ML20149E143

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Forwards Drafts of Matl Responding to Sser 21 Allegations. Required Review Process Complete
ML20149E143
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/12/1984
From: Hoch J
PACIFIC GAS & ELECTRIC CO.
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20149D694 List:
References
FOIA-84-21 NUDOCS 8801130232
Download: ML20149E143 (18)
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i TO: Region V. Nuc, lear Regulatory Comission FROM: J. B. Hoch, Diablo Canyon Project Manager CATE: Janua ry 12, 1984 SUB: SSER 21 Enclosed are draf ts of material responding to SSER 21 allegations. This inforr' ion is being transmitted to you on an informal basis. Although we believe the enclosed information to be accurate, the review process required by the Diablo Canyon Project for submittals to the NRC has not been completed. We expect this information to be formally submitted to the NRC as soen'as this process is complete.

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METHOD OF THE DESIGN CONTROL PROCESS Pacific Gas and Electric Company initially issued its design control .

quality assurance procedures in June ig'70, in the Quality Assurance Manual (cc nonly. ref erred to as the "Red Book")'. The controlling procedures are identified as PRE 2 and PRE 3. During the initial design and c"onstruction phase of the Diablo Canyon Power Plant (DCPP) final, a'pproved drawings (either origint.1 issue ar revisions), were released by Engineering and isrued to the Construction Department. Thus, as soon as the design was co:plete, approved drawings were released for construction.

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As design changes occurred, they werr do'cumented by a description of the change in the revision block on the design drawing. Each design change was e.Tso identified by ballooning (i.e., drawing , clouded circles) are::nd the change on the dra*.fing. The Construction Department bias then resp:nsitie f:

issuing the drawings to the responsible contractor to accot?1ish the work and Curi..; this tite for assuring that the work was. completed by the contracter.

e pcried Engineering hac adoptec a practice of using a cne or :.to letter cede to identify the reason for initiating tne change. For exacple, "(E)", in the change block indicated that the change had been initiated by the responsible .

engineer and "(X)" indicated that the change vas.rc:;uired by a vendor.

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  • Until the issuance of the fuel ~ load license in 1981, there was no formal f'eedback from Construction to Engineering on'the status or completion of construction activities, although Construction kept Engineering informed of-status and cor.'.pletion via telecons and memorandums and also threighlthe issuance of a monthly status report. -
  • t In' Rove-ber 1973, the l'echanic51 and Nuclear Engineering Department

,- recognized the need to adhere tighter control of the design / design change process and issued a procedure cr.lled "Engineering Change Order" (ECO). The .

r. Electrical . Engineering Department adopted the procedure in June,1974. This s.

prece!cre 5:as used by Engineering to instr,uct the Design Draf ting Department ,

to revise a design for Engireering approval. The ECO required the following ,

dccu ertation: ,

1. Description of the change
2. Purpose of the change
3. Cra'.:ings af f ected by the change 4 Approval of the chi.nge prior to issuing the design.

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, 'I These ECOs identified the discipline involve an6 vere .sequentia11y numbered, Ingged and tracked by the Project f.ngineer's office. The ECO also ,

' served the purpose of advising Constr:ction of any pending change and cedidie used to transmit approved d8 sign change sketches to Construction so they could continue' work while a drawing was being, revised. ,,

t The ECO was replaced by t.he Design Chtnge Notice (DCli) when the Engineering I'.anual was issued in . lune 1978. Thr DCN Dracess, dif hed in

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Enginsa,*ing I'anual Procedure 3.6, "Design Change,' is essa!.tially a. refinement of the (C0 process. The DCN itsrove!. upon the ECO by:

fhi 1 ' Requiring more extensbe review, cocrdination, and approval prior t; the design being issued

2. Icproving design documentation by stating the reason'for the change
3. Providing for delegation to Constructic,r. to initiate.* and approve oesign chaoges, followed by Engineerint concurrencea J

