ML20125D811
| ML20125D811 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/13/1984 |
| From: | Trubatch S NRC |
| To: | NRC |
| Shared Package | |
| ML20125D664 | List: |
| References | |
| FOIA-84-740 NUDOCS 8506120478 | |
| Download: ML20125D811 (5) | |
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. , -*a,J'"'cn,1 UNITED STATES
[ . ," u j NUCLEAR REGULATORY COMMISSION ,
E WASHINGTON. D. C. 20553 June 13, 1984 MEMORANDUM FOR: File 7 FROM: Sheldon L. Trubatch i-
SUBJECT:
1 REMAINING ACTIONS FOR FULL-POWER This presents, an overview of-remaining Commission. actions related to a full-power operating license for Diablo Canyo'n and relates those. actions.to the division of institutional responsibilities within the NRC. A review of some important earlier licensing milestones in this proceeding provides the necessary context for understanding the current licensing - -
situation. .
. 1. Full-Power Licensing Board Decision -
-:r PG&E applied for an operating license in 1973. .A Licensing Board held hearings on that application between 1976 and,
~1979. In 1978, the-Licensing Board issued the first-of-four decisions deciding in PG&E's favor various allegations regarding.the_ safety and environmental impacts of plant operation. The Appeal Board subsequently affirmed three of those decisions. . The fourth, LBP-82-70, on emergency
. planning and two safety issues, is currently pending before the Appeal Board. The issues in that decision >did-not have to'be resolved finally before the issuance of a: low-power licensee. But under Ce=mi ssion practice t :before a 3. . .. ::
full-power license can-be issued.to.PG&Eg;the: Commission itself must conclude affirmatively.an-immediater .d _:- .2 affectiveness review of this: fourth Licensing.-Board:: -
decision. -
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- 2. Low-Power Adjudication .. .
In July of 1980, before the full-power licensing proceeding was conclude"d, PG&E applied for a low-power license. The Licensing Board held separate: hearings on:that-request, and granted it.in 1981. .Thereafter,.the Commission.made;the low-power license immediately;effectiver+_However, because of subsequent events,.the. Commission's. involvement with the -
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2 low-power license was unusually extensive. No further Commission action is pending on the low-power license.
- 3. IDVP The Dir tor of Nuclear Reactor Regulation issued the licent s September 22, 1981. The subsequent discovery of a sig . ant breakdown in quality assurance at Diablo Canyon-led the Commission to suspend the license by immedi-ately effective order of Novenber 19, 1981. The suspension was to be effective pending the satisfactory completion of an Independent Design Verification Program (IDVP). Because the reinstatement of the low-power license has been treated as an enforcement matter, review of the IDVP has been conducted by the staff and the Commission in a non-adjudi-catory manner.
Although the IDVP was instituted for the purpose of rein-stating the law-power license, the IDVP has uncovered matters which are important to only full-power operation.
. Thus, the Commission reinstated the low-power license with these matters still open, but will not. authorize full-power operation until those matters have been addressed. Essen-
- tially, the Commission is treating IDVP issues related to full-power as it would treat any uncontested issues related
- to full-power. The staff expects to prepare safety eval-uati.n o reports (SEF.) on the resQlutions of these issues.
- For low-power reinstatement, the Commission's decision relied in part on such SERs.
- 4. Allegations i
l As the IDVP drew to a close and the Commission moved towards a decision on reinstating PG&E's low-power license, several l hundred allegations of design and construction deficiencies l were made to the NRC staff. Not all of these allegations l have been resolved, and the staff has yet to determine whether any of these allegations require resolution prior to full-power operation - Also, the Commission has not adopted
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criteria for determining: that all allegation's have been .
T addressed adequately before authorizing full-power. opera-tion. -
, 5. Adjudicatory Items The IDVP and allegations of. violations of NRC_ regulations have provided the. bases for several adjudicatory issues.
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. which were raised after the record closed for the full-power p hearing.
- a. ALAB-756 This is an Appeal Board decision denying intervenors' motion to reopen the record on alleged deficiencies in construction
- quality issuance (CQA). Petitions for review of this ',
decision are still pending before the Commission. The I
Commission has not decided whether to defer a full-power decision until these petitions have been resolved. The
- Commission could use its immediate effectiveness review of j the Licensing. Board's full-power decision to include a determination on whether a full-power license should be delayed pending final action on ALAB-756.
! b. Motion to Reopen on COA After ALAB-756 was issued, intervenors again moved the Appeal Board to cpen the record on QA and on management
- . competence and character. These motions rely on many of the issues raised in the allegations pending before the staff.
The Appeal Board has not yet acted on those motions. Here c.again, the Commission could unie~its immediate effectiveness' review for a full-power license to include a decision on how the pendency of these motions should be factored into a full-power decision. . ,
- c. ALAB-763 ,
- ' This is an Appeal Board decision finding no merit to l
intervenors' challenges to the adequacy of design quality
- assurance (DQA) at Diablo Canyon. Petitions for review of
!. this Appeal' Board decision- are still pending before the Commission. As with ALAB-756, the. Commission could use its immediate effectiveness review of the Licensing Board's full-power decision to include a determination on whether a
[ full-power license should be delayed pending final action on l l ALAB-763. , ,. ,
- d. Motion to Reopen on DQA
- After ALAB-763 was issued, intervenors again moved the.
Appeal Board-to reopen the record on DQA issues. This
- motion relies on many'of the issues raised in the allegations before the staff. The Appeal Board has not yet i acted on these pending motions. As with the pending motions e
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- 4 to reopen on CQA, the Commission could use its immediate effectiveness review of a full-power license to include a decision on how the pendency of these. motions should be factored into a full-power decision.
- e. Effects of Earthquakes on Emergency Planning The Commission asked the parties to brief issues on whether to reconsider this issue. Because this issue mainly affects offsite emergency planning, the Commission determined that the issue did not.have to be considered when it determined to issue a low-power license for Diablo Canyon. The proceeding on this issue may not be concluded soon.
Accordingly, the Commission could use its immediate effectiveness review of a full-power license to include a decision.on how the pendency of this-issue should be factored into la full-power decision.
- 6. 2.206 Petitions
. There are four 2.206-petitions pending before the staff.
These involve many of the same issues raised by the alle-gations. After the staff responds to those petitions,'the Commission will.have to review any denials. The Commission could use its immediate effectiveness review'of a full-power
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license to include a determination of how the pendency of the 2.206 petitions should affect a full-power decision.
- 7. 'OIA Investigation This investigation is an off-shoot of the 2.206 petitions.
Those petitions contained allegations that-the NRC staff
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made deceptive or material false statements to the Commis-sion during various meetings and in various documents.
Because these allegations go to the Commission's confidence in the staff's assessment of Diablo Canyon's readiness'for full-power licensing, the Commission may want to make at least a preliminary decision on the substantiality of these claims. The Commission could use its immediat.e effectiveness review of a full-power'* license to include a determination on how the pendency of this investigation should affect a full-power decision. i
- 8. OI Investigations These investigations are off-shoots of the allegations presented to the staff. Currently, the staff believes that e
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. none of'these allegations present safety issues requiring resolution prior to the issuance of a full-power license.
The Commission may want to review that assessment prior to deciding on.whether to authorize full-power operation. The
, Commission'could use its immediate effectiveness review of a full-power license to include a determination on how the
. pendency of these investigations should affect a full-power decision.
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fo UNITED STATES ,
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NUCLEAR REGULATORY COMMISSION g$
3 WASHINGTON, D.C. 20555
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OFFICE OF THE ' June 14, 1984 COMMISS40NER The Honorable Morris Udall, Chairman
.3ubconunitee on Energy and the Environment
~ Committee on Interior and Insular Affairs
.- United States House of Representatives Washington,.D.C. 20515
Dear Mo:
'TT regret I will not be able to attend the Committee's
~~hriefing on Diablo Canyon. I would like to submit for the
.: record some brief comments on NRC's- disregard, -in approving
.the plant's operating crew, of the experience requirements
..!in the regulations on operator qualification. None of the
. Diablo Canyon operators have had previous experience
{:' operating a comparable plant.
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- M.say " disregard" because,'after being told, by the General
.- .ECounsel that staff practice, in allowing completely
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3, inexperienced crews to qualify.on simulators, was at odds
,srith the plain meaning of the regulations, the Commission
.did not even bother to grant exemptions. It. simply went
..,xight on and issued instructions that the embarrassing
. regulation was to.be. expunged.an.quickly~as possible. .I shave attached my separate views on that action.
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iUnfortunately, disregard of regulations that stand in the pay of licensing ~ plants, is becoming a habit, with the
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- a Sincerely, 2 ~~
l Victor Gilinsky l "t. . . .
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Attachment:
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.As stated
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! .. , $ct ' Rep. Manuel Lujan' Y_ ' O g , .x y
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5/3/84 e
SEPARATE VIEWS OF COMMISSIONER GILINSKY PROPOSED AMENDMENTS TO 10 CFR PAPS 55 i
The Commissiion is being more than a ,little 6.isingenuous in duplying that its. principal concern is."to update its operator licensing regulations and related regulatory guides 1
to clarify the increasingly important role which simulators play *in the tr=4ning and testing of reactor operators."
.Moreover, it is preposterous for the Commission to clain I
that the Congress and the public have long been aware that the . staff's licensing practice - in ignoring-experience l @ements for operators of new plants - is at odds with the regulations. The fact of.the matter is-that the Commission itself did not know this until a few. weeks ago...
1 2ven the. senior staff _was unawarar of it. : _.--- _ . _ .
( Tnfortunately,. in its scramble to patch up its-operator
! iicensing system, the Commission is throwing the baby out l
with'.the. bath water.c The. healthy affact of'the.axisting rule is to require that. the. operating _ crew that brings a new
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I reac't or into operation s.:
have. e certa.irt amounMo'f- actual
.(... . . ,
1 The regulations provide that the " Commission.may
. .amnsd i i ter a simulated operating test to .an applicant for a
,- license to operate.a-reactor-prior to its initial . -
criticality if ...", among other things, the "... applicant has had extensive actual operating experience:at a-comparable reactor." 10 CFR 55. 25 (b) .
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, c operating exparienca. This is especially important for tha shift supervisors. Once the plant has been successfully operated, and procedures verified, the rule's experience requirement no longer applies, and additional .new operators l
can be qualified on' simulators. Had that regulation been ,
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! observed, the Commission would not now be in the awkward
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position of having to decide on the licensing of plants -
l such as Diablo Canyon, Grand Gulf, and Shorehntn - none of
! whose operators have any actual experience operarting comparable reactors at full power. I do not beILieve any I
l other country with a major nuclear program would have I
~ a.11 owed this situation to arise.
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- , Taced with possible delays in reactor startups iLf it
. complied with the regulation, the Comnission is I
rationalizing 'its disregard for the operator experience requirement on the grounds that simulator trainimg (as i.
- . little as 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />) is so effective that it is acrlonger i ,
essential for a new cres to have actual operating
-experience. This is simply wrong. While they are an
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extremely valuable training device, simulators do not povide the equivalent of actual opesating experience. And while simulators'have become more sophisticated over the .
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. years, so have plants; they. are now more complex and more demanding. (In the case of the above-named plants, the operators were not even trained and qualified on a simulator built to inodal the' plant they would operate.) aforeover, d
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reactor simulators can' simulate only a f action of the
. nuclear plant operations that need to be performed. Even normal startups and shutdowns can only be partially
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simulated. It is worth pointing.out that aircraft simulators 'are far more faithful than reactor simulators but
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'that many hours of actual flight time are still needed to qualify for a pilot's license. No one would dream of allowing an aircraft to take off with a new crew that had
. caly had simulator training.
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Egt.needs to be understood also that power plant simulators
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y-are designed primarily to provide tra4n4ng for the reactor
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,. " i cy'erator5 whose job is. to manipulate controls. The shift p
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- supervisor, by contrast, is responsible for managing the
~I r entire plant, not.just the control room. Managing an antire
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531 ant's startup, operation, and shutdown cannot be learned
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~ 2ry practicing only on a simulator.
, Unlike the reactor
',cperator, the . shift supervisor also has the authority to yhange accident' recovery procedures or to disable safety
~ Nguipment if he judges this necessary. The experience needed to make these important judgements is not developed -
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~ % 'e' simulator.
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Nor do simulators provide airperience on
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'....,,,performin.
g cri.,t.ical siafety reviews of maintenance and
, g., .
,;;;.testing:-
to assure that operating limits are adhered to and
,- transients are avoided. Improper maintenance and testing
- are the most frequent caus'e of plant accidents. Thus, in waiving the experience requirement for the entire operating
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crek the CoM ssion has overlooked the specia.2. i=portance of experience for shift supervisors.
Contrary to whah the Commission claims, the sense of the rule has largely been complied with until the last few years in that , as long as a fair number of operators at a plant had actua.1 operating experience, the purpose c)f the rule was satisfied. It is only recently that the Com=f.ssion has ,
allowed completely green crews to start up plaints without requiring adequate compensato..y measures, in v-iolation not only of the literal wording of the regulation but a.lso of good safety practices.
Instead of expunging the requirement for expe=ience from its rules in an overeager attempt to accommodate the small -
mumber of power reactors schedule'd for licensi!.ng in the near future, the Commission should have taken an approach that would have ensured that, future reactors start mp with an adequate number cf expeEienced operators. For power reactors. which are about to go into operation,. the sensible and responsible course is not to grant a blanicet exemption from the regulation {s requirement for' exper55Ece for the
' entire operating crew, but to ensure that there is at least
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one supervisor on each shift who has had actual operating experience.
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In. sum, the existing rule should .not be cihanged without ensuring- that adequate provision is made for operator experience on every shift.
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E TESTIMONY OF HAROLD R. DBff0N, DIRECTOR .
OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COPMISSION BEPORE THE SUBC0FMITTEE ON ENERGY AND THE EhVIRONENT __.
COPMITTE ON INTERIOR AND INSULAR AFFAIRS -
UNITED STATES HOUSE OF REPPESENTATIVES ..
ON DIABLO CANYON LICENSING CONCERNS JUNE 14, 1984 .
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-CHAIRMAN PALLADINO HAS ASKED ME TO REPORT BRIEFLY ON WHAT STEPS REMAIN BEFORE A DECISION ON A FULL POWER OPERATION COULD BE MADE WITH RESPECT TO THE DIABLO CANYON NUCLEAR POWER STATION' 4
REMAINING ACTIVITIES INCLUDE THE-TECHNICAL ISSUES RELATING TO PIPINhANDSUPPORTS, PROGRAM'MATI'CQUALITYCONTROL' CONCERNS, SEISMIC REEVALUATION PROGRAM, A'FEW OUTSTANDING ISSUES.FROM THE
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INDEPENDENT DESIGN VERIFICATI0'N PROGRAM (IDVP), AND' FOLLOW-UP TO A NUMBER OF 0THER MATTERS INCL'UDIN'G' PETITIONS AND ALLEGATI'ONS',
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PG8E HAS BEIN REQUESTED TO PROVIDE ADDITIONAL INFORMATI0N ON A NUMBER OF THESE MATTERS.
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4 THE STAFF, THEREFORE, HAS NOT REACHED RESOLUTION ON THESE ISSUES l AT THIS TI'ME- . LET ME AS-SU'RE YOU THAT PRIOR T0! APPROVAL OF ANY r
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SUBSEQUENT LICENSING'ACTIVlTIES,I~ THE' STAFF WILL THOROUGHLY
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EVALUATE ALL' APPROPRIATE I NATT'ERS.
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I WOULD NOW LIKE TO SUMMARIZE THE MORE PRINCIPAL OF THESE ISSUES.
THE CONCERNS, RAISED BY MR. YIN, FALL INTO TWO BROAD CATEGORIES:
(I) PROGRAMMATIC DESIGN CONTROL'AND (2) TECHNICAL DESIGN ISSUES ,
IN THE AREA 0F PIPING SUPPORTS. THE REVIEW GROUP AND THE ACRS HAVE BOTH EVALUATED THESE CONCERNS. THAT EVALUATION INCLUDED MEETINGS WITH THE LICENSEE'TO DISCUSS THE CONCERNS AND TO RECEIVE 1
THEIR EVALUATION AND COMMENTS.
! IN ADDITION, THE REVIEW. GROUP DISCUSSED CERTAIN MATTERS WITH THE IDVP PERSONNEL AND CONDUCTED.WALKDOWNS OF THE DIABLO CANYON PLANT WITH REGARD TO SOME OF THE SPECIFIC TECHNICAL CONCERNS, SUCH AS SNUBBER AND RESTRAINT LOCAT, ION AND REDUNDANCY. WHILE THEY CONCLUDED _THAT NONE OF THESE. CONCERNS WERE OF SUCH SAFETY SIGNIFICANCE AS TO FURTHER DELAY THE REINSTATEMENT OF THE LOW-POWERLICENSE,THEYALSO~CONCLUDEDTHdT..CEBTAINACTIONSBY.THE LICE'NSEE AND~BY THE NRC SHOOLD'BE COMPLETED PRIOR TO-A DECISION REGARDING ISSUANCE OF A FULL-POWER LICENSE ~. THE ACRS CONCURRED - -
WITH THIS CONCLUSION...[WHAT ACTIONS ARE THEY?)
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THE COMMISSION REINSTATED THE LOW-POWER LICENSE AT THE MEETING 14ITH THE REINSTATEMENT BECOMING EFFECTIVE ON APRIL 19. THE ACTIONS PROPOSED BY THE REVIEW GROUP WERE ISSUED ON APRIL 18 AS SEVEN SPECIFIC LICENSE CONDITIONS IN AN ORDER MODIFYING THE DIABLO CANYON UNIT 1 LICENSE THAT MUST BE COMPLETED PRIOR TO FULL-POWER.
THE STAFF HAS EXPANDED THIS REVIEW GROUP TO SEVERAL TASK TEAMS FOR THE R5 VIEW, EVALUATION, AUDIT AND INSPECTION OF THE LICENSEE'S EFFORTS. THE TASK TEAMS CONSIST OF 15 SENIOR PROFESSIONAL ENGINEERS INCLUDING BOTH NRC STAFF AND EXPERT CONSULTANTS. MR.
YIN IS PARTICIPATING IN MANY OF THE TEAM ACTIVITIES. THE STAFF WILL ISSUE THE RESULTS OF ITS EFFORTS AS A SAFETY EVALUATION WHICH WILL SERVE AS 0,NE OF THE BASES FOR OUR FULL-POWER DECISION. WE EXPECT THAT THIS EFFORT WILL BE COMPLETED WITHIN ABOUT A. MONTH.
ANOTHER MATTER THAT IS RECEIVI.NG CONSIDERABLE ATTENTION IS GEOLOGICAL INFORMATION-THAT:RECENTLY BECAME~AVAILABLE. IN MARCH
. 1984, THE LICENSEE PROVIDED US WITH A PREPRINT OF A SCIENTIFIC a
PAPER REGARDING NEW INFORMATION AND INTERPRETATION OF DATA LREGARDING THE HOSGRI FAULT NEAR THE DIABLO CANYON SITE. WE HAVE REQUESTED THE ACRS TO EVALUATE THE INFORMATION AND ADVISE US OF -
ITS IMPACT REGARDING-A FULL-POWER DECISION. THE FULL ACRS COMMITTEE AND ITS CONSULTANTS ARE MEETING TODAY WITH THE LICENSEE, 1
STAFF AND DR. CROUCH, THE PRINCIPAL AUTHOR OF THE PAPER.
IN ADDITION, THE STAFF IS CURRENTLY FORMULATING SPECIFIC DETAILS' I i FOR A LONGER TERM REVALIDATION PROGRAM FOR THE SEISMIC DESIGN BASES OF THE DIABLO CANYON PLANT. THE NEED FOR SUCH PROGRAM WAS J .
INITIALLY DISCUSSED BY THE.ACRS IN 1978 AND IS NOW A CONDITION IN J .
l THE LOW-POWER LICENSE. THE, PROGRAM MUST BE ESTABLISHED BY JANUARY 0F-N5XT YEAR AND BE COMPLETED'BY 1988. -
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THE LAST SUBJECT I WANT TO MENTION IS THE MATTER OF ALLEGATIONS.
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.-.THE STAFF HAS DEVOTED EXTEN51VE EFFORTS OVER THE PAST MONTHS TO ,
' EVALUATE ALLEGATIONS. SINCE EARLY NOVEMBER 1983, VE HAVE EXPENDED 4
IN EXCESS OF 18,000 STAFF HOURS. OUR FUNDAMENTAL APPROACH IS TO
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j- FOCUS,0N TWO BASIC QUESTIONS: ,
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-* FIRST, DOES THE ALLEGATI0!l PRESE. A TECHNICAL PROBLEM
, WHICH COULD AFFECT THE SAFETY OF HE PLANT?.
'SECOND, DOES THE ALLEGATION REVE1.L A'iY SIGNIFICANT DEFECTS
't IN THE LICENSEE'S OR HIS CONTRACTC95 MANAGEMENT ON QUALITY SYSTEMS?
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! THE STAFF EVALUATED ALMOST ALL OF THE :I".ST APPROXIMATELY 200 ALLEGATIONS TO ADDRESS THESE QUESTIONE. I'.3RE RECENTLY, SEVERAL 1
i HUNDRED ADDITIONAL ALLEGATIONS HAVE- BEEl. RECEIVED FROM A VARIETY
- OF SOURCES. AS THIS PICTURE EVOLVED T.-!E STAFF DEVELOPED SCREENING CRITERI A TO DETERMINE WHICH ALLEGATI0hs MUST BE COMPLETELY ,
1 RESOLVED FRIOR TO EITHER LOW-POWER OR FL*LL-POWER OPERATION. AS A
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THESE CRITERIA ARE CONTAINED IN OUR SA=ETY EVALUATION REPORT
- SUPPLEMENT 22.
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USING THESE CRITERIA THE STAFF HAS IDENTIFIED ALLEGATIONS IU
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SEVERAL AREAS THAT REMAIN TO BE RESOLVED PRIOR TO FULL-POWER. ONE OF THESE AREAS IS' PIPING AND SUPPORTS WHICH IS ALSO INCLUDED IN -
THE STAFF REVIEW TEAM EFFORT I DISCUSSED EARLIER.
THE STAFF IS CONTINUING ITS ALLEGATION EVALUATION EFFORT AND WILL REPORT TO US, PRIOR TO A FULL-POWER DECISION ON DI ABLO CANYON, IN CLOSING, TWO OTHER ACTIONS SHOULD BE NOTED. THE FIRST IS THE DECISION BY THE APPEAL BOARD IN' MARCH REGARDING MATTERS OF DESIGN QUALITY ASSURANCE. THAT DECISION WAS FAVORABLE TO THE LICENSEE.
THE SECOND ITEM IS A NOTICE 0F VIOLATION AND PROPOSED IMPOSITION OF A CIVIL PENALTY FOR $50,000 RESULTING FROM THE FACILITY STAFF NOT RECOGNIZING FOR A PERIOD IN EXCESS OF 15 HOURS THE INOPERABLE STATUS OF THE EMERGENCY CORE', COOLING SYSTEM.
MR." CHAIRMAN, THIS CONCLUDES MY REMARKS.
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- .THE'hTTENDEES AT THE JUNE 14 UDALL HEARING ARE:
IsAYIN --
t HAROLD DENTON JACK MARTIN DICK VOLLMER JIM TAYLOR t
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TESTIP0NY OF NUNZIO J. PALLADING CHAIRMAN U,'S, NUCLEAR REGULATORY C0FTilSSION BEFORE THE SUBC0FiilTTEE ON EERGY AND THE ENVIRONENT C0ffilTTEE ON INTERIOR AND INS.ULAR AFFAIRS UNITED STATES HOUSE OF REPRESENTATIVES ON .
DIABLO CANYON LICENSING CONCERNS
. JUNE 14,1984 o
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MR. CHAIRMAN, WE ARE PLEASED TO BE HERE TODAY TO ADDRESS THE MATTERS STATED IN YOUR LETTER OF MAY 23 REGARDING THE DIABLO CANYON NUCL-EAR POWER PLANT AND TO RESPOND TO YOUR QUESTIONS. I AM ACCOMPANIED BY MY FELLOW COMMISSIONERS, AS YOU REQUESTED, WE ALSO HAVE PRESENT CUR PRINCIPAL STAFF INVOLVED IN THE SAFETY REVIEW AND LICENSING DECISIONS ON THE DI ABLO CANYON PLANT, I WILL BRIEFLY SUMMARIZE EVENTS AND ACTIONS SINCE WE LAST MET WITH YOU ON THIS TOPIC IN JANUARY OF THIS YEAR AND THEN ASK HAROLD DENTON, AS DIRECTOR OF THE OFFICE OF NUCLEAR REACTOR REGULATION, TO COMMENT MORE FULLY.
AS YOU WILL RECALL ON NOVEMBER 8, 1983, THE COMMISSION REINSTATED THE PACIFIC GAS AND ELECTRIC'S AUTHORITY TO LOAD FUEL AND CONDUCT COLD SYSTEM TESTING. ON JANUARY 25 0F THIS YEAR, WE AUTHORIZED HOT SYSTEM TESTING. THIS WAS FOLLOWED BY COMMISSION e ,
2 MEETINGS ON MARCH 26 AND 27 TO HEAR FROM THE STAFF ON THE STATUS OF DIABLO CANYON UNIT 1 AND, IN PARTICULAR, TO DECIDE WHETHER TO REINSTATE THE LOW-POWER LICENSE TO ALLOW CRITICALITY AND TESTING AT LEVELS UP TO 5 PERCENT OF RATED POWER.
AT THAT TIME, A MEMBER OF THE NRC STAFF, MR. ISA YIN, INFORMED THE COMMISSION THAT BASED ON HIS FINDINGS FROM HIS INSPECTION ACTIVITIES, HE COULD NOT RECOMMEND TO US THAT THE LOW POWER LICENSE BE REINSTATED, AFTER A THOROUGH EVALUATION OF THESE CONCERNS BY A SPECIALLY ASSICNED REVIEW GROUP AND THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS, THE COMMISSION REINSTATED THE LOW-POWER LICENSE ON APRIL 13, 1984.
THE .DI ABLO CANYON REACTOR SUBSEQUENTLY WENT CRITICAL ON APRIL 29, LOW-POWER TESTING WAS SUCCESSFULLY COMPLETED ON MAY 23.
THAT ESSENTIALLY SUMMARIZES EVENTS UNTIL THE RECEIPT OF YOUR MAY 23 LETTER OF INVITATION. A NUMBER OF ISSUES REMAIN TO BE RESOLVED BEFORE ANY COMt'.'SSION DECISION ON WHETHER TO PERMIT 8 x
FULL POWER OPERATION OF THE DIABLO CANYON PLANT. I HAVE ASKED MR. DENTON TO REPORT BRIEFLY ON THE STATUS OF THESE ISSUES FOR THE Susc0MMITTEE. FOLLOWING HIS PRESENTATION, WE WOULD BE HAPPY TO ANSWER QUESTIONS.
