ML19329E706
| ML19329E706 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Midland  |
| Issue date: | 07/29/1971 |
| From: | Bernsen S BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML19329E699 | List: |
| References | |
| NUDOCS 8006170853 | |
| Download: ML19329E706 (56) | |
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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of )
) Docket Nos. 50-329 CONSUMERS POWER COMPANY ) 50-330
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(Midland Plant Units 1 and 2) )
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TESTIMONY OF DR. SIDNEY A. BERNSEN Dated July 29,1971
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TESTIMONY OF DR. SIDNEY A BERNSEN I am the same Dr. Sidney A. Bernsen who was previously sworn and testified in this proceeding. The testimony contained in this state-ment is given under oath.
I have been in attendance at substantially all of the public hearings in Midland in which testimony was given concerning quality as surance.
and have reviewed the transcript of the testimony with respect to that subject.
This testimony is based upon my personal knowledge and knowledge available to me as Manager of Quality Assurance for Bechtel.
At pages 2 914-2 915 of the transcript Dr. Goodman asked a question concerning the changes in Bechtel's Quality Assurance Program during the last four years, and at pages 4532-4533 Chairman Murphy asked a general question about the way in which quality activities are supervised.
The first portion of this testimony is in response to those questions.
As indicated in my oral testimony, changes in Eachtel's Quality Assurance Program have been largely evolutionary as a result of many ,
years of Bechtel experience and, with frw exceptions, the principal one ;
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being Appendix B of 10 CFR 50, were not specific procedures designed j
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solely to satisfy AEC regulations. 'the following are the significant ;
changes in the program which hav s occurred since 1967:
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- 1. The program was revised and new procedures prepared where necessary to implement the requirements of 10 CFR 50, Appendix B which became effective July 27, 1970.
While it would unduly extend this testimony to review each change in Bechtel's program which are reflected in the Field Inspection Manual (Saginaw Intervenors Exhibit 28) Nuclear Quality Assurance Manual (Saginaw Intervenors Exhibit 16),
Quality Control Manual - ASME Nuclear Components (Saginaw Intervenors Exhibit 15) and the quality assurance plan set forth in the PSAR (Amendment 6), some examples are as follows : Formalization of Bechtel policy with regard to verifying and checking the adequacy of design by individuals other than those who performed the original design; established program of regular quality assurance audits of construction and design quality assurance activities by representatives of Quality Assurance Management; prepared specifications for vendors quality assurance programs to incorporate the applicable re-quirements of 10 CFR 50, Appendix B (Nuclear Quality Assurance Manual. Section 2.33 and Exhibit 10 [Saginaw
- Intervenors Exhibit 16]).
- 2. A formal quality assurance group headed by a Manager of Quality Assurance was established to guide, review and audit project quality assurance programs and provide and oversee staffing of Field Quality Assurance Engineers.
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- 3. Established the position of Field Quality Control Engineer whose duties solely relate to quality control activities including coordinating of inspection programs, assuring that the field engineers make the inspections required by the Quality Assurance Program and reviewing quality control documentation for accuracy and completeness.
- 4. Established home office Quality Control Coordinators for the construction department to give guidance and implement the construction department quality control program and provide quality control support to construction.
- 5. Expanded existing vendor inspection programs and initiated formal quality assurance audits of vendors.
- 6. Standardized and improved field quality control procedures by means of preparation of Field Inspection Manual (Saginaw Intervenors Exhibit 28) and initiated quality control orientation and indoctrination ot field personnel.
- 7. Initiated formal audits of welding and non-destructive testing programs (Qutlity Control Manual - ASME Nuclear Components.
[Saginaw Intervenora Exhibit 15) and section 6.22 of the Nuclear Quall'ty Assurance ?Aanual. [Saginaw Intervenors Exhibit 16]).
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- 8. Implemented requirements of ASME Boiler and Pressure Veseel Code,Section III (see Quality Control Manual - ASME Nuclear Components [Saginaw Intervenors Exhibit 15]).
After extensive review by ASME, Bechtel was authorized to perform work covered by ASME Code Rules including use of the "N" stamp.
It is my opinion, based upon my experience in quality assurance and quality control activities and my knowledge of Bechtel's Quality Assurance Program, that the Quality Assurance Plan in Amendment 6 of the PSAR and documents referred to therein meet and satisfy the re-quirements of 10 CFR 50, Appendix B.
The importance of people to the achievement of quality construction 5
is strongly endorsed by Bechtel and its current position and record of successful performance is due in large part to the abilities of its person-nel. The following testimony describes, in geesral, the current practices with regard to staffing, training, supervision and review of quality as svisace/ quality control personnel on Bechtel jobs.
- 1. Quality Assurance Engineers The total quality assurance staff within Bechtel's Power and Industrial Division currently numbers approximately 50.
This group includes individuals with formal training and experience in quality assurance and quality control, some
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with specific non-destructive testing experience, and others
. with facility design and field engineering experience. A large percentage are college graduates and those who are not have practical engineering experience to compensate. In addition, some are registered professional engineers.
A new quality assurance engineer is given direct personal attention by QA Coordinators and Quality Assurance Manage-ment which is specifically tailored to complement his prior experience. Quality assurance engineers assigned to the field are initially assigned to work with the project engineering
. design team in the Home Office in order to become familit.
with project design, and the members of design team. This
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is an indoctrination period, and the quality assurance engineer is given direct personal attention by the Project Engineer.
Quality assurance engineers assigned to the design office are j
given similar indoctrination. Upon completion of the initial indoctrination field quality assurance engineers participate in construction site quality control indoctrination and training sessions which also include the field organization. Office quality assurance engineers attend monthly training and program review meetings with QA Management. In addities, formal QA program seminars are being held at least annually. Continuing
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surveillance and supervision of field quality assurance engineers is achieved through review by the Project Engineer and QA
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Management of Weekly Reports submitted by the quality assurance engineers, and is supplemented by visits to the jobsite by the Troject Engineer and Quality Assurance 1
Management personnel for discussions with the field quality assurance engineers. In addition, performance of field quality assurance engineers as well as the field Quality Control Program is formally audited at least twice a year and norn. ally 4 times a year h the course of Managemem Quality Assurance audits of the field operation. The effice
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quality assurance engineers are similarly monitored through frequent supervisory contact.
- 2. Quality Control Engineers Quality control engineers are. selected by the Quality Control Coordinators and are assigned to projects by the coordinators with concurrence of the cognizant Construction Manager.
Qualifications of quality control engineers are similar to those previously identified for the quality assurance engineers. At pre ,ent, there are approximately 40 quality control engineers
'a the division.
Quality control engineers supervise and monitor tbs field inspection program for the construction department .
Field personnel who are performing non-destructive examination
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7 are selected and assigned by the Chief Welding Engineer in
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the Materials and Fabrication Quality Control Services s e ction. These personnel are qualified in accordance with the requirements of the American Society for Non-Destructive Testing (SNT-TC-1A).
Quality Control Coordinatcre visit the construction site at frequent intervals and conduct training sessions for quality control engineers, field engineers and field supervision to explain the requirements of the Quality Assurance / Quality Control Program and to assist them in implementation of the various procedures. They also observe the performance of quality control and field engineers during these visits.
Each jobsite is also required by Construction Management to hold regularly scheduled Quality Control Indoctrination and Training sessions.
Quality control engineers are continually monitored and super-vised by the project field engir.eer and project superintendent.
Additionally, the overall performance of the Quality Assurance /
Quality Control Program and individual field personnel is monitored by the quality assurance engineer stationed at the jobsite, who is in a position to initiate remedial action through i
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The project field engineer, the project superintendent or
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appropriate Home Office personnelin the event of unacceptable individual performance.