Like the ECDs, the DsHs are nuc ered, 1ctged, and tracked.by the Project l Engineer's office and are used primarily as the means by which Engineering i

instructs Design Drafting tbout drawing revisicas. ,

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  • The DCN identifies,the scope of work to *ae accomplished and'to make_the l-best use of construction manpower, allows construction to proceed as portions of the design'are ccr leted. TPis_ procedure recognized.that the tonstruction i activities were different from design activities and met the need by allowing revisions to the DCN as design was completed.

i For example, in the electrical area the conduit layout is the first construction activity and the easiest design issue after the system (schematic) design has been completed. The first DCN issued generally would

(), De for Construction to install the conduit. depending on the amount of work inecived, Several revisions may have been , required for conduit and- equipment icycut. The next construction act4.vity is wire placement, which cay requi're ,

ye; another revision. The final revision (s) would be for electrical.

icr.c..u tics and wire terr.inations. Construction may initiate some revisions to be'p r? solve construction interferences. A concept is designed by Et;ineei.cg, built and understood by Construction since they are responsible 1:r ccnstruction and start-up testing. l l

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. 1 In April 1SEO, PGandE created the 1:ucitar Power Generation Oc;crtment to j

l censelidate the managemer.t and operation of its nuclear power plants under one 3rscnizttion. This department became the interface between. engineering and c'crstruction cttivities at DCFP. All designs were issued by Engineering to y n ,.r-+r .- -

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  • Page C he Nuclear Projects (HP) organizatior.' of the Nuclear Power Generation  !:

I Department. Nuclear Projects then irsued the design to Construction, j-In recognizing the requirements for design change control for an operating plant, PGandE in early 1981 formed a ta,sk force to research and develop a system that would incorporate these requirements ir.to ?GandE procedures. The task force comprised individuals f rom all impacted organizations including Engineering, Construction, Nuclear Projects arid Plant Operations, lhese requirements basically were 6eveloped from TM1 requirements, .PtandE

(' committeents and in recognizing the problems of other plants in contro. ling the a's-built condition of the plant for safe,and reliable operation. As an l

initial step in developing the system, the task fcrce solicitated other utilities to find out how thcy.vtere taeeting these requirements. After r'eviewing the responses, the task force modeled its procedures after those deyeloped by Duke rower Company s.ince they felt the Duke Power's procedures most adequately met the requirements.

The procedures developed by the task force established a metMd f or assuring that all construction and other activities were ccCleu arior to design drtwings being finalized and issued. To accomplish tt)is, a .

cenfiguration control system wou.1d have to be implemented to assure that no design drawings used in the operation of the plant wculd be issued unles::

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. a All safety questions in the design were resolved- i 1.

2. Construction was completen  !.

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Construction was accepted by the operating department-3.

4. As-built conditions were maintained, controlled, and assembled until the design drawings were issued. '

To acnieve this, all designs woule have to be issued as co.plete discipline

, design packages (instead of design drawings), Construction would have to work only to the design package, and any revision would have to completely (e supercede all previous revisions. The task f 6rce reccgnized that this would be a 'tejor shif t f ree the existing design /, design change process and, therefore, made the conscious decision to allow DCl?s that had been issued .

prior to receipt of the oparating license to be revised without superceding til previous revisions. However, they decided all other requirements would.

. have to be tet.

fhe f uel 1 cad license for Unit I was issued it. Septe.tber 1981, prior to ]

issucnce of the procedures that describe the above process. This did not chtn;e the goal of the new process because 1) the design ar.d construction of Unit i was essentially cc plete, 2) virtually no new designs were being -

l issued, and 3) all involved organizations undcr; toed the required process and I

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they agreed to follow it. The license was suspended in November 1981 af ter-PGandE discovered and reported what has become_known'as the "mirror image  ;

error." Subsequently, the design verification program was established and virtually no designs were issued until af ter all the new design control procedures.were established. The initial procedure identifying the requirements and respcnsibilities, I?uclear Power Generation Proc-dure M606, "Plant F;odification Follovier," was issued in fiay 1982. The Engineering procedure EriP 3.60ti, "Design Char.ges for Operating Nuclear Power Plants" was issued in .luly 1982.

