ML20112A694
| ML20112A694 | |
| Person / Time | |
|---|---|
| Site: | South Texas |
| Issue date: | 03/01/1985 |
| From: | BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML20112A688 | List: |
| References | |
| NUDOCS 8503180421 | |
| Download: ML20112A694 (13) | |
Text
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ST-HL-AE-1201.
File #: G9.11/Q39
' Attachment PART B BECHTEL ENERGY CORP' ORATION QUALITY ASSURANCE PROGRAM DESCRIPTION SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION QUALITY' ASSURANCE DURING DESIGN AND CONSTRUCTION t3e o
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BECHTEL QUALITY ASSURANCE PROGRAM DESCRIPTION FOR SOUTH TEXAS PROJECT
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INTRODUCTION The Bechtel Quality Assurance Program Description used by the Bechtel Energy Corporation.for the South Texas Project is described in the NRC approved Bechtel Topical Report BQ-TOP-1, Rev. 3A, Bechtel Quality Assurance Program for Nuclear Power Plants and the modifications and additions described below.
Throughout the Program Description (Part B) where the Program Description states Thermal Power Organization, it shall be construed as synonymous with Bechtel Power Management.
Throughout the Program Description (Part B) where Construction Quality Control is stated, it shall be construed that Project Quality Control reports to the Project Quality Assurance Manager.
SCOPE OF SERVICES Bechtel Energy Corporation is responsible for Engineering, Procurement and Construction Management activities at the South Texas Project. Tnis activity includes receiving, storage, maintenance, receiving inspection and Quality Assurance functions. Bechtel Construction Management is responsible for management of the construction and quality assurance / quality control activities of the Constructor / Contractor (s). Construction Management consists of planning, scheduling, monitoring and evaluating the Constructor /
Contractor (s) construction and quality assurance / quality control activities.
The construction, field engineering, and quality control activities defined in the topical will be the responsibility of the Constructor / Contractor (s). The Constructor / Contractor (s) will be responsible for submitting to Bechtel, for approval, a quality program which is consistent and compatible with the applicable sections of Bechtel's Topical Report.
The following is a description of the South Texas Project modifications to meet the scope of the project and client requirements.
Introduction l
Page 4 - item #5 l
Division Quality Policies - Guidance defining requirements and responsibilities for accomplishii Quality Program functions which may be modified, deleted by, or supplemented with project documents to meet specific project / owner requirements and the scope of the project.
Revision 9 Page 1 of 12
1 Section 1 - Organization
- o 1.5.4 Division Construction Managers of Division Construction provide technical and administrative
' direction to the Construction Department personnel. Managers of Division' Construction are assisted by Construction Managers and Chief Construction Engineers, where assigned. Construction Managers are responsible for the management and technical direction of assigned projects, and for assuring that construction projects are provided with
-appropriate personnel and are following prescribed division practices and procedures for conduct.of construction activities..
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1.6.1 Project Quality Assurance The project quality assurance program is directed by the Project Quality Assurance Manager who is responsible to assure that Quality Assurance or
' Quality Control actions listed below are accomplished in accordance with the requirements of the project:
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- 1) - Coordinate the functions of the project quality program, and serve as the focal point for project communication on matters relating to this program.
2)
Coordinate project quality-related activities of Engineering, Procurement, Project Administration, Records Management System, and:
Construction.
3)
Audit and surveillance of project quality-related functions and adherence to procedures. Advise management of the status of 4
program implementation.. Conduct prescheduled project audits and supplemental audits directed by the Project Quality Assurance Manager.
4)
Review Supplier and. Constructor / Contractor (s) quality assurance program requirements in procurement documents and conditional releases of nonconfonning items at the construction site.
5)
Review turnover packages and selected quality verification records prior to turnover to the Client.
- 6). Concur with evaluation of recommended supplier's quality assurance program, in accordance with subsection 7.1.
Evaluate supplier.'s Quality Programs for jobsite originated safety related purchases when determined necessary by the Project Quality Assurance Manager.
7)
Take stopwork action when warranted.
[
8)
Identify quality problems, initiate documented action leading to a solution, and verify implementation of solutions.
9)
Review project plans and schedules for quality-related activities to assure timely and effective implementation of the quality assurance functions for the project.
Revision 9 Page 2 of 12
- 10) Provide periodic reports to the Division Quality Assurance Manager and Project Manager evaluating the status of the project quality assurance program and advising of any problems requiring special attention.
- 11) Coordinate quality assurance functions within the project and with
. groups outside the division, such as M&QS and Procurement Supplier Quality.
- 12) Assure that quality assurance related procedures and manuals prepared by or used for the project meet project quality program requirements and initiate revisions when necessary.
