ML20212N782
| ML20212N782 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/23/1970 |
| From: | Andrea Johnson, Spencer G, Stello V US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML20212N718 | List:
|
| References | |
| FOIA-86-585 50-323-70-02-01, 50-323-70-2-1, NUDOCS 8608290152 | |
| Download: ML20212N782 (15) | |
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U. S. ATOMIC ENERGY COMMISSION DIVISION OF COMPLIANCE REGION V Report of Inspection C0 Report No. 50-323/70-2
- dd i Licensee:
Pacific Gas and Electric Company t
Diablo Canyon Unit No. 2 Docket No. 50-323 Category A Dates of Inspection:
March 26 and 27, 1970 Iates of Previous Inspection:
December 8 and 9,1969 and
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January 6, 1970 L
Inspected by:
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Reacto nspector (In-Charge)
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M V. Stello
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Project Engineer, DRL O!70 Reviewed by:
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G.S.Spe$er Senior Reactor Inspector Proprietary Information:
None I.
,S_UMMARY PG&E has comitted its QA program to a formal, implementing document.
.r Procedures for carrying out the program were found to be in various stages of development and use. However, the licensee stated that the imediately l
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pertinent procedures should all be approved and in use within 30 days from the inspectiot date. According to the licansee, the draft procedures awaiting-approval are generally in use; however, mandatory c.2mpliance with all of the provisions of the procedures is not required until official approval and issuance of the procedures for implementation. Considering the advanced stages of design activities relative to Unit 1, and since essentially the same L
design will be applicable to Unit 2, the licensee has given priority status to implementing the E requirements concerning design activities within the 4
g PG&E Engineering Department.
Pursuant to PI-3800/2, information concerning implementation of the %
program requirements pertaining to procurement and on-site construction activities has been reviewed and reported in connection with routine inspection activities of Unit 1.
Based on that information and on the information in this report, the licensee should have a comprehensive QA program developed for these areas prior to conunencement of construction activities for Unit 2.
II. GEFERAL
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A.
Backaround and Purpose
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%^ 74 An initial inspection of PG&E's Quality Assurarca Program (QA) 7 related to tne construction of the Diablo Canyon nuclear power plant No. 2 was conducted on December 8 and 9,1969, pursuant to Mr. G. S. Spencer's memorandum dated November 21, 1969. The i
deficiencies identified by the inspection team were reported in i
CO Report No. 50-323/69-2. Those deficiencies were subsequently the subject of discussions between corporate officers of PG&E and Region V personnel on January 6,1970, with the details later l
reported in CO Report No. 50-323/70-1.
l In general, the inspection team found that PG&E 1*ad not formulated a QA Manual to provide the necessary assurance that the plant would be desi;;ned and constructed consistent with the QA program commitments sede in the PSAR. At the time of the inspection, PG&E had recognized the need for such a document and had begun development of a manual
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designed to assure compliance with the requirements of the PSAR.
The current inspection was conducted to determine the status of development and implementation of the proposed QA Manual and to ascertain the licensee's corrective action concerning the specific deficiencies previously idectified during the initial QA l
inspection.
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It should be recognized that PG&E's efforts toward the development of their % program and inanual for Unit No. 2 reflects the current practices being followed for the construction of Unit No.1.
The licenses has indicated that the requirements of their % program will be applied (as applicable) to both Units No.1 and No. 2..
Implementation of the licensee's informal %-QC program for procurement and construction activities related to Unit No.1 has been reviewed by the assigned inspector and reported in CO Report Nos. 50-275/69-3, 4, 6, 7 and 275/70-1. The information M@
contained in those reports coupled with that obtained during the initial @ inspection for Unit No. 2 provides sufficient evidence i
to show that the licensee has been implementing a $ program, related to procurement and construction activities, essentially consistent with the @ program outlined in the PSAR for Unit No. 2.
Specific deficiencies noted were identified in C0 Report No.
50-323/69-2. In view of the availability of the above cited information, the current inspection effort was limited in scope i
to the subject deficiencies identified in CO Report No. 50-323/69-2.
i The pravious CO inspection efforts related to Unit No I had not included a comprehensive audit of the design activities of PG&E's e
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Engineering Department. Therefore, the deficiencias noted in
.h this area of activity during the initial % inspection conducted i
on December 8 and 9,1969, were given special attention during the current inspection effort. The absence of objec,tive evidence to show that the licensee's informal S program was consistent
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with the PSAR @ requirements had been particularly identified as a major deficiency during the initial $ inspection.
e B.