The performance of all quality assurance and quality control personnel is formally reviewed and evaluated on at least an annual
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basis by supervision and management.
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9 Saginaw Intervenors Exhibits 17 through 27 have been offered in ,
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an attempt to show an inadequacy in the Quality Assurance Program for Midland because of an alleged failure to prevent the occurrence of problems at Palisades, where a low power testing license has been issued. While it is not the purpose of this testimony to review such alleged problems, as they have been fully discussed in the redirect
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testimony offered in the Palisades hearing and submitted in this proceeding, it is my opinion and I believe that it must be recognized that no quality assurance program can absolutely prevent discrepancies from occurring.
However, a properly implemented quality assurance program will demonstrate the reliability and safety of a nuclear power plant by identifying, controlling and correcting any discrepancies which occur, and provide means for modifying procedures, where necessary, in order to preclude repetition of significant conditions adverse to quality.
Although I do not have detailed personal knowledge of the matters referred to in Exhibits 17 through 271 believe that it would be of assis-tance to the Board to elaborate upon some of the procedures by which the Bechtel Quality Assurance Program for Midland will deter, identify and correct various hypothetical problems which could occur on any undertaking of the magnitude and cornplexity of the Midland project where they may not have been fully described in other testimony.
(Specific steps taken to ensure the proper implementation of the Quality Assurance Program by Bechtel personnel are dealt with in a prior portion of this testimony.)
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Adequate record keeping. Section 5.2 of Field Inspection Procedure G-1 (Saginaw Intervenors Exhibit 28) requires that the quality control file reflect the current status of construction and be available at all times for review by Consumers Power Company and the AEC. In addition Section 1.8 of the Nuclear Quality Assurance Manual (Saginaw Intervenors Exhibit 16) identifies and states the requirements of the documentation necessary for the quality assurance / quality control files.
Following of Field Procedures. Sections 4.2.1 and 4.2. 3 of Field Inspection Procedure G-1 (Saginaw Intervenors Exhibit 28) require that field procedures be established and approved by project engineering for the implementation of unique installation inspection requirements.
Furthermore, the Quality Assursace Engineer audits work done pursuant to the field procedures to assure that they are followed (Paragraph 7.23 1 of Nuclear Quality Assurance Manual, Saginaw Intervenors Exhibit 16),
and is empowere(. to stop work if it is not being performed in accordance with quality procedures (Paragraph 7.23 7 of Nuclear Quality Assurance Manual. Saginaw Intervenors Exhibit 16). Additionally, the Quality Assurance Program's general audits of fleid activities (Procedure 8.2 of Nuclear Quality Assurance Manual (Saginaw Intervenors Exhibit 16h provide for periodic independent assessment of cdherence to such pro-cedures and correction of any discrepancies found. In order to provide for reporting, control and correction of discrepancies. Significant Deficiency Reports must be prepared and processed in the event
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non-compliance with field procedures is detrimental to quality work.
(Paragraphs 7.23 10 and Procedure 8.1 of Nuclear Quality Assurance Manual (Saginaw Intervenors Eashibit 16).
Witnessing of Inspections by Field Engineers. The Field Inspec-tion Manual (Saginaw Intervenors Exhibit 28) specifically provides in the third paragraph of the Introductions to Sections 2, 3, 4 and 5:
"The terms, verify, check, confirm as utilized in the procedures have the common meaning that the assigned Field Engineer shall perform the inspection / test, witness the performance of the inspection / test, or have knowledge and records to substantiate that other responsible Field Engineering personnel or qualified sub-contractor technicians have performed the inspecticn, surveillance or tests that have been a pe cifled. "
Proper correction of discrepancies. Procedure G-3 of Field Inspection Manual (Saginaw Intervenors Exhibit 28) provides detailed requirements for the ide'ntification, control and correction of r.on-conforming items including necessary documentation for follow-up and assurance that the proper correction was made.
Coordination between engineer-constructor and nuclear steam supply system supplier. Page 12 of the Quality Assurance Plan (sub-mitted with Amendment 6 to PSAR) specifically states that Babcock and Wilcox will furnish erection criteria for its equipment, supply erection consultants to assist Bechtel and Consumers in interpreting Babcock and Wilcox requirements and advise Bechtel and Consumers of field con-ditions and actions which do not meet such requirements. The specific l
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responsibilities of each of the companies is further delineated in the contracts previously submitted and in the answers to Saginaw Interrogatories 142 and 154. Similar requirements are contained in Section 3 of Procedure M-1 of the Field Inspection Manual (Saginaw Intervenors Exhibit 28).
Cleanline s s. Bechtel has traditionally required high levels of construction site and system cleanliness consistant with work being performed. Specific guidance on this subject is now provided in Section 7.3.2.3 of Procedure M-1 of the Field Inspection Manual (Saginaw Intervenors Exhibit 28). Additionally each project must pre.
pare a specification for cleanliness control as is indicated in that section.
Similarly cleanliness requirements for storage of components either in designated storage areas or in place are delineated in Section 5 of Procedure G-5 of the Field Inspection Manual (Saginaw Intervenors Exhibit 28).
Prevention of Reoccurrence of Significant Conditions Adverse to Quality. The primary mechanism for accomplishing this is contained in the Procedure for Significant Deficiencies (Procedure 8.1 of the Nuclear Quality Assurance Manual [Saginaw Intervenors Exhibit 16]).
At page 4245 of the transcript a question was raised concerning stacking of crates on top of each other. Section 5.5.4.2 (6) of Procedure G-5 of the Field Inspection Manual (Saginaw Intervenors Exhibit 28) i
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4 requires for Midland that crates of components not be stacked upon each other unless the crate is capable of sustaining the load.
The foregoing are examples of specific procedures and require-ments which are representative of the manner in which the Bechtel Quality Assurance Program is designed to identify, control and correct problems.
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Beginning on page 4296, line 25, and continuing through three subse-quent pages of the transcript, I was asked to compare the field inspection procedure as set forth in Section 7 of the Palisades QA/QC Manual (Saginaw Intervenors Exhibit 30) with the field inspection procedure provided in Pro-cedure W-1 for the Midland project in the Bechtel Power ac Industrial Divi-sion Field Inspection Manual (Saginaw Intervenors Exhibit 28.) A similar comparison could be made between many sections of Exhibit 30 and Exhibit 28.
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- However, this comparison is generally representative of the evolution and continuing improvement of Bechtel's Quality Assurance Program since 1967.
The following testimony will summarize the provisions of Field Inspec-tion Procedure W-1 on a section-by-section basis, which were either not a
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part of Section 7, Exhibit 30, or which are different from that section. (A copy of Section 7 of Exhibit 30 is attached to this testimony as Appendix 1, and a copy of Field Inspection Procedure W-1 is attached to the testimony as Appendix 2 in the event the board wishes to make its own comparison.)
The numbers in the following paragraphs refer to the sections in W-1:
1.0 Scope. The scope of W-1 is simplified and clarified.
- 2. 0 References. W-1 describes, in detail, applicable references, including welding and non-destructive testing procedure speci-
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Manual-ASME Nuclear Components (Saginaw Intervenors Ex.
hibit 15).
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- 3. 0 Responsibility.
3.1 Clarifies responsibility of non-destructive testing labora-tories and references the technical specification governing their work.
- 3. 2 Provides a single comprehensive definition of the responsi-bilities of Field Welding Engineers.
- 4. 0 Material Control.
4.2 Incorporates the receiving inspection requirements con-
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tained in Field Inspection crocwdure G-5 from Exhibit 28 so as to provide increased assurance of proper receiving in-spection and control. For example, Field Inspection Proce-dure G-5 requires planning for inspection prior to receipt of material, ;.rovides a more comprehensive receipt inspec-tion report form and clarifies requirements for review of documentation and control of nonconforming material.
