ML20083B734

Plan to Verify Quality of Const, in Response to Section IV.B(2)(a) of NRC 821112 Order to Show Cause & Order Immediately Suspending Const (CLI-82-33)

ML20083B734
Person / Time
Site:	Zimmer
Issue date:	12/19/1983
From:	BECHTEL GROUP, INC.
To:
Shared Package
ML20083B697	List: ML20083B694 ML20083B717 ML20083B734
References
CLI-82-33, PROC-831219, NUDOCS 8312210261
Download: ML20083B734 (200)

Text

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y/ THE CINCINNATI GAS & ELECTRIC COMPANY - - - -

clNCINN Ah omo 45201 December 16, 1983

s. wnuam s. , LOZ-83-0242 SEh6CR VICE PRESIDt%f huCLtam OPEmanONS Docket No. 50-358 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Attention: Mr. J.G. Keppler Regional Administrator Gentlemen:

RE: WM. H. ZIMMER NUCLEAR POWER STATION - UNIT 1 PLAN TO VERIFY THE QUALITY OF CONSTRUCTION (PVQC)

W.O. 57300, JOB E-5590, FILE NO. 956C

[) Attached in accordance with Section IV.B(2) (a) of the

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Commission's November 12, 1982, " Order to Show Cause and Order Immediately Suspending Construction", is the CG&E Plan to Verify the Quality of Construction (PVQC) of the Zimmer facility. The PVOC contains responses to cuestions contained in your letters dated October 28, 1983 and No" ember 15, 1983, as they pertain to this program. These responses also reference the section within the PVOC which provides a more detailed response.

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Our preparation of detailed procedures for implementation of the PVQC is in progress. These procedures will be made available for your staff review at the site at their convenience.

Should you have any cuestions or recuire any additional information, please let me know.

Very truly yours, THE CINCINNATI GAS & ELECTRIC COMPANY

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SENIOR VICE PRE. DENT

(~s k.)

GCF/sfr 8312210261 831219 PDR ADOCK 05000358 A PDR

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Mr. J.G. Keppler Regional Administrator December 16, 1983 LOZ-83-0242 Page 2 cc: NRC Office of Inspection & Enforcement Washington, D.C. 20555 NRC Resident Site Supervisor ATTN: W.M. Hill NRC Zimmer Project Inspector, Region III ATTN: E. R. Schweibinz NRC Of fice of Nuclear Reactor Regulation ATTN: D.G. Eisenhut L.L. Kintner NRC Office of Executive Leaal Director ATTN: Jim Lieberman O

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12/15/83 PVQCCOA

, ( BPC/PVQC RESPONSE TO NRC QUESTIONS ON COA ROUND 1 (Reference NRC Letter J.G. Keppler to J. Williams,Jr. Dated 10/28/83, Enclosure 2)

Question 1. Regarding the determination of the quality of every existing safety-rel'ated system, structure, and component (SSC), as a minimum the SSC list should include the structures, systems, and components in the PSAR (Section i 3.2). In addition, NRC (Region III) will review the more detailed listing prepared by CG&E.

Response: The scope of the PVQC will encompass all safety-related SSCs. Where additional commitments have been made in the FSAR on other SSCs,- these will be included in the scope of the PVQC. Acceptance criteria of these SSCs will be provided by Sargent & Lundy. Sargent & Lundy is preparing a list which identifies all such SSCs. Reference PVQC Program, Page 8, Paragraph 4.

Question 2. Does procurement documentation review include verification i

O. that suppliers' Quality Assurance programs have been determined to be acceptable and the supplier is on the Approved Vendors List (AVL)?

Response: PVQC will verify that vendors are identified on an Approved Vendors List (AVL). The AVL will be supplied by CG&E, HJK and other contractors. In addition, PVQC will verify the AVL in accordance with the provisions on Page 33 of the PVQC.

Question 3. Will PVQC review documents to a set of " validated" design drawings and specifications or to the drawings and specifications approved for construction on November 12, 19827 l Response: PVQC will utilize both the current design drawings and specifications and those A/E approved design drawings as of November 12,'1983, as follows:

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1. The visual and physical inspection process requires the use of A/E approved design drawings for these activities. These will be the current design drawings and specifications. Reference PVQC Program, Page 20, Paragraph 3.

2. After completion of these activities a comparison evaluation will be performed between as-constructed design drawings, specifications or other documentation, as necessary, and the approved l

I 12/15/83 Page 2 baseline data as of November 12, 1983. The PVQC refers to those as " validated" design documents. The results of this comparison will be included in the QA trend program where appropriate. Reference PVQC Program, Page 44, Paragraphs 4 and 5, Baseline Data Comparison Evaluation.

Question 4. If the review is to a " validated" original, explain the validation process. If the review is to both a " validated" design and the design approved for construction on November 12, 1982, provide additional clarification.

Response: " Validated" hase line data refers to the approved design as of November 12, 1982, and is defined in Section 2.2 of the PVQC Program. The validation process requires the Sargent and Lundy organization to formally identify the revision status of approved design documents as of the date of the show cause order. Reference PVQC Program, Page 7, Paragraph 3.

For part 2 of Question 4, see response to Question 3.

() Question 5. General statements, "...may be uncovered..." and "...may be physically inspected..." do not provide sufficient guidance as to when these actions are performed. Provide further

, guidance to clarify these statements.

Response: The question as stated . refers to the last sentence of Paragraph 1. Page 23 of the 00A which states: " Inaccessible i

portions of SSCs may be uncovered in order to be visually inspected or they may be physically inspected." In the PVQC l Program, Sections 2.0 and 4.0 provide clarification of the term " Inaccessible" and provides a detailed description of visual and physical inspection activities. (Also see i

response to Question 7.) Reference PVQC Program, Pages 26 through 30.

Question 6. The statement that physical inspections will be performed on ,

a sample basis is too general. Proviue additional information relative to the standards used to determine sample size and the degree to increase in inspections when ~

one or more items in the sample size are found deficient.

Response: Sample basis methodology is described in the PVQC Program.

The specific details supporting the described methodology will be detailed in procedures and/or Quality Verification

() Instructions. Reference PVQC Program, Page 28, Paragraph 3 through 30; Page 40, Paragraphs 5 through Page 42, last paragraph.

12/15/83 Page 3 O Clarify the difference between " visual" and " physical" Question 7.

inspections. Guidance should be provided as to what criteria will be used to determine acceptance of the visual inspections.

Response: Visual inspection consists of those examinations that can be performed without special tests and without destructive examination. This includes identification of material and equipment numbers, determination of configuration and

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dimensions, identification of inaccessible areas / components, nonconformances, conformances and collection of other as-constructed data. Equipment for visual inspection will include items such as tape measures, rulers, electronic measuring devices, levels, micrometers, calipers and gauges.

Reference PVQC Program, Page 26, Paragraph 1 through Page 28',

Paragraph 2.

Physical inspections of safety-related SSCs will be performed to provide the as-constructed status of non-visual attributes, when visual inspections will not provide the data required, and to determine whether the as-constructed status conforms to the requirements of design drawings and specifications. SSCs to be inspected include those recommended in the report of the NRC Evaluation Team f-)S (m (Reference 8); reports of the National Board of Boiler and Pressure Vessel Inspectors; NRC inspection reports; the relevant specific and general public allegations now on file; the areas that are the subject of extensive or significant nons 'nformances identified by the Quality Confirmation Program (QCP) and in 10 CFR 50.55(e) reports. There may be some portions of the safety-related SSCs verified by the document review as conforming but that have not been confirmed by physical inspection. These portions will be the candidates for confirmatory physical inspections. Physical inspections will include nondestructive examinations, destructive examinations, and other incpections that can only be performed with special tests or equipment. Reference PVQC Program, Page 28, Pargraph 3 through Page 30, Paragraph 4 and Appendix F.

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Question 8. What is considered " inaccessible"? Who makes this determination?

Response: The term " inaccessible" is defined in Paragraph 2.2 of the PVQC Program. The Project Field Engineer-PVQC will determine what is inaccessible. Reference PVQC Program, Page 5, Paragraph 7 through Page 6, Paragraph 1.

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12/15/83 Page 4 O Question 9: When a portion of a. system is required to be visually inspected by a code to which the licensee is (previously) committed and that portion is deemed " inaccessible," what actions will be pursued by the licensee relative to previous commitments in the PSAR/FSAR?

Response: PVQC will verify all accessible SSCs by visual inspection to approved design drawings and specifications (which address

'the mandatory code requirements) . Physical inspection will

be performed on SSCs inaccessible (non-visual) items as appropriate to supply the required data. SSCs that are inaccessible and have acceptable documentation will be subject to confirmatory physical inspection to provide additional assurance of compliance to design documents.

! Similar accessible items to those inaccessible will be

-considered in review of the inaccessible evaluation.

Reference PVQC Program, Page 40, Paragraph 5 through Page 41, Paragraph 2.

Question 10: Has CG&E or its contractors identified any system or parts of

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systems that by fuel loading will not meet the code (s) previously committed to by CG&E?

() Response: No. If any systems or parts of systems are identified as not meeting code by the time of fuel load, as previously committed by CG&E they will be brought to the attention of the NRC. It is the intention of the project that all such conditions, if identified, will be resolved before fuel load.

Question 11: Will all nonconformances be recorded as a "nonconformance" report? .

I Response: Yes. Reference PVQC Program, Page 39, Paragraph 3 through Page 40, Paragraph 3.

Question 12: Will any other document or record be used to identify a condition adverse to safety-related criteria such as a

" deficiency report? If so, what other documents may be used in this manner? ,

Response: During the performance of PVQC activities, suspected deficiencies will be identified and tracked by the use of a

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discrepancy list. During the status determination process for SSCs, nonconformance reports will be initiated for all SSCs listed on the discrepancy list which are determined to be valid nonconformances (e.g., during the walkdown a O discrepancy may be noted and during the status review it may i

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12/15/83 Page 5 O

be determined.that an existing nonconformance report has previously identified the nonconformance; the discrepancy would not be documented again on an NCR). Reference PVQC Program, Page 38, Paragraph 3.

Question 13: If documentation other than nonconformance reports will be used, what criteria will be employed to determine which type of documentation should be useshould be used? What supervisory review will be established to assure the proper distinction is made?

. Response: Discrepancies will initially be identified and tracked on a Discrepancies list. During status determination, evaluation by the PVQC team (Quality Control and Pield Engineering) will be performed to determine if the discrepancy is to be reported on a nonconformance report. An investigation will be performed to identify duplicate NCRs, obtain improperly filed documentation, material traceability numbers, etc., and the results of the investigation used to evaluate the discrepancy. Quality Control personnel assigned to the team will review each discrepancy listed and concur with its final determination which includes issuing nonconformance reports.

O, Each completed verification package is further subjected to a review by QC personnel other than those who performed the initial verification. Reference PVQC Program, Pages 13, 28, 30, 33 and 34.

Question 14: The COA states that Bechtel will utilize personnel from CG&E

, for member (s) of PVQC team (s). Does CG&E intend to use the CG&E team sembers to both participate in and oversee the

' activities of Bechtel?

Response: The personnel assigned to the Manager of PVQC and Nuclear Project Support Services have the responsibility for overseeing Bechtel activities. These individuals will not be assigned as team members. The CG&E members of the PVQC teams participating in PVQC activities will have no other major responsibilities while assigned to PVQC and will not be

" involved in overseeing Bechtel. Re,ference PVQC Program, Page 22, Paragraph 2.

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12/15/83 Page 6

.O. Question 15: Is it planned to continue the QCP as a subset of the PVQC or to cease work on the QCP upon activation of the PVQC. If the QCP is stopped before completion of all of the tasks, please describe how the remainder of the program would be incorporated into the PVQC.

Response: Upon activation of PVQC activities that will encompass the associated QCP activity, the QCP activity will cease and a status report will be developed for the QCF activity.

Should any QCP activity remain to be completed it would be incorporated in PVQC, Any reduction in scope to the QCP.

activity will be submitted to the NRC for approval.

Reference PVQC Program, Page 18, Paragraph 3 through Page 19, Paragraph 1.

Question 16: What is meant by " concentrated" inspections to be provided by the PVQC7

. Response: PVQC will " concentrate" inspections in certain attributes of .

SSCs to investigate generic concerns identified' by QCP. In addition, physical inspections will " concentrate" on' deficient areas. This will be accomplished as depicted in the PVQC Program. Reference PVQC Program, Page 19, Paragraph l

_O 1, Page 28, ,sragra,h 1 through Page 30 Paragra,h 1.

l Question 17: The statement, "...significant quality concerns..." is used to determine when corrective action is initiated to prevent recurrence. This statement must be sufficiently clarified so there is no misunderstanding as to when these types of corrective actions are to be performed.

Response: A generic project corrective action procedure applicable to both PVQC and CCP is being developed which will clearly define the phrase "significant quality concerns" in terms of significant singular events, recurring events, items reportable under 50.55(e) and items reportable uader 10CFR Part 21. Reference PVQC Program, Section 6.0.

l Question 18: Will QA/QC inspectors use separate procedures or sign construction check lists at a predesignated hold point (both

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for QCP and ,PVQC)?

Response: All PVQC personnel will perform verification activity in accordance with PVQC procedures that provide for

! documentation of QA/QC activity, including establishing and O -

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0 acknowledgment of QA/QC hold points on verification checklists. PVQC will utilize their own procedures and checklists. Reference PVQC Program, Page 33, Paragraph 3 through Page 34, Paragraph 3, Section 6.0.

Question 19. Will a revised quality assurance manual be submitted for CG&E, Bechtel, Kaiser? ,

Response: Yes. The manuals are being revised and will be available for NRC audit at the site. .

Question 20. Does the PVQC include systems that may be considered

" associated" systems, e.g., non safety-related cable run in a safety-related tray; non safety-related pipe which is mounted above a safety-related pipe; adjacent masonry walls.

. Response: ' To the extent that these subjects are committed to in the Zimmer FSAR, Sargent & Lundy will include them on the list of SSCs to be inspected and provi-de acceptance criteria for meeting these commitments. Reference PVQC Program, Page 7, Paragraph 2.

Question 21. Will the PVQC inspect these "Q" systems against drawings, design specifications, and construction specifications?

Response: PVQC will inspect these systems against design drawings and specifications and construction specifications as approved by the architect-engineer for construction. Reference PVQC Program, Page 11, Paragraph 3 and Page 24, Paragraph 2.

Question 22./23.

Will the PVQC review all design drawings and specifications?

(If not, which ones will they review?)

Response: The PVQC scope of work covers safety-related systems, structures and components and, therefore, only the 4.pplicable design document will be reviewed. In addition, PVQC will utilize the current, approved design documents for

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verification purposes and therefore will not review all previous designs and design revisions except as provided for by baseline data comparison activity and except as necessary to determine whether an item is a nonconformance or incomplete by virtue of subsequent design changes. PVQC will 0 et review a 7 des 81 n drawinas and sPecificatien fer technical adequacy. Reference PVQC Program, Page 24, Paragraph 2.

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Question 24: Will the PVQC review all construction dra ings? (If not, which ones will they review?)

Response: PVQC will not review all construction drawings (those prepared by H.J. Kaiser or contractors). Some construction drawings, such as PSKs and ISKs, may be utilized to supplement use of approved design drawings. PVQC will use construction drawings that are approved design by Sargent &

Lundy. PVQC will only review drawings, within the scope of PVQC. PVQC will review any installation data recorded on construction drawings. PVQC will not review construction drawings for technical adequacy. Reference PVQC Program, Page 24, Paragraph 2.

Question 25: Will the PVQC review all construction specifications? (If not, which ones will they review?)

Response: PVQC will review all construction specifications to ensure that specifications reflect the appropriate S&L design. Some construction specifications, such as expansion anchor bolt installation, may be utilized to supplement use of approved design specifications. PVQC will not review construction specifications for technical adequacy. Reference PVQC

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() Program, Page 21, Paragraph 2.

Question 26: Will any Bechtel approval signatures be on any documents?

Response: Bechtel will sign, during the verification process, the Quality Verification Checklists (QVCL). There will be no Zachtel approval signatures on any approved design drawings and specifications except for those required by the PVQC Program.

Question 27: Will QC inspectors do the system inspections? If yes, will they report to a quality assurance manager or the PVQC manag'er? If they report to the PVQC manager, what quality assurance / quality control activities will be connected with the PVQC?

Response: Yes, Quality Control personnel assigned to PVQC are directly supervised by lead QC engineers who report to the PVQC Project Quality Control Engineer who is directed by the Project Quality Control Manager. The Assistant Project Director for PVQC will provide project coordination through the PVQC Project Quality Control Engineer including the identification of assigned tasks to be performed by O

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quality control personnel. Quality Control personnel performing PVQC verification activities will be assigned to verification teams for the validation of collected data and performance of inspection, as appropriate and necessary, to complete team verification tasks. Team leaders coordinate directly with assigned QC personnel. Reference PVQC Program, Peges 22, Paragraph 1 through Page 24, Paragraph 1; and Section 5.0.

Qpestion 28. What records will the personnel conducting the system walkdown generate?

Response During walkdown PVQC will generate PVQC completed checklists; nonconformance reports; nondestructive examination reports, including radiographs; destructive test results; and other special test results, when required. All of the above are considered QA/QC records when fully processed. Additional items generated such as deficiency lists and as-built status drawings detailing completion status of a system will be controlled documents. Reference the PVQC Program, Page 25, Paragraph 2. ,

O Question 29. Will these records be classified as " Quality Assurance" or

" Quality Control" records?

Response: See answer to Question 28.

Question 30. Will PVQC review all records relative to previous safety-related construction?

Response: PVQC will review quality related records and documents as described in the PVQC Program. Reference PVQC Program, Page 30, Paragraph 3 through Page 34, Paragraph 3.

Question 31. When some portion of safety-related structures, components, ,

supports, or equipment is not available for inspection and acceptable documentation does not provide sufficient evidence that the activity was performed in a quality manner, what actions will be performed?

Response: Those SSCs that are not available for visual inspection and have acceptable documentation, whether or not this documentation is adequate to substantiate that a particular quality level has been achieved, will be candidates for

() physical or confirmatory inspection. Reference PVQC Program, Page 14, Paragraph 4 through Page 16, Paragraph 2; and Page 40, Paragraph 1.

12/15/83 Page 10 O Question 32: After an examination of a safety-related construction activity, including a quality record, or quality document, and a condition advarse to a requirement is confirmed or suspected, what actions will be performed?

Response: Suspect conditions, not confirmed as a condition advera to a requirement, will be identified as a discrepancy and tracked by the use of a discrepancy log until such time the condition is confirmed or resolved as being conforming. Conditions adverse to a requirement which are confirmed will be documented on a nonconformance report. Reference PVQC Program, Page 3G, Paragraph 3 through 4; and Page 40, Paragraph 3.

Question 33: h e physical control and protection will be provided to both quality related documents and records?

Response: During PVQC review of quality related documents and records, physical control and protection will be maintained in accordance with approved procedures which will define specific requirements such as controlled access, filing, and protection. Reference PVQC Program, Page 58, Paragraph 5.

Question 34: N will do the training and certification of the personnel conducting the PVQC7 Response: Teams will be trained by Bechtel and certification will be performed by Bechtel for those conducting the PVQC.

Reference PVQC Program, Page 22, Paragraph 4 through Page 23, Paragraph 1 and Section 8.2 (entire section).

Question 35: h t training will individuals receive prior to performing activities pursuant to the PVQC?

Response: The training of PVQC Personnel prior to performing activities pursuant to the PVQC will be defined in the PVQC training matrix. The training of PVQC personnel is defined in the training matrix and includes indoctrination training and training in the discipline task its individual is working.

Reference PVQC Program, Page 71, Paragraph 4. ,

Question 36: h t previous occupational experience will be required as a prerequisite to selection of individuals for examination of quality-related construction, records, or documents? How will this be verified?

Response: Each individual selected to examine quality-related hardware, records or documents will have a sufficient combination of education and experience to ensure understanding, and ability 1

12/15/83 Pags 11 l g to implement, the principles of quality construction and procedures related to the individual's assignment. Quality Control personnel performing examination of quality-related construction records, and documents will be certified in accordance with the Project Quality Assurance requirements.

Specific requirements for personnel qualification are to be detailed in project procedures. Verification of prior employment is made in accordance with personnel procedures.

Question 37. Will the walkdown of a particular system be made relative to all requirements applicable to that system, e.g.. code, design drawing and specification, construction drawing and specification and QC procedures? If one or a selected group of documents is used for the walkdown, how will the licensee assure that this group of documents contain all of the requirements relative to that particular installation?

Response: The walkdown of a system is accomplished to a specific verification instruction prepared for each unique type of equipment, component, installation or commodity to be

verified during walkdown activities. Each verification instruction shall incorporate, as applicable requirements (attributes) obtained from

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a. The Architect / Engineer

b. Applicable standards, codes and. code cases

c. Drawings, specifications and procedures

d. Purchase Orders

e. NRC Committaents and NRC Evaluation Team (NET) report

. f. National Board and ASME audits

g. Immediate Action letter l

h. Show Cause Order CL-82-33

i. 50.55(e) reports -

j. Other documents and public concerns, where relevant and on file.

Major attributes will be identified or concurred with by Sargent & Lundy and used in PVQC. Thr verification instructions will be prepared by PVQC Field Engineering and

, O reviewed and approved by Quality Control to assure instructions address all relative requirements. Reference PVQC Program, Fage 20, Paragraph 3 through Page 21, Paragraph 1; Page 24, Paragraph 2; and Appendix B, Page 1.

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12/15/83 PVQCCOA3 4

RESPONSES TO NRC PVQC QUESTIONS ,

Round 2

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(Reference NRC Letter J.G. Keppler to J. Williams,Jr. Dated 11/15/83, Enclosure 2)

Question 1: The PVQC should address the process for self-monitoring,  ;

identification of needed changes to the PVQC, and the '

process for making these adjustments.

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Response: A. In addition to the independent auditor, PVQC will be [

audited and monitored by Bechtel and CG&E QA providing an internal mechanism for monitoring. Reference PVQC Program, Page 33, Paragraph 4.

B. Quality assurance will be trending PVQC _ audit findings, i corrective action requests, and findings from outside auditors. Periodic QA management reports will be issued discussing the PVQC operation. Reference PVQC Program, Page 63, Paragraph 2; Page 64, Paragraph 2; Page 65, Paragraphs 1 and 4.

C. Monthly progress reports will be issued by PVQC discussing status, and progress on near term PVQC

/ activities, results and findings of PVQC, restraints and action items; providing early warning of developing and

.( ) potential problems; and recommending corrective action.

The development and issuance of these progress reports will be controlled by a PVQC procedure. These reports will be forwarded to the NRC by CG&E. Reference PVQC Program, Page- 73, Paragraph 3 and 4.

D. Changes to the PVQC program in light of PVQC findings will follow a formal process including NRC review and approval. This process is further detailed in the PVQC Program. Reference PVQC Program, Page 47, paragraphs 1 and 2.

E. In addition, as a matter of course, periodic PVQC management meetings will be held with key PVQC personnel to evaluate progress and discuss problems.

Question 2: The PVQC should address plans for trending problems / deficiencies / nonconforming conditions and plans for addressing these items determined to be generic or repetitive.

Response: PVQC is the organization responsible for identifying conforming, nonconforming, and incomplete work statuses of d the SSCs. The Bechtel QA organization will review the NCRs

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12/15/83 Recp:nras to NRC PVQC Qu2sticns Round 2/ Enclosure 2 Page 2 e

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generated by PVQC and prepare trends of these nonconformances. In addition Bechtel QA will trend the PVQC audit findings, corrective action requests, and findings from outside audits to which PVQC will respond.

(See discussion and references in Response 1). Reference PVQC Program, Page 62, Paragraph 5. Generic deficiencies will be identified in the Construction Verification Report (CVR). Reference PVQC Program, Page 45, Paragraph 6.

Question'3: Personnel participating in the PVQC and CCP must be qualified and appropriately trained. Have qualification requirements and training commitments been identified?

Response: Personnel participating in PVQC will be qualified and appropriately trained. The specific qualifications of PVQC personnel will be detailed in a PVQC procedure and the training requirements specifically identified by class and/or type of training in the PVQC training matrix. The detailed training requirements are currently being established. ,

[T N-Quality control personnel will either perform, participate in supervising, or surveiling the performance of inspection i or tests intended to verify the quality of construction.

Quality control personnel will be qualified and certified in accordance with ANSI-45.2.6-1978. Reference PVQC Program, Pages 71-73 and Appendix M.

Question 4- The PVQC includes physical inspections of safety-related structures, systems and components on a sample basis.

Describe the basis for determining sample size and acceptance criteria. How will structures, systems, and components be selected for physical inspections? What types of physical inspections will be made? Can you give some idea of the portion of total safety-related structures, systems, and components that will be selected for initial physical inspection? (Page 23, Volume 1).

Response: Verification teams will identify inaccessible items as a result of walkdown inspection activity. Safety-related SSCs will be evaluated by type, construction method, previous tests and inspections performed, etc., and categorized into sample groupings as candidates for physical or confirmatory inspections. PVQC engineering will evaluate and identify sample groups that are to be physically inspected or to be 4 part of the confirmatory physical inspection program.

