ML20136B293
| ML20136B293 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, 05000000 |
| Issue date: | 03/12/1982 |
| From: | Cloud R ROBERT L. CLOUD ASSOCIATES, INC. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20136B092 | List:
|
| References | |
| FOIA-84-293 P-105-4, NUDOCS 8601020510 | |
| Download: ML20136B293 (86) | |
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,i ROBERT L. CLOUD ASSOCIATES, INC.
125 UNIVER$1TV AVENUE BERKELEY. CALIFORNI A 94710 E 415 8 641.9296 a
P 105-4 March 12,1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda; Maryland 20114 -
Dear Mr. Denton,
Robert L. Cloud Associates will issue the ninth progress report on the Seismic Verification Program on Monday, March 15, 1982.
Yours truly, W
ko r R. L. Cloud cc: Distribution List RLC:1j s Fo th L93
) (s 3601020510 851125 i
LEICHTOB4-293 PDR
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DISTRIBUTION LIST r
Pz. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20114 Attention: Mr. Hans Schierling, Program Manager
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Mr. George Maneatis Senior Vice President l
Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Mr. Roy Fray Pacific Gas and Electric Company 215 Market Street San Francisco, California 94106 Mr. R. F. Reedy, President R. F. Reedy, Inc.
236 N. Santa Cruz Avenue Los Gatos, California 95030 Mr. Carl O. Richardson, Jr.
Assistant Engineering Manager
-Stone & Webster Engineering' Corporation 245 Summer Street Boston, Massachusetts 02107 O
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C R. F. REEDY, INCORPORATED 236 N. Santa Cruz Avenue
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Los Gatos, Caltfornia 95030 = (408) 354-9110 March 8, 1982 3@@MU\\V/[s 3 I
s WRI01982 125 University Avenue i.@ T U.... _.. [#-
Robert L. Cloud and Associates, Inc.
7.
4.'T241 r m."h" Berkeley, CA 94710
Subject:
Report of R.
F.
Reedy, Inc.
Review of Pacific Gas and Electric Company
Dear Mr. Cloud:
Attached is a copy of our Quality Assurance Audit and Review report of Pacific Gas and Electric Company (PGaE).
We have reviewed the Quality Assurance Program as it related to seismic safety-related design performed prior to June, 1978.
The 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.
V ly yo s
Rog F.
e dy, P.E.
R.
REEDY, INC.
RFR : mc.
Encl.
cc:
Mr. Harold Denton l
Roger F. Reedy, P.E. - Engineering Cn.nulting
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QUALITY ASSURANCE REVIEW AND AUDIT REPORT PHASE I 4
h By:
R. F. REEDY, INC.
4
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On:
SAFETY-RELATED ACTIVITIES PERFORMED BY PACIFIC GAS AND ELECTRIC PRIOR TO JUNE, 1978 4
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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 Scope:
On February 23, 1982 R..F. Reedy, Inc. completed 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 PG&E Quality Assurance Program prior to June, 1978 with particular emphasis on activities that could affect seismic related design.
The baseline for this review and audit were the-requirements of 10CFR50, Appendix B.
PG&E Activities:
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:
This Quality Assurance Review and Audit of PG&E addressed
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the requirements of 10CFR50, Appendix B with selected parts of ANSI N45.2.ll being considered for guidance.- Follow-up items were introduced that evolved from 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 meetings; 2.
Quality Assurance Manual and Procedure
- review, and, 3. Audit of program implementation.
Steps 2
and 3 were performed to detailed checklists, and a 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 Qdality PG&E - March 8, 1982 2/89
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e Assurance, Design-Drafting, Mechanical, Civil, Electrical, and Engineering Services.
The Chief Engineers -and other persons from these groups were met to discuss review and audit
- approach, 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 review was completed on Jan.
30, 1982 at R.
F. Reedy, Inc. offices.
Revisions of the Manual between 1970 and 1978 were reviewed along with applicable implementing procedures.
The 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 three parts:
Part A:
General Requirements and Management Control of Quality Assurance Part B:
Design Control Part C:
Follow-up. Questions from Supplier Audits.
Procedures and documentation were examined to ascertain program coverage.
Where procedural coverage.was not in
- place, the design documentation was used for determining if positive though informal controls were practiced.
Documentation examined was from design activities performed prior to June 1,
1978.
Later activities are to be separately covered in the Phase II review.
Completed-checklists from Parts A, B, and C are included in Appendix C
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to this report.
==
Conclusions:==
1.
The PG&E Quality Assurance program for design work was not adequate in areas of
- policy, procedures and implementation.
The Quality Assurance organization had insufficient program responsibi,lity.
2.
A general weakness existed in internal and external interface and document controls.
This ' questions whether appropriate design information was being exchanged and utilized by design groups and consultants.
PG&E - March 8, 1982 3/89 m
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One concern is.if the latest Hosgri seismic data was inputted for design analysis.
3.
The design verification program was not formalized and was inconsistently implemented and documented.
This included major gaps in design overviews of the design approach for mechanical and other equipment.
Findings Programmatic Deficiencies:
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 determining QA requirements.
2.
PGaE had no procedure for assuring the completeness of the QA program to address the requirements of 10CFR50, Appendix B.
3.
There were no provisions for
' document control of correspondance and design documents.
4.
During Phase I, there were no controlled procedures for design control, design interfaces and design responsi-bilities.
PRE-9 and PRE-10 on these subjects were released in 1979 and are to be audited during Phase II.
5.
PG&E did not require design consultants to implement
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Quality Assurance requirements.
6.
Corrective action provisions were not addressed except with respect to audit deficiencies and deficiencies at the site.
7.
Indoctrination and training were not addres' sed in the QA Manual or procedures.
8.
The QA Manual contained no provisions for PGaE management review of the QA program for status and adequacy.
Implementation Deficiencies:
1.
PG&E management did not review and assess the effectiveness of the Quality Assurance Program.
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No documentation was available to verify that PGaE reviewed the QA program to show that all requirements of 10CFR50, Appendix B were addressed and met.
o Management-Review committees 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.
o A'
program review by Energy, Inc. for.an ASME N-
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stamp (December 22, 1975) lists many of the same '
findings that were found during.this Phase I
Review.
2.
The PG&E audit system and corrective action system were not effective.
o Audit reporting and follow-up was not timely.
Reports were issued sometimes three or four months after the audit.
o Corrective actions for.
audit findings were ineffective in that the same findings were found during later audits.
o Corrective action verification was by re-audit only.
o Formal corrective actions were not invoked on the engineering groups.
3.
Design consultants were' not required to implement Quality Assurance Programs.
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o Blume had first contract to require Quality Assurance in late 1977.
o Responsible" engineers did not document Quality Assurance requirements for purchase specifications on consultants, as required by the Quality,
Assurance Manual.
o The Quality Assurance group did not review the Quality Assurance Programs of design subcontractors-prior to mid-1977.
PG&E'- March 8, 1982 l
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WYLE was not contractually required *to have a i
Quality Assurance Program until Dec.
1, 1979.
o ANCO was not contractually required to have a Quality Assurance Program until May.1978.
4.
PG&E design verification on in-house activities and
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suppliers was unstructured and applied inconsistently.
We consider that design verification consists of the following three elements:
1)
Design overview for design approach, methods, design input selection, and assumptions.
2)
Detailed checking of design steps and completed design documents.
3)
Verification of approved "As Built" condition against approved design.
Activities for element 3 were not initiated until 1979 and are to be reviewed during Phase II.
Documentation 4
showed detailed checks to be performed on PG&E work with design overviews being performed on a selective basis.
Most of what PG&E refers to as Design Reviews consists of element 2.
o Comprehensive overviews and detailed checks were performed by EDS on Class I electrical design, some HVAC, and structural items.
Design overviews were not evident for mechanical designs.
PG&E did not require design contractors to perform o
design reviews of their own work.
o For the majority of cases
- reviewed, design verification criteria were not defined and were dependent on the discretion of the reviewing engineer.
l o
Documentation of design verifications was inconsis-tent and at times incomplete.
5.
-There was no effective document control system
. established.
o Design interfaces internally and externally were PGLE - March 8, 1982 6/89 I
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not effectively controlled.
Various organizations sometimes had different revisions of 'the same documents.
o Identification and control of support drawings was inadequate.
There were cases where different versions of the same drawing revision were in use.
o Engineering groups considered the Fosgri design criteria in the FSAR as a controlled document, which it was not.
o There was no effective method for controlling the Hosgri seismic data which was distributed within PG&E and to design consultants.
o Historical copies of some procedures and manuals revisions were not available.
. o The construction drawing list (January 1982) was not accurate for some of. the support drawings which were checked.
o Approval signatures were' not entered on support
- drawings, but approvals were in the calculation package.
o There was no evidence that all revisions of supplier test plans, procedures and reports were reviewed by PG&E.
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PG&E - March 8, 1982 7/89
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APPENDIX A AUDIT ATTENDANCE LIST PG&E - March 8, 1982 8/89
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- -l ATTENDANCE LIST FOR INTRODUCTION MEETINGS 12/17/81 12/18/81 W. S. Gibbons R. F. Reedy, Inc.
x x.
P. J. Herbert R. F. Reedy, Inc.
x x
.b
.R. F. Reedy.
R. F. Reedy, Inc.
x x
P. Chen R. L. Cloud & Assoc.
x x
E. Dennison.
R. L. Cloud & Assoc.
x C. Ralston PG&E x
W. Raymond PG&E x
J.-Rocca PGEE x
C. Eldridge PGEE x
J. McCracken PGGE x
x R. Bettinger
~PG&E x
E. P. Wollack PG&E x
J. McCann PG&E x
A. Lomas PGEE x
M. Cunley PG&E x
E. Kahler PG&E x
G. H. Aster PGEE x
J. R. Herrera PG&E x
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ATTENDANCE LIST l
AUDIT INTERVIEWS 1982 l
Name Company 2/2 2/3 2/4 2/5 2/9 2/10 2/11 2/12 2/16 2/17 l-l W. S. Gibbons R.F.
Reedy,Inc.
x x
x x
x l
P. J. Herbert R.F.. Reedy,Inc.
x x
x x
x x
x i
R. F. Reedy R.F.
Reedy,Inc.
x x
x x
x x
l Q
R.
F.
Petrokas R.F. Reedy,Inc.
x x
x x
x l
F.
Zerebinski PG&E x
x x
x x
x x
x x
x i
T.
deUriarte PG&E x
x x
~ x x
x D. O. Brand PG&E x
x E. P. Wollak PG&E x
x D.
Smith PG&E x
D. L.
Polley PG&E x
H. J. Hansen PG&E x
x R. M. Laverty PG&E x
x T. N. Crawford PG&E x
F. J. Dan PG&E x
E.
R. Kahler PG&E x
W. Vahlstrom PG&E x
x J. E. Herbst PG&E x
x x
x P. Antiochos PG&E.
x x
M.
D. Tresler PG&E x
x C. M. Li PG&E x
g J. Ante PG&E x
x x
R. Breed PG&E x
O. Rocha PG&E x
G. Tiedrick PG&E x
P. Hinschberg PG&E' x
C. Coffer PG&E x
R.
B.
Lew PG&E x
J. Bulanda PG&E x
S. Skidmore PG&E x
J. Hoch PG&E x
. PG&E - March 8, 1982 10/89 i
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ATTENDANCE
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s EXIT LIST
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INTERVIEW t
W. S. Gibbons
,,_o!g2any PG&E i
AT C
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R. F. Reedy R. F. Reedy, In M
1 P. J. Herbert R. F. Re dy, Inc J. R. Herr Cogpany c.
T. G.'deUriart e
R. F. Reedy, In D. A. Brand PGEE J. W. Colw ll era e
PG&E c.
e Dnn Brand PGEE' J. J. McCunn PG&E I
R. M. Laverty PG&E J. V. Rocca PG&E J. E. Herbst PGEE E. Denison PG&E i
F. 2erebinski PG&E J. B. Hoch R. L. Cloud E. R. Kahler PG&E G. H, Moore PG&E
& Assoc.
i
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R. S. Breed PG&E M. R. Tresler PGEE
\\
D.-L. Polley
.PG&E G. H. Aster PG&E W. A. Raymond PG&E E. P. Wollak PG&E I
i C. E. Ralston PGGE PG&E 1
R. V. Bettinger PGGE PG&E I
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APPENDIX B PROGRAM REVIEW CHECKLIST e
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PG&E - March 8, 1982 12/89 l
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R. F.