4.4 Formalizes existing practice by specifically requiring the Welding Engineer to report to the Project Field Engineer or the Quality Control Engineer any instance when corree-tive action is not properly taken so as to ensure proper cor-rection of the item. and effectuate supervision of the person-nel involved.
5.0 Welder Qualification. This section is essentially the same. How-ever, W-1 has been expanded to include cadweld operator qualifica-tion testing and test recording requirements.
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1 6.0 Surveillance of Weldina.
6.1 Subcontractor Surveinance.
r Provides additional and detailed instructions for surveil-lance of welding subcontractors and non. destructive test-1 ing subcontractors.
- 6. 2 Field Welding Inspection.
i 6.2.1 Clarifies the requirement' that all welding procedure specifications are to be approved by Project Engi-neering.
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6.2.4 These sections provide more detailed instruction for in-process welding inspection, specifically directed to each of the three major areas of welding fabrica-tion: civil-structural, pipe, and tanks and liner plate.
6.2.5 Post Weld Heat Treatment Inspection. Requires in- ,
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spection of hea+.ing equipment installations, re-quires inspection of the calibration of temperature measuring devices and provides for inspection sign- ,
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offs on temperature charts.
7.0 ASME Code Inspection. Requires use of Quality Control Manual -
ASME Nuclear Components (Saginaw Intervenors Exhibit 15) for
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welding covered by the ASME Code.
- 8. 0 Non-destructive Tests. Requires use of specifically identified non-destructive testing procedures.
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- 9. 0 Repairs. Requires use of the Procedure for Handling Noncon-forming Materials (Field Inspection Procedure G-3) for extensive repairs which provides for proper identification and review of the s defect as well as appropriate direction and approval of the repair.
- 10. 0 Documentation.
10.1.1 References Non-destructive Testing Procedure WD-1 which contains and requires the use of extensive and detailed instructions and forms for welding documenta-tion.
10.1.2 Requires a weekly report which provides information on status of field welding operations.
-10.1.4 Nonconforming material reports added pursuant to required use of Field Inspection Procedure G-3.
10.2 Clearly defines records required to be maintained in quality control files.
W-1 deletes paragraph 8 from Section 7 of Exhibit 30, entitled "Causes
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for Weld Rejection", because these are contained in specifications appropri-ate to the specific welding work to be performed.
Paragraph 3 of the Introduction to Section 5 of Exhibit 28 emphasizes the requirement that field welding engineers cannot accept reports from craftsmen or superimendents (e. g. , the welder or his supervisor) to verify that work operations were completed satisfactorily.
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.s v July 29,1971
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sidney A. BErnsen Manager of Quality Assurance Bechtel Corporation Fifty Beale Street San Francisco, California 94119
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Subscribed and sworn to before me this 29th day of July,1971.
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Notary Public
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Su Francisco County, CaMornia E. LO;Y,TET26 My Commission expires: May 25,1972.
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ucu2v pcuc c.mo ;a an s cons cr vmw.0% s M/ W, Commes,e twem 8Asv 13.1971 (
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- APPENBDC I TO -TE'STIMONY OF DR. SIDNEY' A. BERNSEN
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- SECTION 7 QC INSPECTION
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FIELD WELDING UNITS AND SYSTEMS Inspection reeperting for field welding of units and systems shall follow
- procedures issued by the Meta 11urgyand Quality Control, the QC general procedure outlined under Section 4,and as detailed hereunder. QC con-struction inspection' reporting is required for' units and systems as desig-natc3 on NQAM Form QC-1, " Inspection Assignments".
J A. SCOPE Documentation of welding and non-destructive testing in significant se-quentsal steps shall be required for units and eystems designated by the Project Engineer to receive QC inspection. Engineering documents
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applicable to each unit or system governing field welding and test shall be referenced, including identification of qualified welders, design or erection drawings, and procedures approved under Code provisions by Engineering. .
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B. R ESPONSIBILITY The Field Wolding Engineer shall be responsible for inspection and documentation of field weldinh accomplished for Structural, Mechanical, Piping Electrical, Instrumer.c& tion and other engineering groups.
He shall also monitor, inspect and keep records on subcontractor welding. He shall report receiving of welding sapplies (primarily electrodes) on Form QC 101. He shall report slignment, fit-up, and weldment inspection on Forms QC 102, QC 102 (Welding), and/or Form QC-150.
C. FORMS AND RECORDS
- 1. In general the Field Welding Engineer st.all use Form QC 101 (Welding) (Appendix 7D) and shall not us a Forms QC 101-2-3 ex.
cept as noted.
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Exceptions ar'c Form QC 101 for quality control welding supplics.
~ Form 102 shall be used for reporting reworked weldments in-i cluding ratests .
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Form QC-150 (Appendix 7A) sha11 be used for individual welds except Primary Coolant 30" and 42" I. D. Welds. (See Paragraph C. 3 below.)
Form 102 (welding) shall be used for inspection of an isometric
, section of a system cevered by a Form QC-160.
- 2. _Q C 101 - Engineer's Receiving Report The Field Welding Engineer shall use this form to report general quality control inspection of supplies, electrodes, and accessories.
identification, and issuance of welding electrodes Jobsite Storage, hield Procedure 20.
shall conform to
- 3. Forms QC 102 (Weldina) (Appendix 7D)
In the appropriate sequence of construction process requiring PFE shall make arrangements welding inspection, the for inspection by the Field Welding Engineer. Depending . canupon assign the scope of welding to be inspected, the PFE In
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the Field Welding Engineer to report inspection of weldments.
general. QC inspection of Field welding is to be done on a "uults" or " systems" basis. Pipe welding will be reported by isometric drawing,except 30" and 42" I.D. primary pipe welds which will be reported individually on a QC 102 Form. The verification of cor-
- rect electrodes and welding accessories used by welders for each designated Q unit and system shall be reported by the Field Weld-ing Engineer on Form QC 102 (Welding). Dye checking, X-Rays and other non-destructive tests will be reported on QC 102 (Weld-ing) on an isometric basis.
- 4. Suoplemental QC Records and Drawings
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Systematic back-up records and suitable drawings shall be pre-pared prior to and during construction. Such erection records and drawings may be referenced in Form QC 102 for designated units and systems and shall be accorded identification by Q num-ber and filed. Supplemental Fie'Id Welding Records and Drawings are outlined as follows:
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- a. Containtnent Structure Liner Plate
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(1) Radiocraohic Inspection
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Form QAE-6 and drawings shall be used to show progres-sive inspection of designated welds and identification of certified welders. Supplementary records will be kept of the following information:
(a) L,'egend showing location of radiographs.
(b) Radiographs of ~ acceptable and unacceptable welds.
- (c) Detailed design of joints showing corner welds bottom seam. overhead seam, girth Jeam and vertical seams.
(d) Welder's identification to be shown.
(2) Weldina Inspection Roll-out type drawings should show all the necessary in-formation, such as: .
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(a) Weldirq procedures (b) Inapection procedures (c) Walders performing the work (d) Defects and method of repair (e) Results of final inspection (f) Correlation of each plate with heat number (3) For cther types of testing use the same type of a drawing as recommended above, such as:
(a) Unit number - job number (b) . .reas showing type of test and dates
(c) Type of tests
(.1) Vacuum (2) Dye Check (1) Air test pressure system numbers (4) Magnetic particle testing (5 ) Visual
- b. Welding of Reinforcing Bar Progressive inspection and documentation requires drawings that sh'ow elevations and locations. Records of welder quali-fication must also be in order.
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- c. Nuclear ' Power Plant Piping Progressive inspection and methods of documentation for
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permanent inspection records of critica1 piping systems require:
(1) An Index of all critical systems.