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12/15/83 Racpens2s to NRC PVQC Ou2sticns Round 2/ Enclosure 2 j

Page 3 The accepeance criteria will either be pre-defined attributes depicted on Quality Verification Instructions and Checklists (QVI/QVCL) or specific data will be gathered and submitted to the A/E for further evaluation. PVQC procedures will be written for executing the sampling program. We cannot at this time quantify the SSCs to be physically inspected. Reference PVQC Program, Pages 28-30; Page 39. Paragraph 5 through Page 43, Paragraph 1.

Question 5: One of four objectives of the physical inspections of safety-related structures, systems and components is to determine the validity of specific and general allegations now "on file" regarding the quality of construction of l Zimmer. Provide a list of the types of allegation on file and describe the type of physical inspections which will be made to determine their validity. (Page 24, Volume I)

Response: A list of representative quality problems previously reported including allegations now on file, and the action planned for further PVQC evaluations including physical i

testing, has been prepared as an appendix to the PVQC program. In addition, a project problem matrix is being developed defining allegations, NET reports, audit findings, 50.55(e), etc, along with any project commitment made as a result. This will be used to address specific and general allegations now on file. The type of physical test will vary depending on the components involved. Types of physical tests and their results have been discussed in the referenced letter. Reference PVQC Program, Appendix P; and J. Williams, Jr letter to J.G. Keppler dated November 18, 1983, Docket No. 50-358, LOZ-83-0233.

I Question 6: Item 159 of Attachment 6, Volume 2, indicates part of the PVQC will be a field walkdown to identify any discrepancies from the validated drawings and specifications. In this field walkdown part of the visual inspection or in addition to the visual inspection? Provide additional details.

Response: The visual inspection process is part of the field walkdown. After the evaluation verification packages (EVP) are developed, PVQC will walk down the accessible SSCs to the currently issued design as defined by Sargent and Lundy.

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12/15/83 R cptn 20 to NRC PVQC Qu2stiens Round 2/ Enclosure 2 Page 4 m

The current design documents will be redlined to depict the as-constructed condition. Deviations from the current design documents will be noted on discrepancy lists and identified as a design change as appropriate. In addition, PVQC will provide a baseline data comparison to the as-constructed condition. A comparison evaluation will be performed to identify Quality Assurance problems or discrepancies that exist between the A/E validated (baseline) design drawings and specifications in effect on the date of the SCO and the as-contructed design drawings and specifications verified by the PVQC. The purpose of this activity will be to document those quality assurance issues that existed at the time of the SCO which have been resolved by design changes. This is further detailed in the PVQC program. Reference PVQC Program, Page 24, Paragraph 2; Page 25, Paragraph 3; Page 34, Paragraph 5; Page 44, Paragraph 4-5.

Question 7: In light of problems identified in the construction of some of the systems and components in the NSSS, has General Electric provided input to the PVQC and the CCP with respect (j )

to their portion of the Zimmer project? (Page 3, Table 3, Volume I).

Response: PVQC is a project-wide program, including General Electric which is covered by the program details. Where General Electric supplied materials or components, it will be incorporated into the materials review and the contractor fabricating and installing those components will be covered under the fabrication and installation records review and visual and physical inspections program. General Electric will provide input to the inspection criteria and attributes that are to be included on the quality verification instructions and checklists. In addition, General Electric has and will continue to assist in developing lesson plans for PVQC personnel inspecting their scope of work.

Reference PVQC Program, Page 25, Paragraph 2; and Page 71, all of Sectin 8.2.

Question 9: CG&E's plan of action to respond to the NRC Evaluation Test Report (NUREG-0969) does not consider NRR staff letters to CG6E requesting additional information regarding certain NUREG-0969 recommendations concerning design of equipment (letters dated July 26 and August 25, 1983). Commitments made in the response to these requests may influence the final resolution of these items. For example, in Item EH-5 of the table, a commitment was made in a September 21, 1983 letter from CG&E to install backup over-current devices for

12/15/83 R2cp:nsas to NRC PVQC Qu2stions Round 2/ Enclosure 2 Page 5 low and medium voltage containment penetration circuits prior to fuel load. Will the tracking of the NET report items include NRR requests and CG&E responses to applicable items?

Response: CC&E licensing group has developed a licensing commitment tracking system which identifies commitments made by the licencee in response to NET reports and NRR requests. In addition, the project problem matrix being developed by the project also identifies previous project problems, such as NET reports, 50.55(e), and commitments made as a result. No references.

Question 10: On page 27 of Volume 1 of the COA there is a list of significant problems - for example, procurement documentation, welding quality, and, material traceability and a statement that they will be resolved by the PVQC and the CCP. Provide additional detail on how resolution of these problems will be accomplished by the PVQC and the CCP.

( Response: Relative to these examples, PVQC will identify and resolve all discrepancies / deficiencies in essential documentation of physical attributes of safety-related SSCs (i.e. , material composition). In resolving these discrepancies, PVQC may determine the condition to be non-conforming and document it accordingly. CCP may resolve these NCRs as rework, repair or replace or send them to the A/E for evaluation and resolution as to the adequacy of the current condition. In all cases actions will be sufficiently documented to provide an auditable and verifiak e tracking for external review.

The NCR procedure details the process for identification, tracking, dispositioning and resolving of nonconformances.

A summary of this process has been prepared in Appendix H.

A table of representative quality problems previously reported and the action planned for further PVQC evaluation has been prepared as an appendix to PVQC. Reference PVQC Program, Page 39, Paragraph 3; Pages 30-32; Appendix C; Appendix H; and Appendix 0.

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Page 1 of 7 PVQC EXECUTIVE

SUMMARY

i On November 12, 1982, the Nuclear Regulatory Commission (NRC) issued a I show cause order, which immediately suspended all safety-related construction activities. at the William H. Zinser Nuclear Power Station

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(Zinser). Additionally, the order directed The Cincinnati Gas & Electric Company (CG&E), the project manager of Zimmer, to obtain an independent review of the management of Zinser, to submit for !!".C approval a .

reconsended course of action to complete construction of Zimmer, to submit for NRC approval a comprehensive plan to verify the quality of e

• construction (PVQC) of Zimmer, and to submit for NRC approval a comprehensive plan for continuation of construction (CCP). The PVQC then, constitutes only one part of a more comprehensive program to provide reasonable assurance that construction of Zimmer will conform

• with the provisions of NRC regulations and Zimmer's construction permit.

By its very definition, the purpose of the PVQC is to " verify the quality

• of construction" of Zimmer. The quality of construction of Zimmer will be verified by determining whether its existing safety-related structures, systems, and components (SSCs) conform with approved design drawings and specifications supplied to the constructor for use in plant construction. The PVQC will consist of four rain inspection and documentation review activities, which may be conducted concurrently or in sequence, depending on the SSC to be verified. These activities are visual inspections of as-constructed SSCs, physical inspections of O

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() Page 2 of 7 as-constructed SSCs, reviews of documents a... elated with the purchase and supply of fabricated or manufactured materials and equipment, and reviews of documents associated with the site fabrication and installation of SSCs. Following these activities, the individual SSCs will be statused as conf orming, nonconforming, or incomplete. On a sampling basis, in p.rallel with other FVQC activities, confirmatory

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physical inspections of conforming SSCs will be performed. The results of the PVQC will identify conformances and nonconformances between the existing safety-related SSCs and the design drawings and specifications, 1p-and will also identify whether construction work has been completed on the SSCs. This information will provide the basis for planning

? l construction completion under the CCP.

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Verification of the quality of construction of Zimmer will consist of the following process:

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1) Existing project documentation will be gathered and categorized for use in'the PVQC.

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I 2) Data regarding existing safety-related SSCs will be collected by the following means:

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(a) Visual inspections will be conducted on each accessible

! safety-related SSC to determine its as-constructed configuration and to obtain other data for use in determining whether the as-constructed SSC conforms with

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approved design drawings and specifications. Visual l

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Page 3 of 7 O

s inspections will consist of observatione and measurements that can be performed without special tests or equipment.

Where systems are not accessible, physical inspections will be conducted as described in (b) below.

(b) Physical inspections will be conducted where necessary and

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appropriate in the case of an SSC not accessible for visual inspection or when visual inspections will not provide data required. Physical inspections will include nondestructive w

examinations and/or destructive examinations, that can only be performed with special tests or equipment. -

4 13 *

-- (c) Documents will be reviewed to obtain data related to the procurement, receipt, handling, and storage of materials and equipment. A material and equipment identification log will

• • be developed for use in determining whether the documents demonstrate that material and equipment used in each safety-related SSC conform with design drawings and specifications.

(d) Documents will be reviewed to obtain data related to l'

construction installation of each safety-related SSC for use in determining whether the documents demonstrate that the SSC conforms with design drawings and specifications.

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3) Data collected by the above process will be compared to determine O the status of each safety-related item. Any inconsistency l

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between (a) the characteristics of the items that exist according to project documents and records, (b) the characteristics of as-constructed items that actually exist based upon the results of the visual and physical inspection conducted during the PVQC, or (c) the design drawings and specifications governing the item ,

will indicate the presence of a nonconformance, which will be

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documented on a nonconformance report for evaluation and resolution pursuant to the project nonconformance program. If this data is consistent, the item is conforming. This data will y.

also identify any incomplete work.

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4) Features of safety-related SSCs verified to be conforming will be subject to a confirmatory physical inspection program. These physical inspections will be performed on a sampling basis to provide confidence that the relevant portions of the SSCs are, in Jh' fact, conforming as indicated in the documents. This program will utilize physical inspections already performed under the PVQC as a part of the process to provide sufficient confidence in the quality of the relevant portions of the SSCs.

l

5) As verification activities are completed, a construction l

verification report (CVR) will be prepared, which will summarize and evaluate the results of the PVQC for those particular systems, subsystems, areas, or components. This report may be prepared on a system, subsystem, area, or component basis. A final construction verification report will also be prepared

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The above process provides for a comprehensive program to verify the ,

quality of existing construction of Zimmer. This process also accounts for the recommendations in the report of the NRC Evaluation Team on the quality of construction of Zimmer, and the results of CG&E's Quality Confirmation Program for Zimmer and addresses allegations now on file from public groups and other reports on the quality of construction of

/* Zimmer. The PVQC has been designed to ensure that inspections recommended or indicated by these reports will be conducted as part of the PVQC.

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$ -e Although the PVQC will provide a comprehensive plan for verifying the

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. quality of construction, there are several activitie.s that, though

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related to the PVQC, are outside its scope and will not be encompassed by it. First, the PVQC will not include an. independent design review (IDR),

which will be conducted separately to verify the quality of the 3,. engineering and design for Zimmer. Second, the resolution of nonconformances identified during or prior to the PVQC will be handled under the CCP and therefore is outside the scope of the PVQC.

The PVQC will evaluate nonconformances for trends of generic problems.

Disposition and resolution of such nonconformances will be conducted pursuant to a new project program for resolving nonconformances identified during construction of Zimmer. This program is described in Appendix H/ Finally, completion of construction on safety-related SSCs will be performed in accordance with an approved CCP and will not be undertaken under the auspices of the PVQC unless approved to be O

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J performed as part of the inspection process by the NRC. For example, bolt replacement may be part of the sampling process. Thus, the sole purpose of the PVQC is to provide a systematic, controlled method for identifying the status and determining the quality of construction of Zimmer. Activities needed to correct nonconforming items found during the PVQC will be undertaken as part of CCP or in accordance with relaxations to the Show Cause Order.

Several steps will be taken to ensure that the results of the PVQC will accurately identify conformances, nonconformances, and incomplete work in existing safety-related SSCs. First, the verification process will be

$. controlled by procedures and checklists, and will be subject to a quality assurance program. Second, all personnel engaged in verification activities will be trained and qualified to perform the duties required of them. Third, all data and results produced by the PVQC will be J" documented. Fourth, PVQC activities will be subject to quality assurance audits and surveillance under the project quality assurance program.

Fif th, project management will closely monitor the conduct and results of the PVQC by such means as progress reports and periodic meetings.

Finally, PVQC activities will be subject to an independent audit.

Bechtel Power Corporation will manage and direct implementation of the PVQC, in accordance with the policies of and subject to surveillance by CG&E. PVQC activities will be performed by teams of PVQC personnel headed by a Bechtel team leader. Each inspection team will also include at least one Bechtel quality control engineer. Other team members will D

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() originate from Bechtel and other companies including CG&E, Kaiser (for ASME Section III items only), and Sargent & Lundy. PVQC team members who are employees of other companies will receive their technical direction from Bechtel, all team members will be trained and qualified by Bechtel, and every effort will be made to ensure stable team composition. Bechtel quality control engineers will validate all verification data collected by the PVQC teams.

In summary, the PVQC provides for a comprehensive plan to verify the quality of existing construction of Zimmer. This plan will provide reasonable assurance that conformances, nonconformances, and incomplete work in each safety-related SSC will be accurately identified.

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CONTENTS Section Page 1.0 BACKCROUND 1 2.0 DEFINITIONS 3 2.1 Acronyms 3 2.2 Terms 5 3.0 PURPOSE AND SCOPE OF THE PVQC 8

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4.0 VERIFICATION PROCESS 11 4.1 Policies 11 4.2 Overview 13 Verification Data Collection 14 4

Status Determination 18

\. - Quality Confirmation Program (QCP) 18 Baseline Data Comparison Evaluation 19 4.3 Specifics of the Verification Process 19 Components of the Database 19 Personnel 22 Preparatory Activities 24 l

Visual Inspections 26 1

Physical Inspections 28 Document Review 30 Material and Equipment Documentation 30 l

Construction Installation Documentation 32 Use of Data From QCP and Other Support 33 l

Verification Programs Documentation of Results 33 QA/QC Audit and Monitoring 34 l

O Status Determination 34 l

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Page 2 of 3 CONTENTS (Continued)

Section Page Discrepancy List . 38 Conformances 39 Nonconformances 39 Incomplete Work 40

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Confirmatory Physical Inspection Program 40 Example of a Sampling Method for the 41 Confirmatory Inspection Program

, Confirmatory Physical Inspection Personnel and Activities 43 Product of the Verification Process 43 e

Baseline Data Comparison Evaldation 44 Construction Verification Report 45 Evolution of the Verification Process Applicable to 47 Confirmatory Inspection Program 5.0 ORGANIZATIONAL STRUCTITRE FOR PVQC 48

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5.1 Management of PVQC -

48 5.2 Interfaces 49 5.3 Bechtel PVQC Staffing 49 6.0 QUALITY ASSURANCE PROGRAM FOR PVQC 54 6.1 Policies 54 6.2 Implementation 54 6.3 Division of Responsibility 55 6.4 Appendix B to 10 CFR 50 56 l

6.5 Additional QA Considerations for.PVQC - 65 O

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CONTENTS (Continued)

Page Section 66 7.0 INDEPENDENT AUDIT OF PVQC 7.1 Selection and Qualifications of Independent Auditor 66

7.2 Purpose and Scope

of the Independent Audit 67 7.3 Evaluation of Reports of the Independent Audit 68

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69 8.0 ADMINSTRATIVE SUPPORT ACTIVITIES 69 8.1 Schedule 8.2 PVQC Training 71

• 73 8.3 Progress Reports 74

9.0 REFERENCES

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0 APPENDICES Appendices Title A. Sample Classification List for Safety-Related Systems, Structures, and Components B. Typical Visual Inspection Activities C. Typical Review Points for the Material Documentation Review (for Piping)

D. Types of Data To Be Collected During Material Documentation Review E. Types of Construction Installation Documentation To Be Reviewed F. Examples of Confirmatory Physical Inspections

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G. List of Representative Quality Problems (by Task)

H. Description of Project Nonconformance Procedure (NCRs) r 4.

I. PVQC Document Control J. PVQC Computer Applications K. Flow Diagrams PVQC Activities Acquisition of Documents Visual Inspections Physical Inspections Material Documentation Review Construction Installation Documentation Review L. PVQC Implementation Schedule M. PVQC Training Matrix N. Initial Systems, Areas, and Components to be Verified O. Problem Resolution Matrix i

P. Specific Examples of Physical Testing Methods l

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N- FICURES 1

Title Page

) Fiaure FLOW DIAGRAMS

't Appendix K 1 PVQC Activities 2 Acquisition of Doctaments Appendix K 3 Visual Inspections Appendix K 4 Material Documentation Review Appendix K 5 Construction Installation Document Review Appendix K 6 PVQC Organizational Interfaces 50 7 Bechtel PVQC Organization Chart 53 8 PVQC Implementation Schedule Appendix L h .

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Page 1 of 75

1.0 BACKGROUND

On November 12, 1982, the Nuclear Regulatory Commission (NRC) issued an

" Order to Show Cause and Order Immediately Suspending Construction" (SCO)

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regarding the William H. Zimmer Nuclear Power Station (Zimmer)

(Reference 5). Among other things, the SCO stated that "the Zimmer facility has been constructed without an adequate quality assurance (QA) program to govern construction and to monitor its quality, resulting in the construction of a facility which currently is of indeterminate

. quality." The SCO immediately suspended all safety-related construction at Zin=er and directed The Cincinnati Gas & Electric Company (CG&E), one

.' of the licensees and project manager of Zimmer, to undertake the n

y following four actions prior to beginning any additional safety-related construction activities.

p- o Retain an independent organization approved by the NRC regional administrator to review the management of the Zimmer project (including the QA program and the quality confirmation program), and, to consider,

. at a minimum, the four alternative management structures described in the SCO, then to recommand measures to ensure that construction of Zimmer can be completed in conformance with NRC regulations and the construction permit.

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o Submit for approval to the NRC regional administrator a recommended l course of action based on the independent organization's review and a l

schedule for implementing those recommendations, oa

Page 2 of 75 O I I

o Submit for approval to the NRC regional administrator a comprehensive plan to verify the quality of construction (PVQC) of Zinner, including an l audit by a qualified independent organisation to verify the adequacy of the quality of construction.

i' o Submit for approval to the NRC regional administrator a comprehensive

p. ..

continuation of construction plan (CCP) based upon the results of the

! verification program.

W la short, the SCO requires CG&E to establish a four part program as a prerequisite to continuation of safety-related construction activities.

. The first two parts were completed with:

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o The selection and approval of Torrey Pines Technology (TPT) as the independent management reviewer and the submission of its recommendations m' regarding the management of Zimmer in August,1983 (Reference 9) o The submission of CG&E's recommended Course of Action (COA) submitted october 5,1983 (Reference 6).

The PVQC, which is described in detail in this document, has been prepared to satisfy the third part of the SCO calling for a comprehensive plan to serify the' quality of construction of Zimmer. The fourth and f'inal part, r.he CCP, is under development and will be suhaitted to the NRC at a future date. Thus, the PVQC constitutes only one part of a larger program designed to provide reasonable assurance that construction

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of Zinner will conform to NRC regulations and to Zimmer's construction permit.

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Page 3 of 75 0 ,

2.0 DEFINITIONS 2.1 ACRONYMS  !

A/E Architect / Engineer ANSI American National Standards Institute AQL Acceptance Quality Level ASME American Society of Mechanical Engineers AVL Approved Vendors List

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CAR Corrective Action Report CCP Continuation of Construction Plan C0A Course of Action j CVR Construction Verification Report CWIS Computerized Weld Information System e.

b DDC Design Document Change O. FSAR Final Safety Analysis Report HJK Henry J. Kaiser Company l IDR Independent Design Review LTPN Lot Tolerance Percent Nonconformance NET Nuclear Regulatory Commission Evaluation Team NR Nonconformance Report (issued prior to implementation of the nonconformance program described in Appendix H of this plan)

NCR Nonconformance Report (issued under the nonconformance program described in Appendix H of this plan) l NRC Naclear Regulatory Commission O

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NQAM Bechtel Nuclear Quality Assurance Manual OC Operating Characteristics PQAM Project Quality Assurance Manual PVQC Plan to Verify the Quality of Construction QA Quality Assurance QC Quality Control

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.. QCP Quality Confirmation Program QVCL Quality Verification Checklist SCO " Order to Show Cause and Order Immediately Suspending Construction" or Show Cause Order 1p S&L Sargent & Lundy Engineers SSC Systems, Structures, and Components *

i. TPT Torrey Pines Technology (a Division of GA Technologies, Inc.)

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Page 5 of 75 2.2 TERMS APPENDIX B TO 10 CFR 50 - NRC regulations governing quality assurance AREA - the section or part of a plant typically defined by coordinate lines, elevations, or room designations, or functional purpose

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AS-CONSTRUCTED - safety-related SSCs as currently constructed

• AS-CONSTRUCTED STATUS - the status of existing work as determined by the PVQC . ,

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AS NECESSARY AND APPROPRIATE - the extent.of quality examinations, applications, and/or evaluatica ac'tivities which are sufficient to form a basis for acceptance of a particular activity.

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APPROVED DESIGN DRAWINGS AND SPECIPICATIONS - design drawings and specifications by the architect /;agineer for construction at the time of

- the verification process of that SSC. Defines requirements provided to the constructor by tha responsible designer that identify the necessary attributes and chsracteristics for construction of SSCs. These include DDCs and NRs that document nonconformances which have received approved dispositions of " repair" and " accept-as-is" INACCESSIBLE - an SSC or part of an SSC is inacessible when, due to its physical location or configuration, it cannot be visually inspected r- '

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Page 6 of 75 without removing or invalidating installed work. Characteristics of SSCs which are normally inspected in process or which subsequent construction processing covers and therefore cannot be inspected are considered inaccessible. Examples include piping fit-up, root veld and subsequent layers under the cover pass, anchor bolt hole drilling, embedeent in concrete, etc. An SSC is not considered inaccessible if it can reasonably be reached by scaffold erection, if access to the SSC requires the physical size of the inspection personnel to be limited or if the SSC can be viewed by removal of access covers or panels, e.g. electrical consoles, cabinets, conduit boxes, etc. Characteristics covered by paint or insulation are not considered inaccessible. The Project field g . '

Engineer - PVQC is responsiblat for deteruining if an SSC is inaccessible.

INCOMPLETE WORK - construction or inspections that have been performed in accordance with design and drawing requirements but have not yet

'* proceeded to a status of completion .

NONVISUAL ATTRIBUTE - an attribute of an SSC that cannot be verified by visual inspection PHYSICAL INSPECTION - an inspection performed with special tests or equipment or by inspectors who,have special training or qualifications.

This includes both destructive and nondestructive examinations QUALITY CONFIRMATION PROGRAM - CG&E program established in 1981 to investigate the quality of specific types of items or documents i - - -

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Page 7 of 75 REDLINING - the process of marking a drawing to depict the as-constructed status of an SSC SAFETY-RELATED SSCs - those SSCs necessary to ensure 1) the integrity of the reactor coolant pressure boundary, 2) the capability to shut down the reactor and maintain it in a safe shutdown condition, or 3) the capability to prevent or sitigate the consequences of accidents that

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could result in potential offsite exposures comparable to those referred to in 10 CFR 100.11. As used in this PVQC, the term " safety-related" includes some SSCs that are designed as Seismic Category I or which are W -

subject to FSAR couaitments which expand the scope of the QA program (e.g., fire protection).

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VALIDATED BASELINE DATA - design drawings and specifications for safety-related SSCs approved for use in construction as of the date of the SCO me' VALIDATE - the process of confirming inspections or reviews by observation, including review of documentation, and checking to the degree necessary to provide reasonable assurance of completeness and accuracy VISUAL INSPECTION - an inspection of an as-constructed SSC that can be performed visually without special testing or equipment. These inspections may include, among others, the use of tape measures, fillet gauges, micrometers, borescopes, TV cameras, fiber optics and other visual techniques.

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Fage 8 of 75 O

3.0 PURPOSE AND SCOPE OF THE PVQC By its very definition, the purpose of the PVQC is to " verify the quality of construction" of Zimmer.

The quality of construction of any product, including a nuclear plant, p.

can be verified by determining whether or not the as-built product conforms with the specifications directly governing its construction. In ,

the case of a nuclear plant, construction is governed by the approved w

design drawings and specifications supplied to the constructor. Thus, the PVQC for Zimmer will determine whether construction of Zimmer conforms with the approved design drawings and specifications supplied to v the constructor for use in plant construction. ,

There are two principal methods which are used to determine whether 3*' construction of a plant conforms with the design drawings and specifications, used in construction. The first is to review existing material, equipment, and construction-related documents to determine

• whether they demonstrate that the plant was constructed in conformance with design drawings and specifications; the second is to perform visual and physical plant inspections to determine directly whether constructzon conforms with design drawings and specifications. Both of these methods will form the basis of the PVQC for Zimmer.

The scope of the Zimmer FVQC will be bread. All safety-relsted SSCs will be encompassed within the purview of the PVQC, (See Appendix A for a O' sample list of SSCs.) Additionally, where CG&E FSAR safety related

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5 Page 9 of 75 consitzents have expanded the scope of items subject to a quality program, additional SSCs will be included within the scope of the PVQC.

The acceptance critaria for meeting these commitments will be provided by Sargent & Lundy. Sargent & Lundy is preparing a " classification list" which identifies all such SSCs to be evaluated in PVQC.

p. .

The classification list provided to the PVQC will list the safety-related SSCs at Zimmer. The verification process for the safety-related SSCs will be extensive. Available and relevant documents relatsd to w

procurement and installction of safety-related SSCs will be reviewed to assess the'ir conformance to design drawings and specifications. Visual e

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inapections will be conducted to determine the as-constructed .

-- configuration and to identify other as-constructed characteristics of safety-related SSCs. Additionally, physical inspections will be performed to the degree necessary to provide confidence that the 3* ' condition of as-constructed, safety-related SSCs is as indicated in the documents. The PVQC provides for a comprehensive verifiestion of ths quality of construction of Zimmer.