6 To implement configuration control, construction activities are only conducted using the self-ccr.tained DCR design package. Ccnstruction was no

'onger performed in accordance with the approved issued drawings as when the diantdidnothaveanoperatinglicense Engineering issued only approved sketches uniquely identified with.'the DCH and also identifying the dras:ing on which the design would be incorporated. The design control of the DCN is Engineering's responsibility. 'Although it is the individual , engineer's a

" resoonsibility to know the design he issues, it is generally ccr. trolled by the creation of a ":;aste"' fro. the original drawing. All DCI' thanges are ::de on the caster, r.nd the specific DCN change is converted to a sketen using an ,

alpha-nur.cric revision f or issuing with the DCl!. This raster allous '

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  • Engineering to maintain a composite of all change's affacting a drawing. .Some .p

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engineering disciplines have also developed. logs, composite dross-reference ,

drawings, cross-reference indexes and use both Records Itanagement System (RI:5) and DCU tracking logs sorted by drawing number to assist in controlling design change: ...

The R!'.S is a computer-based decement storage and retrieval system used at

,- DCFP that contains a list of all drauings issued. When a DCN is issued for i

ccnstruction, the drawing to be revised is f. lagged in the Rl:S to show that a OCN is still outstanding against it. The DCR' tracking system (System 38) is a cc ;'lter-based system used for track'ng all DCN's through all responsible c ;aM zations frem inceptien through final closecut. ,

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The manual drawing log was converted in May 1982 tc the computer-based,.

1 real time DCU tracking system for a greatly cxpanded trakcing process. The J s; stem has been expanded over time to include information f rom Engineering and l I

ev.tr departents; such as drawings a#f ected, interim revision nu .ber, respcasible enginecr, priority schedule, expediting codes, and construction 'f g :.:p assigned. \

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- The' flow chart attached to EMP 3.60N giscs.tt5e detailed activities of the engineering process and a gent. cal overview of construction and operations activities. Construction's process is detailed in Project Instruction P1 17, "Document Control Operating Instructions." Operation's process is detailed in their Aaministrative Procedure, AP C-1 51, "Onsite Review and, Handling'of Plant liodifications." The process is briefly as follows:

1. Engineering completes and approves complete design packages by discipline, and transmits to Nuclear Plant Operations in San -

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Francisco (NPO-SF). .

2. NPO-SF reviews the DCil, completes the written safety evaluation, and transmits to NPO at Diablo Canyon (NPD-DC).

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3. NPO-DC reviews the package for operational requirements (e.g.,

I additional trainir.g), obtains the Plant Staf f Review Comiittee (PSRC)

E;preval of the safet evaluation, and assigns and transrAts the work f to Construction.

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4. ' Construction Document Control ~ coordinate's distribution.to the I

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- responsible groups. -The Construction Resident Engineer assigns.the work responsibility to a contractor and to' his own personnel to' 'I follow the work. After the werk has been completed, Construction

' f routes the completed package (including as-builts) to cognizant i:

personnel. 1.' hen they verify that, all construction activities (includingconstructionttI: ting)havebeenccpleted.. Construction transmits the package back to I;PD-DC.

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(; 5. I?FO-DC reviews the returned package for operational accepta.bility,

  • ' distributes the design sketches to all their drawing centrol points, and returns the package to Engineering. , ,
6. Engineering reviews the package (including any as-builts) for ,  ;

[ acceptability, incorporates the infe'tation r into design drawings, ,

l then approves and issues the drawings.

in 1979, tJO and Encinccring had jointly. identified thc_ crawings necessary t

to c fciy cacrcte and shut to.m the plant as required c' Et'P,3.7. These are n identified as Priority I drtuings.and Engineering com:itted to issuing these l detvings witMn thirty da'.*s af ter recciving the cc:.pleted dcs.ign package frem  ;

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'NPO in accordance with EMP 3.60N. . All' other drabings are to beEissued within nincty days. In the maantime, NPO is able to assemble the as-built condition.

