2_ rrected. The .

Deficiencies identified on DRs and NCRs have been t left coimplemented to insure that

, recommendation in Finding 1, above, should beitems k not re uncorrected.

fi$ ding 3_

a procedure for reporting

, Contractors, are not required to havePCandE has that responsibility.

10CFR50.55(e) deficiencies. i deficiencies in Pullman does have a procedure in effect for report ng accordance with 10CFR Part 21.

Criterion IVII We agree with the Findings and proposed revisions. .

Criterion IVIII Finding 1 dit program is i

Contradicts other findings in this section by say ng au adequate.

that it is 1,eing Finding 2_

EFP-18 references Corporate procedure XVIII-1 and statesNeither procedu 12-30-77, need by the corporate office. EFF-18, revision internal or Corporate audits. i dic audits which shall be scope is to present a system of planned andf the perQuality Assurance o Nowever, it carried out to assure compliance with all aspects ocombination - of Program and to determine the effectiveness of the pro f Abe_psogram are the two will cover all aspects of the program. i n 4, paragraph 3 212).

needs to be generated to assure that A12.mapacts.aaud ld be incorporated Corporate procedure XVIII-1 or its requirements shou into the site program. ith written In addition, audits are to be performed i in accordance quirementwB, for Criterion 17111) procedures or checklists (ref. 10CF150, Append xChec their mee has been added to the program. ort No. 80422.

i

{ Corrective action is outlined in Appendia A to aud t rep .

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Faga 12 sf 12 i

w Crication 17111 .

Finding 3 d

-Bo evidence could be found to indicate that audits were ineffect.u Deficienaies identified were corrected, and corrective action to prevent Eowever, deficiencies have tended to recur.

~

recurreece was implemented.

j For example, deficiencies in drawing control were identified in Feb l j

May, and September 1975.

l Veadors List were identified in April 1975 and January and June 1976. l l' This does not indicate that audits were ineffectual, but it may indicate a meed to establish a monitoring system to identify trends so that special - ;

• measures may be taken to prevent recurrence of deficiencies.

Findina 4 j Management audits of the pipe support manual were, Theindescrip-fact, not performe KFF-18 does not appear to apply to hangers.

prior to 1978.t!.on of the Quality Control procedures manual (KFF) in ,the front o manual states that it applies to field installation of components, mate-A similar page i rials, parts, piping subassemblies and appurtenances. ii the front of the pipe support manual (KFFS) c-ys that it applies to p p ng The applicability of program elements needs to be m Finding 5 See comments to Finding 2 above.

Finding 6 EFF-18, revision 8/22/72, paragaraph 18.5 and IFFS-16, revision 8/22/72, paragraph 16.5 require audit reports to be written and forwarded A to the responsible supervisor and require that he institute corrective action.

follow-up audit is also required.

30, 1977'to require a response In addition KFF-18 was revised on December to corporate audits within 30 days of motification of violation.

Eote:

[

l I

Bo written requirement for defining such time limitation exists.

Existing procedures for audit reports and responses already met 10CF150, Appendix B and 8pecification 8711 requirements.

Finding 8 ,

l See Finding 3 above. Corporate procedure IV-2 does not apply to audit i

findings.

( Findina 9 In addition. IFF-18, revision 12/30/77, paragraph See Finding 2 above.

assurance by personnel not associated with quality The werd " periodic" abould be defined.

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

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teolementation.ofMd msotu. tion wilt nr =t -ur=~

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70 se conertef rn av ountrTv_AssuitAmt e 1st

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d // /8/ / 7 [

j 10nnirICAfloN- /M r M , , , AWM4f8d?

The Mm.neisen mal ca.ecsia Acne.i we cesrud.w esea _, YEW .,wme . < bash e.ase.I ossrniauf eon, Io her o.c=in ean se rep ind O 5- --f ty i

(

. y

,C Aunterided lossiector (fin ASME items)

O Psa,d 51-pdaterJent Esegineering Ranearch WHelais contraesortigdddier /Laa/d Whef.

O Steam Ge.wrapon

~

Oustity Asswooce -

O Engi erie a _

Safety Hosim sud Claims Other

• .4 )( Station Comt,venian R.O.lb4.a)[R.D I

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., C1 Amiie e n=a muerw

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1. NONCONFOMANCi' REPORT Page14P4

~

M .q -

TJn DC0 M - 004 ~

:1.3 (T

Description:

-P .1 5 M

J The Pullman Power Products Quality Assurance Program is l

C (A) adequately defined. The ASME Boller and Pressure. Vessel Section' III, paragraph NA4140 of the 1971 edition requi

{,

0

• the Quality Assurance Proqram be doctamented in detail ini # I consisting of written poltcies, procedures, and instructl

• 4 Corporate procedure lio. XVIlf-1 is presently being usedCorporate for the O performance of management audits of field activities.

R procedure No. VII-1 is being used for qualifying vendors for the g These procedures implement Quality g Approved Vendors List. Assurance requirements of the contract, but are not 3 as part of, the program and revisions are not controlled by the C

E P"*9"***

The program is required to he approved by the ASNE, and changes

' to the manual are to be approved by.the Authorized Inspection '

Agency. KFP-1, paragraph 1.13 states that Engineering specifi-cations (ESDs) shall be part of the program. Host ESDs appear-to be implementing procedures, but some define actual program elements. For example, ESO-240 establishes the Noncompliance Report (NCR) system. No evidence could be found to indicate that ESD-240 has been reviewed and approved by the ASME or the

. Authorized Inspection Agency.

^

(.' It tj f which manuals and procedures are applicable to

.spee! . The pipe support manual is considered by site per n p lerent to the piping manual. The piping manua; O man's Vice President but the i e field QA Manager. Ilowever, support manual is on t it establishes the the front page of each ma es q manual. The-quality requirements for work pe pply to defined scope of each manual indicates different construction activities. .

Engineering S'pocifications appear to supplement one or both manuals or independently estahlish quality assurance program requirements.

(8)

P G and E Specification'8711 and the 1971 Code, Section !!!,

paragraph MA4700 require a comprehensive system .

aspects of the Quality Assurance Program. p .y.p Procedure XFP-18 states in its scope that it establishes.such e-system. Ilowever, two types of audits, management audits'and; internal audtts,' are described. The procedure does not establish the scope of either type of audit and no detailed schedule has been developed to show that all aspects of the program are being (b audited. Furthemore, audit recntds at the site do not indicate 9C

~ ~

Hanconfermaaee Raport 9  % ., 1 l' DC0 RM - 004 r

N

• i N Description (continued): -

6 0

0 (B) (continued) $ '

!I' C that all aspects of the program are being audited: -

0 not indicate that management audits have been performed W N support work. An unofficial, unapproved internal audit schedule 4 F uists, but it has not been followed consistently and fet ES0s 0 appear on the schedule. A March 1977 internal audit erroneously R states that KFP-3, -5, -9, and -14 are not to be audited as they do not apply to Otablo Canyon. Internal audits scheduled for  ;

l

[ M A October, November, and December, 1978 and January 1978 were not N performed..