The results of the PVQC will identify conformances and nonconformances between the as-constructed safety related SSCs and approved design drawings and specifications. In addition, incomplete work will be identified. This information will provide the basis for planning construction completion under the CCP.

Although the PVQC will provide a comprehensive plan for verifying the O quality of construction, there are several activities that, though related to PVQC, are outside its scope and will not be

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Page 10 ' of 75 encompassed by it. It will not include an independent design reviev (IDR) conducted to verify the quality of the engineering and design for Zimmer and it will not determine the resolution of nonconformances or given problems identified during or prior to the PVQC. A separate IDR will be performed independent of the PVQC. Nonconformances identified by PVQC will be evaluated and a trend analysis performed to find generic

.s. .

problems. Disposition and resolution of such generic nonconformances will be conducted according to a new project program for resolving nonconformances (see Appendix B). In addition, the Construction v -

Verification Report (CVR) will identify any generic non-conformances in

, the as-constructed SSC. Completion of construction and any necessary rework on safety-related SSCs will be performed in accordance with the approved CCP and will not be undertaken under the auspices of the PVQC unless approved to be performed as part of the inspection process by the NRC. For example, bolt replacement may be part of the inspectica preccca.

The Bechtel Power Corporation will manage and direct execution of the .i PVQC. Bechtel's organization to perform this work is discussed in Section 5. laplementation of the PVQC will be subject to a quality assurance / quality control program conducted by Bechtel and, further, will be subject to a quality assurance review by CG&E. These QA programs are described in Sections 6 and 7. The PVQC will also be audited by an outside organization which is independent of previous activities associated with the Zimmer project, as described in Section 7. The combination of these checks and balances provides the requisite assurance that the results of the PVQC will be accurate and reliable.

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Page 11 of 75 l 4.0 VERIFICATION PROCESS 4.1 POLICIES The following policies have been established to serve as a basis for defining the specific concepts, procedures, and techniques of the PVQC

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verification process:

o The quality of construction is considered to have been verified when w

it has been determined whether or not safety-related construction conforms with the design drawings and specifications. The approved

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t design drawings and specifications form the standards against which all O'

V verification activities are conducted.

o The collection of verification data is to be accomplished through the

1. ~ use of checklists and other documents that identify applicable requirements in the design drawings and specifications. This will assure rb7: the verification process will address the condition of the safety-related SSC conformance with the approved design drawings and specifications.

o The verification process is structured to produce an objective determination of the quality of construction, i.e., either the

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as-constructed condition of the safety reisted SSC conforms with the approved design drawings and specifications, or it does not.

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o The PVQC is to be executed in a controlled manner. Varification activitics will be conducted according to specific and relevant procedures approved for its implementation.

o Data generated or reviewed by the rv'QC will be documented and will form the only basis for PVQC.results and conclusions.

o PVQC activities shall be subject to QA/QC validations and audits.

Documents and data generated by the PVQC shall be considered controlled es ~

documents and shall be in a form that will facilitate audits.

o o Personnel who perform inspections, or testing, or review quality

,13 k ) '

s documents to verify conformances, will be qualified and certified to the requirements of ANSI 45.2.6.

1. • ' o ' Personnel involved in the verification process will be trained commensurate with their assigned tasks. Verification activity performed during the PVQC shall be surveilled and validated by certified Bechtel QC personnel.

l o Appropriate data gathered during the PVQC shall be organized and

! entered into a database to facilitate status, monitoring and scheduling of PVQC and CCP activities.

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Page 13 ~of 75 o Physical inspections will be performed when necessary and appropriate in cases of an SSC not accessible for visual inspections or when visual inspections will not provide data required.

o Confirmatory physical inspections will be conducted on a sample basis to provide confidence that the as constructed condition of

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safety-related SSCs is conforming as indicated by the documentation review. .

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o Partially completed work will be evaluated to determine whether the completed portion of the work conforms with the approved design drawings O

n. and specifications.

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4.2 OVERVIEW m- There are two main phases of the PVQC: collection of verification data and status determination.

The verification activities of both phases will be grouped and performed on the basis of logical groupings of systems, structures, or components.

These activities will provide reasonable assurance that each safety-related SSC, as it currently exists, conforms to thi approved design drawings and specifications; that nonconformances have been properly identified on NCRs; and that incomplete work and the as-constructed status of each are accurately known (see Appendix K, Overall PVQC Activities).

Page 14 of 75 O

w.,

Prior to beginning PVQC verification data collection and status determination activities, various types of documents will be provided to the PVQC (see Appendix K, Flowchart for the Acquisition of Documents).

This information ir.cludes a classification list of safety-related SSCs; design drawings and specifications; construction aids and sketches used in construction; documents related to materials and construction

~

installation; data from the quality confirmation program (QCP) and applicable reports issued by the NRC, t.SME, and others. Documents will also be provided for the PVQC by CG&E, S&L, HJK, and other contractors involved with Zinuser.

(

• Verification Data Collection ,

O The collection of verification data will consist of four activities that may be conducted concurrently or in sequence, depending on the SSC to be

.1m. - verified. These activities are:

o Visual inspections to determine the as-constructed configuration and other as-constructed data for each accessible safety-related SSCs; identification of those portions of the SSCs that are inaccessible; and determination of existing identification numbers on material and equipment, dimensions of SSCs, configuration, and other attributes required by design drawings and specifications that can be observed wfthout special tests or equipment.

o Physical inspections of safety-related SSCs will be performed when necessary and appropriate to provide the as-constructed status of

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_ . _ _ .._. . ? . _ . . _ . - 1 .

4 Page 15 of 75 O

nonvisual attributes ^, when visual inspections will not provide data required, and to determine whether the as-constructed status conforms to the requirements of approved design drawings and specifications. These attributes are evaluated by using special tests and equipment and by trained and qualified personnel.

The Physical Inspection Program will also:

o be responsive to the findings and recommendations of the ERC i

• • Evaluation Team (reference 8); reports of the National Board of Boiler and Pressure Vessel Inspectors; and NRC Inspection Reports 1

()

o address the specific and general public allegations on file that lend themselves to resolution by physical inspection 3.- o reflect the findings of the QCP and issues addressed in 10 CFR 50.55e reports i

. o Provide, on a sample basis, confirmation that SSCs verified by document review to be conforming are in fact conforming l

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Page 16 of 75 There may be some portions of the safety-related SSCs verified by the document review as conforming but that have not'been confirmed by physical inspection. These portions will be the subject of confirmatory physical inspections which will be of sufficient numbers and' types, based upon statistical analysis, to provide confidence that the relevant

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portions of the SSCs are, in fact, conforming as indicated in the documents.

In cases where the results of the physical inspections indicate that an appreciable number of nonconformances or a significant nonconformance had

$, previously been unidentified, consideration will be given to an expansion of the group of physical inspections, including inspection of up to all of the relevant attributes.

• ~ o Construction installation documentation for all safety-related SSCs will be reviewed to determine their as constructed status ss indicated by the documents, to identify documents that verify the quality of O

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Page 17 of 75 construction, and to identify documents that are defective, missing, or which otherwise do not conform with requirements and, therefore, are deficient for use in verifying the quality of construction.

o Material documentation will be reviewed to provide data regarding procurerent, handling, and storage of materials and equipment of safety-related SSCs. The objective of this review is to determine whether the documents indicate that the materials and equipment conform to approved design drawings and specifications, to develop material and equipment identification lists, and to identify documents which are deficient for use in verifying the quality of materials and equipment.

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Data collection activities will be co'nducted and documented using checklists and other appropriate documents (see Appendixes C, D, and E).

Jn- The sequence of visual and physical inspections and documentation review activities will vary depending on the SSC being verified. For example, for systems, the material document review and the visual inepection could

- be done concurrently. The results then would be compared with the installation documentation to determine whether the SSC was installed in conformance with approved design drawings and specifications and that the proper documentation exists. Appropriate physical inspections would be performed as necessary and appropriate for nonvisual attributes to verify their conformance. A different sequence of activities may be used to

^

verify structures. Visual and physical inspections could be performed concurrently with material and installation documentation reviews, and O

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Page 18 of 75 then the results of these four activities would be reviewed to assess conformance. Once a nonconformance has been determined or it is found that the extent of investigation necessary to firmly establish the condition is not cost effective, the review may be terminated and a decision made to replace the affected SSC. The plan allows flexibility in the sequencing of activities in order to conduct the PVQC in the most efficient manner.

Status Determination ,

ei Status determination will identify conforming, nonconforming, and e -

! g, incomplete work. Data pertaining to an item will be reviewed following

) completion of the verification data collection activity to determine whether inconsistencies exist among the approved design drawings and j specifications, the as-constructed data, from visual and physical

! 3*~ inspections, and existing material or installation documentation data.

l From this verification data it will be determined whether a conformance, l

. nonconformance, or incomplete work exists for each portion of the safety-related SSCs.

Quality Confirmation Program (QCP)

I i The SCO states that the PVQC shall determine whether the scope and depth l

of the QCP "should be expanded in light of the hardware and programmatic problems identified to date." The PVQC described above greatly exceeds the scope of the QCP. Under the PVQC, safety-related SSCs will be subject to documentation reviews and visual inspections for comparison

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Page 19 of 75 against approved design drawings and specifications, and the number and types of visual and physical inspections will be far more extensive than under the QCP. Additionally, the PVQC inspection program will be structured to account for the results of the QCP. For those areas in which the QCP has identified a significant number of nonconformances, the PVQC will provide concentrated inspections of items' attributes not

• ' *

• inspected by QCP. Thus, consideration of QCP expansion has been fully accounted for in the preparation of the PVQC.

• Baseline Data Comparison Evaluation 1

A baseline data comparison evaluation will be performed. The purpose of

{-

k, this activity will be to identify, where possible, desiga changes made subsequent to the SCO that, had the change not occurred, would have

> resulted in a quality assurance program discrepancy.

m' 4.3 SPECIFICS OF THE VERIFICATION PROCESS

. Components of the Database

! To perform the PVQC, it will be necessary to identify and collect l

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Page 20 of 75 O documents relevant to Zimmer constructfon. (See Appendix I that describes s

Construction Document Control, a center for collecting and controlling documents relevant to the PVQC).

In order for the PVQC to utilize these documents in an effective manner, appropriate documents will be recorded in the data base. By appropriately categorizing these documents, the PVQC will be able to identify documents relevant to a particular item with greater efficiency.

The A/E will provide the PVQC with validated data consisting of a classification list of all safety-related and other SSCs subject to PVQC and the design drawings and specifications (including approved DDCs and

() NRs) for such SSCs approved for construction. These approved drawings

'wL11 comprise the basis for verification of the quality of construction and will be used to prepare checklists for collection verification data.

The classification list will be forwarded to the NRC for review.

CG&E, HJK, and other contractors will provide the PVQC with documents and records related to procurement, handling and storage of materials, and documents reisted to construction installation of safety-related SSCs.

These documents will include in process and completed documents such as:

approved vendor lists or the qualification status of vendors; purchase orders for materials and equipment; material logs; records related to receipt, handling and storage of materials; equipment maintenance 1

records; construction aids and sketches; drawing and specification O

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W Page 21 of 75 registers; traveler forms; weld cards; welder certification records; welding procedure and certification records; certified QC and NDE personnel lists; QC inspection records; cable pull cards; contractor and subcontractor listings; inspection records; nonconformance reports; and inspection procedures and other documentation, as required. These records and documents will be subject to reviews to determine whether

~

safety-related SSCs conform to design drawings and specifications according to plant records. In addition, the approved vendors list will be verified as described in sections below.

CC&E will provide data being generated by the QCP. Nonconformances e -

7 identified by the QCP will be used to assist in planning the program of

(_j physical inspections.

In addition to records for materials, equipment, and construction an installation, other types of documents will be used for development of checklists during the PVQC. These include the QCP and NET reports, 10 CFR 50.55(e) reports, reports of the National Board of Boiler and

- Pressure Vessel Inspectors, audit reports, corrective action reports, NRC inspection reports, and allegations now on file.

Appropriate documents identified above will be entered into the computerized database, which will be programmed to provide variable sorting. The computer may be used to sort cross-referenced data based upon requirements to be developed for the PVQC (see Appendix J).

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,4, Page 22 ~o'f 75 Personnel Collection of verification data will be accomplished by teams of The personnel organized according to a system, structure, or component.

1 visual inspection teams may be further divided into groups corresponding to various disciplines (e.g., civil, structural, piping / mechanical, electrical, and instrumentation). The teams for visual inspection will be augmented by specialists and subcontractors approved by Bechtel who will perform physical inspections, such as radiography. These activities w

will be subjected to surveillance and audit by Bechtel.

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) The personnel performing the material documentation reviews will be l

organized into teams as. appropriate to review documents related to a type of material or equipment, vendor, or purchase order.

'"' The personnel performing the construction installation documentation review will be organized into teams similiar to those organized for visual inspections, i.e. , by structure, system, component.

Teams will vary in the number of members. Each team will be headed by a Bechtel team leader. Each team will include one or more Bechtel QC engineers certified to perform the types of inspecti~ons required of that team. Team members will be assigned fulltime to the PVQC and will have no other major responsibilities during the period in which they are working on the PVQC. Non-Bechtel team members will receive training under the Bechtel training program for FVQC required activities.

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Page _ 23 of 75 x

Quality control and field engineering personnel of the contractor responsible for construction of an SSC may be assigned to PVQC teams corresponding to that SSC to assist PVQC field engineering. HJK personnel will be included on PVQC teams reviewing ASME Code Section III systems and will, with one-on-one Bechtel supervision, only perform activities required to fulfill their code commitment. The data obtained

• *

• can be utilized for other PVQC evaluations where applicable. Training and certification in support of such inspection commitments shall be the responsibility of HJK.

en If non-Bechtel team members have concerns about the conduct of the PVQC, they should address those concerns through the Bechtel supervisory

{

]) organization up to and including the Aseistant Project Director - PVQC, If a satisfactory resolution is not forthcoming, they are free to pursue the issue with the CG&E Project Manager for PVQC and Nuclear Project 3-Support Services and through him to the CG%E Project Director and Project Manager.

NOTE: The foregoing in no way precludes anyone who has a concern relative to quality f rom utilizing the established avenues to Bechtel, N N CG&E, and NRC management.

Team members not employed by Bechtel will be directly supervised by Bechtel personnel who will provide the sole technical direction to such

- members while they are assigned to PVQC. When the team member is an RJK ba .

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Page.24 of J QA/QC individual assigned for the purpose of ASME code work, Bechtel will provide one-on-one supervision in conduct of visual and physical inspections. All team members, including those who have been qualified or certified by other employers, will be trained and qualified and will be certified as necessary, by Bechtel to perform the types of inspections or reviews required of them under the PVQC. Bechtel QC engineers will be

~

1, resent during the collection of verification data, and they will validate all data.

@ t Preparatory Activities e -

( Inspections and reviews will be controlled through use of checklists and.

evaluation verification packages which contain relevant documentation, identify activities to be performed, and reference procedures for performing the work. Each team will be assigned an area of

'.**~ responsibility for conducting inspections or reviews. For each such area, the team will assemble applicable design drawings and specifications, A/E identified major attributes and other appropriate

- documents. Based upon the requirements in the design drawings and specifications, checklists will be prepared by Field Engineering that include each of the applicable attributes and characteristics for a particular inspection or review. S&L will provide or approve major attributes for incurporation into the checklists. The ma.ior attributes include those necessary to the safety-related function of an item. These

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Page . 25 of. 75 checklists will be used during data collection, and the results will be documented to provide objective evidence of the review or inspection.

The checklists for the material documentation review will also include requisite attributes and characteristics identified in purchase orders and proced tres governing procurement, receipt, handling, and storage of material and equipment. These checklists will also identify other review points needed to trace the material or equipment (see Appendix C which identifies typical review points for the material documentation review).

-w The checklists for the construction installation document review will include those items necessary to demonstrate that the SSC has been

$, constructed according to design requirements (see Apper. dix E for a list

.p n .

of the types of construction installation documentation that will be reviewed).

D' An evaluation verification package will be used in the inspections. This package will typically consist af the instructions and checklists identifying the items to be inspected or reviewed. S&L will provide or

• approve major attributes for incorportation into the checklists.

Additionally, evaluation verification packages for visual inspection teams will include copies of the design drawings and, if necessary, PVQC aids / sketches for the purpose of " redlining" the drawings to reflect the as-constructed status of the SSCs.

Bechtel QC will review and approve the checklists prior to implementation by the team and also review the finished evaluation verification packages O for completeness.

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Page 26 of 75 Visual Inspections Visual inspections will consist of those examinations that can be performed without special tests or equipment and without destructive examination.

Visual inspections include identification of material and equipment numbers, and the determination of configuration and dimensions. They will determine the as-constructed configuration, identify other

• as-constructed data for each accessible safety-related SSC, and identify

• those portions of the structures and systems that are inaccessible to

( visual inspection. These inspections will also identify components and portions of the structures and systems not yet constructed or installed.

The data generated by the visual inspections will be do'cumented for later l

i use (see Appendix B that lists typical SSCs within each discipline, l

! 2.- typical attributes that will be the subject of the visual inspection, and I

the extent of the inspections). Inaccessible portions of SSCs may be uncovered in order to be visually inspected, or they may be physically

- inspected.

l The visual inspections are to be conducted in accordance with approved l PVQC procedures and will be performed using checklists, appropriate l

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design drawings and specifications, and installation documents.

l Verification data collected will be transcribed onto the appropriate documents, which will provide a record of the as-constructed configuration and other as-constructe'd data.

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Page 27 of 75 The type of visual inspections to be conducted will vary depending upon the type of SSC being inspected. Rum =ples of typical visual inspection activities are included in Appendix B. These visual inspections will be defined and controlled by quality verification instructions and che cklis ts. For example, visual inspections will include, but will not be limited to, the following:

o Piping / mechanical - Visual inspection will be performed on piping, valves, welds, pumps, supports, snubbers, restraints, and hangers.'

, g o Electrical - Visual inspections will be performed on exposed

()

conduit, trays and wireways, supports, welds, juncton boxes, penetrations, busses, cables, panel boards, motors, and motor l

control centers.

l ha ' ,

o Civil - Visual inspections will be performed on concrete structures, penetrations, soils, anchor bolts, embedments, and painting .

l o Structural - Visual inspections will be performed on steel structures; galleries, ladders and stairs; equipment supports; 1

bolting; welding; and special doors.

o HVAC - Visual inspections will be performed on ducts, vents, and dampers; supports; and fans and blowers.

()

l

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() Page 28 of 75 o Instrumentation - Visual inspections will be performed on tubing, supports, and instrumentation.

Upon completion of the visual inspections by each team, a Bechtel QC engineer, who did not collect or validate the verification data, shall review the completed documents to ensure that the required visual

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inspections were completely documented.

4 Physical Inspections

-w Physical inspections will focus on four areas of activity. First, e *

.r g physical inspections will be conducted, where necessary and appropriate, Q* . to obtain as-constructed data, including data on those portions of SSCs that are inaccessible and for which documentatien does not provide adequate assurance of the quality of those portions of the SSCs. This Jn- data will be used for later comparison against approved design drawings i

and cpecifications and for confirmation of data generated by the documentation review. Second, physical inspections will address the

- recommendations for inspections contained in the NET Report, the reports of the National Board of Boiler and Pressure Vessel Inspectors, and in the inspection reports of the NRC (see Section 9, References). Third, physical inspections will focus on deficiencies previously identified in the reports mentioned above, in 10 CFR 50.55(e) reports, by programs such l

l as the QCP, and in the specific and general allegations now on file regarding the quality of construction at Z'immer (see Appendix G, a list of representative quality problems). Fourth, physical inspections will M() be used, where necessary and appropriate, to provide additional confidence

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Page 29 of 75

() . that verified confonaing safety-related SSCs with appropriate supporting documentation and/or visual inspections are in fact conforming.

The physical inspections will consist of examinations that require a

special tests or equipment, specialized training and knowledge, or destructive examination. Examples of physical inspections include spectrometer analysis, ultrasonic testing, torque measurements of bolts, chemical analysis, dye penetration and X-ray examination of welds, hydrostatic tests, strength tests of concrete, soil compaction tests, and structural integrity tests.

Examples of typical physical inspection activities are included in Appendix F, with additional detail for ASME embedded or buried pipe, concrete structures, and electrical equipent given in Appendix P.

Examples -of physical inspections include, but will not be limited to, the

. following

o Bolting will be physically inspected for tension and torque.

o Welding (Piping) will be physically inspected by means of nondestructive examination, destructive examinations, mechanical tests, and chemical analysis, o Material Traceability (Piping) will be physically inspected by means of physical analysis and chemical analysis.

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/ Page 30 of 75 o Cable and Terminations will be physically inspected by means of magger tests, hi pot tests, resistance and continuity tests.

o Motors will be physically inspected by means of megger tests and polarization index tests.

1. ~ '

o Concrete will be physically inspected by strength tests on core samples, ultrasonic examination and destructive testing'at selected locations, w

Data collected during the physical inspections will be transcribed onto j-s the appropriate documents for later use in the PVQC.

U' Document Reviews 3>- The purpose of the material documentation review is to gather quality related data regarding procurement, receipt, handling and storage of material and equipment used in construction installation of all

- safety-related SSCs. This data will be used to prepare material and equipment identification logs that will provide traceability and a material status for the PVQC, and, ultimately, for construction of Zimmer.

Material and Equipment Documentation The material and equipment documentation review will encompass documents related to material and equipment traceability. Material and equipment documentation will be divided for review according to type, vendor, purchase order, or other appropriate category.

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Page 1 of 75 p),

Documents may be identified during the review that were listed in the as-constructed status data, but which are not available. This condition will be documented, and the appropriate organizations will be requested to obtain acceptable documentation. If the documents cannot be located, an NCR will be written.

Review teams will also examine the documents for evidence of unauthorized entries or deletions. Any such modified documents will be reviewed in accordance with PVQC procedures to determine whether the modification

• renders the document invalid and, therefore, nonconforming. This review will cons,ist of the following:

e -

D o the document will be reviewed to determine whether the modification was made in accordance with applicable project procedures. If the modification was made in accordance with them, this fact will be

.1m. -

documented and appropriate data in the document will be used in the PVQC' .

o for modifications not in accordance with applicable project

- procedures, a review will be conducted to de' rmine whether the modification has been identified by the project and resolved. The PVQC N

reviewer will determine whether this resolution has been properly documented and, if so, will document this fact. Data in such modified documents will be used in the PVQC, o for modifications not'in accordance with applicable project procedures and not resolved to the project program, the modified document will be reported on a nonconformance report. Such NCRs will be handled as described in Appendix H.

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Page 1 of 1 Upon completion of the review, documents will be considered as validated construction records. These records will be used in determining the as-constructed SSC status.

Construction Installation Documentation

p. .

The purpose of the construction installation documentation review is to determine whether the documents demonstrate that construction installation of safety-related SSCs conforms to approved design drawings I w

and specifications. This review will encompass documents related to

- const ructio. istallation activity to determine whether the documents e

demonstrate that safety-related SSCs conform to approved design drawings O. and specifications. During this review, the team may identif y documents that should exist, but are not available. This activity will _be documented, and the team will request appropriate organizations to obtain 2* acceptable documents. If the required documents cannot be located, an NCR will be written. The team will examine the documents for evidence of unauthorized entries or deletions. Any such modified documents will be

• reviewed in accordance with PVQC procedures to determine whether the modification renders the document invalid and therefore nonconforming.

This review will follow the same method as the material documentation review, i.e., determining whether a modification was made according to project procedures or not, whether any nonconforming conditions were identified by the project, if it was documented, and if the modified document is a nonconformance or not.

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Page 1 of J Upon completion of the review, documents will be considered as validated construction records. These records will be used in determining the as gonstructed SSC status.

Use of Data f rom QCP. AVL. CWIS, and Other Support Verification Programs

1. • There may be cases in which the QCP, AVL, CWIS or other special verification programs have conducted inspections or reviews similar to those to be included in the PVQC. A group of those inspections or

reviews will be validated under the PVQC to determine the validity' of those results as compared to the approved design drawings and

- specifications. If the results of the two programs are in agreement, the O results of the QCP, AVL, or other special verification programs will be incorporated for use in the PVQC. However, if the results of the PVQC and QCP, AVL, or other special verification programs are not in an agreement, a determination will be made whether to include the results in the PVQC, The criteria for determination will differ from task to task, but will be in accordance with the sampling methodology described in

. subsequent sections. Nonconformances identified in the QCP or any other verification program will be utilized in the PVQC, Documentation of Results Verification data generated by the reviews and inspections will be -

identified on redlined installation documents or other documents 2 sed in the reviews and inspections. Material documentation review teams shall O

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(} Page 34 provide input to a material identification log, which identifies the status of each purchase order and the type of material and equipment.

This log will contain the types of data identified in Appendix D.

Bechtel QC shall determine the accuracy of the completed material identification log. Handling, transmittal, and storage of checklists, material identification logs and other data collection documents will be controlled.

Checki'ists, identification logs, redlined installation documents, activity lists and data collection documents will be submitted to the

-~g computerized records management system.

~_f

• QA/QC Audit and Monitoring 35' -

The data collection process shall be subject to periodic QA monitoring and audits by Bechtel; by CG&E; and by the Independent Auditor. These monitoring and audic activities will determine whether the PVQC

• procedures governing the data collection and logging processes are being complied with and whether the program is being properly implemented.