(2) Form-QC-150 (Appendix 7A) to be prepared and maintained.
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(3) Individual isometric' drawings showing field weld num-p bers, prefabricated spool numbers, and other pertinent information.
(4) When applicable, the stress relieving chart will be in-cluded in the X-ray envelope.
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(5) All welding will be done in accordance with Bechtel Weld-ing procedures designated on Form 84 (Bechtel Dwg.
5935.M-249).
(6) Forms WR-5 and WR-6 (Appendix 7B k C) may be used to facilitate weld inspection and completion of Form 150.
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, 5. Qualification of Welder and Welding Procedures
- a. Weldira Procedure Speelfications
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All welding and weld testing performed for designated units and systems shall be in strict accordance with the applicab,a job specifications. Specifications shall not includo procedures but shall require Engineering approval of appropriate pro-cedures when required to be submitted, or shall require welding to be done in accordance with appropriate procedures authorized by the Field Welding Engineer. No welding shall be permitted without prior approval of such procedures by Engineering. The Field Welding Engineer shall be responsible for correct wolding procedure and welder qualification used for Structural, Mechanical. Electrical, instrumentation units and systems. Welding Procedure for Piping is specified on " Schedule of Field Welding Procs.durcs" Form 84. Neces-sary clarification or interpretation shall be obtained from En-gineering.
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- b. Welder Qualifications
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All welders shall be qualified by performing the tests required
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by Wclder Performance Specification WQ-F-1 for ferrous ma-terials and/or WQ-NF-1 for non-ferrous materials. No welder
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shall be permitted to perform any welding on units and systems, as designated on NQAhi Form QC-1, "Inspecti(n Assignments",
for the Constructor or Sub-contractor until he has passed the necessary tests and has the Welder Performance Qualification Test Record, Form No. WR-1, on file with the Field Welding Engineer a't jobsite.
D. INS PECTION.
The general instruction for welding inspection which follows is intended to cover welding performed on designated units and systems.
- 1. Welding Procedure Specification It is the responsibility of the Fleid Welding Engineer to assure that all welding performed on Q units and systems is in strict accord-ance with the appropriate qualified welding procedure specifica-tions. Specific items to be checked are:
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- a. Determine that the proper welding procedure specification has been selected to match the base materials being welded and the welding process being employed.
- b. Permit only welders properly qualified under the essential variables of each welding procedure specification to make welds under that procedure.
- c. Check to see that the welding electrodas, bare illier rod, consumable insert rings, and backing rings all match that which has been specified.
- d. Inspect weld joints, as necessary, prior to welding to insure proper edge preparation, cleaning, and fit-up,
- e. Check to see that the welding machina settings are correct and fall within the range of current and voltage specified.
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- f. Check for proper preheat and interps.ss temperature.
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- Inspect the in-process welding for proper technique, cleaning between passes, and appearance of individual weld beads.
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- h. Determine that correct shielhing and purging gases are be-ang used for inert gas welding.
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. The Field Welding Engineer shall inspect each postweld heat treat-ment (thermal stress relieving) operation to insure conformance with the applicable. job specifications. Specific items to be checked are: .
- a. A sufficient number and proper location of thermocouples shall be selectedto accurately record temperatures.
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- b. The thermocouples shall be connected to temperature indicator records which will provide a permanent record of the heating
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rate, holding temperature and time, and the cooling rate.
- c. Temperature charts shall be checked for proper heating rate, holding temperature, holding time, cooling rate, and that the proper weld identification is recorded on the chart.
- 3. Visual Inspection of Welds The Field Welding Engineer shall be responsible for carrying out
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the necessary visualinspection to insure the following prior to, dur-ing, and after welding:
- a. All weld beads, passes. and completed welds shall be free of slag, cracks. porosity, incomplete penetration, and lack of fusion.
- b. Cover passes shall be free of coarse ripples, irregular sur-face, non-uniform bead pattern, high crown, deep ridges or valleys between beads.
- c. Butt welds shall be slightly convex, of uniform height, and shall have full penetration.
- 4. Non-destructive Tests
- a. General When the applicabic job specificatio.is require non-destructive inspection test of welds made by the Constructor or Sub-con-tractors, the Field Welding Engines:r shall be responsible for determining that standard. methods are followed and that the completed tests are properly interpreted and reported. He 7-6 ~
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shall require the respcusible personnel to demonstrate their
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knowledge and understanding of the applicable specifications, standard methods and procedures prior to beginning the tests.
He shall also review and record each completed test.
- b. Inspection Agencies
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Where non-destructive testing is specified to be performed,the services of a qualified independent inspection laboratory may be employed under the direct supervision of the Field Weld-
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, c. Acceptance Standards
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i Standards of acceptance shall be in accordance with the ap-plicable specification conforming to recognized methods.
- d. Methods Specified non-destructive te.sts shall be in accordance with Bechtel NO AM-7.
- e. Leak and Hydrostatic Tests ,
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Leak and hydro testing shall be the responsibility of the assigned Field Engineer.
- 5. R epairs It shall be the responsibility of the Field Welding Engineer to de-termine that all weld defects in excess of specified standards of acceptance shall be removed, repaired, and re-inspected in ac-cordance with the applicable job specifiestions.
- 6. Storare and Idsntification of welding Supolies and Accessories
- a. Electrodes Classification shall be in accordance with AWS-ASTM Classi-fication System. ASTM (Vol. 4) specifications are illustrated as follows:
ASTM A 233 Mild Steel Covered Arc-Welding Electrodes 7-7
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Corrosion-Resisting Chro-ASTM A 298 mium and Chromium-Nickel Steel Covered Welding
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Electrodes Low Alloy Steel Covered ASTM A 316 Ar .-Welding Electrodes Mild Steel Electrodes for
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ASTM A 559 Gas Metal-Arc Welding
- b. Sto rage _
Electrode storage and control shall be in accordance with Field Procedure 20.
- 7. _R e cord s
- a. It shall be the responsibility of the Field Welding Engineer to prepare records and use the appropriate Q number to identify units and systems reported.
- b. Records shall be maintained and used for effettive operation
~ of the program and shall be subject to review to determine completeness and usefulness.
- c. Records shall be subject to regular analysis by the Field Weld-ing Engineer to determine cause for scrap and rework and to develop trends in processes and wonk performance.
Corrective action in regard to perft rmance of suppliers and vendors shall be recommended to the Project Engineer.
Corrective action in regard to discrepant material shall be recommended to the Project Superintendent.
B. Causes for Weld Rejection All welding of Q units and systems, lacluding welder qualification tests,shall comply with the following requirements. Any weld hav-ing one or more of the typical defects listed below shall be subject to rejection by the Field Welding Eng'neer. Records of weld de-fects and repair shall be kept on the weld X-Ray envelope.
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~ a. Failure to meet radiographic acceptance requirements,
- b. Less than 100 percent penetration for entire weld length,
- c. The presence of porosity or inclusions in excess of that per-mitted under the specification.
- d. Lack of fusion. ,
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- e. Cracks. .
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- f. Co,1d lapping.
- g. Evidence of peening.
- h. Undercutting adjacent to complete weld.
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Welds not reasonably uniform in appearance.
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Failure to meet required tests.
- k. Welding performed by unqualified personnel. ,
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- 1. Unacceptable indications as disclosed by magnetic particle or liquid penetrant inspections.
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BECHTEL JOB NO.
Field Weld CheckOf f List I
, Weld No. _
System . ISO .- _ ..- - .___._
Dia. W.T.
Material _
Root Pass Welding Filter Metal
,* Feller Passes Weld Procedure . ..