C ,

E .

6 CAlj5E OF NONCONFORMMiCE Since the beginning of the et.ntractor's installation work at Diablo Canyon there have been changes to the scope of Class I work. T se changes have been required by P G and E and in some cases f ty requirements were not set at the time of the -

change t changes involved work not under ASME Jurisdictf or's quality assurance manual was written primari a rdance with ASME Code work.

The manual was appro e riginally and has since t design additions ind been reviewed and reapprove y increased quality requirements h ed under separate l supplementary procedures. The addit a quality requirements caused the quality programs t that organization and control was cumbersome and di clearly define.

O Resolutton:

I S (A) Write a program description which clearly identifies the documents P

that are to be considered part of the total quality assurance pro-0 gram and establish the hlararchy of the documents (where necessary 7 5 obtain approval by the proper authority).

I T Oefine approval requirements for the above documents and for  :

I revisions and obtain approvals where pecessary. ..,

0 M Clearly define the scope.of work to which the above documents - *-

are applicable. .

~

Review the program to insure that supplementary procedures do not include requirements which conflict with requirements of the procedures they supplement. Several XFP procedures require the involvement of the AI. Corresponding KFPS procedures allow work to be done without AI involvement. KFPS procedures clearly O

e

'l .

. *. ~.- .

, ._ . %f. . p?!5 , 'y --

O Nonconfonnance Report 'Page 4 cf 4.f

.=.

f .y..

s 0C0 RM - 004 (9 y l \

0 Resolution (continued) .

I -

5 (A) (continued)

P cannot supplement KFP procedures without revising the KFP O

7 5 p(rocedures to allow Example: KFP-7 and KFPS-6). waiving AI involvement on non-code .

g T (8) Establish and implement a detailed audit schedule to assure I compliance with Specification 8711 and the Code, -

j 0

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I W NONCONFORMANCE REPORT 97

-Tage'J;of 2, t

s . . i.so. i,< ,,z4 ,u.

• J. 4..y is.ms n . mir v a-. o . se .

~

nevsa --

cennncAnon: 0 C 0 7 8 R M _0 0 5 .

1 ---

( ..

To es constrian av inmAvon

'"4 5d""" - . . , -

asa , -

t Independence of Quality Control Personnel from Production CKM amusenSDT5 2 "*" ",

= = see p.,e z.

fa5 .

3.a E M "

a -

p1M u m ..- a a v #

"$ . u 0,310,7. . riu unT . , , , ,

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s oaiona^reo TTMechari.' cal **" 6/15 / 78 [M7f/fa , @.'NUs To et CQadPLETED SY TECMMsCA6 REVIEve GMoue

,e., . .. .

. m a mi f MTi W/ al ( W ( 'l W Y a-- see page 2. -> -

is ss ,v i "

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-? . ,u.s. = une i a yes a neo oaa o, o .. } ** /'/

C*""""^'"*""**a'""'"'"*' Same as resolution and contractor to audit functionina

{e.

of the new ESO. NOTE: ESO-264 issued 7/10/78.

O N $$$, ,

9-/5- 7[

A s.eu f 2' L d :s 9-l2- 7 Y

$ ?* L n

h O' ,+. [ &lWN / O 4P'/)A'/7?

a scuouuo coyf6nou /H- o-.

1:=.

to es cowPtsTso av insetessmnMG ORGAnlZATION f/)ffL,, '*"* 9//r /yr

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, ,',~~~' f/)fM *"' 9 yr 77,9 _

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O N

To af COMPLETuo av QUALITY AssuM A#eCE _[

• A m "'

TOVEA&MCATioN:

n,.e.w ,oe.~A . .

4/P'l.,i. _

9/sy/7r_'

o.,rmunanmi..~,.. e.h. % . u g Authorised inspector (for ASME leemsJ . O Most Supertatepfant Q Seewity Q, Ecgineering Research O Materfans tJ 5 teem Generation N Quality Aswance W convectorA, sew Asa.utt /M'C' O fagi.; O Other-O Safety Medth ased claims g Staden Co,uvvedon

• Q Adeuensi Sh.sta AttarAed ,

. . .: .s.. Am e.,ilts e - - + u

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W E , ,

M JWMCONFORMANCE REPORT y2'

• DC0 RM - 005

.} - Fl 1

N Aescription: P G and E Specification 8711, Section 4, paragraph 3.11 ., .

0 requires that Quality control personnel perfom only quality control -  ;

M functions and that they be free of scheduling and production pressures DF C

0 A review of procedures and work in progress indicates that Quality Control inspectors

• independence from scheduling and production 8 N Procedures 4 F pressures is not assured by the program as written.do not clearly ,

in 0

R responsibility to road and use the process sheet insuring that M steps are performed in the required sequence and hold points are

• A observed. '

.H C

E 6 Cause of Monconformance Responcibilities of production personnel were not specifically defined in writing nor consistantly understood.

I

! E $" to clearly define responsibilf tfes h,) D hesolution: Contractor to issue an ES 1 of production and Quality Control personnel and to provide instruction to S that personnel understand the policy.

P 0

7 $

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4;g _c 3; *j, f MINOR VARIATION REPORT g)PER5[DED SY 10*MMCAN ' IIEablo Canyon $.' 2 NE 87'9 -

1 at 1 _

$ i=T~e attIch ts,mva a. I N ') :

e Pullman Power Products

's*"'%" '

w *** a caa* * ' M '<- om "*

Puliman Power Products

_ w.DDT Q W i

~

osscnienow op omenerueev

"" Various Unit 2 Pipe Supports oer attached 0.R.'s.

DiMM l I

"*"** PG&E Q.A. Department perfomed an evaluation. of the Pu11 sun Poirer Products co- graf Fifty-nine l audit of the Unit 2 hardware installed by Pullman Power Products corporation.

(59) installations were inspected by PGaE Q.A. and twenty-six (26) were accepted. Of thirty-three installations found unaccentable by Q.A. twenty were accepted by G.C. Field The remainina thirteen Enaineers usino various criteria established by PG&E Enoineerino.

(13)' discrepant supports will be repaired.

Wo.e?"' U S 9h  ?* 6/12/78' _

\

emum Re.iect . FUir the discreoant nice suooort installations per the attached A few of pe Pulle:an Power Products 0.R.'s #3624, 3625, 363f, 3640, 3641', 3642, 36I5.

supports found_ dj_screpant by PG&E Q.A. and G.C. Field Engineers will be corrected wit the requirement for a Pullman 0.R. or PG&E MVR, but as nonsal course of work.