Status Determination During the status determination process, verification da'ta generated during both the visual and physical inspections and the material and construction installation documentation reviews will be reviewed and

[

evaluated. The purpose of this is to identify conformances,

Page 35 of 75 nonconformances, and incomplete work in safety-related construction and to provide direction for additional confirmatory physical inspection, if required. However, to ensure that nonconformances are not inadvertently overlooked, data pertaining to an SSC collected during the PVQC visual and physical inspection activities will be compared with existing inspection and documentation data to check for inconsistencies.

Evaluation verification package and checklists will be used to control analysis of verification data. ,

es Personnel determining status will be trained and qualified by Bechtel,

p. .

and certified Bechtel QC engineers will validate the status results.

O. Status determination will be performed only by Bechtel personnel. They will use checklists for comparing the approved design drawings and specifications against inspection data and documentation review data.

• • The results of this status review will be documented. The Bechtel QC engineer will review the checklists and other documentstion for completeness prior to final approval of the verification packages.

By using appropriate documents such as redlined drawings, Bechtel documentation teams will determine those portions of the safety-related SSCs which have not been constructed or installed. This work shall be classified as incomplete in accordance with the Problem Resolution Matrix in Appendix 0.

f Page 36 of 75

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s.

As a result of design changes, there may be cases where the as-constructed status of an ites is consistent with the ccustruction installation documentation, and is consistent with the design drawings and specifications actually used in construction, but is inconsistent If the with the-current approved design drawings and specifications.

inconsistency can be demonstrated to be the result of a design change it will be designated as incomplete work and processed accordingly (see Appendix 0). All other inconsistencies, including those where doubt of actual reason for the inconsistency exists, will be classified as w

nonconforming and processed accordingly. A list of incomplete work for each SSC will be prepared. The status determination review will analyze all data categories (visual and physical inspection, material / equipment, g_

construction / installation) in determining the existence of conformances and nonconformances.

3" ' Data f rom inspections or documentation reviews may not exist for some element of a safety-related SSC. For example, an installation record for completed work or a certified material test report from a material

• supplier documenting the quality of a safety-related SSC may not be available. This will be treated as 's follows:

o If, based on the status of construction, documentation should exisc but does not, the item shall be designated as nonconforming. This would be the case for certain types of documentation for in process inspections that do not exist. In the case where documentation should not yet exist, A the item shall either be inspected under the PVQC or shall be designated t,_)

as incomplete work.

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

Page 37 of 75 This would be for case's of post process inspections that were not conducted.

o If documentation data should exist by procedure or specification and it is determined that such documentation is not required:

(1) The item shall be designated as conforming if the documentation review data demonstrates that the installation conforms with the current design data. Such conformance o shall, if appropriate, be the subject of the confirmatory physical inspection program to provide confidec;e that the

• items do in fact conform with the approved design drawings and specifications. For example, specification may require radiography tests of a weld which is not required by code.

8* - (2) The item shall be designated as nonconforming if the documentation review data does not demonstrate that the installation conforms with the current design data.

Results of the status determination will be documented and recorded.

These documents will then be submitted to Bechtel Document Control (see Appendix 1) where they will be retained. The results of the status determination will be entered into the database.

The status determination process shall be subject to periodic QA monitoring and audits by Bechtel; by CG&E; and by the Independent

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. 1

f Page g of 7s Auditor. These auIdits will determine whether the PVQC procedures governing the status determination process are being complied with and whether the program is properly implemented.

The QA audits will be conducted in accordance with the QA program for the PVQC. Audit reports will be formally transmitted to the Bechtel

~

assistant project director (PVQC) and others as appropriate for review and determination of necessary corrective action.

Discrepancy List Discrepancies between the as-constructed status of an item, the approved design drawings and specifications, or the contruction installation documentation will be identified on a discrepancy list by the PVQC teams during the performance of data collection activities. Discrepancies will zu be reviewed to determine: 1) whether the discrepancy has already been identified on a nonconformance report (NR), 2) whether the discrepancy concerns missing documentation which can be located with further effort.

- or 3) whether the discrepancy is incomplete work as indicated by Appendix

0. Discrepancies which cannot be placed in one of the above categories will be classified as a nonconformance and will be identified on an NCR.

Following this review, the classification of each discrepancy will be written on the discrepancy list and the quality verification check lists will not be considered complete until each discrepancy on the discrepancy list has received a classification. Each classification will be subject to concurrence by the team qualiry control engineer.

Os e

1

_ _ _ ~ _ - . . . _

o Page to of 75 Conformances Conformances will fall into one of two categories: (1) those items that have been verified as conforming to the current design data by the documentation review, the visual inspections, and the physical inspections; and (2) those inaccessible items or nonvisual attributea

?*

• that have been verified as conforming to the current design data by the documentation reviews, but which have not been subject to physical inspections. No further PVQC action is necessary for those conforming .

en items in category (1) above.

e:

Conforming items falling into category (2) will be subject to the

[1 ,

Confirmatory Physical Inspection Program. This program will provide additional confidence that the items are conforming as indicated by the documentation review.

me -

Nonconformances Bechtel will review all nonconformances not previously identified in ,

as-constructed SSCs and will formally advise CG&E of potential significant deficiencies. CG&E and its contractors will then conduct any evaluation pursuant to project procedures to determine whether the nonconf ormance is reportable under 10 CFR Part 21 or 10 CFR $0.55(e).

1 O

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__.__ ___.________m _ _ _ . _ - _ . . _ - . . _

4 Page 40 of 75 Existing project NRs, IIDEs, and document deficiencies will be included in the work packages used for inspecticas and reviews. As new nonconformances are identified by the PVQC, an NCR will be prepared and submitted in accordance with the project nonconformance program.

If during the status determination the PVQC identifies inconsistencies in

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• the data, the inconsistency will be documented on an NCR.

The project nonconformance program contains a system for tracking nonconformances. This program will be expanded to include the capability

• for tracking nonconformances specifically identified by the PVQC (i.e.,

those that are not the subject of an existing NR).

i

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NCRs will be documented using the project program as described in Appendix H. The NRs and NCRs will be resolved outside the scope of the PVQC under the proje'te nonconformance program.

.1> -

Incomplete Work

. Incomplete work will be documented for each safety-related SSC. This documentation will include lists of work-to go and redlined drawings, which indicate the status of tha as-constructed SSCs.

Confirmatory Physical Inspection Proaram Ihere will be SSCs where visual inspection and documentation review demonstrate that the SSC is conforming in all respects.

Page g of 75

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In these cases, confirmatory physical inspection will be performed which will provide added confidence that the SSCs are in fact conforming as indicated by the results of the documentation review. This will consist of a sample based program of selective inspections which will apply to systems and components. Some of these programs may be statistically based. Others will employ engineering analyisis, industry / military standards, or alternative methods, whichever is most appropriate for the SSC characteristic being confirmed.

es .

The confirmatory inspections may not be necessary if the results of previous physical inspections, using selective sampling methods such as;

- the examples described below, achieve the required reliability and O, confidence level. For example, if a particular release of material from a vendor was found to be nonconforming, concentrated physical inspections may have been performed on other similar asterial n1w determined to be

.1s - conforming. Other confirmatory physical tests will not be necessary on the other similar material.

• Example of a Samplina Method for the Confirmatory Inspection prograa One sampling method is to use randomly selected units for verification of compliance to design requirements. Approved procedures, containing appropriate industry-accepted sampling techniques, may be applied to the following categories:

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l Page 42 of 75 O o Attributes Sampling - This technique, used primarily for confirmatory inspections on homogeneous lots, involves selection of a sample using an appropriately determined confidence level.

Once a lot size is fixed it determines the size of the sample.

If nonconformances are found in the first sample, additional investigations will be performed based on the significance and number of rejectable attributes.

o Variables Sampling - The variable sampling plan would be used when the variability of a lot with respect to the quality characteristic (the characteristic of a unit of product, measured to determine its conformance to the design documents) is to be determined. Statistically selected samples would be used to establish the expected variability of the lot with a given confidence level and for assessment of the characteristic against acceptable engineering standards.

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Page 43 of 75

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Confirmatory Physical Inspection Personnel and Activities Inspection personnel and activities are essentially the same as those described earlier in this section. Appendix F lists examples of confirmatory physical inspections.

p. .

Product of the Verification Process

~

D Several products will result from the verification effort:

y+ t

a. Identification of the as-constructed configuration and other g,,

D~ as-constructed data of safety-related SSCs

b. Identification of conformances an -

c. Identification of discrepancies and resulting non-conformances

'with approved design drawings and specifications in

- safety-related SSCs

d. Identification of incomplete work O

Page 44 of 7s

e. Data bases including relevant information regarding the as-constructed status of safety-related SSC to be used as a management tool

f. Material and equipment identification log, welder qualification log, and similar logs

p. .

g. A comparison evaluation of the as-constructed design data with that existing at the date of the SCO v

Baseline Data Comparison Evaluation o '

D- A comparison evaluation will be performed to identify Quality Assurance problems or discrepancies t' hat exist between the A/E validated (baseline) design drawings and specifications in effect on the date of the SCO and p- the as-constructed design drawings and specifications verified by the PVQC. The purpose of this activity will be to document those quality assurance issues that existed at the time of the SCO which have been resolved by design changes.

PVQC personnel will perform this review and the results will be provided to Bechtel quality assura'u:e for inclusio'n in the quality trend program.

Significant trends will be analyzed as a source for input to the problem discussion section of the PVQC status report and the construction verification reports.

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Page 43 of ' 75 Construction Verification Report Construc*. ion Verification Reports (CVRs) will be prepared. They may be prepared on a system, subsystem, area, or component basis af ter verification of each system, area, or component is completed.

Confirmatory inspection may be performed on SSCs which have already been processed on CVRa to obtain additional data. These results will be reported on separate CVRs. The CVR will include the following elements:

" a. Introduction and Background

b. Summary of applicable program elements and procedures

c. Identification of the SSC or area verified and a description of the methods used to perform the verification

d. Status of the findings of the PVQC (e.g., as-constructed status of the SSC or area verified, nonconformances found during verification and audit, and identification of incomplete work)

e. Identification of any generic nonconformances in the as-constructed SSC or area

f. Summary of the major findings and conclusions of the PVQC s g. Demonstration that PVQC provides reasonable assurance whether the quality of construction of the SSC or area has been verified.

9

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)

Page 46 of 75 l .

A PVQC review team will review a CVR for completeness prior to submittal to CG&E management for review and approval. The CVR will then be forwarded to the NRC.

This Upon completion of the entire PVQC, a final CVR will be prepared.

report will contain the following:

p. .

.a. Introduction and Background w

b. Summary of the verification program and procedures i

e.

c. Summary of the independent auditor findings and any corrective action for the PVQC

d. Summary of the CVRs for all systems and areas

e. Analysis of the overall effectiveness of the PVQC in accomplishing its intended purpose

f. Major findings and conclusions regarding generic nonconformances in the construction of the SSCs

g. Demonstration that the PVQC provides reasonable assurance that the quality of construction of all safety-related SSCs has been verified.

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-.2 1 _ . _ _ . - . . . . .

E. .

,Page , 47 of 75

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The PVQC review team..will review the final CVR for completeness prior to submittal to CG&E for review and apptoval. The final CVR will then be forwarded to the NRC.

Evolution of the Vertification Process As is explained above, the quality of construction of safety-related SSCs will be verified by means of documentation reviews, visual inspections, and physical inspections.

w As verification is completed for several SSCs, it may be expected that certain patterns will begin to emerge. For example, one type of construction discipline, such as concrete, may be found to contain little

).

or no nonconformances while another discipline, such as structural welding, might contain many nonconformances. Based on the results of the j

verification of the first several systems or structures, consideration 2m- A may be given to modifying the degree or direction of verification.

modified verification plan for the remaining SSCs in construction I

disciplines which have been demonstrated to be of acceptable quality may be developed and submitted to the NRC by CG&E for review and concurrence. Such a plan will include a sumsary of the results of the verification conducted to date and justification in support of the ,

I planned modification. This justification will account for such factors as the number of items already verified, the number and type of j

l nonconformances discovered in the verified items, the number of items l

remaining to be verified, and intra-discipline variables (such as the use

() of different construction contractors and different time periods of construction activities).

e

Page 48 of 75 5.0 ORGANIZATIONAL STRUCTURE FOR PVQC CG&E has the responsibility for ensuring that the PVQC is properly formulated, managed, and completed. CG&E will provide overall guidance and policy direction to the Bechtel Project Director.

5.1 MANAGEMENT OF PVQC Bechte l is responsible for PVQC management, including planning, implementation, cost control, contract administration, quality control, and quality assurance. Bechtel is also responsible for PVQC interface with CG&E and other contractors at the site. PVQC management will be

() established as a separate organization reporting through an Assistant Project Director to the Project Director to ensure independence, f

l

, Bechtel will require that Bechtel-approved procedures and checklists exist prior to the start of each PVQC activity requiring them. Bechtel will also require that each PVQC activity is documented in a manner that will facilitate quality assurance audits and inspections. Management control of PVQC activities shall be retained by Bechtel and may not be delegated to other organizations.

CG&E will conduct audits and surveillances of Bechtel's performance of these responsibilities, the results of which will be the subject of written progress reports and periodic meetings.

l l l' i , .L - - _ . . _ .-

Page 49 of 75 5.2 ORGANIZATIONAL INTERFACE The CG&E nuclear operations organization is under the direction and management of the Senior Vice-President, Nuclear Operations, who is responsible for the PVQC (see Figure 6). He has delegated the day-to-day responsibility for the PVQC to the CG&E Assistant Vice-President, Nuclear Projects, who is the primary interface with the Bechtel Project Director.

The Assistant Vice-President, Nuclear Projects, has charged the CC&E D k nager, PVQC and Nuclear Project Support Services who will interface with the Bechtel PVQC Assistant Project Director, to oversee Bechtel I

management and direction of the PVQC.

The CG&E h nager, Quality Assurance, communicates with the Bechtel k nager of Quality on problems identified in PVQC as a result of CG&E

, Quality Assurance overview of the PVQC activities. The CC&E h nager of Quality Assurance reports the effectiveness of the quality program in PVQC implementation to the Assistant Vice-President, Quality Assurance -

who communicates with the Assistant Vice-President, Nuclear Projects on the effectiveness of the PVQC program implementations.

5.3 BECHTEL PVQC STAFPING The Bechtel Project Director is responsible for the overall management and direction of Bechtel activities at Zimmer, including activities under the PVQC. The Project Director is supported by a staff, which includes a O construction manager, manager of controls and services, and a manager of engineering and licensing. These individuals are supported by a suitable

o . ,

9-O^ I

\ -

FIGURE 6 PVOC ORGANIZATIONAL INTERFACES i

Bechtel Division Sr. V. President Manager of QA Nuclear Operations I I I I Asst. V. President Amst. V. President Amst. V. President Asst. V. President Nuclear Projects Nuclear Engineering Quality Assurtsace Nuclear Operations l

I  :

i Hanager ,," Bechtel ,,

a Bechtel l CG&E PVQC Manager u l I

I Onality Assurance Manager of Quality Project Director I i

E I -

\

l Bechtel (Asat. Project Director) een a um e su e as e em E PVQC Manager KEY

-Direction

======Connunication/ Coordination

'" 8 " Administrative Direction 5 la e,

la

Page 51 of 75 staff to perform the assigned duties. The Bechtel Manager of Quality maintains day-to , fay coordination and communications with the Project Director, reports to the Division Manager of Quality Assurance, and is .

supported by a project quality control manager, project quality assurance engineer, and a project quality engineer. These, in turn, are supported by a suitable staff to perform their assigned duties.

The PVQC will be managed and directed by the Bechtel Assistant Project Director-PVQC, who will report to the Bechtel Project Director. The L' '

Assistant Project Director-PVQC provides project direction to those members of the Bechtel organization performing the PVQC activities.

i b(./ The PVQC Supervisor is responsible for coordination and direction of the activities of the verification teams and coordination with Quality Control personnel.

me-The PVQC will be implemented through teams composed of team leaders, field engineers, quality control engineers, and other personnel with

. skills in the appropriate disciplines to perform the assigned activities. The size of the teams will vary from team to team, but each will consist of at least a team leader and a quality control engineer.

The PVQC team leaders and the quality control engineers will be Bechtel personnel; other team members may be Bechtel employees or employees of other organizations. Regardless of the origin of the team members, each will be trained and qualified and will be cer".ified as necessary by Bechtel. Such members of other organizations will be under the sole directica of Bechtel during their assignment to the PVQC.

~

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

e Page _ 52 of 75 Although employees of other organizations will be team members and will assist Bechtel personnel in data collection, Bechtel will be solely responsible for the collection and validation of the data, i

The number of teams will be a function of project schedule objectives.

Procedures will define the responsibilities of each team and of the team

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• members. Personnel performing' inspections document reviews, and other functions relating to quality will be appropriately trained and certified in accordance with approved procedures prior to performing the specific

• tasks to which they are assigned.

i Figure 7 depicts the Bechtel organizational structure for the PVQC, O

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Q FIGURE 7 BECHTEL PVOC ORGANIZATION CHART 1

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Page 54 of 75 6.0 QUALITY ASSURt.NCE PROGRAM POR THE PVQC 6.1 POLICIES o It is CG&E's policy that all PVQC activities be performed in accordance with the applicable Appendix B criteria of 10 CFR 50,

r. e o The CG&E project quality assurance program is described in the Zimmer Final Safety Analysis Report (Chapter 17.1) and the CG&E Project Quality w, o Assurance Manual (PQAM). The Bechtel Nuclear Quality Assurance Manstal (NQAM) describes the Bechtel quality assurance program and is applicable to all Bechtel PVQC safety-related activities.

6.2 IMPLEMENTATION

.>- The purpore of the PVQC is to verify the quality of construction of the safety-related structures, systems, and components of the Zimmer plant.

involvement, Quality is achieved through such measures as management proper controls, appropriate supervision, qualified personnel, certified personnel, and training of personnel. In addition, the quality assurance program provides important checks on quality and adds additional confidence that the conduct and results of the PVQC are valid.

The Quality Assurance Program is described in several project documents.

These documents are identified below in the established order of precedence:

4 D

Page 55 of 75 (1) Final Safety Analysis Report, Chapter 17.1 (2) CG4E Project Quality Assurance Manual (3) Bechtel Nuclear Quality Assurance Manual

r. .

(4) Zimmer Procedures Manual (5) PVQC Program Description e ~

(6) PVQC Implementing Procedures (where necessary)

D. .

6.3 DIVISION OF RESPONSIBILITY

• ' CG&E, as the licensee, has overall responsibility for quality assurance for the Zimmer project, including the PVQC. In this regard, CG&E performs the following functions:

o approves all submittals to the NRC that are related to the PVQC, including those concerning quality assurance o audits and surveys the Bechtel, HJK, and S&L quality assurance program O

/'"% Page 56 of 75 V

o performs continuing management review of the PVQC program o initiates actions necessary to ensure the continued effectiveness of the quality assurance program in regned to the PVQC, Bechtel has responsibility for the management of the PVQC, pursuant to

r. ,

the overall policy guidance provided by CG&E. Bechtel is responsible for implementing an effective qualie- assurance program for the PVQC.

Bechtel will establish separate organizations, reporting to the Project ee.

Director, to ensure PVQC and QA independence.

i e

• 6.4 APPENDIX B TO 10 CFR 50 l -

This section provides<a brief description of.the PVQC activity associated with the appplicable requirements of 10 CFR 50, Appendix B.

.m -

Organization (Criterion I)

The quality organization for CG&E and Bechtel is described in Section 5 of this program and is also described in the Bechtel NQAM.

O

2 Page 57 of 75 The PVQC quality assurance program for the PVQC administered by Bechtel -

will function by verifying (through means such as checking, auditing, and inspecting) that PVQC activities have been correctly performed.

Personnel performing quality assurance functions have sufficient

~

authority and organizational freedom to identify quality problems; initiate action and recommend solutions; and verify the imple' mentation of solutions.

Bechtel requires that its contractors or subcontractors provide quality assurance programs and procedures pertinent to their specified activities, which reflect Bechtel's commitment to CC&E, o

O. Quality Assurance Program (Criterion II)

The Bechtel quality assurance program contains written policies, am procedures, or instructions, and identifies those matters covered by the program in order to provide control over the quality of PVQC activities.

- The quality assurance program ensures that indoctrination and training is provided for personnel performing PVQC activities, identifies those PVQC activities covered by the quality assurance program, and provides quality assurance control over those activities.

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() Page 58 of 75 Desian Control (Criterion III)

This criterion is not directily applicable to the activities of the PVQC.

Procurement Document Control (Criterion IV) 9

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Although major procurement activities are not planned for PVQC, the program permits limited procurement of such services / supplies required for design testing, NDE test / sampling etc.

Procedures provide for the inclusion of the applicable technical and ,

o "

quality requirements to be imposed on suppliers of such services.

O.

Instructions, Procedures, and Drawings (Criterion V1 3" The quality assurance program ensures that PVQC activities are prescribed by documented instructions or procedures appropriate to the activity, including quantitative or qualitative acceptance criteria, if necessary, to determine that important activities have been satisfactorily accomplished. Where other site procedures are in place, a specific PVQC procedure will not be necessary.

Document Control (Criterion VI)

The quality assurance program ensures that measures are established to control the issuance of documents for PVQC activities, such as instructions and procedures; that such documents are reviewed for

-, - , , - - r--, ,, ,-- - - - . - -, , n,- , ,,- - , . . -- - - - - - - ~ . , ,., - - - - - w--- - = .n-,- - - - - - ,-,-y

Page 59 of 75 adequacy and released by authorized personnel and distributed to and used at the location where the prescribed PVQC activity is performed; and that changes to such documents are reviewed and approved by the organization that performed the original review and approval, unless otherwisa designated by Bechtel.

Control of Purchased Material, Equipment, and Services (Criterion VII)

The program provides control of purchased material, equipment and/or o t services which may be required to perform design / specialized test services such as NDE testing in PVQC. These controls provide for tagging, marking or otherwise preserving the specified conditions of test specimens / materials. The applicable Bechtel and/or CG&E approved procedures will control these activities.

1. Identification and Control of Materials, Parts, and Components (Criterion VIII)

Provisions will be established in the QA program of CG&E and Bechtel to control materials and parts that are procured for conducting NDE test sampling and any other specialized test services.

h 1

-- - _-- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ J

4ew e.-%,s4 .

s.

Page 60 of 75

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Control of Special Processes (Criterion II)

The quality assurance program ensures that PVQC activities involving special processes, such as nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and

?. .

other special requirements.

Inspection (Criterion X)

,p The quality assurance program provides a method to verify conformance o ~

w with documented instructions and procedures for accomplishing PVQC r .

activities. The program ensures that:

o inspection personnel are appropriately qualified and certified and J" independent of the individual or group performing the activity being inspected

- o inspections or tests are performed for each PVQC activity, as necessary, to verify the quality of the activity o indirect control (by monitoring processing methods, equipment, and personnel) is exercised if direct inspection of processed materials or products is not practical O

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

W Page 61 of 75

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w o inspection and in process monitoring are used when control is inadequate without both The inspection program also ensures that inspection procedures and instructions are available for use prior to performing the inspections and that inspectors' qualifications or certifications are kept current.

.me .

Test Control (Criterion XI) e The quality assurance program ensures that testing associated with PVQC activities is performed in accordance with approved written test e

1- , procedures. These test procedures will: .

o incorporate requirements and acceptance limits (if applicable given the objectives of PVQC testing) 3>

c include provisions assuring that

1) all prerequisites of the given test have been met x

2) adequate test instrumentation is available and being used

3) testing is performed under suitable environmental conditions

4) personnel are certified O

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Page 62 of 75

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o require that test results are documented and evaluated to ensure that test requirements have been satisfied Control of Measuring and Testing Equipment (Criterion XII)

The quality assurance program ensures that measures are established to

p. .

ensure that tools, gauges, instruments, and other measuring and testing devices used for PVQC activities are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary w

limits while such equipment is dedicated to the PVQC.

~

Handling, Storage, and Shipping (Criterion XIII)

) ,

The quality assurance program provides for controlled handling, shipping, and storage of test specimens and other materials or parts necessary for 3" conducting specialized design /NDE test services associated with PVQC inspection activities.

Inspection, Test, and Operating Status (Criterion XIV)

The quality assurance program ensures that measures are established to indicate by the use of markings or other means the status of testing accomplished as part of the PVQC activities.

Nonconforming Materials Parts, and Components (Criterion IV)

O .

The quality assurance program ensures that measures are established to control nonconforming materials, parts, and components. Nonconformances

_ ___._.___m_..m____.____J

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

o s

Page 63 of 75 O

will be trended and Analysed to identify significant conditions that are potentially reportable.

Corrective Action (Criterion IVI)

The quality assurance progran ensures that conditions adverse to quality

t. .*

in the implementation of the PVQC are promptly cotracted and that evaluation of the cause and corrective action to prevent recurrence are accomplished for significant conditions adverse to quality.

go -

, Quality Assurance Records (Criterion XVII)

O' The quality assurance program ensures that suf ficient rsuords of PVQC activities are maintained to furnish evidence of quality, including the

• ' following:

o results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses o qualifications of personnel, procedures, and equipment o inspection and test records that identify (as a minimum) the inspector or data recorder, type of observation, results, acceptability, and action

~

taken in connection with any deficiency noted I

s Page 64 of 75 Records will be identified and retrievable; they will be retained in accordance with the site records and document control system.