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P TESTIMONY 0F NUNZIO J. PALLADINO CHAIRMAN i U.S. NUCLEAR REGULATORY COMMISSION
. BEFORE THE i
SUBCOMMITTEE ON ENERGY AND THE ENVIRONMENT COMMITTEE ON INTERIOR AND INSULAR AFFAIRS
- UNITED STATES HOUSE OF REPRESENTATIVES.
ON DIABLO CANYON LICENSING CONCERNS .
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JdNE Id, .19814 . . .
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q f'R, CHAIRMAN, MEMBERS OF THE SUBCOMMITTEE, GENTLEMEN FROM THE STATE OF CALIFORNIA. WE ARE HAPPY TO BE HERE TODAY TO ADDRESS THE MATTERS STATED IN THE CHAIRMAN'S LETTER OF MAY 23 REGARDING 1
THE DIABLO CANYON NUCLEAR POWER PLANT AND TO RESPOND TO YOUR QUESTIONS. I AM ACCOMPANIED BY MY FELLOW COMMISSIONERS. AS YOU REQUESTED, WE ALSO HAVE PRESENT OUR PRINCIPAL STAFF. INVOLVED
- IN THE SAFETY REVIEW AND LICENSING DECISIONS OF THE PLANT, ;
INCLUDING MR. ISA YIN. BEFORE RESPONDING TO YOUR LETTER I WILL j
d BRIEFLY SUMMARIZE EVENTS AND ACTIONS SINCE WE LAST MET-WITH'YOU j IN JANUARY OF THIS. YEAR.
1 AS YOU WILL RECALL ON NOVEMBER R, 1983 WE REINSTATED-THE LICENSEE'S
- 4 j AUTHORITY TO LOAD FUEL AND CONDUCT COLD SYSTEM TESTING.- ON -
JANUARY 25 0F THIS YEAR WE AUTHORIZED HOT SYSTEM TESTING. ON MARCH 26 AND 27 THE-COMMISSION MET TO HEAR FROM THE STAFF ON THE STATUS OF DI ABLO CANYON UNIT l At(D IN PARTICULAR;T0; DECIDE WHETHER TO REINSTATE THE-LOW-POWER LICEt!SE_TO ALLOW CRITICALITY .
AND TESTING AT LEVELS UP TO 5 PERCENT OF RATED POWER. AT THAT f MEETING, A MEMBER OF THE NRC STAFF, MR. ISA YIN, INFORMED US, I
THAT BASED ON HIS FINDINGS FROM HIS INSPECTION ACTIVITIES, HE j COULD NOT RECOMMEND TO US THAT THE LOW POWER LICENSE BE REINSTATED.
IHIS WAS -
CONTRARY TO THE-RECOMMENDATION OF THE.NRC STAFF. AFTER A-THOROUGH EVALUATION OF THESE CONCERNS BY,A SPEQl' ALLY ASSIGNED.
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REVIEWGR0'UPkNDTHEADv!$0RYCOMMITTEE0NREACTbR. SAFEGUARDS,ON py q APPIL 13, THE COMMISSION REIMSTATED THE LOW-POWER LICENSE.
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k THE DIABLO CANYON REACTOR SUBSEQUENTLY WENT CRITICAL ON APRIL 29, i
LOW-POWER TESTING WAS SUCCESSFULLY COMPLETED ON MAY 23, AND THE
,Q FACILITY IS NOW,' READY FOR POWER ASCENSION.
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- LET ".5 ASSUP.E Y^,U M T PRIOR TO APPROVAL OF ANY SUBSEQUENT !
] lLICENSINGACTIVITIES,THESTAFFWILLTHOROUGHLYEVALUATEALL ,
, e 7, AJPROPRIATE MATTERS. REMAINING ACTIVITIES INCLUDE THE TECHNICAL
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' ISSUES RELATING TO PIPING AND SUPPORTS, PROGRAMMATIC QUALITY l
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CONTROL CONCERNS, SEISMIC REEVALUATION PROGRAM, A FEW OUTSTANDING l
l ISSudSFROMTHEINDEPENDENTDESIGNVERIFICATIONPROGRAM(IDVP),
AND FOLLOW-UP TO A NUMBER OF OTHER MATTERS INCLUDING PETITIONS l AND ALLEGATIONS. PG8E HAS BEEN REQUESTED TO PROVIDE ADDITIONAL INFORMATION ON A NUMBER OF THESE MATTERS. THE STAFF, THEREFORE, HAS NOT REACHED RESOLUTION ON THESE ISSUES AT THIS TIME,
, i I WOULD NOW LIKE TO SUMMARIZE THE-MogE.PRINICIPAL OF'THESE !
ISSUES. THE ' CONCERNS , ** * "" "" "" V'"
FALL INTO:TWO BROAD'
". CATEGORIES: PROGRAMMATIC DESIGN CONTROL AND TECHNCAL' DESIGN I i .
ISSUES IN THE AREA 0F PIPIRG SUPPORTS. THE REVIEW GROUP AND THE ,
i ACRS HAVE BOTH EVALUATED THESE CONCERNS. THAT EVALUATION INCLUDED l [
l MEETINGS WITH THE'LICFNSEE.TO DISCUSS.THE CONCERNS AND RECE!VE -
l THE!R EVALUATION:AND^ COMMENTS. 'IH ADDITION, THE'PEVIEW GROUP DISCUSSED CERTAIN MATTERS WITH THE IDVP PERSONNEL AND CONDUCTED i j WALKDOWNS OF THE'DIABLO CAN. YON PLANT WITH. REGARD TO SOME OF THE:-*
i i SPECIFIC TECHNICAL CONCERNS, SUCH AS SNUBBER AND. RESTRAINT .
LOCATION.AND REDUNDANCY. WHILE THEY CONCLUDED THAT NONE OF THESE f i
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CONCERNS WERE nF SUCH SAFETY SIGNIFICANCE AS TO FURTHER DELAY THE REINSTATEMF.NT OF THE LOW-POWER LICENSE, THEv ALSO CONCLUDED THAT CEDTAIN ACTIONS BY THE LICENSEE AND BY THE NRC SHOULD BE COMPLETED PRIOR TO A DECISION REGARDING ISSUANCE OF A FULL-POWER LICENSE.
THE ACRS CONCURRED WITH THIS CONCLUSION.
! :D THE COMMISSION REINSTATED THE LOW-POWER LICENSE AT THE, MEETING WITH THE REINSTATEMENT BECOMING EFFECTIVE ON APRIL 19. THE
! ACTIONS PROPOSED BY THE REVIEW GROUP WERE ISSUED ON APRIL 18 AS SEVEN SPECIFIC LICENSE CONDITIONS IN AN ORDER MODIFYING THE l
DIABL6 CANYON UNIT 1 LICENSE THAT MUST BE COMPLETED PRIOR TO FULL-POWER. THE STAFF HAS EXPANDED THIS REVIEW GROUP TO SEVERAL TASK TEAMS FOR THE REVIEW, EVALUATION, AUDIT AND INSPECTION OF
] THE LICENSEE'S EFFORTS. THE TASK TEAMS CONSIST OF 15 SENIOR ,
i PROFESSIONAL ENGINEERS INCLUDING BOTH NRC STAFF AND EXPERT l CONSULTANTS.[MR.YINISPARTICIPATINGINMANYOFTHETEAM l
$ ACTIVITIES THE STAFF WILL ISSUE THE RESULTS OF ITS EFFORTS AS A j SAFETY EVALUATION WHICH WILL SERVE AS ONE OF THE BASES FOR OUR l FULL-POWERDECkS!ON. WE EXPECT THAT THIS EFFORT WILL BE COMPLETED WITHIN ABOUT A MONTH. '
l ANOTHEP. MATTER THAT IS RECEIVING CON 5!DERABLE AT.TENTION IS GEOLOGICAL.INFORMATI0'N THAT RECENTLY BECAME AVAILABLE. IN MARCH, 198h, THE LICINSEE PRO'IDED V US WITH A' PREPRINT OF A SCIENTIFIC PAPFP REGARDING NEW INFORMATION AND INTERPRETATION OF DATA REGARDING THE HOSGRI FAULT NEAR THE DIABLO CANYON SITE. WE HAVE i .
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REQUESTED THE ACRS TO EVALUATE THE INFORMATION AND ADVISE US OF i i
2 ITS IMPACT REGARDING A FULL-POWER DECISION. THE FULL ACRS T. qu COMMITTEE AND ITS CONSULTANTS ARE SCHEDULED TO MEET ON JUNE l E I WITH THE LICENSEE, STAFF AND DR. CROUCH, THE PRINCIPAL AUTHOR OF THE PAPER.
IN ADDITION TO THIS NEW INFORMATION, THE STAFF IS CURRENTLY FORMULATING SPECIFIC DETAILS FOR A LONGER TERM REVALIDATION PROGRAM FOR THE SEISMIC DESIGN BASES OF THE DIABLO CANYON PLANT.
THE NEED FOR SUCH PROGRAM WAS INITIALLY DISCUSSED BY THE ACRS IN 1978 AND IS NOW A CONDITION IN THE LOW-POWER LICENSE. THE PROGRAM MUST BE ESTABLISHED BY JANUARY OF NEXT YEAR AND BE COMPLETED BY 1988.
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THE LAST SUBJECT I WANT TO MENTION IS THE MATTER OF ALLEGATIONS.
THF STAFF.HAS DEVOTED EXTENSIVE EFFORTS OVER THE PAST MONTHS TO
? EVALUATE ALLEGATIONS, SINCE EARLY NOVEMBER 1983, WE HAVE EXPENDED
.( }INEXCESSOF18000STAFFHOURS. OUR FUNDAMENTAL APPROACH IS TO
[FOCUSONTWOBASICQUESTION.S:
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- FIRSTLY, DOES THE ALLEGATION PRESENT A* TECHNICAL PROBLEM WHICH COULD AFFECT THE SAFF.TY OF THE PLANT 7 ,,
- SECONDLY, DOES THE All.EGATION REVEAL ANY SIGNIFICANT DEFECTS
.' IN THE LICENSEE'S OR HIS CONTRACTORS MANAGEMENT ON QUALITY SYSTEMS 7 0
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l THE STAFF EVALUATED ALMOST ALL OF THE FIRST APPROXIMATELY 200 ALLEGATIONS TO ADDRESS THESE QUESTIONS. MORE RECENTLY, SEVERAL HUNDRED ADDITIO*lAL ALLEGATIONS HA.VE BEEN RECEIVED FROM A VARIETY OF SOURCES. AS THIS PICTURE EVOLVED THE STAFF DEVELOPED SCREENING CRITERIA TO DETERMINE WHICH ALLEGATIONS MUST BE COMPLETELY RESOLVED PRIOR TO EITHER LOW-POWER OR FULL-POWER OPERATION. AS A MINIMUM, EACH ALLEGATION IS BEING EVALUATED AGAINST THE CRITERIA.
THESE CRITERIA ARE CONTAINED IN OUR SAFETY EVALUATION REPORT SUPPLEMENT 22.
USING'*THESE CRITERIA THE STAFF HAS IDENTIFIED ALLEGATIONS IN SEVERAL AREAS THAT REMAIN TO BE RESOLVED PRIOR TO FULL-POWER.
ONE OF THESE AREAS IS PIPING AND SUPPORTS WHICH IS ALSO INCLUDED IN THE STAFF REVIEW TEAM EFFORT I DISCUSSED EARLIER. THE ST4FF,
& ne m IS C,0NTINUING ITS ALLEGATION EVALUATION EFFORT AND WILL REPORT TO USI PRIOR TO A FULL-POWER DECISION ON,DIABLO CANYON.
IN CLOSINGjMY OPEN MG MEnAH(S TWO OTHER ACTIONS SHOULD BE NOTED.
THE FIPST IS THE DECISION BY THE APPEAL BOARD IN MARCH REGARDING 5%
1 a a4 ; MATTERS OF DESIGN QUALITY ASSURANCE. THAT DECISION WAS FAVORABLE ar Q([r.
y TO THE LICENSEE.
THE SECOND ITEM IS A NOTICE OF VIOLATION AND 73' 3;
,,p \ PROPOSED IMPOSITION OF A CIVIL PENALTY FOR $50,000 RESULTING FROM ,y ,
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D THE FACILIT,Y STAFF NOT RECOGNIZING FOR A PERIOD IN' EXCESS OF 15 HOURS THE ' INOPERABLE STATUS OF THE EMERGENCY COD $ COOLING SYSTEM.
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Mo. CHAIRMAN, THIS CONCLUDES MY OPENING REMARKS, WE ARE READY TO RESPOND TO YOUR COMMENTS AND QUESTIONS, e
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l0 Testimony Before Subcommittee on Energy and the Environment
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Comittee on Interior and Insulgr., Affairs U.S. House of Representatives on June 14, 1984 Prepared By: 1. T. Yin Mr. Chairman and members of the Congress, my name is Isa Yin. I am presently working in Region III, Division of Engineering, as a Senior.
Mechanical Engineer.
Relative to the Diablo Canyon Nuclear Power Plant investigation effort, my assignment was to follo'w up on some of the allegations made by Mr. .
Charles Stokes. The specific investigation areas were restricted to site s' mall bore (5/B) piping suspension system design control: However, due to hardware deficiencies observed during plant walkdown, the l'icens-et design control measures for la'rge bore (L/B) piping system had also been included as a part of the overview inspection and evaluation.
On March.26-27, 1984, during the Comission hearing held to reinstate the licensee's low power. test Operation License'(OL), I'b'rought to the Comission's attention the following issues that I had raised, which had ,
not been adequately addressed by the NRC-NRR and Region V management:
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- 1. Substentiation of design allegations. ' NRC overview inspections I
concluded that there had been significant QA. program deficiencies in the areas of S/B and L/B piping design control.
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- 2. An alarmingly large number of calculation errors and deficiencies had slipped through various reviews and checking stages.
- 3. Diablo Canyon Project Organization's lack of concern for establish-ment and irplementation of a sound design control QA program resulted in violation of~ NRC regulations in personnel training, document control, audits, design verifications, and raised questions in many technical and hardware related issues.
- 4. Reinspection..and necessary hardware re-work and modification could be perforned with less complication-prior to reactor criticality.
My testimony resulted in'the Comm'issioners' vote to postpone the OL I reinstatement decision. The Co'rmission also requested ACRS to determine
- the significance of these issues. .
Prior to the ACRS meeting held on April 6,1984, a peer review team was ..
formed under the. direction of Mr. Dircks thr.:NRC. Executive Director for Operations. The peer review team reviewed all the issues and listened to both sides of the story from PG&E and from re. During the ACRS meeting, the staff presented a consensual view that: ,
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- 1. 'It is acceptable to permit low power operation. Such operation will not compromise corrective actions and.will not be -a risk to the public health and safety.
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- j. 2. Prior to operation above 5% power, all the significant issues
! concluded by the peer review team should be addressed and corrected I by PG&E and evaluated and accepted by the staff.
i l The ACRS letter te the Comission, dated April 9,1984,' concurred with l the staff position, an'd requested further review of staff resolution of the va'rious relevant issues raised by NRC inspectors and others.
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l1 The low. power OL was subse'quently' reinstated during the April 13, 1984 ..
i Commis'sion hearing. The'Comission:also asked that the aaae *aviaw team i R l
. issues were to be included in a license amendment. This set forth
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April 18,1984. .
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Presently, the staff is working towards resolving the License Condition items, as well as Independent DesignLVerification Program (IDVP). con- j j cerns and' phogramatic. issues raised by.me.- -
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- . 1. The License Conditions included:
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l a. Re-analyses and re-qualification of all $/B piping support i 1
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computer calculations.
- b. Evaluation and shiming of all closely spaced rigid to rigid restraints and ar.chors.
- c. Performing additional piping analyses te ensure functiorability of snubbers that were installed in close
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proximity to rigid supports.
- d. Establishment of system inservice inspection to maintain required thermal gaps within rigid support structure throughout plant life.
- e. Staff observation of hot walkdewn inspections of Main Steam
'and Residual Heat Remove Systems' to ensure absence of structural interference.
- f. Review of "quickly f xed" significant design changes; and design criteria that were prescribed in those informal "Diablo Problem" correspondence.
- g. Consideration of additional techn.ical topics raised by the Q s
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These issues are presently handled by NRC-NRR staff with help from cutside consultants and Regional staff. I.have not been involved in any of the task actions.
2.- My written concerns on possible inadequate IDVP for L/B and.5/B piping stress analyses and support calculations, and[seeminaly insufficient followup evaluations after deficienc.ies had been identified were fonnally submitted to NRC-NRR management on April h
25, 1984 Joint review of these concerns will be conducted NRR, IE A
staff, and myself.
. 3. Programmatic issues that had not been addressed in the License Conditions, but will' affect the quality of ongoing and futura project activities required the following changes: ..
- a. Improvement of site personnel indoctrination and training program as well as meas'ures to be taken te ensure effective implementation of program requirement:.
- b. More stringent. control of site procedures, including removal of outdated documents, and avoidance of procedure" revisions by -
Jnter-office memorandum. ;
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- c. Upgrade procedures to include better control of preliminary A
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6-design data, design interfaces between site Stress and Support
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' g'rcups, and PG&E and Westinghouse. ..
- d. . Improvement of timeliness of project responses to site personnel safety. concerns, and QA audit findings. Corrective actions should also include identification of underlying causes, and surveillance to prevent recurrence.
- e. Conducting more extensive QA program audits that will include broader scopes and more in-depth review during the audit and prior to accepting audit finding corrective actions.
f., Establishment of' technical audits to ensure all aspects of design control requirements, such as design criteria, assump-tion, judgement basis, review, and approval had been imple-mented in accordance with program provisions. ,
I am presently reviewing some of the licensee actions relative to these progrannatic issues. ,
As it stands to date, followup actions that require my persbnal atten- .
tion have not progressed swiftly. The following situations could stand inthewayofgettingtheissufsresolvedpromptly: ,
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- 1. Geographic distance between Diablo Canyon site and Chicago that requires more travel time and effort. . .
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- 2. Inspection plans and schedules that require interfacing with ants
concurrence by NRR.
- 3. Participation in interviewing new allegers and evaluation of the new allegation issues.
- 4. he licensee top management, including theirgulive VP, has committed to improving the corporate QA program. However, the ,
recent~followup site observations showed that the policy had not "
been effectively carried out at operational levels.
Mr. Chairman, and members of the Congress,*I thank you for'the oppor-tunity to testify, and will truthfully answer any questions that you may
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F (b) EIC V
,8g gt UNITED STATES j tg M / jy NUCLEAR REGULATORY COMMISSION
- , ),. W ASH IN GTON , D.C. 20555
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,,,[y';',,, han,as CHAIRMAN hheHonorableMorrisK.Udall
~ Chainnan Committee on Interior and Insular Affairs U.S. House of Representatives Washington, D.C. 20515
Dear Mr. Chainnan:
Pursuant to your February 22, 1984 request for answers to ten questions related to the functioning of the nuclear regulatory process at the Diablo Canyon' Nuclear Power Plant, I have enclosed our responses.
I trust that these answers are responsive to your questions.
Thank you for your interest. _
Sincerely,
- ' q pb p@(3 W Nunzio Palladino Chairman
Enclosures:
As stated cc: Rep. Manuel Lojan e .
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OUESTION 1: Please sumarize the status of the staff's inquiry into l allegations that pipe support calculations were not perfomed in accord with the requirements of the NRC regulations. Which piping systems, if any, will be modified as a result of errors in the pipe support calculations?
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Answer.
As a result of the Independent Design Verification Program (IDVP) the piping and piping supports, both small bore (i.e., less than 2.5 inch diameter) and large bore were reviewed by Pacific Gas and Electric Company's (PG&E) Diablo CanyonProject(DCP). The results of that effort were reported in Supple-ment 18 of the Safety Evaluation Report (SSER 18). Resolution of some
. issues identified were addressed in SSER 19 and SSER 20. In late 1983 a number of allegations were made regarding the adequacy of design piping and piping supports, in particular for small bore piping. On March 19 of this year the NRC issued SSER 22 which sumarized in Section 5.1 the status of the staff evaluation of allegations on small bore piping as follows:
"The principal technical finding is that the analyses performed by computer for small bore piping supports have been determined to have an unexpectedly large error rate, on' the order of twenty perc'ent as compared to ten .or less percent that experience has shown is-likely.
On the other hand the error rate in the hand calculations for small bore piping supports was acceptably low. In light of :these-findings the staff will require that. PG&E establish a program to review all ~
computer analyses for small bore piping supports." ,
"In partial response to those staff findings the licensee has reported the results of a review of approximately 130 small bore piping support computer analyses including the analyses in which the
. ' staff has previously identified errors. The licensee reported that, with errors corrected where necessary, all completed calculations
- showed final acceptability of the supports. The staff concluded a special inspection to evaluate the process used to re-review the small bore piping calculations packages."
' 7 "We found with minor exception, that the re'fiew proce'ss was compre-hensive, was being carried out by qualified individuals, and was
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conducted in a manner to assure that the results could be accepted
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. with high confidence."
" Analyses of the type and significance of the deficiencies seen to date has led the staff to conclude-that, although the design QA program for the OPEG is not up to acceptable standards, the impact in terms of design adequacy, has not been significant."
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2-9 4 " Based on the results of the staff's review to date and the types of errors that have been identified it is very likely that modifica-tions, if any, would be minor and only to fully meet seismic criteria with little or no impact on operability of systems under the full range of plant operations. Since some piping support modifications are nomally. required as a result of initial plant operation, due to unexpected themal motions or operating require-i ments of attached or supported equipment, there is sound logic in conducting the required calculations review during low power operation so that any resulting modifications could be included in a orderly and consolidated program prior to full power operation."
On Maren 26 and 27,1984 the staff briefed the Concission on a' number of i
issues related to the reinstatement of the suspended low power. license.
Among other matters, the staff addressed the issue of small bore piping as
- l. prisented in SSER 22 and stated above. At the meeting Mr. Isa Yin of the NRC staff informed the Commission of the results of his con:1usions -
i regarding inspection and audit activities he perfomed at the Diablo Canyon site and at the PG&E engineering offices in San Francisco. A copy of Mr.
Yin's prepared statement at.the meeting is' attached. He concluded that
. - Diablo Canyon Unit 1 should not be permitted to go critical and perform low power operations until his concerns have~ been. appropriately addressed.
We directed the staff to further review and evaluate these matters and in particular address each of Mr. . Yin's concerns. Furthemore, we requested
- the Advisory Committee on Reactor Safeguards (ACRS) to review the area of disagreement and to provide us with their evaluation by April 10, 1984. On
-April 5 - 7,1984, the ACRS reviewed the technical issues arising from the Diablo Canyon licensee's design" control measures for small and large bore piping. During this review members of the NRC staff, including NRC Inspector Isa Yin, representatives of PG&E and of the IDVP organizations, and Mr. Charles Stokes, a' member of the public, gave-presentations. In a letter dated April 9,1984 (attached) the ACRS provided their recoamenda-tions on this and the additional connents of three members. The ACRS i 'reconnended that low power operation be pemitted and that the several
- actions proposed by the NRC staff for completion' before operation above five i percent power will provid.e a suitable basis for considering: operation.at
- full. power. At this time we do not consider.the issue of small-bore piping -
- and supports resolved. We have' not detemined that piping system modifica-tions,'if any, will be required as a result of these efforts. .
} The Connission approved.a' low power licens'e for Diablo Canyon on April 19, i 1984. .
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QUESTION 2: It has been alleged that inspectors at Diablo Canyon were instructed that they should not inspect welds on materials supplied by vendors, even in situations where the welds appeared defective on the basis of visual observations. Has the Commission established whether such instructions were ,
issued? If such instructions were issued, what was the purpose and did they constitute a violation of the Conmission's QA requirements?
I ANSWER.
The shff has established that instructions were issued in an April 3,1980 memorandum to Pullman Power Products (PPP) stating, in part, that " Pullman need not report further test results on-shop welds." -
To put the memorandum in. perspective, it is important to understand wlat was occurring at Diablo Canyon at the time. In late 1978, cracks were detected by visual inspection .of pipe rupture restraint welds made;byPPP .in the Unit 1 pipeway structure, The welds in question involved-high strength alloy steel not widely used. The welds were in thick sections end thus highly restrained. The weld defects in question apparently.di. splayed a delayed cracking phenomena -whi.ch -was not imediately noticeabl.e -at the time:
of welding. This is sometimes a problem with high strength alloy-steel. On May 3,1979, PG&E issued a 10 CFR 50.55(e) construction deficiency report to l the.NRC.
A substantial repair and testing program was initiated to identify the type, cause and extent of the defects. The program included Ultrasonic Testing
- (UT) of a sampling of these Pullman high strength welds. Problems were found during the initial repair and testing program such that PG&E expanded the program in order to form a data base to establish the adequacy of these i
welds. The repair program was a large scale effort well known to PG&E and Pullman welding personnel. The effort was extensively reviewed by.NRC. On .
December 9,1980, PG&E issued their final 10 CFR 50.55(e) report .for Unit 1, which s'unnarizes the background, scope and results of actibns taken.-
During the. evaluation and repair of field welds, a parallel program to .-
examine pipe rupture restraint vendor welded materials (shop welds) was
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iinplemented. Vendor welds made with the self-shielded, flux core process were found to be.a particular problem. PG&E reviewed all joints where these electrodes had been used.. Discrepencies were found and repairs were made.
By April, 1980, PG&E had sufficient data on the other types of shop weld defects to make an engineering evaluation and concluded that the type ~of indications found were not a problem. They consequently notified Pullman that they had enough data.
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- 4-Taken in proper context, it would appear that the April 3,1980 memorandum was written with sufficient information to be understood by those involved '
in the large scale repair and test program. In fact, the April 3,1980 )
memorandum stated that PG&E believed that sufficient data on shop welds ,
existed to preclude the need for Pullman welding inspectors to report !
further inspection findings on shop welds.
Some in Pullman appear to have been concerned that this April memorandum reant that unless the shop weld defects directly affected their work they i were to ignore the defect. Over time, while the repair program was completed on Unit I and continued on Unit 2, confusion crept in and prompted
. RG&E to issue a July 26, 1982 letter to Pullma'n to clarify the intent of the April 3, 1980 memorandum.
The July 26, 1982 letter states that unless a shop weld defect directly affects Pullman work, there is no need to address that defect because of the extensive engineering evaluation-discussed above. The letter also states that shop weld defects not directly affecting Pullman's work should be reported separately and turned over to PG&E.