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r s, Proper Fit up Alignment
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Preheat ..._.y._ ,
Post Heat Purge Wekling Completed Released for Welding
- Liquid Penetrant ywg gyg-a NOT Magnetic Particle Radiographed
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Results .
Symbol Welders Name Welders N.wne _ . ._
Symbol .
Cartif M es correct:
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Name Date
- eorem weid no saepector APIENDIX 7B
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% r . wn4 BECHTEL JOB NO.
Filler MetalWithdrawal Auth'orization '}
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Type Systern Filter Rod -
S're ISO Type -
Weld No. .
Coated Electrode Site Weld Procedure
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Authorized by: - - - Date g Warehouse:
Date Issued by .
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APPENDIX 7C
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at oN/SPE C. seo. Stoe.aaEa o **We E A Datt Leong aSa#Sc ost uttS6
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-0 " *E T S n T S co u etqwf Sven Joe E ms, sa n w ec g ese oocuur=T iwSPE c Tion enoc e ss '3**1' o*Te e'restosass=Ean
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own. we a o no. % a..
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wEto rnoCEn no.
WEL DE R ONDENT R Aoeoon Arn ACCap Ea REJEC s t o ASTM E se ACCfPTfD RE JE C T E D ASIM E 309 MAC. PART tCL E UL1RA50Nec ACCErgEn RE JE C f EO A&lM E 864 RE JEC TE D ASTM E 36% LIQ. Pt hE T R AN T ACCEP18D PkTdf kfl& MP.
PO5THE AT TE MP- TIME (LTCf 46bEs
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'"'**'0"E aCanss our THE won Apet iC Ami Ei co ea' 015iRteuTeoss No. I-To the Meiect Enginees No. 2-To the Jet
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leo. 3-To QAE
- etsosace INSTALLED INSPECTION REPORT FORM QC 102
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1 APPENDIX 7D 4
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APPENDDC II TO TESTIMONY OF DR. SIDNEY A. BERNSEN SECTION FIVE WELDING -
INTRODUCTION
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f-The contents of this section will be utilized by field engineering personnel involved in welding to perform the activities defined in bah Project, and Materials and Fabrication Quality Control Services specifications and procedures.
The procedure will be applied in accordance with the It spe'cifications shall provide approved by Project Engineering for the project.
standard direction but not limit or exclude other inspection prac.
tices which may be required to ensure the quality and integrity of it anall provide direction to. fulfill the
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the completed installation: insure the proper performance of the specification requirement, work and provide records of inspection to verify compliance to the
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design.
The terms verify, check and confirm as uttitzed in the procedures have the common meaning that the assigned field engineer shall perform the inspection or tests, witness personally the performance of the in pection or tests or have knowledge aret recordssubcontrac-to substan-tinte that other responsible field engineering p .sonnel, tor's technician or other authorized personnel lave performed taa inspe ctions , surveillance, and tests that have been specified Welding
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SECTION FIVE
. WELDING -
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Rev. Date
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W-1 INSPECTION OF W, LDING 1.0 SCOPE O 8/3/70
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- 2.0 RE FE'RENCES . 0 8/3/70 3.0
- RESPONSIBILITY 0 8/3/70
.4.O MATERIAL CONTROL 0 8/3/70 5.0 WELDER QUALIFICATION 0 8/3/'0 7
6.0 VISdAL SURVEILLANCE OF WELDING
- OPERATIONS 0* 8/3/70 6.1 Welding Engineer i, 4 6.2 Field Welding Inspection
- 7. 0 CRITICAL WELDING INSPECTION O 8/3/70
- 8. 0 CODE INSPECTION 0 8/3/70
- 9. 0 NONDESTRUCTIVE TESTS - 0 8/3/70 9.1 -General 9.2 Magnetic Particle Inspection
- 9. 3 Liquid Penetrant Inspection 9.4 Radiographic Inspection 10.0 REPAIRS 0 8/3/70 11.0 DOCUMENTATION 0 8/3/70
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Field Inspection Procedure W-1
.THE INSPECTION Oh VELDING
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This procedure provides direction for Field Engineers performing inspection and surveillance of field welding operations.
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2.0 - REFERENCES The Project Specifications and design documents including the following shall be utilized in performing inspection under this procedure and shall establish the basis for acceptable installation:
2.1 Project Specification for the Field Fabrication and Installation of Piping and Instrumentation. . ..
2.2 Project Specification for Piping, Material, Classification and Standa rds.
- 2. 3 Project Specification for Radiographic Inspection of Field Welded
, Pressure Vcssels and Piping.
2.4 Nondestructive Testing Standard Procedure Specification.
Form 84 Welding and Nondestructiva Testing Requirement for field erected Piping.
MT-P -1 Magnetic Par ticle Inspection.
PT-S R-1 Liquid Penetrant Inspection.
RT-XG - 1 Radiography, Non-Nuclear.
CR-NDT General Requirements.
WO-1 Welding and Nondestructive Testing Documentation.
F1P W-1
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2.5 Welding Standard Procedure Specifications WQ- F- 1 Performance specification, Ferrous.
WQ-NF-1 Performance specification, Non-ferrous.
WFMC-1 Welding Filler material control.
PHT-500 hostweld heat ' treatment of field welds. -
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2.6 Project Specification for FieId Welding, s
2.7 Quality Control Manual - ASME Nuclear Components.
3.0 RESPONSIBILITY The requirements of this procedure are implemented by:
3.1 Testing Laboratories, which provide qualified technical personnel to implement NDT procedure are sub-contracted in accordance with Reference 2.3 Technical Specification for Radiographic In-
. spection of Field Welds.
'. ? The assigned Welding Engineer, who shall perform the inspection ;
defined by the procedure and the surveillance of the nondestructive testing subcontractor. He shall resolve conflicts, lack of clarity or deviation from the reference documents by the Procedure for Design Document Control G-Z prior to the performance of the work. He shall requisition welding materials required by the )
project welding procedures. He shall e 3rdinate his activities !
with the associated piping, electrical, n schanical and civil field 1 engineers relative to performing integrated inspection, as required. ;
He shall coordinate with field supervision to insure timely inspec- l tion and repair or correction of deficiencies. He will judge the I acceptability of nondestructim testing.M. performed relative to welding and shall monitor or complete documentation in accordance l with project requirements.
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- 4. 0 MATERIAL CONTROL 4.1 The field welding engineer shall utilize Welding Standard
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Procedure Specification number WFMC-1, Welding filler material control, sections 1.0 through 7.0 for direction in the Procurement, Material Receiving, Storage Control and Disbursal of Welding Materials.
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The receivinghersonnel shall record the receiving inspection and status of " documentation for welding materials by signing the (MRR) in accordance with procurement procedures or the Field procedure for the Control of Materials G-5
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The welding engineer shall coordinate with field supervision the control of material storage areas and the utilization of welding rod in accordance with procedure WFMC-1 He shall inform field supervision of discrepancies in the application of the procedure as determined by inspection.
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- The welding engineer shall inform the Project Field Engineer or Quality properly Control Engineer when corrective action is not taken. *
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- 5. 0 WELDER QUALIFICATION Welderengineer.
welding qualification and testing shall be under the direction of a field All welders So are to make welds under Bech: 1 Welding Procedure applicable Technical Specification WQ-F-1 forSpecifications sha WQ-NF-1 for non-ferrous materials. ". rrous materials and the necessary tests. and -has- the.-appropriate -
ssed Welder P nce Qua-lifi-catior. Test Record Record on file at the (Form jobsite.WR-1) or Caldweld Operator Qualificati on Test f.