REEDY, INC.
PROGRAM REVIEW CHECKLIST ORGANIZATION:
PG&E Co.
ADDRESS:
77 Beale Street
- San Fraticisco, CA 94106 QA PROGRAM
REFERENCE:
- QA Manual, January 1970
- QA Manua'1,'Rev.
3', Apr'il 15, 1974 REVIEW CONDUCTED BY: W., k Gibbons @ DATE:
1/30/82 REVIEWED BY:
_DATE:
Z TE:
/ V DATE:
- Through Manual Change No 36 (4/24/78):
Volume I Policy Volume II -
Quality Assurance Procedures NO. OF PAGES:
22 i
PG&E - March 8, 1982 l
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PROGRAM REVIEW CHECKLIST January 30, 1982 2ROTECTt Diablo Canyon
Subject:
I Oroanization (Ann. r)
Page 1 of 3 PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO.
REFERENCES 1.
n e applicant shall be responsible OMt Authoriza-x
' Applicability of W1 to Unit 1 is not for the establishment and execution tion clear in that (W11ev. O and 3 Authoriza-of the quality assurance prn3 ram, tion Statement addresses Unit 2 only.
We applicant any delegate to FSAR Chapter 17 (17.0 Quality Assurance) others, such as contractors, agents p.17.0-1 states (W1 would also be used or ccusultants, the work of estab-for Unit 1 to the extent possible. FSAR lishing and executing the quality Amendment 14, 17.1.1, July 1974, states assurance program, or any part "PG&E... Units 1 and 2, established a thereof, but shall retain responsi-quality assurance program for design, bility therefor.
construction and startup of the plant which controls PG&E's activities and the activities of suppliers and contrac-tors."
2.
W e authority and duties of per-QAM 2.0 (Rev.0)
X Project Engineer is also Chief Mechanical sons and organizations performing Engineer... " coordinates engineering activities affecting the safety-activities within the Engineering and Con-related functions of structures, struction Departments...". Coordination Q
systems, and cmponents shall be is not clear in absence of controlling clearly established and delineated procedures until PRE-9, Design Responsi-in writing. % ese activities bilities and Interfaces (issued 6/18/79) include both the performing func-and PRE-10, Design Control (issued tions of attaining quality cbjec-6/18/79) - (note, these dates exceed tives and the quality assurance June 1978.)
functions. W e quality assurance functions.are those of (a) assuring that an appropriate quality assur-ance program is established and effectively executed and (b) veri-fying, such as by checking, audit-ing, and inspection, that activi-
.PG&E - March 8, 1982 ties affecting the safety-r' elated 14jgg functions have been correctly performed.
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t PROGRAM REVIEW CHECKLIST l
j-6 January 30, 1982
'ROJECT: Diablo Canyon
Subject:
I Organization (Apo B)
Page 2 of 3 PROGRAM AND ITEM i
RE'UIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS Q
NO.
l REFERENCES i
1
'Ihe persons and organizations per OAM 2.1.1 and j
X*
Independence of OA not established in i
V fonning' quality assurance functicos 2.1.2 I
I OAM Rev. O as OA (Quality Engineering) shall have sufficient authority and is responsibility of VP Engineering in OAM organizational freedom to identify until 6/9/72. VP Engineering is also quality problems; to initiate, responsible for design (2.1.3). OA for i
reconraend, or provide solutions; and construction is covered by assignment of j
to verify inplementation of solu-OA engineers to site by Director of Quality t
tions. Such persons and organiza-Engineering who reports to VP Engineering.
l tions perfonning quality assurance OAM change 21, 6/9/72, recognizes organiza-functions shall report to a manage-tional change which established a Director nent level such that this required of Quality Assurance reporting to the Senior authority and organizational free-VP (who is responsible for both Constnic-dam, including sufficient indepen-tion and Engineering).
dence from cost and schedule when opposed to safety considerations, OAM Rev. O and Rev. 3, 2.1.2:
"'Ihe Section are provided.
(Quality Engineering Section and Quality Assurance Department) will carry on its
- j. y function largely by conducting periodic
]
audits."..." insofar as possible, audits j l will be conducted by individuals who have j
had no close connection with the function s
of being audited.
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- Until 3/1/72. when reorganization was
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effected.
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l PROGRAM REVIEW CHECKLIST January 30, 1982 3RO.TECT: Diablo Canyon
Subject:
I Ortianization l App. B1 Page 3 of 3 PROGRAM AND
' REQUIREMENT I
PROCEDURE YES NO N/A REVIEW COMMENTS O.
I REFERENCES 4.
...the individual (s) assigned the 2.0 X'
After 6/9/72 0V1 revision..
y responsibility for assuring effee-tive execution of any porticn of tw quality assurance program at any location where activities subject' to this Appendix are being performed shall have direct access to such 3
levels of mnagement as rnay be necessary to perfonn this functicxt.
A i
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PROGRAM REVIEW CHECKLIST January 30, 1982 2ROJECT: Diablo Canyon
Subject:
II Program (App. B)
Page 1 of 3
PROGRAM AND
- gg REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES 1.
'Ihe applicant shall establis'h at QAM 3.1.1 X
Sch I, 1. (p.1) i a,
the earliest practicable time, con-
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l l
V sistent with the schedule for accan-i X
Repires written procedures. QAM does plishing the activities, a quality not relate inplementing procedures I
assurance program which cmplies witi to specific requirerents of 10CFR50, l
the requirements of this Appendix.
Appendix B.
l
'Ihis program shall be documented by I
written policies, procedures, or instructicas, and shall be carried out throughout plant life in accor-dance with those policies, proco-dures, or Instructions.
l l 2.
'Ihe applicant shall identify the OAM 1.2 X
Itm s classified as Design Class I.
I structures, systems, and ccrrponents l
to be covered by the quality assur-PRE-12 X
Rev. 0 (7/17/70) classification of ance program and the nujer organiza-Structures, Systems and Ccnponents, requires tiens participating in the program, Project Engineer to establish classifications.
together with the designated func-V tions of these organizations.
PRE 12 refers to PRP 4 X
PRP 4 - Suppliers / Contractors Ouality Assurance Requirenents aoplies for imposing quality requirements.
i
.PG&E - March 8, 1982 17/89 s
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. i PROGRAM REVIEW CHECKLIST g
k MOJECT: Diablo Canyon
Subject:
II Program (Aop B)
Page 2 of 3 I
PROGRAM AND l
-REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS
'D*
REFERENCES 3
The quality assurance prograsa PRE-12 X
i Addresses classification of structures,
- f. j shall provide control over actiiri-l systems and cm ponents.
ties affecting the quality of the I
identified structures, systems, and umpsts, to an extent consistent I
with their inportance to safety.
I 4.
Activities affecting quality X
Construction is contracted, shall be acca plished under suitably controlled conditions. Conditions I
include the use of appropriate l
equipnent; suitable environmental l
conditions for m 11shing the j
g activity, such as arkw-te clean-l ness; and namwance that all pre-requisites for the given activity have been satisfied.
1he program shall take into OnM 3.3.6 X
(X) construction is contracted.
l Q.
account the need for special con-OPM addresses requirements.
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trols, processes, test equipment, tools, and skills to attain the I
i required quality, and the need for
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verification of quality by inspec-lf tion and test.
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PG&E -- March.8, 1982 l
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PROGRAM REVIEW CHECKLIST January 30, 1982
- ECT: Diablo Canyon
Subject:
II Program (App. B)
Page 3 of 3 l
FROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COFDfENTS 20.
REFERENCES 6.
'Ihe program shall provide for-X IIob addressed in W41.
indoctrination and training of per-l l
l tb : included until PFM-4 (12/3/79),
V sonnel performing activities affec-f Training of Personnel.
ting quality as necessary to assure that suitable proficiency is achieved and maintained.
7.
Ihe applicant shall regilarly WJ4 2.1.2 X
'Ihe Director Quality Engineering review the status and adequacy of
...is to review continually the QA the quality assurance program. btin-Program and to report on its adequacy agenent of other organizations par-and the extent to which it is being l
ticipating in the quality assurance carried out. 'Ihere is no requirement program shall regularly review the for PG&E management to revic'.e the Quality status and adequacy of that part of Assurance Program..
j the quality assurance program which tley are executing.
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i PROGRAM REVIEW CHECKLIST January 30, 1982
'ROJECT: Diablo Canyon Subje t: III Design Centrol (Ano. B)
Page 1 of 5
l FROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO.
REFERENCES 1.
obasures shall be established to QAM 3.2.1 X
assure that applicable regulatory
,b '
requirments and the design basis 7 PRE-4 X
Soccifications, as defined in Para. 50.2 and as specified in the license applica-OAM 3.2.2.1 tion, for those structures, systems PRE-3 X
Drawings.
and emp_m.ts to which this Apperdix applies are correctly QAtt 1.4 X
Procedures to be in other Volumes.
translated into specifications, drawings, procedures, and instruc-tions.
2.
These measures shall include provi-OAM Rev.'0 sicns to assure that appropriate and Rev. 3, quality standards are specified and 3.2.1 X
Engineering responsible for.
included-in design docments and that deviations frcxn such standards PRE-2 are controlled.
(7/17/70) g 3.3.2 X
Memorandum of Design Criteria includes Quality Assurance Paquirments.
OAM 3.2.2.3 PTM-3 Monconfor-rances and Corrective Action X
Addresses design chanqes.
PRM-3 (issued 2/1/78) - addresses depar-tures frcrn approved requirements....
design.
PG&E - March 8, 1982 20/89
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PROGRAM REVIEW CHECKLIST Diablo Canyon
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Sub ject: INI Design Cbntrol (Acp B)
REQUIRE, MENT I
PROGRAM AND I
l January 30, 1982 RROCEDURE Fbasures rAall also be est bli REFERENCES YES I
Page 2 NO N/A of 5
for the selection and review f i
a shed 1
I REVIEW COMMENTS b/
suitability of application of OW 3.2.4.1 or X
t:uterials
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processes,that areparts, equipnent, and PRE-2 ttructures, systanssafety related functions of theessential to the Design Devel-.
Addresses subject.
opnent
, and ca:ponents.
k Ibt addressed.
.' j X
PRE-6 t
Ccnprehensive
[
the identification and contibasures shall be established f 1
Design Review X
or tion mong participating desidesign interfaces and for coo di rol of OMt 3.2.4.1 Not addressed.
X r
na <
PRE-2 organizations.
For soecifications only gn i
Design 1
f DevelopTnt I
X
- j PRE-3 ij.
Drawing Prep-Assigns to Responsible Engi h.
neer.
aration
(
\\
Review a,nd i
I Approval
)
X Pesponsibil-Not adequately addressed g
PRE-9 Design "j,
ities a d Interfaces k
n g
X First issue e s 6/18/79 n
e g
i D
l
.PG&E - March R
'a"^
f PROGRAM REVIEW CHECKLIST January 30, 1982 i
'ROJECT: Diablo Canyon
Subject:
III Design Control (Arp. B)
Page 3 of 5
FROGRAM AND REQUIltEMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO.
REFERENCES establishcent of procedures ammg I
f f,
Requires procedures, but procedure 5.
'Ibese reasures shall include the EM 3.2.3 X
PRE-9 not issued until 6/18/79.
D participating design organizations See 'III5 4.,.above, for the review, approval, release, distribution, and revision of docu-nents involving design interfaces.
6.
'Ibe design centrol reasures shall
%M-3.2.2.2 X
Inadequately addressed.
provide for verifying or checking the adegaacy of design, such as by PRE-2 the performance of design reviews, (3.2.5) by the use of alternative or sinpli-Design Devel-fied calculational rethods, or by opuent X
Only checking of calculations.
the perforunnee of a suitable test-ing progra:n. 'Ihe verifying or PRE-3 checkirs process shall be performed Drawing Pre-by individuals or groups other than
- paration, those who performed the original Review and y,
design, but who may be frcra the same Approval X
3.5.2 - Responsible Engineer may waive organizatico, checking at his discretion.
