ML20081B061

Answer Opposing Joint Intervenor 831020 Motion for Revocation of OL or for Continuation of Suspension.Applicant Has Not Misrepresented or Failed to Disclose Facts. Certificate of Svc Encl

ML20081B061
Person / Time
Site:	Diablo Canyon
Issue date:	10/25/1983
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8310270263
Download: ML20081B061 (13)

Text

i

(

.' 00CKETED USNRC UNITED STATES OF AMERICA . . .

NUCLEAR REGULATORY COMMISSION v

CFFICE OF SECT.E' CCOM.biWi 4 59 a.

MDl BEFORE THE COMMISSION In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275

) 50-323 (Diablo Canyon Nuclear Power )

Plant, Units No. 1 and 2) )

)

l ANSWER OF PACIFIC GAS AND ELECTRIC COMPANY TO JOINT INTERVENORS' MOTION FOR REVOCATION OF FACILITY OPERATING LICENSE OR, IN THE ALTERNATIVE, FOR CONTINUATION OF SUSPENSION In a document dated October 20, 1983 the Joint Intervenors in this proceeding seek an order from the Commission revoking PGandE's license No. DPR-76 or, in the alternative, an order continuing the existing suspension of the license. While the Commission has the authority to afford the relief requested, grounds for such relief must exist before the relief can be granted, and, as will be shown subsequently, the grounds advanced by Joint Intervenors are not sufficient to afford them the relief requested. Therefore, Joint Intervenors' motion must be denied.

8310270263 831025 , O PDR ADOCK 05000275 /

G PDR

a

1. Statement of Facts Joint Intervenors, in seeking revocation or continued 1/

suspension of PGandE's license No. DPR-76, once again- drag out an audit report dated October 24, 1977 prepared by Nuclear Services Corporation (now known as Quadrex but hereinafter referred to as NSC) for Pullman Power Products Corp. (Pullman). Joint Intervenors cite this audit report as evidence to support their allegation that PGandE has made a material false statement and that therefore its license should be revoked or the suspension continued. PGandE and the NRC developed reasoned responses to the Joint Intervenors' earlier motion, each supported by an affidavit, which are determina- l tive of the merits of the instant motion. Copies of these earlier responses are attached to the Commissioners' copies of this answer, having already been served upon all other parties, and will only be summarized here.

In general, the responses serve to put the audit relied upon by Joint Intervenors in perspective and confirm that both PGandE and its contractor had acceptable programs in place for construction quality assurance at Diablo Canyon during the time in question.

Thus, there is no basis for asserting that PGandE has made a material false statement in so characterizing its construction quality assurance program.

1/

~

The identical report was used as the basis for a supplement to their motion to reopen the record to consider construction quality assurance (COA) . (See discussion infra p. 9 .)

l The audit in question was commissioned by Pullman and was conducted by NSC from August 22, 1977 through September 20, 1977.-

A report of the audit findings was submitted to Pullman on October 24, 1977. This report contained a number of very sweeping and generalized assertions and conclusions. In areas requiring

< evaluation and interpretation, the auditors measured the quality of the work effort against then. current (August 1977) ANSI Standards, Nuclear Regulatory Commission Regulations, and Regulatory Guides.

This approach did not comport with the stated purpose of the audit to evaluate the work effort against the codes, regulations, and standards in effect at the particular time in the past when the work was actually performed. The problem apparently arose from the auditors' erroneous interpretation that organizations must "backfit" work done to previous codes and standards to meet current standards.

This erroneous interpretation and approach to the audit had the practical effect of invalidating much of the entire NSC effort.

1 After receipt of the NSC audit report Pullman conducted its own in-depth review of the findings. Of the original 137 findings by NSC, 58 were favorable to Pullman, Pullman disagreed with 25,

[ Pullman provided additional explanation to clarify its program compliance with 29 findings and took action to correct the remaining 25 findings. The 25 findings with corrective action to

-2/

During the time of this audit the ASME was also conducting its own audit of Pullman which led to the recertification in 1977 by the ASME of the NA and NPT stamps specific to Diablo Canyon previously issued Pullman in 1972, hardly evidence of glaring l

deficiencies in Pullman's quality assurance program.

be taken were softward specific i.e., paperwork improvements.

None required correcting hardware deficiencies. Subsequently, these actions were all documented and dispositioned in accordance with Pullman and PGandE quality requirements.

The NSC audit report and Pullman response were formally forwarded to PGandE April 11, 1978. A PGandE quality assurance audit team retraced in detail the steps of the NSC auditors and concluded that the NSC audit did not give an accurate measure of the overall Pullman quality program. To confirm this and to confirm there were no deficiencies in the physical work PGandE conducted a thorough audit of the Pullman quality assurance program during April and May 1978. The PGandE audit concluded that Pullman's program essentially fulfilled contract and regulatory requirements. Where deficiencies were identified they were documented in accordance with established regulatory procedures and subsequently corrected. In this connection in June 1978 PGandE initiated two nonconformance reports and four minor variation reports, which were all closed and appropriately documented by early 1979.

The NSC audit, Pullman response, and PGandE audit were all timely placed in PGandE's files where they were available for l inspection. During this period of construction NRC Region V Inspection and Enforcement (I&E) Inspectors were conducting unannounced site inspections on roughly a monthly basis. NRC l Inspection Reports, copies of which are attached to the Staff's

~4-l L

reply to the Joint Intervenors' supplement to their motion to reopen to consider construction quality assurance, describe the reviews that NRC inspectors made on a routine basis of Quality Assurance audits and nonconformance reporting. This process reflects that NRC I&E monitored site auditing and problem-solving actions on a routine basis to assure that PGandE and its contractors adhered to quality requirements.

Whether or not the NSC audit and related documents were actually reviewed at the time by the NRC Staff has not been established. However, in its reply to the supplement to Joint Intervenors' CQA motion the Staff pointed out that

"... reviews of the records of both Region V and Region IV now undertaken reveal that the NRC's regional inspection programs had identified similar concerns in the 1971-1978 time frame. Inspection Reports issued by both Region IV and V are publicly available, and in fact, all pertinent Region V Inspection Reports and associated correspondence were provided to the Appeal Board and parties under cover letter dated July 6, 1983...

"More significant, however, is the fact that the information itself does not reveal a major breakdown in the Pullman QA program in the period in question. Rather, the deficiencies identified are similar in kind to the breakdowns identified by the NRC l through its inspection efforts and reflect l only isolated occurrences which have been i corrected by the Licensee." (Staff Response i at 3.)

i

.n - - - - , - - .- -

,.,--,aw, - , , m,, , - - , -,-, , -,- w -- -<-

2, PGandE Has Made No Material False Statement -

a. PGandE's testimony is not inconsistent with the

~

3/

results of the audit.

Joint Intervenors allege that PGandE witnesses gave testimony in prior proceedings inconsistent with the facts presented by the NSC audit (J.I. Motion at 10,11.) However, as indicated above, on investigation the facts showed that Pullman had a properly functioning quality assurance program, which is consistent with the cited testimony. In addition, when placed in context it appears that the witness quoted on p. 11 was testifying as to his present (i.e., July 1983) opinion of the Pullman quality assurance program.

3/

In this and their earlier pleading on construction quality assurance Joint Intervenors show that they have a fundamental misunderstanding of the significance of quality assurance audits. Audits are by nature documents that portray a negative picture. Their purpose is to point out any possible deficiencies that must be addressed. Over the years, hundreds of audits have been conducted at Diablo Canyon. Many, if not all, of these audits have generated at least some findings.

These findings have then been reviewed and appropriate corrective action taken if necessary. Where indicated, program improvements have been incorporated. Obviously it would be totally unreasonable to expect every possible procedure to be followed to the satisfaction of every auditor at any nuclear power plant. Such a result is neither mandated nor expected under the Atomic Energy Act or the Commission's regulations. Rather one looks to see that identified discrepancies or findings have been cured in order to give reasonable assurance that the plant can be operated without endangering the public health and safety. In the Matter of Union Electric Company (Callaway Plant, Unit 1) ALAB-750, Slip. Opinion pp. 1-3, (Sep. 14, 1983.) Thus, a single audit in isolation cannot give an accurate picture of an overall quality program. Instead, it must be looked at as a part of an overall program and a tool for management to use along j with others to assure high quality performance.

b. PGandE Did Not Hide the NSC Audit__

As indicated in the affidavit attached to PGandE's answer to Joint Intervenors' CQA motion, the NSC report was available for inspection both at the plant and in PGandE's General Office, as were literally hundreds of other audits conducted at the site and at the General Office. At no time did PGandE attempt to hide the NSC audit.

c. Investigation of the NRC audit revealed no significant breakdown in Pullman's quality assurance program and, therefore, there was nothing to report under 10 CFR 50.55(e).

The NSC audit was neither an accurate nor a total assessment of the Pullman Quality Assurance Program. Indeed the NSC audit precipitated other audits, which disclosed that the Pullman quality program was an overall acceptable program, albeit needing minor improvements in some areas. Any identified deficiencies were documented in accordance with approved Quality Assurance procedures and promptly corrected.

Contrary to Joint Intervenors' assertions, the NSC audit findings were thoroughly analyzed and appropriate action taken.

More importantly, the response to the NSC audit by PGandE and Pullman demonstrates a fully functioning and effective quality 1

control program.

In short both PGandE and the Staff found that the NSC audit did not indicate a breakdown in Pullman's quality assurance program.

Thus, there was nothing adversely affecting the public health and safety for PGandE to report to the Licensing Board or "to the public" under 10 CFR 50.55(e) as Joint Intervenors repetitively assert.

d. PGandE had no duty to disclose the NSC audit to the Atomic Safety and Licensing Board.

At the so-called non-seismic safety portion of this proceeding the Atomic Safety and Licensing Board took evidence on a number of matters including quality assurance. This hearing took place on October 18 and 19, 1977 when Mr. Russell Wischow testified for PGandE regarding its quality assurance program.

NRC Staff witnesses also testified. This testimony was given in response to a request of the ASLB on its own motion for information as to the current status of PGandE's quality assurance program, which covered design, construction, procurement and operations.

(ASLB Order dated May 25, 1977.) A generalized quality assurance contention was denied in the same order. Joint Intervenors' then attorney of record declined to cross-examine either the PGandE or the Staff witnesses (TR. 3609, 3618.)

According to the Wischow affidavit appended to the PGandE response to the supplement to the motion to reopen the record on construction quality assurance, PGandE received a draft of the Pullman report in mid-February 1978 and it was not until April 11, 1978 that Pullman formally forwarded its response and the NSC audit report. In any event, there was nothing to report

to the ASLB since, on investigation, the audit revealed nothing 4/

detrimental to the health and safety of the public.-

3. The Atomic Safety and Licensing Appeal Board Has Rejected Joint Intervenors' Motion To Reopen The Record Based In Part On The Same Audit As The One Appended To This Motion On September 9, 1983 Joint Intervenors filed with the Appeal Board a supplement to their motion to reopen the record to consider construction quality assurance matters. The sole basis for this supplement was the NSC audit here under review. In an order dated October 24, 1983, the Atomic Safety and Licensing Appeal Board denied the Joint Intervenors' motion. Thus, presumably-5/ the Appeal Board did not find the NSC audit as apocalyptic as the Joint Intervenors have. Because the actual basis for the Appeal Board's decision is not available PGandE's response to the instant motion is perhaps in greater detail than necessary. However, wholly apart from the merits of the instant motion, in finding that the earlier motion to reopen did not meet the standards for reopening set forth in Kansas Gas and Electric Company (Wolf Creek Station, Unit 1), ALAB-462, 7 NRC 320, 338 (1978) the Appeal Board necessarily found, among other things, that the motion did not address a significant safety issue, and that a

~4/

The cases cited by the Staff and Joint Intervenors regarding the obligation to report current developments to Licensing and Appeal Boards involve matters in contention between the parties. As indicated above quality assurance was not a contention in litigation at the time of the NSC audit, which is an additional ground for not reporting it to the ASLB.

-5/

The details of the ALAB opinion are not available at this writing.

different result would not have been reached had the material submitted in support of the motion been considered initially.

PGandE submits that when the Commission considers the record in this proceeding it should reach the same conclusion and deny the instant motion before it.

4. In Conclusion, There Are No Grounds In Joint Intervenors' Pleading Upon Which To Base A Revocation Or Continued Suspension Of The Diablo Canyon License.

A complete review of the facts in this matter indicates that there has been no misrepresentation or nondisclosure. On examination the NSC audit was shown to be deficient; what valid findings it revealed were corrected by Pullman, and the corrections were reviewed by PGandE, all in accordance with their respective, properly functioning quality assurance programs. PGandE made no attempt to hide this audit or the corrective action taken, and nothing was shown that indicated a " breakdown" of Pullman's quality assurance program requiring a report under 10 CFR 50.55(e).

Thus, there was no material false statement made either through acts of omission or commission by PGandE or anyone else, and the i Joint Intervenors' motion must fail.

Respectfully submitted, ROBERT OHLBACH PHILIP A. CRANE, JR.

RICHARD F. LOCKE Pacific Gas and Electric Company P. O. Box 7442 San Francisco CA 94120 (415) 781-4211

~

I ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix AZ 85073 (602) 257-7288 BRUCE NORTON Norton, Burke, Berry & French, P.C.

P. O. Box 10569 Phoenix AZ 85064 (602) 955-2446 Attorneys for Pa 1 Gas and Elec ric mpany i

Dated: October 25, 1983 g //

Philip Trane, Jr.

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

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275

) Docket No. 50-323 Dichlo Canyon Nuclear Power Plant, )

Units 1 and 2 )

)

CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (hnve) been served today on the following by deposit in the United States mail, properly stamped and addressed:

Judge John F. Wolf "

Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety and Licensing Board San Luis Obispo CA 93401 US Nuclear Regulatory Commission Washington DC 20555 Mr. Gordon Silver 1760 Alisal Street San Luis Obispo CA 93401

! Judge Glenn O. Bright Atomic Safety and Licensing Board John Phillips, Esq.

US Nuclear Regulatory Commission Wnchington DC 20555 Joel Reynolds, Esq.

Center for Law in the Public Interest Judge Jerry R. Kline 10951 W. Pico Blvd. - Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 US Nuclear Regulatory Commission David F. Fleischaker, Esq.

Washington DC 20555 P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer Arthur C. Gehr, Esq.

1493 Southwood Snell & Wilmer San Luis Obispo CA 93401 l 3100 Valley Bank Center Janice E. Kerr, Esq. Phoenix AZ 85073 Public Utilities Commission Bruce Norton, Esq.

State of California l

5246 State Building Norton, Burke, Berry & French, P.C.

350 McAllister Street P. O. Box 10569 i Scn Francisco CA 94102 Phoenix AZ 85064 Mrs. Raye Fleming Chairman Atomic Safety and Licensing 1920 Mattie Road Board Panel Shall Beach CA 93449 US Nuclear Regulatory Commission 20555 Washington DC Mr. Frederick Eissler "

Sesnic Shoreline Preservation ~

Conference, Inc.

4623 More Mesa Drive Sinta Barbara CA 93105

f o

a Chairman Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Wachington DC 20555 US Nuclear Regulatory Commission Washington DC 20555 S cretary US Nuclear Regulatory Commission Judge W. Reed Johnson Wachington DC 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555

'* Lawrence J. Chandler, Esq. Judge John H. Buck Esnry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission W30hington DC 20555 washington DC 20555 Mr. Richard B. Hubbard Commissioner Nunzio J. Palladino NHB Technical Associates Chairman 1723 Hamilton Avenue Suite K US Nuclear Regulatory Commission Szn Jose CA 95125 1717 H Street NW

• Washington DC 20555 Mr. Carl Neiberger Talegram Tribune

• Commissioner Frederick M. Bernthal.

P. O. Box 112 US Nuclear Regulatory Commission San Luis Obispo CA 93402 1717 H Street NW Washington DC 20555 Michael J. Strumwasser, Esq.

Susan L. Durbin, Esq.

• Commissioner Victor Gilinsky Peter H. Kaufman, Esq. US Nuclear Regulatory Commission 3580 Wilshire Blvd. Suite 800 1717 H Street NW Loo Angeles CA 90010 Washington DC 20555 Maurice Axelrad, Esq.

• Commissioner James K. Asselstine Lowenstein, Newman, Reis, and US Nuclear Regulatory Commission Axelrad, P.C. 1717 H Street NW 1025 Connecticut Avenue NW Washington DC 20555 Wachington DC 20036

• Commissioner Thomas M. Roberts US Nuclear Regulatory Commission 1717 H Street NW Washington DC 20555 e

W

- X, I e Date: October 25, 1983

• Copies delivered by Federal Express Courier.

UNITED STATES OF NERICA NUCLEAR REGULATORY CO M ISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD L

1 l In the Matter of p)

PACIFIC GAS AND ELECTRIC COMPANY h Docket Nos. 50-275 OL

$ 50-323 OL (Diablo Canyon Nuclear Power Plant h)

Units 1and2)

NRC STAFF'S RESPONSE TO JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE l

l Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Dated: October 6,1983 .

0

~ ~ ~ -

,_. , - - - - "'~ ~

, &-o -

em

- - - - - - - - - - - - - - - , - , , . . _ , - - - , , , . , , , , , - ,,-,w ----.--.--,------,,--.n. , , - , , . . - - , -

,,r--, -, ,

10/06/83 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION

, BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Ma".ter of )

PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 OL 50-323 OL (Diablo Canyon Nuclear Power Plant Units 1 and 2)

NRC STAFF'S RESPONSE TO JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE I. INTRODUCTION On September 9,1983, Joint Intervenors filed a " . . . Supplement to Motion To Reopen The Record On Construction Quality Assurance "

(Supplement). This Supplement is based on an appended audit of Pullman Power Products, a contractor to Pacific Gas ar.d Electric Company on the Diablo Canyon Project, conducted in 1977.

As discussed below, the NRC Staff affinns its prior position tha+.

the Governor and Joint Intervenors have failed to satisfy the requirements for reopening the record on the issue of construction quality assurance (CQA).

l II. BACKGROUND The general factual background of this matter and the applicable legal standards were discussed in the NRC Staff's Response To Joint Intervenors' And Governor Deukmejian's Motions To Reopen The Record On

i Construction Quality Assurance, filed on June 6, 1983, and need not be restated herein.

As relevant hereto, on September 9,1983, the Joint Intervenors filed a-Supplement to their motion. Therein they contend that the audit of Pullman Power Products conducted by Nuclear Services Corporation (NSC) in 1977 reveals a significant breakdown in PG&E's contruction quality ii assurance program contrary to PG&E's prior assertions, which warrants reopening of the record on the issue.

f III. DISCUSSION The Joint Intervenors' Supplement sets forth twenty three areas of deficiences identified by the NSC audit (Supplement at 4-5). These deficiencies, Joint Intervenors argue, lend support to their previous allegation that deficiencies in design quality assurance extend to CQA as well, and, therefore, the record should be reopened on CQA issues as it I

was on design quality assurance.

The informAion provided by the Joint Intervenors, as discussed below, is neither timely nor compelling insofar as justifying the reopening of the record on CQA.

l Although the NSC audit appended to the Supplement does not appear to l

I have been publicly available (nor for that matter was its existence known to cognizant members of the NRC's Region V Staff),E reviews of the

'-1/

Affidavit of Gonzalo H. Hernandez, Jr., attached, at 1. The Staff shares the concern expressed by both the Joint Intervenors and Governor that this report was not brought to the Licensing Board's i

attention in a timely manner in that the earlier hearing on quality l

' assurance had been conducted in October 197, concluding just shortly before the NSC audit was sent to PG&E. See, ej . Duke Power Company l (William B. McGuire Nuclear Station, Units 1 anc 2), ALAB-143, 6 AEC

' 623, 625-626 (1973).

--- + -~-- - - . r - - - ,. - - - - - - , - - , ,

records of both Region V and Region IV now undertaken reveal that the NRC's regional inspection programs had identified similar concerns in the 1971-1978 timeframe.U Inspection Reports issued by both Region IV and V are publicly available, and in fact, all pertinent Region V Inspection Reports and associated correspondence were provided to the Appeal Board and parties under cover letter dated July 6,1983. Notably, in his reply to the Joint Intervenors' Supplement, the Governor attempts to lend support to the Supplement by citing a number of the pertinent Inspection Reports provided some 3 months ago which are already exhibits in this proceeding. For example, see, Governor Deukmejian's Response To Joint Intervenors' Supplement To Motion To Reopen A Construction Quality Assurance, September 21, 1983, at 3. It is clear, therefore, that this information is not new although the document itself may be; the Joint Intervenors' reliance on the information is, therefore untimely, see Kansas Gas and Electric Co. (Wolf Creek Generating Station, Unit 1), ALAB-462, 7 NRC 320, l 338 (1978).

More significant, however, is the fact that the information itself does not reveal a major breakdown in the Pullman QA program in the period in question. Hernandez Affidavit at 2. Rather, the deficiencies identified are similar in kind to the breakdowns identified by the NRC through its inspection efforts and reflect only isolated occurrences which have been corrected by the Licensee. Id.

i 2/ Id. Copies of the Region IV Inspection Reports are attached.

1

t As the Appeal Board recently observed:

In any project even remotely approaching in magnitude and complexity the erection of a nuclear power plant, there inevitably will be some construction defects tied to quality assurance lapses. It would therefore be totally

• unreasonable to hinge the grant of an NRC operating license upon a demonstration of error-free construction.

Nor is such a result mandated by either the Atomic Energy Act of 1954, as amended, or the Consnission's implear,enting regulations. What they require is simply a finding of reasonable assurance that, as built, the facility can and

' will be operated without endangering the public health and safety. 42 U.S.C. El 2133(d), 2232(a); 10 C.F.R. 650.57(a)(3)(1).1/ Thus, in examining claims of quality assurance deficielicies in tenns of safe plant operation, one must look to the implications of those deficiencies in terms of safe plant operation.

Obviously, this inquiry necessitates careful consideration of whether all ascertained construction errors have been cured. Even if this is established to be the case, however, there may remain a question whether there has been a breakdown in quality assurance procedures of sufficient dimensions to raise legitimate doubt as to the overall integrity of the facility and its safety-related structures and components. A demonstration of a pervasive failure to carry out the quality assurance program might will stand in the way of the requisite safety finding.

Union Electric Company (Callaway Plant, Unit 1), ALAB-740, NRC ,

slip op. at 1-3 (footnote omitted; September 14,1983). In the instant I matter, the information presented in the Supplement does not establish that there has been a breakdown in CQA "of sufficient dimensions to raise legitimate doubt as to the overall integrity of the facility and its safety-related structures and components."

It is thus evident that this infonnation does not represent a matter of signficance to plant safety and, thus, reopening of the record on the issue of CQA is not warranted. Wolf Creek, supra.

I

IV. CONCLUSION For the foregoing reasons, the Staff affirms its prior position that the Governor and Joint Intervenors have failed to satisfy the long-standing standards for reopening this proceeding on the issue of CQA and, therefore, their motions should be denied.

Respectfully submitted, i

Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Dated in Bethesda, Maryland this 6th day of October 1983 l

e

- ,_ - - -t- - _ - . --_ . - . _ -_ . ,. ..._. --y..,-s.y.,. % - ____ .--_ , . ,-, . -_.y., - --

~ .

s IBiITED STATES W AMERICA NUCLEAR REGULATORY CG911SSION BEFORE TE ATOMIC SAFETY AND LICENSING APPEAL 30ARD In the matter of )

)

) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY, Diablo Canyon )

Nuclear Plant, Unit No.1 )

AFFIDAVIT OF GONZALO H. ERNANDEZ, JR.

STATE OF CALIFORNIA )

COUNTY OF CONTRA COSTA ) SS I, Gonzalo H. Hernandez, Jr. being duly sworn do depose and state as follows:

1. I am employed by the U. S. Nuclear Regulatory Commission in the Region V Of fice, Division of Reactor Projects and Engineering Programs. A statement of my professional qualifications is attached hereto as Exhibit A and incorporated herein by reference.

2. I am a Reactor Project Inspector and have had responsibility for inspection of the Diablo Canyon construction modifications resulting from the independent verification program, and have personally conducted related inspections of the Diablo Canyon facility since January 1983.

3. I have read the document entitled " JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE," dated September 9, 1983; " PACIFIC GAS AND ELECTRIC COMPANY'S ANSWER TO THE JOINT INTERVENORS' SUPPLEMENT TO MOTION TO OPEN THE R ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE," and Attachments Nos. I through 8, dated September 21, 1983. Additionally, other members of the Region V staff examined attachments Nos. 3 through 8 at Pacific Gas and Electric's corporate offices in San Francisco on September 19 and 21, 1983.

4. According to the record and statements of other current members of the regional staff, the Nuclear Services Corporation audit dated July 28, 1977 had not been previously reviewed by any present member of the regional staff who had responsibility for conducting inspection at the Diablo Canyon facility during the referenced period, nor was this document provided to the Region V office, as far as I have been able to determine.

5. I have reviewed the NRC: Region V inspection reports from October 1971 through December 1978, the NRC: Region IV vendor inspection reports from February 1975 through November 1977, and find that the regional .

inspection programs did identify similiar discrepancies in .

Pullman-Kellogg's Quality Assurance Program as reported in the Nuclear ,

Services Corporation audit of July 28, 1977. The NRC identified discrepancies were brought to the attention of the licensee and where appropriate, Notices of Violation issued. The following NRC: Region V

]

, , - _ . _ , , . - - , . - . _ y , . . , _ , . - , , , , _ , _ . , , - _ _ . - - ._ _

w - .

2 inspection reports contai n ref er ences to Pullman-Kellogg construction activities:

50-275/71-03, 72-02, 72-03, 73-01, 73-03, 73-04, 73-07, 74-01, 74-02, 74-04, 75-02, 75-06, 76-01, 76-04, 76-06, 76-09, 76-14, 77-03, 77-06, 77-11, 77-14, 77-16, 77-17, 77-19, 77-22, 78-02, 78-03, 78-06, 78-09, 78-10, 78-12, 78-15. Copies of all of thase reports were previously provided to all parties.

6. The following NRC: Region IV inspection reports contain references to Pullman-Kellogg activities: 99900077/75-01, 76-01, 76-0::, 77-01, 77-02, 77-03. Copies of these reports have been provided to the Office of the Executive I.egal Director (ELD) for distribution to all parties.

7. Based on the foregoing, I an of the opinion that the Nuclear Services Corporation Audit findings do not represent new information with respect to the type of audit findings, and in many cases the findings are similiar to NRC reported inspection findings. Therefore, it is my belief that Pullaan-Kellogg's Quality Assurance Program did not suffer a major breakdown during the referenced period. The isolated breakdowns that did occur, appear to have been detected and corrected by the licensee's Quality- Assurance Program and/or by the Nuclear Regulatory Commission's inspection program in effect at the time.

I attest that the foregoing affidavit is true and correct to the best of my knowledge and belief.

h. p4f, \ M /O _

d ' */

GoploN.Hernandez,Jr.

t j"

N N N D A COSTA i

.before me, the undersoned, a Notary Putdic in and for on- ne + ahav- A, lan?

d e e state. personeity appeared _ Gonzalo H. Hernandez_ Jr.

personally known to me (or proved to me on the base of sffit AL stat ui.vectory evidence) io t the personco =how aam*0tt PETRA C. CONS 0E isie,e evoec,a.d io tne .nh.n .netromeni and act -: m'"* * @

CONTRA COSTA COUlfff to me that hellOf esecuted the same. EbteamteIgha Austime WITNESS my erwl anicial esel. ' -' 1-M *

(This area for oWicial notanal seeQ g >,

d

/

eFana Ptv A 74a (CA)IDeosveuAu

- .,g - - -- ,-wm,vc- ,,y --

,--, , -. - - .- ,---,.--,,,,,,,-,,,-------.,---,--,+---,-,----.,-------,,-,,,n,-v,-,,-,.---,w__,,n- - , - - - , - - - - , _

Exhibit A GONZALO H. EERNANDEZ, JR.

PROFESSIONAL QUALIFICATIONS .

REGION V - WALNUT CREEE, CALI7DENIA ,

NUCIZAR REGULATORY COMMISSION OIRC)

My name is Gonzalo H. Bernandez, Jr. f an employed by the United States Nuclear. Regulatory Commission as a reactor inspector in the Division of Resident, Reactor Projects and Engineering Programs, Region V, Walnut Creek, California. My primary responsibility in this position is the inspection of nuclear power plants during the construction and modification phase to determine compliance with NRC rules and regulations.

I received a Bachelor of Science in Mechanical Engineering from California State University at Los Angeles in March 1975. In March 1977, while pursuing "

a graduate degree, I started work with the Nuclear Regulatory Commission as a co-op student. In September 1977, I discontinued my studies when I starting working full-time as a Reactor Inspector-Intern with the Region V Reactor Construction Branch. In this position I participated as a member of the inspection staff with duties involving training and instruction in nuclear power plant technology and the inspection of nuclear facilities under construction. In September 1979 I completed my internship and was made a reactor inspector in the Region V Reactor Construction Branch. In this position, I performed as a member of the inspection staff and performed numerous inspections at Region V construction facilities to assure compliance with NRC regulations. From 1981 to 1982, I have served as the principal construction inspector for the Rancho Seco Nuclear Power Plant, responsible for assuring that construction and modifications activities conform to the provisions of the facility operating and/or construction permit. In January 1983, I assumed similiar duties for the Diablo Canyon and San Onofre Unit I facilities.

b l

I t

I e*

I

UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 OL 50-323 OL (Diablo Canyon Nuclear Power Plant Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE TO JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, as indicated by an asterisk through deposit in the Nuclear Regulatory Comission's internal mail system, the 6th day of October 1983:

Dr. John H. Buck Dr. Jerry Kline Atomic Safety and Licensing Appeal Administrative Judge Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555* Washington, DC 20555

• Dr. W. Reed Johnson Philip A. Crane, Jr. , Esq.

Atomic Safety and Licensing Appeal Pacific Gas and Electric Company Board P.O. Box 7442 U.S. Nuclear Regulatory Comission San Francisco, CA 94120 Washington, DC 20555*

Mr. Frederick Eissler Thomas S. Moore, Esq. , Chaiman Scenic Shoreline Preservation Atomic Safety and Licensing Appeal Conference. Inc.

Board 4623 More Mesa Drive U.S. Nuclear Regulatory Comission Santa Barbara, CA 93105 Washington, DC 20555*

Mrs. Raye Fleming John F. Wolf, Esq. 1920 Mattie Road Administrative Judge Shell Beach, CA 93449

- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Richard E. Blankenburg, Co-publisher Washington, DC 2.555 0

• Wayne A. Scroyan, News Reporter

' South County Publishing Company l

Mr. Glenn O. Bright P.O. Box 460 Administrative Judge Arroyo Grande, CA 93420 Atomic Safety and Licensing Board .

U.S. Nuclear Regulatory Comission Michael J. Strumwasser. Esq. -

Susan L. Durbin, Esq.

Washington, DC 20555

• Peter H. Kaufman, Esq.

Elizabeth Apfelberg 3580 Wilshire Blvd., Suite 600 1415 Cozadero Los Angeles, CA 90010 San Luis Obispo, CA 93401

Mr. Gordon Silver Harry M. Willis Mrs. Sandra A. Silver Seymour & Willis 601 California St., Suite 2100 1750 Alisal Street San Francisco, CA 94108 San Lufs Obispo, CA 93401 Joel R. Reynolds, Esq. Janice E. Kerr, Esq.

John R. Phillips, Esq. Lawrence Q. Garcia. Esq.

Center for Law in the Public 350 McAllist.er Street Interest San Francisco, CA 94102 10951 West Pico Boulevard Mr. James 0. Schuyler .

Third Floor Nuclear Projects Engineer Los Angeles, CA 90064 Pacific Gas and Electric Company Arthur C. Gehr, Esq. 77 Beale Street Snell & Wilmer San Francisco, CA 94106 3100 Valley Center Phoenix, AR 85073 Paul C. Valentine Esq.

321 Lytton Avenue Mark Gottlieb Palo Alto, CA 94302 California Energy Comission MS-18 Atomic Safety and Licensing Appeal 4111 Howe Avenue Board Sacramento, CA 95825 U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• Bruce Norton, Esq.

Norton, Burke, Berry & French, P.C. Atomic Safety and Licensing Board 2002 E. Osborn Road U.S. Nuclear Regulatory Comission P. O. Box 10569 Washington, D.C. 20555

• Phoenix, AZ 85064 Docketing and Service Section David S. Fleischaker, Esq. U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• P.O. Box 1178 I Oklahoma City, OK 73101 -

Maurice Axelrad, Esq.

Lowenstein, Newman, Reis and Axelrad Richard B. Hubbard 1025 Connecticut Ave., N.W.

MHB Technical Associates 1723 Hamilton Avenue - Suite K Washington, D.C. 20036 **

San Jose, CA 95125 John Marrs, Managing Editor Mr. Thomas H. Harris, Energy Writer San Luis Obispo County San Jose Mercury News Telegram-Tribune 750 Ridder Park Drive 1321 Johnson Avenue San Jose, CA 95190 P.O. Box 112 San Luis Obispo, CA 93406

"!Y -

Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel

^

l -

s O

n s .

January Tf 1978

)

Docket ,. 9 900077 Pullman Power Products Division of Pullman Incorporated

Attn: Mr. E 8. Curcio '

Commereial Vice President 14507 South Paramount Boulevard Paramount, CA 90723 -

Gentlenen: ,

Thank you for your letter of December 13. 1977, in response to our letter dated November 29, 1977 with an attachment. We have no further questions at this time. .We will mview your corrective action during a future inspection.

Sincerely.

" Original Signed by!

D. M. HUNNICUUu D. M. Hunnicutt. Acting Chief Vendor Inspection Branch

- ,, M .t.

j .

l

- kcc .- '-

Central files PDR HQS WEVetter

/ R!. Brown EEEXX1HMR -

/ HRoberds

/

{. r

.l niv S he _ @ [v h' (la)

.m . >

Barnes ; ' Brown Hunnieutt Vetter Roberds/ng 1/10/78 1/10/78 1//4 78

,,,, , .1/10/78 1/10/78 j

• u. . .rewr 4.<, win.*- e i wac romm m w.u wacs aus i

j .

Dmsson of Pudman incorpora .

1 14507 South Paramour..

Paramount Cakto*n's 9C

") Pullman Power Products December 13, 1977 United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. D. M. Hunnicutt, Acting Chief Vendor Inspection Branch

Subject:

Response - N.R.C. Audit October 31 - November 3, 1977 Report No. 99900077/77-03 Docket No. 99900077 Program No. 44020 Gentlemen:

In response to your Audit Report and letter of transmittal, dated November 29, 1977 (D. M. Hunnicutt to E. B. Curcio),

relative to the subject audit, we respectfully submit the attached comments.

l If, in your opinion, supplementary information is deemed necessary, we will extend every effort to comply.

Very truly yours, PULLMAN POWER PRODUCTS Stephen L. Engler Quality Assurance Manager SLE/sw Attachment cc: Mr. E. B. Curcio Mr. E. F. Gerwin Mr. H. W. Owen

I N we RESPONSE TO FINDINGS N.R.C. AUDIT OCTOBER 31 - NOVEMBER 3,1977 REPORT NO. 99900077/77-03 DOCKET NO. 99900077

. PROGRAM NO. 44020 DETAILS - SECTION II Ref: Paragraph 3.A Corrective Action: The 8 to 10 type 7018 electrodes, size 5/32, Heat No. 411XO941, were removed from the 7018 electrode, size 3/32, Heat No. 90M288, and placed in their correct bin.

November 2, 1977 Corrective Action (At the time of discovery.)

Completed:

Preventative Action: This incident occurred as a result of human error. Our rod room was in the process of training a new man. When the rod was

, returned from a welder, it was placed in the wrong bin, but the right oven, to comply l

with our rotating oven technique. The electrodes in question could not have been used in error because:

l (1) use one heat of 7018 electrode, We sizeonly/32, 3 and one heat of 7018 electrode, size 5/32, at one time in our shop. This means that the rod was completely traceable.

(2) The size difference would be quite evident to any personnel because 5/32 rod is almost twice the size of 3/32 rod.

The rod room personnel were cautioned to be

( more careful in the future when returning .'

rod to the ovens.

Corrective Action November 4, 1977 Completed:

l i

l L

? .. ,

4 y,

'Y Docket Number 99900077/77/03 Pullman Power Products Division of Pullman Incorporated

. ATTN: Mr. E. B. Curcio Comercial Vice President 14507 South Paramount Boulevard Paramount, California 90723 Gentlemen:

This refers to the QA program inspection conducted by Mr. H. W. Roberds of this office on October 31-November 3,1977, of your facility at Paramount.

California, associated with the fabrication of nuclear piping / assemblies and to the discussions of our findings with Mr. 5. L. Engler and members of your staff at the conclusion of the inspection.

This inspection was made to confine that, in the areas inspected, your QA Program is being effectively implemented. The inspection effort is not designed to assum that unique quality requirements imposed by a customer are being implemented; nor to assure that a specific product, component or service provided by you to your customers, is of acceptable quality. As you know, the NRC requires each of its licensees to asse ;s i

full responsibility for the quality of specific products, components or services procured from others. You should therefore not conclude that the NRC's inspection exempts you from inspections by an NRC licensee or his agents nor from taking effective corrective action in response to their findings.

Areas examined and our findings are discussed in the enclosed report.

Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection it was found that the implementation of your QA program failed to meet certain comitments in your ASME accepted QA Manual. The findings and references to the pertinent requirements are identified in the sumary section of the attachment to this letter.

days of your receipt of this report Please pmvide us within thirty I'a written statement containing, d .

been or will be taken to correct this itm, 2) a description of steps that havn been or will be taken to prevent recurrence, and (3) the dates your corrective actions and preventive measures were or will be completed.

d M / odd .h N-j/M

. . . . . RIV I

WEVettM

,,,,,,,,,, HWRoberds/sf [MHunnicutt '#

11/22/77 11/13 /77 11/%/77 W v. s. eevsamassav Paintine 4,,683a lete.889.tes yo,e m )ts (Re. 953) ABCM SNS

. - . - . - . . . _ ~ - _ _ _ _ _ _ - , _ _ _ . _ _ . . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ . _ . . . _ _ _ _ _ _ . _ _ _ _ . _ . . . . _ _ _ . _ _

y Pullman Power Products i Division of Pullman Incorporated i

In accordance with Section 2.790 of the Connission's '1 tules of P Part 2. Title 10. Code of Federal Regulations, a copy of this letter and i

your reply, together with the enclosed inspection report will be placed l in the Connisston's Public Doceent Room. If this mport contains is necessary that any you i infomation that you believe to be proprietar make a wri.tten application within thirt;yAny (30)y. itdays to this off such appitcation .

withhold such infomation from public disclosure.

I must include a full statement of the reasons on the basis of which it claimed that the information is proprietary and should be prepared so l that proprietary infomation identified in the l If we do application not hear from is you contained in this

in a separate part of the doc eent.

regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

$1acerely,

[ ' h D. M. Hunnicutt, Acting Chief

. Vendor Inspection Branch

Attacinent

! Inspection Report Number 99900077/03 i

! bec:

IE CHIEF, FC&EB i

IE CHIEF, C&ARPS IE FILES i NRR:DPM:QAB CENTRAL FILES PDR HQS REGIONAL DIRECTORS 1. II, III V W. E. VETTER, RIV

' ASME ,

' NBB&PVI h

4

---

,n- - - - - - , - - - - - - - _ _ _ - . - - - - - - - . . -----n ,- - - - - .-,,-e,,,_.e.r---n- - - - - - . , ,,-,n--r,..m ,

4

}

VENDOR INSPECTION REPORT U.S. NUCLEAR REGULATORY COPMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV

< ~

Report No. 99900077/77-03 Docket No. 99900077

Program No. 44020 Company: Pullman Power Products 14507 South Paramount Boulevard

Paramount, California 90723 Inspection at: Paramount, California Inspection conducted: October 31-November 3,1977 Inspectors: /,' [ 4(2- //D&teM' 'f H. W. Roberds, Contractor Inspector, Vendor r Inspection Branch

t. hD // '

77

t. E. Ellershaw, Contractor Inspector, Vendor Date Inspection Branch

// /2 3 [7 7 ApprovedD.by:. /8=-

M. Hunnicutt, Acting Chief. Vendor Inspection Date g Branch Sumary ,

Inspection on October 31-November 3,1977. (99900077/77-03)

Areas Inspected: Implementation of the ASME accepted Quality Assurance Manual including Welder / Welding Operator qualification; Welding Process Control; Nonconfomance and Corrective Action; Nondestructive Examination

' (Dye Penetrant and Magnetic Particle). Heat Treatment (Post weld); and Authorized Nuclear Inspector (ANI) activities.

(60) inspector-hours on site by two (2) NRC inspectors. .

Results_: In the six (6) areas inspected, no apparent deviations or -

unresolved items were identified in five (5) of these areas; the following was identified in the remaining area.

Deviation: Welding Process Control (DetailsSection II, paragraph C.3.a.).

.,. - - , . , , . , , -r.,, ,,_-,,--n,,,_n,,,,,,,,,.,._-n,-_ . . , - . . , - - - . _ , , , . , , , , --

a 2-1 l

DETAILS SECTION I (Prepared by H. W. Roberds)

A. Persons Contacted S. L. Engler, Manager, Quality Assurance G. Trumbull, Quality Control Inspector J. Mathews, NDE Level II, Radiography J. Labac, Quality Assurance Supervisor Z. X. Corder, Quality Control Supervisor B. Nondestructive Examination (Dye Penetrant and Magnetic Particle)

1. Objectives The objectives of this area of the inspection were to verify that:

a. Nondestructive examination is performed in accordance with approved procedures.

b. Test results are interpreted by qualified personnel.

2. Method of Accomplishment The preceding objectives were accomplished by:

a. Review of Section IX of the Quality Assurance Manual.

b. Review of personnel certification and qualification records.

c. Review of Liquid Penetrant Procedure JS-404, Revision 2.

d. Review of Magnetic Particle Procedure-Dry Powder Method.

JS-405, Revision 3.

e. Review of Radiographic Procedure JS-414. Revision 3.

3. Findings Within this area of the inspection, no deviations or unresolved . '

items were identified.

1

l i  !

)

C. Heat Treatment (Post weld) ,

l .' Objectives The objectives of this area of the inspection were to verify that heat treatment related to welding was specified and performed in accordance with the ASME accepted QA Manual and applicable

- ASME code requirements.

2. Method of Accomplishment The preceding objectives were accomplished by:

a. Review of the QA Manual.Section IX " Control of Special Processes".

b. Review of procedure JS-450, " Proof Testing The Heat Treat Furnace".

c. Review of procedure SR-lli, Revision 1 " Post weld Heat Treatment".

d. Review of randomly selected furnace charts and furnace operator instruction for nuclear piping assemblies.

e. Interviews with cognizant persornel.

3. Findings Within this area of the inspection no deviations or unresolved items were identified.

D. Authorized Nuclear Inspector (ANI) Activities

1. Inspection Objectives The objectives of this area of the inspection were to verify that:

a. The ANI activities include selecting and establishing Verification points for the fabrication process.

b. Established Verification points were being documented.

c. TheANIwasactivelymonitoringtheQualityAssuranceProgra$1.'

2. Inspection Objectives Accomplished by:

i

.- a. Review of Section X of the QA Manual,

b. Selected review of process sheets.

c. Interview of ANI.

. 3. Inspection Findings The ANI is performing the functions identified in the inspection objectives and no adverse findings were identified.

E. Exit Interview A post inspection management meeting was held on November 3,1977 at the Pullman Power Products facility in Paramount, California. The results of the inspection were discussed with the following management representatives:

H. W. Owen, Assistant Plant Manager B. S. Saggu, Staff Engineer S. L. Engler, Quality Assurance Manager The following subjects were discussed.

1. The areas inspected as defined under summary.

2. The deviation from commitments identified in the Detail Section of this report.

l

3. Management acknowledged the finding.

O m

O

DETAILS SECTION II

. (Prepared by L. E. E11ershaw)

A. Persons Contacted K. Canning, Welding Foreman I. Corder, Quality Control Supervisor S. L. Engler, Manager, Quality Assurance R. Gilliam, Rod Room Clerk B. Saggu, Staff Engineer J. Watkins, General Foreman B. Welder / Welding Operator Qualifications

1. Objectives The objectives of this area of the inspection were to verify that Pullman Power Products (PPP) had implemented the system for the control of welder / welding operator qualifications f

as delineated in QA Manual Section II.

l ~

l 2. Method of Accomplishment The preceding objectives were accomplished by:

a. Review of QA Manual Section II, Issue 3, dated June 1,1977,

b. Review of Procedure 11-7 with Shop Supplement II-7P " Welder Perfomance Qualification", dated April 18, 1977, l c. Review of Welder Qualification records,

d. Review of Welder Qualification Status foms,

e. Discussions with cognizant personnel.

3. Findings I Within this area of the inspection, no deviations or unresolved items were identified.

C. Welding Process Control _

1. Objectives t

l The objectives of this area of the inspection were to verify

! that PPP had implemented the system for welding process control as delineated in QA Manual Section IX. -

l

2. Method of Accomplishment The preceding objectives were accomplished by:

a. Review of QA Manual Section IX, Issue 3 dated June 1,1977,

b. Review of Weld Material Qualification Records.

c. Review of calibration status of welding equipment.

I

d. Observation of welding materials storage area and review of welding material approval and release, system. l i

e. Observation of Submerged Arc Welding and Shielded Metal Arc production Welding operations.

I I

l f.

Review of Weld Procedure Specifications referenced as being applicable for welding operations witnessed.

g. Discussions with cognizant personnel.

I

h. Review of Weld Procedure Specifications and their respective Weld Procedure Qualification Records.

3. Findings

a. Deviation QA Manual Section IX, paragraph 2.1.2 states in part, "Only one type, size, and heat / lot of electrode is to be placed in an individual bin in the oven. Each bin will be marked to properly identify the electrode by size, type and heat."

Contrary to the above, one bin in oven SR No. 801 Thecontained bin was more than one size and heat / lot of electrodes.

identified as and contained type 7018 electrodes, size 3/32, heat 90M288. However, type 7018 electrodes, size 5/32, heat 411x0941 were also contained in the same bin.

b. Unresolved Itan None.

D. _Nonconformances and Corrective Action T .* Objectives The objectives of this area of the inspection were to verify that

PPP had implemented the system for the control of nonconformances and corrective action as delineated in the QA Manual Sections XV and XVI.

2. Method of Accomplishment The preceding objectives were accon.plished by:

a. Review of quarterly nonconformance reports,

b. Review of QA Manual Sections XV and XVI. Issue 3 dated June 1, 1977.

c. Observation of nonconforming material hold areas, the non-conforming items and the review of the respective documen-i tation.

d. Review of nonconformance reports and deviation requests.

l

e. Discussions with cognizant personnel.

3. Findings Within this area of the inspection, no deviations from commitnant or unresolved items were identified.

1 e

G

-.,- ..,,n-.-_-.m-,. ----,,,,,-,,,,,g-- --,,,,...---,-----..-,,,-n_.,--,_,_-,-,.-.,,.,-----,.-.--.--.,~w -

,,,,,,,m.--

_nea-, -

. 33 -

1

• 1 ww  ;

i - -

o g 2 o _

u '

,, , _ J w - i g mu>

l

[ g - - - - -

{

e - - - -

, o ma . .,.,_

I 8 n gos

- gO

==> l .

= ~ y -

Es w z 5 m u z o -

w j- u

. 3 >C $

< 3 ..zo-u o ._ '

3 F o S u ww> l l l

< 1 z i -

C -

z M

a er z E 8

$ E= l - -

p m - .- -

p mw>

t y g -

Z u -e l u 1 at lE z ,

w o .; ~ ~ " "g

~

N . E 5h 13A37 -

2 W 8 BE ,

os z a a Ws i 8=

w o<

c u g

3. we$;

a.

wo ~30Wd -

2 -

e; i. $ ,,,g3 ,

o < o-ozz l 3 7vnNVW p e Wr .

o.

m W z=E.50>

-- nsvu -

c. ,

m 5_ovaSv""E o R

~i" I g; snivist i I l RI I l-- I -

l l i - - -

o 1 =w

- W c: e - _

z  ::o- -

m m

\o1-ut 8 J __

- m

- g g -

"8 2

- c g.

4 o u

5 og_heic g=r: 'i %L z

<; E ,M r f"o_  ::

aaa , .x _ ~3 .x - o -

coo 3 o - - - ,

zu~ - -

5

<sg g -

geo o e.

13A37 Q -

5 g A -

- on \ - -

W -

c 3cyg .-

= .,

c -

E

.a --- _ .

c r

c.;s ssno %

< ~g B o ,vnwn o

- i

.* ae. 3. '

3$VNd h i -

e a

_n _ ,

e l e *

• e n jo - n I - -

l W e a ml e o I e a r _.

s; i o{ g _

1 I

l

~ , _ _ _ _ _ _ _ _ _ _ _ _ _ . .

Y .

.. . -s ., .

N Docket .'99900077 1

i) N 1 .

Pullman Power Products Division of Pullman, Inc.

Attn: Mr. E. B. Curcio Vice President 14507 South Paramount Boulevard Paramount, California 90723 Gentlemen:

This refers to the QA program inspection conducted by Mr. H. W. Roberds of this office on June 20-23,1977, of your facility at Paramount California, i

associated with the fabrication of nuclear piping assemblies and to the discussion of our findings with you and man 6ers of your staff at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.

Within the scope of this inspection, we found no instance where you failed to meet the comitments in your ASME accepted QA Manual.

In accordance with Section 2.790 of the Commission's " Rules of Practic i

Part 2. Title 10 Code of Federal Regulations, a copy of this letter together with the enclosed inspection report will be placed in theIf t Comission's Public Document Room.

that you believe to be proprietary, it is necessary that you sake a written application within thirty (30) days Anytosuch thisappitcation office to withhold must such information from public disclosure. include a full statemen

~

claimed that the information If we do not hear from you in this is proprietary, and sho a separate part of the document. regard within the specified pe Public Document Room.

m d A@ db[rv -s%k5b l k 7Y1

. ic .

• RIV

.v w Dttiunnitutt_

w

_JHIllich, WEYettar y

V~

N <=

a. .

• EWRoberds:si. ')

,7/11/77 7/ll/77 ,7/iS/77

.. , 7/11/77 o......-..,,........,,............

r - uc.m in .S m acu = =

e .

Pullman Power Products '

! )

i

$hould you have arqr questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely.

I "Orlai;al signed tr/r , , ,

l 3, g putomrriu ,

l J. H. Tillou, Chief '

. Vendor Inspection Branch

Attachment:

Inspection Report No. 99900077/77-02

bec

IE CHIEF, FC&EB

- IE CHIEF, V&ARPB IE REG. COORDINATOR IE FILES NRR:DPM:QAB -

CENTRAL FILES .

PDR HQ .

REGIONAL DIRECTORS I, III V W. E. VETTER, RIV ASME NBB&PVI '

e 9

l l

l.

I S

M.

VENDOR INSPECTION REPORT U. S. NUCl. EAR REGULATORY C0091ISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900077/77-02 Docket No. 99900077

}

Program No. 44020 Company: Pullman Power Products Division of Pullman, Inc.

f 14507 South Paramount Boulevard Paramount, California 90723 Inspection conducted: June 20-23,1977 Inspectors I ISh7) # 7////77 H. W. Roberds, Contractor Inspector, VI Branch Date' Approved by: 3k &# 7////77 D. M. Hunnicutt, Chief, Components Section 2, Date' VI Branch Summary Inspection on June 20-23, 1977 (99900077/77-02)

Areas Inspected: Implementation of the ASME accepted Quality Assurance Manual including nondestructive examination (radiography) and actions on previous inspection findings. The inspection involved 24 inspector-hours on site.

! Results: In the two areas inspected, no apparent deviations or unresolved I items were identified.

l f

1

\

O

-- - ---, - -, ~ -, -- -

~

DETAIL SECTION (Prepared by H. W. Roberds)

A. Persons Contacted S. L. Engler, Quality Assurance Manager l M. H. Hill, Receiving Inspector B. Actions on Previous Inspection Findings

1. (Closed) Deviation (Report No. 77-01): It was verified that all aspects of the Quality Assurance Program had been audited by May 27, 1977.

2. (Closed) Deviation (Report No. 77-01): It was verified that all Weld Procedures had been reviewed for completeness and revised, as necessary. Also periodic spotchecks had been conducted to assure that all required nonessential variables were included in the welding procedure specifications.

3. (Closed) Deviation (Report No. 77-01): It was verified that Procedure No. X-8P, Inspection Procedure for Receiving Inspection, had been revised to include a sample dimensional inspection on items received ~for each purchase order and receiving inspection forms had been revised to include a column requiring the inspector to document the sample dimensional verification operation performed.

4. (Closed) Deviation (Report No. 77-01): It was verified that process sheets had been revised to indicate those operations which require processing in a given order was sequenced accordingly on l

the traveler.

5. (Closed) Unresolved Item (Report No. 77-01): It was verified that a recent audit had been performed and was documented that verified the vendors heat treatment capabilities with respect to the specification requirements for solution annealing.

- 6. (Closed) Unresolved Item (Report No. 77-01): It was verified that process sheets requires that the minimum diameter be measured prior to the bending operation and the maximum diameter be measured after bending and the percent (%) ovality be computed .

and recorded. ,

. . - _ . - . . , , . , , _ . , _ - , . _ - . . . , , , , - _ - _ , , . _ , , . _-_,,_.,-,.__m _______.._,_._,_.,___,_.__,,,,_.,_m,.. , , - , . . , . . . ,._m_-,,.._

-e 4

7. (Closed) Unresolved Item (Report No. 77-01): It was verified that contact pynimeters and oxygen analyzers are included in the calibration program and are scheduled for calibrated at

- specified intervals.

C. Nondestructive Examination (Radiography)

1. Objectives The objectives of this area of the inspection were to verify that:

a. Radiographic examination is performed in accordance with approved procedures.

b. Examination results are interpreted by qualified personnel.

2. Method of Accomplishment The preceding objectives were accomplished by:

a. Review of Section 6 of the QA Manual.

b. Review of radiographic procedure, specification number JS-414.-

c. Review of personnel qualification and certification records.

d. Observation of work in progress.

i

e. Interviews with cognizant personnel.

3. Findings Within this area of the inspection, no deviations or unresolved items were identified.

D. Management Interview l

f-I

1. A management interview was held on June 23, 1977, at the Pullman Power Products facility in Paramount, California. The results of the inspection were discussed with the following management representatives:

E. B. Curcio, Vice President .

W. Owen, Assistant Plant Manager .

S. L. Engler, Quality Assurance Manager

2. Management was infonned that implementation of their ASME accepted Quality Assurance Program had been inspected with respect to actions on previous inspection findings and nondestructive examination (Radiography).

3. The status of previously identified deviations and unresolved items,

as described in the detail section of this report, were discussed with management representatives present.

f

4. Management coments were generally related to clarification of certain aspects of the inspection and general comments.

p e

l 1

• • UNetsy statss asucLEAa meCutatony t es e -

F07N N;C 766 AUGUST 1776 cuc e535, INwECTION tr ENFORCEMENT - STATIS..JAL DATA 1

' SAC 6: 7v NAME f"M MC MME INSPECT 0m(5s f W bMEdO PaaNCePAL INSP -4 CTom sEveEwEn_-- -- -

.f

~

.. LiCEN5EE v NoOm MEG.

4Al miPon T Pv0. DATEl iN0 'lNvistisN5P T R ANS.

COCEf1 Nuwtim fno" 25 COND.. .NG 20 ACTivit -

ACTION 2 9 ggg Tras i h O =s hh$b as W D D Y Y AE On LeCEN55 No rev PRODUCT!

t% 36 3_1 2

O oi=

Jud=* '*' o 6 2: 3 1 7 y

z.~~ u nn 0 0 y Tvpt of ACTeviTV CONDUCTED ICwf CE ONE gar CNLys 33 34 essSPtCTION OTHEm I

05 O MANAGEMENT audit 80 0 MATL ACCT. 13 D sadPORT l 14 D INQUIM 7 01 O mouTINE (FEEL 02 D mout N! INO Fill 05 D MAN AGEMENT visit 10 D PLANT SEC. ( 15 D ' INVESTIGATION 11 D INVENT.vimit l IF INVEST. AL50 03 D INCIDENT 07 D SPECI AL De D EN50mCEMENT oggvfNDom 12 0 SHerutNT/EXPoint l (CHECK SLOCK IN5pt CTiom on iNvf 5TicAfiO4 I gANNouNCED 2 D ussANNouNCED * .- , . . ,J., , ,,

35 iN576CTeON iNvESTicATiON NOTipicatiON CnECK ONE s0x ONLys M

3 D RE FE matD TO MOS FOR ACTION 4 0 mEciON LETTER & MOS 70m ACTsON 10 'iS t 2gmEGIONALOSFiCELETTER iN5*sCTi3N iNvt17sCaficN ssNDiNC5 (CmECK ONE 80x ONLYs 37 3 D DEVIATs0N 4 O NONCOMPLIANCE & DEVIATION 2 O NONCOMPLIANCE 1kCLEAm

=.

• NusweE m op NONCoupLIANCE lTEW5 sN LETTim TO LICENSEE. N? wE VEm RE LY J

so ,, CITED ITEM O8 NONCOMPLIANCE .

15 075sts ALLY DELETED 7 m0M NuwSE 4 08 Deva ATION ITEM 5 IN LETTEm 70 LaCENSEE lMOl THEREconD 42 a)

I L Nuwstm 08 NONCormLIANCE eTEMS :DENTIFIED BY LICENSEE (AND NOT CITED # ll l M Nuweta 08 A8N0mWAL OCCum4ENCES REVIEWED ONS4TE Tms eN SPECTION l l mECIONAL 08 ssCE LETTEm 0m mf *0mf TRANSMITTAL DATE FOm <NSPECTt04 0e rNvfstacAfe0N REPORT SENT TO MOS FOR ACTION 58104 LETTEm 855vtDTO LICENSEE 32 gy N as St 1: bl/l l',M IIIIIl l u w 0 0 y v M M 0 0 y y SuSJECT Op iNvf 5TiCATiON iCMECE ONE 80s ONLve le te 10 CF m 20 405 Mr$C TYPE A to CF m 20 403 TYPES 1513 CattsCALITY 280 toutp FA Lunt 010 eNTERNAL 0vEnEEP05unt 06 0 11 0 NT OvEmEXP05UmE 12D Ext ovEmExP05umE 16D LO55etMtFT 22 D ALLE G Afl0N t0MPLAINT 02 D E xTs mN AL OVE RE EP05unt OT O 170 MUF 230 PuSLiC INTEREST 03 D RELE A5E To uN4157. AREA 08 D 13 D E XCESS MAD LEVELS 00 0 140 EXCESS CONC LEvlLS IS D TmAN5ponTAT80N 24 D 5ABOTAct 04 O LO55 08 8 ACILITv 10 D IS O CONTAM LE AttNG 50umCE 25 0 ASNomv&L OCCum 050 P20*EmTvDAMAGE 10 D E Nvim0Nvf NT AL tvtNT 2ED OTMEm MEADouamTCMSENTmiES -

11 y

' N05 ACT 0N ON INSP'tNVEST mistanEO sv AEciON *

(Sem N we Lest tas Coues __

at si i

NOTE BLOCKS e 70 L wus? St VER'813 av #E MOS *=ENtvf a O DATE n0% EN80mCEvthT LETTE st.t40TiCE.0moin e55utD ENTE E5 ARE uaOg im ogCCa5

• p u O O v v G4 P 0 ANO m 1

p Civil PENALTv e55utD et 72 A.ts s DATE 7 4 t .1E nE D ENTO CowuTEm f ett .*m vme attERENCE e.* ** y

. v ,

[

May 12. 1977 Dock No. 99900077 Pullman Xe11ogg Division of Pullman, Inc.

,- Attn: Mr. E. B. Curcio Comercial Vice President 14507 South Paramount Boulevard Paramount, CA 90723 Gentlemen:

Thank you for your letters of March 28,1977 and April 18,1977, in response to our letter dated February 14, 1977, with an attach-ment, and our letter dated April 12, 1977. We have no further questions at this time. We will review your corrwetive action during a future inspection.

Sincerely.

(), N' W h eV J. H. Tillou, Chief Vendor Inspection Branch bec:

t Central Files

!- PDR HQS i WEVetter I Barnes RLBrown

.o r c a n. _ gly f .%- .

Tillou I hk

.. .-. __Barnes/r%. . - - RLBr y.ow*n ... 5,33yy Hunnicutt -5,33,,, gyy,r ,

Ve,tte

.m

• - ... e a" a =-'a

, e.- ac.m u. m acx ==

l l

'Putnen inco ad Power Mping Get 14507 Sourn Parae Blvd Pullman Kellogg  % % if'!fG L ?'

L 5. Curcio commerce Vee Presdern April 18, 1977 United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. J. H. Tillou, Chief Vendor Inspection Branch

Subject:

Revision to Response Dated March 28, 1977 Docket No. 99900077 Program No. 44020 Gentlemen:

We are submitting with this letter Revision 1 to Page 3 of our original response as requested by your letter, dated April 12, 1977.

If, in your opinion, supplementary information is deemed necessary, we will extend every effort to comply.

Very truly yours, PULLMAN KELLOGG

~

E. B.'Curcio EBC/sw .

Enclosure cc: Mr. J. E. Bowes Mr. S. L. Engler Mr. E. F. Gerwin wone neaceanws for M W Ke tecnneecy ano sennees Mr. H. W. Owen Houston, Texas 77046

F Pcgs 3, vioicn 1 1 .

Ref: Paragraph 3.c(2)

Corrective We have asked Flowline to verify that the L tt Action treat performed by the plate manufacturer an.

Flowline meet the requirements of A.S.M.E.,

Section II, SA-403, Paragraph 8.3. In that letter, they state "Please be assured that when we show the tensile properties of the we are plate used towith in compliance manufacture the fitting,8.1, 8.2, SA-403, Paragraphs and 8.3". The heat treatment of Flowline's

fittings is essentially the same as that given by the manufacturer of the raw material. Our interpretation of Paragraph 8 is that the tensile properties of the fittings must meet the minimum tensile requirements of the material listed in Table 1. We are not required to show actual tensile results unless Supplementary Test S-2 is part of the order requirement.

I Corrective March 22, 1977 Action Completed Preventative A meeting was held by the Q.A. Manager to inform Action all material document examination personnel to be more aware of the requirements of the Code in the area of heat treatment. In the future, any questionable areas of vendor documents will be verified by the vendor before acceptance.

Preventative April 18, 1977 Action Completed j Ref: Paragraph 4.c Corrective All applicable traveler packages are in the Action process of being revised. Those operations which must be processed in a given order will be sequenced on the traveler.