• = * -

4.s % < = . nee. u .. , ,.4 gfg G/T9/78 NN $0*fklL4) Oper tie mapartstria fan.1 Title locFR N 2tl DI kla Mot Reportstdes E (2f kis Noe e.Nonconformance an OsAned in Proes@s PRM4 ,

j NO $0-JO

~*

_ $/2Ll/f s

"s 0 V [ M M ,n -: P 6/19/78

/

ossrosmon u:coasusano n_=,

4 4

o.e.

gi. oc

_,o,-,

1 Telecon w/CMLi, 2-14-78,0815 hrs. 3) Telecon 2/CMLi , 6. g gtpM' Y^***'"" 2) Telecon

) w/HCKlyce, 2-15-18, 4) PPP 0.R.'S.3635, 3424, 1 3641,3642.

N.t!? l "weeN2 ine

u. MINOR VAMIATION MEPORT m RSEDED W in )iablo Canyon - I 87l1 I W I

( ) c.sanHCADON

. .- - i  : see pa.we asarr Pullman Power Products Ih6.i n :stemehmes uva m b3725%1

p. "

saw y = c==== Osn. Pullman Power Products ' M 'E ossemrnau op oincapa#eev swe -

Dn A.

( Various Unit 2 Pf oe Sucoorts per attached D.R. 's.

See page 2. WNS Fa 7 # Med/ Mad ' 10/11/78 DSMETloM Re.f ec t. ReDair the discreOant Dice tuDDort installations Der the attachad _ _

Pulls:an Power Products D.R. 's #3624, 3625. 3631, 3640, 3541, '3642. 3635 k-1. A few Df De SUDDorts found discreDant by P 6 and E QA_ and G.C Field Enoineers will be tor-rected without the requirement for a Pullman 0,R. or P G and E MVR, but as normal I

course of work.

(5. Adm.* mrm on.pw ====

yj3 a,i,

'- _ 10mns

. v. ' "i S a= am au.,wn - w n..cm % w s _

1. 8 M ia N t a h ie nen e m osha d h % m a y o***

e $N.[] Q oc ,

7,fy,j ,

k- .1., 10/11/78 I deEFoE8710# m roeso -

non i

c  % oc an.

{ , - - , ..

88*='* , . ,

garracnnnes 4)PPPOR's3635R-1,3624,3625,3631.3640,3641,3642, M dtfaClted. l 9

./ .

N MINOR VARIATION REPORT

....~.

M-3725 R-1  ?

bi. , . .

EXPLANATION: PG&E Q.A. Department performed an avaluation of the Pullman Power Products corporate audit of the Unit 2 hardware installed by Pulian Power Pro-ducts corporation. Fifty-nina (59) installations were inspected by PG&E Q,'A.

andtwenty-six(26)wereaccepted. Of the thirty-three (33) installations found l unacceptable by Q.A. twenty (20) were accepted by G.C. Field Engineers using various criteria established by PG&E Engineering. The remining thirteen (13) ,

discrepant supports will be repaired.

REY. 1: Revised to correct hanger nusiber as shown on OR 3635 Rev.1.

s o .

( -

N 7

o o r , e . w - - -- 3 ..

=

l-

- ps.t wa - -

osen 4 we MINOR VARIATION REPORT .

m ee tirs .,

TiabloCanyon

• 1w  !

to8a m anon' 2 1&2 D E" . $711 '- 2

".,E,"

e # Pullman Power Products AY aftachats Mva no NNN2 '

8'"'***'C***""' R v. O n. ""'

Pulinen Power Products M4M i oescaianon o#r ossensrancy -

'etWW

"*" Various Unit 1 & 2 Pipe Supports per attached 0.R. 's. -

See page 2.

' fY.,dbM!

nema. 4/18/79 1 pisposano" Reiect. Rena tr the discrenant ofoe snooort instaf f ations ner the attnehmt

_ Pu11: nan Power Products 0,R. 's #3624. 3625, 3631. 3640. 3641, 3642. 3635 R-1. A few oice sunoorts found discrecant by P G and E OA and G.C. Field Enoineers will be cor-rected without the requirement for a Pullinan D.R. or P G and E NVR, but as nonnal -

course of wort amen.n. em-iu, ,,# n rp.a * **

N/A

~

$*.,Y.a' \ *& b $ (_alA' ' -

$/2/79 l l r i11 Sie n.: n ,=we: Ou=, he neparisme sper Tide socFn Pere 211

, , y

,8 (2) Ils Not a Nencesdor,rnaces es O. tined la Precedwo PAM4

~~

a IEOD J. AMo/W/ '

d'/4bn*) _.

l N l f_ _ -

M dh 4

7 2oaromnon .coseusato 5/2/79 Hangers noted on' O.P.. 's #3624, 3625, 3631, 3640, 3641 & 3642 have been repaired, inspected and accepted by Pullman _ Power Products in accordance _with the respective discrepancy reports.

Mangars Itsted in 0.R. 3635 under itevis 1 thru 4 have been processed per the approved

__disposttion. Pullman Power Products conducted a T-shoe audit per OR 3635 item 5 and reworked as necessary Unit 1 installations. OR 3911 (ref. WR M-3895) has been esta _

bitshed to continue the T-shoe audit and rework program for Unit 2. P%-

4 _

(

. n .

e _

$# [w/[$ JA $/S/?9 GdWM W r N rr l Ti.'t;~f/ '

1) PPP DR's J635 R-2, 3624, 3625, 5631, 3640, 3641, 3642.

f

.- \

l' Page"t l ,

MINOR VARIATION REPORT l

() M-3725 R-2

( Explanation: P G and E QA Department performed an evaluation of the Pullman', , , y Pmducts corporate audit of the Unit 2 hardware installed by Pullman Power F .

corporatlon. Fifty-nine (59) installations were inspected by P G and E QA ami',h , g l twenty-six (26) were accepted. Of the thirty-three (33) installations found un-acceptable by QA twenty (20) were accepted by G.C. Field Engineers using various criteria established by P G and E Engineering. The remaining thirteen (13) discrepant  !

supports will be repaired.

1 Rev. 1: Revised to correct hanger number as shown on OR 3635 Rev.1.

Rev. 2: Revised to note that the discrepant supports were in both Unit 1 & 2, and include revision to OR 3635.

- .u.%

Y. l b

. - , , . ~ - - . - , , . - - , . . - . - - , e -,

_g -r.

. ..s.  ;

PCwE MINOR VARIATION REPORT wey 4.==e.

• 794be i/TS

( ,, i n = n ca m 2 * 'fablo 0 Canyon $ 1&2 Nm.T 8711 1 er ' l c.av cw /

w Pullman Power Products e.

Tow.Ew.!