PRE-6, Cmprehensive Design Peviewa X
"Suoervising Engineers are responsible for selecting structures, systens and ccrnponents which require cmpre-hensive design reviews..." rather than for all Class I items.
PG&E - March 8, 1982 22/89
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PROGRAM REVIEW CHECKLIST January 30, 1982 ECT riablo Canyon
Subject:
TTT Desion Centml (Aro. B)
Page 4 of 5 FROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS i
I REFERENCES 1
j l st.\\Afy the adequacy of a specific
%here a test progra:n is used to ver-K Not addressed.
design feature in lieu of other verifying or checking processes, it shall include suitable qualifica-ticns testing of a prototype unit ur.3er the rest adverse design condi-ticns. Design control measures shall be applied to items such as the followirg: reactor physics, ctress, thermal, hpiraulic, and accident analyses; ccrpatibility of materials; accessibility for inservices inspection, maintenance, and repair; and delineaticn of acceptance criteria for inspections arxl tests.
k./
PG&E - March 8, 1982 23/89 O
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4 J
Dirblo Canyon PROGRAM REVIEW I.
Subject:
CHECKLIST REQUIREMENT III Desian Ocrit sFROGRAM AND
. Design
'FROCEDURE 1 (AnN B) l 1 W, changes, including field REFERENCES YES
.t Page 5 i
NO shall be N/A of 5
.Jontrol rneasures thase spplied to the o isubject to design (AM 3.2.2.3 REVIEW I
1 design and be approved bccanmensurate with X
COMMENTS r ginal jization that performd thy the organ-Only requires design kngineer and Supervising Ereferral to Re y tes anotherunless the applicant desig
~*
e original PRE-2 review responsible organiza-Design Devel-
' don.
and written pproval.ngineer for a
s opnent j'
X PRE-3 Does Drawing Prep-not address
(
subject.
aration 4
BeView,nd F.
a Apprwal I,
1 X
t.
/'.
3
~
Specificatio AMresses for PG&E dra i i
Preparation,n w ngs.
'\\
Review and Approval 1
X PRE-10 h
Design h3 dresses for pec
~I s
Control changes.
X Issued 6/18/79 2
e
- s' 4
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/PROGRAMREVIEWCHECKI.!ST January 30, 1982 ROJECT: Diablo Canyon
Subject:
TV Procurment Doctznent Cbntrol (Arn. B)
Page 1 of 1
PROGRAM AND REQUIREMENT
/ PROCEDURE YES NO N/A REVIEW C0tDtENTS D
50.
f REFERENCES
/
i 1
M3asures shall be established to
)
07413.2.4 and l
assure tlut aplicable regulatory
/
3.2.5 X'
Adequately addressed.
l D
reg h ts, design bases, and
, other require ents which are nece-ssary to assure adequate quality are suitably incitx3cd or referenced in documents for procurment of cater-ial, equi rent, a:xl services, 1
whether purchased by the applicant or by its contractor or st6contrac-tar.
2.
'Ib the extent necessary procurenent OMt 3.2.5.1 X
Adequately addressed.
documents shall require contractors or snhmntractors to provide a qual-PRP-4 ity assurance pr%tas consistent Sumliers/
with the pertinent provisions of Contractors this Appendix.
OA Ps@ssas X
Addresses Suppliers and Contractors -
y for equiarent and field contractors.
Does not include specifically consul-tants until Rev. 3 (9/15/78).
l l
- PG&E - March 8, 1982 l
25/89 i
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PROGRAM REVIEW CHECKLIST January 30, 1982 103ECT: Diablo Canyon
Subject:
IV Instructions, Procedures, and Drawincs (Arc. B)
Page 1 of 1 PROGRAM AND
~
REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS O'
REFERENCES
- 1. -
Activities affecting quality shall OAM 1.4 and sm ;had by <b' e ted instruc-O m 3.1.1 x
j Requirement for procedures prescribed si be D
'tions, procedures, or drawings of a and are contained in Supolemental type appropriate to the circisnstan-Voltnes.
ces and shall be m lished in accordance with these instructions, procedures, or drawings.
2.
Instructions, procedures, or draw-Om and PIM-1 ings shall include appropriate or Quality Assur qualitative acceptance criteria for ance Program defamining that important activi-Control X
% ese do not address thic requirement, ties have been satisfactorily however, it is included in the speci-m lished.
fic _vrucedores.
L V
PG&E - March 8, 1982 26/89 t
a
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t PROGRAM REVIEW CHECKLIST l
January 30, 1982 2ROJECI: Diablo Canyon
Subject:
VI Document Control (749. B)
Page 1 of 1 PROGRAM AND j
REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS 0.
REFERENCES I
1.
!basures shall be established to 3.1.2 X
Fequirment addressed.
control the issuance of docunents, V
such as instructions, procedures, ON4 3.2.3 i
i and drawings, including changes Written pro-thereto, which prescribe all activi-cedures are ties, affecting quality.
required to control cor-respondence,
- drawings, specifica-tions,...etc.
PRE-5 Correspon-X Never issued.
dance Control 2.
'Ihese neasures shall assure that OY{ 3.1.2 and documents, including changes, are 3.1.1 X
Requirements addressed.
y reviewed for adequacy and approved for release by authorized personnel, Ovi 3.6.2 X
Audit programs will examine adequacy and are distributed to and used at of procedures....
the location where the prescribed activity is performed.
.3.
Changes to documents shall be Ovt 3.1.1 X
Original reviewer aspect not speci-reviewed and approved by the sane fically stated in ON4 for procedures, organizations that perforned the however, it is incitxicd in PRE-3, original review and approval unless Drawirgs..., and PRE-4, Specifications....
the applicant designates another responsible organization.
.PGSE-March 8, 1982 27/89 e
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PROGRAM REVIEW CHECKLIST bIControlofPurchasedMaterial, January 30, 1982 dECT: Diablo Canyon
Subject:
Ecmirunent, and Services (App. B)
Page 1 of 3
' PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES
- X Addresses equignent supoliers and field Measures shall be established to OAM 3.2.1
.C - cssure that purchased material, OAM 3.2.4 j
contractors. Does not address design equipnent, and services, whether QAM 3.2.5 censultants.
purchased directly or through con-tractors and subcontractors, conforn PRP-1 to the procurement docunents.
Suppliers Pre-Award Quality Survey and Evaluation (PRP-1 Rev.3, 9/15/78, re-vised to in-clude services in supplier definition)
PRP-4 Suppli-ers'/Contrac-tors' Quality
.,.Q Assurance Pro-grams.
PRP-5 Qualified Bidders List PRE-7 Sugplier Bid Review and Award PRE-8 DH Preparation and Release PG&E - March 8, 1982 28/89 i
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PROCRAM REVIEW CHECKLIST
/
.VII Control of Purchased Material,-
ang 0, h82
-- OJECT: Diablo Canyon
.Subjectt EcNibnent, and Services (App. B)
Page 2-of 3 PROGRAM AND 4
j REQUIREMENT PROCEDURE YES NO N/A ~
REVIEW COMMENTS 0.
REFERENCES s,
%ese measures shall include provi-See.1,
,.?, j siens, as appropriate, for source.
above and Objective evidence of quality covered
~
o evaluation and selection, objective OAM 3.3.9 X
i evidence of quality furnished by in PRP-4.
i the contractor or subcontractor,
~
inspection at the contractor or subcontractor source and examination t
s of products upon delivery.
~
Doctsnentary evidence that material',
X To this Phase I, work.
_ l and equipnent conform to the pro-i curement requirements shall be
~
available at the nuclear power-plant... prior to installation or 1
.use of such material and equipnent.
Wis doctanentary evidence shall be retained at the nuclear power plant i
...and shall be sufficient to iden-t
] {.tify the specific requirements, such as codes, standards, or specifica-i tions, met by the purchased material and equipnent, t
1 I
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l PG&E - March 8, 1982?
l 29/89 3
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..h PROGRiM REVIEW CHECKLIST VII Control of Purchased Material, ROJECT: Diablo Canyon
Subject:
Fxtuirxrent, 'and Services (Aco. B)
Page 1 of 1 PROGRAM AND
- NO.
REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES
~4.
'1he effectiveness of the control O m 3.2.5 g of m ality by contractors shall be Om 3.6 j
' arxsssed by the applicant or desig-O m 3.6.2 X
nee at intervals. consistent with Covered by PG&E Surveillance and audits, I
the importance, emplexity, and States: " Audits will be apolied to PG&E'
~
s quantity of the product or cervices.
own organization, as well as consultants, contractors, and sug liers."
1 i
i
.1.
a 1
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PG&E - March 8, 1982 30/89 e
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..ggem -. -
PROGRAM REVIEW CHECKLIST January 30, 1982 2ROJECT: Disblo Canyon Subj ct: XVI Corrective Action (App. B)
Page 1 of 2 PROGRAM AND REQyIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS REFERENCES 1Q Measures shall be established to OPM jX l
Addressed for nonconformances, I
assure that conditions adverse to deviations, discrepancies, defici-quality, such as failures, malfunc-encies, etc.,
tions, deficiencies, deviations, defective material and equipnent, and nonconformances are prcnptly identified and corrected.
2 In the case of significant condi-OAM 3.2.5.3 tions adverse to quality, the mea-and 3.3.5 X"
Addresses corrective action for sures shall assure that the cause Suppliers and Contractors of the condition is determined, and corrective action taken to preclude PRC-12 repetition.
On-Site Discrepancies X*
Addresses corredive action to preclude repetition for
-site discrepancies.
C QAM 3.6.2 X*
Mentions correc
- .'e action for audit program results.
- Corrective action provisions are not prescribed except for those cases noted above.
- PG&E - March 8, 1982 31/89 b
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PROGRAM REVIEW CHECKLIST January, 30, 1982
\\2. of 2 Subjects, XVI Corrective Action (App. B)
Page
- ROJECI: Diablo Canyon PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS NO.
REFERENCES 3..
%e identification of the signifi-OAM 3.6.3 X
See items 1. and 2., above.
" Audit y
cant conditions adverse to quality, reports forwarded to a.ppropriate the cause.of the condition, and the management officers."
corrective action taken shall be documented and reported to appropri-ate levels _ of managcrnent.
V PG&E - March 8, 1982 32/89 I
1
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'.,,8 l
- 1 PROGRAM REVIEW CHECKLIST l
January 30, 1982
! ) JECT: Diablo Canyon
Subject:
XVII Quality Assurance Records (App. B)
Page 1 'of 2
'M
{*
REQUIREhENT PROCEDURE YES NO N/A REVIEW C0bOENTS REFERENCES n
Sufficient records shall be main-tyM 3.5 X.
diresses overall requirenents.
r O tained to furnish evidence of activj-ties affecting quality.
?RE-14 Engineering Release X
Addresses for */ c.;hased equipment.
PRP-4 Supplier / Con-tractors OA Programs X
Addresses for QA Programs of Suppliers /
. Contractors.
4 l
No soecific procedure addresses records (prior to June 1978).
'Ihe reco'rds shall include at least See 1., above the following: Operating logs and b.theresultsofreviews,'inspcctions tests, audits, monitoring of work performance, and materials analyses
'1he records shall also include-l closely-related data such as quali-fications of personnel,. procedures, and equipnent.
Inspection and test records shall, See 1., above.
as a minimum, identify the inspec-1 tor or data recorder, the type of l
observation, the results, the acceptability, and the action taken 4
nection with any deficipncies PG&E - M 8,
1982 i
4 m
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PROGRAM REVIEW CHECKLIST January 30, 1982 r LTECT: Diablo Canyon
Subject:
XVII Quality Assurance Records (Aco. B)
Page 2 of 2 PROGRAM AND PROCEDURE YES NO N/A REVIEW COMMENTS REQUIREMENT REFERENCES i
Records shall be identifiable and See 1., above.
{
t
}
" I' retrievable. Consistent with appli-l
' cable regulatory requirements, the applicant shall establish require-ments concerning record retention, such 'as duration, location, and assigned res[xmsibility.
l PG&E - March 8, 1982 2
34/89 i
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PROGRAM REVIEW CHECKLIST I
January 30, 1982 t
I Page 1 of 1
'ROJECT: Diablo Canyon
Subject:
XVIII Audits (App. B)
PROGRAM AND REQUIREMENT PROCEDURE YES NO N/A REVIEW COMMENTS.