To address the issue of whether or not there were~ shop welds -that were
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ignored between April 3,1980 and July 26, 1982, the staff interviewed six welding inspectors. This' represents an estimated 20 percent sample of ~
welding inspectors on site.during that int'erval. Five of the interviewees were o'n site during this . subject time frame. All of the interviewees stated that they were aware of PG&E's engineering evaluation which accepted all shop welds. They also stated, however, that shop weld defects were reported when noticed by issuing a DCN (Deficient Condition Notices) and that final
'walkdown packages included this infonnation. ,
In summary, it is the staff.'s opinion.that the technical aspects of this
, . issue were handled properly and that PG&E's April 3,1980 memorandum was l
proper when taken in context. Later, confusion apparently spread so PG&E responsibly responded to'that confusion in their July 26, 1982 letter to Pullman. . . -
Finally, the April 3,1980 memorandum which included instructions to Pullman to not. report further results on shop-welds -did-not violate' the Commission's QA requirements.-
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OUESTION 3: With respect to the findings of ongoing inquiries, SSER 21 (P. E-13,14) states that "...no direct evidence was offered by the interviewees concerning experiencing or knowing of r.ny corner cutting, intimidation or harassment..." and that management was " responsive and supportive" of employee concerns. Does the NRC now possess substantial evidence '
that would cause the staff to change SSER 21's findings regarding harassment and intimidation?
ANSWER.
Based on the staff work in this area it appears that a few iiidividuals feel strongly that they have been directly intimidated. Some have offered specific and detailed reports in support of their allegation. These cases are complex. The staff could not readily tell whether the cases involve intimidation, proper exercise of management prerogatives, or just poon .
communication. As appropriate, these few cases (eight total) are being ~
addressed through the Department of Labor regulatory process, and/or review by the NRC Office of Investigations. A few additional individuals were
. concerned _about intimidation but indicated their views stemed from events
! not directly related to their own experience, such as: general perceptions that the pressure was on to get the. job don,e; rumors of the layoff or firing i of another employee as a result of writing a nonconfomance report; or, media reports of intimidation. The staff does not detect any widespread company attitude to suppress employee concerns or corrupt the overall.
effectiveness of the Quality Assurance Program. The staff also found in the conduct of the vast majority of personnel interviews that employees were not afraid to identify and deal with quality problems in a responsible manner, both within their own organizations and with the NRC.
The staff concludes that a widespread suppression problem does not exist at Diablo Canyon, however, the staff is concerned with employee perceptions in this. area. Licensee management shares this concern. The staff has reviewed this subject with licensee management and notes that the licensee has undertaken steps to make improvements. This effort incTudes'such actions as the development of video tape presentations for all existing and new
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employees regarding surfacing of quality concerns; an "800" telephone number for receiving quality concerns; and a system for receipt and resolution of concerns. The licensee's. activities in this area will be monitored by the staff.
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- 6-QUESTiN4: What is the nature of ongoing investigations into allegations of intimidation and harassment? i l
ANSWER.
OI presently has eight investigative matters involving, either singularly or collectively, intimidation, harassment, and threats. These investigations involve allegations of threats of physical harm; firing of individuals, transferring of persons who raise questions to other jobs; oral reprimands to persons who raise issues; directing quality, control inspectors to disre-gard violations on the grounds defects will be caught by other depart-ments; persons who have.used the hotline to report concerns have been contacted by a construction superintendent and e'ither told directly he did not like the person's complaint or questioning the persons about their call giving them a definite chilling effect.about using the hotline; and supervisors instructed not to discuss matters any further with managemgnt.
- QUESTION 4: When did the Office of Investigations initiate its investigation into this matter? ,
kNSWER.
The Office of Investigations became involved with the series of allegations
'. referred to in the referenced letter as "this matter" in early December 1983. Iriitially, the Investigators listened to the testimony of one of the allegers to determine if any of his concerns came under OI's jurisdiction.
Following this interview,11 investigative matters involving Diablo Canyon were opened by the Office of Investigations. ,
As of March 23, 1984, the Office of investigations has 17 pending investiga-
'tive matters involving Diablo Canyon. In addition, the Office of Investigations is just beginning a review of approximately 54 allegations that may fall under the Office of Investigations jurisdiction. These allegations have to be further evaluated by 01 as to whether or not they should.best be investigated by .the Office of Investigations.
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QUESTION 4: How many Investigators have been assigned to the task?
ANSWER.
OI presently has two Investigators (OI's total investigative compliment based in 01's Region V Field Office) assigned to investigating allegations against a vendor who supplied fabricated steel to Diablo Canyon. Assisting these two investigators is a Vendor Inspector specialist from Region IV and a Reactor Inspector, who is a metallurgist from Region V. Two 01 Investigators have been detailed initially for 90 days from 01's Region II office to work on the pending investigations at Diablo Canyon. The first of -
these-two investigators reported to the 01 Region V Field Office on March 5, 1984. They began their work as a team at Diablo Canyon on March 12, 1984.
The majority of the 01 Field Office Director's time for Region V has been 1 dedicated to supervising OI's investigative efforts concerning Diablo Canyon '
- since early December 1983. . ._
QUESTION 4: When wil'1 the investigation be complete?
l ANSWER.
! OI is addressing the numerous allegations as individual investigative
- matters and not as one investigation as most of these matters are not interrelated. Because of the number and variety of investigative matters involved, it is impossible to forecast a completion date with any degree of i accuracy.
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- 8-QUESTION S: Does the Comission believe that PG&E fulfilled its comitment to comply with the Comission's regulations pursuant to Appendix B of 10 CFR 50 in the design and construction of the Diablo Canyon powerplant?
ANSWER.
The Comission believes that PG&E has sufficiently fulfilled its quality assurance comitments to. allow restoration of the low power testing authorization. The Comission is aware that there have been. instances of non-compliance with these comitments. The significance of this must be decided in reaching a decision on full power operation.
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QUESTION 6: Were the QA requirements comitted to by PG&E vis-a-vis Diablo Canyon significantly different from requirements ,
committed to by utilities that received construction pemits ;
in 1972? In 19757 ANSWER.
The QA requirements comitted to by PG&E for the design and construction of
, Diablo Canyon generally reflected the evolving NRC regulations such that the PG&E comitments during 1972 were comparable to comitments of utilities.
that , received construction permits in 1972.
! Utilities whose Preliminary Safety Analysis Reports were reviewed after detailed NRC guidance on QA was issued in the 1973-1974 time-period
- were
- required to comit to meet the guidance or provide specific detailed alter-natives . PG&E and other uti.11 ties with construction pemits issued bedore the guidance were not required to comit to meet the guidance during the design and construction of their plants.
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- Guidance issued during thissime period included the following:" WASH" . - -
! documents:- ,
Design and Procure-(a) "ment Guidance Phase of on-Quality Nuclear Power Assurance Plants," Requirements June 7,1973 During(WASH-1283) and Rev. 1 May 24, 1974 .
-(b) " Guidance on Quality Assurance Requirements During the Operations Phase
, of Nuclear Power Plants," October 26,1973 (WASH 1284).
l i (c) " Guidance on Quality Assurance Requirements During the Construction
! Phase of Nuclear Power Plants," May 10,1974(WASH 1309).
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QUESTION 7: Was full documentation demonstrating compliance with the Commission's QA requirements turned over to PG&E by Pullman Power Products and the Foley Company prior to issuance of the low power Operating License in Septenber 19817 ANSWER.
Ro. Pullman Power Products and Foley had not turned over to PG&E all documents demonstrating compliance with the Commission's QA requirements prior to issuance of the low power Operating License in September 1981, i -
because they were still on site and performing work.
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QUESTION 8: Does PG&E (as opposed to its contractors) possess now a
, comprehensive collection of the records (e.g. work packages) indicating that specific tasks (e.g. specific welds) were carried out in accordance with the NRC's quality assurance requirements? If not, when will such records be turned over to PG&E7 ANSWER.
PG&E (as opposed to its contractors) does not now possess a comprehensive collection of the Unit I records indicating that all specific tasks were carried out in accordance with the NRC's quality assurance requirements.
Some contractors who worked at Diablo Canyon have completed their contrac-j tural requirements, but are no longer engaged in work at the site. Prior to i '
their departure, PG&E took custody of all quality records generated by__that contractor.
l PG&E does not currently have custody of all quality records generated by contractors currently engaged in quality related work at Diablo Canyon j (Pullman and H. P. Foley). These Unit I records are in the process of being
! turned over to PG&E. ,
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Prior to exceeding 55 power, all H.P. Foley and Pullman Power products l quality related records will be turned over to PG&E with the exception that i
records for work in progress will be turned over within 60 days of work '
completion. -
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OUESTION 9: mat specific rework.has been required at Diablo Canyon as a result af inquiries, undertaken since September,1983, into ,
allegations of failures to comply with design or i construction Q.A. requirements? What is the time schedule for com,)1eting such work?
ANSWER.
Post September 1983 review of allegations and NRC inspection items concerning allegations has resulted in the following minor modifications and repairs:
j 1. PG&E review of small bore pipe support number 100-111, identified for NRC review by an alleger, resulted in a modification. The support
! .provides restraint of the valve operator and the pipe at the valve. The modification ' ras the addition of a~n axial restraint at the pipe to-.
prevent transfer of forces to the operator in the axial direction. This change was made for consistency with Project standard practices even
. though analysis showed the change was .not necessary to meet acceptance criteria.
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1 2. One 1/2 inch diameter' electrical raceway ' anchor bolt was replaced during th.e audit of concrete anchor bolt embe5 ment. The original bolt was
, removed to verify, by physical measurement, the depth of embedment as
- indicated by sitrasonic measurement. The replacement bolt was fully
- embedded; however, engineering analysis would, in all probability, have shown qualification of the initial installation. Thirty-nine similar install.ations were analyzed,and adequate safety factors were demon-strated as reported in PG&E letter DCL-84-059, dated February 16, 1984.
, 3. The NRC review of allegations related to electrical wire traceability led to the following change: Approximately eighty-four feet of
. Continental HTR wire, installed in the Control Room Positive Pressure l
- . Ventilation System was replaced. The wire was documented to be !
qualified and of the. proper type and color sode, howevei traceability to I
the source (wire reel) was not established. This is discussed in PG&E j letter DCL-84-066, dated February 17, 1984. )
l 4. Eighty ASTM A325 bolts were welded to the Unit I containment fan cooler support structure in order to mount component cooling water pipe l supports. Although these installations had been verified to be capable of meeting design assumptions, the licensee elected to weld the support plates to the fan cooler supports; thus, removing the welded bolts from the support leads. This was done to provide added assurance of pipe support adequacy throughoc'. plant life.
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In addition to the above listed items, the investigation of allegations has resulted.in extensive records review and some engineering analysis and testing to demonstrate the acceptability of existing installations.
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1 CtTETICN 10: Tce feil: wing refe-s te tse s=: :a y ficcirgs of :ne N11ran audit c# 7: lim: Power P-ce:: s ::c,::::e: :y A;: lear i
Services Cor:c atice (KSC) in 1977.
(a) ih.at is de Ocarissic:'s assessme- ef itest fit:ie;s?
MS'mTE.
The sta*f's assessmect is previded i: the fellowirs E Inspectice tex-ts:
- a. Repc-: N:s. .L275/E3-37, 50-223/E3-25; : ara;n;:e at
- h. Repert E:s. L275/E3-34 L223/E3-24; :aragra;e.s 4.a. 4.b and l
4.:
l E'Inspe:tien Re:cr. h:s. EZ75/E3-37, 50-223/E3-15 (;a-ar a;h 44) s:ates, in part, the follorit;:
- Althoup., ce E h.as icentified a pctantiti vi:latice (;arag a:c 17)
. c;: ring this inspe:tice, rega-ding the c:alifica:ict cf Niina: vis;al welding ir.spe ::rs : tis'itan is cf rea::ed sig-ifican:t sia:e all bc t> cf the inc;e::ces had.adecuate ba:kg-xm:s and expe-ience in the l '
areas cf welding er cuality coet ci insbe:tioc. It does net appear that j this problast uts chrceic er widespread.
l l It is the staff's c;inise that the MSC audit findings de act provide a ,
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basis for ccecluding tts; the Pulleen-Kailogg Quality Assu ence F.ww l suffered a sejer breakdme dudeg the time period prier tc the R$s-l audit. Furtherscre, based cc this significar.: saacle of tne ecs:
l important MSO findir4s it is cce:luded that examinatice cf the remaining l
itants is net warranted.' .
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. The staff's findiegs, docusented in iR2 Inspe:tice Repc-t hes. LI75/83-34, .'
W 323/83-24, did net icantify any instances cf regulate~ ~y~ mwliance oc progrmunatic quality assirsace deficiencies. -
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QUESTION 10(b): To what extent do these findings indicate significant violations of the NRC's QA requirements?
ANSWER.
NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25 identifies, in paragraph 17 and Appendix A, one violation regarding the qualification of Pullman visual welding inspectors. Paragraph 44 of that same report further states that "this item is of reduced significance since all but two of the inspectors had adequate backgrounds and experience in the areas of welding or qu,ality control inspection. It does not appear that this problem was chronic or widespread." '..
.i Also, NRC Inspection Report Nos. 50-275/83-34, 50-323/83-24: documents that i no items of noncompliance or deviations were identified in the area of compliance with QA requirements. -
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1 QUESTION 10(c): Please describe the nature of inquiries conducted to determine whether the NSC findings were valid and if so, what the implications might be? Please provide all reports i prepared by NRC staff and contractors in conjunction with i
the staff's assessment of NSC's findings.
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ANSWER..
, The nature of the staff's inquiries and assessments are described in itRC .
Inspection Report hos. 50-275/83-37, 50-323/83-25 and 50-275/83-34,
. 50-323/83-24. Additionally, Attachment No. I to NRC Inspection Report i No. 50-275/83-37, 50-323/83-25 documents the work of an NRC consultant's 2
(Parameter Incorporated) independent verification of field work and records.
for compliance with code requirements. -
) Ba' sed on the staff's inspection effort, as documented in the above ._
referenced NRC inspection reports, the staff concluded that the Pullman
- Quality Assurance program did not suffer a major breakdown during the time
! period prior to the NSC aud,it.
I l The referenced NRC Inspection Reports 50-275/83-37, 50-323/83-25 and
- 50-275/83-34,50-323/83-24 are enclosed. ,
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i QUESTION 10(d): The Pullman audit states on Page 22 under Item 10 that i control of the welding process was inadequate in several respects. During what period, if any, did such deficiencies
! exist? If the deficiencies listed under Item 10 did exist, what is the basis for a deterinination that weld quality is that required by the Connission's regulations? Does 4 documentation exist to demonstrate the adequate resolution of the alleged deficiencies listed under Item 107 l
1 1 ANSWER.
l The s'taff's assessment of the items referenced on page 22 under item 10 of
- the NSC Pullman audit are contained in NRC Inspection Report i' Nos. 50-275/83-37 and 50-323/83-25 paragraphs 34 and 18 through 30. One item, re report) garding welder is addressed BF (see4.c in paragraph second of NRC paragraph Inspection on Reportpage 23 of the NSC audit Nos. _
50-275/83-34,50-323/83-24. The basis for the staff's determinations are j
provided in these two inspection reports, wherein the staff' concludes that isolated welding discrepancias were identified and correctad, Wr the Pu11aan
! welding program. However, the staff concluded that the aggregate of problem areas were not so pervasive as to support the NSC conclusion that "There is no confidence that welding done prior to early 1974 was performed in accor-
- dance with welding specification requirements."
The referenced NRC Inspection Reports, including Inspection Report
- 50-275/84-16, provide the basis for the staff's assessment and conclusions i regarding the alleged deficiencies listed under Item 10 of the NSC Audit l Report. The documentation reviewed by the staff in forming this conclusion is identified in Inspection Report 50-275/84-16 and those documents exist at i the Diablo Canyon site.
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QUESTION 10(e): The Pullm' a n audit states on page 25 that "...there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements?" Does the Comission have documentation to refute this finding? If not, what is the basis for a finding that, for welds produced prior to early 1974, weld quality was that required by the Comission's regulations?
- ANSWER.
The staff's documentation to refute the NSC finding is contained in NRC Inspection Reports No. 50-275/83-37, 50-323/83-25, and 50-275/83-34, 50-323/83-24. .These reports clearly document the staff's basis and conclusions. Also, as a result of discussion 'at the March 26 Comission i meeting, the staff reviewed the Pullman audits and the Pacific Gas and Electric Company audits done in the pre-1974 time period in more detai.1
. The results are reported in Inspection Report 50-275/84-16 in which the
- staff confirms that the audit program met the requirements of Appendix B.
The documentation reviewed 'by the staff on forming their conclusion exists
! at the Diablo Canyon site 4
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DUESTION 10(f): Do the Comission's regulations require prompt reporting to the NRC of findings su:h as those listed in the NSC audit of Pullman Power Products? Did the failure to proactly report the NSC findings constitute a violation of the Comission's regulations?
ANSWER.
The question of the reportability of the NSC audit is addressed in +Je attached " Director's Decision under 10 CFR 2.206* which was issued by the Director of the Office of Inspection and Enforcement. The decision is currently pending before the Comission for its possible review in accordance with the provisions of 10 CFR 2.106(c).
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- c UNITED STATES '
!' ,9, j ~NUOLEAR REGULATORY COMMISSION'
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- j ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINCTON. D. C. 20555 Q
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I April 9, 1984 Honorable Nunzio J. Palladino Chairman .
U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Dr. Palladino:
SUBJECT:
ACRS REPORT ON DESIGN CONTROL MEASURES AT THE DIABLO CANYON j
NUCLEAR POWER PLANT During its 288th meeting, April 5-7, 1984, the Advisory Committee on .
Reactor Safeguards reviewed the technical issues arising from the Diablo Canyon Licensee's design control measures for small and large bore piping, as requested in your letter dated April 4.,1984. During this review we had ,
the benefit of presentations by members of the NRC Staff, including NRC Inspector Isa Yin, by representatives of the Pacific Gas & Electric Company (Licensee) and of the Independent Design Verification Program organiza-tions, and by Mr. Charles Stokes, a member of the public. We also had the benefit of the documents listed. ,
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We were infomed that there 'is'no longer disagreement between the NRC Staff and Mr. Yin. They now agree on a series of actions that must be completed
- by the Licensee and by the NRC Staff to resolve certain questions, and agree that these should be completed before operation at full power. They agree also that operation and low power testing at levels up to five
- percent of full power can be permitted without undue ' risk to. the health and
' - safety of the public. , ,
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- We agree that it is acceptable to permit low power operation at this time.
We believe that such operation. will not compromise corrective actions that may be -reouired. . . -
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l We believe that the several actions proposed by the NRt Staff for comple *
' tion before operation above five percent , power will provide a suitable basis for considering operation at' full power.
The Licensee has agreed to the actions proposed by the NRC Staff before operation above five percent power with one exception. This exception relates to the need for or desirability of " hot shimming" for closely spaced restraints on large bore piping. We believe tha.t this requirement ~
deserves further technical review and discussion between the NRC Staff and the , Licensee.
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Honorable Nunzio J. Palladino April 9,1934 We understant that allegations such as those made by Mr. Stokes will be
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investigated and appropriately considered by the f{RC Staff.
Add.itional comments by ACRS members Robert Axtmenn, Jesse Ebersole, and David Okrent are presented below. -
Sincerely, M w< A >
Jesse. C. Eberso3e Chairman Additional Comments by ACRS members Robert Axtmann, Jesse Ebersole, and Davio Okrent We agree with the ACRS conclusion on operation at five percent power.
In view of the limited time available for review of this matter, the bulk of documentation, and the lateness of some documents in reaching us, our review was of necessity limited in its depth.
Prior to an ascent in power above five percent, the NRC Staff'should pre-pare a document
- discussing in considerable detail how the various relevant issues raised by its inspectors and othe,rs have been handled. The NRC Staff should also perform a careful examination of a selected sample of actual construction details to help assure that the appropriate quality has been accomplished.
We believe the ACRS'should be given an opportunity to review these results .
prior to the achievement of full power at the Diablo Canyon Nuclear Power
. Pl ant. . ..
References:
1.- U. S. Nuclear Regulatory Commission Transcript of the March 26 and 27,.
1984 meeting in the matter of Discussion /Possible Vote on Diablo Canyon Criticality and Low Power Operation, Pages JiS-102, 233 256, 263, 279, '
and 281-287
- 2. U..3.. Nuclear Regulatory Commission Transcript of the March 28, 1984
. meetin'g between Staff, Applicant and Intervenor on Diablo Canyon, Pages 1-124 .
- 3. U. S. Nuclear Regulatory Commission Transcript of the meeting on April 2, 1984 in the matter of Pacific Gas & Electric Company on Diablo Canyon, Pages 1-272
- 4. I. T. Yin, "Diablo Canyon 1, Summary of Findings Resulting From Follo*w -
up of Allegations and NRC. Independent Overview," Draft dated March 29, l 1984 .
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- Honorable Nunzio J. Pallatino April 9,1984 C. I. T. Yin, "Diablo Canyon 1, Draft Investigation / Inspection Report,"
Rev. 3, dated March 29, 1984 '
- 6. Memorandum, with enclosure, f rom Darrell C. Eisenhut, Director, Division of Licensing, U. S. Nuclear Regul atory Comission, to Chairman Palladino and Commissioners, U. S. Nuclear Regulatory Commission,
Subject:
Diablo Canyon - Allegations Concerning Small <
Bore Piping and Supports (Board Notification No.83-171), dated -
October 27, 1983
- 7. U. S. Nuclear Regulatory Commission, " Safety Evaluation Report Related to the Operation of Diablo Canyon Nuclear Power Plant, Units 1 and 2," USNRC Report HUREG-0675, supplement No. 22, dated March 1984
- 8. Exhib.it A, " Affidavit of Charles Stokes," dated November 1983 to Motion to Atomic Safety and Licensing Appeal Board, " Joint Inter -
venors' Motion to ' Augment or, in the Alternative, to Reopen the Re-cord" in the Matter of Pacific Gas and Dectric Company (Diablo Canyon Nuclear Power. Plant; units 1 and 2), dated February 14, 1984
- 9. Pacific Gas and Dectric Company's Answer in Opposition to Joint Intervenors' Motion ts Augment or, in the Alternative, to Reopen the Record in the Matter of Pacific Gas and D ectric Company .
(Diablo Canyon Nuclear Power Plant, Units 1 and 2) without attach-ments, dated March 6,1984
- 10. Letter No. DCL-84-131, from J. 0.. Schuyler, Pacific Gar and D ectric Company to Mr. Harold R. Denton, Director Office of Nutlear Reactor Regulation, U. 5. Nuclear Regulatory Commission.
Subject:
Response to
- Board Notification B4-071 on Diablo Canyon Unit 1, dated April 4,1984
- 11. Sumary of Remarks of Charles Stokes Before the Advisory Committee on Reactor Safeguards Concerning the Diablo Canyon Nuclear Power Plant, dated April 6,1981 *
- 12. L'etter No. P105-6 f ra Robert L. Cloud, Robert L. Cloud Associates, !
Inc., to Mr. G. A. Maneatis, Pacific Gas and Dectric Company, Mr. H. "
R. Denton, U.' S. Nuclear Regulatory Commission, and Mr. J. B. Martin, Region V, U. S. Nutiest Regulatory Comission, regarding allegations at Diablo Canyon, dated February 3,1984 '
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REB 2 g yp Docke Nos. 50-275 and 50-323 ,
Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Attention: Mr. J. O. Schuyler, Vice President - -- - -
Nuclear Power Generation Gentlemen: __
Subject:
NRC Inspection of Diablo Canyon Units Nos. I and 2 This refers to the special inspection conducted by Messrs. D. F. Kirsch, T. M. Ross, and G. B. Bernandez of this office on November 14-18 and November 1
28 - December 9,1983, of activities authorised by NRC License No. DPR-76 and l Construction Permit No. CPPR-69, and to the discussion of our findings held !
with Mr. D. A. Rockwell and other members of your staff at the conclusion of l the inspection.
Areas esamined during this inspection are described in the enclosed inspection report. Within these areas, the inspection. consisted of selective
,, examinations of procedures and representative records, interviews with '
personnel, and observations by the inspector.
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Based on the results of this inspection, it. appears that 'one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.
Your response to this Notice is to be submitted in accordance with the ;
provisions of 101FR 2.201 as stated in Appendix A, Notice of Violation.
In accordance with 10 CFR 2.790(a), a copy of this letter anE the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of ,
the date of this letter. Such application asst be consistent with the l
- requirements of 2.790(b)(1). , , ,
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Pacific Gas and Electric Company .
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the_ Office of Management and Budget as requiredbythePaperworkReductionActof19807PL96-511.
. Sincerely, -
T. W. B shop, Director Division 'of Reactor Safety and Proj ects ._
T.nclosures: -
A. Notice of Violation B._ Inspection Report Nos. 50-275/E3-37 and 50-323/83-25 with Attachment 1
'ec w/ enclosures: .
P. A. Crane, PGEE W. A. Raymond, PGE 5.*H. Skidmore, PG&E R. D. Etzler, PGE (Diablo Canyon)
- R. C. Thornberry, PGEE (Diablo Canyon) bec: .
1 RS5/ Document' Control Desk (RIDS) -
State of CA
- Resident Inspectors ;
Mr. Martin -
- piak/ green / docket file copies Sandre Silver (report only) ...'
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. dot BISBOP 2g/84 2/29/84 2 84 , - 2/11/84 2/ /84
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APPENDIX A .
NOTICE OF VIDIATION l
Pacific Gas and Elect =ic Company Docket No. 50-275 ;
77 Beale Street I.icense No. DPR-76 1 Room 1435 Docket No. 50-323 l San Francisco, Califor:nia 94106 Construction Permit No. CPPR-69 As a resElt oi~the insqpection conducted on November 14-18 and November 28 -
~
i December 9,1983, and in accordance with NRC Enforcement Policy,10 CFR Part j
- 2. Apptagix C, the foI~ Lowing violation was identified: )
j Section 17.1.5 of the FSAR (dated October 1978) and the Pacific Gas and ;
i Electric Company Qualisty Assurance Manual Section V (dated August 15, 1978) +
i states, in part, that,. " Activities affecting quality shall be prescribed by document'ed instructions, procedures, or drawings...and shall be ' accomplished in accordance with these instructions , procedures, or drawi_ngs...."
Engineering Standard Diablo (ESD) No. 237, " Quality Assurance Inspector i Training Program," dated February 26. - 1974 prtates-in paragraph 2.3 that.,. "All i personnel engaged as Tield QA Inspectors involved in the inspection of
} weldsents, interpretation of Engineering Specifications and Welding i Procedures, and documentation work, shall-be7equired to complete ~an l indoctrination period as described in Section 4 of this specification." ,
i Paragraph 4.1 states that, "The indoctrination period for the Field Q.A. .
i Inspectors described in Section 2;3 shall contairas a min 4==, but not - ~
i necessarily limited to, the following courses:
i Visual Inspection Welding Procedures Welding Inspection Welding Processes Basic Q.A. .
i !
, Other courses offered as optional are: 1 I
I Welding Steae Power Plant Fundamentals j Basic Power Plant Instruction Welding & Piping Engineer. Technology j Introducing Nuclear Power (I . C.S. )
The Visuar Inspection and Welding Inspection teste shall bela~dministered and I
controlled by the N.D.E. Training Officer. All N.D.T. training, l qualifications and certifications will be' covered by ESD-235."