Team Membership and Assignments
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G. S. Spencer Senior Reactor Inspector, CO:V Responsible for the overall inspection effort, including the l
planning of the inspection, and the review of the results.
l A. D. Johnson Recctor Inspector, CO:V In charge and responsible for the coordination of the inspection details and for the inspection effort related to the previously identified deficiencies concerning PG&E's program, procurement and onsite activities. Specifically, this included Criteria II, VIII, XI, XIII and XV as designated in the PSAR.
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V. Stello Project Engineer, DRL Responsible for the inspection of PG&E's program pertaining to the previously-reported deficiencies concerning Criteria III, V, VI, XVI, XVII and XVIII as related to design and engineering 4
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PG&E Personnel Contacted During Inspection Activities v.r~g; D. V. Kally Project Engineer
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J. O. Schuyler Supervising Mechanical Engineer R. V. Bettinger Supervising Civil Engineer A. J. Pleves Construction Engineer W. R. Forbes Supervising Inspection Engineer W. R. Hersey Project Superintendent G. V. Richards Dirs: tor, Quality Engineering I
L. H. Carr QA Engineer J. Eipperer QA Engineer III.' SIGNIFICANT INSPECTION FINDINGS
. l f" The significant findings during the inspection are summarized below, i
N tabulated by criteria as shown in the PSAR and grouped by major inspection A-activity. Only those criteria where specific deficiencies were identified during the initial QA inspection are discussed in this report. The j
previous genersi finding that in the absence of a QA manual it was impossible to determine with reasonable assurance that the criteria would be interpreted and implemented in a consistent manner for the overall project scope has been remedied as discussed under criterion II. The supporting details are retained in CO:V files and are available if required.
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A.
QA Program, Procurement and On-Site Activities The deficir acies identified in C0 Report No. 50-323/69-2 related to these activities were reviewed to determine the status of corrective action implemented subsequent to the initial QA inspection conducted on December 8 and 9,1969.
Criterion II. Program I
1.
Previous Finding A 4A Hanual had not been formulated and implemented to provide for a cicar and well de'ined quality assurance pr'ogram for the design and aa ns tr tetion of Unit No. 2.
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2 Discussion i
PG M is developing a formal QA program. The program includes a QA manual divided into four volumes titled:
Volume I Policy Instructions Volume II QA Procedures Volume III QA Standards for Nondestructive Tests Volume IV QC Surveillance Plans
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The current status of the program development was found to be as follows.
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Volume I has been cospleted and approved by Executive Vice President John F. Bonner. Bonner states in the j
QA program authorization that "...The PCE Nuclear Unit 2, Diablo Canyon Site, will be designed and 4
constructed in full compliance with the Quality Assursrce Program developed from the plan described in Appendix G l
of the Preliminary Safety Analysis Report for Unit No. 2.
The policy for the Quality Assurance Program is set forth
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in Volume I, PG E Quality Assurance Manual.
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"The PGE management is fully committed to this program and I hereby direct that it be implemented by those persons responsible for any aspect of the design and construction of the plant."
The content of Volume I was observed to include clearly j
stated policies to assure proper assignment of responsi-bility to the appropriate departments and personnel within PGE for implementing the QA plen described in the
,,,44,3 PSAR. Volume I also included as Appendices the following:
(1) Atomic Energy Commission Quality Assurance Criteria j
(2) Quality Assurance, Appendix G. PSAR (3) Westinghouse Quality Assurance Plan (4) List of Pertinent Regulations, Codes and Standards 1
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(5) Suppliers'/ contractors' Quality Assurance Requirements I
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(6) Defint.tions l
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(7) PG&E Standard Practice 510-A, Buyer Purchase Authority (8) PG&E Standard Practica 420-1. Initial Testing and Startup (9) Abbreviations b.
To date, seventeen det. ailed QA procedures (Volume II) y,N implementing Volume I requirements have been formulated in draft form. The licensee indicated that the procedures were generally in effect; however, since the procedures had not yet received final approval, nandatory compliance with them was not required at the time of the inspection.
Mr. Richards stated that several of the procedures were ready for issuance and that within 30 days all of the draft procedures should be issued and in use by appropriate personnel, c.
Volume III of the manual was essentially complete since it-generally contains only a compilation of standard
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code requirements concerning the nondestructive tests
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referenced in the various construction and supplier gj contracts.
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Volume IV which is the QC surveillance plans was observed
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to be up to date concerning PG&E's surveillance plans j
as related to construction activities currently in progress at the site for Unit No. 1.