0.
REFERENCES 2
- 1. _
A ccmprehensive system of planned
.OAM 3.6 X.
Prescribes applicable requirements.
and periodic audits shall be carried PRM-2 Audits I
Does not provide specific frequency 6
out to verify ccmnliance with all
.of Quality l
l
- considerations are: "The audit aspects of the quality assurance Assurance Pro-should be conducted early enough so program and to determine the effec-grams that any necessary corrective action tiveness of the program.
can be taken in a timely and efficient manner."
- 2.
'Ihe audits shall be perfonned in See 1.,above.
accordance with the written proce-dures or check lists by appropri-ately trained personnel not having direct responsibility in the areas being audited.
- 3.
Audit results shall be documented See 1.,above.
and revieml by managment having responsibility in the area audited.
.4. V.'
~
Follow-up actlon, including reaudit X
Follow-up within 10 days by Quality i
of deficient areas, shall be taken Engineering in PIN-2 Rev. O.
Changed where indicated.
to "prmptly" in Rev. 1 (3/15/77).
pG&E - March 8, 1982 35/89 1
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. 3 i
O C>
APPENDIX C PART A GENERAL REQUIREMENTS AND MANAGEMENT CONTROL OF QUALITY ASSURANCE i
I l.
PG&E - March 8, 1982 36/89
a
. t AUDIT CHECKLIST Pacific Gas & Electric Company Page 1 of 19 Ccspany l
Applicable QAM Rev.'O thru-Rev. 3 Auditor WSG Date February 2-23, 1982 s.
B.
Statement
' Audit Instruction Comment I
Such persons and organiza-(a) Determine project organ-(a) Historical copies of organ-tions performing quality as-
.ization and specific person-ization charts were not
(/
surance functions shall re-nel in effect for time per-retained as QA records.
port to a mangement level lod (pre-June 78) by review Reviewed the charts that were such that this required auth-of objective evidence.
made available (earliest was ority and organizational 1/13/70) and other documents freedom, including sufficient to verify existence of project independence from cost and organizational structure.
schedule when opposed to Responsible engineers were safety considerations, are identified in discipline provided (10CFR50, App. B).
group lists issued as memoranda It may be possible to establish 2.1.2
... Responsibility for execu-the precise organization in 4
tion and implementation of effect at a given time, but i
the Quality Assurance. Program this would require a. detailed is assigned to both the Vice review of memoranda and was President-Engineering and not done for this audit.
Vice President-General Con-struction...The Vice President.(b) Verify for quality en-(b)
Until March 1982 Quality 5 '.
-Engineering has primary gineering and quality;assur-Engineering, which had respon-responsibility for dcsign...
ance that the job functions sibility for total quality (and) is also responsiale for and relationships described program, was part of engineer-3 development and coordination include sufficient indepen-ing and reported to same i
j of the Quality Assurance Pro-dence from cost and schedulc engineering Vice-President.
1 gram.
considerations when opposi-During this time Quality j
tien to safety considera-Engineering was not independent i
2.1.2 Has authority to stop work if tioas may arise.
of Engineering.
Reorganization L
(a)p8 technical and regulatory in March 1972 created Quality t
requirements are not being Assurance Department reporting j
- observed, to the Executive Vice-President I
PG&E - March 8, 1982 37/89 i
~.
AUDIT CHECKLIST Company Pacific Gas & Electric Company Page 2 of 19 l
i Applicable QAM _ Rev. O thru Rev. 31 - t Auditor WSG Date February 2-23, 1982 App. B.
QAM Statement Audit Instruction Comment Crit.
Re f.-
which was independent of Engineering and Construction.
(2)
Some of the Field QA Engineers were loaned from Engineering to QA for temporary assign-ments to the field.
(c)
Verify that Quality (c)Not applicable tx) Phase I.
personnel performing verifi-cation actions (Tests, In-spections, etc.) have auth-ority and organizational freedom to identify quality problems, initiate, recom-mend or provide solutions to problers; verify imple-mentation cf solutions, and control further processing on-of nonconformances until (J'
proper dispositioning has occurred.
4 (d)' Was work stopped by (d)
It was stated that QA QE/QA manager?
stop-work in the field had not been documented and that stop work had not been applied to engineering work.
i i
PG&E - March 8, 1982 l
38/89
~
s----
4 i
AUDIT CHECKLIST Ceapany Pacific. Gas & Electric Company Page 3 of 19 Applicable QAM Rev. O thru Rev. 3 Auditor WSG' Date February 2-23, 1982 Ap B.
Q Statement Audit Instruction Comment 2.1.3.1 Each Department Chief is re-(a) Determine how this was (a) Was to be performed by sponsible for... Development accomplished.
Responsible Engineer via
,s N a/
of quality assurance require-Procedure PRE-2 which required ments for all vital compon-a Memorandum of Design Criteria ents... Review and approval of These Memoranda were not ade-quality assurance programs quately developed; however, developed by others.
for procured equipment appro-priate OA requirements were invoked; for subcontracted design services they were not.
2.1.3.4 Project Engineer:
Coordina-(a) Determine how this was (a) -In the absence of con-tion of all engineering acti-accomplished.
trolling procedures coordina-vities with other departments.
the Project Engineer.
The tion was at_the discretion of Project Engineer distributed all correspondence as he deemed necessary.
In addition, Responsible / System Engineers
\\.'
were responsible for. inter-faces with other affected disciplines.
Memoranda were reviewed that did list which engineer and discipline were to be involved, but these memoranda were not in a con-trolled system.
PG&E - March 8, 1982 I
39/89 N
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1 AUDIT CHECKLIST Company ~ Pacific Gas & Electric Company Page-4 of 19 Appli:able SAM Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982 Ap. B.
Statement Audit Instruction Comment
.i 2.1.4 The Vice President-General (For information) t Construction is responsible
(,f for administration and man-agement of plant construction test, and startup, including full responsibility for all quality assurance aspects included in these activities
...the Manager, Station.
Construction... Plans for and implements field quality, control... Evaluates contrac-tors.. The Project Superin-tendent ( 's)... responsibility include (s)... Administration i
of construction contract, including the quality assur-ance provisions.... Review and approval of contractor's kw/
quality control ~ programs...
Also on the Project Superin-
.I tendent's staff and reporting i
directly to him is the Coor-dinating Quality control Engineer...the responsibili-ties of a Resident Engineer
, include... Direction of qual-ity control activities...
approval...of. quality control plans... Supervision of Inspec-tors.
PG&E - March 8, 1982 2
40/89 t
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AUDIT CHECKLIST Company Pacific Gas & Electric Company Page 5 of 19 Applicable QAM Rev. O through Rev. 3 Auditor NSG Date February 2-23, 1982
~
Statement Audit Instruction Comment 3.2 5.2 On-site surveillance is po -
Review for evidence of on-Not applicable for Phase I.
f formed by the Station Conl site surveillance by the I D struction Department.
Inspection Section.
3.2.5.3 The surveillance ~representa-Review reports of surveil-Not applicable for Phase I.
tive confirms on a continuing lance by Inspection Section, basis that the supplier's or contractor's sytem is adequato to assure that quality work will be accomplished.
II 3.1.1 The Quality Assurance Program (a)llow did program assure (a) No formal method (matrix, requires that written pro-procedures were developed etc.) was used to assure com-cedures be used in all key for all key activities.
prehensiveness of procedures activities... periodic audits to 10CFR50, Appendix B require-
... provide objective assur-ments.
Audits were relied ance of both the adequacy of upon to assure adequacy of the procedures and compliance procedures.
Audit reports were with them.
(S reviewed that did include evaluation of a given procedure for adequacy.
It was stated that in 1974-1976 an audit had been performed for compar-ison of the program to Appen-dix B requirements.
This audit.was not reviewed because there are clear pro-cedural gaps in the program all the way through this Phase One review.
PG&E - March 8, 1982 41/89 i
e
e AUDIT CHECKLIST Company Pacific Gas & Electric Company
.Page 6 of 19 Applicable QAM Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982 AM Ap(B.
Statement Audit Instruction Comment II 3.1.1 cont.
(b)
Verify that quality as-(b)
See (a)'above.
d surance audits provided ob-jective evidence of the ade-c r.
quacy of the procedures, as well as compliance with i
them.
(See XVIII)
.?
3.6.2 Audit programs will examine (c) Verify that the follow-(c)
Received PRE-6,"Rev. 0 (1) the adequacy of proce-ing procedures existed and and PRE-ll, Rev.
O.
Record dures and practices, and (2) are available:
copies of other procedures the compliance with estab-were not located during this lished procedures.
PRM-1, Rev. O audit.
PRE-1, Rev. O PL_, 6, Rev. O PRE-ll, Rev. 0
- PRE-12,.Rev. 0 PRE-13, Rev. 0 PRP-4, Revs. O, 1, 2
-b.
PRP-5, Rev. O PRC-ll, Rev. 2
. PG&E - March 8, 1982 1
42/89 e
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4 AUDIT CHECKLILT Company Pacific Gas & Electric Company Applicable QAM Rev. O thru Rev.
1 3
Page 7 of 19 Auditor WSG 8*
l^,"
1 i
Statement Date February 2-23, 1982 Audit Instruction II i
3.6.2 Comment-cont.
" (g/
1 (d)
Prior to PRE-9'and PE i
i 10, what proce,dures applieE-(d) d existedNo formal procedures to interface control and design control?
PRM-1 The Director, QA, will nain-4.0 QA manuals.tain a list of those holding (e) a Verify distribution to identified Project person-(e)
Could not verify, as nel. -
1.2 records are not available
...These items are classified earlier than 1979.
as Design Class 1.
The Pro-(For information) gram will be applied to any g
particular component o
or structure in a man,ner and system its importance in preventito the extent appropriate to tk
- v of a nuclear accident.or mitigating the consequencea ng
' ?,
j l'
3.2.1+
...The Project Engineer is PRE-12 structures, responsible for identifying (a). Determine how these systems and com-items were classified and (a)
Program was applied via ity Assurance Program,ponents covered by the Qual-designated, and how the i
Classification of Components extent of application of Systems and Structures issued he Program was determined, t
by Project Engineer.
eviewed, and verified.
r f
Veri-led by review of April 13,
?
1 972.
(DCPE-1), Project I
Engineer Instruction No.
istribution shown was D
1.
ac ceptable address ser.. Listing did not vice contractors.
~~
4
.PG&E - March 8, 1982 43/89 d
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)
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.f AUDIT CHECKl.1ST I
4 Page 8 of 19
{'
Company Pacific' Gas & Electric Company Date February 2-23, 1982 r
Audi tor ' WSG Applicable QAM Rev. O thru Rev. 3 i
Comment.
Audit Instruction i
App. B.
GAM Statement Crit.
Ref.
The program shall provide for (a) Verify that trainirfg (a)
Could not verify -
i 1
j indoctrination and train $ng and indoctrination proc rams no proqcdur,e-existed.
j
(,j of personnel performing acti-were conducted and documen-
~
1 l
vities affecting quality as ted (prior to PRM-4, i
necessary to assure that 12/3/79).
i suitable proficiency is achieved and maintained.
(b) Verify that effective-(b)
Could not verify.
ness of training programs (10CFR50, App. B.)
was audited and docum'ented.
j
3.3.2 Policy
Train' field person-(a) Verify that the status (a)
It was stated that I
nel for proficiency in spe-and adequacy of the PG&E QA/QE Director gave verbal cial skills required by as-quality assurance program status reports to Executive was regularly reviewed and Vice-President.
There was signed duties.
that the reviews were ade-no objective evidence of Items for incorporation as quately documented.
management reviews for i
3.6.2 status and adequacy.
A part of these audit programs report:" Evaluation Report-include the following as Pacific Gas and Electric 2
\\/
applicable... Familiarity of Quality Assurance Program",
j personnel.with required 12/22/75, performed by documents... Effectiveness of Energy Incorporated to deter-j training programs.
~
certificates, was the only 4
The applicant shall regularly evidence provided to docu-i review the status and ade-ment a management type of i
quacy of the quality assur-review.
This did present l
0 ance program.