I i
! Parag'raph 4.2 states that, " Tests .used. for .the indoctrination courses for I I
Field Q. A. Inspectors shall be: l 1 For Basic q.A. Test-ESD's. l 2'. . .For Weld Procedure Test-Approved Welding Procedures. . l
- 3. ~ For the Wald Process Test, Welder Qual.ification Card and Pipefitter's l l Manual. 4
! 4. For Welding Inspection Qualifications, General Welding. Information.
l 5. Visual Insper. tion Qualifications-General Dynamics NDT Introduction." ,
I
%fWh*AT i ,
- --,----.--..----,#,- r,--'w----w-~~ - ---~~~~~--
i i, .
+
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g e.
A Nuclear Services Corporation (NSC) Audit dated October 27, 1977, identified in Criterion IX, Finding No. 3 (of the audit) twenty-eight individuals which were alleged to have begun performing their duties without fulfilling the Pullman Power Products procedural requirements for certification and qualification of Quality Assurance (Welding) Inspectors.
Contrary to the above requirements of the FSAR and Pullman procedures, the inspector identified on November 15, 1933 that in virtually all cases the !
individuals hired after September 25, 1973, named in the NSC audit finding ,
(who were assigned to perform welding inspections), began inspecting and '
accepting weldsents, before completing the required training, taking the required examinations, and before being certified as a welding inspector. It is noted that the Pullman Power Products response to this Nuclear Services Corporation finding states, in part that, "All current inspectors have.been qualified by test as outlined in ESD-237. The requirement for qualification and certification of field inspector were added.in ESD-237 on September 25, 1973 to reflect the requirements of ANSI N45.2.6, just published. Persons hired before this time vere not necessarily tested at time of hire.
Subsequent to 1973, the records indicate that all inspection personnel received required training ~and' examination." lii> wever, the Pullman response is silent with regards to inspectors performing inspections prior to certification. -
l This is a Severity Level IV Violation (Supplement II).
I
. Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit to this office within thirty days of the date of .
this notice a written statement or explanation in reply, including: (1) the l corrective steps which have been taken and the results achieved; (2) :
corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
89b Date
. R. L. Canter, Chief i
Reactor Projects Section No. 3
+
. t
, I
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U. S. NUCLEAR REGULATORT CO.ESSION -
REGION V Report Nos. 50-275/83-37 and 50-323/83-25 Docket Nos. 50-275 and 50-323 License No. DPR-76 and Construction Permit No. CPPR-69 Licensee: Pacific Gas and Electric Company 77 Beale Street, Room 1435 g San Francisco, California 94106 Tacility Name: Diablo Canyon Units I and 2 Inspection at: Diablo Canyon Site, San Luis Obispo County, California Inspection conducted: November 14-18 and November 28 - December 9,1983 Inspectors: d. z at.4 & A/ST/SY G@. ernandez, actqf)nspector Date S1Tued
- C
- /W 29 Y R ss, Reactor Inspector Dat.e s'igned
. AM D. T. Kit 1Gh', Chief, Reactor Safety 3 ranch ehs'n' Dite' Signed Approved by:
E. L.' Canter, Chief
) /34/8 9 Date Signed Reactor Projects Section No. 3 Inspection During the Period of November 14-18 and November 28 - December 9, 1983 (NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25).
Areas Inspected: A special, unannounced inspection by regional-based inspectors to perform an in-depth review of selected findings contained in an audit of the Pullman Power Products Quality Assurance Program conducted by Nuclear Services Corporation (NSC), during August,- September-1977. -
Concurrently, the licensee and contractor responses were evaluated to establish whether the outstanding issues identified by NSC were resolved or corrected. '
The inspection involved 402 inspection-hours by three NRC inspectors.
Results: Of the areas examined one item of noncompliance was identified (failure to assure that welding inspectors are qualified and certified in accordance with procedural requirements, paragraph No.17).
l
~H d ',41p &$
I
l DETAILS i
1
- 1. . Individuals Contseted -
1
- a. Pacific Gas and Electric Company (PG&E) i
- - R. D. Etzler, Project Superintendent j
- *D. A. Rockwell, Project Tield Engineer * ~ -
i *M. E. .Leppke, Onsite Project Engineer
} ',_
- C. L. Eldridge, Quality Control Maanger (Nuclea1 perations) 0 i *W. K. Glean, Quality Control Supervisor l *T. E. Pierce, Quality Control Englaeer
- M. N. Nores, Lead Startup Engineer
- J. Arnold, Resident Mechnical Enginear -
l
- R. Taylor, Quality Assurance Engineer
- b. Pullman Power Products Corporation (PPP)
! *R. W. Karner, Quality Assurance / Quality Control Manager !
I~ *T. J. Lyautey, Assistant Quality Assurance / Quality Control Manager
- J. Guyler, Internal Auditor I
- Denotes attendees -at.the NRC eriti asnagement meeting on November
. 18, 1983.
i .
No MRC Hanagement Meeting was held with 'the licensee at the l e
, . conclusion of the NRC inspection which ended on December 9,1983.
l
[ In addition, Mr. M. M. Mendoaca, the NRC Senior Resident Inspector, and 1 Br. T. Polich, MRC Reactor Inspector, were present at the exit management l
'. meeting. -
i i 2.
Introduction:
I The Nuclear Regulatory Commission (NRC) staff performed an unannounced j in-depth inspection to review. the validity of the NSC audit findings and evaluate the adequacy of the Pullman and PGEE responses to the NSC audit-
- findings. ,.
l Licensee and contractor actions in-response to the NSC audit findings had
- been previously reviewed by the staff. Inspection Report 50-275/83-34 ,
l documented this inspection and concluded that problems identified in the '
NSC' audit were properly hedressed and resolved by the licensee's Quality i Assurance Program. This previous inspec4em did not include an in-depth l review of each and every MSC audit findias; but instead evaluated the '
! results of the licensee's and PPP's response'and specifically addressed l three particular NSC finding's that required, further clarification. Base'd i
upon Inspection Report 43-34 and other reviews conducted by the NRC
! inspection program, the staff (in October 1983) provided.an affidavit to 4
the Atomic Safety and Licensing Appeal. Board concluding that the PPP
!. Quality Assurance Program did set suffer major breakdowns which could j have significant adverse impact en construction actisities.
g ,
i J
The staff inspection effort documented in this report represents a much !
. more in-depth aramnnation of specific NSC audit findings and their impact on PPP construction quality, assurance.
3
Purpose:
The goal of this inspection effort was threefold:
(a) To assess whether the NSC audit findings represented a major defect in the Pullman or ,P 5E management of quality programs. ,
(b) To establish an additional level of assurance that Pullman Power Products and theE-==ee's responses to the NSC audit findings were accurate, appropriate, .and effective in resolving all issues i pertinent to compliance with codes and regulations.
(c). To assess any NSC audit findings which appeared to identify
~
noncompliance with accepted standards, codes and regulations.
i 4. Scope of Inspection Plan: ,
2
! The NRC inspection effort involved a review of all NSC audit findings ;
j listed in the NSC report issued October 24, 1977. In conjunction, a face
- value assessment was performed to assess the adequacy and' completeness of the responses provided- by Pullman Power Products and the licensee (dated April 11, 1978 and June 16,.1978, respectively) to each of the NSC findings. A selection of the more significant NSC audit findings was l generated by the NRC. These selected items formed the basis for the ' ' ~
i NRC's on-site *w=minations.
l The NSC audit identified 175 total findings. The staff considered that 110 of thess audit findings could be interpreted as apparent
~
deficiencies. The NRC had previously examined three of the NSC audit findings. Those findings are documented in NRC Inspection Report 50-275/83-34. of the 130 apparent deficiencies, the NRC staff selected 47 of the most significant items, giving priority to those findings which could reasonably impact upon construction quality. Thus, about 45% of the NSC identified deficiencies were ev==4nad in an in-depth manner by I
) the staff. (This ex==4ation represents about 70% of the principal j deficiencies cited by the Joint Intervenors in their supplementary motion l to reopen the record on construction quality assurance based upon the I results.of the NSC audit).
- u. .
. - -- v. . . . .
.Those NSC findings selected as high priority topics for the NRC
, inspection were based on the following rationale: ..
- (a) Audit findings which appeared to have the greatest potential for manifestation in poor quality work in the field.
(b) Audit findings which specifically reference characteristics of poor field work practice.
I (c) Those findings'that appear to be in noncompliance with accepted
.s'tandards, codes and regulations. ,
~ '
, , < v.,,. , - . + - ..-a .n.-.,. . .,
.,. ( l j 3 s
Where the NSC findings involved a potential for disputes over NDE results, the NRC contracted with an independent consultant to examine the i field work and records for compliance 'with code requirements. To establish whether adequate control over weld delta ferrite content had
- been implemented in the shop and field, a sample of twenty-five stainless steel welds was chosen and e ==fnad for delta ferrite content. These welds was chosen from small bore piping which contain both field and shop welds. To establish whether inking of numbers onto radiographs was a wide-spread practice or if the NSC finding represented an isolated
- -- l
~ instance,102 field weld radiographs were selected to verify field weld '
and radiographic interpretation adequacy. The 102 welds examined were selected from several of the more important safety systems; including the Reactor Coolant System (system 7), safety injection system (system 9),
4 containment spray system (system 12), main steam system (system 4),
chemical and volume control system (system 8) and residual heat removal system (system 10). In addition, four specific welds, from among those identified in the NSC findings, were en=4nad to establish whether the surface preparation was acceptable for nondestructive examination.
Liquid penetrant testing,of these four field welds was performed to
- ascertain the degree of actual compliance with acceptance standards. The above items were selected to provide an independent feel of the Pullman j'
work, rather than solely relying on information provided by licensee-records.
I The NRC also reviewed the.non-conformance reports (NCR's) and minor
- , variation reports (HVR's) issued by the licensee as a result of an audit, conducted by the PG&E Q.A. department, of the PPP Q.A. program, issued l June 13, 1978.- Corrective actions identified by these NCRs and MVRs were
! , evaluated for adequacy and implementation, and appeared acceptable.
j The NSC Audit Findings selected by the NRC for in-depth examination and
,, the NRC findings are detailed in the following paragraphs.
i
. 5. Criterion I, NSC Audit Findina No. 3: ,
"The field Quality Assurance Organization has performed functions other
'than those described in KFP-1 and KFPS-1; and some functions were outside i ' he quality responsibility, i.e., writing and approving Engineering t
i .
Specifications, performing welding engineering functions, approving
- ' engineering changes. These activa. des raise j qualification of Quality Assurance personnel to ,theperform question of the these ,
functions and the problem of requiring the Field Quality Assurance Organization to i
aud.it its own performance." -
j ,
NRC'T$lnding:
l To resolve this issue.the inspector's ap'proach was to establish who in the Pullman organization was allowed to writ'e procedures or procedure i changes, perform the review 'and approial process for such documents and -
, whether sufficient control was exercised by Pullman in the writing,
- . review and approval process. In addition, the validity of the Pullman
- response was assessed.- -
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. 1 l . . _ , - . , , - - - - - , - . - . - - , - . - - - - - + - - - - - ---,-.----.,---,-.----,_.,.-------------r---------
4 i
The quality assurance program prescribed by the Pullman ASME Quality Assurance Manual procedure KFP-1, and as implemented in part by procedure l ESD 269, apparently allows anyone to be assigned the task of writing i procedures. However, the point of control in this procedure writing process is that the cognizant discipline management is required to review I and approve the procedure prior to issuance for use. For example, the Pn N = Chief Field Engineer is required to review and approve engineering and construction procedures to assure compliance with code, i specification and contract requirements and the Quality Assurance Manager is required to review and approve quality assurance implementing
) procedures. In addition, engineering specifications covering quality i
~ assurance functions are required to be reviewed and approved by the i contractor's Quality Assurance Manager and the licensee. Engineering i specifications may provide -instructions to field Quality Assurance l inspectors, field engineers and foremen. One exception to this is that welding procedures to be used onsite were, and are, required to be j qualified by the Welding Engineer at the Pullman home office, approved 1 and issued by that office, and approved by the licensee's engineering.
Engineering Specifications must also be approved by the licensee.
While the inspector concludes that adequate controls were applied in the
' procedure review and approval process to assure procedure adequacy--a
- stated concern was whether~QA would be involved in auditing for adequacy i a procedure which QA~~ authored, thus potentially auditing their own performance. Quality' Assurance normally audits to assure that the QA program requirements are properly implemented by quality effecting
- procedures and to assure that contract specification and code l requirements are adequately implemented in the field. The inspector
- further concludes that while QA and QC may audit or inspect for implementation of these procedures such action is not considered to be an auditing of their own performance because program implementation is the ,
- responsibility of production oriented organizations.
The inspector concludes that there is no regulatory or procedural requirements. which provide limits as to whom may write procedures. The l
inspector further concludes that Pullman has provided adequate controls j
.to assure procedures are reviewed and approved by appropriate discipline and managerial authority prior to issuance and use of a new procedure.
I No items of noncompliance or deviations were identified.-
6~. Criterion II.. NSC Audit' 7inding No. 4 ' -
"There is no evidence that upper ma'nagement has performed scheduled
! reviews of nonconformance reports, personnel qualifications, and corrective. actions."' !
j l
NRC Findina: . !
The inspector examined the historical records of nine corporate management audits conducted between September 1972 and June 1977. This
~
examination verified that nonconformances, personnel qualifications, and l corrective action were consistently among those activities audited by )
l corporate management. ,
l - .- - -- _-_ _ ._ _ _ _ _ _ _ _ _
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In addition, Pullman Power Products has since provided programmatic improvements and incorporated an on-site management revi'ew systes requiring that the Quality Assurance / Quality Control Manager submit
, monthly reports " Summarizing all significant Quality Assurance events, audits, nonconformances including trends noted, and may offer suggestions for Q. A. program improvement."
i The inspector concludes the historical records of corporate management audits do provide evidence that reviews of nonconformance reports,, _ _
personnel qualifications and corrective actions were performed.
No items of noncompliance or deviations were identified. __.
- 7. Criterion V, NSC Audit Tinding No.1: .
"There is no requirement that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings."
NRC Finding: [
- The inspector determined that Section IFP-8 (revision dated August 22, 1972) of the Pullman Quality Assurance Manual'contains procedures tT be used to establish " Process Planning and Control" for on-site work.
Specifically IFP-8, in paragraph 8.1, requires that "The field process sheet (Figure No.11) serves as a traveler to identify, in sequence, the field work to be done.. -It is used both for the field fabrication of piping assemblies and for the- erection of pipe in the plant." A_ field i process sheet will list in sequence all'significant operations and inspections associated. with a particular field activity. Specific written procedures are required to be referenced, for each operation and inspection listed, to identify those detailed instructions necessary to actually perform the work assignments. Applicable isometric or detailed l drawings and code . requirements are.also indicated on the field process i
sheet. Procedure KFPS-7 (issued December 3,1973), of the Quality Assurance Procedures for. Pipe Supports, establishes a similar " Process Planning and Control" system using 'the Field Support Process Sheet.
1 The inspector concludes the progra's elements of KFP-8 and KFPS-7 did establish that documented instructions and procedures were required to b~e prescribed for control of Pullman's quality related c'onstruction .
aetivities.
- No items of noncompliance or deviations were identified.
l Criterion V,' NSC Audit Tinding No. 2:
8.
"Many activities affecting quality are not described in procedures.
l Among thos- activities are:. hanger package review, pre-heating for. I
, welding, use of Note-0,-Grams, use of . Rejection Notices, and maintenance i
! of Field Quality Inspector Daily loss."
i .
NRC Findiar:
\ .
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g .
N. .
t The .aspector ex en,d the procedures and program instrnetiens that were available for the specific activities identified. !
i The inspector detezniaed that hanger package review is descrhd in ITPS-12 (dated December 3,1973), whi:1 is eenm-med with the final doe ===?ation of pipe supports. II?S-u requires that "all field i fabricated and field installed agports have been inspected, and accepted j drawings are essyiled and indeaed as -+14=-d* by the inclative program 6 instractions. Supplementary requiremsats were W:7 -- 117 incorporated I into ISD-254 (dated December 30, 1977) za .he form of-a docneemt review i checklist to establish a " Guide for assembly and review of hanger i i _
docenatation packages." , _
Preheating for welding is prescribed ir the applicable Pullama " code weld j procedure s==e mcations," whick are specifically referenced $y the field ' l' l process sheet. Iater revisions of the field process sheet and ISD-218 (dated October 1977) included aglification of preheat tamperstare range requirements. !
i i The inspector does not consider it necessary that docements sack as j Note-O-Grams, Rejecties Estices, and laspector Iags be controlled and prescribed by writtaa procedures. These documents are implemesh is?>rmally as sa aid to the quality assurance program management and i provide administrative tools .for statas reporting and recording. The i
! inspecter determined that these documents de met establish regoirements, ;
i procedural instreetions, or final acceptance documentation for quality i j related activities. .Pn11*an's Qmality Assurance Program delimaates those j i procedsres required to be ased for the. inspection and docuestation of
- quality related activities. .
1 -
- In c==r1==ies, the inspector femed the Q.A. program elements-deserN== l
- hangar pachase review and weld yreheat were adequate and set the !
1 applicable code requirements. Note-O-Grams, Bejecties Notices and l l laspector legs are not required, by applicable codes, to be prescribed in i
. , procedures. The Pal'-= and PGEE responses were consistaat with these '
coeclusions. !
No items of meecespliance or deviations were identmed. ;
i T
- 9. Criterios V, NSC Andit Yindiaz Ec. 3:
~
." Many activities ai'ecting quality are insufficiently described in !
- _ procedores.' Ameag these activities are isometric package review, post j l .- welding heat treatment, ass-casformance reporting, aimety-day welder's i les and weekly qualified welder's list, and auditing." . i i
., . MRC Tindian: ,,
o
- The inspector ====4=ad Pali 's Quality Assurance Program to detezzine
{ if the specific activities identified in the ESC Andit Yinding were L adequately and sufficiently described. The, inspector's findings are as i
.. follows l l - . ,
l I l
l ,
~ - - _ _- - - . - -- . .- .- - -- --
7 i
Field procedure ESD-254 (dated May 6,1975) appears to provide an i adequate outline guide for review of isometric drawing packages.
May 6,1975 was the earliest date that could be found for ESD-254.
! While most piping installations had been completed prior to May 1975, the inspector found that the final complete document review of l isometric drawing packages were performed after ESD-254 was in i effect.
Appropriate post weld heat treatment requirements were always :
prescribed by weld procedure specifications. These were further l amplified in ESD-218 (October 1977), as a program improvement subsequent to the NSC audit.
! Nonconformance 'rnporting requirements prescribed by the Pullman ASME ,
j certified Quality Assurance Program Manual Section KFP-10 (dated January 4,1973) and procedure ESD-240 (dated December 6,1973) were consistent with Appendix B criteria. A significant rewrite of ,
ESD-240 in 1978, and subsequent revisions, established additional j detailed instructions to clarify nonconformance reporting aspects. '
l such as documentation, specific personnel responsibilities, the .
1 functional use,, cle:ing-out, and 10 CFR 21 applicability. Pullman '
l Power Products calls their nonconformance reports Discrepancy ~
j Reports, the terms are synonymous.
\ Ninety-Day Welder's Log and Week 1y Qualified Welder Lists are only 3 -
ref.erencedm by_KFP-15_(dated. August 22,1972) and ESD-216 (dated i
.__ June 17, 1976), to figures appended in the procedures. Although desirable, -there were no amplifying
- descriptions on these forms to specify personnel responsibility, functional use, implementation, i scope, etc. , until significant revisions were incorporated into
- ISD-216 (dated July 10,1979). These documents were used to 4
maintain welder qualification status and were maintained by l -
experienced personnel under the cognizance of the Quality l
" Assurance / Quality Control Manager. A review of the application of '
l 90-day welder loss and weekly qualified welder lists did not i
identify any evidence of inconsistencies that would have adversely ;
, affected quality control activities. The Co' d e merely requires that a contractor assure that- welders are qualified but doesn't prescribe' i ,
methods effecting administrative control of this activity. Thus, the inspector finds that Pn11=== did adequately ' tiack welder-qualification to assure Code compliance. This subject is further examined in paragraph 21 of this report. * ~
Internal and Corporate Management audits of the Pullman onsite Q.A.-
program were described by Q.A. manual section IFF-18 (revision
- 8/22/72). The program elements prescribed by IFP-18 were not
- complete and very general in nature. Those areas which appeared particularly deficient.were audit personnel qualifications, audit
{ scope, audit scheduling and disposition of audit records.
, , A corporate procedure (no. XVIII-1) prescribed further instructions ,
i l*
for corporate management audits, ' directed and conducted by Williamsport headquarters management personnel. Corporate audit procedure No. XVIII-1, provided the detailed instructions for
- ,._g . ., .,.n.. ,.,.-e-- , . , - , , - - - , ,,-..,w-.m, , , - - - , ,m, _-,,,,-g, ,_..-.-,..m._,..,-,--,,-,-,-~_n,ew-,-e----u---,_ .m
, L .
8 <
s conducting the management audits required by KFP-18. A review of I corporate management audits, performed in accordance with Procedure l XVIII-1, reveals a history of Quality Assurance Program audits based i upon checklists following 10 CFR 50 Appendix B criteria. This l established a comprehensive corporate audit system which appeared to review all field Q.A. program facets. Thus, for performing
. corporate management audits, Procedure XVIII-1 did provide effective
! amplifying instructises to implement the general elements of KFP-18.
l There did not exist any comparable detailed procedure to implement l
" internal" audits required to be performed by on-site Quality ,,,
j t Assarance personnel. A staff review of internal audit records prior to the NSC audit indicates that all aspects of the Pullman field j Quality Assurance program were not being addressed. This deficiency 1 was also clearly identified by a licensee audit of Pullman and i subsequently documented on nonconformance report No. DCO-78-RM-004 j . (dated October 1978). Pullman's resolution included a rewrite of i
!
- IFP-18 and development of an internal audit procedure,' issued as i
ISD-263, dated June 26, 1978. To further provide for audit program j consistency, the corporate audit procedure XVIII-1 was incorporated
! into field procedure ESD-274, dated yebruary 19, 1980. Adequate corrective action was implemented to assure that all Q. A. fie44 program elements were scheduled for internal auditing ~(as of June f l 1978). Records of subsequent internal and corporate audits verify j that no asjer breekdeem of the-Quality Assurance program had i occurred, nor had any significant problems gone undetected, due to )
! the deficiencies identified with the internal auditing program.
j ." '
i In conclusion, the inspector determined there were adequate controls !
j whiah prescribed requirements for isometric package review, post welding i he . treatment and nonconformance reporting. Further, the practices used I l by Pullman in implementing the ninety-day welders log and weekly
( qualified welders list effectively accomplished the intent of these i, activities even though specifics regarding how these activities were to I be performed were not prescribed in detail by procedures until July 10, l 1979. Eeen though the internal audit program, implemented by on-site
! personnel, (prior to 1978) was determined to be of a marginal quality, a l redundant program of comprehensive corporate audits was performed i
concurrently. Based upon an ===4mation of the findings identified in corporate ame internal audita, there did not appear to be.any adverse i impact on quality related activities as a result of the inadequate ,
description of the internal auditing program. The inspector concludes !
that, with bo'th programs operating simultaneously, sufficient records are l
, evailable to assure the necessary criteria of Appendix B were being !
audited periodically. This conclusion is based, in part, on the absence of recurring significant audit findings.
. l No items of noncompliance or deviations were identified. ,
- 10. Criterion VI. NSC Audit Finding No. 9a:
"For Isometric 2-14-77: The Process Sheet was changed to show the completion of IV-192 on April lo and April 11, 1974, approximately 19 ;
l months *after the work was done." .
v-m-r,-- ,-,,--.---~.n ++,-~.n_---- _ . - - , . . . , . _ - , , , , _ _ _ _ _ _ , . _ , , , . . - . , . , . , , , , , . , . . , . , , , _ . , . , _ , , , , _ _ _ , , _ .
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1 i
l NRC Finding:
1 : \
l' The inspector found that even though the NSC audit finding identifies the !
- incorrect isometric package, presumably due to typographical error, the i 4
Pullman response correctly addresses the intended isometric package, !
l i.e., Isometric Package No. 2-14-47. Examination of isometric package l 1 no. 2-14-47 indicated that FW-192 was completed on April 11, 1974, as i indicated by the signing and dating of the line item by the Pullman ,
l welding inspector. The signature and date were in ink and the inspector !
' ~~ ~
could not find any evidence to indicate that the completion date or
, , signature had been altered or that any attempt had been made to alter the i signature and data. The weld was liquid penetrant examined on De' cember
{ 2,1975, found acceptable, and the line item for the non-destructiLve 4 ===4=ation on the process sheet was then signed and dated. Examination j of the I,iguid Penetrant F==i== tion record indicated that both the i signatures and. dates on the process sheet. and the I.iquid Penetrant I j Examination Record were in ink and no evidence could be found to indicate i
that there had been an attempt to alter the dates or signatures on either j or both of these documents. ,
i s Therefore, the inspector could not corraborate the NSC auditor's finding '
- that the date for completion of W-192 had been changed or backdater.
f No items of noncompliance or deviations. were identified. t i
l 11. Criterion VI. NSC Audit Findian No. 9b
~
l " Isometric 2-14-8: W-1673 was performed.to Revision.2 of-the isometric, i
. which did not show W-1673. Revision 3 of the isometric, which included i the W-1673, was generated approximately one week after completion of the i weld. It is therefore concluded that FW-1673 was performed without the i normal controls of a Process. Sheet, a weld procedure call out and a ,
I -
call-out of NDE requirements,"
l . -
l NRC Tindinz:
'. inspector examined the.various contractor pr6cedures and documents i
- The i l that existed during the time frame in question to determine whether the
! , design change control system was circumvented by the Pullman Quality j Assurance Inspector which allowed or directed, the welding of a valve to a capped pipe. The inspector examined Isometric No. 2-14-3 which in .
Revision 2, dated December 11,1972, .shows a capped'. pipe -(tezued a nipple)..and in Revision 3, dated May 29, 1974, the required valve and vent;(actually a capped pipe),are depicted. Revision 2 of the isometric dirawing did not show W-1673. A review of the weld process sheet '
indicated that the weld (N-1673) was completed on May 24, 1974, five l
. days before the issuance of revision 3 to the isometric drawing. Thus6
- the inspector concludes that W-1673 was made prior to the issuance of , I revision 3 to the isometric drawing. However, it appears that the !
installation of W-1673 was accomplished in a controlled manner as described bel,ow. ,
The inspector examined Pullman Quality Assurance Instruction No. 52, dated December 13, 1973 which states that, "Due to a shortage of valves
i'
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l .
' N. ,, , .
- used for vents and drains at this complex, it has become necessary to i instan twelve inch nipples, capped on end, to facilitate flushing." .
