ML20133C577
| ML20133C577 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire, 05000000 |
| Issue date: | 06/26/1973 |
| From: | Staples A US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Hand C, Lazo R, Luebke E Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20132B649 | List:
|
| References | |
| FOIA-84-722 NUDOCS 8507200531 | |
| Download: ML20133C577 (15) | |
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(, Sabert M. Lazo. Esi.. Chairman Dr. Cadet H. Hand. Jr.. Director Atamic Safety and Licensing Board todega Marine Lab of California W. 4. Atomic Ener Commission P. 9. tax 247 5.' thshington. D. C. 5 to( ys Sny. California 94923 Dr..Emmeth A. (mebke .[ $. tomic Safety aM Licensing Board !{ panel -s W. S. Atomic Energytoamrission Washington, D. C. 20545 .'.,~ pj ~ e. f.~ a In thinatter of DURE POWER CCFFANY '5 (William B. McGuire Nuclear Station. Units 1 and 2) ?. Docket Nos. 50-369, 50-370 z i' Goetlemen: y Se response to the estion in r order of June 18. 1973 directed to i the Regulatory sta, enclosed s the testisoeg of Domenic 3. Wassane. q-and truce J. Cochren. These witnesses trill be present at the Evierw -h tary hearing to be convened at 10 a.n..Teee day, July 10.1973 tr the p ~ 11. 5. Court of Clales. Room 309, 717 Madison Place. N. W.. Wash'egten. ,t. S. C. 20005. F, 4 Stacerely. q' N -l. .fl* + A. Sr. i staples Counsi i for AEC Re;platory Staff f V-es '4r. Jisrry Forrun ~ ? se d M. Se ser. Jr.. 'sq. N.' von i. Che . E sc -. /'; .:41 ann C la'seell c .a. renn Jr.. <sq. 5 'Y JSI N 3- \\ :,d ~ .. ' i suus. Asaisp e s -W.'.Saras; Orief. PPS , b,'4, -. o 'g 1, .+ 507200531 850524 pp g ( q _,7 {- ~ P R gO g
i e. TESTIMONY OF DOMErlIC B. VASSALLO Ny name is Domenic B. Vassallo. I am presently employed as Chief, Pressurized Water Reactors Branch No.1. Directorate of Licensing, U. 5. Atomic Energy Comission. Prior to my promotion to Branch Chief in February 1972, I held the position of Project Manager since i, joining the Directcrate of Licensing in Septed>er 1966. 1 In my present position, I am responsible for supervising and coordina-1 ting the safety analyses of the design, construction, and operation of nuclear power reactors as assigned. Prior to my assignnent as 1 Branch Chief, I served as the Project Manager wno had the principal -j responsibility for the safety review of the McGuire Nuclear Station Units 1 and 2. 1 I INTRODUCTION Paragraph 50.34(a)(7) of 10 CFR Part 50 of the Comission's Regula-i tions requires that each application for a construction perr.it of a r.uclear power plant include in its preliminary safety analysis report (PSAR): 1 A description of the cuality assarance progran to 9 be applied to the design, fabrication, construction, (. and testing of the structures, systems, and corponents y of the facility. Appendix B. "Cuality Assurance Cri-u teria for Nuclear Pr er Plants,* sets forth the re-D quirerents for quality assurance prograns for nuclear
- d power plants. The description of the quality assurance progran for a nuclear pov er plant shall include a l-$
i discussion of how the acclicable reovirements of Appe.::ix jl 8 will R satisfied. e Appendix B. " Quality Assurance Criteria for Nuclear Power Plants.* 3 following publication in the Federal Register (35 FR 10498), became JC effective July 27, 1970. M i .4 In its June 13, 1973 decision in the matter of the McGuire Nuclear '9 Station Units I and 2, the Atomic Safety and Licensing Appeal Board (Appeal Board) directs that the record be clarified in the area of D quality assurance. In particylar the Appeal Board requests the f 1 hl I Regulatory staff to furnish: I An unequivocal response as to whether the applicant's quality assurance organization conforms to Appendix B ^; j to 10 CFR Part 50, Quality Assurance Criteria for J Nuclear Power Plants." ? l' 4 Atomic Safety and Licensing Appeal Board Decision. pp. 35 and 36. .i3 'I This same questiens was posed in the June 18, 1973 order of the ASLB. l 4
