ML20136B285

Draft Commission Paper Recommending Approval of Transmittal of Encl 10CFR50.54(f) Ltr to Util Re Error in Seismic Design of Equipment & Piping in Containment Annulus.Related Documentation Encl

ML20136B285
Person / Time
Site:	Diablo Canyon, 05000000
Issue date:	12/10/1981
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20136B092	List: IA-84-293, Revised Testimony of Wp Haass on Governor Deukmejian & Joint Intervenor Contentions 6 & 8 Re QA Design ML20136B086 ML20136B108 ML20136B120 ML20136B209 ML20136B238 ML20136B265 ML20136B272 ML20136B278 ML20136B285 ML20136B293 ML20136B298 ML20136B309 ML20136B313 ML20136B321 ML20136B336 ML20136B349 ML20136B361 ML20136B369 ML20136B395 ML20136B405 ML20136B417 ML20136B436 ML20136B466 ML20136B485 ML20136B552 ML20136B616 ML20136C187 ML20136E236 ML20136E544 ML20136E550 ML20136E554
References
FOIA-84-293 NUDOCS 8601020506
Download: ML20136B285 (198)

Text

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./p)n e-1 z.p-OR:f . . :u :n The Commission'brs: - 7 :- cc. t :t .- -um v t , .. .. .

.JROM: i..i ' ' itih . William J.-Dircks; Executive Dirdctor for Operations:: '4 Fi.. A n ' l- '

t JUBJECT:: 2 9.p,'.i r DIABLO CANYON UNITII SEISMIC DESIGN' ISSUES

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NUk. POSE:;: 4;s a, 6 :

1 t rm :t : To obtain Commis'sion.apprpval ifod.btrarismittal of. the'attachid i' - "

' .::-l.tn i10 CFR 50.54(f)Jetter tonthe Pacific: Gas & Electric Co:apany- - '

'i DISCUSSION:W:.

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m. .ti Corgission In SECY-81-6361 ths staff forwhrdid!a 7 draft 50.54(f)l:G' rletter to Pacific.Gasfa

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-T .c 4. r .et.m-int whs briefed , Electric Company:{PG&E). The u M l" .

s.', i t , . r u: n..s.e: on this matter' on November 9.; 1981..r:: A- -

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r ~ .. c. Based upon: discussions:during: that. meeting .:the draft: 2: -

's e 1 50.54(f) letter: to PG&E'was revised.' i > . r i. . . . '. , ' 3 i .. t . . J u .i _

TREC041ENDAT. ION:.' sit is; recommended that:the Commission approve the transmittal 'of i

the attached-letter to-PG&E.

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"9 .e'. i .."r! t i: . '.

William J. Dircks, 24 1-

, i Executive Director for Operations -

Enclosure ' ~ ','

cc: SECY OPE . -

OGC OCA - -

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Contact:

.  ; 1 Frank J. Miraglia, NRR ,

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8601020506 851125 o .

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! PDR FOIA LEIGHTOB4-293 PDR k a

Mr. Malcolm H. Furbush -

1 itce President - General Counsel Pa

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1 4.cific Gas & Electric Company D. Box 7442. ' ..: 'O - 84 ' * '1A' r ' '

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- 1 i i i San Franciscoi California 94120 i! '

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! tear Mr. Furbush: ~

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q Jat,efeptemb,ey .1981ian error sin the: seismic design , g L'[ "t Y %f'eq 0 "

g n.theicontain' ment arinulus-of;Diablo Canydn UnitD1!was yPidific'4 W O 'l #"

' detected b 3

q,.;,,gs.;and Elect,dc: (PG&E);tand ifeported ,

i toe q,i ...t thedNRCd ?PG5E .' initiated "a' 'reai1Idysis N + ! T

j Portic'nsgof6thefseismic design' of .the'ifacilityi.f As' a 'resul t! I 'n'uf,.bdf ! 5 "

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fg d,f f,ferent..aciditionali errors thaVe 'beeni fourid.Nt At ati October 9 i i -(n:eUng.betwe;en !PG&E and.the NRCastaffj we'rsquestsd , "i ' : ' ' ' E ? i "

..+, thai.following. activities;and s'ubmi.t

the 'documentin'g'0reports 8b ' '

to the h N

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A . technical. report that disciisses the regnalyses conducited .

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i. g.h M.i t,w: .- the seismica design 6f theistructures, systems and components

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4. top.:.in the containment. annulus of Diablo Ca \yori llnit l'and any Pi

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ui -17 n modifications'.resulting from the .reanaly' sic.' cr t.

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. r C(2) e Aiverificationlof. alh safet.t-related sei'siriteIddsign .

tt.: C:u, V ; performed'under!the :

. . _ . activittisil1"'.49WR*61 ~

I PG&E/Blume' contract. as ;they : relate to ths r1

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e Hosgri reanalysit. . u .s ;r r..- : e 'M 1 !

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t.h(3) A<v;erification 'of!the' seismic! design of; tall:' safety-related .i:t !

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1 e : v. c structures; tsystems; 'and! coniponents;;1A; program p1an foru;S.

this t:t:- ie.

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' N.. effort was 'to!be .provided for WRC staff review.1 ;i ii c .$ - := J.i -

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i, i ,. . Based upon recent NRC . inspections conducted at PG&E an'd+the!B1dme' Offi'ces P- I ' * ': M" '

i ,lInJan Eranciscogthe. HRC 'has.. identified!a!numbsr ofeQuality AssidrincF'(QX) " ^3 l- -

4 r. ; !Prograa weaknesses related both to theselerrorstin1the~ Unitilsismicidssigh s v!d c'd 8 i ri1 $nd ito the..fmplementation by..PGAE of: applicable" criteria of! Appendix"BC D4d ': ;

! i i ;of c1,0..CFR

Pa;rt:50. ?. We:have' prelimiha' r fly concidded.ttdt:i WLii ' J tlkM J'i '

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4. p!, jg .,ilan the.;PG8E QA; program didinot appear to effectively exercise! con' trol * 'diu '-

spt cm . ec; pve? f.heTrev.few.aWdriipproval of designdinfonnation passed to 'and-

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. received from Bl ume, , . '-

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i qia 6pjb. sthe..PG&E- QA Program did not appeari to ta'dequately cont?ol the'i 0 r ,

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! .t.. , .,e .u;; 3 distribution .of desfgn-information from Blume within'affected - t'- Ox-  !

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< internal PG&E design groups, and. ;i a ? :?: W .; * . -

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-y ; +: . c..::ThetPG&E -QA; Program did .not appeartto defineiand imple tent adequatu / WIa -

p..  ;.r. s y,=. quality. assurance procedures and controls:over other service:related V l -

contracts. .

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vi, A follow-upieeting1was held' oneNovis55ei*341981 'between PG AE and!the NRC t t:

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'i - l' staff _to furthe'r.. discuss these; seismic. destgriierrors and-related quality A @ -W. - i isi isssurance :progr&m deficieRTes. - -Based on these . discussions and'our review:  !" o' '

to, dates we-thave-determined:there is:a n'eed for : additional infomation to 4 e u %

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X bo.:p' rov.ided.b' y . PG&E.to: the- )(RC. cAccordingly,'you are requested .in accordance .ti .

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ub rwith;10 CER:.50:54(f)h:tolsubmit Written statements. signed under oath oi . .1 i  :.u . .i t '

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u- affirmation.concerningithese: matters toi enable:the Corrnission to deterbiine ' - '

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i'. 'whether orc notiyour license *should'be! modified,. suspended or revokedr . 4  ?

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Specifica11yryou are requested to submit the following information to  :

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the NRC on the ~schedhles indicated below:

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i 1.ci At least 45. days prior to the date you p'lan to procee'd with

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. : fuel loading, provide the' following ' info'rmation:

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For. All Seismic Service-Related Con'tra'c'ts Prior to unel'975 T'y. !

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v,4.r..lal The results of an.; independent design verificati6n prosrain ' '

.....D 3p h 3.. . Pi! .1 Np all . safety-related activities p&iformed prior' to Odn'e 1,* * '

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,io ps(n O.4 vr.,' 1978.under. all seismic-related ' service contracts' utilized ' J' i ' " '

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R !, i4. y.,in. .the. design process for safeti-related st'riicturei,[systemsj' ~

.. .[ , i.- and components. c . - *

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, r,: p.gr . J H H u!:Information concerning this program should address ydal'ity'!I '

,c in pi:hi fiW9 . assurance proc dures, controls and practices condernfrig the ' '- "'

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. developmentl,. accuracy,' transmittal; and use of'all safetf ' 3 ' 3 "

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i, ;v. .:s related.information both within PG&E and within ea'ch'h f -

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.:U. contractor's organization; as Well as 'the transmittaFof 9 h '

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. .;,information between PG&E and each contractor. - It sh6uld e .

w. . o n .,

i. .: ca also include performanc'eof a suitable number of sample- ' ' *

.y L . .. . r t; calculatiorls relatgd to, each con' tract to verify the >

i. a . F n, D i rN tl !"'i '.!1': adequacy *

.and : accuracy of the design process for affected ! .

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. . ...wr,,.f. rn.raysafety related structures systems , and components. The' 'l'

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..;,... uan.3 j ;a linformation .to be provi.ded concerning this design a

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.: : verification program should be: based on and include '-J  ! l r-

.:n i:W .y r i$ .t .the results.of conducting the prograin elements set forth in Enclosure A. '

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., >.,i., . . rig (b); A technical.. report that fully assesses the basic cause ofi )

,t. w t C .I :D 1 pi:1 i- .j all design,. errors identified by this pro. gram, the signiffiance

~ ; t. . i,p:p. q. if . ... id i i N of. designierrors .found;Iand' their impact on facility design' i .-

. . .i q r,{: d e.: v:!:4(c). PG&E's c6nclusforis on ths effectiveness of this desfgn -

I ~l a, .e! }e .s.t.:g..::per p 3 verification program:in. assuring the adequacy of facility design. i . .

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.: % 4 5.p: nn : s..itrrg(d). A. schedule .for: completing any ' modifications 'to the facility: ' i w

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3n' i.:.ot.n e : ;uqu:,i: that are required 'as a resul t of this program.. For modifica-4 .-  :: : : : :: ti ; ;. h it y.. .tions that you propose. not completing prior to fuel load; the a

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.t 2: i a: y,ta bases for proceeding should be'provided.' -

r i p:: oin::v2s r At least 45 days pi'ior to the date yo'u plan to proceed with'i' N V . ":c: r. '

J !.:l :s1 : -er operations above 5% power., - prov'ide 'the following infon% tion:; 8!' c': . t : :i 1

!.p ;r : u,pgrp .py. + (a), !Fon All:Other' Service. - Related Contracts Prior to June.1978 r '

'u m :.:t si t o % t! ..',.n,i(1) . The results.of ari independent design verification program i

.; , . ;u t 1:nat :. . of allisafet'y.-related activities performed prior to .- ..

l' & . d .e:4!'t d 5, c June-1 L.:1978 under all non-seisaic service contracts

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.j . sj cq g; ;..m. : jt. util.ized in the tdesign process for safety-related i. . i

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. structures,' systems and ' components.'

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Information concerning this-program should address f;ua'li i . . .! .c) , ..: 1...,I i i.. ,- .

assurance procedures, . controls and practices concerning' -

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. . (.je;i,'y .', ;l'. VIM.i.. the development, .accuracyg. transmittal' and use of all ' - , '

.n, .. y $: y;,.;.;:p i. .

t . safety-related .infortaation both .within' PG8E and withiri -

3.iJ3.iq M r.ind hi.}t .ieach contractor's organizationi as well as. the trans' -4'- '

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mittal-of information between PG&E and each ~contrac S-It should also include performance of a. suitable nuraber s '; '

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of sample c,}1culations related. to each contract to 'vei-ify ; '

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the adequacy and- accuracy 'of the design process for' ' #,"'i-d e ;a, t aj i.-

., ni; . '. i, ; affected safety-related structures, . systems and componehts.- '

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i ! The. in' formation to be provided concerning this design

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verification program should be based on and include ' ' '

r.) .u.; :t . .qr. o 1

,the risults of conducting the program elements '-

set forth in Enclosure A. ' . . .

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(2) i A tectinical report.

a that fully assesses the basic c~ause .

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ofn. all design-errors identified by this program, the

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.i', o-M ..- signif,1cance of de. sign triors found, the their impact on'. facility desigri.

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PG&E'.s; copclusions on the. effectiveness of this~ design -bi I

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. verification progFam in assuring the adequacy of facility i design. .

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H. Furbush . .

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.l  ; (4): A schedule for completing any modifications to the ' -

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N ,- facility that are required as' a res' ult of this progrcm. r x 1i J :.i> pri r.t i3. .; For modifications that you propose not completing prior u.

n. p . p -: :' r.. t o i ir: . : M u.: to operations above 5T. power; the bases'for proceeding -

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1 . should be provided. -'- _

. ;p 41 a :i..a. .. (b). For PG&E: Internal Design Activities

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^(1)' The results of an independent design verification :. _

a l' r.u i,i?J/.rr. ..:li s .! p :.c..

2 l.i. program ci;PGiE internal. design activitiesi performed .o :' . .

a if c i a Hh 5 r V. on Diablo Canyon Unit 1. related to the development i .

C hr.;: 2;.y .v: . a- of the design of a suitable sanple of safety-related

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.:.- , i: a stru'ctures, systems or components. . The extent of .

i, I :r c v. iiin g. p i. thes.information provided related to this p,ro, gram a. ' ,:-  :

i rl l .1 .- t : : .4i. %.;.v e  :. should,be that.which .is ~ necessary to detemine 'whether' - "~

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- -7 v- the overall PG&E qualityiassurance procedures and : ': '  !

. t+V a. c, r : ; ' controly described 'in its QA Manual and associated i 5 -

.t.  :'- dt s e - procedures-since 1970; have been fully and effectively i  ! . . i . : < ; r:". .>aF iimplemented. 3 This .infor; nation.should also include- t .~

. ..;, -;;. >: m M .r.'tl.i:.e v ;t: 'a. suitable number of so:iple calculations to verify .

P,  ! * . .' . t : :i a , - l

.i the adequac.) nd accura'cy of the PG&E internal- , -

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-;[.i n t$.i c r.- design Iactivities, for the sespl e.of' safety-related . ' >:

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. 4: 2.P.c rr ri: a '. structures,isystems," or! components. ;The infor::iation

:1 i .ipm i n i. i : i . . < .n i  : to be' provided concerning.this design verification , .

u. m 'M- program should be based on and include the results i

. . .- of ponducting the program elemsnts set forth in -

Enclosure B.

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(2) i A technical report that fully assesses the basic i-p t. ,i.;.t.- T ~i a r

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cause of all designe rrors identified by this9< +

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t i s progr.am, the significance of design errors found, '

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.and their impact on facility design, i"

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,p: @ .:!.s. M :M i.1 r. ;(3) J:PG&E's conclusions -on thi effectiveness of th'fi . i :.'

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.H i > .ineso @ing :i a 7 .,, d 3 esign ,verif.fcation program f,n ass' uring the adequacy - >

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of facility design. .!

l 10 i t e . M.L n: t i.r : (4) ' A schedule f6r completins any modifications to i 1

a iT7 e t..! n : ti. N .. e tiie fadlity that are required as a result of this t.r . . p s.,

. .-  ; # . :: 1. program 7 For modifications- that you propose not. " -

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:. i,: . r,: % . t..F e ir : - V canpleting prior to opeiations above 5".. power,' .  ; - '

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the bases for proceeding should be provided; - .

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.ti.. (c) For A11hervice-Related. Contracts. Post-January 1c197 '

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.; 4 3(1) The results' of an independent design verification' - '

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program of T.su3 table sanple.of the activities . i

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. performed,ca Diable. Canyon Unit 1 by each service---

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.g r3 Jte.d. contractor that were: completed s'ubsequenU :

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J: u to January 1,1978 related to the development of[ . J. -

te:t t . 4 + -  ; i- t ,:

- he design 6f srfety-related structures, systens 4

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tTitFcomponents. , The extent of the informationt '

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, provided:related to this program should be that which:  ;

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, is hec.essary'to determine whether the overall contractor.

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..- I H. H. Furbush ~ ,. ..: i

. . and PG&E: quality assurance procedures and controls m.. ..... .

i,o .. r  ; that were in effect during this time period were' - .

,i.vt i ii .119, p;.v$: .fullyiand effectively implemented.. :This informatibn i t

' should 'also include; a . suitable nurr.ber of sample

+. : + , r n. 'r i s p.i ..

i'a ,t ir,s.. er.f. i d . ;c ..; ,4 ,: -calculations to verify the adequacy and accurach .

i 1.r. Ui-;W6P hit i; -e 'll ' '- l of.the tample contractor and PG&E design activities i h., 43 ; ig.t ym N . 3 mfor safety-related structu.res, systems and . omponents ' . ,

i,; -re. b a ir. n - , ~.Jhe-information-to--brprovided concerning this ':

.O j ,:. . ... . hJ i . t ..,. o  ; design verification' program should be based cn and .i- i

. v. c . . L t j; e . include the results of conducting the program *

- .

r.  ; .: !.- i , 5. eleme.nts set forth in Enclosure C.

j. . . j : ri P;.ic-t ys -> ' (2) A technical. report that fully assesses the basic d.u '

p . . a . ir,: . gr.A.p -

cause:of all, design errors identified by -this program;- '

4 1 yiiJ.re..c' 'g.h +i the significance of' des 1gn errors found, 'and their - i' 11npact on fac,111ty design. .

P i> ..t! i F , :. i:1 .i . i (3)- P.G&E's daclusions on :the effectiveness of this ..

l g y , r s. a. (. :." '2ry. -

design verifi~ cation program in assuring that the

.g i .; ! , ,... 7 .e.1 .. idequacy of facility design. . y'

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.- -(4) > A schedule for completing any modifications to .

ti i n ab i. r's- ~i L- the facility that areirequired.as ,a result of this .

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. programa:.Foi modifications that you propose notiv - -

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completing. prior to operations above 5". power; the l

. ..  : bases for proceeding should be provided. - '

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f N. H. Furbush -

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., a 3; Within 30 days. of .the date.of this letter,' provide' the following -

u. . r . . . s . / information for NRC review and approval: ~

' ' i ' ' -' ~

1 i.;.l3 :..:: n. . ... 4 . t..,,.Qualif,1 cations of Companies Proposed To Corduct Independent.Rdv'ieds'

!l.

g.,9 v.o h.i ..; ! A description:and discussion:of the ' corporate qualificatioits *'

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. qg. . . n;.:i - f.; of the companies that PGaE would propose'to ciirry 'out the ' - '

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. . -Js various independent' design'verificatio/n programs $ r 4 -

,,;l ue p .: ;; . i...; n .,p o i discussed in .l .and 2 above,1inclu'dingif nformation' thHt '

-" P) p, 3 ;.17. { < J .., demonstrates the .f.ndependence of these companies;. ' " ' -' ' -

.( l t;;cti ra,l4. ..Within> 20 days of theidates of HRC': approval of the c6mpanies' "~ ' '-

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in ini, i - : toiconductithe..variods . independent. design verification' No~ grams; F J-

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,.1.u provide ithe: folldwing -information forrNRC:revie~w and approval: .- -

i. r{;;&!, d t. 3pi Program Plan For' the Design Vdrification Programs ' !'4 . n. ? -

I

• iitt I : rf h:.4. A detaiTed program plart for.condui: ting ~ the various de~ sign !( - i:

.mj*ryb rnturoverification prograris;discussid in 1 and 2 above:" The'infonnation i i

,.ips.: p m s.u;,.. provided should,in'clu ...de the-bases for.the criteria proposed ' i i

1 9m 5

b'h a t to be used for selection of a suital.,le number and type'of; . 1

.)

. a . ip ': sample calculations to be performed under these programs.f c;J. L: ": .l 7

m:.:ria t ;ez.leti;.and .the " bases forethe cri.teria proposed to'be'used for expanding *  ;-

M m s , i p r *.

mi" the sample size based upon the.results of the' initial sampless o' '

/

i,t rp . 4 . y . 'In ' addition, the criteria for -selecting the e sample safety:

tilI "' l I 31. t: t;ar.J. :; i related strhetures,' systems and components and' sample contractori . . t seew}.a. 1" activities .in theidesign vertfication program'stinder 2(b): , '- <

~

and 2(c): above should be provided. e. e . .: - I l

i l * ,

1 -

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

~

..(

O e

l 1

1

)

d. H. Furbush i Status Reports) '

5. . '

' d' # -

27,1981,ia semi-monthly status -

Starting on Friday, November

t '"

'tn ;.. h~: L si =e i report on .the second and fourth Friday of each month,'on' ' ' ' ' n+- te '

I is'fi- ,

r,s n . .

$ ongoing reanalyses efforts and design verificationjprogran # .

d for: PG8E, should be' submitted to th61; CT

.rir n. ;being conducted by an -

' N -

Director,.0ffice of U "

y!> "; . . Regional Administrator,: Region Y and the' ~

3..J f .".r I' ~ i :

-' 7-

. Nuclea'r. Reactor Regulat[on.* ' '

W; .

.- tion.of yourisubmittals, se reque' f s t 'A i' "f -1 N' ' '

f l ' '

• e iInitha.interesti of efficient eva ua onse to the requer,t' for additional M '

(

that..you. subutt as soon as practicable a' resp

the _ Staff's. Meeting Summary dated October 19;?-

information th'at was enclosed;f o' ~2

.i : - T T'- -

.1981tg on the October.14-16 meetingsi With PG&EU: : .

~ Sincerely,

. - - ilarold 'R. Denton, Director Office of Huclear Reactor Regulation

+ , ;: -w -

- . ~

Enclosures:

As stated .

. [

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- - .-.d

. , , _ , . ~ .

- /

ENCLOSURE A t i o n ' i .: '

g; "

, Elements Which should be Included in the Design Yerifica r .

bacli,"

j;.1.,. .A review of.all quality:, assurance

• piocedu'res and controls;used ~

t

' by Pd&E:with regard t'o tha't cdn'tNct;'

p : y : pre-June,1978 service contractor' and'by' C j-3 ,u a comparison;of_.these: procedures. and contiols with the relaf.ed'britdris '  ; - '.

c.,p of, Appendix B to .10 CFR 50; -and'an identificati6ti'of'ahy d

~

i ' '- ' '

the quality as.surance procedures'and.in controls 'of [-

, ,9 3. . or weaknesses-ini ~

'3 1 9 '*"- M 1C . . .r; .-

<- the contractor and PG8E.* s .- "

. 3 phlated ' - ' 'ii i a;j s-

, y 2..dDevelopmen't of.a-network for the desigM chain f6rja11 safety >

structures,. systems =,. and componentsrinvolved. This'should 'ini:1ude "

PG&E intertial'

. .. .,i . interfaces.where designinformation'wasittansmitted :between "5 1E Y~ S 1" "'I ' ': !"'- I:

p design groups and each contractor.

. s.1 34 Aireviewlof.the. impler.ientation of quality assurance -proceduies and

- i

~n

' controls used by and for: ,

IJ

. so PG&E internal design groups.  ;

L-  !-  : a- -

[

each contractor inteTaal. design group (s)

,..: . t o. '

i >

. ' .rcc. sao. transmittali of'information between PG&E and each contra'ctor '

h[

g!

e i.

J: et. ;o , transmittal 9Y contractor developed information within PG&E -

.t .

':i and, identification'of any- deficle'ncies' cr weaknesses-in/the - .

s .2 ,. g

,- . m; 7. 'i t ii . inplementation.ofuquality assu'ratice procedures and controls by H

' - ' .-  : t:

4 each contractor and by PG&E.

t 5 ii 3 ,

. 43 Developaint of:cr. iter.ia .for the conduct 6fdthis design verificdtiori I

' 6

! I' -

r; i program should consid'er the guidelines contained in ANSI' N45.2.)1,

)

.-

• j' Section 6.3.1.

ii

~

! "~~~~~~

~~

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

- - ~ ~ - _ .

. . r c..,

Enclosure A (cont' d)

- 2- .

t ,

. S., > Development .of criteria for. selection' of 'a ' suitable number and' type of p g isample.calculattons related to ,the design ofisafsty' rehted stfucturss' .

'- "" r G

at pisystens .,and components, involved.;; .The p'u'rpos'e of these' sa#1e halculation 8 af  !

s i ipshould be to verify..the design. pscess; particularly in'th'e'arsas of * il

' !T' >t 4

l g pp iny identif.ied. contractor.or.'PG&E qualityna'sturance' weaknesses orb #:!C '

.;p gadeficjencies! as , determined:from 'the procedure and impleie*ntatfori reviewd i 7" i' l '" '

r

,3. , discussed 1,n

-steps;.1.through.3 above.." CrIte' f a' fo'r ex'paddirig'the ss3;il

' '( " - ,

9;:i s1zer.when problems in verific,ation are'encounterdd should als6'bs' '

developed. . .

e M O e

e

e. .

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e WI'amm 9 g e #N. W -

b

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ENCLOSURE B

. Elements:Mhich Should be Included in the Design Yerification - t' .

>- 3. i. - '

. .e..... Program of PG&E Internal Design Activities y 4 ,

' - I,

]

{.} f . -

.* y12 A, review of alls. quality: assurance: procedures'aand, controls used by internal' ' , . c-Pn .; : i-

.. ; .iih. PG&E: design groups by selectin'g for' detailediexariination certain safety : ,

~

t tuthrelated structures ' systems or, components 'as! representative.[amples of: e [ :A. t :[

'. U

,' Mnthe. overall- facility.. design'. . A:. comparison of..the. PG8E procedures and e t. . .

t- wri.controlsrused for the sample structuresrsystems.or compon'ents with them

• v t-

b:6 ~.i m .related criteria of Appendix;B to 10 CFR-50;i'and cais identification of r:

tt-

! ni $'il: any deficiencies or weaknesses.in these PG&Enquality. ass.urance' procedures

~

'. and controls. .

~ '

n.!

'r : t aZJ UDevelopment.of a networic for;.the design: chains .for. the sample structures,.i 99 a m en, systems oracomponents-i.nvolvede,.This.shouldMnclude all ;fnterfaces where. (m i ., t e t Wi disign'infomatf ori vias '.transthitted between'. internal..PG&E design:. groups.ru:u

- .30 A revies of the'implementationt of,_ qual'ity assurance procedures and controls.  : n.

. m's used in th'e de' sign of .the shople str'ucture,.: systems or components by ..

, t.::  ;

I.9 .. r

• intsrnal.PG&E design groups;'and-an identificatfor of deficiencies.or.' i. it ..

'+..

h h.. i iweaknesse's irr the imple5entation' of quality

assurance procedures .and

. .c i ,

o

> controls by internal-PG'&E design groups..i 4.i.h . .- . 2 Ma: ;. -i .

i

4. -Development of criteria for the.~ conduct of tthis desigin verification 4  : , .

ie 1:-i s progras should consider the guidelines ' contained;.in ANSI: 45.2.11., . 3 j

I Seck ton 6.3.1. ,

. g

. t . s

- 1 e

f 4- -

P l

. ae I

-~ - - - -- - - - . . - , . ..,,,,.4+-..*y**-""

f r Enclosure B (cont'd) -

2-

., .. 5.

Development of. cr.iteria for selection of a 'suitable number and type of ' *

• Si it

,. m . i, sample. calculations related to the design 'of. the sample structuresP >'- #

!+

.:,t t systems .or ccoponents . involved. .iThe purposehof these senple' calculations

( i:

4 i !.:should;besto : verify. the designp' rocess'; particularly in 'the area's'of

't i '- -' i ' ' '

q tp i fac.any identified.;PG&E. qdality assurance Weaknesses br.. deficiencies' ~as's : e i

l';'-i'-

n: - tmt determined from ther procedure and implementation reviews discussed P  : -' :"' ' -6 4..i  : oW in steps 1,through 3: above..:

Ct1teria for--ex'pandiphe rsspTevsTie r m  :' i

1.

.e n den problems in verificationsare -encountered s ' hould 'also be d&velop'ed i

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.. f' EHCLOSURE C '

, i u

. Trogram of Service-Related Contracts Af ter January 1,1 ~

r,

, s 1. 3 A geview of. quality assurance procedures and controls used by each post

,g .

. . . , January 1, .1978 contractor and by PG&E with regard to that' contractorrb) '

, ,tr: i r, selectinggor detailed examination certainiactivities of the contractor. '

4c .. i , As representative Samples 'of the entirela'ctivities cal r'ied outi a ' d'

t.  ;;

g comparison of the procedures and controls used by the contractor and' O'- '

3 j, ,.  :

j'

..;. PG8E for the :samp1'e activities with thehrelated criteria of Appendix'8 ' -

, 7 (, .to 10 CFR Part 50; and an identification 'of -any deficiencies or kcaknesses

4e .r , i. ,

. l ,

in the <'uality assurance controls of the c' ontractor and PG&E '- ' ' ' "

t i

\

24 Development of. a. network. for' the design chain for the structures, systehs '

9;.:i or components involved with the sample activities.

This should include ' - -

l' 3:..

. all: interfaces where .. Idesign information was transmitted between PG5E' '

tr,

, internal design groups and eac.h contractori . ' - i.

,3. '

l'\

A review of-the impleinentation of quality assurance procedures and i

i i controls used in the conduct of the sample activities by and for:

l

- o PG&E internal- design groups .

p. !

o  ;

. . i.

each contiactor . internal design group (s) .  :  ! ' ' -

i i ,

.. .o '

transmittal, of information between PG8E and each contractor-o; transmittal of:co'ntractor; developed information within PGAE '

q .i and.an identification of any deficiencies cr. weaknesses in the t .I

.t

.. . implementation..of quality assurani:e procedures and controls .i

io

{

by each contractor and.by PG&I ~

.. 1 l

\

$ e

,, _ m - * - * * *

• r f.

.. .. ~ -

Enclosure C'(cont' d) -

2- '

i ) .- 4.. Development.of: criteria for the conduct of'this design verification '

r.;- sprograintshould: consider .the guidelines contained in ANSI N45.2,11, '- " ' " F -

i Secti6n 6.3.1. . .

a S.; Development. of criteria for. selection of a 's'ultable number and "tip6 of' ' ' di o'-

rit .-

t ;:.t.. sanple calculations related to the ' sample activities involved. : 'Ths ' -

- . ' O -

19 s.Q purpose 3of3 these sample calculations should be to verify .-the design processb4-a

. ij : .gpa-ticularly-in the areas oY anyTdentified i tontractor or PG&E quality l - " -

i ; assurance.. weaknesses or deficiencies las det' ermined from' the pro'cedure' : t - U

. u. ,3 %and implementation reviews discussed in steps lhtbrought3 above. 2 Criteria ' - '

.i at i. .for. expanding.the sample sije when p'oblems:in r verificatTon a~re' encounthred: -

should also be , developed. *  : )

8 . WB &

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• i l D Lt.1 '

j R. F. REEDY, INCORPORATED 236 N. Santa Cruz Avenue 1

Los Gatos, California 95030 = (408) 354-9110

. l, March 1, 1982 _

)

' ' ' ' ~

't).il $$

Robert L. Cloud and Associates, Inc. nw 125 University Avenue -

I Berkeley, CA 94710 d "~ ~

1, .

Subject:

Report of R. F. Reedy, Inc.

l

) Review of ANCO Engineers (Formerly Applied Nucleonics, Inc.)

\

Dear Mr. Cloud:

} Attached is a copy of our Quality Assurance Review

) report of Anco Engineers (ANCO). We have reviewed the

/ ANCO Quality Assurance Program as it related to seismic

/ safety-related design services performed for Pacific

( Gas and Electric Company prior to June, 1978. All J details of our review are contained in this final report.

)

I am transmitting a copy of this report to Mr. Harold Denton of the NRC.

f j Very truly your.

h oge F. Reedy, P.E J R. . REEDY, INC. l RFR:na

! cc: Mr. Harold Denton Encl.