Subsequent to instruction no. 52, on March 8,1974 an apparently generic discrepancy report (Discrepancy Report No. DR 2100) was written in an effort to expedite the instanation of vents and drains in erected pipe.
Iten Mo. 3 of the approved disposition of the discrepancy report states i that, "All welds added for this change win be recorded on the process sheet and isometric. An added weld senbar selection vn1 be coordinated i between drafting, Quality Assurance Inspector, and Engineering." Itas I J
Bo. 4 etatee-that, " Engineering is to notify the area Quality Assurance 1 Inspector prior to starting instaustion of standard vents and drains."
j Therefore, it appears that the Quality Assurance Inspector was in contact
~
wit lh Ehgineering for the installation of vents and drains and welds were i required to be recorded on process sheets. Thus, the inspector concludes -
that the licensee and Pullman adequately controlled and docusented the .
) instanation of nipples, in place of the required vents and drains.
! Furthermore, the inspector concludes that the licensee and Pullaan r adequately contro ned the restoration of the systen to design !
l configuration by. adding the required vents and drains when valves became
- l
- available. , ,
1 4 A process sheet for field weld, W-1673 is contained in Isometric No. j 2-14-8, as required. Therefore, the inspector concludes that rw-T6'is was performed using the normal control _s, of a process sheet. , , , ,
i Turther, Pullman procedure ESD-239, dated April 2,1974, states in
- paragraph 2.1 that " Piping systems shan be closed out.by. Quality ~
1 Assurance Inspectors. Piping shan be checked when necessary against ~
l PGEE area drawings, Section 3 of Specification 8711 and:the PG&E flow .
l
. diagrams. An missing or incorrect itans shall be recorded on 'a punch
! list and D.R. (discrepancy report) written if required." ESD-239 further j states in paragraph 3.1 that "The fonowing is a guide for Quality i Assurance Inspectors when closing out piping systems" and proceeds to state in paragraph 3.1.2 to " Check field run pipe and fittings for correct materials, rating and specifications when.so identified," and in paragraph 3.1.15 to, " Check that instrument connections, vents, drains and plugs are installed per the Isometric and now Sheets." Therefore, it appears that Quality Assurance Inspectors were required to verify ,
l conformance to PGGE design drawing (now Sheets), and to record any :
I discrepancies. The field QC inspector, in conjunction with Puuman Eng'ineering, had apparently accepted the instanation"of W-1673 knowing l that the nest isometric revision would be update,d to correspond to now l l .
' Sheet requiements. .
I
~ -
f A comparison of the contractor operated Isometric'No. 2-14-8 to the PGaE
! now Sheet (PGEE Drawing No. 108014) indicated that the required valve i
! and vent were depicted on the line referenced on Isometric No. 2-14-8. l
!* Therefore, the weld (W -1673) attaching the valve and vant was, at least
! implicitly, required on the PG&E now Sheet (No. 108014). It ' appears l
! that the valve and vent were not instan ed on the line'due to the shortage of valves, as stated in the aforementioned Quality Assurance l Instrueden No. 52. Bowever, adequate provisions had been nede for the . j i , .
subsequent instanation of the valve, as shown by the installation of the :
nipple an6 cap depicted in Revision 2 of the isometric. A check of one l
- - , -,.,.4--,- ,.--.,.-,--w----n.--.~m-.----.---.--.-w. ,.-~r , . . - - - __ m---. ,v,-v.- -,,v %- - . . . . . , . _ ~ -. -.,--w._
4 O'
- c .
i 1 ~
31 l t l
\
j other line with a similar configuration (there are four similar lines '
i j -
with valves and vents in the same area) confirmed that a~ similar l
situation had occurred for Isometric No. 2-14-6, Line No.1759-6 (i.e., j i the weld had been made and completed before the revision to the isometric l l
depicted the weld). l
}
j Additionally, the inspector verified that, in the time frame in question, a method existed to maanze that the proper welding procedure was used for the p4pt io v1 13e. weld in question. The inspector found that ESD-227, dated December 20, 1973 provided a chart indicating the proper weld .
- procedure for different materials and configurations required. For this ,
i case a socket veld was required and weld procedure no. 92/93 was the :
) weld procedura needed and used. A review of the process sheet for !
- W-1673 confirmed that weld procedure 92/93 was used. -
i l Finally, the inspecter verified that contractor originated . drawings (for example, isometric drawings) are reviewed by the Engineer (PGIE) for
- conformance with the PGEE design drawings. The PGGE Drawing Control
+
Procedure, dated September 11, 1972, paragraph 3.11 (Contractor's Field ,
Drawings and Procedures) states that " Drawings that are drawn by the !
contractors onsite (Lift drawings, piping isometric, hanger drawing, l etc.) are submitted to PG&E onsite office for approval. These drafings j are checked by PGEE drawings. They are returned to the contractor with i
- the stamp (no. 6).below noting _the appropriate condition of the drawing."
Isometric No. 2-14-3 was stamped as approved, therefore indicating review l
and acceptance by the . licensee. ;
l !
} In conclusion, it appears that under certain conditions welds could be I added (through coordination with the Quality Assurance Inspector and the i
} Engineer) which did not circumvent the then existing design change
! control system. Furthermore, these additions were accomplished in a l
- controlled, orderly and proper manner. .
4 j W-1673 was completed using 'a weld' process sheet, a welding procedure was .
j specified, including identification of necessary nondestructive !
! examinations. Further, while W-1673 was not depicted on the contrsetor
! . generated isometric drawing, revision 2, the weld was implied to be !
I necessary by the PGEE' generated and approved Flow Sheet (Drawing No. -
l l . 10:014) and the inclusion of W-1673 was accomplished and documented in a l l controlled manner. -
- ,,.No items of noncompliance or deviations were identified.
. ..-~ _
i
.12. Ciriterion VI. WSC Audit Tindina No.' Sc: .
" Isometric 2-14-53: W-247 was. completed on February 20, 1975. l Approximately December 1,1975, the visual . acceptance was signed off and
'- - .. backdated; the Wald Rod Requisition was changed to show that more than '
the original quantity of one had been burned."
NRC Findios: . .
f i The inspector examined the daily work los of the Pullman inspector who l performed the inspection'on W -247. The daily work los records indicate
. i o
? . ; 12 l that the inspector did perform the final inspection of W-247 on yebruary j 20, 1975, as stated in the Pullman response. Therefore,'the inspector 1
-does not consider this to be an unauthorized, or improper, backdating ,
l because the signature reflects the actual conduct of inspections.
i
{ Ima=ination of the Weld Rod Requisition records indicated that the j guantity of weld rod was changed on one weld rod slip as stated by the NSC auditor, however the change was initialed by a Pullman inspector.
j The change to the Wald Rod Requisition slip was apparently made because ;
4 - --*
- the Pullman inspector entered the number of weld rod returned on the i j wrong line item and subsequently changed the line item to reflect the jI correct conditions. It appears that the condition was caused by an error, which was later caught by the Pullman inspectors. The inspector -
l'j considers this acceptable in that the record was apparently modified to reflect the actual conditions existing. NRC examination of approximately 1 l one hundred weld rod requisition records contained in isometric packages <
j Nos. 2-14-77, 2-14-47, 2-14-8, 2-14-53, 2-14-59, and 2-26-417, did not :
- identify any similar conditions.
The inspector concludes that this iten does not represent an instance of unauthorized changing of quality related documents and that the changes ,
- made had been made with adequate basis and reason. _
l J
j As a side issue, it was reported (in Pullman's response to this audit i finding) that this problem had been found as a result of an internal i Pullman audit. The inspector reviewed Pullman's internal audits and I could not verify the Pullman audit response. It appears that the I
discrepancy was found by Pullman as a result of the documentation review of the isometric package. This minor inconsistency in the Pullman response is not considered to be significant.
No items of noncompliance or deviations were identified.
, ,, 13. Criterion VI. NSC Audit findina No. 9d:
I
" Isometric 2-14-59: W-268 was completed February 5,1975. On December 2,1975, the entry on the Process sheet for removal of dans was signed j off and backdated. There is no proof that the dans had been removed."
t l NRC Findina: , , ,
i The inspector found that FW 264 is a Code Class 3 weld which the records indicate was' made with .the,use of a bacusa ring, thas, no dans were to j ,be used. The signing on the line entry for dam removal, by the Pullman
- inspector, appeared to be _an oversight on the part of the Pullman -
i inspector. Examination'of Isometric I/ackage No. 2-14-59 indicated that a
{ ,
Warehouse Requisition Record specifying a b>'. sing ring for W-268 was l coatained in the package. The inspercr could not verify the December 2, 1975 date, when supposedly the backem u g occurred.
! ,, The inspector did find that, apparently in response to the NSC finding, the Pullman inspecter did cross ouc the "Ramove Dam" entry, wrote "not
! applicable", dated and signed this line entry on December 7,1977. This
! same Pullman inspector also found that he had performed the same error on j ,
i
1
- i 13 I
- IV-269, which is cantained on the same isometric package. The Pullman
- : inspector than crossed out, wrote "not' applicable", and dated and signed i this line entry on Recember 7,1977.
j Examination of five isometric packages, by the NRC inspector, identified three other similar cases wherein a different Pullman inspector had I signed the " Remove Ass" line entry, when in fact a backing ring had been l j used. Isometric package so. 2-14-53 contains W-246 and M-247 and. I
} Isometric package us. 2-14-47 contains FW-196, which have similar i discrepancies.
1 1 ,
! The inspector coachsdes that no safety significance can be attributed to j this MSC finding and no purpose would be served by reviewing and i correcting any other similar record discrepancies. The NSC finding I appears to be the mesult of errors by pullman inspectors, who .
subsequently correasd these errors to indicate the actual state of ,
activities. 2he inspector does not consider this to be a QA program 3 deficiency; rather, these appear to be instances where inspection !
personnel were trying to.show that no dan was installed as opposed to actually removing a dan.
- l j .
l No items of noncompliance or deviations were identified. -
I
- 14. Wrfon VI. MSC Audit Findinz No. 9e; j .
"Insetrie 2-26-417: FW-144, 145, 196, and 197 were completed on May 14,.
1976. The Wald Rod Requisition had been altered to add FW-197. However, l the Weld Rod Requisition shows that 14 rods'had been burned, which seems
. improbable for the four welds that were supposedly welded."
f
, NRC Findina: -
f
. '. The inspector verified that the H.W. Kellogg (Pullman) Field Warehouse Requisition record indicated that four 3/4" sockets were issued on May 13, 1976 and welded on May 14, 1976. It is the inspector's opinion that j ,14 weld rods provida sufficient weld rod to weld the four 3/4" socket l , welds referred to by the NSC finding. The inspector examined Pullman j procedure ESD-202, ested April 28,*1975, which states in part, in l
- paragraph 3.2, that "For socket welds, up to four welds may be put on one i requisition (weld and requisition slip)." The. inspector did find.that all four socket we34s were documented on one weld rod requisition slip.
~
' The inspector conc 3mded that this NSC finding has no safety significance and was in accordassa with existing procedures, j
(
- No items of noncomptiance or deviations. ware identified. !
- 15. Criterion VI. MSC tedit Findina No.10:
I .
"No procedure or regmirement' prohibits the changing or alteration of the !
records and docusess that are necessary to track the work. Field >
Process sheets, WeM Rod Requisitions, inspection records, etc., should -
not be changed or esuld be changed only by Quality Assurance supervisory personnel and then signed and dated." - *
..m. _ , . . . _ _ ___.,-.-._._...,....,.,_,.m. __-c._,_r_,.,_.. . .,,_.-__,,,_,.c _.... -._m.._,_,_,.,...,-..,____m.-.,
. - _ . . ~ - - . . _ - - - - - - -- -- -
i d' -
i, . I r 15 i
NRC Tinding: l 2
The inspector reviewed the historical file for ESD-223, " Installation and {
Inspection of Pipe Supports" and, specifically, the extensive revisions that occurred on November 11, 1975 and May 25, 1976. The inspector found [
l that the procedure revisions contained adequate Quality Assurance / Quality l l'
Control instructions for the control and identification of Class I pipe j supports. Additionally, the inspector found that other existing l
procedures, contained in the Pullman Quality Program, provided additional ,
j or amplifying instructions for the identification and control of Ciss I ;
piPe supports. * -
l
- ) ^ '
f No items of noncompliance or deviations were identified. [ l l 17. Criterion II. NSC Audit finding No. 3: ,
4 "The qualification and certification program for NM-and inspection i
personnel has been inadequate. The records of the following personnel
, were m M aed: D. R. Geske, T.1. Koch, J. E. Cavalti, G. P. Keeler, E. E. Beck, L. Glass , W. R. Johnson, E. Stanton, C. B. Athay, R. G. i Sears, D. S. Tutko, J. N. Shironizu, V. J. Casey, J. A. Brasher, L. T. l Myrick, S. R. Stanley, I. Guest, D. E. Bentley, R. D. Iincade, K. IL, Guy,
- J. R. Rowlby, E. R. Jennings, A. L. Newton, C. C. Lenzi, J. J. Sisk, L.
- E. Thomas, A. A. Conques, and R. L. Marks. In virtually all cases, the
- individuals began performing their duties without fulfilling the
i specified requirements. The most prevalent discrepancies are: not l l completing the required training, not having proof of previous l experience, insufficient ~ time as Level I, unsigned tests, and !
l insafficient background and experience." l NRC Tindina: l i
! The inspector' exanised the procedures for qualification and certification of non-destructive examination and inspection personnel thap existed in Pullman's program before September 1977. These are Engineering Standard-Diablo (ESD) No. 235, " Nondestructive Examination Personnel Qualification and Certification Procedure," dated September 25, 1973, and EsD No. 237, " Quality Assurance Inspector Training Program," dated February 26, 1974.
l The requirements for qualification of Pullman inspectoes must have been j revised er amplified on or after September 25, 1973. This is based ea the Pullman response, to the above NSC audit finding', which states in ,
! . part, that "All current inspectors have been qualified by test as outlined in ESD-237. Requirements for qualification and certification of field inspectors were added in ESD-237 on September 25, 1973 to reflect
. the requirements of ANSI N45.2.6, just published. Persons hired before .
i this time were not necessarily tested at time of hire. Subsequent to 1973, the records indicate that all inspection personnel received required training and examination." A review of the ESD-237 historical file indicated that a prior revision had occurred on May 1,19,6f, however, no procedure revision could be found which was specifically dated, September 25, 1973.
___ _ - - . . - . - . - - . . - . - , . ---,-,--------%-m -
--.w-w,ww__...,.-m_,-,. --y,_,__m. _ __,--,,_,.-,.-.-~y,-.,m%-._-,.
~
3Gd * :. k.h n .g
? y - ~, .
. 14 NRC Tinding:
A review, by the inspector, of historical procedures indicates the NSC audit finding is substantiated in part. Prior to 1977, insufficient requirements existed to control the changing or alteration of quality records and documents specified in the NSC finding. The ASME certified PPP Q.A. manual program elements describing field process sheets, weld rod requisitions, and inspection records did specify the qualified personnel responsible for filling out tr-re.vieing these documents; however, there was no concise administrative Q.A. program instructions w:-itten to control how ' changes to Q.A. field documents would be implemented. This concern had been freva.ohsly addressed by Pullman's own corporate management audits, which identified a few findings of editorial changes made to Q. A. field documents without adequate administrative controls.
In response to the NSC and Pullman corporate, audits, several on-site Pullman QA procedures were revised to provide more explicit administrative controls. ESD-254, entitled " Document Review", was revised on December 30, 1977 to establish for records, process sheets, requisitions, and reports that " corrections, if made, shall be initialed and dated by the responsible individual". The scope of change requirements in FTP-17 (dated August 31, 1977), the QA Manual chapter on revisions and deled ons,. was broadened to also include all field procedures (ESDs). Corrections and/or changes of field process sheets, according to ESD-264 (dated September 15, 1978), titled " Process Planning and Control," shall be initialed and da,ted, and limited to specific
, qualified personnel.
Neither the NSC nor the Pullman corporate audit findings, nor the staff review, identified any unapproved technical changes or other substantive changes which would have adversely affected construction quality.
Rather, .the issue of concern merely involves editorial field changes made to Q.A. documents and records completed ' prior to 1977 and the NRC finds
, that this concern has only minimal. safety significance.
~
Therefore, the inspector concludes that Pullman Q.A. took effective corrective action to correct the programanatic concern identified by the NSC audit and previous Pullman corporate audits.
In conclusion, the inspector determined that Pullman Q.A. took effective corrective action in addressing the programmatic concern identified by the.NSC audit and previous Pullman . corporate audits. Purthermore, there is no evidence in the NSC, PGEE and P=1Mn corporate audits to suspect that any field changes made to pre-1977 documents and records 'impacte'd adversely on the quality of field cons'truction.
No items of noncompliance 'or deviations were identified.
- 16. Criterion VIII. NSC Audit Finding No.122,
- " Procedure ESD-223 does not give adequate instructions for the identification and control of Class I Pipe Supports."
O
16 ESD-237, dated February 26, 1974, states in paragraph 2.3 that, "All personnel engaged as field QA laspectors involved in the inspection of ;
- weldseats, interpretation of Engineering Specifications and Welding i Precedures, and documentation work, shall be required to cesplete an i indoctrination period as described in Section 4 of this specification." .
Paragraph 4.1 states that, "The indoctriaaties period for the Field Q.A. !
laspectors described is secties 2.3 shall eestain as a =4=4=, but met
" aseessarily limited to, the fallowing courses: 7 1
- ~ ' - -
Visual Inspecties Welding Procedures Welding laspecties Welding Processes
. [, , , .
. Basie Q.A. .
I', other eeurses effered as optiemal are: .
Welding steam Power Plant Fundamentals
, Basic Power Plant lastrue. Welding & Piping Eas. Technology
- Intredacing Nuclear Power (I.C.g.)
The Visual Inspecties and Welding Inspection tests shall be adaimistered and centrolled by the M.D.E. Training Officer. All N.D.T. trainias, qualifications and certifications will be eevered by EgD-235." Th e ses ,
NDE and NDT are synesynous and refer to acadestructive esaminaties. l
[
Peregraph 4.2 states that testa used for the indoctrinaties courses ter (
Field Q. A. laspectors shall be j
. t l'.~ for Basic-Q.'A7 Test *EgD's.- , l
- 2. For Wald Procedure Test-Approved Welding Proceduses. (
- 3. For the Wald Process Test, Walder Qualificaties' Card sad l Pipefitter's Naamal. i e 4. For Welding laspecties Qualifications, General Walding Informaties. !
- 5. Visual Inspecties Qualifications-General Dynamics NDT Introducties. i Emanimation of EgD-235 indicated that although this precedure is a mondestructive perseasel qualificaties and certificatise procedure, the procedure mise describes levels of qualificaties for visual inspecties I perseenal, the type of emanisaties, the musher of guestions, and the !
acceptable grade for the esaminatism. Additiemally, a welding test j regairement is contained in paragraph 11.2.14 which states that, "A l eembinaties of General, Specific, and Practidal ====4=ations will be ' i gives using the Diable Canyon Welding Seminar Test Paper, eestaining 66 l guestioat."' ,
Therefore, it is spparent that Field QA laspectors were required to be i indoctrinated threesh a program of courses related to their job functies, imeloding visual and welding taspecties tests administered and controlled by the NDE Training Officer. Disenssions with contracter perseasel indicated that, in the pre-1977 time frame, the trainias officer centrolled all perseemel eartifications, with me distincties being made
.. between NDE and welding inspecties perseasel.
The inspector esamined the personnel files of 20 of the 28 individuals named'la the NSC sudit, sempering the date when eseh individual started
l '. 4 ; -
. 17 employseat with Pullmaa Power Products versus the date each individual
+
started accepting work. This esaminaties ceafirmed the'N10 audit finding that la virtually all cases, weldiam Quality Assurance laspectors begaa perfoming their deties without fulfilling the specified requirassets and withest completing the required trainias. Two amaaples are as follows:
Y. J. Casey beses employeest with Pallana power predacts se Neosaber 19, 1973 and beges accepting weldmaats is Neosaber,1973.
So was met certified as a welding inspector astil February 27, 1974.
, E. R. Jemaings begna employeest with pullmaa power products sa Jassary 16, 1974 and began accepting weldments em Jasmary 22, 1974.
Be was not certified as a welding inspector antil April 21, 1974.
Additiemally, .two other inspectors were feend to have questionable bachareenes which, is the inspector's epimies, weald met warrest their immediate certificaties as welding inspectors. K. D. Guy had esammetatty me background la quality eestrol/gmality assurance, yet withis two anoths was a fully certified inspector accepting weldmaats. A. L. Newten had some backgreemd in the aircraft industry, but a lapse of several years had occurred between the time he had tessiasted his employment in the aircraft industry and the time he begaa empleyanat with Pullaan. Es withis two meaths Newton was accepting waldseats. - Both of these individuals had takes several, but mot all, of the regaired welding esaminaties tests specified in EgD-137. Therefore, both of these individuals aise begas performing their duties witbeat fulfilling the specified requiremonta and.withest campleting the required traiatas.
h failure to assare that Quality Assurance laspectors were geslified and certified La accordance with the centracter geslity procedures is censidered as apparaat item of asaceay11ance (50-275/313/83-37/03).
It should be seted that forLall perseasel files enemined, with the encepties of Nessrs. Guy and Newtes, all. individuals appeared to be esperienced, with adeguate backgrounds either in weldias or la the area
. of geslity centrol inspecties. ,
h laspectors review of perseemet files further comeluded that pallaam
'. M perseasel were properly certified and had met metapted or perfossed work prior to being certified is steerdance with Pallana procedures or eedes. '
I h taspector concurs with the NBC audit finding that welding inspecties perseasel perfereed inspections prior to being certified. . h inspector does met esseur with the NBC finding that M pereennel perfereed meadestructive emanimations prior to being certified.
- 18. Criteries II. NgC Andit Findima No.10b "The Ninety-Day Waldes%' Les was met asistained free Angmat,1972 to December, 1972. hre is no Weekly Qualified-Welders List for that time period to embetaattate that the wel4ers'were actually geslified.'
j - .
t 18 l .
1 NRC yindias
- 1 1 I The inspectors approach to resolving this issue was to examine the 90 day i welders logs to determine whether the alleged gap in the los exists, to determine the basis for establishing the weekly qualified welders list, i l to determine whether the weekly list is available for the above time j period and, if not., the reasons for the ansvailability.
i i The inspector ==dmad the 90 day walder's log and found that no void i existed between g/72 and 12/72. While it is true that no weekly --- -
- qualified welders list exists for that time period, the basis for j establishing the weekly list is the 90 day qualified welder's log. .
{, Eowever, the inspector notes that the weekly qualified welder's list 1({~
not a document requiring retenties by the Pullman Quality Assurance ~ !
) program. The 90 day welder's los provides documentary evidence of welder !
performance during a specific period, to assure qualification within code requirements. . This los is based upon weld filler metal withdrawal sheets and the welder' qualification records. Therefore, the inspector concludes i
that, based upon the records available, no code or procedural violation can be determined because the 90 day welders los existed for the time period referenced by the NgC audit and the weekly qualified welders list j'
4 The NRC considers this practice is not required to be retained. -
acceptable.
No items of noncompliance or deviations we-e identified. _
i
- 19. Criterios IX, W3C Audit Findina 10c: ..
"The Ninety-Day Walders' Los is not sufficiently detailef tEdetermine E :
the welder is qualified to perfora certain procedures. The Ninety-Day [
Walders' 143 has been revised a number of times, and the ~ detail has 6 j improved with each revision. Previous to the latest revision (November, t
! 1974), the log was very poor in giving precise information relative to j procedure and thickness ranges to which the welder was qualified." ,,
i .
i NRC Tindias:
I The inspector's approach to resolving this issue was to ==ad== a l representative sample of the early.90 day qualified welder's' loss and'
- detesmine 'if the information contained was su(ficient to conclude that a welder wes qualified to perform certain welding procedures.
L a
! The 90 day qualified welder's loss for the period frasi 1972 through 1973
! " ' .were saarised. The los identifies the walder, weld stasy identifier, the
' procedures which the welder was qualified to perform, and the welding process (i.e. , metal-arc, insert, Gas Tungsten Arc for both carbon and
- . stainless steel, and Gas Metal Arc for carbon steel). qualified to .
l perform. Process use in the 90 day los was, and still is, determined
! from a review of weld filler metal withdrawal sheets.
I .
I The inspector discussed the Pulless method of tracking welder ,,
qualifications with the Code Authorized laspector who was easite during the early constructies years. The fosser Anthorized Inspector stated
! that b's reviewed the Pullman methodology for documenting welder i .
{
i .
1 19 i
$ . qualifications and was satisfied that th Pullman method had been I -
acceptably implemented. '
l
. The inspector observed that the 90 day qualified welders log form had j . been frequently revised to provide more information; including qualification coupon wall thickness, and specific (versus general)
! identification of procedure and process as the misaber of welding procedure specifications in use expanded. In the early days of j construction the number of specific welding procedure,s was,small with ,
j these procedures being refined and narrowed in applicability as )
l
- construction progressed and experience dictated t
- l. _.
}' The inspector finds that the 90 day qualified welear's log was sufficiently detailed to determine whether a welder was qualified to
- perform certain procedures and complied with applicable code requirements. Weldment thickness a welder was qualified to perform was added to the 90 day los as a result of an NRC concern during the later i
phases of construction, in order to clarify welder's qualification to make welds on limited or unlimited thickness sections. This was not a 1 j critical addition since other means existed to establish each welder's l thickness qualification (ie: the original qualification record). ~
\
i No items of noncompliance or deviations were identified. . l l
- 20. Criterion IX, NSC Audit Finding 10d:
)i "No procedure states what the Field Quality. Assurance Inspector uses as the primary means to determine welder ghalification, the Ninety-Day j -
Welders' Log, the Weekly Qualified Welders List, or the Welder's
- Qualification Card."
i-t
. NRC Findina: ,
The inspector's aipproach to" resolving this issue was to evaluate the validity of the NSC findins and Pullman response.
j
. The ASME QA Manual, procedure IFF-15 (Welding Qu'alifications, dated j August 22, 1972) generally describes the responsibility and methodology -
used by Pullman in assuring dat welders are tested, qualified and issued i .
!' a stamp. ESD-216 (Welding Performance Qualification) is the implementing procedure for the welder qualification process. Neither procedure l describes precisely what the assigned Quality Assurance Inspector uses to 1 determine whether a welder has used a specific process and is thus l qualified; however, discussions with the former Authorined Inspector and '
j Pullman personnel who have been onsite since the early 1970, indicate j that weld filler metal withdrawal sheets had always been used to
] determine whether a particular welder had used the specific process l during the previous 90 days or whether he had used another process during j the extended 6 month period, specified by. the ASME Code, immediately ,
j prior to the point in' time under consideration.