M/A pc.we.N wvn m OM-s.wcm =com e., o v. gm

• yf4

@_Q osecnierion or oisensirAsocy r_G& -e

""" Frecuency of audits perforroed by Pullman Power Products corno' rate 0.A. staM.D4 t=enenema The Pullman Power Products OA omedure KFP-18 states that ali. aspects of the PPP QA program will be audited every 6 months however, the PPP Corporate Audit Procedum XViit-1 states that the OA Procram will be audited annua 1Tv,

$7" # d[ 6/12/78 888PC88 N Aaroe eh'an audit frecuency and revise Pu11 man Power Products OA Field j

Audit Procedure KFP-18 or the Pullman Power Products Corocrate Audit procedure l XVIII-1 accordinciv.

mio e -f,.f=g,w ufa bN MN A N/14/7R

,, ,,, yj,,,,,,, ' na Mi.*sn m aww in aw. ten me wn w 2n m h m. e w- . o.n- i. em enua a $"r"=a* 1 S ed ~*

<,////pr "En ' [/ //2! /

& omonmon acccwusuno s/1enB

" The Pullman Power Products Quality Assurance procedure XFP-18 was revised '

8/18/78 and requires that ali aspects of the Pullman Power Products Quality Assurance r Program be_ audited annualIV, m

9

// _

5 "'" l d M ass . //Xv/7 9 /

ODY DY N_hdh 1/11/79 GAvracnusnn

. d . ~ ~!l?V 380WE 3  %:

.AINOR VARIATION REPORT s way A wa a.o ..

mese ins diabloCanyon N' 2 $ no. 8711 1w 1

~

N# Pullman Power Products D T M/A

• EE. N.U34 a

• Send oopy to Centrartes O Yes ked, gjg OG0C7t1PT10M OF Ot3CRETAleCY WM -

Field Weld No. 362.

ShYd swea.= Inspection point was bypassed as described on attached PPP NCR f2il5.p:m _

Reference P G and E QA Audit #80422. _ _ _

?YW"~ 'An R lx/L ~

6/12/78 j oiseosmaa Rej ect. sui >stitute radiograph inspection for penetrant inspectier, missed and create a new ESD per the "Reconnended Corrective Action" on attached FPP NCR d255.

bJ Am w Ma** *"

p== p ,.irw M/A D N El SMAwh '

9/21/78

, , , y_

iu' p(i.noinon.m. Om. n. n n c., ns. tocra e=t sis m x. ... . n._,_ . . _ ,_, ,_ s

?F?72 f f M **

9/n/7s Y M V.C.1646o ucf /cA 9/21/78

% b OISPWIDON ACCOMISHED Radiographic inspection was We and new ESO #264 was iniplenented per above disposition.

l _-

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~

b"6"*** Y- --l .- L lO /$ Y l

%7-#A44&L 9/z1/78 gmacmsNrs 1) PPP NCA #265, 4

, - . . - .,. ----------,--w- , . - - - , . - - - , , - , . - - - - - - - - . , - . - - - - - - - - - - - , - - , . , - - , - , . - , .

---_ ,-___ i-

- .I nt H. w . nr.i.e.vwu n . ;.. . . ,-

. e l'OllCOMPt. LANCE itEPoltT .

s' .

Q .

265 G 1I *- ;

f.

REPORT No.

. k

~

DATE 5/208 .

'M. PROJECT MilACER ~

• - 3. ..

M~

M clPinc suris. . ' *

. . . '='

.M ClilEl* EllGINEER . . . - -

,] PlPE Sil0? CHGINEER

• ~- -

.'.1Ilht:GEP. Chr.IllEEP. * . '*

i'.3 WEl.OlllG SUPERINTCf! DENT * '

~.31.EAD EnGlNEER

, .c ,.

,G:(AUTHORIZED INSPECTOR ,

's 4HPLIANCE: -

the hold point, es tablished. by P.P.P, S.A.

i area grind-out was

_'uring repair of F9-362 on Iso 5010I14  : . '

..id the. A.N.I ., on -a liquid penetrant examination of- the repa rESD-221. g 'I Para sWit observed in violation of: i .

gecifically KFP-8, Pa,ragroph 8.l. ,

~ . . ,. .. .,

.. . ...t

p. /abL .

q.A. 6tPARTiiElli it Is flieli .

. . ~

.;tf.lbDED C5A?.FCTIVE ACTION: .

!., Construction Superintendent to notify.all prod'uctfori . . - persoonel . *t ' t riisponsibility. to folIow '

'thet febrication oi-2.

Const,ruction Supcrin'tenden't to' Inform all production h is pers'conel.ignated'

) , '

• In

, erection shall nnt proceed beyond any hold point until t e t e Inspectors c.the A,N. , -

hen made & signed of f by the indicated

• fleid .Q.A. .

b ~ itutec

• 3.

As agre'ed by .the 6A. Manager & the A.N'.l ., radio

• graphic.Ins '

fpr the penetrant Inspect'lon missed hold point; ' '

J7r I, "  ; ,

q.A. m m atn .

See reverse side.

4, . . . .. .. ,

.=.

- . ~.  :, . . . .

. y,juy..C NOT REQU,lRED N,

- ,,e . .

• d C0t.'T]N000$ .

- SURVEILLAllCE CRECTIVE ACTION

// St/4#S [ , ..".

SU.IREh d

we --_s _Ta.xE n.cm r neunwice .

&. M.7e_b @ 4dyf s LL 4.Q/p(;.;f.,.. ' L. ..

'G.4 m-m. a..... .

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y 4 .

• ~ .. - - . . .

I, I c.- 7 JP-7N ,

USRECTIVE ACTioff hl' PROVED 6 ':

I DATE:

3- .

. 3. .

6 hi y .m . -

/* .

(}WP

.t 8, :

9

?

4 .

~

4. The. Chief. Engineer in concert with the q.A. Manager shall . develop, publish, and -

implement a specific ESO concerning Fleid Process sheetu planning and control Indicating responsibility for initiating, Issue, possaision, functilonel use,'docu--

~- mentation; notification of hold points, and retention as a historical record. *

. . . . . s..., . . .

. .' l, , , . .;

.f) 78. . .

1. < s: . . . . . . .

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' . Wd.$TCD. U. M ';

' owy pew == n eae. MINOR VnRIATION MPOST - - e.

. .e 75 454 IlFB hjggJCC4DyOR . 2 No. s71I Id T

(} "IOMMCAT10N eX# . Pullman Power Prod >xts *

> Yn M/A _ WN bainir i I

~

sene empy se cm.vaior O v= . g= "*"*

g/A Tr$4% i ossenwrion oF OMCnEFANCY T TIMNE -

'** Piping and Associated (somuttric Documentation Packages. ' j@@

5ee nace 2.

U $'"" Reject.  % RSee/wpageh 2. 6/12/78

1. 5sPoS8T80H One E

• • • eiaast yrrenca. 3 pase ,

L-- gjg 9/21J78 NY lh f & i et Mar. O usy be Rep We > Tiete tocFn Part 21)

A TMs M6ner V la Not e Nemoonformance se Oeffned b Pem;egy, pgg.g W

[ _

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08SPOEITN3N eNugggo Mammas All chances have been made to correct Iso's and doctnentation ner the above disocsition.

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MINOR VARIATION REPORT ~Pege T of f.

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(.J M-3726 .

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Explanation: The following discrepancies were found on Pullman Power Produc, f Isometric Orawings during P G and E QA Audit #80422.  !

Support or Isometric Description of Olscrepancy 2-3-18 ISO shows check valve as Spec 8729 Itan 17.(Velan).