]

l l ,

1 Fo/ A-84-M1 x,,, r: am.ix. i. r.. _ i:,,,,,,m ,,,,y c.......i. ...

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. l1 -

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QUALITY ASSURANCE REVIEW REPORT [j PHASE I '

h

- SEISMIC SAFETY-RELATED DESIGN SERVICES 1 l.t t j

PERFORMED FOP. PG&E

. 'N By

- i

~

ANCO ENGINEERS #

(Formerly Applied Nticleonics, Inc. )  :

PRIOR TO JUNE 1978 '

L. t o ,

F :

?

a

- 3

-4

,i i

i 9

ANCO - March 1, 1982 1/41

- -- - - - -- - . ,,geNgggy,y -

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in

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9

/ Quality Assurance Program Review Report i Phase I 5 f Seismic Safety-Related Design Services i

Performed for PG&E [f l By ANCO Engineers j Prior to June, 1978 a

,e Introduction i

~

, Scope: .

11, 1982, R. F. Reedy, Inc. completed the On January Audit of ANCO Engineers Quality Assurance Review and 3 (ANCO). i The purpose of this review and audit was to address the adequacy oi ANCO's quality assurance the development, procedures, accuracy controls and and practices concerning ,

transmittal of seismic safety-related information The basis by ANCO of this to PG&E and other consultants was to PG&E.to determine if the ANCO Quality review and audit as implemented prior to June 1978 met Assurance Program of 10CFR50, Appendix B for the applicable requirements the seismic safety-related design services performed for PG&E's Diablo Canyon Unit 1 Plant.

Type of Design Services:

During the time in question ANCO performed a feasibility study to determine if in-situ vibration testing could be performed on selected seismic safety-related systems and items to verify dynamic analysis that PG&E had performed- the result of the

~

systems and items. As on the feasibility study ANCO performed, vibration theytesting were contracted on selected to ..

and did perform in-situ seismic safety-related systems and items.

Contracts: "

l PG&E had identified two PG&E General Manager Authoriza-to ANCO seismic safety-tions (contractc) applicable These two related design services prior to June 1978. '

j (5-68-77 and 5-82-77) were verified by the Audit Team to I

be the only two PG&E contracts in effect during the time in question.

r Covered a feasibility study to {

a) Contract 5-68-77:

determine if in-situ (Diablo Canyon Facility) tests could be performed on selected items and systems; and if the test results would be meaningful for verification of the ANCO - March 1, 1982 2/41

. -___ esp.a een e .eme e= w ar4 + *h* e = "** *N. eet

• t? * -**==-e-em-e --

@ / .

lj

e. .,. -

designs for meeting the i of PGSLE's seismic The ANCO p;

/ ,s.dequacy Hosgri earthquake seismic criteria.

/

r '

postulatedproject/ contract number for this 1122.4.

effort was v

j!

t f Contract 5-82-77_: Covered the actual in-situ ij i

f b) ANCO performed on items and systems selected on 6 testiilg basis of the conclusion (s) of the feasibility studyident$

• d

,I the 5

ANCO (5-68-77).subdivided it into the tasks 1122.4B,1 through further 1122.45.5AAugust was added in 1/79 and task  !

Task 1978 and therefore j

_,,, 1122.4B.10. was performed - in Appendix A ,

1122.45.10 included ina this' review / audit. breakdown listing of the ANC1 neither were gives to this report _

tasks related to contract 5-82-77.  %

Evaluation Criteria: [9 dM' Our Quality Assurance Review < Appendixlicable of 10CFR50, and AuditB.of ANCO at g raddress We G

1. psfot p#j the required criteria valuated the ANCO Quality Assurance reviewed activities were Manual app performed, d ANCO the ime the available documentation and records, and intervieweto personnelrequired criteria of 10CFR50, Appendix B. Procedures were not a Quality Assurance Implementationas none were prepared by ANCO for this review therefore ANCO's part of these activities and against detailed control of could not be evaluated performance approved procedures. were Og/7 pointed that ANCO contracts It should be out the requirements of Igg.S and later and Audit Mg stMg initiated in 1977 Appendix B were published inthat 1970.theThe required '

10CFR50, find any evidence Team could not Appendix B, were Because referenced or of 10CFR50, of lity this criteria imposed on ANCO contracts.

specifically our reviewManual and auditANCO was performed against ANCO's QuaSpe Assurance Reports for their tasks 1122.4B.1 ..

the ANCO Final Test through 1122.4B.10 contain a certifying statement that reports were performed under and metthis the the tests and The purpose of requirements ofwas this manual).

to determine whether the required review / audit criteria of Appendix B were met.

Conclusions _: '

On the basis of our review and audit it was concluded that:

Quality Assurance Manual (ANCO Spec. QAM-(1) The ANCO ANCO - March 1, 1982 3/41

Y y [g':

l' k i

./

'I > ,

required preparation, approval d numberand of -

May 1978) ", f

[

.I 002, implementation procedures of whereby a sufficient 10CFR50, variety Appendix anif B,

accomplished could by ANC jf applicable criteria QA of 7

i k'

have been achieved.

I ANCO Spec. QAM-002 in April 1978 butwas ij'l pG&E accepted evidence made a formal g:j (2) no documentary PG&E pjp~

that . indicated and submit to PGLE for survey team request that ANCO prepare nce Implemen- p.

approval the applicable Quality Assura -

7 l l, tation Procedures, _

1 documentary evidence of any 3a ANCO did not provide review work . performed implied prior to control }j (3) actions taken to to the May 1978.

for compliance April 78 s requirements of ANCO Spec. QAM-002,by ANCO to evidence was provided l 1978 to f;

3 documentary (4) verify that activities performed No from Apri QAM-002, accordance with the T were performed in -

iy June 1978control requirements of ANCO. Spec. .

i,4 implied some QA files had tl; May 1978. ification to advised that Note: ANCO b.f inadvertently been destroyed without not '

'l PG&E. Team that of this Audit f the opinion is (5) g ufficient It documented evidence exists, during this or was

, use:u cuouw j

available ANCO, prior to June 1978,-had in fact - orwo<te M .

verify that implemented a quality assurance program.

Method of Review isted of the method of review and audit hfor (4) below:

ANCO cons The following steps enumerated as (1) throug ANCO on ~

meeting was held with An introductory The purpose of this meeting d the was typeto (1) 1982.

an understanding of ANCO's operation an vided January 4-5, ting obtain of seismic A

safety-related design services they prom .

to PG&E. and implementing was consumed Program Manual, in an effort to determine practices f d. ,

Assurance procedures had been applied to the activities per ormeANC Appendix B lists the at all meetings with ANCO.

personnel in atten' dance ANCO - March 1, 1982 4/41 e_

,n_w,__,

~ * * ' ' ' * * ,

f' .

4

vl l

r j

. . [

Initially it was the intent of the team to discuss )

[ . (2) which had been prepared based on a preliminary questions ANCO Quality Assurance Manual "ANC Spec. pG&E h review of the 1976" which had been provided by L QAM-001, December-to R. F. Reedy, Inc. .as the controlling QAM for the preANCO advised Services ANCO provided to pG&E. that ANCO's 1

June 1978 Team during these discussions jh(

the AuditAssurance ' Manual "ANCO Spec. QAM-002, May 1978" Quality  !.s was the applicable was QAM shown for the services they performed. copies[,.o Team The Auditfor their tasks 1122.4B.1 through 1122.4B.10 tand by Reports

(('

each of these the reports contained "

a certifying statementests repo ANCO Spec. QAM-002, May l

' ANCO that of and met At the requirements

• 1978."

this point it was necessary for the Audit Team discussion and review to  ;

introductory d expand this ' '

to establish, on the basis of available documentary irecorand s, what ANCO Quality Assurance program Manual, pract cesfor its review an[

should be used procedures The results of these discussions and ,

ANCO's activities. the detail possible from the reviews are reported in the Audit Team in documentary evidence provided to Appendix C to this report.

On the basis of the review performed under (2) above (3) Appendix C it is the conclusion of theQuality A and reported. in ANCO's

[$

Audit Team that Spec. QAM-002, May 1978" applied for the ANCO activitiesA then ANCO's to be audited. this manual, and Team against and audited to verify whether Audit performance was reviewed under sufficient did their activities ANCO performthe Audit Team could verify compliance This controls whereby j with the required criteria of 10CFR50, Appendix B. Team Findings ,

checklist and Audit included as Appendix D to this report. ~~

The Quality Assurance review andOn audit of ANCO January was 6, 1982 (4) performed on January 6 and 7 of 1982. apparent that sufficie

~

it became implementation of -

verifying the program did not exist or could not be quality assurance Team whereby a determination of '

provided to the Audit compliance with 10CFR50, Appendix B requirements could be verified. The audit and audit and.the Audit Team's observations and findings are included as Appendix D to this report.

ANCO - March 1, 1982 '

5/41

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ShhNNNS 6 [ % @@!!1 54hV Q ri g g .c._, ,w

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-/ ,

/ Summary of Findings and Observations I N\O Gk The primary findingw<in of this Audit Team is that a Quality not implemented by ANC_O'for those PM /

Assurenco Procram seismic safety-related design activities they provided to _

PGEE for the pre-June 1978 time period..

I I

i i

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i 1

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0][Y R. F. REEDY, INCORPORATED e 236 N. Santa Cruz Avenue Los Gatos, Callfornia 95030 = (408) 354-91 to l

March 4, 1982 Robert L. Cloud and Associates, Inc.

125 University Avenue Berkeley, CA 94710

Subject:

Report of R. F. Reedy, Inc.

Review of ANCO Engineers (Formerly Applied Nucleonics, Inc.)

Revision 1

Dear Mr. Cloud:

Attached is revised replacement page 41 to this report to add the omitted signature.

Very ly yours, e . e y , P. E.

R. REEDY, INC.

RFR:na '

Attachment ..

cc: Mr. Harold Denton 3@@ MEW 1s 3

{l-J e

~

I; v.2R-5192 d,

R.ger F. Recily. P.E. - Engineering t'on%..tung,

t

.s_t 7 .

RHG&A AUDIT FINDING REPORT, PAGE 1G OF 16 AFR NO. 1 DATE: 1-15-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PGEE 5-82-77 ANCO Engineers Inco porated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES ANCO QA manual did not contain 10CFR50 requirements for: QA Mgr. to initiate, recommend or provide solutions to QA Program, nor systems for control of design / order changes, release and control of documents including changes, qualifying QA and QC norsonnel and control of nonconformities and deviations.

OBSERVATION: As a result the Audit Team could not audit the t

implementation of systems / procedures not part of ANCO's quality program.

RECOMMENDED ACTION: .

j/ - ** '

REPORTED BY: 8 /d7/ ACKNOWLEDGED BY:

E ." E . VarntIm ,' Audit 9f [/ P. J. Herbert, Lda# Auditor THIS.SECTION TO BE COMPLETED B TH$ RESPONSIBLE ORGANIZATI9N:

PROPOSED CORRECTIVE ACTION: -

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:

NO YES Name Date, FOLLOW-UP As3 CLOSEOUT CLOSED BY: DATE:

ANCO - March 4, 1982 41/41

• • Revision 1 l

1 e

~' ~

T_ - ^ ^ ^ l _;~_~- . .

dlE

, APPENDIX A

~

ANCO TASKS RELATED TO CONTRACT 5-82-77

.- ~

ANCO - March 1, 1982 7/41

~

O l

ANCO 112264B SUB TASKS

, Report Task No. Date Description 1122.4B.1 7/78 VIB Tests of a Boric Acid Tank 0 Diablo

, Tests / Data /Results

.2 7/78 VIB Tests on Emer. Power Diesel Engine Generator 0 Diablo ~

Test / Data /Results

.3* 7/78 VIB Tests of a Component Cooling Water Condenser 0 Diablo Test / Data /Results

.4 7/78 VIB Tests of a Liquid CO Tank 2

(Cardex Sys) @ Diablo Test / Data /Results

.5* 7/78 VIB Tests of Six Piping Systems 0 Diablo

.5A** 1/79 Res. f & Stiffness Determinations of Fire Control H O Header & Unit 1G

. EastCCWSupplhHdrettoExcess Letdown Line & Valve In-House Analysis

.6 7/78 VIB Tests of a Component Cooling H O 2 Strge Tank 0 Diablo Test / Data /Results

.7 7/78 VIB Tests of a Liquid Hold-up Tank 0 Diablo --

Test / Data /Results

.8 7/78 VIB Tests of 3 Valves 0 Diablo Test / Data /Results

.9 7/78 Test /Exp Proc - General Similar to

.1 .

.10** 8/78 Dynamic Modeling & Seismic Analy of Comp Cooling H 2 O Heat Excgr 0 Diablo Model/ Anal / Summary Selected for audit

• • Performed after June 1, 1978 ANCO - March 1, 1982 8/41 m -

f

m u. %

l.

l - APPENDIX B

.  ?

7; ATTENDANCE LIST I

I .

i

}

I I

ANCO - March 1, 1982 9/41 ,

7

Appendix 3 -

MEETING ATTENDANCE LIST l Name Title 1-5-82 1-6-82 1-7-82 1-8-82 h ANCO '

C. J. Endler Deputy Director Monitoring Center x x x x P. Ibanez Principal ANCO

• x* x K. Blakley Acting' Assistant Chief Engineer x PGLE F. Zeribinski Engr. QC Dept. x x x x W. T. Spitzer LA Resident Inspector x R. F. Reedy, Inc.

E. V. Varnum Auditor x x x x P. J. Herbert Audit Team Leader x x x x

• Briefly to answer Audit Team Questions l

ANCO - March 1, 1!

. 1 10/41

7 i

APPENDIX C APPLICABLE ANCO QUALITY ASSURANCE PPOGRAM MANUAL AND

~

QUALITY ASSURANCE IMPLEMENTATION

~

PROCEDURES 9

ANCO - March 1, 1982 11/41 i

_ _ _ _ . _ _ _ - , , -g _ - _ , , . - , , , _ -

i y-Q3 Q _ J -

2 3$5.4 ' ~

i 1 M R.

'? h fk,D f APPLICABhEy.ANCO QUALITY ASSURANCE PROGRAM MANUAL AND igg SUPPLEMENTING: QUALITY ASSURANCE PROCEDURES y.y :.yf Quality Assurance Program Manual a:-

.CF Prior to this audit, PG&E provided R. F. Reedy, Inc.

, with a copy of ANCO's Quality Assurance Manual (ANC Spec QAM-001) dated December 1976 and indicated that this manual was the manual applicable for the subject ANCO activities. The manual was transmitted to R. F.

~'

Reedy on 12-7-81. .

During our initial discussions with Mr. Gerald J. -

Endler, II of ANCO, the audit team was inf9rmed that the applicable ANCO Quality Assurance Manual was "ANCO Quality Assurance Manual - ANCO Spec QAM-002 dated May 1978".

The audit team was shown copies of the final reports for tests 1122.4B.1 through 4B.10. Each of these reports contained a sheet certifying that ANCO had performed this in-situ testing and reporting of results under the requirements of ANCO's Quality Assurance Manual ANCO Spec QAM-002 dated May 1978.

The audit team decided it was necessary to resolve the variance between the PG&E submittal'of ANC QAM Spec-001 dated December 1976 as the ' applicable manual, and ANCO's stated use of ANCO QAM-002 dated May 1978 prior to proceeding further with the audit. A further review of correspondence related to the two PGSE contracts (5-68-77 and 5-82-77) disclosed the following points:

1. On September 29, 1977, Mr. R. V. Bettinger requested, in a letter to Mr. Paul Ibanez, that ANCO provide PG&E by October 14, 1977 "the procedures that are used to control your work".

Attached to this PG&E letter was a copy of PG&E's ~

" Specification for Consultant's Quality Assurance Program No. CO-E-0, Rev. 0 (no date)." ANCO was -

requested in this PG&E letter to: "If you feel that portions of this specification are not- -

applicable to your work or that aspects of your procedures are not covered by this specification, -

please include this information with your ,

submittal."

The PGSE letter further required of ANCO, "Your submittal does not necessarily have to be in'the form of a formal Quality Assurance Manual, as called for in the attac.hed specification. The procedures you submit should, however, be detailed enough so that PGEE auditors can verify that your ANCO - March 1, 1982 12/41

controls comply with the criteria in the attached

, , specification."

2. Under a transmittai memorandum dated October 20, 1977, ANCO's Mr. Ibanez submitted a copy of their Quality Assurance Manual, ANC Spec-001 dated December 1976. ANCO in this submittal did not take any exceptions to PGSE's " Specification for Consultant's Qaulity Assurance Program No. CO-E-0, Rev. O.

~.

3. PG&E .in a memorandum from Mr. P. Atiochos

_ accepted ANCO's Quality Assurance Manual'ANC QAM _

Spec. 001 dated December 1976 for the Quality Assurance of seismic safety-related design / testing services that ANCO was providing to PG&E. PG&E in their acceptance did not request ANCO to make any changes or additions to that manual, nor was a request made to ANCO for preparation and submittal of implementation procedures.

4. During a PG&E audit of ANCO in January 1978, ANCO ,

was advised that additional quality assurance controls were required to be included in their Quality Assurance ProgramManual to comply with PG&E's requirements.

5. ANCO made a change to their manual and issued QAM Spec-002 dated May 1978. No implementating Quality Assurance procedures were developed by ANCO in conjunction with this Quality Assurance Program manual change i.NCO submitted this QAM Spec.-002 to PG&E on May 23, 1978 and Mr. R. J. Pillers of PG&E accepted Lt a3 meeting PG&E's requirements on April 11, 1978.

ANCO - March 1, 1982 13/41 i

h a_--- - - - -

g-..._ _ _ _ , _ _ _ _ _ _ _ _ ___

I

. APPLICABLE ANCO QUALITY ASSURANCE PROGRAM IMPLEMENTING PROCEDURES As for the Quality Team Assurance Program Manual discussed above,had the Audit determine which ANCO correspondence and transmittals to applicable for the Procedures were Quality Assurance and Quality Assurance controls evidence of the ANCO

, implementation Program. N.) documentary was Quality Assurance had developed or produced by ANCO to verify that ^they submitted Quality Assurance Procedures to PG&E for approval.

ANCO portion of our pre-audit discussions -

During this P. Ibanez to PG&E provided a series of Memorandum Plans." fron Mr.These Memorandum " Test which were titled " Testto the Audit Team as fulfilling the Plans" were submitted Work Plan as listed above requirements ANCO for developing a did provide copies of correspondence The " from Test under 3.2.

accepting these' Memorandum " Test Plans".

PG&E Plans"- were assessed by the Audit Team as not acceptable as

" Work Plans" in-that the following conditions the required .

exist:

1. These " Test Plans" were unsigned memorandum which in some instances were not dated.

2.

No notations of review and approval are present.

not specifically address the

3. The " Test Plans" did following criteria of PG&E's CO-E-O specifications.

3.1 Did not identify all work to be performed.

to' be 3.2 Did not identify the characteristics analyzed and reviewed at each step.

analysis and review Did not describe the 3.3 procedures to be used at each instructions and ..

step.

records, forms, or other 3.4 Did not list the documentation used or collected at each step.

hold points for witnecsing and 3.5 Did not indicate review prior to proceeding. .

test procedure, ANCO submitted to the Audit As a detailed of their " Final Test Reports". The Audit Team Team copies reviewed these " Final Test Reports" and concludcd that while the text of these reports did contain a detailed summation of the testing activities that ANCO performed, they were not ANCO - March 1, 1982 14/41

~

I

' a ' substitution for the required " Test Procedures" defining i details of how to perform and control the test activities.

ANCO did not provide to the Audit Team " Test Procedures" L which were prepared by ANCO, reviewed and approved by ANCO and submitted by ANCO to PG&E for PGaB approval prior to commencement of ANCO testing activicies.

Areas which, in the opinion of the Audit Team, they were not provided with sufficient documented evidence of implemented quality assurance procedures to accept ANCO QA!.!-002, May 1978 document as meeting 10CFR50, Appendix B, are: _

1. Procedure for the preparation and distribution control of quality assurance program manual.

2. Procedure for the preparation, review and approval of project work plans.

3. Procedure for the review of Engineering calculations and analyses work.

4. Procedure for the preparation, review and approval of instructions, procedures and drawings.

5. Procedure for subcontracting work related to their design / testing program and to other design / testing organizations.

6. Procedure for quality related document control to include: review for adequacy, approval for release by

. authorized personnel, controlled distribution, document change control, identification of individuals or orgniazations responsible for preparing, reviewing, p

approving and issuing documents and change control.

7. Procedure to provide for the status of analysis and analyses reviews, to assure that only analysis-results "

which have passed required reviews are used, and that '

unaccepted work is clearly identified.

8. Procedure for corrective action controls.

9. Procedure for Records control, identifying records which are to be retained, prescribing retention period, -

storage locations, and assignment of responsibility.

10. Procedure to govern internal audit program, and external audit program if sub-contracting is applicable and the training and qualification of QA auditors.

ANCO - March 1, 1982 15/41

~ , - - - .

11. Procedure for nonconformance determination, reporting h and resolution.

12. Procedure for controlling design / requirement changes.

13. Procedure for hold points where mandatory inspection is required.

14. Procedure for inprocess inspections and monitoring.

15. Program for training and qualification of personnel -

performing activities affecting quality.

16. Procedure to govern final inspection /QA audit.

The Audit Team lists the above 16 items as observations, since it is not feasible at this time to list them as findings for which corrective actions can be performed, after the fact of completion of the testing program.

At the conclusion of these discussions and reviews, the Audit Team concluded that the audit should proceed along the following lines:

1. A revised audit checklist would be prepared using ANCO's QAM Spec-002, May 1978 to determine compliance with applicable 10CFR50, Appendix B criteria.

2. ANCO's quality assurance activities would be audited against this checklist to determine if the actual quality assurance (or engineering practices) activities ANCO did perform met the requirements of their-QAM-Spec-002 May 1978 and if these activities could be assessed as also meeting the intent of the applicable 10CFR50, Appendix B 18 point criteria for the performance of the testing and analysis activities they ..

performed.

P ANCO - March 1, 1982 16/41

' 'I; .,

APPENDIX D ANCO SPEC. QAM-002, May 1978 AUDIT' CHECKLIST -

AND

SUMMARY

OF IMPLEMENTATION .

AUDIT FINDINGS / OBSERVATIONS l

1 i

l

)

ANCO - March 1, 1982 17/41

~

i

.u Summary of Observations Noted During i Implementation Audit i 2.2 Verification of QA audit of 4B.5 missing. ,

2.3 Checking by " qualified" persons not documented on some 4B.5 testing records.

2.4 ANCO management audit'of QA performance (semi-annual) not available, and no indication to substantiate that one was ever made.

3.1 Documents to verify calibration of critical instruments' not complete as to procedure used, results, adjustments and identity of calibration person.

3.1 Verification of data recording records missing.

I 3.2 Changes to calculation sheets not marked clearly to show date, author, Rev. No. and consultation with author. ,

1 3.3 Documents and calculations not initialed by creator.

3.2 Document control not applied to Test Procedures 3.6 Equipment used to assure accuracy of test not identified to usage.

3.9 Computer test case documentation not retrievable.

3.9 Client not notified before destroying files and records.

3.9 Required cover letter with list of enclosures not available. ,,

3.13 Field test procedure not prepared, approved nor implemented.

9 ANCO - March 1, 1982 18/41 w

V.

l l

R. F. REEDY, INC.  !

AUDIT CHECKLIST v

ORGANIZATION: ANCO ENGINEERS, INC. _

ADDRESS: 9937 Jefferson Blvd.

Culver City, CA 90230 QA PROGRAM

REFERENCE:

ANCO Ouality Assurance Manual, ANCO Spec.

OAM-002. May 1978 AUDIT CONDUCTED BY: f N DATE: [~[d

/ DATE: /d

' f/ ' '

/ /

g , DATE:

REVIEWED BY:

y -

M/>sy r -/ - -

DATE: ,Ny- 2 DATE: -

8A ,

7 - -

8 DATE: 2 87 _,

NO. OF PAGES: 6 ANCO - March 1, 1902 19/41

~: '~~ . .,. .:.. . . ......., . . . .

f i

\

AUDIT CHECKLIST ,

Company ANCO Engineers Page 1 of 6 Applicable QAM ANCO Spec. QAM-002 (Miy 1978; Auditor E.E. Varnug/P.J. Herbert Date January 5 through'8, 1982 App. B. QAM Crit. Ref.

Statement Audit Instruction Comment -

1.1 Scope . Verify scope of project and Order (a) PG&E Inquiry - No documented Control, evidence available, A "Prepro-poGal" attachment to ANCO letter dated August 1,1977 not Inade j '

available, j (b) Technical Proposal-Volume I, attachment to technical proposal

~

for second contract not made avai able; claim made it was given j verbally.

Also see ccuplete audit report regarding selection of ANCO QA program to be used as basis for j this audit.

I i 1.2 General . Verify authorization of changes Said that Board of Directors in a to QAM, their first approval (minutes ll dated Novmber 16, 1976) gave QA F Manager complete responsibility l

over changes to the OA program.

? .

) 2.1 Organization Verify that assigned QA Manager Documented evidence satisfactory.

i retains overall quality responsi-F bility when another individual is

( appointed QA Manager on any' pro-ject where assigned QA Manager is

! the Project Manager.

I l .

ANCO - March 1, 198:

(

. 20/41 h -

' '&QG1pu@.q ll 4 AUDIT CHECKLIST Company RICO Engineers ,

Page 2 of 6' Applicable QAM ANCO Spec. Omi-002 (May 1978) Auditor E.E. Varnum/P.J. Herbert Date January 5 through 8, lw[ V 3 AE 0* Statement Audit Instruction Comment .

2.2 Organizational structure Verify type used - project team. No documented evidence available verify position of principals - on one of the audited tasks.

Vice President.

Veirfy QA Audit not performed by QA Manager when he has been assigned as Project Manager.

2.3 QA Program Verify that checking was perfor- Sme QA records missing frcm files med and that it was done by a - unable to verify. Documented qualified person. training program not available and no evidence that qualification levels were established.

2.3 QA Program changes Verify'that program changes were Documented evidence not suhnitted 2.1 described, reviewed and approved which described in detail the change

. as required. parties reviewing same, but evidence i

thta PG&E accepted application of QAM-002 (May 1978) as applicable QA program for projects.

Audit of QA Program performance Verify audits were conducted in Ib documented evidence of required 2.4 accordance with program require- audits, or qualification of auditor ments. or auditing in areas of direct responsibility, or auditing proce-dures.

t i

l .

ANCO - March 1, 1982 1 21/41 l i I l t . \

I . . .

.. . ;- a..~ n ..y . ., (. ..,g ,. . . . . . , . ., _

' - ' ut ug 1)

AUDIT CHECKLIST >

Page 3 of 6' (

i Company ANCO Engineers Date January 5 through 8, 198 E.E. Varnum/P.J. Herbert Applicable QAM ANCO Spec. QAM-002 (May 1970) Auditor -

Comment Audit Instruction App. B. CAM Statement Crit. Ref.

(a) Verify that theoretical anal- (a) Documentation suhnitted found 3.1 Duties of the QA Manager . inadequate.

yses have been checked.

(b) Verify OA checked calibration (b) Documentation subnitted in-and proper use of instrumentation results conplete or (no calibration proc.

adjustments).

(c) Adequate documentation not (c) Verify OA checked use of pro- suhnitted (records missing) .

per data. recording methods.

.d) Verify OA checked final (d) Documentation subnitted inad

( quate.

reports.

(e) Documentation subnitted on (e) Verify that proper documenta- Il25.4B.5 inadequate.

tion was maintained.

(a) Unsatisfactory (a) Changes marked clearly to 3.2 Documentaticn show date, author, Rev. No., con-sulting with orign original author (b) Preliminar't copies stamped as (b) Satisfactory cequired (c) Test data P5.1, "% damping (c) Documents and calculations frequency plot,'EPage 9 Not ina initialed by creator.

(d) Document control: Test proce- (d) No objective evidence Sure ccrnpliance for make/ review /.

approve / release.

(e) Change in project guidelines (e) No documented evidence to i 0A Program change:

cequire review bp cognizant prin- ccrnpliance.

.iple and the client project man- documented.

acer. ANCQ_ -- Var _Ch l 1

l AUDIT CHECKLIST l

CcmpanY ANCD Engineers Page 4 of 6' ApplieabLe QAM ANCD Spec. QAM-002 (M5y 1978 Auditor E.E. Varnurg/P.J. Herbert Date January 5 through 8,19 App. B. CAM Crit. Ref.

Statement Audit Instruction Comment l

l l

! 3.2 Verify that activities requiring There are no documented controls l 3.4 PG&E approval prior to perfor- to provide this assurance.

I mance were not perfonned prior to receipt of PG&E approval.

l 3.3 Inspection Verify whether paragraph relates Discussion with Mr Endler indica-to " inspection", or monitoring, ted there were no inspections per 1 - -

or dev,wnt review, or observa- sec by ANCO, only observations.

ticn/ witness. Further, the paragraph relates to review of documents. PG&E made

randon visits - no regular schedult nor specific items of testing to bc witnessed.

3.4 Test ccntrol Verify thati " Test Procedures" " Memorandums" not signed, sanetune!

, were established, controlled, undated, claimed to be a " Test pro-reviewed and approved, and final- cedure", but they appear to be a ly approved by FG&E, general procedure rather than a specific test procedure. No provi-sions for assuring pre-requisites have been met. No verification the these memos have been reviewed and approved.

3.5 Instru:ent and ralibraticn proce- Verify that calibration program Satisfactory, dures. meets requirements.

l -

ANCO - March 1, 1982 23/41 1

F -- -

. . .. .. . . . ._ .:. a . .. . . _ _ . . . , , .

l AUDIT CHECKl.IST ANCO Engineers Page 5 of G' k Company Applicable QAM ANCO Spec. QAM-002 (May 1978 ' Auditor E.E.Varntgr/P,J. Herbert Date January 5 through 8, Audit Instruction Comment Statement Inspection, test and operatire sta- (a) Verify de'cumentat'io'n' of t (a) Specific accumentation not 3.6 available as Test Report is said tus specifies test procedure.

to contain test procedure.

(b) Verify that transducers and (b) Documented evidence not recordin2J equipnent subject to available in all instances audit changeout prior to next system

~

ml aration are documented for traceability.

3.7 Nonccnfonnance Verify controls used to reject No documented evidence of contrc any analysis, calculation or test exercised after PG&E NCR 002 found not to meet all require- (2/21/78) not received until mnts cif this dmwrit (ANCO Spec 8/22/78. This on ll22.4B.5 and 002 - May 1978) . should be investigated in Phase of independent audit. Control procedure inadequate.

3.8 Corrective action Verify ccntrols used for correc- No object evidence of control tive acticn to prevent repetitive available. Control procedure is type conditions adverse to qual- inadequate.

- ' ity.

ANCO - March 1, 191 24/41 l '

I

( .

.. , . . . - ,.... .. . , .;. .. , , u .f ,. .... ._. ; ,... , , , , .

AUDIT CHECKLIST -

)

Page 6 of 6' l '

I.

Company ANCO Engineers j Applicable QAM ANCO Spec. OAM-002 (May 197 Auditor E.E. Varnun/P.J. IIerbert Date January 5 through 8', 198 App. B. GAM Statement Audit Instruction Comment

~

Crit- Ref. .

3.9- i QA Records '

(a) Verify that individual can- (a) Objective evidence not availab~

ponent calibration records are naint e ed during test.

(b) Verify that cmputer test (b) Such ccruputer records are not case records are nuintained. retrievable.

i .

(c) Verify that PG&E was notified (c) Unsatisfactory.

orier to. destroying records .

(d)~ Verify cover letter with list (d) Not available.

af enclosures.

3.11 Sample records leviewi (a) OA Manager Checklist (a) Appears insufficient to assure

. all program requiranents carried c (b) OA Release (b) ?bt described / controlled in manual.

(c) Test Plant (c) Not implemented.

(d) QA Audit Fonn (d) Appears insufficient for OA Program audit.

3.13 Field Test Procedure . Verify inplementation None implemented or made availablc ANCO - March 1, 1982 i

25/41

t AUDIT FINDING REPORT' PAGE 1 OF 16 O. 1

SUMMARY

DATE: 1-15-83 ROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorpicated ANCO: ll42.4B (Formerly Applied Nucleonics Inc.) Santa Monica, CA REQUIREMENTS AND REFERENCES To audit ANCO implementation of ANCO-QAM-002 (May 1978) for compliance thereto; and to verify conformance to applicable requirements of NRC 10CFR50, Appendix B, with respect to QA program requirements of PGSE Contract 5-82-77.-

OBSERVATION: ANCO QA Program ANCO-QAM-002.(May 1978) not fully imple-mented. Had ANCO fully implemented subject QA program, it is the opin-ion of this Audit Team that the intent of 10CFR50 would have been met.