The inspector finds that no Pullman procedure identifies what the field l
Quality Assurance inspector uses as a primary means to determine welder j qualification, bewever, the practice utilined by Pullman was generally
l
- 20 '
! well known by both personnel and management assigned primary responsibility for tracking welder qualification. Furthermore, the inspector esasiders that the method historically used by Pullman (i.e. ,
weld filler metal withdrawal sheets and welder. qualification records) was sufficient and adequate to document and verify welder qualification, as j required by the AstE BriPV Code,Section IX.
No items of moncompliance or deviations were identified.
- 21. Criterion II, RSC Audit Tin'diEn 10E 1 ; _ _
"No procedure specifies wb_is . responsible for the Ninety-Day Welders' f I43, the Weekly QualifiedWelder's List, or the Welder's Qualification l Card; how the information is obtained; how the logs are used; to whom they are distributed; etc." ,
2 MRC'. Finding:
) i l The inspector's approach to resolving this issue was to assess the ,
validity of the NSC finding and Pullman response, examine the applicable !
{ procedural requirements and practices employed and assess the adequacy of ;
l the findings for compliance with code requirements.
! As described in finding 10.d, above, the inspector ===4=ad (1)
I procedures KFP-15 and'ESD-216, and (2) the 90 day qualified welder's loss j from 1972 through 1978. The inspector found that the 90 day log was '
continuously maintained, except for the strike during June-November, 1974. All welders who returned followiig the strike were requalified by performance of test welds to reestablish a basis for the 90 day log..
I Both procedures (KFP-15 and ESD-216) imply that the assigned QA inspector i is to keep and maintain the 90 day qualified welder's log, the weekly qualified welder's list, and the velder's qualification records. This l was apparently the understanding of both the Quality Assurance inspectors and Quality Assurance management and appeared to be consistently implemented. That the procedures do not specifically assign such responsibility for the maintenance of the above documents is of ninimal significance. The inspector finds that the Pullman practice and procedures for documenting and maintaining welder qualification status j was and is. adequate.
4 No items of noncompliance or deviations were identified.
l 22. Criterion IX, NSC Audit Findinz 10f: * -
4 l
" Procedure KFPS-13 differs from KFP-15 in that it .does not permit a six-month extention of welder qualifications if the welder has been actively welding on some other welding process. Procedure KFPS-13
) requires the welder to use the specific welding process ,within a j three-month period or be requalified. There is no evidence of adherence to this requirement for pipe support. welding."
NRC Tinding:
6 e I w-,. m- , , - ~ , ,,--..ww -,--+,-----,-w,--%e,-,,w-.- mv,,m..,--,v.-,-,,-,--_,-.--v-e.w- -
i . . .
i.
- 21 The ir.spector's appproach to resolving this issue was to, examine the NSC referenced procedanres, assess the validity of the NSC finding and Pullman f
response, and evalluate the findings for compliance with the ASE Code.
- The 1971 edition aof the ASE Boiler and Pressure Vessel Code Section IX i i provided, is paraggraph Q-26, that " Renewal of qualification of a j l performance speciification is required...when a welder. ..has not used the i
specific process....to weld either ferrous or nonferrous materials for a period of three amonths or more... ." This paragraph was revised in the l Winter 1977 Addemda to read " Renewal of qualification of a performance I specification is = required...when a welder. . .has not used the specific i
i piocess...to weldi-sither ferrous or nonferrous material for a period of thrEm"onths or amore except when employed on some other welding process -
- the period may be
- -extended to six months. . . ." The inspector found that i Pullman had not tarvised procedure XFPS-13 to reflect the revised
' requirements of tihe Winter 1971 Addenda and' that, up to November 30, 1977, KFPS-13 refHected the original, more conservative, requirement of
- the 1971 Edition, .Section IX, paragraph Q-26i The inspector also found
! that Pullman's we21 der qualification program implemented the appropriate !
Code requirements regarding renewal of qualification in compliance with l the code preamble requiring that "Any regualifications or new _ !
} qualifications shall be made in accordance with the test requirements of !
l i
the current editimn." Thus, the inspector finds that Pullman complied (
with the revised uselder requalification provisions of the ASE B&PV Code, t after the revisica, although Pullman was slow in revising XFPS-13 to '
reflect the revised code requirements.
The inspector reviewed procedure KTPS-13 Pipe Support Field Procedure - i Welding Qualifications e dated December 3,1973) and notes that paragraph
- i l 13.2.3 was revised on November 30, 1977 to reflect the. applicable !
L provision of the ASME Code,Section IX regarding renewal of j' qualification. ,
i The.ASE Code prescribes that l the most current edition of Section IX be
) (
implemented at all times., Discussion with the Pullman Quality Assurance !
j Manager, the Welding Qualification Quality Assurance Inspector, and the j Authorized Inspector daring the early construction phase, indicated that j
the current revision of Section II*was consistently implemented and that j .
the apparent omission of the time extension provision.of the Code in KFPS-13 was an omission of the relased requirements provided in Section IX. . Examination of the 90 day Welder Qualification Loss for the years of i
' 1972 through 1979 indicate that adequate welder qualification .
documentation was maintained.. Further, discussions with the above individuals indicates that verification of a welders use of another i
process, as provided by Section IX, was accomplished by review of the ~
weld filler metal withdrawal sheets which issued weld filler metal to the 3 welder. These sheets document the procedure.to be employed by the welder
! in performance of welding with the filler metal issued. The ASE Quality Assurance manual for code piping (KFP procedures) provided for use of the
{ referenced ASE Section*II option; however, the Pipe Support Quality i Assurance manual (KTPS procedures) were subordinate to the ASE Quality i
Assurance manual and, therefore, welder qualifications were accomplished i' using the option Provided by the ASE Quality Assurance manual and
(
.,.,.,--.,.__.--*-..,,-,-~---.-,.~e- -, --..,,w..,.--,----mn,-. -~-.,,--v-.,,._.,.%,_.,.y,.,-m.-n-~,.~,..~--.e~_~%.r.-- ~ - '
t' i 22
- . Section IX. The inspector finds that,the Pullman practice for welder ,
qualification tracking was consistent with the AS!E B&PV Code.
{r No items of noncompliance or deviations were identified. !
l 23. Criterion II. NSC Andit Finding 10h
(
t i a
l j " Procedure ESD-219 requires random sampling of in process welding, with l 4
the sampling to be noted on the Field Process Sheets. In enemining Field i i Process sheets, it is obvious that the sampling by the area inspectors l l was not performed."
j NRC Findian: 1 1 . !
l The inspector's approach to resolving this issue, was to assess the validity of the NSC finding and Pullman response and evaluate the NRC i findings for safety significance and/or compliance with the Pullman j program.
, ESD-219 required that welder audits were to be' performed on each welder :
j every six weeks and recorded on the welde,r audit sheet. The procedure l ESD-219 did not require that welder audits be recorded on the Field--
l Process Sheets. The audits are a Pullman program requirement in excess ,
j of the AStE Code requirements and were performed on a sampling basis and [
recorded on the welder audit sheets. The welder audit sheet format was upgraded on 12/10/73, 2/4/74,12/6/74, 6/27/74 and 6/17/76 as esperience j in the use of the audit sheets identified an upgrading need. The j
- inspector esamined welder audit sheets and observed that activities monitored were recorded on these welder audit sheets. The inspector
- l considers that the performance of welder audits of each welder every sin ,
j weeks was an appropriate method for recording in process welding i
observations. The fact that the procedure did not require that such observations be recorded on the process sheet is viewed as a finding of '
{ no safety significance since this activity is over and above the ASIE j Code requirements.
The inspector enamined the revision / change records of procedure ESD-219 !
) (Weld Procedure Monitoring) and observed that paragraph 4.4 was revised on December 30, 1977, apparently in response to the NSC audit finding, to
! prescribe 'that sampling checks of in process swalding gy,-be noted on the l l process sheet or inspectors daily work sheet.
I
[
j No items'of noncompliance or deviations were identifi'ed. -
l i !
i
- 24. Criterion II. NSC Audit'Findina 101:
. " Procedure ESD-219 requires periodic auditing by the Welding Auditor. l j These audits were not performed until November 5,1973; and Pullman Power
[ Products was not in compliance with this procedure for approximately 23
~
i months." '
\ ,
NRC Findiant l l
{ l
, r j.
/
.- 23
! N inspector's approach to resolving this issue was to assess the l
) validity of the NSC finding and Pullman response, and evaluate the NRC l
- findings for ceaformance with tha specified Pullman program. l h inspector esamined the receses of change / revision to 15D-219. N l
} records show that the precedure ses writtaa in draft fore en yebruary 14, !
! 1973. h November 1973 revisies apparently was issued and implemented !
i begimming in November 19y3. Esasiastian of the 1973, 1974 and 1975 (
i welder audit sheets ladisete that the required welder audits were l
} perfemmed begianing November 1,1973. Discrepast findings appear As basa '
been adequately dealt with ,and resolved. , !
i i !
h ASIE Code does not contain amp requirements for performance vP - ,
welding audits. N Pullaan_ program for conducting welder audnts appears l
- to be in as
- ess of AstE Code er SS D1.1 requirements sad the NRC finds .
- me irregularities in the Pullman implementaties of this welder audit
{ . Program, j
1 The inspector concurs with the Mc finding that these audits were not i
! performed until early November 1973, s.ad centurs with the Pullman '
, response that ESD-219 was not writtaa until yebruary,1973. N !
- procedure implementaties appears to have begun in November 1973. . _ l I
Based en the above, the inspector was not.able to correberste the NSC !
statement that Pullana was in menneeg.11ance with the precedure for about i
O ,
23 months. i
- . r N inspector concludes that Pu13aan di( implement a program of periodic l welder audits in 1973 shortly after procedure 18D-219 was issued. j Pullman apparently exceeded the seguirements of the ABIE Code and AW8 ,
, D1.1 in the area of welder audittag and had implemented a program i i consistaat with industry practies of the time in the area of welder !
abditing. t s
No items' of neucempliance er deviations were identified. [
j 25. Criterica IX. MSC Audit hin4ing 303 I 4 . .
l , Peocedure ESD-219 requires moeitering stataless steel welds for ferrite I l .
centrol. Bewever, the Severia Guages were met es site,ustil the j beginaias of 1973; and Pu11mes Buwer Products was not in' compliance with r
! this precedure for appremiastely 12 meeths. I
,ypC 74d4mm3 ~ ..
u ; !
! The inspector's approach to resolving this issue was to examine the '
Pullmaa response to the NSC findlag, establish the degree of response '
1 validity and have Parameter, Inc., as NRC censultant, independently '
j esamine a sample of staisiless steel welds in Unit 1 for _ delta-ferrite and I i
i establish the degree of cesfezzece with regulatory requirements. '
Based en di eussions with 708E perseasel it appears that stainless Meel welding on site began in early 573. ' la,dications are that the early stataloss steel es-site melding ens performed es radios,ctive waste j
,,,--,..---,-,.n,- +,,e-_----,,-<- - ------- - -,- er ,-,,,,m .,-- _ .--. _ ,-.,._ nv -n-,-n,---,--n-_,-,,w.-,,,,v_,,-
li ~.
- j. .
26 l
systeen, a sea-safety related activity. Prior to this time stainless 4 steel welding was performed es prefabricated pipe spools at the I '
Eellogg-Pullmaa shop in Paramenst, Califersia. Procedure ESD-219 was !
issued for taplementaties in November 1973, shortly af ter the beginaias l l '
of site stainless steel welding. k first Severia gauge was received !
t ee-site about December 20, 1972 and the second was received about Jaamary l j 30, 1973. Thes, the inspector was met able to corroborate that Pallmaa l
- was in aescompliamee with this procedare requirement for 12 months. ;
i !
} As an additiemal cheek the-inspector chose a randes sample of 25 i
! stainlama steel welds in ' gait I and had these welds esamined for I
{ delta-ferrite by Parameter, Inc. perseenal. N results of this l 1 esaminaties are IUGd'in Attachment 1 of this report and indicate that t j ,all welds esamined easy 11ed with delta-ferrite acceptance criteria. !
! No items of aeseempliance er deviations were identified. !
l l 26. Criteries 3. "C Audit TN- No.10k: ;
i l
l " gangers are met welded is accordamee with Pacific Gas and Electrie !
Ceepany requirement. Eaagers 2023-IV and 2039-2V are two saamples of a l l ameber of hangers observed that are welded to the structural steel _pa the l
! wress side of the bracket." !
I -
l BC Tindias: -
l h inspector esamined Baager No. 2039 2V, the related hanger _ drawing, and detemmined that the hanger is Class II/E hanger which received me l l guality control inspection hosee no field weld process sheets were -
i
! senerated er available for review mer were they regaired. Class II/E l j compements are not safety related and, hence, not included in the gaality l assarance/ control program. NRC esaminaties of the hanger drawing
- establiebed that the drawing called out a 1/4" fillet weld es the front
] and bach of the beam attaehment. k beam attachment is the saly 1 component specified on the drawing as requiring weldias. The inspector !
found the beam attachment to be welded as specified es the drawing. NRC '
- esaminaties of Esager No. 2023-19 (a Class I hanger) and the related I
! hanger drawing established that the been attachment was welded as j specified on the hanger drawing. Both of these hangers are located La l Dmit No. 2. , , . . . .
! h inspector eensledes that the Pallana response to the NSC findias is l 1
accurate and that the NSC finding was is errer.
- During the field 'esaminaties of the above meted hangers the inspector . f l selected eight additiemal hangers from the 'same general area with stallar l
! eenfisaretions. h inspector noted that all hangers chosaa were similar l j to Naager Nos. 2039-2V and 2023-1Y: that is, a welded been attaehment i l supporting a spring hanger. All of these hangers are loested at (
! appremiantely the 130', elevation is the general ares where the mais stesa !
- lines esit containeest,Va. 2. k followiss hassers and their related '
I hanger drawings were esamined and found to confers to the specified !
drawing requirements.
I i .
I l
25 e
Esaner No. Class Destamation 2040-IV -
Class II/E 2023-7V Class II/E 2023-6V Class II/E 2021-4V Class 2 2023-57 Class II/E 2021-37 Cless 2 2037-1V Class I 2021-17 . --
4taes II/E Ne'itans of noncompliance er deviations were identified.
- 27. Criteries I1 m NBC Audit Findina 101:
"The Asterface 'of welding to other suppliers' parts and cogements is met clear. Welding is dess to'jeta Westinghouse and paramenet parts and eesponents. The aseessity for addressing impact property requirassats for these weldsents is met clear; la addities, the requirements for addresslag sayset property requirements for'pullana power products field welds are set clear. If impact properties are necessary, the acceptability of each weld that has been repaired and subjected to more than see stress relief is indetesaimate because of the time at
, temperature limitations withis the qualified weld precedure."
, IOLCTindiant h Inc approach .se resolving this issue, was to esamine the'requirementa of the Code is the area of impact testing and evaluate the NSC finding
- and pullass reopease is this area. *
- The 1971 addeada to ASA 331.7 states, is paragraph 1-723.2.3, that "When
. the design specifiesties requires impact testing of ferritic steel
' esterials, the, testa and acceptanee standards shall be la accordanes with the requirements of Appendis l'." h 1976 edities of 331.7, same paragraph, requires evaluaties of toughness properties if service is espected to be less than 30*F. -
petE specification muaber 8711, ispeeed on Pu11asa, doesn't require
. imyoet testing of qualificaties welds for precedure goalificatient thas, impset testing of precedure qualificaties wetheats was met performed.
h taspector further observes that tapest testing is met unilaterpily regelsed for such.weldseats;bi the 331.7 Code; Specificaties 8711, ,
Change 3 ,.
it, requires eempliasee to the 1970 Addenda of ASA 331.7.
h inspector finds that Pu11aan procedures for impact testing of qualitiestice weldmeats and specificaties 8711 are eensistost with 331.7 Code requirements. ,
No items of aeseearliasee er deviations were identified.
- 28. Criteries IXl NBC'A*udit Findha leer ,. .
9
26 ,
1 "Some welders do not receive sufficient training. Welders, fabricating the pipe rupture restraints within the centainment, are welding heavy
] plate. While these welders are qualified by virtue of welding heavy wall j pipe, the techniques are differest. The welders who were already
. qualified to heavy wall pipe were met given additiemal training on j plate."
10tC Findiant l m inspector's approach to resolvins this issue was to examine the coes I requirementa in this area and evaluate the validity of the NSC and pu11=am reopease. ,
2 The 1974 Edities of the ASIIE B&pV Code, Secties IX, paragraph QW 303.5
! states "... qualification as pipe shall qualify for plate, but met vice- '
j versa eseept that quellficaties en plata shall qualify for pipe over 24
- inches in diameter."~ Therefore, it appears that the Code recognises pipe l as more difficult to weld than pista, m Code does not require 1
additional trainias en plate for welders originally qualified es pipe.
1 mse Cese requirements are also reflected in the current edition of
{ Secties II, table QW-461.9. ,
! Qualification en heavy wall' pipe (wall thickness greater than about
- 0.75") requires additional qualificaties by performance of welds sa l thicker membersi se also does qualifiesties to weld besvy plate.
m inspector found that Pullana welder qualification procedures comply with Code Secties IX requirements, m.NSC audit finding appears to 3
apply as interpretaties which is set ogpersed by Code requirements.
No items of neacompliance er deviations were identified.
i j 29. Criterios IL NSC Audit Findian 10s:
j l ,"yhere is se precedure for preheating weld joints."
WRC Findiant -
The inspector evaluated the validity of the NSC finding and Pullaan response and evaluated the Pullana preheat ptogram for. eenfermance with specified requirements. .
Specificaties 8711 preserthe,s that preheatias may be performed using
. either the electrical resistance heatias mothed or localised tersh method is ceajusetion with appropriate tempil sticks. .
m inspector esamined the following welding precedure code numbers and welding precedure specifications and found that each contained as adequate definities of preheat, postweld heat treatneat and interpass -
temperature requiraseets: Code Nos. 4/S, 7/8,15/16, 79/80, 86/87, 48/89, 91/93,105/106,129,154,149,150, 200, 201, 202, 203 and 208 m- Weldias Procedure Specificaties Nos. 88 1-4/5-K 12, 90-1-8/4-K-12, 200-111-8/45-03-1, 404-111-CARF20-08-1, 409-111-34-08-1, and 507-1-42-08-1. ,
2 .
l 27 i
i i
1 \
, ESD-218 (Postweld Meat and Preheat Treatneat Precedure) was revised and ,
improved December 30, 1977 to prescribe prehea't requirements and indicate !
i
- prehaat applicability, in addition to the information prescribed on the (
. Welding preesdure Specifications. )
} ESD-264 (presess plamains and Centrol-Field process sheet) was reviewed [
i by the inspector. The Field Process Sheets were revised in early 1978 to ;
indicate prehaat requirements. Prior to early 1978, ceay11ance with the prehaat requirement was dependent se the welder's knowledge of and ;
ceay11ance with the welding precedure specification and was indicated en f
- the preeems abeet by the craftsman and QC signature in the welding block, l I
which specified the welding precedure to be used. The philosophy used was that when each signed a block, the signature meant that all applicable precedure requirements had been accesplished.- -
t The inspectar concludes that, while se separate and specific precedure j fespreheating of weld , joints existed prior to December 30, 1977, i preheating requirements were adequately prescribed by the welding [
precedere specifications.and documented by signature en the welding block of the process sheet, which specified the applicable welding precedure. l
~
)
No items of nescespliance or deviations were identified." --
- 30. Critarian__2L_MRC_ Audit findina leet .
6 "yhe initial results of the welding auditing (fren Nevenber 5,1973 to February,1974) indicate that the fellevias problems asistedt . .
- (1)' The welders did met understand shielding and purging.
r (2) Tagil sticks were set used. (
o (3) Asperages were met withis precedure limits (mainly root welds and i task welds). . , !
l
.(4) Wold procedures were not available, and many welders did met haev !
I
'. where te obtain them. !
'. (S) The esygen analyser was met available er not operative. Also, the !
sine vs. flow rate alternate technique use met usedt ,
(
(6) , Oves red temperature sentrol was met monitored by .the weldere. -
(7) . Many welders did met understand their duties and reopensibilities. l i
Based es.a soview of the pullman Power Products welding audit reports and the frequency of the above-noted problem areas, there is ne confidence i that weldias done prior to .early 1974 was perfessed is accordance with weldias specification requirements.", .
i P
Efr IIA $ARI8 - . ,
i The inspeeter's appreeth was to esamlas the records of welder audits senducted bring the above time period and assess the validity of the NSC
-r.._- - _ - - . , -,m- .~~,-,...r.,_.y.,.,._,_,--, ,,,,.,_.-~,-.e _,,,y,,,,. . . , m,__,w.,m..,,,__,.-..,%,,,-.. ..mr,_-.,-.,,.
23 i '
finding and pullman response. N welder audit program is an example of .
I estra effort, met required by the Code, to provide assurance of a quality l 4
- welding progren'implementaties and affect prompt corree:.ive acties for
! ident.ified discrepancies.
l l h taspector crittently enemined the records of welder audits perfossed j between Devember 1,1973 and April 1,1974. A total of 133 welder audit '
I reeeres were esamined. Each of the above NSC audit statements are *
} addressed be g . ,,,,, !
f l
I h MSC audit statement was that "The welders did met understand .
I shielding And Purging." The inspector observed that 23 of the reviewed i l audits identified problems regarding compliance with the 20 psi and 20 eda requiremssta for gas pressure and flew. Wald quality preblems eenld ;
escur if the gas flew rates are ascessively high or low. h vast !
] mejerity of esfety-related stataloss steel welds were radiographically (
j esamined and the fila,wes. reviewed and accepted by a qualified {
j interpreter for code eemplissee. The audit findings did met fadieste l 1 that welders did met understand shielding and purging, rather the !
i findings point out the difficulties which saa be saperienced when more l i than ese purge /skield line is connected to a single gas seures and j regulater. la all. cases, corrective acties was taken to retura.the- ,
.! pressure and flev rate to the required values. -
i 1
! h NSC audit identified that tagil stiska were met used. h puspese 1 of Tempil stieks is te verify proper preheat and assure that the
{ interpass temperature was low enough to besia welding the rest weld pass.
! Of the 133_ audits eaaadaad...fourtees of the audits identified that the j welders did not have tempil sticks La their possession. la esek. ease ;
) action was takaa to provide the welder with Tempil sticks. Several of 1
the welders apparently told the auditors that prior to resuming welding they weit until they can touch the weld; thus providing assurance that interpass temperature requirements are met aseeeded. This is sa j acceptable pseettee. ..
'N NSC audit identified that amperages were not withis precedure limits.
Of the 133 audits reviewed, four instanees were identified whereia ,
asperages were met withis welding precedure specification lietta. la , !
each ease the welder eerrected his asperage setting. A lower thes ;
seceptable ageress would result La lack of adequate,ree), penetraties or !
lack of aseeptable heat affected some easies'; which would be seen La a i radiograph and any be detestable by awface eneminaties methods, such as !
.the liquid penetreet er magnette partiene techniques. Righ amperage . j
.would result la eseessive opetter, a sensities which qualified weldere '
would met waJd under because welding is gutte diffleult under high ,
asperage senditions. Further, esperage is met se essential variable specified by the ARE Code, secties II and is saly a supplementary !
essential variable for meterial with notah toughness requirements - I The NSC audit identified that weld precedures were met available and asey ;
welders did met Amew w6ere to obtata them. Welders are required to have '
a sepy of the weldtas procedure at the job loesties. Of the 183 audits ;
, saamtmed, five audits ident.ified esses where the welder did met have a j j'
welding precedure. Three of the five esses identified that the welder ;
t l .
. i .
29 i
did not know where to obtain them. .In each case the corrective action was to have the welder obtain a copy of the welding procedure along with
, an explanaties of the location from where they could be obtained. The i inspector concludes that the vast majority of welders used welding
! procedures and knew where to obtata them and that this NSC finding has i
{ only minor technical significance.
The NSC audit indicates that the oxygen analyser was not available or
- operational. Although this was not a required checkpoint, only one J
finding of the 133 audits reviewed indicated a problem with the oxygen
- . analyser. This problem was corrected. Thus, the inspector considers l
l that the welder audit records do not sepport the NSC conclusion.- l
-~
1 The Nsc audit indicates that' oven rod temperature control was not
- monitored by the welders. Of the 343 welder audit records reviewed, -
)
fourteen of theos medits . identified instances where the. welders rod even i temperatures were lower than the 225'T required by Pullman procedure, and
! did not meet the 225'T requirement. Nest tastances observed by the i auditors identified deviations up to 35'T, however, two' audits observed temperatures as low as 150*T. In all cases the welder was required to return the defective. oven to the rod room and obtain another. The audits
] further indicate that a large ausbar of the apparently discrepeat ;
! findings were due to the-thermometer being out of calibration and reading 1
low, thus indicating that the actual temperature of the even was higher ;
1 them that indicated on the thermometers. The primary reason that rod !
ovens are maintained het is to preclude moisture entry into the welding i l electrode coating and, .thus, =Inimine the potential for inducing '
j underbead cracking.. Recent industry findings indicate that-when the
} .
temperature of the weld rod is maintained significantly in excess of the {
l atmospheric temperature, thus above the dew point, the entry of moistare l j into the coating is effectively precluded. The NgC finding that rod ovea l l temperature was not moattered by the welders is not supported by the j -
inspector's review of the audits, although isolated instances of ovens i being below temperature were identified by the audits. In addition, this ;
i i '
should not be a technical probles because rod is removed from a '
. hermatically sealed shipping container and immediately put into an ovea ;
with temperatures of sufficient value to preclude moisture intrusion. !
a^
The NSC audit indicated that many welders did not understand their duties and responsibilities. The NRC considers that, the reason these welder audits were done was to identify such instances and provida corrective
! action. of the 183 audits reviewed, five welder audits indicated that
! the welder in questies did not understand their dutie's and -
- responsibilities. In each case the welder was reinstructed'by the ;
Quality Assurance , inspector auditing the welding activities, including i notification and reinstruction of the welder's foreman, as applicable.
- i. ~'
j It is important to recognise that some of these were NSC findings, but i
! were instead findings of the Pullman welder andit program, which wa: !
{ designed te detect program weaknesses and provide prompt corrective j action during the early phases of site welding activity.
l l In summary, the inspector notes that isolated instances of probles areas
! were identified and corrected by the Pullman welding inspectors.
4 .
1 8
_ , _ ,_ _ _ __._ , ._.- _-.. , . ,_,.- .. ._ _ e _ __,_.,__,, __.- __m___,_ _ . _ . . - . _ _ _ _ - - - _ _ _ , . ,
. 30 However, the inspector does not consider the aggregate of problen areas to be so pervasive such that support can be given the NSC conclusion that "There is no confidence that velding done prior to early 1974 was
," perfomed in accordsace with welding specification requirements."