' of the plant since the information has been sent to their drawing control

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n,n..-L; points and the information is available through the Rl45 cm which DCR's af f act a drawing. ,

t.s a result of the Internal Technical Program (ITP) instituted by the Diablo Canyon Project (the integrated PGandE/Bechtel project), Constructon was asked to review all DCNs issu'ed prior to EI4P 3.60N and verify that the work h had been comp.leted. These OCNs are easily identifiable since the numbering ,

systemh.aschangedwiththeimplementationofEI4P3.60N. Revisions to these DCNs that were allowed af ter El'.P 3.60N are aiso easily identifiable since they, .

5: Ere required to nave a Plant l'odification Follower !Pi4F) attached thich cece.ents completion of all Engineering, Construct bn, and Operation ,

activities. This information is readily available on the DCN tracking systta. Censtruction documented to Engineering that work was cceplete by so irdicating on the DCN tracking' system. This activity was formalized by l l

issuing DCP Project Procedure 111-10 on Novciber 2, 1983. This procedure i 1

rc:ciret that all of the cid DCNs that Ccnstruction had not verified as l ccepleted be returned and <ccumenter ,under the requirements of. El'.P 3.60:1 fcca the tito of construction through operations and enginer; ring..

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11 METHODFORINSURINGCLOSURE$FCOMPLETIONOFWORK . .;

g CONTRACTOR REPORTING OF WORK COMPLETION ,

. j During the initial design and construction phase of the Diablo Canyon Power Plant (DCPP) final, approved drawings (either original issue or revisions), were released by Engineering and issued to the General Coustruction (G.C.) Department. Thit.* as soon as the design was complete, approved drawings were released for construction. Construction was considered

.couplete when the contractor submitted documentatics that indicated satisfactory verification of installation, e.g., coupletion of loop tests and dry rEn tests for electrical circuits.

1 Throughout the construction phase the nethods for initiating and

, i PCandE/PTCC identifying con;1etion of ecastruction have been modified.  :

I personnel have tivsys been assigned to f ollow the progress of the work l j

thrcughout the various.nethods of design change, .  ;

i Where required by the contracts, a utv issued design-vas assigned to the centractor via Work Request, Field Change Orders, etc. These. documents were ,

, I assigned sequential numbers for identification tracking and accounting - 1 purposes.

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'To ensure the as-beilt information was ibeorporated onto the  :

- i appropriate design drawing, a sketch number.vas assigned when .. the .

as-built drawing was submitted to Drawing Control. The sketch was logged against the aff ected dra'ving, copies transmitted to San Francisco via transmittal Form #77-G-4, and distribution made, including to the [

contractor. Upon contractor receipt of the as-built drawing, the construction resumed to its completion. Whereupon the contractor notified PGandE/PTCC that the work was cocplete via Construction Con;1etion Notices. (i.e., Couplete6 Work Requests, Ciraait Completion Lists for Specific DRT, Loop Tests, Hydro Tests, etc.) In all cases the i

final acceptance was based on documentation that the Contractor was reqcired to provide with the various work packages. ,vhich included Q.C.

Aign-ed!'by the Contractor. Receipt of this notification allowed the disciplines to perfor: the appropriate tests 'and ultizately release the sys:en te startup for preoperational testing.

sinultaneous with constru:tian the as-built informatica was incorporated on the applicable dr5ving by Project Engineering (P.E.). ,

pen G.C. receipt of the as-built incorporated desigt docunen:s, the a

he responsible onsite irspector would go to Oraving Centrol, get applicable sketch, Verify thot the sketch infortation I3d been incorporated on the applicable dreving, place "incorporated" stamp on the sketch, then si;n and date ,the sketch.' Drawing Control vould then transfer the sketch to the closed file. ,

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;i Page'3 e In November, 3973, the Mechanical discipline starced'che use'of i-Mechanical Engineering Change Orders' (ECOs). and the Electrical discipline

. j, commenced *a similiar program in March 1974 ,

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The ECO required the f ollowing information:

- a description of the chante, .

the parpose of the change, .

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- the drawings affected by the chstge, ,

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- approval of the chatsge pr:.4 to issuing the design.