According to the licensee, these plans will continue to be developed and 4
must be approved and implemented prior to commencement W***
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.o! any particular job. The schedule for development of the appropriate QC plans has been tied to the construction schedule for Unit No. 1.
Since Unit No. 2 will be an identical plant, the developed plans will he applicable with possible minor changes.
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3.
Findinn The licensee has formulated and implemented a formal QA Program. With the exception of design activities already completed, the formal program should assure development and implementation of appropriate QC procedures in a timely manner.
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Criterion VIII. Control of Purchased Haterial. Eauipment and Services 1.
Previous Finding A procedure requiring preparation of written inspection plans
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for use by PG62 vendor inspectors had not been formulated to assure compliance with the PSAR requirement.
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Discussion J
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A detailed QA procedure has been developed which requires all PG&E vendor inspectors to conduct inspections pursuant to written inspection plans. The procedure included standard provisions and provisions for special inspection requirements as stipulated by the responsible design engineer.
Mr. Forbes stated that the procedure would be implemented within 30 days.
3.
I. LIM 11B1 The implementation of the QA procedure should satisfy the PSAR requirement.
Criterion II. Test Control I[. (
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Previoup Findina
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The means by which design engineering personnel review acceptance test procedures and results was not prescribed in a written procedure to assure involvement of design engineering in a consistent menner.
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The provisions in the QA manual (Volume I) clearly delineate the responsibilities of the Construction, Operations and Engineering Departments as to preparation of test procedures concerning plant equipment, performance of tests, and review of the test results. The Construction Department (Startup Engineer) is responsible for obtaining all design information necessary to enable preparation of equipment acceptance criteria. Also the Construction Department is charged with the responsibility along with the operations Department to prepare appropriate written preoperational and acceptance test procedures to demonstrate that equipment and systems have been properly installed and will operate in accordance with design requirements. The Operations Department then has the responsibility to perform the required tests. If a tested system meets or exceeds its acceptance criteria, L
e the Construction Department will release and the Plant Superintendent will accept the equipment. Any inadequacy to acceptance criteria will be reported to the responsible design engineer for resolution. Test results will be reported in formal test reports for distribution to all interested parties including the Engineering Department.
3.
Findinas M
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The provision in the QA manual should provide the necessary instructions to assure appropriate Design In,11neering review of equipment test activities in a consistent menner.
b.
The Engineering Department has not been delegated a direct responsibility for review and approval of test procedures to assure that the acceptance criteria are consistent with the designed function of any given equipment or system.
Criterion XIII. Handline. Storare. Shfnoint and Preservation C'.
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Previous Findina i
PG&E had not established a written procedure related to the activities concerning this criterion.
j 2.
Discussion Detailed procedures related to the requirements of the (q
criterion currently in force at the site were shown to the inspector. The procedures,were f und to be comprehensive and included appropriate checklist and instructions to assure proper compliance with the PSAR QA requirements.
l Mr. Hershey stated that PG&E's procedures concerning equipment purchased by PG4E are applicable from the time the particular j
equipment is loaded on a carrier until PG&E delivers the i
equipment to a particular contractor for use. PG&E's vendor inspectors and QC inspectors are guided by written procedures i
to a ssure that the vendor or contractor 1.1 implementing the l
appropriate procedures previously approved by PG&E.
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Findinn l
The currect procedures appear to sactsfy the PSAR QA commitments concerning this criterien.
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Criterion XV - Nonconformine Material Parts. or Components 1.
Previous Findina i
A written procedure had not been implemented to assure appro-priate disposition of noncenforming material or work.
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Discussion i
' 'C@t A procedure has b een developed and implemented to assure nonconforming asterial or work is appropriately resolved and documented. The procedure defined.a nonconforming item as a l
discrepancy which is then further classified by the resident l
engineer as a d eviation or a minor variation. The minor variation may be resolved by the Construction Department in
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conjunction with the QA section at the site. Reports of these j
items along with the resolutions are forwarded to the Design Engineering Department on a monthly basis for review and t
concurrence. A deviation, however, requires that the appropriate design engineer be immediately notified of the discrepant condition and concur in the proposed' resolution
,f prior to continuance of the particular job involved, i
f The inspector noted that the procedure provided that certain j
items corrected in the " ordinary course of business" need not
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be reported under the formal report requirements. The licensee
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indicated that whenever a PG&E inspector observes any variation l
from specifications,the observation is related to the contractor.