- 13) Review, prior to use, Procurement Quality Surveillance Inspection plans and Quality Control instnictions for clarity and the existence of the information described in Sections 7 and 10.
In addition, evaluate.the adequacy of selected plans and instructions by performing an in-depth review of:
.a.
Accuracy of translation of drawing and specification requirements.
b.
Basis for detemining inspection level and requence.
c.
Adequacy of inspection method.
This review provides assurance that the total quality program requirements inclusions are complete.
Reviews of generic plans and instructions can be performed on a generic basis.
In that case, the PQAM only verifies that the review of the generic plan or instructions has been performed.
.14) Review and approve Constructor / Contractor (s) quality programs.
- 15) Prepare quality assurance descriptions in Safety Analysis Reports.
- 16) Review Honconformance Reports and other quality problem related documents to determine trends, identify significant deficiencies, and recommend appropriate corrective action.
The field quality assurance program includes the capability to perform:
o Receiving inspection of permanent plant material and equipment.
o Maintenance and storage inspection of pemanent plant equipment and material in Bechtel's custody.
o Review of receiving and Bechtel QC documentation.
o Surveillance inspection of work performed by Constructor /
-Contractor (s). This inspection supplements the quality programs of the Constructor / Contractor (s) who have responsibility for their work and their quality verification.
Revision 9 Page 3 of 12
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. Surveillance inspection includes either selected physical inspection at prescribed hold points and observation or witness of inspections performed by the Constructor / Contractor (s):
o Reviewing quality control documentation, o
Reviewing Bechtel and/or Constructor / Contractor (s) quality documentation.
o
.Providing technical direction to testing laboratories and inspection Contractors.
o Reviewing supplier quality verification document packages for completeness and traceability to the item (s).
o Identifying quality problems, initiating action leading to solutions, and verifying implementation of solutions.
o Reviewing Constructor / Contractor (s) quality verification documents.
o Reinspection of Conctructor/ Contractor (s) completed work may be imposed as deemed necessary.
- 1.6.2 Project Engineering 3)
. Prepare specifications for Supplier and Constructor / Contractor (s)
Quality Assurance Program.
5)
Review and approve the design changes and approve nonconformance di spositions.
6)
Review drawings, procedures, test data, manuals and reports submitted to Engineering by suppliers and Constructor /
Contractor (s).
8)
Provide support to Construction management relative to storage and maintenance of permanent plant equipment.
-1,6.3 ' Pro ect Construction Management j
A Manager of Construction is assigned to each nuclear plant project involving construction or construction management assignment, and is responsible for the project field construction performance. The Manager of Construction is responsible for assuring that construction activities are performed in accordance with the design requirements as established by project engineering 4
and other applicable requirements.
The project construction management organization is shown in Figure 11.
The Constructor / Contractor (s) are assigned first-level responsibility for the control of the quality of their work. Their performance is coordinated and monitored by the Bechtel field organization. The Bechtel Quality Assurance organization performs documented audits and surveillances and has the capability to perform surveillance inspection.
Revision 9 Page 4 of 12
In cases where the Constructor / Contractor (s) are responsible for quality verification inspection or other quality assurance functions, the contract documents incorporate the requirements for the Constructor / Contractor (s) i quality assurance program.
Constructor / Contractor (s) quality assurance and quality control personnel are required to have the appropriate authority, organizational freedom, and independence within their own organization.
Constructor / Contractor (s) program requirements are specified by incorporation of the requirements of Reg. Guide 1.28 (6/7/72) or the ASME Boiler and Pressure Vessel Code,Section III, as appropriate.
In the event that the Constructor / Contractor (s) is unable to provide an acceptable program, Bechtel may assume quality verification inspection responsibilities or these may be contracted to another organization.
1.6.4 Project Procurement The Project Procurement Manager receives technical and administration direction from the Manager, Division Procurement, LAPD through the Manager, Division Procurement, Houston and project direction from the designee Project Manager.
Section 3 - Design Control Page 30 - first paragraph:
In the case of proposed changes to the original design, initiated at the construction site, the design changes shall be reviewed, accepted and documented by Bechtel Project Engineering. Acceptance of design changes by Bechtel Project Engineering is required prior to implementation. For design changes proposed by suppliers, acceptance of the design change by Project Engineering is required prior to shipment of the item to the jobsite.
- third paragraph:
Certain design work may be performed by Bechtel Site Engineering providing it is in compliance with the design control features utilized by Bechtel Project Engineering in the design office.
Certain detailing work may be perfomed by selected contractors; however, the nature, scope and parameters will be identified in design disclosure documents for each contractor with checking of field sketches required by an individual other than the detailer.