No items of noncompliance or deviations were identified.
j 31. Criterion I, NSC Audit Finding Nos. 5 and 6:
Tinding 5: "For all ins'pectiE processes, there is no mechanism to provide the inspector the particular characteristic to be inspected; the particular acceptance..cziteria; the particular methods and equipment to be used; and provisi6ns for recording results, other than acceptance for the particular inspection being made. The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures that specify the use. of particular equipment (such as some of the ultrasonic procedures)." _
Yinding 6: "The inspection process is generally not auditable. The practice of exhibiting an acceptance signature only does not permit auditing to determine if the individual characteristics.were examiged, the correct criteria were used for acceptance, and the correct specific
~
l l- measuring devices were used."
NRC Finding: '
i To resolve this issue the inspector examined the Pull =E program f procedures in this area, the validity of the NSC findings and. Pullman ~
responses and ar==ined field process sheets to verify compliance with the
- '. = prescribed Pullman program and 10 CFR 50, Appendix B, Criterion I.
The inspector examined ESD-264 (Process Planning and Control - Field Process Sheet) and observed that the field process sheets do identify, and are required to identify, the procedures necessary to perform a
- 'particular inspection. The inspector's signature is meant to verify that t
the required inspections were performed in accordance with the referenced procedure. j l
i tr==ination of some of the procedures referenced on the,. process sheet l indicates that each contains numerous inspection requirements and acceptance criteria. These inspection requirements and criteria are so numerous that inclusion of'each on the-field process sheet would
~
-excessively complicate the process sheet. .The inspector considers that
" inclusion of each inspection requirement and. acceptance _ criteria on the process sheet would decrease the effectiveness, and work process pontinuity, afforded by the ' field process sheet. - .
. ,. , :~.
Examination of about 100 completed field process sheets indicates that -
~
the required procedures, were consistently identified on the process sheet, thus identifying the group of . inspections and examinations to be performed by field, inspectors.
The.NSC' finding that the ' inspection process is generally not auditable is true if one defines auditability as the ability to verify, af ter the 7 .
/
I 31 inspect-ion, that each inspection requirement and acceptance criteria was considered and so documented by the inspector's signature by each t
requirement and criteria. However, if one accepts the philosophy that the inspector's signature verifies the conduct of inspection / examination
! in accordance with the identified procedure, then the inspection process is auditable. The inspector considers the Pullman practice acceptable, in accordance with standard industry practice, and in compliance with ASE code requirements, which do not provide specific rules and guidance in this area. , .,. _
. No items of noncompliance or deviations were identified.
- 32. Critierion I, NSC -Audit finding No. -7 "A large number of welds in Unit 2, ~ System 14 (W-110, Ill, and 112 in
~
4 isometric package 2-14-31 are examples) were accepted for visual
- examination and thereafter accepted based on surface NDE inspection (E
~
or PT). Visual examination of those welds indicates that the surface is not suitable for the performance of surface NDE inspection."
NRC Finding: l 1 -
The NRC retained the services of a certified level II Liquid Penetrant Examiner through Parameter, Incorporated.
~
The certified examiner was directed to evaluate the surface condition of field welds 110,111 and 112 on isometric.2-14-31 (Component Cooling
- Vater ~ System-Return Header B) and perform, and interpret the results of,
- liquid penetrant tests on those welds. The NRC consultant determined that the surface condition of those welds was acceptable for surface NDE inspection. All welds examined, except for an indication ~ near~ W-111, were found to be acceptable. The examiner observed an indication
. approximately 1 inches long in the base metal of the pipe about 3/8"
' from Field Weld-l'11. The examiner's findings are detailed in Attachment I to this report.
- . Pullman wrote Discrepancy Report No. 5567 to remove the indication by flapper wheel grinding and conduct further liquid penetrant examinations.
The inspector observed these activities. The indication was determined to be' a ishallow surface lap-in the metal caused by the rolling operation i-
_ during pipe fabrication. The indication was ' removed by grinding.
Subsequent liquid penetra:R ba=4 nation verified that the indication was a s'urface type and not a rejectable indication, eved. prior to removal of the indication. The' grinding operation did not violate minimum wall
. thickness criteria.. -
1
- The inspector concludes that th'e NSC fi.nding (that the . surface .of the welds was not acceptable- for surface NDE inspection) was in error.
No items of noncompliance or deviations were identified.
- 33. Criterion I NSC Audit Tinding No. 9:
l 1
, 1 32 l
l l
. "W-83 (isometric Process Sheet. package 1-10-9) was repaired in accordance with a valid symbol, but R1 was inked onto the radiograph.The radiograph of that is questionable for acceptance to visual standards."There is a surface defect NRC Finding:
The NRC retained the services of a qualified radiograph interpreter who arm =ined 102 radiographs of various welds in several Unit I syst ems . The results(Attachment report of this er==ination 1). are contained in the attached Parameter, Inc.
I following. repair. This examination included the FW-83 radiograph 4
The Parameter consultant examined boch the original radiograph, and the radiograph were of the same following weld. repair, of W-83 and concluded that both radiographs Turther, the Parameter Consultant informed the is sometimes done..because the lead labels may have positioned outside the film area.
a radiograph unusable. This isolated instance would not make area to be examined. The code prohibits marking of radiographs in the -
inked onto the repair radiograph, ~outside of the area , has to be e no safety significance and is not a violation of code or regulator ~y~~
requirements.
The inspector examined the surface of IV-83 in the field and found that 4
the veld does not contain a surface defect. The inspector did ' observe a gradually sloped grinding line (about 1/8" wide, 2" long and less than 1/64" deep) which may. be what the NSC-referred to ar a " defect".
depth 'obviously did not violate minimum' wall thickness criteria. The Discussions with the Parameter, Inc. radiograph interpreter indicated that the' obserWd" densities did not vary si Aficantly on the film , thus indicating that the grinding line was not of sufficient depth to significantly decrease wall thickness in the weld area.
No items of noncompliance or " deviations were identified.
- 34. Criterion L NSC Audit Finding 10a:
" Records of welder qualification prior to 1972 are not availabl e."
IRC Finding: '
The inspector's approach to. resolving-thi~s issue was to determine if welder qualification documentation was available prior to 1972 and to assess the validity of the Pullman response to the NSC finding.
i
coupon test results; form titled " Manufacturer's Record of
~
l Performance Qualification Tests on Groove Welds."The inspector found that 20 welders (welder stamp 1etters A, B, C, D, E, F, G, R, I, J, K, I,,
N, 0, Q, R, S, T, U, and V) wer,e qualified during the period beginning August 4, 1971 and ending December 23, 1971. There are no indications 4
_ _ _ _ _ _ . ._ _ - . . .- ._.....e.._ _. _ _ _ , , - _ , , , . , , , . . , , . . , , - . , . . , , . . . . . ~ , . , , , , , . _ _ . , , . . , . ,
- h. s _
~ .
33 that safety related welding was performed prior to August 4,1971. The i i
inspector did not corroborate the NSC finding.
The 90 day qualified welders log was started at the beginning of 1972 and l was coatinued through the present time, except for the labor dispute between June and November,.1974.
The inspector concludes that records of welder qualification prior to 4
1972 were available and were in acceptable order.
No items of noncompliance or deviations were identified.
- 35. Criterion II, NSC ALSTt'Tinding No. 5:
"The 331.1 and B31.7 Codes. required that all piping is leak-tested, where practicable. Pullman Power Products is only leak-testing Class A and B piping and that Class C piping specified by' Pacific Gas & Electric -
Comipany. Classes D. I special, and E piping is not being leak-tested. A letter from Pacific Gas & Ilectric Company (dated January 13,1976) does exist, which states that Pacific Gas & Electric Company will assume responsibility for the leak-testing of Clas's C piping. There is concern that Pn11=n Power Products is not discharging its contractual _
obligations (that specify w yliance to B31.1 and B31.7) by not performing piping leak-testing to Code requirements for Classes C, D, E special, and I piping systems and, as a result, may be legally
~
. vulnerable." --
NRC Finding: -- - -;
,~ -
. The inspector examined. the referenced licensee letter dated January 13, 1976 and a contractor letter dated January 8,1976 relieving Pullman Power Products of responsibility for code compliance on Class C components. T,he inspector also found that the licensee did not have a piping class designated as Class D. Additionally, the inspector found
- that Clas's E and Class E special are (vere) being hydrotested, though (in i some cases) at'less than. code requirements. ANSI B31.7 allows, in paragraph 737.4, for components to be tested at less than code
. requirements, because of limiting components within the piping system.
. The. inspector has no further quest'i ons on this subject.
~
- ..The ihspector concluded that Pullman appeared' to be pro"perly discharging
.their contractural requirements in ,this area.
3to ii. ass of noncompliance or ~ deviations were identified.
- 36. ~ Criterion III, NSC Audit Finding No. 3d:
~
" Severin bauges 2947 and 2971 were receive'd on the site in January,1973.
t Initial calibration was August 29, 1973; and the next calibration was i
November 19, 1974 for gauge 2947 and January 23, 1975 for gauge 2971.
Procedure ESD-213 requires annual calibration."
~
4 0
34 NRC Finding:
Field Procedure ESD-213, " Gauge and lustrument Control / Calibration", does require an annual calibration check of the two onsite severin gauges (2947 and 2971). There are equipment calibration record cards which document calibration status and provide a historical record of the !
-frequency cf calibration checks performed since August 1973. These '
records verify the NSC finding and indicate a subsequent history of consistently exceeding the required frequency of calibration checks. ,
- Associated test equipment control records establish, since 1978 (the
' custody Iog was not maintained prior to this time), that neither gauge
~-
, was ever psTd liluring any out-of-calibration period for material testing.
In each case, the instrument was logged out for calibration check and unavailable for testing during the lapsed period.' Documentation since 1973, which verify calibration checks performed on-site by PPP personnel or by Severin Engineering.Ovy, provide no evidence that either gauge was discovered to be out-of-tolerance. Test equipment ' control implementation appears to adequately remove from service any instrument
~
exceeding the required re-calibration date. There is no evidence to indicate that Severin gauges ~2947 and 2971 were used-in ferrite examinations when these gauges.were outside of their calibration limits.
In conclusion, the NSC audit finding was substantiated but determined to have no safety significance. Evidence indicates test equipment control was adequately implemented since August of 1973 and was under control. ,
No items of noncompliance or deviations were identified. .
- 37. Criterion XII, NSC Audit Finding No. Sf:]
, "There is no documentation available to verify calibration of " Tong Test" amp meters."
NRC Findinz:
Tong test amp meters were contracted off-site for the required periodic calibration checks. . An equipment calibration record card exists for each
- instrument, documenting the frequency of calibration checks performed since the particular tester was acquired. Calibration certificates are on file from the~ applicable lab verifying completed calibration for each tong tester. These records appear to' provide adequate documentation that ,
" Tong Test" , amp meters were being. calibratedi ~ ~ --- - -- - -
' No items of noncompliance or deviations were identified. ,
- 38. Criterion XII, NSC Audit Findinz No. 3r:
" Tong Test amp meter TT2527403 was out .of calibration for the period December 12, 1976 to January 31, 1977. No DR has been written against
.that instrument "
NRC Finding:
O O
'_-,_____,____.______,___ _ _ _ . . . _ - , . _ . . . . . - , - - , _ . - - . . . . _ ..,.,__,,,,,_-,...w,. . _ , , , _ , , , . , ,_..,,,m_,. . . _ _ ..,,,_,
f
. 35 NRC review meter TT2527403 of the(200 equipment calibration record cards for " Tong Test" amp concerning the Periodamp Crompton Parkinson) supports the NSC finding out-of-calibration. i Records also' indicate several subsequent time Periods where the calibration check frequency had others. the ISD-213 annual requirement for .this Tong Tester and- two exceeded It would appear the fundamental cause for these apparent lapses in cali.bration control were due to the transit time necessary to ship instruments back and forth from the contracted calibrating facility.
Equipment control records clearly establish that, since 1978 (prior records were not kept), none of the other Tong testers examined were ever used during an out-of-calibration period. Unfortunately, for meter IT2527403 equipment control records were not retained when the instriment was broken and removed from service April 15,1983 (although calibration records are still on file). ,
Based upon PPP past history of adequate test equipment control a~nd the
. non-essential nature of.the welding. current parameter'(as identified by AS!E code) the inspector considers this item to have no safety significance. This activity was under control.
No items of noncompliance or deviations were identified.
- 39. Criterion XIII, RSC Audit Findint 5- ;_ .
" Handling procedures do not- exist;-and, the only handling instructions are contained in ESD-222 and a number of other procedures, which contain a caution against the use of carbon steel in handling stainless steel, t
i Procedure Snubbers during: ESD-259 installation.has excellent detail as to ,the handling of Grinnell 1
Januaxy 27, 1977; Howeverr. Procedure ~ESD-259 was issued and there is not assurance that materials, parts, and components were properly handled during the period prior to ~Jan~uary 27, 1977, when most of the installation activities were occurring."
- '. NRC Pinding
- -
The inspector examined those handling activities which were performed by both the licensee and Pullman to establish the validity of the NSC
. finding and Pullman response.
The inspector discussed, with Pullman and licensee personnel who~were i
- workigg .at the site since the early 1970s, the. practice ( employed
! regarding receiving, storage and handling of safety related equipment, incitiding which organizations. performed.such activities'and snder%t circumstances 'these_.ac.tivities were performed. l The inspector determined that PGEE receivedt stored, handled, surviilled, and maintained valves, snubbers,allmotors, large class etc). 1 components (including pipe, pipe spools,'
~
Contractors, . such as Pullman, would "
requisition components when the contractor was ready and required to install the particular component in the plant. The primary reason ~that the licensee performed the above activi' ties was because warehouse and laydown space. was limited at the site.
To obtain sufficient area for warehousing Pismo Beach, California. and laydown, the licensee used the larger areas available at Items shipped to PG&E for use at Diablo Canyon i
y--,y,,--- . - - , . - - - - . - - - , - - _ . - , -- ,, -w-,---- - , , , , , - . , - - - , ---,.-,,.,,,--w-.~.-....w -,- - ..- .-_,e---
~
l 1.
were received and stored in the Pismo Icaci areas until contractors were ready to install those particular items. The material was then loaded onto t.rneks, by the licensee, and off 1:aded at the site, by the contractor under licensee surveillance, and moved into the plant. The contractor, prior to accepting custody zf the component or equipment, would perform receipt inspection activi::ies, after which the component was moved into the plant. From the time the contractor accepted the material until such time as the system /:nsponent was turned over to the licensee, the contractor was responsible to perform necessary surveillance and maintenance activities, as appropriate. . ... --
The inspector ar==ined the following precedures detailing the licensee's program for handling of equipment. The requirement for sueb-a prograa was cone =4ned in the licensee's Quality Assurance Manual, procedure PRC-1 (Receiving Inspection, Storage and Handling). Procedures implementing ~
the required program, for mechanical egripment, were reviewed.
MFI-0-1 (dated. September 17,1971): Me=nical Department Procedure -
Receiving, Inspection, Handling and Stozage of Iquipment/ Materials.
The inspector found that this procedure accomplished the following:
assigned responsibility for amlishment -
provided adequate handling ins:;rnetions prov_ided detailed inspection requirements _
provided adequate storage requiressents provided adequately for accomp4ht of surveillance while in storage _
provided the _ mechanism for processing and ' responding _to contractor requests for transfer of the equipment to the planY ~
provided for keeping equipment history records' from receiving through shipping and storage. ~
MFI-2-2 (Revisions dated 10/75, 5/72 and 8/70): Mechanical Department Procedure - Instructions to Inspectors - Power Plant Piping" E
The inspector found that the procedtre accomplished the following:
assigned responsibilities for accomplishment adequately addressed inspector qualifications
. . adequately defined. inspector A*4 i -- -
- ** 'proirided adequate handling ~ ins ructions
_ provided adequate storage. surveillance and installation-inspection requirements.- -
hhe licensee contracted with Bigge Crane and Rigging Company for the conduct of handling activities at the Pismo 3each Yard and transfer of material to the site. . The inspector ermened the Bigge " Procedure for
~ Receiving,11andling and Storing Nuclear Fower Plant Equipment and Material - Pismo Beach Tard." This procefnre provided (1) adequate instructions for receiving and unloading, (2) adequate instructions for storage, (3) adequate instructions for p: servation, (4) adequat"e instructions for care and handling of S*T ess Steel and Class I items, (5) adequate instructions for load-out an! hauling, and (6) adequate
s
, . l
- n. ' 37 i 1
i 4
' instructions regarding types of handling equipment necessary and inspections necessary for handling gear.
The inspector examined the following documents which provided handling
. instructions for Pullman personnel.
Specification 8711 (Specification for Irecting Main Systems Piping and Furnishing, Fabricating and Erecting Balance of Power Plant Piping
- paragraph 6.12 provides definition of. respons4bility for receipt inspection, including general receipt inspection criteria, and
, unloading of carriers.
l ,
- T ~~~ "'
paragraph 6.13 addresses storing of3 material including general
! contractor requirements such as protecting items in storage from damage by requiring >'use of dust proof, fireproof and waterproof
, . tarpaulins, adequate spacing and temporary heaters", as necessary.
- ~
paragraph 6.23~ requiYes tinat all mat'erial'be stored on cribbing when in laydown areas. .
paragraph 4.1181 and .82 contain. specific requirements for wel4ing electrode receiving, storage and control. , , _
paragraph 3.211 of' Section 4 provides for Quality' Assur' ance requirements related to handling, storage, packaging, shipping and preservation. .
~
+
ASME QA knual Procedure IFP-7 (Reheiving Inspection)
I[. ,
provides that inspections be conducted to verify that off-loaded items are to prevent ~ damage, contamination' or'det'eriohtion. -
A
- ESD-215 (dated September 23, 1971):. Visual Inspection ,
This procedure provided requirements for handling such as (1) flame
. cutting of stainless steel was not allowed; (2) weld preparation dressing
. requirements; (3) examination for and removal of mill scale', oil,' rust, slag, paint, marking materials and'serface oxide and dirt prior to welding; (4) removal of.are strikes and subsequent liquid penetrant retest; (5) pipe alignment' criteria; and .(6) cleaninsi ~- -
Quali,ty Assurance. Instruction 94 (dated July 29,_1973p _ Performing h intenance Surveillance
' ~
Thi procedure contained criteria for- capping cf pipe ends, actions required when loose nuts / bolts, missing parts or equipment damage was.
observed? The instruction provides inspection guidance for both hangers, snubbers and piping. .. . .
ESD-217 (dated September 23,1973): Receiving Class 1 Procedure
! This procedure requires monthly mainranance surveill'an~ce reports for 4
items in storage such as Class I pipe, Class 1 Pipe Supports, Class 1
-, .-- - -m---- -ww-w-w- ,-----.- e- ,
.w--- --,er v- s-w----,, -,y,+,,---- --,- - ..--- - - _ - _ _ - - - - = - _ _ _ _
38 l
valves, and Class I pipe, valves and supports erected and installed. ;
3 Protection and maintenance requirements were provided by PGEE. 1 ESD-222 (dated February 2'3, 1972): Protection, Installation, Maintenance and. Surveillance of Control Valves j This procedure specifies appropriate handling requirements and criteria for pneumatic and motor operated valves and attached devices, manual 1 operated valvesg and relief valves, free receipt through installation.
Beginning about April,1977, PGGE installed a snubber test facility on the upper floor of the fuel handling building, between the Unit 1 and Unit 2 areas. All-Gesanell hydraulic snubbers were removed, reworked, refurbished and subjected to dynamic stroke, lockup and load tests on the testing machine. Snubbers determined by test to be acceptable were reinstalled. Unacceptable snubbers were either reworked and retested or replaced with an acceptable snubber. This activity was completed in 1978 i
and, thus, verified the operability of Grinnell hydraulic snubbers installed prior t'o the issuance of ESD-259. The information gleaned from this testing program was incorporated into ESD-259 revisions in order to minimize the potential for harm or- deterioration of the snubbers.
Sanbbers installed 'out of doors were also placed inside a rubber be.pt to i
prevent deterioration and corrosion of snubber shafts.
Unit 2 hydraulic snubber maintenance .is performed every 6 months on each ~
Dnit 2 Grinnell snubber and this activity tracked by Pullman.
It is correct, that Pullman.did not have a procedure specifically i addressing handling instructions. However, . viewing in the . aggregate all l
of the Pn11== procedures applicable to Pullman equipment handling and g
considering the limited scope of equipment handling Pn11== was required to exercise, the inspector concludes that appropriate and adequate handling requirements were in place. The inspector also finds that the ,
i limited addressing of snubber handling requirements prior to the issuance of ESD-259 -is of minimal safe ~ ty significance given the conduct of the 1977-78 testing program and the subsequent issuance and upgrading of ESD-259. ,
~
l No items of noncompliance er. deviations were identified. l
- 40. Criterion XIV, NSC Audit Finding No. I s "The major mechma4== that exhibits the status of the work is the Tield ~
Process, Sheet. The Field Process Sheet provides for performance statas-of some important ~ fabrication steps and for inspection status. However, many important fabrication steps are .not indicated by the Field Process Sheet: erection steps; cleaning prior to installation of insulation;. and some critical welding-steps as preheating, checking ga's' flows, and checking for 02 e atent in the backing gas. The Field Process Sheet, as a mechanism to exhibit status, is considered inadequate. The inadequacy of the Tield Process Sheet is considered a major weakness in the Pullman Power Products System." - -
4
. , , , , - - - - , - ,, , . - - - - -.,,..,-n.- e , , . . , , . . -..,,.-,,._..,,v- ,,. ,,,_ . e_., __,.,,,,,,,,nn-_,,,n,.
I
- g 39 I l
l NRC Tinding: The NRC findings relative to Field Process Sheets are contained in paragraphs 7 and 31 of this report.
- Based upon the discussions contained in these paragraphs the inspector i concludes that the use of the field process sheet adequately controlled
- and specified required work activities. Specific steps for fabrication, erection, welding, etc. are not required to be listed on the Field Process Sheet. Status of these activities can be ascertained by reviewing the actual field procedure. The Field Process sheet sequences, by procedure, the required construction events. It is not a mechanism to maintain status of specific work steps.
.\
p No items of noncompliance or deviations were identified. ~
- 41. Criterion XVI, NSC Audit Finding No. 2:
i i
, " Based on the results of this audit and the problems encountered in the pa'st, it appears that a corrective action system has -not b'een operative." ,
NRC Finding: *
- 4 The inspector examined corrective actions -taken as a result- of items -
i identified by licensee audits, Pullman Management audits and the NRC, and
~found corrective actions had been taken, as appropriate,' when problems were identified. Tor; example each of the following represent corrective actions taken in respons'e to audit findings: 'the pipe -support procedure 4 was extensively rewritten in June 25, 1975; Quality Assurance Instruction
- Ec. 98 was created fonhe inspection of sxisting-concrete-expansion-.
j anchors; and in March 13,7979" the pipe'suport quality-essurance: manual !
was' superceded by ESD-223 to provide all the elements of installation,
- inspection, and as-builting of pipe supports in one procedure.
Additionally, as a result of NRC identified discrepancies with radiographs (Referencei Inspection Neport No. 50-275/77-06 dated May 6, i
, 1977) the licensee constitted to requiring that all radiographs would be j reviewed'by a I.evel III or a 'second I,evel II individual.
During this inspectiosi, an NRC consultant reviewed 102 radiographs, to confirm the corrective action on the radiographs, and to confirm that all the radiographs were reviewed by a I,evel III or*a second I.evel II radiographer. No discrepancies were identified during,this review by the NRC ' consultant. '-
The discussion in paragraph 42, below, is particularly germain to this issue.-
The inspector concludes that the Pullman corrective action system has
- been' operative. .
! No items of noncompliance ~ or deviations were identified
! 42,., Criterion YVIII, NSC Audit Findinz No. 3:
I "In response to KFP-18, Paragraph 18.2.k, management audits were -
performed approximately every six months. Check sheets were employed.
-.,-m -
, . . . . ~ - , , . - . - -_.- , . , , _ , , . . _ . , _ , . _ _ , _ , , _,, . _ , -- , - , _ _ , , . . , , - , , - ,,.,,,,.m.,-_v-,c,.,.,,,
- s 1 40 Based on the resuilts of this audit and the results of Pacific Gas &
Electric Company audits, these management audits appear to have been i ineffectual."
f NRC Finding:
Corporate management audits, conducted from September 1972 through February 1978, of 1:.he Pullman on-site Quality Assurance program were reviewed for content, completeness, and effectiveness. There is a file
- of ten management . audit reports, performed during this time period, indicating that cmsprehensive inspections were conducted by the Pullman j Corporate office en appronmately a semi-annual frequency. In accordance '
.with Q.A. progranc element IFP-18 (dated .Tanuary 4,1973) these audit reports specifica.3.ly identified deficiencies, provided recommendations for corrective action and required on-site resolution by the responsible supervisor. As a;ppropriate, each report followed up on the adequacy of corrective action implemented to correct and improve previously
_ identified deficient conditions in the Quality Assurance program.
As a further sigz:ificant improvement to their program Pullman revised EFP-18 on December 30, 1977 to require direct written response from the resident construction manager and the field Quality Assurance / Quality Control manager for " Schedule completion of implementation of corrective action and measures taken to preclude re-occurrence." The field Quality Assurance / Quality Control manager is responsible to monitor audit findings for trends.
In conclusion, there is every indication the on-site PPP Quality
. . Assurance organization was responsive to corporate management audits and there -is-mo basis to suggest these audits were ineffectual.
No items of noncompliance or dehations were identified.
- 43. Criterion XVIII, NSC Audit Iinding No. 5:
! "In response to IFP-18 and EFPS-16, internal audits were performed every l six months. Check sheets were not employed." ,,
i NRC Finding:
' ' ~
- iAt the- tiime of the NSC finding, checksheets were not b'eing used by the onsite Quality Assurance prganization to. Perform internal _ audits._.,
Corporate-audits, -being -performed .by. Williamsport Headquarters personnel, did use checksheets to coordinate their inspections. This inconsistency
- lwas resolved when-internal auditing became proceduralized in, June 1978.,
.by the evolution of field procedure ESD-263. The scheduling of program l
_ n elements_to.be audited and use of checksheets is detailed in ESD-263.
iThe inspector. concludes that, while the NSC finding is factual, the
~
i
-f finding is of minimal safety significance, because adequate corporate audits had been performed using checklists and subsequent audits, both
- internal and corporate, indicate that no fundamental QA program breakdown occurred as a result of the inadequately described internal auditing v- , - - ..-v-,.-
,m .
41 program. (The Pullman internal audit prograr. is further discussed in paragraph no. 9 of this report).
No items of noncompliance or deviations were identified.
44.
~
Conclusion
- The NSC audit contains a total of 175 dom- ' 54aMngs, of which 110 were findings of apparent discrepancies or prag::ma: weakness by NSC.