If the contractor corrects the condition, the inspector includes the observation and the contractor's response in his
.,p,,,j daily report to the appropriate Resident Engineer. These j
reports are review.td by the QC Engineer assigned to the I
particular discipline involved.
If, for example, a Contractor ignored the inspector, the inspector is then required to contact the PG&E Building Engineer. If the Contractor and Buildir.g Engineer cannot resolve the discrepancy the Resident Engineer is notified. In any event, the work is not allowed to continue until the discrepancy is resolved so that the work conforms to the prescribed specification unless the j
responsible design engineer is contacted and approves a specification channa.
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The inspector directed the licensee's attention to the wording i
" corrected in the normal course of business" and stated that this could be interpreted to mean that if a significant item were corrected, a formal report need not be made and the 7
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appropriate design engineers would never be apprised of the discrepancy or its resolution. The licensee stated that the wording was intended to apply only to minor items such as cleanliness of an area before pouring concrete, etc. However, they agreed that the wording certainly could be interpreted as the inspector suggested. In view of this the licensee stated the procedure would be clarified.
M 3.
Findinz
?h' The licensee's procedures, with clarifying provisions concerning discrepancies which are significant and corrected immediately by the contractor, s'iould provide assurance that all nonconforming materials and work is corrected or appropriately resolved, reviewed and documented at the appropriate level within the PG&E organization.
4 B.
Desten Activities The deficiencies identified in CO Report No. 50-323/69-2 related to design activities within the PG&E Engineering Department were b.4 j g explored in detail to determine the status of corrective action j(
implemented since the initial QA inspection. Results of this i
!l exploration provide the bulk of the discussion that follow.
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h on III. Desian Review 1.
Previous Findf.nn Written procedures to guide the design review activities within PG&E had not been developed.
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Discussion A procedure has b een developed which includes a list of components that will be subjected to the quality assurance program. The list appeared complete and was more comprehen-sive than the list provided in the PSAR. The conduct of design reviews for components on this list is governed by written procedures. These procedures are detailed and inchde a check list containing the elements which are to be considered in the design review. Components which require i
performance of design calculations naast piso have all calcula-(
tions checked by an engineer in another design group. These checks are to be approved by a supervising engineer before r
the component is approved for construction. As written, I
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A procedure has been develop'ed which provides a mechanism for documenting and approving changes in the PSAR. The procedure identifies the various groups within the PG&E
-@dM organisation that must review the changes before incorporation
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into the design. A form is included in the procedure which lists the information that is required to justify the change.
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After appropriate review and approval these changes are distributed for incorporation into the PSAR.
The applicant stated that the Westinghouse design review procedures are adequate and therefore does not plan to conduct e design review of elements within the Westinghouse scope of 1
supply.
If, however, a responsible engineer believes a check of Westinghouse design data is required such a check would be conducted.
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Findinz 4 fr>7 a
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- The QA requirements contained in the PSAR should be satisfied if the written procedures developed to guide the design review l
activities are approved and fully implemented.
Criterion V. Instructions. Procedures and Drawins 1.
Previous Findina
> M' a i; Written policy and procedures establishing the stated
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practices of PG&E concerning the QA requirements under this criterion had not been forsulated and implemented, r
2 Discussion J' "-
Various inspection procedures are being compiled into a volume which will be incorporated as part of the QA manual i
(Volume III). These procadures contain the detailed' instructions for the various inspections performed by PG&E personnel at i
the site. Acceptance standards are included in the l
procedures. Mr. Forbes' group has developed a procedure which will be implemented for the conduct of inspections to i
be performed at various vendor shops.
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c 12-Requirements for generacica and submiccal cf various records (mill test reports, radiegesphs, etc.) are incl.uded in the specificacions issued for a component. Disposcion of these records are discussed further in the discussion of Criterion XVII (Records).
Special instructions related to a specific design are included in the drawings for the desics (issued with a drawing number) and are included in the specificacion for the component.
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Requirements in this regard are outlined in a procedure covering design development.
3.
Finding Written policy and procedures required by the PSAR QA commitments have been formulated and should be approved and fully implemented by the first of May, 1970.
Critation VI. Document Control-1.
Previous Find _itz
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'.c t Written procedures to handle the overall control of documents
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had not.been established.
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D_iscussion Procedures have been developed to control phases of design development, fabricatien and erection. Specific procedures reviewed in this regard include provisions ou drawing index system, design develo'pment, correspondence control, specifi-e t#
cation development and Engineers' hhterial thmos. Assurance that these documents and other records generated as a result of them are given proper disposicion will be provided by a cross-reference to the procedure for record control (Cricerton IVII).
t The procedures included a section devoted to requirements for review and approval as well as the distribucion rsquired for i
the particular document. A mechanism for changing the various documence is identified. In-most cases the approval of the change to the document would bc the sama as required for the original document.