Revision 9 Page 5 of 12
- fourth paragraph:
Suppliers are not allowed to changa Bechtel design requirements or Bechtel reviewed supplier design documents without obtaining approval by i
- Bechtel Project Engineering. Construction site changes to engineering design are documented by means of change notices or change requests which require authorization by Project Engineering. Significant or unique changes are authorized individually; Project Engineering may give written authorization in the fonn of specifications or other instructions to field organizations to make routine changes. Field organizations have the authority to approve changes to design details in cases where the original design details were prepared by that field h
organization.
i Section 4 - Procurement Document Control Page 32 - paragraph 3, item 1) chrough item 8) Page 33:
Replace the paragraph t.eginning "...The following describes the sequence of steps..."
with the following paragraph:
Appropriate project procedures provide details to accomplish the -
administrative actions in processing procurement documents in the design office and at the jobsite.
Section 5 - Instructions, Procedures, and Drawings Page 34 - sixth' paragraph:
Field organizations prepare other procedures when engineering documents require amplification to perfonn various discipline activities associated with fabrication, cleaning, erection, installation, test, repair, modification, etc., of items.
Section 6 - Document Control Page 35 - sixth paragraph:
Changes made to approved design documents by Project Engineering or l-proposed by field organizations are reviewed and approved by Project l
Engineering in accordance with established procedures which provide that changes are reviewed in the same manner as the original issue.
Section 7 - Control of Purchased Material, Equipment & Services
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Page 37 item nunber 2):
2)
Detennination by Engineering and Quality Assurance that the supplier or i
Constructor / Contractor (s) quality program is capable of meeting the specified requirements. This may be based on evaluations by Procurement Supplier Quality for manufacturing suppliers or Quality Assurance for jobsite Constructor / Contractor (s), and field procurements, l-Revision 9 Page 6 of 12
Section 14 - Inspection, Test, and Operating Status Page 50 - fourth paragraph:
Project Engineering and supervisory personnel are authorized to apply and remove identifying tags, markings, and labels on equipment in accordance with approved procedures. Quality Control personnel are the only ones authorized to direct application and removal of inspection status indicators. Bechtel, in cooperation with the plant owners' operating personnel, establishes a tagging procedure which delineates those authorized for applying and removing tags during preoperational testing phases.
Section 15 - Nonconforming Items Page 51 - paragraph 2 items 2, 3 and 5):
- paragraph 2 item 4 - Delete 2)
Determine interim disposition by field organizations.
3)
Have Project Engineering approve dispositions.
5)
Provide conditional release of nonconforming items upon approval of Quality Assurance.
- last paragraph:
The authority for disposition of nonconforming items follows the rules for approval of design changes described in Section 3 of this report.
Quality Assurance reviews dispositions to determine that they are fully responsive to the conditions described in the nonconfomance report.
Quality Control is responsible for verification of rework and repair l-dispositions, applying inspection processes at least equivalent to that applied to the original work.
" Repair" or "use as is" dispositions on nonconformances to procurement requirements at a supplier's plant must be accepted by Project Engineering.
Page 52 - second paragraph:
Nonconforming items discovered at final inspection which cannot be corrected by rework or completion of originally prescribed processing are required to be identified, tagged, and/or segregated.
Discrepancies in work not yet submitted for final inspection which can be corrected by rework or completion of work processes are not considered to be nonconfomances. For construction work perfomed by Bechtel, no further work can proceed on the nonconfoming item until an approved disposition is implemented, unless a conditional release is approved by Quality Assurance. Suppliers, and Constructor / Contractor (s), as required by procurement documents, apply similar procedures involving their quality assurance functions. Bechtel Procurement Supplier Quality Representatives are instructed to withhold release for shipment until all nonconfomances have been resolved or an interim disposition is approved by Project Engineering.
Revision 9 Page 7 of 12 J
t' Page 55 - first paragraph:
A comprehensive program of audits is conducted by STPEGS covering the various project activities to assure applicable portions of the Quality Assurance Program are adequately and effectively implemented.
' - second paragraph, first-sentence:
The STPEGS audit program includes both monitoring by Quality Assurance Personnel of daily activities conducted at the construction site or home '
office as well as formal periodic team audits perfomed by individuals independent of project activites being audited.
The following is a modification of Appendix "A" of the topical which describes Bechtel's position on Regulatory Guide and ANSI standards:
o Reg. Guide 1.58 Rev. O, 8/73 As modified by positions C.5, ANSI N45.2.6,1973 C.6, C.7, C.8, and C.10 of Rev. 1.