Installed valve _is Spec 2550 (Weston__Myd.)

_2-3-19 Same as 2-3-18 t.fne 1058; dimension shown as_2' _ is l'-8".

_2-4-418 _

2-9-418 F.W. 858 is etched on_ _two welds 2-12-5 F.W. 170__is staaped 17_6 2-14-14 Detail for PX263 refers to pump 2-1, should be 2-3.1

/

2-3-418 F.W. 1390, 1391, & 1392 are shown by the process sheet to have been perfonned using stainless steel 309 rod. Joints are all carbon to carbon.

Note: Documentation was determined to be incorrect. The correct rod was verified to have been used.* __ _

~

Oisposition:

ISO _

Otsposition _ _ _

2-3-18 Change iso to reflect as-built condition.

2-3-19 Chan9e iso to reflect as-built condition.

2-4-418 Otmension is within allowable 6" tolerance.

2-9-478 Field weld is correctly marked. Numberwas:(sread ,

by auditor. 9; .. 1

. h. kl .

2-12-5 Same as 2-9-478.- j-:,qg :

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, 2-14-14 Change iso to indicate pump 2-3.

. _2-3-_418 Coirect documentation to indicate correct weld rod _.

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$"S nee im MINOR VARIATION REPORT igr

'*""*"' NAabloCanyon $ 2 M .'., 8711

= = -

fo I si t 5 ,=.= -m.. r.s..wsme. Siiis s.1 :

( / 'cinni a=ww - i Pullman Power Products 3L51 agbQg j ggfg sw , = ce=== 0 v. Km.

osecnenon oc oncampancy v*%n i r

"*" Piping and Associated Isometric Documentation Packages.

'd085$

" '" See page 2.

.#4[siti Uk'~"'Re.iect. N wSee0page_2, /w / 11/22178 068*omm (A samu w 5:=.gg. * *w , N/A "a C Y l -- '/> 00Ns  ?" ~11/22/78

. met am; 0% w nw w m. wn r. m a m. ns.= vws.iw news. gh Met a Nanc=vfenwen e Ounned k Pmmen PRM4 s ta g

L  %""M L fl >A 4N$7/

ENYM '

IfbAd r oposmom mcceertensa 11/22/78 A.mws: All chant:es have been made to correct Iso's and documentation per the above disposition.

REY. 1:

When this MVR n'amher was oricinally taken. no PPP QR ni==har was antered in the log. Therefore, the existence of the OR was not known_when this MVR was written and ,

when it was closed. lloon receival of the closed OR.it was realired" that this MVR was i inadvertantly closed before the OR had been closed.

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/3!P/2f f "s A ** * (/ - =/ M _bD __

?a*,,,*,<Y (/ ,$ d ? /s b 11/22118 j(munnen: 1) PPP OR f3651.

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Page t of 2 MINOR VARIATION REPORT 5'W M-3726 R-1 Explana tion: The following discrepancies were found on Pullson' Power Produ Isometric Orawings during P G and E QA Audit #80422. ,

Support or Description of Discrepancy Isometric 2-3-18 ISOshowscheckvalveasSpec8729 Item 17[Velan).

Installed valve is Spec 2550 (Weston Ryd.)

2-3-19 Same as _2-3-18 t.ine 1058; dimension show as 2' is l'-8".

2-4-418 2-9-478 F.W. 858 is etched on two welds 2-12-5 F.W. 170_is sta=ned 176 2-14-14 Detail for PX263 refers to ptsop 2-1, should be 2-3.

2-3-418 F.W.1390,1391, & 1392 are shown -by the process *

(:.,f sheet to have been perfanned using stainless steel 309 rod. Joints are all carbon to carbon, Note: Documentation was determined to be incorrect. The correct rod was verified to have been used.

Disposition:

ISO Disposition 2-3-18 Change iso to reflect .as-built condition.

2-3-19 Change iso to reflect 'as-built condition.

- 2-4-418 Dimension is within allowable 6" tolerance. , ,

2-9-478 Field weld is correctly parked. Number was Risread by auditor. 4. a

'I .

2-12-5 Same 'as te9-478. hN- -

2-14-14 Change iso to indicate pump 2-3, 3 Correct documentation to indicate correct weld rod..

g 2-3-4_18__ .

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A. T1-1 M.W. KELLOGG COMPANY- . asLislL d

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, M _ dlSCREPANCY REPORT asth mo.

unst 880. - 4 2 4 . *

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m go, y E M > .r- n June 9. ITTS d M ,'cr Peelfle Gas & Electric spec. m _8711 gays.

cusToMEn:

enonc7 Diable C* area m no . 7m inrecroa. RunyanMm rm-oisenspor irm. gcumentation Package for Flaid Welds 1390, 1391, and 1392 { g, f exet.AxArion or onscatrancy, During a P. C. & E evdit, it was noted that the thrWM cnced welds were documented es being Installed using wid code 150. This procadvrels *- I used for welding P8 to Pi aaterlats. The staterials involved are PI only. Investtgatten

. by P.P.P. personnel revealed that the original weld rod requisition and process sheet 'did j Indicate w id code 150. The Q.A. Field inspector did not allow this procedure to be used i

and the weld procedure was changed to weld code 203. A second weld rod requisition was prepared. The Q.C, copy of the original weld rod requisition, whIch was in error and should have been volded, was filied in the Isosietric package. The 4,C. copy of the second weld rod requisition, which was correct and should have been filed, cannot be found.

Verification of weld procedure used, correct weld code and weld rod used was determined by review of the Q.A, field Inspector's cally Work. sheet, Varehouse copy of the weld rod reatuisition and magnetic sample of the installed welds. This discrepancy occurred because the fleid work was acconiplished without a revised Isometric, the Q.A. Field Inspector did '

not correct all pertinent documents and the Q,A, Auditors matched weld rod requisltione to en inaccurate process sheet rather than a revised (sometric, -

nEcowMSNDEO olSPOSino_N. N Correct the w id code entry on the process sheet from 150 to 103, ,

(I.

, Replace the inaccurate 4.C. copy weld rod requisition with the accurate Varehouse COPY.

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• I 3. As-6uild ,the isemetric to reflect all welds and weld codes. { pg g 3(,,%

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omo cenaamn c:::.n. new o.A. how l'n addltion to current procedbres, a new r$0, srsrs To rarv snr a ecunn'sucs ohm Aceh 6te The key h saing forwulated at this time, shall be adequate to eliminate this type probles.

L cnd lesent in the ESO is to develop a field process sheet from the orf ginal source document to insure that work is not performed without a revised Isometric.

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i I ,pt_ 2 6 'd.ii i

e.-s,y Docket !!os. 50-275 -

50-323

'i i

i Pacific Gas and Electric Company l

77 Beale Street San Francisco, California 94106

)

l Attention: Mr. Philip A. Crane, Jr.

i Assistant General Counsel l .