Audits (Criterion XVIII)

The quality assurance program includes a comprehensive system of planned and periodic audits of PVQC activities to verify compliance with all aspects of the quality assurance program and to determine its effectiveness. The audits are conducted in accordance with written es procedures by trained personnel who have no direct responsibility for the activities being audited. Audit results are documented and reviewed by management personnel responsible for the audited activities. Follow-up

() action, including reaudit, will be taken where indicated. Audits will include, but not be limited to audits assessing:

3= o procedural compliance for all activities o effectiveness of data collection o ef fectiveness of documentation reviews o validity of inspections O

. h

~' - -- - - _ _ _ . __________..a_________.________ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Page 65 of 75 O

6.5 ADDITIONAL QUALITY ASSURANCE CONSIDERATIONS FOR PVQC o Monitoring The quality assurance program includes a monitoring program for use by quality assurance engineers to observe, analyze, and report to the manager of quality the extent of conformance of ongoing PVQC work activities. It will be performed in accordance with prepared checklists, and'the results will be documented.

o Stop Work Authority CG&E has stop work authority for all PVQC activities. Bechtel has stop

} work authority for any activity within its ovsrall PVQC program

() management responsibilities. Each contractor has stop work authority

~

within its own PVQC responsibilities. The ZPS-1 Stop worn procedure (s) further allow (s) for limited stop work authority as assigned by the J= - Manager - QAD for inspection personnel on the specific task or activitiy being inspected. Supervisors and directors may then stop work on an entire task or activity based upon evaluation of the inspector's findings.

o Quality Assurance Management Meetings CG&E mansgement will preside over periodic QA management meetings to review and assess ongoing quality assurance activities related to the PVQC. Contractors will attend and provide appropriate input, as requested by CC&E.

o Quality Assurance Management Reports (k Bechtel will prepare periodic quality assurance management reports that discuss quality assurance matters associated with carrying out the PVQC.

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9 Page 66 of 75 w.,

7.0 INDEPENDENT AUDIT OF PVQC The SCO requires that the PVQC " include an audit by a qualified outside organization, which did not perform the activities being audited, to verify the adequacy of the quality of construction." This audit is separate from and not a substitute for the QA program for the PVQC, which

~.

is described in Section 6. This audit will be a continuing audit throughout the duration of PVQC. This audit will be expanded to cover the QA/QC aspects of the Continuation or Construction Plan (CCP) to w

ensure a smooth transition from PVQC to CCP.

7.1 SELECTION AND QUALIFICATIONS OF INDEPENDENT AUDITOR O

CG&E has selected an Independent Auditor f or the PVQC. The independent auditor's technical qualifications have been be described in a submission 3* to the NRC for approval (reference 33).

The outside organization has been determined to meet the independence criteria of previous activities associated with the Zimmer project. The independence has been defined as not having previously performed any of x

the construction installation or inspection activities, supplied any of the materials under the scope of PVQC, surveilled of the quality assurance activities, or been otherwise involved with any of the work under the purview of PVQC.

To maintain the independence of the independent auditor, all O communications between the independent auditor and CG&E or its

---

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

., . . . - . -. a. - . . . . ~ . . ~u .u. .-.. a .: .. ;

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Page 67. of 75 contractors and subcontractors, heluding Bechtel, will be conducted in accordance with the March 2,1983 " Protocol Governing Communications Eetween CG&E and Independent Organizations Conducting Review or Audits Under The Commission's Order."

7.2 PURPOSE AND SCOPE OP THE INDEPENDENT AUDIT

?*

To maintain the independence of the independent auditor, CG&E has not and will not direct the independent auditor in the specific content of its es '

audit program or in the manner in which that audit program is carried out. However, in requesting proposals to perform the independent audit,

) i CG&E did identify prerequisites it believed should be included in the audit program at a very minimum. These prerequisites included the following:

D' a. An evaluation of whether the procedures for the PVQC, and any amendments thereto, are consistent with and fully implement the PVQC approvad by the NRC

b. An evaluation of whether the procedures for the PVQC have been completely and adequately implemented

c. An evaluation of whether the results obtained by and during impleuentation of the PVQC are complete and accurate

d. An evaluation of the adequacy of the steps taken to correct elements of the PVQC in response to reports of the independent auditor 1

0 Page _68_ of 75 O

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e. An evaluation of the effectiveness of the implementation of the quality assurance program for the PVQC

f. An auditor-established quality assurance program to govern the auditor's activities and verify the quality of the audit

r. . g. Provisions for submission of periodic audit reports and a final (at completion of PVQC) audit report to CG&E

'm . h. Trovisions for immediate reporting of nonconforming items and significant noncompliances discovered by the independent auditor.

e

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CG&E, Bechtel, and contractors performing PVQC activities will give full cooperation to the independent auditor in the conduct of its audit. This includes providing the independent auditor with any and all PVQC procedures, records, or other information required to perform the audit tasks.

7.3 EVALUATION OF REPORTS OF THE INDEPENDENT AUDIT Periodic audit reports will be submitted by the independent auditor to CG&E. These reports will be reviewed by CG&E and Bechtel to determine any shortcomings in the execution of the PVQC. Ary necessary or The NRC appropriate corrective action for the PVQC will be implemented.

will be informed of any corrective Attions takea as part of the periodic The

( progress report management summaries, described in Section 8.3.

.( ) independent auditor will audit the corrective actions to ensure their adequacy and responsiveness.

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.e_ . _ . _ - __. .

Page 69 ~f o 75 O

l 8.0 ADMINISTRATIVE SUPPORT ACTIVITIES 8.1 SCHEDULE FOR PVQC

~

As manager of the PVQC, Bechtel is responsible for maintaining a schedule to complete it. Once this schedule has been established, PVQC management will accordingly allocate resources such as manpower and skilled personnel. Since the PVQC approval date by the NRC is uncertain, it is not possible to establish precise dates for beginning and completing the o PVQC. However, a schedule based on elapsed time has been developed.

This schedule, depicted in Appendix L, identifies milestone dates and the time for completi$n of the PVQC. As the PVQC proceeds, the schedule will be periodically revised, based upon actual experience.

It may be noted that the PVQC will, in general, be implemented on a system, subsystems, structure, area, or component basis.

The sequence of its activities will be established based upon factors such as the expected length of the verification process, expected extent of construction and rework, and the sequence of testing for the systems, areas, or components. For example, systems that will require early testing and lengthy periods of verification and construction will be verified first. Conversely, verification will be deferred until late in i

O 1

i1

.--___________:-__.m

.. . , . ~ . __. ._

Page 70 of 75 the PVQC for those systems and areas that prove to be relatively easy to verify and construct and that are not required until later in the startup schedule. Thus, it is planned to verify, construct, and test the plant in an orderly phased manner, thereby minimizing the potential for delay in plant startup caused by differences in the times required to verify, construct, and test various systems and areas. Appendix N lists the

s. .

typical systems, subsystems, areas, and components to be verified under the PVQC. These prioritie: may be modified based on constraints identified during the implementation of the PVQC.

p

, A plan for the continuation of construction (CCP) will be developed and

+ su'umitted to the NRC with a request to commence construction, as explained in CG&E's Course of Action (see References). As verification of each system, subsystem, area, or component is completed, the results will be recorded and evaluated.

Ccnstruction work will not commence until that system, subsystem, area, or component is verified. Appropriate safeguarda and controls will be implemented to ensure that construction does not interfere with remaining PVQC activities or affect as-conetructed SSCs that require verification.

A schedule control program will be implemented to inform management of developing and potential problem areas so that corrective action can be initiated. The basic elements of this program will include a plan based on critical path milestones, a monitoring system to measure progress and performance against the plan, and a reporting system to identify progress O and deviations f rom the plan and to communicate this information to management.

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r a

s Page 71 of 75 O

8.2 TRAINING OF PVQC PERSONNEL PVQC personnel.will receive indoctrination, training, qualification, and certification commensurate with assigned duties. This includes an overall program orientation as well as training in specific procedures.

9 Training program description and lesson plass, including descriptions of _

the Quality Control examination and certification proctes, will be submitted to the NRC prior to the start of final training. Training

~

s; .

schedules will be submitted to the NRC to allow for monitoring of the classes. The PVQC training program will be a part of the overall site e

i master training plan.

Upon assignment to the PVQC, each employee will be notified of the requisite training applicable to their position. The employee will be 3" required to complete satisfactorily all parts of the applicable training program prior to performing any work activities under the PVQC. Due to the estimated length of the PVQC, it is anticipated that extensive

~

periodic training of PVQC employees will not be necessary. However, retraining, requalification, and recertification will be provided should it become necessary. Employees will be given additional training for new or revised PVQC procedures, as necessary.

Typical training requirements for FYQC personnel can be found in Appendix M. Prerequisite training may consist of reading, reading and reviewing with a supervisor, and formal training. The amount of training provided for each employee will depend upon their responsibilities.

9

- m._.. .. . . . . . . . _.

.}-

Psge 72 of 75 All formal training classes will be conducted with written lesson plans containing content of the program, and an overview of the plan will be in a format such that a qualified instructor could readily teach it. Each

. le eson plan will be reviewed and approved for technical content.

Attendees of the class and the dates of their attendance will be recorded.

In addition to the training requirements described above, quality control personnel and document reviewers will be qualified and certified in accordance with the requirements of ANSI N45.2.6-1978 (see References),

cs Additionally, QC engineers performing or witnessing nondestructive examinations will be certified by test pursuant to SNT-TC-1A-1975 (see e -

i. Ref erences) .

O~

PVQC training programs will consist of, but not be limited to, the following:

n' o indoctrination of all PVQC personnel concerning the purpose, scope, and implementation of quality assurance requirements and related procedures. This orientation will be completed before performing activities that may affect the quality of any PVQC activity o training of each employee regarding the purpose, scope, and impl'ementation of requirements in applicable manuals, standards, and procedures (including revisions) as specified in the training matrix o testing of personnel as required by qualification or certification o on-the-job training as specified in the training matrix 6

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, l. . ' . .: :2_ .= .. = -.: : .____..- . . . . .

4

, 't

'a Page 73 of 75 o optional training may be scheduled as required, including offsite training, such as seminars Training will be documented, and the records will be maintained by the designated jobsite training coordinator.

.s. ..

8.3 PROGRESS REPORTS Monthly progress reports for the PVQC will be issued by the Bechtel w

Project Director to inform CG&E and Bechtel management of the status of the PVQC, to provide early warning of developing and potential problems, and to recomend corrective actions. The progress reports will include a gs management summary briefly describing program status, items of concern, and areas of interest to management.

• The reports will include a susmary of key issues on the findings of PVQC, analyses of trends in nonconformances and identification of any generic deficiencies, findings fram the quality assurance,(QA) program, key findings by the Independent Auditor, analyses of problems in executing the PVQC, schedule status on detail activities, manpower status, identification of major areas of concern, as well as any corrective action to be taken by PVQC and recommended changes to the program. In reporting the status, the report will contain graphs, charts, or other visual aids, as appropriate, to display conditions and to clarify data for management review.

O V .

^ve

- .m .  :-. . . = . .-. .- .

e

' Revision R Page 74 of 75 Disk #3PVQC14 O DOC fPROC8o0 N

9.0 REFERENCES

1. A.J. Duncan, " Quality Control and Industrial Statistics," R.D. Irwin Inc., Homewood, Illinois, 1974, 4th Edition.

?- -

2. American National Standards Institute, ANSI /ASQC Zl.9-1980, Sampling Procedures and Tables for Inspection by Variables for Percent Nonconforming,

3. American Society for Nondestructive Testing, SNT-TC-IA-1975,

• " Recommended Practice for Nondestructive Testing Fersonnel

~

Qualification and Certification".

4. American National Standards Institute, ANSI-N45.2.6-1978,

" Qualifications of Inspection. Examiner and Testing Personnel for 3

Nuclear Power Plants".

5. Cincinnati Gas & Electric Co., (William H. Zimmer Nuclear Power Station), CLI-82-33, 16 NRC (November 12, 1982).

s

6. Cincinnati Gas & Electric Co., William H. Zimmer Nuclear Power Station Course of Action (October 5, 1983).

7. U.S. Nuclear Regulatory Commission, Docket No. 50-358, NRC Questions on the Course of Action, dated October 28, 1983.

O

4 ,

Revision K Page 75 of 75 Disk #3PVQC14 C) DOC # PROC 8oO

8. U.S. Nuclear Regulatory Commission, Docket No. 50-358, NRC Questions 4 on the Course of Action, dated November 15, 1983.

9. United States Department of Commerce, NBS HBK-91, National Bureau of St'andards Handbook 91. Experimental Statistics.

• • *

• U.S. Nuclear Regulatory Commission, NUREG-0969 Report of the NRC 10.

Evaluation Team on the Quality of Construction at the Zimmer Nuclear Power Station, (April 1983).

en

11. Torrey Pines Technology, Independent Review of Zimmer Project Management (August, 1983).

O~

12. Cincinnati Gas & Electric Co., LOZ-83-0239 William H. Zimmer Nuclear Power Station / Unit 1, Course of Action (dated November 23, 1983) sm a

13. Cincinnati Gas & Electric Co., LOZ-83-0249 William H. Zimmer Nuclear Power Station / Unit 1, Independent Audit of the Quality of

. Construction, (dated December 6,1983)

O 9

l APPENDIX A l

[

' CLASSIFICATION LIST FOR SAFETY-RELATED SYSTEM 3, STRUCTURES, AND COMPONENTS i

O I

/

()~ -

. STRUCTURES. COMPONENTS AND SYSTEM Ct.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Comnents (See Note a) (See Note b) (See Note c) (see Note d)

I. Civil Structures

1. Reactor Building i i E

2. Service Water Pump Structure i I E NA Radwaste Building NA WN NA

3. II

4. Auxiliary Building I I E NA

5. Turbine Building N4 11 WN NA

6. Service Water Pipe Supports & Encasements 1(50) 1 WS NA II. Nuclear Steam Supply Systam (GE Supplied) h h. N .N '

l. Reactor Vessel i I A A.

2. Core Structure  ! I A NA

3. Steam Dryer Assembly NA 11 'WN

4. Jet Pumps i I P l S. Control Rod Drive i I A NA

6. Head Spray Nozzle i I P

7. Reactor Vibration Instrument WM

8. Steam Separator Assembly' NA 1.1 WN

9. Source Range Monitoring /interm Range Monitoring Drive Unit WN

10. Main Steam isolation and Relief Valve Accumulat0: s I I P

11. Condensing Chambers I I A

12. T-Quencher and Base Supports I I A C

13. Reactor Recirculation Pumps i I P A

14. Recirc. Flow Control Hydraulic Power Units NA 11 WM

15. l.ow Frequency Motor Generators NA II WN

O~ O' O~

STRUCTURES, COMPONENTS AND SYSTEM CLASSIFICATION l Quality Quality Group Principle Seismic Assurance Essential or Classi-Conponent Category Requirements Non-Essential fication Comments II. Nuclear Steam Supply System (Cont'd) GE-Supply

16. Control Rod Drive Water Pumos I(50) 11 WS

17. Drive Water Filters NA II WN D

18. Air Filters NA 11 WN

19. Control Rod Drive Hydraulic Control Unit i I A E

20. Control Rod Drive Pump Suction Filter I(50) 11 WS

21. Standby Liquid Control Storage Tank I i P B

22. Standby Liquid Control Test Tank l(50) WS 11 l

23. Standby liquid Control Pumps I I A B l 24. Traversing in-Core Probe Disposal Cask. NA II WM

25. Traversing in-Core Probe Drive Mechanisms 1(SD)' 11 WS

26. Traversing in-Core' Probe Indexing Mechanisms 1(50) 11 WS

27. Traversing In-Core Probe Valve Assemblies i I A l 28. Traversing in-Core Probe Cham 5er Shields I(50) 11 WS

29. TIP Purge Equipment NA 11 WN l WN

! 30. Hotor Module NA II

31. Reactor Protection System Power 1(50) WS NA Distribution Panel 11

32. Motor Generator Sets NA II WN

33. Electrical Protection Assemblies i I A

34. Miscellaneous Cabinets, Typewriters, f k Monitors, etc. (equipment number series .

D,. .o IC91-XXXXX)7 NA 11 WN

35. Off Gas Post Treatment Sample Panel 1(50) II WS

36. Off Gas Vial Sampler Rack #2 1(50) 11 WS

31. RHR HX Exchangers - Water Discharge to 1(50) II WS Rad Non Skid

38. Off Gas Vent Pipe Sample Panel (Spare) 1 50) II WS

39. Area Radiation Monitoring Cabinet lA I[L SD) 11 WS

40. Ramaining Misc. Equipment I's IDXX-XXXXX NA 11 WN

41. RHR Heat Exchangers - Primary Side /

Secondary Side I I A B/C I I A B

42. RilR Pumps i I A

43. Core Standby Cooling Systan Water Leg Pumps

44. Low Pressure Core Spray Pump i i A B I A 11

45. liiqh Pressure Core Spray Pump I I A Il

46. Reactnr Core Isniation Coolinq Pumo I

O O O STRUCTURES, COMPONENTS AND SYSTEM CLASSIFICATION -

I l Quality l

( Quality Group I l Principle Seismic Assurance Essential or Classi- l Component Category Requirements Non-Essential fication l l

(See Note b) (See Note c) (See Note d)Cmynents l (See Note a) j 11. Nuclear Steam Supply System (Cont'd) GE-Supply

47. Reactor Core Isolation Cooling Steam Turbine Asser.bly i I A E l

48. Steam Line Plugs i I P NA

49. Head Strongback I I A NA

50. Refueling Platfom Equipent Assembly I I A

51. Channel Storage Rack NA 11 WN

52. Remaining Racks and Containers (Equipment f's IF16-E00X) i I P S3. Remaining Misc. Equipeiit l's IFlX-E0XXX) NA 11 WN

54. Reactor Water Cleanup Regenerative Heat Exchangers f(50) 11 WS C

55. Reactor Water Cleanup Non-Regenerative Heat Exchangers 1(50) 11 WS C

56. Reactor Water Cleanup Filter /Demineralizers 1(50) II WS C

57. Reactor Water Cleanup Filter Demineralizer Control Panels 1(50) 11 WS

58. Remaining Reactor Water Clesnup System Tanks, Pumps, Agitators, Collectors, etc. N/A 11 WN C

59. Panels, Instruentation and Monitoring .

Cabinets numbered 1H13-P600; P604; P607; -

P610; I(50) 11 WS

60. Panels, Instrumentation and Monitoring - Q9 Cabinets remaining lH13-P601 thru P642 I I P I

>1i l

61. MSIV Leakage Control System Panel i I A si..

d Q

62. Control Rod Drive & Reactor Vessel '

l Temperature Record Panel f(50) 11 WS

63. SRM-IRM Drive Control Relay Rack 1(50) 11 WS

64. Remaining Panels and Racics fed lH22-P001 through 1H22-PO41 I I P

65. ESS-1 & ESS-2 MSIV Leakage Control Panels I I A

66. All IT49-XXXX equipent (Flarrynability Control) I I A B I I I'. AC-Acid Systems All Fouine nt un it wi

O OT 0-STRUCTURES, COMPONENTS AND SYSTEM CLASSIF! CATION Quality Quality Group Principle seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Comments (See Note a) (See Note b) (See Note c)(See Note d)

IV. AF - Misc. Sump Pumps:

AII Equipment NA 11 WM O.

• V. An - Annunciator Alarms: %p/mj 4 ' fl\3 M hv 0 b.

All Equipment D 1(50) II WS VI. AP - Auxiliary Pouer:

1. Aux XFM and Reserve XFM s NA 11 WN

, 2. 6.9 + 4.16 KV SWGR(s) I I A

3. HTG Bl.R SWGR(s) NA II WN

4. 480V ESS Substations 1 - I A

5. 480V 80P' Substations lA-3A, IA-4A, 18-3A, 1(SD) 11 WS ,

18-4A, IC-2A

6. 480V 80P Substations IA-38, IA-48, 18-38 NA 11 W4 18-48, IC-28

7. 480V RXMCC 1A & 18 I I A

8. 480V RXMCC IC through IG 1(50) 11 WS l 480V A8MCC 1A through IF I I A

9.

l 10. 480V TRMCC la through IJ: W8MCC-58MCCs; NA 11 WM CWMCC; COMCCs; MDMCC's, H8MCC; GMCC; Load Center IA-5 and 80P 1 Substation IG-1

. 11. 480V WSMCC 1A, 18 & IC I I A

12. 480V Plug-in Bus IA through 10 1 I P

13. 480V Plug-in Bus lE. IF & IG NA 11 WM

14. Primary containment Electrical Penetration E-1 through E-19 I I P VII. AS - Auxiliary Steam System:

All Equipment NA 11 WN VIII. CA - Condenser Vacuum Systam_:_

wa ""

All Equiomnt .

h STRUCTURES, COMPONENTS AND SYSTEM Ct.AS,SIFICATION .

Quality j

Quality Group I Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Cor.iments (See Note a) (See Note b) (See Note c)' (See Note d)

IX. CB - Condensate Rooster System:

All Equipnent NA II Weg X. CD - Condensate Syst g.

All Equipment NA 11 WN XI. Ct. - Chiocination System:

All Equipment NA 11 WM Xti. CO - Carbon Dioxide (Fire Protection) System:

All Equipment NA II WM XIII. CP - Condensate Polishing Demineralizer System:

All Equipment NA 11 WN XIV. CW - Circulating Water System:

All Equipment NA 11 WM A fi ;

3 XV. CX - Misecallenous Cabinets, Panels and Data  ; *)[' TQ

. h Yn:.9 Acquisition Systems:

1. MCR Div. Ill Multiplexer (3F) - Eq. flCX10J I I A

2. All Remaining Equipment is' ICX_J NA II WN XVI. CY - Cycled Condensate Systems:

All Equipment NA II WN D s

a O O O$

~

STRUCTURES, COMPONENTS, AND SYSTEM Ct.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essentist fication Comnents (See Note a) (See Note b) (See Note c) (See Note d)

XVil. DC - OC Batteries:

1. 250V DC TB MCC 1A NA II WM

2. Computer Room Mon-lE Batteries and NA Il WN Chargers NA II WM

3. 25')V DC Distribution Cabinets C-A and C-B I I A

4. All other IDC_ _E_ Equipment XVill. DG - Diesel Generator Auxillacy System:

I I A

1. Diesel Generators .

A

2. Diesel Generator Heat Exchangers  ! I Diesel Generator Air Compressors 1(50) II WS 3.

1(50) WS

4. Dibsel Generator Heaters II WM

5. Reducers w/ Turning Vanes 16 CYL NA II Reducers w/ Turning Vanes 12 CYL NA II WN 6.

Diesel Generator Technical Support Center NA II WN

7. P

8. Diesel Oil Day Tank I I l 9. All Remaining Equipment 10G_ _ _ _ l I ,p .

P DL - Laundry Floor Drain Sumo Pumps _ y' , \ , i. '

XIX. _

t W ' ' j, .o NA I -

WN All Equipment XX. DM "- Service Water Pump Structure Sump Ptanos NA WN All Equipment II XXI. 00 - Diesel Fuel Oil System:

1 Diesel Oil Storage Tanks  ! I P

2. Diesel Fuel Oil Transfer Pumps i I A Diesel Oil Transfer Pumps NA 11 WN .

3. .

Technical Support Oil Storage Tank NA II KN 4.

a g

g -

STRUCTURES. COMPONENTS, AND SYSTEM Cl.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Comments (See Note a) (See Note b) (See Note c) (See Note d)

XXil. EH - Turbine Generator:

All Equipment NA II WM XXill. ES - Extraction Steam System:

All Equipment NA 11 WM l

XXIV. FC - Fuel Pool Cooling & Cleanup System:

1. Fuel Pool Cooling Pumps I(SD) 11 WS C 1

2. Fuel Pool Heat Exchangers f(50) 11 WS C 1

3. Refueling Bellows I I P

4. Remaining IFC_ _ _ _ Equipent NA II WN C XXV. FP - Fire Protection System:

All Equipment NA 11 WM NA l

XXVI. FW - Reactor Feedwater System:

All Equipment NA 11 WN n'\

XXVil. GS - Turbine Gland Seal System: << .' \

All Equipment NA 11 WM XXVill. HC - Cranes, Holsts and Trolleyg _

1. Main Reactor Building Crane i I P

2. Power Distribution Panel (eq. #1HC72J) 1(50). 11 WS

3. All Remaining 1HC_ _ _ _ Equipment NA 11 WN XXIX. HD - Heater Drain System:

All Equipent NA 11 WN

Cr O~ ~ Ox -

STRUCTURES, COMPONENTS AND SYSTEM CLASSIFICATION .

Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Comments (See Note a) (See Note b) (See Note c) (See Note d)

XXX. HT - Station Freeze Protection

1. 9KVA, 480-208/120 Transformers for Panels IPLE7JA & B I  ; A

2. All Remaining lHT_ _E Equipment NA 11 WN XXXI. HY - Hydrogen System All Equipment NA 11 WN XXXil. IA - Instrument Air System ,

l

1. Instrument Air Dryers Prefilters and After Filters I(SD) 11 WS

2. Instrument Air Compressors, Receivers.

l Compressor After Coolers, & Compressor

! Pulsation Dampeners . NA 11 X(Xill. IN - Drywell Pneumatic System T^' -

1. Dryw111 Pneumatic Nitrogen Cylinders &

Racks I I P

2. Drywell Pneumatic System Dryers, Dryer Outlet Filters & Prefilters 1(50) 11 WS

3. Drywell Pneumatic Compressors and System Air Receiver 1(50) 11 WS .

4. All Remaining IIN_ _ _ _ Equipment NA 11 WM l XXXIV. IP -

1. 120 VAC Instrument Buses  ! I A

2. DC to AC Inverter Equip (IA & IB), 120 VAC Uninter & Computer Distr. Panel 1(50) 11 WS WN

3. All Remaining IIP _ _ _ , Equipment NA II XXXV. l_L Lighting Syst_em All Enuinnsnt NA  !! WN

O- O. Os STRtlCTURES, COMPONENTS AND SYSTEM CLASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requireents Non-Essential fication Ccanents (See Note n) (See Note b) (See Note c) (See Note d)

XXXVI. MC - Makeup Condensate Storage System All Equipment NA II WM XXXVII. MP - Main Power All Equipment NA II WM XXXVill. MS - Main Steam AII Equipment NA 11 WN l

XXXVI. OG - Of f Gas System

1. Off Gas Guard Beds, Prefilters, Dryers, l

' After-Filters, and Blowers 1(50)  !! WS D NA 11 WN D'

2. All Remain 10G_ _ _ _ Equipment XL. OH - Csustic System NA 11 WN

! All Equipmeat XLI. OT - Turbine Oil System 9(h k All Equipment HA 11 WN g J $ I

XLII. PA -

1. Misc. Autenatic Control Cabinets I I P

2. Electrical Transducer Power Supply Cabinet and 480V Power Olstribution l Panel Aux Bldg Holsts & Trolleys NA II WN 11 WS

3. All Remaining IPA _ _ J Equipent 1(50)

Cr O' 0" i

i STRUCTURES, COMPONENTS, AND SYSTEM CLASSIFICATION 1

Quality Quality Group i Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Comments.

(See Note a) (See Note b) (See Note c) (See Note d)

XI.III. PL - Panels t

l 1. HVAC Tube Condensing Unit Control Panels (1 R 83J to C1J) I I A i 2. Heat Tracing Control Panels (IPLE7JA and B) I I A i 3. Switchgear Remote MUX CAB (IPLG9JA and B) I I A Valve IEll2-F009 Alternate Power Supply

! 4.

j Panel (IP!.L4J) I I A

5. Diesel Generator Control Panels (IPL10JA, j 8 & C) I I A i 6. ESS-1, 2, 3 Essential Relay Panels (IPL12JA, 8 &~C) I I A l . .

i 7. Control Room Vent and Air Cond. Eqpt.

i Control Panels (IPLl4JA&B) i I A 2

8. Primary Containment H /0 / Fission Products i SamplePanels(IPL40J$&Bf I I A

9. Olesel Generator R m Vent Panels (IPL60JA, j

1 B & C)

10. Service Water Pump Cooling Panels (IPL61JA -

i I A M@E\

1. U ig-lj ,J t) !jf .I j & B) 1 I A

11. Remote Shutdown Panels (IPL67JA&B) I I A

! 12. ESS-l&2 SGTSET (IPL69JA&B) I I A j 13. Service Witer Strainer Control Panels (IPL75JA&J8) I I A l

) 14. Switchgear Heat Removal Unit Control Panels I (IPL91,92,&93J) I I A I 15. Carbon Dioxide Fire Protection Panels -

l DG room (IPLC7JA,B&C) 1(50) 11 WS

! 16. Drywell Pneumatic Compressor Control Panels j (IPLDlJ) 1(50) 11 WS l 17. Primary Containment Vent Water Chiller Panels (IPLD6,7,8&9J) f(SD) II WS

18. Ionization Detector Monitoring Panel for Cable Spreading Room (IPLE6JA) 1(50) 11 WS i

19. Cable Spreading Room Fire Protection Panel I(SD) II WS (IPLE6J8)

20. Misc. Rollding & Area CAMS (IPL38JA thru E) I(50) 11 WS i

O- ON 0"

ST90CTURES, COMPONENTS AND SYSTEM CLASSIFICAf t04

. Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Essential fication Coonents (See Note a) (See Note b) (See Note c) (See Note d)

XLIIi. PL - Panels (Cont'd)

21. Service Water Pumps Minimum Flow Bypass Control Panel (IPLL3J) 1(50) 11 WS

22. Off Gas Instrument Panel IB (IPl.30JB) I(Sh) II WS

23. Misc. Atmospheric Rad. Sample & Diff.

Pressure Controls (IPL31JA&B; IPL33J:

IPL37JA through JG) I(SD) II WS

24. Turbine Building HVAC Control Panel (IPL38J) I(SD) It WS

25. Reactor Building Process sample Instr.

Panel (IPL50J) I(50) II WS

26. I.aboratory HVAC Control Panel (IPL51JB) I(50) 11 WS

27. Fuel Pool Filter Control & Instrument Panels (IPL54JA&B) 1(50) II WS

28. Service Water Pump H0use Vent Panel (lPL63J) I(SD) 11 WS

29. Station VentlIstion Purge & Primary '

Cont. HVAC Panel (IPL65JB) 1(50)  !! WS  ? Qy;d A ,,!i}: ,

30. Drywell to Suppression Chamber VAC Relief g {} Q[ib bo Valve Contro Panel.(IPL79J) f(SD) II WS

31. Cle~anOATFde)Y PoM Phase Separator Tank Instr Panel (IPL84J) I(SD) II WS l 32. Reactor Bldg. Floor Drain Tanks Instrument .

Panel (IPL87J) I(50) 11 WS  ;

33. Reactor Bldg. Equipment Drain tank Instr. _

l Panel (lPL96J) I(SD) 11 WS

34. Off Gas System Solenoid Valve Panel IB l (IPL98JB) I(50) II WS I 35. All Remaining Equipment (Panels) flPL J- NA 11 WN l 36. Post Accident Sampling System HVAC Coiitrol l

Panel (lPL65JC) I(SD) II WS

37. Reactor Building hVAC Control Panel (IPL37J) f(50) 11 WS l

l l

O- O-STRUCTURES. COMPONENTS AND SYSTEM CLASSIFICATIGN Quality Quality Group Seismic Assurance Essential or Classi-Principle Non-Essential Comments Category Requirements fication Component (See Note c) (See Note d)

(See Note a) (See Note b)

XLIV. PM -

1. Generator and Station Auxiliary Panel t i A (LPM 0lJ)

2. Leak Detection Panel /St) tion Services A Panel (IPM06 & 08J) t I

3. HVAC & Standby Gas Treatment Panel I I A (IPM07J)

4. Radiation Monitoring & Recording Panel A I I (LPM 17J)

5. Primary Containment & Reactor Vessel A I I Logic Panel (IPM18j)

6. Control Room lonization Detect Relay st I i A Padels (IPM19JA & B) WM It

7. Main Control Room Isolator Cabinets I I A #,y % ; i '

(IPM23JA & 8)

8. SRVM System Panel (IPM25J) I I A

\} h h-

9. Meterlogical Data Output Teletype .

WN NA 11 (IPM14J)

10. Turbine Condenser /Feedwater Heaters & I P Aux. Panels (IPM02 & 03J)  !

11. Generator & Station Transformer Recorder I P l

Panel (IPM04J) I l

[ P

12. Station Totalizing Panel (IPM05J) [ (

13. Fire Protection & Deluge Valve Control I i P Panel (IPM09J)

14. Status of excess Flow Check Valves - I P

' Indication Panel (IPM13J) 1 I 15. 345 KV Switchyard Mimic Bus Panel P

! I l (IPM16)) 11 WS

' 16. All Remaining IPM_ _J Equipment 1(50)

XLV. PR - Process Radiation NA 11 WN All Eq'sipnent

r% s V

STRUCTURES, COMPONENTS AND SYSTEM Ct.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requiree nts Non-Essential fication Coments (See Note a) (See Note b) (See Note c) (See Note d)

XLVI. PS - Process Sampling

1. Sample Station IPL50J Chiller' I(SD) II WS

2. PASAS Power Center .

l(50)  !! WS

3. All Remaining IPS_ _ _ _ Equipment NA 11 WN XLVII. RE - Reactor Building Equipment Drains

1. Reactor Building equipment Drain Tank (IRE 0lT) 1(50) II WS

2. All Other 1RE_ _ _ Equipment NA II WN XLVill. RF - Reactor Building floor Drain System All Equipment NA II WN XLIX. SA - Service Air System All Equipment b '

L. SH - Station Heating System NA 11 WN Ty ,,ha!.>

5-All Equipment (*) NA  !! WN Lt. TD - Turbine Drains & Vents

\

All Equipe nt NA 11 WN Lit. TE - Turbine Building Equipment Drains All Equipment NA 11 WN Lill. TF - furbine Building Floor Drain System All Equipment NA 11 WN l

1

O-

• O- O.

STRUCTURES, COMPONENTS AND SYSTEM CLASSiflCATION .

Quality

, Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requirements Non-Fssential fication Comnents (See Note a) (See Ncte h) (See Note c) (See Note d)

LIV. TG - Turbine Generator e

All Equipment NA 11 WN LV. TO - Turbine Oil System All Equipment NA II WN LVI. VA - Auxiliary Building HVAC Aux. Bldg. Charcoal Bed Room Exhaust Fan (LVA03C) (No Other VA Equipment Listed) i II WS LVil. VC - Control Room & Aux. Equip. Room HVAC

1. Control Room HVAC Heating Coils (LVC01AA & AB) NA 11 WM

2. Control Room HVAC Toilet & Kitchen Exhaust Fans (lVC06 & 07C) NA II WN

3. Control Room HVAC liumidifiers (IVC 14MA&B) 1(50) 11 WS

4. Control Room HVAC Humidifier Boiler (IVCISB) I(50) 11 WS a

5. All Remaining IVC---- Equipment i I A g{

LVill. VD - Diesel Generator Room Ventilation ) .

l TNg e \'T3 -

All Equipment i I A .6 s-

t. i t . VG - Standby Gas Trehant System All Equipment I l- A NA LX. VH - Service Water & C.W. Pump Structure Ventilation F. Service Water Pump Cooling System Fans IA - 10 I I A

2. Service Water Pump Cooling system lleat I A Exchangers IA - 10 I WM l

3. All Remaining IVil_ _ _ _ Equipent NA II

^

CT O O' STRUCTURES, COMPONENTS AND SYSTEM CLASSIFICATION -

Quality Quality Group Principle .

Seismic Assurance Essential or Classi-I Component Category Requirements Non-Essential fication Comments (See Note a) (See Note b) (See Note c) (See Note d)

LXI. VJ - Machine Shop Ventilation System All equipment NA 11 WM LXII. VL - Laboratory HVAC System

1. Laboratory HVAC Exhaust Air Filter Package and Air Handling Unit (IVLO4 & 055) I(50) 11 WS

2. Laboratory & SW GR Makeup Air Filter, Heating Coll, and Air Fan (IVLO1F, 09A, and 20C) I(50) II WS

3. All Remaining IVL_ _ _ Equipment NA II WN LXIll. VP - Primary Containment Ventilation System

1. Primary Containment Ventilation Fans i I P

2. Primary Containment Ventilation Cooling Coils (IVP03AA & A8) I I P

3. Primary Containment Ventilation Construction Filteri (lVP07FA & B) NA 11 WN

4. Primary containment Cooling Colls (IVP104A thru 12AB) NA 11 WM

5. All remaining lYP Equipment 1(50) 11 WS LXIV. VQ Pr:ssef Containment & Suppression Pool r*r" .

Purge . .

,

• j t. H

1. Primary containment Purge Electric lleaters NA 11 W

2. All Remaining IVQ _ _ _ Equioent I(50) 11 WS LXV. VR - Reactor Building Ventilation System

1. Reactor Building Ventilation Fans IA-lC 1(50) II WS

2. Reactor Building Ventilation Exhaust Fans IA-lC f(SD) 11 WS

3. All Remaining IVR_ _ _ _ Equipent NA 11 WN

, g'w I STRUCTURES, COMPONENTS AND SYSTEM Ct ASSIFICATION Quality Quality Group Principle Sels1Ic Component Assurance Essential or Classi-Category Requirements Non-Essential fication Cownents (See Note a) (See Note b) (See Note c) (See Note d)

LXVI. VS - Service Building HVAC All Equipment (*) NA II WN LXVII. VT - Turbine Building Ventilation System

1. Turbine Bldg. Vent Decontamination Area Exhaust Fan and Filter I(50) II WS

2. PASAS Room Air Cooler, Supply Air Filter, Cooling Coll, and Supply Fan I(SD) II WS

3. All Remaining IVT_ _ _ ,, Equipent NA II WN LXVIII. VV - TSC & Gate House HVAC All Equipment (*) NA 11 WN LXIX. VW - Rakaste Facility Ventilation System

1. Radwaste Sullding Ventilation Exhaust Fans I(SD) II WS

2. All Reaaining IVW_ _ _ _ Equipent NA II WN LXX. VX - Switch Gear Heat Removal System All Equipment I ,,..I? A LXXI. VY - Core Standby Cooling System Nb- DN '#

All Equipment I k \\ 3I A s

LXXil. WE - Radwaste Demineralization Syst_em All Equipment NA 11 WN LXXill. WF - Radwaste Building Floor Drain Snt;:3 All Equipment NA 11 WN

4*

+9 & O 8

@e IMAGE EVALUAT'ON k//j q g/ TEST TARGET (Mr.3) ((/g%j,d,f4&dp4#

// pp NNNN#/77 7

+

4 6" >

1. % / 4'

'4)>%g>

• $['>'*p,,

off

+ -f IMAGE EVALUATION Test Trager (ut-a) (( f8/4 's . + <- 1.0  !!W Un ylyEl 1.1 i'"EE ~ 1.8 1.25 I l.4 1.6 I 4 150mm > < 6" > i /4 4Vbt hj 't}

 ! h b h= STRUCTIMES, COMPONEN15 AND SYSTEM Ct.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Component Category Requireents Non-Essential fication Comments (See Note a) (See Note b) (See Note c) (See Note d) LXXIV. WG - Gland Water System All Equipment NA  !! WM LXXV. WM - Makeup Demineralizer System ) All Equipment NA 11 WM LXXVI. WR - Reactor Building Closed Cooling Water System

1. Reactor Building Closed Cooling Water .

Expansion Tanks i I P

2. Chemical Feeders NA 11 WM

3. All Remaining LWR, _ _ _ Equipment i I A LXXVII. WS - Service Water System

1. Service Water Pumps IA - 10 I I A

2. Service Water Strainers IR & IB 1 I P 1 3. Traveling Screens I(50) 11 WS

4. Auxiliary WS Pump NA 11 WN -

5. Dechlorination Tank, Agitator, and Pumps NA 11 WN

6. Effluent Monitor Pumps NA 11 WN LXXVill. WT - Turbine Building Closed Cooling Water ,

Sp tem ,, o ; , - A ?vl \ ^ All Equipment NA 11 WN ( ., Nj 'h. LXXIX. WW - Well Water Systam QD ! ' All Equipment NA II WN LXXX. WX - Solid Radwaste l All Equipent NA 11 WN p l O O' O '- l ST!!UCTtRES. COMPONENTS AND SYSTEM Ct.ASSIFICATION Quality Quality Group Principle Seismic Assurance Essential or Classi-Caponent Category Requir w nts Non-Essential fication Crmeants ,(See Note a) (See Note b) (See Note c) (See Note d) i LXXXI WY - 1 l All Equipent NA 11 WN j i LXXXII WZ - l All Equipment NA  !! WM i n% i ' T{NT.6A ys i, 1 l t l I i. 1 d v NOTES a.) Seismic Categories: Seismic Category "I" The equipment and piping are designed in accordance with the seismic requirements for the SSE. Seismic Category "I(SD)" The equipment or piping supports are seismically Designed. Seismic Category "NA" The seismic requirements for the SSE are not applicable to the equipment and/or the piping. b.) Quality Assurance Requirements: Quality Assurance Group I) "I" ( The equipment shall meet the quality sa4arance requirements l i of 10 CFR50, Appendix B. Quality Assurance Group "II" The equipment shall meet the quality assurance requirements defined in the purchase specification. c.) Essential or Non-Essential: Essential "A"-Active A safety-related piece of structure, components, or systems which must remain functional within a defined response both during and af ter all postulated dynamic events. Essential "P"-Passive A safety-related piece of structures, components, or systems which is not required to remain functional, but must maintain its structural and pressure integrity both during and after all postulated dynamic events. Non-Essential, Seismic "WS" Structures, components, or systems which do not perform any l(]) nuclear safety-related function but which must maintain their structural integrity during any postulated dynamic event. t 'O NOTES (Cont'd.) Essential or Non-Essential: Non-Essential, Non-seismic "WN" Structures, components, or systems which are not required to maintain either functional or structural integrity during or after any postulated dynamic event, d.) Quality Group Classification is defined as found in FSAR Section 3.2. P O  ; 9 0 o* Q J S Page 1 of 14 -

APPF.NDIX B 5

TYPICAL VISUAL INSPECTION ACTIVITIES SSCs identified on the approved Classification List will be subject to visual inspections. The visual inspections will be performed on accessible SSCs. The essential attributes will be defined by the responsible designer. The following are typical visual inspection attributes.

p. .

Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC en Piping / mechanical Large bore piping Elevation, size, slope, heat numbers, welding, welders identification, , line/ spool 3 identification, code data nameplate [\ 'T identification (when required), visual damage Visual / measurement Small bore piping Elevatioa, size, slope, 3* heat numbers, welding, welder identification, line/ spool identification, code data nameplate identification (when required), visual damage Visual / measurement Valves and operators, Elevation, size, position indicators location, valve type, flow direction, bolts (if flanged), gaskets, welding (if welded), welder identification, heat numbers, manufacturer, position indicator (open/ closed), packing, alignment, O e m r w , - -m-- --------.9ry .w--. 3 -, ---- --r +p-,.-e- + ----m--m --- -. ----g w- .-vy- m - , , . 89- Il _ __.. _ . _ ._ _. _ s Page 2 of 14 ( APPENDIX B (CONTINUED) i l Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC operator manufacturer j and type, operator stem i orientation, nameplates, tag number Visual / measurement Pumps, gear boxes,' Eleva, tion, size, and couplings location, type, direction of rotation, y, , manufacturer, heat numbers, motor manufacturer and type, velding (if welded), bolting, gaskets, y alignment, nameplates, . - gear box type, gear box () manufacturer, gear box lubrication, coupling type and fit, tag numbers Visual / measurement J> Hangers Elevation, size, location, type, welding, welder identification, shims, bolting, thread engagement, , identification, spring i - loading (as applicable) pipe clearance, clamping l to pipe l Visual / measurement I i I

l. _ . . - - _ _ . . - - _ - _ . , , . _ _ _ _ . , _ _ _ _ . _ _ . _ . , , _ . . , . _ . _ _ . _ . . _ _ _ . . _ _ . . . _ _ , _ _ , _ _ . . . . . , _ . _ _ _ _ _ , _ _ _ _ _ . . . . _ . . , . _ .

~ ^ } I . l s Page 3 of 14 O N-APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual inspection Plant Area SSC Within Each Area Under PVQC Supports Size, location, elevation, welding, welder identification, anchor bolt type, anchor bolt size, clamping, thread engagement, heat numbers, identification Visual / measurement Snubbers Size, location, elevation, type, manufacturer, setting, bolting, welding, welder j identification, leakage, fluid levels, 1 identification Visual / measurement Restraints Size, location, elevation, welding, welder indentification, D' placement, fit, bolting, thread engagement, identification Visual / measurement i NOTE: The above-l.'9ted attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented. O Page 4 of 14 0 APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection , Plant Area SSC Within Each Area Under PVQC , Electrical Exposed conduit Size, material type, visible damage, routing, bend radius, smoothness, number of bends, distance between pull points, ground connection, fittings, bushings, Seismic II/I criteria, identification, end seal after cable installation, channel separation Visual / measurement Trays and wireways Size, material, type and . construction. identification, routing, proper fittings, grounding, dropouts and spillovers, covers and mounting, splice types, ym. and visible damage Visual / measurement Supports Type and configuration, spacing or location, - material type, welding, welder identification (when required), concrete expansion anchors and cannections, identification (when 3 required), and visible damage Visual / measurement O o s Page 5 of ,14 APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Junction boxes Size and type, location, orientation, identification (when required), mounting, connection to conduit, and visible damage Visual / measurement Penetrations Identified and installed ,, at correct location and elevation, proper bolting and thread i engagement, protection , . of machined surfaces (if

s. not closed), proper orientation, and visible

/*w damage. \ l Visual / measurement l l Busses Identification, proper sup port, routing, 3" ' configuration, connections made, no oxide grease used (when required), boots, clearance ta conductive material maintained, and visible damage Visual / measurement Cables Type, acheme identification, correct termination point, routing, channel separation, clamping, bund, ling, proper lugs and connectors used, ccaductor insertion into lug, proper crimp, O - ..~ ... Page 6 of 14 ,i APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC conductor and insulation undamaged, bend radius, support, insulation or stress cone installed, termination tight Visual / measurement Panel boards Identification, location, mounting, grounding, shipping splits properly joined, internal interconnections completed, expansion

1. anchors, welded

1. attachments, and visible

() damage. Visual / measurement Motor control centers Identification, f location, mounting, , am grounding, shipping splits properly joined, interconnecting jumpers l installed, bus bars connected, welded attachments, concrete - expansion anchors, and ' visible damage Visual / measurement %) l l Page 7 of 14 APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Motors Mounting, identification, location, shaf t rotation and lubrication, and

p. .

visible damage Visual / measurement I, O. P l l NCTIE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, l and it is recognized that there may be additions, deletions, and/or ! substitutions necessary as the PVQC is implemented. O -e_ . ,. m_,.. - - , , , . , - - ~ - _ . , - , _ ,-a,-. - . ,,, -w,,, , . , ,, ,_n.,- , ,,,,y_,,,_.., ___,m,,-, p_, -g, - , , , ,- , ,,e- d s Page 8 of 14 /" ( N- APPENDIX B (CONTINUED) Attributes and Characteristics Subject tc Visual Inspection Plant Area SSC Within Each Area Under PVQC Civil Concrete structures Location (line and grade), voids, honeycombs, embedded debris, form mismatch, surface irregularity,

• . exposed rebar, column size and location Visual / measurement Penetrations Location, azimuth and elevation, envelope dimensions, identification .