Corrective April 11, 1977 Action To Be Completed Preventative Engineering personnel involved with the pro-Action cessing of travelers reviewed Section 4 of the Q.A. Manual and the Process Sheet (Figure 19B) . -

A typical example for sequencing of bending operations was distributed to involved personnel for their comments. An example of a typical Process Sheet was then issued to personnel for use on updating all travelers in process and will be used as a guide in the future.

Preventative March 24, 1977 Action Completed

g

+ .. c.1 April 12,1977 I

r '

Docke . 90900077 t.

Pullman Kellogg Division of Pullman, Inc.

, Attn: Mr. E. R. Curcio i Comercial Vice President 14507 South Paramount Boulevard Paranount, CA 90723 Gentlemen:

Thank you for your letter of March 23, 1977, in response to our letter dated February 1A, 1977, With an attachPent. As a result i

of our review, we find that additional information. as discussed l with your Mr. S. L. Enaler durinc a telephone call on April C.

' 1977 is needed. Specifically, in regard to item A.3.b. Surecry of Findings, describe the steps or measures you have taken or intend to take to assure reliabla conformance with this recuiremnt, how you intend to document these preventative measures and the date such actions will be completed.

Please provide us with the required information within twenty (20) days to enable us to co@lete our review of your response and to verify your corrective action durina a future inspection.

Sincerely, griginalSii;ned by:

l sh?TM l J. H. Tillou, Chief l.

'. Vendor Inspection i; ranch l

~

BCC: .

PDRHQS .

Central flies WEVETTER BARNES ,

.....* RIV W /. _.

Tillou WEVetter Barn /r ' RLBrwown Hunn t

'"""'"'" - 4/12/77 4/12/77- ~4/ ')/77 4/12/77 4/12/77 W u. a. eevanansare emienne errica sete.sae.tes Fere ABC.518 (Rev. 7 S$3 ABCM 9340 l~'mg- ew- ~ - -+,-- 3w-,aw ,.wwww- -w--,y,v--. ,oo-----yp- _m----x.--v t--- y m,-,-,-ys--y.w,,- m.,-_w. -, ..,m-m -w,---,,-,-,,--o----,w- -~ -m-

~

' ' Dmsen of h incor, se pos,er moins e m 14507 South Paramc. Bivo Paramount, Canfome -

Pullman Kellogg. - cna> s3,.u,'23

a. s. cweio Commercal vce Presdent March 28, 1977 i

United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. J. H. Tillou, Chief Vendor Inspection Branch

Subject:

Response - N.R.C. Audit January 24-27, 1977 Docket No. 99900077 Program No. 44020 Gentlemen:

In response to your audit report and letter of transmittal, dated February 14, 1977, (J. H. Tillou to E. B. Curcio) relative to the subject audit, we respectfully submit the attached comments.

We would like to thank you for granting us an extension from March 16 to March 31 to complete our response. If, in your opinion, supplementary information is deemed necessary, we will extend every effort to comply.

i Very truly yours, AN GG

', .': p -

f

,/ E . urcio EBC/sw cc: Mr. J. E. Bowes Mr. S. L. Engler l wone neacquaners for M W ke'

Mr. E. F. Gerwin tecnnee;;y ano semees Mr. H. W. Owen Houston. Texas 77046 l

l l

l Pcg2 1

)

RESPONSE TO FINDINGS - N.R.C. AUDIT - JANUARY 24-27, 1977  :

Docket No. 99900077 Program No. 44020 DETAILS - SECTION I Ref: Paragraph 5.c

,' Corrective As implied by Section 12 of the Q.A. Manual, Action it is intended that an audit be conducted on a semi-annual basis to verify compliance with all aspects of the Quality Assurance Program.

In the past, internal audits have covered all aspects of the Q.A. Program; however, only areas of noncompliance were reported. We realize that this may not fully document the scope of the audit; therefore, effective with the next internal audit, we will report all areas audited, whether they are areas of compliance or noncompliance. An indepth audit will be conducted within sixty (60) days of this reply by Central Staff personnel.

Corrective May 27, 1977 Action Completed Preventative Procedure No. XVIII-1, entitled " Internal Action Auditing Procedure of Shop' and Field Q.A.

Programs by Central Staff , dated March 21, 1976, will become a part of the Paramount Plant's Procedure Manual. This procedure covers all aspects of our Quality Program and will be used on all subsequent audits by Central Staff.

Preventative May 27, 1977 Action Initiated O

age M 'na n . i Pcgs 2 DETAILS - SECTION II Ref: Paragraph 2.c(3)(B)

Corrective All welding procedures that are distributed to shop personnel have been recalled. These Action procedures were reviewed by the Welding Foreman for completeness and reissued.

Corrective January 27, 1977 Action

- Completed Preventative On February 8, 1977, a meeting was held between Action production personnel for the purpose of correcting a deviation discovered in the January, 1977, N.R.C. Audit. The method of handing out the complete welding procedure was emphasized. A periodic sporcheck by the Welding Foreman was instituted as a preven-tative measure. A subsequent meeting was held by Mr. Ken Canning with his Rod Dispatchers concerning this subject on February 10, 1977.

Preventative February 10, 1977 Action Completed Ref: Paragraph 3.c(1)

Corrective In the past, Receiving Inspection has not docu-Action mented any dimensional verification. To correct this, we have revised our Receiving Inspection Procedure to include random dimen-sional inspection on a per-purchase order and item number basis. This procedure will be included in the Paramount Plant's Procedure Manual.

Corrective May 27, 1977

. Action Completed Preventative All Receiving Inspection forms and worksheets Action will be revised to include a column to cover

" Random Dimensions Verified" which will require the inspector to initial that this operation was completed. .

Preventative May 27, 1977 Action Completed

, y Pegs 3 Ref: Paragraph 3.c(2)

Response

We have asked Flowline to verify that the heat treat performed by the plate manufacturer and Flowline meet the requirements of A.S.M.E.,

- Section II, SA-403, Paragra7h 8.3. In that letter, they state "Please le assured that when we show the tensile properties of the plate used to manufacture the fitting, we are

- in compliance with SA-403, Paragraphs 8.1, 8.2, and 8.3". The heat treatment of Flowline's fittings is essentially the same as that given

- by the manufacturer of the raw material. Our interpretation of Paragraph 8 is that the tensile properties of the fittings must meet the minimum tensile requirements of the material listed in Table 1. We are not required to show actual tensile results unless Supplementary Test S-2 is part of the order requirement.

As we do not feel a deviation exists, no corrective action has been offered.

Ref: Paragraph 4.c Corrective All applicable traveler packages are in the Action process of being revised. Those operations which must be processed in a given order will be sequenced on the traveler.

Corrective April 11, 1977 Action To Be Completed Preventative Engineering personnel involved with the pro-Action cessing of travelers reviewed Section 4 of the Q.A. Manual and the Process Sheet (Figure 19B).

A typical example for sequencing of bending operations was distributed to involved personnel for their comments. An example of a typical Process Sheet was then issued to personnel for use on updating all travelers in process and will be used as a guide in the future.

Preventative March 24, 1977 Action .

Completed

I t l 0

ME v

~

ib' i b

i Docket No. 99900077 Pullman Kellogg Company Attn: Mr. E. B. Curcio Comercial Vice President

- 14507 South Paramount Boulevard Paramount, California 90723 l Gentlemen:

This refers to the QA program inspection conducted by Mr. H. W. Roberds of this office on January 24-27, 1977, of your facility at Paramount.

California, associated with the fabrication of nuclear piping assemblies, and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.

Areas examined and our findings are discussed in the enclosed report.

Within these areas, the inspection consisted of an examination of pro-cedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection it was found that the implementation of your QA program failed to meet certain comitments in your ASME accepted QA Manual. The findings and references to the pertinent requirements

("Susnary of Findings "

are identified in the attachment to this letter.

paragraph " Deviations from Comitments.")

- Please provide us within thirty (30) days a written statement containing.

(1) a description of any steps that have been or will be taken to correct these items, (2) a description of any steps that have been or will be takentopreventrecurrence,and(3)thedateyourcorrectiveactions i

i and preventive measures were or will be completed.

In accordance with Section 2.790 of the Comission's " Rules of Practice.

• • Part 2. Title 10. Code of Federal Regulations, a copy of this letter and your reply, together with the enclosed inspection report contains If this report will be placed any in the Comission's Public Document Room.

Information that you believe to be proprietar make a written application within thirty days to(30)y, this office it istonecessary withhold such information from public disclosure. Any such application "

must include a full statement of the reasons on the basis of which it -

is claimed that the infonnation is proprietary, and should be prepared y .. ,

.r ... . e _RLL__.h fa Md g_DMHunnicutt _.JHIllls hh WEVettar

...--.* _JfWRoberd

• 2L10/77 _2/1/17 _.2/w /77 __2Ld/77

<n.,. s.m acu ma s ..... n.....,e.,~n~. .er,c.., u. .

r. ac.m

Pullman Kellogg Company so that. proprietary inforsation identified in the application is con-tained in a separate part of the doctanent. If we do not hear from you in'this regard within the specified period, the report will be placed in the Public Docisnent Room.

.~

Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

$1ncereiy,

' originai s.;c. :: cy:

\ htLJillou_

J. H. Tillou, Chief Vendor Inspection Branch Attactrier.t:

Inspection Report humber 99900077/77-01 bcc:

IE CHIEF, FC&EB IE CHIEF, V&ARPB IE REG. COORDINATOR IE FILES NRR:DPM:QAB CENTRAL FILES

~

PDR HQ REGIONAL. DIRECTORS 1. III V

' W.E. VETTER RIV ASME l NBB&PVI

(

i

!^

t e

e

,,,,,,___,-,-__y--__ --

- . - - . - , . . _ , , - ,...-_.,,..-,.-p

1 L 11/76 U. S. NUCLEAR REGLIATORY COW.ISSION OFFICE OF INSPECTION & ENFORCEMENT REGION IV REPORT OF VIB INSPECTION Inspe'ction 3,,g,g yo,99900077 Report No. 99900077/77-01

• Company Name:

Pullman Kellogg progr ,yo,4020 14507 South Paramount Boulevard Address:

Paramount, California 90723 Type of Routine, Announced Inspection:

Date(s) of January 24-27, 1977 Inspection Date(s) of August 23-26, 1976 Previous Insp.

LeadInspectorf,M. k _ _

Date: M/d/7' W. MoDerds, LontraCT,or inspector, vi erancn i /

4A ns $ sf: ,' N of Date: M/0!77

1. Barnes, contractor Inspector, vi urancn Date:

/0!7' /

H. M. Wescott, Contractor Inspector, V1 Brancn 4

Date:

i Date:

Date:

Reviewed By: k ,k M

• Y Date: . J.[/D!7 f Chief Components Section 2 / . /.

D.Vendor M. Hun'nicutt,Inspection Branch i

.~.,,-w,- -

-.- :,,,, ,v-.--ne-----.--.----y.,ym,,., --,,_-,3 e,, _-_, ,..___m,--e..- ., ,.,.--.--,-.y----. ,,,___y,--,,

SUMMARY

OF FINDINGS A. Deviation From Comitments

1. Contrary to the QA Manual, paragraph 12.1, certain aspects of the Quality Assurance Program were not audited on a semi-annual basis. (DetailsSectionI, paragraph 5.c.)

2. Contrary to the QA Manual, paragraph 5.3.3, and paragraph NA-4411 in ASME Section III, an addendum to a welding pro-cedure specification, which invoked additional required nonessential variables, was not supplied to the welder for performance of the assigned weld. (DetailsSection II, paragraph 2.c.(3)(b).)

3. Contrary to the QA Manual, paragraph 3.4, and paragraph NA-4430 in ASME Section III:

a. The receiving inspection records and forms do not documen*. that physical checks were made of incoming materia ~ls with respect to dimensional conformance to purchase order requirements.

b. Documentation for welded piping was accepted and released by QA, which contained a certified material test report that was not in compliance with the require-ments of the applicable material specification. (DetailsSection II, paragraph 3.c.)

4. Contrary to the QA Manual, paragraph 4.1.1, a process sheet was issued by Engineering, which failed to list a required operation and also did not note those operations to be performed in a specific sequence. (DetailsSection II, paragraph 4.c.)

B. Vendors Actions on Previously Identified Deviations

1. Item A.1 of Report Number 76-02, Summary of Findings, is closed. (DetailsSection I, paragraph 3.c.(1)).

2. Item A.2 of Report Number 76-02, Summary of Findings, is closed (DetailsSectionI, paragraph 3.c.(2)). ,

.-,.-n~m.- ,.-- - - - - - - - - - - - . - , ,

- , , -----,w-.m . - - - . ,_--%--_.m.,~.,m---_..m- .mm-- -,.

3. Item A.3 of Report Number 76-02 Sumary of Findings, is closed (DetailsSection I, paragraph 3.c.(3)).

4 .' Item A.4 of Report Number 76-02, Summary of Findings, is closed (DetailsSectionII, paragraph 2.c.(1)).

- 5. Item A.5 of Report Number 76-02 Sumary of Findings, is closed (DetailsSection II, paragraph 2.c.(2)).

6. Item A.6 of Report Number 76-02, Summary of Findings, is closed (DetailsSection II, paragraph 2.c.(3)(a)).

7. Item A.7 of Report Number 76-02, Sumary of Findings, is closed (DetailsSection II, paragraph 2.c.(4)).

8. Item A.8 of Report Number 76-02, Sumary of Findings, is closed (DetailsSection II, paragraph 2.c.(5)).

9. Item A.9 of Report Number 76-02 Sumary of Findings, is closed (DetailsSectionII, paragraph 2.c.(6)).

10. Item A.10 of Report Number 76-02, Sumary of Findings, is closed (DetailsSection II, paragraph 2.c.(7)).

11. Item A.11 of Report Number 76-02, Sumary of Findings, is closed (DetailsSection II, paragraph 2.c.(8)).

l i C. Status of Previously Reported Unresolved Items There were no previously reported unresolved items.

D. Other Significant Findings

1. Current Findings The Pullman Kellogg Company, Paramount, California plant, has rewritten their Quality Assurance Manual, and they are scheduled for an ASME survey starting May 31, 1977.

! 2. Unresolved Matters This Inspection

a. Lack of audit documentation to verify adequacy of vendor heat treatment capabilities with respect to

' solution annealing specification requirements (Details -

SectionIII, paragraph 2.c.). ,,

b. Lack of documentation to verify compliance with ovality requirements of the ASME Code (DetailsSection III, paragraph 3.c.).

c. Measures, procedures and documentation had not been l established to assure that contact pyrometers and oxygen analyzers were included in the calibration system (Details

'~

SectionIII, paragraph 4.c.).

E. Management Interview A management interview was held on January 27,1977, at the Pullman Kellogg facility in Paramount, California. The results of the inspection were discussed with the following management representatives:

E. B. Curcio, Comercial Vice President S. L. Engler Quality Assurance Manager D. E. Cochrane, Quality Assurance Manager

1. Management was infomed that implementation of their ASME accepted Quality Assurance Manual had been inspected in the following areas:

(a) Material Control (DetailsSection I, paragraph 4.).

(b) Audits (DetailsSectionI, paragraph 5.). .

l (c) Procurement Control (DetailsSection II, paragraph 3.).

(d) Control of Bending and Ferming (DetailsSection II, paragraph 4, and Section III, paragraph 3.).

(e) Control of Special Processes (Heat Treatment) (DetailsSection III, paragraph 2.).

(f) Calibration (DetailsSectionIII, paragraph 4.).

- 2. The four (4) deviations from comitments, described in Section A above, were discussed with management representatives.

'- 3. The status of previously identified deviations, as described in Section B above, were discussed with management representatives.

4. The three (3) unresolved items identified during this inspection -

as described in Section D above, were discussed with management .

l representatives.

5. Management representatives had no coments on the above four (4) items.

DETAILS SECTION I (Prepared by H. W. Roberds)

1. Additional Persons Contacted In addition to those persons listed in the management interview section of this report, the following persons were contacted:

J. A. Swanson, Manager, Engineering Z. X. Corder, QC Supervisor

2. General This inspection was conducted to verify that the Pullman Kellogg Company, Paramount, California plant (PKCA), Quality Assurance progran as described in the ASME accepted Quality Assurance Manual is being implemented, and gives reasonable assurance that parts and/or components manufactured under this program will comply with applicable codes and standards.

3. Vendors Action on Previously Identified Deviations

References:

IE Report Number 76-02, and PKCA's response letters of October 15, 1976, and December 8, 1976.

a. Inspection Objective The objective of this inspection was to verify that PKCA had implemented the corrective action measures identified in their response letters of Dctober 15, 1976, and December 8, 1976, to the USNRC, the corrective action measures were com-plate and steps had been taken to prevent recurrences,

b. Inspection Objective Accomplished By:

(1) Review of Inspection Report Number 76-02.

Review of PKCA's response letters dated October 15, (2) 1976, and December 8,1976.

(3) Review of Radiographic Procedure JS-414 Revision 3, .

of 7/21/76. -

(4) Selective review of production radiographs.

l l

l

6-(5) Review of NDE personnel qualification and certification records.

," (6) Review of data reports on file in the QA Department.

c. Inspection Findings (1) Inspection Report Number 76-02 Item 1, of Summary of Findings.

It was verified that PKCA had initiated the corrective action and the steps to preclude recurrence, as defined in their response letter dated October 15, 1976.

This item is closed.

(2) Inspection Report Number 76-02, Item 2 of Summary of Findings.

It was verified that PKCA had initiated the corrective action and the steps to preclude recurrence, as defined in their response letter dated October 15, 1976.

This item is closed.

(3) Inspection Report Number 76-02, Item 3, of Sunnary of

' Findings.

It was verified that PKCA had initiated corrective action to meet the requirements of Section V of the l ASME Code.

I l This item is closed.

4. Material Control

a. Inspection Objective The objective of this inspection was to verify that PKCA had implemented the system for control of material, as defined in Section 3 of the ASME accepted QA Manual.

b. Inspection Objective Accomplished By:

(1) Review of Section 3 of the QA Manual. ,

(2) Review cf Purchase Orders.

(3) Review of receiving inspection reports.

(4) Selective review of documentation and material certification records.

'- c. Inspection Findings There were no deviations from comitments identified within the scope of this inspection.

5. Audits

a. Inspection Objective The objective of this inspection was to verify that PKCA had implemented the system for audits as defined in Section 12 of the A':E accepted QA Manual.

b. Inspection Objective Accomplished By:

(1) Review of Section 12 of the QA Manual.

(2) Review of internal audit file.

(3) Interviews with cognizant personnel.

c. Inspection Findings Within the scope of this inspection the following deviation from comitment was identified and discussed with management:

I Paragraph 12.1 of the QA Manual states in part, "On a semi-annual basis, the General Manager of Quality Assurance Central Staff assigns qualified personnel . . . to audit jobsites or fabrication plants, including Paramount Plant."

Section III of the ASME Code, Article NA-4000, paragraph NA-4900, states in part, "A comprehensive system of planned and periodic audits shall be carried out by the Certificate of Authorization holder's organization to assure compliance with all aspects of the Quality Assurance Program . . . ."

l l

l i - . . . _ _ . . _ , _ , _ _ . _. _ _ _ , _ , . _ _ _ , _ _ ._.

1 Contrary to the above, PKCA did not audit all aspects of (

the Quality Assurance Program on a semi-annual basis to

. assure compliance, as illustrated in the following example: j Two in-plant audits were performed in 1976, one on June 9, 1976, and one on November 17, 1976. The November audit ,

did not include the QA program aspects of Process Control, i

.~

Welding, NDE, Calibration, Heat Treatment, Documentation and Nonconfonnance, and Corrective Action.

f

• e O

D 1

4 DETAILS SECTION II (PreparedbyI.Barnes) l

1. Additional Persons Contacted In addition to those persons listed in the management interview section of this report, the following persons were contacted:

K. G. Canning, Welding Foreman Z. X. Corder. QC Supervisor R. C. Gilliam, Rod Room Clerk J. A. Swanson, Manager Engineering

2. Vendors Action on Previously Identified Deviations

References:

IE Report Number 76-02, and Pullman Kellogg Company, Paramount plant (PKCA) response letter dated October 15, 1976.

Inspection Objective a.

The objective of this inspection was to verify that PKCA had initiated the corrective actions identified in their response letter of October 15, 1976, to the USNRC, the corrective action measures were complete, and steps had been taken to prevent recurrence.

b. Inspection Objective Accomplished By:

(1) Review of Inspection Report No. 76-02, dated September 17, 1976.

(2) Review of PKCA response letter, dated October 15, 1976.

(3) Examination of the proposed revised QA Manual, Issue No. 3, dated December 30, 1976.

I (4) Observation of rod room and production welding operations for control of welding materials.

(5) Review of training record pertaining to welding material selection and issue. '

(6) Review of selected welding procedure specifications for ' -

/

completeness with respect to nonessential variables.

e

- , , . . , , _ - - - , - --- -.- , - . , . - . ---,._-_.,,,-.e_.-_. ___,_v,-----, , _ , , , , , , , _ - - .-_ . _ - , , , - - - . - - . , - _ , - - - - - , , . - ,

. s (7) Review of proposed format for welding procedure specifications.

(B) Review of production welding machines for posting of amperage and voltage correlation charts.

(9) Review of supporting procedure for calibration of welding equipment.

(10) Verification of presence of selected nonconforming materials in QA hold area.

(11) Review of draft procedure, dated January 2'1, 1977, l

" Indoctrination and Training of Personnel Other Than QA and QC."

(12) Interviews with cognizant personnel.

c. Inspection Findings (1)

Reference:

Inspection Report Number 76-02, Item A.4 of Sunnary of Findings.

It was verified that the proposed revision to the QA Manual, dated December 30, 1976, resolved the discrepancy identified in the QA Manual, dated July 15, 1976.

This deviation is closed.

(2)

Reference:

Inspection Report Number 76-02, Item A.5 of Sunnary of Findings.

It was verified that PKCA had implemented the corrective actions described in their response letter of October 15, 1976. No further instances of incorrect welding material usage were observed during observation of production welding operations.

This deviation is closed.

(3)

Reference:

of Inspection Report Number 76-02, Item A.6 Summary of Findings.

(a) It was verified that PKCA had reviewed active

• welding procedure specifications and issued addenda, where required, to include applicable nonessential variables.

This deviation is closed.

(b) During review of implementation of corrective action, the following additional deviation from comitment was observed:

Section 5 of the QA Manual, paragraph 5.3.3, states in part, "Each welder or welding operator completes the assigned weld, welding, or portion thereof, using the specified procedure . . ."

i Paragraph NA-4411 in Section III of the ASME Boiler and Pressure Vessel Code states in part, "The Pro-gram shall include measures to control the issuance and disposition of documents, . . . including changes thereto, which prescribe the activities affecting quality. These measures shall assure that documents, including changes, are . . . used at the location where the prescribed activity is performed."

Contrary to the above, Addendum No.1 to welding procedure specification JS603 (LA 3(A)-1-08-1),

which specified additional required nonessential variables, was not supplied with the welding pro-l cedure specification to the welder for welding operations on Weld A. Job No. 2745, Sheet F-126.

(4)

Reference:

Inspection Report Number 76-02, Item A.7 of Sumary of Findings.

It was verified that PKCA had implemented the corrective actions described in their response letter of October 15, 1976, with respect to calibration of welding power sources.

This deviation is closed.

Inspection Report Number 76-02, Item A.8 (5)

Reference:

of Sumary of Findings.

) It was verified that PKCA had implemented the corrective l acticns described in their response letter of October 15, l*

1976, with respect to placement of nonconforming materials in the QA hold area.

This deviation is closed.

Inspection Report Number 76-02, Item A.9 (6)

Reference:

of Sunnary of Findings. .

It was verified that the proposed revision to the QA i

-..----,---,_,---__--,,,,,_,-,.,,.----.,.._,.,-..-.----.-,,_-.-n,-.-

Manual, dated December 30, 1976, clarified the criteria for referral of drawing revisions to the organization

. responsible for the stress report.

This deviation is closed.

(7)

Reference:

Inspection Report Number 76-02, Item A.10 of Sunnary of Findings.

• It was verified that PKCA had implemented the corrective actions described in their response letter of October 15, 1976, with respect to collection and destruction of voided specifications.

This deviation is closed.

(8)

Reference:

Inspection Report Number 76-02, Item A.11 of Sumary of Findings.

It was verified that the proposed revision to the QA Manual, dated December 30, 1976, addresses the require-ments of NA-4132 in ASME Section III.

This deviation is closed.

3. Procurement Control .

a. Inspection Objective The objective of this inspection was to verify that PXCA had implemented the system for control of procurement, as defined in Section 3 of the ASME accepted QA Manual.

b. Inspection Objective Accomplished By:

(1) Review of QA Manual, Section 3, dated July 15, 1976,

" Procurement Control."

(2) Selective review of purchase order numbers 2740-1, Item 61; 2730-8, Item 14; 2745-1 Item 42; and 2730-36,

' Item 478.

(3) Review of certified material test reports, receiving .

records, and receiving inspection reports for referenced purchase order items. ,,

l

l (4) Selective review of inspection report worksheets.

(5) Review of receiving inspection procedure X-8, dated December 1,1976.

(6) Review of " Purchasing Specification for Mild Steel Covered Arc Welding Electrodes," IV-100-S'75, Rev. O.

c. Inspection Findings ,

Within the scope of this inspection, the following deviation from comitment was identified with respect to adequacy of procurement control measures:

Section 3 of the QA Manual, paragraph 3.4, states in part with respect to receiving inspection, ". . . The QA Department reviews and approves documentation and initiates an Inspection Report. The inspector assigned to receiving inspection, using the Inspection Report, purchase order, and/or other applicable documents, physically checks the material to verify compliance Paragraph NA-4430 in Section III of the ASME Boiler and Pressure Vessel Code states in part, " Measures shall be established to assure that all purchased material, items and services conform to these requirements . . ."

Contrary to the above requirements:

(1) The Inspection Report foms and Inspection Report Worksheets used by PKCA do not address or require dimensional verification of incoming materials with respect to purchase order requirements. No other documentation was made available to the inspector to confim this activity was bcing performed.

A documentation package for welded SA-403 Type 304 (2) piping, Final Heat Number 40895, was accepted and

. released by QA, which contained a certified material test report from the piping vendor, that was not The in compliance with paragraph 8.3 of SA-403 1.c.

plate manufacturer tensile properties were used by the piping manufacturer without the required assurance that the heat treatments used by both plate manufacturer -

and piping manufacturer were the same. _

i 1

I i

1 . .

, s

4. Bending and Feming a ., inspection Objective The objective of this inspection was to verify that pro-visions were made in process control to provide assurance that bending and foming operations were controlled in accordance with the requirements of Section 8 of the ASME accepted QA Manual.

b. Inspection Objective Accomplished By:

(1) Review of the QA Manual, Section 4, dated July 15, 1976,

" Process Control."

(2) Review of the QA Manual, Section 8, dated July 15, 1976,

" Heat Treating."

(3) Review of process sheet for Job No. 2740, Sheet F-312.

(4) Interviews with cognizant personnel.

c. Inspection Findings Within the scope of this inspection, the following deviation from comitment was identified and discussed with management:

Section 4 of the QA Manual, paragraph 4.1.1, states in part,

" . . . The Process Sheet writer lists the operations, in-spections, and examinations to fabricate the piping sub-assembly (Figure 19A). Operations which are required to be perfomed in a specific sequence will be so noted, on the Process Sheet (Figure 198). . . "

Contrary to the above requirements:

(1)

The Process Sheet writer did not list the operation required for bending on the process sheet applicable to Job No. 2740 Sheet F-312.

(2) Operations required to be perfomed in a specific sequence (example: annealing, quench, pickle and passivate, and ultrasonic and liquid penetrant examinations),ofthebendarea,werenotlisted ~

on the Process Sheet for Job No. 2740, Sheet F-312.

4

DETAILS SECTION III (PreparedbyH.M.Wescott)

1. Additional Personnel Contacted Z. X. Corder QC Supervisor J. A. Swanson, Manager, Engineering J. C. Watkins, General Foreman F. Ferrara, Welder W. Pegram, Staff Engineer J. Smith, Pipe Bending Foreman

2. Control of Special Processes (Heat Treatnent)

a. Inspection Objectives The objective of this inspection was to verify that Pullman Kellogg had implemented the system for control of heat treatment as defined in the ASME accepted QA Manual.

b. Inspection Objectives Accomplished By:

(1) Review of the QA Manual, Section 8 dated 7/15/76.

(2) Discussion with QA/QC personnel.

(3) Review of furnace uniformity check records.

(4) Review of applicable procedures and documents.

(5) Observation in shop area.

c. Inspection Findings Pullman Kellogg has not performed any heat Astreatment of a result, nuclear piping in approximately one year.

' implementation of Section 8 of the QA Manual could not be verified during this inspection. A further examination of this activity will be made during a subsequent inspection.

Review of the audit records of a heat treatment vendor providing solution annealing services showed no documentation -

to support the capability of the vendor's equipment and ..

Practices to conform to Pullman Kellogg's specification requirements.

l

QA personnel stated that another audit would be performed prior to contracting for soTution annealing.

This item is considered unresolved.

3. Sending and Forming

a. Inspection Objective The objective of this inspection was to determine that Pullman Kellogg's process control provisions include forming or bending of pressure retaining material and to verify that these operations are conducted in accordance with applicable

' procedures and the ASME accepted QA Manual.

b. Inspection Objectives Accomplished By:

(1) Review of the QA Manual. Section 8. dated 7/15/76.

(2) Discussion with QA/QC personnel.

(3) Review of applicable procedures and documents.

(4) Review of shop travelers.

(5) Observation of pipe bending in progress (non nuclear).

(6) Review of records.

c. Inspection Finding There was no documented evidence to verify that the eight percent (8%) ovality tolerance requirement of ASME Code.

Section III, paragraph NB-4233.2 was being met. Management stated that the required measurements would be recorded on future documents.

This item is considered unresolved.

4. Calibration

a. Inspection Objectives The objectives of this inspection were to verify that a '

system for calibration of equipment is being implemented as -

defined in the ASME accepted QA Manual.

-"-e'*wr-+- --- ._ _.,.,

b. Inspection Dbjectives Accomplished By:

(1) Review of the QA Manual. Section 7 dated 7/15/76.

(2) Random selection of measuring equipment in the shop area.

is (3) Observation made in shop area.

(4) Review of applicable procedures.

(5) Review of calibration certifications.

c. Inspection Findings Within the scope of this inspection, the following unresolved item was identified:

The QA Manual, Section 1, paragraph 1.1, states in part.

"It meets the quality assurance requirements contained in Section III of the ASME Code, entitled," Nuclear Power Plant Components," and specifically responds to the require-

' ments for establishment of a Quality Assurance Program as defined in Article NA-4000. " Quality Assurance" of Section III of the ASME Code."

The ASME Code Section III, paragraph NA-4531, states in part.

" Measures shall be established and documented to assure that tools, gages, instruments, and other examination, measuring and testing equipment and devices used in activities affecting quality are of the proper range, type, and accuracy to verify

! conformance to established requirements . . . ."

l Measures, procedures and documentation had not been established to assure that contact pyrometers and oxygen analyzers were included in the calibrations system. These instruments were used to measure parameters affecting quality.

G

• O

C. .&

I l

' January 17, 1977 Docket $o. 99900077 Mr. E. B. Curcio

- Cosamercial Vice President Pullman Kellogg Company 14507 S. Paramount Boulevard

- Paramount, CA 90723 Gerstienen:

h is is to confirm the telephone conversation on January 6, 1977 by Mr. B. Roberds of this office with Mr. S. L. Engler of your staff, concerning the inspection at the Paranount, California plant on January 24-28, 1977.

The NRC inspection team will consist of Messrs. Barold Roberds, Ian Barnes, and Harvey Wescott.

The inspection will relate to implementation of the following elements of your QA program: procurement, material control, heat treatment, forming, equipment calibration, audits and corrective action commit-ments on previous identified deviations.

Your cooperation concerning this matter will be appreciated.

Sincerely, Original Signed by:

J.H.Tillou J. B. Tillou, Chief

., g , ., .. .. , ;, , Vendor Inspection Branch cc: Mr. S. L. Engler

> r

• • m a *  ?. kl-- ..A Roberds/ng Hundichte T:,no

'"" " * " ' " - 1/17/77 1117/77

-1/17/77 save >

• in e, sevsammam, panemme erreces s.va.eae.ses Perm ABCate (Ear. 919) ANGE 8849 6-

• - ----+,-,%- _ v,-- - . . - - - _ --,,.----,-ww-,

, . -,v , , . ,,,e e- - ---- . - -- .-. -w r y---

Puttman W N' Power Piping Steep '

14507 South Paramiv' Paramount. Cahfornia 9; Telennone (213) 531 137 Pullman Kellogg I

' - October 15, 1976 United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. J. H. Tillou, Chief Vendor inspection Branch

Subject:

Response - N.R.C. Audit August 23-26, 1976 Docket No. 99900077 Program No. 44020 Gentlemen:

In response to your audit report and letter of transmittal, dated September 17, 1976, (J. H. Tillou to E. B. Curcio) relative to the subject audit, we respectfully submit the attached comments.

If, in your opinion, supplementary information is deemed necessary, we will extend every effort to comply.

Very truly yours.

PULLMAN KELLOGG l h t I

~ _

H. W. Owen Assistant Plant Manager I- HWO/sw I

cc: J .E. Bowes .

D.E. Cochrane ' '

E.B. Curcio E.F. Gerwin l

World beacquarters for M W.KelloGG technology and sen, ices Houston. Texas 77046 g ---r - , - - - - -

e e _ ,, , _ , - -

- - , - - - - - - - , , ,. ,. ,- - - - - - - , , , n ,

P

, P g3 1 RESPONSE TO FINDINGS - N.R.C. AUDIT - AUGUST 23-26, 1976 Docket No. 99900077 Program No. 44020 DETAILS - SECTION l Ref: Paragraph 5.c We have recalled all applicable traveler packages. The Corrective necessary ASME Code Data Reports were completed and

Action inserted in the packages. The completed package was returned to the Q.A. Department for file, awaiting Inspection.

Corrective September 3, 1976 Action Completed We propose to revise our Q.A. Manual to enable the Prever ta ti ve Engineering Department to issue the ASME Code Data Report Action at any point during the fabrication cycle prior to final inspection.

December 31, 1976 Preventative Action To Be Completed Ref: Paragraph 7.c(1)

The Level 11 Individual whose certification had lapsed Corrective has been re-examined in accordance with Pullman Kellogg's Action NDE Personnel Certification requirements.

September 30, 1976 Corrective -

Action Completed To prevent reoccurrence, the Q.C. Supervisor will review Preventative the certification status of all NDE personnel on a monthly Action basis. When an NDE technician's recertification is due in the succeeding month, the Q.C. Supervisor will schedule the necessary activities.

l-I Preventative September 30, 1976 -

l Action ,,

Initiated f .

} -- -- _- __ _ - _ _ _ . . _ _ _ . _ _ _ _ __ _ __

. m. .

V 9:g2 2 Ref: Paragraph 7.c(2)

ASME Section V. Summer 1974 Addenda, states in full, ",

Response

the radiation passes through one wall and inaccessibility prevents source-side placement of the penetrameter, a film side penetrameter may be used from T-261. When the radiation must pass through two walls of a cylinder, the penetrameter given in Table T-270 may be used." The radiation did pass through two walls of the object in producing the radiographs at Job No. 2730, Sheet No. F-343, Weld A. The welds for Job No. 2730, Sheet No. F-87, have been radiographed to date. The alleged deviation is a result of an Individual definition of inacceptability.

The penetrameter placement requirements have been more specifically defined in Winter 1975 Addenda, T-271-2(a),

which states in full, "When the radiation must pass through two walls of the object, a film side penetrameter shall be used. Penetrameter placement shall be as Indicated in T-263-1." It is our feeling that the radiograph for Job No. 2730, Sheet No. F-343, Weld A, complies with the intent of the ASME Code and Pullman Kellogg's Specification No.

JS-414.

As we do not feel a deviation exists, no corrective action has been offered.

DETAILS - SECTION ll Ref: Paragraph 4.c(1)

Response

As a supplement to the requirements of the Q.A. Manual, all welding materials which are used to join P No. I are being tested in accordance with the requirements of ASME Section ill, Paragraph NB 2431.2, Standard Test Requirements.

l The Pullman Kellogg Q.A. Manual will be revised to correct l Corrective this condition, Action i

December 31, 1976 Correcti ve Action To Be Completed The Pullman Kellogg Q. A. Manual will be revised as needed Preventative l' Action to remain current with the ASME Code.

Ref: Paragraph 4.c(2) .

Response

The welding procedure had been qualified using EM12K wire '

with the lot of flux being used.

l

P5g2 3 Ifi-The welding procedure was revised to include AWS Cl.- -he Corrective Action cation EM12K and has been submitted and returned fro customer approved.

l Corrective September 20, 1976  :

Action j Completed ,

A training session pertaining to the above incident was ,

Preventative conducted at this facility. In attendance were personnel Action from Q.A., Shop supervision, and management. The system of handing out welding wire and flux was reviewed, and ,

emphasis was stressed on the fact that no substitutions could be made.

Preventative September 28, 1976 Action Completed Ref: Paragraph 4.c(3)

The welding procedures will be amended to include all non-Corrective Action essential variables.

December 31, 1976 Corrective Action To Be Completed We propose to adopt WPS form similar to the form currently Preventative This form, with minor changes, Action shown in ASME Section IX.

would fit our requirements and would cover all variables, essential, supplementary essential, and nonessential.

Preventative January 30, 1977 Action To Be Completed Ref: Paragraph 4.c(@_)

A chart will be developed for each welding machine

• to Corrective correlate the machine dial settings with the amp and volt Action requi rements of the welding procedures. This will supplement our existing welder audits which require a Q.C.

Inspector to periodically check the electrical current output with currently calibrated testing equipment.

• Welding machines equipped with a pointer-type presentation for selecting electrical values. .

December 31, 1976 Corrective Action To Be Completed

y;ge b r

The amp and volt correlation charts will be posted or Preventa tive near each welding machine for operator reference.

Action December 31, 1976 Preventative Action To Be Completed Ref: Paragraph 5.'c All nonconforming materials have been moved to the Q.A. (

Corrective " hold" area.

Action September 20, 1976 Corrective Action Completed The " hold" area has been moved and enlarged, and additional Preventative personnel have been hired to handle additional receiving Action inspection.

Preventative September 20, 1976 Action Completed Ref: Paragraph 6.c(1)

The drawings released for fabrication by the Pullman Kellogg

Response

Engineering Department are prepared from drawings which the engineering organization responsible for the stress report has issued to Pullman Kellogg as " approved for construction".

Any change to our shop drawings which could have an effect on the stress report are made as a result of drawing changes or drawing change notices received from the engineering The type organization responsible for the stress report.

of revisions which may be Initiated by Pullman Kellogg's Engineering Department are not of the type These thatchanges, would effect in the design or integrity of the system.

general, consist of changes in material identification or the addition of other information developed during the fabrication process.

l The Pullman Kellogg Q.A. Manual will be revised to clarify Corrective that portion of Paragraph 2.2 which states that Pullman Action Kellogg's Engineering Department will refer all revisions back to the person or organization responsible for the

,~ stress report.

December 31, 1976 Correction .

Action To Be ,

Completed

- ---n ~ - - , -

P093 5 Ref: Paragraph 6.c(2)

All volded revisions in the controlled copies of our Jc.

Corrective Specifications Book have been picked up and destroyed.

Action August 30, 1976 Corrective Action

• Completed ,

A runner has been appointed to distribute specification Preventative revisions and to pick up all volded revisions for Action destruction in accordance with the Instructions in the Q.A. Manual. The Project Engineers have been Instructed that the above procedure must be followed.

Preventative August 30, 1976 Action Completed Ref: Paragraph 3.c(1)

The Pullman Kellogg Q.A. Manual will be revised to incor-Corrective porate the requirements of the ASME Code through the Action Sunener 1976 Addenda.

December 31, 1976 Corrective Action To Be Completed Preventative i n the future, the Pullman Kellogg Q.A. Manual will be revised as needed to reflect the current requirements of Action the ASME Code.

l l

l e

O l

l

..y

bitman incorporett t

= .

Poest Pipene 4keup 3

14507 South Peremour.

Paramount. Califomia 9; Teiephone (213) 531 137<

Pullman Kellogg December 8, 1976 United Sta:es Nuclear Regulatory Commission Region IV

• 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Attention: Mr. J. H. Tillou, Chief Vendor ine,pection Branch

Subject:

Response - N.R.C. Audit August 23-26, 1976 Docket No. 99900077 Program No. 44020 Gentlemen:

Enclosed please find our revised response to the findings identified in the NRC Inspection Report No. 99900077/76-02,Section I, Paragraph 7.c(2).

In response to our telecon of November 8, 1976, with Mr. H. W. Roberds, we have reconstructed our response in an attempt to clarify our position and correct typographical errors.

We wish to thank you for your cooperation in extending us the opportunity to resubmit our response, if we can be of any further service in this matter, please contact us.

Very truly yours, PULLMAN KELLOGG

[hl. r I.,,. m.

D. E. Cochrane Quality Assurance Manager I

H. W. Owen

' Assistant Plant Manager DEC/sa World headquarters for M W.KelloG3 tecnnoiogy one services cc: J.E. Bowes Houston. T**** 77046 E.B. Curcio E.F. Gerwin

, . - , - - - , . , , , . - - - . . - - , - ---e

e RESPONSE TO FINDINGS - N.R.C. AUDIT - AUGUST 23-26, 1976 Docket No. 99900077 Program No. 44020 DETAILS - SECTION l Ref: Paragraph 7.c(2)

Response (Revision 1) The radiographs referenced in the NRC audit findings of Pullman Kellogg, Paramount Plant, dated September 17, 1976, are for the San Onofre project, Unit No. 2. The 1974 Edition, including the Sumner 1974 Addenda of the ASME Code, governs this project as it relates to our fabrication.

The radiographs referenced in the NRC audit findings wsre identified as follows:

1. Job No. 2730, Sheet No. F-87

2. Job No. 2730, Sheet No. F-343, Weld A Background of item No. 1 These welds had not been radiographed at the time of the NRC audit. We do not have an explanation for the reference to these welds in the NRC audit findings; and because they had not been radiographed, no corrective action can be taken.

Background of item No. 2 This weld is a circumferential buttweld joining a 6" ScLedule 40 long radius 45' stainless steel elbow to a length c' 6" Schedule 40 stainless steel pipe.

The radiographs were produced for single wall viewing, while the source of radiation was placed so that the radiation passed through two walls. Five equally spaced exposures l

• were taken to examine the entire weld. A pecetrameter desig-nation 10 was selected from Table T-270 of ASME Section V, Summer 1974 Addenda, and placed on the film side for each exposure. A lead letter "F" was placed adjacent to the penetrameter to indicate the film side placement.

The ASME Code does not dictate or Ilmit the placement of the source of radiation relative to double wall or single wall ..

exposures for circumferential buttwelds over 3-1/2" in outside di ame ter . Furthermore, the Code allows the placement of the penetrameter to be either source or film side, without restrictions or limits, when a technique is employed which requires the radiation to pass through two walls.

- , - ,--e- , - , , - . - - --,--,-----am - - - . , , , v- --n----,v,--g- r --- - - - - - - - , - , - - - - - - - - - - - -

P g2 2 of We support the above statement by reference to Paragraphs T-271 and T-272 of ASME Section V, Summer 1974 Addenda, which read as follows:

T-271 single Wall Viewing "Except as permitted in T-273, radiographic examination of circumferential buttwelds shall be performed with single wall viewing only. The radiation may pass through one or both walls. Where the source is located outside the cylinder, a minimum of four exposures separated by 90' shall be required for single well viewing. When the radiation must pass through two walls of a cylinder, the

,~ penetrameter given in Table T-270 may be used."

T-272 Film Side Penetrameter "If the radiation passes through one wall and inaccessibility prevents source-side placement of the penetrameter, a film-side penetrameter may be used from T-261. When the radiation must pass through two walls of a cylinder, the penetrameter given in Table T-270 may be used."

Paragraphs T-271 and T-272 clearly state that accessibility is only a consideration when placing a penetrameter for a single wall exposure technique.

As the radiographs in question are a result of employing a double wall technique, the placement of the penetrameter relative to source or film side is not restricted by the Code; and because no restrictions exist, a deviation is not possible.

As we do not feel a deviation exists, no corrective action has been offered.

m i

I

-- , - - -- - v- ,y

a

'* - . ~ Y h[ o.

EEExx 76011

' I

/ \p

$,}/\

i Pullman Kellogg ATTN: Mr. g. B. Curcio Connorcial Vice President Docket Number 99900077 14507 South Farsmount Boulevard Program N aber d4020 i Paramount, California 90723 Centlemen:

This refers to the QA program inspection conducted by Mr. E. W. Roberds l

of this office on August 23-26, 1976, of your facility at Paramount, California associated with the fabrication of nuclear piping and to the discussions of our findings with Mr. 5. W. Owen and members of your staff at the conclusion of the inspection.

Areas awa=4aad and our findings are discussed in the enclosed report.

Within these areas, the inspection consisted of an e===fantion of pro-cedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection it was found that the implementation of your QAThe program failed to meet certain commitments in your ASME QA Manual.

specific findings and references to the pertinent requirsmants

(" Summary are of Findings, identified in the attachment to this letter.Please provide us within paragraph " Deviations from Commitments.")

thirty (30) days a written statement containing (1) a description of any steps that have been or will be taken to correct these above iteam.

(2) a description of any steps that have been or will be taken to pre-vent recurrence, and (3) the date your corrective actions or preventive measures were or rill be completed.

In accordance with Section 2.790 of the Commission's " Rules of P Part 2. Title 10, Code of Federal Regulations, a copy of this letter and your reply, together with the enclosed inspection If thisreportreportwill be contains N placed in the Commission's Public Document Room.

l i

any information that you believe to be proprietary, it is necessary that you make a written application within 30 Any dayssuch to this office tomust application withhold such information fore public disclosure. '

include a full statyment of the reasons on the basis of which it is

• elaimed that the'information is.,-....proprietary, and. .should

,.....be prepared

-~~

.. - ...so~

~~

a;go y&f .NE7at!"

=w====** HVR s:mjg DMEunnicutt_. JEI111ou n> 09/15176 f8[_/I [~

l 9 v.s.eewsmaastet poisetsass errecss s.va.see see Form ABC-)IS (Rev.933) ABO 8s2 9

- mw ,

' ' m. .m

?

o Fullman Kellogg .

in a separate part of the docsment. If we do not haar from you in i this regard within the specified period, the report will be placed in the Public Document Room.

should you have any goestione concerning this inspection, we will be i pleased to discuss them with you.

Sincerely.

i i priginalSigned by:

M &Th ,

i J. 5. Tillou, chief '

i Vander Inspection Branch

Attachment:

Inspection Report Number 99900077/ W O2 bec:

l IE CHIEF, FC&EB i

IE CHIEF, C&ARPB IE REG. COORDINATOR f IE TILES Ng:DPM:QAB CENTRAL TILES W f PDR HQ REGIONAL DIRECTORS I, III, V

)- ASME

', 1 i'

e l

b 6 e" i

I i

e e

Rev. 5-75)

U. S. NUCLEAR REGUIATORY COMMISSION OFFICE OF INSPECTION & ENFORCEMENT REGION IV REPORI OF VIB INSPECTION Inspection 99900077/76-02 Docket No. 99900077 Report No.

Program No. 44020 Company Nace: Pullman Kellosa 14507 S. Paramount Boulevard Paramount, CA 90723 Address:

Type of Inspection: Routine Announced Date(s) of Inspection Aueust 23-26. 1976 Date(s) of February 2-5, 1976 Previous Insp.

)

Lead Inspector: ./[ /d Date f A*

H. W. Robards, Contractor Inspector, VI Branch Acco::rpanying Inspector (s): 3- Date r/)< /7d I. Barnes, Contractor Inspector, VI Branch J. P. Viola, GAO Auditor Date Observer:

'Date Date Date N

Reviewed By: ,7 w,s$ecM Date9//4/7[

• D. M.'Hunnicutt, Chief. ComponentsSection II, VI Br'ancti ..

• e

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

, --- - , . - - - - - - - - - , . - - - - . . . , - ,,,--------v--,-,-----

, - - . - . , _ --- n. . ---.-- - - , , - < - - --

w

SUMMARY

OF FINDINGS A. Deviations 7 ton Commitments

1. Contrary to Section 4 of the QA Manual, paragraph 4.1.1 Data Reports were not filed in the QA Department as required.

(DetailsSection I, paragraph 5.c.).

2. Contrary to Section 6 of the QA Manual, paragraph 6.1.1, a Level II individual was not re-annined and racertified every 36 months as required. (DetailsSection I, paragraph 7.c. (1)).

3. Contrary to Radiographic Procedure Specification No. JS-414, paragraph 18.3, and ASME Section V, paragraph T-272, a film i

side penetrameter was used on radiographs instead of a source side penetrameter as required. (DetailsSection I, paragraph 7.c.(2)).

4. Contrary to ASME Section III, paragraphs NB-2431 and NB-2431.1(c),

the current QA Manual does not require welding of test coupons to conform to the applicable Welding Procedure Specification l

I for production welding relative to preheat and interpass temperatures, for those welding materials to be used on F-1 l

base materials. (DetailsSection II, paragraph 4.c. (1)).

5. Contrary to the applicable welding procedure specification LA 14(A)-1-DWM-3-EH14, submerged are welding was observed being performed with a different type of wire to that specified.

(DetailsSection II, paragraph 4.c.(2)).

6. Contrary to ASME Section IX, paragraph QW-201.1, Welding Pro-cedure Specifications LA 14(A)-1-DWM-3-EH14 and LA 30(A)-8-K-1 (Details did not list all of the required nonessential variables.

Section II, paragraph 4.c.(3)).

7. Contrary to ASME Section III, paragraph NA-4531, measures were not established with respect to welding power source Number 520 to assure conformance of amperage output with (Details applicable welding procedure specification requirements.

j Section II, paragraph 4.c.(4)).

8. Contrary to Section 11 of the QA Manual, paragraph 11.2, non-

conforming materials were not sent to the hold area by the l Receiving Inspector.

(DetailsSection II, paragraph 5.c.).

9. Contrary to Section 2 of the QA Manual, paragraph 2.2, drawing revisions were not being referred back to the person or organi-~*

zation responsible for the stress report for reconciliation (

with the stress report.

~

1. 9 S .

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

- - - , . --.,....--.-.,-.--,-w. - - , - - - , , , . . - , _. - - , , , - , - - - . - - - - _.-m,, -- v-.---.y,-- , ,

.. g

2. Unresolved Matters This Inspection

. None.

E. ' Management Interviev A management interview was held on August 26, 1976, at the Pullman Kellogg facility in Paramount, California. The results of the inspection were discussed with the following management l

- representatives:

H. W. Owen, Assistant Plant Manager D. E. Cochrane, Quality Assurance Manager W. B. Pegram, Staff Engineer

1. Management was informed that implementation of their ASME accepted Quality Assurance Manual had been inspected in the fallowing areas:

(a) Manufacturing Process Control. (DetailsSection I, paragraph 5.).

(b) Nondestructive Examination. (DetailsSection I, para-graph 7.).

(c) Document and Drawing Control. (DetailsSection I, para-graph 6.).

(d) Design Control. (DetailsSection II, paragraph 6.).

- (a) Welding. (DetailsSection II, paragraph 4.).

(DetailsSection II, (f) Nonconformance/ Corrective Action.

paragraph 5.).

(g) Authorized Inspector. (DetailsSection II, paragraph 7.).

2. The eleven (11) deviations from commitments described in

~-

Section A above, were discussed with management representatives present.

~

3. The status of previously identified deviations, as described in Section B above, was discussed with management representatives .

present.

. ~

4. Management concents were generally reisted to clarification ~

i of the above subjects.

g.

.y -- - . . . w -. _ - . - _ _.--,,.rm,__,,._,._,--,_---_____,.__,_,__,._.___e-,_, , , _ , , , ,,,..--.c.,., ,._--3,7.,.,-.-,_,w-,, m-,.,.. ,.._,%-py,,.-

DETAILS SECTION I

- (Prepared by B. W. Roberds)

1. Additional Persons Contacted In addition to those persons listed in the management interview section of this report, the following persons were contacted:

Z. X. Corder, QC Supervisor

2. General This inspection was conducted to verify that the Pullman Kellogg Company, Paramount, California plant (PKCA), Quality Assurance Program as described in the ASME accepted Quality Assurance Manual is being implemented and gives reasonable assurance that parts and/or components manufactured under this program will comply with applicable codes and standards.

3. Vendors Action on Previously Identified Deviations

References:

IE Report Number 99900077/76-01 and PKCA's respense letter dated March 4, 1976.

a. Inspection Objectives The objective of this inspection was to verify that PKCA had initiated the corrective actions identified in the response letter to the Nuclear Regulatory Commission, dated March 4, 1976.

b. Inspection Objective Accomplished by:

(1) Review of Report Number 99900077/76-01.

(2) Review of PKCA's response letter dated March 4, 1976.

c. Inspection Findings

- (1) Report Number 99900077/76-01, Item 2, of attached enclosure.

It was verified that PKCA had implemented the corrective .

action identified in their response letter dated March 4, '

1976. This item is closed.

- ---,.w -,.-------i-* -

,a-- -- ---m-----++y----> w w--- eve----w-r----m --- -m e m ew gsq

\ '

l 5-(2) Report Number 99900077/76-01. Item 1 of attached enclosure.

- It was verified that distributed books of fabrication specifications did not contain voided fabrication speci-fications. This item is closed.

4. Status of Previously Reported Unresolved Matters. IE Report

. Section II, paragraph 2.c.(2) and paranraph

> Number 99900077/76-01.

3.c.(2).

a. Inspection Objective The objective of this inspection was to verify that PKCA plant had provided corrective action for unresolved matter identified during the prior inspection.

b. Inspection Objective Accomplished bv:

(1) Review of training records.

(2) Review of calibration status cards.

c. Inspection Findings (1) Item 2.c.(2), Training of Personnel. It was verified that PKCA now maintains records of training subject matter and personnel attendance. This item is resolved.

Item 3.c.(2), Calibration Status Card. It was verified l

I (2)

! that the calibration status card for the tong tester had been corrected so that the serial number on the card corresponded with the tong tester. This item is resolved.

5. Manuf acturing Process Control

a. Inspection Objective The objective of this inspection was to verify that PKCA had implemented the control of manufacturing processes as delineated in Section 4 of the Quality Assurance Manual.

b. Inspection Objective Accomplished by:

(1) Review of Section 4 of the QA Manual.

(2) Selective review of Process Sheets at various work locatio

- - , - . - - . -. .m_v,.,, ,,.m. _...,,,.m._. _.._..._,m., .--.....,,,..y-.___,__.-,-,....r-.,__...r - ---

(3) Observations of work in progress.

c .. Inspection Findings i

Within the scope of this inspection, the following deviation from commitments was identified and discussed with management.

"The

' Section 4 of the QA Manual, paragraph 4.1.1 states in part, Engineering Department prepares and signs the ASME Data Report and forwards it with the traveler package to the QA Department where it is filed until final inspection."

Contrary to the above, the Data Reports were not filed in the QA Department for Job Number 2730, Sheet Numbers F-67, F-70, F-184, and F-204, and final inspection had not been performed.

6. Document and Drawing Control

a. Inspection Objective The objective of this inspection was to verify that FKCA had implemented the control of documents and drawings as delineated in Section 2 of the Quality Assurance Manual,

b. Inspection Objective Accomplished by:

(1) Review of Section 2 of the QA Manual.

(2) Review of Procedure Specifications at various work locations.

(3) Review of 25 traveler packages.

c. Inspection Findings There were no deviations from commitments identified within the scope of this inspection.

7. Nondestructive Examination (Radiography, Liquid Penetrant and Magnetic Particle)

a. Inspection Objective The objective of this inspection was to verify that PKCA had '

implemented the controls of nondestructive examination as delineated in Section 6 of the Quality Assurance Manual. .

. e

- ,,-,-m,m-,,-- - - - - - - -

i

b. Inspection Objective Acconolished by:

(1) Review of Section 6 of the QA Manual.

(2) Review of specification Number JS-404 of August 8, 1975 Revision 1.

~

(3) Review of specification Number JS-405 of August 8, 1975, Revision 1.

(4) Review of specification Number JS-414.

(5) Review of personnel certification records.

c. Inspection Findings Within the scope of this inspection the following two deviations from commitments were identified and discussed with management:

(1) Section 6 of the QA Manual, paragraph 6.1.1 states in '

part, "Each Laval I and II individual must be re-examined and recertified every 36 months."

Contrary to the above, of the three NDE personnel certi-fication records examined, a Level II individual was 14 days past the 36 months recertification date of August 9, 1976.

(2) Radiographic procedura, specification Number JS-414, paragraph 18.3 states in part, "The penetrameter shall be placed on the source side or film side of the object being radiographed."

ASME Section V, paragraph T-272 states in part, "If the l

radiation passes through one wall and inaccessibility Prevents source side placement, a film side penetrameter may be usea from T-261."

Contrary to the above, although veld joints were accessible for placement of a source side pentrameters, a film side penetrameter was used on radiographs for Job Number 2730, Sheet Number F-343, Wald A, and Job Number 2730 Sheet 1

Number F-87. .

e e

met

--,w----.-- - - , . - , .m._,.,-.,-,---,..,,---,--------,,,,e,e. - - - -. , . , - , _ , . , . ~ , . _-- , . - . . , . - , , , _ - - . , _ - , , - , , , - - . - - . , , - - , - --,-,-,.-e.. -.--n

1 DETATLt SECTION II (Prepared by 1. Barnes)

. 1. Additional Persons Contacted i

A. Barnes, Welding Foreman

- Z. X. Corder QC Supervisor R. C. Gilliam, Rod Room Clark i

J. Guyler, Pressure Vessel Safety Engineer, State of California, Division of Industrial Safety J. A. Svacson, Manager, Engineering J. C. Watkins, General Foreman

2. Vendors Action on Previculsy Identified Deviations

References:

IE Report Number 99900077/76-01 and Pullman Kellogg Company, Paramount plant (PKCA) response letter dated March 4,1976.

a. Inspection Objective ,

The objective of this inspection was to verify that PKCA had initiated the corrective actions identified in the response letter to the Nuclear Regulatory Commission, dated March 4, 1976.

I b. Inspection Objective Accomplished by:

(1) Review of IE Report Number 99900077/76-01 and PKCA response letter dated March 4, 1976.

(2) Review of QA Manual, Section 5, " Welding Quality Assurance,"

dated July 15, 1976.

(3) Review of welder audit files.

c. Inspection Findings

! Report Number 99900077/76-01, Enclosure Item 3.

V- IE was verified that PKCA had initiated the corrective action identified in their response letter dated March 4, 1976. This ,

item is closed. .

f i

I -. - - . - - , - - - - . _ . - - _ - - . - - , - - - , , , ~ - .-

-.--m-- - _ _ . , . - _ _ - , . - _ . - , , - . , - , , - - , , . , , , , , ---c- - - .y,-.._-- - - ..__m --_

, - - , - . , .- -,.--,,mm ,y,-,--- ,.c7---

4 9-

3. Status of Previously Reported Unresolved Items (IE Report Musbar 99900077/76-01, DetailsSection I, paragraphs 4.c.(1) and 5.c.(1).

a. Inspection Objective The objective of this inspection was to reinspect and report the status of those arass previously identified as an unresolved

. item.

)

b. Inspection Objective Accomplished by:

(1) Review of paragraphs 4.c.(1) and 5.c.(1) in IE Report Number 99900077/76-01.

(2) Review of QA Manual Revision 2 dated July 15, 1976.

(3) Review of " Documented Telecon Confirmation Sheets," for Job Numbers 2730, 2735, 2740 and 2745.

(4) Interviews with cognizant technical and management personnel.

c. Inspection Findings (1) IE Report Number 99900077/76-01. DetailsSection I, paragraph 4.c. (1) .

Paragraph NA-4132 of ASME Section III, 1974 Edition, states in part, "The Program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained . . . ."

Contrary to the above, the current QA Manual does not provide for indoctrination and training of personnel performing activities affecting quality (other than those personnel required by ASME to have sandatory qualifications).

This previously reported unresolved item has been determined to be a deviation from commitment. Furthermore, this deviation is cited as only one example of QA Manual l

deficiency relative to upgrading of program requirements

' with respect to current contracts and applicable code and addenda. .

1 l

- 10-(2) IE Report Number 99900077/7fr-01. DetailsSection I, parmaraoh 5.c. (1) .

Review of " Documented Telecon Confirmation Sheets" for Job Mumbers 2730, 2735, 2740 and 2745, showed that the customer resolution part was now complete.

This item is considered closed.

4. Welding

a. Inspection Obiective The objective of this inspection was to verify that PKCA had implemented the system for control of welding as defined in Section 5 of the ASME accepted QA Manual.

b. Inspection Objective Accomplished by:

(1) Review of QA Manual, Section 5, dated July 15, 1976,

" Welding Quality Assurance."

(2) Examination of travelers and observation of welding cperations on selected assemblies from Job Numbers 2730 and 2735.

(3) Review of welding procedure specifications LA14(A)-1-DWM-3-EH14 and LA30(A)-8-K-1, which were used for welding operations witnessed on referenced job numbers.

(4) Examination of supporting procedure qualification records for referenced welding procedure specifications.

(5) Review of qualifications for welders used on assemblies from referenced contract numbers and tracking system used for verification of qualification status.

(6) Review of consumables certification data for selected

.* welding materials from the approved welding materials list.

(7) Observation of temperature control and electrode segregation in distribution ovens.

(8) Review of welding materials approval and release system. ,

(9) Examination of calibration status of welding equipment in production use.

l i

I

,,....,_...,n,. -,.n,.,,- ,--.,-,, - , _ , , - . , - , . . , , - . , , , . , , -...n.,,,., , y,---., ,,, . ,, , ,, - , -- .,, -, ---.

.. n.,n_.,-.-- - . , . . - - , _ , , _ , . - . .

(10) Review of " Supplement 'A' to Procedurc 421 for the Calibration of Welding h ehines," dated July 25, 1975.

c. Inspection Findings Within the scope of this inspection, the following four (4)

. deviations from connaitment were identified and discussed with management:

. (1) ASME Section III, paragraph NB-2431 states in part, " Tensile and impact tests shall be made in accordance with this paragraph, of welding materials which are used to join P-number 1,3,4,5,6,7,9, and 11 base materials in any combination . . . ."

ASME Section III, paragraph NB-2431.l(c) states in part with respect to the General Test Requirements for welding materials, "The welding of the test couron shall conform to the applicable Welding Procedure Specification (WPS) for production welding relative to preheat and interpass temperatures . . . ."