= e. 2 Thus we must focus on whether the applicant's quality assurance (QA) organizational structure conforms to Criterion I (Organization)of Appendix B. Criterion I states: The applicant shall be responsible for the establish-ment and execution of the quality assurance program. The applicant may delegate to other organizations the work of establishing and executing the quality assur-ance program, or any part thereof, but shall retain y responsibOity therefore. The authority and duties of persons and organizations perfoming quality assur- = ance functions shall be clearly established and delineated in writing. Such persons and organizations shall have sufficient authority and organizational ,5 freedom to identify quality problems; to initiate. to recomend, or provide solutions; and to verify implementation of solutions. In general, assurance of quality requires management measures which pro-vide that the individual or group assigned the respon-sibility for checking, auditing, inspecting, or h otherwise verifying that an activity has been correctly ( performed is independent of the individual or group directly responsible for performing the specific activity. f: .This criterion requires that the QA program must contain the following elements, which the Regulatory staff must detemine (that when properly L iglemented) conform with Criterion I, i A clear delineation of authority and duties, persons and organiza-a. tions responsible for QA functions. }-- b. Sufficient authority of QA personnel to identify, recomend solutions, and verify solutions to QA problems. 4 .c Management policy and procedures to provide QA personnel resoonsible )+ c. for verifying that an activity has been correctly performed, with sufficient independence fron organizational units directiv responsible I-for perfoming a specific activity. ? II OA PROGRAM (OPGANIZATION) AS EVAL.UATED FOR ISSUANCE OF CONSTRUCTION h PERMIT 5 FOR f1CGUIRE UNITS 1 AND 2 j-- t Duke Power Company submitted an application for construction pemits for g the McGuire Nuclear Station Units 1 and 2, on Septerter 19, 1970. In .m accordance with Paragraph 50.34(a) of 10 CFR Part 50, the aoplicant
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} presented in Appendix 1.C of the McGuire PSAR a description of the QA g .cg .g j i 'V l
l ~h 1 I i l program as applied to the design, fabrication, construction, and testing of the structures, systerns, and components of the proposed facility. This l section also provided an assessment of the confonnance to all 18 criteria of Appendix B. l As described in the PSAR, engineering design was to be performed in the Civil, Electrical and Mechanical Engineering Divisions of Duke Ft-er, under the direction of an anpropriate Principal Engineer in each of the respec-tive divisions. For all safety related items, the design calculctions, specifications, procedures and drawings were to be prepared by qual.ified individuals. The work of these individuals was, in turn, to be checked by another qualified individual, separate from the originator, but who snight be in the same organizational unit. Surveillance was to be pro-vided by a Senior Engineer and/or Principal Engineer. (As I read the Appeal Board's opinion, there was no question in this area.) Briefly, with respect to the Qf, program for construction, the functions of quality assurance anc technical support are the responsitility cf the Principal Fi:ld Engineer. The Principal Field Engineer is not rcs;cesible for-the assignnent of craf ts, the productivity of craf t personnel ce for rnecting job schedulcs, figure 1.C-3 of thc PSAP illustrates the separa-g tion of QA functions from the construction functions which are the responsibility of the Job Superintendent and the various Craf t Super-intendents. Both the Principal Field Engineer and the Job Superintendent s report to the Project Engineer. As shown in Figure 1.C-1 of the PSAR the Project Engineer reports directly to the Construction l'anager, who ' in turn reports to the Vice President of Constructicn. Although it was our understanding that the Construction l'anager and Vice President of Construction had other duties beside Ouality Assurance ratters, it was also the responsibility of these officials to re>oive CA oifferences within the Construction Departr.ents. Further, on page 1.C-Ca of the PSAR it states that "In addition an audit tear.>;ill periodically inter-view inspectors and craft people at all levels, thus giving those interviewed an opportunity to express concerns, in confidence, to persons at the tr.anagement level. All of these safecuards are in addition ~ to the regular managenent functions of the Project Engineer and other managec,ent levels within the Construction Department.' The Duke Power Steam Production Department has the responsibility for all plant operating functions and the preoperational testing of plant systems and cor.ponents. Quality assurance sneasures >:ere to be required to be developed to assure safe operation of the plant in conformance with t Appendix B. However, in accordance with Paragraph 50.34(b)(f)(ii), the ff3 applicant's description of the plan and the regulatory staff's evaluation M of the acceptability of the plan is deferred to the operating license stage of the review (FSAR). F M h 2f PSAR, Figure 1.C-2.