Gentlemen:

.(ff

.u

Subject:

NRC Inspection at Diablo Canyon Unit Nos. I and 2 .

This refers to the inspection conducted by Messrs. D. F. Kirsch, T. W. Hutson and G. Hernandez of this office on -July 10-13,1978 of activities authorized by !RC Construction Permits No. CPPR-39 and j CPPR-69, and to the discussion of our findings held by Mr. Kirsch with Mr. M. R. Tressler and other members of your staff at the con-clusion of the inspection.

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, *l Areas examined during this inspection are described in the enclosed

. .; inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, in-teniews with personnel, and observations by the inspectors.

( No items of noncompliance with f!RC requirements were identified within the scope of this inspection.

l In accordance with Section 2.790 of the NRC's " Rules of Practice "

Part 2, Title 10, Code of Federal P.egulations, a copy of this letter and

,- l the enclosed inspection report will be placed in the !!RC's Public Docu-

ment Room. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to

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'"'"** U $T $ .-H(rnandez h..- .We Spencer

... . . Kirsch /db Hutson p

-7/.a 4 /78.

7/ X ,/78 7/ E /78 _ _ _ _ _ _ _

- - - . . -7/ F. /.7.8

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! JUL 2 6 E78 Pacific Gas and Electric Co.

~

1 this office, within 30 days of the date of this letter, requesting that

- such inforr.ation be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The apolication should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also

'AS" be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

~

Should you have any questions concerning this inspection, we will be l l

glad to discuss them with you.

Sincerely, 1

~

l

.. ; w . sis n e at L L 1 Foe.ar G. S. Spencer, Chief

' Reactor Construction and 1

- Engineering Support Branch Mj,

Enclosure:

IE Inspection Report ,

Nos. 50-275/78-10 and 50-323/78-10 cc w/o encl:

1. ~ ~ ' '

R. P. Wischow, PGaE J. D. Worthington, PG&E Sent to Reproduction, HQ for Distribution Sent to Accessions Unit. HQ for: PDR, LPDR, NSIC TIC, Central Files l

l Distributed by RV: State of CA (JOHNSON /HAHN), RV PDR (2)

Sandra Silver (Report only) l Y,

Engelken (Itr), (2)

Inspector files O

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U. S.- NUCLEAR REGULATORY COW 4ISSION '

OFFICE OF INSPECTION AND ENFORCEMENT ,

I - REGION Y i' - 50-275/78-10 l

Report No. 50-323/78 ,

CPPR-39 50-275 Safeguards Group License No. CPPR-69

.- Docket No. 50-323

).9 Pacific Gas and Electric Company Licensee:

77 Beale Street San Francisco, California 94106

, 1 Facility Name: _ Diablo Canyon Units No.1 and 2 Inspection at: Diablo Canyon Site, San Luis Obispo County, California Inspection Conducted: July 10-13,1978

Inspectors: b ht h BLM")5 D. F. Kirsch, Rea'ctor Inspector Q DC e Signed Mb

7. W. Hutson, Reactor Inspector a

b' .

6 Ste Signed M M78 -

Gala M;19*7V k18m w db / Date Signed ,

~Ggernandez,ReacgrInspector Approved By: CA 7/M[77 Date Signed G. S. Speru:er, Chief, Retctor Construction

! - and Engineering Support Branch Sumary:

~

Inspection on July 10-13,1978 (Report Nos. 50-275/78-10 and 50-323/78-10).

Areas Inspected: Unannounced inspection of seismic modification activities involving: structural steel welding procedures, work observation and record review, reinforcing steel welding procedures, work observation and record.

review, welding electrode control, structural steel bolting, procedures, work observation and record review, ultrasonic equipment calibration and examina-lf. .:/

' .? -

tion of structural steel welds, electrical and instrumentation raceway supports and circuit separation, structural concrete work observation and record review, 10 CFR 50.55(e} followup, and licensee QA audits and nonconfomance report review. The inspection involved 75 manhours by three NRC inspectors.

G

- 'Results: Of the eleven areas inspected, no items of noncompliance or deviations were noted.

l s- . .d

~-

IE:V Form 219 (2) l

. . 2

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DETAILS

1. Individuals Contacted

a. Pacific Gas and Electric Company (PG&E)_

• M. R. Tressler, Project Superintendent

• " *4 *C. K. Maxfield, Station Construction Superintendent l

l

• R. P. Wischow, Director, Quality Assurance

• D. A. Rockwell, desident Electrica.1 Engineer l i

"' *R. D. Etzler, Resident Mechanical Engineer

~

• V. L. Killpack, QA Engineer

• M. E. Leppke, QA Supervisor

• L. G. Rasmussen, General Construction Supervisor

• J. Arnold, Coordinating QC Engineer J. N. Cochran, Resident Civil Engineer B. Gragg, Welding Inspector R. Breed, QC Engineer F. M. Russel, Civil Engineer

b. Guy F. Atkinsch Co. (GFA) f.i1 .

M. M. Walsh, QA Manager

- T. Loomis, QA Engineer D. Haffey, QA, Weld Rod Control A. Kridle, Structural Steel Inspecto'r K. Brainard, Concrete and Reinforcing Steel Inspector M. E. Chevalier Welding Inspector B. Vines, General Foreman

1. AW B. Driver, Foreman R. L. White, Batch Plant Operator M. Anderson, Lead Inspector

c. H. P. Foley Co. (Foley)

V. Tennyson, QA Manager

- d. Endurance Metal Products Co. (EMPCO) _

D. J. Grsgg, QC Manager 4 } e. Pullman-Kellogg (Kelloqq) f-J. P. Runyon, QA Manager V. J. Casey, NDE Level II Examiner

('

• Denotes those present at the exit interview.

i

. 3

-_ . . . ..~.-..m_ . . , , , - , , _ . ., .,,,..y . . . - , - , , _ . . . . _ . - . _ . _ . , , , . . , , . , , , . . . . , ,.__,.-m_ . . , , . .. - , ,,- .m.,

2. Licensee Action on previously Identified Ooen Items

a. (Closed) On-site Approval of Open Items Identified by Licensee QA Audits (50-275 and 50-323/78-09).

The licensee had revised Quality Assurance Department Procedure No.16.1 (0 pen Items) to allow the QA Director to assign cer-tain personnel the authority and responsibility for approval of g;.g- - open item classification and corrective action. The QA Director had assigned this function to the onsite QA Supervisor by letter dated June 20, 1978. The Open Item log and recently identified open item reports were examined. It was noted that the onsite j j

QA Supervisor had been approving the open items and that the approvals and resolutions were being made in a timely manner.

This item is closed.

b. (closed) Structural Steel Erection (50-275/78-05)_

The plug welding of unused bolt holes was stopped by PG&E QA when it was observed that the welding procedure had not been qualified in accordance with AWS D1.1-1975. The contractor per-E t-forming the welding has received a reply from the AWS in regard W to the question of procedure qualification for plug welding of ,

J the unused bolt holes. The reply received stated that the pro-cedure used in the plugging was considered as prequalified.