Attached report sheets 2-16 describes areas of concern found during January 5-7, 1982 audit. -

RECOMMENDED ACTION: .

/ r REPORTED BY': ,

_ ACKNOWLEDGED,BY: / ,

E. E. Vafnum, Aud/ top / P. J. Herbert 4/ Lead Auditor THIS SECTION TO BE COMPLETED'BY YHE RESPONSIBLE ORGANIZATION:

~

PROPOSED CORRECTIVE KCTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE: ..

RHG&A CONCURRENCE:

NO YES Name Date, ,

FOLLOW-UP AND CLOSEOUT -

CLOSED BY: DATE:

AMCO - March 1, 1982 26/41

AUDIT FINDING REPORT' PAGE_jLOF 16

SUMMARY

O. 1 DATE: 1-15-82

, h03ECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 2.2: documented evidence that QA audit / check performed

)y assigned alternate QA Manager (when assigned QA Manager is the Project f Manager). -

~

, OBSERVATION: No documented evidence available.

RECOMMENDED ACTION: -

REPORTED BY: O /Lg . .

ACKNOWLEDGED BY: .

E . "E . Va'rnu"m,' Audit /r // P. J. Herbert , 6 Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

j PROPOSED CORRECTIVE ACTION:

'\  ;

l

! SCHEDULED COMPLETION DATE: PROPOSED BY: DATE: ,,__

RHG&A CONCURRENCE:

NO YES ~

Name Date . 1 FOLLOW-UP AND CLOSEOUT "

CLOSED BY: DATE:

AMCO - March 1, 1982 27/41 4*

-WNW

, AUDIT FINDING REPORT. PAGE 3 OF 16 NO. 1

SUMMARY

DATE: 1-15-82 ROJECT COMPANY / ORGANIZATION AUDIT LOCATION PGEE 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

~

R.EQUIREMENTS AND REFERENCES QA Program Para 2.3: Documented evidence that checking was performed by qualified personnel. _

l _

OBSERVATION: Documented evidence not available to verify that all checking performed on ll22.4B.5 was performed by qualified personnel.

RECOMMENDED ACTION: .

/f REPORTED BY: ## M ACKNOWLEDGED BY: r/F

f. E . Varnum, Au/itoV P. J. Herbert,9 Lead Auditor l

THIS SECTION TO BE COMPLETE 6 BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

l l

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE : --

l RHG&A CONCURRENCE:

NO YES --

Name Date

• FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

ANCO - March 1, 1982 28/41

AUDIT FINDING REPORT' PAGE 4 OF 16

SUMMARY

0. 1 DATE: 1-15-82 c, ROJECT COMPANY / ORGANIZATION AUDIT LOCATION PGLE 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

~3 x REQUIREMENTS AND REFERENCES QA Program Para 2.4: ANCO Management audit of QA performance.

OBSERVATION: No' documented evidence available to substantiate that any such audit (s) actually performed.

RECOMMENDED ACTION: .

REPORTED BY: fM ACKNOWLEDGED BY: ,

T. E. Varnum, Aud tor // P. J. Herber't[/ Load Auditor THIS SECTION TO BE COMPLETED BY IHE RESPONSIBLS ORGANIZATION:

PROPOSED COhRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPCSED BY: DATE:

RHG&A CONCURRENCE: . _

1 1

NO YES '

Name Date

• l FOLLOW-UP AND CLOSEOUT -

I l

l l

CLOSED BY: DATE: )

ANCO . March 1, 1982 29/41 e

a = = - . .

y -

g~,,, AUDIT FINDING REPORT ^ PAGE 5 OF 1G g NO. 1 .

SUMMARY

<- DATE: 1-15-82

. /_ '**

" PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 3.1.2: Verification'of calibration and proper use of instrumentation. -

OBSERVATION: Docur!entation submitted for review was incomplete as to identification of calibration procedure used, results of the calibration, adjustmants made if any, and identity of personnel performing the calibration.

RECOMMENDED ACTION: -

RSPORTED BY: . .

}

ACKNOWLEDGED BY:

E. E. Varnum, A/dth/or P. J. Herbert,4/ Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPdESIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE: ~ ~

NO YES Name Date FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

ANCO - March 1, 1982 30/41

l

? ; say, AUDIT FINDING REPORT' PAGE 6 OF 16

.$ r. , -.;

~

fN u Wr:0. l

SUMMARY

DATE: 1-15-82 f

/lROJECT COMPANY / ORGANIZATION AUDIT LOCATION PGSE 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES

.QA Program Para 3.1.1: Verification.that theoretical analyses were checked (data recording records).

OBSERVATION: Documented evidence not available to verify conformance to requirements.

RECOMMENDED ACTION:

/

REPORTED BY: , ,r / . ACKNOWLEDGED BY:

1. E.~ Varnum, Aggit9y/

f P. J. Herbertg/ Lead Auditor THIS SECTION TO BE COMPLETE'D BI THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

P SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE: -

NO YES Name Date FOLLOW-UP AND CLOSEOUT ,

CLOSED BY: DATE:

ANCO - March 1, 1982 31/41 d

AUDIT FINDING REPORT, PAGE 7 OF 16 NO. 1

SUMMARY

DATE: 1-15-82

' PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 3.2: Revised calculation sheets are clearly marked to indicate the nature of revision (including dates, author, and revision number). .

OBSERVATION:

Changes audited did not clearly indicate the date, author, Rev. No., and consultation with author -- as required.

RECOMMENDED ACTION: .

REPORTED BY: ACKNOWLEDGED BY:

E. E. Vainum, Audi/op// -

P. J. Herbert (/Uead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

N

\

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE : ~~

~:-- - - - - . = . _ - , - - _ _ - - - - - ~^ - - - - -

-" ~ ~ ' ~

RHG&A CONCURRENCE: - - - -- - -- --

NO YES Name Date, FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:  ;

l l

AMCO - March 1, 1982 32/41 i

O

g yc " ~i[ lie M -

'.ansre WWQUY5- ,

S AUDIT FINDING REPORT' pr.I .

. . PAGE 8 OF 16 A NO. 1

SUMMARY

DATE: 1-15-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 3.3: All documents and calculations must be initialed by the person creating them.

= -

OBSERVATION: Sample check on ll22.4B.5 Test P5,1 revealed some failure of creator (s) to initial their work as required.

RECOMMENDED ACTION: -

/

REPORTED BY: # .

ACKNOWLEDGED BY:

5. E. Va'rn'um, AuditoV P. J. HerberQC/ Lead Auditor THIS SECTION TO BE COMPLETED BY 'THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE : --

RHG&A CONCURRENCE:

NO YES- _

Name Date ,

~

FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

ANCO - March 1, 1982 33/41 k

.s_

ig . . .

$ j AUDIT FINDING REPORT' PAGE o OF in y

SUMMARY

a 1 DATE: 1-15-82 f'/R NO.

?l f PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 3.'2: Changes in the project guide lines require a -

review by Cognizant Principal and the Client Project Manager. .

.=

OBSERVATION: Documented evidence that such a review was made was not available for items audited. .

RECOMMENDED ACTION: .

REPORTED BY: . ,

ACKNOWI. EDGED BY: /

E! E. Varnum, Aud/ tov P. J. Herber)(/, Lead Auditor

/

THIS SECTION TO BE COMPLETED BY"THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

~

RHG&A CONCURRENCE:

NO YES Name Date FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

ANCO - March 1, 1982 34/41

• r g

_ _ _ _ _ _" = ' = -

MME AUDIT FINDING REPORT' PAGE 10 OF lG t;O .

SUMMARY

j 'l t.. DATE: 1-15-82 PROJECT COMPANY / ORGANIZATION XDDIT LOCATION l PGS3 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Program Para 3.2: Document Control required to be applied to test

' procedure. .

OBSERVATION: Documented evidence not available to verify that pro-cedure required for testing was controlled as required for preparation, review, approval and release for use.

RECOMMENDED ACTION: .

1%

REPORTED BY: /

1. ,, ACKNOWLEDGED BY: /.

E ." E . Varifum$ Audi/for// P. J. H'erbert// Lead Auditor I

THIS SECTION TO BE COMPLETED BY @HE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:-

~: __

NO YES _

Name D' ate FOLLOW-UP AND CLOSEOUT ,

CLOSED BY: DATE:

l e '

ANCO - March 1, 1982 35/41 l

M _

illlilliiiS"' .

)

AUDIT FINDING REPORT. PAGE_110F 16 R NO. 1 .WMMARY DATE: 1-15-82

{

PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PGLE 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

E RQUIREMENTS AND "3FERENCES QA Program Para 3.6: During testing, transducers and recording equip-ment will be documented to assure traceability. .

OBSERVATION:

- DUdumented evidence not available in some instances to verify compliance with this requirement. .

RECOMMENDED ACTION 3 .

REPORTED BY: J7 ,4/ ACKNOWLEDGED BY:

E' E . Vainum, Audi/o// P. J. Herbert (/ Lead Auditor THIS SECTION TO BE COMPLETED /BYliHE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

~,

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE: __

.= =

RYG&ACONCURRbNCE: - - - - ~

NO YES Name Date, FOLLOW-UP AND CLOSEOUT '

CLOSED BY: , , _ _ , DATE:

ANCO - March 1, 1982 36/41

AUDIT FINCING REP 3RT' PAGE 120F 16 NO. 1

SUMMARY

~

DATE:1-15-82

?'

PROJECT COMPANY / ORGANIZATION AUDIT LOCATION

/G&E 5-82-77 ANCO Engineers Incorporated ANCO: 1142.4B Santa Monica, CA (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES

• QA Program Para 3.9: Records to be maintained to furnish evidence of -

l activities affecting quality. -

i /

j OBSERVATION:

i Computer test cases were found not to be retrievable.

i i

RECOMMENDED ACTION: . .

REPORTED BY: / / ,,)

J(ACKNOWLEDGED BY:

E.'E. Varn{fm,'Audito/ // '

P. J. Herberf/ Lead Auditor THIS SECTION TO BE COMPLETED BY/THs RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

i I

.~

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

} RHG&A CONCURRENCE: - -

NO YES Name Date i FOLLOW-UF AND CLOSEOUT '

i 1

CLOSED BY: i DATE:

ANCO - March 1, 1982 37/41

m * '

AUDIT FINDING REPORT' PAGE 13 OF16 _

a NO. 1 S ARY DATE : 1-15-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E-5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND~ REFERENCES QA Program Para 3.9: Client to be notified before records are destroyed. ~

OBSERVATION: - Client was not notified before some records were destroyed.

RECOMMENDED ACTION: -

N ,

REPORTED BY: .

o W ACKNOWLEDGED BY:

(. E. VarE1u ( Audi/orf P. J. Herber[/ Lead Auditor THIS SECTION TO BE COMPLETED 8Y 'fHE RESPONSIBLE ORGANIZATION:

\

PROPOSED CORRECTIVE ACTION: ~

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

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

~ ~ ~

RHG&A CONCURRENCE: - -

NO YES -

Name Date FOLLOW-UP AND CLOSFOUT CLOSED BY: DATE: -

ANCO - March 1, 1982 38/41

. . - , - _ . _ ~ ,

L'

.J. AUDIT FINDING haPORT' PAGE 14 0F 16 FR NO. 1 MMARY DATE: 1-15-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO' Engineers Incorporated Santa Monica, CA ANCO: ll42.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA Prc7 ram Para 3.9: Final Reports to include a Cover Letter to include latn, Job number and list of enclosures.

OBSER7AT.T':1:

CoV^t Letters were not available for items audited.

RECOMMENDED ACTION: .

REPORTED BY:_;e Jf/9 c ACKNOWLEDGED BY: (

E. E. Varnum, Aud/to// P. J. Herb 5rt,#L ead Auditor

/

THIS SECTION TO BE COMPLETED BY"THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

1

= .-_ __ __. _

- ~ ~

' ' ' '"'"~"'

RHG&A CONCURRENCE: '

- Ti NO YES Name Date, 1

FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

ANCO - March 1, 1982 l 39/41

• =w we w-

t .

^

, &'R AUDIT FINDING REPORT' PAGE 15 OF 16 AFR NO. 1 DATE : 1-15-82 O

PROJECT COMPANY / ORGANIZATION AUDhT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES QA-Program Para 3.13: Field test procedure required.

OBSERVATION: Documented evidence that a tield test procedure was on hand during field testing not available.

RECOMMENDED ACTION: .

s REPORTED BY: #f _A/ ACKNOWLEDGED BY:

'E . E. Varn'um, Augitc/;/" ' P. J. Herbery/ Lead Auditor THIS SECTION TO BE COMPLETED BYfTHE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE AC1' ION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE: -

NO YES Name

~ ~

Date, FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

I ANCO - March 1, 1982 40/41

fyA .E '

AUDIT FINDING REPORT' PAGE 16 0F 16 AFR NO. 1 <

., DATE: 1-15-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E 5-82-77 ANCO Engineers Incorporated Santa Monica, CA ANCO: 1142.4B (Formerly Applied Nucleonics Inc.)

REQUIREMENTS AND REFERENCES requirements for: ANCO QA manual did not contain 10CFR50 QA Mgr. to initiate, recommend or provide solutions to QA Program, nor systems for control of design / order changes, release and control of dccuments including changes, qualifying QA and QC nersonn 1 and control of nonconformities and deviations.

OBSERVATION: As a result, the Audit Team could not audit the implementation of systems / procedures not part of ANCO's quality program.

RECOMMENDED ACTION: .

REPORTED BY: .

~

/

/I7/ ACKNOWLEDGdD Bf:

E . E . Varnum, Iuditpf // P. J. Herbert, Lead Auditor THIS SECTION TO BE COMPLETED B THh RESPONSIBLE ORGANIZATION:

PROPOGED CORRECTIVE ACTION: -

SCHEDULED COMFLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE: ,

NO YES Name Date, FOLLOW-UP AND CLOSEOUT l

l CLOSED BY: .

DATE:

1 ANCO - March 1, 1982 ,

41/41

. ??

. , d.., ~o

~. .)

.l 1 ' .

4 R. F.

1.: REEDY,'INC.

PROGRAM REVIE' W CHECKLIST e

ORGANIZATION: .

WYLE Laborat'ories ,

ADDRESS: Western Operations QA PROGRAM.

REFERENCE:

QC Manual, 4/30/75 QC REVIEW CONDUCTED BY:

Procedures Manual , 4/30/75 REVIEWED BY:

DATE:[2 2.s[6/

r/ g ,j DATE:

V /7-[?C!g/,

WM DATE: /2 C 8[

DATE:/ --

M M

r

'NO . OF PAGES: 20 s

.s. :e. 3:

..3 e,..~.

J/(Yf' ;

- \

WYLE - March 1, 1982 .

7,;.<:

9/61 - ~~'

' ~ 1

.. 2. , - . . . )

_ . , , *h . '. * * , *s. t '

+ **

. ; . ..~.'4 1 a e.

= ~n.~w_ m . _u :.xe- =:.=.. .,. a.~: a . .. ...

j . , :-= -

I WYLE Page 1 of 20 '* .

PROGRAM REVIEW CHECKLIST

. ?ROJECr: Diablo Canyon

Subject:

I organizatiSn (Ann _ R1 Page 1 of 2 PROGRAM AND REQUIREMENT PROCEDURE YES N0' N/A REVIEW COMMENTS NO.

, REFERENCES

1. The ' applicant shaLL be responsible 1.1 X .

QAM and Standing Practice Procedur for the establishment and execution (SPP) pager not signed in approvec of the. quality assurance program. by, issued.by, or written by b' lank The applicant may delegate to ,

others, such as contractors, agents ,

or consultants, the work of estab- l Lishing and executing the quality  :

assurance program, or any part

, thereof, but shaLL retain responsi-bility therefor.

l

2. The authority and duties of per , Preface "

sons and organizations performing 518-3 X Manager of QC given authority by activities af fecting the safety- General Manager, Western operation related functions of structures, QC Department; Manager, Q.C.

systems, and components shaLL be Project Engineer is responsible fc clearly established and delineated in writing. These activities each test program, including QA compliance.

include both the performing func~

tions of at'taining quality objec-tives and the quality assurance f me tions. The quality assurance functions are those of Ca) as'suring

, that an appropriate quality'assur-ance program is established and effectively executed and (b) veri-fying, such as by ch'ecking, audit-t ing, and inspection, that activ1- .

WYLE - March 1, 1982 ,

ties af fecting the safety-related ' 10/61 '!

functions have been correctly per fo rmed. .

' ~

l .  !

I '

,g WYLE Page 2 of 20 .*

' " e t .

n. .

PROGRAM REVIEW CHECKLIST h_

I !ROJECT: Diablo Canyon

Subject:

I Oraanization (Aco, B) Page 2 of p PROGRAM AND

. ' TEM REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO. REFERENCES

3. The persons and organizations,per- 3.1 X - -

QC Manager has enithority [or all forming quality assurance fynctions shaLL have sufficient authority and i decisions affecting qualithf. -

organizational freedom ,to identify. l ,.7 quality problems; to initiate, a recommend, or provide solutions; and to verify implementation of solu- ,

tions. Such, persons and organiza-tions performing quality assurance functions shall report to a manage * .,

ment level such that this required authority and organizational free-dom, including suf ficient indepen- .

dence from cost and schedule when opposed to safety considerations, are provided.

4. ...the individual (s) assigned the 3.1 X Manager, QC reports to General responsibility for assuring effec- Manager. ,

tive execution of any portion of _the quality assurance program at any location where activities subject to this Appendix are being per-formed shall have direct access to such levels of management as may be necessary to perform this function.

sr .

WYLE - March 1, 1982 i , 11/61 -

i

i I o -

i l }j '

o WYLE Page 3 of 20 *' b P ' '

', PROGRAM REVIEW CHECKLIST

'ROJEct: Diablo Canyon

Subject:

II Program ( App. B) -

Page 1 of 3 E '

PROGRAM AND

'D REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS

[h NO.

REFERENCES

1. Theapplicantshallestablishati QCM X Separate QC Procedures Manual, E! the earliest practicable time, chn- QCPM Both manuals dated 4/30/75.

i!! . sistent with the schedule for acdom- ^

$l plishing the activities, a quality I':

, assurance program which complies with ii! the requirements of this Appendix.

b This program shall be documented by h written policies, procedures, or .

p instructions, and shall be carried p ,

out throughout plant Life in accor-dance with those policies, proce-((.ii

i*

l: dures, or instructions.

U 3,

.,r

i. -

2. The applicant shall identify the 1.1 X Manual applies, unicss agreed

' g structures, systems, and components otherwise by contract; no to be covered by the quality assur- specifics provided.

.ance program and the major organiza-tions participating in the program, together with the designated func-tions of these organizations.

6

.i  : ,

! i -

. viYLE - March 1, 1982 i j ~ '

12/61 i

q d u-_ ----_-----_ _ - _ _ - _ _ _ _ -

- - .- - . - _ - , ... -. -. . --. . .. - -=

]

WYLE Page 4 of 20 'I.

,,,a . . , ,

PROGRAM REVIEW CHECKLIST -

2ROJECf: ' Diablo Canyon

Subject:

II Program (App. 8) . Page 2 of 3 PROGRAM AND -,

?NO. REQUIREMENT- -

PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES The' quality assurance program' I

3. X  ; Importance to safety not con-shall provide control over activi- ,

sidered.

ties affecting the quality of the .

l identified structures, systems, and

, components, to an extent consistent ,  !

with their importance to safety. -

J i

i e

4. Activities affecting quality 4.1 X Equipment is surveyed at beginnil!

shaLL be' accomplished under suitably 6.2 of contract and calibrated

, controlled conditions. Conditions 518-1(4.1 ) periodically. Conditi,ons are coi 518-9 include the use of appropriate equip- trolled by specifications and te:

i ment; suitable environmental condi- procedures to the extent that is tions for accomplishing .the activ- -

felt necessary. Conditions are ity, such as adequate cleanness; and audited monthly by QC.

assurance that all prerequisites for the given activity have been satis-f,i e d .

1 i

2

5. The program shall take into 518-2 X Equipment calibration is control:

account the need for special con- per calibration procedures; trait trols, processes, test equipment, and monitoring are included, tools, and skills to attain the re-

! quired quality, and fhe need for !

• 4 verification of quality by inspec-WYLE - March 1, 1982 13/61

, tion and test.

, .7-.,.,, ..m. . , . , - - - - y- ,. .- y6 , ia = %4- -

• ~

f NYLE Page 5 of 20 . , ,

.' PROGRAM REVIEW CHECKLIST .

'ROJ2Cr: Diablo Canyon

Subject:

II Program (App. 8) Page 3 of _ 3

' - " -~

PROGRAM AND REQUIREMENT

~

PROCEDURE YES NO N/A REVIEW COMMENTS NO. REFERENCES

.., ,i.

6. The pr.ogram shall provide, for , 518-14 X g on-the-job training; possibly for indoctrination and trainir.g ,of. per- -

• mal training classes; initiated

~

sonnel performing activities affec- by QC Manager. No details are.

' ting quality as necessary to assure  !

providec' . ~

that suitable proficiency is-achieved and maintained.

7. The applicant shall regularly 3.1 X Continuous review by Managcr of review the status and adequacy of OC. _No review by higher manage-the quality assurance. program. Man- ment, and no review of QC Deot.

agement of other orgaaizations par-ticipating in the quality assurance program shall regularly review the status and adequacy of that part of I the quality assurance program which l they are executing.

l vr  :

~ '

WYLE - March 1, 1982

. 14/61

J '

o .

WYLE Page 6 of 20 -

PROGRAM REVIEW CHECKLIST ,

?ROJECT: Diablo Canyon

Subject:

III Desian Control (Acc,_ B) Page 1 of I.

PROGRAM AND  ;

ITEM NO ,

REQUIREMENT  ; PROCEDURE. YES N/A REVIEW COMMEXIS NO. '

REFERENCES I i

1. Measures shall be established t~o 3.2 -

X' Contracts Joo order; content not assure'that applicable regulatory 518-16 described. .

requirements and the design basis, .

as defined in Para. 50.2 and as I specified in the License applica- ,

tion, for those structures, sytems -

and components to which this Appendix applies are correctly. -

translated into specifications, drawings, procedures, and instruc- ,

tions.

2. These measures shall include. 518-3(7.) X Project Engineer will decide provisions to assure that appropri- 518-6 plan of action. Notice of Deviat:

ate quality standards are specified is used for other than " minor and included in design documents deficiencies",

and that deviations from such stan-dards are controlled. I

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- 2 15/61

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, WYLE Page 7 of 20 -

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• 1 l .

PROGRAM REVIEW CHECKLIST , -

^

~ ?ROJECT

Diablo Canyon

Subject:

Yff nesian enntr,I (anc_ m Page 3 of t PROGRAM AND

• . TEM REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO.

REFERENCES -

1

3. Measures shaLL also be estab-X ,

lished for the selection and review for suitability of appli- ,

cation of materials, parts, equip-i ment, and processes that are essential to the safety-related i functions of the structures, .

i systems, and components.

• t i

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4. Measures shaLL be established X

, for the identification and control of design interfaces and for coor- .

dination among participating design organizations.

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4

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5. These measures shall include -

~

X .. '

the establishment of procedures l among participating design organi-zations for the review, approval, i release, distribution, and revi-sion of documents involving design -

interfaces. . g WYLE - March 1, 1982 16/61 E

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WYLE Page 8 of 20 .

• % e 5 ,

PROGRAM REVIEW CHECKLIST ,

l 2ROJECT: Diablo Canyon '

Subject:

. III Desinn Cont ol (Ao n g) '

Page z of t PROGRAM AND

'YEM PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT. '

.-.10. REFERENCES l

6. The design control. measures i 3.2.2 X ,

Operating contracts job folder-shall provide for verifying .o'r reviewed by QC prior to submittal checking the adequacy of design, to customer. No design veri .

such as by the performance of design, fication.

reviews, by the use of alternative or simplified calculational methods, .

or by the performance of a suitable testing program. The verifying or checking. process shall be performed by individuals or groups other than ,

those who performed the original <

design, but who may be from the same organization. Where a test program is used to verify the ade-quacy of a specific design feature in Lieu of other verifying or checking processes, it shall in- .

clude suitable qualifications test-ing of a prototype unit under the most adverse design conditions.

Design control measures shall be applied to items such as the fol-Lowing: reactor physics, stress, thermal, hydraulic. and accident '

analyses; compatibility of mater-ials; accessibility for inservice.

inspection, maircenance, and repair; and delineation of accept-ance criteria for inspections and tests.

it .

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. i 17/61 i

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WYLE Page 9 of 20

• b PROGRAM REVIEW CHECKLIST .

?ROJECT: Diablo Canyon

Subject:

III Design Control (App. B)

PROGRAM AND Page 4 of 4 1 '

NO. REQUIREMENT  ; PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES i l*

7. Design changes, including field l X changes, shaLL be subject to design .

control measures commensurate with

'those applied to the original design and be approved by the or--

ganization that performed the ori-ginal design unless the applicant designates another responsible -

organization. -

o 1

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, . i WYLE - March 1, 1982 i

18/61, s

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WYLE'Page 10 of 20 3g .

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J' PROGRAM REVIEW CHECKLIST e' < ?"

, idJECT: Diablo Canyen

' ' Subjecc: IV ' Procurement Document Control (App. B) Page 1 of 1 N, yu PROGRAM AND '

j , 4 REQUIREMEN PROCEDURE YES NO- N/A No. $e. ,

REFERENCES REVIEW CO.TfENTS

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1. Measures shaLL~be established to i 5.. I X QC audits purchase' orders to ensur assure that applicable regulatory lf318-7 requirements, design bases, and other inclusion of applicable specifica -

requirements which are necessary tions and certification require-to assure adequate quality are suit-

~

' ments and description of work ably included or referenced in docu- to be done. Shipping memorandums and purchase orders are reviewed ments for procurement of material, '

by QC, equipment, and services, whether /

purchased by the appt scar:t or by . .;

its contractor or subcontr' actor.

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2. To the 'xtent necer'sary pr curement 5.1 'g Suppliers are notified of dis-

, documents shall require contractors crepancies and are sometimes re-or subcontractors to provide a qual- '

'; quired to submit corrective action i ity assurance program consistent statements for approv::1. QA with the pertinent, provisions of tnis Appendix.

Program requirements are not ade-y quately addressed.

,5 wi e

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WYLE Page 11 of 20 ~

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i " PROGRAM REVIEW CHECKLIST i -

)ROJECT: Diablo' Canyon '

Subject:

IE f V Instructions, Proceddre's, and Drawings (App. B) Page 1

! PROGRAM AND ' of 1 N0* 42QUIREMENT PROCEDURE l ~YES NO N/A REFERENCES " REVIEW COMMENTS l

1. Activities affecting ' uality q shaLL l 3.2 ,X beprescribedbydocumentedinstyuc- 3 .'3 f' i Contracts Job Order. Test pro-tions, procedures, or drawings of 6.2 cedures are written by Project i a type appropriate to the circum- Engineer.

j .518-3 QC Manual is supporte.

stances and shaLL be accomplished by QC Procedures Manual.

in accordance with these instruc-tions, procedures, or drawings.

I I

I 2. Instructions, procedures, or draw-518-19 X

! ings shall include appropriate or Test procedure cont ~ent adequately j qualitative acceptance criteria for described. Other criteria not i

' determining that important activi- specifically addressed.

ties have been satisfactorily accomplished.

/

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, , WYLE - March 1, 1982 20/61

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f

. s WYLE Pace 12 of 20 I f -

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i l PROGRAM REVIEW CHECKLIST *

'I UECT: Diablo Canyon Sub ject: VI Document Control (App. B)~ ! Page 1 of 1

i 3 PROGRAM AND

! REQUIREMENT , PROCEDtiRE YES NO REVIEW COMMENTS j I*

lN/A

! REFERENCES l I

. Measures shaLL be established to 518-3(5.) X Test procedures are reviewed and control the issuance of documents, 518-16 , ,

< edited by QC Department's technical such as instructions, procedures, .518-17 and drawings, including changes editor.. Maintained per contract by thereto, which prescribe aLL activi-Test Engineer,-via change in contra ties, affecting quality.

job orde'r. QC will establish moni-toring system. O': Program changes be issued by memo, and incorporated

, as-needed. Revision. changes are to identified on each page. Requireme arc weak and loose.

s These measures shaLL assure that 518-17 X Distribution log is used for GC Mant documents, including char ges, are 518-18 and Procedures Manual. Forms and reviewed for adequacy and approved . . test procedures are approved by QC for release Ly authorized personnel, prior to issuance. Other documents and are distributed to and used at and distribution, are not adequatel ;

the Location whera the prescribed controlled.

activity is performed.

Changes to documents shaLL be 518-16 reviewed and approved by the same .

X Not adequ'ately addressed.

l organizations that performed.the -

original review and approvat unless the applicant. designates another responsible organizati'on.# I WYLE - March 1, 1982 i 21/61

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WYLE Page 13 of 20 ' '

' PROGRAM REVIEW CHECKLIST VII Control of Purchased Materia (,

2R'0 JECT: Diablo Canyon

Subject:

Equipment, and Services (App. 8) Page 1 of 2 EM PROGRAM AND --

REQUIREMENT , ,5 . PROCEDURE YES NO:

NO. ~ N/A REVIEW COMMENTS

. REFERENCES '

.1. Measures shaLL be established to .

n I Not addressed, assure that' purchased raterial, *

equipment, and services,'whether ,

purchased directly or through con- ,

tractors and subcontractors, con-form to the procurement documents. -

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.2. .,ese measures shalt. include pro- 5.1 X visions, as appropriate, for source 0.C. surveys suppliers' facilities evaluation and selection, objective to determine capability. They are evidence of quality furnished by surveyed annually and' audited-the contractor or subcontractor, periodically. Examination of pro-inspection at the contractor or ducts is not adequately covered.

subcontractor source and examina-tion of products upon delivery..

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WYLE - March 1, 1982 22/61

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i

• PROGRAM REVIEW CHECKLIST l .

,. VII Control of Purchased Material, l- 103ECT: Diablo Canyon *

Subject:

Equipment, and Services ( App. B) Page 2 of 2

PROGRAM AND

'E PROCEDURE YES NO N/A REVIEW CO.TiENTS REQUIREMENT

! 10. REFERENCES

! 3.

Documentary evidence that mat'erial  ; X Not~ adequately addressed. Cert.ific and equipment conform to the pro-  : , tions may be obtained if applicable curement requirements shaLL be-available at the nuclear power- .

plant... prior to installation or use of such material and equipment.

This documentary evidence shaLL be -

retained 'at the nuclear power- - ,

plant...and shaLL be sufficient to e identify the specific requirements, such as codes, standards, or speci-fications, met by.the purchased material'and equipment.

4. T.5e etfectiveness of.the' control X Not specifically addressed-of quality. by contractors shaLL be ,

assessed by.the- applicant or desig- ,

I nee at intervals consistent with

! the importance, complexity, and -

lj quantity of the product or services.

, q ,

WYLE.- March 1, 1982

. i 23/61

b ,- ,,,

f WYLE.Page 15 of 20 * .

t PROGRAM REVIEW CHECKLIST'

'ROJECT:

Diablo Canyon -

Subject:

XVI Cerrective Action' (App. B) Page 1 of 2 i

PROGRAM AND

, I. ".TDI ~

REQUIREMENT PROCEDURE YES NO N/A . REVIEW COMMENTS -

l- No. REFERENCES 1

i 1, Measures shall be established to 3.5 X assure that conditions adverse to ' 518-3 ( 8.)

Test areas will be periodically, quality, such as failures, malfunc-- inspected.and out-of-calibration tions, deficiencies, deviations, equipment will be red-tagged. Pro-defec'tive material and equipment, gram seems very loose.

l and nonconformances are promptly j identi fied and corrected.

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,L In the case of significant condi-2* 3.5 X' i tions adverse to quality, the mea - 518-3(8.)

For out-of-tolerance conditions,

!* sures'shall assure that the cause 518-9(8.) corrective action is taken as re-quired.

'of the condition is determined,.and '518-11 QC determine's when correct

,1- action is required and initiates corrective action taken to preclude CAR.

ll. r epe *.i t ion.