(mechanical), visible o damage, welder

3

- identification, weld number, weld quality, ,) material type, displacement / distortion, and concrete Visual / measurement Jn Soils Type, estimated sieve analysis for gradation, organic and inorganic debris, moisture j content, grade l Visual / sample s_ Anchor bolts Size, grade, type material, orientation, location, identification, visible damage, full thread e ngagcment , grouting ! Visual / measurement O l _ . . . . . - . ., o i Page 9 of '~14 v APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Embedeents Elevation, location, orientation, identification, bolt hole locations (when bolted), grouting, envelope dimensions, visible damage Visual / measurement , Painting / preservation Dry film thickness (spot check) on steel, holidays, runs, sags, pinholes, crazing, texture, color match, coating material t U~ Visual / measurement I NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete. l and it is recognized that taere may be additions, deletions, and/or substitutions necessary as the PVQC is implemented. l e m -ww. y - ,,,-w.--.->- ,.- g .-,..y ,.,,e,, , y,7,_, , , - _ , - - , , - <gw-, e,.,, , , , , , , , . - - , . _ , - _ , , , , . , , , - , - ,_ ,_ _, s_--_m,, - , . ~ - - - - - - , , , - - - _. _ _ . - . _ . . _ . ~ _ . . Page 10 of 14 O APPENDIX B (CONTINUED) I Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Structural Steel structures Size, type, location, welding, welder identification, bolting, thread engagement, hole location, copes, length, heat numbers (when applicable), visible damage Visual / measurement , w Galleries, ladde:n, stairs Size, type, location, fabrication, bolting type, size and thread engagement, welding, i , , configuration, material, grouting (when () required), mark numbers (when applicable), and visible damage Visual / measurement 3h ' Equipment supports Size, type, location, l bolting type, size and thread engagement, welding, welder , identification (when required), support - contact, grouting (when required) identification, visible damage Visual / measurement l l I l . - ~ . . . e M Page 11 of 14 i APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area SSC Within Each Area Under PVQC Bolting Location, diameter and length, type, proper thread engegement, washers, hole size, number of bolts, visible

1. • damage, configuration Visual / measurement Welding Location, sice, type, weld and welder

'" identification (when required), code acceptability, visible 7 damage l , Visual / measurement Spacial doors Location, size, type, hinges, locks, assembly, identification, visible damage, freedom of operation sw - Visual / measurement NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be. complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented. O l - - . _ - - - .. .. -- ,- . , _ - . , , , . _ , - . , ,_ ,--_ -,__- -- .- , - . , , - - . _, - - . . - , - ~ _ . - , I l J l s . Page 12 of 14 r APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection , Plant Area SSC Within Each Area Under PVQC HVAC Ducts, vents, and dampers Size, location, elevation, routing, identificar. ion, joint configuration, type, gasketing, visible damage, coating (as applicable), envelope dimensions Visual / measurement Supports Size, location, method of attachment (weld size and type, code weld , acceptance, bolting size

3. and type, thread

• ~

engagement), clearances, () coating application (when applicable) visible damage Visual / measurement i 3" Fans and blowers Size and type, mounting, location, connection to ducting, tag number identification, rotational freedom and direction, protection, visible damage, motor '- size and rating Visual / measurement 4 NOTE: The above-listed attributes / characteristics are typical of those i to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented. O ~ s. Page 13 of 14 O APPENDIX B (CONTINUED) Attributes and Characteristics Subject to Visual Inspection Plant Area CSC Within Each Area Under PVQC Insulation Structural Location, material thickness, adhesion Visual / measurement Equipment / components Location, identification, material type and thickness, adhesion, protective covering (when required) -w Visual / measurement Piping Location, size, pipe , identification, type and

3. thickness, adhesion,

- protective covering () (when required) Visual /maasurement 2w- . l NOTE: The above-listed attributes /charscteristics are typical of those l to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC is implemented O . - . - - -m._ _ ._ ,_. ,, -_, ,m ., _ _ _ _ _ _ _ . . . - . , . , - - - , , ._m... - _ . , - . . . _ _ - , ' ~ Page 14 of 14 O(/ AP1'ENDIX B (CONTINUED _)_ Attributes and Characteristics Subject to Visual Inspection-Plant Area SSC Within Each Area Under PVQC Instrumentation Tubing Size, type, material type, routing, radii, connections (nuts fitting, welds), line . marking, smooth bends (no flat spots), and visible damage Visual / measurement Supports Type, size, mounting type and 1..ocation, inserts, fit to tubing / welding, and/or bolting acceptable, and visible damage 3. 1 Visual / measurement I (s) ! lustrumentation, recorders, Location, indicators, alarms, etc. type, recorders, identification, connection to Ja - tubing / supports, mounting, flow directions, visible damage, and protection Visual / measurement NOTE: The above-listed attributes / characteristics are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or subst.itutions necessary as the PVQC is implemented. O_ j . l i e s Page 1 of 2 APPENDIX C ) . uJ TYPICAL REVIEW METHODOLOGY FOR THE MATERIAL DOCUMENTATION REVIEW (FOR PIPING) The following is a typical example of document reviews that may take place to check the adequacy of a valve or an instrument. The document reviews would typically consist of three major steps as follows: I. Pre-Purchased Document Review The document reviewers would check the purchase order to assure ^,, , that the design specifications and regulatory and code requirements were detailed in the purchase order to the vendor. A review is made to aasure that QA requirements are provided for in the purchase order. These QA requirements typically include provisions for the vendor to 1) qualify their sub-suppliers, 2) specify the records required of the vendor (such as data sheets, performance curves, CMTRs, code data sheets, shipping and ' storage requirements, etc.) and 3) properly document nonconformance and/or purchase order exceptions. Any special shipping requirements, record retention requirements, and document review approval by the vendor will be reviewed for inclusion in the purchase order if required by specification or code. Any source' inspection or audit requirements will be reviewed for inclusion in the purchase order. (~N} Past Zimmer problems.from audit reports, NCR inspection reports, etc., are also reviewed to identify any additional requirements. Once the requirements are identified, they are incorporated into the QV checklists, which will be utilized for the detailed review zu- and verification of the receiving and installation documentation. Provisions in the purchase order for documents, such as specifications, that ,are to be sent to the vendor, will be reviewed. The approved vendors list (AVL) will be checked to assure the vendor was qualified to supply material during that time period. II. Receiving Documentation The receiving documentation review includes jobsite receiving reports, documentation from vendors, and source inspection reports (when required). Receiving reports (MRRs) will be reviewed according to the checklist to assure the quality-related aspects of the document are ' properly completed for such things as quantity and description of . material received. In addition, receipt inspection reports are reviewed to assure that the form 1) is adequate for the purpose intended, 2) is properly completed (noting exceptions as required),

3) properly identifies the material, 4) identifies the required documents, and 5) is traceable to the material. In addition these

o E. () APPENDIX C (CONTINUED) receipt inspection reports will be reviewd to assure that configuration checks, which are required to be performed upon receipt, were actually made, proper storage was provided, and nonconformance or discrapancies were identified. Documentation from the vendor is reviewed according to the checklist to assure that it meets the pruchase order requirements. A review of the documents will be made to assure that the required technical or purchase order forms are included. Also, source inspection releases, if required by the P.O., will be reviewed. Where concern exists that documentation may have been falsified, additional checks against vendor retained data and cle results of visual and physical tests, will be made. Finally, the source inspection reports, and audit and shop releases will be technically reviewed for adequacy. III. Storage, Maintenance, and Installation Documents As part of a separate review, storage and maintenance documents for safety-related SSCs will be reviewed against pre-defined checklists to assure that these SSCs meet vendor and design specifications. 3 Installation documents will also be reviewed against pre-defined 3' checklists. The inspection documents will be reviewed to assure ,,) the forms are adequate for the purpose intended. The data on the document will be' reviewed to assure that required inspections have been made, hold points have been verified, cleanliness requirements have been met, special processes have been performed (such as non-destructive examinations), inspectors have been certified and craf tmen have been qualified (when required), and nonconforming U"' items have been documented. Where concern exists that documentation may have been falsified, additional checks against vendor retained data and the results of visual and physical tests, will be made. I l l i l l (o -/ 6 -- - - , , a--, - - - , _ - , - , ,-.,,.--,.n -

---

.,,-y,.,,

~

g o

[

APPENDIX D TYPICAL TYPES OF DATA TO BE COLLECTED DURING  !

THE MATERIAL DOCUMENTATION REVIEW

l. Heat number

2. Heat code

3. NRs

4. Description of material

5. Supplementary tests

6. Material specification

7. Material grade

8. Size 3 . 9. Purchase order number

10. Vendor

11. Code

12. Class

13. Code cases used The above-listed types of data are typical of those to be collected. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, and/or substitutions necessary as the PVQC

, is implemented.

4.

h D

O .

i .

.,. , . , . , - - . , -.- --.., - _ .-- -- -, - - ,., .-_. _.-.-._-,----,,,,,,n , . , , . , . _ , - , , - - - , - , , , - - - - - , ~ , . . , -n_,, -- , , .

- . - - .. -- .... . --.. ...__ . :e . . _. a. .

)

() APPENDIX E TYPES OF CONSTRUCTION INSTALLATION DOCUMENTATION TO BE REVIEWED ,

Welding procedure / procedure qualification records Welder qualification records Welding consumables, identification, and traceability '

Preweld inspection report (weld prep., cleanliness, alignment, fit up)

Welding records Stress relief records Visual inspection reports NDE report (s) and radiographs es Work traveler (s)

/. Bolt-up records e

g, Group placement records

..q.

(,) Dimensional control records Alignment records Rotation / operability verification records 2* Electrical check records Calibration records Cable pull records 4

Termination records Environmental test records Hydrostatic test records l Batch plant records cylinder test reports (3, 7, and 28-day strengths)

Rebar placement records O

l t

yw -w er g-----w y w w -- y ep--- ,. . . ---,- p. ,

~

..:. ..- . . - . . . -.~. .. - . . - - - -

~; ,

2.

Page 2 of 2 APPENDIX E (CONTINUED)

Embedment placement records Concrete placement records Equipment / material identification records Repair records Nonconformance reports Inspection reports 1

Test reports Field design change records

-w Certified as-built records / drawings i , Note: The above-listed documents / records are typical of those to be reviewed / evaluated. The listing is not intended to be complete, and it is recognized that there may be additions, deletions, O_ and/or substitutions necessary as the PVQC is implemented.

l l

~

l O

l

-*-'# " - 9-e e-w hr- . . " ' N'-* =

• r= y

e Page 1 of 3 APPENDIX F EYAMPLES OF CONFIRMATORY PHYSICAL INSPECTIONS l

AREA / DISCIPLINE I ATTRIBUTES AND CHARACTERISTICS I

l l

1

1. Bolting / Concrete Expansion l 1. Tension (Pull) Test Anchor Bolts l

. , l A) Verify proper installation I of installed bolt l

l B) Verify proper tensioning and I integrity of bolt I

, 1 2. Torque Test 1

I A) Verify nut installation with I required torque applied

$, II. Welding / Piping 1. Testing of weld deposited filler

- material (production welds) l A) Perform NDE I

l -Radiography 1 -Dy'e penetrant testing l -Ultrasonic testing

• l -Magnetic Particle testing 1 -Material sampling I -Fiber optics and TV camera

,, l inspections l -Plastic impressions of l questionable areas for I outside analysis I

i l B) Mechanical tests l

l l -Tensile test 1 -Bend test l -Charpy V-notch l -Etc I

l C) Chemical (spectrographic) l analysis l

l D) Hydrostatic testing of l piping systems

()

u

. . . . . , .. - , -c. -i , , .: .

O Page 2 of 3 O

APPENDIX F (CONTINUED) i AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS 1

1 III. Material Traceability / Piping i 1. Testing Installed Pipe l

f. . 1 A) Physical analysis l

l -Tensile test l -Bend test l -Charpy V-notch l -Etc 2, l 1 B) Chemical (spectrographic) l analysis l

, IV. Cable & Terminations / Electrical l 1. Megger Test

> l l A) Verity cable insulation

() integrity l 2. Hi-Pot Test l 1 l 'A) Confirm insulation I characteristics by J" l measuring leakage current l

l l B) Verify proper l corstruction/ installation l of stresscones l

l l 3. Resistance Test l

l A) Verify continuity of l circuits l

l 4. Signal tracing to determine l cable routing l

l 5. Time domain reflectometers to l identify discontinuities l

l 1. Megger Test V. Motors / Electrical l l A) Verify winding insulation l integrity

O I i

4

.~ . .w. .w ...,u c o

Page 3 of 3 APPENDIX F (CONTINUED)

I AREA / DISCIPLINE l ATTRIBUTES AND CHARACTERISTICS I

l l 2. Polarization Index Test l

l A) Verifies acceptable l moisture level in motor l windings I

l 3. Conductivity and chemical I residue testing for break-l down of internal components

, l VI. Concrete / Civil /Masonary Walls l 1. Strength Test l

l A) Rebar mapping of area with l sonic or radar units to

$ 1 ,

determine appropriate area l to obtain samples l B) Core drill to obtain sample I for compression test to l varify adequate concrete I strength I

>- l C) Schtidt Hammer and Windsor l Prole test to verify

, I concrete strength l

l D) Hans er testing to check I con: rete for voids l

I I

NOTE: Theaboveisatypicallistingofphysica[' inspections;itisnot intended to be a complete list af a e p1as. There may be additions and/or substitutions necessary as the :37QC is implemented.

i

. O '

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Page 1 of 29 r

t' APPENDIX G ,

! I LIST OF PEPRESENTATIVE QUALITY PROBLEMS 4

The following is a list of reprecentative quality problems previpusly reported and the action planned for further  ;

PVQC evaluation. }

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Task Description PVQC Response /Actica t

2

1. QCP Problem:

a) Some unacceptable structural welds Structural welds in this category will be verified have been identified, by means of:

1) Accepting the results of QCP per the program .

, discussed in Section 4.3.

2) All other similar structural welds will have a review of the weld documentation and visual Inspection of the welds, or

3) Physical inspections to provide data not provided by documentation and visual 4 inspections.

! 4) Confirmatory physical inspections.

i b) Some structural welds were painted Paint shall be removed from structural welds in before inspection, this category, which shall be verified by means of:

j 1) A review of all weld documentation and visual inspection of the welds, or

2) For a selection of welds, review of the documentation, and physical and visual inspection of those welds.

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l Task Description PVQC Response / Action i

3) Physical inspections to provide data not ,

. provided by documentation and visual j inspections.

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4) Confirmatory physical inspections. [

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1. 1 & E Report #81-27 Problem:

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a) The ultrasonic thickness measurement We1ds in this category will be verified by j of welds and adjacent base material ultrasonic testing and by means of:

revealed a wall thickness of .758 g ,

inch in the base material adjacent to weld HP-12A. The minimum wall 1) A review of all weld documentation

. thickness in accordance with commercial and testing of the welds, or design tables is .862 inch thick.

2) For a selection of welds, review of the

! documentation, and ultrasonic testing will be l pe rf o rmed.

b) The visual examinations of piping welds Welds in this category will be verified by visual revealed six welds that exceeded the examination and review of the weld documentation

] ASME Code allowable enforcement height on the outside of the weld.

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I Task Description PVQC Response / Action {

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1. Report M-38 Problem:

4 There is a concern regarding material 1) Weld documentation will be reviewed and if traceability in five 10-inch recirculation material traceability for the weld is not pipe welds. The concern involves the potential available, this condition will be noted on an use of carbon steel filler material in stainless NCR.

steel welds.

2) All other similar 6tructural welds will have a review of the weld documentation and visual 1

inspection of the welds, or 1

Report M-50 I

Problem:

A number of ASME piping welds were radiographed in the Af ter proper surface conditioning of all welds as-welded condition which resulted in the inability to . in this category visual and physical properly identify and evaluate weld discontinuities. inspections.

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Task Description PVQC Response / Action National Board Task Report Problem:

Task NBT 3 -

Item 1 Summary All material purchased by HJK must be CC&E, HJK, and other contractors will provide received from material manufacturers an AVL to PVQC as discussed in Section 4.3.

qualified by HJK as meeting requirements PVQC will review a group to determine the validity of the results. If acceptable, PVQC will ensure Code, the material was purchased from an approved vendor.

Problem:  ;

Task NBT 23 Some weld procedures have not been Weld procedures will be reviewed for compliance properly qualified for all essential to ASME requirements.

variables as required by ASME.

Example:

HJK Weld Procedure SPPM 3.1.50, Rev. O t 9

9

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

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i Task Description PVQC Response / Action i

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p Show Cause Order Problem:

j! Paragraph 3 4

a) Welds were performed by welders not Welder qualifications will be reviewed for i qualified for veld thickness range in compliance to ASNE requirements. Welds will be l accordance with ASME requirements. verified by means of: '

1) A review of all weld documentation and visual inspection of the welds, and '

2) For a selection of welds, non-destructive j examinations will be performed.

j, 3) Physical inspections to provide data not [

j provided by documentation and visual '

j inspections.

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4) Confirmatory physical inspections I

b) Rangers installed for the control rod Hangers in this category will be verified by means  ;

i drive system are of indeterminated quality of:

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, , 1) A review of all hanger documentation and visual j inspection of the welds, and

2) For a selection of hanger welds, a physical non '

! destructive examination will be performed.

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) Task Description PVQC Response / Action I

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3) Physical inspections to provide data not provided by documentation and visual inspection.

4) Confirmatory physical inspections.

! 1) Allegations (JULY 12, 1983) i l Concern:

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! a) Audit 67 conducted by Henry J. Kaiser Co. The Allegations now on file will be reviewed and I in July 1981 has not been closed out to the areas of discrepancies and violations will the auditor's satisfaction, be documented for verification. Verification of these discrepancies may include:

i 1) A review of all documentation and visual j inspection of accessible hardware of the area .

l in question, and/or '

2) For a selection of like discrepancies and i violations, review of the documentation, and physical inspections will be performed.

1

! 3) Physical inspections to provide data not provided by documentation and visual

< inspections. i

4) Confirmatory physical inspections.

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• v *f Page 7 of 29 Task Description PVQC Response / Action b) Comments on CG&E's response dated The Allegations now on file will be reviewed and February 28, 1983, to an NRC request the areas of discrepancies and violations will be for information, documented for verification. Verification of these discrepancies may include:

1) A review of all documentation and visual inspection of accessible hardware of the area in question, and/or .

2) For a selection of like discrepancies and violations, review of the documentation, and physical inspections will be performed.

3) Physical inspections to data not provided by

, documentation and visual inspections.

4) Confirmatory physical inspections.

1. ASME Report Dated June 23, 1982 Probler:

i a) Welder performance qualification records All Past and present welder qualification records l were found with only " bend-accept" on the form. will be reviewed.

Type or number of tests was not stated.

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b) NDE reports did not include the qualification level of All NDE reports will be reviewed to ensure ,

the NDE examiner compliance with Code requirements.

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Page 8 of 29 Task Description PVQC Response / Action Net Report Paragraph 2.4.1.1.5(1)

Identify all safety-related structures, piping, conduit, Concern in this category will be verified as manholes, and so forth, founded on or in backfill that being acceptable by means of a review of all was not placed within the scope of the program outlined documentation and visual inspection.

in the Dames & Hoore report (M.L. Kiefer letter).

Paragraph 2.4.1.1.5 (2)

For all items identifed as a result of the effort Concerns in this category will be verified as outlined above (including the entire service being acceptable by means of:

water pipeline and duct run), investigate and determine the as-constructed backfill density 1) A review of all documentation and visoal conditions using appropriate ASTM field and lu pections, and laboratory sampling and test procedures, and/or perform sufficient engineering evaluations to 2) Review of documentation, and physical inspection demonstrate that indeterminate in situ densities for selected areas.

are adequate considering all postulated loadings,

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PVQC Response / Action Task Description ,

Paragraph 2.4.2.2.5(1)

For safety-related double wythe walls listed Design verification '.nd resolution of NET REPORT Table 3, demonstrate that all nonconformances are not within the PVQC scope.

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postulated wall loadings can be resisted assuming j two independent walls rather than one monolithic wall.

l a) Appropriate modifications must be implemented Resolution of nonconformances is not within the for those walls found to be inadequate under PVQC scope of work.

the above assumption.

b) The applicant must identify any other safety- Reference

• PVQC Response / Action in Task related masonry walls (solid or hollow) where Description Paragraph 2.4.1.1.5(2).

l collar joints were relied on for load resistence,

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and demonstrate their adequacy by either verification of collar joint fill and/or the engineering / modification j approach described above. ,

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! Task Description PVQC Response / Action i

i Paragraph 2.4.2.2.5(2)

For embedded seismic columns in all safety-related

Reference:

PVQC Response / Action in Task masonry walls, structural evaluation of the column Description Paragraph 2.4.1.1.5(2).

end connections must be made assuming the conditions noted in the NET Report.

l Paragraph 2.4.2.2.5(3) a For those walls where 80% or more of the joint

Reference:

PVQC Response / Action in Task reinforcement was relied on to resist load, in situ Description Paragraph 2.4.1.1.5(2),

testing must be performed to establish that the required reinforcement exists.

a) Where required reinforcement cannot be j substained, appropriate remedial actions are required.

b) In addition, it must be confirmed that the discontinuity of joint reinforcement across columns does not adversely affect current or previous wall evaluations.

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O Page 11 of 29 Task Description PVQC Response / Action Paragraph 2.4.2.5(4)

Where fire and/or ventilation seals are required, the

Reference:

PVQC Response / Action in Task '

type of la situ seal must be established and its Description Paragraph 2.4.1.1.5(2) 1 adequacy to perform its intended function verified.

Paragraph 2.4.2.3.1.4(1), (2), (3), (4) ,

Inspection of structural steel welding in the reactor

Reference:

07QC Response / Action in Task building, service water pump structure, and the Desertption Paragraph 2.4.1.1.5(2) auxiliary building revealed lack of fusion, weld [-

u ndercut , arc strikes, unders).ze fillet welds, hole  !?

in base metal, excessive gap, overlap, gouges, etc.

! Paragraph 2.4.2.3.1.4(1)

The NET review identified several discrepancies Concern in this category will be verified as between the as-built connection details and those , being acceptable by means of a review shown in the drawings (see HET Report, Table 5) c2 all documentation and visual inspection.

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Page il of 29

. Task Description PVQC Response / Action L

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Paragraph 2.4.2.3.1.5 The QCP must be expanded to include component PVQC will verify QCP data and perform any mountings and steel added to structural members remaining inspections.

(e.g. , beam cover plates).

j Paragraph 2.4.2.3.2.5(1)

The applicant should implement a program for

Reference:

Cincinnati Gas & Electric Co.,, ,

LOZ-83-165, November 9, 1983.  :.

" inspection of accessible slotted connections to I

' determine that the torques and fit-up conditions are compatible with design assumptions, with corrective actions taken as appropriate."

i Paragraph 2.4.2.3.2.5(2) i The applicant should formalate an inspection plan

Reference:

Cincinnati Gas & Electric Co.,

for all other accessible structural bolting to the LOZ-83-165, November 9, 1983.

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extent justified by engineering evaluations.

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Task Description PVQC Respon'se/ Action Paragraph 2.4.2.3.2.5(3)  !,

The applicant should formulate a statistical / engineering

Reference:

Cincinnati Gas & Electric Co.,

basis for the acceptance of bolting that was LOZ-83-165, November 9, 1983 inaccessible based on the results of actions taken l to address accessible bolting.

Paragraph 2.4.2.3.3.5(1).

Welds of support columns embedded in masonry walls

Reference:

PVQC Response / Action in Task are generally deficient and inadequate. Description Paragraph 2.4.1.1.5(2).

I Paragraph 2.4.2.3.3.5 (2,3)

Evidence of deficient structural steel fillet welds

Reference:

PVQC Response /Actior. in Task records by the KET. Description Paragraph 2.4.1.1.5(2).

Paragraph 2. 4.'2. 4. 5(1)

All bolting in the intake fiume structure must be

Reference:

Ciccinnati Cas & Electric Co.,

verified to be A-325, Type 3. LOZ-83-165, November '9, 1983

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PVQC Response / Action i Task Description l

i Paragraph 2.4.2.4.5(2) ,

In-service is not part of the PVQC An appropriate in-service inspection program must be scope.

j implemented to ensure that corrosion levels are acceptable throughout the structure's service life.

Paragraph 2.4.2.4.5(3)

S&L drawing deficiencies must be rectified.

Reference:

Response / Action in Task Description .

I Paragraph 2.4.7.4.5(3). Not in PVQC secpe.

Paragraph 2.4.2.5.5 deference: PVQC Response / Action in Task i The applicsnt must formulate an inspection program to Description Paragraph 2.4.1.1.5.(2).

ascertain the adequacy of all RC1 work l (both design and construction) performed at Zimmer and to correct any significant deficiencies. Design review if not within the PVQC scope.

i Paragraph 2.4.3.1.5(1)

i. Not in PVQC scope.

l The removal of Iccal indicators from the instruments

' in the automatic depressurization syctem/ safety valve logic circuits should be justified.

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l Task Description . PVQC Responoe/ Action Paragraph 2.4.3.2.2.5 NET examination disclosed a number of examples for Concern in this category will be resolved I-which the cable abparation criteria of the FSAR by means of a verification of all cable routing.

and the construction specifications had not been Cable separation analyses based on routing will be met, mostly involving lack of separation between performed outside PVQC scope.

nonessential and essential cables.

The applicant will analyze all Class lE and associated PVQC will inspect cables and their circuits to cables and their circuits sharing common raceways plus ensure specified separation is met in panels and those cables and their circuits which do not maintain raceways but evaluation of design separation is the specified separation distance in other locations not in PVQC scope, such as panel interiors and transition between panels and raceways.

Paragraph 2.4.3.2.3.5 One example of cable misrouting was identified. Concerns in this area will be resolved by means of verification of all cable routing.

l Paragraph 2.4.3.2.4.5 l Wiring termination discrepancies inside the panels Concerns in this area will be resolved l inspected by NET were found but were infrequent and by means of review of all documentation of a minor nature. and visual inspection.

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f Task Description PVQC Response / Action t Paragraph 2.4.3.2.5.5 /

l' Findings resulting from NET's inspection of the

Reference:

PVQC Response / Action in Task as-built condition of cable trays and support systems Descriptions Paragraph 2.4.1.1.5(2),

at the Zimmer facility included configuration, bolting',

tack weld, and weld deficiencies.

Paragraph 2.4.3.2.5.5 QCP Task IX personnel have been assigned to perform

Reference:

PVQC Response / Action in Task 100% reinspection of cable tray systems in the control Descriptions Paragraph 2.4.1.1.5(2).

room.

i Paragraph 2.4.3.2.5.5 NET recommends that the applicant take steps to ensure

Reference:

PVQC Response / Action in Task consistency between Kaiser and CG&E inspection Description Paragraph 2.4.1.1.5(2),

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activities.

Paragraph 2.4.3.2.6.5 Based on a number of recorded minor deficiencies,

Reference:

PVQC Response / Action in Task NET recommends that the applicant ensure that the Description Paragraph 2.4.1.1.5(2) scope of the QCP is sufficient to provide adequate assurance of conduit quality.

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l Page 17 of 29 j Task Description PVQC Response / Action Paragraph 2.4.3.3.2.5

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NET recommends that the applicant ensure that

Reference:

PVQC Response / Action in Task turnover of instrumentation to operations for Description Paragraph 2.4.1.1.5(2).

i preoperational testing will include a comprehensive system walkdown to verify that configurations are complete and acceptable, a) Preoperational testing of all instrumentation Not within the PVQC scope, that had been previously completed should be repeated to demonstrate functionality.

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PVQC Response / Action l Task Description j l

Paragraph 2.4.3.2.6.5 The NET identifed a number of relatively minor All concerns in this area will be verif qd l

" deficiencies in the facility's conduit installation, as being acceptable by means of These deficiencies included labeling, support welding, visual inspection, anchor bolts, loose fastners, broken sections of flex conduit, and a lack of seismic clearance. .