Management of to PG&E management many of other organizations partici-the~same findings as deter-pating in the quality assur-mined by this Phase One revew..
ance program shall regularly Several management commit-l.
review the status and ade-tees (e.g., CONPRAC) were i-I quacy of that part of t,he chartered to provide a quality assurance program PG&E - March 8, 1982 l
which they are executing
~
44/89 (10CFR50, App.D)
~
AUDIT-CHECKLIST
.,i Ccmpany Pacific Gas & Electric Company Page 9 of 19
[
Applicable QAM Rev. O thru Rev.
3"'
Auditor WSG Date February 2-23, 1982
^
. Statement
- i
' Audit Instruction Comment II 3.3'.2 i'
r 3.6.2 4
M, '
2.1.2 Report on its adequacy and management review, but (p.6) the extent to which it is review of their minutes showed,
- cont, being carried out (Director, that they were only for QE,OA).
operational considerations for the llumbolt and Diablo projects.
(b) Review evidence of (b)
These and other commit-review by General Office of tees only reviewed opera-Nuclear Plant Review and tional considerations, not Audit Committee.
design and construction.
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.PG&E - March 8, 1982 I'
45/89 i
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_. _.~. _
4 f
i AUDIT CHECKLIST 1
1 Page 10 of 19 Itoepany Pacific Gas & Electric Company Date ' February 2-23, 1982 Rev. O thru Rev. 3 Auditor WSG.
Applicable.QAM Comment
- Audit Instruction App. B.
GAM Statement
}
6 Crit.-
Ref.
t I
-(a)
QA requirements not
.IV 3.2.5.1 Specific requirements for (a)
Do any of these requir o (h f' suppliers' and contractors' ments apply to subcontrac-initially imposed on design quality assurance are con-ted designers or consul-consultants.
EDS imposed tained in the following ap-tant?
If yes, verify that their QA. program themselves, plicable documents which are they were included in appli-Responsible Engineers did' either appended to or made a cable procurement documents not document QA requir,ements part of the specification or If no, determine what qual-for these contracts. Ini-other purchase documents....
ity assurance requirements tial PG&E reviews for QA j
Supplementary Specification were imposed.
Determine whenrequirements started in l
for Manufacturer's Quality quality assurance require-1977 with alternate QA Control Systems...Contrac-ments were imposed on sub-requirements specifications
{
tor's Quality Assurance.Re-contracted designers or such as AQAP-51, EO-C-0, quirements... Supplier quality consultants by PG&E.
etc., URS/Blume's first contract that required QA 3
requirements for some compo-was in 1977, but a complete 4
nents or work, where the implemented program cannot above documents would be in-be verified by objective j
appropriate are either in-evidence until 1979.
WYLE
(.-
cluded in'the specification was contractually required or in additional documents.
to apply QA from 12/1/79.
These provisions require the' ANCO was contractually re-supplier to use appropriate quired to apply QA from 5/78.
1
}
quality control systems to HLA was not contractually assure that th4 technical re-required to apply ~u?.
EES quirements are being met...
was contractually required to Equipment suppliers are re-quired to prepare and submit apply QA in March, 1977 (in accordance with their their quality assurance pro-i grams for review and approval proposal of. February 1977).
a
... Field contractors are re-quired to prepare and submi't i
their quality assurance man-PG&E - March 8, 1982 l
uals and inspection and test 46/89 plans for review and approval l'
l
e oi AUDIT CHECKLIST Company Pacific Gas & Electric Company Page llofl9 Applicable QAM Rev. O thru Rev. [,,
Auditor WSG Date February 2-23, 1982 Ap[.B.
Statement
' Audit Instruction Comment IV 3.2.4.3 The Responsible Endi'neer re-(a) Verify that the Respon-(a) No objective evidence ceives a copy of'the purchase sible Engineer documented for quality-related require-( '.
order after issuance and is his approval of the techni-nents.
required to confirm that the cal and quality-related technical and quality control requirements of purchase requirements are correct.
orders for subcontracted design and consulting ser-vices.
(b) Was Quality Assurance (b) Only for equipment pur-i Engineering involved in the chase orders.
QE/QA was not review of purchase orders brought into involvement in to ensure inclusion of appli
-design consultants contracts cable quality assurance re-until late 1977.
quirements?
3.1.2 The procedures developed to (a) verify that such a (a).No means was available.
control documents include...
means of determining the Q ',$
a menas by which persons status of documents was involved in the work can available.
verify that a copy of a docu-ment which they hold is an (b)
PRE-1, Rev.
O, Project (b)
It was stated that they
~
up-to-date and complete copy. Sngineer function referenced could not reach agreement on PRE-5, Correspondence Con-procedure.
trol, from 6/30/70 until l
9/2/75.
Why was PRE-5 never issued?
1
.s J'
i PG&E - March 8, 1982 47/89 NNhmW --
. m ge sw ege s
s
~
AUDIT CHECKLIST Company Pacific Gas & Electric Company Page 12 o69 Applicable QAM Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982 AP Statement Audit Instruction Comment VII
,3.2.4.]
Lists of technically quali-(a) Was Quality Assurance (a)
Ye2 for-equipment
.(,
fled suppliers for equipment Engineering involved in t:1e suppliers.
Not until 1977 specifications are developed review of the programs of, for design consultants.
by the Responsible Engineer equipment suppliers, design and reviewed and approved by subcontractors, or con-t the Materials Department...
sultants?
Qualified bidders' lists for construction contracts are (b) What policies were es-(b)
It was stated that developed by the Manager, tablished by the Vice Pres-PRP-5 Rev. 0 (6/70) was Station Construction, and re-ident of Engineering with used.
A record copy of this viewed and approved by the regard to bidder evalua-procedure was not available.
' Materials Department... The tions?
Verify that they Review of PRP-5, Rev.
l-Responsible Engineer reviews were followed.
(4/25/72) showed it to be of the program the equipment little value for this review,-
1 suppliers intend to follow to and then further view for this meet the specified quality checklist item was stopped.
I control requirements... (The) recommendation as to which (c) How does the Station (c) Not applicable to Phase
(_)
bidder should receive the Construction Department I.
award...is approved by the verify that contractors' Responsible Engineer's super-proposals have adequate vision in accordance with quality assurance provi-policies established by the sions?
l Vice President-Engineering...
i For construction contracts, the Station Construction De-partment evaluates the con-tractors' proposals and pre-pares the recommendation for i
award.
PG&E - March 8, 1982 48/89
AUDIT CHECKLIST
~
-i.
Company Pacific Gas & Electric Company Page l3 of 19 Applicable GAM Rev. O thru Rev. 3 Auditor WSG Date ' February 2-23, 1982 B.
Statement Audit Instruction Comment VII 3.2.5.3 The PG&E surveillance repre-(a) What criteria does the (a)
Not applicable for Phase sentative... brings major PG&E surveillance repre-I review.
d problems to the attention of sentative use to determine the supplier's or contractor' awhen problems are major and management and the Responsibl ishould be brought to the Engineer, and in these cases attention of the Responsible it is required that the cor-Engineer?
rective action be approved by the Responsible Engineer.
(b)
Verify that corrective (b) 'Not applicable for Phase action was. approved by the I
review.
Responsible Engineer.
(c) Was Quality Assurance (c)
Not applicable for Phase Engineering involved in I
review.
subcontractor surveillance?
e,D PG&E - March 8, 1982 f
49/89 i
\\
ne
a AUDIT CHECKLIST Coppany Pacific Gas & Electric Company Page 14'of 19 Applicable QAM Rev. O thru Rev. 3 Auditor NSG Date February 2-23, 1982 App. B.
QAM Statement Audit Instruction Comment Crit.
Ref.,
r VII
3.3.1 Policy
Execute the on-site (a) Verify that inspection (a)
Not applicable for Phase
(,
quality control necessary tb activities were recorded in I
review.
support the PG&E Quality As-daily logs, surance Program...Each field engineer or inspector is as-(b)
How did the supervision (b)
Not applicable for Phase signed an individual structure determine the extent of in-I
- review, and/or item of work for which spection that was necessary '
he is responsible for verify-Was Quality Assurance En-ing compl*ance with Engineer-gineering of the Responsi-ing design and specification:
ble Engineer involved in Only the latest drawing infor-that determination?
mation is used.
Either PG&E or contractor prepared quali-(c)
How did the field (c)
Not applicable for Phase ty procedures are used for ex-engineer or inspector know I
review.
amination of che work...A re-that he had the latest port of the examination re-drawing?
sult is prepared, dated and signed by the inspector and (d)
Who determined what (d)
Not applicable for Phase
()
forwarded to his superior.
If procedure to use for the I
review'.
lack of compliance is evident, work?
How was that docu-the matter is immediately ta-mented?
ken up with the responsible contractor for correction.
Upon completion of the work, including correction if re-quired, the report is filed.
Daily logs are maintained to provide a history of activity and continuity of work.
In-spection is performed to the extent deemed necessary by PG&E - March 8, 1982 the supervision, taking.into 50/89 account the subject matter, records kept, design and specification, and criticality of the nystem.
~
.l.
s AUDIT CHECKLIST Ccwpany Pacific Gas & Electric' Company Page 15of l9
]
t t
Applicable QAM Rev. O thru Rev.'3 Auditor WSG Date February 2-23, 1982
. B.
M Statement'
-Audit Instruction Comment j
e
(
f il VII Documentary eviddnce that Verify that the designs, a n-See Part B Checklist.
f3 6
material and equ'ipment co,nform alyses, tests, and qualifi
\\d/
to the procureMdht 'requi're-cations subcontracted by ments shall be available at PG&E were actually per-the nuclear power plant...
formed, received, and re-prior to installation or use viewed by responsible PG&E of such material and equipment. personnel to verify con-This documentary evidence formance to the specified shall be retained at the procurement requirements.
j nuclear power plant...and shall be sufficient to identi-fy the specific requirements, j
such as codes, standards, or specifications, set by the I
purchased material and equip-I ment. (10CFR50, App. B)'
l The effectiveness of the co'n-Verify that design subcon-Initiated in late 1977.
Was
!(
trol of quality by contractors tractors' and consultants' not fully effective until shall be assessed by the appli-quality assurance programs' 1979.
cant or designee at intervals were surveyed and audited consistent with the impor-at intervals consistent witl tnace, complexity, and quality importance, complexity, and of the product or services, quality of service.
(10CFR50, App. B)
?
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PG&E - March 8, 1982 j
51/89 1
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ii..
i AUDIT CHECKLIST Ccmceny Pacific Gas & El'ectric Company Page 16 of l9 Applicable GAM. Rev. O thru Rev. 3 Auditor WSG Date February 2-23, 1982 B.
Statement Avdit Instruction Comment i
a XVI Measures shall be established Prior to issuance of PRM-3 Corrective action program was to assure that conditions ad-(2/1/78), what measures were linited to audit findings and g
verse to quality, such as established to. identify.and si1:e discrepancies only, failures, malfunctions, de-control conditions. adverse ficiencies, deviations, de-to quality.and obtain cor-fective material'and equip-rective action to prevent ment, and nonconformances are recurrence?
Verify that promptly identified and cor-these measures were fol-rected.
In the case of sig-lowed and that corrective nificant conditions adverse actions were effectively
+
to quality, the measure shall implemented, assure that the cause of the condition is determined, and corrective action taken to preclude repetition.
The identification of the signi-ficant conditions adverse to quality, the cause of the i
~
- i,j condition, and the correc-tive action taken shall be documented and reported to appropriate levels of manage-ment. (10CFR50, App. B)
'PG&E - March 8, 1982
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AUDIT CHECKLIST i
, j Cocptny Pacific Gas & Electric Company Page 17 of 19 I
t
- Applictble QAM Rev. O thru Rev. 3 Auditor WSG Date February'2-23, 1982 1
t i App. B.
QAM Statement Audit Instruction Comment
'-Crit.
Ref.
XVIII 3.6.-14 The Director, Quality Engineer--(a) Review audit schedules (a ) ' Audit schedules reviewed PRM-2 ing, is responsible.for making for planning.
(1969 - 1978) and were compre-j 4..
\\U) planned periodic audits of hensive.
I design, procurement, supplier and contractor quality control (b)
Verify that all aspecto(b)
Quality Assurance / Quality
[
construction, start-up, rec-of the quality assurance Engineering were not audited.