The NRC has completed 'an examination of 50 of the 3tSC findings identified
' as apparent weaknesses or discrepancies. The c=iteria used to select j those findings for NRC an=4 nation are provided in. paragraph 4 of this r '-
report. Of the 50 findings examined by the E20, three of these were I
. ===ined prior to this inspection and are documented in NRC Inspection Report No. 50-275/83-34. - -
~
Although, the NRC has identified a potential viclation (paragraph 17)
- during this inspection, regarding the qualificatio:n 'of Pullman visual welding inspectors, this item is of reduced si@cance since all but two of the inspectors had adequate backgrounds and experience in the
- areas of welding'or quality control inspectioc. It does not appear _that this problem was. chronic or-widespread. '
It is the staff's opinion that the NSC audit '4M4=s do not provide a
~.'
basis for concluding that the Pullman-Kellogg Qcality Assurance Program suffered a major breakdown during the time pe=iod. prior,to. the NSC audit.
Furthermore',' based onTthis significant sample of the most Important NSC -
findings it'is concluded that nm=4 nation of the remaining iteins;is not
, warranted. "
- ~ ~ ~
- 45. Management Meetina - --
~ '
'. On November 18, 1983, the inspectors met with licensee representatives denoted in paragraph 1. The inspection scope, observations, and findings ~
were discussed. The licensee acknowledged the. potential item of
. noncompliance' identified'in paragraph 17.
an e
. >Mg . + #
O em l -
O t- .
l
~*
Attachment 1 l
- s. , -
- a rim e/s e, at c . Report No. PAR ( DCNP )-NDE- 2 consumac r a cin es a s Page 1 of 3 raw ca o vt. wasc o si. November 22, 1983 sub-} ect
- 1. Independent delta-ferrite measurements on 25 miected stainless stee] welds to verif y compliance wit.n Code and l Regulatory Guide 1.31 requirements.
- 2. Visual and liquid penetrant examinatice of field.weldi FW110-111-112 in isometric package 2-14-31.
I
- 3. Examination of radiographs of 102 weld joints per -compli-ance with Code, verification of adequacy of reader sheets and evaluation of overall quality of radiographs.
Re f ers.nces
- 1. Outline of nondestructive examination work to be performed at Diablo Canyon, November 14-18, 1983 by NRC contract personnel (Exhibit 1) . .
- 2. Contract No . NRC-05-8 2-24 9 _ , _ _ ,__ __ _ __ . - __ _
Task Order No. 56 .
- 3. PAR: NRC/IE-82/83 Writer of Report Kenneth A. Ristau, PARAMETER, Inc. , NDT Invel IIi, - MT, PT, RT and UT -
Contract Personnel Assigned
Daniel J. Hunt, Wisconsin Industrial Testing, Inc. ,
Introduction . -
l The NRC outline of work (Exhibit 1) designates 3 welds to be liquid penetrant tested and visually examined.
The 25 stainless pipe welds to be tested for delta-ferrite measurements were designated by Mr. Dennis Kirsch, NRC Section Chief. For a list of the welds and results of the inspection, gee, WIT report (Exhibit 3). Also see WIT report for results of visual and penetrant inspection (Exhibit 4 ) . t
. t Mr. Kirsch also indicated the 102 welds of which radiographs l were to be viewed (Exhibit 2 ).
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Attachment 1
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a ea m elor, a c. Report No. PAR (DONPl-NDE-2 c o w s uin = c twoiws ss Page 2 sta c a ovt. w e s c owssw November 22, 1983 Record of Activities November 15 and 16 inspections were made by Dan Hunt and films were viewed by Ken Ristau.
l In a short meeting with Dennis Kirsch, day end November 16, the results of our findings were convey.ed verbally, as follows:
P
- 1. The delta-ferrite measurements ma the NRC requirements.
j 2.-The LPT of all three welds were a#pproved but FW111 had
'i one LP indication running transverse to the weld in the' base material of the pipe. It was approximately 1/2" away
. from the weld and about 1" long.
' 3. The radiographs of ~the welds were viewed and approved as adequately meeting Code. Comments were also made by the writer concerning film quality, detai) of reader sheet documentation and the excellent condition of the radiogrJphs, nearly 10 years after x-ray date. .
l conclusions ,
- ' 2. Having reviewed the' radiographs" and" reader sheets of all i _ ~~. 102 selected. piping. welds identified in Exhibit 2, the.
writer found reader sheet documentation detailed and clear.
Radiographs were readily available, in good order and of !
i very good quality. Radiographs are approved as meeting the
! requirements of applicable Codes.
I
- 2. -h11 25 welds selected for . delta-ferrite measurements met the requirements of Code and Regulatory ' Guide 1.31 (See Exhibit 3). .
- 3. Visual and liquid penetrant examination of FW110 and 112 were acceptable. FW111 weld was also acceptable but an liquid penetrant . indication was noted in the pipe base . material (See WIT Penetrant Report, Exhibit'4).
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Roport No. PAR (DONP)-NDE-2 a ra m r/se r as c c .
Page 3 of 3 C O N S U (11 N o gNcewgggas November 22, 1983 giu c a o v a, wis c ow s s,,
8 Li st of Exhibits
- 1. Outline at Diablo ofCanyons, NonBeastruet.ive NovemberExamination 14-18, 1983,Work by NRC to be Contract Performed !
l Personnel. .
- 2. Field Welds Chossen for Radiograph and Reader Sheet Review.
- 3. Delta-Ferrite Menasurements.
- 4. V;i*si and Liquidd. PenktFa'nt Examinations. }'
Prepared by:
,.24t.fl.[$ k . f fed O
' Kenneth.A. Risfab, Level III Reviewed by:
- 4 4. %
. Walter J. Folef, Q/A Engi'neer i
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Attachment 1
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' Exhibit I to
, ' Report No. PAR (DCNP)-NDE-2 i
. November 8,1983
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4 OLTTI.1NE OF NON-DESTRUCTIVE EXAMINATJON WORK TO BE PERFOR) FED AT !
{ D3 ABLO CANYON, NOVEMBER 34-18, 1983, BY NRC CONTRACT PERSONNEL. l
! i GENERAL INFORFLAT3 ON: !
l 1
1.ecation: Diablo Canyon Nuclear Plant, Unit Nos. 3 and 2
! San Luis Obispo, California -- - ,
l 1.icensee: Pacific Cas and Electric Company i
. Docket No. 50-275 and 50-323
Purpose:
- 1. Perform independent delta-ferrite measurements on about 25 selected stainless steel welds to verify compliance with code and Regulatory Guide 1.33 requirements.
I I
~
- 2. Visually ' examine and perform liquid penetrant examination of- ,
j field welds JV-110, 1 1.1 , 1 1 2 in isometric package 2-34-31. i
. l
- 3. Examine about 100 weld radiographs 'and verify reader sheet, 1 radiograph and evaluation adequacy.
- i site
Contact:
Mr. Marvin hendonca, -NRC Seaf or Resident Inspector .
4 805-595-2353 ,
j Jtv
Contact:
Mr. Dennis Kirsch, NRC Section Chief, 415-943-3740
_ (
j Work Hours: 0730-1630, Noviember'14218, 1983 - -- -
l REQUIRE!!ENTS: - .
l, To be furnished at the Diablo Canyon Site by'the If eensee: .
l Nard hats and safety glasses ,
l Insulation removal .
i i Scaffolding erection. .
l -E'scorts to locate welds in the plant '
Assistance to assemble documentation (radiographs)
. E3ectrical power and exten,sion cords for portable test equipment Working space for one' or two persons to examine ' radiography re .or.ds Viewer to esamine radiographs ~ - .. _,
. , . Use of lunchroom sad sanitary facilities '
~ '
' ' Use of; Xerox m'achine as bacE-up
~
t
' . : i Calibrated severa gauge -
l To'l .:le furnished at the Diablo Can' yon Site by',the NRC:
l ' - .
, Assistance as required by the Senior Resident. Inspector
- i Telephones in the NRC trailer j -
l Xeron machine for copying -
l
,o I Attat*:c.t I of T. -
To be furnished by the contractor:
Certified level II or Ill liquid penetrant and qualified radiograph interpreter esaminer to conduct visual and liquid penetrast examinations and an examinatise of abast 3DC radiographs far adequacy Two copies of certifications and stealifications of all contractor personnel, and documentation verifying certificatice and qualification of liquid penetraat cleaner, penetrant and developer used shall be given to the M contact upoc arrival at the Diablo Canyon Site.
Measurements performed shall be in accordance with the latest editions of the ASPE code. Two copies of all data sheets will be_ furnished te tia NRC contact at the conclusion of the work.
,A letter report including a description of t.be work performed, the data obtained er examined, and evaluation cf the adequacy cf licensee's documentatioe skall be prepared and delivered to the ERC Region V office by Noweder 25. 1983. An exit meeting will be held with the KRC contact at the conclusion of the work to discuss the scope and findings. -
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Attachment I ha rbm eler, 0n c. Exhibit 2 to cowsotuwe swoo m wcres RCPort No. PAR (DCNP)-NDI-2 sta c a o v t. wisscrowsiw 1
3 yi.ne: eld Welds Chosen for Radiograph ,
and Reader Sheet Review ISO Fjeld ~2 SO Field 1SO Drawing Weld 2)rawino Field ISO Fi el d Weld Drawing Weld Drawing Wg]d 1-7-21 100 :)-7-6 31A 1-7-1 215 1-07-22 106 1-7-21 101 3-7-6 32 )
- 1-10-19 144 1-07-22 107 1-7-21 105 .1-7-6 33 1 34 l
216 -
1-07-22 108 1-7-18 80 .2-7-6 282 1~- 7-f4 l'24 1-07-22' 109 {
1-7-18 81 11-7-6 280 1-7-24
_ .326 ._ 1-10-9 '83"I 1 .7-14 62 12 6' 283 !
1-9'-42 249 1-07-22 11 0 1-7-14 63 U-7 9 - 294 1-9-t2 1-7-14 64 U-~7-9 ' 245 - ~~~1-07-22 ~ lli i 284 1-9-42 250 1-7-10 46 U-- 7 ,9 , .. _1-07 112 182 1-7-8. 242 1-7-2' 1-07=22 113 7 U-7-9 '43 1-7-8 40 1-09-9 75 1-7-5 22 --
U-7 42A . 1-12-8 100 1-09-9 73
. 1 ,7-5. 23 E-7-9 42. 1-12-8 103 1-09-9 72 1-7-5 24 L-8-323 1084 l'2-8 99 l
1-7-5 1-09 74 25 11 1 1 1-12-8 104 1-09-9 71 1-7-5 26 --I.-7-1-~ 7 -~ .
1-7-23 117 1-09-9 77 1-7-5 27 1-7-1 3 1-09-41 242 1~-09-9 78 1-7 295- 'l-7-1 4
__ , 1-0.9-41 243..__. 1-07-17 76 501014 362 1-7-1 201 1-09-41~ 244 1-07-17 77 !
1 321 10 6 9 ----l-7-1~~ ~203 1-09 17 130 1-07-17 78 1-7-28 .186 ._._ _ .1-~7..1 . 9ng .
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1-09 131 l'-07-17 ~ 79 1-7-2'8. 187 1 -'7 -1 206 1-03--17 132, ~ .
1-07-16 -- 72 1-4e153 1428 1-7-1 207 1-09-38 230 1-07-16 _J3
~1-4;153 1060 ^ 1-7-1' - 2'09~
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{ g NUCLEAR REGULATORY COMMISSION g-
"q -l RE env 145o MAR 4A LAM,suTTE 210 f
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WALNUT CREEK.c.talFORNIA 94596 OCT 281983 Docket Nos. 50-275 and 50-323 .
'~
Pacific Gas and Electric Company ~~
77 Beale Street, Room 1435 San Irancisco, California 94106 _ _ . .
Attention: Mr. 7. O. Schuyler, Vice President Nuclear Poiief Generati6n" ~ ~
~
~
Subject:
NRC Inspection'of Diabl~o Ca~xiyun UEfG Nos'.1~ an'd 2 ~ ~ ~
~
This refers to the special"inspiedo~n conducted by M. G. DeBandez of -
this office on October 11-14, 1983, of activities authorized by NRC License ,:
To. DPR-76 and. Construction Permit No. CPPR-69, and to the discussion of our
~
findings held witb Mr; Etzler ind otler members of y~our staff at _Yhe -' -
conclusion of the inspection. .
Areas examined during this inspection are described in the enclosed
- ~
inspection report'._._ Within.these areas, the iEspecti6E'co'iisisiIedRsETe)Eive examinations of procedures- and representative records, interviews with personnel, and observations by the inspector.
No items of noncompliance with RRC requirements were Tdentified within the scope of this inspection.
~ ~
In accordance with ~10 CFR 2.790(a), a copy of this letter and the enclosure
.will be placed .in the NRC Public Document Room unless you notify.this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter.. Such. application must be consistent with the reguirements. of 2.790(b)(1).
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Pacific Gas & Electric 2 0CT 2 81983 i
Should you have any guestions concerning this inspection, we will be glad to
, discuss them with you.
Sincerely,
) . \\ ./'. 6JA(
T. W. Bishop, Director Dirision of Resident, Reactor Projects and Engineering Programs
Enclosure:
Inspection Report Nos. 50-275/83-34 50-323/83-24 cc w/ enclosure: .
P. 'A. Crane, PG&E W. ' A. Raymond, PG&E S. E. Skidmore, PG&E R. I). Itzler, PG&E R. C. Thornberry, PG&E .
d i .. .. . . . .
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U. S. NUCLEAR REGULATORT CO.WISSION REGION V Report Ros. 2-275/83-34 and 50-323/83-24 Docket Nos. 2-275 and 50-323 License No. DPR-76 Construction Permit No. CPPR-69 iicensee: Eneific Gas ant Electric Comoany
. 71 Beale Street, Room 1435 San Francisco, California 94106 Tacility biame: Diablo Canyon Units 1 and 2 Inspe'ction at: Diablo Canyon Site, San I.uis Obispo County, California Inspected conducted: October 11-14, 1983 Inspectors: (p /[J.
~
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/0 g E. E. Hernandez, Reactor Inspector, Date S'igned
.A,,ro,ed by: M
- 3. F. Kifiich, Chief
~
fo/u /n-Late Signed Beactor Projects }Seetion No."3 ' '~ --}" ],
Summary: _
i Inspection Ihming the Period of October 11-14, 1983 (NRC Inspection Report Jios. 50-275/O-34 and 50,323/83-24 Areas Inspected:. A special, unannounced inspection by a regional-based inspector to esamine licensee and contractor actions in response to an audit conducted by Asclear Services Corporation in August-September 1977 of Pullman
~
Power Products construction activities. A copy of this audit was included in documents provided on September 9,1983, t'o the Atomic 'and.. S.pfety Licensini Appeals3oard by the " Joint Intervenors" to supplement their motion for re-opening the record on Construction Quality Assurance (CQA).' ~
~
i The inspection involved 22 inspection-hours by one NRC inspector. _
Results: No items of noncompliance or deviations were identified.
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, DETAILS
, 1. Individuals Contacted
- a. Pacific Gas .and Electric Company (PG&E) !
i *R. D. Etzler, Field Construction Manager !
, D. A. Rockwell, Project Field Engineer
- W. K. Glenn, Quality Control Supervisor
- *C M. Seward, Acting Quality Assurance Supervisor ,
i M. E. Leppke, Mechanical Engineer ,
3
- C. I. 21dridg% Operations Quality Control Supervisor
! D. B. Miklush, Maintenance Manager
- J._ Arnold, Resident Mechanical Engineer ;
j b.- Pullman Power Products Corporation (PPP)
} **E. W. Karner, Quality Assurance / Quality Control Manager
/. .
- Denotes attendees at the NRC exit management meeting on October 14, ;
i 1983.
- f in addition, Mr. H. Eli (LLNL) and Mr. C. Morton (EG&G), NRC !
! consultants, attended the exit manasenent meeting, i
i 2. Backaround om September 9,1983, the Joint Intervenors filed with the Atomic Safety and Licensing Appeals Board a document to supplement their pending motion to re-open the record on the issue of Construction Quality Assurance l (CQA). The documents included (1) a proposal for an independent audit of l Pullman Power Products (PPP) by Nuclear Services Corperation (NSC) and, i (2) the results of a previous Nuclear Services Corporation audit. The l l NSC audit was conducted from August 22 - September 20, 1977, and covered i
Pullman's construction activities from 1971 through September 1977.
- 3. Reaion V Actions -
l The Joint Intervenors' notion and PG&E's response to the Joint l
, . .Intervenors Supplement to Motion To Reopen The-Record On Construction l 4
Quality Assurance was reviewed by the NRC Region V staff,. and a staff j response provided to the ASLAB on this subject on October 4,1983. Based t 1
on the review of the aforementioned documegts, discussions with licensee i personnel and a review of MRC Region IV and Region V Inspection Reports l .
during the referenced period, (1971 through September 1977) the staff concluded that the Pullman Quality Assurance Program did not suffer a major breakdown and for th'ese instances where isolated breakdowns did occur, those problems were identified, addressed, and resolved by the l licensee's Quality Assurance Program or the NRC inspection program in
. effect ut the time. , ,
b -
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. e ?3 The staff did not attempt to reconcile each and every NSC audit finding.
Rather, the staff verified that the licensee made every effort te throughly address, investigate, and resolve each concern identified in the NSC audit. However, a review of the licensee's response indicated that three areas required further clarification to assure that the licensee's response to the NSC audit findings complied with regulatory l sad code requirements. These areas of concern are discussed below in ;
paragraph 4 of this report. i I
- 4. Inspection Results !
During this inspection the inspector met with licensee personnel who !
participated in the April - June 1973 licensee followup audit of Pullman '
- -' Power Products. This audit was conducted as a direct result of the NSC audit findings and was performed to assure that Pullman's Quality Assurance Progran and physical work complied with regulatory and contractual requirements in effect during the time the work was performed. The results of the licensee's and Pullman's response to the NSC audit findings were reviewed with the above referenced individuals.
The review / discussions reaffirmed the earlier staff conclusion that the NSC audit findings had been properly addressed, and every affort had been made by the licensee to throughly address and resolve the NSC audit findings. The three areas of concern were resolved as follows:
i
- a. Criterion III, " Measuring and Test Equipment" finding No. 2 to the ;
NSC audit states that, "The calibration program did not require '
recalibration of themocouples until June 16, 1976 Therefore, there is ao assurance of the accuracy of thermocouples used for pre- and post-welding heat treatment prior to June 16, 1976. Newly purchased thermocouples were required to be calibrated by-the manufacturer.
Bowever, the manufacturer's calibration does not assure that the thermocouples have not been damage during handling and shipping."
The Pullman response states, in part, that, "All thermocouples have been and are purchased with calibration. Prior to June,1976, there
' were no requirements of recalibration to thermocouples. When the program was initiated, all existing thermocouples were recalibrated and none were found to be out of calibration."
l The inspector reviewed thermocouple record packages and confirmed I that the documentation supported the licensee response that thermocouples were purchased with calibration requirements, and that when all existing theomocouples were rs-calibrated on June 15, 1976 !
and July 10, 1976 and that all were found within' calibration
. requir,ements. ,
The inspector has no further questions on this subject. l l
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m__.. _____m _ _ _ , _ , - _ _ - . . . - - - _ _
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. b. Criterion IX, "Special Processes" ites 10.o (2) of the NSC audit finding states that, "Tempil sticks were not used."
The Pullman response states that, "In cases where welders were noted
. without Tempil Sticks in Internal Audit Findings, there was ne indication on the " Welders Audit Sheet" that the interpass temperature was too high. It is, therefore, concluded that weld quality was not affected. Ferrite checks of welds where tempil sticks were not used show acceptable results."
This NSC audit finding may have been based on findings of previously
_ . conducted Pullman audits. The inspector interprets the NSC audit finding as implying that Tempil sticks were not used at all by Pullman welders. The Pullman response makes it clear that only for those cases identified by the Pullman auditor was there a question as to whether the welders audited were using Tempil sticks. The
, inspector found that Tempil sticks were used by Pullman welders as a matter practice during the period.
The inspector has no further questions on this subject.
- c. Criterion IX, "Special Processes", finding 103 of the NSC audit states that, " Welder BF (W. Adair, 251) performed welding on yW-70, 72, 73, 76, 77, 78,100B,132, and 133 in isometric package 21-7 and IV-88, 90, 92,134,135, and 160B in isometric package 21-8. This welder was not qualified for the thickness range;, and the welds were reported on DR's 2536, 2538, 2539, and 2899. In accordance with Pacific Gas & Electric Company disposition, some of the welds were radiographed and found acceptable; welder BF was qualified to the thickness range; and all the welds in question were accepted. This disposition is not permitted by 431.1, B31.7, and ASE Section IX, which all specify that the welder must be qualified prior to making production welds."
The Pullman response. states:
The deviation cited was found by Pullman Quality Assurance and reported to PG&E on appropriate deviation records.
Reference to DR-2536 is incorrect.
The auditor is completely incorrect in indicating that ASE .
Section IX, B31.1 and B31.7 do not permit welding prior to qualification. No such prohibitJons exist.-
DR-2538 Revision 1 and DR-2539, Revision 1 dated July,1975 l report 2-2" butt welds in Diesel Fuel Oil (160B and 2005) made 12/17/73. Walder was not qualified for small diameter (3" and under) uniti 2/28/74. -
Both DR's use the option to qualify the welder by radiography (see 1971 Section IX Winter 71 Addendum - Parasraph Q2(a)).
Both production welds (1605 and 2005) were.radiographed and found acceptable. PGEE accepted qualification on this basis.
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. i DR-2899 dated August, 1975 reported 14 butt welds made prior to
. 2/18/74. Investigation shows these were 2 1/2" pipe size.
Prior qualification by DR-2538 Revision 1 and DR-2539 Revision 1 covers qualification of these seams. No further NDE required..."
The inspector questioned the response to the finding because the code does not allow a welder to perform production welding prior to
-qualification to the particular process. The inspector considered that to adequately resolve this finding the licensee should have radiographed the other fourteen welds in question. Investigation into this ites determined that ihrring the 1973 HOSGRI modifications the diesel oil fuel piping was re-routed. During the re-routing process, the two piping runs containing fifteen of the sixteen welds in question were el4=4 anted. ~ tee o'nly currently installed weld (Weld No.1603) was one of the two welds originally radiographed oy
, the licensee to justify the acceptance of the other fourteen welds.
The radiographs for weld 160B were reviewed and found acceptable. t
' Additionally,' the inspector noted that the original NSC audit ,
. finding came from a Pullman internal audit that originally identified the discrepancy. Therefore, it is apparent that the Pullman Quality Assurance Program was in effect and was ac',ively identifying problems in Pullman's welding program.
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The inspector has no further questions on this subject.
- 5. I. Manarement Heetina .
On October 14, 1983, the inspector met with licensee representatives t denoted in paragraph 1. The inspection scope, observations, and findings
,were discussed. *
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COMMITTEE ON INTERIOR
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$~~~d_ ;ll::E: dh AND INSULAR AFFAIRS Tc==-
NT.9, 7 Se".m. "em"o. U.S. HOUSE OF REPRESENTATIVES couwse.
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,,, WASHINGTON, D.C.20615 g'""f"M7'i- EEE&._.
_ yg,;,, February 22, 1984
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The Honorable Nunzio Palladino Chairman United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear kr. Chairman:
Pursuant to the Committee's ongoing inquiry into the functioning of the nuclear regulatory process at the Diablo Canyon Nuclear Power Plant, I am writing to request the following informatitn:
- 1. Please summarize the status of the staff's inquiry into
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$' allegations that pipe support calculations were not j performed in accord with the requirements of the NRC regulations. Which piping systems, if any, will be modified as a result of errors in the pipt support calculations?
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- 2. It has P'en alleged that inspectors at Diablo Canyon were
, h instruct..d that they should not inspect welds on materials
! supplied by vendors, even in situations where the welds appeared defective on the basis of visual observations. Has i the Commission established whether such instructions were
, issued? If such instructions were issued, what was the purpose and did they constitute a violation of the commission's OA requirements?
- 3. With respect to the findings of ongoing inquiries, SSER 21 h (P., E-13,14 ) states that " . . . no direct evidence was offered by the interviewees concerning experi?sncing or knowing of any corner cutting, intimidation or harassment ...
and that management was " responsive and supportive " of employee
. concerns. Does the NRC now possess substantial evidence that would cause the staff to change SSER 21's findings regarding harassment and intimidation?
- 4. What is the nature of ongoing investigations into allegations of intimidation and harassment? When did the h Office of Investigations initiate its investigation into this matter? How many investigators have been assigned to the task? When will the investigation be complete?
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. jb! 5. Does the Commission believe that PG&E fulfilled its commitment to comply with the Commission 's regulations pursuant to Appendix B of 10 CFR 50 in the design and construction of the Diablo Canyon powerplant?
qL f6 6 .. Were the OA requirements committed to by PG&E vis-a-vis Diablo Canyon significantly dif ferent f rom requirements committed to by utilities that received construction permits '
in 1972? In 1975?
-y p 7. Was full documentation demonstrating compliance with the
.D Commission's OA requirements turned over to PG&E by Pullman Power ^ Products and the Foley Company prior to issuance of the ' low power Operating License in September 1981?
8 '.( Does PG&E (as opposed to its contractors) possess now a
- comprehensive collection of the records (e.g. work hd packages) indicating that specific tasks (e.g. specific welds ) were ca'rried out in accordance with the NRC's quality assurance requirements? If.not, when will such records be turned over to PG&E?
- 9. What specific rework has been require ~d at Diablo Canyon as
{d 'a result of inquiries, undertaken since September 1983, into allegations of failures to. comply with design or construction OA requirements? What is the time schedule for completing such work?
py 10. The following refers to the summary findings of the Pullman r audit of Pullman Power Products conducted by Nuclear Services Corporation (NSC) in 1977 gY a. What is the Commission's assessment of these findings?
RG . b. To what extent do these ' findings indicate significant violations of the NRC's OA requirements?
(d, c'. Please describe the nature of inquiries conducted to determine whether the NSC findings were valid and if so, what the implications might be? Please provide all reports prepared by NRC staff and contractors in conjunction with the staff's assessment of NSC's findings.
gd d. Yhe Pullman audit states on Page 22 under Item 10 that control of the welding process was inadequate in several respects. During what period, if any, did such deficiencies. exist? If the deficiencies listed under Item 10 did exist, what is the basis for a determination that weld quality is that required by the' c Commission's regulations? Does documentation exist to l' demonstrate the adequate resolution of the alleged deficiencies listed under Item 10?
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- e. The Pullman audit states on page 25 that " . . . there is
[d no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements?" Does the Commission have. documentation
- to refute this finding? If not, what is the basis for a finding that, for welds produced- prior to early 1974, weld quality was that required by the Commission's regulations?
- f. Do the Commission's regulations require prompt reporting to the NRC of findings such as those listed ID lRV in the NSC audit of Pullman Power Products? Did the-failure to promptly report the NSC findings constitute a violation of the Commission's regulations?
I would appreciate receiving the Commission's response to the foregoing questions (including additional views of individual Commissioners) prior to April 1, 1984.
Thank you for your . assistance.
Since rely ,
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- MORRIS K. UDALL Chairman O
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