Based on the reply from AWS and review of the completed work, this item is closed.

c. (Closed) Cracking of Concrete Buttresses (50-275 and 50-323/78-09)g

'hi$ The licensee has evaluated the cracking of the Buttress walls

- - and has attributed the cracking to shrinkage caused by the bottom section of the wall being restrained and the top section being

~

free to shrink. The licensee states that the cracks will be filled with epoxy to protect the reinforcing steel from corro-sion. This item is closed.

d. (0 pen) Sand, Aggrecate, and Cement Test Reports (50-275 and 50-323/78-09).

A complete package of all required test reports were not available i.

for review. The licensee had received a portion of the reports and stated that the rest were in the process of being transmitted

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and would be available for review during the next inspection. This

~

1' - item is open. -

b

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3. Structural Steel Welding

a. , Review of Quality Assurance Implementing Procedu'res The following Endurance Metal Products Co. (EMPCO) quality control procedures were examined:

(1) QCP-6, Field Installation - Welding (2) QCP-8, Welding Electrode and Wire Control, Program (3) QCP-9, Quality Control - Field Installation (Welding)

(4) QCP-10, Nonconforming Items (5) QCP-12. Repair - Field Welding The procedures had been approved by the licensee. The fonn QCF-3 had been revised to include the inspection of material placement (see .IE Inspection Report 50-275 and 50-323/78-09). l No items of noncompliance or deviations were identified.

h, b. Observation of Work and Work Activities (1) EMPCO Activities

-- The inspector examined the completed welding on four checker plates and the in-process welding on eleven checker plates being installed at the 104' elevation of the Unit 1 Turbine Building. In addition, the temperature of weld rod holding ovens 1 and 2 and the checker plate storage -

4 area were examined. No items of noncompliance or devia-tions were noted.

(2) GFA Activities The following welding activities related to the Turbine '

Building crane rail were examined:

(a) Approximately 200 completed welds in Bays 14,16, i --

18, 20, 22, 24, and 26. ,

(b) Material fitup in Bay 30.

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(c) In-process welding in Bay 28. ,

(d) The temperatures of Weld Rod Holding Ovens 4 and 5.

. and the weld rod issue activities in the oven 4 and l

,(- 5 area.

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_4 It was noted that all work and inspections had not' been .

completed in some of the Bays and a review 'of pertinent documentation did reflect this fact.

Welding activities on a structural steel addition to the Unit 1 containment annulus area were also examined.

The inspector noted that the structural steel welding in ,

h '". . . the Unit 1 Fuel Handling Building had been completed and l the welds had been painted l Four gompleted welds in the Machine Shop on Columns 184 and 19- at elevation 166 ft.

were visually examined. The welds exhibited excellent workmanship and had been properly prepared for ultrasonic examination.

The ultrasonic equipmegt calibration and examination of  ;

two welds on Column 18-- at elevation 166 ft. were observed.

The equipment was properly calibrated and the examinations l were conducted as required by the UT examination procedure and the AWS D1.1-1975 code. One reject weld was disclosed i~

by the UT examination. The discontinuity was properly 10-cated and evaluated by the examination. No items of non-p". , *

- . compliance or deviations were noted.

c. Record Review

.N "

(1) EMPCO Activities ,

N, The following quality related records were examined:

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(a) Field Installation Inspection Reports for the checker plate welding completed and in-process (see Paragraph 3.b. (1), above).

.f 3 (b) Walder qualification records for_10 welders, (c) The welding electrode issue records for June through July 7,1978.

." (d) The Nonconformance Report Log and NCR Nos. 01 through 04.

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> > (e) The Hold Tag Issue Log. -

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"f-i s No items of' noncompliance or deviations were identified.

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(2) GFA Activities .

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J The following quality related records were examined: ,

(a) Qualified Welder List (b) Welder qualification documentation for eleven welders, he (c) Welding Electrode Issue Log of July 17,1978 for Holding Ovens 4 and 5.

(d) Material Certifications and Receiving Inspettion Reports for 5 weld rod lots.

(e) Field erection inspection documentation for NDE and visual examination of welding performed in Bays 14,16, 20 and 22 of the Turbine Building

. crane rail.

(f) UT ani liquid penetrant examiner certifications A for two Level II examiners.

d;

' :d (g) Qualification records for three Structural Steel -

- - Erection and Bolting Inspectors.

(h) UTequipment(SN 804002) certifications and 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> calibration records. -

(1) Transducer (SN B18429) certifications.

i&h' (j) Field Erection Inspection Reports and UT Test Reports for welding in the Unit 1 Fuel Handling Building.

Discussions with GFA personnel indicated that the methods to be employed for final documentation were not 'proce-durally specified and the system for identifying work remaining in the Turbine Building crane rail bays was not specified by procedure and appeared to be inconsistent.

Licensee personnel stated that this situation would be evaluated and resolved.

No items of noncompliance or deviations were identified.

..Y.I' C

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

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4. Structural Steel Erection and Bolting ,

s. Review of Ouality Assurance Implementing Procedures The following GFA quality control procedures applicable to Structural Steel Bolting were examined and appeared satisfactory:

QCP-3, Rev. 1 - Structural Steel Erection

'M QCP-7, Rev. 0 - Calibration Control and Status No anomalies were noted.

b. Observation o Work and Work Activities The inspector randomly checked completed bolted connections in in the Unit 1 Turbine Building and Fuel Handling Building. The inspector noted that the bolts were being marked as required by QCP-3 after tightening and inspection. Observation of the com-plated work in the Fuel Handling Building disclosed that an existing bolted connection had been loosened to facilitate the slotting of holes in a structural steel member, The subject

..'J connection had not been tightened upon completion of the work.

C,j 7, This item is being corrected in accordance with the provisions of the contractor's nonconfomance control system. .

.e '

N c. Review of Quality Records _ ,

The Field Erection Inspection Reports, Bolting Inspector qualifications ar.d torque wrench calibration records related to work in the Unit 1 Fuel Handling Building were reviewed, w'gi5 No items of nonconfomance or deviations were noted.

,, ,n e

5. Reinforcing Steel Welding 5

a. Observation of Work and Work Activities The in-process and completed welding of reinforcing steel was observed at the following locations:

G line between Colugns 21 and 22, vertical dowels G line at Column 29 , vertical dowels to A-36 steel A line, Unit #1, vertical dowels

"" The walders were observed using the proper procedures and

"-.' materials for the applicable welding process. All portable rod ovpns were p'ugged in and were maintaining the required La '

i

\ " -

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

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temperature. Approximately twenty (20) completed welds were

' examined and appeared to conform to AWS D12.1. No items of noncompliance or deviaticns were noted.

b. Review of Ouality Records The calculated carbon equivalents for the rebar to be welded were reviewed. The inspector noted that heat A1030, size ew eleven, grade 60 had been received onsite and was being welded in the structure. The carbon equivalent of this heat is 64.08 which is higher than the carbon equivalent of 59.17 of heat A2182, which was originally used to qualify Welding Procedures WS-RS-1, 2, 6 and 7. No evaluation as to the acceptability of this new heat for welding was made by the contractor. This item is being corrected by the contractor's nonconformance con- ,

trol system.