~

Cause is determined and it corrective action specified. Verif cation of corrective action .

implementation is not assured.

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24/61 l

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WYLE Pago 16 of 20 ,, .

.  : ~.

PROGRAM REVIEW CHECKLIST .

ROJECT: Diablo Canyon

Subject:

XVI Corrective Action ( App. B) Page 2 of 2 FROGRAM A.VD

• " REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS

.N O.

REFERENCES' L

3. The identifi' cation of the signifi- 3.5 j X l cant conditions adverse to quality,

~

518-11 , { reviewed Corrective by actions continually QC Manager; not reqtiire.

the cause of the condition, and the . to be reported to higher management corrective action taken shall be documented and reported to appropri-ate levels of management. .

P l

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WYLE - March 1, 1982

- t 25/61

• . M$

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WYLE Page 17 of 20 * ,

.  : e PROGRAM REVIEW CHECKLIST .

ROJECT: Diablo Canyon

Subject:

XVII Quality Assurance Records (Aco. 3) Page 1 of 2 PROGRAM AND ITEM PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT MO. REFERENCES 1.' Sufficient records shall be main- 3.4 X Records are kept per procedure tained to furnish evidence of activ-i- . requirements. -

ties affecting quality. I

2. The records shall' include at least. 518-2 Xl Calibration records are maintained, the following: Operating logs and Other records to be kept are not

'the results of reviews, inspections, clearly specified, tests, audits, monitoring of work .

performance, and materials analyses. -

l The records shall also include  ! -

closely-related data such as quali-  :

fications of personnel, procedures, and equipment.  ;

4

3. Inspection and test records shall, 518-2 X Calibration is documented;~defici-as a minimum, identify the inspec- encies a.re not addressed. Test tor or data recorder, the type of record forms are approved by QC observation, the results, the Manager. Test record requirements acceptability, and the action taken are not specific.

in. connection with any deficiencies noted. 't WYLE - March 1,~1982 26/61

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PROGRAM RE\;EW CHECXLIST

• ROJECT: Diablo Canyon

Subject:

XVII Quality Assurance Records (App. B) Page 2 of 2 a'

PROGRAM AND

• EN' PROCEDURE REQUIREMENT YES NO N/A REVIEW COMMENTS

.9 0.

REFERENCES I , .

4, Records shall be identifiable and 518 15 X l Retained one* year at source -

retrievable. Consistent with appli-cable regulatory requirements, the l facility and seven years at Norco, applicant shall establish require-then shredded.

ments concerning. record retention, such as duration, location, and assigned responsibility. -

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• WYLE - March 1, 1982

, 27/61 I

Q .Q 'D -

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, ,e j WYLE'Page 19 of 20 *

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_. PROGRAM REVIEW CHECKLIST 2ROJECT: Diablo Canyon

Subject:

XVIII Audits (Asp. 8) Page 1 of 2 PROGRAM AND  !

ITEM REQUIREMENT i

PROCEDURE YES NO ! N/A REVIEW COMMENTS NO. REr'ERENCES i '

1. A comprehensive system of planned 3.2.2.

and periodic audits shaLL be carried 518-13 X Periodic. informal inspections by QC Department. QC Manager or out to' verify comrLia'nce with all aspects.of the quality assurance designee audits all organizational program and to determine the effec- areas, to a limited degree, every tiveness of the progrra.

six months. They appear to be less than comprehensive.

l 2,. The audits shall be performed in accordance_with the written proce-X Not addressed.

dures or. check lists by appropri-f ately trained personnel not having-direct responsibility in the areas being audited.

1

3. Audit results shall be documen'ed t 518-13 X Documented on audit form W-772. Nc and reviewed by management having required.to be reviewed by manage-responsibility in the area audited. ment above OC Manager.

. i WYLE - March 1, 1982 28/61

, # 8 "A

WYLE Page 20 of 20 ,,

PROGRAM REVIEW CHECKLIST -

ROJECT: Diablo Canyon' 'SuSject: XVIII Audits (App. 8) Page 2 of 2 PROGRAM AN'D

'D PROCEDURE YES NO N/A REVIEW CO.'efENTS

~

R'EQUIREMENT * ' i NO. . I REFERENCES l

• i g [

4. Follow-up action, including reaudit X Not addressed.

of deficient areas, shaLL be taken where indicated.. <

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WYLE - March 1, 1982

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- i 29/61 i .

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e. 5 APPENDIX B REVIEW AND. AUDIT ATTENDANCE LIST I

i WYLE - ?! arch 1, 1982 30/61

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MEETING ATTENDANCE LIST NAME TITLE 1-5-81 . 1-11-81 1-14-81' WYLE

' Larry Housteau QA Manager x x x Jack Bertram Program Manager x x x Orexel Smith Asst. Gen. Mgr. x

'\ x o

PG&E .

F. Zerebinski EQC Dept. x W. T. Spitzel- EQC Dept. x x x R. F. REEDY, INC.

E. E. Varnum Auditor - x x x P. J.-Herbert Audit Team Leader x x x WYLE - March 1, 1982

. i 31/61 i

1 . -

ir 1

I 1

APPENDIX C

.i APPLICABLE i

WYLF -

QUALITY ASSURANCE PROGRAM MANUAL l

. AND QUALITY ASSURANCE IMPLEMENTATI'ON i

l

)

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WYLE.- March 1, 1982 l 3

32/61  ;

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O

1. On September 28, 1977, Mr. R. V. Bettinger requested o in a letter to Mr. Drexel Smith that WYLE provide PG&E by October 14,'1977, "the procedures that are used to control your work". Attached to this PG&E letter was a . copy of .PG&E's " Specification for Consultant's Quality Assurance Program No. CO-E-0,

,, Rev. 0 (No Date). WYLE was requested in this PG&E i letter .to: "If you feel that portions of this .

specificati'on are not . applicable to your work or

-that aspects of your procedures are not covered by -

this specification,.please include this informa~t ion

• with your submittal."- The PG&E letter further '

stated to WYLE "Your submittal does not necessarily have to be in the form of a formal Quality Assurance Manual, as called for in the attached specification.

The procedures you submit should, however, be detailed enough so PG&E auditors can verify that

- your controls comply with the criteria in the attached specification." "

2. WYLE. on October 3, 1977 (Internal-Memorandum from .

Alan Cormeley to A. Heeseman) assigned Mr. Heeseman with . the responsibility of reviewing the WYLE Quality. Control Manuals against the requirements of PG&E*" Specification for Consultant's Quality Assur-ance Program No. CO-E-0, Rev. 0". The Charter given to Mr. Heeseman in this WYLE memorandum was:

"Please ' review the attached PG&E letter -

requesting information- on our quality control procedures. PG&E specification CO-E-O' defines the requirements.

Submit the information to the attention of Mr.

R. V. Bettinger. Suggest that, along with the ~~

data you feel.necessary, a copy of our current QC manual and a copy of the-attached Bechtel letter should also be submitted.

Please forward a copy of your response letter to' my attention for .the contracts file and

• forward a copy also to Drexel Smith." -

1

] 3. On October 10, 1977, Mr. Heeseman, under a letter to i Mr. R. V. Bettinger, of PG&E, submittedLcopies of

. the Quality = ' Control Manual SPP-518-Q and Quality j Control Proc'edures Manual SPP-518. No exceptions j .w ere taken to the requirements of PG&E's specifica-f tion CO-E-0, Rev. O.

{.

i h WYLE - March 1, 1982 33/61 .

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4. The Audit ' Team was- not provided with documentary '

, evidence that PG&E had accep$st. their Quality Assurance Program as described in"thei'r manuals SPP-

518Q and SPP-518. g. _

5. A review of Change Number 5 to'PG&E contract 5-61-77

, dated November 30, 1978, imposed an Att,a'h' c ment B '

" Specification for Testing LAB's Quality Assurance

Program". This PG&E Specification was undated, was

. . not approved- by any~ PG&E authorities and was not given any identifying numbers or letters. Change ,

Number 5 to contract 5-61-77 'made this contract effective December 1, 1978 but did .not make it -

retroactive. .Therefore, in the opinion of the Audit 4

Team, the testing activities performed and. reported on by WYLE prior to June 1978 could not be audited against~this contractual PG&E Specification.

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, 34/61 i

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'l i .  !

APPENDIX D SPP-5,18Q QUALITY ASSURANCE MANUAL AUDIT CHECKLIST AND

SUMMARY

'dF IMPLEMENTATION AUDIT. FINDINGS / OBSERVATIONS f

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R. F. REEDY,'INC.

AUDIT CHECKLIST '

ORGANIZATION: WYLE Laboratories ~

ADDREES: 11841 Hillside Avenue Norco, CA 91760 .

QA PROGRAM

REFERENCE:

Quality Assurance Manudl SPP-5180 Quality Assurance Procedures Manual SPP-518 AUDIT CONDUCTED BY: i . ATE: / ~/ d -.

DATE: 74-FE v <

DATE:

REVIEWED BY:

y vv - -

o ., DATE:

s M( hb .

__ _DATE:

8 G/'

DATE: /z7['Bz "

y T

NO. OF PAGES: 12 e

I'

' WYLE - March 1, 1982 36/61

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,'  !  ; AUDIT CHECKLIST Cr2pany iflLE I Page 1 of 12 Applicable QAM SPP 5180 (April 1975)' l Auditor E.E.Varnum/P.J. Herbert Date January 11-12, 1982 il App. B. QAM Statement Audit Instruction Comment Crit. Ref. '

Preface Page "2" Verify that preface page is part verified by QA Manager and by '

, . of this manual as not shown on checking controlled copy Table of Contents Pag'e and.

appears numbered cut-of sequence.

Preface Page "2" . Verify that responsibilities . Verified by 4 Manager, and fact assigned on Preface Page are page was in manual when signed.

authorized by the General Manager Manual Front Page -

Front pages' describes document as Verified by QA Manager. Termin-

" Quality Control Manual" Page 1' ology change agreed as poor tech.

is titled " Standing Practice Pro-- writing.

cedure"; various instances iden-tify that all these relate to SPP 5180 and SFP518. -

~

Manual QC Proc. In no place, except on Preface After preface page was ascer-r] age of SPP 5180, is the Quality tained to be part of SPP5180,.

Control Procedures Manual SPP-518 this verificatien became unneces-appended to SPP5180 Verify this sary. It appears that SSP 5180 and.

. to be fact. SSP 518 are identified as " Stand Practice Procedures" Verify that the intent is to imnose these 1

practices and proce'dUres as

. standards within WLE wherever other instructions are not imoosed.

This was confirmed correct by'OA Manager.

WYLE - March 1, 1982 l,

37/61 I

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AUDIT CHECKLIST Company . NYLE Page 2 of 12 l

Applicable QAM SPP 518Q (April 1975)- Auditor E.E. Varnum/P.J. Herbert Date January 11-12, 1982 App. B. GAM Crit.. Ref.

Statement Audit Instruction Comment ,

t Prepare Page 2 ' Audit the use of " departmental 'Ihe QA Manager claimed none were '

instructions" which "imolement .

issued, however later the con-the Quality System". tracts Dept. Mg. revealed his depart 2 rent had a set of instruc-tions covering logging of orders and that those instructions had not been given to GA for review.

.r . - .

'; 1.1 Note and 2.0 Applicable Verify, that PG& inposed require- Although nuch effort was expended Documents -

ment of " Specification for Con- on the part of the Audit Team to i

sultants Quality Assurance Pro- find avmmnted response to Mr.

gram No. CO-E-O" on WYLE. R.V. Dettenger's letter of September 28,1977 (PG&E) to Drexel Smith (WYLE), the reply differed as evidence in the opin-

• ion of the Audit Team, failed to fully respond. Further, it was said that no records exist of

- verbal discussions concerning adequacy of WYLE SSP 5180 with SSP 518 meeting the requirements of PG&E CO-E-O. In this area, the StEvey Team was coilcerned about

, NYLE's imolementation of a design / order control procedure during a period of testing when the adequacy of the OA program in use for testing was under question.

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f WYLE - March 1, 1982 38/61 I s

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< ^::*  ; - :v ~ + . . .- . w. e, . - .aw, a ; .

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c AUDIT CHECKLIST Company NYLE Page 3 . of 12-Applicable QAM SPP 5180 (April 1975)- Auditor. E.E. Varnum/P.J. Herbert '

Date January 11-12, 1982 App. B. GAM Crit. Ref.

Statement Audit Instruction Comment

• j i

3.1 Organization "

Verify evidence that QC Dept. ~

~

has established and maintained .

controls which assure quality aspects of:

. (a) D.gineering (a)(b)(c) QA Manager says only

' controls are those given in the (b) Program Management manuals. Engineering is not covered, and Program Magmt, only (c) ' Inspection:

sparingly so. -

3.1 Organization Verify that Manage'r of OC makes QC Manager states "no responsi-all decisions affecting Quality. bilities concerning quality were delegated outside the QC Depart-ment. However, deviations and

, nonconformances are not under his direct control. Contracts Depart-ment assume responsibility for

, document control system in their department; and the project Engi-neer decides resolution of devia-tions and also tests made using out of tolerance %quiprent. This condition indicates that assign-ments of responsibilities are not clearly defined.

I

• WYLE - March 1, 1982

. , 39/61 I

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AUDIT CHECKLIST Company NYLE ,

Page 4 of 12 Applicable QAM SPP 5810 (April 1975)- ' Auditor E.E. Varnum/P.J. Herbert Date Januarv 11-12, 1982 i

App. B. GAM Crit. Ref.

Statement Audit Instruction  ! Comment .

l 3.1 Paragraph 3.1 and Organization Verify that GA bbnager has >

Charts. delegated authority to establish and mair. Lain effective quality prograns in areas of:

(a) Field Services (a) None per GC Manager

~

(b) E.gineering 5ervices (b) None oer QC Manager (c) 'Q eristions (c) None per QC Manager (d) Calibration ' (d) None per QC Fbnager (e) Technical Editor (e) None per QC Manager (f) QC Surveillance (f) None oer QC Fbnager i

j s WYLE - March 1, 1982 40/61 l- -

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j ' AUDIT CHECKLIST i ;

l

• Compay NYLE j Page 5 of 12 i  !

Applicx,te QAM SPP 5810 (Tpril 1975)* Auditor E. E. Varnum/P.J. Herbert. Date January 11-12, 1982 s

App. B. GkM crit. F.e f.

Statement Audit Instruction Comment h 3.2.1 Initial Quality. Planning ,(prior to ' Verify Wyle approval of buyer No evidence was of cred to Audit' contract agreement) special procedures, or deivia- '.

Team concerning deviating differ-tions to Wyle Standing Practice ences between SPP5180 and SPP518 Procedures, including clients and CO-E-O; and no evidence of-(-

l, -

" Specification for Consultants Quality Assurance Program CO-E-review of CO-E-O by Contracts' Department; Test Department and/or O"..

, QC Department. Also, there is no

/ evidence of ccmmnts regarding d 'T , .

, either PG&E acceptance / rejection /

'i - '

, discussion. The Audit Team was told there is no documentation l in file in this area.

3.2.1 Verify'th'at. quality program has- During the period frcun issue of the b been continuously reviewed by program to cut-off of'th'is audit Manager of QC. phase (3 years), only 1 audit was said to have been made (QC remark) .

Auditor unable to review report l

, of that audit as it was locked in a desk / file, but auditor ruled out acceptance of the results of that audit since it had,been performed by the Business Manager, admittedly not qualified, and it was his first. audit performance, i

l . .

l '

l; WYLE - March 1,.1982 l3 l

- i 41/61 l

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. ~

AUDIT CHECKLIST l- .

Company M T.E ' Page 6 of 12. ,

Applicable QAM SPP 5810 (April 1975)

• Auditor E.E. Varnum/P.J. Herbert Date January 11-12, 1982 App. B. GAM Crit. Ref.

Sta:Cment Audit Instruction  ! Comment '

3.2.2 Initial Quality Planning (After (a) Audit contract Job Order. (a) QA Manager says it had been '

contract agreement) reviewed but no evidence to sub-stantiate or date, or the various departments involved. QA Manager says there is no requirement to document the review. -

. 1 (b) . Review "Scecial Job Instruc- (b) There aopears to be no control tions",. including authorization over any instructions issued out-for preoaration. side of the Test Procedure. No such documents were identified or offered for review.

(c) Audit reviews by QC of Job (c) No documentation presented to Orders and Special Instructions. verify that any QC reviews were made.

(d) Audit Project Engineer / Pro- (d) OA Manager cou3d not provide .

gram Manager review of Test Plan documentation to verify that such

. Program with QC Dept. review had been made other than the final sign off of the Test Report.

Wyle assumes such sign-off satisfies the review specified in the program.

(e) Review Wyle inhouse meaning (e) QA Manager says that Wyle Form of term " informal inspection". W-675-A is used for subject inspections and that the word

" informal" has no meaning.

WYLE - March 1, 1982 i 42/61 1

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Company NYIE Page 7 6f 12' Applicable QAM SPP 5810 (April 1975)* Auditor E.E. Varnum/P. J. Herbert .Date January 11-12, 1982 App..B. GAM writ. Ref.

Statement Audit Instruction Comment -

3.2.2

~

(f) Verify that informal inspec- (f) Documentation not made avail-cont. tions were periodically performed able. Said that these records had been destroyed and documented.

Although Audit Team asked to see such documentation-not offered /

(g) Verify that the results of (g) No evidence offered to Audit

. periodic infangal inspections Team..No record of this detennina-assured adequate scheduling and tion offered. Apparently activity planning'to place. not imolemented. QA Manager says that weekly surveillances, not docu-mented were made between 12/77'and

,~ 3/78. This verified by one Utility

' M'y audit report.

3.2.2 No sign-off available Verify that QC reviewed and approved, at ccupletion:

. (a) Operations contract Job Fol- (a) No sign off availble der (b) Test Report (b) Signed off ,

(c) Data (c) No sign-off

$ (d) All salient information (d) No definition and therefore no

. sign off .

4 WYLE - March 1, 1982

, 43/61 i

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AUDIT CHECKLIST

'Conpany WYLE Page 8 of 12' l

Applicable QAM SPP 5810 (April 1975)* Auditor ' E.E. Varnum/P.J. Herbert  ;

Date January 11-12, 1982 App. B. GAM Crit. Ref.

Statement Audit Instruction Comment .

i' i

3.2.2 verify that QC review of job ccm. Check list used by QC was incompl'ete pletion ensured that all require-. as to defining all of the job

~

ments of the' contract' job order reauirements and areas to be covered' were satisfied prior to finaliza- in the review. Otherwise the review ^

tion and subnittal. perfomed could give the required assurance.

3.3 Test Procedures . - . -

Audit responsipility for develop-ing, preparing,. reviewing, approving, approving and releas-ing documents covering activities affecting quality:

(a) Drawings. (a) These cme frcrn custmer unless made part of that procedure.

(b) Specifications, data sheets (b) These documents are.made by the inspection procedures; testing Test Department. OC reviews and procedures and packaging instruc- approves. NorTnally there are no tions. other reviews or verifications.

WYLE - March 1, 1982 44/61

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5 AUDIT CHECKLIST ,

Ccapany WYLE Page 9 of 12 Applicable GAM SPP 581Q (April 1975) Auditor E.E. Varnum/P.J. Ilerbert Date January 11-12,.1982 App. B. GAM i

Crit. Ref.

Statement Audit Instruction Comment -

3.4 (a) Verify that QC Dept. per-

~

Records . (a) Records of these QC activities formed inspections, monitoring were said to constitute a file of and witnessing activities suffi- at least ten (10) inches for the cient to assure that test activi- 3 year oeriod, but were destroyed t.ies were conducted in accor- when QA moved offices. ,

,  ; dance with requirements.

(b) Review of records available

- (b) Audit QC r9 view of records 1

d

~

for canoleteness, concisenss indicated this function satisfac-and' accuracy. toriyl carried out. -

3.5 Corrective action (a) Verify .that the Quality (a) All records for the period ll Program provided adequate moni- under audit were destoryed. No

, toring'of test activities and requirement established for a

that such monitoring did detect number and frequency, and type of

. discrepancies early. auditing to be done - Impossible to verify.

• (b) Audit corrective action (b) Response was that neither Wyle l'

I requests and lists, if any, of. nor PG&E required these actions.

deficiencies to verify if QC Manager is continuously review-cl i ing these documents to identify l unfavorable trends.

l1 .

I' l . .

S .

WYLE - March 1, 1982 i .45/61 8

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l ,

AUDIT CHECKLIST' Company WYLE , Page 10 of 12' Applicable QAM SPP 5810 (April 1975)* Auditor E.E. Varnum/P.J. lierbert Date January 11-12, 1982 App. B. QAM Statement Audit Instruction Comment Crit. Ref.

3.5 .

. cont. (c) Audit controls for recording (c) Actually, only Notices of of discrepancies. Deviations and Corrective Action

. . Requests are covered in Program.

QC does not function until after i

Test Department has approved the

, , , document - although it is not supposed to be. distributed until, f

, after QC approves it. Sme devia-

) ,

tions are not required to be

~

recorded, nor advised to the client 7 and such do not appear to satisfy J

QC's function of making all quality related decisions. .

4.1 Measuring.and Test. Equipment (a) Verify that initial survey of (a) Satisfactory test equipnent was made to assure that equiptent was available to

, produce data acceptable for con-tract requirments.

i (b) Verify that periodic inspec- (b) Satisfactory ,

tions and calibrations were made 1

with certified measurement stan-dards traceable to National Bureau of Standards.

j' '

WYLE - March 1, 1982 46/61

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2

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l AUDIT CHECKLIST i

j -- Company WYLE ,

Page 11 of 12 .. r.

1  : .'

Applic able- QAM SPP 5810 (April 1975)* Auditor E.E. Varnum/P.J. IIerbert Date January 11-12, 1982 i App. B. ' QAM Crit. Ref. Statement Audit Instruction Comment 2 '

l -

I a .

l 4.1 ~

cont. (c) Review records of instances (c) None found on audit contract I where equipnent was found out of but for another job instance noted

( tolerance or inadequate.- where record indicated unsatisfac-l tory calibration results, but there was no reference to a report for l .

handling.

l

~

(d) Verify that suopliers must n (d) Wyle audits subcontractors use'a calibration system which- and files indicate this is one of tssures cmoliance with MIL-C- the requirements for acceptance.

45662A.-

4.3 Advanced metrology requirements Verify that technical personnel 'Ihis is a requirement of Wyle.

l nust be qualified to operate pre- ,

1 cision equipnent. '

6.-2 Te' sting Operatings (a) Review standard logs and (a) Satisfactory l

data sheets for tests.

l l (b) Review release of documents. (b) This is said to be by the approval signature, but when two approvals are required, or when l required approval soaces are not canpleted.

s s

. , WYLE - March 1, 1982 47/61

,1

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AUDIT CHECKLIST I

Company NYLE Page 12 of 12' Applicable QAM SPP 5810 (April 1975)* Auditor E.E. Varnurh/P.J. Herbert Date January 11-12, 1982

. B.

. Statement Audit Instruction Comment ,

6.2 ~

(c) Review how quality program (c) Satisfactory

• cont. assures that appropriate work instructions are followed.

(d) Review what is considered (d) No policy on this was given "suffielent documentation" of to the Audit Team, monitoring activities.

l 6.3 Test acceptance -

(a) Verify acce tance/ rejection (a) Satisfactory of test reports by QC Manager .--

a (b) Verify test rcports were (b) Satisfactory a evaluated against contract, speci.-

fications and standards.

6.4 Handling, Storage and Delivery (a) Review instructions.for han- (a) Satisfactory dling, storage and delivery.

l *

(b) Review how documents are (b) Activities were conitored on

]

i monitored, as required. documents.

6.5 Indication of Inspection Status (a) Review documented instruction: .(a) Stamoing on data sheets and logs, for identification of inspection status, i

s

. i WYLE - March 1, 1982 48/61 4

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5 ...

SUMMARY

OF FINDINGS / OBSERVATIONS

. . t, The implementation of controls pertaining to:

a) Design Control, design interface' control, order control and changes thereto (Ref. AFR-1, pages 1-4);

b) Document. control, including preparation, review, approval and release, for procedures, instructions, and drawings, and changes thereto (Ref. AFR-1, page 5) ; ,

c) Document distribution control (Ref. AFR-1, page 6);

d) Managements assessment of the effectiveness of the quality program (Ref. AFR-1, page 7);

e) Identification, collection and storing of quality related

. records (Ref. AFR-l~, Page 8);

f) Definition of quality responsibilities (Ref..AFR-1),

page 9);

g) Nonconformities and d'e'viations (Ref. AFR-1, page 10);

h) Inspection and monitoring of activitics affecting quality (Ref. AFR-1, page'll); and i) Final inspection activities (Ref. AFR-1, page 12) .

As evidenced by the documents made available to the Audit Team, did'not demonstrate, in the Team's opinion, full com-pliance with the applicable requirements of.10CFR50, Appen-dix B.

7

- WYLE - Ma'rch 1, 1982 49/61  ;

RHG&A AUDIT FINDING REPORT' PAGE 1 OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT COMPANY / ORGANIZATION PG&E: 5-61-77 AUDIT LOCATION WYLE LABORATORIES WESTERN OPERATIONS NORCO, CA REQUIREMENTS AND REFERENCES 10FRC50 APP. B requires applicant to establish a QA Program covering consultants design / testing activities performed on safety related items. -

OBSERVATION: Documented evidence that PG&E had approved WYLE QA program SPP-518Q including SPP-518, both dated April 30, 1975, not made available to Audit Team for period up to June 1978.

RECO:01 ENDED ACTION: WYLE to review their files for missing objective evidence, and to report to R. F. Reedy, Inc. their results of such review.

REPORTED BY: 0 _d ,,vb ACKNOWLEDGED BY: .p E." f. Varnug, //uditor

, P. J. Herbeid Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

~~

RHG&A CONCURRENCE:

NO YES Name Date FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

WYLE - March 1, 1982 50/61

. ~

~

. RHG&A AUDIT FINDING REPORT PAGE 2 OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT COMPANY /ORGANIZAT' ION PG&E 5-61-77 AUDIT LOCATION E: -WYLE LABORATORIES WESTERN OPERATIONS NORCO, CA REQUIREMENTS AND REFERENCES ,

Para. 3.2.1 (SPP-518Q) requires approval by QC on acceptance of any special procedures or deviations to WYLE's " Standard Operating Manual". PG&E 9/28/77 requirement for WYLE acceptance of program CO-E-0 requirements appears to constitute a deviation.

OBSERVATION:

compliance.

No objective evidence was made avialable to the Audit Team to verify RECOMMENDED ACTION: None - '

REPORTED BY: / ..

O w/ -+L ACKNOWLEDGED BY:

'E.E.'Varnum,/Au(1 tor P. J. Herbert ( Lead Auditor 4

THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

N, PROPOSED CORRECTIVE ACTION: _

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

. .= =

RHG&A CONCURRENCE: -

NO YES

• Name Date, FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

r

. WYLE - March 1, 1982 i 51/61

?

l- ___

a .

. s . -

. RHG&A AUDIT FINDING REPORT' PAGE 3 OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT

~ ~ ~ ~

COMPANY /ORGANIZAT' ION AUDIT LOCATION b* ~ ~

WYLE LABORAIDRIES q UESTERN OPERATIONS NORCO, CA REQUIREMENTS AND R5fsRENCES Para. 3.2.2 (SPP-518Q) requires review of the Contracts Job Order program by the project engineer / program manager and the . Quality Control Department to assure that various con-trols are planned in accordance with the quality control requirements.

OBSERVATION: No oble"ctive evidence was made available to the Audit Team to verify that required reviews of PG5Es program CO-E-0 had been made.

RECOMMENDED ACTION: None . -

REPORTED BY: / ., ACKNOWLEDGED BY: ,/

t.E.Varnum,Auditof P. J. Herbe'/f, Lead Auditor THIS SECTION TO BE~ COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE:

PROPOSED BY: DATE-

== . . . .. .-

RHG&A CONCURRENCE:

NO YES Name Date, FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

• WYLE - March 1, 1982 52/61 e

RHG&A AUDIT FINDING REPORT. PAGE_4 OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT COMEANY/ ORGANIZATION PG&E: 5-61-77 AUDIT LOCATION WYLE: ND 58255 WYLE LABORATORIES ND 5R378 WESTERN OPERATIONS '

RSQUIREMENTS AND REFERENCES 10CFR50 APP. B requires design interface control for design / testing activities for -

safety-related items. '

OBSERVATION: No ob[ective evidence was made available to the Audit Team for verifi-cation of this required activity with respect to a change in the quality c6ntrol requirements of the order..

RECOMMENDED ACTION: None -

REPORTED BY: > ACKNOWLEDGED BY: N E.'E.Varnum,Aud[ tor [ P. J. Herbed, Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:

NO YES Name Date, FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

WYLE - March 1, 1982 53/61 E_o____________----_--------- -'------- '

.~

s .

RHG&A AUDIT FINDING REPORT PAGE 5 OF 12 AFR NO. 1 DATE: 1-20-82

, PROJECT --

COMPANY /ORGANIZ5 TION AUDIT LOCATION PC&E: +5 77 WYLE LABORATORIES -

WYLE: ND 58255 WESTERN OPERATIONS NORCO, CA m 58'47R

~

' REQUIREMENTS AND REFERENCES 10CFR50 APP. B requires an ef fective document control procedure including preparation, review approval and release, including changes thereto, for procedures, ' instruc tions ~

and drawings related to activities which affect quality. '

4 OBSERVATION: It waVnoted the Contracting Dept. is using instructions for document control which were not approved by QC. Also, the WYLE QA program defines delegation of t authority to Depts, other than QC, but does not require QC review of quality related {

documents so produced other than the Test Plan / Report. Also, Test procedures are  !

approved by operations prior to QC ' review for editing. Also, the Test Program review

• RECO:O'E:'DED AC"'IO ': required by Program Mgr. and QC Mgr. are made at different i

, stages than. required. Also, Quality Program changes can be  ;

made without the. approval of the QC Mgr. Also, changes on j sogy ocum nts eviewed were not clearly identified.

RECOMMENDED ACTION: N REPORTED BY: _

es J ACKNOWLEDGED BY: [

E. [.-Varnd[Auditorf /

P. J. Herberk L'end Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION 9

PROPOSED CORRECTIVE ACTION: '

[

L i

I f

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:  !

i 4

RHG&A CONCURRENCE:

NO YES Name ,Date l FOLLOW.UP AND CLOSEOUT v

! i

) i 1

CLOSED BY: DATE:

i I 1

i WYLE - March 1, 1982 54/61 .

i r

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._ _ . - . ~ . _

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

.,' T3'

RHG&A AUDIT FINDING REPORT' PAGE 6 OF 12 AFR NO. 1 DATE: 1-20-82 i

PROJECT COMPANY / ORGANIZATION PG&E: 5-61-77 AUDIT LOCATION WYLE LABORATORIES

, WESTERN OPERATIONS NORCO, CA REQUIREMENTS AND REFERENCES 10CFR50 APP B. requires an effective document distribution control procedure. _

J OBSERVATION: The Audit Team was unable to' audit whether the latest authorized documents were used as 'a detailed quality control procedure was not made available.

It was noted there are no records concerning distribution dates within WYLE nor data regards latest authorized documents.

RECOMMENDED ACTION: None. .

REPORTED BY: '

1. A/ .ej ACKNOWLEDGED BY:

E. E.' Var'num. Audi,/or[/ P. J. HerberV, Lead Auditor THIS SECTION TO IC COMPLETID 8Y THE RESPONSIBLE dRGANIZATION:

I PROPOSED CORRECTIVE ACTION:

i SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:

NO ,.YES Name " Date, FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

WYLE - March 1, 1982 55/61 i - . . _ -

F -

RHGsA AUDIT FINDING REPORT' PAGE 7 OF 12 AFR NO. 1 DATE: 1-20-82

, PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E: 5-61-77 WYLE LABORATORIES 83f8 W STERN OPERATIONS ~ NORCO, CA REQUIREMENTS AND REFERENCES 4

Para. 3.1 (SPP-518Q) requires the Mgr. of QC to continuously review the status and

{ adequacy of the quality progr,aci. SPP-518-13 requires periodic audits every 6 months.