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6.0 SURVEILLANCE Oh WELDING OPERATIONS The assigned welding engineer shall be responsible for performing the
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necessary . inspection and/or surveillance of welding operation involved in the construction of the project by Bechtel or Bechtel Subcontractors, 6.1 Subcontractor Surveillance
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A welding engineer will be assigned to perform inspection and surveillance ci subcontractors performing welding and nondes-tructive testing on the project. The welding engineer shall verify that the performance of the subcontractor is in accordance with
- the rei[uirements of the design documents, and is in compliance
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with his own quality control program, where required, auditing
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such programs in conjunction with Quality Control and Quality Assurance engineers in a manner compatible with NOAM require-m ents.
6.1.1 Specifically the welding engineer shall:
6.1.1.1 Confirm engineering approval of all welding procedures used by the subcontractor.
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6.1.1.2 Confirm that subcontractors welder and nondestructive testing personnel are qualified as required before they perform any work.
6.1.1. 3 Check subcontractors welding filler material control practices.
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6.1.1.4 Check the subcontrr : tors in-process welding control practices. \ssure that the sub-contractor's visual a cceptance of welds is compatible with the applicable sections of this procedure under paragraph 6.2.
6.1.1.5 Designate location of spot radiographs in accordance with co stractual requirements.
6.1.1.6 Check the subcontractor's records for docu-mentation of nondestructive tests. Confirm FIP W-1 Rev. 0 8/3/70
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interpretation and acceptability of associated documentation such as :c-ray film ar.d stress
, relieving charts.
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6.1.1.7 Verify repair of all welding defects and repairs made by welding.
6.1.1.8- Witness all subcontractor pressure and
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6.1.1.9 Confirm that all applicable records are available at the site and are readily available f- for review or audit.
6.2 Field Welding Inspection:
The welding engineer will perform visual inspection prior to, during and after welding to verify the compliance to welding procedures and acceptable workmanship.
6.2.1 General
The welding engineer shall, for all welding operations, verify the following:
6.2.1.1 Ascertain that the welding procedure specifi-cations are "those approved by project engi-neering for utilization on the project.
6.2.1.2 Ascertain that all welders are qualified and that qualifications ar.a so documented. .
- 6. 2.1. 3 Ascertain that only selders who are properly qualified under the essential variable of each welding procedure specification make welds under that procedure.
6.2.1.4 Verify that the proper welding procedure designated on the Form 84 matches base materials and the process being employed.
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6.Z.1.5 Ascertain that the welding machine settings are correct and fall within the range of current and voltage specified by the welding
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procedures.
6.2.1.6 Asce'rtain that the welding electrode or base filler wire utilized match the welding pro-
, cedure requirements and application for root
,- pass or, filler.
6.2.2 Civi Structural' Welding' Inspection f The welding engineer shall perform inspection on Civil /
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Structural welding to ensure compliance with design.
The engineer shall:
6.2.2.1 Inspect weld joints as necessary prior to welding to insure proper fit-up, edge preparation and cleaning.
6.2.2.2 Inspect the in-process welding for proper te chnique, cleaning between passes, appear-ance of individual weld beads *and sequence of welding where required, t
6.2.2.3 Verify that proper preheat and interpass temperature is being used.
6.2.2.4 Verify that correct shielding and purging gases a.re being used for inert gas welding.
6.2.2.5 Inspect fillets for s,.ecified size with full throat and legs of s.tiform height.
6.2.2.6 Verify that butt weMs are slightly convex, are of uniform height and have full pene-tradon. ,
6.2.2.7 Verify that wcld beads, passes and completed welds are free of ulag, cracks, po rosity, incomplete penetra* ion, undercut, or lack of fusion.
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6.2.'2.8 verify that cover passes are free of coarse ripple s , irregular surfaces non-uniform bead pattorn, high crown, deep ridges or valleys
' between beads.
6.2.2.9 Confirm inspection of cadwells and rebar splices in accordance with the Field Inspection Procedure for the Installation In4pect.on of
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Reinforcing Steel and Wire Mesh C-4, '
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6.2.3 Pipe Welding Inspection
/ 'The welding engineer shall perform inspection on pipe welding to ensure compliance with project references.
The engineer shall:
6.2.3.1 Ascertain that the cleanliness of piping is acceptable prior to making fit-up as required.
6.2.3.2 Inspect weld joints and pipe before welding and the following during fit-up operations.
- a. Edge preparation.
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- b. Edge transition, from thick to thin sections.
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- c. Mismatch - internal tolerances.
- d. Internal piping cleanliness.
- e. Utilization of insert or backing ring,
- f. . Spacing between ends.
6.2.3.3 Inspect in-process miding for proper technique. I cleaning between paises, and appearance of I individual weld beads. )
6.2.3.4 Verify that proper preheat and interpass temperature is beln-; used.
6.2.3.5 Verify that requiref. shielding and purge gases are being used for inert gas weltaing, i
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6.2[3.6 Inspect fillet welds for specified size with
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full throat and legs of uniform height.
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6.2.3.7 ' Check nondestructive testing of Jillet welds where specified.
.6.2.3.8 Verify the surface weld reinforcement limitations, both internal and external, on
.- piping butt welds. .
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6'.2.3 9 Verify that the fit-up practices on socket weld fittings comply with applicable applic-
. #- able standards and codes.
l Verify that repair, chipping or grinding of 6.2.3.10 welds is done in such a manner as not to gouge, groove or reduce the adjacent base metal thickness.
6.2.3.11 Verify that the correction and nondestructive testing of surface defects has been done in accordance with project specification
require-ments.
6.2.3.12 Verify that weld beads, passes and completed welds are free of slag, cracks, porosity, incomplete penetration, undercut, or lack of fusion.
6.2.3.13 Verify that cover passes are free of coarse ripple s , irregular s triaces, non-uniform bead pattern, high c. town, deep ridges or valleys between bea.es and that they blend smoothly and gradually into the surface of the base metal.
6.2.3.14 Determine weld shr .nkage, when required.
i 6.2.3.15 Check that each we* der stamps or identifies his weld upon com::letion, whether required by code or not.
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6.2.4 Tanks or Line Plate Welding Inspection
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The welding engineer shall perform inspection on tanks, liner plates, and vessels to ensure compilance with design. The engineer shall:
6.2.4.1 Verify that weld area is free of protective
,- surface coating and is clean prior to
,. welding.
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6'. 2. 4. 2 Verify that alignment, root opening and fitup is in accordance with welding procedure.
/ *6. 2. 4. 3 Verify that the plate thickness variations are in accordance with design drawings.
6.2.4.4 Inspect in-process welding for proper tecimique, cleaning and back gouging between passes and appearance of individual weld beads.
6.2.4.5 Verify that the welds are uniform in width and size through the full length.
6.2.4.6 Verify the establishment of welding sequence, as required to maintain alignment, etc.
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6.2.4.7 Assure that each layer of welding is smooth and free of slag, inclusions, cracks, porosity, lack of faafon and undercut. In addition assure that the cover pass is free of coarse ripples, irregular s .rface, nonuniform bead patters, high crown. deep ridges or valleys between beads.
6.2.4.8 Assure that butt welds are slightly convex, of unifcrrm- height and have full penetration.
6.2.4.9 witness testing, vs..:uum or pressure of weld on bottoms, nozzle reinfo rcement, leak detection channels, etc.
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6.2.4.10 Verify that each welder identifies his weld in accordance with specification requirements.
6.2.5 Postweld Heat Treatment Inspection 6.2.5.1 A sufficient number of properly located thermocouples shall be selected 6 record temperatures accurately.
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6.2.[.2 The thermocouples shall be connectfd to temperature indicating-recorders which will ,
provide a permanent time-temperature y record.
6.2.5.3 Check to ensure that coils or resistance matts are properly applied and insulated in accordance with manufacturer's directions.