The E9018 Welding Electrode Issuance records for the month of June were reviewed. On June 5, 1978 the contractors onsite lost electrical power to their electrode holding ovens and '

i portable rod cans. A periodic check by GFA discloged that por table ovens 3 and 6, containing 190 electrodgs, had drgpped

%:: below the minimum holding temperature of 250 F to 225 F.

The rods were subsequengly removed from the field and placed in a rebake oven at 450 Fovernfght. AWS requires that E9018 electrodes be rebaked at 700-800 F for 1 The rods were only exposed to ambient temperature (225' hour.

Fminimum)during transfer between portable ovens and holding ovens. The rods were issued for use the next day. The failure to rebake the

E9018 rods per AWS requirements is documented by the contrac-tor's nonconformance control system and will be resolved accord-bs3 ingly. No items of noncompliance or deviations were noted.

6. Electrical and Instrumentatinn

a. Observation of Work and Work Activities Four raceway supports, incorporating revisions specified by recent detail drawing changes, were examined. One raceway sup-port had been mislabeled as to type, however, this item had been identified by licensee QA Audit No. 80611. The supports appeared to be installed in accordance with the applicable detail drawings.

The lfcensee had. established mutually redundant circuit separation criteria and promulgated these criteria on Draw-

! - ing,No. 050029. The following safety related panels were examined for compliance with these criteria:

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_ _ _ _ , _ . . _ _. _ _ _ _ _ _._ _ . _ .. _ . ___ .._. __. _. . .. ._. ._ _ ~ _ , _ . _ . . . _

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(1) Diesel Generator Control Panels 1-1,1-2 and 1-3 ,

(2) Unit 1 Hot Shutdown. Panel .

(3) Mechanical Panel No. 30 (4) Instrument AC Panel Nos. PY15 and 16 k'd.@

(5) Main Annun::iator Panels PK003, 004, 005 and 009 (6) Rack wiring in the Diesel Generator System, Chem'ical and Volume Control System, Residual Heat Removal System

- and Safety Injection System Control panels located in the Control Room.

It was noted that the Varglass sleeving had been frayed and the Scotch 7700 Tape did not extend into the conduit for mutually redundant circuit wiring in the Diesel Generator 1-1,1-2 and 1-3 control panels. Since these systems had previously been turned over to the operations staff, the f.

QA Supervisor stated that the appropriate organization would fg. ..; ,

be notified and the situation corrected.

P 3: No items of noncompliance or-deviations were identified.

. !N .

Jc' 7. Component Supports The Report marginal weld undercuts No. 50-275/78-09 Paragraph previously) 7.a in baseplate observed (seeforIE Inspection welding Mixed Bed Demineralizers 1-1,1-2 and Evaporator Feed Ion Exchangers 1-2 and 1-4 has been evaluated by Foley. Discrepancy Report No.

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8735-4 specifies repair of areas in excess of 1/32" undercut. This resolution was approved by the licensee and was in the field for work accomplishment. No items of noncompliance or deviations were identified.

8. Structural Concrete c a. Observation of Work and Work Activities Concrete activities, including preplacement preparation, placement, form removal and curing for Lift No. 5-11, were

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observed on the west side of the Turbine Building.

No ano'malies were noted.

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b. Review of Ouality Records Pertinent work and quality records associated with Lift Nos.

5-10 and S-11 were examined. Records reviewed included in-spection, curing, strength tests, qualification of personnel, material certifications, audits. Batch Plant certification and calibration. The records appeared satisfactory, except as noted below.

During review of personnel qualifications, it'was noted that certification of the Batch Plant operator had not been accom-plished as required by GFA's procedures, and that a NCR has been written to correct this item.

Concrete Specification 5422, Section 4.9.3, states that slumps shall be a maximum of 4 + 1 inch for walls and slabs 11 inches thick or less, and a maxTmum of 3 + 1/2 inch for all other work.

Except where reinforcing steel and other embedded items make concrete placement a problem, slump may be increased as required gith prior approval for each case. Design mixes had been

. . approved for a maximum slump of 6 inchcs. Due to a typing error,

(~.c3 , the mix designs did not specify a tolerance and simply gave the il maximum slump as 5". During record review, it was noted that several slumps exceeded the 5" maximum. PG&E has issued MVR

. No. 076 and is acceptieg "as is" the concrete based on previous compressive strength reports that the concrete will meet the design strength. The Concrete Specification will be revised to permit a maximum slump of 5" + 1".

9. Licensee Action on Construction Deficiency Reports

. Repair of Pipe Support Assemblies

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The program for the repair of pipe support trunnions and stanchions as described in the initial 10 CFR 50.55(e) report dated March 7, 1978 was examined. This examination consisted of a review of the status of the work, observation of in-process and completed work and the review of selected records associated with the repairs. The repairs in Unit 1 are approximately 85% complete. The following five pipe support assemblies were selected for examination:

..,,.',- Support Drawing No. Sheet No.42-37A 049254 43 42-714 . 049254 83 52-33A. 049289 37 585 45A 049264 109 i 585-37A 049264 95 h

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The visual quality of the completed welds was excellent and the surface was properly prepared for the applicable non'd estructive examination. The quality records associated with the assemblies noted above were reviewed. These records included Field Process Sheets, Rod Issue Slips, Liquid Penetrant Examination Reports and Wall Thickness Measurement Sheets, where required. All records accurately reflected the status of the work and properly documented the repairs performed. No items of noncompliance or deviations were

% noted. ,

10. 0A Audits The licensee's internal audit system was inspected by examining nine QA audits performed during the period from May 25, 1978 through

- July 6,1978. In the conduct of these audits, the licensee identified 14 findings which required corrective action. The corrective actions had been initiated or completed.

11. Nonconformance Reporting GFA's nonconformance reporting system was examined. The system appeared adequate and a review of NCR's, plus discussions with fF ;,, cognizant personnel indicated that all identified nonconformances G3 were being documented and written in a timely manner.

m .s . .

'5' The PG&E Nonconformance (NCR) and Minor Variation Reports (MVR) generated since June 3,1978, in the Mechanical, Civil and Elec-trical disciplines were reviewed. The documented deficiencies appeared to be properly classified as either an NCR or MVR in accordance with procedure and were being followed and clo. sed out n'i44 in a timely manner. No items of concern were identified by the

'e - inspector during this review.

12. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on July 13, 1978, and summarized the inspection purpose, scope.and findings. The inspectors expressed their continued interest and concerns regard-ing the implementation of modification contractor QA/QC programs -

and noted that while the physical work appears to be satisfactory, ,

I there are some minor inconsistencies in the documentation of work c- activities. The licensee noted that additional evaluations of con-

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tractor activities would be performed and any inconsistencies would

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be resolved. -

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