OBSERVATION: Tocumentation of only one audit in a 3 year period was made available.

That audit was rejected on the basis it had been performed by an ~ unqualified auditor.

1 RECO>S1 ENDED ACTION: None. .

I i . .

REPORTED BY: /0 ACKNOWLEDGED BY: -

d E. Var'nn, Aud/to// P. J. HerbeN, Lead Auditor THIS SECTION TO BE COMPLETE'D B'Y THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

5 j SCHEDULED COMPLETION DATE:

PROPOSED BY: DATE:

. = .- - _ _ _ _ -

RHG&A CONCURRENCE:

t NO YES *

, Name -Date,  !

i

FOLLOW-UP AND CLOSEOUT i

l

CLOSED BY

DATE:

i WYLE - March 1, 1982 56/61  ;

1 t '

s-

RHG&A AUDIT FINDING REPORT. PAGE 8 OF 12 AFR NO. 1

. DATE: 1-20-82 O

PROJECT COMPANY / ORGANIZATION AUDIT LOCATION PG&E: . 5-61-77 WYLE LABORATORIES WESTERN OPEPaTIONS NORCO, CA REQUIREMENTS AND-REFERENCES Para. 3* 4 (SPP-518Q) requires that records of all essential test activities be main-tained. SPP-518-15 requires that QC records be maintained at least 7 years. 10CFR50 Appendix B identifies the types of records required to be maintained.

OBSERVATION: Tha= Audit _ Team was informed that quality records covering the time frame of the independent audit had been destroyed. It was said that all inspection, surveill-ance, monitoring and auditing records / reports were therefore missing and unavailable.

The Aadit Team noted that the available QC procedures did not include provisions for identification of required records. Procedures for the identification, collection, RECO:22NDEO .'.CTION. storage, retention and safeguarding of records should be .

reviewed and revised as may-be found necessary to' meet current requirements.

RECOW. ENDED ACTION: Non .

REPORTED BY: / ,/ ve x/ ACKNOWLEDGED BY:

E.' E. VarntI, Aud[to[/ P. J. Herber k Lead Auditor THIS SECTION TO BE_ COMPLETED DY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

~ -= " ~

^RHG& A CONCURRENi i.I-NO YES Name ,Date, FOLLOW-UP AND CLOSEOUT '

CLOSED BY: DATE:

WYLE - March 1, 1982 57/61 f

o 4

.< e ..

RHG&A _ AUDIT FINDING REPORT' PAGE 9 OF 12 AFR NO. 1 _

DATE: 1-20-82 PROJECT -COMPANY / ORGANIZATION AUDIT LOCATION PG&E: 5-61-77

• WYLE LABORATORIES WESTERN OPERATIONS NORCO, CA REQUIREMENTS AND REFERENCES 10CFR50 App. B requires that the authority and ' duties of persons and organizations per-forming activities (affecting quality) be clearly defined, that persons and organiza-tions performing quality assurance functions have sufficient authority and feedom to identifv quality problems: to initiate, recommend and to provide solutions. . . .

OBSERVATION: i The Audit Team noted: 'a) the Contracts Dept. Mgr. assu:ned responsibi-lity for the document- control activity program, b) SPP-518Q indicates delegation of responsibilities without specific identification, c) QC Mgr. assigned to make all decisions affecting quality, d) the Project Engineer decides resolution of deviations and out of tolerance equipment -- all of which appear to conflict with requirements.

RECOMMENDED ACTION: None. -

REPORTED BY: / pp J ACKNOWLEDGED BY: fe,

'E. E. 'VarnE audto [/ ~

P. J. Herbert [/ Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:

NO YES '

Name ,Date, FOLLOW-UP AND CLOSEOUT '

CLOSED.BY: DATE:

WYLE - March 1, 1982 58/61

. ?

, e.

RHG&A __

AUDIT FINDING REPORT PAGEgOF 12

. AFR NO. ~l _

DATE: 1-20-82 PROJECT COMPANY / ORGANIZATION AUDIT LOCATION

! PG&E: 5-61-77 WYLE LABORATORIES E. 8 WESTERN OPERATIONS NORCO, CA 8

REQUIREMENTS AND REFERENCES 10CFR50 Appendix B requires an ef fective control over nonconformities and deviations.

, OBSERVATION: The Audit Team noted: a) only deviations noted during test are consid-ered; b) the Project Engr. decides the plan of action af ter an anomaly occurs; c) WYLE does not document deviations considered minor; d) QC receives notice of deviation only

, af ter it has been approved by the Test Dept.; e) notices of deviation are not sequenti-ally controlled; f) there doesn' t appear to be any procedure for the -recording, resolu-

!. RECO:'".E::OED ACTIO::: tion and control of nonconformities except by the use of correct-

! ive action request; g) the Project Engr. evaluates results of out of tolerance condi-tions; h) the QC Mgr. apparently is not receiving notification of all nonconformities and deviations - and ew e th PG&E. '

RECOMMENDEDACTION[:"

REPORTED BY: j ,/ O sf ACKNOWLEDGED BY: f E. d. Va"rnb,~Auditdr // P. J. Herberk Lead Auditor THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

I SCHEDULED COMPLETION DATE: PROPOSED BY: . DATE:

RHG&A CONCURRENCE: rr j

j NO YES _

i a

Name -

Date ,  !

E FOLLOW-UP AND CLOSEOUT t

l CLOSED BY: DATE:

. I

I

. (

WYLE - March 1, 1982  ;

59/61 l

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's RHG&A AUDIT FINDING REPORT' PAGE ll OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT COMPANY / ORGANIZATION PG&E: 5-61-77 AUDIT LOCATION WYLE LABORATORIES WYLE: ND 58255 WESTERN OPERATIONS '

ND 58378 REQUIREMENTS AND REFERENCES WYLE quality program in several places requires the performance and documentation of inspections, surveillance and monitoring activities.

OBSERVATION: The Audit Team was not provided with sufficient objective evidence to assure that the above required activities were carried out as required.

RECOMMENDED ACTION: None. -

2 REPORTED BY: ,3 , a ACKNOWLEDGED BY: a

~E. EV@W ~A%it/dr~ ~ ~(/ '

THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:-

PROPOSED CORRECTIVE ACTION:

1 SCHEDULED COMPLETION DATE: PROPOSED BY: DATE: '

. _ . - . = __.

RHGSA CONCURRENCE:

l NO YES ~

Name -

"Date, FOLLOW-UP AND CLOSEOUT

CLOSED BY

DATE: '

i WYLE - March 1, 1982 1 60/61 4

- + - - r_ . _ _

e ,,

, , . ;4 - .

RHGER AUDIT FINDING REPORT' PAGE 12 OF 12 AFR NO. 1 DATE: 1-20-82 PROJECT __

COMPAN,Y/ ORGANIZATION AUDIT LOCATION PG&E: 5-61-77 KYLE LABORATORIES WEE: WESTERN OPERATIONS REQUIREMENTS AND REFERENCES Para. 6.3 (SPP-518Q) requires a final evaluation of the test report by t.he QC Mgr.

10CFR50 Appendix B requires a program for inspection of activities af fecting quality to verify conformance to requirements. ,

OBSERVATION:_The Audit Team noted that' details and forms included in the quality program do not provide for a comprehensive check list and/or procedure which, in the opinion of the Audit Team, is' required to achieve necessary results.

~

RECOMMENDED ACTION: None.

REPORTED BY: . .. Of.

ACKNOWLEDGED BY: . _. M P. J. Her69 ft, lead Auditor E.'E. VIrninIAudito/ //

THIS SECTION TO BE COMPLETED BY'THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED'BY: DATE:

~~

RHG&~A= CONCURD.ENCE .

NO YES Name Date ,

FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

WYLE - March 1,.1982 61/61 e

- -- . . . . - - . . ~ . - - . . - - - . . . ....... --.~ -.. ... ..

lJ_T_______________-___--____- .

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,e AUDIT CHECKLIST Comprny PG&E Page 3 of 5 Applicable QAM Auditor R. F. Petrokas Date February 9, 1982 App. 8. GAM Crit. Ref. .

Statement ' Audit Instruction Comment III Items for PG&E Audit -- from la) Review IC&E file for evi- la) Rev. O of EES interfaces is RFP's EES (Cygna) Audit File. dence of scope of work defini- dated 8/20/79. Earlier traro to v tion and interface controls, file on interfaces was dated June 28, 1978 (File 14G.56).

lb) Was EES ever responsible Ib) Apparently so. M&E letter of for piping analysis 7 February 23, 1978 transnits draw-ings and criteria to be used, latter fran M&E dated October 31, 1977 transmits a number of iso-rretric drawings to be used for llosgri re-evaluation.

2) Check control over M &E 2) EDS received Rev. 2 via letter document " Guidelines for Pipe dated July 12, 1978 and Rev. 3 via Supports and Restraints". Why letter dated December 27, 1978. EES did EES use Revision 4 & EDS received Rev. I via letter of only have Revision 1? What was October 27, 1977.

in Revisions 2, 3, and 4 that v would pertain to EDS scope? What was in Rev. 2 (not received by EES) that would effect EES scope?

3) N &E letters transmitted lists 3) Yes. ICLE letters dated:

of hangers to be analyzed, and 10/31/77, 8/21/78, 8/10/77, therefore established scope of 8/24/77 and 8/26/77.

work. EES file had the follou-ing letters: 10/19/77, 9/26/77, 9/7/77, 9/1/77, 8/16/77 (2 ltrs),

7/25/77, 7/13/77, 7/12/77, 7/6/77, 7/1/77, and 3/1/77. Is there evidenct, of other letters 4 g Q] ! N&E file not received by PG&E - m h 8, 1982 P/i4

m

' .: (

AUDIT CHECKl.IST Company N&E Page 4 of 5 Applicable QAM Auditor R. F. Petrokas Date February 9, 1982 App. B. QAM -

Statement Audit Instruction Comment Crit. Ref..

4) M &E letters dated 7/13/77 4) Support is in N&E files.

III, transmitted data indicating de- Records show it was verified by cont, sign of support #48-17R should URS/Blunn, not EES. Drawing O be verified by EES. EES has no 040256, Sht. 21, Rev. 2, for this record of what was done with support not in N&E Construction ,

this support (See EES AFR-1). drawing index.' Several different What are NSE records regarding versions of this drawing are in this support? the file, all of which are labeled "Rev. 2". M&E has a calc. file for this support.

5) Check a minimum of 5 more 5) Chose 42/40R. Cover sheet supports chosen at random from records 4 sheets of Rev. 3, but data correspondence listed in item 3, package includes 5 sheets of Rev. 4, above, to verify that N&E also. For drawing 040254, Sht. 40:

design criteria were met. Check - There are 3 different Rev. 2's.

documentation accanpanying - There is Rev. 2A & 28.

transmittal of design criteria' and transmittal of engineering

- There is Itev. 3 & 3A

- latest mod is shown as "Itev. 2A.

suppliers recannended design - Construction drawing list shows changes. Rev. 2A to be the latest version.

Could not verify what was installed in the field fran data in the calc.

package. Insofar as this support, as well as the five others reviewed, showed the same general character-istics in their design files, it v.as decided not to review four nure randanly chosen supports.

PG&E - March 8, 1982 87/89

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EES ATTENDANCE LIST -

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EES ATTENDANCE LIST

. /

/ Question Meeting Audit Name Company 12/28/81 1/13&l4/82 PG&E x

• x

7. Zerebinski a S. Tandowsky CYGNA x 'x n','Suryoutomo CYGNA x x

• N. Chauhan CYGNA x *

p. Didonato CYGNA x x 1 _

i R. Rauson CYGNA x o

f 4

W. Gang CYGNA

• I R. Petrokas RFR,Inc.

g

, x

[ W. Gibbons RFR,Inc. x x I R. Falciani CYGNA

• P. Herbert PER,Inc. x R. Reedy RFR,Inc. x B.-Good RFR,Inc. x Part-time EES - March ~1, 1982 7/43 e

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APPENDIX B

. EES FINDINGS

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'---~ =wcw# r-wassuyuu;gir.,gg4;jl7gg , ,ggg gg]f.;f..',,; ;g.,,; ..

....g g AUDIT FINDING REPORT PAGE1 OF 1

-1 . ,

DATE: 1/14/82

~

N' ,c7 COMPANY / ORGANIZATION AUDIT LOCATION

,- jo 141 Battery Street Cygna M San Francisco, CA cn 5r

~ faEQUIREMENTS AND REFERENCES 10CFR50, Apoendix B Criterion III. Measures shall ha established for the identification and control of design interfaces and for coor-dination among participating design organizations.

OBSERVATION: No interface procedure existed. EES could not verify that cne support requested to be analyzed by K,&E had been analyzed or dropped frcm the required analy-sis.

RECOMMENDED ACTION: Peccrrend larger sample be taken to detcmine if this is a gener-ic problem. Review with PG&E to determine input--outout control.

REPORTED BY: R. F. Petrekas ' ACKNOWLEDGED BY:

THIS SECTION TO BE COMPLETED BY THE RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

SCHEDULED COMPLETION DATE: PROPOSED BY: DATE:

RHG&A CONCURRENCE:

NO YES Name Date ,

FOLLOW-UP AND CLOSEOUT CLOSED BY: DATE:

EES - March 1, 1982 9/43

~

e EES-2 (EES Audit Checklist) 05(d) DATE: 1/14/82 ,

'.Jg "I' .O.

COMPANY / ORGANIZATION AUDIT LOCATION

'OJECT 141 Batterv Street Diablo San "rancisco, CA

[ Canyon Cygna (EES)

QA'1 1.6.1 d. - The Project Engineer will issue i REQUIREMENTS AND REFERENCESi:nole:nenting instructions to project personnel in the fonn of OBSERVATION: Femo distribution and control was inadequate. 7/6/77 meno N. Chauhan war 11/21/77 -

'on same subject as 3/7/77 memo but did not say if it suoerseded 3/7/77 reno.

mmo N. Chauhan on Hanger Design Review refers to latest criteria calcualation set for '

reference but does not identify what previous set was.

Review applicable " controlled" mamos.to determine whether con-RECOMMENDED ACTION:

flicting instructions were issued and evaluate ootential imact on work.

ACKNOWLEDGED BY:

REPORTED BY: W. S. Gibbons Y

- F THIS SECTION TO BE COMPLETED BY THE, RESPONSIBLE ORGANIZATION:

PROPOSED CORRECTIVE ACTION:

PROPOSED BY: DATE:

SCHEDULED COMPLETION DATE:

RHG&A CONCURRENCE: ..

NO YES Date Name ,

FOLLOW-UP AND CLOSEOUT -

CLOSED BY: DATE:

ESS - March 1, 1982 10/43 1kk$2 Jhf>f,QTZ'f.)g. Ry; 4 3 ,

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?; h i 'd' APPENDIX C ,

EES PROGRAM REVIEW .'

l EES - March 1, 1982 11/43 i

l

,-;~ .- -

s R. F. REEDY, INC.

N

y. PROGRAM REVIEW CHECKLIST 1

Inc. (EES)

Earthquake Engineering Systems, _

ORGANIZATION:

ADDRESS: _

88 First Street San Francisco, CA Nuclear OA Manual QA PROGRAM

REFERENCE:

Rev. 2, 1/30/76 jh N DATE:/ 12 8/

REVIEW CONDUCTED BY 0 DATE: / 88 REVIEWED BY: MM((M/ h6 DATE:

_DATE:

82 .

/

V v ~

NO. OF PAGES: .

J EES - March 1, 1982 12/4,3 4

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?RO1ECT: Diablo Canyon

Subject:

r organizati,n (Ann _ n ) Page 1 of 2 PROGRAM AND

" PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT NO. REFERENCES

1. The applicant shall be responsible QAM x QA Manual for the establishment and execution of the quality assurance program.

The applicant may delegate to -

others, such as contractors, agents, or consultants, the work of estab-Lishing and executing the quality assurance program, or any part thereof, but shall retain responsi-bility therefor. ,

2. 'The authority and duties of per- 1.4 . x QA Group responsibilities sons and organizations performing are defined; others are not' activities affecting the safety- except by organizational

related functions of structures, chart.

systems, and components shall be (Added to Rev. 4, 1/78.)

clearly established and delineated in writing. These activities include both the performing func-i tions of attaining quality objec-tives and the quality assurance j

functions. The quality assurance

/ functions are those of (a) assuring

,! that an appropriate quality assur-

, ance program is established and effectively executed and (b). veri-I fying, such as by checking, audit- EES - March 1, 1982

-! ing, and inspection, that activi- .

13/43 I ties af fecting the safety-related I _ functions

,_, have been correctly _ _

gi

• j e . .i l.

EES Page 2 ot.

) ,

f PROGRAM REVIEti Ci!ECKLIST '

l ?ROJECT: Diablo Canyon

Subject:

I Ornanizatir n ( Aco, B) Page 2 of 2 ^

'b .

PROGRAM A!iD

~

l

• REQUIREMENT ,] l,'[, PROCEDllRE YES NO N/A REVIEW COMMENTS t , REFERENCES l -

j' '

Thepersonsandorganiz(d{'onsper 2 Fig. 1.2

3. x >

QA Engineer reports to Proj

formingqualityassuranc,e, functions  !

Engineer for project work.

shall have suf ficient auti hairity and l ,

organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solu- .

tions. Such persons and organiza-tions performing quality assurance functions shall report to a manage- /

ment level such that this required s e authority and organizational free-dom, including sufficient indepen-dence from cost and schedule when opposed to safety considerations, are provided.

4. ...the individual (s) assigned the 1.2 QAG !!anager reports to

, responsibility for assuring ef fec- Fig. 1.2 X Technical Director.

tive execution of any portion of the quality assurance program at any location where activities subject to this Appendix are being per-

{* formed shall have direct access to such levels of management as may be necessary to perform this functjon.

Ig g EES - March 1, 1982 14/43

! 1 e EES.Pcga 3 of;20-

" ~

M5 25d W PROGRAM REVIEW CllECKLIST - ', g A

l

>ROJECr: Diablo Canyon

Subject:

II Program ( App. B) -

Page 1 ot ,, , e l ._ PROGRAM AND

^

3 2" '

FROCEDLTRE YES NO N/A REVIEW COMMENTS REQUIREMENT l No. REFERENCES ]

l .

! 1. The applicant shaLL establish at OAM x Revision 2, 1/30/76; -

the earliest practicable time, con- 1.4 l previous revisions 2/75 & 5/75 sistent with the schedule for accom- l j QA Group is to formulate plishing the activities, a quality other procedures. -

assurance program which complies with the requirements of this Appendix.

l This program shall be documented by written policies, procedures, or instructions, and shall be carried out throughout plant life in accor- ,

dance with those policies, proce-dures, or instructions.

l

\

l l

l -

2. The applicant shaLL identify the x Not addressed, structures, systems, and components l to be covered by the quality assur-arice program and the major organiza-tions participating'in the program, together with the designated func-tions of these organizations.

l

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EES - ?! arch 1, 1982 15/43 I

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, EES Pc.ge 4 of 20 .

PROGRAM REVIEW Cl!ECKLIST

._. 'ROJECT: Diablo Canyon

Subject:

II Program (App. 8) . Page p at , [

PROGRAM AND EH REQUIREMENT PROCEDURE YES NO N/A REVIEW C0!C4ENTS l

- 30*

• REFERENCES

3. The quality assurance program .

2.1 x Importance to safety ii shall provide control over activi- '

ties af fecting the quality of the l not considered.

• identified structures, systems, and components, to an extent consistent with their importance t,o safety.

4. Activities affecting quality x shall be accomplished under suitably ,

controlled conditions. Conditions include the use of appropriate equip-ment; suitable environmental condi- .

tions for accomplishing the activ-ity, such as adequate cleanness; and assurance that all prerequisites for the given activity have been satis-

• fied. -

5. The program'chall take into 2.4 x Training is not adequately account the need for special con- addressed, trols, processes, test equipment, -

tools, and skills to attain the:re-quired quality, and the need for EES - March 1, 1982 f verification of quality by inspec- '

16/43 tion and test.

i

.; ,, wo ,' ,-

r j- EES Page 5 of 20 I

PROGRAM REVIEW CHECKI.iST i 4T -

h.d' '

i

+.

I 1ROJECT: Diablo Canyon

Subject:

II Program (App. 8) . Page 3 of {

fj [ TEM PROGRAM AND -

g REQUIREMENT PROCEDLIRE YES NO N/A' REVIEW COMMENTS J:

NO. ..' REFERENCES

.r .. .

g i.. ,

1 1

6. The program shall prov,1,de.,for. 2.4 x Indoctrination is reciuired;

[ indoctrination and traiirying of perp i training is not. Subject c g sonnet performing activities af fect , sessions is not adequately Jdescribed.

b ting quality as necessary to assure g that suitable proficiency is (EES unwilling to amplify

{ achieved and maintained. in Rev. 4, 1/78.)

y , w l ,

I

,, l'

I! 7. The applicant shall regularly 2.2 x QAG Manager meets quarterly h . review the status and adequacy of with other Group Managers.

, i the quality assurance program. Man- There is no requirement for L1 agement of other organizations par- management review at or abc j '

ticipating in the quality assurance the level of the Technical y program shall regularly review the Director.

[ status and adequacy of that part of j

the quality assurance program which -

j -

they are executing.

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EES - March 1, 198 I'l 17/43 I, f.

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EES Page 6 of 20 j

• PROGRAM REVIEW CllECKLIST

?ROJECT: Diablo Canyon

Subject:

III Desian Control (Ano. B) Page 1 of L 3 PROGRAM AND ITEH PROCEDURE YES NO N/A REVIEW COMENTS REQUIREMENT NO. REFERENCES t

Requirements and assumpti h

e:T4

1. ,

Measures shall be established to assure that applicable regulatory 3.2  :

l shall be stated in calcul N requirements and the design basis, i Methods shall be identifi I as defined in Para. 50.2 and as No review is required.

specified in the license applica-tion, for those structures, sytems and components to which this d Appendix applies are correctly j translated into specifications, drawings, procedures, and instruc-j l

tions.

ih i

f

• f l.

y , 2. These measures shall include provisions.to assure that appropri-3.2 x Requirements are specific h ate quality standards are specified and included. No quality 1 , review is required.

< i and included in design documents b and that deviations from such stan-

h. dards are controlled.

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s 4. y . g-EES Page 7 of 20 PROGRAM REVIEli CllECKLIST

(

?ROJECT: Diablo Canyon

Subject:

IIT nedgn rnnte,I ( Ap,e _ ni Page 3 of ,f j PROGRAM AND ITEM NO.

REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES Y .

3. Measures shall also be estab- x (e

L lished for the selection and review for suitability of appli-j Not addressed.

j'

, cation of materials, parts, equip- l ment, and processes that are P essential to the safety-related functions of the structures, 3

systems, and components.

?h r  ;

E i

E

. 4. Measures shall be established x Not addressed.

E '

l for the identification and control ,

of design interfaces and for coor-g i

dination among participating design organizations.

s I l fa I

O I c' .

5. These measures shall include x Not addressed.

C j '~

the establishment of procedures

! among participating design organi-

l j zations for the review,' approval, i release, distribution, and revi- .

,' sion of documents involving design j "~

6 h , EES - March 1, l!

j 19/43

.&, n EES Page 8 of 20 e

I

,i.

PROGRAM REVIEW CHECKLIST .. I; J '

?ROJECT: Diablo Canyon

Subject:

III Desian Cont ol (Ao n B) Page z of 7 'c

' ^

I PROGRAM AND PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT ~

j -

NO. REFERENCES e . ,

h . 6. The design control measures 3.4 'x l , Group leader and checker I shall provide for verifying or review calculations.

I checking the adequacy of design, Checker is independent ~, veri such as by the performance of design design bases, and checks

.- reviews, by the use of alternative mathematics or performs j' or simplified calculational methods, alternate calculations.

or by the performance of.a suitable He checks calculations testing program. The verifying or against design drawings checking process shall be performed and design criteria.

by individuals or groups other than /

those who performed the original l

design, but who may be from the

.  : same organization. Where a test l program is used to verify the ade-l quacy of a specific design feature -

l in lieu of other verifying or .

t checking processes, it shall in-clude suitable qualifications test-l , 3.7 Computer programs are not

! ing of a prototype unit under the most adverse design conditions. required to be certified or j  !

verified.

Design control measures shall be 1 i applied to items such as the fol- (Added to Rev. 4, 1/78.)

Lowing: reactor physics, stress, lh i thermal, hydraulic, and accident

] . analyses; compatibility of mater-l' ials; accessibility for inservice inspection, maintenance, and I repair; and delineation of accept-

[ ance criteria for inspections and l tests.

] ,

l, I EES - March 1, 1982 l 4 20/43

[l I

.y[ r, ; *. , ,, .g.g) q. *;

• r EES Page 9 of 20  ;. '

)

PROGRAM REVIEW CllECKLIST *

?ROJECT: Diablo Canyon .

Subject:

III Design Control ( Ann. 8) Page 4 of 4 T

PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A a 'N0* REVIEW COMMENTS REFERENCES -

i

'l 7. Design changes, including field 3.5 i i Revisions are checked,the

@ i changes,shallbesubjecttodesirjln l same as originals are.

fi$j '

control measures commen urate with' p those applied to the original 31 design and be approved by the or-ganization that performed the ori-ginal design unless the applicant Jesignates another responsible ,

d organization. " '

aiv 4

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21/43 I

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' EES Page 10 of 20 e

n PROGRAM REVIEW Cl!ECKl.IST 4

. Diablo Canyon

>ROJECT:

Subject:

IV Procurement Document Control (App. B) Page 1 of 1 PROGRAM AND NO.

REQUIREMENT PROCEDURE YES 30 N/A REVIEW COMMENTS REFERENCES i

~

1. Me'sures a shall be established to i x No procurement or -

assure that applicable regulatory subcontracting is requirements, design bases, and othe r addressed, requirements which are necessary to assure adequate quality are suit-ably included or referenced in docu-ments for procurement of material,

• ,,fpigi.pment, and services, whether /

l purchased by the applicant or by i its contractor or subcontractor.

2. To the extent necessary procurement X documents shall require contractors or subcontractors to provide a qual-ity assurance program consistent with the pertinent provisions of this Appendix.

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EES - March 1, 1992 g i. 22/43, l

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W Mb M> Y%~%

,t EES Page 11 of 20

' PROGRAM REVIEW Cl!ECKLIST -

Sub ject : V Instructions, Procedures, and Drawings (App. B) Page 1 of 1

?ROJECT: Diablo Canyon

- PROGRMI AND l

' N PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT e NO. REFERENCES 3.8 x x Drawings are used;

. Activities af fecting quality shalt

1. the Procedures described be prescribed by documented instruc - in 1.4 are'not described tions, procedures, or drawings of here; no project instructions a type appropriate to the circum- are required.

stances and shaLL be accomplished in accordance with these instruc- (Instructi~nso added in -

Rev. 4, 1/ 78.)

tions, procedures, or drawings.

?

~

2. Instructions, procedures, or draw- x Not addressed.

in'gs shall include appropriate or i;, qualitative acceptance criteria for

' determining that important activi-ties have been satisfactority .

a ocomplished.

i i &

1 EES - March 1, 1982

! 23/43

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EES Page 12 of 20

~ ?. ;$

PROGRAM REVIEW CilECKLIST Page 1 of 1 j VI Document Control ( App. B)

Subject:

• Diablo Canyon PROGRAM AND REVIEW COMMENTS I.

YES NO N/A g

k .ROJECT TEtt  :

REQUIREMENT PROCEDURE REFERENCES

' O.

N l I x QA Manual is controlled;. report correspondence, drawings, and h

2.5 ,x k 1. Heasures shall be established to control the issuance of documents, j calculations are controlled.

such as instructions, procedures, Procedure controls are not

1. described.

and drawings, including changes (Instructions added in Rev.4,l/

thereto, which prescribe att activi-f ties, affecting quality.

(t .

$)

k l.

2.5 x QA Manual is distributed Drawings are to i 'cach project.

j 2. These measures shalt assure that reviewed by checker and by documents, including changes, are 3.8 4rj reviewed for adequacy and approved Project Engineer.

• j . ' '

for release by authorized personnel i Procedure and instruction conta is not addressed, P i and are distributed to and used at jl the location where the prescribed y

activity is performed.

t ,

I s  : 3.5 x Revisions are handled like the

Changes to documents shaLL be original.

} 3. reviewed and approved by the same 3.8 organizations that performed the '4 arch 1, 19:

{ original review and approvat unless EES l ,

the applicant designates another .

24/43 responsible organization.

) 's E h .

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, EES Page 1

? "

PROGRAM REVIEW CHECKLIST

VII Control of Purchased Material, l 'ROJECT: Diablo Canyon ,

Subject:

Equipment, and Services (App. B) '

Page 1 4

of 2 -

~ PROGRAM AND

,4 REQUIREMENT. ','",,,i PROCEDURE YES NO N/A

• REVIEW COMMENTS f9 REFERENCES l l .i 1

, 1. Measures shall be established to i I X

, assure that purchased material,  ! I i

equipment, and services, whether I

I, 0 . purchased directly'or through con-8 tractors and subcontractors, con-form to the procurement documents.

'r YC ,

~

l l 2. These measures shall include pro- X f[tf visions,,as appropriate, for source by evaluation and selection, objective -

i (dj evidence of quality furnished by

. A* the contractor or subcontractor, I

j inspection at the contractor or g subcontractor source and examina-y '

tion of products upon delivery.

f5 ,

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m 4 pg . -

) #

EES - March 1, 19E 7

25/43

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PROGRAM REVIEW CllECKLIST s

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VII Control of Purchased Material, Page 2 of 2

Subject:

Equipment, and Services ( App. 8)  %

.103ECT: Diablo Canyon PROGRAM AND REVIEW COMMENTS YES NO N/A PROCEDURE TEM REQUIREKENT l REFERENCES

.10.

i x Documentary evidence that mat'erial

3. and equipment conform to the pro-curement requirements shall be available at the nuclear power-plant... prior to installation or use of such material and equipment.

This documentary evidence shall be .

retained at the nuclear power- '

plant...and shall be sufficient to identify the specific requirements, such as codes, standards, or speci-fications, met by the purchased material and equipment.

x

4. The effectiveness of the controt of quality by contractors shalL be assessed by the applicant or desig-nee at intervals consistent with the importance, complexity, and quantity of the p.oduct or services .

EES - March 1, 19

. 26/43 It .

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$ES Page 15 of 20 y PROGRAM REVIEW CllECKLIST ,

I 'ROJECT: Diablo Canyon

Subject:

XVI Corrective Action (App. 0) Page 1 of 2 -

s PROGRAM AND  %

REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO. REFERENCES i

1. M.easures shaLL be established to 6.4 x Not adequately addressed, assure that conditions adverse to The Manual says N/A.

~

quality, such as failures, malfunc-tions, deficiencies, deviations, Table 2.1 defec'tive material and equipment, and nonconformances are promptly identified and corrected.

o' .

2. In the case of significant condi- 6.4 Not adequately addressed.

tions adverse to quality, the mea- .

sures shall assure that the cause of the condition is determined, and corrective action taken to preclude repetition.

EES - March 1, 1982 j)

, 27/43 I

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EES Page 16 ot .Y'

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pj s PROGRAM REVIEW CllECKLIST, i

$ Page 2 of 2

- R

Subject:

XVI Corrective Action ( App. B) ^

?ROJECT: Diablo Canyon PROGRAM AND NO N/A REVIEW COMMENTS

r. PROCEDURE YES l' REQUIREMENT REFERENCES

}f '

x Not addressed.

I 3. The identification of the signifi .

f cant conditions adverse to quality,'

f the cause of the condition, and the l d

j corrective action taken shall be .

docu:nented and reported to appropri-ate levels of management.

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= ?t PROGRAM REVIEW CllECKLIST - ".

$d 3ROJECT: Diablo Canyon

Subject:

XVII Quality Ass'irance Records (Aco. 3) Page 1 of 2 "O PROGRAM AND N ITEM

, REQUIREMENT PROCEDLTRE YES NO N/A REVIEW COMMENTS REFERENCES'/ _

1. Sufficient records shall be main- $,0 lSee below.

tained to furnish evidence of activi-- {x ,

ties affecting quality.

l

2. The records shall include at least 5.0 x '

The QA Procedures described the following: Operating togs and the results of reviews, inspections, in 1.4 are not included in record retention.

tests, audits, monitoring of work performance, and materials analyses.