Contrary to the above, the current QA h nual, paragraph 5.1.1, dated July 15, 1976, requires only that velding materials to be used on P-number 3,4,5,6, 11 and 12 base materials be qualified with applicable welding procedures and does not require those welding materials to be used on P-1 base materials to be so qualified.

The inspector was informed by the QA k nager that this was an oversight that occurred during preparation of the current QA h aual. The present wording reflects the 1971 Edition of ASME Section III, which does exclude welding materials to be used on P-1 base materials from the qualification requirements concerning use of preheat and interpass temperatures of the applicable welding procedure specification.

(2) The traveler for Piece h rk 2-SC-002-4, Job Number 2735,

referenced LA14(A)-1-DkH-3-EH14 as the applicable welding procedure specification (WPS) for veld "A".

Sheet 3 of WPS LA14(A)-1-DWM-3-EH14 requires AWS Class EH14

' vire to be used with the submerged are process. ,

Contrary to the above, the inspector observed Ak'S Class Df12K wire being used in weld "A".

,-e,-- .,e m .-,--,,,,,,_,_e----- ,,_,.,,---,-a--_---__,,,,n,,,,,,m

.----ma .. ., , , - - ,,-e - - - - --r--- - - -

.: ~.

)

(3) ASME Section II, paragraph QW-201.1 states in part, "The welding procedure specification (WPS) shall list in detail . . . variables described for each welding process as either assential or nonessential."

Contrary to the above requirement:

(a) WPS LA14(A)-1-DWM-3-ER14 did not reference size of flux particles, and contact tube to work distance; both of which are defined by the 1974 Edition of ASME Section II as nonessential variables for the submerged are process.

(b) WPS LA30(A)-8-K-1 did not reference orifice or cup size, which is defined by the 1974 Edition of ASME Section IX as a nonessential variable for the gas tungsten are process.

(4) Paragraph NA-4531 of ASME Section III states in part,

" Measures shall be established and documented to assure that . . .

devices used in activities affecting quality are of the proper range, type and accuracy to verify conformance to established requirements . . . ."

' Centrary to the above, measures were not established with respect to welding power source, Identity Number 520, which would provide assurance of conformance of amperage output

' with the requirements of applicable welding procedure specifications as evidenced by:

(a) No method or ==ans of correlating dial setting with f amperage output was made available to the inspector.

(b) No operating guidelines were at the work station to instruct velding personnel on how to set the power source to obtain a specified amparage value.

- 5. Nonconformance and Corrective Action

a. Inspection Obiective The objective of this inspection was to verify that PKCA had implemented the system for control of nonconformances as defined in Section 11 of the ASME accepted QA Manual. ,

e e

~ _ _ _ _ _ _ _ _ _ _ _ _ , _ -,._-,...w.__.

. _,.__m -.4 __,,.,..,4,3--w..-_.,.,,,w__. -

-_r,, - , _ - , -wm., _ . _ , _ ,,,,, _ ___.,pc r,_%. . , ,,_ ,_

b. Inspection Objective Accomplished by:

(1) Review of QA Manual, Section 11, dated July 15, 1976, "Nonconformities and Corrective Action."

(2) Examination of Defective Material Report files.

(3) Observation of QC hold area.

~

(4) Interviews with cognizant management personnel.

c. Inspection Findings Within the scope of this inspection the following deviation from commitment was identified and discussed with managemenc:

Section 11 of the QA Manual, paragraph 11.2 states in part,

" . . . At receiving inspection, nonconforming materials are sent to the hold area by the Receiving Inspector, and he initiates a Defective Material Report . .."

Contrary to the above, materials identified in Defective Material Report Numbers 4184, 4188, 4189, 4190, 4193 and 4194 had not been sent to the hold area.

6. Design Control

a. Inspection Objective The objectives of this inspection were to ascertain whether measures had been implemented that provide for:

(1) Assurance that applicable requirements of the design specifications are correctly translated into drawings, specifications, procedures and instructions.

(2) The review, approval, release and distribution of drawings, specifications, calculations, stress reports and revisions thereto.

l (3) Distribution and use of documents and drawings, including changes, at the location where the prescribed activity is performed. .

1 i

i

_ _ - _ . _ . _ _-.___._,m. ,_.__,...._..._..._.m..._,,.,,___._..._____...._.~,______m.. , . - _ . . , . - _ _ _ _ . _ _ - _ _ . . . . _ . .

~

. , . j l

i 14-(4) The documents and drawings, including changes, used for manufacturing, er==4 nation and testing are the latest applicable edition required by Design Specifications.

i

b. Inspection Objective Accomplished by:

(1) Review of QA Manual Section 2, dated July 15, 1976,

" Drawing and Specification Control."

(2) Review of Engineering Specification Number S023-409-1, l- Revision 2, dated April 21, 1976.

i (3) Selective review of shop drawing revision control.

l (4) Review of customer interface and approval controls.

(5) Review of Engineering system for control of drawings and specification revisions.

(6) Interviews with cognizant management personnel.

f 1

[

c. Inspection Findings i Within the scope of this inspection, the following two (2) l deviations from commitment were identified and discussed with management:

(1) Paragraph 2.2 in Section 2 of the QA Manual, dated July 15, 1976, states in part, " . . . When a drawing revision is initiated by Pullman Kellogg Engineering, this revision is referred back to the person or organization responsible for the stress "

report for reconciliation with the stress report . . . .

Contrary to the above, drawing revisions were not being referred back to the person or organization responsible for the stress report for reconciliation with the stress report.

(2) Paragraph 2.3 in Section 2 of the QA Manual, dated July 15, 1976 states in part with respect to control of specification and standard revisions, " . . . A runner from Engineering makes distribution as outlined on the Transmittal Record to each department and picks up the earlier revisions and destroys them . . . ." .

1

- e-n.-,-- ,,.- - _ - , - - - , -y -

.__,,-_,,---,...--~_.,,_,w_..__,._,___,m__.,_... . , , . . , , __m - , . ....w ,.,,.,..,_e___ _ ,- --,,w--_- - - - -

Contrary to the above requirements, Engineering was not picking up earlier revisions of specifications and destroying them.

7. Authorized Inspector (AI)

a. Insspection Obiective The objective of this inspection was to verify that: (1) the AI activities included established verification points for fabrication processes, (2) these activities were being docu-mented, and (3) the AI was auditing implementation of the QA Manual.

b. Inspection Objective Accomplished by:

(1) Review of Section 10 of the QA Manual, dated July 15, 1976,

" Authorized Inspector."

(2) Examination of process sheets.

(3) Interview of the AI.

c. Inspectier. Findings The AT. is certified as a Nuclear Authorized Inspector and serves the PKCA facility on an itinerant basis. The AI is performing the first two items identified in the inspection cbjective, but to date has not completed any audits relative to implementation of the QA Manual.

l l

l e

i

(

l f  ;

1 i

l March 23, 1976 1

Pullman Kellogg Company

. Attn: Mr. E. B. Curcio Commercial Vice President 14507 S. Paramount Boulevard Paramount, California 90723 Docket No. 99900077 Gentleman: Frogram No. 44020 Thank you for your letter of March 4, 1976, in response to our letter dated February 17, 1976, with an enclosure. We have no further questions .t this time. We will review your corrective action during a future inspection.

Sincerely,

/

Stiginel signed by I

B.L WhileseE J. B. Tillou, inf Vendor Inspection Branch

_bscY &

d

~ - ~ ~ ~

PDR HQ n =.

, q4'~0 0 l

g '

end I eg ( -

$roli.ER/ng [aWhitesell ou

. 3/23/76 3/23/76 3/23/76 Veber 3/ /76

Pullm:n ICliogg owen m on w THE 31.W. KELLOG

. ....sie G COMPANY se P U LL M A N INCO RPOR ATED POWER PlPING isso? soutw panamoWNT SouLEvaRD ,,,,,,,,

EUGENE B. CU A010 panamou=T. caLironssia o07:2 wittiams soev. ..

C;m = Esc.a. v : E ** El O th* NOWS 10m.TEmas 3*D pamaucumi. CaLIFOenia T E . E *= C 'e t 2'3 $ 3' March 4, 1976

~

United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 Attention: Mr. J. H. Tillou, Chief Vendor Inspection Branch Subj ect : Docket No. 99900077 Gentlemen:

In response to the findings listed in the enclosure to your letter of February 17, 1976, we offer the following statements.

ENCLOSURE ITEM 1 Voided fabrication specifications not removed from Superintendent's book of Fabrication Specifications.

Corrective Action The Pullman Kellogg Engineering Department will recall all job specifications and remove all outdated copies. This action will be completed on or before March 15, 1976.

Action To Prevent Recurrence 1

The Pullman Kellogg Engineering Department will reissue job specifications include a in a f:. Each book will be assigned a control number and will j book form.

" Record of Revisions" sheet listing all of the job specifications.

All future 1

revisions to job specifications will be issued by written transmittal, which This will require acknowledgement of receipt and return of the voided pages.

action will be completed on or before March 15, 1976.

l ENCLOSURE ITEM 2 l

L (A) No record of calibration of densitometer.

l l

l I

l l

l - - . -

n i cii ,, 2,w Unitsd Statss Nucle Rigulatory crmmissicn Mr . J . .. Tillcu P;ga Two Attcntion:

THE M.W. KELLOGG COMPANY

. .. . . .... .. P u t t m a n incoaroRaTro PIPluG FABRICATION Corrective Action The Pullman Kellogg Quality Assurance Department will establish a card in the calibration file for the densitometer. The card will reference a log book which will be used to record densitometer calibration. This action will be completed on or before March 15, 1976.

Action To Prevent Recurrence The Pullman Kellogg Inspection Department will be instructed to record densitometer in the log book in accordance with the calibration procedures. This action will be completed on or before March 15, 1976.

(B) Density strip not traceable to the National Bureau of Standards.

Corrective Action The Pullman Kellogg Quality Assurance Department will procure a density strip traceable to the National Bureau of Standards for use in calibrating our densito-meter. This action will be completed on or before April 1, 1976.

ENCLOSURE ITEM 3 No documented follow-up action of welders' audits.

Corrective Action The Pullman Kellogg Welder Auditors will review all welders' audits and complete the documentation of all follow-up action as necessary to comply with the Quality Assurance Manual. This action will be completed on or before March 22, 1976.

Action To Prevent Recurrence

(

The Pullman Kellogg Quality Assurance Manager will review with the Auditors the

( procedures to be followed regarding welders' audits with special emphasis on documenting follow-up action on discrepancies identified during previous audits.

This action will be completed on or before March 12, 1976.

- If you should have any questions, please do not hesitate to contact us.

Very truly yours, i

PULLMAN KELLOGG l

. 8. Curcio EBC/sw l

cc: D.E. Cochrane, Q.A. Manager E.F. Gerwin, Chief Engineer

O: v .' _

n g

.5 M%1 L Pullman Kellogg Company ATTN Mr. E. 3. Curcio

- Commercial Vice President 14507 South Farsmount Boulevard

• Faramount, California 90723

. Docket Number 99900077 Gentlemen .

Program Number 44020 This refers to the @ program inspection conducted by Mr. 1. E. Oller of this office on February 2-5, 1975, of your facility at Paramount, California, associated with the fabrication of piping subassemblies and to the discussions of our findings with Mr. E. 5. Curcio and members of your staff at the conclusion of the inspection. ,,

Areas examined and our findings are discussed in the enclosed report.

Within these areas, the inspection consisted of an examination of pro-cedures and representative records, interviews with personnel, and observations by the inspector.

During the inspection it was found that the implementation of your QA program failed to meet certain connaitments in your AgME QA Manual.

The specific findings and references to the pertinent requirements are identified in the enclosure to this letter.

Flesse provide us within thirty (30) days a written statement containing.

(1) a dsscription of any steps that have been or will be taken to correct these items. (2) a description of any steps that have been or will be i

taken to prevent recurrence, and (3) the date your corrective actions or l preventive measures were or will be completed.

l In accordance with Section 2.790 of the &==4ssion's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and l

your reply, together with the enclosed inspection report will be placed in the Commission's Publia Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 30 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part

. of the document.

~

IE:IV jf!! d5N-  %

RE0Her:mg WEWhitesen RrInlou 2/ /76 WEVet e 2/ /76 lQ )7b/

2/11/76 2/ /76 f

I i -

,J s

.~ -.

i Pullman Ea11ogg Company  !

If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.

Should you have any questions conearning this inspection, we will be pleased to discuss them with you.

~~ Sincerely.

Wnal Siped bys

. i s A&THiou, J. E. Tillou, Chief 7endor Inspection Branch Attachsenta:

1. Enclosure

2. Inspection 1* Port Number 99900077/76-01 bec:

IE CHIEF, FS&EB IE CHIEF, APD \

\

IE REG. COORD DRL (2) VOLIMER, R. ,

IE FILES CEhTRAL FILES PDR HQ c

l ALL REGIONAL DIRECTORS '-

i e

e t

I k

. , , - - - - - - , - - . .- - - - , - , , w y - - - -, - - -,-.- - - , - - - - - ---3--. , ------c-- - ,- -. - - - - ,,.-,.,--,,..-,,---------+,y--,-

susu a s

.. h (REV. 5-75)

U. S. NUCLEAR REGULATORY C01D11SSION OFFICE OF INSPECTION & ENFORCDENT REGION IV REPORT OF VIB INSPECTION ,

~

Inspection 99900077 99900077/76-01 Docket No.

Report No.

Prograza No. 44020

- Company Nace: Pullman Kellogg Company (Formerly M. W. Kellogg Company)

Address: 14507 S. Paramount Blvd.

Paramount, California 90723 Type of Inspection: Routine Announced Date(s) of February 2-5, 1976 Inspection Date(s) of February 24-26, 1975 Previous Insp.

Lead Inspector:

Date: P!8 7g R. E. Oiler, Contractor Inspector, Vendor Inspection Branch Acco=panying Date:

' ~ ~

Inspector (s). -

H. M. Wescott, Contractor Inspector, Vendor Inspection Branch Date:

Date:

Date:

l.

Date:

t + Date:

Reviewed By: ~

D. E. Whitesell, ief, Component I Section, VI Branch w-, - - - - -- - -

,-,,,q - - , - - , - - , -

, ---,,en--

ENCLOSURE Pulla.a Kellogg Company Docket Number 99900077 Certain of the activities at the Pullman Kallogg, Paramount, California, plant appears to deviate from commitments in the ASME accepted QA Manual.

1. The QA Manual Section 2, paragraph 2.3, " Control of Specifi-cations and Standard Revisions" states, "A runner from Engineer-ing makes distribution as outlined on the Transmittal Record

, to each department and picks up the earlier revisions and destroys them."

Contrary to the above, certain superceded fabrication specifi-cations marked " Voided" were not removed from the work area superintendent's book of Fabrication Specifications.

2. The QA Manual Section 7, titled " Qualification of Gauges and Measuring Equipment," date issued January 28, 1974, the opening paragraph states that "It is the responsibility of the QA Department to assure proper calibration and maintain calibration records of all measuring and test equipment." Paragraph 7.1 further states that "All items are recalled to established schedules with standards traceable to the National Bureau of Standards."

J Contrary to the above, the densitometer (Serial Number 2041C) did not have any record of calibration and there was no documentation provided to establish traceability of the cali-brated film density step strip to the National Bureau of Standards.

3. The QA Manual Section 12, titled " Audits," date issued January 28, 1974, paragraph 12.1.4 states that " Discrepancies noted during previous audits are reviewed for close out during subsequent audits. If adequate corrective action is not apparent, the information is noted and sent to the Plant Manager and QA Manager."

Contrary to the above, there was no documented followup action on a discrepancy identified in " Weld Audit Form" report.

,---4-. -,.m_- - - , , , - - . - - - , , , . , . , - . . - , , , , , - - -

,a

SUMMARY

OF FINDINGS A. Deviations From Commitments

1. Contrary to the ASME accepted QA Manual (QAM) Section 2, para-graph 2.3, superceded fabrication specifications marked " Voided" were not removed from the work area superintendent's book of Fabrication Specifications. (DetailsSection I, paragraph 6.c.(1))

2. Contrary to the QAM, Section 7, opening paragraph, and paragraph 7.1, the film density calibration step strip could not be traced

'- to the National Bureau of Standards and calibration of the densitometer could not be verified. (DetailsSection II, para-graph 3.c. (1))

3. Contrary to the QAM, Section 12, paragraph 12.1.4, there was no documented followup action on a discrepancy identified in

" Weld Audit Form" report. (DetailsSection II, paragraph 4.c.(1)

B. Vendor Action on Previously Identified Enforcement Matters

1. IE Report Number 9990077/75-01, DetailsSection I, paragraph 3.b.(2) and 4.b.

a. Item, Stored Material Accept Tags.

I This item is closed. (DetailsSection I, paragraph 3.c.(1)

b. Item. Welding Machines.

This item is closed. (Details Section 1, paragraph 3.c.(2))

C. Status of Previously Reported Unresolved Matters I

i 1. IE Report Number 99900077/75-01. Details, paragraphs 3.b. (1) and 3.b.(3).

a. Item QA Manual.

l This item remsins unresolved. (DetailsSection I, para-

'- graph 4.c. (1))

b. Item, Indoctrination and Training Procedure This item is closed. (DetailsSection I, paragraph 4.c.(2))

_ .. - . . - . _ . , _ . _ _y.__ , , , , , , , , , , . _ _ _ , , , . , . - - . _ . _ _ _ _ _ . _ _ . _ _ _ - . _ , _ . , _ . _ _ , _ , , , , , - ._,,.c,_.,_,--y- . _-,_..,_m._, m. ,,_,_,_._ _,___ _ _ .._ _.,__ ,__,-

D. Other Significant Findings 1.. Current Findings None.

2. Unresolved Matters This Inspection

a. Two unresolved matters identified in DetailsSection I, paragraph 4.c. (1) and 5.c. (1) .

E. Management Interview A post inspection conference was held on February 5, 1976, with the following persons:

Pullman Kellogg Company (PKC) . (formerly M. W. Kellcar Company)

E. B. Curcio Commercial Vice President D. E. Cochrane Quality Assurance Manager The following items were discussed, and are identified in the Details Sections as follows:

1. The two deviations and one of the two unresolved matters identified during the previous NRC inspection are considered closed. (DetailsSection I, paragraphs 3 and 4)

2. One unresolved matter from the previous NRC inspection, dealing with the lack of requirements in the QA Manual for semiannual review of Code Addenda and updating of the QA Manual, where applicable, is still unresolved.

The plant management said they are waiting for a comment on this matter from PKC QA Central Staff. (DetailsSection I, paragraph 4.c. (1)

3. Certain superceded fabrication specifications marked Voided" were in the shop superintendent's Book of Fabrication Specifi-cations for Job Numbers 2730, 2735, 2740 and 2745. This con-I ., dition is contrary to the commitment in the QA Manual Section 2, paragraph 2.3 and is considered a deviation.

The plant management acknowledged this condition. (Details ,

Section I, paragraph 6.c. (1) .

4

, , - - - - n w. .--or---v,r- - - - - - -

,-,,v----,-,,---,------,,,,,~,w.---- e,_ g-., _w._-w,,,-,.,a,ew,me--ww-,,,e,---~~.--,--,--,,w-~4 ,em- , - , , , , -+ , -,-,e -

^ .

4. In the area of PKC comments on customer drawings, the

" Documented Telecon Confirmation Sheets" for Job Numbers 2730, 2735, 2740, and 2745, were incomplete for the customer resolution

~

part. This matter is considered unresolved and will be reviewed during a subsequent NRC inspection.

The plant management indicated they will get the customer's response. (DetailsSection I, paragraph 5.c.(1))

5. Contrary to the QAM Section 7, opening paragraph, and paragraph 7.1, the film density calibration step strip could not be traced to the National Bureau of Standards and calibration of the densi-tometer could not be verified. (Detai% Section II, paragraph 3.c.(1))

6. Contrary to the QAM Section 12, paragraph 12.1.4, there was no documented followup action on a discrepancy identified on a " Weld Audit Form" report. (DetailsSection II, paragraph 4.c.(1))

l l

- y - . - -.- - - , , - - - -- . , _ _ _ _ _ - . , . - , . _ _ . , - . - _ , _ _ _ . - . _ _,,m. ,--- __- .--.. . -

1. 'O DETAILS SECTION I (Prepared by R. E. Oiler)

1. Additional Persons Contacted J. C. Watkins Shop Foreman J. A. Swanson Engineering Production Manager J. E. Warren Authorized Inspector

2. General

a. This inspection was conducted to verify that the Pullman Kellogg Company (PKC) Paramount plant nuclear piping fabri-cation operations were being conducted in accordance with the requirements of their ASME accepted QA program and detailed procedures.

3. Corrective Action On Outstanding Items. Deviations From Commitments, IE Report Number 99900077/75-01. DetailsSection I paragraph 3.b.(2) and 4.b.

a. Inspection Objectives The purpose of this inspection was to ascertain whether the PKC plant had implemented corrective action concerning previously identified enforcement matters, in accordance with its commitments as established in its letter dated May 13, 1975, in response to the NRC letter and enclosure dated April 11, 1975.

b. Objectives Were Accomplished by:

(1) Review of the QA Manual issued January 28, 1974.

(2) Review of records and procedures updated and/or generated subsequent to the NRC inspection in February 1975.

(3) Inshop observation of calibration stickers on welding

- machines and review of selected calibration record cards.

(4) Examination of completed " accept" tags on piping and fittings in the storage yard.

~

(5) Discussions with cognizant personnel. f

!t I

l

.m

c. Findings (1) Item 3.b. (2), " Accept Tags" On Material In Storage Not Filled Out Examination of nuclear class piping spools and fittings

' in the storage yard established that the green " Accept Tags" on this QA cleared material were now completed by the QA inspector. Discussions with the QA inspector established that he had been verbally instructed to put the required information on the tags.

This item is closed.

(2) Item 4.b., Welding Machines Not Calibrated Examination of the welding machines in the shop and the related calibration record cards established that the machines are now calibrated and have appropriate cali-bration tags which are traceable to the records.

4. Status of Previously Reported Unresolved Matters, IE Report Number 99900077/75-01, DetailsSection I, paragraphs 3.b.(1) and 3.b.(3).

a. Inspection Objectives The purpose of this inspection was to verify that the PKC plant had provided corrective action for unresolved matters identified during the prior NRC inspection.

b. Objectives Vere Accomplished by:

(1) Review of the QA Manual issued January 28, 1974.

(2) Review of records and a procedure generated subsequent to the NRC inspection in February 1975.

(3) Discussions with cognizant personnel.

c. Findings (1) Item 3.b. (1), No QA Requirements For Semiannual Review Of Code Addenda And Updating Of The Manual

' Review of the QA Manual established that the subject -

requirement had not been added. The plant management indicated they are waiting for comments from the PKC I

.w s,

QA Central Staff before they take action on this matter.

. This item remains open.

(2) Item 3.b. (3). No Written Procedure For Indoctrination And Training Of Audit Personnel Review established that procedure Number II-1, "Qualifi-cation Of Quality Assurance Program Audit Personnel "

revised January 1, 1976, was issued subsequent to the NRC inspection in February 1975. The PKC management said that training sessions for audit personnel were held but no records of subject matter or attendance were kept.

This item is considered closed.

5. Design Control j

a. Inspection Objectives l

The purpose of this inspection was to verify that the QA pro-gram had been implemented to provide for the assurance that:

(1) Quality Assurance management actively participated in design activities in a manner that provided independence and freedom from design production.

(2) The QA personnel performing QA design activities were identified, and their duties, responsibilities and authorities were clearly delineated in writing.

(3) The applicable requirements of the customer's design specifications are correctly translated into drawings, specifications, procedures and drawings.

r l

(4) The customer's design specifications and drawings are lt' prepared and certified by a registered professinnal engineer.

'i

!! - (5) The review of the stress reports and overall designs are made to verify compliance with Code and customer i

requirements.

i (6) The review, approval, release and distribution of drawings, specifications and revisions thereto are perform'ed.

s (7) The latest applicable drawings, specifications and instructions required by the design specification and

- authorized changes thereto are used for fabrication, examination and tests,

b. Objectives Were Accomplished by:

(1) Review of the QA Manual, Section 2, " Drawing And Speci-fication Control," applicable to the Engineering Department design activities.

(2) Review of a specified customer's design specification Number S023-409-1, (covering MWK Job Numbers 2730, 2735, 2740 and 2745), including Addendum 2 dated May 13, 1975, and related correspondence for certification of 'the :

specification to the ASME Code Section Ill by the customer.

(3) Review of M. W. Kellogg (now PKC) letter record of reviev, dated November 27, 1975, of the above customer design specification.

(4) Review of MWK material review record of customer drawings for the above work.

(5) Review of MWK " Customer Drawing Record Release For Construction."

(6) Review of MWK " Documented Telecon Confirmation Sheets" related to MWK verbal drawing comments on the customer's drawings for Job Numbers 2730, 2735, 2740 and 2745.

(7) Review of customer release record " Shop Fabrication Spool Release Sheet" for materials identified on Drawing 40360.

(8) Review of the following MWK shop detail sketches for Job Number 2735:

(a) Number F-24, Revision 1, Piece Number ACH-070-004.

(b) Number F-8, Revision 1, Piece Number 3-CC-246-002.

(c) Number F-22, Revision 2, Piece Number 2-FS-019-2. .

(d) Number F-21, Revision 2, Piece Number 2-FS-019-1.

k 1 .

~,

(9) Review of MWK " Piping Release And Transmittal Record,"

dated January 7, 1976, for shipment related to the above Job Number 2735 subassemblies.

(10) Reviewed customer records of drawing changes reconciliation j

to stress report " Drawing Change Notice " dated January 12, 1976, for Drawing Number 41417, Revision 1. )

(11) Reviewed the following MWK specifications, prepared by Engineering and approved by QA for Job Numbers 2730, 2735, 2740 and 2745.

(a) Number JS-150, " Cleaning And Preparatioa For Shipment."

(b) Number JS-151, " Standard Marking. . . "

(c) Number JS-152, " Internal Cleaning And Preparation."

(d) Number JS-304, " Repair Of Weld Metal Defects."

(e) Number JS-205, (1971), " Impact Testing."

(f) Number JS-403, " Ultrasonic Thickness Measurement Procedure."

(g) Number JS-500, " Bending Carbon Steel Pipe."

c. Findings (1) Discussion with the Engineering representative established that MWK drawing review comments on customer drawings had been verbal, but were now being documented on records l called " Documented Telecon Confirmation Sheets," with provisions for written customer resolution. Review of I

several of these records for Shop orders 2730, 2735, 2740 and 2745, established that the customer resolution part was not completed. The MWK representative said he expected to receive the customer's written resolution

'- within a few days.

This matter considered unresolved.

(2) There were no deviations from commitments identified.

-- -- . - . _ _ _ _ _ _ - - _ _ "-"'NT"-- --- - - - -m_w- , _,, _

. 3,

- 9-

6. Document Control a ., Objective The purpose of this inspection was to verify that measures have been implemented to:

s (1) Control the issuance of documents, such as purchase specifications, instructions, procedures, and drawings.

including changes thereto, that prescribe the activities affecting quality.

(2) Assure that documents, including changes thereto are reviewed for adequacy and released by authorized personnel and are distributed to and used at the location where the prescribed activity is performed.

(3) Assure that the latest applicable drawings, specifications, and instructions required by the Design Specifications, the Code, and authorized changes, are used for manufacturing, examination, and testing.

b. Objectives Vere Accomplished by:

(1) Review of the following applicable sections of the QA Manual:

(a) Number 2. Design And Specification Control.

(b) Number 3 Procurement Control.

(c) Number 4 Prozess Control.

(d) NwserS, Documentation.

(2) Examination of procedures located in shop work areas.

(3) Review of the six purchase orders for QA approval; also, the related Advance Bill Of Materials used in preparing these PO's for Shop CTder Number 2735.

~ (4) Reviewed "ASME-III, Approved Vendor List," Revision 4, dated December 16, 1975, for correlation with vendors identified on the above six PO's. .

e 9

-.y. - ,-ng ,rw - --

-,7.s - n+_n--~,--n,. . - - - ---,,,,-,------.,,.,.,.---.,,---_-,.,.------,----g, , + - - . , - , - - . . , -,,_-,n, ,,,,,

(5) Reviewed the work area (Shop Superintendant's) book of shop Fabrication Procedures for Shop Order Numbers 2730, 2735, 2740 and 2745.

(6) Reviewed the following completed traveler record

- packages for Job Order Numbers 2730, 2735 and 2745.

(a) Subassembly Mark Number A-CH-070-001, F Sheet F-1, dated May 1, 1975 Job Order Number 2735.

(b) Subassembly Mark Number A-CH-150-004, F Sheet F-3, dated May 1, 1975, Job Order Number 2735.

(c) Subassembly Mark Number A-CH-227-001, F Sheet F-5, dated May 1, 1975, Job Order Number 2735.

(d) Subassembly Mark Number 2426-883-1, F Sheet F-1, dated January 24, 1975, Job Order Number 2730.

(e) Subassembly Mark Number 2426-883-2, F Sheet F-2, dated January 24, 1975, Job Order Number 2730.

(f) Subassembly Mark Number 3-CC-246-001, F Sheet F-7, dated May 1, 1975, Job Order Number 2745.

(g) Subassembly Mark Number 3-CC-246-002, F Sheet F-8, dated May 1, 1975, Job Order Number 2745.

c. Findings (1) Deviation The QA Manual Section 2, paragraph 2.3, "Centrol of Specifications And Standard Revisions" states, "A runner from Engineering makes distribution as outlined on the Transmittal Record to each depart-ment and picks up the earlier revisions and destroys them."

Contrary to the above, certain superceded fabrication specification Numbers ES-JP-1, dated April 18, 1975, JS-150, dated December 14, 1975, and JS-151, dated October 14, 1974, marked " Voided" were identified in the shop superintendent's work area book of -

Fabrication Specifications for Job Order Numbers -

2730, 2735, 2740 4'A 2745.

The }30t representative acknowledged this condition.

, - - - - ,- - , - - - -- - - , , - - - , - ,---,n. - , ,-e. - ,-, .- w- --

. .g

7. Authorized Inspector (AI) a.. Obj ectives The purpose of this inspection was to verify that:

- (1) The AI has direct contact with the cognizant plant QA/QC representative.

- (2) The AI has free access to all parts of the plant concerned with supply or manufacture of ASME Code work.

(3) All applicable documents are available to the AI for review.

(4) The AI identified and signoff on witness hold points on process control documents and witnesses qualification of special NDE procedures.

(5) The AI maintains a log of activities reviewed and/or witnessed.

b. Objectives Were Accomplished by:

(1) Discussion with the AI.

(2) Review of the Al log book.

l (3) Review of completed traveler " Process Sheets."

c. Findings The AI, employed by the State of California (the AIA), inspects at the MWK Paramount plant on an itinerant basis. He has direct contact with the plant QA Manager. No problems relative to plant area access and availability of documents for review were identified by the AI, completed traveler process sheets showed evidence of the AI activities related to assignment of hold-witness points and his signoff and dating after witness.

The AI has started to maintain a log of activities witnessed.

b 9

b l

_.___.m _ _ _ . _ . . _ . . _ . . _ . . _ . . _ . _ _ , . _ . . . , , , . , . . . , _ _ . - . . _ _ . _ _ _ _ _ . . . . , . . _ _ _ _ . . _ _ _ _ - _ _ _ , _ . , _ . _ , . . - _

cN 12-DETAILS SECTION II (Prepared by H. M. Wescott)

) 1. Additional Personnel Contacted:

Z. Corder Level II Examiner M. R. Teplansky Lavel II haminer A. Barnes Welding Foreman J. C. Watkins General Foreman

2. Nondestructive Examination (NDE)

a. The objectives of this inspection was to verify that non-destructive examinations are:

(1) Performed in accordance with detailed instructions, pro-cedures and drawings that delineate requirements and l

acceptance standards.

(2) Performed by qualified personnel other than those par-forming the activity being examined.

J

.(3) Performed using appropriately calibrated instruments. 1 (4) Evaluated and test results documented to assure that the component or material examined contain no rejectable defects.

b. Objectives Accomplished by:

(1) Review of M. W. Kellogg's (Paramount, California), QA ]

Manual Section 6, titled, "Non-Destructive Exanination," l date issued January 28, 1974.

(2) Review of three (3) NDE personnel qualification records.

(3) Review of the " Personnel Training Procedures" as follows:

(a) Procedure II-1, titled " Qualification of Quality Assurance Program Audit Personnel," date issued l l

May 1, 1975, revised January 1, 1976. .

e

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

y.,....ry ,,,,-_,y_. ,_,2-w.,_w.. - , __ __,,,.,,-,y..,n- ,, ,%.--, -, ..-,___. .-,._ _,, , _ _ _ m

(b) Procedure II-3, titled " Inspection and Testing Personnel Training," date issued May 1, 1975.

(c) Procedure II-4, titled " Inspection and Testing Personnel Qualification and Certification," date issued May 1, 1975.

(d) Procedure II-5, ritled "Non-Destructive Examination Personnel and Training," date issued May 1, 1975.

(e) Procedure II-6, titled "Non-Destructive Examination Personnel Qualification and Certification," date issued May 1, 1975.

(4) Review of liquid penetrant and magnetic particle docu-mentation for Job Numbers 2730 and 2740.

(5) Review of Specification Number JS-404, titled " Liquid Penetrant Procedure," ASME Section III, 1974 Edition, dated December 5, 1974, and Specification Number JS-405, titled '9 Magnetic Particle Procedure Dry Powder Continuous Prod Method," ASHI Section III, 1974 Edition.

(6) Checked calibration dates on Magnetic Particle Tester.

(7) Checked type of density step strip used for densitometer calibration.

l (8) Discussion with QA/QC personnel.

(9) Review of Material Certifications for liquid penetrant materials.

(10) Observations made in shop.

c. Findings (1) Deviation There were no deviations identified.

(2) Unresolved Matter Procedure Number II-3, titled " Inspection and Testing Personnel Training," date issued May 1, 1975, paragraph 5.

^

, s Review states that, "On a periodic basis, Level III personnel will review current requirements and explain new developments in Quality Assurance, applicable Codes and Standards, M. W. Kellogg Company procedures and specifications and new inspection, test, or documentation methods."

Level III personnel stated that the above was being complied with but that to date, there was no documentation as to subject matter and attendees. It was further stated that future reviews would be documented.

M. W. Kellogg management stated that this situation would be corrected.

3. Equipment Calibration

a. Objectives The objectives of this inspection was to verify that:

(1) tools, gauges, instruments and other inspection measuring and testing equipment and devices used in activities affecting quality are of the proper range, type and accuracy.

(2) these devices are calibrated and properly adjusted at l specified periods or use intervals in accordance with written procedures.

(3) the calibration is performed against certified measurement standards which have a known relationship to National Standards.

(4) the control measures include provisions for test equipment identification and calibration status by marking or on records traceable to the equipment.

. (5) the manufacturer determined and implemented corrective action for materials and items checked, using measurement or testing equipment later found to be out of calibration.

b. Objectives Accomplished by:

(1) Review of MWK's (Paramount) QA Manual Section 7, -

titled " Qualification of Gauges and Measuring Equipment," .

date issued January 28, 1974.

--wyr-w--,-w, +

(2) Review of Engineer Specification ES-421, titled "For The  !

Calibration of Welding Machines," date issued July 25, 1975, l and Supplement "A" which replaces Section 7.11.

(3) Random selection of four (4) calibrstion recall cards and checking calibration dates.

(4) Review of Gauge Calibration Certificates.

(5) Discussion with QA personnel.

(6) Observations made in the shop area.

(7) Review of calibration certificates for four (4) pressure gauges.

c. Findings (1) Deviation The QA Manual Section 7, titled " Qualification of Gauges and Measuring Equipment," date issued January 28, 1974, the opening paragraph states that, "It is the responsibility of the QA Department to assure proper calibration and maintain calibration records of all measuring and test equipment." Paragraph 7.1 further states that, "All items are recalled to established schedules with standards traceable to the National Bureau of Standards."

Contrary to the above, the densitometer (Serial Number 2041C) did not have any record of calibration and there was no documentation provided to establish traceability of the calibrated film density step strip to the National Bureau of Standards.

M. W. Kellogg management acknowledged this deviation.

(2) Unresolved Matter (a) The QA Manual Section 6, date issued January 28, 1974, titled " Qualification of Gauges and Measuring Equip-ment," paragraph 7.1, titled "Means of Recording and Testing" states that, "Each item requiring calibration is assigned a coded number or serial number which is traceable to a Calibration Status Card.".

, - - - . - - - - . _ . , . - _ , - - - - . - - - - _ - _ - - .-_---.---,v__ -._,-------,.,----~..-----_._m._, -.~-,.--.....m ,- _ . - . - - . _ - ,- . - - - - - - , - ~ - . - , . . ,

The Tong Tester was Serial Numbered 39943 on the Calibration Certificate. The Calibration Status .

Card has this item Serial Numbered 60418.

M. W. Kellogg management stated that this item would be corrected.

4. Welding

. a. Obj ectives The objectives of this inspection were to verify that:

(1) welding procedure specifications (WPS) used in production velding are prepared, qualified and controlled in accordance with the QA program.

(2) welding materials purchase, acceptance, storage, issuance and use are controlled and documented in accordance with detailed procedures.

(3) weld joint fitup alignments meet requirements.

(4) requirements of essential variables and other welding procedures parameters are concurred with to produce weldments which are capable of having the required proper-ties for the intended application.

(5) completed welds meet visual acceptance standards of the program.

(6) welders are qualified in accordance with the ASME Code.

b. Objectives Accomplished by:

(1) Review of MWK's QA Manual Section 5, titled " Welding Quality Assurance," date issued January 28, 1974.

' (2) Review of MWK's QA Manual Section 12, titled " Audits,"

date issued January 28, 1974.

~

(3) Review of " Welder Audit Forms."

(4) Discussion with QA personnel. ,

(5) Review of " Welder Performance Qualification Tests."

. . - , . . - . . - ,-._.c. ._..__-,,.-,_--..-,,,,w,,._,___,.m,.%, - _ . . . . . . , _ . , _ . --.m__,_,,_,.-. , , , , - _ . ,. , , , _ , , , -,,,,,.- y. _ - . - - , _ ,- -~

(6) Discussion with welding personnel.

(7) Observation in veld shop area.

(8) Review of weld material certifications.

(9) Review of weld procedure specifications.

c. Findings (1) Deviations The QA Manual Section 12, titled " Audits," date issued January 28, 1974, paragraph 12.1.4 states that, " Dis -

crepancies noted during previous audits are reviewed for close out during subsequent audits. If adequate corrective action is not apparent, the information is noted and sent to the Plant Manager and QA Manager.

Contrary to the above, in reviewing a " Weld Audit Form" for Job Number 2640, dated August 22, 1975, it was noted that in the space provided for " Comments," it was stated that, "No welding procedure in possession and welder not quali-fied to 86-87. Notified welding foreman to update welder by qualification." There was no evidence of any documented followup action.

M. W. Kellogg management acknowledged this deviation.

5. Nonconformances

a. Objectives The objectives of this inspection was to verify that:

(1) written procedures are used to control material or items l

which do not conform to requirements to prevent their j inadvertent use.

's I (2) the procedures include provisions for identification, documentation, segregation and disposition.

,; (3) nonconforming items are reviewed for acceptance, rejection, repair or rework in accordance with documented proceduras.

(4) the responsibility and authority for the disposition are

.. defined.

I

.i

'I 15

---

9--,-- .-

--.9 .

w---w,,,----.,--.---y

-w--7 --, , ..y-y,--or 7.w,-m my-ww 7,-w--yme..s--------------e--+----e---& -.w,----- y-----

,, ~.

(5) repaired or reworked items are re-examined in accordance with applicable procedures.

~

(6) ultimate disposition of nonconforming items are documented.

b. Objectives Accomplished by:

(1) Review of the QA Manual Section ll, titled, "Non-Conformities and Corrective Action," date issued Janaury 28, 1974.

(2) Discussion with QA personnel.

(3) Review of " Defective Material Reports," (DMR) Number 4092, 4093 and 4094, dates issued September 22, 1975, and September 23, 1975, with followup action.

(4) Review of DMR's 4097, dated September 24, 1975, and 4099 dated September 25, 1975.

(5) Observations made in receiving section.

c. Findings No deviations or unresolved matters were identified.

o.

e S

e 9

e e- - -, - . - , . . - - m_

_. , ---m_. - . - . , - - . - - -- , c -.__ ,,-y ,m,

,.., .g 8C8tu Ni'C 764 us.ars:stztesinact: An mesw6Atoav co as.o.

JU. 1975

,v0 0535, INSPECTION Er ENFORCEMENT - STATISTICAL DATA sA a:TyNaut_'a* - -* iN5esCT0aisi m l e- ,,,ue,, A L ,,3,,Cro n mte , 4

! MCasstE.vt%00n Pu1 N-

.~ .vmm --.

W=wLi ,,,,,,,,, Vetter N I

7 p a g g, DOC =ET:40444 a ga; p g pOa T sO. DAT15sh @ wvtST,ih5P pacion AC? rON 2 9 go FRou pg CONOUCTissG  ;

. ACTtysTV TvPE is i l9 l9 l9 l Q q d 7l 7l '

<C l0l2 l0 l2 l7 l6 l iti At $*4 u u O O Y Y Co L' CENSE NO 'av PaCDeCT l 4

o. 2 'l to it

, Ill llllllllll

• l0l2 l0 l5 l7 l6 l u u o o v v f = st 08 A:Tivivv C0%D.Cvt 3 eCat:< S%f 30s C%Lvt 333a th5P!CTION 0*wtn 1

8 si O aCutigt iFEtt 050 uANAGivikTAu0iT C9 O MATL ACCT 13 0 tWPO8tf l 14 O IN0uimf C; O acu? NE :NO 8It) 06 0 uAh AGEutNT VI5iT 10 0 PL4%f SEC l 15 0 INVESTfGATICae c3lD isC404%T C7 O SP!CIAL tt 0 inevt%T .Ia a l G8 0 f58CA:!ul%T ce%lxv t% Con 12 O SmputNT is* CAT l OF INVEST ALSO CHECK BLOCK Sp o.tst:* ION on 'WIS'iCa?:04 DQ(A%houmCt3 2 O bha %NOWNCEO ;M* , , " , .;M %

@,'

.,*p " 'N";[%[3

" M. . ;.ex. -  :

25 ,

r.SatCT.ow iw 57. SAT,CN =0 Tis > CAT.cw cas:s Osa som Ostvi 36 t Q 131 3 Q nieEnatD TO *C5 FC 4 ACTION 4 0 ptGiome LITTER 6 MCs F0m ACTION

• g af GiONAL OFFeCI LETTER

.5et:T.3. .walv.ca . s smo.NC5 iC=t:n CNE a:n e%tvi 37 1 0 CLEAm 2 O r.ONCouPL ANCE 32bCE va T:0N 4 0 NDMCouP hiaNCE & CEViATiON 3t 19 4 N,;vstm 07 NONCou'LIANCE eTtus is LETTEa TO L.Cth5EE p 10] NOTE. ONCMANGt.uu.ST m .tvia Pai BE SueuiTTf D c u5tv e 4 CITE D 1714 06 NCACohmPLi ANCE IS OFfits ALLY DE LETED F A04

" THERfConQ NUVlt a CP DEviaT40N ITf us im LETTE R T3. CENSEE o o L suutta C# NO%C WhiANCE ITEUS IDE4'.8at3 tv LICENSEE nNO NOT C:*ECe l g j u as u muuata 'a's AsmosuAL OCC'., sat %CES mavitweQ ON5iTE TM.5 th setCT-Cw g g g atCi3%AL C8 810E LE*Tt a Ca at*0m? TR A%5uiTTAL D ATE 80m iN58tC?,CN Sa sw!STicATION 581 Om LtTTIR 1534.,t3 TO LICENSEE REPonT SENT 70 pac 5 POR ACTION

1. ao S$ u tv IrLE/ l#7nl d IIIIIII u u o o v v p u , 3 v v SutJECT 08 e4vt5?sCATIC4 aCatCE 0%E Son ONLvi se Se tvPE A toCsn20aC3 Tv*t 4 10 Cta 20 act u'5C Ci O iNTta=AL Ovt at x*c5 gat DE O 180 INT ovtataPClunt 15 O CaitsCAutv 21010uiP

• AiLumt C2 O E xfingAL ovE mixPO5uht 07 0 12O ext.OvimEx*CSURE '60 LD5s.iMEsT 220 ALLEGAT!ON#CouPLAINT C3 0 atti A5t 70 UNa EST. Amt A Os O 130 txCt15 mao LtvtLS 170 wup 23 0 PutL:CinTEntst C4 C LC55 08 8 AC LITv C9 0 14 0 ExCE55 COsc. LtvtLS is O TRAh570mTATION 24 0 5A60TAGE 05 0 PPCPtnTV OAuAGE 10 0 it D CONTate'LE AKING 50umCE 25 0 AS40auaLOCCUR.

l **

20 0 ENvip0NutNTAL Eb thT 260 OTMtm

• =E ADCua4TE A5 E NTpiE5 P MOS ACTsON CN iN5P'iNytST 4EFERRt0 0v REGION- l (see m.fe.eace Lis for Cames _,,,,,,,J l e3 8' l ', *s0TE SLOCES B TO L uuST 84 venesogo DATE MQ5 ENSORCluGNT LETTE R.h0Tict. 04cEm f55uto avIt woS *atNEeta

• O EN*m E5 Amt MADE aN BLOCats at u O O Y v

(

- 88 P. O. AND m

• l n CiV LPthALTY155Uf0 $O ee n Ac5

! 5 eaTt tu t%tt =ED mTO CouruT a 7 LE suo'vRs ,

n!8E8ENCE tt u v v r

i

F FOPV *.80.TWS

.".'LY $ 6* 5

• h 30 ms.

umrtto st:Tes muCLaan mesukatoav cou. 4.

INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENEnn iNStouC?iDNS BLOOK A MUST BE CMECKED TO SMC.V TYPE 08 INFCRMATION CONTAiNEO ON THE PO4h8 ONE Fonw is TO SE C098 ETED L FOR EACH (AJ ITEM OF NONCouPuANCE CITED.

(B) ITEM 08 NONCOMpuANCE NOT CITED. AND (C)

DEviAT.ON CITED aN EN80RCEMENT CommESPONDEACE 99900077 on uCENSa muusEn . mEponT uvweEn NO .

0004ET NuwsEa 3 8 l A.-TvPE Or NO N S 8 esEC 8'c NONCovau ANCE (CME 0n 'CNE BOX ONLY) l l l l l l l S*E0iC O!viatiev A NONCOM *'.t ANC E 3 2 8

[

2 B NON00V*Li ANCE (NOT CITE 06 C

• DEV AT.CN IDENTIFICATION SPECIFIC GulDE 04 STANDARD 0 0 ,t?E" iOE%trEO D-trMfS'?Ncf1

.0-104 CNE B0x QNLv! CalCK ONE 80x ONLYi

^ c^ust oa con 5':'u'5o ^c'u^' occua**~ce L 0 uceN5t=

14 i h INSPECTOA 1>

O ~^o o'<N'ia' 'o a55c '~ ^c'u^' occuaa'ac' o O o' Mea ~ 8 o'o ~o' ~^vi ao's~' 'o ar$v '~ ac'u^' occuaa'~c5 F~ A038PON AL UN'TS E - E '* v8T IN80W AT'ON IENTER M ' IN F4RST sox FQwtOWED Bf OTHER UNIT hvuSERS)

S h C=EOK BCt IF !*Eva? isecavATioN 21 2d IS INOLUDED 'N TEXT 3ELOW PEA 10 CFR 2 ?W G *!'T f ENTE A up TO 800 CM An AO*Ea5 F09 E Aca ITEv IF THE TEXT OF TME NONCCuegl ANCE OA CEvi AT40N ErCEEOS THIS N w:L'. BE NECESSAAf TO PA%P>4 ASE i 50 1

Contrarv to the AS$5 accepted QA Manual, SeCtion 2 paragraph 2.3, superceded 12.

fabrication specifications marked " Voided" were not removed from the work area superintendent's Book of FabricatiCn Specifit.ations. (4) til e6 iTi 181 19)

, (10J

! n,,

• ft2;

'I (13 114 til it$

l

& l E l N l 0 l & l NOTE DATA ENTmv CLERE-TME LAST LINE ENTERED wuST CONTAIN tovE")THis

1 S h

i 6

ALY '9*8a . .g 4 % 02 & ATo., a V ,

. Ts stT.. et A. .

INSP2CTluN & ENFORCEMENT-STATISTICA. DATA SUPPLEMENT CEstaat i*isTa 30T'ON5 .860C4 A MUST BE OwtCKED TO SHOW TYPE 08 INFOmwAT ON CONTAINED ON TME FOmkl.

CNE F0au is TO SE CouPLETED FOR EACM LA> 6TEv OF NONCOM *LI ANCE C:TED.

ist ITEV 0F NONCouettANCE NOT CITED. AND (C) OEVI AT:0N CITED t** EN8080EvfNT C049ESPONDENOE 99900077 , ,, ,, ,,,,

76-01

, ,,, g y,,, ,

C.:<ET NuvaEm 3 e A-TYD! 08 AND N35 3-seta s e NON:*evevaNes 0MiO4 ONE 60x ONLY, g SSEO ' O !Eviat.oN A h NONCCYPL' ANCE

• 2 8 NONCOYPUANOE tNOT CITED A C U T t A M 4 i ff b T i l l IDENTIFICAT;0N iPECIFIC GUIDE OR STAM0Aa0

• C DEWATICN C.ce*:ste M*; cts c_ c e, itts o!. is.E;

.;*E;< CNE 30s 0%Y. ICwg:< CNE sox ONLY:

L uCENSEE A CAUSE On CONSTITUTED ACTUAL OCCummENCE 19 t! 6 'N5*E 0?OR P O ^o o =NT' A' 'o a*5u'nN acTu^' occuaa'N==

~ o:= NOT Avi Pot <NT'^' To assu'n~ acTu^' occuaa=Nc=

0 0 oT <-

E - E u E*.*pf W'C89 A*> 0N F- ADD'T'ON AL UNf?S tENTE R .A ' 'N FIRST sox FOLLOW!D BY OTHEm UMT NUMSE85) 22 S C-E:n Box IF EXEYP* NF09VATl0N 21 24

'S IN w;EO N TEXT EE.0W *ER 10C842TE l ll l l G-E f ENTEa Us TO gc Omam AC+Em5 rom E A w ITEY iF TME TEXT 08 TwE NONCOVPL1ANCE OR CEv1AT:0N

.% 3E *.10E55Amy T3 P Am.7=a ASE ; so i

Contra-v to ASME Accreved OA Manual. Section 7. oneMq nwngrank and paragraph 7.1 the filti density calibration step strio could not be

traced to the National Bureau of Standards and calibration of the densito- (4) reter could not be verified. ts,

1. 61 (T)

(8p 19s

(!O.

[11)

(12)

II #

1141 (15) fif-4lElNl0lE NOTE DATA ENTRY CLERK-THE LAST LINE ENTERED MuST CONTA.N TMis INFOAVAT govge j 1 5

e

, e s se: tse-3 JJ.y * **b v; ;t:s-wwTso STATES mWCLEAa mesutafont C0ammsteen INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GtsE*A. 'sSta :s T.ess ag:CA A uv5T BE CMECKED T3 SMO* Type OF m80*uatiCN CONTAaNED on TME PCow 0.st 804u 15 TO BE CCUPLETED FCa EACM (As 'TEu C8 hC.%CCuauaNCE CITED tes TEu 08 NONCCu8vANCE ACT CITED, ANO

) deviation CITED W EN80aCEutNT CommEspoNcE%CE 3 0AET huvstm 04 UCENSE NUutta , mEpoor Nyvet. 76-01 .

I A-T**E C8 mN3'NTil 8-1*Ec s e NcNCountias0E 3 8

( MEGA ONE BGE ONkv. ggggl l l A Nc%C vpuANCE SPECi81C DEveAT+om 3 7 8 17

• • NONCV80ANCE it.QT CITED

, 2 8 iDENT6FsCATioN SPEC.5 C GU.QE 04 STANCamo C h DEVIATION

-Ow i*su Tas* f E3 D-??s tf Su*NEf t

'CaE0m ONE SOE ONi* CMIC4 0NE com CNLvl L UCENSEE A CAUSE DA CONSTITUTED ACTUAL 00CJRaENCE 19 P NAD PQTENTIAL TO 415#.T m ACTUAL OCCJamENCE is a h IN5pt: TOR O O o' mea ~ B oso aoT NAvt o'EN ' A' 'o aEte ' sN A:TuA occua ENet I

i E- E s tus' 'N'C"W A f'CN I 8-A 3s?'ONAL UNITS

. ENTER u ' W FimST Sox FCLLOWED BY CTMER UNif NuuSE45s 20 5 CMECK 90s 68 Extve inromuAtioN 21 24 is INCLUDE 1% TEXT BELO* PER 10 CFR 2 790 l l l l l G ~T E a T f ENTEm up TO SM CM ARAC En5 *C4 E AOM itty is TME Test 08 Twt NCNCCuevaNCE On CEvi ATiCN EXCEEDE TM 5 Nbu3Em 17 wgL SE %E:E35Aav TO PAmappaASE i So 1

(1)

Cn* ? ? n Vj fn V%e ECW sym cy-d ny hyg3*, e

_gges _ o there was no decuranted follevue action en a discrecancv identified on a 13)

                     "tfal d Attdi t Tn " Da""P -

(4) (5) (6) (D (el (0) (101 i (til 9 (128 e. (13) (tal insi tiss

                   & l E l N l 0 l & l NOTE DATA ENTay CLER<-THE LAST UNE ENTEmE3 MUST CONTA N tnt 3 WFQ4uAfiON 1                 5

Y f I 1 May 21, 1975 NRC Public Document Room

-                      1717 5. Street, NW

Washington, D. C. 20545

 -                     Gentlemen:

Enclosed are copies of documents listed below relating to The M. W. Kellogg Company, Paramount, California, Docket No. 99900077.

1. Inspection Report Number 99900077/75-01, dated February 24-26, 1975.

2. Transmittal letter to Mr. E. B. Curcio from Mr. J. E.

Tillou dated April 11, 1975.

3. Response letter from Mr. E. B. Curcio to Mr. J. E. Tillou dated May 13, 1975.

4. Acknowledgement letter to Mr. E. B. Curcio from Mr. J. H.

Tillou, dated May 21, 1975. This correspondence is submitted pursuant to arrangements made with the Public Proceedings tranch. Office of the Secretray, for use by the public. Sincerely, J.11. Tillou, Chief Licensee Contractor, Vendor Inspection Progran Branch cc NSIC, w/ enc 1 [ TIC, w/innel bec: Central Mail & Files Unit, Document Room Clerk, w/o/ encl.

                                                                                                                                                                                    ~

N ,

                                                                                                                                                                   . c}
                                                                                                          #                                              G'           '   ni  i omer >        1E IY .a -        -,

3 2.yye--- - Fr 0 .)

• sumeaur >

Ollerfu&g itesell

                                      - - - - - .. . . . . -                    Tillou.                                                              - -

can v .31 4 J.75... . 5/A J.75 ..5/fil25- - .- ver= Anc. sis tan. an . , ,, /,m, .e,-

                   ,e.            ,           - , - - -          -- - -,w,.-,    , -    ,.- - n, - - - - . ~ - ~ - , , , , , , - - - - - - - - - - -
                                                                                                                                                          -w - m y      ,---,,.,y--   ---

                        ~

i May 21, 1975 l The M. W. Kellogg Company Atta: Mr. E. B. Cuzcio Commercial Vice President

    .                      14507 S. Paramount Boulevard Paramount, California                   90723 Gentlemen:                                                                 Docket No. 99900077 Thank you for your letter of May 13, 1975, in response to our letter dated April 11, 1975, with an enclosure. We have no further questions at this time. We will review your corrective action during a future inspection.

Sincerely, b J. H., illou, Chief Licensee Contractor, Vendor Inspection Program Branch bcc .- l IE: Chief FS&EB } IE:HQ(4) Licensing (4) DR Central Files IE Files PDR HQ NSIC s? TIC R. E. Oller l

                                                           . -                                      f          L o m er >            ..Ign.IV.

77..l O.-i tr- e - pO Tillou . y.ee.r su==4wr > .. 011er/ng itesell ! ,, ,,,5/{/75 5//f/75 5/d/75 5/p/75 i Form Aac. ass ain.e mi u . 4,,.o,m em.

                       ,a-   , ,, -              - , ,-        -- - ,,      . - . _ . . - - - - , -

THE M.W. KELLOGG COMPANY a e.. sien se PULLM AN INCORPORATED POWER PIPING sesor souTM panamouwt souLtvano

                                                   ~      o   .e-a a -n                                   .iNOW8
                                                                                                             ..:.::P      :'

if.5T.MPSP0,.T tem.ftsas Panau0Wuf. Cauf 0emia Tg6g.=0=t 8:3 53 -#370 May 13, 1975 United States Nuclear Regulatory Commission Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 Attention: Mr. J. H. Tillou, Chief Licensee Contractor, Vendor Inspection Program Branch

Subject:

Docket No. 99900077 Gentlemen: In response to the findings listed in the enclosure to your letter of April 11, 1975, we offer the following statements: Enclosure item 1(a_) To prevent reoccurr-We will complete all existing " Accept Tags" by June 15, 1975 ence of this violation, Quality Assurance personnel responsible for applying

                   " Accept Tags" have been Instructed to complete the tags when they are applied.

I Enclosure item 1(b) The welding machines that were noted without calibration stickers are not equipped To date, we do not have procedures for calibration with ammeters or voltmeters. of these machines; therefore, they were not included in our calibration flies. Our calibration procedures are being revised to include welding machines without ammeters or voltmeters. When these procedures are issued, the welding machines will be added to our calibration files, calibrated, and will have calibration stickers applied to them. This will be accomplished by July 1, 1975 l l l

twxs ceuu P ge Vwo Attn: Mr. J. H. Tillo THE 31.W. KELLOGG COMPANY

                                    . .. . . .. .. .. P U L L M A u incoeronaTro plPinG FABRICATION By entering welding machines without ameters or voltmeters in our calibration files, reoccurrence of this violation will be prevented.

If you should have any questions, please do not hesitate to contact us. Very truly yours, THE M. W. KELLOGG COMPANY 4 E. B. Curcio EBC/sw cc: D.E. Cochrane, Q. A. Manager E.F. Gerwin, Chief Engineer i' f. b

                                                         === = nrwxx Offies of Inspection and Enforcement                                                                                             l 611 Ryan Plass Drive, Suite 1000 Arlington, Texas 76012 f//                  15
 ..      M. W. Kellogg Company                                                      -
 ,       ATIN: Mr. E. B. Curcio Commercial Vice President 14507 S. Paramount Blvd.

Paramount, California 90723 Gentlemen: Docket No. 99900077  ; This refers to the QA program inspection conducted by Mr. R. E. Oiler of this l office on February 24-26, 1975 of your facility at Paramount, california asso-I ciated with the fabrication of nuclear piping and to the discussions of our findings with you and members of your staff at the conclusion of the inspec-j tion. l Areas examined and our findings are discussed in the enclosed report. Within l these areas, the inspection consisted of an examination of procedures and re-presentative records, interviews with personnel, and observations by the in-spector. During the inspection it was found that the implementation of your QA program l' failed to meet certain commaitments in your ASME QA Manual. The specific find-ings and references to the pertinent requirements are identified in the enclosure to this letter. Please provide us within thirty (30) days a written statement containing, (1) a description of any steps that have been or will be taken to correct these items, (2) a description of any steps that have been or will be taken to prevent recurrence, and (3) the date your corrective actions or preventive measures were or will be completed. In ,accordance with Section 2.790 of the Comunission's " Rules of Practice," Part 2, Title 10, code of Federal Regulations, a copy of this letter and your reply, o together with the enclosed inspection report will be placed in the Connaission's Public Document Room. If this report contains any information that you believe

                                                                                                                                              .O
                                                        /

• h,,__, .,,_,,,_,,, t# q g .omcr> .IE IV..g CN_ht[ N JETillou WEVe r qg ol 4/3/75RE0ller N1 .-

l =4=> /75 g 4,/J/ /75 4 /, /75_, 4/1 om>41.7/.f75 ,, f t

    '*""^"c  " *"

• u n.,, ,,n. . , _,,.

_, - .,_,._. -. ,,,-- n,,-- - - - ,--,_- n_,--,------

                                                                                                                                              \
                                                                                                                                              )

l to be proprietary, it, is necessary that you make a written application within 30 days to this office to withhold such information from public disclosure. Any "such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document. If we do not hear from you in this regard with-in the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely,

  ~

k J. B. Ti lou, Chief Licensee Contractor, Vendor Inspection Program Branch Attachments:

1. Enclosure -

2. Inspection Report No. 99900077/75-01 bec: IE: Chief. FS&E3 IE:HQ (4)

Licensing (4) DR Central Files IE Files PDR:HQ NSIC TIC f e e f -- - - - . -._ ,, - . . , - , , . , , - - . _.n,,,,_, .--.a .w---- . , . .-

SUMMARY

OF FINDINGS A. Deviations From Commitments (Details, Paragraphs 3.b. (2) and 4.b) B. Vendor Action Previously Identified Enforcement Matters Not applicable

 ,                C.              Other Significant Findings
 '-                               1.                        Current Findings

a. Except for the foregoing deviations and the unresolved matters 1

hereafter identified, there was evidence, within the areas in-spected, that the Vendor's QA Program was being implemented.

b. The MWK Paramount plant is authorized to use the ASME NPT Stamp for Class 1, 2, 3 and MC vessel parts, vessel appurtenances and Class 1, 2, and 3 piping subassemblies.

The authorization expires on March 4, 1977.

c. The Authorized Inspection Agency is the Division of Industrial Safety, Department of Industrial Relations, State of California. The plant is inspected by an itinerant inspector.