[
]
ords, training programs, and program were audited, in-Reviewed audit reports from j
1 personnel and procedure certi-cluding Quality Assurance April 1970 through March 1978.
fication functions as they Engineering.
relate to the Quality Assur-Audit scope and coverage was
[
i acceptable.
ance Program... Members of I
i audit teams will-not have (c)
Verify that audits (c)
Some. audits did cover direct responsibility in the evaluated adequacy of pro-adequacy of procedural subject
{
5 4
area of being audited.
cedures.
area being audited.
- However, audits did not assure total J
2.1.2
... Engineers assigned to the Quality Engineering Section program adequacy of 10CFR50, l
will be experienced in plant Appendix B requirements.
{
! J(],
design and construction and (d) Verify that auditors (d)
OA auditors were indepen-familiar with the quality re-were independent of the arei dent.
Reviewed engineers
)
j quirements of the project...
being audited (especially temporarily assigned to audits l
i j
Personnel assigned to the for engineers assigned to and concluded they were suffi-2 Cuality Engineering Section auditing).
}
will be experienced engineers ciently independent of specific specially chosen for their activity being audited.
L j
knowledge and judgement.
In-
[
i sofar as possible, audits will
[
i be conducted by individuals i
who have had no close connec-tions with the function bein~g j
audited.
[
f PG&E - March 8, 1982
{
I 53/89 2
1
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)
1 P
1 i
AUDIT CHECKLIST i
Company Pacific Gas & Electric Ciompany Page 18 of 19.
4 i
r 4
Applicable QAM Rev. O thru Rev. 3,,
Auditor.
WSG Date February 2-23, 1982 2
l' l
1 AE f
Audit Instruction Comment Statement f
i l
j XVIII 3.6.1+
j i
-. j PRM-2 l
)
C,' 1 2,1,2 1
cont.
(e)
Verify that auditors (e)
Auditors training and
{
j were properly qualified and qualification was not documen.
i trained.
ted until Procedure QAPD17.1
[
j Rev.
O, was issued June 1977.
l Qualifications for eleven 1
auditors who. performed audits from 1970 to 1978 vere re-4 j
qu'ested, only two were docu-mented.
i (f)
Verify that audit re-(f)
Audit reporting was not j
sults were issued within 10 timely.
Generally, the 10 days and were reviewed by day results requirement was responsible management, not met.
Many of the audit reports were formally
,'(
transmitted to management three months after the audit.
There was no docu-
{
mented evidence of the (appropriate)Vice-Presidents' j
review of audit reports sent 4
{
to them.
l i
i i
PG&E - March 8, 1982 i
54/89 l
i l
4
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_ _ _ _ _. _.. _.. _. _ _ _ _ _ _ _ _ _ _ _ _ _. _. _, _. ~
9 AUDIT CHECKLIST i
Company Pacific Gas & Electric Company Page 19 ofl9
\\
Applicable QAM Rev. O thru Rev. 3 Auditor WSG
'Date February 2-23, 1982 App. B.
QAM Statement Audit Instruction I
Crit.
Re f. -
Comment l
XVIII 3.6.1+
.. h PRM-2
\\i) 2,1,2 cont.
(g) Verify that follow-up (g)
Review of audit reports' l
action and timing including shows that corrective action 5
reaudit of deficient areas, by the audited group was was taken where necessary, ineffective.
The same subject areas are repeatedly audited with the same findings re-curring.
Audits of Design i
Reviews (PRE-6) performed from May 1972 through Feb-i ruary 1978 show that corrective action was ineffective.
The
)
same results apply to the Construction Drawing Index.
I \\)
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~
PG&E - March 8, 1982 55/89 i
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APPENDIX C PART B-DESIGN CONTROL
.=
PG&E - March 8, 1982 56/89
AUDIT CHECKLIST
\\ PART B Ctx:panY Paci.fic Gas and Electric Company Page 1 of 14 Applicable QAM Rev. O thru Rev. 3 Auditor R.
F.
Reedy & R.
F. Petrokas Feb. 3 -16, 1982 Date Statement Audit Instruction Comment 5111 I
3.2.1
'Ihe Departunt of Engineering is (For Information) y responsible for the preparation of desips and specificaticns...,'Ihis respcusiH11ty includes the specifi-caticn cf rjiality assurance require-ments.,,. ma nuality Assurance Pro-I gran recWits written procedures l
which an. ec r+-,it the regulatory re-quiremem - u rhe design bases are properly incorporated in the speci--
fications, drawings,. and the other desis doctuents prepared b Department of Engineering. y theA systan of design reviews is provided to verify that desi p s meet require-ments in all respects....Pespcnsi-ble Engineers develop design criter-3 La...Where design caanitments are b
raade in the PSAR or other filings before the Atcznic Energy Ccumission, they are incorporated into the desip....nuesticus in this area are referred for resolution to the Safety Analysis Report Group.
3.2.2.1 Using the. design criteria, the design inputs, and ccnceotual design as a starting point, design draw-ings are prepared, PG&E'- March 8, 1982 3.2.2.2 Specifications and purchase orders 57/89 are review d by thf Safety Analysis Report Group to confinn that the regulatory requiranents 'are properly incorporated.
~_
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AUDIT CHECKt.IST PART B Page 2 Of'14
. Company Pacific Gas & Electr$c Company Applicable QAM Rev. 0'thru 3 Auditor R.
F. Reedy & R. F. Petrokas Date Feb. 3-16, 1982 App. 8.
G A'M.
Audit Instruction Comment Statement...,...
Crit.
Ref.
f,,
(
t h,e h
PRE-1, I"'
i Revs.
1.
1, 2, !
The' Project Engineer is re-(a) Verify that the Project (a) Index and specification sponsible for preparation and Engineer prepared a Project stmary prepared as issuance of.the following:
Correspondence File Index required.
Project Correspondance File and a Summary of Specifica-Index tions.
g.
(b) Randomly select a mini- (b)
Items selected:
mum of 6 Class I items (2 1.MSIV*
M 8721 Summary of Specifications from each discipline, Elec-2.CCWHX M
8757 trical, Mechanical, and 3.EXP JTS M ~ 1160 Civil),from the Summary of
- 4. PIPING STS M
Specifications,for later 3.4.16 KV E
8805 use in verifying design 3.480 VMC CENT.
E 0738 n
criteria and engineering
- 7. EXII. VENT C/S8831 G,
releases were prepared per OUTDOOR TNK C/S8844 PRE-2 and PRE-14 (See Check _*HOSGRI ONLY list items 2 and 14
)
PRE-2, Para. 3.2.1 - Each assigned Verify that Design Criteria Design Criteria Memorandum 2.
Rev 3 engineer shall. develop and Memoranda were prepared were prepared only for the prepare'information which iden'for items selected in 1, piping systems.
Criteria tifies the specific functions above.
for equipment were i
to be performed by a struc-
,locumented in purchase ture, system,or component, specifications or by letter and'the specific values,or ar vendor reports, but no range of values chosen for Design Criteria Memoranda controlling parameters as ref-vere available for these erence bounds for des'ign...
i.tems.
PG&E - March 8, 1982 This information is'to be doc-i amented-by a Design Criteria 58/89 i
sfercorandum or similar docu-i ent.
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o AUDIT CHECKLIST Company PART B Pacific Gas & Electric Company Page 3 of 14 i
Applicable QAM Rev. O thru Rev. 3 Auditor R.
F.. Reedy & R.
F.
Petrokas
.Date Feb. 3-16, 1982 App. 8.
qAM Statement Crit.
Re f.
Audit Instruction Comment p P.E-3,
Para. 2.2-Re usible'Engin-For'the items selected in Prepared fob piping 3..
EUV* I cers are resporisi'til'e f'or:1) 1.,
above, verify written systems.
This requirement y.
providing written design cri-design criteria were pro--
is not applicable to other teria in ace'ordance with vided to the Design Drafting items which are designed PRE-2, " Design Development,"
Department.
by the vendors.
to the Design-Drafting Depart.
ment for the Development of Project drawings...
PRE-4 The. complete file of specifi-Verify that the specifica-Reviewed for selected Revs.
4' cations with all approved tion file for the items items.
Found no 1, 2 changes is located in the chosen in 1.,
above, is discrepancies.
Some Engineering Department Cen-complete.
tral Files.
piping design criteria in FSAR.
i 5*
- 3. 2. 2. 5 Design reviews are conducted (a) Verify that Design Re-by competent persons other views were performed, and (a) and (b) It&E's program than those who performed the by individuals other than addressed the above three elenents V
original design... Comprehe'n-those who performed the as followst sive reviews of Design Class I original design.
For element 3. "As Built,, veri-structures and systems as-
'fication, review work was initi-i sure that the necessary design (b) How were the necessary ated in 1979 and will be within steps have been taken, design s'teps determined and the scope of Phase II.
documented?. Verify that Element 2. Detailed checks were-NorrE the necessary steps were performed on IC&E designed items,
[
Verification should include 3 ele-taken.
ments:
such as piping systems and con-
- 1. Overview of design approach sultant's design reports.
methods, input selection and assump-Element 1. Design ' overview acti-tions.
- 2. Detailed, check of desigt} steps PG&E - March 8, 1982 vities were performed by ITS on nd complete design, 59/89 IG&E design items for Class I a
electrical designs and sce llVAC j
- 3. Verification of approved design and structural designs. No de-against "As Built" condition.
sign overview was documented for 1
l nochanical systems designs. The
u AUDIT CHECKLIST Company Pacific Gas & Electric Company Page 4 of 14 Applicable QAM llev. O thru llev. 3 Auditoril. F. Ilcedy & 11. F. Petrokas.
Da te Feb. 3-10, 1982
]
App. B.
G AM.
Statement Audit Instruction Comment
' ' ~
Crit.
Ref.,
'F"
- 5.,
system and procedures in place 4
l
'M"'
.4w I
ddH'ng' Phase'I'wouldnotassur${.
C
' cont.
I n.i-l that," required overviews were 'l constantly performed. The details and documentatior}.yf the reviews were left to'the i-judgment of the reviewing engineer.
4 s
b i
i i
PG&E - March 8, 1982 l
a 60/89 i
1
l 1
+
AUDIT CHECKl.IST PART B Company Pacific Gas & Electric Company Page 5 O f 14 Applicable QAM Auditor R. F. Reedy & R. F. Petrokas Date Feb. 3-16, 1982 App. B.
QAM' Statement Audit' Instruction Commen t Crit.
Ref.
PRE-6 Para. 3.1 - Comprehenside re-(c) Verify required design (c) Reviews performed on (d-Rev. O views of Design Class I struc-reviews for items chosen in consultant work and piping 5.
(?)
tures and systems shall be 1.,
above, have been per-con t.-
7/17/70 conducted to assure that the formed.
systems as discussed in (a) and (b).
design is complete and ade-quate, and confirm that the design bases have been pro-perly incorporated in the de-sign.
Para. 3.2 - The Responsible (d) Check reports for the (d) Reports were available Engineer or Lead Engineer will items chosen in 1.,above.
but in cases they were notify the Supervising Engin-uncontrolled or eer when the design is com-in mPlete.
NOTE: Final llosgri Criteria plete enough for a review t be conducted.
The Supervis-established May 9, 1977.
ing Engineer will then desig-(,
nate an engineer to conduct the review.
The design review will be conducted by a quali-fled engineer who has had no significant involvement in the design under review.
The reviewing engineer will pre-pare a report of his work, i
PG&E - March 8, 1982 61/89 l
1
,;. l J._. Ja a i t.,.
n
.ii AUDIT CHECKLIST l
PART.B i,.
Company Pacific rias and El'ectric i
Page 6 of 14 Applicable QAM Rev. O thru Rev. 3 Auditor R. F. Reedy'& R. F. Petrokas j Da te Feb. 3-16, 1982 APP. B.
GAM Statement Audit Instruc tion Comment Crit.
Ref.
5 PRE-6
~
4' Design reviews shall' consider (e) Verify existence of (e)
Review plan b.
cont. Rev* -0 as a minimum the design steps plan developed in accord..
developed only.for (7)
~
outdoor storage tanks outlined in Quality Assur-ance with PRE-6.(Note this 771777(
ance Procedure PRE-2, " Design requirement was deleted in (dated November 17, Development".
An-engineer-Rev. 1, dated March 15, 1977.: 1978).