The records shall also include -

closely-related data such as quali-fications of personnel, procedures, and equipment.

3, Inspection and test rc ords shall, x as a minimum, identify the inspec-tor or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficienci,es noted. EES - March 1, 1982

.', . 29/43 I'

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EES Page 18 of 2u s

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,,', PROGRAM REVIEW CilECKLIST Page 2 of 2 4

Subject:

XVII Quality Assurance Records (App. B) 2ROJECT: Diablo Canyon PROGRAM AND

NO N/A REVIEW COMMENTS PROCEDURE YES ITEM REQUIREMENT ,

i NO. I REFERENCES

4. Records shaLL be identifiable and Project engineers are respont retrievable. Consistent with appli- 5.2 x cable regulatory requirements, the 5.3 for project records; records are sent to client.

applicant shall establish require- Table 5.1 OA Manuals, training records ments concerning record retention, and audit reports are only S-such as duration, location, and records; no responsibility f' assigned responsibility. -

retention is assigned. Afte sending copies to client, retention responsibilities a.

location of EES records are ignored.

(Fire-proof storage added in Rev.4, 1/78.)

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., 4 PROGRAM REVIEW CllECKLIST Page 1 of 2

'ROJECT: Diablo Canyon

Subject:

XVIII Audits (A3p. B) i PROGRAM AND '

NO N/A REVIEW COMMENTS ITEM PROCEDURE YES i '

REQUIREMENT I j NO. REFERENCES  !

I A comprehensive system of planned 6.2.2 j x Audits are scheduled.at 3-

!Y 1. month intervals. The fregt and periodic audits shall be carried

(@d out to verify compliance with all for each group or departmer 32 is not clear. QA Group ma

( aspects of the quality assurance not be audited.

M program and to determine the effec-tiveness of the program.

j i.' '

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Nd The audits shall be performed in 6.3 2.

.accordance with the written proce- Exhibit 6.2 x The standard audit checkli

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dures or. check lists by appropri-is inadequate. Method of

[  ;

ately trained personnel not having ensuring auditor independe (it direct responsibility in the areas is not stated. Auditor tr IS is not addressed.

being audited.

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w tv w Audit reports are sent to

3. Audit results shall be documented 6.4 x

{j and reviewed by management having Project Engineer, not_to p responsibility in the area audited.

Management.

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PROGRAM REVIEW CllECKI:IST l .3

Subject:

XVIII Audits ( App. B) Page 2 of 2 2ROJECT: Diablo Canyon l -I PROGRAM AND h

" PROCEDURE YES NO N/A REVIEW COFQfENTS d REQUIREMENT NO. REFERENCES ,

4 j

Follow-up action, including reaudit X Not addressed.

4.

j of deficient areas, shaLL be taken 5 i where indicated.

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' . h APPENDIX D

!$ iW' EES AUDIT CHECKLIST

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'y R. F. REEDY, INC'.

AUDIT CHECKLIST ORGANIZATION: CYGNA/EES ADDRESS: 88 First Street San Francisco, CA QA PROGRAM

REFERENCE:

EES Nuclear OA MANUAL Rev. 2, 1/30/76 AUDIT CONDUCTED BY:My - -

a -- # # DATE: ,/ ,

((

. ) DATE: [ /d

. ~

8L

, _ DATE:

REVIEWED BY:

O_ ,f DATE: 38, kb - -.

M DATE: [ 78 -

DATE: -

NO. OF PAGES: 5 EES - March 1, 1982 34/43

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@T AUDIT CHECKLIST '

V.~ p f Company Cygna (EES) 1 Page 1 of 9 ,y Applicable QAM Rev. 2, 1/30/7,$ h Auditor (1) (2) NSG & RFp Date January 13 and 14, App. B. QAM Ref.

Statemebt ' Audit Instruction Comment f Crit.

(1) General: Note PG&E ccmnents Determine applicability of Rev, GAM Rev. 4 (12/28/77) was appli

[$k I (11/15/77), D.V. Kelly to S. Tan-dowsky regarding program elements 3 and Rev. 4 of QAM to Diablo cable and audit checklist was Canyon work. If applicable, revised. Rev 3 (9/13/77) was

! , implemented by EES, but not items 2, 4, 6, 7, and 9 of 1/10/7Falso applicable, but Rev. 3 addressed in QAM. EES response letter must be considered in ccm- changes had no effect.pn this f). (1/10/78) S. Tandowsky to D. V. pleted this checklist. checklist. Rev. 5 (4/13/78)

O Kelly added paragraphs in OAM as. also was effective, but was on h Rev. 4 (12/28/77), edge of time perfihd (pre-June t .

1978) for this review.

@y (2)

~

General - Contractual (a) Identify projects / contracts Contract 5-16-77 dated 3/19/77

[ .

and dates applicable to Diablo Canyon work.

only contract during this time period. Scope was to perform 9 (b) Review contracts to verify seismic re-analysis of selected y scope of work. piping systems and design revie J.i of thepipe supports for PG&E's

{F Units 1 and 2, Diablo Canyon Si in accordance with contractor's f (EES) proposal dated 2/18/77.

f

• EES' proposal states that anall b will use response spectra for z

f. earthquake occurrence postulatc

[ on the Hosgri fault. Change orc t Number 1, date-18/15/77, added f analysis of Class 1 piping and

'l re-evaluation of supports for r

all Class 1.

] I t j , EES - March 1, 198' 35/43 i

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, L AUDIT CHECKLIST u y

J Page 2 of i

9 ' " . kl Date January 13 and 14, lg Company Cygna (EES) h Auditor (3) (4) (5) WSG

!M Applicable QAM Rev. 2, 1/30/76 Comment

' Audit Instruction App. B. QAM Statement .

~t Crit. Ref.

(a) Earliest organization char l

7 (a) Verify applicable project as dated 10/1/77. Chart Rev.

1.3 Figure 1.2 is a Typical Project o rganization (and personnel) used w was dated 9/28/78. Issuance c.

(3) Organizational Chart. for Diablo Canyon contracts. charts was minimal because of

%$)3 S4 (b) Verify assignment of Project small size of project team, QA Engineers fran OA Group.

i approximately 15 people.

(c) Verify independence of Pro- (b)&(c) OA Manager (S.Tandowsk yi ject QA Engineer. was CA initially. Subsegaent I ',"

$* used 2 others fran his staff auditors.

-Indoctrination and training l Review documentation of indoctrin-records, form 2.1, were revic W and conduct indoctrina- ation and training for personnel Was satisfactory for basic 01 M($

U I/II (4) 1.4 (c) Fornulate 2.4 tion and training programs for the PGAE's and project personnel. An identified in (3) , above. one to one and one/ half hour:

r. i initial indoctrination and training Engineering training was on--

job training and was not doc M3] session will be carried out on ted.

ft each project... attendance...will be l documented cn... form exhibit 2.1. No OA procedures other than j .

During Dec. 2, 1981 Questionnaire are in OA Manual were used.

1.4(d) Fornulate procedures for implemen- meeting, Cygna stated that addi.-

1 (5) trolled" mmoranda were isst f h tation of the Quality Assurance Program on projects, tional instructions and nmoranda will be empiled by the time of evident Distribution and control

%p[d based on our review the RFR audit. 3/7/77 meno M. Chauhan to P.

g'; (a) Verify existence of instruc-rr Eile (Job E703) was not add

1. ; tions, memoranda, and QA procedu to all key project personne

• pP i (b) Review for effect on program 0A. Memo on 7/6/77 was on and this checklist. subject as 3/7/77 mmo but 3 (c) Review for distribution to

, address whether or not it s project personnel, the 3/7/77 memo. Other dmm f,j ]

(d) Ref. OTM Rev.

4 Par. l.6(d)-

check for PE issuing implanenting reviewed and were not a eqt E controlled (See AFR No. EES instructions. EES - March 1, p3

-e 36/43

l '

k AUDIT CHECKLIST Company Cygna -(EES) .

Page 3of9 l

Applicable QAM Rev. 2, 1/30/76 Audi'to r (f>) (7) WSG Date January 13 and 14, 1%2 App. B. QAM Crit. Ref. Statement Audit Instruction Comment

,, .,~s (6) 2.2 The Manager of ON3 is responsible (a) Verify that meetings have Meetings were held:

to initiate review meetings,., been held. 1/26/77 - Minutes quarterly...- (b) Review meeting attendance,

2/18/77 - Minutes j

especially for management in- 12/ ?/77 - Cited in forward to volvement. ON4 Rev. 4. No minutes were (c) Review for evidence of available.

audit result input to meetings. 1/16/78 - Minutes (Rev. 4, 12/28/77 deleted this.) 4/18/78 - Minutes

' 9/21/78 - Minutes. Meetings were held, frequency was not quarterly,

.i -

and no evidence of audit input to

. ... . . . . these meetings.

(7) 2,5 ,,,ane copy (QA Itinual) is issued Verify distribution control of \

to each project, QAM to project (Exhibit 2.3), Reviewed distribution for QAM's Rev.'s 1 through 5. Distribution of Rev. 2 (1/30/75) and 5 (4/18/7E .

to N. Chauhan (Proj. Eng. to Proj. Mgr.) could not be verified

. by records.

1

, A EES - March 1, 1982 37/43

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AUDIT CHECKLIST I

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f Cempany Cygna (EES) . Page 4 of 9 ',, ,

w r..:

t Applicable QAM Rev. 2, 1/30/76 Auditor (8) RFp Date January 13 and 14,19n App. B. QAM S t ' Audit Instruction Comment Crit. Ref.

III (8) 3.0 Generally, each calculation shall . (a) Select two calculations and (a)Five calculations were chosen 4 1 3.2(d)f list the basic criteria design  ! review for inclusion of criteria, at randan fran several of the man:!

- assumptions, and applicable codes, assumptions, codes, standards, lists of scope pipe supports standards, and references, etc. provided by PG&E to EES. The folloaing items were chosen:

Support PG&E EES Calc.

Number Transmit. Log Number l 52-35R 7/12/77 R-42

/ 56N-78R 7/2/77 R-4

98-31R 7/13/77 R-190 48-17R 7/13/77 Not found 98-134R 9/7/77 R-137 EES showed a master log giving th-status of supports analyzed at th time period under investigation.

Support 56N-78R was listed on the 3

Taster log as 56/78R. Support 48-17R was not found cn the maste list. Subsequent investigation showed that there was no calcula-tion file on record of dispositio for this support. Other 48 serie supports on the same PG&E trans-mittal may also' be missing fran the master list used by EES. (See AFR No. EES-1) Calculation files for other supports had references for applicable design criteria in EES files. Basic criteria were provided by an uncontrolled and unnumbered TG&E document.

I

- EES - March 1, 1982 l 38/43 i

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Q ' ' ' ? *x i 1 -

$; AUDIT CHECKLIST ~4 ,[,

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[ Company Cygna (EES) . Page 5 of 9 g N ' ti g Applicable QAM Rev. 2, 1/30/76 Auditor (g} ppp Date January 13 and 14, ig '0

App. B. QAM

! Crit. Ref.

Statement ' Audit Instruction Comment III ,

j (8)  ; l j; cont. (b) Are these inputs traceable to (b) Inputs were traceable ~to j PGSE requirements provided to design guidelines PG&E meeting f

I

EES? minutes, correspondence, etc.

As discussed in itcm 8(a), no l . evidence of analysis could be found for one support which PG&E

[ , bad requested to be analyzed. A j e PG&E letter dated 8/16/76, which aas a referenced criteria docune l Could not be found, i

I (c) Are quality requirc*nents (c) No reference to quality specified? cequirements could be found in tl calculation packages, (d) Is there evidence of review (d) No evidence, l af these criteria?

. (c) Verify that a system existed (e) No interface control within

o govern the control of design IS could be found, (See AFR No.

interfaces. Check documentation IS-1) One interface chart pro--

for evidence of coordination and sided by PG&E was found in the le review, approval, release, Pile, This was a matrix which and distribution by organizations indicated distribution of trans-or departments involved nittals,

,, EES - March 1, 1982 39/43

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AUDIT CHECKLIST ..

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Auditor (8) RFP Date January 13 and 14, 1982 Applicable QAM Rev. 2, 1/30/76 Comment APP B- OAM Statement Audit Instruction Crit. Ref.

) -

III l l

(8) (f) Found no specific checks 3.3.2 (f) Review calculations for evi- against design bases. Drawings cont. dence of checking, including 3.4 verification of design bases and in the form of hanger sketches checking against drawings. are included in the calc. package:

This item appeared satisfactory.

1 N ' (g) Review qualifications and (g) Could not find documented l 3.4 (a) independenc6 of checkers. verification of checker qualifica tions. Checkers were independent

^

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to the extent that they did not sign off work as " preparers".

1 r

Ccmpliance with this item is decmed satisfactory.

i 0

(h) Review drawings referenced - (h) Drawings are ' included as part 3.4(b) in calculations to verify correct of each calc. package and are 3.8 revisions. (See ll(b) , below.) correctly referenced as bases for ig calculations.

(i) Review drawings for evidence rhere is no evidence that EES fg af checking. produced drawings. There wre sketches made.as part of calcula-J ~

tions and thece were chgeked.

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CcnoanY Cygna (EES)

Auditor (9) (10) RFp Date January 13 and 14, ign

' s.

' Applicable QAM Rev. 2, 1/30/76 -

Q. Comment B. 0 Statement Audit Instruction I W,

• III N' cont. (a) Review calculations for evi- (a) Revised calculations Eere 3.5 The same checking procedure shall found in the files, -

9 (9) be used for revised calculations as dence of revisions, (b) Revisions were controlled in 3

for original calculaticns, (b) Verify control of revisions, the sa;te manner as originals, f (c) Verity that revisions are l

N reviewed and approved in the sarra There was no formal procedure fo manner as the original calcula- control of revisions, N (c) Revisions were reviewed and tions, approved in the same manner as l

l Q

f; '

original calculations.

I , f.,

ij (a) Select two cmputer progra:rs (a) Programs SPECTRA and SAPIV vx

[

(10) 3,7 Cmputer Outputs (Include Para. 3,8 for Diablo Canyon work; selected as they were referencec p;.! of QTM Rev, 4, 12/28/77 for (c)), in sane calculatica packages.

l FO (b) Review for evidence of group

y. leader checking, (b) Could not verify that a grot l

j;$ f (c) Is evidence available of leader checked programs, I

', i, programverification/qualifica- (c) A verification file was pro duced for program SPECTRA, Pro

{

i tion? versions are identified by date

/

, / The earliest verificaticn in th tt was dated 2/16/77,

<< / .

No file as 'such existed for SAT

'N A canputer run, dating fran 195 j.

, was produced. This run was all N ' ly a carparison of the EES vert

. c,f the program with the originz program sa:rple prcblen run by [

'gh',6:SpM., -

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Berkeley. There was no documer lf to describe and backup what war

~~

)

Ah'g. ; .k . In the auditors opinion, chech:

verification would not be poss:

'~jfj !$yhh8g. .

9 '

'iithout the verbal description f.* s ,

1 the process given by Mr. Don G) y,y $)$hrg,g. , , . N Of EES. EES - March 1, 198 f.gg p

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AUDIT CHECKLIST

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Coe.pany Cygna (EES) .

Page 8 'o f 9 . *J Appticable CAM Pev. 2, 1/30/76 ' Auditor (11) (12) WSG Da.te January 13 and 14, 1982 App. B. QAM Ref.

Statement -Audit Instruction Comment Crit.

V s .

(11) 4 Dx m t Control (a) Was! inconing correspondence (a) Correspondence was controlkd, 4.2 logged? but.not strictly. QA had their j ,4.4.2 (b) Was Client Drawing Control o'm correspondence with PG6E List maintained? separate fran the project. The outgoing correspondence log had recently been re-done to add I

subjects to the listing.

(b) Yes, but drawing control was

, at stick file, not by listing.

XVII (12) 5.2 Project engineers are responsible (a) Review evidence of records Records were available. Records for the accunulation, review, and accumulation, review, and dispo- sumary (Par.5.31 has not yet dispositicn of project quality sition. been prepared because the contract assurance records. (b) Is the sumary in 5.3 appli- has not been canpleted.

cable?

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EES - March 1, 1982

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AUDIT CHECKLIST i{ ]- Company Cygna (EES) i '

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Applicable QAM Rev. 2,1/30/76 1 Page 9 of 9 N

)- App. B . QAli Auditor (13) WSG Date January 13 and 14,1982 Crit. Ref, Statement Audit Instruction AVIII Comment ',.

d. (13) 6 n Ifh 6.2.2 Audits will be scheduled at three- ^

'T month intervals or earlier... (a) Select at least tm audits l y)4 aaplicable to Diablo Canyon work Audit records reviewed were:

i (b) Review for canpliance with (a) (10/21/77) h , Section 6 of ON4 (b)(5/15/78)

(c) Review auditor training and observations; with the following r' qualifications,

$,$' (c) No audit schedule was docu-hy (d) Review for evidence of correc-3mented practice did not treet tive action,' separate fran audit month interval .

g1 -

program. "

(d) Audits were not canprehensiv:

h (c) Review evidence of PG&E of Q?s systen - were only of calc.

< T; audits of EES applicable to and canputer binders.

L'.! Diablo Canyon work, particularly (e) Except for OA Manager, audito of EES QA activities. qualifications were questionable.

M(; (f) Review results of these (f) Effective corrective action was not evident, '

} audits for evidence of corrective Y

actions taken, including reaudit of deficient areas.

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EES - March 1, 1982 43/43 i

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.___ _ .. . . _ _ . _ . - = _ _ . . _ _ _ _ . _ . _ . _ _ _

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QUALITY ASSDRANCE REVIEW AND AUDIT FIPORT s

PEASE I -

By: R. F. REEDY, INC.

On: SAFETY-RELATED ACTIVITIES PERFORMED BY PACIFIC GAS'AND ELECTRIC PRIOR TO JUNE, 1978 l

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' 1/29 i

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4 A

4 4

QUALITY ASSURANCE PROGRAM REVIEW REPORT PHASE I SAFETY RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC 3

PRIOR TO JUNE 1, 1978 i

Introduction Scoce:

} . On February 23,'1982 R. F. Reedy,-Inc. cc=pleted the Quality Assurance Review and Audit of Pacific Gas and Electric 3

' (PG&E) safety. related activities concerning the Diablo ,

-Canyon Nuclear Project. .

J The . purpose of- this. review ~ and audit was to assess the

-adequacy. of PG&E Quality Assurance Program prior to June, 1978 with particular emphasis on activities that could.  ;

i affect seismic related design. The baseline for this review and audit were the require =en.ts of 10CFR50, Appendiz 3.

~ '

, PG&E Activities:

8 2 .

PG&E had the responsibilities of Architect-Engineer'and .

Construction Manager for the Diablo Canyon Project. PG&E was supported .in their design activities by contracted design consultants.

Evaluation Criteria:

7 This Quality Assurance Review and Audit of PG&E addressed l the require =ents of 10CFR50, Appendix B with selected parts ~'

of ANSI N45.2.ll being considered for guidance.. Follow-up ,

ite=s were introduced that evolved from earlier-R. F. Reedy, e Inc. audits of PG&E design consultants.

i. ,

Method of Review and Audit:

"; The. review and audit was conducted in three steps: 1. ,  !

Intreductory. meetings; 2. Quality Assurance Manual and-  !

j Procedure review, and, 3.. Audit of program i=ple=entation.

i '

Steps 2 .and 3 were performed to detailed checklists, and a r general questionaire was used-for Step 1. (

The introductory meetings were held at PG&E on Dec. 17 and  ;

18, 1981. The discipline groups visited were Quality f 1 ..  ;

j s, r i .  :

PG&E - March 8, 1932' l

, 2/89 l 1 -

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. 1 3

6 # 5

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f. . .

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Assurance, Design-Drafting, and Engineering Services. Mechanical, Civil, Electrical, The Chief Engineers and other persons fro = these, groups audit approach, PG&E progra= were =et to discuss rev.iew and and project status prior to June, 1978. Attendees at these meetings are listed in Appendix A. ,

~

The Quality Assurance Manual and Procedures co=pleted on Jan. review was

~~ 30, 1982 at R. F. Reedy, Inc. offices.

Revisions of the Manual between 1970 and 1978 were reviewed along with applicable i=plementing procedures.

• The--- .-

co=pleted checklist fro = this review is included as Appendix-B to this report.

.The i=ple=entation audit was perfor=ed Feb. 2-23, 1982 at

• PGEE. This step of three parts: the review and audit was broken into Part A: General Require =ents and Manage =ent Control of Quality As.surance Part 3: Design Control '

Part C: Follow-up Questions fro = Supplier Audits.'

Procedures and docu=entation were exa=ined to ascertain progra= coverage. Where place, procedural coverage was not in positive.thethough design docu=entation was used for determining if infor=al controls were practiced.

. Docu=entation exa=ined was fro = design a.ctivities performed prior to_ June 1, .1978. Later activities are to be separately covered in the Phase _II ,,

review. Co=pleted

• checklists to this report.

frc= parts A, 3, and C are included in. Appendix C ~ '

Conclusions:

1. The PGSE Quality Assurance progra= for design work was not adequate in areas of policy, procedures and jg! ',

i=ple=entation. The Quality Assurance organination had Ag. 5 I".

insufficient progra= responsibilit7 v D ',g .

2. A general' weakness existed 31.

interface and document in internal and external r? . . 'i..

controls. This questions i,#~

whether appropriate design infor=ation was being exchanged and utilized by design groups and consu'tants.4,,cg.

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pG&Z - Mar:h 3, 1932 3/33 w - em

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One ' concern is ' -if the latest Hosi;ri seisd.ic data was inputted for. design. analysis. .

3. The design verification program was not for=alized and was inconsistently implemented and documented. This Cbj r &

included major approach for mechanical gaps in anddesign overviews other equip =ent. of the design], y ' r"f '

. q q beld i @V Findings gi Progra==atic Deficiencies: a d < go. '

1. Quality Assurance as defined in the QA Manual was -

. essentially an audit role. The Quality Assurance group -

. was not assigned a primary role in deter =ining QA .

_ .. ; ; _ : . requirements. .

2. PG&E had no procedure for assuring the completeness of <

the QA progra= to address the requirements of 10CyR50,-  ;

, Appendix B. ,

l 1

3. There were no provisions for docu=ent control of l corresj:onda'nce and design docu=ents. ~ "

/ {

M k

4. During Phase I, there were no controlled procedures for C ; g',, g d j

' design control, design interfaces and design . respond - 1 bilities. PRE-9';and

• PRE-10" on these subjects were r 3 r6" ' i.  ;

released in 1979 and are to be audited during Phase II. r.4 , , n n- .

,  ; .3- ,

n , .o -

5.' PG&E did not require design consultants to imple=ent 7:14" *

. . Quality Assurance require =ents. SM/ #% p ,. c_ . I I -

6. Corrective action provisions were not addressed except

. with respect to audit deficiencies and deficiencies at --- - -

g '. .

~

r, g the site.  :. . - - - - $

[. -

7. Indoctrination and trainingf' ere not addressed -in the [

QA Manual or procedures. .]

w ." 9

8. The QA Manual contained no provisions for PG&E \ i~

canage=ent ~ review of the QA' program for status and ,e adequacy. /

I_=clementation Deficiencies:

5g j

\' f

1. PG&E . management did- not review and assess the effectiveness.of the Quality Ass 1:ance Progra=. f g

s a

+ ?M - 9, %u. Reye-v4.II es{Th Jn:? -t! 74_PG&I

- March 8, 1932 C

N" l

+ + P U N. h.p.,(.b %l,"6.is.79 , c c

. O L

e No documentation was available to verify that PGEE  !

reviewed the QA program to show that all i requirements of 10CFR50, Appendix B were addressed 2 and met. p r og Tr 2-only reviewed plant e Management Review co=mittees y

operational considerations and experiences from the Humbolt Bay Plant. They did not review the QA

. progras- for design and construction of the Diablo -

. Canyon Plant.

i e A program review by Energy, Inc. for an ASME N- ~

l I' ..

lists many of the same stamp (December 22, 1975) .

' ~

. findings that were found during~:this. Phase I.

Review. _

2. The PG&E audit system and corrective action system were not effective'. -

e Audit reporting and . follow-up was not timely. '

Reports were issued so=etimes three or four conths -

after the audit.

r e

~

Corrective actions for audit findings were ,

ineffective in that the sa=e findings were found 3 l

i -

during later audits. *

! verification was by re-audit i

, . e Corrective action

! only. ,

~l .

6

- __. ~

o yor=al corEective ' actions were not invoked on the '~

?

engineering groues.' i Design consultants were not . required to i=ple=ent i

! 3. **

j Quality Assurance Progrs=s. [

t i

e Blume had first- contract to req'uire' Quality. .,

l Assurance in late 1977.

{

L - -- - c, , ,a i e Responsible engineers did not document Quality *

[

! Assurance requirements for purchase specifications on consultants, as required' by the Quality ,

[

i Assurance Manual'.

i i e The . Quality Assurance group- did not review the i j Quality Assurance Programs of design'subcontracters  ;

i prior to mid-1977. +

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1 PG&E .Marnh 3, ~-32 -

- 5/99 i i, 1

l

. _ _ . . ___ __ __. . _ ~ .

. f.

t r 6 . .

t e WYLE was not contractually required to have a  ;

Quality Assurance Program until Dec. 1, 1979. l l e ANCO was not contractually re' quired to have a

. Quality Assurance, Program until May 1978.  ;

)

4. PG&E design verification on in-house activities and '

i suppliers was unstructured and applied inconsistently. f We consider. that . design'verificatica consists of the ~ - ~ ~

.t following three elements:

• __l I

1)- 'es ((.. . ,, - tloyertiew for design approach,. methods, D

~^* 'de~s(gn input selection , and assumptions. <- u - --.

i j

, ' r

,........--? .r steps and

2) ' Detailed _._ checking

- of design 7 4 ,

completed design docu=ents. *

[

i

~

Verificatio'n 6f approved "As Built .

3) condition ~#

~~

against approved design. T' --- -- - " '  ;

i j -

Activities for ele =ent 3,were not initiated until 1979 i 1 and are to be reviewed during Phase II. Documentation i showed detailed checks .to be perfor=ed ,on PG&E work a

[

i with design.. overviews being perfor=ed on a selective basis. Most of what PGEE refers to as Design Reviews

. consists of element 2.

- e Ccmprehensive overviews and detailed checks were i per*ormed by EDS on Class I electrical ~ design, some EVAC, and structural items. Design overviews  !

l-

' - were not evident for mechanical designs. f e PG&E did not require design contractors to perfors ..

i . design reviews of their own work. j i ^- .

i e- For the majority of cases reviewed,. design verification criteria .were not defined and were 3

j dependent 'on the discretion of the reviewing  ;

engineer. ,l l

' i e Documentation of design verifications was inconsis- -  ;

tent and at times incomplete. l' e

1 was no effective docu=ent control system l

5. There i

established. ,

e ' Design ' interfaces internally and externally were l I

's. N . u

?G&E ..M arch 8, 1982  ;

i 6/89 ,

j

- .. . _ . . .. _,- _ -,.._ - ,. .. ,__,.4 _ _ . . , _ _ _ _ . . ._.,_,,,,.,_.....,___,...,,.__.r,.....__,.._, . _ - , . . . _ . . , _

not effectively controlled. Various organinations soceti=es had different revisions of. the sa=e documents.

o Identification and control of support drawings was inadequate. There were cases where different versions of the same drawing revision were in use. _

the Hosgri design e Engineering groups censidered as'a controlled docu=ent, criteria in the FSAR .

~ -

which it was not. . -.. .

• e There was no effective method for controlling-the Hosgri seis=ic data which was distributed within PG&E and to design consultants.

Historical copies of some procedures and =anuals e

revisions were not available. .

o The construction drawing list (January 1982) was the support drawings n o t- accurate for sc=e of '

which were checked.

1 Approval signatures were not entered on support o

were in the calculation

- drawings, but approvals package. -

e There was no evidence that all revisions of supplier test plans, procedures and reports were reviewed by PGaE.

.r r

9 s,

\

PG&E March 8, 133;

! 7/89 l .. .

j .

t

-m.

. ~

ROGER F. REEDY, P.E.

Mr. Reedy has worked power industries since in the pressure vessel and nuclear 1956. His experience quality assurance, design, analysis, includes erection of nuclear power plant components. fabrication, and -

encompasses boiling water, His background pressurized water nuclear power and HTGR petroleum, chemical, plants, as well as pressure and other energy . industries.

vesse,ls for the -

Reedy is an acknopledged expert Mr.

in the design and construction'of nuclear components meeting the requirements of the ASME Boiler and Pressure Vessel Code, which includes

' detailed quality assurance requirements for all components.

He has been. involved in quality assurance programs *and audits, licensin'g, engineering review, project coordination and' training of personnel.

witness before regulatory groups,He has testified as an expert on topics including USNRC and ACRS quality such as_ design criteria, analvsis, fabrication, assurance and fracture toughness.

~

~

Mr. Reedy has years as a been an active ' participant for the past 15 member and as chairman of major nuclear Codes -

and Standards nuclear power plant Co=mittees in the development of criteria for components. In this activity he was a 1

member of the first Material Manufacturers Task Group on Quality Assurance for his Chairmanship, and Suppliers (NCA-3800) and under instigated

_"Ouality Assurance the incorcoration of NOA-1.

Plants " into the ASME Program Recuirements for Nuclear power _

Nuclear Code. He .has served utilities, architect / engineers, consultant and manufacturers, as a on all aspects of construction. nuclear power plant ..

5As an original member insisted of the N626.3 Comm.itee, Mr. Reedy.,-

that registered professional engineers understand .- -. --

the-reqQirements for quality assurance, materials selection s  ;

welding parameters, and selection of examinations for all structures non-destructive document was recently they design. The N626.3 Code (Section incorporated into the ASME Nuclear '

III) and engineers designing comply with its provisions. nuclear components must now These irequirements are unique to the nuclear power industry. L During the past ten years, Mr. Reedy has conducted training Code requirements. courses for engineers in Quality Assurance and ASME Nuclear

[

NRC regional inspectors.He has also conducted many setninars for

~

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1.

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.. . . . - . . . - - ~ . -

s Profession 11 Sackground A=erican Society of Mechanical Engineers o

Boiler and Pressure Vessal Committee e Chairman, Subcotnittee III) on Nuclear Power (Section o Executive Committae, member '

o Main Committee, member In 1980, Medal he was awarded the 1980 ASME Centennial by the Policy Board for Codes and Standards in recognition of his long contribution .0 the development of the Boiler and Pressure Code. Vessel o Subgroup on Containment, past chairman ~

o Subgroup on Fabrication and Exacination, former me.7ber o ASME Pressure Vessel and Piping Division g

o Past Chairman o Board on Nuclear Codes and Standards, cember dp ANSI /ASME N626.3 Ad Hoc Task Group for Qualifications and Duties of Personnel Engaged in ASME Boiler and Pressure Vessel Code,Section III, Division 1 and 2, Certifying Activities, member Registration Profession.tl Structural Engineer -- Illinois

~

Profe'.sional Civil Engineer -- California, Illinois, Indiana, Michigan, Wisconsin -

Professional Excerience 1956 to 1976

- Chicago Bridge and Iron Company Oak Brook, IL -

Mr. Reedy was successively a designer, staff engineer, proje:: en3ineer, design :::asar, and senior e:giaetr r+;cr ing c ;' e 'li c e President of E ;in-ering. His du:les O O

. s s., 1 9

'L included

- design of pressure vessels, service as a staff engineer concerned with unique design and analysis problems, as well.as {

consulting on quality assurance and related questions. ,

- He helped to develop and implement the company's ' Quality Assurance Program for design and fabricati of pressure vessels _

for a NASA project in 962 This crocram was the first forca11 zed quality assurance brne-am in the coccany, and provided the Tasis for future nuclear quality assurance programs. -

.' -As Manager of Special Structures Design, he

~

was responsible for design and analysis of

- all nuclear components. In this position he was instrumental in the develop =ent of the company's nuclear quality assurance program for the design and construction of nuclear reactors and containment vessels, and helped company's first quality to select the' ,

assurance manager. As Design Manager he initiated _ the concept of independent design _ 1 verification by an independent engineering group within the company.