l _4_ During the course of the safety review of the McGuire plant, the Regulatory staff held numerous meetings with the applicant in an effort to better understand the applicant's QA program and to further crystalize its own j views concerning the acceptability of the program and the conforrvnce to j Appendix B. Our principal area of concern focussed on the QA organizational i structure and whether it confonned to the intent of Criterion I of Appendix B. Further clarification of this matter was requested of the arplicant in question 1.3.F in an attempt to clarify its views, the applicant re-sponded in revised page 1.C-2 of Revision 1 of the PSAR, in part: The adopted criteria sometimes suggests that quality assurance functions be perfomed by an organizational component separate and distinct from the organizat onal component having responsibility for an activity. Duke conforms to this suggestion with resp;ct to activities perforced by crafts rn; i.e., cuality assurance organi-zational corronents are secarete and distinct from the organizational components responsible for accomplishinn work py crgf tsmen,and tneir supervision.., in the area. 3,,.,., of professional engineering as a:rlied in design, con-g struction, testing, and operation, Duke has intentionally assigned quality assurance responsibilities to the same organizational coeponents responsible for professional engineering activity. This has been done in the firm conviction that responsibility for quality is an integral and inseparable part of the engineering function. . As part of its review of the PcGuire application for construction s pennits, the Regulatory staff reviewed and approved the applicant's QA program, as delineated in Appendix 1.C and revisions thereto 3/ I althouch not clearly stated in the staff Safety Evaluation. At the d time the Safety Evaluation for the McGuire Nuclear Station was written, it was the judgement of the staff that the quality assurance prograr for the 14cGuire Nuclear Station satisfies Criterion I (and the other 17 criteria) of Appendix B to 10 CFR Part 50. That is still the staf f's opinion. The following points explain the basis upon which y this conclusien was derived. As we understood the intent of the regulation then, we did not reovire that the professional engineerina staff's activities be reviewed hv non-professionals, but that the review would be done by other professional engineers (who could be within the same organization) other than the G originator. The applicant chose to interpret its views with respect to a design engineering as an exception to the conformance of Appendix B. j h r.! 3] Question 1.3. Letter from Dr. Peter A. Morris to Mr. William Lee, hi February 19, 1971. .j 4/ Regulatory staf f Safety Evaluation pages 99 and 100 3 Y: J h .d
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3 ; m qWr@@M*WOf %2&%b'Yg;ie 2.Wmgen b wh-9eLr%nh&p'Q.64&n%2g = O. b However, in its evaluation of this matter, the staff did not concur that the applicant's approach was an exception to Appendix B (Tr.1935). Our basis for this conclusion was that, in accordance with Criterion 3 i of Appendix B (Design Cnntrol), individuals or groups other than those who performed the original design but froe the same organization r.ay verify the desigi adeauacy. i liith respect to the 1)A organization for construction, we cased oo r approval and evaluation on the projrarr as described in the PSAR, and, the implementation of the prograr to be subsequently verified by inspectors of the Directorate of Regulatory Operations. A representa-tive of that Directorate will subtrit testimony in a separate document. The inspectors subsequently verified that the applicant's Quality Assurance Manual contained written procedures specifying that the QA Principal Field Engineer can direct corrunication directly to the Vice President for Construction on Quality Assurance r'.atters end that ..QA. Inspectors have the authority.to stop work where non-conformance .u is observed. We therefore concluded that the QA organizational h structure as descriDed by the applicant and overseen by our field inspectors, met the requirenents of Appendix B, even though the applicant appeared to express otherwise. w 111 QA PRDGRAM (ORGA'i!ZATION) AS REVISED FOLLOWING ISSUANCE OF CONST RJCTION PER' ITS On or about January 1973, Duke Power modified its 0A program, primarily ~ '; = with respect to the organ 12ation responsible for QA functions. It is ocr understanding that this modification was a corporate chance and nc>., applies to all of Duke Power's plants under construction (including McGu i re ), and even proposed plants such as Catwba now under review by the Regulatory staff. This is borne cut by renn of our files on Catawba and inspection reports made by our fielo inspec tors. The revised Duke Power cuality assurance program is documented in the Catawba Nuclear Station PSAR (Docket has. 50-413 and -414, Amendment No. 9). As will be attested to by a sta f f witness froe the Directorate of Reaulatory Operations, this ser.e prograr has been implemented for the McGuire plent. The corcorate quality assurance program, with respect to organization can be suTarized in the following paragraphs. The Duke Power corporate organization is composed of the Design ) Engineering, Purcnating, Construction, and Steam Production depart-d g t+ ments. Within the Design Encineering end Construction departrents ( there is a Quality Assurance Manager reporting administratively p k m . s , s. ~ P ,4 y . 1*