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Other documents generated as a direct result of QA operations j
such as audits, design reviews and discrepancy reports, are routed to various section heads and, depending on the particular document (e.g. audit report) will be neviewed by upper levels of management.
3.
Findinzs g
Written procedures, in some cases containing a great amount of detail, have been prepared to control the various phases 4
of design, procurement and construction activities. Approval and full implementation of the procedures should satisfy the QA requirements prescribed in the PSAR.
Cri_tfrion XVL Corrective Action l
1.
Previous Findina i
Written procedures as required by the PSAR had not been fully developed and implemented,
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Discussion t
A procedure has been developed to document any discrepancy l.-
discovered as a result of site u tivities.
This procedure is currently in force and has resulted in a total of 56 discrepancy reports. The procedure, and actions following 4
issuance of the disa.repancy reports, were discussed in detail.
The procedure and resulting reports should provide a mechanism i
whereby actions required by the engineering office would be j
apparent, see Criterion XV for more detail.
Any discrepancy discovered as a result of activities within the vendor shops is documented in the inspection report issued by Mr. Forbes' group. These inspection reports are routinely routed through the various engineering departments for information. The advisability of issuing a discrepancy report, similar to the ones issued on field activities, was discussed. The applicant responded favorably in this regard l
and indicated thst the procadures for vendor inspection would be modified to reflect this consideration.
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Findinz Existence of written procedures and evidence of their implesentation were readily apparent in this area of activity.
Criterion XVII. Records 4
1.
Previous Findine
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Written procedures had not been established concerning the -
required records to document the Quality Assurance Program.
2.
Discussion A number of individual QA procedures and documents (such as specifications) were reviewed to assess the methods used to generate and store the various records related to the QA i
activities. The system used to control the records at the site was reviewed on a recent inspection of the site (C0 Report 50-275/70-1). The results of this inspection j
indicated an acceptable record system. However, an overall system to control the various QA records had not yet been developed. After considerable discussion of this subject l
the applicent draf ted a procedure which, if isolemented, should
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j result in a complete compilation of all QA records.
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The procedure will identify the place of storage, responsible engineers and type of record as well as other data. The j
requirements for generation, distribution and review of the i
records will siso be contained in various other procedures
,D*j or documents. Verification of this fact is to be accomplished i
by a cross-reference to the overall records procedure.
3.
Finding l
Although a system for overall control of records required by i
the QA program was not readily discernible, the drafted procedure and stated methods intended to be used to assure that an effective system is developed should satisfy the PSAR i
QA requirements for this criterion when the procedure is approved and implemented. Plans were to have the system fully implemented by the first part of Hey, 1970. Follow-up i
information concerning the status of the licensee's effort i
concerning this criterien will be reviewed during the next l
's scheduled visit to the site (June 1970) for a routine inspection related to Unit 1 construction activities (Docket No. 50-275).
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.. griterion XVIII. Audits 1.
Previous Findina
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Written procedures governing PG&E audit responsibilities g7M had not been fully developed and implemented.
2.
Discussion A procedure has been developed which provides guidance for the performance of the audit functions. This procedure includer considerable details concerning requirements on reports, check lists, distributica (includes upper management),
follow-up and a schedule for audits to be performed. Audits of the QA program related to field activities have been conducted and appeared to have been effective. Examplea of the proced.res generated for the field audits were examined and found to be complate and detatted. Question lista, used
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to measure the competence of verious site personnel, were included in these orocedures.
'heo schedules are provided in the procedure for the conduct of audits, one schedule outlines the dates when certain audits are to be performed for various site activities and reflects consideration of coordinating the audit schedule with site activities (e.g., many of the field audits performed to date relate to concrete work). A second schedule was
- .g developed to specify the chronology of the audits related to j
design (Engineering Department). Apparently this schedule was prepared without consideration of the design development i
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J' schedule. The applicant immediately recognised the inconsistent ;
and stated the schedule would be changed so that it would be l
consistent with the schedule related to the design work, i
3.
Findines The necessary procedures to guide the conduct of PC&E QA audits of activities have been prepared. The procedures were considered adequate in view of the changed schedule concerning audits of Engineering activities. The first audit of Engineering was planned to be performed during the first, 1
part of April, 1970 I L i
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