See (a) and (b) conducting a review shall above.
make thorough-preparations and shall develop a plan to assure that all critical as-pects of the design.are.ex-amined.
Engineers conduct-g ing reviews shall also justi-fy why certain aspects, if any, were not considered. A
~
typical System Design Review Check List for. guidance in preparation of the design re-G, view procedure is attached.
PG&E - March'8, 1982 62/89 1
~
AUDIT CHECKl.IST Part B i
ompany Pacific Gas and Electric Canp sy Page 7 of 14 I
appticable QAM Rev. O tluu.Rev. 3 AuditorR. F. Reedy & R. F. Petrokas Date Feb. 3.-16, 1982 8*
Statement Audit Instruction comment 111
.n 6.
3.2.2.3 Design changes, including changes (a) Verify that design changes (a) Eesign changes were D
proposed by suppliers and contrac-wre approved by the Responsible approsed for all itons.
tors, are referred to the Responsi-Fagineer and his Supervising However, for supports approvals ble Fngineer and his Supervising Fagineer.
of the design change k gineer for review and written calculations were not traceable 5
approval.
(b) Verify that Design Reviews to the drawing (dra.vings not were perfonned to detennine the signed-off).
inpact of desi n changes cn the (b) Design changes were reviewed F
N original designs.
for impact.
((
p llowever, no review sign-offs (c) Verify that changes were were evid,ent for support PRE 11 reviewed for impact and change drawings.
to FSAR.
(c) There was no evidence of impact reviews.
(DCN's introduced in phase II control this activity.)
- f[
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I PG&E - March 8, 1982 63/89 i
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!o AUDIT CHECKLIST i
Part B l
company Pacific Gas and Electric Cm pany Page 8 of 14 Applicable QAM Rev. O thru Rev. 3 Auditor R. F. Reedy & R. F. Petrokas Date Feb. 3 - 16, 1982 AE j
Statement Audit Instruction Comment 6
'III i
V
- 7. i 3.2.2.2 Suppliers / contractors performing (a).How did PG&E ensure that (a) and (b) 'Ihe requirement l
design are also required to conduct suppliers / contractors conductx1 for design reviews was not design reviews.
design reviews? Verify that % &E inposed on suppliers. Any procurement documents required design reviews performed design reviews to be performed.
were done by PG&E for con-sultants design work.
i The Responsible Engineer does not (b) What criteria is used to check a supplier's design unless detern;ine the necessity of such there is reason to believe such a a review? Determine if any check is necessary.
such reviews were performed.
I i
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i 4
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I G&E - March 8, 1982 1
2 64/89 t
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lL AUDIT CHECKLIST j
CecpanY Pacific Gas and Electric' Oxmany l Page 9 of 14 acptictbte QAM Rev. O thn Rev. 3.
Audi tor R. F. Reedy & R. F. Petrokas.
Dat?Feb. 3-1G, 1982 App. B.
QAM Audit Instruction Comt.en t Statement Crit.
Ref.
IIT..
@3.
".2.4.1 The Resxnsible Engineer deyelops (a) Hcw does the Responsible En-(a) For purchased equipnent and the tec mical requirments and coor-gineer coordinate the interfac-pipirg systes the dinates the work done by interfacing ing engineers for work on speci-specifications were circulated engineers cn the specification, ficaticns?
via routing slips. There was no Draft specifications are reviewed by evidence of interface reviews for all engineers engaged in the desia;n (b)Were final soecifications' piping support specifications.
whose work might be affected by be reviewed with all the interfacing (b) Final specifications were equipment, and by other engJneers as engineers who made ccuments on circulated except for piping appropriate, e.g., traterial applica-the draft specifications?
supports as identified in (a) tlcns and quality assurance,,,,'Ibe above.
final specificaticus are reviewed (c) Verify that the final speci.
(c) All specifications were l
and sigped off by the Responsible fications were reviewed and approved as required except for L
Engineer, and the Department Chiefs approved by the Resnonsible supports as noted above.
Engineer and the Department l
- 011efs, fr
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PG&E - March 8, 1982 65/89 2
... ;;. r t
AUDIT CHECKt.IST PART B Page 10 of 14 Company Pacific Gas and Electric Ccnpany Applicable QAM Rev. O thru Re'. 3 Auditor R. F. Reedy & R. F. Petrokas Da te Feb. 3 -16, 1982 v
Statement i
Audit Instruction Comment App. B.
GAM Crit.
Ref.
l 3.2.2.2... Correspondence, construction (a) Uho detennines who may be (a) The Responsible Engineer
~
drawings, specifications, etc. are affected? What criteria are detennines who nny be affected on 9.
reviewed by Stpervising Engineers used in the detennination?
the basis of personal j
and others who may be affected in judgnent.
their principal respcosibility....
(b) Verify that corresponderv (b) Evidence exists to verify i
In additicn, the Responsible Engi-was reviewed by Suwrvisince that correspondence was reviewed neer reviews correspcodence received Engineers and the Responsi51e but no fonnat procedures were j
frcxn suppliers.
- Engineer, used.
(c) Review correspondence and (c) Evidence exists that doctrnentation to and from I1G&E correspondence was received, and AN00, URS/Bltune, EDS, EES, distributed and filed, but Ilarding-IAwson and Wyle for con. correspondence was not logged nor 3
trol and distribution, distribution controlled and i
documented.
j (d) Review drawing transnittals (d) Blume used design drawings to Blume for piping analysis for their analysis,
],
j worktodeterminewhether\\ design [
or as-builts were sent.
2 i
4 l
PG&E - March 8, 1982 l
66/89 I
i
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p--
AUDIT CHECKt.!ST PART B C mpany Pacific Gas and Electric Ccupany Page 11 of 14_
Applicable QAM Rev. O thru Rev. 3 Auditor R. F. Reedy & R. F. Petrokas Da t e Feb. 3-16, 1982 App. B.
QAM Statement Audit Instruction Comment Crit.
Ref.
III 3.2.2.2 Nhere a design is so innovative or Does the Supervising Engineer.
N 3t applicable - designs of
, 60.
has so many inter-related require-determine Waen a design is "so e ancern were not i
ments that independent review by innovative" or has " man innovative.
I individual engineers would not related reouirements"? y inter-hhat assure a conprehensive view, a criteria are used in the deter-review meeting is held with con-mination and how is it doctnens cerned engineers and the Responsi.-
ted?
ble Engineers. Situaticns recuir-ing this review are identi,fied by the Supervisin3 ngineers and it is F
their respcnsibility to call and c
ccnduct such meetings, b
PG&E - March 8, 1982 67/89
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i AUDIT CHECKLIST PART B Page 12 of ' 1,4 Company ' Pacific Gas and Electric Ocnoany Applicable QAM Rev. O thru.Rev. 3 Auditor R. F. Reedy & R. F. Petrokas Da te Feb. 3 -16, 1982 f
Statement Audit Instruction Comment A
8' i
illI 3.2.2.1 If changes are made later to the Verify that drawing changes we ce Drawing changes approved as i
- p drawing, they nust be designated in approved by the Responsible required. However as stated the change block and approved by Engineer or the Supervising En31.- previously, approval of support 17
- i the Responsible Engineer (the lead neer,priorto4/13/74,andby design is evident only on the gineer, and) the Supervising the Responsible Engineer, the design calculations. There are no Engineer. (Rev. 3,4/15/74).
Irad Engineer,and the Supervising approval signatures on or directly Engineer,after 4/15/74 traceable to the drawing issued.
i 3.2.4.3
...'Ihe Statim Constructim Depart-llow is it detennined whether the Evidence exists that the ment may edit the technical mater-Station Construction Department Responsibl.e Engineer was contacted j
12.
ial furnished in the B H, but any changes to technical material are for direction on station initiated changes of substance to the techni-editorial or technical, and who changes.
i cal material require anproval of thunakes that determination?
j Respcnsible Engineer.'
i
!L 1
)
i s
'PG&E - March 8, 1982 68/89
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p AUDIT CHECK 1.IST PART B Page 13 of 14 Company Ncific Gas & Electric Ow:*ny
^
~
Auditor R. F. Reedy & R. F. petrokas Date Feb. 3 -16, 1982 Applicable QAM Rev. O thru Rev. 3 Audit Instruction
. Commen t App. B.
DAM Statement Crit.
Ref.
PRE-13, Para. 2.1 (Rev. 1) The Supervisor, Verify. existence of Cbnstruc' ion Q
i 13.
Revs.
Records and Reproduction, of Design Drawing List.
1&2
-Draf ting Department is responsible for preparing and distributing a) Check that Construction Drawinga) The current list has been copies of the Construction Drawing List was kept up to date.
updated, but old lists are not kept.
List.
b) Verify that Construction Draw-b) Evidence indicates the Para. 3.2 (Rev. 2) The Construction ing Index supplements were is-List was regularly Drawing List will be reissued sued periodically, distritnted.
monthly.
c) Equipnent ddtwings for 4
c) Verify that applicable drawings Para 3.2.1 - Supplements to update for items chosen in 1., above, checked itms were verified the Construction Drawing Index will F.ppear on the Construction DrawinE to be entered correctly. One i;
be issued periodically, but at Mst.
support drawing was absent least every two weeks.
frcm list (support 48/17R) ttnd another support had 2
incorrect revision
+
2ntry.
O 1
i 4
j I
i PG&E ' March 8, 1982 69/89 4
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...........,......m AUDIT CHECKLIST PART B Page 14 of 14 Company..
Pacific Gas & Electric Cunpiny Applicable QAM.Rev. O thru Rev. 3 Auditor R. F. Reedy & R. F. Petrokas Da te Feb. 3-16, 1982 i
Audit Instruc tion Comment App. 8.
GAM Statement Crit.
Ref.
PR'E-14, PrIra. 2.1 - The assigned engineer Verify that engineering release I:ngineering Release Foms i
Rev. 1 is responsible for:
(1) initiating foms were completed for the vem conpleted for itans U"
the Engineering Release fom; (2) items chosen in 1., above.
verified.
14.
coordinating, if necessary, the review of all docisnents listed on -
i the fom; and (3) evaluating, ap-
[
proving, and forwarding the Engin-eering Release to his supervisor.
Para. 2.5 - The Manager, Station Verify, if possible, that re-Either Engineering Releases Construction, is responsible for leases were issued prior to in-or Manager Releases were used issuing Manager's Releases and sta11ation for the itens chosen as pemitted by the Program.
Field Installation Releases' and in 1., above.
(Note that supple-assuring that no Design Class I' ment to PRS-14 dated January 20, conponent is installed in the plant 1971, modifies this requirement without a satisfactorily conpleted under certain circumstances.)
Engineering Release, Manager's Release, or Field Installation Re-
.s lease. A Field Installation Re-lease may be used for listed Design Class 1 off-the-shelf.itens pur-chased by FG&E Engineering for which the quality can be verified after receipt.
PG&E - March 8, 1982 70/89 i
APPENDIX C PART C FOLLOW-UP FROM SUPPLIER AUDITS e
i A
PG&E - March 8, 1982 71/89 I
6 g
AUDIT CHECKLIST
]
Company WYLE/PG&E Design Control Interface Page of 7
7 s
I j
App'ticable QAM PG&E Auditor P. J. Herbert Date Feb. 2-17, 1982 I
App. B.
QAM Statement Audit Instruction Comment Crit.
Ref.,
3.1.2 Document Control J
Procedures are used to assure 1. Verify that PG&E used a Not Acceptable. PGEE did l (j that the latest approved procedure to assure that not establish their drawings, specifications' WYLE was issued and used Document Control Procedure procedures,-purchase orders' the correct HOSGRI data in PRE-5 and it was never and other documents are in establishing their Test issued.
the hands of personnel carry-Plan Report No. 26286.
1 ing out the work.
)
2.
Determine if PG&E can Not Acceptable.
PG&E could 7
verify what HOSGRI data not provide documentary was used by WYLE to. develop evidence to establish i
the Test Plan Report exactly what !!OSGRI data l
No. 26286.
was given to WYLE.
The Responsible Engineer stated that WYLE made copies of i
selected HOSGRI Data during j
meetings with PG&E, No documentation exists to
-kJ establish exactly what I!OSGRI Data WYLE received in this manner.