As Senior ' Engineer reporting to t'he Vice President of Engineering he was responsible for consulting on all company activities concerning ASME Code design, construction, and quality assurance.

1976 to 1981 Nutech

- San Jose, CA __ ,

~' ~

Managed Special Projects Group -including -

Quality Assurance, Training, and Program Management. Served as Code Consultant to ,

other engineers and clients of Nutech.

During this time Mr. Reedy was_ Director of_

the Quality Assurance Group and consulted

~ith w clients in developing QA Programs to meet the requirements of 10CFR50, Appendix B, ANSI N-45.2 and the ASME Section III Code. .

As Chief Consultant, he served as ex-officio advisor to all in~h use -p. rejects and all cliects oc quality issuranza, design, and fabrication questions, as well as cocsulting G

.,7,..;. _ _ - _.. . . - _ . _ _ . _ _ . _ .- _ _

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. .~ . ..-.

• l .. . . -..- - -- . . . -

4 I Code problems.

i j He worked with the P.epublic of China Atomic Energy Council to set up an independent-Inspection and Quality Verification Program i

in Taiwan and-has given a number of lectures on Quality Assurance in both Korea and i

Taiwan. . .

i j 1981 to R. F. Reedy, Inc. ,

Present Los Gatos, CA -

i

, Founder and President of .an engineering

• - consulting company which advises client company's management on Quality Assurance, i

design, fabrication,, construction and lic-i

- ensing. .

j Education .

1 B. S. in Civ.il Engineering Illinois Institute of Technology' 9

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4 5

QUAI.ITY ASSURANCE REVIEW AND AUDIT REPORT PEASE I By: R. F. REEDY, INC. .

• On: SAFETY-RELATED ACTIVITIES 4

2 .

PERFORMED BY PACIFIC GAS AND ELECTRIC

- PRIOR TO JUNE, 1978 i i i . .

1.

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i PG&E - March 9, 1932 I 1/99 -

l

• L I I

QUALITY ASSURANCE PROGRAM REVIEW REPORT PHASE I SAFETY RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC PRIOR TO JUNE 1, 1978 Introduction Scoce:

. On February 23, 1982 R. F. Reedy, Inc. ccepleted the Quality Assurance Review..and Audit of Pacific Gas and Electric (PGEE) safety related activities concerning the Diablo Canyon Nuclear Project.

The purpose of this review and audit was to assess the

. adequacy of PG&E Quality Assurance Progra: prior to June, 1978 sith particular e=phasis on activities that could affect seis=ic related design. The baseline for this review and audi: were the requirements of 10CFR50, Appendix 3.

PG&E Activities: ,

PG&E had the responsibilities of Architect-Engina - and .

Construction Manager for the Diablo Canyca Project. PGEE was supported in their design activities by contracted design consultants.

Evaluation Criteria:

This Quality Assurance Review and Audit of PGEE addressed the require =ents of 10CFR50, Appendix B with selected parts ~

of ANSI N45.2.ll-being considered for guidance.. Follow-up

' ite=s were introduced that evolved free earlier R. F. Reedy, Inc. audits of PG&E design consultants.

Method of Review and Audit:

The review and audit was conducted in three steps: 1.

In :cdue:ory teetings; 2. Quality Assurance Manual and '

Preced"-= eview, and, 3. Audit of progra: i=ple=ents:1on.

Steps 2 and 3 were perfor:ed to detailed checklists, and a general questionaire was used for Step 1.

The introductory teetings were held at PG&E on Dec. 17 and 18, 1981. The discipline groups visited were quality pG&E - P.sr h 3, 1952 2/89

u .

H a

I

' Assurance, and Engineering . Services.

Design-Drafting, Mechanical, Civil, Electrical, The Chief. Engineers and other persons from these, groups audit . approach, PG&E program were met to' discuss rev.iew and q

June, 1978.

and project status prior to Attendees at these meetings are listed in 1

i Appendix A. -

4 The Quality Assurance Manual and . Procedures .

-completed on Jana 30, 1982 review was i

i Revisions at R. F. Reedy, Inc. offices.

of the Manual between 1970 and 1978 were reviewed along with applicable implementing procedures.

The-- 7 completed checklist from this review is included as Appendix

. B to this report. --

The implementation audit was performed Feb. 2-23, 1982 at .

PG&E. This step of the review and audit was broken into i

three parts:

part A: General. Requirements and Management Control of Quality As.surance ,

part B: Design Control

• a I

Part C: Follow-up. Questions from Supplier Audits.'

procedures and documentation were examined to ascertain ~

program coverage. Where procedural coverage was not in plac e. ,

positive ,though the design docu=entation was used for determining if infor=al controls were practiced.

j i

Docu=entation examined was from design a.ctivities performed prior to June 1, 1978.

i separately covered Later activities are to be i

in the Phase .II review. Co=pleted -'

checklists to this report.

frem Parts A, B, and C are included in Appendix C ,

'Conclusi'ons

r i 1. The PGSE Quality Assurance program for design work was

, not adequate in areas of policy, procedures jg t -

{ -implementation. and -5 -

1. 3 ",

j insufficient program responsibility.The Quality Assurance organization ~5 e l l ',

ha '

a -

! 2. A general weakness existed in internal and external X"

.t..'

j interface and document #,~

controls. This questions v. e

whether appropriate design  ;

exchanged ind utilized by design groups and consultants.

infor=ation was being ,,,,e, u.

, 5:

i '.., .

ff i N. ,a ***^ p.e i

{

i gg . Y" * \

l PG&E - : tar:h 9,19 32 1

4

'3/39 l

l [

l-

-_,__y., .

---

r-- - ' ' ' = " " ' " " " ' " ' ' ' ' , ' . . _ _ _ _ . _ , . _ - ~ - - - - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~

j One concern is if the latest Rosgri seis=ic data was inputted for design analysis.

(}L .7 C  :

3. The design verification progra= was not for= alined and l was inconsistently imple=ented and docu=ented. This C,g,s ,,* , p" included major gaps in design overviews of the design ; 99y3 approach for mechanical and other equip =ent. >

' - cef.L ~'

4 ,el t & CU Findings gge M " f../ ,,".hrg s

Procra==atic Deficiencies: sd" p p ) 'l g

1. Quality Assurance as defined in the QA~ Manual was

. essentially an audit role. The Quality Assurance group was not assigned a primary role in deter =ining QA ,

_. requirements. ~. -

2. PGaE had no procedure for assuring the co=pleteness of- -

the QA progrs= to addresc the requirements of 10CFR50, i Appendix 3..  !

3 There ,were, no provisions for docu=ent _ control of ,

correspondance and design docu=ents. t g 4'-

4. During Phase I, there were no controlled procedures for *(t.d.u.,gj e < e l

design control, design interfaces and design responsi- ___ e bilities. PRE-9 and PRE-10*

• on these subjects were e s r0 " ' r,, {

released in 1979 and are to be audited _during Phase II. e-1 , vc o -

l m...: ,

5. PGSE did not require design consultants to i=ple=ent Odo" * .:

Quality Assurance require =ents. 5 s f t t'/ #%

pet '

6. Corrective action provisions were not addressed except

- with respect to audit deficiencies and deficiehcies a;_ _. ._

the site. c. Jg ,yg (z}: . ....r .

7. Indoctrination and trainingf'were not addressed in the QA Manual or procedures. ,

s

8. The QA Manual contained no provisions for PGaE -

,' l'

=anage=ent review of the QA progra= for status and adequacy.

Imole=entatiou Deficiencies: ( '

l. PGaE managemen't did not review and asses 5 the 'I g

effectiveness of the Quality Assurance Prcgra=. ,

6

+ ? M ~ h * %*. v ,?v,p. . . b. I i e f T.Jn -

' t .* 5 7 4 f PG&E - :4 arch 8, 1932

[

-k + D.u a. D:. y,,t. % % I,' e 85 1, O

y t

e No docu=entation was available to verify that pGSE program to show that all reviewed the QA requirements of 10CFR50, Appendix B were addressed and =et. pro Ft e Management Review cocmittees only reviewed plant operational considerations and experiences from the Humbolt Bay Plant. They did not review the QA

. program for design and construction of the Diablo _

Canyon Plant.

e A program review by Energy, Inc. for an ASME N-stamp (December 22 , - 1975) lists many of the same

. findings that were found during this Phase I

- Review. .

2. The PGkE audit system and corrective' action system were

- not effective. .

w a's not 'ti=ely.

e Audit reporting and follow-up Reports were issued someti=es three or four conths after the audit.

Corrective action's for audit findings were e

ineffective in that the sa=e findings were found ,

during later audits.

e Corrective action verification was by re-audit

- only. .

actions were not invoked on the

_ __ ~~

e' yor=al corEective engineering groups. .

consultants were not required to i=ple=ent

3. Design Quality Assurance Progra=s.

had contract to require Quality Blume e first Assurance in late 1977. .

u _' _

Responsible engineers did not document Quality e

Assurance requirements for purchase specifications ,

consultants, as required by the Quality on -

Assurance Manual.

e The Quality Assurance group did not review the Quality Assurance Programs of design subcon::ac: ors prior to mid-1977.

PG&I - March 3, 1332

'5/99

~

e WYLE was not contractually required to have a Quality Assurance Progra= until Cec. 1, 1979, was not contractually required to have a e ANCO Quality Assurance Progra= until May 1978.

4. PG&E design verification on in-house activities and suppliers was unstructured and applied inconsistently.

We consider that design verificatica consists of the following three elements:

- 1) Desfgyio$krv3ev'fordesignapproach,=ethods, d(sign input selection, and assumptions.-- --

... ,e- -

.'r Detailed ___ checking of design steps and 2) completed design docu=ents.

3) 'Ie'rific'atioh of approved "As Built"

^

cctdition #

against approved design. f' Activities for ele =ent 3 were not initis.ted until 1979 and are to be reviewed during Phase II. Docu=entation showed detailed checks to be perfor:ed on PGLE work with design.. overviews being perfor=ed on a selective 8

- basis. Most of what PGSE refers to as Design P.eviews consists of ele =ent 2.

e Cceprehensive overviews and detailed checks were perfor ed by EDS on Class I electrical design, some EVAC, and structural itecs. Design overviews were not evident for mechanical designs.

e PGLE did not require design contractors to perform ~

design reviews of their own work.

e- For the majority of cruses reviewed, design

-- verification criteria were not defined and were dependent on the discretion of the reviewing ,

engineer. .

e Docu=entation of design verifications was inccasis- ,

tent and at ti=es incomplete.

was no effective docu=ent control system

5. There established. .

e Design interfaces internally and externilly were s,

pG&E . March 8, 1982 6/39

, ~ s.

I 4

4 . .

I not effectively controlled. Various organizations sometimes had different revisions of the sace docu=ents.

e Identificaticn and control of support drawings was  :

l inadequate. There were cases where different versions of the sa=e drawing revision were in use. .

4 the Hosgri design Engineering groups considered

/ e

• as a controlled docu=ent, criteria in the FSAR which it was not. .., . __

There was no effective method for controlling the e

Hosgri seis=ic data which was distributed within r

pGEE and to design consultants.

~

e Historical copies of some procedures and =anuals revisions were not available. .

The construction drawing list the (Janua'ry 1982) was ,

e support drawings

. not accurate for.sc=e of which were checked.

Approval , signatures were not entered on support e

a l - drawings, but approvals were in the calculation package.

evidence that all revisions of e There was no supplier test plans, procedures and reports were 4

reviewed by pGkE.

i 4

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PG&E'- March 8., 1331 1

• 7/89 i i

i

ROGER F. REEDY, P.E.

Mr. Reedy has worked power industries since in the pressure vessel and nuclear 1956. His experience quality assurance, design, analysis, includes erection of nuclear power plant components. fabrication, and -

encompasses boiling water, His background pressuriced water nuclear power and HTGR petroleum, chemical, and plants, as well as pressure vesse,ls for the ~

Reedy other energy industries.

is an ackno:aledged expert Mr.

in the design and construction of nuclear components meeting the requirements of the ASME Boiler and Pressure Vessel Code,'which includes

. detailed quality assurance requirements for all components.

He has been involved in quality assurance programs'and audits, licensing, engineering review, project coordination and training of personnel.

witness He has testified as an expert ,

on topicsbefore regulatory groups, including USNRC and ACRS quality such as_

assurance _ and design tracturecriteria, toughness. analvsis, fabrication, ~

, Mr. Reedy years as a has.-been an active participant for the past 15 member and as chairman of major nuclear Codes -

and Standards nuclear power Committees plant components. in the development of criteria for 1 member of the first In this activity he'was a Material Manufacturers Task Group on Quality Assurance for his ~ Chairmanship, . instigated and Suppliers (NCA-3800) and under 2Ouali~ty Assurance the incorcoration of NCA-1 1 Plants," Program Recuirements into the ASME Nuclear Code. for Nuclear Power __

utilities, architect / engineers, He has served and manufacturcrs, as a consultant on all aspects of nuclear power plant construction.

tAs an original member

~ '

insisted of the N626.3 Commitee, Mr. Reedy. .

the requirements welding parameters, forandquality assurance, materials sele ~.

tiomt

__ 1-examinations for selection of non-destructive all structures they design.

document was recently The N626.3 ,

Code (Section III) andincorporated engineers into the ASME Nuclear -

components must now comply with (.esigning nuclear its provisions. 7hese requirements are unique to the nuclear power industry.

During the past ten years, Mr. Reedy has conducted training Code requirements, courses for engineers in Quality Assurance ar.d ASME Nuclear

.NRC regional inspectors.se has also conducted man'/ seminars for_

.t j .

I

, e

4 .. . _ o..___ .. , _ _ . _

• • u ..

Professional Back round A=erican Society of Mechanical Er.gineers o

Boiler and Pressure Vessal Coccittee 9 Chairman, Subcocaittee on Nuclear Power (Section o Executive Committee, member -

o Main Committee, member In 1980, Medal by the he was awarded the 1980 ASME Centendial

[

in recognition Policy Board for Codes and Standards

- of his long contribution to the development of the Boiler and. Pressure Vessel Code".

o Subgroup on Contain=ent, past chairman o Subgroup on Fabrication and Examination, former member o ASME Pressure Vessel and Piping Divisien g

o Past Chairman o

Board on Nuclear Codes and Standards, r.e=ber gp ANSI /ASME N626.3 Ad Hoc Task Group for Qualifications and Duties of. Personnel Engaged in ASME Boiler and Pressure Vessel Code,Section III, Division 1 and 2, Certifying Activities, me=ber Rezistration Professional Structural Engineer -- Illinois Professional Civil Engineer -- California, Illinois, Indiana, Michigan, Wisconsin .

Professional Experience 1956 to 1976

- Chicago Bridge and Iron Co=pany Oak Brook, IL Mr. Reedy was successively a designer, staff engineer, pro.'e:t engineer, de:tg and senior engineer regor ing :e ;ue'tice  : ca;3r, President of E.gineeri:5 His du ties

. s

.y...

incly'ded design of pressure vessels, service as a- staff engineer concerned with unique design and analysis problems, as well as consulting on quality assurance and related questions.

- He helped to develop and implement tne company's Quality. Assurance Program for design and fabricati a of pressure vessels for a NASA project in 962 'This orogram was the ~first forcalized cuality assurance comoany, and provided the

_ornersm in the basis for future nuclear quality assurance programs.

As Manager of Special Structures Design, he was responsible for design and analysis of

. all nuclear components. In this position he was instrumental in the development of the cc=pany's nuclear quality assurance program ~

for the design and construction of nuclear reactors and containcent vessels, and helped t o' select the company's first quality ,

assurance manager. As Design Manacer he initiated _ the concepE of independent design _ i verification o'y an independent engineering group within the company. _

As Senior Engineer reporting to the Vice President of Engineering he was responsible for consulting on all company activities concerning ASME Code design, construction, and quality assurance.

1976 to 1981 Nutech San Jose, CA -

~ '

Managed Special Projects Grou0, including ,

Quality Assurance, Training, and Program-Management. Served as Code Consultant to "

other engineers and clients of Nutech.

During this time Mr. Reedy was Director of -

the Quality Assurance Group and consulted luith clients in developing QA Programs to meet the requirements of 10CFR50, Appendin B, ANSI N-45.2 and the ASME Section III Code. .

As Chief Consultant, he served as ex-officio advisor to all in-h:use pr:jects and all clients en quality 1ssuran:a, design, and fabrication questions, as well as consulting 4

.= _

.1  :-- c . L :- -

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Code problems.

He worked with the Republic of China Atomic Energy Council to set up .an independent Inspection and Quality Verification Program in Taiwan and has given a number of lectures on Quality Assurance in both Korea and Taiwan. _

1981 to R. F. Reedy, Inc.

Present Los Gatos, CA

. Founder and President of an engineering consulting company which advises client company's management on Quality Assurance, design, fabrication,, construction and lic-ensing. ,

Education .

B. S. in Civil Engineering Illinois Institute of Techn61ogy-9 9

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3 i QUAI.ITY ASSURANCE REVII~.4 AND AUDIT REPORT PEASE I -

By: R. F. REEDY, INC.

Y Cn: SAFETY-RELATED ACTIVITIES >

6

, +

. t PERFORMED BY PACIFIC GAS AND ELECTRIC

) i PRIOR TO JUNE, 1978 I J

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QUALITY ASSURANCE PROGRAM REVIEW REPORT PHASE I SAFETY RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC PRIOR TO JUNE 1,1978 Introduction Seoce:

. On February 23, 1982 R. F. Reedy, Inc. cc=pleted the Quality

. Assurance Review and Audit of Pacific Gas and Electric (PG&E) safety related activities concerning the Diablo Canyon Nuclear Project.

The purpose of this. review and audit was to assess the

. adequacy of. PGhE Quality Assurance Program prior to June, 1978 with particular e=phasis on activities that could affect seismic related design. The baseline for this review

. and audit were the require =ents of 1CCFR50, Appendix 3.

PG&E Activities: ,

PG&E had the responsibilities of Architect-Engineer and .

Co.nstruction Manager for the Diablo Canyon Project. PG1E was supported in their design activities by contracted design consultants.

Evaluation criteria:

This Quality Assurance Review and Audit of PGLE addressed the requirements of 10CFR50, Appendix B with selected parts ..

of ANSI N45.2.ll being considered for guidance. Follow-up

. ite=s were introduced that evolved frem earlier R. F. Reedy.

Inc. audits of PG&E design consultants.

Method of Review and Audit:

The review and audit was conducted in three steps: 1.

Introductory =eetings; 2. Quality Assurance Manual and -

Procedure review, and, 3. Audit of program i=ple=entation.

' Steps 2 and 3 were perfor=ed to detailed checklists, and a general questionaire was used for Step 1.

The introductory =eetings were held at pC&E on Cec. 17 and 18, 1981. The discipline groups visited were Quality l

e pG&E . March 3, 1932 2/89 em -

Assurance, Design-Drafting, Mechanical, Civil, Electrical, and Engineering Services. The Chief Engineers and other persons from these. groups audit approach, were met to discuss review and PG&E program and project status prior to

. June, 1978. Attendees at these meetings are listed in Appendix A.

The Quality Assurance Manual and Procedures co=pleted on Jan. review was 30, 1982 at R. F. Reedy, Inc. offices.

Revisions of the Manual between 1970 and 1978 were reviewed along with applicable implementing procedures.

- The ce=pleted checklist from this review is included as Appendix

, B to this report.

~

The i=ple=entation audit was perfor=ed Feb. 2-23, 1982 at PG&E. This step of the review and audit was broken into ,

three parts:

Part A: General Require =ents and Manage =ent Contr31 of Quality As.surance .

Part 3: Design Control Part C: Follow-up Questions from Supplier Audits.'

Procedures and docu=entation were examined to ascertain program coverage. Where procedural coverage was not in place, positive the design documentatioc was used for deter =ining if though infor=al controls were practiced.

Docu=entation examined was from design activities perfor=ed prior to June 1, 1978.

separately covered Later activities are to be in the Phase II review. Co=pleted ..

checklists to this report.

frco Parts A, B, and C are included in,Appendis C

Conclusions:

1. The PGSE Quality Assurance program for design work was not adequate l .

in areas of policy, procedures and .s j,i

'imple=entation. The Quality Assurance orga:1:ation bad /-/ .

-D ,', ,

insufficient progrs= responsibility. ell ',g .

t . > *.

2. A general weakness existed in inter:al and exter:al K _., .

interface and document controls. This questions g P a whether appropriate design infor=ation was bei:5 exchanged and utilized by design groups a:d co:su*tants.gr.t",p. v ery s.t "

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PG42 [- : tar:h 9, 193; 3/37 b

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O ne, concern is if the latest Ecsgri seis=ic data was inputted for design analysis. ./' .y

3. The design verification progra= was not for=aliced and l was inconsistently i=plemented and docu=ented. This Cb',sr included =ajor gaps in design overviews of the design 1 a

Dp' T *' d' approach for =echanical and other equip =ent.

Findines gee i b 4 ' L,e ld' s

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.a l" *' f. A -}, m Progra==atic Deficiencies: ls

1. Quality Assurance as defined in the QA Manual was

. essentially an audit role. The Quality Assurance group was not assigned a pri=ary role in deter =ining QA requirements.

2. PG&E had no procedure for assuring the ce=pieteness of the QA progra= to address the requirements of 10CFR50, i Appendix B. ,

3 There ,were, no provisions for docu=ent control of ,

correspondance and design docu=ents. -

! I-r

4. During Phase I, t!kere were no centr _qQed procedures for

• u, nu. ik p,,y. o S ,

' design control, design interfaces and design respond - _ l bilities. PRE-9" and PRE-10" on these subjects were :3fi "'n, released in 1979 and are to be audited during Phase II. gngo- , ,

o,...

5. PG&E did not require design consultants to i=ple=ent 7do"

• Quality Assurance require =ents. S M/ * % jut 'I.:

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6. Corrective action provisi;ns were not addressed except with respect to audit deficiencies and deficiencies at the site. g ,_,

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7.

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5 Indoctrination and training /'were not addressed in the QA ifanual or procedures.

8. The QA  :.!anual contained oc provisions for PG&E ' ,

l

=anage=ent review of the QA progra= for status and j adequacy. <

J= ele =entation Deficiencies: g l I

1. PGLE =anagement did not review and assess the effectiveness of the Quality Assurance Prcgrs=. l

+ P R *9 , $ q . 2 6 p u .4. N e [ M J.en # t if 74 PG&E - March 8, 1992 i

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docu=entation was available to verify that FGEE e No j'- program to show that all reviewed the QA i

requirements of 10CFR50, Appendix B were addressed

! and met. Prog F*

a.

e Management Review coc=ittees only reviewed plant l opera.tional considerations and experiences from the j ,

Humbolt Bay Plant. They did not review the QA

. progras for design and construction of the Diablo ~

l ,

' Canyon Plant.

'e A program review by Energy, Inc. for an ASME N-stamp (December 22, 1975) lists many of the same

. findings that were found during :this Phase I

^

Review. # -

2. The PG1E audit system and corrective action system were I, . .not effective. 1 and follow-up was not'-timely.

j e Audit reporting 4 Reports were issued sometimes three or four =enths I after the audit.

3 Corrective actions for audit findings were e

i i

ineffective in tha. the sa=e findings were found a j during later audits. .

I e Corrective action verification was by re-audit j

. only. .

e For=al c'o'rfective actions were not invoked on the l ,, , engineering groups. ,

u

3. Design consultants were not required to implement i

Quality Assurance Pregrs=s. ,,

i .

Blume had first contract to require Quality l e l

• Assurance in late 1977. . ,;.,,,,

r

e. Responsitie engineers did not document Quality Assurance requirements for purchase specifications s

required by the Quality

! on consultants, as -

' Assurance Manual. .

! e The Quality Assurance group did not review the i

Quality Assurance Programs of design subcoctractors prior to mid-1977.

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M arch 9, *.332

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e WYLE was not contractually required to have a i'

Quality Assurance Program until Dec. 1, 1979.

e ANCO was not contractually re' quired to have a t Quality Assurance Program until May 1978.

design verification on in-house activities and

. 4. PG&E suppliers was unstructured and applied inconsistently.

We consider that design verification consists of the ,

following three elements: _

- 1) METgn15$hiew'fordesignapproach,:=ethods, ,

design input selection, and asEumptions.-~'---

4

~.__. .. _..n.- -' O and Detailed ___ checking cf design steps 2) 4 completed design docu=ents. . .

3) Verifigatio'd of s'pproved "As Built" condition #

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agavnst approved design. r ,

Activities f~or ele =ent 3,were not initiated until 1979 and are to be reviewed during Phase II. Docu=entation showed detailed checks to be perfor:ed on PG&F work l with design.. overviews being perfor=ed on.a. selective 4

Most of what PGEE refers to as Design Reviews r

basis. i consists of element 2.

e Comprehensive overviews and detailed checks were

performed by EDS on Class I electrical design,

some EVAC, and structural ite=s. Design overviews were not evident for mechanical designs. .

i e PG&E did not require design contractors to perfors ~'

l design reviews of their own work. l e- For the majority of cases reviewed; : design  ;

"~'

verification criteria were not defined and were .r ;

i dependent on the discretion of' the:: reviewing. -

i engineer. ,

e Docu=entation of design verifications was inconsis- ,

tent and at ti=es inec=plete. ,

was no docu=ent control system -

5. There effective established. .

l e Design interfaces internally and externally were "s'

. March 8, 1982

?GGE f 6/39 1 .

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4 not effectively controlled. Various organizations had different revisions of the sa=e someti=es documents.

e Identification and control of support drawings was' There were cases where different inadequate.

versions of the sa=e drawing revision were in use. _

groups considered the Hosgri design e Engineering as'a controlled docu=ent, criteria in the FSAR which it was not. _ __

e "There was no effective =ethod for controlling .-ttie' seismic data which was distributed within Hosgri -

PGEE and to design consultants.

e , Historical copies of so=e procedures and =anuals .

revisions were not available.

The construction drawing list (January 1982) was 1

I 1 o the support drawings not- accurate for so=e of which were checked.

not entered on support  :

signatures were e Approval

- drawings, but approvals were in the calculation package. -

revisions of e There was no evidence that all supplier test plans, procedures and reports were reviewed by pG&E.

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PG&E --Mar:h 8,-1352 I 7/89 G

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U ROGER F. REEDY, P.E.

!! Mr. - Reedy has worked power industries since in the pressure vesnel and nuclear 1956. His experience i quality assurance, design, analysis, includes erection of nuclear power plant components. fabrication, and i;1 encompasses His background

't boiling water, pressurized nuclear power water and RTGR petroleum, chemical, plants, as well and other energy as pressure vesse,ls for the _

Reedy is an acknowledged expert. in industries. . Mr. '

the design- and construction ~of nuclear components meeting the require =ents

~ '

- of the ASME Boiler and Pressure Vessel Code, which includes -

detailed quality assurance requirements for all components.

He has been. involved in quality assurance programs ~and

{ audits, and licensin'g, training engineering review, project coordination of personnel.

~

j -

witness He bas testified as an expert .

^ ini topicsbefore regulatory groups, including USNRC and ACRS quality such as_

assurance and design fracture criteria, to'ughness. analysis, fabrication, ~'

1

,. Mr. Reedy. has i i years as a' been an active ' participant for the past 15

. member and as chairman of major nuclear Codes -

and Standards

. nuclear power plant Committees in the development of criteria for components.- In this activity be was a i

member of the- first 4 Material. Manufacturers Task Group.on Quality Assurance for

his Chair =anship, instigated and Suppliers (NCA-3800) and under

-1 . -

l'Ou ali ty Assurance the incornoration of NOA-1.

Plants," into the Program Recuirements for Nuclear power _

1

' ASME Nuclear Code-1 utilities, architect / engineers, He .has served.

i! consultant on all aspects and manufacturers as a construction.

of nuclear power, plant ,,

!As an original member

<. insisted of the N626.3 Commitee, Mr. Reedy..  :- .: :

that registere'd professional engineers understand.. .a

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'-the welding rbquire=ents for quality assurance, mat'erials selection? : . : -

parameters, and selection of

i examinations for all structures non-destructive document was recently they design. The N626.3 Code ~(Section incorporated into the~ASME Nuclear -

III) and engineers designing cocponents must .now' comply. with nuclear its provisions. These requirements are unique to the nuclear power industry. i jj During the past ten' years, Mr. Reedy has conducted training courses Code for engineers in Quality Assur~ance and ASME Nuclear requirements. -

'l NRC regional inspectors.He has also conducted many seminars for

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.s Professional Backrround American Society of Mechanical Engineers o Boiler and Pressure Vessel Co==ittee i

' S Chairman, Subcommittee. on Nuclear Power (Section III) o Executive Committee, member -

) o-Main Committee, member .

In 1980,

Medal he was awarded the-1980 ISME Centennial ';-

' by the Policy Board for Codes and Standards in recognition of his long contribution to the.

' development of the Boiler and Pressure Vessel' __

Code.

i-t o Subgroup on Containment, past chairman-2 L

o Subgroup on Fabrication and Examination, former

' member t-j o ASME Pressure Vessel and Piping Division t g

o Past Chairman 4 * ~- .

o Board on Nuclear Codes and Standards, member  !

dp ANSI /ASME N626.3 Ad Hoc Task Group for Qualifications and Duties of Personnel Engaged in ,

i ASME Boiler and Pressure Vessel Code,Section III, i Division 1 and 2, Certifying Activities, member' -

Registration --

. l-

)

Professional Structural Eng'ineer -- Illinois  !

- Professional Civil Engineer --- California, Illinois, 'l Indiana, Michigan, -

i t

Wisconsin -

professional Experience  ;

1956 to 1976 Chicago Bridge and Iron Co=pany Oak Brook,.IL .

[

i Mr. Reedy was successively a designer, s:sff F

, engineer, project e:gineer, design m1:1ger, i and senior engineer reporting to the Vice'  !

President of Engineering. His duties i, 9

e

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. . ;j,

.. . b L* .s included 6, design of pressure vessels, service as a staff engineer concerned with unique design and analysis problems, as well,as consulting on quality assurance and related questions. ,

develop and implement the

- He helped to company's ' Quality Assurance Program for design and -fabricati of pressure vessels ~

for a NASA project in 962 _This crocram was the ~.first forca11 zed quality assurance' ~

, ,ornerim in the company,- and provided the -

basis for future. nuclear quality assurance ,

~'. programs. -

- As, Manager of Special Structures Design, he responsible for design a'nd analysis.of was all nuclear components. In this position he '

was instru= ental in the development of.the company's nuclear quality assurance program for the design and construction'of nuclear reactors and containment vessels, and helped to select the*' company's first quality ,

assurance manager. As Design Manager. he initiated the concept of independ nt design __ 1 verification by an independent engineering group.within the company.

As Senior Engineer reporting to the Vice President of Engineering he-was responsible for consulting on all company activities concerning ASME Code design, construction, and quality assurance. .

1976 to 1981 Nutech

.. San Jose, CA .

_1.

2 .' . 1 I I!c s  : :. _ . 1;,,

s

, _?;;J ~

_: Managed Special Projects ' Group,: . including: ( _ _ I ' ~ ' ~ _~ l - ,

' - ~

~

Quality Assurance, Training, and- Program Management. Served as Code Consultant to '

other engineers and clients of Nutech.

During this time Mr..: Reedy was Director of -

the . Quality Assurance Grour and consulted

~w itn clients in developing QA Programs to meet the requirements of 10CFR50, Appeb. dix B, ANSI N-45.2 and the ASME Section Ill Code. .

- As Chief Consultant, he served as. ex-officio ~

advisor to all in-hcuse ' projects and all clients on quality assdrance, design, and-fabri:1 tion questions, as.well as consulting 9

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____C.,,,_.,_,_____ , _ _ , , , , . . . . .

Code problems.

He_ worked with the Republic of China Atccic Energy Council to set up an independent Inspection and Quality Verification Program in Taiwan and has given a number of lectures on Quality Assurance in both Korea and Taiwan. .

1981 to R. F. Reedy, Inc.

Present Los Gatos, CA - .

. Founder and President of an engineering consulting company . which. advises clisnt' ~

company's management on Quality Assurance, design, fabrication,, construction and lic-

!. - ensing.

i .