2. Unresolved Items This Inspection Details, Paragraphs 3.b(1) and 3.b(4)

3. Status of Previously Reported Unresolved Items None D. Management Interview

1. A post audit interview was held on February 26, 1975 at the conclusion of the audit with the following persons:

d K. W. Ke11can Company (MWK) E. B. Curcio, Commercial Vice President H. W. Owen, Shop Superintendent D. E. Cochrane, Quality Assurance Manager

• J. A. Swanson, Engineer, Production W. R. Paget, Purchasing Manager W 4

        -   --a -      .-,-.,7,,<,,--,,_.,-,,-_,,,,,,--,v.m                              - _ -    -
                                                                                                      --,--.--,--.n-e,   , e , , - . - -ev   - , ,
                                                                                                                                                     ~-w-- ,.   -- --

i I 2-i

2. The following summarizes items discussed:

' a. QA organization (Details, Paragraph 2)

b. QA program (Details, Paragraph 3)

c. Control of Special Processes (Details, Paragraph 4) n O

e e

                                     , . - ---------.,.,----,-,-m_y, e,.,    y- m-,-,-w.m ma w- ,-,. -- - - - - - - - - - , - , ,   n- ~ ,   m-

Report Details

1. Additional Persons Contacted M. W. Kellogg Company (50 E. F. Siwora, QA Engineer H. W. Sullivan, cleaning and Shipping Inspector

  ~

J. Walkins, Shop General Foreman A. Barnes, Welding Foreman Authorized Inspector, State of California J. E. Warren, Safety Engineer

2. Organization

a. Scope

The purpose of inspection of this area, was to verify that MWK Paramount plant had established and implemented a quality organization with adequate authority and organizational free-dem to identify problems. In addition, that the organization had documented measures which provided that the individual or group performing quality related functions is independent of the individual or group directly responsible for performing the specific activity.

This area of inspection was accomplished by review of applicable sections of the QA manual, including organizational charts and, l l interviews with plant personnel.

b. Findings The following area was identified as follows:

Review of the plant organization charts established that lines of reporting and advisory functions were in the manual as de-id lineated. e e l I

      ..n- , , ----,.- - - - - _ .       -         , . _   ,,,.n.,_,,,,
                                                                        .,p_,,.  , _ , , _ . , _ , _ , .         ,,,..,,,e   _ _ -, . , ,-n . ,     ,   ,,,.__y..-, _ . . ,,,  . , , _, __ ,     ~,n,

j

3. QA Program l

a. Scope

                         *The purpose of this area of inspection was to verify that the ASME approved QA program provided measures to assure quality of the fabricated piping subassemblies to meet ASME Code requirements, and that procedures were in effect to implement these requirements.
    ~

This area of inspection was accomplished by: (1) Review of the entire QA manual (2) Review of implementing procedures and personnel qualifications (3) Interviews with plant personnel (4) Shop inspection.

b. Findings The following areas of the inspection were identified as follows:

(1) Unresolved Matter Review of the QAM established that it did not provide requirements for semiannual review and updating of sections affected by new changes in Winter and Summer of the ASME Code Addenda. The MWK representative said they did not want to commit to putting this requirement in their manual due to changing customer contract requirements. (2) Deviation - Procedure Not Followed Section 3 Paragraph 3.4 of the manual required the use of green " Accept Tags" for QA cleared materials and referenced ,4 Figure 19 as an example. Review of Figure 19 established that information identified on it included: material descrip-tion, purchase order number, items nueber, quantity, heat or 5 serial number, inspector and date. i

• l I

(

                         ,,          -  . _  , . _ . _ _ , _ . . . _-r..-.. - y _-, .,_ _ . _.- -mm,, ___,,._y,,_, - .,.__,,,

Contrary to this, inspection of pipe spools and fittings in storage established that numerous items had " Accept Tags" attached with no information on the tags, to provide trace-ability to receiving inspection records. The MWK representative said he did not consider that the manual required that the " Accept Tags" be filled out. (3) Unresolved Matter ASME Code, NA-4112 requires the QA Program to provide for indoctrination and training of personnel performing activities affecting quality. Contrary to this requirement there was no formalized procedure available to include this requirement for in-plant audit teams, and with the exception of NDE personnel and welders, there was no procedure controlling this QA requirement for other personnel performing quality related activities. The MWK representative said they are in the process of developing a program which will meet the NA-4112 require-ments.

4. Control Of Special Processes

a. Scope The purpose of this area of inspection was to verify that the QA program provided for and implemented measures to meet require-ments for calibration of measurement and test equipment.

This area of inspection was accomplished by: (1) Review of the applicable section of the QA manual (2) Shop inspection q (3) Interviews with plant personnel.

b. Results The inspection identified the following:

9

Deviation - Procedure Not Followed The MWK manual Parsgraph 7.1 requires welding machines to have calibration stickers applied. Contrary to the above, several welding machines were observed which had no calibration stickers.

 '     The MWK representative indicated ha interpreted paragraph 7.1 as meaning "each item requiring calibration" and that he does not consider that this requirement included the subject welding machines.

l

                                                                       =

l l l lO N ] l I

ENCLOSLM M. W. Kellogg Company Docket No. 99900077 Certain.o'f your activities at the M. W. Kellogg Company ParamountThese plant appear to deviate from the requirements of your ASME QA manual. activities are identified in Item No. 1 as follows:

1. Procedures Not Followed

a. Section 3, Paragraph 3.4 of the MWK QA manual requires the use of green " Accept Tags" for QA cleared materials and references a completed tag as an example.

Contrary to the above, inspection of nuclear material pipe spools and fittings in storage, established that numberous items had

                                       " Accept Tags" attached which did not contain any information.

b. Section 7, Paragraph 7.1 of the MWK QA manual states in part "Large items as welding machines and ovens will have a calibra-tion sticker applied."

Contrary to the above, several welding machines were identified , which had no calibration stickers applied. s l l { l .

                                                                                                ~ - - - -                  .------.-- -------- - ~ - - - - - - -       ,n-     - - - ---
       , - .        , , . , , - ,         - - - , - . _ , - . . - ,    .-,-----,-,,.%---                  ----.w_,,,p-7,

• 3' 3. Nuclear Regulatory C 3 mission
• Officrof Inspection & Enfo ..atnt OIE:IV REPORT' OF INSPECTION Docket No.: 99900077 99900077/75-01 Inspection Report No.:

M. W. Kellogg Company Company Name: 44020 14507 S. Paramount Blvd. P am No.. Paramount, California 90723 Address: Vendor QA Program Implementation NA-4000 Type of Inspection: February 24-26, 1975 Date of Inspection: appHcable Date(s) of Previous Inspection: b Yb- Date: 'i " ~ Lead Inspector: R. E. Oller, Contractor Inspector, LCVIP Branch Date: Accompanying Inspector (s) _ Date: Date:

                                                                                            ~       -

i Date: ,' -- ' s Reviewed By: , ,, &si N

                     D'. E. Whitesell, Sectiorr Head, 'LCVIP Branch O

e

                                                                    .w.

           **'M             -'                                                t).S. ATO.'.11C E NE RGY CQ'.1Ms55:ON ta s.                                                                                                                                    t. DATA REGULATORY CPE RAT!ONS-STATi" i
               ,.. -;                                                                                                                                                                                                               1 FL                            ' e ' ^ a r t 3 N C 1 F --                       I #.67.0g4      i C rea% G g a rgsonta.ud314                  E # *' U I 0 4' .                                       -
                                     "c i se A L;: .* ! * %

Cgj,oy ,' ;

                   .i .

3 , ,0 ,:, o s.  % . . .. L ..:.. i s . . n. . 9 l9l q 0l0 0 7l 7 7M7l5

                                                              /7                         0     1
                                                                                                       , AC.o r v 0 2 2 4 7 5                       kO '         2   2      6 7 5 umsa .. a =.

4 7 L,w..u s a:.:s a

     - A                 M. W. Kellogg Co.                                                                 Paramount, California                                                                                                    l 1

a: Tow'Tv CG%3sCTED: ) asAgactutNT e C O i~ovi y . D*VI% i% >>> Die CT:os .O viser . O :.%cuiny e LiCa sis 2, 1 O .%s>> CTeo- O i~visT.C=T.Cs r.47ACT.3% a%vistsCaf f 04 RF&gtTS. 1 ste 2 RAGiO%AL O88sCE LETT..  : D == > > a= T= os > == ictio- . O Rtrei>ia L ONALOsF.Cti.tTTl2A

                                                                                                                                                                                                       <>2. ci oa CT>o4 isi,a CT o v.svis"o'" " '*"*o' DEVLWION                                                               NONCOMPLIANCE 3hWN 2 h g..evamey I:ts              t b Cttaa 814LD ACT.0% as a m4&vkT Op im00sev                                                                         3 L,j #883 4 70 0f>td AIC60~                                          . O ' o= >oa >Crio~

a l pI PE 4 70 NOa>hB3. Aufn h C0% DICT p t vit'.1 N8 x? i3b i 6%v437scatiON 3 1%5850780 % g' of st a TO OT=t a as3.copsCt T O o Puaf-a= 4CT.oa p.s SUBJECT 07 sNousav 0m tavasteC ATIOss u we aDouamit as iticas CN s%6PaCTION L" ., L 85a&C% iNSP FsNOthC$ ntstanto AND wvastasa'Os

             -              T3 mt aD0gaaf t AS POR ACTsON:                       ,

13 % 2 5: r33 2ts

                ' 3 & 34.

Ol Q Typt a eNT. OVing x*'15ua s iveto..T T a T To .... 01 C pt ALTee a?.D Sa#ETv c.6 d 'Tv'aAExT.ovanax.osuas es Dio N **8hudio 03 Q- TYPE A ntLEAst CQv7Lt x sTEne ogvoLvisec: 92 D Lim e-CLlan

                                                                                         #d D, T'P3 A LoS3 o8 8aC8L,7y 02 Q AO%CoyeuamCaihomCo4somuaNCE 03 Q u*f N$iNG PROSLf A8                                                               ,                                                                                              ,

g4 Q P0u;v . aTTf m 9 g6 O 7798 8 fNT.0vt AE MPO5ung es D m' 8 "'""^7'o* sr D T88*7 o*'"'*'o'*** *a D ttriani_sassTv Ttw pt Q TYPE SRILlaSE 04 [ Sa8f tv if tga n D Pant 3 *.0'.C3 09 Q TvPs B LOLS OHatsuTY 0 7 C *.* A*d a 4 YINT Di plCt4Ney PART 2 hot Cl agelbuLT O8

                                                                                                                                                                                         .F o LLOeus TO Plcoc yag 04 O e%A330 mipLv TO LETTan                                          10 D TYPi S PRO 8IRTY D AM ACI sa D c'aits tut se y n t.0 atPLv To LETTE A                                                       to CPR 20 405 to O so oanacTive actio* *LamNe                                     at D istan.%aL0vantamosunt                                                          or D Omota
                              . ..atou.ra CoansCriva il D 10T'o%PLANNIO                                                  gg M 81,754%ALOVlagupetuat in D -es teTTem aaouins                                             13 0 C855 " *o?'oa. Lavs ts                                                  es n 8'"'

• To 'L 'o* "3 50* % *

85C855 ts C a'o**8vil'"860'"8o yy CON CTeatsON f.w'v 8 LtV8LS gg Q L,Na t vie WE D $a8 ETV M ATTf A Cast.Cauty gg g R E8 t

• 10 RL 809 :58 0 49ATf 04 l gg C Lil4% Cada%Ct it D LOL1cmTwear IS C gy Q COwf Au.NaTiOm go y fit Fl a 7 *.. FD4 . P130LUTeON 19 C L'%la8 f O*f aaTION _

ie D in D '

" '"to5 o= .. -

is o aa n s . To vL ,c= .. .e. . AT,o, pp y D'uvaNiO*fea y [ s er as.. & C act o% oaTas __ D Co '* L a ' 12 O P t P E a T: assiC= Ta CLoss ou? 3 ase:a r 2 .- to -sa: avan?tas i , , , , , ,,,];" " I\ S 09 # O b _ 23 O Lt AMAC S3 act 13 C OTwgas A LE M d p. P. 1.043t- %6AD late.4TT3aen;ugo 24 D Taagt*0atatsCy y 7 (

4% s3, 0l4l0l9l7l5 ,,D .

E** oL : %i. o Datt L.C(P.eK I T2 PLv as;t es s l T . C ptPLYN0fagou.mso 4.. 25 O v.3 s **J e ,v.

• l. dN.i *a o.

                                                                                                                                   . 8.*.*o                                  u i

N m o, u;.

                             = v.g > Ci~ .                                                ,, a C . ., s. m ,,,,, , ,. ... C , . .. t ,. :.

v 4 4.glIIIII ,, o , m.... .s . .., onE

                                                                                                                                                                          , , ,     ,g           ,,,,,,,,,..,,,,      .
                       ,a                    ..e. Aoiouar.                             nD . . -n o uC r u ..,: > = s                                                                                          .             ,,,
        ,,.                                                                                                                                                               ,, ,,                                  ! ,,,,, ," W '

23 Q Die se rt;st r agu #la n ts's con i O CA .w os, si O ot-ta (OVE R) l - -- - - - - - - . _ . . - _ _

A. 0 .:r , .u . a a . . R .~ nu:.m3 it'l ) l lN I I

                                              ,[:j ,              9 l9       9 0        0 l 0 l7 j ?        (1 23'       j :'    T    N  u   9.:lpg 7 l3 ; c0                  1

.t0E NSE ?.t .:EF A C.. ACTIVITY CONOUCTED 1. INSPECTIO.*J 2. INQUIRY 3. INVEST :

11 10) A C: T I y /. 4 4 VE.NCCR 5. MANAGE?. ENT 6. 1*.Ov;r.Y-INSPECTION vlSIT NON. ti:E E. $PECIFIC NONCO:.1PLIAi;CE D. REGiCN CCNCLCTI.NG ACTIVITY 1 2 3 4 5 R E o I o N [/ 4 '(1_]g; (1158 N C O u kNMVjGlFlClP F. HOW 4T551 IDEr.T3FIED ENTER ONE CCDE symbol in po:i:lons 1. 2 & 3: enter cause code in position 4: r

                                                               --         ' - O '"'"                         cedure coce in position 5 and code identifying noncorncliance
                   '                       .X.' .g                         .~                                (1-violation. 2-infraction,3-deficiency) in paiti=n 6 as on 'o
 ~

comrnent biect s) i 766.) G. CONSEQUENCES ENTER ONE CODE

• A - Caused or constituted actual occurrence (1*01 C O N 5 E C N N P - Had co enties to result in en actu=3 occurrence

                                                  #'                                     N - Did not have pctential to result in en actual occurrence H-                EXE'?T INFOD'ATION
                                                .. .                            Enter '5' if exe::ipt infornaticn is E       X    E   i1   P   T) ;]. JN,-                          included in text below, per 10 CFR                           2.790.

(1-10) -

                                                                                    'M,            W NTs N st CK -F (NOT TO SE KEY 80ARDED) 8-AdditiCnal unit (s) cited. Enter and other unit numbers.

Vendor QA program implementation inspection

                                     -                                1     ')    3     4, (1 12)   U       .N   I T      A   T   T    R     /*f,_
                                                              ;/

i l J. NONCO*.*PLIANCE TEXT (14) N C O M T & X T Contrary to QA manual requirements numerous nuclear pipe (1) spools and fittings in storage had attached QA " Accept Tags' (2) whiCh were not filled out with mquired information. (3) (4) (5) (61' (7) l (8) l (Q) . l l (10) I (10 72) E. . (13) E f: D

                 ,0C :TT 7.U:/s,ER                                                                                                     6. R k P' ' nut.tEER th) 0l0         .C     K    E      7
                                                           ,7.' J.,
                                                               .                 9l9             9 0      0l0l7i?                     n t3' h ' ? T                                  N  U   ?.i '                7      5 ! O5!
           . O E .S E ?.U *.:IFA                                        C.. ACTIVliY CONOUCTED                                                        1. INSPECTION                 2. l*40VIRY                 3. INVEST; (1 10)    A           C  'T    I  y                  /.

l 4 4 VE.NDCR 5. MANAGEP. TENT 6. I!;Ov:r.y. INSPECTION vlSIT Nos.t,:; D. REGION CONDUCTI.NG ACTIVITY E. SPECIFIC NONCOMPLIANCE 1 2 3 4 5 M *153 N C O M R E G 1 O N 4

                                                                                              '( } -] Q)                                                                                                       VlG Fl Cl P F. Hor.' IT E!i IDEf,TIFIED                                                       ENTER ONE CCDE syrnbol in pc,:itions I. 2 & 3: enter cause sede in position 4: r (1 10)        I     o    q     NlT                '
                                                                                 ]               -I      et r d - Other (Emplain in                                           ' "'               " ** "*            *'"            * " " "

comtnent blecks! l700 I

u. CONSEQUENCES ENTER O';E CODE

   =

A - Caused or constituted actual occurrence U 10) C O N 5 C N P - Ha8 po entia' to reiutt in *a actual occurrence E N#k' ' N - Did not have pctential to result in en actual occurrence H- EXE'2T INF0bb7 ION Enter 'S' if exempt inforcatiCn is E X' E i1 P T).cjsi JN included in text below, per 10 CFR 2.790. (1-10) - -

          '-                                                                                                                    "             "                   #                " '              ' ^"            '

Additicnal unit (s) cited. Enter 'M' and other unit nucbers. Vendor QA program implementation inspection 1 7 3 4 (1 12) U N I T A T T R J. NONCO*/.PLI ANCE TEXT I1C) N C O M T E, x T Contrary to QA manual requirements numerous nuclear pipe f spools and fittings in storage had attached QA " Accept Tcgs' (2) which were not filled out with zequired information. (3) (4)

     .                                                                                       (5)

(6)* (7) (8) I?) . l (10) 0072) (

u. .

l (13) E N D e

                      .,                         -    --%-       , - --            _ . . - .                                                                          . _ _ . +         ,
                                                                                                            ,,,_,9--,--.y           . - - , , . , . , _ -                                         -       ,,,m

                                                ...r     .-
 * .i                                                 -

0.s 1 UNITED STATES OF AMERICA . . 2 NUCLEAR REGULATORY ColetISSION Q: m : 3 4 Before The Atomic Safety And Licensing Appeal Board 5 6

                                                              )

7 In the Matter of ) Docket Nos. 50-275 0.L. Pacific Gas and Electric Company ) 50-323 0.L. 8 (Diablo Canyon Nuclear Power ) Plant, Units No. I and 2) ) (Construction Quality 9 ) Assurance) 10 11 PACIFIC GAS AND ELECTRIC COMPANY'S 12 ANSWER TO JOINT INTERVENORS' SUPPLEMENT TO MOTION TO REOPEN THE 13 RECORD ON THE ISSUE OF CONSTRUCTION QUALITY ASSURANCE 14 15 16 On September 9, 1983, Joint Intervenors filed a 17 document styled a supplement to their motion to reopen the 18 record on construction quality assurance which included 19 copies of (1) a proposal by Nuclear Services Corporation 20 (NSC) for an independent audit of one of the Diablo Canyon f 21 construction contractors,. Pullman Power Products Corp. 22 (" Pullman"), and (2) a report of the audit conducted by NSC of Pullman, dated October 24, 1977. 4 23 l 24 On September 14, 1983, PGandE notified the Board 25 that it would respond to this supplement within the time 26 ///

                                                          / , a         mdh?M              ~

ypujJouatu . _,

1 prescribed by the rules. In accordance with that letter the a , 2 following response is submitted. ,.'){

g. .

3 BACKGROUND L 4 On June 8, 1982, Joint Intervenors filed a motion 5 to reopen the Diablo Canyon record alleging deficiencies in 6 the quality program. After hearing argument on this and i 7 other matters on April 14, 1983, the Board issued an order 8 on April 21, 1983 requiring Joint Intervenors to promptly 9 refile their motion to reopen on construction quality 10 assurance and further required that all evidence that they 11 claimed supported reopening should accompany that motion. 1/ l 12 Notwithstanding that the Board had ordered the motion filed 13 promptly, Joint Intervenors did not file their motion until 14 May 10, 1983. PGandE filed its response to that motion (and Governor Deuknejian's) on May 31, 1983. On June 28, 1983, 15 16 the Board issued an order setting an evidentiary hearing on 17 the motions to reopen for July 19, 1983. A mini-hearing was 18 then conducted on July 19-22, 1983 on the question of 19 construction quality assurance. At the close of the hearing 20 the parties were allowed to file closing briefs by August 4, 21 1983 on certain issues limited to the standards for 22 /g 23 24 J/ The Board noted that .on the eve of the argument the Joint Intervenors had filed certain documents with the 25 Board in an improper manner without seeking leave of the Board. (Appeal Board, Memo and Order, April 21, 26 1983, p. 2-4).

                                                                                                    . - . - - - . .            : =       . = .-...- - .-

1 reopening a closed record. A decision on the motion has not y. 2 been issued by the Board. 3 THE SEPTEMBER 9, 1983 SUPPLEMENT 1 4 As they have many times in the past, Joint Inter-5 venors have completely ignored the established rules of 6 practice by dropping documents out of thin air on the Board 7 without requesting leave to file. Indeed, as noted above, 8 the Board admonished Joint Intervenors as recently as 9 April 21, 1983 to follow the established rules of practice 10 in filing documents with the Board. Suffice to say, the 11 instant filing falls into the same category and for that 12 reason alone should be ignored. i 13 However, there is another and more fundamental 14 reason why the Board should refuse to entertain this sub-15 mittal. With any administrative proceeding there must be a 16 time when the evidentiary record is closed. The practical 17 principle of administrative finality must be applied in a 18 reasoned manner if an administrative matter is to be brought 19 to a logical and timely conclusion. See, ICC v. Jersey , 20 City, 322 U.S. 503, 514 (1944). 21 In the instant, case, Joint Intervenors have 22 practiced a fine art of delay by continually filing 23 documents out of time or otherwise ignoring the rules of 24 practice. No cogent explanation or affidavit accompanies 25 this " filing" to explain its lateness (the documents are 26 more than five years old) or otherwise explain or sponsor 'I e

   . . , _ . _ . . . . _ _ , _ _ _ _ _ . . _ _ _ _ . _ . , _ _ . . _ . , _ _ _ . _ . . _          ,..,,_.=___,Ju__-.._.,             .i________,__-.___.._-L*_,_.-J._______

I the conclusions contained in this filing. Obviously, this is not "new evidence" which has recently been generated and 2 3 which might arguably justify this eleventh-hour filing. Sf. 4 I_n n The Matter of Metropolitan Edison Company (Three Mile l 5 Island Nuclear Station, Unit No. 1) LBP-82-34A, 15 NRC 914 6 (1982)). Indeed it was a similar filing in April of this 7 year which prompted this Board to require the filing of new 8 motions and a subsequent " mini-hearing" on the construction 9 quality assurance issue. Nanifestly this process takes time 10 to accomplish and the delay which results serves the stated 11 purpose of the Joint Intervenors to delay or stop the 12 operation of Diablo Canyon. If this information had been 13 produced at the July hearing PGandE could have responded to 14 it as appropriate. Therefore, to allow Joint Intervenors to l 15 proffer it at this time would be rewarding such conduct. 16 Accordingly, we urge the Board to refuse to consider the 17 Supplement in its deliberations on the motion. Notwithstanding our foregoing arguments in 18 19 opposition to the receipt and consideration of these 20 materials at this late date, PGandE, in accord with its 21 September 14 letter, conducted an in depth review of the 22 events and subsequent actions surrounding the NSC audit. 23 If the Board decides to consider the Supplement 24 filed by Joint Intervenors, .PGandE requests leave to file 25 the affidavit of Russell P. Wischow in explanation of, and 26 ///

                    . . _     . _ . _ _ , .                           #~NN"W-N9"-*c   wq,w , , . _       __

1 in rebuttal to, the Joint Intervenors' filing. 2/ As . 3 2 explained in our September 14, 1983 letter, this additional 6 y - 3 information places the NSC audit in perspective and confirms j 4 that both Pullman and PGandE had acceptable programs in 5 effect for construction quality assurance at Diablo Canyon f 6 during the time in question. l 7 In reviewing this information we believe that it 8 must be kept in mind that audits are by nature documents 9 that portray a negative picture. Their purpose is to point 10 out any possible deficiencies that must be addressed. Over 11 the years, hundreds of audits have been conducted. Many of 12 these audits have generated findings. These findings have 13 then been reviewed and appropriate corrective action taken. i 14 Where indicated, program improvements have been 15 incorporated. Obviously it would be totally unreasonable to 16 expect error-free construction at a nuclear plant. Such a 17 result is not mandated by the Atomic Energy Act or the 18 Commission's regulations. Rather you look to see that 19 20 2/ Attached to the Wischow affidavit are the following documents: (1) Statement of Qualifications of M. W. 21 Russell P. Wischow; (2) ASME Certificates Kellogg Co., Div. of Pullman, Inc. Diablo Canyon Work, 22 dated December 18, 1972 and October 14, 1977; (3) NSC Audit, dated October 24, 1977; (4) Pullman Review, 23 dated April 11, 1978; (5) PCandE Audit No. 80422 dated ' June 12, 1978; (6) PGandE Review of Nuclear Services 24 Corporation Audit Findings, dated June 16, 1978; (7) PGandE Non-Conformance Reports DCO-78-RM-004 and 25 005; Minor Variance Reports M-3723, M-3724, M-3725, and M-3726; and (8) NRC Inspection Report 50-275/78-10, 26 50-323/78-10, dated July 26, 1978.

l 1 identified construction errors have been cured in order to ..r.- < 2 give reasonable assurance that the plant can be operated . 3 without endangering the public health and safety. Jn_ the }.? 4 Matter o_f_ Union Electric Company (Callaway Plant, Unit 1) 5 ALAB-740, Slip. Opinion pp. 1-3, (Sep. 14, 1983.) Thus, one 6 audit in isolation cannot give an accurate picture of an 7 overall quality program. Rather, it must be looked at as a 8 part of an overall program and a tool for management to use 9 along with others to assure high quality performance. 10 1971-1977 PULLMAN POWER PRODUCTS SCOPE OF WORK AND QUALITY ASSURANCE PROGRAM 11 12 During the 1971-1977 time period encompassed by 13 the NSC audit, Pullman was the principal piping contractor 14 for Diablo Canyon Power Plant Units 1 and 2. 3/ The prime 15 piping contract was written to include power plant piping 16 and associated supports with the exception of the main 17 reactor coolant loops (which were done by Wismer and 18 Becker), the majority of the fire protection system, and the i 19 plant embedded piping. The erection of all rupture 20 /// 21 , 22 3] Much of the following information has been obtained from PGandE records and is attested to in the attached 23 affidavit of Russell P. Wischow who was PGandE's Direc-tor of Quality Assurance at the time of the NSC audit. 24 As Mr. Wischow states, the results of the NSC audit were not communicated to him until early 1978. Accord-25 ingly, he could not have testified as to its Affidavit, results in the October 1977 hearings. (Wischow 26 para. 3.)

                                                                  - - - _     .--------.~....u,                                    ::_ = - .           :-- - -.

- 1 restraints was also included. The contract with Pullman e :. included the inspection and documentation necessary to  ; 2 3 demonstrate compliance with quality requirements. 4 The Quality Assurance Program associated with this 5 contract was originally written to accommodate the j I 6 requirements of the 1968 edition of applicable parts of the This 7 ASE Nuclear Pressure Vessel Code (USA B-31.7 ) . compliance was reviewed by the State of California who l 8 9 requested that it be modified to incorporata the Quality 10 Assurance requirements of the ASME Boiler and Pressure These 11 Vessel Code, (ASME Section III) 1971 Edition. j 12 commitments are consistent with the requirements of 10 CFR 13 50, Appendix B and became part of the program manual. 14 The Pullman program was subjected to the review 15 and extensive onsite survey by the ASME who granted Pullman l 16 NA and NPT-stamps in 1972. These NA and NPT stamps specific 17 to Diablo Canyon were recertified by ASME in 1977 following 18 an updating audit. (Wischow Affidavt, Attachment 2) 4/ For 19 ASME code certified work, the NRC Regulatory Guides provide 20 that this Quality Assurance Program is a recognized means of 21 meeting the intent of 10,CFR 50, Appendix B. Appropriate 22 quality procedures were provided for all non-code work 23 performed by Pullman. The Quality Assurance Program was 24 25 4/ Interestingly, this audit survey by ASME was conducted from August 29-31, 1977 during the audit conducted by 26 NSC (August 22 through September 20, 1977).

                             ~ - _ _ _

I then submitted to PGandE and approved, after review and ny..l'-. 2 comment, to control Pullman's work in accordance with the:uhji;: . 3 requirements of PGandE's specifications. 'I ~ _ 4 NSC AUDIT OF PULIJtAN POWER PRODUCT QUALITY ASSURANCE PROGRAM 5 6 At the request of PGandE to further confirm the 7 quality of the installed materials at Diablo Canyon NSC was ! 8 contracted by Pullman to perform an independent audit of the 9 installed piping components and supports in August 1977. 10 The actual audit was conducted from August 22 to 11 September 20, 1977. Thereafter, a report of the findings was submitted to Pullman on October 24, 1977. This report 12 13 contained a number of very sweeping and generalized Affidavit, 14 assertions and conclusions. (Wischow 15 Attachment 3.) 16 In areas requiring evaluation and interpretation, l 1 17 the auditors measured the quality of the work effort against 18 then current (August 1977) ANSI Standards, Nuclear 19 Regulatory Commission Regulations, and Regulatory Guides. 20 This approach did not comport with the stated purpose of the 21 audit to evaluate the work effort against the codes, 22 regulations, and standards in effect at the particular time 23 ///. 24 /// 25 /// 26 g.

l 1 1 the work was being performed. 5f The problem apparently 9 l 2 arose from the auditors' erroneous interpretation that 4.. . 3 organizations must "backfit" work done to previous codes and f 4 standards to meet current standards. This erroneous 5 interpretation and approach to the audit had the practical 6 effect of invalidating much of the entire NSC effort. 7 PULLMAN POWER PRODUCTS RESPONSE TO THE NSC AUDIT 8 9 After receipt of the NSC audit report, Pullman 10 determined to conduct their own an in-depth review of the 11 findings (Wischow Affidavit, Attachment 4). This review 12 consisted of a point-by-point evaluation and rebuttal of 13 each of the NSC Rt. port findings. In its response, Pullman 14 15 Sj The NSC proposal defined the scope of the audit as 16 including a review of (1) the overall adequacy of the exi:; ting quality assurance program against current NRC 17 requirements, (2) the implementation of the guality workmanship of assurance program, and (3) the (NSC Proposal, 18 field-fabrica tedthe Where: and installed auditors wentitems. astray was in applying

p. 2. )

19 current NRC requirements to the installed work rather The audit report itself than to the existing program. 20 provided that the audit scope and purpose wasand to against the codes evaluate the work effort 21 standards in effect at the particular time that the work was being performed. However, the Report goes on

22 to state that "in areas requiring interpretation, the Canyon was quality of the work effort at Diablo 23 measured against the current [1977] ANSI Standards and Regulatory Guides, accepted todayMoreover, as valid interpreta-they also 24 tions of regulatory requirements.

cautioned that the long time span and the specific time 25 interval of the work effort had toAffidavit, (Wischow be considered Attachmentwhen 3, reading the report. 26 p. 2.)

                                               .g-
 -.-:--_          : rucx x u::_ ;_;_;__ x           _ _ _

L'L. _L _

 ]

I drew attention to the fact that the audited work took place:g.; -- .. 2 over a time period spanning 1971 to 1977. Pullman notedc.3S: ;.. 3 that the audit team did not adhere to their definition of (z 4 the scope and purpose of the audit which was to evalusta 5 work against those codes and standards in effect at the time i 6 the work was performed. (Wischow Affidavit, Attachment 4, 7 p. 2.) Instead, NSC inappropriately applied 1977 8 requirements retrospectively to the prior work, thus 9 producing invalid findings. 10 The Pullman review and analysis, following the 11 format of the NSC report, was organized into the 18 criteria 12 matching 10 CFR 50 Appendix B. Within this framework the 13 NSC report contained 137 findings of which 58 were 14 favorable. With those 58 favorable findings the Pullman 15 review agreed. As for each of the remaining 79 findings the 16 Pullman responses were formulated in three categories: 17 disagreement with the finding (25); providing additional 18 explanation to clarify program compliance (29); and 19 corrective actions taken as a result of the findings (25). 20 The twenty-five (25) findings with corrective action to be 21 taken were software speci,fic, i.e. paperwork improvements. 22 None required correcting hardware deficiencies. 23 Subsequently, these actions were all documented and 24 dispositioned in accordance with Pullman and PGandE quality 25 requirements. 26 ///

1 . 0 1 The NSC Audit Report and Pullman's Response were i? 2 then formally forwarded to PGandE on April 11, 1978. ff. - 3 (Wischow Affidavit, para. 3. ) 4 PGandE'S REVIEW OF THE NSC AUDIT AND PULLMAN'S RESPONSES S 6 As the licensee responsible for the overall 7 quality of the plant, PGandE performed a detai, led, j 8 finding-by-finding review of the NSC audit findings and (Wischow Affidavit, Attachment 6). A 9 Pullman's responses. PGandE Quality Assurance audit team retraced the steps of 4 10 11 the NSC auditors to verify the validity of alleged 12 deficiencies. The following conclusions were reached by the 13 PGandE QA auditors: 14

• Many of NSC's findings resulted from an incorrect 15 NSC interpretation of requirements. NSC audited l

l 16 to codes and standards that did not apply and to 17 NSC guidelines (opinions). 18

• Many NSC findings were simply incorrect or could not be supported by objective evidence. They 19 20 apparently were not adequately researched before 21 conclusions were reached.

22

• Pullman's responses to NSC findings were in 23 general correct. Pullman could have strengthened 24 their responses to many of the findings by 25 addressing the applicable codes, standards, or 26 guidelines involved.

    --  - - . - .         -_: = - = ,__ 3

l

   ..                                                                                         l I

1

• As a result of this review, PGandE concluded thatg~7 . . n.

2 the NSC audit did not give an accurate measure of , 3 the overall Pullman quality program. ":l' 4 5 PGandE AUDIT OF THE PULIJEAN POWER PRO-DUCTS QUALITY ASSURANCE PROGRAM 6 7 In order to confirm that no deficiencies had 8 inadvertently occurred in the physical work, PGandE 9 conducted a thorough audit of the Pullman Quality Assurance 10 Program during April and May 1978. (Wischow Affidavit, 11 Attachment 5). The audit consisted of an in-depth 12 assessment of Pullman's quality program and a detailed 13 inspection of selected installed hardware. The PGandE audit 14 plan was formulated by utilizing codes and standards that 15 were thoroughly researched and ve-ified to be applicable to i 16 the time the work was performed. 17 The PGandE audit concluded that Pullman's program 18 essentially fulfilled contract requirements and complied 19 with requirements of the ASME Boiler and Pressure Vessel 20 code, 1971 edition and, hence, the requirements of Appendix 21 B. Where deficiencies were identified, they were documented 22 in accordance with Quality Assurance procedures and 23 subsequently corrected. (Wischow Affidavit, Attachment 5.) 24 In this connection, PGandE initiated two Nonconformance 25 Reports (DCO-78-RM-004 and -005) and four Minor Variation 26 Reports (MVR-M-3723, -3724, -3725, and -3726). These C -. . e:__:__.__ n _.___,_ _ __

 ^*

i 1 problem reports, which were initiated in mid-June 1978, vers y 2 all closed by early 1979. All problems which had been 7)i.. i 3 identified were promptly corrected and the disposition ,. 4 appropriately documented. (Wischow Affidavit, Attachment 7) 5 NRC INSPECTION EFFORTS 6 Another aspect not to be overlooked with regard to 7 the Pullman work covered by the NSC audit was the ongoing 8 NRC inspection effort. 9 During this period of construction NRC Region V 10 Inspection and Enforcement (I&E) Inspectors were conducting 11 unannounced site inspections on roughly a monthly basis. 12 NRC Inspection Report 50-275/78-10, 50-323/78-10 documents 13 the inspection performed on July 10-13, 1978. (Wischow 14 Affidavit, Attachment 8.) Paragraphs 10 and 11 of the 15 details portion of the NRC Inspection report describe the 16 reviews that NRC inspectors made on a routine basis of 17 Quality Assurance audits and nonconformance reporting. ! 18 Paragraph 10 describes an examination of the nine Quality 19 Assurance audits performed during the period from May 25, 20 1978, through July 6, 1978. The NRC Inspection report 21 concludes that fourteen findings were identified and that 22 corrective actions had been initiated. 23 Paragraph 11 describes the review of PGandE Non-24 conformance and Minor Variation Reports generated since 25 June 3, 1978. PGandE Nonconformance and Minor Variation 26 Reports dealing with Quality Assurance Audit No. 80422 were C- --

                                               . _ = .                                    -  .-

J

       ~

1 generated from June 12 to June 15, 1978. The report goes es.t. . . . - .

                                                                                                          .w :h     .

492., 2 to say all deficiencies appeared to be properly classified 5.",:; 3 as either an NCR or MVR and no items of non-compliance with'!.4~. 4 NRC requirements were identified by the inspectors during 5 the review. 6 This process reflects that NRC I&E monitored site 7 auditing and problem-solving actions on a routine basis to 8 assure that PGandE and its contractors adhered to quality 9 requirements. 10 CONCLUSION 11 As the foregoing information reflects, the NSC 12 audit was neither an accurate nor a total assessment of the i 13 Pullman Quality Assurance Program. 14 Indeed the NSC audit precipitated other audits, 15 which disclosed that the Pullman quality program was an 16 overall acceptable program needing only minor improvements 17 in some areas. Any identified deficiencies were documented j 18 in accordance with approved Quality Assurance procedures and 19 promptly corrected. 20 Contrary to Joint Intervenors' assertions, the NSC l 21 audit findings were thoroughly analyzed and appropriate 22 action taken. More importantly, the response to the NSC 23 audit by PGandE and Pullman demonstrates a fully functioning 24 /// 25 /// 26 /// gm.. .. ... . g .s. . . . - m,---..i_~_,_.___._

1 and effective quality program. Therefore, we urge that the . ju 2 Board deny the Motion to Reopen. 1. . ; 3 4 Respectfully submitted, 5 ROBERT OHLBACH PHILIP A. CRANE, JR. 6 RICHARD F. IACK5; Pacific Gas and Electric Company 7 P. O. Box 7442 San Francisco, CA 94120 8 (415) 781-4211 9 ARTHUR C. GEHR Snell & Wilmer 10 3100 Valley Center Phoenix, AZ 85073 11 (602) 257-7288 I 12 BRUCE NORTON Norton, Burke, Eerry & French, P.C. 13 P. O. Box 10569 Phoenix, AZ 85064 14 (602) 955-2446 15 Attorneys for Pacific Gas and Electric Company 16 By ' > 1 Richard F. Locke 19 20 DATED: September 21, 1983. 21 . I 22 23 , 24 25

26

_,.___ 3_ _ _3 _

l

                                                                                  .             .                        . /16.*Q' a-
                                                                                                                               .:.v v.

a., . UNITED FFATES OF ANSRICA , NUCLEAR REGULATORY C000625SION

                                                               )

In th3 Matter of ) .- Je

                                                               )      Docket No. 50-275                          -
                                                                                                                                "f
   ' PACIFIC Gh5 AND ELECTRIC COMPANY )

Docket Ep. 50-323 *

Diablo Canyon Nuclear Power Plant, )) .s q ..c ! -

Unito 1 and 2 - . 3 CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (hnvo) been served today on the following by deposit in the United States mail, properly stamped and addressed: Judg3 John F. Wolf Mrs. Sandra A. Silver 1760 Alisal Street Chairman San Luis Obispo CA 93401 Atomic Safety and Licensing Board CS Nuclear Regulatory Comunission Mr. Gordon Silver Nachington DC 20555 1760 Alisal StreetCA 93401 San Luis Obispo Judg3 Glenn O. Bright Atomic Safety and Licensing Board

• John Phillips, Esq.

 '      98 Cuclear Regulatory Comunission                               Joel Reynolds, Esq.

DC 20555 Cachington Center for Law in the Public Interest "~ 10951 W. Pico Blvd. - Suite 300 Judg3 Jerry R. Kline Los Angeles CA 90064 Atcaic Safety and Licensing Board

'      - US Cuclear Regulatory Comunission                              David F. Fleischaker, Esq.

l C3chington DC 20555 P. O. Box 1178 Oklahoma City OK 73101 Mro. Elizabeth Apfelberg  ; c/o Setsy Umhoffer Arthur C. Gehr, Esq. ' 1493 Southwood 93401 Snell & Wilmer Can Luis Obispo CA 3100 Valley Bank Center Phoenix At 85073 Janice E. Kerr, Esq. Public Utilities Comunission

• Bruce Norton, Esq.

Stato of California Norton, Burke, Berry & French, P.C. 5246 State Building F. O. Box 10569 350 McAllister Street 94102 Phoenix AE 85064 Can Francisco CA , Chairman Mrs. Raye Fleming Atomic Safety and Licensing 1920 Mattie Road Soard Panel Ch311 Beach CA 93449 l j US Nuclear Regulatory Comunissian - Washington DC 20555 Mr. Frederick Bissler

• Sc:nic Shoreline Preservation Ccnference, Inc.

4623 More Mesa Drive Santa Barbara CA 93105 l *Via Sky Courier . t

                                                                         .,                                        e L         - - - - - - ---         - . . - . . - . _ _ _       _
                                                                            ---~~------a-~,s,,-     ,;,_     _

} t .. t .. Chairman

• Judge Thomas S. Moore Atomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing g.

US Nuclear Regulatory Commission Appeal Board , ,T . ..S DC 20555 US Nuclear Regulatory Countissiedl :,4.; Czhington , % ., Washington DC 20555

                                                                                    ;F
  *Sscrotary US Nuclear Regulatory Commission

• Judge W. Reed Johnson Cachington DC 20555 Atostic Safety and Licensing Appeal Board Docketing and Service US Nuclear Regulatory Cosmaission Attns Washington DC 20555 section 0 Lawrcnce J. Chandler, Esq.
• Judge John H. Buck Eenry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Comunission N2chington DC 20555 Washington DC 20555
• Michael J. Strunwasser, Esq.

Mr. Richard B. Hubbard Susan L. Durbin, Esq. MHB Technical Associates Peter E. Raufman, Esq. 1723 Hamilton Avenue Suite K 3580 Wilshire Blvd. Suite 800 San Jose CA 95125 Los Angeles CA 90010 Mr. Carl Neiberger

• Maurice Axelrad, Esq.
• Telegram Tribune Lowenstein, Newman, Reis, and P. O. Box 112 Axelrad, P.C.

San Luis Obispo CA 93402 1025 Connecticut Ave NW Washington DC 20036 p Dato: September 21, 1983 Richard F. Locke

       *Via Sky Courier

3 f? e[r 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY C000tISSICBT . g# 4. 2 Before The Atomic Safety And Licensing Appeal Board 'j] ;,[ 3 y 4 5 6 ) In the Matter of Pacific Gas ) Docket Nos. 50-275 0.L. 7 and Electric Company (Diablo ) 50-323 0.L. Canyon Nuclear Power Plant, ) (Construction Quality 8 Units No. 1 and 2) ) Assurance)

                                                          )

9 10 11 AFFIDAVIT OF RUSSELL P. WISCHOW 12 13 14 I, Russell P. Wischow, being duly sworn depose and l 15 state as follows: l 16 1. I am currently employed by Pacific Gas and l 77 Beale Street, San Francisco, 17 Electric Company, California; my title is Manager, Geysers Project. During 18 19 the period from September 1,1976 through January 31, 1978, 20 I was Director, Quality Assurance Department. A copy of my I 21 professional qualifications is attached (Attachment 1). 22 have read the Joint Intervenors' Supplement dated 23 September 9, 1983, and have the following comments. 24 2. In July 1977.PGandE requested Pullman Power 25 Products Corporation (Pullman) to have an independent audit 26 performed of the work Pullman had done at Diablo canyon with l l

                                                  /l 0 / en         m e   QQ-s 3

T)U/W)U#W'

i l

l l l

 % 'e 1          particular attention to the adequacy of installed hardware.    ., ,,

Z. . 2 Pullman is the principal piping contractor for Diablo Canyon e 3 Units 1 and 2. Pullman was issued American Society of .- 4 Nechanical Engineers (ASME) Certificates of Authorization 5 (NPT and NA) in December 1972 which were renewed on 6 October 14, 1977 (Attachment 2). Pullman contracted with 7 NSC to have the audit done and PGandE concurred in that 8 selection. The audit was performed by NSC from August 22 9 through September 20, 1977 and the Report submitted to 10 Pullman by letter dated October 24,1977. (Attachment 3.) 11 3. I testified at the October 1977 hearings in 12 San Luis Obispo as to the adequacy and content of the PGandE 13 QA program, procedures, policies, audits, and implementation j 14 thereof. The NSC audit was not complete at that time and no 15 definitive results were provided for us to review and 16 evaluate prior to early 1978. 17 4. After receipt of the NSC audit report Pullman l 18 conducted an internal review of the Report during the period 19 October 1977 through January 1978. Pullman determined that 20 the NSC had directed the audit primarily toward a review of 21 program, procedures and policies rather than to concentrate 22 on the adequacy of the installed hardware as was intended by 23 PGandE. Pullman also concluded that NSC performed the audit 24 of the 1971-77 Pullman QA program against the 1977 MRC 25 regulations and interpretive guidelines rather than against 26 the regulations and interpretive guidelines that were i

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

ej 1 applicable at the time that the work was done. Furthermore,. w. _., 2 to some extent, the audit was also performed and evaluated

                                                                                                   .I.-       -

3 against NSC internal guidelines and opinions rather than 'i. x 4 what was actually required by the regulations, guidelines, 5 and applicable codes. 6 5. In mid-February 1978, Pullman provided PGandE 7 with a draft of its review together with a copy of the NSC 8 report. Pullman formally forwarded its response and the NSC 9 Audit Report to PGandE on April 11, 1978. (Attachment 4.) 10 PGandE reviewed these documents in February-March 1978 and 11 held discussions with Pullman concerning the findings. 12 PGandE agreed that the NSC audit was misdirected in that the 13 hardware installed by Pullman had not been audited by NSC as 14 was intended. We concurred with Pullman that many of the 15 NSC opinions were not consistent with the QA requirements at 16 the time that the work was done and, in some instances, the 17 opinions were inconsistent with the then-current 1977 i 18 regulations and requirements. Regardless of this 19 misunderstanding, we required appropriate corrective actions 20 to be taken on the results of this audit in accordance with 21 the then current PGandE Corporate QA Program. 22 6. Furthermore, I established a special review 23 team, reporting directly to me, to review and evaluate the 24 NSC audit report and to perform an audit of what NSC was 25 supposed to have done; i.e., audit the Pullman physical work 26 at Diablo Canyon. This audit was specifically designed to:

                                                                    .__       _ _ .__ ___ _ ___ _.                         _ . _ _ _ _         c____-.      __ _ _ a        _:_1 _. . _ -

                                                                                                        .,u.-

( . 1

• Determine if the Pullman QA program met the , , .

2 requirements of the applicable regulations, codes and ' 3 standards at the time that the work was done; T:(  :,. 4

• Determine if the NSC findings were valid; and 5
• Verify if the components and supports installed by 6 Pullman conformed to applicable specifications, 7 drawings, and quality standards.

8 7. The PGandE audit was conducted front April 2 9 through June 1, 1978 and a summary report submitted to Mr. 10 J. D. Worthington, Executive Vice President and the 11 applicable departments on June 13, 1978. In the cover 12 letter of this audit report, I concluded that the Pullman Program met applicable requirements. (Attachment 5.) A 13 14 separate report which reviewed the NSC audit findings in 15 detail was submitted to Mr. R. S. Bain, Manager, Station l 16 Construction, on June 16, 1978. (Attachment 6.) 17 8. Corrective actions as a result of the PGandE 18 audit and review were identified as either Non-Conformance 19 Reports (NCR) or as Minor Variation Reports (MVR). The department, through continuing on-site 20 PGandE QA 21 surveillance efforts, assured that identified corrective 22 cctions were taken, results were evaluated and the 23 deficiencies or non-conformances were closed out in 24 accordance with the PGandE QA Program. (Attachment 7.) l 25 9. This documentation was available both on site 26 and in the General Office for NRC inspection. An NRC _ _ _ _ _ _ . . _ _ _ . _ _ , - ==____...e__

               ^ -

l. 4 l4' i 1 inspection was made during the time period after the audit  : p 2 results were reported and while corrective actions were ,d..- l ~E 3 being taken by PGandE and Pullman. (Attachment 8.) t - 4 10. The foregoing actions taken by both Pullman 5 and PGandE forcefully demonstrate that the PGandE QA program 6 was responsive to the applicable NRC quality requirements 7 and that Pullman had an effective quality program. 8 Deficiencies were identified and corrective actions were 9 taken in a prudent, prompt manner consistent with good 10 quality practices. 11 11. Attachments 2 through 8 to this affidavit are 12 true and correct copies of documents in official PGandE 13 files. 14 I 15 Dated: September 21, 1983 16

                                                                    . :: =            'J w 18                                           ' RUSSELL P. WISCHOW '

19 subscribed and sworn to before me 20 this 21st day of September, 1983 C. T. NEAL MADISON 21 u.t *ao COUNTY oF 19 Nortf TEUC """ 22 0-[ ~ MM a,- u n.sm C. T. NEAL-MADISON 23 Notary Public in and for the 24 City and County of San Francisco, State of California. 25 My commission expires f 26 December 27, 1985

Professional Qualifications of _ () Russell P. Wischow Education , Ph.D Chemistry, Vanderbilt University 1958 M.S. Chemistry, North Dakota State University 1952 B.S. Chemistry, North Dakota State University 1951 Registration Professional Engineer, Quality Engineering, State of California Professional Societies American Chemical Society Fellow, American Institute of Chemists Sigma Xi Project Management Institute Professional Experience September 1976 - Present Pacific Gas and Electric Company () - Director, Quality Assurance 9/76 - 11/78 Geysers Project Manager 12/78 present April 1970 - September 1976: President, Nuclear Audit and Testing Company and Vice President, E. R. Johnson Associates, Inc., Washington, D.C. September 1967 - April 1970: Director, Division of Nuclear Materials Safeguards, U. S. Atomic Energy Commission, Washington, D.C. October 1965 - September 1967: Assistant General Manager, Nuclear Fuel Services, Inc. , Washington, D.C. April 1963 - October 1965: Supervisor, Chemistry Department, Martin Company, Baltimore, Maryland June 1952 - April 1963: Senior Research Chemist, Callery Chemical Company Company Group Leader, Union Carbide Nuclear Company Summary over thirty years experience. Management positions were in regulatory, government, research and development, chemical process, design, construction, plant operations, and project management activities. 1 O

6

                   ..                                                                r.       ~.
              +                                                       s          -
                                                                                       *           -;a-              -

1-- - f;--- - __ i t 4 m r e -s

                                                                    ~'

W: = IB AMERICAN SOCIETY OF MECHANICAL ENGNERS L< r . l, Certi6cate of Authoriution

                     !                                                                      Number N .       592 2 i

H.w. rELLOGG CO. DIV. OF PULLMAN, INC. g THIS IS TO CERTIFY thar Pacific Gas and Electric Co. Nuclear Station, Diablo Canyon, Cal. i' is hereby authorized to use the. "NPT" symbol of The America >e Society of Mechanical Engineers for f . Classas 1, 2, 3 4 HC Field Fabrication of

                  '                                                                  Nuclear Parts , Appurtenances , and Piping
                                                                                    ,Subassesblies, 72 inches, maxiem diameter, at Diablo Canyon site, Units 14 2 only.

k 1 in accordance with the applicable rules of the Boiler and Pressure l

                        ,                                         Yessel Code of The American Society of Mechanical Engineers.

l , The use of the Code symbol and the authority granted by this { certifcate of anthoritdlion are subject to the fron*sions of 164 j V ggreemerti set forth in the afplication. Any construction stamped l with this symbol shall have been built strictly in accordance with i, the provisions of the Boiler and Pressure Yessel Code of The + , . American Society of Mechanical Engi>teers. THIS AUTHORIZATION expires on completion of contrac_t

                              ,                                   Authorized on               O'Cttb*T 18s 1972          for d                                       THE AbERICAN SCCIETY OF MECHANICiL ENGINEERS ly the BOfLER AND PRESSURE VESSEL COMMITTEE
                               ]

l Chairman . . $xh . i - p-o secretary L& h ( __ _ l y __f _

                                                                                   =    < - - ~ , , :c- - -

4 - w -~" minw.,c- - _9 1 p - n ..

p. . .

                                                                     -,- - - _ - - - - ,     -    -A   ..

p' t V

      ,     a Oh ,

' M 1 0 --

E 'S

m ._.

l , Till AMERICAN SOCIETY OF MECIIANICAL ENGINEERS

            ;                                   Certipcate of vruthorization.                                                         i Number N -                10 s.2                                              \   .
            '*                                                                                                                      i
                                                                                                                                                          ~

THIS IS TO CERTIFY that M.W. KEt,thCC CO. DIV. OF_ POLI. MAN. INC. . Pacific _ Gas and Electric Co. Nuclotr Station, Diablo Canyon, Cal.

                                                                                         "NA"                                        j is hereby authorized to use the
                                                                                                                                     'i ;

symbol of The American Society of Mechanical Engineers for d Classes l, 2, 3 4 MC Field Installation of ... Nuclear Components. 72 inches maxirum diameter .Y 1 : at Diablo Canyon site, Units 1 4 2 only. O in anordance with the applicable rules of the Boiler ,md Pressure ,i! l Yessel Code of The American Society of Mechanical Engineers.

            '                      The use of the Code syrnhol and the authority granted by this                                      }

certificate of authorization are subject to the provisions of the ll agreement set forth in the application. Any construction stamped

l. ,

l with this symbol shall have been built strictly in accordance with the provisions of the Boiler and Pressure Vessel Code of The Americ.m Society of Mechanical Engineers. [

            ' i l.j THIS AUTHORIZATION expires on                               coroietion or cermt                      ,

j ' 1 l' 8 Authorized on DeCWher % 1272 for \ k h - H P

                       )           THE AMERICAN SOCIETY OF MECHANICAL ENGTNEERS by the Boil.ER AND PRESSURE VESSEL COMMFITEE                                                b l

if I cs t- . [ a/4. . O J sa,ac.,, wq c 4- H  ! c mmjj! p p -- e j x - p _ _ - -

                                                                                                                 . . . . .                                  j

 ,    yu m:=== :-=w_w                                                                            -= - :                          +=;                  '

5 - s -!! t H EKL J  ? e +fs,, - c _. u;:w is

                                                                               ~

s .. wl - TE AMER CAN SOCIETY OF MECHAN: CAL ENGINEERS 4

                                                                                                                                    ~

Certikate 0.f vruthorizatien J Number N. 3,2-2 h THIS IS TO CERTIFY that txz M. v. ntioco cmPANY. - i] A DIVISION OF PULDtAN, INCORPORA'IZD; REACE ROAD) , g vru1AssPoRT. PEWSYLyANM 17701 , k is hereby authorized to use the KPt - t .) symbol of The American Society of Mechanical Engineers for l j FIELD FABRICATION OF CLASS 1, 2, 3 & HC CO(PONENT PARTS & APPURTENANCES AND CLASS 1, 2 & 3 PIPING SUBASSEMBLIES AT ' Jin i '$ n!E DIABLO CANYON NUCLEAR POWER STATION, Utr1TS #1 & #2; AVIIA BEACH, CALIPORNIA ONLY

                                                                                                                                                 !h
                                                                                                                                                 ;        )

j l f., in accordance with the applicable rules of the Boiler end Pressure } [i

     $d                     Vessel Code of The American Society of Mechanical Engineers.                                                         Q
             !.$            The use of the Code symbol and the authority granted by this                                                         l         l
      }%                    certifcate of authorization ere subject to the provisions of the                                                     l l
      ,1,                   egreement set forth in the e fication. An construction stamped                                                       111 I

with this symbol shall have een built tiri ly in accordance with l

            };;             the provisions of the Boiler end Pressure Yessel Code of The American Society of Mechanical Engineers, f(

y ka L L s l-i s THIS AUTHORIZATION expires on _ ocToeER 14, 1980 ' 8 ;I 1 Asthorized og DECEMBEA 18,_ 19_72 for

         %                                          RENEVED:  OCTCEE R 14, 1977                                                                    ,

d k THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS ( [j l 1 6716e BOILER AND PRESSURE VESSEL COMMITTEE i t

                                                                                                                                               .             l' 1                               l M                  ,
   <                                                                    sareiri                \,3Cb \ k 2

4 a x-=-= m s+-e r n n?

         %g_ w r = _ = =

m - e-

p=&wz=%2n=g=a+ck&W 2+6-l_

                   .ph-b l           1 K

E ?. . S l.

u. - w .

l

                                                                                  'O 1                           TIE AMER CAN SOCIEH 0F MECLIANICE ENGINEERS r

[ - [ Ce# ate of Authorizatto" .

                                                                                                                         ~

l Number N - 393-2 _ 3

                           !                     THIS l' TO CERTIFY th2e THE M. W. E LLOGG COMPANYr                                '

l A DIVIS40H OF PULIRAN, INCORPORATED; REACH ROAD; g t@ VILLIAMSPORT, PENNSYLVANIA _ _17701 f 1 .

                                                                                                                     .         q
                 "         3                     is hereby authorized to use the     NA        -
                                                                                                                                    '    i symbol of The American Society of Mechanical Engineers for                              l J                       FIELD INSTALLATION OF CLASS 1, 2 & 3 CCHPONENTS AT THE                                 8
          } J                                    DIABLO CANYOH NUCLEAR POWER STATION, UNITS #16 f 2;                           i[$'

ilt - AVILA BEACH, CALIFORNIA ONLY {j y

                                                                  -                                                              u in accordance with the applicable rules of the Boiler and Pressure               }

l " 1h Yessel Code of The American Society of Mechanical Engineers. h pfr The use'of the Code symbol esd the authority granted by Ibis  ; 6 . certifcate of authorization are subject to the provisions of the 7 li agreement set forth in the application. Any construction sto;nped q j with this symbol shall have been built strictly in accordance with l

                       !)

the provisions of the Boiler and Pressure Yessel Code of The , l American Society of Mechanical Engineers. ' 4 ,$, l . THIS AUTHORIZATION expires on MTOBR 14, 1980 Autl> ors' zed on M 3El 18* 19I2 RENEWED: OCTOBER 14, 1977 for '

                                                                                                        ,                                7,        1 l

THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS j i l J( l hy the BOILER AND PRESSURE VESSEL COMMITTEE 1 , i l l a%= msg = = =

                                                                                             =
                                                                                                 %            - w+tk 3

e-1 1 1 .  :

fw hUCLCR2 4 SERVICC3 n ant'tavt ur ca-scu.catnamus== ut==c m =25a - CORPORRT10Ti, TW4914590 243s October 24, 1977 i NSC-QAS-KEL-003 , JW-77-072 Mr. Edward F. Cervin Chief Engineer / Quality Assurance Manager Pullman Power Products Post Office Box 1007 Williamsport, Pennsylvania 17701 ,

Subject:

Audit Report of Diablo Canyon Effort

Dear Mr. Cervin:

The audit, conducted under your cognizance, of the Diablo Canyon work ef-fort has been completed end is documented in the attached audit report. Section VI, " Summary," of the audit report contains the audit team's over-all evaluation and conclusions concerning the work performed at Diablo O Canyon. To facilitate corrective actions, as much d, tail and as many d specifics as possible have been included in the audit report, which ac-counts for the length of the report. If any additional details are re-quired, do not hesitate to call me. It is my understanding that informatien to confirm the disposition of the audit findings by Pullman Power Products and eventually by Pacific Cas and Electric Company will be transmitted to me. As.ve discussed, a copy of the letter transmitting the audit report from Pullman Power Products to Pacific Cas and Electric Company will be sufficient to confirm your dispo-sition. The precise method of verifying Pacific Cas and Electric Company disposition was not defined, but you did commit to requesting that Pacific Cas and Electric Cospany send me a copy of any official corsunicetions con-cerning their actions relative to the audit. I trust that you have been able to obtain Pacific Cas and Electric Company's. concurrence. In behalf of the audit team, I would like to express my appreciation to all the Pullman Power Products personnel for 'their cooperation and to you for your personal attention and involvement in the audit. Ve truly yours. Of (,4lfbr dackWeber

    '                                                                       Audit Team Leader Attachment

__ _ . _ . . - . - _ . , . - , - - . - - - . _ _ . . . _ - . . , , . , _ _ . _ . ~ . . . . _ - . . , _ _ , -

             -,  e - +-a-- --o - -s  - -,..      - a     -                 a   w-.-

e O F

c(o-e i

S AUDIT REPORT PULLMAN POWER PRODUCTS WORK SCOPE AT THE DIABLO CANYON SITE O a 9# t 22 thr s* 5 at 6 r 2o. is77 - 6 9 l e 4 e e 9

   >e

lI 1. INTRODUCTION A. Audit Scope and Purpose - A quality assurance audit wes performed on the PutIman Power Products work scope at the Diablo Canyon site. The purpose of the audit was to evaluate the performance of the Pullman Power Products Diablo Canyon Site Organization with respect to the Quality Program and contract-requirements. The audit was performed under the cognizance of Mr. E. F. Gerwin, General Manager, Quality Assurance, Pullman Power Products and, as such, was an Independent, Internal audit of the Pullman Power Products Diablo Canyon work scope. The scope of the audit included the following: (1) The organizational arrangement and the Independence of the quality organizaticn. (2) The qualifications and certifications of personnel performing

(. the work. .

(3) The Quality Assurance Program, including the procedures and instructions by which the work is accomplished. l (4) The implementation of the Quality As'surance Program. (5) The systems by which deficiencies are found, reported, tracked, I and corrected. (6) The records and documentation system. . (7) The workmanship of the fleid-fabricated and Installed items. (8) The status, adequacy, and ef.fectiveness of receiving Inspection, warehousing, Installatio'n , welding, heat treating, NDE, installa-tion inspection, testing, and records functions for installed ( (O , 1

 #                                                         - _ . - . _._._.,,.-,._.,___,,_.mm~.      ._,_m_-,~     . ,.m_..,_,_,

and erected piping, field-fabricated piping (<_2-inch diameter), piping supports, piping snubbers, piping restraints , weld rod, . and material (excluding the Primary Coolant System) examined by nondestructive testing, as appropriate. . The audit was performed by identifying each system or program that is used to control the work effort and sampling those systems or programs until a conclusion could be reached concerning the adequacy or in-adequacy of that system or program. The Pullman Power Products effort at Diablo Canyon was initiated in 1971, based on the contractual agreement of May 1970 between Pullman Power Products and Pacific Gas and Electric Company. During the time period of 1971 to the present, the requirements relative to the Pullman Power Products work scope have changed. The

       - ' audit scope and purpose were to evaluate the Pullman Power Products

[ work effort against the codes and standards In' effect at the particular time that the work was being performed. When requirements are issued, there is always some room for Interpretations concerning what is an acceptable method of satisfying these requirements. During the 1971 to 1974 time period, a number of ANSI standards were promulgated to define acceptable methods of satisfying 10 CFR 50, Appendix s. It is required that organizations revise their quality programs to sat-Isfy present interpretations. In areas requiring Interpretation, the quality of the work effort at Diablo Canyon was measured against the current ANSI standards and Regulatory Guides, accepted today as valid Interpretations of regulatory requirements. The long time span and the specific time interval during which the work effort was conducted should be considered when reading this audit report. l ( - ik C .,_ i . L .