(a) On Nov. 25, 1981 PGLE requested by letter that WYLE "... document the Spectra you used to devel'op the RRS Plots... contained in your report No. 2G28G...and Ad-dendum...."
WYLE responded on Dec. 15, 1981 and pro-vided attachments but did PG&E - March 8, 1982 not establish dates in their 72/89 letter for the attachments.
(b) Inian internal pG&C memo O.
Steinhardt to J.
Ilerbs t
_ ~.., _. _.. -. _ _ _ _.. _ _.. _ _ _ _. _ _ _ _ _ _ -
.____.m I.
.t AUDIT CHECKLIST l
Compa*y WYLE/PGEE Design Control Interface Page 2 of 7 i
1
,Date February 2-17,.1982 Applicable QAM PGEE Auditor P. J. Herbert t
j App. B.,
GAM Statement Audit Instruction Comment Crit.
.Ref.
, 3
.I l { f g lt T Steinhardt dated 2-16-82 Mr.
1}
D l
('
' states'"In 1977...I made available...the currently applicable HOSGRI spectra...;
" Currently applicable" is nc i identified by Mr. Steinhardt.[
by date or any other trace-able characteristic.
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PG&E - March 8, 1982 73/89 i
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AUDIT CHECKLIST Company WYLE/PG&E Design Control Interface Page 3 of 7 i
Applicable QAM PGLE Auditor P.
J. IIerbert Date Feb.
2-17, 1982 B.
Statement Audit Instruction Comment 3.2.2.2 Supplier Contractor Designs Specifications require sup-Verify whether WYLE pre-WYL E prepared and submitted par d detailed test plans test plan (Report'No. 20286) ubm d
a ed t st p ans, and test procedures and and Addendum to this test etc., as the work progresses.
submitted them to PG&E as plan -- both were submitted the work progresses.
to PG&E for review and approval.
WYLE prepared test procedure No. 3642 and revisions A, B, and C to this procedure. The original procedure No. 3G42 and Revision A were submitted to PG&E and were approved by PG&E.
No records were available to verify whether Revisions B and C were sub-mitted to PG&E for review
,' ~
and approval.
The Responsible Engineer stated that he was in residence at WYLE when Revs. B & C were prepared during testing and he ver-bally agreed to the revisions but did not sign off as approving them.
' March 8, 1982 74/89 e
8
-... - -. ~ _ -.
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AUDIT CHECKLIST Caesumy WYLE/PG&E Design Control Interface Page 4 of 7 Applicable QAM PG&E Amfi tor '
P. J. Herbert Date Feb. 2-17, 1982 i
Statement Audit Instruction Comment t.
)
3.2.2.2 These documents are reviewed Verify that the Responsible Te'st Plan
)
by the Responsible Engineer Engineer or another engin-The Test Plan Report i
[]
an'd/or other engineers and eer' reviewed WYLE's Test Nc 26286 was reviewed returned to the supplier with Plans and Test Procedure fcr the Responsible Engineer comments and/or approval.
and. returned them to WYLE by Mr. O.
Steinhardt.
It i
either approved or with was returned to WYLE I
comments.
unapproved with comments l
requesting revisions to Figure 8, page 22 (Response Spectrum) for the Vital i
Relay Board.
l
}
WYLE prepared and submitted 4
Addendum to Report No. 26286, PG&E could not provide documentation establishing that Addendum 1 to Report No. 26286 had been reviewed to verify that WYLE in fact 4
(,)
nade the required revision 4
i to Figure 8.
A cursory check of the re-vised Response Spectrum in i
Figure 8 of Addendum 1 i
disclosed that WYLE had not
(
included all the requested changes.
+
Test Procedure i
Review and approval signa-PG&E - March 8, 1982 tures are in evidence for L
j 75/89 Test Procedure No. 3G42 and Revision A to this proced-j ure.
Review and approval l
AUDIT CHECKLIST
- Company WYLE/PG&E Design Control Interface Page 5 of 7 i
Ap;licable SAM PG&E Auditor P. J. Herbert Date Feb. 2-17, 1982 App. B.
QAM Statement Audit Instruction Comment
- i. Crit.
Re f.
- signatures are not in evi-dence*for Revisions B & C tb' thib procedure. '
(j (See previous comments concerning this' test pro-cedure.)
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PG&E - March 8, 1982 76/89 i
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AUDIT CHECKLIST Page 6 of 7 Comp:ny WYLE/PG&E Desir.n Control Interface Applicable QAM PG&E Auditor P. J. Herbert Date Feb.2-17, 1982 I
Statement Audit Instruction Comment
. B.
XVI Corrective Action Verify that Responsible 1.
WYLE NOD #3 Appendi x A
Pg.
Measures shall be estab-Engineer was cognizant of The Responsible Engineer
(/
lished to assure that con-WYLE Notices of Deviation provided a copy of NOD #3 and XVI ditions adverse to quality No.'s 3 and 4 which were it was written by WYLE on the such as failures, malfunc-not included in their Final Vital Relay Board Test for tions, deficiencies, de-Test Report No. 58255.
structural failure during viations, defective mater-testing.
Note the comm'ent ial and equipment, and above for Figure 8 of WYLE Test Plan Report No. 2G286 non-conformances are promptly identified and NOD #3 was shown to be incor-corrected.
porated in design documents but the system did not pro-vide evidence that the field implemented the change.
2.
WYLE NOD #4 The Responsible Engineer pro-vided a copy of NOD #4 and
(-
it was written by WYLE on the 4160 Switch gear for specimen failure during testing.
It was established that the 4160 Switch gear was redesigned by General Electric and new test procedures were prepared by GE/WYLE/PGEE and were reviewed and approved.
After the modified test spe-cimen of the 41GO Switch gear was satisfactorily tested.
PG&E - March 8, 1982 PG&E Engineering prepared 77/89 design drawings for field modification to other sections
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AUDIT CHECKLIST
! Coa.pany WYLE/PG&E Design Control Interf ace Page 7 of 7 Applicable QAM PGLE Auditor P.
J. IIerbert Date Feb.
2-17, 1982
,Apo. B.
CAM Statement
' Audit Instruction Comment Crit.
Ref.
.c
~
of the 4160 Switch gear and design drawings were checked.
(d' s
No evidence were on file verifying field incorporation of the design modificati,on.
Verify in PG&E purchase Contract #5-67-77 was voided, records that Contract
- 5-67-77 was not activated with WYLE.
%,/
PG&E - March 8, 1982 78/89 i
I AUDIT CHECKLIST Company ANCO/PG&E Design Control Interface Page 1 of 5
[
AppticabLe QAM IC&E Auditor P.J. lierbert Date February 2-17, 1982 App. B.
GAM Statement Audit Instruction Comment Crit.
Ref.
3.1.2 Doctment Control: Procedures are a.
Verify that PG&E used a pro-a.
Not Acceptable. PG&E's G.
used to assure that the latest cedure to assure that AtKD was procedure was not in effect approved drawings, specifications, issued and used the correct for the control of inforrnation procedures, purchase orders, and llOSGRI Data in establishing their PG&E gave to AIKD.
other documents are in the hands of Test Plan, personnel, carrying out the work.
. Determine if PG&E can verify b.
Not Acceptable. No docu-b.
that Il0SGRI Data was used by mentary evidence was made ANCO to develop the Test Plan.
available to the audit team fran which a determination could be made as to what IIOSGRI Data or other data was given to ANCO by PG&E for use in developing Test Plan (s).
b PG&E - March 8, 1982 79/89 t
a
1 AUDIT CHECKLIST Company ANJo/PG&E Design Control Interface Page 2 of 5 Applicable QAM IC&E P. J. JIerbert App. B.
QAM Statement Audit Instruction Comment Crit.
Ref.',
3.2.2.2.
Supplier Contractor Designs
{
Test Plans
,s
\\/
Specifications require su@ liers Verify whether AFKD prepared de-It was verified that NKD did pre-and contractors to subnit det-tailed test plans and test pro-prepare a test plan memo for each ailed... test plans, ect., as cedures and subnitted them to item to be tested.
(See Attached the work progresses.
PG&E as the work progressed.
Table 1)
- To perform or control the Test _ Procedures testing program.
Not Accentable.
MKD did not subnit detailed test procedures to PG&E for approval prior to testing. The Test Plan Memos contained smo details, but no procedure controls, acceptance criteria..
The final reports gave details of what was done but not hew.
L
'PG&E - March 8, 1982 s
80/89
AUDIT CHECKLIST d'
Company ANCO/PG&E Design Control Interface Page 3 Of 5
Applicable QAM PG&E Audito:P.J. Ilerbert Date February 2-17, 1982 Ap B. I QAM p,,
Statement Audit Instruction Comment 3,2.2.2.
% ese documents are reviewed by Verify that the Responsible Nct Acceptable.
U..
the Responsible Engineer and/or Engineer or another engineer other engineers and returned to reviewed AN00's Test Plan, and See Table 1.
the supplier with ccnments and/or Test Procedure and Test Reports i
- approval, and returned th e to ANCO either Note. Responsible Engineer PG&E approved or'with cmments.
oculd not verify that he or another engineer had reviewed 5 of 11 N00 Test Plans subnitted.
l No detailed test procedures approved by the Responsible Engineer or another engineer.
l We Responsible Engineer provided i
doctanentary evidence which verified l
~
that he had reviewed the draft MJCO Test Reports and provided N CO with ccnments or approval, i U he Responsible Engineer could not verify that the Final Test Peport had been revised by NKD to include PG&E review ccmnents. Their is no evidence of PG&E review and/or approval of Final Test Reports.
PG&E - March 8, 1982 I
81/89 i
4
t 9
AUDIT CHECKLIST i
Page 4 of 5 l
Company ANCO/PG&E Applicable QAM IG&E Auditor P.J. IIerbert Date February 2-17, 1982 i
AEP* 0*
Statement Audit Instruction Comment Crit.
Ref.
1 WJ neer Acceptable. It was determined 3
Appendix XVI Corrective Acticru Measures Verify that Responsible 1 i
Q A, pg.
shall be established to asdure was cogrtizant ofl.ANOO No : ices of during these tests that the XVI that conditions adverse to ' quality, Deviations.
ccrrponent cooling water heat such as failures, malfunctions, exchanger required redesign of deficiencies, deviations, defec-its support to be acceptable tive material and equipnent, and for IIOSGRI design. PG&E non-conformances are prcurptly prepared design change draw-identified and corrected.
ings for field rnodification of these support which ccurr-plied with the ANCO reccarenda-tions. It was not verific<1 frczn as-built drawings that the required field nodifications have been rnade.
Y PG&E - March 8, 1982 82/89 eee *, o eee 4
Page $ of 5-February 2-17, 1982 7
(
TABLE 1 1
Initial
-TEST PLAN TEST PROCEDURES
-PG&E Prelim.
Final Data Subm.
Appr.
Subm.
Appr.
Test Rpt.
Report 1
1.
Di'esel Generator 4
1 11-8-77' 3
2 7-5-78 2
l
& Acc.
i 2.
Borldk Acid Tank 4
1 12-1-77 3
2 7-5-78 2
! (w.2) 3.
Liquid Holdup Tank 4
1
.12-1-77 3
2 7-14-78 2
l 4.
' Comp. Cooling 4
1 11-8-77 3
2 7/78 2
l' Water Ht. Ex.
4 1
12-1-77 3
2
.7-13-78 2
W er S rge Tank i
G. - Limitorque Oper.
4 2-3-78 2
3 2
7-14-78 2
. Valve 7.
Rotork Oper.. Valve 4
2-3-78 2
3 2
7-14-78 2
.B.-
Air Oper.~ Valve 4
2-3-78 2
3' 2
7-14-78 2
l 9*
8f*_[f[eRuns 4
11-30-77 1-10-78 3
2 7/78 2
,, )
l l
10.
45 Pipe Hangers 4
2-3-78 2
3 2
7/78 2
..(i) 11.
Diesel Gen. Air 4
2-3-78 2
3 2
7/78 2
Tank
- .r..
1 - ANCO Submittal was not dated o'r signed
-(
l 2
Pk) record of PG&E review and approval l
3 - No record of preparation or transmittal by ANCO
.s 4 - No record of PG&E initial data transmittal i
or data useage by ANCO e
. PG&E - March 8, 1982 l
83/89 n-
.