Education >

. B. S. in Civ11 Engineering Illinois Institute of Technology

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, , . pa arcy g[g UNITED STATES

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NUCLEAR REGULATORY COMMISSION g l WASHINGTON, D. C. 20555

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% Se W e~ , PM Y '2.J7 L o The Honorable. Morris K. Udall, Chairman Committee on Interior and Insular Affairs -

United States House of Representatives ~

Washington, D. C. 20515

Dear Congressman Udall:

I am responding to your letter of January'11,1983 in which you refer to

. concerns of individuals living in the area near the Diablo Canyon Nuclear

,-_ Power Station. Your letter raises five specific concerns regarding the requirements which must be satisfied prior to authorization.to load fuel. .

Each of these concerns is addressed in the enclosure.

i Let me assure you that under no condition will we authorize the Diablo ,

. , Canyon facility to begin operation until we have confidence that the public

, , health and safety is . assured. More specifically, we will require that all seismic analyses and evaluations required by the Cc.vnission's November 19 -

l 1981 Order are completed prior to a fuel loading decision. Further, we

, will require.a high level of confidence that no other significant design or construction deficiences exist at the facility before reaching such a

, decision. '

1 l I hope this letter provides information responsive to the concerns. I appreciate the opportunity to provide the information.

Sincerely, '

i --

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I Nunzio J. Palladina i Chairman i -

Enclosure:

As stated '

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Enclosure Response to Five Concerns i

The first concern is that "the Commission has approved a licensing schedule-that would permit fuel loading prior to completion by PG&E of its review of th'e plant's seismic' design and prior to implementation of all necessary corrective measures that might result from this review." On March 4, 1982 the Commission approved a program plan.for Phase I of the Independent l Design Verification Program (IDVP). The Phase I activities (described -

below in our response to the third concern) must be completed prior to '

reinstatement of the low power license. On December 8, 1982, the Commission approved a plan according to which a decision regarding the low power  ;

license reinstatement will take place in two steps. A third step will i

- be the decision regarding issuance of the full power license. Before any ,

. decision to permit PG&E to load fuel, all activities prescribed in Step 1  !

must be completed, and before any decision to permit low power operation ,

(less than 5".), all activities prescribed in Step 2 must be completed.

Steps

. 1, 2, and 3 are. defined in the Enclosure of the PG&E submittal of December 2, 1982 (copy attached). While PG&E has proposed specific dates for both steps (March 31, 1983 and May 15, 1983, respectively), we do not consider these dates controlling and will reach decisions only after all necessary review and evaluation has been completed. All modifications to safety-related structures, systems, and components re' quired for any particular mode cf operation of the facility must be completed prior to a decision regarding that mode.  !

The sec' oncern is that "no provision has been made .for considering analyse's of the seismic design now being prepared by Brookhaven National y Laboratory" (BNL). The results of the seismic design analyses that have ,

been ongoing at BNL since late 1981 will be fully taken into consideration in the NRC evaluation and determination regarding the seismic design adequacy of Diablo Canyon Unit 1. The first BNL effort involved the containment annulus structure and selected associated' piping systems and was documented '

in a report. We have requested the IDVP'to review this report, consider --

the results in its own design verification efforts, and provide us with its conclusions. The NRC staff is evaluating the BNL report in parallel ~

and will have the additional benefit of the independent view provided by the.IDVP.

In mid 1982 the NRC requested continued participation by BNL to undertake -

a horizontal seismic analysis of the containment annulus structure, seismic ,

and stress analyses of a buried tank, and additional analyses of piping systems. The purpose of the BNL analyses is-to provide the NRC with additional insight as to the character of.results obtainable by use of current state- '

of-the-art analytical techniques without regard to methods or procedures previously approved in the licensing process for Diablo Canyon. These analyses ar'e therefore not intended as a substitute for the design and evaluation efforts now underway nor are they a substitute for the analytical effort being performed by the IDVP. Our experience has been, however, that such analyses often provide insights to assist in our review. The

- BNL analyses will be sufficiently completed and taken into consideration prior to any decision regarding restoration of.the license.

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The third coricern is that " fuel loading will be allowed before completion of an adequate review of non-seismic safety-related plant elements." The Commission Order of November 19, 1981, which suspended the low power license, sets forth the recuirements that must be completed prior to reinstatement of the license. These requirements relate to seismic analyses and design activities perforned prior to June -1978 by PG&E and its co6 tractors (i.e.,

service-related. activities) and to the implementation of the quality assurance program for those efforts. .The activities associated with the Commission Order have become known as Phase I of the independent design verification j effort and, as discussed above, will be completed in'two steps. In addition, _

the NRC Office of ~ Nuclear Reactor Regulation required PG&E in a letter, .

. also dated November 19, 1981, to initiate an independent design verification effort of safety-related structures, systems and components with respect

to seismic analyses and design activities performed after 1978 and with respect to non-seismic analyses and design efforts performed by PG8E and

.its contractors. These efforts have becone known as Phase II of the design verification program. By the Commission's approval of the program plan

~

. on December 8,1982, the utility is required to submit a status report on all Phase II activities prior to any decision regarding restoration ,

of the license. Such work must be sufficiently complete to ensure that all major deficiencies were detected.

The design verification efforts for Phase I and Phase II are well underway.

. The activities that.we require now to be completed prior to a fuel load decision exceed those originally specified in our Order. We have expanded Phase I to include the following additional IDVP activities: (1) audit i

of the implementation of the Diablo Canyon Project quality assurance

program (2) audit of a sample of quality assurance program implementation of construction activities, (3) review of the PG&E/ Westinghouse design .

interface, and (4) verification of the appropriate Hosgri and non-Hosgri spectra.

As explained above, at the time of authorization for fuel loading.all' efforts required for reinstatement of the license will be complet'ed except

, for modifications to those structures, systems and components that are not required for Step 1, in order to protect the public health and safety.

In addition, the Phase 'II. activities (i .e., no'n-seismic, safety-related analysis and design) of PG&E.and the IDVP will have proceeded to an extent that will allow us to reach a conclusion with respect to any additional design verifi' cation that might be required. At this time the IDVP has ,

completed its review of those structures, systems and components that .

comprise the initial sample to.be verified under Phase II.. Prior to fuel loading, PG&E and the IDVP will both submit to the NRC a report on the '

status of their respective Phase II activities. Again, we will require ,

a high degree of assurance, at the time of a decision regarding fuel loading, i

that any further design verificati.on efforts in the seismic and non~ seismic i

1 area will not reveal any major deficiency in Diablo Canyon ' Unit]l.

l s e D

i L

aceived from the ongoing audit of the quality assurance pro oplementation of correctiveAsactions,-if stated above any, which might in response to the be called

s a result of this program."and third concern, an audit of the quality assurance

~ '

'o11{jpg (0

hnir implementation by PG&E and'its contractors is required as-partThese ,p, 3 ; vo audits l gjp 1e' Phase I and Phase II activities.

ne IDVP; interim technical reports have been issued and are current d,AAA.; y In addition, the design verification effort has -

rgoing NRC review. -

expanded to include an audit This activity of QA and is ongoing activities a statusregarding report the construction  ! .

iablo Canyon Unit 1. Other

.ba provided to the NRC as part of the Step 1 requirements.-

ts of QA programs and their implementation include an IDVP QA audit ,

angoin'g PG&E activities, a PG&E internal- QA audit of its contractors,In addition, a PGaf QA audit of its own ongoing activities.

ion V Office has routinely inspected ongoing Mostdesign of the verification activities, luding the implementation of appropriate QA programs. ill J'

ve QA audits will be completed prior to fuel loading and reports wWe w

-~

provided to'the NRC.

ions'be implemented befo,e r fuel load authorization.

fifth concern is that " fuel loading will be permitted prior to an ltd

quate NRC review of the various seismic and non-seismic The safety-re a e its, analyses and corrective actions undertaken since late 1981." clear

Order of November 19, 1981, st be met and procedures that are to be followed for the authorization fuel loading. In Section 5.of Attachment 1, the Order states:

" Prior to author'ization to proceed with fuel loading the NRC shall ~

be satisfied with the results of the seismic design verification program referred to in paragraph 1, and with any. plant modification resulting from that program that may be necessary prior to fuel loading.

The NRC may impose additional requirements pri,or.to fuel loading necessary to protect health ~and safety based upon its-review

of the. program or any of the information provided by PG&E pursuant This may include some or all of the requirements to paragraph 4. 19,'1981." , ,

• soscified-in the letter to PG&E, dated. November j'* ' ~ -

i t ent J ar aporovaT of the two-step process for a decision regarding re nsta em f the license does not permit any deviation from the.se requirements.the concept o '

.s stated earlier, the approval is limited to -

'or decisions regarding reinstatement of the license, but is in no wayAt this time f semi-monthly estricted to.the target schedule proposed by PG8E.

ts and tne IDVP are providing us with much information in O

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on the various facets of the design veri.fication efforts in Phase I and i Phase-II. Although we intend to give substantial weight in our decision i

i~ to the findings; conclusions, and recoamendations of Teledyne Engineering Sevices as the manager of the IDVP, under no condition will we consider the IDVP to take the. place of the necessary and adequate NRC review. We will not be restricted in our own review efforts by the specific schedule proposed but will take the time necessary to assure ourselves and the l public that there are no deficiencies that would prevent safety-related structures systems and components from performing their intended safety

' functions. '

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ESTIMATED SCHEDULE FOR CCP9LETION OF ACTIYITIES REQUlRED FOR FUEL LOADING, LOW POWER TESTING, AND FULL PCHER OPEMTION 12/02/82

. SCHEDULED COWLET104 ACTIVITY DATE REPACKS Stas I 1. Project Reports submitted:

Fequirements for A. Final Repcet for Phase i ,02/15/83 R:storation of the B. Status Report for Phase 11 02/15/83 Lov Power License C. Supplement for As-builts' 03/15/83

2. IDVP reports submitted: (See Note I)

A. Status Report for Phase 1 03/01/83 B. Status Report for Phase 11 03/0!/83 (See Note 2)

C. Status Report for ITP QA Progras 03/01/83 D. Status Report for Construction QA 03/01/83

. E. Status Report for Non Hosgel spectra 03/01/83

, F. Final Report for PG&E/_W interface 03/01/83 G. Final Report for Hosgel spectra 03/01/83

. H. Supplement for As-built 03/15/83 For f uel load items

. verification (Modes 5 & 6) (See-Note 3)

- 3. NRC Decision for Restoration of 03/31/83 the Low Power. License Step II

l. Project Reports submitted: ,

Fequirements for Initial A. Final Phase i Report supplement 04/01/83 Criticality and Lov, Power B. Supplement for As-builts 04/30/83 Tcsting

2. IDVP reports submitted: ,

A. Final Report for Phase 1 04/15/83 B. Status Report for Phase 11 04/15/83 C. Supplanent for As-built 04/30/83 For low power items verification (Modes 2,3,4,5 & 6)

~~

. (See Note 4)

3. NRC DecIslon for initial 05/15/83 Criticality and Low Power Testing , , .

Stro Ill 1. Project Reports submitted Paquirements for issuance A. Phase ll Report 05/15/83 '

of a Full Power License B. Supplement for As-built 06/15/83 .

2. IDVP reports submitted:

~

A. Final Report for Phase il 06/01/83

8. Final Report for ITP QA 06/01/83

• C. Final Report for Construction QA

• 06/01/83 D. Final Report for Non-Hosgel spectrs 06/01/83 E. Supplement for As-built 06/15/83 For full power items j .

Yorification (Modes 1-6)-

~

3. NRC Decision for issuance of .06/30/83 .

a Full Power License l

l

NOTES

~

NOTE l -

10VP reports may be started approximately mld December, 1982, with f urther proj ect input in mic January and February. It Is anticipated that the reports can be completed within two weeks of receipt of the last project input. The IDVP is In continual contact with the project throughout this period.

NOTE 2 - Phase 11 status report will address that Phase 11 activities are sufficiently complete to provide reasonable assurance that no -

major deficlancies remain undetected.

NOTE 3 - Items to be completed after fuel loading:

o Civil structural final' confirmatory load review (supported

. loads). Primarily Annulus and Class .1 platforms.

l ,

o Fuel handling building modifications (Unit I only)., ,

o Turbine building modification design and construction.

NOTE 4 -

Items to be completed after RCs heatup and low power testing:

m Turbine building modification design and construction.

Note This attachment was enclosed in the PG&E submittal of December 2,1982. It lists the activities of Phase I, Phase II and other efforts that must be completed at the two steps for reinstatement of the low power license and at the issuance of a full power license. ..

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.E ';F. lam FOR: Itcve ri: S b rc. .

IF.:M: Frederin Forscnep 5.'iJECTt Status of 3 at the~Diablo Canyon HPP. January 25, 1983 The following paragraph is taken from a 4-page enclosure to a letter from

hairnan Falladino to Morris Udall, in response to Udall's (5) concerns regarding,

$iablo Canyon, expressed in a l'etter dated Jan.11, l'983. .wf ph S,'gtud . _

"An audit of the quality assurance programs and their implememtation by PG&E and its contractors is required as part of the Phase I and Phase II activities.

These audits have been completed by the IDVP; interim technical reports have been issued and are currently undergoing NRC review. In addition, the design verification j , hffort has been expanded to include an audit of QA activities regarding the con-struction of Diablo Canyon Unit 1. This activity is ongoing ard a status report

. will be provided to the NRC as part of the Step 1 requirements. Other audits of QA programs and their implementation include an IDVP QA audit.of ongoing PG&E activities, a PG&E internal QA audit of its contractors, and-a PG&E QA audit of .

its own ongoing activities.

In addition, the NRC Region V Office has routinely inspected ongoiiig design verification activities, includirig the implementation of appropriate QA programs. Most of the above audits will be completed prior to fuel leading and reports wil.1 be provided to the NRC. "

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n be used by Inpo and tne uttuucs ui .omsu .. .... ,..... .

NRC IS PERPETUATING ' CONFUSION AND PROCEDURAL COMPLEXITY'IN ITS HEARINGS by failing to combine low- and full-power license proceedings into a single one for piablo Canyon, a: cording to Commis-s5ncr Victor Gilinsky.Gilinsky's comment wanttached to a Dec. 23 comm:ssion order that denied an inter-venor's request for a hearing on extension of Pa. die Gas & Electric's suspended low-power license. In the i

same order, the commission responded to a request for advice by telling the Diablo Canyon licensing boards j to handle intervenor motions to reopen hearing records with a " business as usual approach."

Gilinsky was disappointed, according to informed sources, that th'e comrnission did not take the oppor. ';

. ~~ '

' tunity to simplify this particular hearing process. NRC could have directed the boards to "collJph" suchie -

o

~

quests into one hearing process, one source said. "The problem with Diablo Canyon is that the whole process has gotten mixed up. The procedures made sense a year and a half ago, but not anymore. If the boards decide

9

[ to reopen the hearing records the same issues are going to be raised at both proceedings," he said.The only ressen not to meld the two proceedings into une is the possibility that PG&E could gain a few weeks of oper- '

ating time by keeping them separate, said Gilinsky l

Other NRC, and PG&E, sources disagreed. Delaying formal consideration of Diablo Canyon's low-power li:ense until NRC is prepared to consider its fu!! power license could delay startup of the plant by as much as D a year, they said.N's would have to deny PG&E their request for a low power license and force them to sit {-s l

Q-idly by ,with their f1 rushed plan . until a full power license decision is made," an NRC source said.

The Atomic Safety & Licensing Appeal Board withjurisdiction over the motion to reopen the low. power proceeding last week relieved the Atomic Safety & Licensing Board of responsibility for considering the mo-

' tion. As a result, both proceedings would be conducted by the appeal board ifit decided to grant the inter-senors' request to reopen the re

ord. Accordpg to NRC staff, however, nothing is likely to happen until the l commis:icn reviews the independent design verification proeram still being conducted by Teledyne Engineer.

l 's. ; at Diablo Canyon (Inside NRC,13 Dec. '82,13). .

NRC '.*!ON'T EXEMPT REPLACEMENT PARTS NOW IN STOCK FROM OUALIFICATION RULE The SRC commissioners voted Jan. 6 to issue a final environment:1 qu:lifi::t!cn rule for electrical e,Jp:r:::. cxtending the compli:n:e ded!ine :nd a::eptin; a mff rewmmentti:n that equipment to d= _ _ _ ' _ _ _ _ _' _$__ _  ?"#" ' '~ ' ' ' ~ ' '

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NUCLEAR REGULATORY COMMISSION

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, PM Y ~2 ~/ t o y

The Honorable Morris K. Udall, Chairman Committee on Interior .ind Insular Affairs United States House of Representatives -

Washington, D. C. 20515

Dear Congressman Udall:

I am responding to.your letter of January 11, 1983 in which you refer to

. concerns of individuals living in the area near the Diablo Canyon Nuclear Power Station. Your letter raises five specific concerns regarding the requirements which must be satisfied prior to authorization to load fuel. ,

Each of these concerns is addressed in the enclosure.

Let me assure you that under no condition will we authorize the Diablo

, Canyon facility to begin operation until we have confidence that the public

, health and safety is , assured. More specifically, we will require that all seismic analyses and evaluations required by the Commission's November 19,

~

1981 Order are completed prior to a fuel loading decision. Further, we will require.a high. level of confidence that no other significant design or construction deficiences exist at the facility before reaching such a decision.

I hope this letter provides information responsive to the concerns. I appreciate the opportunity to provide the information.

Sincerely, Nunzio J. Palladino '

Chairman

Enclosure:

As stated '

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Enclosure Response to Five Concerns The first concern is that "the Commission has approved a licensing schedule that would permit fuel loading prior to conpletion by PG&E of its review of the plant's seismic design and prior to implementation of all necessary corrective measures that might result from this review." On March 4, 1982 the Commission approved a program plan for Phase I of the Independent Design Verification Program (IDVP). The Phase I activities (described -

below in our response to the third concern) must be completed prior to reinstatement of the low power license. On December 8, 1982, the Commission approved a plan according -to which a decision regarding the low power license reinstatement will take place in two steps. A third step will

- be the decision regarding issuance of the full power license. Before any decision to permit PG&E to load fuel, all activities prescribed in Step 1 must be completed, and before any decision to permit low power operation (less than 5%), all activities prescribed in Step 2 must be completed. Steps 1, 2, and 3 are. defined in the Enclosure of the PG&E submittal of December 2, 1982 (copy attached). While PG&E has proposed specific dates for both steps (March 31, 1983 and May 15, 1983, respectively) Ne,do not consider these dates controlling and will reach decisions only after all necessary review and evaluation has been ccmpleted. All modifications to safety-related structures, systems, and components re' q uired for any particular mode of operation of the facility must be completed prior to a decision regarding that mode.

The second concern is that "no provision has been made for considering analyse's of the seismic design now being prepared by Brookhaven National -

Laboratory" (BNL). The results of the seismic design analyses that have been ongoing at BNL since late 1981 will be fully taken into consideration in the NRC evaluation and determination r' egarding the seismic design adequacy of Diablo Canyon Unit 1. The first BNL effort involved the containment annulus structure. and selected associated ' piping systems and was documented in a report. We have requested the IDVP'to review this report, consider --

the results in its own dasign verification efforts, and provide us with its conclusions. The NRC staff is evaluating the BNL report in parallel

• and will have the additional benefit of the independent view provided by the.IDVP. ,

In nid 1982 the NRC requested continued participation by BNL to undertake .

a' horizontal seismic analysis of the containment annulus structure, seismic ,

and stress analyses of a buried tank, and additional analyses of piping systems. The purpose of the BNL analyses is to provide the NRC with additional insight as to the character of results obtainable by use of current state-of-the-art analytical ~ techniques without regard to methods or procedures previously approved in the licensing process for Diablo Canyon. These analyses are therefore not intended as a substitute for the design and evaluation efforts now underway nor are they a substitute for the analytical effort being performed by the IDVP. Our experience has been, however, that such analyses often provide insights to assist in our review. The BNL analyses will be sufficiently completed and taken into consideration prior to any decision regarding restoration of the license.

8

- e e

The third concern is that " fuel loading will be allowed before completion of an adequate review of non-seismic safety-related plant elements." The Commission Order of November 19, 1981, which suspended the low power license, sets forth the requirements' that must be completed prior to reinstatement of the license. These requirements relate 'o seismic analyses and design activities perforned prior to June 1978 by PGSE and its contractors (i.e.,

service-related activities) and to the implementation of the quality assurance

< program for those efforts. The activities associated with the Commission Order have become known as Phase I of the independent design verification effort and, as discussed above, will be completed in'two steps. In addition, the NRC Office of Nuclear Reactor Regulation required PG&E in a letter, .

also dated November 19, 1981, tu initiate an indepe'ndent design verification effort of safety-related structures, systems and components with respect to seismic analyses and design activities performed after 1978 and with respect to non-seismic analyses and design efforts performed by PG&E and its contractors. These efforts have becone known as Phase II of the design s verification program. By the Commission's approval of the program plan on December 8, 1982, the utility is required to submit a status report on all Phase II activities prior to any decision regarding restoration of the license. Such work must be sufficiently complete to ensure that all major deficiencies were detected.

The design verification efforts for Phase I and Phase II are well underway.

The activities that.we require now to be completed prior to a fuei load decision exceed those originally specified in our Order. We have expanded Phase I to include the following additional IDVP activities: (1) audit of the implementation of the Diablo Canyon Project quality assurance program (2) audit of a sample of quality assurance program implementation of construction activities, (3) review of the PG&E/ Westinghouse design .

interface, and (4) verification of the appropriate Hosgri and non-Hosgri spectra.

As explained above, at the time of authorization for fuel loading all efforts required for reinstatement of the license will be completed except for modifications to those structures, systems and components that are ,,

not required for Step 1, in order to protect the public health and safety.

In addition, the Phase II a.ctivities (i.e., non-seismic, safety-related analysis and design) of PG&E and the IDVP will have proceeded to an extent that will allow us to reach a conclusion with respect to any additional design veriff' cation that might be required. At this' time the IDVP has '

completed its review of those structures, systems and components that .

comprise the initial sample to be verified under Phase II. Prior to fuel loading, PG&E and the IDVP will both submit to the NRC a report on the '

status of their respective Phase II activities. Again, we will require ,

a high degree of assurance, at the tine of a decision regarding fuel loading, that any further design verification efforts in the seismic and non-seismic area will not reveal any ma,jor deficiency in Diablo Canyon ' Unit '1.

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1. J l ourtn concern is that " fuel loading will be permitted before results eceived from the ongoing audit of the quality assurance program and 4

l mplementation of corrective actions, As stated aboveif in any, which response to might the be called l .s a result of this program.". and third concern, an audit of the quality assurance g l ; heir implementation by PG3E and its contractors is requ' iredgas.partThese 3;[Q  !

l y audi d and are currently

' 1e Phase I and Phase II activities.

d b .;

i le IDVP; interim technical reports have been issueIn addition, the design verific  ; ~

lrgoingNRCreview.cxpanded to' include an audit of QA activities regarding This activity is ongoing and a status report  ! the co l iablo Canyon Unit 1. Other  :

ba provided to the NRC as part of the Step 1 requirements.

l .

[ ts of QA programs and their implementation include an .

~

j :a PG&E QA audit of its own ongoing activities.on V J0ffice has routin Most of the l luding the implementation of appropriate QA programs. ill ,

A '

l <e QA audits will be completed prior to fuel loading and reports wWe wil

! provid:d to~the NRC.

ions be implemented before fuel load authorization.

~

! fifth concern is that " fuel loading will be permitted prior to an j quate NRC review of the various seismic and1"non-seismic The safety-relate

its, analyses and corrective actions undertaken since late 198 . clearly set

Order of November 19, 1981, j st be met and procecures that are to be followed for the authorization -

! fuel loading. In Section S of Attachment 1 the Order states: "

i - " Prior to authorization to proceed with fuel loading the NRC shall l be satisfied with the results of the seismic design verification j piogram peferred to in paragraph 1, and with any. plant modification resulting from that program that may be necessary prior to fuel loading. The NRC may impose additional requirements prior to fuel j loading necessary to protect health and safety based upon its review ..

of the programThis or any of the information provided by PG&E pursuant-may include some. or all 'of the requirements I

to paragraph 4.

~

19, 1981."  :  :" ..

sptcified in the letter to PGAE, dated November - . .

, ~

j - i

5 I f the license does not permit any deviation from the_

• jsstatedearlier,theapprovalislimitedtotheconceptoftwosteps '

?

• or decisions regarding reinstatement of the license, but is in no wayAt this time, PG '

i in the form of semi-monthly l -estricted to the target schedule proposed by PG5E.lind the j j

l eports, interim technical reports, and sections of- their final reports I  : [

. \

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} l V . . i

i

_ - . ___.___._n__,_._.,_ .___-;__._.. ___ _ _ _J

i on the various facets of the design veri.fication efforts in Phase I and 1 Phase II. Although we intend to give substantial weight in our decision to the findings; conclusions, and reconmendations of Teledyne Engineerina Sevices as the-manager of the IDVP, under no condition will we consider the IDVP to take the place of the necessary and adequate NRC review. We will not be restricted in our own review efforts by the specific schedule

! . proposed but will take the time necessary to assure ourselves and the

. public-that there are no deficiencies that would prevent safety-related

. .. structures, systems and components from performing their intended safety i functions. '

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' ,- ESTIMATED SCHEDtJLE FOR CCM"LETION OF ACTIVITIES' REQUIRED FOR FUEL LOADING, LOW POWER TESTING, AND FULL F04ER CP: ERAT 10N w a .

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. . SCHEDULED r COW LETION ACTIVITY DATE REWA ES Stt:0 1 1. Project Reports submitted:

Requirements for A. Final Report for Phase I ,02/15/83 Razteration of the B. Status Report for Phase 11 02/15/83 Low Power License C. Supplanent for As-builts -

03/15/83

~

2. IDVP reports submitted: (See Note l} -

A. Status Report for Phase 1 03/01/83 s B. Status Report for Phase 11 03/01/83 (See Note 2)

C. Status Report for ITP QA Program 03/01/83

' ~

D. Status Report for Construction QA .03/01/83 - -'~ ~

. E. Status Report for Non Hosgel spec

• 4 03/01/83

, , F. Final Report for PG&E/_W interface

,03/01/83 G. Final Report for Hosgel spectra 03/01/83

• ~

. H. Supplaynt for As-built 03/15/83 Fcr f uel loe'd items

. verification (Modes 5 & 6) (See' Note 3)

. s 3. NRC Decision for Restoration of - 03/31/83

- c the Low Power License St p II I. Project Reports submitted:

Recuirements for initial A. Final Phase i Report su'pplement 04/0l/83 Criticality and Lov, Power B. Supplement for As-builts 04/30/83 Testing .

2. IDVP reports submitted:

A. Final Report for Phase 1 04/15/83 B.- Status Report for Phase 11 04/15/83 C. . Supplanent for As-built 04/30/83 For low power items verification (Modes 2,3,4,51,6)

(See Note 4)

, ' 3. NRC Decision for initial 05/15/83 ~ ~

Criticality and Low Power Testing. --

Stro lli 1. Project Reports submitted Paquirements for issuance A. Phase il Report 05/15/83 cf a Full Power License B. Supplement for As-bullt 06/15/83 .

2. IDVP reports submitted:

A. _ Final Report for Phate 11 06/01/83

8. Final Report for ITP QA 06/01/83

.- C. Final Report for Construction QA 06/01/83 D. Final Report for Non-Hosgel spectr's 06/01/83 E. Supplement for As-built 06/15/83 For f ull power Items Yorification (Modes 1-6).

I -

l 3. 'NRC Decision for issuance of 06/30/83 .

a Full Power License i

- 6 .

NOTES NOTE l -

IDVP reports may be started approximately mid December, 1922, =lth f urther proj ect i nput in mle January and February. It is anticipated that the reports can be completed within two weeks of recelpt of the last project Input. The IDVP is In continbal contact with the project throughout this period.

NOTE 2 - Phase 11 status report will address that Phase !! activities are sufficiently complete to provide reasonable assurance that no -

major deficiencies remain undetected.

NOTE 3 - Items to be completed after fuel loading:

o Civil structural final' confirmatory load review (supported

. loads). Primarily Annulus and Class I platforms.

~

o Fuel handling building modif ications (Unit I only).

o Turbine building modification design and constructi'n. o NOTE 4 - Items to be completed after Res heatup and low power testing:

t Turbine building modification design and construction.

~

Note This attachment was enclosed in the.PG&E submittal of December 2,1982. It lists the activities of Phase I, Phase II and other efforts that must be completed at the two steps for reinstatement of the low power license and

. at the issuance of a full power license. ..

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.Tl0T'*.?J. FOR: SiCVe Ei?.UdECn

M:

Frederick Forscher I'JEJECT : Status of GA at the Diablo Canyon HPP. January 25, 1983 The follcwing paragraph is taken from a 4-page' enclosure to a letter from

'hairman Palladino to Morris Udall, in response to Udall's (5) concerns regarding

$iabloCanyon,expressedinaletter dated Jan. 11,1983. >>f pth Qtud .

"An audit of the quality assurance programs and their implementation by FG&E and its contractors is required ~as part of the Phase I and Phase II. activities.

These audits have been completed by the IDVP; interim technical reports have been issued and are currently undergoing NRC review. In addition, the design verification

, effort has been expanded to include an audit of QA activities regarding the con-struction of Diablo Canyon Unit 1. This activity is ongoing and a status report will be provided to the NRC as part of the Step 1 requirements. Other audits of QA programs and thei'r implementation include an IDVP QA audit of ongoing PG&E activities, a PG&E internal QA audit of its contractors, and a PG&E QA audit of

.its own ongoing activities.

~

In addition, the NRC Region V Office has routinely inspected ongoing design verification activities, including the implementation of appropriate QA programs. Most of the above audits will be completed prior to fuel loading and reports will be provided to the NRC. "

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NRC is PERPETUATING ' CONFUSION AND PROCEDURAL COMPLEXITY'IN ITS HEARINGS by failing to combine low. and full-power license proceedings into a single one for Diablo Canyon. according to Commis-sioner Victor Gi!!nsky. Gilinsky's comment was attached to a Dec. 23 commission order that denied an inter-venor's request for a hearing on extension of Pacific Gas & Electric's suspended low. power license. In the .,

same order, the commission responded to a request for advice by telling the Diablo Canyon licensing boards to handle intervenor motions to reopen hearing records with a " business as usual approach."

Gilinsky was disappointed, according to informed sources, that thei commission did not take the oppor-M~ tunity to simplify this particular hearing process. NRC could have directed the boards t ' o " collapse" tuch re> -

-~

o quests into one hearing process, one source said "The problem with Diablo Canyon is that the whcle process has gotten mixed up. The procedures made sense a year and a half ago, but not anymore. If the boards decide 9

[ to scopen the hearing records the same issues are going to be raised at both proceedings," he said. The only reason not to meld the two proceedings into one is the possibility that PG&E could gain a few weeks of oper.

ating time by keeping them separate, said Gilinsky Other NRC, and PG&E, sources disagreed. Delaying formal consideration of Diablo Canyon's low power license until NRC is prepared to considerits full-power license could delay startup of the plant by as much as D a year, they said. "We would have to deny PG&E their request for a low power license and force them to sit {s y-idly by,with their finished plants unto a full power license decisiors is madel* an NRC source said. '

The Atomic Safety & Licer. sing Appeal Board withjurisdiction over the motion to reopen the low. power proceeding last week relieved the Atomic Safety & Licensing Bo:rd of responsibility for considering the mo-( tion. As a result, both proceedings would be conducted by the appeal board ifit decided to grant the inter- -

senors' request to reopen the record. According to NRC staff, however, nothing is likely to happen untD the commissien reviews the independent desien verification program still being conducted by Teledyne Engineer-p at Diablo Canyon (Inside NRC,13 Dec. '82,13) .

NRC WON'T EXEMPT REPLACEMENT PARTS NOW IN STOCK FROM OUALIFICATION RULE i The NRC commissioners vo.ted Jan. 6 to issue a final endronmentc) qualificction rule for electrical 4;;; .t.cxtending the compliance deadline and acceptin; a s:sfirecommendation that equipment to

.-% edd shutdown need not sneet the ru': g t!.!s ilme. Ilme.r.er, t! e comrds?!on reh-cted a 5:: fiaro. _ _ _ _ _ _ _ _ _ _ _