6.2.5.4 Temperature charts shall be checked for recorder r. umber, prope r heating rate, holding temperature, holding time, cooling ra te , date, weld identification and inspection signoff on each recorded chan,
- s. 6.2.5.5 Check to assure that thermocouples and
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recorders are properly classified and calibrated.
7.0 ASME CODE INSPECTION Field inspection of welding covered by the ASME Code as noted on Form 84 shall be in accordance with the Qualit) Control Manual -
ASME Nuclear Components.
- 8. 0 l NONDESTRUCTIVE TESTS ' l i
Specification requirements calling for nondestru:tive testing will be dono in accordance with the following Procedurn Specifications published FIP W-1 Rev. 0 8/3/70 Page 10 of 12
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by Materials and Fabrication Quality Control Servicest GR-NDT General Requirements RT-XG-1 Radiographic Tssting MT-P- 1,2 Magnetic Particle Testing PT-SR- 1, 2 Liquid Penetrant Testing 9.0 REPAIRS .- .
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It shall be the responsibility of the field welding enginese to determine that all weld defects in excess of the specified standaris of acceptance shall be remoyed, repaired, and re-inspected in accordance with the applicable job specifications.
The field welding engineer shall .itiate the application of the Procedure for Handling Nonconforming Materials when he discovers the existence
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of unique or abnormal defects requiring extensive repairs. Acknowledg-ment or engineering direction will be obtained, according to the procedure, prior to proceeding with the repair.
10.0 DOCUMENTATION
'i.;, 10.1 The field welding engineer shall initiate and maintain the following records to implement this procedure and provide verification of
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compliance to design, 10.1.1 Documentation as listed in Nondestructive Testing Procedure WD-1.
10.1.2 A weekly report and records cuvering the status of the followingt 10.1.2.1 Nondestructive Testing.
10.1.2.2 Welders Qualified hf craft on hand.
10.1.2.3 The number of welds performed and the reject rate for Pipo Fitters.
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10.i.2.4 The material inventory and filler metal -
control.
10.1.2.5 ' Accept / Reject rate of process piping welds.
-10.1.3 Field Inspection " Reports For a record of field inspection performed on civ'1 components, subcontractor activities field fabrication of tanks and conventional piping to define, Ghat was inspected, nature of inspection, result, corrective
' action, as required.
J' 10.1.4 Nonconforming Material Reports ,
For a record of nonconformances as determined by application of the Field Procedure for the Control of Nonconforming Materials.
10.2 The records required by Nondestructive Testing Procedure WD-1, paragraph 10.1.1, Field Inspection Reports, paragraph 10.1.3, and the Nonconforming Material Reports, paragraph 10.1.4 should re-flect the current status of construction and shall b'e in the Quality Control files.
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The weekly reports and records Paragraph 10,1.2 are administrative information that may be obtained from the Welding Group upon Project Superintendent approval.
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, FIELD WELD CHECK-OFF LIST Jcb No. Unit No.
GENEtt AL INF ORMATION Bechtet W. F.. l Atithoriacd C..d.' Ina t Initiais j Da te l Sienaturc lDate
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l System f Iso, No.
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Weld No.
Material Diameter Wa 1 Thickness
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Welding Procedure Filler Metal: R oot Filter Passes Preheat Proper Joint Preparation ..
and Fit-Up
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Released for Welding Welders Name 8: Symbol Weldera Name k Symbot WELD INSPECTION DATA Visual Inspection
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Post Heat Temp. Time Liquid Penetrant: Root Cover Ma;;netic Particle Radiogra phed
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Radio;traphy Results: Accepted Rejected CEf!T!FIED CORit ECT -
Ucchtet .'Ic tding Enginee r Date -
Signaturc
. Wlt -i. It e r. (4/14/70)
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FORM WR.6 Revised 8/6/69
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BECliTEL JOB NO. <
FILLER METAL WITifDRAWAL AUT110RIZATION _ ~
FOR SPECIAL NUCLEAR SYSTEMS -
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Welder's Name 1. Bare Rod & Consumable Inserts *.
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System Type Size Santity
- Heat No.
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- 2. Coated Electrodes Weld No.
- Type Size
. Procedure Spec. No. Santity
- Lot No. ,
Special Certified Test '
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Reports Required (Yes) (No) i l
Authorized by Date
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(Field Welding Engineer)
Issued by . Date
(Wa rehouseman)
- NOTE: lleat and Lot Nos. required only when so designated on Form 84.
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- CCNSUMERS POWER COMPANY ENGINEERING DEPA N QUALITY ASSURANCE PROGRAM
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Differences Betwee's Engineering Department QA Effort Prom Vintage 1967 to Midland Plant
- 1. Organization
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- a. In 1967 there was one perse, the Quality Assurance Engineer (QAE),
s who was responsible for shop auditing, and be used engineers from the engineering and operations group to assist him. There were Civil, Electrical, Mechanical, and Nuclear Engineers. Tir QAE was available upon request to audit any phase of the plant constmetim.
- b. The present organizatim is defined in Appendix 1B and Amendments 6 and 8 of the PSAR. This organization was also described in answer to Interroga-tory 11+8. The present organizaticut can be briefly described as consisting of a QAE vho performs independent audits on all phases of the Midland Plant in-cluding design, fabrication of compcsients, construction, pre-operational testing, and plant maintenance and operations. The present organization also consists of increased personnel in N engineering categories, including a metallurgist who functions as assistant QAE. The QAE can still call upon any speciality groups within the Capany to assist him in his duties.
- 2. QA Program
- a. In 1967 there were no written policies, procedures or instructions.
- b. The Midland QA Audit Program consists of procedures and instmetions which are included in the Consumers Power Capany GA Manual [3.I. Exhibit No. 31].
See answer to Interrogatory 162.
- 3. -Design Control a.
In 1967 there were Project Procedures manuals which controlled the routing of specifications, purchase orders, piping and instrumentation diagrs=s, and electrical schematics to the various engineering disciplines.
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2 b.
The present design control procedures are effectively the same, how-
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ever, there is a larger staff of engineers for the projects and the services group.
- 4. Procurement Document Control
- a. In 1%7 there was no procedun to define requirements of docunent review.
- b. There is now a procedure for reviewing documents (E-1) which is in-cluded in the Consumers Power Company QA Manual.
5 Instructions, Procedures, and Drawings a.
In 1%7 there were no instructions, procedures, or drawings to control Consumers Power Company's activities affecting quality.
.b. . There are nov instructions and proceduns which are a part of the Consumers Power Company QA Manual and written responsibilities for the engi-neering disciplines.
- 6. Document Centrol a.
In 1%7 there vere no written procedures or instructions for document control within Consumers Power Capany.
b.
The present doctsment control procedures and instructions are a part of the Ccasumers Power Company QA Manual (DOC-1).
7 Control of Purchased Material, Equitment, and Services a.
In 1%7 there were measures established to assure that purchased ma-terial, equilment, and services were obtained from a qualified vendor. There vere no measures to assure that equi}snent conformed to the procurement documents.
b.
The present QA Audit Plan requires that the Consumers Power Ccapany QAE file vill enain or otherwise have available at the conclusica of the QA progres
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3 verification by a responsible Eschtel Engineer that a structure, system, or component has been designed and procured in accordance with governing documents.
- 8. Identification and Control of Materials, Parts, and Components Not Applicable.
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, 9 Control of Special Processes
- a. In 1967 Consumers Power Company reviewed welding procedures, velder qualifications and non destructive testing procedures, however, there were no detailed check sheets,
- b. The present progrsa is the same as above except that detailed check lists and doctmentation are used. See Interrogatory 159 which includes examples of check sheets (General Material and Veld Review Sheets).
- 10. Inspection
- a. In 1967 there were reviews made of saae vendors inspection programs to designate Applicants Hold Points.