As an alternate, I
compliance with ANSI N45.2.6-l 1978 and R. G.1.58 (Rev.1, l9 9/80) in its entirety is I
acceptable.
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ANSI ' N45.2.5,1974 Exception 2. & 3. (listed below) o.
Reg. Guide 1.116, Rev. 0-R, 6/76 ANSI N45.2.8,1975 Exception 4. (11sted below) o Reg. Guide 1.144 Rev.1, 9/80 ANSI N45.2.12,1977 Exception 1. (listed below) o Reg. Guide 1.146 Rev. O, 8/80 ANSI N45.2.23,1978 Full Compliance - No exceptions Exceptions 1.
ANSI N45.2.12-1977, Section 4.5.1 states, "The audited organization shall provide a follow-up report stating the corrective action taken and the
- date corrective action was completed." This implies.that the audited organization must provide the auditing organization with written notification detailing what corrective action was taken and when the
' corrective action was completed.
In actual practice, the audited organization will provide the auditing organization with documented corrective action including the date when the i
i corrective actir4 will be completed.~ The auditing organization will y
evaluate the corrective action response to determine if corrective action verification is necessary.
If verification is necessary, the corrective action verification will be perfomed after the scheduled completion date and' the result of the verification will be documented.
~ 2.
ANSI N45.2.12-1977, Section 1.3 states, "In no way shall the performance-of audits by an organization diminish the responsibility of the audited organization or contractor for audit of his designated portion of the
. quality assurance program or the quality of his product or services." For Revision 9 Page 8 of 12 b'
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the South Texas Project all quality related activities implementsd for the
' South Texas Project are audited annually at a minimum, or at least once
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i within the life of the activity, whichever is shorter. These audits are perfomed by either HL&P, BEC, or ESI Quality Assurance personnel.
3.
ANSI N45.2.5-1974, Sectioa 4.8, states " Pumped concrete must be sampled
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from the pump line discharge."
In lieu of this statement, in-process
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stmngth samples of pumped concrete are taken at the delivery point.
Correlation tests of air ';ontent, slump, and temperature are performed to j
verify these plastic properties of the concrete at the placement point in 1
accordance with the follcwing frequency requirements:
a.
A minimum of 2 correlation tests are performed for each pumped
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placement exceeding 200 cu. yds.
i b.
Otherwise, a minimum of 2 correlation tests per week are performed i
l when any individual pumped placement during a week requires delivery of more than one truckload of concrete.
L c.
During a week when a pumped placement exceeding 200 cu. yds. is make, the correlation tests perfomed on that placement will satisfy the weekly requirement for perfoming two correlation tests as specified in Item b above.
I When any of the specified limits and/or tolerances pertaining to air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery paint and placement point will be accomplished for each 100 cu. yds. of concrete placed as long as limits i
and tolerances are exceeded.
If two consecutive tests are out of i
tolerance, corrective action will be implemented to adjust the limits for the concrete entering the pump intake so that no concrete from the subsequent trucks will enter the pump intake as long as the tolerances are j
exceeded.
" Correlation Tests," " Delivery Point," and " Placement Point" are as defined in ANSI N45.2.5-1978, Section 1.4.
4.
ANSI N45.2.5-1974, samples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, *3 sued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).
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5.
ANSI N45.2.8-1975, Section 4.6, Care of Items. HL&P retains the authority and is the " Responsible Organization" for temporary usage of equipment or facilities unless specific (i.e. on a case by case basis) or general authority is granted in writing to the Construction Manager's organization.
-Appendix A second paragraph
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Page A-4 item #2
" Access to storage areas for Levels A, B, and C will be controlled by-the individual (s) responsible for storage. - While the above areas will be posted to limit access l other positive controls (other than that for the overall site area or guards may not be provided. Level D areas will be posted with the storage level designation only."
Figure 9 This Figure, indicating STP actual organization, replaces Figure 9 of BQ-TOP-1, Rev. 3A, PROJECT TEAM ORGANIZATION (TYPICAL).
Revision 9 Page 9 of 12
Attachment' A-is a modified Table I to the topical which describes Bechtel's Quality Program Documents.
t Revision 9 page 10 of 12 i
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,1 ST-HL-AE-1201 File #2 G9.11/Q39 s
u PART C EBASCO ENERGY CORPORATION QUALITY ASSURANCE PROGRAM DESCRIPTION q
.-SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
' QUALITY ASSURANCE DURING DESIGN AND' CONSTRUCTION
~ REVISION 10*
'DATE March 1, 1985
);
- Revision 10 of the STP QAPD, Part C did not change from Revision 9, dated December 28, 1984. The revision number was-changed to be consistent with Parts A & B.
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