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The ECO process only allowed the work to proceed on the basis of the

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approved design. ECO's were considered co=pleted upon incorporation en J applieghlc det;ign drawings. And the coupletion of the work associated -

i vith an ICO vas tracked and conpleted in the same catner as a new design.

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' During a brief period between the ECO program ar.d the Design Change Ectice (DCN) program, the as-built Minor Variation Report (MVP) ves used by the Electrical group for expeditir.g conpletion of construction vork.

This involved Q.C. documentation and tracking for closure.

In January 1970, the seched of trans.=1tting field changes,vas codified. Transmittal fors #77-G-4 was replaced with Field Change ,

Trans:ittal (T.C.T.) form F62-5537. .

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- The ECO process was in effect until the fugineering Manual was issued ~

in Juna 1976, and Engineering Manual' Procedures 3.63 "Design Change", and '

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3.7, "As-iuilt Documents" became the controlling engineering documents

' for design issues and incorporation. Destgn Change Notices (DCNs). h, t

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. require review, coordination, and approvals prior to initial issue'of

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4 design, and allowed, by specific delegation to the Resident Engineer,. i 6

therebyallowingfieldapprovalofcertain'designchangeswithProject.

Engineering concurrence taking place simultaneously with the coCrinuing construction, but prior to incorporation into the design documents. ,

DCN's were nunbered, logged and tracked by the Project Engineer'.s office.

The DCN also was used by Engineering to instruct Design Drafting t

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' to revise drawings.'

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  • 6 The DCF identified a specific secpe of vork to be accenplishtd and alleved construction to proceed as pertions of the design vere completed, to facilitate the optimal use of construction canpower. This procedure ,

recognized there was a need for General Construction to proceed with cc struction prior to full conplation of all design activities, as long j

as the approved design was included.

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For exa=ple, in the electrical area the conduit layout is the first construction activity and the easiest design issue after the systen The first DCN issued s'enerally (schatatic) design has been. completed.

Depending on the ,

vould be for Construction to install the conduit. ,

amount of' vork involved, several revastens nay be requ .ced f or ccchit. ,

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and equipment layout. The next construction Activity is vire placement, { ,

which may require yet another revisio"c. The-fina.1 revision (s) unuld be for electrical schematics and vire terminations. Under their delegation,

  • Construction may initiate some revisions to f acilita?.e resolution of ll construction interferences.

In September,1981, the G.C. DCN closure process was foraalized, and

  • the f em used was the fore-runner of the present DCN Conpletion'Notite

'7ct: (0E-86). The systen of cantrac.Ir notification of construction ,

coupletion was not substantially changed as a result of the initietics of t.

the DCN process, F

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In Oc[ober,1982, G.C. started a review process of all DCK's that, .

vetk had been initiated prior to September of l'981 to deternine the current construction status, i .

The status of the varicus DCN's since the beginning of the DCS progran v,ts obtained f ron the Draving Centrol logs of all DCNs and revisions t'eceived cr generated at the site. Status tables based en

~ logs vore distributed to the onsite disciplines. The various

. sci; lines checked early records and work to confirm the cons,truction I

status of these DCS's. Tha infor ation fron the various discipline's was 9 0 9

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I. Mcdonald /DS/gk Page 6 i then tabulated and forwarded to San Francisc6 Project Engineering for ,

thea; use. A copy of the information forwarded to Project Engir tring wais maintained by G.C. All DCNs not shown as closed status were then  ;

lutar addressed by the'r'esponsible discipline. The first updates were

. transmitted to engineering for insertion to Records 80 on a hard copy

  • basis until the System 38 program was implemented.

After the Syste= 38 program was initially updated and i=pleftented, the construction status infor:ation was provided to the data base directly by inpuring through onsite terminals tied to the = aster data base in the Ecce Office. The maintenance of construction status of all DCN's is ongoing. ,-

Periodic audits by G.C. Docu:ent Cont:cl p'ersonnel have been perfer:ed on Centractor's work decu ents to insure that they were verking to.the latest design changes. The Contractor is required to sub=it to PGandE/PTGC documentation identifying verk co:pleted as well as in process inspections and final insp'ections.

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