- b. This same program is presently used.
- 11. Test control
- a. In 1967 there were preoperational test procedures written and reviewed by Consumers Power Company cognizant engineers. . Vendor test procedures were also reviewed. After r nning of vendor tests or preoperational tests the results were reviewed by the same engineers and by other Consumers Power Campany engineers.
- b. The present program vill be the same as above with the additica of an audit responsibility by the consmers Power Company GAE.
- 12. Control of Measuring and Test Equignent
- a. In 1%7 there was an audit made to assure that tools, gages, instrtments, etc., which were used in vendors' shops and affected quality were properly con-trolled, calibrated, and adjusted to maintain accuracy.
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- b. The present program is the same as above except that check sheets are used (General Material and Veld Review and QA Program Audit Review (10 CFR 50) .
13 Handling, Storage and Shipping
- a. In 1%7 engineers reviewed specificatiens fer shipping, cleaning and storage requirements. The Consumers Power Company CAE audits vendors for handling, storage, shipping, cleaning and preservation of equipment.
- b. The present, program is the same as above except that it is included as an entry on the check sheet (General Material and Weld Review and QA Program AuditReview10CFR50). In additica a more comprehensive audit of site k amas and storage of equipment is planned.
14 Inspection, Test and Operating Status
- a. No audits were made in 1%7 since it was not a part o- our Engineering Department Program.
- b. The present program vill require an audit of inspection, test and operating status. (General Material and Weld Review Check Sheet and QA Program Audit Review 10CFR50).
15 N mem fo ming Materials, Parts, or Components
- a. In 1%7 control of non-conformance was by letter only. There was also review of vendors' non-conformances to assure corrective actim was taken.
- b. The present program for ccatrol is in Consumers Power Company QA Manual Procedure D8C1. There vill also be reviews of vendors' and constructim non-confonnances to assure corrective action is taken (General Material and Weld Re-view Check Sheet and QA Program Audit Review 10 CFR 50).
- 16. Corrective Action
- a. In 1%7 there vere no written measures to assure that conditions adverse to quality were pro:nptly identified and corrected.
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Tim present program consists of a discrepancy report by the Consuers Power Company QAE. This report along with the overall QA Program is reviewed periodically with Consmers Power Ccapeny management.
- 17. ' Quality Assurance Records a.
In 1967 the Constaners Power Ccmpany QAE records consisted of specifi-cations, inspector reports, miscellaneous correspondence, and Constners Power Company QAE reports of vendor audits.
{ b. The present program for maintaining records in the Constners Power Campany QAE file is defined in Amendments 6 and 8 to the PSAR and a file check
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sheet is used to assure that required documents are in the file. See Interroga-tory 159 (Consumers Power Capany QAE File Check Sheet).
- 18. Audits
- a. In 1967 there were no written instructions or procedures for the Consumers Power Company QAE Audit.
b.
The present program includes procedures, check lists ar4 foms. The vendors which are to be audited are selected by the Censumers Power Ccupany QAE.
This is defined on page 9 of Amendment 6 to the PSAR.
The QAE at his discretion also now audits the architect-engineer, Constners Power Company's progrc: 3, field inspection and operations. The present program provides for all 18 Criteria of 10 CPR 50, Appendix B.
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CONS"!ERS POWER COMPANY CO!QFrRUr*2 ION ORGANIZATION Quality Contzel/ Quality Assurance Program From 1967 to the Present
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I. Orgnnization In 1957 no tomally designated Quality Assurance or Quality control or-genization existed in Consumers Power Capany Field Forces. A staff of Field PntH neers conducted surveillance and inspection based up m code and specifica-tion reluirements, and methods of good castruction practice. A Quality Assur-ance Program was fomally organized for the Consumers Power Capany Field Forces in 1969 The present Quality Control / Quality Assurance organization is shown on the attached organizational chart.
The construction organization consists of a Quality Control Team headed by the Quality Control Supervisor, fomerly called the Field Quality Assurance Engineer, who zuports to the Project Superintendent.
The Quality Control Supervisor's responsibilities include:
- 1. Detemining that Bechtel's field QC-QA Program is properly inplenented.
- 2. Insuring that necessary corrective actions to deviations fr a the QC-QA Programs are accomplished.
3 Insuring the proper documentation of QC-QA measures during the con-struction and start-up phases of the project is provided.
- 4. Cmducting quality coordination meetings between contractor and Consumers
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personnel.
5 Reporting confomance to, or deviations fzum plans, specifications, and QC-QA requirements to the Project Superintendent and the Quality Assurance Engineer.
The Quality Control Supervisor has the authority to stop work on any construc-tica operation in the event of nonconformance with applicable requirements.
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2 II. Quality Assurance Program In 1%7 no formal Quality Assurance Progrea was defined for construction.
Inspection was conducted as in I., above.
In 1%9 a group of audit forms were prepared as a guide for perfoming Quality Assurance audits. A Field QA engineer (now called Quality Control Supervisor) was appointed to dirwet this newly created QA Pro 6 rem. Scme pro-cedures were written to provide guidelines for performing the audits.
Presently a group of inspection procedures and check lists for field quality surveillance at the Midland Plant Project comprises the Field Audit and Inspection Manual (S.I. Exhibit No. 23]. These procedures generally have evolved fram previously used procedures which were modified, expanded, and rewritten in considerably more detail.
III. Design Control - Not Applicable.
IV. Procurement Document Control In 1%7 no forinal review of field procurement doctaments for quality re-quirements was in effect.
Presently a procedure for quality review of field procurement doctments has been drafted for inclusion in the Field Audit and Inspection Manual for the Midland Plant. This procedure vill insure that Quality Control / Quality Assur-ence requirements are specified in field procurement documents, and will be in-cluded in the manual prior to the restanytion of construction.
V. Inst metions, Procedures and Drawings - Not Applicable.
VI. Document Control.
In 1%7 there were no formalized procedures to control the issuance and review of documents in the field.
Presently, Procedure DOC-1 of the Midland Plant QA Manual [S.I. Exhibit 31]
has been placed in effect for the Midland Plant to assure that documents, and changes thereto, are properly controlled and reviewed for adequacy.
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3 VII. Control of Purchased Material, Ecuipnent and Services In 1967 Consumers Power Ccarpany Field Engineers reviewed purchased ma-terial, equipnent and services to verify confomance to procurement documents, but no written procedures were used to accomplish this activity.
Procedures are in effect for the Midland Plant Project to assure that purchased material, equipnent, sai services conform to procurement documents.
Procedure FI-ll3 of the Field Audit and Inspection Manual provides a guide for perfoming audits to assure that Bechtel Corporation has conpleted the proper receiving process for purchased material.
VIII. Identification end Control of Materials, Parts and Cmponents In 1967 identification sai traceability of material was required to scoe degree, however, no fomalized procedures were in effect.
As described in VII above, Procedure FI-113 has been placed in effect to assure proper identificatice and traceability of material.
IX. Control of Special Processes In 1967 no formalized procedures vere in effect, however, special proc-esses were perforned by adherence to specifications and requirenents. This ad-herence was checked by Consumers Power Company Field Forces.
Presently, the field audit and inspection procedures for the Midland Plant provide detailed, femal instructions for the control of special processes.
(See Procedures FI-104, FI-107, ani FI-ll2 of the Field Audit and Inspection Manual).
X. Inspectica As stated in I., above, inspection was perfomed by Consumers Power Ccmpany Field Engineers using code and specification require =ents as a basis in 1967 Presently, inspection is perfomed by a Consumers Power Ccupany @ulity Control Group using a set of inspection procedures prepared for the Midland Plant Project.
(Field Audit and Inspection Manual).
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