(

8. Audit Team ,

The audit team consisted of the following Nuclear Services Corporation personnel: ' Jack Weber, Audit Team Leader G. J. Larsen T. C. Newnan (part-time) G. W. Rowe C. Audit Report . The audit report is divided into six parts: Section I, " Introduction"; Section 11, " Audit Preparation"; Section li t , " Entrance Intervied'; Section IV, " Audit Findings"; Section V, " Exit intervied'; and Section VI, " Summary." Corrective actions will be determined by the appropriate Pullman Power Products personnel upon receipt and review of this audit report. NO e { l l l . ( 0 3- .

 * ,., ..,- ,-,-- -    - *  .,.,..,-,_,-,v_.-,.------._.-- -,r.-
                                                               ,     .._,-,--,,,.,.-.-.,,..-..-.-,..e,,-,.-----..---..._--,--n--                                   _ - - - - , . . - - - -

'I II. AUDIT PRE'PARATION A series of meetings were held in which the following tentatife schedule was established: j o Preparation of checksheets *  ; e Receipt and review of Pullman Power Products Quality Program documents and contractual commitments to Pacific Gas and Electric Company . o Finalization of checksheets e Entrance interview e Audit of Organization, Personnel qualification and Certification Program, Document Control Nonconformance Program, Auditing Program o Feedwater Systems, Unit 1 and Unit 2

                                                                           ~

e Main Steam System, Unit 1 e Chemical and Volume Control System, Unit 2 e Residual Heat Removal System, Unit 1 . e Safety inspection System, Unit 1 e Containment Spray System, Unit 1 e Component Cooling Water System, Unit 1 she schedule was changed to meet the progress and findings of the audit, but the full scope of the audit was achieved. (- (O 4

                                                   ,.,,..,.-,_,.,_n-         - -,. -- -   - - -   -

a

( lit. ENTRANCE INTERVIEW

                                                                     '                ~

An entrance Interview was held August 16, 1977, at the Diablo Canyon site to introduce the audit team. In attendance at the entrance interview were: . Jerry Arnold Pacific Gas & Electric Co. Diablo Canyon Site Quality Assurance Coordination Al Eck Pullman Power Products Quality Engineer, Central Staff Rick Etzler Pacific Gas s Electric Co. Lead Mechanical Engineer Gerry Larsen Nuclear Services Corporation Auditor Bill Rowe Nuclear Services Corporation Auditor Pete Runyan Pullman Power Products Fleid Quality Assurance Manager John Ryan Pullman Power Products Resident Construction Manager Mike Tressler Pacific Gas & Electric Co.

• Station Superintendent Jack Weber Nuclear Services Corporation Audit Team Leader During the entrance Interview, a discussion was held of the progress and problems associated with the Pullman #ower Products effort and the present status of the work effort. The scope and schedule of the audit were discussed, and agreement was reached to perform the audit in accordance with the schedule presented in Section il above.

Mr. J. P. Runyan, Field Quality Assurance Manager, Pullman Power Products, and his staff were designated as the audit team contacts. O f

((O iv auoi' "oi"os The audit findings are divided into the 18 sections consisteg with , 10 CFR 50. Appendix 5. The audit findings are given to present the status of the program and, therefore, include both the acceptable and ' unacceptable areas detected during the audit. e IO e (0 (

                                                                ,     .-_._--_--_a-...-.          _ _ . . . . . _ . - . - . . . _ . _ . . _ . _ _ . . _        - _ . . - , _ . - _ _ - . _ . . - _ . _ .. ._

 ! F Criterion 1.                 Organt'zation I[])

1. A current organizational chart does exist. . .

2. Procedures KFP-1 and KFPS-1 do describe the quality organization. .

as well as some of the functional responsibillt,les of the quality organization. 3 The Fleid Quality Assurance Organization has performed functions other than those described in KFP-1 and KFPS-1; and some functions were outside the quality responsibility, i.e., writing an,d approving . Engineering Specifications, performing welding engineering functions, approving engineering changes. These activities raise the question of the qualification of quality Assurance personnel to perform these r functions and the problem of requiring the Field Quality Assurance Organization to audit its own performance. 1

I' ~ 4. Procedures KFP-4, KFPS-4, KFP-6, KFPS-5, KFP-8, KFPS-7, KFP-S, and KFPS-8 do describe some of the responsibilities of the field Engineering Organization. The responsibilities of the other Field Construction Organizations are not described, nor are the full responsibilities of the Field Engl.neering Organization described.

i 5 The descrj ptions of Individual position responsib111 ties are in-adequate. Some elements of position descriptions exist in the KFP and KFPS procedures, and job descriptions exist for inspection and Inspection technician positions. No position descriptions exist for any of the upper-level site personnel. i 6. The description and controls of the interfacial relationship between Pullman Power Products and Pacific Cas and Electric Company are inadequate. The contract and some Engineering Specifications do describe some interfaces and mechanisms. However, for the greatest scope of the work effort, there is little to describe how the inter-

   '                                                  face will be managed and controlled. Some of the activities that
       )

J ( require Interface control are hydrostatic testing, reonconformance reporting, meetings, work on pipe rupture restraints, w& k on hangers, document control, reporting of deficiencies, responses to Pacific Gas and Electric Company audits, interfaces with other , Pacific Gas and Electric Company contractors that impact Pullman Power Products work, etc. 7 The description and the controls of the interfacial relationship between Pullman Power Products Field Organization and the other Pullman Power Products organizations involved in the Diablo Canyon effort are inedequate. The Quality Assurance Manual does describe some quality interfaces between the Field and Corporate Offices. However, there are no requirements for periodic reporting from the Field Quality Assurance Organization to the Corporate quality

 ;                                        Assurance Organization; there are no requirements for an upper-management review of corrective action reports, nonconformance reports, and personnal qualifications; the Interface between the        ,,

[O rieid Organization and the Paramoent shop is not described; the Interface between the Resident Construction Manager and the Corpo-rate Construction Manager is not described; the interface between . Field Quality Assurance and Corporate Quality Assurance is not described with respect to field purchases and Corporate quality Assurance auditing of those suppliers, l

8. The description and the controls of the interfacial relationship between the Pullman Power Products Field Quality Assurance Organiza-tion and the other Pullman Power Products Field Organizations are inadequate. The Quality Assurance Manual and many of the Engineering l

i Specifications describe Interfaces and mechanisms. However, the interfaces relative to the construction and engineering efforts in l regard to drawings approval; review of isometric, hangers, and { restraint document packages; welders logs; and control of the weld-Ing process are not described. h(o. w- .,n-- me, , _ _ . _ _ _ , , , _ _ , , , _ _ _ __ __

9 The stop work authority for the Field Quality Assurance Organization is not adequate. Procedure ESD-240 does describe ~the step work , authority for Hold Tags, but there are no mechanisms described or authority addressed for the circumstances when the Construction O'rganization elects to proceed through'a Hold Tag stop.

10. The Field Quality Assurance Organization does report to a sufficiently high level of management.

fO . e e

    .O
   %_)
                                             .g.

O w

((O Criterio ii. eroaram

1. The contract between Pullman Power Products and Pacific ens and Electric Company was signed in May 1970, prior to the enforcement of 10 CFR 50, Appendix s. The contract did contain certain quality ,

aspects that vere requirements for the Pullmar. Power Products work effort. Work was not initiated on the Diablo Canyon site until late 1971. when Appendix s had become a requirement (Appendix B was added to 10 CFR 50 on June 17, 1970, effective July 27, 1970 (35 FR 10498), and amended September 11, 1971, effective October 11, 1971 (36 FR 18301)]. Even though the contract was not amended by Pacific Gas and Electric Company to include Appendir. 8 as a requirement, Pullman Power Products was obligated to conform to Appendix 8 requirements; and the total quality program was evaluated against Appendix B and ANSI M45.2. While a written Quality Assurance Program exists, the program does not meet the requirements of 10 CFR 50, Appendix 8 or ANSI M45.2. The specific inadequacies of the program are described throughout ' the findings.

2. There is no description of the overall Quality Assurance Program.

Special Quality Assurance Instructions s're not described; the rela-tionship and purposes of the KFPS, KFP, and ESD procedures are not described; the Pipe support' Quality Assurance Manual is not described; and the relationship of the Pipe support Quality Assurance Manual to c

                                      -                      the balance of the Quality Assurance Program is not documented.

3 Procedures KFP-1 and KFPS-1 do provide a broad and generalized description of the scope and applicability of the Quality Assurance Program. These procedures also refe'rence the contract between - Pullman Power Products and Pacific Gas and Electric Company. However, the total scope and appilcability of the Quality Assurance Program are not adequately described. The efforts relative to pipe rupture restraints, receiving and control of materials and components other than Pullman Power Products-procured,and the work as'sociated with anchor bolts are not adequately described. ( , D.-.--., . , . - , - - - _ - , . , _ . - , . . . - . . - . . . - - . _ , -.-.,.,e . . . , _ -- - --,-._-,.,_..,.,,,-,,,--.-.-,..-.,,-------------w.--------,------ y .y.--.-, -.--r-- - - - - - -

4. There is no evidence that upper management has performed scheduled reviews of nonconformance reports, personnel qualifications, and

                                                                                                    *            ~

corrective actions'. 5 There is evidence that upper management has performed reviews of . audit reports generated by Pullman Power Products and Pacific Gas and Electric Company.

6. The Indoctrination and training program requirements for personnel involved in inspection activities are adequate. Procedures KFP-2, '

KFP-3, KFPS-2, and KFPS-3 require training of NDE personn'el; Procedure ESD-237 specifies a training program for the NDE personnel; Procedure ESD-237 also describes a training program for Quality Assurance Fleid Inspectors.

7. The indoctrination and training program requirements for personnel involved in quality-related activities are inadequate. There is no

 ,                                         requirement for Indoctrination and training of welders, foremen, W                                   engineering personnel, warehousing personnel, etc.

8. There is no evidence that personnel have been trained to assure their familiarity with the procedures they are responsible for Implementing, except for welders, who have been traine*d and quallfled to specific i weld procedures.

1 4 e 6 .

   - -   ---,ng-,-   , - , , ..,.-.----,,,_--l,,_,,_,_ , _ , , _ _ _ _ , _ , _ , , _ _    __  _ _ _

Criterion Ill. Design control (

1. There is no design manual for the preparation of Isometgics and ,

fleid fabrication drawings.

2. Procedure KFPS-4 provides adequate control of the pipe support design effort.

3 Procedure KFP-4 requires that the Chief Field Engineer and C Fleid Quality Assurance / Quality Control Manager review field changes to Pacific Gas and Electric Company-approved drawings and specifications for ASME Code compliance. No written procedure for this review exists.

4. A mechanism does exist for checking and reviewing Pullman Power Products drawings. However, this mechanism is not described in a written procedure. Documentation of the implementation of this informal procedure does exist.

l S. The isometrics and field fabrication drawings do indicate the classification of systems.

6. Procedure ESD-205 does contain a classification of systems and the f requirements'for each classification.

7. The changes to isometric drawings and field fabrication drawings are

• Indicated on the documents, as well as the reason for the change.

Procedure KFP-9 establishes a mechanism to permit tracking of all revisions, i.e., the Chief Field Engineer is required to maintain a copy of all voided drawings. ,

8. Procedure KFPS-8 requires the Chief Field Support Engineer to assure that all supports are fabricated to the latest drawing revision. Rio mechanism exists to comply with this requirement.

l l l l--.

r(' Criterion IV. Procurement Document Control

1. Procedures KFP-6 and KFPS-5 adequately describe the responsibilities .

associated with fleid purchase order processing. Proceduce ESD-226 adequately describes the quality requirements for 2. purchase specifications of the usual Pullman Power Products scope of purchased materials.

3. Procedures KFP-6 and KFPS-5 do not require that the purchase order state that Pullman Power Products is given the right to gadit the .

subcontractor shop.

4. No written procedure permits verification of the selected supplier as one identified on the Pullman Power Produc'ts corporate-approved vendors IIst.

5 There is no mechanism by which Pullman Power Products Corporate is Informed of the procurement of safety-related parts, components, equipment, and material to assure that the selected supplier is placed on the Corporate audit schedule. l \ 1 l m -

l Criterion V. Instructions, Procedures, and Drawings .[g

1. There is no requirement that activities affecting quality shall be ~

prescribed by documented instructions, procedures, and drawings.

2. Many activities affecting quality are not described in procedures.

Among those activities are: hanger package review, pre-heating for welding, use of Note-0-Grams, use of Rejection Notices, and mainte-nance of F! eld Quality inspector Daily Logs. 3 Many activities affecting quality are insufficiently described

• in procedures. Among those activities are: Isometric package review, post-welding heat treatment, nonconformance reporting, Ninety-Day Weiders' Logs and Weekly Qualified-Welders Lists, and auditing.

4. The present procedures ere generally inadequate for providing direction to those performing the work. The procedures do not follow the flow of the work; many procedures are very long (over 10 pages); Insufficient information is given; important Information

(( }) is not provided or referenced in the procedure. 0 o 14 - N-----.---- . . - - . - . - - _ _ - - - , _

Criterion VI. Document Control

1. Procedures KFP-3 and KFPS-8 are adequate for field drawing control.

and Procedure ESD-253 is adeqt .e for pipe-support drawing control.

2. Procedures KFP-17 and KFPS-15 are adequate for control of the KFP and KFPS procedures and are appropriately implemented.

3. There is no procedure f or control of ESD procedures. ,

4. There is no procedure for control of Special Quality Asstarance Instructions.

5 The Pullman Power Products review of completed packages relative to. ,

• hangers and pipe restraints is not detailed in a procedure, nor is ESD-254 complete as to what is actually done for the isometric package.

Procedure ESD-254 does desc-ibe some aspects of " Piping System Docu-5 mentation Review." .

6. The Pullman Power Products log, Drawing Control index (KFP-9 and KFPS-8),

is maintained in a nonpermanent manner. The log is filled out in l pencil; and when the number of revisions exceeds the available space, the early revisions are erased to accomniodate the new revision. 7 No mechanism assures that the Pacific Gas ar.d Electric Company drawings being used as the reference drawings are the latest-Issued revision. Audits are frequently performed to determ!'ne that Pullman Power Products has the latest Pa:Ific Gas and Electric Company draw-Ings. However, the audit mee.hanism is not satisfactory when l't is the only mechanism.

8. There is no Weld Rod Requisition for one of the welders who partici-poted in FW-345 of Isometric' 04-500-139 1

O \

 . _~.---. _--._ . _ _ _a _             - _ -   . , - - , . - - _ - _ _ . - _ , - . _ _ _ . . - . . .                  . . - - - - - . . _ , , , , - - , . _ _ - - - , . - .-

l l l There is evidence that documents have been backdated and changed to j 9 meet requirements without any substantiation of the information. , e For Isometric 2-14-47: The Process Sheet was changed to sh:mw the completion of FW-192 on April 10 and April 11, 1974, approx- . Imately 19 months after the work was done. e isometric 2-14-8: FW-1673 was performed to Revision 2 of the isometric, which did not show FW-1673 Revision 3 of the Iso-metric, which included the FW-1673, was generated approximately one week after completion of the weld. It is therefo,re concluded * ' that FW-1673 was performed without the normal controls of a Process Sheet, a weld procedure call-out, and a call-out of NDE requirements. e isometric 2-14-53: FW-247 was completed February 20, 1975 Approximately December 1, 1975, the visual acceptance was signed off and backdated; and the Weld Rod Requisition was changed to show that more than the original quantity of one had been burned. e isometric 2-14-59: FW-268 was completed February 5, 1975 On December 2, 1975, the entry on the Process Sheet for removal of dams was signed off and backdated. There is no proof that the dams had been removed. o Isometric 2-26-417: FW-144. -145, -196, and -197 were completed on May 14, 1976. The Weld Rod Requisition had been altered to add FW-197 However, the Weld Rod Requisition shows that 14 rods had been burned, which seems improbable for the four welds.that were supposedly welded.

10. No procedure or requirement prohibits the changing or alteration of the records and documents that are necessary to track the work.

Field Process Sheets, Weld Rod Requisitions, inspection records, etc., should not be changed or should be changed only by Quality Assurance supervisory personnel and then signed and dated.

       ~

xre-ia. *res-i2. eso-239. d eso-255 r 4 a t ia tr c-(60 ii. eroc a r tions to assure that the correct documentation has been *assembled and . the system is ready for turnover. e CD . e 6 e e L-

( Criterion Vll. Control of Fe-chased Material,' Equipment, and Services

1. The interface between the Pullman Power Products Fleid Srganization -

and the Pullman Power Products Corporate Organization relative to selection and monitoring of suppliers' fulfilling field purchase . requisitions is inadequate.

2. Procedures KFP-7, KFPS-6, ESD-217, ESD-226, and ESD-261 are adequate for the performance of receiving inspection.

(D l k . + - -

Criterion Vill. Identification and Control of Materials. Parts, and

                           ' Components

1. Identification and control of piping and valves are adequately specified by Procedures ESD-200 and ESD-201.

2. Identification and control of weld material are adequately specified by Procedures KFP-12, KFPS-11, and ESD-202.

3. Identification and control of backing gas dams are adequately speci-fled by Procedure ESD-214.

4. Procedures KFP-8 and KFPS-7 are adequate for specifying that the identification of parts and components is to be recorded on the Field Process Sheet. The implementation of this procedure is adequate.

5 The isometric drawings and field fabrication drawings are the major documents for recording the identification of the parts, spools, and components. While there is no procedural requir=nent, this mechanism has been followed and is an excellent technique.

6. Identification of welds and welders is adequately described in Procedures ESD-203, -204, -221, and -243

7. Proper methods of marking are specified in Procedures ESD-200, -201,

              -202, -203, -204, -221, -223, and -243

8. Material control techniques for temporary pipe attachments are ade-quately described in Procedure ESD-232. ,

9 Procedure ESD-248 adequately describes kontrols c, f'or the repair of installed valves and for valve parts control.

10. Adequate control of snubbers, plate, and other components is achieved by using Procedures ESD-200, ESD-201, KFP-8. KFPS-7, and the practices associated with field drawing preparation. However, no procedures specifically address these items.

s .

I 11. Procedure KFP-20 provides an adequate mechanism to control nuts, bolts, etc.

12. Procedure ESD-223 does not give adequate instructions for the identi-fication and control of Class I Pipe Supports.

13 Procedure ESD-228 does provide adequate guidance for the marking of tools used In grinding stainless and carbon steel welds. e G 30 -

                                                                                  ~

edb= ___v---___ - _ _ - - ___i_

e - Criterion IX. Special Processes

  ~

1. Nondestructive examination has been properly specified as .

a special . process. Procedures KFP-3, KFPS-3, ESD-235, and ESD-256 adequately specify requirements for NDE personnel. *

2. The requirements for Field quality Assurance inspectors are adequately specified in Procedures ESD-237 and ESD-256.

3 The qualification and certification program for NDE and inspection l personnel has been inadequate. The records of the following person-nel were examined: D. R. Geske, T. L. Koch, J. E. Cawelti, G. P. l Keeler, K. E. Beck, L. Glass, W. R. Johnson, E. Stanton, C. B. Athay, R. G. Sears, D. S. Tutko, J. N. Shiromizu, V. J. Casey, J. A. Brasher, i L. F. Myrick. S. R. Stanley, H. Guest, D. E. Sentley, R. D. Kincade, l K. D. Guy, J. R. Bowlby, E. R. Jennings, A. L. Newton, C. C. Lenzi, J. J. Sisk, L. G. Thomas, A. A. Conques, and R. L. Marks. In vir-tually all cases, the individuals began performing their duties without fulfilling the specified requirements. The most prevalent discrepancies are: not completing the required training, not having proof of previous experience, insufficient time as Level I, unsigned tests, and insufficient background and experience. 1

4. NDE procedure qualification is adequately described in Procedures KFP-2 and'KFPS-2 as being the responsibility of the Manager of Qual-Ity Assurance, Williamsport Headquarters.

5 Welding has been properly specified as a special process. a

6. Welding procedure qualifications are adequately described in Proce-dure KFP-15 as being the responsibility of the Welding Engineer (Williamsport). .

7 Procedures KFP-15, KFPS-13, and ESD-216 are adequate for specifying welder qualifications. O(

                                              - ti ~

~-

, ((]

8. The certification of the following welders, by weld symbol, was examined arid found acceptable: U, AN, lH, P0, VD, QZ, NY, PD, JL, ET , HL , AY , MO , TQ, I Q, PG , KP , XC , FC , and ZC.

9 The certification of welder U was not ' signed. i

10. A number of procedures provide mechanisms for control of the weld-Ing process: ESD-203, -204, -215, -219, -221, -225, -227, -242, and

                                          -243              However, the control of the welding process has been inade-quate as follows:

e Records of welder qualifications prior to 1972 are no't available. I e The Ninety-Day Walders' Log was not maintained from August 1972 to December 1972. There is no Weekly quallfled-Welders List for that time period to substantiate that the welders were actually qualified. i e The Ninety-Day Welders' Log is not sufficiently detailed to ' determine if the welder is quellfled to perform certain proce-l dures. The Ninety-Day Welders' Log has been revised a number of times, and the detail has improved with each revision. Pre-l vlous to the latest revision (November 1974), the log was very poor in giving precise information relative to procedure and thickness ranges to which the welder was quellfled. e No procedure states what the Field Quality Assurance inspector uses as the primary means to determine welder qualification, the Ninety-Day Walders' Log, the Weekly Qualified-Welders List, or the Welder's Qualification Card. e No procedure specifies who is responsible for the Ninety-Day Walders' Log, the Weekly qualified-Welders List, or the Weider's Qualification Card; how the information is obtained; how the logs are used; to whom they are distributed; etc. l -

       .-->-,---------,--,-,--n,-.-        4 e-,,-rw,--          - - - - -    m-. -----n,-+-   - -        _----,------,---,-m-.--~e-,-----e            m-n.-w           < ~ ~ -       n-

                                                            ~

e Procedure KFPS-13 differs from KFP-15 in that tt does not permit a six-month extension of welder qualifications if the, welder has , been actively welding on some other welding process. Procedure KFPS-13 requires the welder to use the specific welding process within a three-mont'h period or be requallfled. There is no evi-dence of adherence to this requirement for pipe support welding. e Welder BF (W. Adair, 251) performed welding on FW-70, -72, -73,

           -76, -77, -78, -loos, -132, and -133 in isometric package 21-7 and FW-88, -90, -91, -92. -134 -135, and -1608 in isometric package 21-8. This welder was not qualified for the thickness range; and the welds were reported on DRs 2536, 2538, 2539, and 2899 In accordance with Pacific Cas and Electric Company dis-position, some of the welds were radiographed and found accept-able; Welder BF was qualified to the thickness range; and all the welds in question were accepted. This disposition is not permitted by 831.1, B31.7, and ASME, Section IX, which all f

specify that the welder must be quallfled prior to making pro-l U f duction welds. l I e Procedure ESD-219 requires random sampling of Inprocess welding, In

          . with the sampilng to be noted on the Field Process Sheets.

examining Fleid Process Sheets, it is obvious that the sampling by the area inspectors was not performed. e Procedure ESD-219 requires periodic auditing by the Welding Auditor. These audits were not performed until November 5. I 1973; and Pullman Power Products was not ,In compilance with this procedure for approximately 23 months. l e Procedure ESD-219 requires monitoring stainless steel welds for ferrite control. Howeve,r, the Severin Gauges wer's not on site until the beginning of 1973; and Pullman Power Products was not in compliance with this procedure for approximately 12 months. s

( e' Hangers are not welded in accordance with Pacific Gas and

     -                             Electric Company requirements. Mangers 2023-IV and 2039-2V are two exempt'es of a number of hangers observed thd are welded to the structural steel on the wrong side of the bracket.

e The interface of welding to other suppliers' parts and compo-nents is not clear. Welding is done to join Westinghouse and Paramount parts and components. The necessity for addressing . Impact property requirements for those weldments is not clear; in addition, the requirements for addressing impact property requirements for Pullman Power Products field welds are not clear. If impact properties are necessary, the acceptability of each weld that has been repaired and subjected to more than l one stress relief is Indeterminate because of the time at tem-perature limitations within the qualified weld procedure.

 - /

e some welders do not receive sufficient training. Welders,

     \J                             fabricating the pipe rupture restraints within the contain-ment, are welding heavy plate. Wtille these welders are quell-fled by virtue of welding heavy wall pipe, the techniques are different. The welders who were already qualified to heavy wall pipe were not given additional' training on plate.

I e There is no procedure for the preheating of weld joints. I e The initial results of the welding auditing (from November 5, 1973, to February 1974) Indicate that the following problems existed: .

• The welders did not understand shielding and purging.
• Tempil sticks were not used.
• Amperages were not within procedure Ilmits (mainly root

                                                                                                            - 2k -

l 7 m. _-, _ _, ._ .__.-* ,. . _ , , , _ . . _ _ _ . _ _ _ - _ .__.._,.--.__.___.___-mr -,,,,_......c . - - ,,.,,,___.,,_._,_y,,. _ __,,_.,_____ m_ ,,

welds and tack welds.

• Weld procedures were not available, and many welders did not know where to obtain them.

The oxygen analyzer was not available or not operative. Also, the time vs flow rate alternate technique was not used. Oven rod temperature control was not monitored by the welders. Many welders did not understand their duties and responsi-bilities. Based on a review of the Pullman Power Products welding audit reports and the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification require-ments.

11. Welding procedures for carbon steel welding require preheat and Inter-pass temperatures for material that has a carbon content in excess of 0.30 percent and a thickness of one Inch or more. There is no i mechanism by which the welder can determine carbon content.

12. Procedure ESD-221 does provide adequate guidance on weld repairs. -

13 Heat treating has been identified as a special process in the Pacific., Gas and Electric Company co'ntract (as well as in Appendix 8), but it has not been controlled as a special process by Pullman Power Products.

14. Procedures KFP-13 and ESD-218 provide controls of the post-weld heat I treatment process. The implementation of Procedure ESD-218 is acceptable.

15 cleaning has not been identified as a special process. e _,.. -,p-, , _m,._..,.,,.,ym, y,-_,, _ . _ _ , , . , , . ,e..,,~,,,--g,, _ _ _ . - . , _ , - , . . . ...

Procedures ESD-220, -224 -238, -242, -252, -258, -259, and -261 ((( ) 16. provide adequate guidance in cleaning and cleanliness of.the various , materials, parts, and components.

                                                                                                     ~

17 Procedure ESD-231 provides some guldence on hot and cold bending of small bore piping. The guidance is considered insufficient to assure that the bending is done properly to avoid high stresses and thinning of the wall.

18. Procedure ESD-238 provides adequate instruction in torquing of botting for pipe flanges.

19 Procedure ESD-259 provides adequate instruction for Installing Grinnell Snubbers.

20. Procedure ESD-224 provides excellent instruction for assembly and torquing of installed valves.

21. Procedure ESD-260 provides adequate instruction f'or Installation of Williams Rock Bolts.

22. Procedure ESD-230 provides good instructions for entering an in-stalled line.

t e a e

                                                                                            . gs .

e

                               ,-n ,. _.-, -,,,-- , - - - - - - - - - , . . - - - - - - , ,                                                        --   .

.(  .

Criterion X. Inspection

l. Procedures KFP-5, -8, and -14 thoroughly describe the int,erface between Pullman Power Products and the Authorized inspector.

2. Procedures KFP-8 and KFPS-7 provide the requirements for the Fleid Process Sheet, which specifies inspection points and inspector sign-off.

3 The Field Process Sheet references procedures to which the work and the inspections will be performed. .

4. The inspection procedures are detailed in Procedures ESD-206, -2Q7,

                                              -208, -209, -210 -211, -215, -219, -225, -233, -234, -236, -241,
                                              -243, -244, -249, -250, -251, -255, -259, and -260. These procedures are, in general, broad descriptions of the inspection process for the total range of the work scope and are adequate for that purpose.

5 For all inspection processes, there is no mechanism to provide the k inspector the particular characteristic to be inspected; the partic-ular acceptance criteria; the particular methods and equipment to be used; and provisions for recording results, other than acceptance for the particular inspection being made,. The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures that specify the use of particular equipment (such as some of the ultrasonic procedures).

6. The inspection process is generally not auditable. The practice of exhibiting an acceptance signature only does not permit auditing to determine if the Individual characteristics were examined, the correct criteria were used for acceptance, and the correct specific measuring devices were used.

         -                             7        Alargenumberofweldsin$ nit 2, system 14(FW-110,-111,and
                                                -112 in isometric package 2-14-31 are examples) were accepted for l

I

     ~ . _ . . , . _ _ _ _ _ _ _ . .

visual examination and thereafter accepted based on surface NDE (n inspection (MT or PT). Visual examination of those welds indicates -~ that the surface is not suitable for the performance of surface NDE Inspection.

8. For FW-110 (Isometric package 2-14-31), the Process Sheet Indicates that MT was performed; however, the Inspection sheet for PT shows that weld number, and the inspection sheet for MT does not show that weld number.

9 FV-83 (isometric package 1-10-9) was repaired in accordance with a valid Process Sheet. The radiograph of FW-83 does not exhibit the required R1 symbol, but R1 was Inked onto the radiograph. There is a surface defect that is questionable for acceptance to visual standards.

10. Isometric package 1-03-1 has a step that requires a Pullman Power j

Products inspector sign-off. This requirement was removed, and the l step was accepted by a Pacific Gas and Electric Company employee. j - 1 e e

       ---.,--.-----,-w.,-n-,-             , .,nn - - ,, ,   - - - , , , , , , , - - , , - . , , , . , _ , , . ,       .,-   _.,,--g , , , - - , - _ . - - -. -.-    , e.--.,,.-

Criterlon XI. Test Control (O. 4

1. Procedure ESD-229 adequately defines the methods'and inspctions ,

relative to performing hydrostatic tests.

2. There is no desc. Iption of the respons'ibilities of Pacific' Gas and Electric Company or of the Pullman Power Products / Pacific Gas and Electric Company Interface relative to hydrostatic testing.

3 Procedure ESD-229 is not adequate for describing the flow and authorities relative to the individual hydrostatic test procedures to be performed.

4. Hydrostatic test packages 7-2, 7-2A, 8-12, 9-12, 106, 106A, 106B, and 64 were examined and found acceptable.

5 The B31.1 and 831 7 Codes require that all piping be leak-tested, where practicable. Pullman Power Products is only leak-testing ( Class A and B piping and that Class C piping specified by Pacific Gas and Electric Company. Classes D, E special,'nd a E piping is not being leak-tested. A letter from Pa'cific Gas and Electric Company (dated January 13,1976) does exist, which states that Pacific Gas and Electric Conipany will assume responsibility for the leak-testing of Class C piping. There is concern that Pullman e Power Products is not discharging its contractual obligations (that specify compliance to B31.1 and 831 7) by not performing piping leak-testing to Code requirements for Classes C, D, E special, and E piping systems and, as a result, may be legally vulnerable. o I e w .,w., ---- ,n- . _,

Criterion Xil. Measuring and Test Equipment

1. Procedures KFP-11, KFPS-10, and ESD-213 describe an adequate call ~

bration program.

2. The calibration program did not require recalibration of thermo- .

couples until June 16, 1976. Therefore, there is no assurance of the accuracy of thermocouples used for pre- and post-welding heat treatment prior to June 16, 1976. Newly purchased thermocouples were required to be calibrated by the manufacturer. However, the manufacturer's calibration does not assure that the thermocouples have not been damaged during handling and shipping. . . 3 The calibration program has not been adequately implemented. e Paragraph 11.5 of Procedure KFP-11 and Paragraph 10.5 of Pro-cedure KFPS-10 require reinspection of materials and components if the measuring and test equipment is found to be out-of-call-bration. Except for hydrostatic testing and heat treating, the Identity of measuring and test equipment is not related to the ( inspections performed. e Procedure ESD-213 does not contain a mechanism to report out-of-calibration measuring and test equipment to Pullman Power Products. Some forms used by the calibration subcontractors only contain provisions for attesting to calibrating the equip-

       -                    ment to appropriate standards and have no provisions for record-l Ing the actual values obtained.

e The calibration records of recorders were confused by having two recorders identified on one record, and the acceptability of the records could not be determined. e Severin Cauges 2947 and 2971 were received on the' site in January 1973 Initial calibration was August 29, 1973; and the next calibration was November 19, 1974, for gauge 2947 and January 23, b m= -

1975, for gauge 2971. Procedure ESD-213 requires annual ( calibration. . . o Magnetic Particle Test Equipment Y-6 bas no documentation to verify calibration. e There is no documentation available to verify calibration of

         " Tong Test" ampmeters.

e " Tong Test" ampmeter TT2527403 was out of calibration for the period December 12, 1976, to January 31, 1977 No DK has been written against that instrument. e storage requirements for instruments are not specified. (0 l l 1

                                   +..                                                                            l

( Criterion Xill. Handling, Storage, and Shlpping

1. Procedures ESD-202, -215. -217, -222, -223, -240, -259, and ,

                                                                                                                                                               -261              ,

provide some information relative to handling and storage of mate-rials, parts, and components for the total scope of the Pullman , Power Products effort. (

2. Procedures for storage are generally inadequate. Procedures ESD-222, l

                                                           " Control Valves," and ESD-2D2, " Weld Material Withdrcwal and Control,"

are specific and adequate. Procedure ESD-215, " Visual Inspection," provides some guidance on storage. There is very little information " relative to how specific items are to be stored or the delineation of storage areas relative to the protection each area provides. 3 Procedure ESD-240 requires a segregated storage area for " scrap" material,and Procedure ESD-215 requires separate areas for material with Hold Tags and for P1 and P8 material separation. These proce-dures are adequate. However, they do not relay much.Information on how these segregated areas are to be established and maintained segregated. I

4. There are no procedures or manufacturers' instructions for the storage of flow Indicators and strainers, which were stored in the Pullman Power Products storage area.

l S. Handling procedures do not exist; and the only handling instructions are contained in ESD-222 and a number of other procedures, which con-l i tain a caution against the use of carbon steel in handling stainless steel. Procedure ESD-239 has excellent detalt as to the handl,Ing of Grinnell Snubbers during Installation. However, Procedure ESD-259 was issued January 27, 1977; and there is no assurance that materials, parts, and components were properly handled during the period prior to January 27,1977, when most of the Installation activities were occurring. _m...~, _ . _ _ , . , ,. . - - _ _ - . . , - ..,y.. ,m_,.- ., , y y,,m,__,,,-m_0__.___,_._ _,,,_,_,,__.______,._,._,,,,,.,.,,r.,__.. r_,_ _ _ _ , . - , _ _, ,._ .__.-

6. The present storage areas were found to be in excellent condition,

( with areas clearly defined, materials supported on adequate dunnage, and openings capped. 7 Procedures KFP-19, KFPS-17, and ESD-222 provide for an adequate storage surveillance program. Prior to October 31, 1973, the sur-ve111ance was performed using a checksheet that contained the stor-age requirements; after October 31, 1973, the checksheet was changed so that the storage requirements were not listed. While the sur-ve111ance program appears adequate, the checksheet used after October 31, 1973, does not appear adequate. (O( e e 4 1 - . L.

i

( Criterion XIV.

                                                           ~

Inspection, Test, and Operating Status

           )                                    The major mechanism that exhibits '+.he status of the work* is the

1. .

      ~

The Field Process Sheet provides for perfor-Field Process Sheet. mance status of some important fabrication steps and for inspection " status. However, many important fabrication steps are not Indicated by the Fleid Process Sheet: erection steps; cIsaning prior to in-t stallation of insulation; and some critical welding steps as pre- ' heating, checking gas flows, and checking for 02 content in the backing gas. The Fleid Process Sheet, as a mechanism to exhibit ! status, is considered inadequate. The inadequacy of the Field Proc-ess Sheet is considered a major weakness in the Pullman Power products system.

2. The Hold Tag mechanism described in Procedure ESD-240 is an accept-able method of exhibiting status when a defective or discrepant condition is noted.

The method of using the Fleid Process Sheet,'the Hold Tag, and the (((]) ~ 3 Discrepancy Report is an acceptable mechanism to track the status of a discrepant condition and the final disposition of that condi-tion. However, the mechanism is not always utilized. e DMR-604, dated February 14, 1973, for isometric package 1-03-1 required rework and reinspection of 14 Class B welds. There are no Fleid Process Sheets or inspection Reports to demonstrate that the work had been performed. e The Fleid Process Sheet for FW-347 states that the weld was cut out in accordance with a specified DR. The referenced DR ,Is not applicable to cutting out FW-347 4 1

4. The method of Indicating repair welds, as described in Procedures ESD-203 and -204, and the notation of repair welding on the Field However,

        -                                         Process sheet are acceptable for showing repair status.

FW-83 (Isometric Package 1-10-9) and FW-348 (Isometric Package 04-500-(

                                                                                                                   - sk -

e 0- ,-ww-. --y.,,,-1w-,--,--,-w--y ---,-y.- . .,,,---y ,--v-,,--w.------,w-wm,.w,wwe-w,-w _e-ee,--,ww--ww--wr+-,---,-- - - , - , .

139) were not stamped "R" to indicate repair.

                                                                                                                                                                                             *   ~

5 Procedures KFP-8 and ESD-239 do present some Information relative to the release of the systems for hydrostatic testing. Procedure ESD-229 does contain'a method of Indicating hydrostatic test status. These mechanisms are acceptable. Procedure ESD-229 should reference Procedure ESD-239 and require that the release be confirmed prior to initiation of the testing.

6. Paragraph 8.12 of Procedure KFP-8 requires that the Fleid Process Sheet be maintained in the area where the line is being Installed.

This requirement has been interpreted as having the Field Process Sheet in the area inspectors' station and not as being available to the foremen and the people performing the work while the work is in progress. This practice causes the Field Process Sheet to become an inspection sign-off record, rather than a traveler that presents necessary information to all Individuals involved in the [ performance of the work. O 7 Paragraph 7 2 of Procedure KFPS-7 requires that the foreman or pipe-fitter procure a drawing and Process Sheet prior to starting work and check off operations as completed. There was no evidence that this practice (which is in conflict with KFP-8) is observed. O 5 9 (O l l

Criterion XV. Nonconforming Materials, Parts, or Components

 '(O I

1. Procedures KFP-10, KFPS-9, and ESD-240 describe an adequgte system ,

i of Identifying nonconformances. I

2. Procedure ESD-240 does not adequately describe the actual process by which Nonconformance and Discrepancy Reports are processed.

3 The Pullman Power Products / Pacific Gas and Elactric Crunpany inter-face relative to Discrepancy Reports is not described.

4. Procedure ESD-240 does contain adequate information relative to disposition and close-out (use of logs) for Nonconformance and Discrepancy Reports.

5 Systems that circumvent the nonconformance system have been estab-lished. Use of Note-0-Grams and Rejection Notices to denote dis-crepancies usually precludes their pick-up on a subsequent NR or DR. (p The use of these alternate systems removes the controls and reviews that have been Integrated into the NR and DR system and also pre-vents information relative to the number and types of problems from being identified. These alternate systems are unacceptable. e

Criterion XVI . Corr'ective Action 4(IO 1. Procedures KFP-10, KFPS-9, and ESD-240 describe a corrective

• action .

system. The corrective action system is inadequate in that it does not require: oCategorizationofreporteddiscrepanciestopermitevaluation and tracking. f e Documentation of all discrepancies. e inclusion of documented discrepancies in the NR and DR system,

• i.e., discrepancies reported in Note-0-Grams are not subsequently written as a NR or DR.

e Tracking of discrepancies to determine which discrepancies are recurring. e Analysis of discrepancies to determine programmatic problems. (O e Reporting of significant conditions adverse to quality and the corrective actions taken to appropriate levels of management.

2. Based on the results of this audit and the problems encountered in the past, It appears that a corrective action system has not been operative.

3 There is no procedure for reporting 50.55(e) deficiencies. 6 e b .

l Criterion XVil. Quality Assurance Records (OI- 1. Procedures KFP-16 and KFPS-14 and most of the ESD procedures adequately Identify the records to be retained.

2. Procedures KFP-14 and KFPS-12 provide adequate guidance and mechanisms to assure collection of most records. Records that are not specified in these two procedures (e.g., records on heat treatment, torquing, pipe rupture restraints) do not have any documented mechanisms for

                                                          ~

l collection, but are adequatel'y' assembled and retained. 3 There are no procedures for filing, storing, and protectt'ng records, l.e., no requirements for the' vault, no method on how records other than isometric packages are identified, no Instructions on how records are to be stored. However, the practices employed do provide for adequate Identification, retrieval, and fire protection.

4. Procedure ESD-212 does adequately describe a security system that

(. provides "out" cards for identification of the record and the Indi-vidual using the record and for the overall security of the records within the vault. w

       .                                                                                   1 Criterion XViti. Audits

1. Procedures KFP-18. -19, -21; Procedures KFPS-16. -17. -18; and .

Procedures ESD-219 and -222 describe an adequate audit program. 1

2. The audit program does not require the use of checksheets or pro-cedures to delineate the scope and extent of the audit, nor does it require that the audit team leader be quellfled.  ;

3 In response to KFP-18, Paragraph 18.2.1, management audits were performed approximately every six months. Checksheets g re employed. Based on the results of this audit and the results of Pacific Gas and Electric Company audits, these management audits appear to have l

• been ineffectual.

4. Procedure KFPS-16 does not require management audits.

5 In response to KFP-18 and KFPS-16, Internal audits were performed ta r a' r e-

 -(O                                 ch ck 8 t          t rv i                                  .

6. There are no procedures for audit reports, audit responses, and time.

limitations on responses. 7 Procedures KFP-18 and KFPS-16 require that a copy of the audit report be transmitted to the Manager of Quality Assurance.

8. There are no requirements that the Manager of Quality Assurance track the audit reports or take any corres,tive actions when program-matic or recurring deficiencies are noted.

9 There are no requirements for periodic, independent, Internal audits of the total quality program. ,

10. One independent internal audit was performed in January 1976.

   'O e

W .

V. EXIT INTERVIEW The exit interview was conducted on September 20,197 gat tan Pullman . Power Products offices at Diablo Canyon. In attendance w. at the exit Interview were: . . Pullman Power Products Vice President, Jack Bowes Production r: Pullman Power Products General Manager Ed Gerwin Qual,ity Assurance i John Ryan Pullman Power Products Res.l. dent Construction Manager . Pullman Power Products Field quality Assur-Pete Runyan ance M9 nager V Pullman Power Products Chief Fleid Engineer Chris Scannell A1 Eck Pullman Power Products quality Engineer, Central Staff John Mitchell Pullman Power Products Conshtt' ant 58 rm # " r ru a ci r 5 rvic carPor tio= 'er id #t (O. Nuclear Services Corpora'tlon Audit. Team Leader Jack Weber . till Rowe Nuclear Services Corporation Auditor Gerry Larsen Nuclear Services Corporation Au ,ltor TheexitInterviewwasinitiatedbyMr. Weber'ssummarizkngofthepurpose 1,- and scope of the audit, the basis against which the Pullman Power Productsi effort was measured, and the purpose of the exit inter, vip. Additionally, a discussion was held on the fundamentals of auditing.,i.e., an audit is a sampling technique, that enough samples are taken from each program or system to draw a conclusion, and that the conclusion is then applied to t'ha adequacy of that program or system. , Each audit finding was presented,.and discussions were hel,d to clarify

       -                      or refute the findings. Some findings were modified, based on additional evidence presented by Pullman Power Products. Upon completion of the
                                                                                                                                                                                                                           =
    --.,---.-.w.,      u.-  ,-,,--r... -.-,--.-,.--.,---,----m.--,         , - , - - - , . - - - - - - - - - - - - - - - - - . - . , - , , - -    - , ,                       .-n-n,_.,,.   . - - - - - - - - , , .,,,-m

P presentation of the audit findings, an overall sunenary of the findings O .a. ,,e,ented. . .

                                                                           ??(

Ct 9

D 9 9

                                                                           . e.

g 4

                                                                                      'T O

'g'O

                                            -   41 -

O

i . VI.

SUMMARY

k nort us -tended <r- i97i

    .O            The runman e-r eroducts Diewo Can The findings Indicate that there were threl distinct             .

to the present. periods as related to the quality of the work. These findings are: . . , ,

         '             e Prior to early 1974, there is l'Ittle evidence available to verify                            '

the adequacy of the work performed. The available evidence indicates , that only a rudimentary quality control program existed and that con-trol over the production organization was minimal. i e From early 1974 to late 1974, there is evidence available to verify the adequacy of the work performed. The available evidence indicates that control was achieved of the materials control program and the welding. control program. o From late 1974 to the present, an increasing amount of documentation and records has been generated to verify the adequacy of the work performed. The available evidence demonstrates that an Increasingly f( more stringent quality program has been placed into effect and in-h creasingly greater control of the work effort has been achieved. However, the present program and controis s,till do not meet 10 CFR 50 Appendix B requirements in those areas as dell'neated in Section IV of the audit report. .

               -                                                   &               J Jack Weber, Audit Team Leader y
                        &@           4t.                .

l

                                                                                      ) F. f.1,rj ekp, t,1 I TB  '{,                7G. J. Larsen, Auditor 3                           Q,
                            !!a.1107 4                    4
                                                           . T. C. Newman, Auditor
                        '7                                    .

C b! C'.' ,

   ,                             s F 8 : #!i! .
                                                     .          . W. Aowe, Audi tor b~

PWanen- _ _ D 4 G f/r1 G W r- Z _. P. O Som 3308. Meech Mood weemsport. Pennov venne e 17701

   ,                                                                                         Telephone (717) 323-9s91
 .(                                ,                                                         Toten s41416 ca % -

J; Pullman Power Products - l [/ [ftSB M SE. April ll, 1978 senmaatirs SPFICE Wm KM EM M APD 141978 gp b Pacific Gas & Electric Company 77 Beale Street h%@' Room 2505 g - San Francisco, California 91405 yg Attention: Mr. R. Rain

                                                                                                         =

Subject:

Pacific Gas & Electric Company Diablo Canyon - Units 1 & 2 ' NSC Audit of August 22 through September 20 i

Dear Mr. Bain:

Nuclear Services Corporation conducted an audit of the piping installation work at Diablo Canyon Units 1 & 2 at the request of Pullas.n Power Froducts, Division of Pullman Incorporated. drafe of (O m er receivt of the SC Audit Re , ort, we ,re,ared a ,re11minarP proposed responses and corrective actions for review by our field site Their cosusents and suggestions have been reviewed and con-personnel. sidered. Attached for your review is the NSC Audit Report and our responses and proposed corrective action for each finding. You will note in our Observations As thata we were not entirely satisfied result, we have had hosee office with the direction of the audit. personnel conduct in-depth auditsThese ofreports the installation are filed from at January site. There through March of this year. were no significant findings. After you have he.d an opportunity to review this report, we would be pleased to meet with you to conr.ider future actions you may consider necessary. Sincer ours, f.Diraetor

                       . wu          -

of Quality Assurance

                       /

EPs/kal . (O 4tt. cc: E. Manning (Bone Office File) w/att. J. F. Runyaa (Site File) w/att. T. D. Landale

8. Esodler J. I. Bowes

____. _ _ _ ___J._Rgan _ _ _ _ __ ,_ _ __ _

i fO .. b PACIFIC GAS & EIECTRIC COMPANY , DIABLO CANYON UNITS 1 & 2 AUDIT OF PULIMAN POWER PRODUCTS INSTALLATION WORK 0 4 f 4 00

( 1. INTRODUCTION As a result of a meeting between PG&E and Pullman Power Products representatives in early July,1977, an independent audit of the Pullman Power Products installation activities at Diablo Canyon - Units 1 & 2 was conducted. The auditing was subcontracted by Pullman Power Products to Nuclear b Services Corporation of Campbell, California. Nuclear Services Corporation was selected by mutus1 agreement between PG&E and Pullman. The purpose of the audit was to verify that the installation met all the requirements of the applicable contract specifications and drawings. , The audit was conducted during the period from August 22 through September 20, 1977. (O 00

                                        -R-

 '                                                                                                   . . . - . - . . = - - . - . . _ _ . . . _ .

10 2. AUDIT RESULTS A copy of the NSC Audit Report was received by Pullman Power

• Products October 27, 1977. This report is atteched as Appendix "B" to this document.

(O i l O LO

O 3. Aun T *tsvo"st The Pullman Power Products response is attached as Appendix t'A". For each finding, Pullman has reviewed the item in depth and pre-pared a suitable response. Where corrective action is required,

       -     the c'orrective action which has been, or is to be taken, is defined.

b For ease of review, the audit finding from Appendix "B" has been copied verbatum. It is imunediately followed by the Pullman response and corrective action where applicable. O (O

t 4 . OBSERVATIONS  ! O a. Although one of the major purposes of the audit was to verify B the adequacy of the workmanship of field fabrication and ~ installation against the contractual obligations, very few of the findings cite discrepancies in this area. This cocid be interpreted as a vote of confidence in the physical installation but NSC does not so state. 4 g b. NSC points out that auditing is a sampling procedure and

                             -           that opinions are based on the asamber of deficiencies within the sample. Unfortunately, the sample sizes and ammbers of discrepancies per sample are not reported. Neither is there any indication as to whether discrepancies notea are                                     l serious or minor. Both items of information would have helped in formulating an opinion regarding the physical                          .

installation. , I

c. Many findings aske general statements that some procedure or i control is not adequate. The specific reasons for the I inadequacy are not listed, and frequently even specific procedures are not cited. Such lack of specificity askes it almost impossible to respond. Where possible, we have attempted to identify these areas to correct the alleged inadequacy. More of ten than not, one mast conclude that personal opinion was involved.

fO d. The -s3or thrust of the audit was directed at the Pu11 man Quality Assurance Program. Our original Quality Assurance Program was written to reflect the Quality Assurance requirements of the 1968 Edition of the ASME Nuclear Pressure Vessel Code, as it applied to piping. This program was modified as requested by the State of California to reflect special State require-ments. It was accepted by the ASME as the site Q.A. Manual as a result of a site survey in February, 1971. f It must be borne in mind that 10CFR50 Appendix B was published sub-sequent to the contract date. The ANSI N45.2 documents and Regulatory Guides which were issued as specific methods for fulfilling Appendix B requirements were published for the most part during 1973 and 1974 when most of the actual work was underway. As part of our obligation to improve the quality of our Program as a result of our greater experience as well as graster sophistication in Quality Assurance resulting from the issuance of the aforementioned documents, we revised our quality Assurance Manuai and published scores of Engineering Specifications and quality Assurance Instructions to supplement it. No attempt was made to r oodel the Msnual to the Appendix (O "B" format. All applicable points, however, are scattered

    -                                           throughout the Manual Specifications, and quality Instructions.

                                                                             ~ 1 ., _ _ _.-

No attempt was made to apply newer requirements to work com-pleted to earlier requirements. This is not required by the { NRC or the Code. We have been audited on numerous occasions (the text of bae response indicate 68 audits) by PG&E, the NRC, ASME, State of California, and one other independent auditing group. Our program has been reviewed and our work monitored by both

      ~

the State of California and Hartford Steam Boiler Insurance g Company, our Authorized Inspection Agencies. We recently underwent an ASME audit for renewal of our ASME Certificates with flying colors. No one has found major fault with our Quality Assurance Program,

e. NSC, on Page 2 of the Audit Report, rightfully points out that the work has taken place over the time period from 1971 to present, and that the audit scope and purpose was to .

evaluate the work against Codes and standards in effect at the particular time the work was performed. Unfortunately, in making their evaluation and conclusione, the audit team did not adhere to their own precautionary statement. The audit findings are profuse with instances where records, documents, and procedures were judged against 1977 criteria instead of those in effect at the time the work was done. This, we feel, was a great disservice to Pullman and our customer. rCO I

                                                                            -   :- = .             . _ . . .

su""^^v

( O 5-

a. The NSC audit failed in fulfilling one major purpose, the

• verification of the adequacy of the installation.

b. Nowhere in this report is there any indication of a finding which indicates an inadequacy in the installed work or

        ~

an inadequacy in the documentation which constitutes 5 evidence of compliance. These two basic points are totally omitted in the NSC Summary, but are most relevant in judging the quality of the installation. We strongly disagree with the NSC Summary that prior to early 1974, there is little evidence available to verify adequacy of the work. All of the evidence exists in the form of doctmentation and other records which were required by the Code and Quality Assurance requirements existing at the time the work was performed.

c. The conclusions regarding the adequacy of as-installed work should be judged against the Codes specified in the contract documents. Conclusions regarding adequacy of the Quality Assurance progran should have been evaluated assinst practices in effect at the time the work was accomplished. Findings relative to Quality Assurance appear to be judged against >

current (1977) criteria. (O d. The statement that the Quality Assurance Program does not meet 10CFR50 Appendix B is an opinion only.- In our opinion, the

program does adequately meet Appendix B.

e. The audit results were useful only in the sense that they pointed out areas where the current Quality Assurance Program can be improved to suit current (1977) requirements even though the work was essentially completed to earlier requirements.

O f

                                                       "A"
                                                           ~

APPENDIX AUDIT RESPONSE CRITERIO_N I. ORGANIZATION

  .(.9 FINDING 1.      A current organizational chart does exist.                                 .

Response: No comment. No Corrective Action required. . FINDING 2. Procedures KFP-1 and IFPS-1 do describe the quality organisation. as well as some of the functional responsibility of the quality organization. Response: No connent. No Corrective Action required. FINDING 3. The Field Quality Assurance Organisation has performed functions other than those described in KFP-1 and EFPS-1; and some functions were outside the quality responsibility, i.e., writing and approving Engineering Specifications, performing welding engineering functions, approving engineering changes.' These activities raise the question of the qualification of Quality Assurance personnel to perform these functions and the problem of requiring the Field Quality Assurance Organization to audit its own performance. Response: There is no evidence of deficient work as a result of the system described. Welding procedures were originally prepared by the Welding Engineer lg( at Williamsport, however, Mr. R. Fink, Q.A. Manager, later revised some of these and prepared some additional procedures. In all i cases, procedures were revieved and approved by PGEE Engineering i and Construction. Where Q.A. personnel were involved in procedure preparation, Engineering input was solicited and incorporated where applicable. Present policy requires Engineering to prepare and/or revise Engin-i eering Procedures. Q.A. Department reviews and approves. No further Corrective Action contemplated. FINDING 4. Procedures EFP-4. EFPS-4, EFP-6, EFPS-5, EFP-8, KFPS-7, EFP-9, and EFPS-8 do describe some of the responsibilities of the Field Engineering Organization. The responsibilities of the other Field Construction Organisations are not described, nor are the full responsibilities of the Field Engineering Organisetion described. Response: At the time our Quality Assurance Manual was written and imple-mented on this job, there were no requirements for position descriptions or responsibilities other than those of the Quality Assurance Department. Corrective Revise the Q.A. Manual Section KFP-1 to better define the Action: Field organisation and responsibilities outside of the Q.A. Department, and to clarify the responsibilities of the Q.A. Department. (O m __

FINDING 5. The descriptions of individual position responsibilities are inadequate. Some elements of position descriptions exist if

  \-              in the KFP and KFPS procedures , and job descriptions exist for inspection and inspection technician positions. No position descriptions exist for any of the upper-level site personnel.

Response: At the time our Q.A. Manual was written, it met the require-ments of the Code and contract. Carrective Corrective Action for Item 4 above will cover this finding. Action: FINDING 6. The description and controls of the interfacial relationship between Pullman Power Products and Pacific Gas and Electric Company are inadequate. The contract and some Engineering Specifications do describe some interfaces and mechanisms. However, for tte greatest scope of the work effort, there is little to describe how the interface will be managed and controlled. Some of the activities that require interface control are hydrostatic testing, nonconformance reporting, meetings, work on pipe rupture restraints, work on hangers, document gentrol, reporting of deficiencies, responses to Pacific Gas and Electric Company audits, interfaces with other Pacific Gas and Electric Company contractors that impact Pullman Power Products work, etc. Response: At the time of the contract, our Q.A. Manual addressed inter-O faces between our site departments, but only with PG&E insofar as design changes were concerned. Subsequently, many specifications have been written which do cover inter-faces with PG&E in other areas. Interfacial activities are functioning properly, but are not necessarily documented in written form. The following addresses each item in Pinding 6 specifically: 6a) Hydrostatic Testing: PG&E has a procedure for preparation of the Procedure for each Hydrostatic Test. These test requirements are transmitted to Pullman Power Products Chief Engineer. When the requirements are received from PG&E, Pullman Power l Products Chief Engineer or designee prepares the < specific Bydro test procedure in accordance with ESD-229. This system complies with the job specifications and code requirements. 6b) Nonconformances are reported on a Discrepancy Report (DR)in accordance with Pullman Power Products Procedure BSD-240. DR's are transmitted to the PG&E's Resident Mechanical Engineer for disposition and/or approval. Following customer disposition l('. the DR's are returned to Pullman Power Products' QA Department. The QA Department then issues approved DR's to personnel responsible for per-forming the work. Work is performed and documented m

O .. 6b) in accordance with approved procedures. We fail (Cont.)to understand why nonconformance reporting is con-if sidered inadequate by Audit Team.

.t.

6c) Meetings are held twice weekly be. tween PG&E and , Pullman Power Products to maintain an open

• communication line between the Utility and Con-tractor. In most cases, itema discussed are merely 1 1 up-dates of work in progress. If major changes are made, these are handled via drawing change, con- ,

g tract change or field orders. Official meeting , minutaa are not kept and distributed to attendees. l i Each attendee notes items of concern within his area of responsibility. L 6d) Work on pipe rupture restraints and hangers are handled in the same manner as other work within the scope of Pullaan Power Products contract. We . disagree with this finding. 6e) Document Control: Drawinas, specifications, and contracts and their revisions are tranau.itted to Pullman Power Products via PG&E Drawing Control Procedures. They are logged and distributed within Pullman Power Products in accordance with Pullman approved procedures. 6f) Reporting of deficiencies - see b - Wonconformances. ( 6g) Responses to PG&E's company audits: PG&E audit l reports have been responded to in the same meaner as any other audit report. Pullman Power Products has determined the cause for noted discrepancy, performed corrective action when required, estab-lished the necessary steps to prevent reoccurance ard responded to PG&E in writing indicating all actions taken. PG&E has further reviewed the implemented corrective action to determine that the steps taken were adequate and properly implemented. Copies of all audit reports are on file for review. 6h) Interfaces with other PG&E contractors are handled through the responsible PG&E resident engineer and in weekly contractors meetings. Contractors prepare and submit weekly schedules which are distributed , among all active contractors. Corrective Review all current practices with PG6E site personnel to Action: determine whether they antisfactorily define interfacial relationships. If not, modify existing or prepare new procedures as required. (.o

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

l FINDING 7. The description and the controls of the interfacial relation- , ( ship between Pullman Power Products Field Oisanisation and 4.O the other ruilman rower troducts or.anisation in.oived in the Diablo Canyon effort are inadequate. The Quality Assurance ~ Manual does describe some quality interfaces betweer the Field and Corporata Offices. Bowever, there are no require-ments for periodic reportin5 from the Field Quality Assurance Organisation to the Corporate Quality Assurance; there are no requirements for an upper-management review of g corrective action reports, nonconformance reports, and personnel qualifications; the interface between the Field Organisation and the Paramount shop is not described; the interface between the Resident Construction Manager and the Corporate Construction Manager is not described; the inter-face between Field Quality Assurance and Corporate Quality , Assurance is not described with respect to field purchases i and Corporate Quality Assurance auditing of those suppliers. Response: Although it is not documented in the site Q.A. Manual, a corporate policy was established to require corporate audits on a semi-annual basis. These cover requirements for review of corrective action, non-conformance and personnel qualification by upper management personnel. Corporate or ' management audits were conducted on a semi-annual basis starting September, 1972. There are records of nine (9) management audits on file indicating findinge and recommended corrective action. In addition, the field site Quality '( l Assurance Manager has beer. required since mid-1977 to forward a monthly report to the Director of Quality Assurance in Williamsport citing these items. The Paramount Shop is considered as a supplier to PG&E and all interfaces must come through PG&E. Interfaces between Field and Corporate Q.A. regarding purchasing is covered in the Q. A. Manual, Section KFP-6, Paragraph 6.3(g). Corrective The Q.A. Manual Section KFF-18 will be revised to include Action: current practices of management audits and reviews. No Corrective Action is required for the balance. Interfaces between the Resident Construction Manager and  ! Corporate construction Manager will be covered in the corrective action for Item 4 above. Purchasing interface with Field and Corporate Q.A. will also be better defined. FINDING 8. The description and the controls of the interfacial relation-ship between the Pullman Power Products Field Quality Assurance Organisation and the other Pullman Power Products Field Organisations are inadequate. The Quality Assurance (~O

                                                         -s-P

l l, FINDING 8 Manual and many of the Engineering Specifications describe l (Cont.) interfaces and mechanismis. Bowever, the interfaces ralative d =i ri = <r == i rd *- {' O t ** tr==ti drawings approval; review of isometric, hangers, and restraint document packages; welders logs; and control of the welding

• process are not described.

Rerponse: There are Engineering Specifications which describe the inter-facial relationship for the items listed. Carrective As part of the review contempleted under Item 6 above, Action: revisions will be made to procedures where necessary. FINDING 9. The stop work authority for the Field Quality Assurance Organisation is not adequate. Procedure ESD-240 does describe the stop work authority for Bold Tags, but there are no mechanisms described or authority addressed for the circumstances when the Construction Organization elects to proceed through a Hold Tag stop. Rerponse: The Quality Assurance Manual as originally written did not specifically address the stop work authority of the Q.A. Department. It has been understood by all Pullman employeec l throushout the length of the job that the Quality Assurance , Manager had the right to stop work at any time and that he 7 had access tc the President through the Director of Quality Assurance. It has never been necessary on this project .f j( =etive-

                                        =*e ite a ^

O < =er rci e =*i er Corrective A stop work authority statement will appear in the revisions Action: to Section KFP-1 of the Q.A. Manual as part of corrective action described for Item 4 above. I FINDING 10. The Field Quality Assurance Organization does report to a sufficiently high level of management. Response: This finding tends to support the stop work authority response to Itan 9 above. No Corrective Action is required. (O

                   . ~ - _ - _ _ _ _ _ - _ _ _ - . _ . .. - _ . _ . . - _ . _ ... _ - - - - __

CRITERION II. PROGRAM I'Q FINDING 1. The contract between Pullman Power Products and Pacific Gas

                                   & Electric Company was signed in May,1970. Prior to the enforcement of 10 CFR 50, Appendix 3. The contract did con-tain certain quality aspects that were requirements for the                               -

Pullman Power Products work effect. Work was not initiated on the Diablo Canyon site until late 1971, when Appendix B

had become a requirement. GLppendix B was added to '10 CFR 50 on June 17, 1970, effective July 27,1970 (35 FR 10698), and b amended Se ember 11, 1971, effective October 11, 1971 (36 FR 18301X. Even though the contract was not amended by Pacific Gas & Electric Company to include Appendix B as a requirement, Pullman Power Products was obligated to conform

to Appendix B requirements; and the total quality program was evaluated against Appendix B and ANSI N45.2. While a written Quality Assurance Program exists, the progray does not meet the requirements of 10 CFR 50, Appendix B or ANSI 345.2.