4 The occurrence of deficiencies was diffuse, and the overall quality of conduit installation was judged adequate by the NET. All deficiencies identified appeared to be readily correctable. [

Paragraph 2.4.3.3.3.5 I

1) The applicant should expand the existing All concerns in this are will be verified as i program associated with electrical switchgear being acceptable by means of a and panel anchorage shimming to include visual inspection, verification of adequacy of all panel foundation welds for all safety-related switchgear and panels to provide for the required structural integrity.

2) The applicant must establish a program to verify

Reference:

PVQC Respanse/ Action in Task the installed adequacy of foundation bolting and Description Paragraph 2.4.1.1.5(2) bolting interconnecting cabinets and modules through engineering evaluations and/or modifications.

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Task Description PVQC Response / Action Paragraph 2.4.3.4.5

" NET recommends that the applicant inspect electrical Re,f erence: PVQC Response / Action in Task l system and equipment identification during QCP tasks Description Paragraph 2.4.1.1.5(2).

and turnover walkdown inspections to ensure proper system identification before operations." ,

J Paragraph 2.4.3.5

1) NET found that electrical equipment labeling i deficiencies were widespread.

2) NET recommended that panel and equipment foundation

Reference:

PVQC Response / Action in Task i bolting inspection be incorporated into the QCP. Description Paragraph 2.4.1.1.5(2). '

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3) NET has recommended that the applicant ,

j ensure that the program to conduct final inspections of instrument racks be reviewed to ensure completeness. ,

4) The NET recommends that the applicant compare Reports such as NET, National Board, ASME, NET's findings with the activities inspected by 50.55(e), CARS, NCRs, and inspection reports QCP to obtain added assurance that the scope of will be addressed (uring the PVQC.

the QCP is suf ficiently comprehensive. ,

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Task Description PVQC Response / Action p.

4 Paragraph 2.4.3.6(4)

Reference:

PVQC Response / Action in Task Il l 1) NET recommends that the applicant reinspect those areas of extensive rework to identify Description Paragraph 2.4.1.5(2).

equipment in need of repair.

2) NET recommends that the applicant examine the Will be examined under CCP. . 2 program for protection of surrounding equipment l'

4 to lessen damage caused by rework or modifications. ((

i Paragraph 2.4.4.1.4(2)(a) i The applicant should clarify the existing practice Not in the scope of the PVQC program.

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' of residual heat removal system hanger design not j strictly in accordance with ANSI B31.7 latent nor as  ;'

defined in the FSAR.

l Paragraph 2.4.4.1.4 (2b, 3, 5) i:

Numerous system supports required in these areas Concerns in this category wil1 be resolved by  ;

were found by NET to be complete. reviewing all documents and visual inspections.

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1 l Task Description PVQC Response / Action Paragraph 2.4.4.1.4(2B)

$ s Corrosion and debris in two valtes (F0047B and All concerns in this category will be resolved i j F0528) indicated poor equipment storage and inadequate by means of visual inspection and for inspections before installation. selected SSCs, physical inspections.

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! Paragraph 2.4.4.1.4(3) 1 Numerous arc strikes noted by the NET should "be All concerns in this category will be resolved as *

inspected in the final walkdown inspection as discussed being acceptable by means visual in the RHR walkdown paragraphs" (REF NET Report, inspection. t Paragraphs 2.4.4.1.4 2a & B).

Paragraph 2.4.4.2.4(6) l NET inspection records indicate that design of supports Not withln the PVQC scope.

j for cable duct assemblies for safety-related incore

] reactor instrumentation inside the reactor cavity near ,

f the CRD mechanisms is grossly inadequate.

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Task Description PVQC Response / Action j l

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Paragraph 2.4.4.2.5(1) 4 The applicant should " review (pipe support) Concerns in this category will be verified inspection and maintenance procedures and make as being acceptable by review of all appropriate revisions to provide additional assurance inspection.and maintenance procedures.  ;

that deficiencies" such as those recorded by NET ,

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j [REF: 2.4.4.2.4(7)(d & e)] "are identified and -

t corrected."

Paragragh 2.4.4.2.5(2)  !

The applicant should " reinspect all QC accepted,

Reference:

PVQC Response / Action in Task 4 safety-related small bore pipe supports for Description Paragraph 2.4.1.1.5(2).

appropriate weld size and take appropriate remedial ,

actions."

l Paragraph 2.4.4.2.5(3)

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1) Undersized U-bolts on small bore piping must be

Reference:

PVQC Response / Action in Task subjected to appropriate evaluations and/or Descripiton Paragraph 2.4.1.1.5(2).

modifications.

2) Any generic implications must be addressed accordingly.

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i C Task Description PVQC Response / Action Paragraph 2.4.4.2.5 (4) f J

The applicant should institute a program to provide Not within the PVQC scope.  !

appropriate temporary supports and/or to restrict I

construction activities to ensure that excessive loads will not be imposed on unsupported small-bore piping and instrumentation lines.

Paragraph 2.4.4.3.5 (1)

1) "The applicant should establish a program to

Reference:

PVQC Response / Action in Task inspect and review separation of anchor bolts Description Paragraph 2.4.1.1.5(2).

installed before the date of implementation of the current generic separation criteria."

2) "The anchor bolt inspections should cover the various disciplines which used anchor bolts in safety-related applications."

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Task Description PVQC Response / Action Paragraph 2.4.4.3.5(2) 7

1) "The applicant should initiate an inspection Concerns in this category will be resolved a program to randomly sample a minimum of 5% of the by a sample based inspection, total number of safety-related supports with review of the documentation and concrete expansion anchor bolts." physical inspection of those samples.

a Deficieccy correction is not within the PVQC scope.

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2) " Identified deficiencies must be corrected."

! 3) "The inspection program should be limited to inspection (NET) of anchor bolt torque."

i Paragraph 2.4.4.3.5(4)

, The applicant should review the adequacy of S&L Not within the PVQC secpe.

I anchor bolt specification regarding the abandonment of inadequate anchor bolts.

1 Paragraph 2.4.4.4.5 q

"All safety-related piping drawings should be reviewed Not within the PVQC scope.

4 and revised to reflect the intended valve operator orientation. The review should ensure that the operator j orientation in the piping analysis will be properly .

! reflected in he design drawings."

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[ Task Description PVQC Response / Action

1) " Inspection ef forts by the applicant's QC program All concerns in this category will be resolved i:

1 and system walkdowns must confirm proper valve by means of a visual inspections.  ;-

operator orientation."

2) In cases where discrepancies are determined, the Not within the PVQC scope.

Impact on the piping system analyses must be determined and any required corrective accons taken."

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Paragraph 2.4.5.1.4(2g)

The applicant should provide "further evaluation of PVQC will review the procedures and training ,-

his procedures and training of radiographic personnel.: of radiographic personnel.

Paragraph 2.4.5.2.4(2)

The applicant should evaluate the sensitized area noted Test and physical inspections will be conducted by in the recirculation Loop B, pump suction elbow PVQC. Evaluation of results is outside PVQC scope.

t longitudinal weld.

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i PVQC Response / Action Task Description ._

Paragraph 2.4.5.2.4(2) .

The applicant should perform additional examinations Test and physical inspections will be conducted by

PVQC. Evaluation of results is outside PVQC scope.

and evaluations to determine the extend of the martensitic/bainitic structure condition noted I by NET. .

Paragraph 2.4.6.5(1)

Not within the PVQC scope, The applicant should retest " electrical protective relays before preoperational testing of diesel generators and associated systems."

Paragraph 2.4.6.5(2a)

PVQC will perform documentation and visual

• Tt.e applicant should verify the adequacy of the installation of the diesel generator and inspections.

I associated systems.

Paragraph 2.4.6.5(2b)

Not within the PVQC scope.

l The applicant should develop and implement an

! adequate inspection and maintenance program for the diesel generator and associated systems.

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Task Description ,

PVQC Response / Action

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l Paragraph 2i4.7.4 (9 and 10) 1 Mounting bolts on the NET Note 5 Ingersol-Rand pumps

Reference:

PVQC// Action in Task and on all similarly mounted safety-related mechanical Description Pr.ragraph 2.4.1.1.5(2) for ,

components should be verified for proper torque. Paragraph 1 and 2.

1) "This bolting should include component to concrete anchorage and, where used, component to mounting plates or flanges."

2) "In addition, as part of the system turnover for preoperational testing, the presence and proper bending of lock tabs; should be verified."

! 3) " Instances in which deficiencies are found must Not within the PVQC scope.

be reviewed and evaluated / corrected."

Paragraph 2.4.8.5(1)

"The completion of (HVAC) thermal insulation Not within the PVQC scope.

j installation and calibration of the position dampers should be adequately controlled by the final installation inspection procedure, NO. HVAC-6."

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. Page 28 of 29 Task Description PVQC Response / Action 7

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Paragraph 2.4.8.5(2a)

All identification of concerns in this category The applicant should identify (and correct) the will be lack of seven anchor bolts on the west side of filter resolved by means of inspection. Correction is not within PVQC scope.

i package IVC 095 (B Train).

Paragraph 2.4.8.5.(2c)

1) "The applicant must determine that all HVAC Not within the PVQC scope for paragraphs 1 and 2.

j equipment meets the (hot spot temperature) i requirements assumed in design and take appropriate );

corrective actions." (NOTE: The acceptance t, criteria is not clear.)

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2) "All HVAC equipment must be reviewed to ensure compliance with this specification and the applicant .

4 must take appropriate corrective actions."

Paragraph 2.4.8.5(3c)

1) " Flange bolting design must be re evaluated for Not within the PVQC scope.

adequacy."

4 All concerns in this category will be resolved

, 2) "The faulty condition on pinlocks on doors must be rectified bef ore final system turnover." by means of a visual inapection. ,:

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Page 29 of 29 Task Description PVQC Response / Action Paragraph 2.4.8.5(4)

1) The applicant should correct the absence of current Not within the PVQC scope.

calibration stickers for instruments placed in operating service.

2) The instrument group (operations) and quality '

assurance personnel, as necessary, should establish ,

a frequency schedule for calibration and maintenance.

This program should also address other programs such as damaged conduit.

Paragraph 2.4.9.5 The applicant should review the interface between Not within the PVQC scope.

operations and construction in relation to responsibility for maintenance and housekeeping.

This review should include procedural controls, jurisdiction, and periodic inspections.

Paragraph 2.5 i An independent design audit (of the S&L design process) Not within the PVQC scope, is recommended to satisfactorily resolve the issue of design adequacy.

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() APPENDIX H DESCRIPTION OF PROJECT NONCONFORMANCE PROCEDURE Existing project procedures for control of nonconformances were reviewed by a site interorganizational committee to determine whether the procedures and methods could be improved. As a result of the committee's review, it was determined that the procedures for

~

documenting and controlling nonconformances and discrepancies should be replaced by a single, project-wide procedure.

A new procedure for controlling and documenting nonconformances is being developed. One prerequisite is that all affected Zimmer project organizations will use this NCR flowpath. They will identify 1

responsibility.. by title, for activities in compliance with the nev

• i 6- requirements. These requirements comprise the following principal elements:

3> '

o Only one form, titled nonconformance report (NCR), shall be used to report, control, disposition, and complete nonconforming items.

o A nonconformance is defined as a deficiency in characteristic, documentation, or procedure that renders the quality of an item unacceptable or indeterminate with respect to project requirements including design criteria and specifications.

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l Examples of nonconformances include physical defects; test l

failures; incorrect or inadequate documentation; l

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\,,) APPENDIX H (CONTINUED) and deviations from prescribed processing, inspection, or test procedures.

o Other documents, such as the existing nonconformance reports (NRs), in process inspection discrepancy reports (IIDRs), and 4 , field requests for design change will no longer be used to report nonconfonaances. NRs and IIDRs that were issued and validated prior to inception of the new NCR procedure, if 4

found to be correct, will be transferred to CCP for processing. If it is determined these reports are incorrect as a result of PVQC, the NRs and IIDRs will be transferred to

. an NCR for clarification and processing, s0 V

o NCRs shall be initiated by those individuals who are assigned the responsibility to perform inspections to verify quality.

Typically this includes cognizant field engineers and quality control personnel. ,

1 o The cognizant field engineer or quality control person shall be notified by any person who observes or becomes aware of a nonconforming condition. Upon determination that an NCR is warranted, an NCR shall be written, signed, logged and -

forwarded to the applicable discipline QCE for review and validation.

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() APPENDIX H (CONTINUED) o Once an NCR has been logged it cannot be voided. Should it

' become necessary to discontinue processing the NCR for reasons of redundance, erroneous reporting, or other similar conditions, quality control shall state the basis for the action and sign off the appropriate block with PQCM or PQCE concurrence. No further action is required except for removal of hold tags, final distribution, and filing.

i o All nonconforming items shall be segregated, tagged, marked,

• ' or appropriately identified to prevent inadvertent use or ,

installation. Only quality control may remove hold tags or other identifiers from the nonconforming items.

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O o NCRs that have been logged, but not validated, shall be ,

maintained as a quality record with a qualifying statement as

p. . to why the NCR was not processed. If the NCR originator disagrees with the decision not to validate the NCR, he has the right of recourse to as high a level of management as

. necessary to obtain satisfaction. A separate procedure will be issued to explain this method.

o All NCRs shall be reviewed by quality assurance to determine a

whether the nonconformance is possibly reportable under .

10 CFR 50.55(e) or 10 CFR Part 21 in accordance with applicable procedures.

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Page 4 of 4 AFPENDIX H (CONTINUED) o During activities under the plan to verify the quslity of construction (PVQC), NCRs will be issued, validated, tracked, and trended. Dispositioning of NCRs is not included within the scope of PVQC activities; however, there may be instances where a generic condition is discovered in which a standard resolution can be used for specific occurrences of applicable nonconformances.

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, Dispositioning will be performed under the CCP.

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APPENDIX 1 BECHTEL DOCUMENT CONTROL Bechtel Document Control (BDC) will establish a Records Center for in-process control of design and quality-related documents required to support the PVQC.

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The BDC will be responsible for the the receipt, recording, and issuance of documents. This will include all CG&E and contractor documents. H.J. Kaiser will be responsible to control its ASME w

Section Ill quality documents under Bechtel documentation control center supervision and management.

o I

BDC will maintain personnel within the center and will control access to all quality-related document files.

• ' PVQC personnel will be required to acknowledge by signature their receipt of records. A list of personnel authorized to receive records shall be posted at the PVQC Records Center.

Accountability for records shall be maintained by requiring the periodic return of all records to the center. The f requency of returns will be determined by the Records Center Supervisor, and it will not exceed dnce a week. Provisions will be made in the document review work area to assure the security of records while they are being processed there.

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APPENDIX J PVQC COMPUTER APPLICATIONS The PVQC has the option of using computer databases that will identify, collect, sort, compare, and status project information and allow variable reporting capability for support of the PVQC effort. Examples of key function databases desired for the PVQC effort include:

o providing status of PVQC efforts and record PVQC nonconformances o relating baseline documentation to' systems, structures, and components o concerns and previously written nonconformance reports from other reports (for example NET, Q'P) to plant SSCs o sorting and printing out data to aid in the status determination

. phase of PVQC The databases will contain, but not be limited to, the following

, information for use in the PVQC:

i'

1. . System, structure, and component identities including appropriate generic data such as the system, area, elevation, QA/QC requirements, or seismic. class

2. Drawing, specification, and document numbers including revision, status, and date zu . 3. Nonconformance and/or deficiency log identities including revision, status, and date

4. Status information regarding PVQC activities (such as date completed)

5. Information on welders and welding data (CWIS)

It will be the intent of PVQC to use the computer to the maximum extent practical to aid in the PVQC effort by replacing manual operations with proven computer applications.

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i APPENDIX X t FIGUPE 1 l FLOW DIAGRAM 0F PVQC ACTIVITIES [

Confirmatory Physical N Inspections l j

(as required + ,

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Collect & Catalog Deta.

' P'ff0f8 IR5P*CtlonS Status Transmit Assist in enter in PVQC Database ' 'P*

• Construction VISuel Determinetton Defining Pre are I Database 4 PVQ

% i "nstallation Documentsql c ,, g Q Material Documents

-+ Conform 4l Verification f{

Format & Procedures Check ists f ncomp e CCSE COD

• Material Documents Other Data QCP NET Report Existing Project Database, Etc. ..

Send to Dase Line Data l QA for W

Cunpertson Trend l

Program

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ACQUISITION OF DOCUENTS ,

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FIGURE 3 F

VISUAL INSPECTIONS 1

4 Design i

Drawings i l

And Specs l

Divide Conduct aggoc.g. Call up Prepare Review welkde.ns Docueents Plant Int E*I """I Task Check-I Discipline. 41 Appropriate Porti n To 4l Dra,'engs & W' list & Work l l And Approve Checklists Wl And Record As Constructed 4l To Document Control 1

Systems.

Each Te m Design Specs Package Data Center Areas e

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1 APPENDIX K 4

FIGURE 21 L' MATERIAL DOCUMENTATION REVIEW Categorize

. Collect Specs, Receipt Revle" Prepare l Purchasing l Docs, Vendors gl SPets IOf gl Qvl's and [

& Receiving Subcontrac- Meterial QVCL's Documents tors,"Q s leon Attributes Q" Material t

i Approve l Qvi's s (

QvCL's t

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Prepare Prepare I"

EVP Table of Perform Meterial/ '

l Contents and MI Document W' Equipment Wl ,, "3 t

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Assemble Review identiff- System ,

cation Log EVP Identify l l Missing Documents l I

Locate or NCR f i i

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4 i APPENDIX K p F1GURE 5 .

h i CONSTRUCTION INSTALLATION DOCUMENTATION REVIEW '

j Specs d Prepare Approve y((, ,y 4 Procedures %J QWl's and gi QVI's and  ;- Contents and l '

QVCL's for Required QVCL's Assemble

] gyp Attribures 1

I Data from P.O. Review and Visual l

( Inspection l

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! 7 Enter Status '**'*

into Pro ect l '- M"*"I

' leforma Ion System RevI**

I i Identify l 1 Missing Documents l Locate or '

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APPENDIX L FIGURE 8 PVQC IMPLEMENTATION SCHEDULE l

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pygg T T T Plenatog & Procedures Mu'un e

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Porfare acoriei  : ; j Documentat ion , . .

Routes , l e Perfore lastellation l l w

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APPENDIX M PVQC TRAINING MATRIX (SAMPLE FORMAT)

JOB TITLES Field Const. QC Department / Eng. Super. Insp. QA File Training Discipline EE Mech. Weld. Auditor _ Clerk Subject Jobsite F F F F F Orientation All PVQC F F F F F Orientation A11 QA F All F F F F Orientation

w N Safety Brief Const. FD F F N

,F F N N PVQCP Const./EE F Eng./ Mech. F F F N N

$ PVQCP

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' Audit

-N N N F,J N i

Training QA l

l Walkdown Checklist Const. FD FJ F,J FD N l

• • Documer.t Document RO F N Control Control RO R0 LEGEND N - Not Required , ,

RO - Read Only l

l RR - Read end Review F - Formal Training J - On-the-Job Training FD - Formal Training Delayed 1

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Page 1 of 1 APPENDIX N INITIAL SYSTEMS, AREAS, AND COMPONENTS TO BE VERIFIED Note: This program may be modified based on constraints identified during implementation of the PVQC.

Priority Sub-Priority Comments

1. Drywell A. Str:tetural steel Review by elevation priority

.. . as follows:

'l 1. El. 525

2. El. 535

3. El. 546/561

4. El. 572 1 5. El. 583 j e 6. El. 530 B. 2-1/2" & over pipe & welds Review in start-up system sequence C. 2-1/2" & over pipe supports as follows:

l i. D. 2" & under pipe & welds 1. Residual heat removal (RH)

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E. 2" & under pope supports 2. Control rod drive (RD)

(_ ,# F. Instrumentation- 3. Feedwater (FW)

G. Electrical 4. Mainsteau (MS)

H. HVAC 5. Reactor recirc. (RR)

I. Grating 6. Nuclear boiler (NB)

J. Bio-shield doors 7. R.B. clad clg water (WR)

K. Painting 8. Control rod pos. ind. (PI) 8" L. Reflactive insulation 9. Fuel pool cig. (FC)

10. Reactor wtr. cleanup (RT)

11. Reactor core isol, cig. (RI)

12. High press. core spray (EP)

, 13. Low press. core spray (LP)

14. Standby liquid control (SC)

2. NSS & ECC . Service water (WS) Review in following order of systems Residual heat removal (RH) commodity (Outside Control rod drive (RD) 1. 2-1/2" & over pipe & welds i dryvell) Feedwater (FW) 2, 2-1/2" over pipe supports Mainstream 3. 2" & under pipe, welds &

Reactor racire (RR) supports Nuclear boiler (NB) 4. Instrumentation R.B. clad. cig. water (WR) 5. Electrical Control tod pos. ind. (PI) 6. Civil / structural i

Fuel poo?. cooling (FC) as required

3. Balance of See Comm< nts Final integrated project essential schedule will be issued systems later.

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! APPENDIX 0 i

PROBLEM RESOLUTION MATRIX AS-CdNSTRUCTED COMPONENT COMPONENT STATUS AS STATUS STATUS CONSTRUCTION DETERMINED COMPONENT COMPONENT SAME AS NOT THE SAME INSTALLATON BY PVQC NOT IN CONSTRUCTION CURRENT AS CURRENT l

I DOCUMENTATION INSPECTION PLACE IN PROGRESS (2) DESIGN DOC DESIGN DOC i

Installation documentation I.W. I.W./NCR(4) NCR NCR 1.W. = Incomplete Work (l) not available

, Installation documentation 1 W.(3) I.W./NCR(4) C NCR/1.W. C = Complete Installa-j incomplete tion Documentation (5)

• i or NCR i

Installation documentation I.W.(3) NCR NCR NCR NCR = Nonconformance i complete but inconsistent

] with as-constructed condition Installation documentation I.W.(3) 1.W. Conformance I.W./NCR complete and accurate with i as-constructed condition i

1 j 1. " Incomplete Work" will require new inspection documentation.

I 2. " Construction in Progress" is defined as obvious construction activity taking place at the time of the show cause and stop work order issuance.

6

3. Documentation to support the removal of the component must exist.

, 4. Such components are nonconforming if construction installation documentation should, but does not, exist for the l completed portions of the component.

5. There may be cases where a component has been completed, but has not yet received an inspection, thereby rendering l the installation documentaiton incomplete. In such cases, an inspection may be performed under PVQC and the construction installation documentation completed.

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Page 1 of 2 APPENDIX P SPECIFIC EXAMPLES OF PHYSICAL TESTING METHODS 1

The following are examples of methods that can be explored to determine the acceptability of inaccessible materia'. or material surfaces that are nat exposed for visual examination. Three cases were considered (1) ASME III buried or embedded pipe, (2) concrete structures, and (3) electrical equipment.

1) ASME III Buried or Embedded Pipe

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Available methods for visual internal pipe examination of inaccessible installations range from fiber optics units to T.V.

cameras. These methods provide visual two dimensional inspection.

For large diameter pipe visual internal examination may be performed by placing inspection personnel in the pipe (limited by physical e conditions, pipe configuration and safety regulations). Personal visual inspection can be enhanced while in the pipe by use of a T.V.

camera that allows more qualified personnel visual access from outside and produces tape record of the evaluation process and use of

, plastic impressions of questionable areas that can be processed as ure ref ence Physical inspections such as liquid penetrant, magnetic particle, eddy current, in place metallography, ultrasonic examination (would require developement of unique procedures), and field metal analysis equipment (portable spectrometer) can be used to evaluate material grade and acceptability. In addition, destructive examinations such

• • as scrapings and small diameter plugs can be removed for chemical analysis. Larger pipe wall material semples, above 2" x 2", can be removed for mechanical property testing. These methods would require engineering evaluation of the extent to which applicabla codes or standards permit repairs and modifications (e.g. may require an ASME code case).

1 Different methods of gaining access to the pipe such as through valve.s (disassemble the valve allowing access through valve), small l or identical branch connections (access through an accessible branch), limited excavation and open ended lines will be utilized.

Preliminary analysis of embedded and buried safety-related pipe i indicates a total of 3678 linear feet and 845 welds in the service l water cycled condensate and fuel pool cooling and cleanup systems.

I In total, this represents less than .4% of the total piping on the project. Of this total less than 500 linear feet are embedded in concrete. All of this piping is for low pressure service with a design pressure less than 200.psig. A program to perform an early l documentation review of this inaccessible pipe is being developed so that the condition of weld and material traceability and quality is

/ known at an early date.

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APPENDIX P (CONTINUED)

2) Concrete Structures Available physical verification techniques are: 1) hammer testing to locate prior consolidation areas, hollow /voida and poor repair work;

2) concrete strength tests such as Schmidt Hammer, Winador Probe, or selected core samples (e.g., 2" size which is destructive but can be repaired easily); 3) rebar location by use of sonic and/or radar

' units (not suitable for use in congested rebar areas), some of these units may distinguish between different size bars such as a #8 or #11

. . but not necessarily between #10 and #11 bars; 4) some radiographic methods could be developed that would have limited application for providing a definable rebar pattern. Application limits are based on source size, concrete thickness, and accessibility.

3) Electrical Equipment:

w Available physical verification techniques are: 1) Megger testing for motors and electrical cable, 2) use of time domain reflectometer to identify discontinuity, 3) signal tracing to determine cable e routing 4) high potential testing for capacity testing of equipment

1. such as transformers; and 5) oil test (s) of electrical equipment oil

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/% reservoirs for conductivity and chemical residue that may indicate a

(_ / breakdown of internal components.

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