The specific inadequacies of the program are described through-out the findings. Response: Our Quality Assurance Program as accepted by PG&E and I implemented on the site meet the contractual requirements. It addresses Quality Assurance as required by ASME Section III Nuclest Vessel Code 1968 Edition. The manual was modified to suit specific added requirements of the State of California and was accepted by the AEME as a result of a field site ( survey. O As noted in the findings, Appendix B did not become effective , l until af ter the program isas implemented in the field. Most of the ANSI N45 docssments which gave specific direction for ' implementing Appendix "B" were not published until 1973 and 1974 when the bulk of the work was underway. As the work progressed and experience dictated, we incor-ported many provisions of the above documents in our Quality Assurance Manual. Engineering Specifications, and Quality Assurance Instructions. Bowever, no attempt was made to address each specific requirement in one place. The program in effect at any given time complied with the requirements of 10 CFR 50 Appendix B and implementing dccuments which existed at the time. All work was performed and doce ented to the program in effect. Thsrefore, the work is considerad to have met the job requirments and was completed to the applicable quality isval. Numerous audits by PG&E, the NRC, the State, ASE , etc., have mot focad any fault with our program from this point of view. Other than Corrective Actions noted throughout the response ( . Corrective Action: to the audit as a whole, no corrective action is anticipated.

                                                                   -s-m                                 .

_.w,,,______....__, ___.__.___,_____.__2_____,___,.______,.__.._..__.___,_..

FINDING 2. There is no description of the overall quality Amaurance j( O c

• tr ti e Pr==r - =Pci2a titP*

described, the relationship and purposes of the EFPS, IFP, and ESD procedur-e are not described; the Pipe Support

• Quality Assura.m P.:_2 a1 is not described; and the salation-ship of the Pipe Support Quality Assurance Manual to the balance of the Quality Assurance Program is not doctmented.

i Response: Our Quality Assurance Manual KFP-1 Paragraph 1.13 indicates that Engineering Specifications covering specific Quality i I b Assurance functions would be prepared at site and approved by Company Q.A. and PG&E. These become part of the Q.A. Program. l ' The term " Engineering Specifications" was intended to cover , all program supplements without the need for specific identification as KFPS, KFP, or ESD's etc. The pipe support annual was added at a later date and served as an extension of the original manual. , No Corrective Action contemplated. FINDING 3. Procedures KFP-1 and KFPS-1 do provide a broad and generalized description of the scope and applicability of the Quality Assurance Program. These procedures also reference the contract between Pullman Power Products and Pacific Gas & Electric Co. However, the total scope and applicability of the Quality Assurance Program are not adequately described. 'O ( The erforts re1 tive to P Pe i Pe re re tr i== . receivi = and control of materials and components other than Pullman Power Products procured, and the work associated with anchor bolts are not adequately described. Response: Efforts relative to receiving and control of materials and components other than Pullman procured are very adaquetely covered in KFP-7 Paragraph 7.2. l Efforts relative to pipe rupture restraints and anchor bolts are covered by the Pipe Support Manual although act specifically listed. Rupture restraints and anchor bolts are covered by atsnerous EDS's and Q.A. instructions. See ESD 243, 259, 260, 261, and Q.A. Instructions 72, 95, 96, 97, 105, etc. No Corrective Action required. FINDING 4. There is no evidence that upper management has performed scheduled reviews of non-conformance reports, personnel qualifications, and corrective actions. . (O a

Response: Corporate Management Audits have been performed on a regular basis since 1972. (See response to Criterion I, Finding 7.) Part of the auditing activity is to review non-conformance reports, .( O personnel qualifications, and corrective action. . Since mid-1977, all site Q.A. Managers are required to submit a monthly report which includes a review of non-conformances, corrective actions, and personr.el requirements. g No Corrective Action is required. FINDING 5. There is evidence that upper management has performed reviews of audit reports generated by Pullman Power Products and Pacific Gas & Electric Co. Rerponse: This finding r.orfirms existance of audit reports menpioned in 4 above. No Corrective Action required. FINDING 6. The indoctrination and training program requirements for personnel involved in inspection activities are adequate. Procedures KFP-2, KFP-3, KFPS-2, and KFPS-3 require training of NDE personnel; Procedure ESD-237 specifies a training ,( program for the NDE personnel; Procedure ESD-237 also describes a training program for Quality Assurance Field I O 2 r ct=r - Rerponse: No comment. [ l No Corrective Action required. l l FINLING 7. The indoctrination and training program requirements for personnel involvad in quality-related activities are inadequate. There is no requirement for indoctrinstion and training of welders, foremen, engineering personnel, warehousing personnel, etc. Response: At the time our Q.A. Manual was originally issued, there vere no requirasents for training of quality related personnel outside of the Q.A. Department. We have conducted but not necessarily documented training sessions with Enginearing personnel, General Foresen, welders, and other craft personnel. A full time welding engineer has provided instructions and directions to weldern during original qualifications and during subsequent work. He has'monit'ored their activities. Corrective Add a requirement in the Q.A. Manual, Section KFP-1 to (- _ Action: cover a requirement that personnel in quality related O i = =i l t l

                                               -s-

FINDING 8. There is no evidence that personnel have been trained to

                        ** ir < iti rier ith **        *r    ** 7   -
<O             responsible for implementing, except for welders, who have been trained and qualified to specific weld procedures.                     .

Response: Requirements for documented evidence of training was never addressed in our Q.A. Manual. We have conducted required training for NDE and inspection personnel to the require-

     -         ments of our procedures (See Item 6 above), very often over and above contract requirements. Quality-related b         personnel were also trained (See Item 7 above). We have alvsys performed this training on an informal basis but not necessarily documented it.

Corrective All future training will be documented. Action: l c6 0 00

CRTTERION III. DESIGN CON 11t0L FINDING 1. There is no design manual for the preparation of isometrics and field fabrication drawings. , Response: Preparation of isometrics and field fabrication drawings do not involve any type of design. They are merely transfer of customer requirements from orthographic projections to more manageable documents. to permit ease of installation 6, and doctamentation of work performed. The Q.A. Manual covers requirements for control and approval by Q.A. Department of such drawings. No Corrective Action required. FINDING 2. Procedure KFPS-4 provides adequate control of the pipe support design effort. Response: No Connent. No Corrective Action required. FINDING 3. Procedure KFP-4 requires that the Chief Field Engineer and the Field Quality Assurance / Quality Control Mansser l review field changes to Pacific Gas & Electric Company - '( approved drawings and specifications for ASME Code com-dr< **i i it-O vii c - -ite >r Response: In order to assure that Code requirements are correctly applied, our Q.A. Manager KFP-4 requires a review of PG&E initiated drawings and revisions by the Pullman Chief Field Engineer and Field Q.A. Manager. Both individuals were selected for this work because of experience and ability. They are well versed in applicable customer and Code requirenants, and a witten procedure for this review is not deemed necessary. When drawing changes are requested by Pullman, a discre-pancy report is witten and submitted to PG&E for approval prior to any work. l - l No Corrective Action is necessary. FINDING 4. A mechanism does exist for checking and reviewing Pullman l Power Products drawings. Bowever, this mechanism is not described in a witten procedure. Documentation of the ! implementation of this informal procedure does asist. Response: Our Q.A. Manual Section KFP-4 outlines requirements for rwiew ,( and checking of Pullman prepared documents. The finding, !" indicator, that implementation is acceptable. No formal pro-cadure is deemed necessary. No Corrective Action is contemplated. i f sa j n - .- -_____ _ _

                                           - ~~                   -
                                                                    ... _2 _ m ._ _ ___. 2 ___ ___ _

FINDING 5. The isometrics and field fabrication drawings do indicate the classification of systems. { Rerponse: No comment.

• No Corrective Action required.

FINDING 6. Procedure ESD-205 does contain a classification of systems and the requirements for each classification. Response: No comment. No Corrective Action required. FINDING 7. The changes to isometric drawings and field fabrication drawings are indicated on the docimients, as well as'the reason for the change. Procedure KFP-9 establishes a mechanism to permit tracking of all revisions, i.e., the Chief Field Engineer is required to maintain a copy of all voided drawings. Response: No comment. No Corrective Action required. Co FINDING 8. Procedure KFPS-8 requires the Chief Field Support Engineer to assure that all supports are fabricated to the latest drawing revision. No mechanism exists to comply with this requirement. Response: Pipe supports are part of the total piping, system. Q.A. Manual KFP.4 Paragraph 4.3.7 requires the Chief Engineer to assure that all systems are built to latest drawing revision prior to test. ESD-253 covers pipe support drawing control in detail. ESD 239 requires release from support engineering before closecut. No Corrective Action required. (O

      --               . - - .          ,.                  ~
                                                                          ....~.,:n     _ -

CRITERION IV. PROCUREMENT DOCtBENT Colf!ROL FINDING 1. Procedures KFP-6 and KFPS-5 adequately describe the respon-sibilities associated with field purchase order processing. Response: No comment. No Corrective Action required. BINDING 2. Procedure ESD-226 adequately describes the quality require-ments for purchase specifications of the usual Pullman Power Products scope of purchased materials. Response: No comment. No Corrective Action required. . FINLING 3. Procedures KFP-6 and KFPS-5 do not require that the purchase order state that Pullman Power Products is given the right to audit the subcontractor shop. Response: All vendors or subcontractors are placed on the Approved Vendor List as a result of successful surveys and yearly audits by the Q.A. Department, Williamsport. Field purchases must be made 4 from the Approved Vendor List issued by Corporate Headquarters.

(. C) No Corre::tive Action required.

FINDING 4. No written procedure permits verification of the selected supplier as one identified on the Pullman Power Products corporate-approved vendors list. Response: Q.A. Manual Section KFP-6, Paragraph 6.3.6 requirer that the j ' Q.A. Manager review all requisitions to verify that the supplier is on the Approved Vendors List. A separate procedure is superfluores. No Corrective Action required. FINDING 5. There is no mechanism by which Pullman Power Products Corporate is informed of the procursment of safety-related parts, com-ponents, equipment, and material to assure that the selected supplier is placed on the Corporate audit schedule. Response: As noted in 3 and 4 above, suppliers must appear on the Approved Vendor list prepared at Corporate Headquarters. All suppliers are audited on a yearly basis. Copies of all Field Purchase Orders are sent to the Construction Engineer in Williamsport. No Corrective Action required. t

                                                     -R2-

                                                             -     --_a_-.______-.__._._.   ;

^ I l CRITERION V. INSTRUCTION

S. PROCEDURE

S. AND DRAWINGS 1O FINDING 1. There is no requirement that activities affecting quality shall be prescribed by documented instructions, procedures. . and drawings. Response: We disagree with this finding. The Q.A. Manuals in Sections IFP-1. Paragraph 1.13. EFP-8, and EFPS-1 all specifically require that activities affecting quality b be identified on the field process sheets by specific reference to the special process procedure by number. Welding procedures by number, NDE procedures by number, etc. Specific ESD's listed give the detailed instructions. No Corrective Action is required. FINDING 2. Many activities affecting quality are not described in procedures. Among those activities are: hanger package review, pre-heating for welding, use of Note-O-Cress, use of Rejection Notices, and maintenance of Field Quality Inspector Daily Iogs. Response: Hanger package review is covered by IFPS-12. ESD-253 describes hanger drawing control. A detailed check list for hsnger review needs to be developed. (O Preheating for welding is covered in the Wald Procedure Specification. ESD-218 also describes preheat require-ments. Prahsat temperature range is also listed on the process sheet. When specified, it was performed and documented on the appropriate process sheet. Note-O-Crams, Rejection Notices, and Inspector Imss are internal working tools of the Q.A. Department primarily for status reporting and record. They are intended to make the system more fool-proof by reducing verbal consnunication to a minimmt. Special procedures for these appear to be superfluous.. Corrective Revise ESD-254 to include hanger and restraint check list. Ac tion _: a FINDING 3. Many activities affecting quality are insufficiently described in procedures. Among those activities are: isometric package review, post-welding heat treatment, nonconformance reporting, Ninety-Day Welders' Los and Weekly qualified-Welders List, and auditing.

 ,O

( Responre: Isometric package review requirements are described in ESD-254. l{ Post veld heat treatment is covered by ESD-218 and weld

• I procedures. .

Non-conformance reporting is adequately covering in ESD-240. Ninety-Day Walders' Log and Weekly Qualified Walder Lists b are covered in the Q.A. Manual System EFP-15 and in ESD-216. Auditing is covered by our Q.A. Manual EFP-18. Corporate audits are conducted by selected, qualified personnel from Williamsport Headquarters under a qualified lead auditor. A copy of the Corporate Audit Procedure XVIII-1 is available from the site Q.A. Manager. , In the past, there have been 16 NEC audits, 2 ASME audits, 9 management audits, 1 independent audit and 40 PG6E audits of Pullman for a total of 68, performed at this site to verify performance to applicable requirements. No Corrective Action is required for any of the above items. FINDING 4. The present procedures are generally inadequate for providing ( direction to those performing the work. The procedures do not follow the flow of the work; many procedures are very O long (over 10 pages); insufficient inforration is given; important information is not provided or referenced in the procedure. Rerponse: This is a very general statement which is impossible to track due to lack of specificity. All procedures now in effect, have been reviewed and approved by PG&E. l Corrective A review of all procedures will take place under Corrective l Action for Criterion 1. Finding 6. l Actior.: 4 I (:

  .O
                                                           ?,.

CRITERION VI. DOCUMENT CONTROL (O FINDING 1. Procedures KFP-9 and KFPS-8 are adequate for field drawing control, and Procedure ESD-253 is adequate for pipe-support drawing control. Responre: No comunent. No Corrective Action required. FINDING 2. Procedures KFP-17 and KFPS-15 are adequate for control of the KFP and KFPS procedures and are appropriately implemented. Response: No consnent. No Corrective Action required. FINDING 3. There is no procedure for control of ESD procedures. Response: ESD's have been controlled in the same manner as the Q.A. Manual. Their control is not specifically governed by written procedures. Corrective Revise Q.A. Manual KFP-17 to include control of ESD procedures. C. Action: FINDING 4. There is no procedure for control of Special Quality Assurance Instructions. Response: Special Quality Assurance Instructions are used for clarification of ESD's. Corrective Corrective action of Item 3 above will include definition and Action: control of Special Q.A. Instructions. FINDING 5. The Pullman Power Products review of completed packages relative to hangers and pipe restraints is not detailed in a procedure, nor is ESD-254 complete as to what is actually done for the isometric package. Procedure ESD-254 does describe some , espects of " Piping System Documentation Review". Response: ESD-254 is intended to cover the entire piping system which incorporates hangers and restraints and the system is working effectively. Specific hanger information is not covered on the checklists. Corrective Revise ESD-254 to include hanter and restrafat check list. Action:

FINDING 6. The Pullman Power Products log Drawing Control Index (KFP-9 and KFPS-8), is maintained in a nonpermanent manner. (O r* 1 = i ritt a e i P =i1 a * == 6 r r revisions exceeds the available space, the early revisions are erased to accomodate the new revision. . Response: The purpose of the Drawing Control Index is to assure that all site departments are working with the latest drawings.

Once a draving has become obsolete, the record of when it was received has no meaning. Accordingly, we have not b concerned ourselves with maintaining a record of obsolete drawings.

No Corrective Action anticipated. FINDING 7. No mechanism assures that the Pacific Gas & Electric Co. drawings being used as the reference drawings are tHe latest issued revision. Audits are frequently performed to determine that Pullman Power Products has the latest Pacific Gas & Electric Co. drawings. However, the audit mechanism is not satisfactory when it is the only mechanism. Response: It is PG&E's obligation to assure that we receive the latest drawings. As they are received, they are logged in the Drawing Control Index as outlined in KFP-9. PG&E personal regulatly audit this document. Since" August ,1977, PC&E has been forwarding, on a monthly basis, a list of ' (O intest drawinis. No Corrective Action required. FINDING 8. There is no Wald Rod Requisition for one of the welders who participated in FW-345 of isometric 04-500-139. Response: FW-345 was welded by several welders including welder "LB". Rod requisitions are available for all but "LB". Records indicate that "LB" welded on FW-345 and FW-346 on the same day. There is a requisition for rods on FW-346 for Walder "LB". Rod withdrawn for FW-346 is the same type and heat number as that withdrawn by others for FW-345. FW-345 and FW-346 are both welded in accordance with the ' same procedure. ESD-215 requires the field inspector to verify that proper veld rod was used. Es was not necessarily required to verify requisition as it related to the specific weld number. Since this incident, all requisitions are reviewed by the welding insputor for veld number, welding procedure, ( electrode, and welder symbol. No Corrective Action is required. ~ . w

FINDING 9. There ic evidence that documents have been backdated and changed to meet requirements without any substantiation

 ;I                      of the information.

(a) For Isometrie 2-14-77: The Process Sheet was

• changed to show the completion of FW-192 en April 10 and April 11, 1974, approximately 19 months after the work was done.

(b) Isometric 2-14-8: FW-1673 was performed to  ! b Revisfor 2 of the isometric, which did not show W-1673. Revision 3 of the isometric, which included the FW-1673, was generated approximately one week after conspletion of the weld. If. is, therefore, concluded that FW-1673 was performed without the normal controls of a Process Sheet, ' a weld procedure call-out, and a call-out of NDT. requirements. . (c) Isometric 2-14-53: FW-247 was completed February 20, 1975. Approximately December 1, 1975, the visual acceptance was signed off and back-dated; and the Wald Rod Requisition was changed to show that more than the original quantity of one had been burned. (d) Isometric 2-14-59: W-268 was completed February 5, 1975. On December 2, 1975, the l(

<                                  entry on the Process Sheet for removal of dame was signed off and backdated. There is no proof that the dans had been removed.

(e) Isometric 2-26-417: FW-144, 145, 196, and 197 were completed on May 14, 1976. The Wald Rod Requisition had been altered to add FW-197. Bowever, the Weld Rod Requisition shows that 14 rods had been burned, which seems improbable for the four welds that were supposedly welded. Response: (a) For Isometric 2-14-47: The weld was completed but not examinad by PT until 19 months later. It was . then accepted. (b) For Isometric 2-14-8: FW-1673 did not show on Revision 2 of the isometric. During the installation tc the required Process Sheet, it was determined that an additional weld (FW-1673) was required. In the earlier days, Field Engineers, in conjunction with the Field Q.A. Inspectors, were permitted to initiate field proces's sheet revisions with the required information. The Engineers revised the process sheet and marked the working drawing with Field Q.A. Inspector approval. This information was { transmitted to the office where the original iso-metric was revised. The Process Sheet and all required documentation for FN-1673 are in the Isometric Record Package. 4-..---_-----_. _ __ __ _ __ _ _ _ _ _

. .1b__ d - ~. . -._ -

s, Response: (b) Frasent procedures require that the need for added 1 (Cont.) welds be reported to the office where the original l drawing is revised before a new process sheet is

 '(                                         prepared.

(c) For Isometric 2-14-53: During an in-house audit, the Pullman auditor noted that a visual inspection ' point for W-247 was not initialed by the Field Q.A. Inspector. The inspector verified from his daily

           ~

vork log that he had completed the required inspection. g He accordingly signed and dated the sheet as of the inspection date. Records indicate that the requisition change was , initiated by a Q.A. Inspector. l Current procedures require initials and date. (d) For W-2-14-59: Records indicate that this was a Code Class 3 veld made with a backing ring. No dras were used. The standard process sheet form requires verification of dam resoval. Field Q.A. Inspector should have indicated "Not Applicable" rather than signing this point. (e) For W-2-26-417: Field weld ambers W-144-145+196 and 197 are 3/4" socket welds. The required fillet is approximately 1/4". Fourteen (14) rods are sufficient. { Field Process Sheets have provisions for more than l one veld on a sheet although seperate entries are required for each weld. Frocess sheets show that all welds were completed on the same day. Frocedures permit a single requisition for not more than four (4) socket welds at a time. The field Q.A. Inspector noted that sufficient rods were available to permit completion of W-197 and added this number tc the requisition. This precluded necessity of the welder returning unused rods and obtaining a new requisition and rod for one 3/4" socket weld solely for record. No Corrective Action required for any of the above. . FINDING 10. No procedure or requirement prohibits the changing or alter-ation of the records and documents that are necessary to track the work. Field Process Sheets, Weld Rod Requisitions, inspection records, etc., should not be changed or should *oe changed only by quality Assurance supervisory personnel and then signed and dated. (: Response: A Pullman audit of December,1975 pointed out the sub. ject of changer without dating. The requirement for initials and date appear in ESD-254 on a check list.

   - - - -      _ . _ , _ _ _ _ .               ________-1_S.-.---_--_.                           .     -

u . Corrective Revise ESD-254 to specifically detail the need for initialo Action: and dates on record changes made by Q.A. personnel. ,(O FINDING 11. Procedures KFP-14, KFPS-12. ESD-239, and ESD-254 are adequate , instructions to assure that the correct documentati6n has been assembled and the system is ready for turnover. Response: This statement seems to negate part of the statement on

      ~

Item 5 regarding isometric packages. 6 No Corrective Action required. ( O

 'O in,                               _.

                ~     _      _                       . _ . _

CRITERION VII. CONTROL OF PURCHASED MATERIAL. Euutreiw i. AND SERVICES -( O FINDING 1. The interface between the Pullman Power Products Pield - Organization and the Pullman Power Products Corporate Organization relative to selection and monitoring of suppliers' fulfilling field purchase requisitions is inadequate. z _ Response: This finding does not cite any specific supplier or b purchase order which was found inadequate. This conclusion is not justified by the evidence. Pullman Power Products corporate organisation through the Quality Assurance Department in Williamspert maintains the updated Approved Vendor List which is used throughout the Pullmar. Power Products organisetion (fscluding Diablo Canyon) for use in procurement of materials from qualified suppliers. All suppliers are accepted on the basis *of appropriate ASME Cartificates or a fullman survey. Vendors are audited annually. (See also Criterion IV Items 4 and 5). All field purchased material is subject to field receiving inspection as outlined in KFP-7. No Corrective Action is required. (O FINDING 2. Procedures KFP-7, KFPS-6. ESD-217, ESD-226, and ESD-261 are adequate for the performance of receiving inspection. Response: No coerent. No Corrective Action required. 4 (O Ob

A. CRITERION VIII. IDENTIFICATION AND CONTROL OF MATERIALS. PARTS. AND COMPONENTS

( O r FINDING 1. Identification and control of piping and va?ves are adequately -

specified by Procedures ESD-200 and ESD-201. . l i Response: No comment. 1

     -            No Corrective Action required.                                                           1 b

FINDING 2. Identification and control of weld material are adequately specified by Procedures KFP-12, KFPS-11, and ESD-202. Response: No comment. No Corrective Action required. , FINDING 3. Identification and control of backing gas dans are adequately cpecified by Procedure ESD-214. Response: No comment. l No Corrective Action required. FINDING 4. Procedures KFP-8 and KFPS-7 are adequate for specifying that the identification of parts and components is to be recorded i on the Field Process Sheet. The implementation of this procedure is adequate. l l Response: No comment. f I No Corrective Action required. FINDING 5. The isometric drawings and field fabrication drawings are the major documents for recording the identification of the parts, spools, and components. While there is no procedural require-ment, this mechanism has been followed and is an excellent technique. Response: No comment. No Corrective Action required. FINDING 6. Identification of welds and welders is adequately described in Procedures ESD-203, 204, 221, and 243. I l Response: No coussent. I No Corrective Action required. l f ! n

FINDING 7_. Proper methods of marking are specified in Procedures ESD-200, 201, 202, 203, 204, 221, 223, and 243. l{ , Response _: No comunent.

                                                                                                                                  .                                   \

No Corrective Action required. Material control techniques for temporary pipe attachsents f_INDING 8. are adequately described in Procedure ESD-232. b R'esponse: No comment. No Corrective Action required. FINDING 9. Procedure ESD-248 adequately describes controls for the

 '                                         repair of installed valves and for valve parts control.

Response: No commsent. l No Corrective Action required. FINDING 10. Adequate control of snubbers, plate, and other components is l achieved by using Procedures ESD=200, ESD-201, KFP-8, KFPS-7, and the practices associated with field drawing preparation. i f- Bowever, no procedures specifically address these items. l( Response: Snubbers, plates, and other components are covered in ESD-223, 243, 261 No Corrective Action required. FINDING 11. Procedure KFP-20 provides an adequate mechanism to control nuts, bolts, etc. Response: No comment. 1 ' No Corrective Action required. FINDING 12. Procedure ESD-223 does not give adequate instructions for the l identification and control of Class I Fipe Supports. Response: We disagree. ESD-223 is adequate. No Corrective Action required. FINDING 13. Procedure ESD-228 does provide adequate guidance for the

'( i marking of tools used in grinding stainless steel and carbon steel welds.

Response: No comment. No Corrective Action required. s .. C _ _ _ . _ . - . _ _ _ _ _ . . . . _ _ - . . -

CRITERION IX. SPECIAL PROCESSES I seen ro ,erir see ified a O 11ND1No 1. Nonde tructive e min ti n a special process. Procedures IFP-3, EFPS-3. ESD-23% and ESD-256 adequetely specify requirements for EDE personnel. Respor.se : No comment. No Corrective Action required. b FINDING 2. The requirements for Field Quality Assurance Inspectors are adequately specified in Procedures ESD-237 and ESD-256. Response: No comunert. No Corrective Action required. FINDING 3. The qualification and certification program for NDE and inspection personnel has been inadequate. The records of the following persoenel were ====ined: D. R. Geske, T. L. Koch, J. E. Cawelti, G. P. Keeler, K. E. Beck, L. Glass, W. R. Johnson, E. Stanton, C. B. Athay, R. G. Sears, D. S. Tutko, J. N. Shironizu, V. J. Casey, J. A. Brasher, L. F. Myrick. S. R. Stanley, H. Guest, D. E. Bentley, R. D. Kincade, K. D. Guy, J. R. Bowlby, E. R. Jennings, (. A. L. Newton, C. C. Lenzi, J. J. Sisk, L. G. Thomas, O A. A. Conques, and R. L. Marks. In virtually all cases, the individuals began performing their duties without fulfilling the specified requirements. The most prevalent discrepancies are: not completing the required training, not having proof of previous experience, insufficient time as Level I, unsigned tests, and insufficient background and experience. Response: The finding fails to differentiate between NDE personnel and inspection personnel. A review of the files (certificates and e===inations) indicetes that all NDE personnel had completed the exam-instions specified by ASNT-TC-1A as required by our original Q.A. Manual, before they were allowed to perform, any work. They were trained under the General Dynesics program but doc e ented evidence in terms of subject matter and hours spent is not available. l A review of the files indicate that all NDE personnel aither had required experience and background to permit l immediate qualification to Level II, or that they took an examination, worked the prescribed time as inval I and subsequently, passed a Level II examination before (. being allowed to work as Level II. P rn -

                                                                    +- --+... -..._,   _   _ . , ,

6 Response: Records indicate that some NDE ==aminations were graded but (Cont. ) not signed by the Q.A. Manager. There are no requirments ( for this. The Q.A. Manager did sign the Certificates and identification cards as evidence that estisfactory test . results were attained for the Level summined. . All current inspectors have been qualified by test as outlined in ESD-237. Requirements for qualification and certification of field b inspectors were added in ESD-237 on September 25, 1973 to reflect the requirements of ANSI N45.2.6 just published. Persons hired before this time were not necessarily tested at time of hire. Subsequent to 1973, the records indicate that all inspection personnel received required training and examination. No Corrective Action is required. FINDING 4 NDE procedure qualification is adequately described in Procedures KTP-2 and KFPS-2 as being the responsibility of the Manager of Quality Assurance, Williamsport Headquarters. Response: No comment. a ir e-(O " cerr etiv ^=ti = FINDING 5. Welding has been properly specified as a special process. Rerpor.se: No comment. No Corrective Action required. FINDING 6. Welding procedure qualifications are adequately described in Procedure KFP-15 as being the responsibility of the Welding Engineer (Williamsport). Response: No comunent. Nc. Corrective Action required. , FINDING 7. Procedures KFP-15. KFPS-13, and ESD-216 are adequate for specifying welder qualifications. Response: No comment. No Corrective Action required. n

l . i l 1 FINDING 8. The certification of the following welders, by weld symbol, l was eramined and found acceptable: U, AN, IE, F0, VD, QZ, a =c-l( O =v. ro. 3t. ='. ='. ^'. ao. 'a. to. ic. =r. =c. ic. Response: No comment. No Corrective Action required. The certification of welder U was not signed.

     .T,INDING 9.

Response: The qualification records indicate that welder "U" was successfully qualified. The welding engineer failed to sign the certification at the time. Corrective Field Q.A. Manager has reviewed the qualification record and Action: will attest in writing on the certificate that welder * "U" records indicate he was properly qualified. FINDING 10. A number of procedures provide ipechanisms for control of the welding process: ESD-203, 204, 215, 219, 221, 225, 242, and 243. However, the control of the welding process has been inadequate as follows: C 10a) Records of welder qualification prior to 1972 are not O availadie. Response: The first job weld was done on December 28, 1971. A record of the welders qualification for this first weld is dated December,1971. No other welding in 1971. 10b) The Ninety-Day Welders' leg was not maintained from August,1972 to December,1972. There is no Weekly Qualified-Welders List for that time period to sub-stantiate that the welders were actually qualified. Respense: There is a void in the 90 day weld los from August,1972 to December, 1972. By reviewing welding records, a qualification status for this period has been reconstructed. All welders were found to be within the 9 H ay requalification period. Records' are available for review. No further Corrective Action is required. 10c) The Ninety-Day Walders' Log is not sufficiently detailed to determine if the welder is qualified to perform certain procedures. The Ninety-Day Walders' Iag has been revised a number of times, and the detail has improved with each C-a revision. Previous to the latest revision Osovember,1974), the log was very poor in giving precise information relative to procedure and thickness ranges to which the welder was qualified. p .

loc) Cont. The 90 day Walder Status hg was modified and improved on

Response

several occasions. It is intended to assure the welder r remains qualified by process.. The Code requires requal-l ification in the event the welder did not use a process within 90 days. Specific welding procedures or specific thickness range of qualification are not part of this - form. They appear on each qualification certificate. No Corrective Action is required.

       $        10d) No procedure states what the Field Quality Assurance Inspector uses as the primary means to determine welder qualification, the Ninety-Day Walders' Ims, the Weekly Qualified-Welders List, or the Welder's Qualification Card.

Response: The Q.A. Manual Section KFP-15 Paragraph 15.2.c indicates that the qualification status of each welder is kapt on the 90 day Welders Status log. The Inspection Supervisor prepares the Weekly Qualified Status List from the 90 day log and distributes it to the foreman and Welding Q.A. Inspectors. No Corrective Action required. 10e) Ne procedure qpecifies who is responsible for the Ninety-Day Walders' Log, the Weekly Qualified-Welders List, or c rai * ** i r et *- O **

• ta t' a tiric ti obtained; how the logs are used; to whom they are dis-tributed; etc.

Response: Q A. Manual Section KFP-15, Paragraph 15.2 states that a ' field Q.A. Inspector appointed by the Q.A. Manager is responsible for welder qualification. This would include collection of qualification results, use of logs, and distribution of logs. Cc.rrective Rt.quirements for qualification results, use of logs, and Action: distribution will be added to KSD-216. 10f) Procedure KFPS-13 differs from KFP-15 in that it does not permit a six conth extension of welder qualifications if the velder has been actively welding on some other welding process. Procedure KFPS-13 requires the welder ' to use the specific welding process within a three-month period or be requalified. There is no evidence of adherence to this requirement for pipe support welding. Response: KFPS-13 did not incorporate the option to permit extension of welder qualification to 6 months when employed on other welding processes. This is not a deviation, but merely ii- srrs-12

• see i a == r**=.2 7 -

f(.O Wo Corrective Action is required. l' SY%

                                                                     .         ..w. - . -._ . - _                -

10g) Walder BF (W. Adair, 251) performed welding on FW70, 72, 00 u, 76, n, 78,1=B, u2. and m in 1-tric ,s.ha.e 21-7 and FW-88, 90, 92,134,135, and 1605 in isometric package 21-8. This welder was not qualified for the

• thickness range; and the welds were reported on DR% 2536, 2538, 2539, and 2899. In accordance with Pacific Gas &

Electric Company disposition, some of the welds were radio-graphed and found acceptable; welder BF was qualified to

• the thickness range; and all the welds in question'were g

accepted. This disposition is not permitted by 331.1, B31.7, and ASME Section IX, which all specify that the welder must be qualified prior to making production welds. Response: The deviation cited was found by Pullman Quality Assurance and reported to PG&E on appropriate deviation records. Reference to DR-2536 is incorrect. The auditor is completely incorrect in indicating that ASME Section IX, B31.1 and B31.7 do not permit welding prior to qualification. No such prohibitions exist. DR-2538 Rev. 1 & DR-2539, Rev. 1 dated July, 1975 report 2-2" butt welds in Diesel Fuel Oil (160B and 1008) made 12/17/73. Walder was not qualified for anali diameter (3" and under) until 2/18/74. Both DR's use the option to qualify the weider by radio-l graphy (see 1971 Section II Winter 71 Addendum - Paragraph ' ( (n/ Q2(a)). Both production welds (1608 and 100B) were radiographed and found acceptable. PG&E accepted qualification on this basis. l DR-2899 dated August,1975 reported 14 butt welds made l prior to 2/18/74. Investigation shows these were 2%" pipe size. Prior qualification by DR-2538 Rev. 1 and DR-2539 Rev. I covers qualification of these seams. No further NDE required.FG&E accepted seams on this basis. 10h) Procedure ESD-219 requiras random sampling of in-process welding, with the sampling to be noted on the Field Process Sheets. In examining Field Process Sheets, it is obvious that the sampling by the area inspectors was not performed. Response: ESD-219 requires random sampling of in-process welding,. There is no requirement for recording on the process , sheet. Each welder is audited to a specific weld procedure on a production weld at least once every six weeks per ESD-219. The completed check sheet serves to verify this in-process check. There is evidence of sampling of in-process welding indicated either on process sheets or recorded in Inspectors Daily Logs. l Corrective Revise ESD-219 to permit recording of random sampling CO Action: checks, either on the process sheet. Inspectors Daily Log,

• or Wald Check List.

rM-

l

f 101) Procedure ESD-219 requires periodic auditing by the Welding l Auditor. These audits were not performed until November 5, rr a=== eti i==

O 1973 a >=11 this procedure for approximately 23 months.

• i Response: ESD-219 was originally written in February, 1973. It uns j revised in September,1973 to initiate auditing of welders.

Audit reports were begun in November, 1973. All welds, including those performed prior to audits had fit-up, in-b process, final inspections and required NDE to verify acceptability. No Corrective Action required. 10j) Procedure ESD-219 requires monitoring stainless steel welds for ferrite control. However, the Severin Gauges were not on site until the beginning of 1973; and Pullman Power Products was not in compliance with this procedure for approximately 12 months. Response: From the outset of the project, all stainless steel filler material was purchased with a 5 to 15% ferrite requirement. ESD-219 was issued February, 1973 to respond to the intent of Safety Guide 1.31 issued August,1972. Severin gauges were on site in early 1973 to implement monitoring of completed welds. 4 { A sampling of completed welds made : prior to receipt of Severin These gauges were checked subsequent to receipt of gauges. Welds made indicace acceptable ferrite per Safety Guide 1.31. after receipt of gauges were all in compliance with ESD-219. No Correctiv'e Action required. l 10k) Hangers are not welded in accordance with Pacific Gas & Electric f Crepany requirements. Bangers 2023-IV and 2039-2V are two examples of a number of hangers observed that are welded to the structural steel on the wrong side of the bracket. Responre: Pullman Inspection personnel have reviewed Bangers No. 2023-IV and 2039-2V and found that they were welded in accordance with customer drawings. This was pointed out to NSC at the exit interview. Pullman asked that they reinspr.ct, but NSC declined. . I No other hanger discrepancies were reported. l No Corrective Action required. 101) The interface of welding to other suppliers' parts and components is not clear. Welding is done toThe join Westing-necessity house and Paramount parts and components. ( for addressing impact property requirements for those l

 'O                      weldsents is not clear; in addition, the requirements for addressing impset property requirements for Pullman Power Products field welds are not clear. If impact properties are necessary, the acceptability of each weld that has been

101) repaired and subjected to more than one stress relief is Cont. indeterminate because of the time at temperature limitations

;                    within the qualified weld procedure.

Response: Review of contract reveals that impact testing of welding . procedure qualifications was not required. Requirabants , for impact testing of procedure qualifications when required by customer specifications does not appear in 331.7 until 1972. Present procedures are acceptable. 5 No Corrective Action required. 10m) Some welders do not receive sufficient training. Welders, fabricating the pipe rupture restraints within the contain-ment, are welding heavy plate. While these welders are qualified by virtue of welding heavy wall pipe, the techniques are diffarent. The welders who were already qualified to heavy wall pipe were not given additional training on plate. Response: Welders receive written fastructions when qualified. N se include rod requisitions, use of WPS, notification of Q.A. prior to welding, etc. All welders are qualified on pipe in required positions, m auditors seem to feel there is a difference in welding pipe and plate. h re is, plate is easier. Note that ASME Section IX Faragraph QW303 indicates that for 1G and 2G positionr., qualification may be made on pipe or plate interchangeably. In the 5G and 6G .( positions qualification on pipe qualifies on plate but not vice-versa. We feel no added training is required. No Corrective Action required. 10n) m re is no procedure for the preheating of weld joints. Response: Requirements for preheat temperature are given in each Welding Procedure Specification and shown on the Process Sheet. For pressure retaining materials, ESD-218 outlines the provisions for installing resistance coils, blankets, N ee thermocouples for post veld heat treatment. requirements apply equally for preheat, since preheat, weld and post heat are carried on as one continuous process. Corrective Reference to preheat will be added to title with specific Action: requirements in Paragraph 5.2 of Rsc-218. 10o) The initial results of the welding auditing (from November 5, 1973 to February, 1974) indicate that the following problems existed: ( O e_ _ .

10o) (1) The welders did not understand shielding Cont. and purging.

( O (2) Tempil sticks were not used. .

f (3) Asperages were not within procedure limits (mainly root welds and tack welds). (4) Wald procedures were not available, and g many welders did not know where to obtain them. ' (5) The oxygen analyser was not available or not operative. Also, the time vs. flow rate alternate technique was not used. ' (6) Oven rod temperature control was not monitored by the welders. (7) Many welders did not understand their duties and responsibilities. Based on a review of the Pu11 man Power Products weiding audit reports and the frequency of the above-noted problem areas, there is no confidence that welding done prior to early 1974 was performed in accordance with welding specification requirements. (. The ro11o ins is a res,onse to eacw individ 1 finains: O mes ense: 5 (1) Welders do understand shielding and purging. During welder audits, it was found on few occasions that the welders were not operating within the criteria established. Findings indicated that welders were using higher flow rates than was permitted by the i procedure. This is a non-essential variable of the ASME Section IX Code. If there were problems associated with excessive flow rate, the resulting indications would have been porosity. This did not occur since welds were subsequent 1y found acceptable by visual and nondestructive examination. < (2) In cases where welders were noted without Tempil sticks in Internal Audit Findings, there was no indication on the " Welders Audit Sheet" that the interpass temperature was too high. It is, therefore, concluded that weld quality was not affected. Ferrite checks of welds where t a pil sticks were not used show acceptable results. (

  -O
                                                        -3 0-Ca                                          _

(3) Review of weld audit sheets revealed a snail

                            -6 r r     1d r   1di = t <e ==a       -

T~ O scribed procedure amparage range. Amperage is a nonessential variable and visual inspection - and NDE examination indicates welds were . acceptable. (4) Wald procedures are available. Each foremsa,

general foreman, and QA inspector has copies of procedures. The welders are issued a k synopsis of weld procedures giving voltage and saperage range, and rod type and size for each procedure. Review of audit report indicates a small number of this type procedure deviation occurred.

(5) The inavailability of an oxygen analyser at time of internal audit does not indicate that the weld was not purgad. Acceptable NDE is an indication that purge was satisfactory. There appears to be no basis for the statement that the Tine vs. Flowrate techniques were not implemented. i (6) The weld rod control procedure permits the exposure of weld rod without the use of an oven up to four (4) hours. In those cases where we noted oven ten,eratures to be 1ess O than that required by the procedures, we also noted that rod had been issued for 1ess than 4 hours. It was deterwined that weld quality was not adversely affected. The welders were required to hrse ovens repaired or replaced in each case. (7) Welders were tested and met the Qualification Requirements of ASME Section 11. They were issued written instructions indicating the requirements for securing veld rod, inter-pass temperature control, proper voltage / amperage range settings. Their supervisor has also issued instructions to the welders on a daily basis as deemed necessary. All the findings recorded above were derived free Pullman Field Audit per ESD-219. In each case Corrective Action was immediately taken. If it was determined by the Pullman Welding Auditor that the finding would result in defective welding, further action in-the form of discrepancy report would have been initiated. The items listed are ASME gection IX Non-Essential Variables and do not necessarily ( infer defective welding. All welds were subjected to lf fit-up, and fine.1 visual inspection and NDE and found to ( be acceptable. i

                    ._._________.__.at.__________._._____._._____________

FINDING 11. Welding procedures for carbon steel welding require pre-heat and interpass temperatures for unterial that has a fO carbon content in escess of o So ,ercent and a thichness of one inch or more. There is no mechanian by which the welder can determine carbon content. , Response: It is not the welder's prerogative to determine the carbon content of any particular material. This is a requirement of the Engineering Department and the process sheet writer 5 will indicate the required preheat and interpass temperature as a result of his review of the minimum specified carbon 4 content of the materials being joined. The welder need only follow the requirenants of the process sheet. No Corrective Action is required. FINDING 12. Procedure ESD-221 does provide adequate guidance on weld repairs. Response: No c - nt. No Corrective Action required. FINDING 13. Heat treating has been identified as a special process in the Pacific Gas & Electric Company contract (as well as in Appendix B), but it has not been controlled as a special process by Fullaan Power Products. ( Response: Fi 4 ding 14 below indicates that KFP-13 and ESD-218 do provide adequate controls for proper post veld heat treatment. We can only assume that the finding points out that we do not identify beat treatment as a special process in our Q.A. Manual. Beat treatment has been controlled as a special process, including operator training, and evidence of satisfactory performance is on file. No Corrective Action required. FINDING 14. Procedures KFP-13 and ESD-218 do provide controls of the post veld heat treatment process. The implementation of Procedure ESD-218 is acceptable. . Response: See Item 13 above. No Corrective Action required. FINrING 15. Cleaning has not been identified as a special process. Response: Cleaning is act identified in la CFR 50 Appendix "B" as a speial process. g Clasning of components prior to installation and cleaning of surfaces to assure freedom fran halogens are performed by Pullaan to various ESD's. See Item 16 below. A

R*Sponsa: Cleaning of tha cystem prist to ctartup is perfonsed by PG&E Co. (Cont.)

,(

No Corrective Action required. O ~ Procedures ESD-220, 224, 238, 242, 252, 258, 259,'and 261 FINDING 16. provide adequate guidance in cleaning and cleanliness of the various materials, parts, and components. . Rebonse: See Item 15 above. No Corrective Action required. FINDING 17. Procedure ESD-231 provides some guidance on hot and cold bending of small bore piping. The guidance is considered insufficient to assure that the bending is dora properly to avoid high stresses and thinning of the wall. Response: All piping field bent is 2 inch and analler. All stainlese steel was cold bent. That inside the containment was solution heat treated, pickled, and passivated to eliminate any stress corrosion problem. That outside the containment was installed as bent. All of this conforms to PG&E specifications. ( Corrective Action: A sampling of bands has been measured for thickness by U.T. (34 on Unit 1, 27 on Unit 2 or about 25% of the bends). Results indicate all are above the required minimum wall. Q ESD-231 has been revised tc require UT thickness check on future bends. FINDING 18. Procedure ESb-238 provides adequate instruction in torquing of bolting for pipe flanges. Response: No comment. i No Corrective Action required. l FINDING 19. Procedure BSD-259 provides adequate instruction for installing Grinnel Snubbers. Response: No causient. No Corrective Action is required. FINDING 20. Procedure ESD-224 provides excellent instruction for  ; I assembly and torquing of installed valves. '( i e Response: No eausent. O No Corrective Action is required. } b

FINDING 21. Procedure ESD-260 provides adequate instructions for (O i= t 11 ti i vi111 c= 1t - Response: No coussent. No Corrective Action is required. 5 FINDING 22. Procedure ESD-230 provides good instructions for entering an installed line. Response: No consnent. No Corrective Action is required. , ( O C O

                                                  -u-g                 ,

CRITERION X. INSPECTION O,11ND1No1. r oced res =rr-5. a. a d 14 ta ro shir describe the

• interface between Pullman Power Products and the .

Authorized Inspector. Response: No comment.

          -                    No Corrective Action required.

b FINDING 2. Procedures KFP-8 and KFPS-7 provide the requirements for the Field Process Sheet, which specifies inspection points and inspector sign-off. Response: No cosament. , No Corrective Action required. FINDING 3. The Field Process Sheet references procedures to 1 which the work and the inspections will be performed.

Response

No comment.

                               .No Corrective Action required.

O 11ND1No 4. The ins,ection ,rocedures are detai1ed in erocedures ESD-206, 207, 208, 209, 210, 211, 215, 219, 225, 233, 234, 236, 241, 243, 244, 249, 250, 251, 255, 249, and 260. These procedures are, in general, broad descriptions of the inspectica process for the total range of the work scope and are adequate for that purpose. Response: No comment. No Corrective Action required. FINDING 5. For all inspection processes, there is no mechanism to provide the inspector the particular characteristic to , be inspected; the particular acceptance criteria; the particular methods and equipment to be used; and provisions for recording results, other than acceptance for the particular inspection being made. The exceptions to this statement are radiography, where the reader sheet allows the recording of results, and those procedures that specify the use of particular equipment (such as some of the ultrasonic procedures). Response: The process sheet indicates each point where an inspection O or awa=4mation is required and references the appropriate procedure number. Each procedure defines the inspection requirements, equipment, and accept-reject criteria. No Corrective Action required.

r1 o1*c 6. rae in Fe=ti n v ee i 8 re11F t dit al - ra-

 'c O                practice of exhibiting an acceptance signature only does not permit auditing to determine if the individual characteristics were ewsmined, the correct criter,ia were             .

used for acceptance, and the correct specific measuring devices were used. Response: An acceptance signature indicates that the requirements of the referenced procedure were ast. We have had audits l b by ASME, by the NRC, PG&E, by Eartford Steam Boiler, and

          ~

the State of California, ann our own independent auditing companies, as well as Pullman Power Products. Bad the  ! inspection process not been acceptable or auditable, these other agencies would have brought this to our i attention long ago. l No Corrective Action required. l FINDING 7. A large number of welds in Unit 2. System 14 (FW-110, , 111, and 112 in isometric package 2-14-31 are examples) were accepted for visual examination and thereaf ter accepted based on surface NDE inspection Orr or PT). l Visual examination of those welds indicates that the surface is not suitable for the performance of surface I NDE inspection. CO Response: Records indicate that FW-110 was penetrant examined. FW-ill was mag particle ewsmined, and a repair was subsequently penetrant examined. FW-112 was mag particle examined. When these items were called to our attention, paint was removed from the welds and all welds were visually inspected and penetrant examined. FW-110, FW-ll2, and the repaired aras of FW-lli were effectively examined. FW-111 (originally M.T.) had soste interbead crevices which contained residual paint. The paint produced several broad indications which were not considered relevant. Visual examinations indicated FW-lli I I could be effectively ang particle examined. Welds cited appear to be the worst cases from the group

• reviewed.

No further Corrective Action is required. FINDT18C 8 For FW-110 (isometric package 2-14-31), the Process sheet indicates that NT was performed; however, the inspection sheet for FT shows that weld stanbar, and the inspection (O sh.e. ior xT does - s- tot -u -ser.

                                              ~

1 Response: PT or NT are equally acceptable methods for taspecting j g,. this weld. j I Process Sheet called for NT. Recording indicates PT. - Inspector signed Inspection Point without having. Process Sheet revised to indicate PT. Corrective A review of all Process Sheets was made to verify that Action: actual process used is on the Process Sheet. DR was

         -           issued to cover those items found in error.

L No further Corrective Action needed. FINDING 9. FW-83 (isometric package 1-10.-9) was repaired in accordance with a valid Process Sheet. The radiograph of FW-83 does not exhibit the required R1 symbol, but R1 was inked onto the radiograph. There is a surface defect that i*s questionable for acceptance to visual standards. Response: FW-83 was repaired. El symbol was inadvertently omitted from radiograph (R1 was inked on) and weld surface. Alleged surface defect was inspected independently by two Level III personnel and found to be acceptable. Corrective R1 symbol has been added to weld. C Action: O FINDING 10. Isometric package 1-03-1 has a step that requires a Pullman Power Products inspector sign-off. This requirement was removed, and the step was accepted by a Pacific Gas & Riectric Company employee. Re sponre: The inspection in question was a clean and fit-up operation. l It was Code Class "C". There is no requirement that this operation be witnessed and signed off. This is an isolated I ' problem which occurred in 1972. This procedure has not been permitted since that time. No further Corrective Action required. O L , l3 _ __ _ ___._ .__ _ _._ _

 -  . _ .               -                              ..                                              =    -

CRITERION XI. TEST CONTROL FINDING 1. Procedure ESD-229 adequately defines the methods and , inspections relative to performing hydrostatic tests. . Response: No comment.

           #               No Corrective Action required.

b' FINDING 2. There is no description of the responsibilities of Pacific Gas & Electric Company or of the Pullman Power Products / Pacific Gas & Electric Company interface to i hydrostatic testing. Response: A complete description of the extent of each hydr.otest is prepared by PG&E and given to Pullman. Fu11 man personnel performs the test under guidance of PG&E employees and to their specific requirements. All ' records are complete and acceptable. Clarification cf interf acial relationships will be covered in response to Criterion I, Pinding 6. FINDING 3. Procedure ESD-229 is not adequate for describing the flow and authorities relative to the individual hydro-l( l static test procedures to be performed. t Response: ESD-229 is a general procedure for conducting pressure tests. Specific test limits, requirements, authority, are all furnished by PG&E in a written procedure for each test. See response for Finding 2 above. No Corrective Action required. FINDING 4. Hydrostatic test packages 7-2, 7-2A, 8-12, 9-12,106, 106A, 106B, and 64 were examined and found acceptable. Response: No comment. No Corrective Action required. . FINDING 5. The 531.1 and 331.7 Codes require that all piping is leak-tested, where practicable. Pullman Power Products is only leak-testing Class A and 5 piping and that Class C piping specified by Pacific Gas & Electric Company. Classes D, E special, and E piping is not being leak-tested. A letter from Pacific Gas & ( Electric Company (dated January 13, 1976) does exist, which states that Pacific Gas & Electric Company will assume responsibility for the leak-testing of Class C Pipias. There is concern that Pullman Power Products is not discharging its contractual obligations (that

                                                                            . e .

FINDING 5 specify compliance to 531.1 and 331.7) by not performing

(- (Cont.) piping leak-testing to Code requirements for Classes C, D, E special, and E piping systens and, as a result, may be legally vulnerable. ,

Response: Pullman is hydrostatically testing Class A & B piping to the Code. There is a letter on file from PG&E which relieves s Pullman of respontibility for Code compliance on Class C (B31.7 Class III) relative to hydrotest. In some cases, testing is performed at less than Code requirements because of limiting components. 531.7 paragraph 737.4 permits an upper limit of hydrostatic test to be established by the designer if the required 1.25 design pressure exceeds component limits. Balance of syste s are given an initial service leak test as permitted by Code. None of the Class "C" systems are Code stamped if hydrotest is not per Code. There is no Class "D" piping. Class "E" and Class "E Special" are 531.1 Systems. Most are tested per Code, some at less than Code because of limiting components and others are given initial service leak tests as permitted by the Code. (. In our opinion, the owner, PG&E is ultimately respon-sible tc the NRC for the suitability of the system. O In following their instructions, we are fulfilling our contractual obligations. No Corrective Action is required. t I l . i I

    'O eg - - - . - _ - - . . _ _ - _ _ _ _ _
                                                  *""*---r**---,,g            _

CRITERION XII. MEASURING AND TEST EQUIPMENT (O Procedures KFP-ll, EFPS-10, and ESD-213 describe en FINDING 1. - adequate calibration program. Rerponse: No coment.

• No Corrective Action required. -

5 FINDING 2. The calibration program did not require recalibration of thermocouples until June 16, 1976. Therefore, there is no assurance of the accuracy of thermocouples used for pre- and post-welding heat treatment prior to June 16, 1976. Newly purchased thermoccuples were required to be calibrated by the manufacturer. However, , the manufacturer's calibration does not assure tfiat the thermocouples have not been damaged during handling and shipping. Response: All thermocouples have been and are purchased with calibration. Prior to June,1976, there were no require-ments of recalibration of thermocouples. When the program was initiated, all asisting thermocouples were recalibrated and none were found to be out of calibration. ( Code requires best treatment in the range of 1100-1200 which is fairly wide. In addition, each weld joint has more than one thermocouple. Any thermocouple with significant deviation would show as widely divergent from the others on the charts. No Corrective Action required. FINDING 3. The calibration program has not been adequately implemented. 3a) Paragraph 11.5 of Procedure EFP-11 and Paragraph 10.5 of Procedure EFPS-10 require reinspection of materfals and components if the measuring and test equipment is found , to be out-of-calibration. Except for hydrostatic testing and heat treating, the identity of measuring and test equipment is not related to the inspections performed., Response: The system now in effect requires recording of the instru-ment serial neber used on each inspection, thus petuitting reinspection of work if instrument is found to be out of calibration. As noted Eydrotest sages and Beat Treatment Recorders were found to be satisfactory.

Response: Torque wenches were used for the most part on rupture (Cont.) restraints to AISC requirements which required daily

 'f                                                                    calibration of each wench prior to use. Accordingly,
 !\

the wrenches were calibrated but the serini number of the wrench used was not recorded. game bolted pressure .. joints were torqued with calibrated wrenches, bu't serial numbers were not recorded. Any leakage would Fave been detected in hydrotest. I PG&E has reviewed previous records and fin 6s no out-b of-tolerance condition which would result in over-stress of bolting. Tong Testers are used only to monitor welding asperage which is a non-essential variable in welding. Due to the wide range of amperage permitted, a deviation on the Tong Tester would not be detrimental. . Corrective The procedures have been revised to require recording Action: of instrument serial number on inspection or audit sheets. A 100% review of all torque records were made to assure ' that correct torque was applied. A program of random verification of torque loads is underway. (.O 3b) Procedure ESD-213 does not contain a mechanism to report out-of-calibration measuring and test equipment to Pullman Power Products. Some forms used by the calibration subcontractors only contain provisions for attesting to calibrating the equipment to appropriate standards and have no provisions for recording the actual values obtained. Response: The only items for which calibration is subcontracted are tong testers and potentiometers. i For tong testers, see response in prior finding. Unless a potentiometer were badly out of calibration, the very wide range of heat treatment temperature permitted by the Code would not be violated. A badly out-of-range ' potentiometer would have been called to our attention by the subcontractor. Corrective Procedures now require vendors to report actual values Action: of deviation before recalibrating equipment to permit review of any previous' work. 00 41

l l 3c) The calibration records of recorders were confused by having two recorders identified on one record and the l 10 -cePtabi11tv of the records co 1d not he deter.ined. Response: There are separate calibration certificates for each , recorder ~ on file attesting to their acceptability. - The Calibration Inspector recorded both instruments on one card. Norrective Separate record cards for each instrument are prepared and sction: now on file. This has no effect on work performed. 3d ) Severin Gauges 2947 and 2971 were received on the site in January, 1973. Initial calibration was August 29, 1973; and the next calibration was November 19, 1974 for gauge 2947 and January 23, 1975 for gauge 2971. Procedure ESD-213 requires annual ca11bration. Response: There was a strike during the period June, 1974 to November, 1974. Cs11brations were allowed to lapse. Both were recalibrated as soon as needed. No Corrective Action required. Magnetic Partic1e Test Equipment Y-6 has no documentation

'( (./A       3e) to verify calibration.

Response: Magnetic Particle Equipment consists of yoke type equipment. Calibration coasists in determining whether yoke is capable of lif ting a 10 lb. weight. No tolerance is involved. A card is on file which indicates the yoke t capacity was checked as required. No Corrective Action required. 3f ) There is no documentation available to verify calibration of " Tong Test" amp meters. Rerponse: There are calibration certificates from the subcontractor and cards in the calibration file atter. ting to the docu-- mentation. No Corrective Action required.

33) " Tong Test" amp meter TT2527403 was out of calibration for the period December 12, 1976 to January 31, 1977. No DR has been written against that instrument.

It is rarely Response: Tong Tester mentioned is of the 0-1000 range.

used. It was not used in the December 1976 to January 1977 period and so noted on the calibration card file.

No Corrective Action required. i 1

3h ) Stercg2 requirementa fcr instrraents cro not specified. Response: There are no specific requir ments for construction >{ equipment storage and consequently no written instructions were prepared. Q , Tong Testers, micrometers, hydrotest sages, and small torque wrenches are stored in locked file cabinets in the Q.A. office. , Temperature recorders are normally in use, but when stored, i are in a heated warehouse. Large torque wrenches are stored in a heated warehouse. ESD-213 environmental control indicates that each Q.A. Inspector is responsible for calibrated tools in his area. No Corrective Action required.

(

O 1 - 1 l (- O

                                                  -o-
 .,I- - - - - -                            .       -_.- -             _                    _ _ . .

                                 =^=ottac. sto=icz. ^== ==1 ret =c

!( O ca'rix'o= xt't-

                                                                                                          ~

FINDING 1. Procedures ESD-202, 215, 217, 222, 223, 240, 25A and 261 provide some information relative to handling and storage of materials, parts, and components for the total scope of the Pullman Power Products effort. Response: No comment. No Corrective Action required. f FINDING 2. Procedures for storage are generally inadequate. Procedures ESD-222 " Control valves" and ESD-202,

                               " Weld Material Withdrawal and Control" are specific and adequate. Procedure ESD-215 " visual Inspection",

provides some guidance on storage. There is very little information relative to how specific items art to be stored or the delineation of storage areas relative to the protection each area provides. Response: In general, storage conforms to N452.2. All large pipe materials are stored outside on dunnage in drained areas and were properly closed to prevent i? trusion of dirt, etc. Valves and other items were (O tored 1 rewo e - we1d a t riet w Prover 1P stored as indicated in ES-202. Please note Pinding 6 below. No Corrective Action is contemplated. FINDING 3. Procedure ESD-240 requires a segregated storage area for " scrap" material, and Procedure E3D-215 requires separate areas for material with Bold Tags and for P1 78 materisi separation. These procedures are l sdequate. Bovever, they do not relay such information on how these segregated areas are to be established and maintained segregated. Response: It is significant to note that the auditors found the storage areas in excellent condition. (See Pinding 6 below). The main concern is that proper, segregated , storage is used. There are a variety of ways this can be accomplished, i.e., roped off areas, separate storage bias, pallets, etc. We use any or all of these procedures depending on the specific circumstances. No Correceive Action contemplated. a--=a-(O Pr=>1=c 4. =ere are - Pr-ed-es or -faa -rs for the storage of flow indicators and strainers, which were stored in the Pullman Power Products storage area.

 --    . . - -            -__-.-__-.---.._na-_____..___.-                               -               .. - -_ -

Response: These itesis are stored on the sasse fashion as valves.

('

We fail to see why any special instructions are required. - No Corrective Action required. , FINDING 3. Bandling procedures do not exist; sad the asly handling

                       -                         instructions are contained in ESD-222 and a number of b                          cther procedures, which contain a caution against the use of carbon steel in handling stainless steel. Pro--

cedure ESD-259 has excellent detail as to the handling of Grinnell Snubbers during installation. However, Procedure ESD-259 was issued Jancary 27, 1977; and there is no assurance that materials, parts, and components were properly handled during the period prior to January 27, 1977, when most of the installation

• activities were occurring.

Response: Materials, parts, components, valves, etc. were handled in accordance with ESD-215 issued September,1971 and ESD-222 issued February, 1972. We also point out that our Quality Assurance Manual KFD-19 which was part of our program from the beginning, requires maintenance and surveillance of spools, hangers, valves, etc. on a monthly basis. Quality Assurance Instruction 94 and - (- PG&E Specification 8711 also give requirements for tandling and storage. Our Pipe Support Manual Section KFPS-6 describes storage ar.d hand 11ms, and KFPS-17 describes maintenance and surveillance. Prior tc issuance of ESD-259, Grinnell Snubbers were controlled under ESD-215. All Grinnell Snubbers have been reinspected and tested in accordance with ESD-259 procedure on both units. No Corrective Action contemplated. FINDING 6. The present storage areas were found to be in excellent condition, with areas clearly defined, materials supported on adequate dunnage, and openings capped. Response: This finding confirms proper storage is implemented despite alleged inadequate instructions in the above findings. No Corrective Action required. i l FINDINC 7_. Procedures EFP-19, KFPS-17, and ISD-222 provide for an adequate storage surveillance progran. Prior to October 31, 1973, the surveillance was performed using a check-(. aheet that contained the storage requirements; after g October 31, 1973, the checksheet was changed so that the storage requirements were not listed. While the sur-veillance program appears adequate, the checksheet used after October 31, 1973 does not appear adequate. p . N - - . . . _ . _ _ _ _ _ . , . . _ _ _ - . - - __ . _ _ _ _ _ _ _ _ _ - - _ _ _ . _ , _ _ _ . _ . _ . . _ - . , , _ . _ _ _ _ . _ . -

Reponse: Th2 criginal checklict cyplied ts valves la partientar during the period cf time when valves vers o cignificant part of th2 ct:rcg2. ^( After October 31, 1973 when valve storage was significantly reduced, surveillance of valves was incorporated in with O ther t ri 1 - . We feel the original checklist is too detailed and the current one is satisfsetory. No Corrective Action required. I l I i I O , e O a._

CRITERION XIV. INSPECTION. TEST. AND OiPEllATINC STATUS FINDING 1. The major mechanism that exhibits the status of the .. work is the Field Process Sheet. The Field Proedss Sheet provides for performance status of some important fabrication steps and for inspection status. Bovever, j many important fabrication steps are not indicated by t

             ',             the Field Process Sheet: erection steps; cleaning b              prior to installation of insulation; and some critical welding steps as preheating, checking gas flows, and                                         ]

checking for 0,,cestent in the backing gas. The Field Process Sheet, as a mechanism to exhibit status, is considered inadequate. The inadequacy of the Field Process Sheet is considered a major weakness in the Pallaan Power Products system. i Response: The Field Process Sheet is intended to fulfill the requirements for field welding in particular. Steps taken to erect a piping sub-assembly are not necessarily quality related, and are quite obvious. They need not be indicated on the Process Sheet. Cleaning prior to installation of insulation is a tott.lly separate operation on a system basis and does cet appear on a process sheet but is controlled by l( special procedure, t Critical welding steps such as preheat, gas flow, I oxygen content of backing gas are all part of the Welding Procedure Specification and it is felt they need not be repeated on each process sheet. The Process Sheets give the required specific instructions for weld fitup and inspection as required by Code. Recent revisions to the Process Sheet include more specific procedure requirements. No further Corrective Action required. FINDING 2. The Bold Tag mechanism described in Procedure ESD-240 - is an acceptable method of exhibiting status when a defective or discrepent condition is noted. Response: We coment. No Corrective Action required. ('O FINDING 3. The method of using the Field Process Sheet, the Bold Tag, and the Discrepancy Esport is an acceptable machenism to track the status of a discreyent condition and the final disposition of that condition. Bowevar, the anchenism is not always uti'Lised.

   - , - -      .__.___._______.47._                                                                                  _

3n. DMR-604, dated Fcbrutry 14, 1973, fsr isometric package 1-03-1 required rework and r=4=vtion of .( 14 Class B welds. There are no Field Process Sheets or Inspection Reports to demonstrate that the work O had been performed. , Response: Comment is incorrect. 191R-604 for isometric 1-03-1 has no Class B attachments indicated. There are Clas T C attachments which are documented and inspected in accordance with the DMR. A'- 3b. The Field Process Sheet for W-347 states that the weld was cut out in accordance with a specified DR. The referenced DR is not applicable tc cutting out W-347. l i Response: DR-1247 was written to cover rerouting of the line and tt e addition of W-347. This DR is referseced on the criginal process sheet. W-347 was cut out and revelded to facilitate installation of other work. Reveld is complete and correctly documented. The as-built condition is documented. No Corrective Action required. '( FINDING 4. The method of indicating repair welds, as described in Procedures ESD-203 and 204, and the metation of repair welding on the Field Process Sheet are acceptable for O showing repair status. Bowever, W-8'! (Isu.etric Package 1-10-9) and W-348 (Isometric Package G4-500-N -83) were not stamped "R" to indicate repair. Response: See Crittrion X, Finding 9, the same response applies to W-348. The Corrective Action taken applies also. FINDING 5. Procedures KTP-8 sad ESD-239 do present sme information relative to the release of the systems for hydrostatic testing. Procedure ESD-229 does contain a method of indicating hydrostatic test status. These mechanisms ' are acceptable. Procedure 351>-229 should reference Procedure ESD-239 and require that the release be confirmed prior to initiation of the testing. Response: This again applies to procedures not to the quality of the installation work.  : Corrective ESD-229 will be revised to cross reference ESD-239. ( Action:

   'O

                                                                                 . ~ . . - .   - ~ . - _ _ _ . . -
 . FINDING 6.           Paragraph 8.12 of Procedure KFP-8 requires that the Field Process Sheet be maintained in the area where the line is being installed. This requirement has been interpreted as having the Field Process Sheet in                      -

the area inspectors' station and not as being available to the foremen and the people performing the work while the work is in process. This practice causes the Field Process Sheet to become an inspection sign-off record, rather than a traveler that presents necessary b information to all individuals involved in the performance of the work. Response: This is a requirement of our original Q.A. program. The inspection station server as a focal point for work being performed in the area and controlled by the individual inspector. Process sheets and other requirements are reviewed with the foreman and we!1ders prior to the work. The Process Sheet is available at all times. Since the Process Sheet is a permanent record needed fcr final documentation, it was decided to retain them at the inspector station. Distribution directly to the fereran might result in loss or damage which would destroy prior records. This procedure l furnished control required. l(o l No Corrective Action required. l ( l FINDING 7. Paragraph 7.2 of Procedure KFPS-7 requirer that the I foreman or pipefitter procure a drawing and Process Sheet prior co starting work and checkoff operatiour. , as completed. There was no evidence that this practice (which is in conflict with KFP-8) is observed. Response: Since hangers are more spread out and loss of process sheets for hangers were not considered as critical as those for pressure welds, the procedure of KFPS-7 was established in 1973. Process Sheets are issued with each hanger drawing and are completed as required as work progresses. These drawings and process sheets are on file in Q.A. vault for all cosipleted " and accepted work. No Corrective Action is required. 1 (O

CRITERION XV. NONCONFORMING MATERIAIS. PARTS. OR CGtPOWENTS ( O rxxo sc 1- rr c a r =rr-1o. =res-' a ==>-2*o 4 i* - adequate system of identifying nonconformance. , Rerponse: No comment. No Corrective Action required. . I Procedure ESD-240 does not adequately describe the FINDING 2. actual process by which Nonconformance and Discrepancy Reports are processed. Response: We disagree ESD-240 does adequately describe process. If specifics were listed, we could better evaluate this finding. No Corrective Action contepisted at present. FINDING 3. The Pullman Power Products / Pacific Gas & Electric Co. interface relative to Discrepancy Reports is not described. Response: ESD-240 requires approval of all DR's and NCR's by PG&E. Specific individuals contacted are not mentioned. This ( will be corrected under Criterion I, Pinding 6. O No further Corrective Action reeuired. FINDING 4. Procedure ESD-240 does contain adequate information relative to disposition and close-out (use of logs) for Nonconformance and Discrepancy Reports. Response: No coment. No Corrective Action required. I FINDING 5. Systemas that circumvent the nonconformance system have been established. Use of Note-O-Grams and Rejection i Fotices to denote discrepancies usually precludes their-pickup on a subsequent RN or DR. The use of these alternate systens removes the controls and reviews that have been integrated into the RN and DR system and also prevents information relative to the number and types of problems from being identified. These alternate systems are unacceptable. ( O

                                               -n C.

Rerponse: DR's cre written to cover deviations ubich cro found after an item has been completed and presented for ( inspection. . During the course of a job, it is necessary to call - attention to status of items still in progress, but not yet presented for inspection. Note h are an internal type of communication regarding the work

       ;-      in progress. They were introduced to reduce the risk
       .       associated with verbal communication.

b Rejection Notices were also introduced to call attention to conditions which must be corrected before presenting for final inspection. They are also written to preclude six-up associated with verbal communication. They are similar to the weld repair orders used when unacceptable indications are found* by RT, PT, or MP. Once again, we must emphasize that deviations or non-conformances are defined as unacceptable items found after the item is considered complete and has been presented for inspection. No Corrective Action required. ( O 1 l l l

 'O l

l 3 - . - - - - _ _ _ .

CRITERION XVI. CORRECTIVE ACTION l(.O FINDING 1. Procedures KFP-10. KFPS-9, and ESD-240 describe a corrective action system. The corrective action , system is inadequate in that it does not require. J

a. Categorisation of reported diserapencies to /.

permit evaluation and tracking. 4 V g b. Doc e entation of all discrepancies.

c. Inclusion of documented discrepancies in the RN and DR system, i.e., discrepancies reported in Note M rams are not subsequently written as a RN or DR.

d. Tracking of discrepancies to determine which, discrepancies are recurring.

e. Analysis of discrepancies to determine programmatic problems.

f. Reporting of significant conditions adverse to quality and the corrective actions taken to appropriate levels of management.

Response: At the time of the contract, Corrective Action require-

                                               *ir-

• r** c *'
• ec4 -

{O * *** Iack of a procedure for categcrization may have a. resulted in repeated deficiencies, however, each discrepancy as defined by the Q.A. Manual was reported on a DR. Appropriate disposition was l made and steps were taken to prevent reoccurence. Current Corporate Procedures do cover this situation.

b. Doceentation of all discrepancies are reported I

as required by KFP-10 of Q.A. Manual. Discre-pencies that can be corrected in the normal course of construction are not required to be reported on a DR.

c. Items written on Note-0-Grams to expedite incom ,

( plete work, is not considered a discrepancy and is not subsequently reported on a DR. l

d. Tracking of Discrepancies - see response to Item 1 of Finding 1.

e. Analysis of discrepancies te determine programmatic problems - see response to Item 1 of Finding 1.

(O f. Reporttag of significant conditions adverse to quality are reported via a monthly Q.A. Report and copies of all significant BR's are ser.t to Director of quality Assurance for evaluation and recommendations.

                                                   -E %

4

Response

No Corrective Action is required. TCc.nt. ) i FINDING 2. Based on the results of this audit and the problems encountered in the past, it appears that a corrective action system has not been operative.  : iaroonse: This is a very general statement. Each time a dis-crepancy is found, Corrective Action was taken to insure compliance with the contract and resgulatory requirements. It is recognized that there were some problems in the past. It should be noted that these problets were detected and dispositioned. Corrective actions were implemented in the form of revised procedures, further training of field inspectors and additional inspection goints. Essaples of these are; rewritten procedure for hanger installation and inspection, inspection points established for installation of concrete anchors, established a requirement that all radiographs be re-reviewed by a Level III or second 14 vel II individual. Corrective We have performed an internal review to determine if other quality deficiencies exist. No additional defi-( Action: ciencies were noted. yINDING 3. There is no procedure for reporting 50.55(e) deficiencies. Response: 10 CFR 50.55(e) requires the holder of the permit (PG&E) to notify the commission of each fault in design and construction. Our DR System reports all such deficiencies to the owner. It is his obligation to report any he determines may adversely effect plant safety if uncorrected. k O m ,

CRITERION XVII. QUALITY ASSURANCE RECORDS IO F1ND1NG 1. Procedures --u and mS-u .a -st of t,e - adequately identify the records to be retainad. . ed-Response: No comment. No Corrective Action required. l . b Procedures KFP-14 and EFPS-12 provide adequate guidance FINDING 2. and mechanisms to assure collection of most records. Records that are not specified in these two procedures (e.g., records on heat treatment, torquing, pipe rupture restraints) do not have any documented mechanisms for collection, but are adequately assembled and retained. Response: No comment. No Corrective Action required. FINDING 3. There are no procedures for filing, storing, and protecting records, i.e., no requirements for the vault, no method on how records other than isometric packages are identified, no instructions on how records are to be stored. Bowever, the practices employed do provide for adequate identification, (O retrieval, and fire protection. Response: The finding notes adequate systems, but wants specific instructions. Some are included in ESD-212. Corrective Revise ESD-212 to more specifically reference storage Action: methods. FINDING 4. Procedure ESD-212 does adequately describe a security system that provides "out" cards for identification of the record and the individual using the record and for the overall security of the records within the vault. Response: No comment. No Corrective Action required. j

                                                                                 -M-

l CRITERION XVIII. AUDITS  ! Procedures KFP-18, 19, 21; Procedures EPPS-16, 17, 18; FINDING 1. *** a er e a =s"-21'

• 222
• ri$ d a t O program. .

A Response: No commaant. 1 5 No Corrective Action required. b' I FINDING 2. The audit program does not require the use of checksheets l or procedures to delineate the scope and extent of the audit, nor does it require that the audit teamileader be qualified. Response: At the time the audit program was instituted, audit reports were made in narrative form. See Q.A. Manual KFP-18 Paragraph 18.4. When preliminary issues of N45.2.12 and N45.2.23 were first available in 1975, Corporate Quality Assurance prepared necessary auditing procedurcs and qualified , audit team leaders as required, to perform the auditing required at 6 month intervals of the site by Central Staff personnel. This is all outlined in Corporate Procedure XVIII-1 available from the site Q.A. Manager. { Corporate procedures do use check sheets but Internal l

                         ^=ait 67 fieta c i aa =at =ec        rit7 re==ir   t* ir    -

1 O Corrective Use of checksheets has been incorporated as a requirement Action: when internal audits by site Q.A. personnel are performed. j FINDING 3. In response to KFP-18, Paragraph 18.2.1, management audits were performed approximately every six months. Check sheets were employed. Based on the results of this audit and the results of Pacific Gas & Electric Company audits, these management audits appear to have been ineffectual. Response: Management audits of the Diablo. facility were started 9/19/72 and have been conducted at periodte intervals since t, hat time. There is a record of nine management audits on file from the time period of 9/19/J2 through 6/21/77. These audits clearly detect and define areas of deficiencias, and are followed by recommended corrective action for implementation. Verification of the adequacy of the implementation of corrective action was verified on subsequent audit's conducted by management personnel. - We disagree with the statement in audit findings that {- these management audits appear to have been ineffectual. O No Corrective action re ired. Q , 7

FINDING 4. Procedure EFPS-16 does not require management audits. ( Response: The ASME approved Q.A. Manual requires manag e t audits. It covers the entire scope on site inc}uding f. hangers. EFPS was written only to supplement it. W. No Corrective Action required. ,

                                                                                               }p
           ;                                                                                              1 kNDING5.          In response to EFP-18 and EFPS-16, internal audits were performed every six months. Check sheets were not employed.

Response: EFP-18 and EFPS-16 specifically reference narrative reports and use of check sheets was not required. . i i See Corrective Action audit Finding 2 above. l l FINDING 6. There are no procedures for audit reports, audit l j i responses, and time limitations on responses. l l Response: Corporate procedure XVIII-1 covers all these require-l l ments and is available at job site. No Corrective Action required. FINDING 7. Procedures KFP-18 and EFPS-16 require that a copy of the audit report be transmitted to the Manager of Q Quality Assurance. Response: No comment. No Corrective Action required. FINDING L. There are no requirements that the Manager of Quality Assurance track the audit reports or take any corrective actions when programmatic or recurring deficiencies are noted. Response: Q.A. Manual RFP-18 require that medit findings be reviewed by the Q.A. Manager. Be must assEre corrective action has been taken. This requirement cosers pro-

• i I

grammatic or recurring deficiencies. Corporate Procedure IV-2 for non-conformance requires evaluation of non-conformances to determine whether they"are programunatic or recurring, and outlines required steps to do so. No Corrective Action required.

     .O w                  ._
                     -         -    L -.             _ _ - - - _ - . _ _ - -          . - . - . _ - -

                                                                                                                        ~              -
        ~

3- ,.

c. Al g .:- FINDING 9. There are no requirements for periodic, independent,.. , j ,q g.. internal audits of the total quality program, at . ; . . .c .

                                                                                                                                                                           ~
                                                                                                                                         ~

3+ '{ O Response: There are no Regulatory Code or Customer requirements _: ~ for independent audits. Use of independent endits is a mechanism used by Pu11mac to review the adequacy of . their work and program. Independent groupe have,tsen p employed on occasion to obtain alternate views. ' *

     -              No Corrective Action required.                                                                                               g b                                                            '                                                                                        _e-FINDING 10. One independent internal audit was performed in                                                                               - p C: -%

January, 1976. ~ 7e? 4 Response: No comment. ,_ No Corrective Action required.

                                                                                                                                                                         .~

m

                                                                                                                                                      ~

(O G P (*

                                                                                                                                                      ~.'           g'               '

a%

                                                                                                                                                             . ._ - Y,J
                                                                                                                                                  *E. . * :=_- ! *

( m ___ . . _ _ . . _ _ __ . _ _ _ . . . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ . . _ . . . _ _ . _ _ _

                                                              .                                                        m o 6... .wv. m p    own ron surna-courawy vers
                                                                                               .                                ATTACMmeur Y
           " Nnv a    e"uv    QUALITY ASSURANCE                                                                                                                                                 .

No. -

         "'t*"*"                                                                                                           .                                                           .

sumaser Pullman Power Products Quality Assurance Program

                 .        Audit No. 80422 June 13, 1978 MR. J. D. WORTHINGTON:

Attached is the report of an audit conducted by the of the Quality Assurance:program quality assurance Department to determine implemented at Diablo the adequacy"Canyon Power Plattt by Pullman Power Products. The report concludes that, in general, the Pullman program meets applicable requirements. However, three programmatic deficiencies and three deficiencies in the implementation of established procedures were noted. (- Two Nonconformance Reports and four Minor Variation Reports were initiated by the General Construction Department. O General Construction personnel are working closely with Pullman's management in correcting the deficiencies identified. Resolution of these deficiencies will be verified by the Quality Assurance Department. . l R. P. WISCHOW VLK (3694):en . cc: JRAdams CKMaxfield RSBain RDRamsay WHBarr HWReynolds EPBraun GVRichards JCCarroll J0Schuyler FACrane, Jr. CHSedam JBHoch BWShackelford DVKelly MRTresler FCMarks RWWhite FFMautz - ( . 1 O .

• e dr
• Audit No. 80422

    '                                                               ~

• I sue Datas 6/13/78 Pag) 1 cf 12 PACIFIC CAS AND ELECTRIC C(MPANY QUALITY ASSURANCE DEPARINENT Fullman Power Products Quality Assurance Program

Title:

Audited Organiration/ Facility: Pullman Power Products at Diablo Canyou Power Plant Auditors:* M. E. Leppke (Lead Auditor) C. L. Eldridge R. W. Taylor Dates Perforned: April 2 - June 1. 1978 1.0 _Scope This audit was performed with three objectives in mind. They were: (a) Verify that the Pullman Power Products Quality Assurance Program (splemented at the site meets contract requirements and the require-ments of applicable regulations, codes, and standards. (b) Review objective evidence to determine the validity of the findings (- of an audit performed by Nuclear Services Corporation (NSC) in 1977 and determine if Pullman's responses were accurate and appropriate. O (c) Observe the as-installed condition of components and supports fabricated and installed by Pullman to verify adherence to applicable specifications, design drawings, and quality standards. 2.0 Conclusions and Exit Interviews 2.1 Conclusions . The Pullman Power Products. Corporate QA Program and the implemen-tation thereof were reviewed in light of the audit performed by Nuclear Services Corporation. 'dditional audit activities included a review of the installed hardware. Se primary conclusions are given below with additional detaile set forth in Appendix A. (a) Adequacy of the Pullman Power Products QA Program The Quality Assurance Program implemented by Pullman Power

                             . Products essentially fulfills contract requirements and meets requirements of the ASME Boiler and Presspre Vessel Code, 1971 8          edition. However, three program deficiencies were identified and three deffilencies in the implementation of established procedural requirements were noted. Two Nonconformace

(, Reports and four Minor Variation Reports were initiated by General Construction. Areas were also identified where it O appears.co be to Pacific Cas and E1ectrie ComPanP s advanta e to upg'ade r program elements though no violatione of applicable regulations, standards, or the contract are apparent. e

s. . - - . _ _ _ - . - _ . _ _ _ _ _

 ' '                                                                                                                                                           Audit No. 80422

• Pagn 2 cf 12 (O

(b) Evaluation of the Nuebear Services Audit of Pullman Power Products QA Program

                                                                                                                                                                                                                             .g 1

Several apparently generic deficiencies in work performed by 4 P, ullman were previously identified by the General Construction

                                             . Department. As a result, extensive reinspections were directed or performed by the General Construction Department. Additionally, Pullman was asked to perform an overall evaluation of the aatept-                                                                                                                       i ,
                             .                ability of the installed components and supports. An independent party, Nuclear Services Corporation (NSC) was contracted by Pullman to perform this evaluation. However, the resulting audit did not 6                             achieve its main objective in that NSC concentrated almost entirely on Pullman's Quality Assurance Program and inspected very little of the installed hardware to determine the quality of the work.

NSC's audit findings allege that major portions of Pullman's program are inadequate. It is essential to understand the requirements which NSC audited againet to place the NSC audit findings in . Perspective. The audit checklist used by NSC states that require-ments for the NSC audit were extracted from the following sources: a) 18 Criteris (10CFR50 Appendix B) b) Crey Book (WASH.1283 " Guidance on Quality Assurs. ace Requirements During Design and 'frocurescat Phase of Nuclear Pocer Plants") c) ANSI Standards d) Nuclear Services Corporation (internal guidelines) The 18 criteria of 10CFR50 Appendix B are applicable. Chapter l 17.1 of the Diablo Canyon Final Safety Analysis Report constits l to a quality assurance program meeting the intent of 10CFR50 Appendix 5. Pullman's program also commits to the ASME Boiler l and Pressure Vessel Code (CODE),1971 edition for quality assurance requirements. The 1971 Code is consistent with the requirements of 10CFR50 Appendix B. The WASH 1283 document (Grey Book) is not applicable. Chapter 17 of the Diablo Canyon Final Safety Analysis Report makes no commitment to WASH 1283 for the design and construction of Diablo Canyon. WASH 1283 endorses ANSI N45.2, 1971 and ANSI M45.2 series standards. ANSI M45.2 states in its foreword that it is not applicable to work performed in accordance with the Code. ANSI N45.2 series standards state under " Scope" that they are intended for use in conjunction with ANSI N45.2, 1971. The ANSI Standards are not applicable for the same reasons (O. . e Pressed for WAS 1282. Internal MSC corporate guidelines only represent the' opinions l of the auditors and are not interpreted by PGandE as requirements. l

        .                                                            %                      i*                                                                                                                                           l e , , e- - - - - , - - - - - - , .            ,  r - -,      ---n   - - - . - - ,    - - - - - , - - .         --~----.n--- --. -- --,- - - , - , , - - - , - - -                  , , - - - - - , - - _ , - , , - - _

w. - ... - _ _ _ . _ . _ _

m= _ Amdit No. 80422

                .                                                                                                Paga 3 of 12

Many NSC audit findings state that elements of Pullman's program are inadequate but specific deficiencies and references for l requirements are not identified. Some actual deficiencies were .

identified by the NSC auditors but many of their findings appear to represent the auditor's opinions with no bases in applicable regulations, codes, or standards. i I The audit performed by the PCandE QA Department essentially retraced the steps of the NSC auditors. Deficiencies identified

                                  /

are IIsted in Appendix A. Other alleged deficiencies stated by NSC do not appear to be supported by objective evidence or do I not appear to be based on applicable codes, regulations ' standards. Pullman's responses to the NSC audit findings in general appear to be correct. Bowever, to place the NSC audit findings in I proper perspective, Pullman should have assessed the applicability of requirements which NSC alleged that Pullman violated. , l (c) Evaluation of the Pullman Power Products Corporate Audit of the Unit 2 Hardware Installed by Pullman Power Products Corporation In February 1978 Pullman's corporate office performed an audit to verify that Unit 2 hardware items were installed in accordance with design drawings and specifications. One hundred twenty-two h - hangers, restraints, and snubbers and seventy-seven isometric drawing packages were inspected; no discrepancies were noted by the Pullman Power Products auditors. Approximately half of the items inspected by the Pullman audit I team were reinspected by PGandE during this audit; several l discrepancies weta noted. In light of the number of discrepancies noted, it is apparent that the Pullman audit did not effectively evaluate the quality of their work. Most of the discrepancies noted appear to be minor in nature. l Similar problems identified by reinspections in other areas l have generally been " accepted as is" by the PGandE Engineering Department. However, an overall assessment of the situation still should be done to determine whether additional reinspections should be performed and the scope thereof. Pullman's management agreed, during a meeting held on Kay 25, 1978, to send additional qualified staff to the site to perform the required evaluation. General Construction plans to direct the performance of the Pullman evaluatiou. MTR M-3725 and M-3726 wara initiated by General Construction to document and provide far resolution of the noted discrepancies. l(O W*

                          -c.,_..

Audit No. 30422

• Page 4 cf 12

( 2.2 Exit Interviews - Two preliminary meetings and a final exit secting were held to discuss - the audit findings and to establish the recorwended corrective actions.  : (a) Preliminary Exit Meeting (May 10, 1978) 1 A meeting was held on May 10, 1978 to discuss the results and ,

               .-    preliminary findings of the audit of the Pullman Quality Assurance Program and of the overall pipe and pipe support inspections. The         j following personnel attended:

General Construction Quality Assurance Engineering C. K. Maxfield R. P. Wischow J. B. Hoch M. R. Tresler V. L. Killpack R. Etzler M. E. Leppke G. Arnold C. L. Eldridge , R. W. Taylor (b) Preliminary Exit Meeting (May 25, 1978) A meeting was held on May'25, 1978 to discuss corrective actions with General Construction and Pullman Power Products. The General ( Construction Department directed Pullman Power Products to perform the required corrective actions. Those in attendance were:

                             ~

Pullman Powr Products Quality Assurance General Construction M. Evans V. L. Killpack C. K. Maxfield P. Runyan M. R. Leppke M. R. Tresler J. Ryan R. Etzler A. Eck (c) Final Exit Meeting (June 1,1978) A final exit interview was held on June 1, 1978. Audit findings and agreed-upon corrective actions were suimmarized. All deficiencies identified during the audit had been documented prior to the exit interview by General Construction on Nonconformance Reports or Minor Variation Reports. Those in attendance were: General Construction Quality Assurance C. K. Maxfield R. P. Wischow M. R. Treslar V. L. Killpack R. Etzler M. E. Leppke G. Arnold - C. L. Eldridge ( O

                                       %. p.

• Audit No. 80422
• Fasa 5 cf 12 .

(O As a result of this audit the following Nonconforrance Reports GlCRs) and Minor Variation Reports (MVRs) were written by the - General Construction Department to resolve the problema identified: NCR Description DC-78-RM-004 Documents the lack of program definition and lack of detailed

                       .'                                                                                audit schedule.

DC-78-RM=005 The relative responsibilities of QA and production are not clearly established. Description MVR ,, M-3723 Fullman Corporate Management audits were not performed,at the scheduled frequency. M-3724 Bold points were bypassed. M-3725 Hardware discrepancies were noted. M-3726 Discrepancies concerning isometric drawing packages were noted. Corrective actions were agreed upon; the QA Department will verify the resolution of these nonconformances and deficiencies. Prepared by: ~M E bf? Kt- . f A N. E. Leppke i

                                                                                                              ' ~
                                                                                                                                                 'C. L4Eldridge flu Tn JR.erW.{.,/ taylor                            h.            J~

f.bf a 4 l 9 , Approved by: y1 - . w-  ! i

                                                                                                                                                        *)
                                                                                                                                                                   .4            %
                                                                                                                       ' -                        V. L. K111 pack t
                                                                                                                                            ~                        b R. P. Wise 6ow / "
                                                                                                                        ~

BEL /CLE/RWr:cs *- Attachments

Audit No. 80422 Pag 2 6 cf 12 APPENDIE A {

• In this section, the deficiencies which were identified as a result of the audit cre discussed. The problem in each instance is identified to a specific Noncon-fermanc.e Report- (NCR) or Minor Variation Report (MVR) that was initiated by the General Construction Department.

Inadditio$,non-mandatorysuggestionsandrecommendationsofprogramimprove-ments are given for consideration. 1.0 Program Deficiencies Two Nonconformance Reports were initiated for the three identified deficiencies. (a) Nonconformance Report No. DC-78-RN-004 This NCR is comprised of two parts as follows: (1, The Pullman Power Products Quality Assurance Program is not adequately defined. The ASME Boiler and Pressure Vessel Code, Section III, paragraph NA4140 of the 1971 edition requires that the Quality Assurance Program be documented in detail in a h- manual consisting of written policies, procedures, and instruc-tions. Corporate Procedure No. XVIII-1 is presently being used O for the performance of management audits of field activities. Corporate Procedure No. VII-1 is being used for qualifying vendors for the Approved Vendors List. These procedures implement Quality Assurance requirements of the contract but are not identified as part of the program and revisions are not controlled by the program. The program is required to be approved by the ASME, and changes to the manual are co be approved by the Authorised Inspection Agency. KFP-1, parag,raph 1.13 states that Engineering Specifi-cations (ESDs) shall be part of the program. Most ESDs appear to be implement.ing procaduras, but some define actual program elements. For example, ESD-240 establishes the Noncompliance Report (NCR) system. No evidence could be found to indicate that ESD-240 has been reviewed and approved by the ASME or the Authorised Inspection Agency. It is not clear which manuals and procedures are. applicable to specific activities. The 1;1pe support manual is considered by site personnel to be a supplement tu the piping manual. The piping manual is approved by Pullmar.'s Vice President but the support manual is only appreved by the field QA Manager. However, the front page of each manual indicates that it establishes the quality requirements for work performed under that manual. The defined scope of each asnual indicates that the two apply to (O different construction ectivities.

             -                                                   r.       ,.

      *-                                                                                       Audit No. 80422

• Pago 7 cf 12

                               '.. -l<jg (O                        Engineering Specifications appear to supplement one or both manuals or independently establish quality assurance program requirements. Special QA instructions are dritten to supple-                               ,

ment and clarify Engineering Specifications or procedures in T one or both manuals. Recommended Corrective Action

                      ,.       (a) Write a program description which clearly identifies the documents that are to be considered part of the total quality assurance program and establish the hierarchy of the documents 6

(where necessary obtain approval by the proper authority). (b) Define approval requirements for the above documents and for revisions and obtain approvals where necessary. (For example, approval requirements are not provided for special QA instructions). (c) Clearly define the secpe of work to which the above documents are applicable. (For example, do requirements of the piping manual apply to pipe support work?) (d) Review the program to insure that supplementary procedures do not include requirements which conflict with requirements of the procedures they supplement. Several KFP procadures {( ) require the involvement of the AI. Corresponding KFPS procedures allow work to be done without AI involvement. KFPS procedures clearly cannot supplement KFP procedures without revising the KFP procedures to allow waiving Al involvement on non-Code work. (Example: KFP-7 and KFPS-6). (2) PGandE Specification 8711 and the 1971 Code, Section III, paragraph NA4700 require a comprehensive system of planned and periodic audits to be carried out to assure compliance with all aspects of the Quality Assurance ProFram. Procedure KFP-18 states in its scope that it establishes such a system. However, two types of audits, management audits and internal audits, are described. The procedure does not establish the scope of either type of audit and no detailed schedule has been developed to show that all aspects of the program are being audited. Furtheracre, audit records at the site do not indicate that all aspects of the program are being audited. Records do not indicate that management audits have been performed on pipe support work. An unofficial, unapproved internal audit schedule

   .     . . .. .               exists, but it has not been followed consistently and few ESDs                           ...... ...

appear on the schedule. A March 1977 internal audit erroneously states that KFP-3, -5,'-9, and -14 are not to be audited as they I do not apply to Diablo Canyon. Internal audit schedules for October, November, and December.1977 and January 1978 vere not (O met. l l 1 l

1_ ~ Audit No. 00422 Pag 3 8 cf 12 ( Recommended corrective Action Estabitsh and implement a detailed audit schedule to assure compliance with Specification 8711 and the Code. (b) Nonco'nformance Report No. DC-78-RM-005 PCandE Specification 8711, Section 4, paragraph 3.11 requires that huslity Control personnel perform only quality control functions and that they be free of scheduling and production pressures. 6 A review of procedures and work in progress indicates that Quality Control inspectors' independence from scheduling and production Procedures pressures is not assured by the program as written. do not clearly indicate that it is the Production Department's responsibility to read and use the process sheet insuring that steps are performed in the required sequence and hold points are observed. During the course of this audit, it was noted that two hold points were bypassed on FW #362 (see Section 2.2 below). Discussions with individuals involved indicated that the Quality Control inspector was expected to follow the work and ensure that inspections were performed at hold points indicated on (_ the traveler. The Foreman apparently had not read the traveler and was unaware that hold points existed. A QC inspector should O not be responsible for directing the course of construction to ensure that hold points are observed, particularly if he also signs off these hold points. Pullman's procedures identify the Field QA/QC Manager as responsible for ensuring that most Quality Assurance Program functions are performed. Field QA personnel had already determined that some procedures needed to be revised to clarify or redefine responsibilities l to ensure that production responsibilities are not assigned to l QA/QC personnel. The Assistant Field QA Manager has drafted revisions to three pipe support manual procedures and is reviewing others to determine whether revisions are needed. Recommended Corrective Action (a) Revise KFP-8 and KFPS-7 to clearly state that production is responsible for following the traveler and ensuring that hold ' points are observed. QC should only be responsible to inspect or audit. ( (b) Review procedures and practices to verify that QC is neither procedurally nor functionally placed in situations where their (), independence may be compromised. Revise procedures as necessary. g.

Audit No'. 80422

 .                                                ~

Faga 9 cf 12 ( (c) Perform the training necessary to ensure that produc' tion and QC personnel fully understand their relationship and the functions , they are expected to perform.

    -         2.0 Deficiencie's in Implementation of Procedures 3 --           -

Four Minor Variation Reports (MVR) 723; }i-A M-3725, and M-3726 were,. initiated by General Constructica for the identified aerici=uues. (a) Minor Variation. Report No. M-3723 Records indicate that management audits have not been performed by Pullman Power Products Corporation at the specified frequency. Management audits are required by KFP-18 to be performed at least every six months. Since December 1975, audits have been performed at eight to ten month intervals. . Recommended Corrective Actio_n Conduct audits at required intervals or change the requirements. (b) Minor Variation Report No. M-3724-On April 25, 1978, work in progress was inspected to verify that {- the Field Process Sheet was being used as required by procedure KFP-8. It was noted that the repair work on FW #362 had proceeded ( to step 4 on the Field Process Sheet. The Field Process Sheet was in the custody of the area QC Inspector. Inspection of the Field Process Sheet indicated that, contrary to KFP-8, paragraph 8.4, j work had proceeded beyond two hold points and the designated inspections had not been performed. Corrective Action The Field QA/QC Manager issued Nonconformance Report #265 and agreed to write a procedure requiring the isnuance of a Field Process Sheet to production. The procedure is to clearly define l responsibilities for using and completing process sheets. (c) Minor Varlation Report No. M-3725 Minor Variation Report M-3725 was initiated to document the ) following hardware discrepancies, noted by the PGandE QA Depart-ment, to facilitate their resolution. C O e 9' e

Audit No. 80422 Paga 10 cf 12

        .         i Supp:rt er
 .                    Isometric               Description of Discrepancy                .

47-69R Vertical clearance is' 1/2" should be 1/16" ( 47-70R Vertical clearance is 1/2" should be 1/16"

• 46-17R Clearance is 3/16" should be 1/16"- .

Weld Item 2 to 1 not all around ,

          .             77-12SL   Snubber installed on wrong pipe

• 77-14SL No torque seal 23-7v Location Item 7 is 5/8" should be 4" 23-8V Weld Item 9 to pipe not all around

                .       23-5R     Clearance Item 12 is 1/4" should be 1/8" 23-12R    Missing anchor bolts 23-16R    Grinder Gouges 3/32" deep.
            **                    Loobs. bolt

• Clearance is 1/8" should be 1/16" 23-66R Clearance is 0" should be 1/16"
• 947-1R Weld Item 1 is not all around 90-44R Weld Item 9 is not all around
• 90-45R As-built does not reflect added shim . . . _ .
• 90-47R Weld Item 6 only tacked

(( 90-48R As-built does not reflect added weld

• 96-6V 5/8" tod used in lieu of 1/2" rod 90-46A Weld Item 2 is 5/1C' should be 3/8" 72-19SL Weld Item 4 not both sides
• 6-4R Weld on attachment is 1/4" should be 3/8" 6-28R Fabrication of "t" shoe not to as-built
• 6-6V Dimension is 3'-1 1/2" should be 2'-11 11/16" 6-SV No load on support, not tightened 2730-61 No Clearance "t" shoe to clip 2730-63 Broken stud 2730-65 No clearance "t" shoe to clip 2730-66 No clearance "t" shoe to clip

2730-42 Clamp loose, wrong location -

l 2730-21 No clearance "t" shoe to clip 935-23 Brace weld not all around 935-24 Brace is 45* should be 55' . 935-25 _ Configuration opposite'to DWG. 935-27 Brace weld not all around

• These items were accepted as-is by General. construction during the l -  !

course of the audit. ~ ,

             ** C cm corrected during the course of the audit.

Audit No. 80422 Fage 11 of 12 (( (d) Minor Variation Report No. M-3726 ' Minor Variation Report No. M-3726 was initiated to document the following discrepancies noted in isometric drawings to facilitate their resolution:

                                                 ;    Support or Description of Discrepancy Isometric 2-3-18       ISO shows check valve as Spec 8729 Item 17 (Velan).

Installed valve is Spec 2550 (Weston Hyd.) 2-3-19 Same as 2-3-18 Line 1058; dimension shown as 2'-8" is l'-8". 2-4-418 2-9-478 F.W. 858 is etched on two welds 2-12-5 F.W. 170 is stamped 176 2-14-14 Detail for PX263 refers to pump 2-1. should be 2-3. 2-3-418 F.W. 1390, 1391, & 1392 are shown by the process sheet to have been performed using stainless steel ' ~~

                       ~                                              309 rod. Joints are all carbon la carbon.

Note: Documentation was determined to be (-(])- incorrect. The correct rod was verified to have I been used. 3.0 Recommendations l Several comments and recommendations for program requirements were presented l i for consideration to the General Construction Dept. during exit interviews and are summarized as follows: , (a) Schedule for Implementation of Commitments A schedule for implementation of the following comunitments should be established: . Training program - added to KFP-1, 12/23/77. Use of internal audit checklists - made in draft responses to NSC audit. Issue a procedure requiring a process sheet to be issued to production. Commitment .of' 4 /.25/ 78. -

                                                                                                  ~

1 Implemer.tation of corrective action resulting from this audit. (( )

                                                                                               &e r
             ,. , . ~ - - - - - , , . - ,-.. --.                            - , , - . , . , -                    ..,,,,-r     , ,,      .      r.,

                                                                                                                                             ~
                                                                                                                                                  - . . . . .                        =                  -

s* - Audit No. 80422

          .                                                                                                                                      Page 12 of 12
   ' co                                                                                                                                        .

(b) Pullman Problem Reporting Procedures These procedures should be revised to facilitate determining and l' g verifyi,ng corrective actionc. The following changes are recommended: I.ssue internal audit findint.,s as NCRs. Expand the use of NCRs to cover all conditions adverse to quality which are not covered by DRs. Require the cause as well as the corrective action to prevent recurrence to be documented. Establish a management review system for DRs and NCRs to identify trends. (c) Inspector's Certification The Pullman inspector's certification <ard should be amended to eliminate the claim that inspectors are qualified to ANSI N45.2.6 or inspectors should be qualified in accordance with its requirements. A review of ESD-237 and qualification records indicates that some ((]} Pullman inspectors are not qualified to ANSI N45.2.6. (d) Description of Supervisory Responsibilities The KFPS (pipe support) manual assigns specifie quality functions to the " Hanger Engineering Supervisor". The responsibilities and duties of this position should be defined in the program. (e) Special QA Instruction Index ( An index for special QA instructions should be prepared. This index should identify the procedures being amplified and the subject being addressed. (f) Update Pipe Support Procedure KFPS-7 ! The procesa sheet shown in KFPS-7 is Revision 7 and the process sheet abown in ESD-223 is Revision 8. The latest revision of the process sheet should be placed in EFPS-7 or the process sheet should be removed from the procedure, i (O i

                                                                             \                k*

4 esyg (85T # N o.PGwE co.in na-co - aNv use. g g g y 3 (OlvlS80N04 sepaavusut QUALITY ASSURANCE ._ . . _ _ . , . . _ I Fai.s No. j

           .svvan or                                                                                                                                     ,

scv Review of Nuclear Services Corporation , l Audit Pindings June 16, 1978 MR. R. S. RAIN: An audit of the Pullman Power Prod >. acts quality assurance program was conducted at Diablo Canyon Power Plant by Nuclear Services Corporation (NSC) in August and September 1977. The

                       " attached is a review conducted by the Quality Assurance Department of the NSC audit findings and Pullman's responses. Not all findings are addressed; those NSC findings which are not addressed in this review either stated that a program element was acceptable or only concerned insignificant, isolated discrepancies in documen-(                    tation.

O Pr- this 1 - conc 1ude that the =SC audit was directed primarily at the progransnatic aspects and did not address itself to the verification of the adequacy of the installed hardware. The NSC audit was superficial with respect to the hardware and very critical in the review of the QA program itself. As a result, the NSC audit is considered to represent an inadequate and inaccurate ameasure of the overall Pu11-= Power Products quality program. If you have any specific questions or need clarification of any point, please call either M. E. Lappke (69-1727) or C. L. Eldridge (3694), the QA Department Mrsonnel who performed this review. R. P. WISCHOW (3694):en l l cc: CIMaxfield IRTrasier ' IEELappke k- Attachemet -

                                                               %             ~. ..,.           ...,-..n-                                    -
                                                                                                                                                               ..--s'                                .

n>

                   .                       . . - . . .      .g         . .
                                                                                                                             .       . . . . .             .-N
                                    *          .                     a        .          ..         ..

q.

Pag 3 1 ef 12 Q Criterion I Finding 3* . The functions listed are not outside the scope of Quality Control as

                 -     defined in Specification 8711. The title, " Engineering Specifications "

is misleading since Engineering Specifications are actually Quality Assurance procedures. Engineering changes are reviewed only to verify compliance with Code requirements. Quality Control personnel have performed functions which should have been

                     , perfor'med by production personnel. Details and recommended corrective actions are outlined in Appendix A to QA sudit report No. 80422.

No cases where Quality Assurance has audited its own performance were identified. Corrective actiere recommended in Appendix A to QA audit report No. 80422 should insure that this will not occur. Finding 4 Responsibilities and duties of key personnel except for the Construction Superintendent were described in the manual at the time of NSC's audit. IFP-1 was revised on December 30, 1977 to include responsibilities and duties of the construction Superintendent and to add job descriptions for each type of Quality Control Inspector. General responsibilities aca C duties of Quality Control Inspectors were already identified. Fir.(iM Existing pcsition descriptions appear to meet the requirements of Specification 8711 and the 1971 Code. Finding 6 Interface procedures for each activity listed appear to meet the requirements of Specification 8711 and the 1971 Code. No interface procedure for holding meetings is required. Finding 7, KFP-18.3.2 requires the Field Quality Assurance Manager to send copies of internal audit reports to Corporate Quality Assurance. Management reviews of corrective action reports, nonconformance reports, and personnel qualifications were performed and documented as Management Audits. Fullman's reoponse was incorrect in that Management Audits on a semiannual basis are required by EFP-18, paragraph 18.2.1, revision 8/22/72. , (

                 *For exact wording of the NSC finding, the reader should consult-the NSC report "Fullman Power Products Work Scope at Diablo Canyon Site", dated October 20, 1977.                -
                                                                                     .g

                                                                                           -         I Fag 2 2 ef 12

( Criterion I -.  : O Findina 7 (continued) , The interface between the field and the Paramount Shop is described in 'T

               . EFP-6, paragraph 6.5 (Rev. 8/31/77) and EFP-4, paragraphs 4.2 and 4.3.1 (Rev. S/27/76).

Some functions performed by the corporata office at Williamsport are not controlled by the program but are performed in accordance with Corporate Procedures. Details are described in Appendix A to audit report

                   ,No. 80422.

Finding 8 Interfaces appear to be adequately described as follows: Drawing approval - IFP-4 and EFT-8. Review of isometrie, hanger, and restraint document packages - IFP-4, KFPS-7, and ESD-243 and -259, ro pe=tively. Walders' logs - IFP-21. Control of welding process - EFP-12 and -15. Finding 9 O No objective evidence could be found to indicate that the stop work l authority of the Field Quality Assurance Organisation is not adequate. j ESD-240 requires a hold tag to be placed et discrepant items. Construc-l tion personnel are forbidden by the procedure to work through a hold tag. l Eo objective evidence was found to indicate that a hold tag had been intentionally bypassed. The stop work authority described in ESD-240 appears to meet requirements of the contract and 1971 Code. Criterion II Findios 1 Chapter 17.1 of the Diablo Canyon Final Safety Analysis Esport commits to implementing a Quality Assurance program which meets the intent of l 10CFR50, Appendix 3. The Pullman Quality assurance Program cormits to meeting the Quality Assurance requirements of Section III of the ASME Boiler and Pressure Yessel Code, 1971 edition. The Quality Assurance requirsments of the 1971 Cods were written to be consistent with the requirements of 10CFR50, appendia E. ANSI E45.2 states in its foreword that it does not apply to work performed l ( l A. In accordance with the Code. 10CFE50.55a requires that nuclear power plant piping and components be l cometracted and inspe ted in accordance with the Code. l !~2

.. Page 3 of 12

                        .,           v.

(O Crn-ria u - Finding 1 (continued) . . The documents which establish requirements for the Pullman Quality * -

                      -           Assuraned Program are FGan2 Specifiestion 8711 and the 1971 edition of the Cod'e. ANSI N45.2 does not apply.

The program appears to meet the requirements of Specification 8711 and the 1771 Code except for the deficiencies listed in Appendix A to audit report i No. 80422.

                                ' Finding 2 Bevisions were made to the piping manual on December 23, 1977 to more clearly describe the prograu. The revisions improved the program description, but the program is still not adequstely defined. See Appendix A to audit report No. 80422 for details.

Finding 3 Fullman's response appears to be accurate. Bovever, the scope and applicability of the program do need to be more clearly defined. See Appendix A to audit report No. 80422 for det4ils.- Finding 4 Corporate Management Audits were verified to include nonconformances, personnel qualifications, and corrective action. However, implementation of a system for reviewing nonconformances to detect trends is recommended. See Appendix A to audit report No. 80422. Finding 7 Pullman's response appears to be correct. Procedure EFP-1 was revised on December 23, 1977 to require Quality Assurance training of all personnel ' involved in quality-related activities. Finding 8 Written examinations are retained in inspectot' qualification files. These examinations document the inspectors' familiarity with the requirements of myrlicable procedures. ESD-237 is a detailed training program for Quality Assurance and Quality Control personnel. Criterion III Findias.1 Pullman' response appears to be accurate and appropriate.

                                                              ~

9 e s ea + e gag ==

                                                                                                     ,,,               em e . . eneeme
     - . - - , - - ,      - ,----            ---.-,,,--,,,,m,          , , , , , . - - m-ac -w - t r---T----  w--*w-         -u--  -
                                                                                                                                           --'w-w--     -wye 7   yy===-vw=--- -
                                                                                                                                                                                ----*m'=7-------r--'v-v~-'-       -

                                                                                ~

P232 4 cf 12 Criterion III . O ,inding 3 It should be pointed out that Pullman's review is simply to verify code , compliance. Reviews performed to reconcile changes with original desiga requir&ments and objectives are perforr.ed by PGandE. No violation of the 1971 code or Specification 8711 is apparent. . Finding 4

                      , EFF-4 appears to be detailed enough to allow effective iaplementation. A more detailed procedure does not appear necessaary. No violation of the Code or cuatract is apparent.

l Finding 8 ESD-253 appears to adequately cover drawing control. EFP-4, however, may not apply. See Appendix A to audit report No. 80422. Criterion IV i Finding 3 i ( - Pullman's response appears to be correct. However, the Corporate procedure for qualifying vendors has not been oficially identified as part O of the program to be implemented at Diablo Canyon Power Plant. See Appendix A to audit report No. 80422. Finding 4 Pullman's response appears to be correct. l Finding 5 ( Suppliers are not used unless they appear on the Qualified Vendors List. a Yendor audits are controlled by Corporate procedures. See Appendix A to audit report No. 80422. Criterion Y I l . Finding I l ! The seditors' specific words do not appear in the program. Bowever, EFP-8, paragraph 8.2 requires that the Field Process Sheet identify "all operations i.nd inspections and the sequence in which they occur." Procedure numbers ars required to be referenced for each operation or inspetion. This effectively requires activities significant.to obtaining l [. quality to be controlled by writtsn procedures. O .

                           .    't .-         .      .
                                                                           .a                  ,

l . - - - - - - - 1 ~

                                                ~

m? --- - - - - - .

;*                                                                 ,                                                    Pass 5 af 12                      ,

a Criterion V (O Findina 2 . i Manger package review and preheating for welding are covered by procedures' as explained in Pullman's response. De other activities listed do not significantly affect quality and need not be performed in accordance with ' written procedures.

                            .Fioding 3 H e auditors state procedures are insufficiently described but do not l
                          ' reference requirements. With the exceptions listed in Appendix A to audit report No. 80422, the Pu11aan Quality Assurance Frogram appears to meet the requirements of Specification 8711 and the 1971 code.

Finding 4 Procedures do appear to follow the flow of the work. EFP-8 requires that process traveles identify the sequence in which operations and inspections are to be performed. D e response to Finding 3, above, is again appropriate. Criterion VI , Findings 3 and 4 EFP-17 was revised on December 23, 1977 to control R$D proceduru and Special Quality Assurance Instructions. Finding 5 - R ic Finding is directly contradicted by Finding 11. Finding 11 appears

to be correct.

l Finding 6 l H is Finding does not appear to be based or, requirements of applicable regulations or standards. Rere is ao apparent reason to change the established practice. Finding 7 PGandE's drawing control precedures assure that Pu11aan receives the latest drawing changes. De drawings are logged-in on the Drawing Control Index and controlled in accordance with established procedures. Field Engineers are required by procedure to verify that they are using the latest revisions. Drawing control appears to be effective and so violation of applicable requiremenes is apparent.  ; l

Pag 2 6 sf 12 .

                                                                 --                              c                  .

Criterion VI

O Finding 10 .

Corrective action was completed on December 30, 1977.

               ~

Criterion VII Finding 1 The inti d ace appears to be

                   .' See Appendix A to audit report No. 80422.

functioning adequately. Criterion VIII Finding 10 Applicable regulations and standards do not require trecific procedures for these items. , Finding 12 ( ESD-223 appears to meet the requirassents of Specification 8711 and the 1971 Code. O Criterion II Finding 3 SNT-TC-1A allows a person to be Pullman's response appears to be correct. meets the certified directly as a Level II if his training and experienet sum of requirements for Level I and Level II. It was noted that inspectors other than NDE personnel have notBowever, always met the guidelines compliance with for prior experience established in ANSI E45.2 6. Traicing and ANSI N45 2.6 is not required for this project. indoctrination guidelines of ANSI N45.2.6 were adopted and appear to have been met. Finding 10 Fullman's responses appear to .be correct. Findings 11' 13._15, 17 Fullman's responses appear to be correct. No violations of the Code or Specification 8711 are apparent. I

     .,O                                      '

4

      '.-                                                                                                              .t I

k

                            *-=--* --- ..
                             = - - . - _

                                                                                                                                          - Paga 7 cf 12                              ,
               *"*"' " '                                                                                                                        - -- T (O

Finding 5 . . Agree with Fullman's response.

               ~

Findina 6 Agree with Pullman's response. Inspection record sheets used reference ,

                     .the inspection procedure and establish acceptance criteria. The inspector

• does not put a check mark by each acceptance criterion but signs the form saying that all acceptance criteria specified have been met. This method of performing and documenting inspections appears to meet the requirements of the contract and the 1971 Code.

Finding 8 Records indicate that the proposed review was completed. No further corrective action is required. Criterion 21 Finding 2 ( EFP-8, paragraph 8.17, addresses this interface. ESD-229 describes the methods of performing hydrostatic tests. These procedures appear to meet O all requirements of ANSI B31.1 ANSI B31.7, the contract, and the 1971 Boiler and Pressure Vessel Code for work performed by Pullman. Finding 3 l Agree with Pullman's response. Finding 5 i Agree with Pullman's response. In addition, it should be pointed out that all systems required to be code stamped are being hydrostatically tested in accordance with the Code and witnessed by the Authorised Inspection Agency. Criterion III l Finding 2 Agree with Pullman's response. Calibration system does not appear to violate contract requirements or requirements of 1971 Code.

                                                                                                                         ~

(O~ . i ________mm..-_, , .__..___,- , , . , _ _ . _ - . _ , , , , _ , , , , , , , _ _ , _ - , _ , , _ _ _ . _ , , _ , , , _ _ , , _ , ,

l..

                                                                                     ~

V Paga 8 sf 12 Criterion III - O nau. 3 .- In addition to Pullman's response, it should be poinced out that

• procedures in effect since 1972 appear to meet requirements of the contradt and the 1971 Code. If significant out.-of-tolerance conditions had been identified, all items that could conceivably have been inspected by.the device could have been reinspected.

The code requires that measures be established to assure that measuring

                 ,and test equipment used in activities affecting quality be usintained
                 . within specified accuracy limits. The findings do not indicate that instruments that were outside specified accuracy limits were used in activities affecting quality.

Finding 3(g) contradicts Finding 3(f). Finding 3(h) has no basis in the contract or the 1971 Code. Criterion XIII Findie d Storage procedures appear to meet the requirements of the contract and ASME Boiler and Pressure Vessel Code, Section III, 1971. No corrective O et = r-Finding 3 Procedures appear to meet the requirements of the contract and ASME Boiler and Pressure Yessel Code, 1971. Finding 4 - No procedures required. Finding 5 Procedures appaar to meet the requirements of the contract and the 1971 Code. Finding 7 Beither the procedure nor the checklist appear to violate requirements of the contract or the 1971 Code. (, O . O e 9

                                                                 = em =

• e, g .. ..

            '                                                                                                                                    ~

Pass 9 of 12 Criterion XIV - Finding 1 . H e auditor appears to be saying that the process traveler is inadequate *

                      .          for indicating status since it is kept at an area inspector's station rather*than at the point vbers work is being performed.

2 Bere is no written requirement in applicable regulations or standards for

                             *t6e process traveler to be attached to or adjacent to the work being performed. Bold tags and discrepancy reports are need to indicate the
                           , status when discrepant conditions exist. H e traveler is available to the
                           ' person directly responsible for supervising the work.

Bovever, repair work in progress on main steam Field Weld #362 was checked and the process traveler was reviewed. It was noted that two hold points had been bypassed. Discussions between the assigned Quality Control inspector and the foreman in charge of the work indicated that the foreman had not read the process traveler. In this particular case, the traveler did not accurately reflect the status of the work and was not effectively controlling the work. Ses Appendix A to audit report No. 80422. D ere is no basis in applicable regulations and standards for requiring the process traveler to include cleaning prior to installation of insulation, preheating, checking gas flows, or checking 02 content in the backing gas. Dese are handled by established procedures. (O Finding 5 ! Corrective action was completed by Rev. 12/30/77 of ESD-229. I l Finding 6 Process sheets are available for foremen to read, but evidence indicates that they do not always read them (see Finding 1). Finding 7 h is practice has not been followed and is not required for work performed under the piping (EFP) manual (see Finding 1). EFP-8 is vaguely written and the field's interpretation is less restrictive than the wording of EFFS-7 for pipe supports. EFFS-7 does not conflict with KFP-8. It simply ad:Is additional requirements. Criterion IT Findina 2 l ESD-240 is a detailed procedure and appears to adequately implement l f h Specification 8711 and 10CFR50, Appendix 3 requirements. De procedure

          \)     ,

does not specifically address routing to PGandE, but the D.R. form has a space for customer approval. A check of 20 completed D.R.s was performed i and all were approved by PGandE. PGandt approval is required by IFP-10. Controls appear to be adegnate. .

Pag 2 10 cf 12 ( Criterion IV ~ l . O india 3 . EFP-10, paragraph 10.1.4 and ESD-240, paragraph 3.3 adequately describe l , the interface from the Pullman side. It is PGandE's responsibility to designate PCandE personnel to perform such interface functions. NCRs are l not required to be approved by PGandE. (See comment Criterion IVI,  ! Finding 1.) e' Findina 5

                     .'See comment - Criterion IVI. Finding 1.

Criterion IVI Finding 1 The corrective action system meets the contract requirements and the 1971 requirements of the ASME Boiler and Pressure Vessel Code. A non-sonformance was defined as a deficiency in a hardware item. EFP-10, EFPS-9, and ESD-240 require writing Discrepancy Reports for all deficient hardvere items. - (. ESD-240 also requires writing a Noncompliance Report for an item or work

              -        process which deviates from a specified condition or requircuent, but which can be corrected during the normal construction process. They are O               not considered to be permanent documents and are not presented to PGandE for review.

Deficiencies noted in internal audits are only required to be written up is narrative form in an audit report. They are not presented to PCandE l for review. 4 Becausendation: Espend the noe of Noncompliance Reports or establish a new reporting system to cover deficiencies which are not associated with a specific item or component. Make them permanent documents and submit them to PGandE for review. Use them to document findi1rgs of internal audits as appropriate. (See comment Criterion IVIII Finding 3.) Perform periodic reviews of DRs and NCRs to determine trends or identify areas where practices might need improving. Este: PGandE Specification 8711, paragraph 3 28 states "All conditions adverse to quality, the cause, and coirective action shall be docu-masted and forwarded to the Constructor and Contractor's supervision ( and management for analysis, evaluation, and review." Today's accepted definition of " conditions adverse to quality" is not O t i t d e

• dw items o 1P-

                                                      ,,       ,r                               .
  ~1.                                                                                                                  .

i Pass 11 sf 12 j Criterion IVI O Finding 2 , , Deficiencies identified on DRs and NCRs have been corrected. The recommendation in Finding 1, above, should be implemented to insure that . items not required to be documented on a DR or NCR are not left uncorrected. 75hding3

                         , Contractors are not required to have a procedure for reporting 10CFR50.55(e) deficiencies. pGandE has that responsibility.

Pullman does have a procedure in effect for reporting deficiencies in accordance with 10CFR Part 21. Criterion IVII . We agree with the Findings and proposed revisions. . Criterion IVIII . Finding 1 O Contradicts other findia.s in =>is section b7 sarin. audit . o ram is adequate. Finding 2 EFP-18 references Corporate procedure XVIII-1 and states that it is being need by the corporate office. Neither procedure defines the scope of internal or Corporate audits. EFF-18, revision 12-30-77, states that its scope is to present a system of planned and periodic audits which shall be l carried out to assure compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program. Bowever, it l doesn't say whether Corporate audits, internal audits, or a combination of j the two will cover all aspects of the program. A detailed audit schedule needs to be generated to assure that all - ,---*=..af 1.be. program are audited by somebody (ref. Specification 8711, section 4. paragraph 3.212). Corporate procedure XVIII-1 or its requirements should be incorporated into the site program. In addition, audits are to be performed in accordance with written j procedures or checklists-(ref. 10CF150, Appendix B, Criterion IVIII). Checklists for internal audits have been drafted but no requirement for their use has been added to the program. Corrective action is outlined in Appendix A to audit report No. 80422.

                                                        .             (     .

( g

__ __.__ .m.m . __ _ _ m.m

                                                                                                 ~
                                                                                                     .              paga 12 af 12 criterion IVIII                                                                                ,,

Finding 3 , 4 So evidence could be found to indicate that audits were ineffectual. Deficieseles identified were corrected, and correctiv. .d ion to prevent recurrence was implemented. Sowever, deficiencies have tended to recur. For esemple, deficiencies in drawing control were identified in February, i May, and September 1975. Deficiencies concerning the see of the qualified vendors List were identified in April 1975 and January and Jane 1976. This does not indicate that audits were ineffectual, but it may indicate a ' meed to establish a monitoring system to identify trends so that special l measures may be taken to prevent recurrence of deficiencies. Finding 4 Management audits of the pipe support manual were, in fact, not performed prior to 1978. EFP-18 does not appear to apply to hangers. The descrip-tion of the Quality Control procedures manual (KFP) in ,the front of the manual states that it applies to field installation of components, mate-rials, parts, piping subassemblies and appurtenances. A similar page in the front of the pipe support manual (KFPS) says that it applies to piping supports, rupture restraints, snubbers, pipe hangers, and structural work. The applicability of program elements needs to be.more clearly defined. Finding 5 See comments to Finding 2 above. Finding 6 EFF-18, revision 8/22/72, paragaraph 18.5 and EFPS-16, revision 8/22/72, paragraph 16.5 require audit reports to be written and forwarded to the A ! responsible supervisor and require that he institute corrective action. follow-up audit is also required. In addition EFF-18 was revised on December 30, 1977'to require a response to corporate audits withic 30 days of notification of violation. Bote: No written requirement for defining such time limitation exists. Existing procedures for sedit reports and responses already met 10CFR50, Appendix B and 'dpecification 8711 requirements. Finding 8 See Finding 3 above. Corporate procedure IV-2 does not apply to audit

                                                                                                   ~

l findi=Ss. Finding 9 See Finding 2 above. la addition, KFF-18, revision 12/30/77, paragraph li 18.7.1 requires periodic independent audits of the Director of quality Assurance by personnel not associated with quality Assurance function. The word " periodic" should be defined.

     ;       ,g 4 ,. h, A.,x.

NONCONFORMANC5 REPORT , h0e I.. v n.ans ne.13111 o'y%;t* pimumn v, _a,w o.et depe*er

                                                                                                                                                                                                    ' c:::
          , iocutwicAnoN:                                             0 a
       -                                             O     C                         7                          R     H            .         0 '0                     4                                   ~

( ~

                                                                            ~TO BE cOMrl.ETED IfY INITIATOR 2 l"O,* ,,,,, Specification 8711                                                                                                                                                                           0 3 g*",f'                  (A) Quality Assurance Pro ram and (B Audit Plart                                                            'CKM'                                                                     *
              $, *""*"*" See pages 2 and 3.

c Y'* NOV 2 2Wru r - y _ olu _ STATHNt401181. 4oP MRT _mpeym,n Fl' E . u se, ..o a .i. . g e. ,o.a.o COPY f$1 __ f 5 OMIGWATED: g"'*[*hgggggjgg] * g/ ]V7g "O /My[f ,, , , E W5dow TO sE COMPLETED sY TECHNICAL HE)/IEW OROLM _ et...., r .a.m. C _ , , See Dage 3. _ . . . . nr.rern 3CS I,' .

                                                                                                                                   .;,ur cuinarXMT s 110 E _                                                                 ,
                                                                                                                      ."                       ........,n  _

i. t ,,,

n o. c c I.i Seepartes3andgJn .. --

0 T

                                                          .s f-      g '
                                                                                                                              ;'-             ~ ' -                .
                                                                                                                                                                                       ,,3 J                                            ._                UD.                                        n. a                           =               w-
             ?   .>...., .u. i o n .<c ,

5 ca.. c. nvu A<or,.i to r e,en. fr . . ns.

                                                                             )(nJ M ,/re;<             -T n,   c w o.                                            f*                  /_ /

Implementation-of/thb+esolution inill nrovont es.curr nc. h i; pp - , m A ! f $U. (( /M.dNo, M a 10/3/78 8 $<TL. $///h 1, T Y1 A&. ~' '

                                                                                                                                                               ?._1Gn/78 I

o C"......,R 1 / [ 8 A Q, . _ ton /7a a ,c,,t mEo A,,<m / a- T,...

                                                                            /ofa,,3f YO E COAsPLETED by IMPLE.MENTING OftGANIZADON

m . ..

aAAf ~~ ~ l

             ,,  ne,.*,,u.n c.n.su. ..e
                                                                            ,""'* fhh                                                                                      ~*/ / //3l7y 1
            } c...,s.,,,..,...,-

,~

                                                                                           'Me f/jffQ
                                                                                                                                                                             ~ w i /,7 i n

_/ /

       ,y'         .   ,,.n . .. e . .. .

j

                 ....,.,......-i                                         Oy"-"                //g                                                            ,
                                                                                                                                                                                               /           j r n.,....
                                                                                                                                                                                                 .. .. s TO 31; COMPLCTCD SY OUALITY A$5UllANCE                                              /            ,

. .v.e l 10vc

nirscAnOu: /'

n n ii.a.a.:c.m Arna.r.<**.= /44 s, ,m

                                                                                                                                       ,##4L9                                           // /8/ / 7P

(, ossTnisuTeon to.ha o.,,mia aes_ e see.;,. info,,n.ne i ybV. ,n,.ncere . .e..ies i s t l AutNori:ed in4ector (los ASME items) O Plant SuperintenJent O Security s3 Steam Gmeration Engineering Raeardi Q aplatesists l O Engi. srisia _ Ouality Assurance f( ContractordubftdJ t'J=W #MWf.(

    *-. ) )( Statir,n Comteuction R.D.9J4. A)[R.b.traul                           $stety Hoofth and CWnn                           O Other l

O AMitiovie sheesi s attachsal , N

w,

          ~

y, *

• s .%

Page l' NONCONFOPHANCE REPORT .

        -                                                                                                                                                                           r DC'O RH - 004                                                                              014':~

() U di. . W H Oescription: ,

                                                                                                                                                                  'O The Pullman Power Products Quality Assurance Program is l   (A) adequately defined. The ASME Soller and Pressure Vesse                                                                            -,

C Section~ III, paragraph NA4I40 of the 1971 edition requi O

• the Quality Assurance Prcoram be doctamented in detail in'

                                                                                                                                                                                      }

N consisting of written pol' cies, procedures, and instruct 4 F Corporate procedure No. XVill-1 is presently being used for the * [ 0 perfonnance of management audits of field activities. Corporate R procedure No. VII-l is being used for qualifying vendors for the . g g Approved Vendors List. These procedures implement Quality Assurance requirements of the contract, but are not identified N as part of the program and revisions are not controlled by the g program. The program is required to he approved by the -ASHE, and chan0cs to the manual are to be approved by.the Authorized Inspection ' Agency. KFP-), paragraph 1.13 states that Engfnaering Specifi-cations (ES0s) shall be part of the program. Host ESDs appear. to be Iglementing procedures, but some define actual program elements. For example, ES0-240 establishes the Noncompliance Report (NCR) system. No evidence could be found to indicate that E50-240 has been reviewed and approved by the ASME or the l

                                                 . Authorized Inspection Agency.

(. ' which manuals and procedures are applicable to It tj i .spce 1 The pipe support manual is considered by site per p ement to the piping manual. The l piping manua - n's Vice President but the support manual is on i field QA Manager. Ilowever, l I the front page of each ma i t establishes the l quality requirements for work pe manual. The - defined scope of each manual indicates pply to different construction activities. I Engineering Specifications appear to supplement one or both manuals or independently establish quality assurance program I requirements. l (B) P G and E Specification'8711 and the 1971 Code, Section III, paragraph itA4700 require a comprehensive system of planned and periodic audits to be carried out~ to assure compliance with all aspects of the Quality Assurance Program. p- ,y.. Procedure KFP-18 states in its scope that it establishes 'such 4- ' system. Ilowever, two types of audits, management audits:en6 internal audits, are described. The procedure does not establish the scope of either type of audit and no detailed sc.hedule has been developed to show that all aspects of the program are being audited. Furthermore, audit records at the site do not indicate

                       ,   -------,.--.--._..%_,                      . . ,- - _ _ _        ,,,_.._,.-._..,-,---.-_,%m.,,r-
                                                                                                                                             --w------**--e             -----w            --e

                                                                                                                                       ^ Bi     ~
                                                                                                                                         ~

Nonconformance Report . Page 3 et 4 OC0 RM - 004 ' ' l N Description (continued): 1 1 0

           .         0      (8)                            (continued)                                                                 i                        i C                                    that all aspects of the program are being audited..

O not indicate that management audits have been perfonned N support work. An unofficial, unapproved internal audit se le 4 F exists, but it has not been followed consistently and few E50s 0 appear on the schedule. A March 1977 internal audit erroneously . R states that XFP-3, -5, -9, and -14 are not to be audited as they M do not apply to Diablo Canyon. Internal audits scheduled for A October, November, and December,1978 and January 1978 were not N performed.. C E 6 CAUSE OF NONCONFORMANCE Since the beginning of the contractor's installation wrk at Diablo Canyon there have been changes to the scope of Class I work. T se changes have been required by P G and E and in some cases ft ty requirements were not set at the time of the change changes involved work not under ASME - Jurisdic or's quality assurance manual was written primari a nce with ASME Code work. The manual was appro riginally and has since been reviewed and reappro t design additions ind increased quality requirements h ed under separate supplementary procedures. The addit a quality requirements caused the quality programs t that organization and control was cubsbersome and di o Clearly define. O Resolution: I S (A) Write a program description which clearly identifies the documents P that are to be considered part of the total quality assurance pro-0 gram and establish the hf ararchy of the documents (where necessary 7 S obtain approval by the proper authority). I T Oefine approval requirements for the above documents and for I revisions and obtain approvals where pecessary. . . . . 0 :z. N Clearly define the scope.of work to which the above documents ' are applicable. . e*N Review the program to insure that supplementary procedures do not include requirwments which conflict with requirements of the procedures they supplement. Several KFP procedures require the involvement of the AI. Corresponding KFPS procedures allow work to be done without AI involvement. KFPS procedures clearly

                         .                                                                                                                                           l en           -.               - - - - - - _ - - - - - - - - - -

g . - - _

                                                                                                              . y -,     _v Nonconfonisance Report                       'Page 4 ef 6                             '

l' YT-j;%ll-DC0 RM - 004 *@

                                                                                                                                                       -f 0               Resolution (continued).                                                                                       -

r - t 5 (A) (coni:inued) I P cannot supplement KFP procedures wf thout revising the . . O yrocedurestoallowwaivingAIinvolvementonnon-codewort . . 7 5 sExample: KFP-7 and KFPS-6). I , T (8) Establish and implement a detailed audit schedule to assure - I compliance with Speciffcation 87il and the Code. 0 - N e 4 (g . Akg74

g. ,2l;;

WJ{

                                                                                                                                        . . -+f
                                                                                                                                                             -(

e

                                                                                              . m_.9d                _      ___m--.----_------

g,--- r - i,70,,a Omlef Assursio pg.3:s Mov. I2177 O ==c= = = cean=r O- . w w i. E m. #.

                                                                                                                                                                                               ' V < ,y' 'nq
              .                                                Met /ste                     veer               mese. Dept.                 8tusener                              ,

8:ENTlHCA rlON: O C 0 7 l8 R M 0 0 5 . Ci TO 95 CQh4PLETED SY INinATOR _ 2 Ed"," ass

                                  ,,,                                                                                                                                                                                   jt  1 3 " "" ,*'                     Inoependence of Quality Control Personnel from Production CKM                                                                             MDTE                                    !

n.

                        "**"*" See page 2.                                                                                         -

f

                                                                                                                                       - - - ~ - gg g . g g yg 3.3 8,                                                                                                                                    >>u                                                                :
                  **                                                                                                - - ~

4 f, , - sans eser. i MRT aewnner . FILE jn s==g,jwaa 00py m - l l t _ s oniwsreo: *1'"'C"'Mechanica i "* 6/15 / 78 " [/M[7/8,,j @.'NN"a".n*e". ' _TO_ se cossPLETED SY TECHMfCA6 JifviEW GM00P gc ., a.-ii.n , - . .

                                                                                                                                                                                                                           )
               "                        see page 2.                       IhlLnRM g345 %f B 4 5 T 5 8 % B a I ' FIN Cl W Y ' %8' B v              " " '                                   "

{ _

,..w. .unei a ves ao a n w or e o , .. l"* / / l j

                      **"" " ^'"*"' "'"*" "'

Same as resolution and contractor to audit functionina of_ the new ESO. NOTE: ESO-264 issued 7/10/78.

                 $ Y**~.
                                               - /WWAN,                              ,
                                                                                                                                **                qqc- 7,f"
                 @    ML                        s'# w f f L ulea                                     -
                                                                                                                                *~

9-iss 7 7 l

8. C '- - .

8 sentoutto cgtrioN figCeM!ro --

                                                         /,"**=i=' a o m                                         -
                                                                                                                                "~-

c*'g% W u/'n ' ro sE COMPLETED SV WLWWENDMG ORGANIZATWI

                                                                             **'~*
                  ,   n m. e e c.,                                                           f/)fff,,,                                                             ** 9//r/7f i      ,,.        ,, . . . , ., wi
                                                                                                           /                                                       **
                                                                                                                                                                                           /          /          _

l cwrestin Aecen coensscw e [ [hy

• 9 //f /g

           .'        n ,, a.n <a w ..e,                                      ,'~~                     /                                                         *~

j j f, n._, . _ 4 l To sf COMPLtrue av OUALITY ASSOMAMCE [ 10 VET.lMCATt0N: DW' -~ "' _ rhe Roseletion and corre:<ive Acties are temsfets. ,y _ f /,)$/ 7_ ~ __ ot TaisurioM toth- o rvnene. to receiw sc=h: /.h when a,w.ma . ca sk bd I Authorised inspector (for ASME itenal . O Pfmt Superintendent Q Seewity O Stasm Generation Q, Engineering Reseerch O Materials O Engineenca _ m Quality Asurance $ Cc.ntractorA,2ew /swd /A,am e tt g Stadoa Construction O Safety Headth trud Cialtns O Other-_ O Adesuemel Sheets Attached - - . . - . . - . - _ . - . - . - . _ . - - - .

                                             ~

O O

                                                                                                                              *:"*;{' '
                                                                                                                 %2 ~$

g- M NCONFO M W 4 REPORT - ( 0C0 78 - RH - 005 N .Descrlption: P G and E Specification 8711, Section 4, paragraph 3.11 . I O requires that Quality control personnel perfom only quality contml o N functions and that they be free of s.heduling and production pressures ~ . , C V. ' 0 A review of procedures and work in progress indicatas that Quality - - N Centrol inspectors' independence from scheduitng and production 4 F pressures is not assured by the program as wr1tten. Procedures O do not clearly indicate that it is the Produtica Departs.ent's ,

p. responsibility to road and use the process sheet insuring that M steps are performed in the required sequence and hold points are A observed. *

         .N C

E 6 Cause of Nonconformanca Responcibilities of production personnel were not specifically defined in writing nor consistently understood. D Aesolution: Contractor to ist'H: an EES6" to clearly define responsibilities I of production and Quality Control personnel and te provide instruction to S that personnel understand the policy. P 0 7 5 .. . . I ~ i" p\08co?N

                                                                                                                                ,~,( L'
                                                                                                                                ?                 ^-' I' t
                                                                                                            -. .L , _ 54i                                        'd R-..,       - ~.- -               . - , . -   .. , _ - , - --                                                  - , . . . . _ - - - . . . - - - - -

f [4 m MINOR VARIATl0N REPORT gy h ~ {. iosenricanw - YabioCanyon E2 D 37'i 1 er 1 ._

                @ '#                       Puliman Power Prndu_ cts

_ __ hei_T_isatdektn. Y

                                                                                                                                         ~~'            -
                *d * ** C*"*"'            M v.           Om                                                                                             *
                                                                      " Pu11 man Power Products ossemenow or o;senapancy w.

f" Various Unit 2 PfDe SUDDortS Ger attached 0.R.'s. NEW

                "*PG&E Q.A. Departsent p'erformed an evaluation.of the Pull =an Power Pw4E                                      _       t -

s $. - t , audit of the Unit 2 hardware instaIIed by Pullman Power Products corpoNtion. Fifty-nine (59) installations were inspected by PGAE 0.A. and twenty-six (26) were accooted. Of_ the i thirty-three installations found unacceptable by 0.A. twenty were accepted by G.C. Field Enafneers usino various crf teria established by PG8E Engineerino. The remaining thirtesy (13) discrepant supports will be repaired. 4/,7 ' 6 b M ** 6/12/78-osseosim Re.f ect. Mir the discreoant ofoe sunoort installations cer the attached ' Pullman Power Products 0.R.'s #3624, 3625, 363f, 3640, 3641', 3642, 3635. A few otoe _ supports found discrepant by PGRE 0.A. and G.C. Field Enaineers will be corrected without the requirement for a Pullman 0.R. or PG&E MVR, but as normal course of work. Amers e s e.ao m . ace. we.n .. ,u.d km "' N/A

              ~N Nhk$M) ena G/19nA
                ,  , % y[                      ,

Itt gis mi asoon=ht= 0 me.,s. m pert.ei s nie. nacra e. 29 tre 4 _

                                  ,                        (> m . S ne nronn.ne. . o.nn.d in p,a.e n pania ,         .

i 8Ef2 fB zo ""' 4/:Peffi EEN bM/Nn /

                                                 ~

6/19/78 ~~ osseasmow meconerusato n n.ww. t'

        --                                                                                                                         .        :1 b     **

Emslae. Hand tapneet l 0.e. . 1 Telecon w/CR.f, 2-14-78, 0815 hrs.

3) Telecon 2/CML1, 6.ge atfyv Y^*c**"" 2 Telecon w/HCuyce, 2-15-18, "I *

                                                                                       )          ;

                                                                                                                                                                    ^~

fpg

                                                                                                                                                                  -      '*~,                                   n
                                                                                                                                                                            .aw
               ' na<UN sna   w-o.

MINOR VARIA710N r% PORT mRSEDED W' ,

                                                                                                                                                                                      .",w-- f>
                                                                                                                                                                                                       ~

l

                   'om mican0N:                                                                '                    ^

lablo Canyon - 2 8 71 ) I W f "n.EEIv" # Pullman Power Products _ _____ kJ m.:atbts W # -*' w= j osecmmon or osecaswecy

                                                                                                                                                         ,t
                                                                                                                                                                              -o I

Various Unit 2 Pf oe suooorts per attack.d D.R. 's. - s l

                                ^

I See oace 2. _ __

N'E3 '  ! l l

                                                                                                                                                                                                                    \

a== MW[ MNd _

                                                                                                                                                 ,,   ' 10/11/78                                         -
                "3N                                            Repair the discreoant ojos surnore installations ner the attmehad _ -

J a.fect. Pullman Power Products D.R. 's #3624, 3625. 3631._3G40, 3641. '3642. 3635 R-) . A few otoe supports found discrepant by P_6 and f QA:and G.C.3feld Enoineers will be cor-rected witheJt the requirement for _a Pullman 0.R. or P G and E WR but as nonnal course of work. AMaand gerne. *=i,,= vied " " N/A

t. coma ' Y I ' - 10/11/78 - _

I

                    , ,,y                                        til   Min Not ReportsWS                Ousy W Aeoortshe, leer use socFn rwt 211 m     $n-. - --                                      u m , - enm E                       ,                 .Y              a lOf2 0 7/
                        "u: M L C J h .<J . L .                                                  ~
                                                                                                                                                        ,antne I          GesFostrica Accourt:94EO nemwse s

O s & k WW . liens Envecser i Oate 2!P='- ___

      -      garracmatars 4) PPP OR's 3635 R-1, 3624, 3625, .3631. 3640, 3641, 3642. M M

     ~-

j

                                                                                         - e ny. ,._,y y

MINOR VARIATION REPORT

                                                                                             .   #lsa M-3725 R-1                               :?

y, , EXPLANATION: PG&E Q.A. Departzoent perforsned an avaluation of the Pullman Power, Products corporate audit of the Unit 2 hardware installed by Pulisen Power Pro-ducts corporation. Fifty-nina (59) installations were inspected by PG&E Q,A. and ttranty-six (26) were accepted. Of the thirty-three (33) Installations 'found unacceptable by Q.A. twent;y (20) were accepted by G.C. Field Engineers using various criteria established by PG&E Engineering. The remaining thirteen (13) , discrepant supports will be repaired. REY. 1: Revised to correct hanger nueber as shown on DR 3635 Rev.1.

 -(O O

8*% s e 9

7.: . .

                                                                               ,   ,.              ,        .s                          ~.x

[. powD . '^ og y MINOR VARIATION REPORT ,

                                                                                                                                                 ~
                                                                                                                                                         ^-.a "TiabloCanyon E k . 6711 !-

• ioen m a n : .' 1&2 IW 2 _ f f-c.e:r.stw / m- ---

                                                                                                               ,PTW     Posidt -

Iman Power Pro pun me. ' ' s.4 ca,y a ceae. = R v. O n. """*

                                                                                     ,j     .p,      p          g,                                              ci onenimon op osecnenamey                                                u Various Unit 1 & 2 Pipe Supports per attached 0.R.'s.

t=msem, - See page 2. f tw ossposam

                           '[                 ibm                                                              4/18/79 Reiect.         Renair the discrenant nfoe suonnet inetaf f atione one ha ettachmA

__ Pullman Power Produc ts 0.R. 's #3624. 3625, 3631. 3640. '3641. 3642. 3635 R-1. A few p_ foe sunoorts found discrecant by P G and E OA and G.C. Field Encineers will be cor-rected without the reoufrement for a Pullman 0.R. or P G and E MVR, but as nonnal course of work.

           *** w ** =ca. * '9 =8 N/A                                 b WNk           *
                                    . $)$ {_Alb'                                                 ~*

6/tl79

               , ,,                 ,           [9    esi nei n w mi.:               Ony w n., anew. r,.r Tns nacra pure m a                                m     afi. n.: . nea       v.,   ww.

m ows, a sa er e re.mo c ** a aC2 J. Asea.aJM ' de/>*> E.v d 1 . f_ _

                       ~

(O [.1 2 5/2/79 l < - 7 osa,osman acconsrusasu l Hangers noted on 0.R. 's #3624, 3625, 3631, 3640, 3641 & 3642 have_been repaired, inspected and accepted by Pullman Power Products in accordance with the respective discrepancy reports. Mangers listed in 0.R. 3635_under items 1 thru 4 have been processed per the approved disposition. Pullman Power Products conducted a T-shoe audit per OR 3635 f tem 5 and reworked as necessary Unit 1 f astallations. OR 3911 (ref. WR M-3895) has been esta-bitshed to continue the T-shoe audit and rework program for Unf t 2. 3' N

                                                                                                                                 .          'W
         ~

_(

                             //                     _

W*$w./(/- /0 W/V/79 r?.,.2~f/ 6&#JM ~ rNn p _ _ i) PPP OR's 363s a-2, 3624, as25, 363i, 364o, 3641, 3642. 7

                                              ~                                                                                                         '
                                                                                                                                                                         ;.,Q        ,
 .-                                                                                                                                                                      ?2          ,

Fage"E ' ~' '

    ,                                                                                MINOR VARIATION REPORT M-3725 R-2                                                        -

s t _ Explanation: P G and E QA Department performed an evaluation of the Pul! ' i' Pmducts corporate audit of the linit 2 hardware installed by Pullman Power P corporation. Fifty-nine (59) installations were inspected by P G and E QA asEl twenty-six (E6) were accepted. Of the thirty-three (33) installations found un-~ ~ acceptable by QA twenty (20) were accepted by G.C. Field Engineers using various criteria established by P G and E Engineering. The remaining thirteen (13) discrepant supports will be repaired. - Rev. 1: Revised to correct hanger number as shown on DR 3635 Rev.1.

        .Rev. 2: Revised to note that the discrepant supports were in both Unit 1 & 2, and include revision to OR 3635.

S

                                                                                                                                                                *I            4 QN$s,.

, s . f; I

                      . . - - _ _ , _ _ _ _     - , .       , , , _ . , . . _ _ , . . , , , , . . . . _ , ,            , . - ..,,,.,_._y , ., , , _       _ _   ,._,,,-y

     -                                                                                                                      ~

pcws ww m If78 4==== MINOR VARIATION REPORT *

           ' *E"" C^ " '                       NiabloCanyon                                              E          1&2         Nm.J                            8711                       1.

• 1 -

N# Pullman Power Products . b we' M/A Ya[$ YI seas cm = cear==w O v. gw

• gf4 7 ~'

DesCAtPf10N _OF OiSCREPAMCY %g45 *

          "*" Frecuency of audits perfonned by Pullman Power Products corsorsta 0.A. 'stENINS
                                                                                                                                                                                                                          '~

I The Pullman Power Products OA procedure XFP-18 states that ali assects of the PPP QA program will _be audited every 6 months however, the PPP Corocrate Audtt Procedure XVIlt-1 states that the OA Procram vill be audttad annually. [EJ" # [ "' 6/12/ 78 ___ ciaposim

                      ' Aaree dan audit freousney and revise Pu11rnan Power producte GA Fiald Audit Procedure KFP-18 or the Pullman Power Products Corporate _ Audit procedure XVIII-1 accordinalv.

44mo = yn,.finy M "* ufa

nnA (~- >wn

           , ,        yj, 'm                                                            $. n.t n           rew.:     Ou., in a   =ia em ne tocen % un e

m gi,n.i. ~ 6 - - o.n,,- e m enua I k $*& ! $ hS ~~

                                                                                                                                                           &l///71                                        _ __

Q 2 ::: (/ M A 4 9 .a

                                                      /                                               oispasmon mecawi.imiao awn The Pullman Power Products Quality Assurance procedure KFP-18 was revised 8/18/78 and requires that all aspects of the Pullman Power Products Qualf ty Assurance

__ Program be_ audi ted 47nually. e

g. 4 W"'**/ J M_AR, //hl? 9 /

10'37 dhL .f - iiii/79 O ATTACHMENT 1 e -- . . _ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ . _ _ _ _ _ . . _ _ . - . _ _ . _ _ _ _ . _ _ - . . _ , , _ ___ . _

                                                                                                                                   ~ l" U Aw,wwe M I/78                                        MINOR VARIATION REPORT                                    .
                                                                                                                                  * .    ' ' - NI3 ~                 !

iosu m cA m . *dfabloCanyon D 2 M 8711 1w ~1  ! N** # Pullman Power Prod "

                                                                                                                                    =                     -

I" ) 4.nd on se ce=cario, O vm [b yg - - oescnierica or ossenepancy .-  ! F d i No. 362 ,c InspectionpointwasbypassedasdescribedonattachedPPPER#2E5l* _ Reference P G and E QA Audit #80422. s5W""'5n S bsf ~" 6/12/78 otsposi m '

                                                   ~

Reject. Substituta radiograph inspection for penetrant inspection missed and create a new ESD per the "Recossnanded Corrective Action" on attached PPP KR #265. Admiw y.n. p ,wre M*" '"" M/A wa ' N El b efg "" 9/21/78 [ x

                                               ~
              , , ,, y_                              m pd. noi n eram.            Om., = a   ,um t r nn. tocs.4 r=t to m   p. n.: . ~,,<-. . ~ e- enus
                                                                                             ~~

b 8 9e 2 2 f f M 6Ar UM V.C.1646ook 6/cA

                             ~

9/21/78 osspoemON ACC0a4Ptl0HEO

                                                                                                                                                      ~

[ _ l Radiographic inspection was stade and new ESO #264 was implemented per above dispos 1 tion. e.

                                                                                                                                                 }
                                                                                                                                         $' ?'r.3 4-c'~T"* f __s e s D

_m

                                                                                            ~~
                                                                                                     /of.u/7r                                      -
  '-  L *"r ~ F L M Zr i                                                                * *~

eiest1e

      #ATTAC            sNfs 1) PPP NCR #265,

TIIE H. W. KEl.l.0GG C0i!PANY ,

                                                                                                                                                                                                                                                              ,                                            ~

l

• NollC0HPt. LANCE itEPORT .

4 . \

                                                                                                                                                                                                                                                                               ..                                                */*            j
                                 ,                                                                                                                                                                                                                                                       .'                                                     i s'
                                                                                                                                                                                                                                                                   .                                                   .                        l
                                                           -                                                                                                                                                                                 *                                                    * .                                           l j
                                                                                                                                                                                                                                                                                                    ~
                               ,                                                                                         ' '                                                                                                                                                                                                                    l REPORT NO,~~' 265 7                                                       '!                )

SUU8

                                                                                                                                                             ~                                                                                                                                                                                  i 7dPROJECT M4ACCR                                                                                                                                                            (ATE M Pl?tNG SUFTS.
                                                                              -                                                                '                                                ~

i Nf

                                                                                                                                                                                                                                                                                          'W
                                                                                                                    ~                              *
                                                                                                                                                                                                                                                                           .                                              ~l'                   f M ClllEF EllGlHEER -                                                       .                                      .                                                  ,
                                                                                                                                                                                                                                                                                                                               .: '             l
      .] PIPE Sil0P CilGlHEER                                                                        .
      .':.1 \\AtlGER El(G f flee %                                                #                                                                                 .

i3WELDiltG SUPERitITCilDGilT -

".3 LEAD ErlGlHEER -

     ,G:(AUTIIOnl2E0 IMSPECTOR                                                                                            .
                                                                                                                 '                                                                                                                                                                                                                              I
                                                                                                                                                                                                                 *            . g.        ..              .                                           '

i i.<bHPl.IhHCE : *

• the hold point. established. by P.P.P. Q.A.

Juring repair of W-362 on (so 5010th

.nd the. A ll.l.. on a liquid penetrant examination of the repair area'lgrind-  : .

eat observed in violation of: .

        ,pecl(ically KFP-8, Paragroph 8.81
                                                                                                                                                                                                                                                                         ,'                      .                .I DL                              /4tN                                      .
                                                                                                                                                                                                                                                                                                                               ~.

Q.A. 6EP4RTitEllT '

                                                                                                                                                                             .                                                                                                                                            ~
     .;0MibDED C53P.ECTIVE ACTION:                                                                                                                                                                                                               that it is their                                                .

l Conr.truction Superintendent to notify, all product!'od persoons) h t -

               . riisponsibility, to follow the* sequeneg indlcated on the furnished pt'ocess s ee .                                                                                  .                   .

C6nsliructico Supcrin'tenden't to' Inform all production d',pers'otinel Inspection has'that fa ,' 2. ~i Inspectors G.the A.N.J ., l l

             . erection shall not proceed beyond                                            .                       .

any hold point suntil the radiographic inspection shall'be 'ubs,'itutec

                                                                                                                                                                                       ~
                                                                                                                                                                                                                                                                                                                    ~

t As agrded by.the 4.A, Manager s the A.N'.l., \ ~ .

3. '

                    *('pr the penetr:*nt Inspect'lon missed hold point;                                                                                                    '                                                                                                                                                    .

d7r 'd' . . h.* See reverse 5ide. . Q.A'. MlMGER l

                   -                                               .                    .l'           .                              .
                                                                                                                                                                                                       ~' ' '

fj,t f

                                                                                                                                                                                                                                                                                                                          's          ,
                                                                                                                                                                                                                           ~ d C0l!TINUOU$                                                                                         -

C NOT REQU) RED SURVEILLAllCE l QHECTIVE ACTION  :// 84/4#$ p

      .RUIRED                                                                                                                    '
                                        .Q..ERredTRECURRFHCC
                                                                                                                                                                                                                                  .q,g//j-,'~&.,..

iTPS TAKC , , , _S.A; p jAht. s.  ? 7sAf%rdyy ,dlL - 7-y *. + ~ . w a + p* . k . u , R g i y . . ,/.

                                                                                                                                                                                                                                                                .x 4
                                                                                                                                                                                          .           s 0!!flECTIVE ACT10!! APPROVED BY:.

I 5 It. - _DATE:M

• e -

                                                                                                                                                                                                                                                 ?.:.%Q?%    -:-y; y                                           l 1
                                                                                                                                                                                                                                .                                     q.c .                                 1 pp,. -                    .

t

                                                                                                                                                                                                                 .                                       .                                             f V                                               !
                            ~
                                                                                                                                                                                                                        .                                                                        G
                                                                                                                                                                                                                                                                                                 ~J

e. . . . . . . ,

4. The. Chief Engineer in concert with the- Q.A. Manager shall. develop, publish, and implement a. specific ESO concerning Fiel# Process Sheets planning and control -

Indicating responsibility for initiating, Issue, possessloc, funeflonel use,'docu-- mentation; notification of hold potats, and retention as a historical record..

                                                                                                   . ..                                              .s.           .u         ..      .                                                        e f 3 78. .                                     :
                              .                   .                 .                              .                                                                                                                           f. d.      ' e...i                     e                .

C. . ; :. \h .

                                                                                                                                                                                                                                                           . , , +.si.
                                                                                                                                                                                                                                                             - ::.4
                                                                                                                                                                                                                                                                                               .._ y e

8 *

                                                                              , , A-               , ._-                   . . _ - . , , , . . , , ,,, . , , -                             -_n,         ,.n_          _, _ - - - _ - _ , _ , - __ "             . , - _ . , - _ - _ .,

  .r '                                                                        .
                                                                                        .                                    7 ;y5 - T--
 /          -
                    ,c.o                                                                         AUME3 ED. 8% BEL $

os,y 4w, , MINOR VA'RIATION REPORT- J. ,: .j mes4 1/73 - (} IDU'"CAN '6fablo Canyon E.* _2 @ d _87_11 D 14 Y O* # W Pullman Power Products Y AA as . .

                                                                                                                                            'I NA                                         E                  i' 055CRWTIOf6 OF 089CREPA80CY                                     W                  4
                  ~~

Pining and Associated Istzettric Docu=aritation Packages. _ [NN 55 See oage 2. ~? IR'r ' % R /w / 6/12/78__ . oseonvioN Reject. See page 2. ( Assistaaet phrrww. wn,.n y;,.e , M*'** N/A OI I fly f M __  !"' 9/21/78

                    ,   _ JC Q, ni g i. a., n                            .      a mia       w. > w. iocca e- m m     ) t,. n.. . n - r - ., u , - a e, - e m .z a
                        $*tE25. U = M                                                     l**

V/J&/7/ e T 9 V,t.la.d om k k o 9/21/78 I ' DISPOEITlON aNUSMED Asmarks ~ All ch_ances have been made to correct Iso's and documentation ner the above disposition. _ e e ._ . / YeO"# I d O L_Q. ~*

                                                                                                  /0// Y?/                                  /

i % 'r '"(/ ;-/ d R f n L 10/1717s O nTACHh006TS U

  ;, f                                                            *
                                                                                                   ~ -&$
   /-                                                                                                  ,,,.,

4 MINOR VARIATION REPORT page i af 3: {. M-3726 y-l Explanation: The following discrepancies were found on Pullen Power Prodve, (

       !sometric Orawings during P G and E QA Audit #80422.

Support or Ee [ 2 Isometric Description of Olscrepancy 2-3-18 ISO shows check valve as Spec 8729 from 17.(Vef an). Installed valve _is_ _ Spec 2550 (Weston_Nyd.) _2-3-19 same as 2-3-18_ _ 2-_4-418 ___ Line 1058; dimension shown as_2' __ is l'-8". 2-9-4_78_ F.W. 858 1s etched on__two welds 2-12-5 ___ F.W. 170_i_s stamped 176 2-14 1.4 Detail for PX263 refers to pump 2-1, should be 2-3.

 .r           2-3-418            F.W. 13SO, 1391, & 1^92 are shown by the process A                               sheet to have been parfanned using stainless steel 309 rod. Joints are all carbon to carbon.

Note: Documentation was determined to be incorrect. The correct rod was verified to have been used'. __ _ Disposition: ISO _ O_isposition __ 2-3-18 Change iso to reflect as-built condition. 2-3-19 Change iso to reflect as-built condition. l 2-4-418 Otmension is within allowable 6" tolerance. i 2-9-478 Field weld is correctly tarked. Numberwasafsread by auditor. . b: C 2-12-5 Same as 2-9-478. g[ ' 2-14-14 Change iso to indicate pump 2-3. _2-3__418 coirect documentation to indicate correct weld _ rod. e L . .

                                                                                                                           . v -ig ain.;                                     :.

s i$9, .;. I

                                                                                                                                              -.I
                                                                             ~

Db.a , MIN 0R VARIATION REPORT ' -

                                                                                                                                               - hm .;M                   --

4 mese ins *a. ( ""C**'"' DabloCanyon $ 2 NE 3711_ _ _ . f f . ei Nf d - A# Pullman Power Products k N 3651 Enn. 427as lan 4 l-e osecnenon or om=masAncy . ic Documentation Packa s. h See page 2.  :$ -- i

                 ~                                                                                              **

namen? ' N K 0 /m b 11)2217g _ N'0"T* _ Reject. See page_2 _ Adat w s q . when <*edred _

                                                                             ,        _   N/A Dk             . b _ Yif bd s                                                  _

I" ^11/22/78 m

                       ,           y
                                                     $1' kin m neerswe; 0% w n rewe w noe tocen est 25
                    ;                     o        _

m s i. . - - - o . e , - ,n u . __ k Wf,. ff -A 4l'.tW71 "JOVG ' JrffnuL P f OsIPUS4 TION ACCo8WLIEMED 11/z2/7s nemerts All changes have been made to correct _ iso's and documentation per the above dispositfoli._ I ' REY. 1: When this MVR nimher was arf ainally taken. no PPP QR nier was antered in the log. Therefore, the existence of the OR was not known when this MVR was written and

 ,                  when it was closed,                    lloon receival of the closed OR.it was rea11 red that this MVR unt __

inadvertantiv closed before the OR had been closed. _ Wg

                                                                                                                                                    . ; ;y A
                 'O* f_- J 0n_ b _D                                                          __
                                                                                                                       /$/P/?f                                 f 5?S5d D/M!u' l

11/22/18 MArracnuswTs 1) PPP OR f3651. 3

a $ ~ F.a . i

                                                                                                                  +L41 y                   ,      i l
                                                                                                                         -' .t g     s e. ;

MINOR VARIATION REPORT Page t d 2 (

     /                                                                                                                                  '

1 f M-3726 R-1 , t- _( xplanation: The following discrepancies were found on Pulison' Power Prod Isometric Orawings during P G cad E QA Audit #80422. Support or Isometric Descrip_ tion of Discrepancy _ 2-3-18 ISOshowscheckvalveasSpec8729Itei17(Velan). - Installed valve is spec 2_550 (Weston___Nyd.) 2-3-19 Sasm as _2-3-18 __ 2-4-418 1.tne 1038; dimension shown as 2' - __ is l'-8". 2-9-478 F.W. 858 is etched _on two welds 2-12-5 F.W.170_ is s+=ned 176 2_-_1_4 -14 _ _ ' Detail for PX263 refe_rs to ptamp 2-1,* should be 2-3'. b 2-3-418 F.W.1390,1391, & 1392 are St.0wn by the process sheet to have been perfonned using stainless steel 309 rod. Joints are all carbon to carbon, Note: Documentation was determined to be incorrect. The correct rod was verffted to have been qsed_. __ _ Disposi tion: Ofsposition

                                                          ~

ISO __ 2-3-18 Change iso to reflect .as-built condition. 2-3-19 Change iso to reflect 'as-butit condition. .

       .              2-4-418              Dimension la within allowable 6" tolerance.                        ,

2-9-478 Tield weld is correctly marked. Number was Risread by auditor. l-. I 2-12-5. same as.2;9-478. W' pm 2-14 '14 Change iso to indicate pump 2-3. 2_-3 _418_ correct documentation to _ indicate correct weld rod...L b

_...m._ - _ _ _ -_ _

                                                      -                                                                                      . f ejiy. . "5                   .

n s.r W TI-I

• M.W. KELLOGG COMPANY

                             \.                                          '
                                                                                                                                      , estaut' -
                     -       /                                       A oives.ow or puu. man incoaronArto
                                                                                                                                         . ,,e e                             gk }r g\                             . DISCBEPANCY_RffORT                                         testaso _ M 4 r~Mer -
                                                                                                                                       @ 9e NO.-         E       N *~

curioufR: Pacific Gas & Electste SPEC.No. .8711 SATE: e Copyon Jo1 Mo.: F1TF geogPfCfoe: eno4ECT. of 5CREPANT ITg. Documentation Fackage for Field Welds 1390, 1391, and 1392 , During a P. C. s. E. eudit, it was noted that the th i reAnON OF olSCRE*ANCY, *>

         . cnc;d weIds were documanted as being installed usIng weId code 150. This procedver h1 ussd for welding P8 to PI materials. The materials involved are Pl only, investigatten *

• by P.P.P. personnel revealed that the original weld rod requisiclon and process sheetidfd j indleste weld code 150. The Q.A. Field laspector did not allow this procedure to be used-l snd the weld procedure was changed to weld code 203. A second weld rod requisition'wes
• prepared, The Q.C, copy of the original weld rod requisition, which was In error and sh uld have.been volded, was (tlid in the isometric packsge. TM q.C. copy of the second.

weld rod requisition, which was correct and should have been filed, cannot be found, . Verification of weld procedure used, correct weld code and weld rod used was detennf tied by review of the Q.A. field Inspector's cally Worksheet. Varehouse copy of the wsid rod ' rcquisition and magnetic sample of the installed welds. This discrepancy occurred because the field work was accomplished without a revised Isometric, the q.A. Field inspectori did ' not correct all pertinent documents and the q,A, Auditors matched weld rod requisitiond to en inaccurate process sheet rather than a revised (sometric, ascomusNDEO olSPOSmO_* _

        ,     I,       correct -the weld code entry on the process sheet from 150 to 103, l
 .,              ,     Replace the inaccurate q.C, copy weld rod requisttlon with the accurate Varehouse COPY.

l I 3. As-8uild the isometric to re'flect all welds and weld codes. ( gg K 3(,,,% 4ec 3eE . y ' j . .. . 1(-11.-7f M* T,72 1 u.w.n.radaA.uk.8l fee 4_ _ on. d -S'-72 casana $ h o,u 6/$k/ A,eae ner eneAt. osseosmow# ma now - e _ o .H ".ad .,,,...i re,,4.. din * ' va c ,r.gsa.,: . o.i.: #-H ) v.,ouin e c ,s.te,p r 4 7.'.,: een -

                                                                                    ~~
              $Xrt.AMARON DP MfClimsu n.-           -              .       .

coeums, c.c.it. mew o.A. Menses, osu ares To rntvsarnacuRA'ancs O Hw A,,h We in addition to current procedbres, a new :ST6,. _Ing formulated at this time, shall be adequate to eliminate t.his type problas. The key 7lement in the ESO is to develop a field process sheet from the original source document cod to insure that work Is not performed without a revised Isometric. l-T v'au u.n.u.a.e, o om., U bs$s 4.-7 98 oist m unom a u i., aA. es, a Aom. u e e va o.m. -- Onc ; O mens seepicer ( i a Cws.ne.

              .              s  ,
                             ,,      4                           ,*

'[ k. k'. .' l i T  : l ,,pt 2 6 Sld h i

   . -d.h                            Docket Nos. 50-275 50-323                                                  .

i i Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention: Mr. Philip A. Crane, Jr. Aseistant General Counsel c:..u Gentlemen:

Subject:

NRC Inspection at Diablo Canyon Unit Nos.1 and 2 This refers to the inspection conducted by Messrs. D. F. Kirsch, T. W. Hutson and G. Hernandez of this office on -July 10-13,1978 of

                     ,                 activities authorized by tRC Ccnstruction Permits No. CPPR-39 and l

CPPR-69, and to the discussion of our findings held by Mr. Kirsch

                    .                  with Mr. M. R. Tressler and other members of your staff at the con-
 ..;g,cq                               clusion of the inspection.
              ..n Areas examined during this inspection are described in the enclosed
     .                                 inspection report. Within these areas, the ir:spection consisted of selective examinations of procedurcz and representative records, in-tenriews with personnel, and observations by the inspectors.

No items of noncompliance with NRC requirer.ents were identified within the scope cf this inspection. In accordance with Section 2.790 of the NRC's

• Rules of Practice,"

l Part E. Title 10, Code of Federal P,egulations, a copy of this letter and the ehelosed inspection report will be placed in the MRC's Public Docu-

          ' .l:

ment -Rbom. If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to

                   <                                           a O: -
                                  *"'e=*          U );5
                                                                  ... M..      _     .
                                                                                              -. Jk_.       _ . _ . . . . . . . . . . . _ .          .._
                   ;            ,,,,,,,,,,      Kirscli/db          Hutson              rnandez  Spencer
                                      ,,,,,,   ,,7/ y , /78          7/ a /, /78       7/. S /78   7/.% /78

                                                    )

{ ( Q Pacific Gas and Electric Co. JUL 2 61978

                                                                                                                                =.

O this office, within 30 days of the date of this letter, requesting that such information be withheld from public disclos;te. The application must include a full statement of the reasons why it is claimed that thi information is proprietary. The application should be pr pared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in - this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be glad to discuss them with you. Sincerely,

                                                                                                                ~
                                                                               .. a. sissiD at L s. sposta G. S. Spencer, Chief Reactor Construction and                                    1

((h,. Engineering Support Branch ' ,j ,

                                                               *                                   ? ~- -

Enclosure:

IE Inspection Report . ' Nos. 50-275/78-10 end 50-323/78-10 M cc v/o encl: R. P. Wischow, PG&E J. D. Worthington, PG&E t . Sent to Reproduction, HQ for DistriL1 tion Sent to Accessions Unit, HQ for: PDR, LPDR, NSIC, TIC, Central Files Distributed by RV: State of CA (JOHNSON /HAHN), RV PCR (2) - Sandra Silver (Report only) Engelken (ltr), (2) Inspector files d i ' S~ O* ,,~.,y---~.wem .- _ _ w_- -.,,m._

l p' - t ( . l l

                .                                                                           U. S. NUCLEAR REGULATORY COMMISSION                                                      l OFFICE OF INSPECTION AND ENFORCEMENT
                                                                                                                                                                            -f      )

REGION V 50-275/78-10 Report No. 50-323/78-10 , 50-275 CPPR-39

              .-                      Docket No.                     50-323                                       License No.               CPPR-69   Safeguards Group
?.99 Licensee:                      Pacific Gas and Electric Company                                                     -

77 Beale Street San Francisco, California 94106 Facility Name: Diablo Canyon Units No.1 and 2 1 Inspection at: Diablo Canyon Site, San Luis Obispo County, California

       .,                             Inspection Conducted:                                            July 10-13,1978 k         ;~

Inspectors: Mh D. F. Kirsch, Rea'ctor Inspector

                                                                                                                                                            %A &W)E Q 08 e Signed

• h 25M18

                           .                                        T. W. Hutson, Reactor Inspector                                                          g E)Je Signed 0 8 m z u / /r                                                                ~
                                                                                                                                                             *2ain-95~ 19 77
                                                                                                                                                             / 06te Signed

_Ggernandez,ReacyrInspector , Approved By: h 7/M/77 G. S. Sperier, Chief, Reactor Construction Date Signed

                  ~-                                                       and Engineering Support Branch Sumary:
           -                          Inspection on July 10-13,1978 (Report Nos. 50-275/78-10 and 50-323/78-10).
        ~~

Areas Inspected: Unannounced inspection of seismic modification activities involving: structural steel welding procedures, work observation and record review, reinforcing steel welding procedures, work observation and record

         .c .                         reytew, welding electrode control, structural steel bolting, procedures, work
           ..                         observation and record review, ultrasonic equipment calibration and examina-
      , "? .

tion of structural steel welds, electrical anti instrumentation raceway supports

              .                     and circuit separation, structural concrete work observation and record review, 10 CFR 50.55(e} followup, and licensee QA audits and nonconfonnance report review. The inspection involved 75 manhours by three NRC inspectors.
 , (.cO Results: Of the eleven areas inspected, no items of noncompliance or deviations were noted.
           .0                                                                                                                                            IE:V Form 219 (2)

l ( ( 1'O  ;

                                                                                             ~

DETAILS 3. .  !

                                                                                                .=:
                                                             *   .                              .W
                                                                                                -~

1. Individuals contacted -

a. Pacific Gas and Electric Company (PGSE)

                                     *M. R. Tressler, Project Superintendent
 ***d                                *C. K. Maxfield, Station Construction Superintendant               '
                                     *R. P. Wischow, Director, Quality Assurance
                                     *D. A. Rockwell, Resident Electrical Ergineer
                                     *R. D. Etzler, Resident Mechanical Engineer
                                     *V. L. Killpack, QA Engineer
                                     *M. E. Leppke, QA Supervisor
                                     *L. G. Rasmussen, General Construction Supervisor
                                     *J. Arnold, Coordinating QC Engineer                               i J. N. Cochran, Resident Civil Engineer B. Gragg, Welding Inspector R. Breed, QC Engineer
                                      -F. M. Russel, Civil Engineer
, rf                             b. Guy F. Atkinsoh Co. (GFA) v             ,

h , M. M. Walsh, QA Manager T. Loomis, QA Engineer D. Haffey, QA, Weld Rod Control A. Kridle, Structural Steel Inspector K. Brainard, Concrete and Reinforcing Steel Inspector M. E. Chevalier, Welding Inspector B. Vines, General Foreman

'M

9 B. Driver, Foremsn R. L. White, Batch Plant Operator M. Anderson, Lead Inspector

c. H. P. Foley Co. (Foley)

V. Tennyson, QA Manager

d. Endurance Metal Products Co. (EMPCO)

D. J. Gragg, QC Manager

  ,           ?                  e. Pullman-Kellogg (Kellogg) 7                  :

J. P. Runyon, QA Manager - V. J. Casey, NDE Level II Examiner

• Denotes those present at the exit interview.

                                                      .C                 ,-

f (O. .

2. Licensee Action on Previously Identified Open Items ig

a. (Closed) On-site Approval of Open Items Identified by Licensee QA Audits (50-275 and 50-323/78-09).

 !                                            The licensee had revised Quality Assurance Department Procedure No.16.1 (0 pen Items) to allow the QA Director to assign cer-tain personnel the authority and responsibility for approval of
   *U                                         open item classification and corrective action. The QA Director had assigned this function to the onsite QA Supervisor by letter dated June 20, 1978. The Open Item log and recently identified open item reports were examined. It was noted that the onsite QA Supervisor had been approving the open items and that the approvals and resolutions were being made in a timely manner.

This item is closed.

b. (Closed) Structural Steel Erection (50-275/78-05)

The plug welding of unused bolt holes was stopped by pG&E QA  ! when it was observed that the welding procedure had not been qualified in accordance with AWS D1.1-1975. lne contractor per-forming the welding has received a reply from the AWS in regard

                  ~

to the question of procedure qualification for plug welding of the unused bolt holes. The reply received stated that the pro-cedure used in the plugging was considered as prequalified. Based on the reply from AWS and review of the completed work, this item is closed. -

c. (Closed) Cracking of Concrete Buttresses (50-275 and 50-323/78-09)g "h.h$ The licensee has evaluated the cracking of the Buttress walls and has attributed the cracking to shrinkage caused by the bottom section of the wall being restrained and the tep section being

                ~

free to shrink. The licensee states that the cracks will be filled with epoxy to protect the reinforcing steel from corro-sion. This item is closed.

d. (Open) Sand, Aggregate, and Cement Test Reports (50-275 and  :

50-323/78-09). A complete package of all required test reports were not available m  : for review. The licensee had received a portion of the reports

           ~ ^:                               and state 1 that the rest were in the process of being tran mitted 2[;

and would be available for review during the next inspection. -This

                 -                            item is open.

e,.O

     .---....,.,-_~._.._.,..o.___-.-_._-.-..~___---.m                                           __-. -

( ( (. _.

3. ~ Structural Steel Welding ,- - .

                                                                                                                                                                                     =4

a. Review of Quality Assurance Implementing Procedures The following Endurance Metal Products Co. (EMPCO) quality control procedures were examined:

(1) QCP-6, Field Installation - Welding

 ~N                                               (2) QCP-8, Welding Electrode and Wire Control, Program (3) QCP-9, Quality Control - Field Installation (Welding)

(4) QCP-10, Nonconforming Items (5) QCP-12, Repair - Field Welding The procedures had been approved by the licensee. The fonn QCF-3 had been revised to include the inspection of material placement (see .IE Inspection Report 50-275 and 50-323/78-09). No items of noncompliance or deviations were identified.

b. Observation of Work and Work Activities (1) EMPCO Activities _ ,

    -                                                          The inspector examined the completed welding on four checker plates and the in-process welding on eleven checker plates being installed at the 104' elevation of the Unit 1 Turbine Building. In addition, the temperature of weld rod holding ovens 1 and 2 and the checker plate storage
~4~ '                                                          area were examined. No items of noncompliance or devia-tions were noted.

(2) GFA Activities The following welding activities related to the Turbine Building crane rail were examined: (a) Approximately 200 completed welds in Bays 14,16

           --                                                                       18, 20, 22, 24, and 26.

[

(b) Material fitup in Bay 30.

In-process welding in Bay 28.

                                     ~
      ^!                                                          (c)                                                                                                              -

(d) The temperatures of Weld Rod Holding Ovens 4 and 5

                                                        .                           and the weld rod issue activities in the oven 4 end Q]   .

i 5 area.

         ' h
                     ,+v   - -
                                .,,.---,,.------g     - - , - - - - - - , , - - . .         - - ,    , , , - - - - - - . , - , - - - . -
                                                                                                                                             , , - - - , , ,-a- ,,,,. -,- ,,--- -.         ~e,- - - , .

( ' ( (OV' . 4 T . T. It was noted that all work and inspections had not been .:. completed in some of the Bays and a review of pertinent M documentation did reflect this fact. Welding activities on a structural steel addition to the Unit 1 containment annulus area were also examined. 4 **. .8, The inspector noted that the structural steel welding in the Unit 1 Fuel Handling Building had been completed and the welds had been painted Four Machine Shop on Columns 184 andat19gompleted elevation 166 welds ft. in the were visually examined. The welds exhibited excellent workmanship and had been properly prepared for ultrasonic examination. The ultrasonic equipmegt calibration and examination of two welds on Column 18- at elevation 166 ft. were observed. The equipment was properly calibrated and the examinations were conducted as required by the UT examination procedure and the AWS Dl.1-1975 code. One reject weld was disclosed by the UT examination. The discontinuity was properly lo-

   . Qg                                ,                                    cated and evaluated by the examination. No items of non-
               ;                                                            compliance or deviations were noted.
           .a                                       c. Record Review (1) EMPCO Activities                                                                                                       ,

The following quality related records were examined: .hs's (a) Field Installation Inspect. ion Reports for the checker plate welding completed and in-process (see Paragraph 3.b. (1), above). (b) Welder qualification records for 10 welders.

      . . . .' .                                                            (c) The welding electrode issue records for June through July 7.1978.

(d) The Nonconformance Report Log and NCR Nos. 01 through 04.

 . . X-2                              (e) The Hold Tag Issue Log.
               '                            ~~
          .                                                                No items of noncompliance or deviations were identified.--

6 d ' e:-a

                       . . _ _ _ _ _ . we [e _,-..w,,  .,,__,--.-.._,.,.,..w-_,            ,-,,2 y-m     .,,,..-_.,..e_       ,,-r,.. , , , , _ . - _ . - - , . _ _ _ _ . . . - _ . . _ , _ - , _ - . _ . _ , , . _ , . ,

t . . ( ( Q

                                  ~                                                                                                   -

(2) GFA Activities The following quality related records were examined: (a) Qualified Welder List (b) Welder qualification documentation for eleven wel c'ers.

. ,Ar s (c) Welding Electrode Issue Log of July 17,1978 for Holding Ovens 4 and 5.

(d) Material Certifications and Receiving Inspection Reports for 5 weld rod lots. (e) Field erection inspection documentation for NDE , and visual examination of welding performed in Bays 14,16, 20 and 22 of the Turbine Building

                                           .               crane rail.

(f) UT and liquid penetrant examiner certifications

       .J                                                  for two Level II examiners.

V. (g) Qualification records for three Structural Steel Erection and Bolting Inspectors. (h) UTequipment(SN 804002) certifications and 40 hour calibration records. (1) Transducer (SN 818429) certifications.

  .9 era 1

(.1) Field Erection Inspection Reports and UT Test Reports for welding in the Unit 1 Fuel Handling Building. Discussions with GFA personnel indicated that the methods to be employed for final documentation were not 'roce- p

                    .-                     durally specified and the system for identifying work remaining in the Turbine Building crane rail bays was not specified by procedure and appeared to be inconsistent.

Licensee personnel stated that this situation would be evaluated and resolved.

     ,.f.Il                       :        No items of noncompliance or deviations were identified.
                *              ~

9

 'UJ -_.__.-
                                            --m..,,.m._--._____-.--._-, . _ , - , , _ . . . - . . . _ . . _ , -       . _ _ , . _       ._----_,-._.m-_-.

( . ( ( cp 4.- Structural Steel Erection and Bolting  ;

a. Review of Ouality Assurance Implementing Procedures The following GFA quality control procedures applicable to Structural Steel Bolting were examined and appeared satisfactory:

QCP-3, Rev. 1 - Structural Steel Erection

      'W                                             QCP-7, Rev. 0    -   Calibration Control and Status No anomalies were noted,

b. Observation of Work and Work Activities

          .                                   The inspector randomly checked completed bolted connections in in the Unit 1 Turbine Building and Fuel Handling Building. The inspector noted that the bolts were being marked as required by QCP-3 after tightening and inspection. Observation of the com-pleted work in the Fuel Handling Building disclosed that an existing bolted connection had been loosened to facilitate the slotting of holes in a structural steel member. The subject

.ziN4f. connection had not been tightened upon completion of the work.

~ This item is being corrected in accordance with the provisions of the contractor's nonconformance control system. Q- , ! W c. Review of Quality Records , The Field Erection Inspection Reports, Bolting Inspector qualifications and torque wrench calibration records related to work in the Unit 1 Fuel Handling Building were reviewed. WGd No items of nonconformance or deviations were noted. n' - .

5. Reinforcing Steel Welding -

q, 5

a. Observation of Work and Work Activities The in-process and completed welding of reinforcing steel was observed at the following locations

_

G line between Colugns 21 and 22, vertical dowels G line at Column 29 , vertical dowels to A-36 steel i A line, Unit #1, vertical dowels ['  : The welders were observed using the proper procedures and o materials for the applicable welding process. All portable rod ovpns were plugged in and were maintaining the required _-

    ,._              - - ~.-. _ .-. _ ._- -

a " ' - -- -

(

O' C 7-C 3 temperature. Approximately twenty (20) completed welds were y examined and appeared to conform to AWS D12.1. No items of noncompliance or deviations were noted.

b. Review of Ouality Records The calculated carbon equivalents for the rebar to be welded were reviewed. The inspector noted that heat A1030, size ww eleven, grade 60 had been received onsite and was being welded in the structure. The carbon equivalent of this heat is 64.08 which is higher than the carbon equivalent of 59.17 of heat A2182, which was originally used to qualify Welding procedures WS-RS-1, 2, 6 and 7. No evaluation as to the acceptability of this new heat for welding was made by the contractor. This item is being corrected by the contractor's nonconformance con-trol system.

The E9018 Welding Electrode Issuance records for the month of June were reviewed. On June 5, 1978 the contractors onsite lost electrical power to their electrode holding ovens and L portable rod cans. A periodic check by GFA disclosed that por-O gJ::/ . tabieovens3and6.containins100electrodas.haddrspoed below the minimum holding temperature of 250 F to 225 F. The rods were subsequengly removed from the field and placed in a rebake oven at 450 Foverng'ght. AWS requires that E9018 electrodes be rebaked at 700-800 F for 1 hour. The rods were only exposed to ambient temperature (225 Fminimum)during transfer between portable ovens and holding ovens. The rods were issued for use the next day. The failure to rebake the E9013 rods per AWS requirements is documented by the contrac-l -WW tor's nonconfortnance control system and will be resolved accord-

              ~

ingly. No items of nencompliance or deviations were noted. i l

6. Electrical and Instrumentation

a. Observation of Work and Work Activities Four raceway supports, incorporating revisions specified by recent detail drawing changes, were examined. One raceway sup-port had been mislabeled as to type, however, this item had been identified by licensee QA Audit No. 80611. The supports e appeared to be installed in accordance with the applicable l ,, _.

detail drawings. The licensee had established mutually redundant circuit separation criteria and promulgated these criteria on Draw-ias.No. 050029. The following safety related panels were examined for compliance with these criteria: {O

         +w-       wa+--,ce---       e- e-#  ,,,e-o,aermm+--    --e--,4r----w+==-.-s*    -e-%-e   -rs-w-ueo ae-w- gww-    e.r- m e nw- r      et-t-e----+=e---.*e-*-*-,-e*we=-i-   wewe9 -y-r--**w-' -e v = w m *9*F-*FwSt---

1 s*%>& O b k) g,

       ~'

IMAGE EVALUATION ///g'f

                                                               /g$ 4'# ,,47 #4 y k//77                   @//     TEST TARGET (MT-3)
  'W 9                                                    %,,,,h I.0   !!E DE E 9 Hiss 1.1    !..'-EE l.25      1.4 ljg 150mm              >-

4 6" >

   #         **                                           4$     4
*%fpf
          %p                                           AQ4    v

C ( '

     ~Q-                                             .

T (1) Diesel Generator Control Panels 1-1,1-2 and 1-3 ' (2) Unit 1 Hot Shutdawn. Panel d (3) Mechanical Panel No. 30 (4) Instrument AC Panel Nos. PY15 and 16 "fM@ (5) Main Annunciator Panels PK003, 004, 005 and 009 (6) Rack wiring in the Diesel Generator System, Chemical and Volume Control System, Residual Heat Removal System and Safety Injection System Control Panels located in the Control Room. It was noted that the Varglass sleeving had been frayed and - the Scotch 7700 Tape did not extend into the conduit for mutually redundant circuit wiring in the Diesel Generator 1-1,1-2 and 1-3 control panels. Since these systems had previously been turned over to the operations staff, the QA Supervisor stated that the appropriate organization would be notified and the situation corrected.

        . '9* :                                            No items of noncompliance or deviations were identified.
      , g. x
              -. c'                 7.      Component Supports The Report        marginal         weld undercuts No. 50-275/78-09              Paragraph              previously)       7.a in baseplateobservedwelding (see IEforInspection Mixed Bed Demineralizers 1-1,1-2 and Evaporator Feed Ion Exchangers
..;.y's 1-2 and 1-4 has been evaluated by Foley. Discrepancy Report No.

i 8735-4 specifies repair of areas in excess of 1/32" undercut. This l resolution was approved by the licensee and was in the field for work accomplishment. No items of noncompliance or deviations were identified.

8. Structural Concrete

a. Observation of Work and Work Activities Concrete activities, including preplacement preparation, placement, form removal and curing for Lift No. 5-11, were

                     ~

observed on the west side of the Turbine Building. _. No anomalies were noted. _ s , 8 n,--_- - ~ . . .-. - .. - - --. - - . - _ - . - _ _ . _ - - . . . - - . - . - . - . . - - - . - _ -

1

                                                   .                                                        l

( (

                                                                                                 ~

b. Review of Quality Records Pertinent work and quality records associated with Lift Nos. d S-10 and S-ll were examined. Records reviewed included in-spection, curing, strength tests, qualification of personnel, material certifications, audits, Batch Plant certification and calibration. The records appeared satisfactory, except as noted below.

 -a,s During review of personnel qualifications, it'was noted that certification of the Batch Plant operator had not been accom-plished as required by GFA's procedures, and that a NCR has s

been written to correct this item. Concrete Specification 5422, Section 4.9.3, states that slumps shall be a maximum of 4 + 1 inch for walls and slabs 11 inches thick or less, and a maxTmum of 3 + 1/2 inch for all other work. Except where reinforcing steel and-other embedded items make concrete placement a problem, slump may be increased as required with prior approval for each case. Design mixes had been approved for a maximum slump of 6 inches. Due to a typing error, the mix designs did not specify a tolerance and simply gave the ("ci' , maximum slump as 5". During record review, it was noted that several slumps exceeded the 5" maximum. PG8E has issued MVR No. 076 and is acceptieg "as is" the concrete based on previous compressive strength reports that the concrete will meet the design strength. The Concrete Specification will be revised to permit a ;.iaximum slump of 5" + 1". l .. 9. Licensee Action on Construction Deficiency Reports ww.1 Repair of Pipe Support Assemblies The program for the repair of pipe support trunnions and stanchions as described in the initial 10 CFR 50.5S(e) report dated March 7, 1978 was examined. This examination consisted of a review of the

          -                    status of the work, observation of in-process and completed work and the review of selected records associated with the repairs. The repairs in Unit 1 are approximately 85% complete. The following five pipe support assemblies were selected for examination:

Support Drawing No. Sheet No.

  .g ;

3'- - 42-37A 049254 43

       ~                    --

42-71 A 049254 83 _- 52-33A, 049289 37 . 585-85A 049264 109 585-37A 049264 95 6 m

b'

                                     ..      t

( [ Q]!' . T  :- - The visual quality of the completed welds was excellent and the  : surface was properly prepared for the applicable nondestructive -f examination. The quality records associated with the assemblies i noted above were reviewed. These records included Field Process Sheets, Rod Issue Slips,l.iquid Penetrant Examination Reports and Wall Thickness Measurement Sheets, where required. All records accurately reflected the status of the work and properly documented

           . . .                                                         the repairs performed. No items of noncompliance or deviations were i
        'M                                                               noted.

10. QA Audits ,

The licensee's internal audit system was inspected by examining nine QA audits performed during the period from May 25, 1978 through July 6, 1978. In the conduct of these audits, the licensee identified 14 findings which required corrective action. The corrective actions

had been initiated or completed.

11. Nonconformance Reporting GFA's nonconfomance reporting system was examined. The system

'           .F,h                                                        appeared adequate and a review of NCR's, plus discussions with A                                                  cognizant personnel indicated that all identified nonconformaaces f.s were being documented and written in a timely manner.
       *M                                                               The PG&E Nonconformance (NCR) and Minor Variation Reports (MVR) generated since June 3,1978, in the Mechanical, Civil and Elec-trical disciplines were reviewed. The documented deficiencies appeared to be properly classified as either an NCR or MVR in accordance with procedure and were being followed and closed out A'yl'd                                                           in a timely manner. No items of concern were identified by the
          '-                                                            inspector during this review.
           "                                                   12. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on July 13, 1978,

and summarized the inspection purpose, scope.and findings. The inspectors expressed their continued interest and concerns regard-ing the implementation of modification contractor QA/QC programs -

and noted that while the physical work appears to be satisfactory.

         .                                                             there are some minor inconsistencies in the documentation of work                                                                     '

I activities. The licensee noted that additional evaluations of con-

                .:                                                  _. tractor activities would be performed and any inconsistencies would _

be resolved.

                                                                                       .                                                                    ~

l *' ' - - - - - - - ~ - " ' - - - ' - - " - - -

                 - - . . . , _ _ _ .      ...,..---..--.----.,w                   -..m.m.          ..-re--.     .w----.-r,ce-----,

s-------~~ -w}}