MifyMA.A 9 W 4 W Cr5:E'M M M W 9 P iiu d G W Q G P M $ n W M R 7 @ :e @ W 9 .,l,.... .pa .:. x ~, .au-.+.... . ~.,. ~ :.3 .~ Wh%m ? h<r O / ? 4s;wn-% di:.wd&& W R $:.-@ b @~':? ~h to the respective department vice-president, and reporting function-ally to the Corporate Quality Assurance Manager, a position currently filled by the Senior Vice President of Design and Construction 1 (Figure 1). The Design Engineering Department consists of three divisions; Civil, Mechanical and fiuclear, and Electrical. A Quality Assuance Manager is assigned to each division who reports adcinistratively to the division chief engineer and functionally to the department quality assurance manager. Each division quality assurance manager is provided with a staff for implenentation of the civision's OA nrn-gram. The OA r.anager in the Hechanical division has the additional responsibility of vendor surveillance and audit. The Purchasing Department is the Mi'!1-Power Supply Company, a wholly owned subsidiary of Duke Power. The OA manager for purchasing reports administratively to the Manaoer of Purcha' s - Plant Construction and functionally,to Duke Power.Corpotate. QA,Mana.ger.. The Purchasing
- * * ~~~ *"' Department origina'tes Durchese orders based on purchase recuisitions
.s. provided by the other departments and places these orders with pre-viously approved vendors. The principal function of QA manager in this department is assuring that the requirerents of the purchase requisitions have been properly translated into the purchase orders. The Construction Department is organized by projects (Figure 2). Each project has a QA Engineer responsible for QA activities at the site reporting administratively to the site project r.;anager and functionally to the Departr,ent GA Manager (Figure 3). As in the previous plan, the Principal Field Engineer and his staff, responsible for cuality control, is not responsible for ttc assign-t ment of crafts, the productivity of craft personnel or fer meeting job schedules. The Steam Production Departtent is responsible for sll operating station functions. A OA Engineer is assigned to each operating station and reports administratively to the As:1stant Station Superintendent r and functionally to the Department 04 Manager. In turn the Department QA Manager reports administratively to the !!anacer, Operation ard Maintenance and functionally to the Corporate OA i:anager (fi ure 4). 3 5 g-d Since the area of quality assurance is a dynanic and on-going program, ( it is expected that following issuance of a construction permit or 1 operating license, periodic revisions to and updating of the acolicant's 4 l Quality Assurance Panual will be required to assure continued Pegula-h tory staff acceptability of compliance to the intent of Appendix B. a., T9 3 z :.- 5
- a x = m m g r w = p :.::q n.= =. r y. y ::7 p ; p g; q g y y g g g y &.:h q & h y m y ~..h,wLL, _.-. ^. ; ; dQ,;,; tl.&M&G;M& t it f;; & % M O W s M ? "IS O % d b $ 5 ^ j h . Since inception of the modified Duke Power Corporate QA program on or about January 1973, the staff, through the Directorate of Regulatory Operatio s has been rnonitoring the implementation of the program at the McGuire plant and other plants of Duke Power. On the basis of staff review of the Corporate QA program (Organira-tion) and inspection by the Directorate of Regulatory Operations. we believe this new plan is an improvenent in and is superior to the forr.er plan for the following reasons: l '. There is a clear co nitrent by Duke Power's too manaaerent to establish. - 1 within each Depart ent, QA flanaa'ers whose resconsibility is to verify that the ir.;,lementation and direction of the overall QA Program is, in fact, being followed. 2. There is a clear co rnitment that the QA F'.anaaers will report functionally to tne Corporate QA Flanager ano in so doing, will receive thcir QA policy direction and instructions from the - , ' ' ' ~ Corporate QA Manager. 3. There is a clear co nitment in writir.; by the Senior Vice President of Engineering and Construction, that the QA 'lanagers have the authority as well as the responsibility to identify quality problems, to initiate, recocend, provide or review solutions; and to verify inplenentation of solutions. 4. There is a clear delegation of stop wor k authority to the various QA Managers. 5. Duke Power's comitnent to controls, that recuire the QA Managers to document and report the results of their effort not only to those in charge of the various line depart 2nts but also to the Corporate QA Manager. 6. Duke Power's corr-ittent that in the event of disputes between a line manager and the Corporete QA lianager over the adequacy of perforrance of QA personnel, the Cercora*e OA 'ianaarr's vote shall take precedence, i.e., he snall have veto to.ver over the line manager's perfomance evaluation. i +[ Based on the infomation above and verification of implementation of the QA program, as now constituted, we conclude that the QA organiza-7 tional structure of Duke Power meets the intent of Criterion I of 4 Appendix B and is acceptable. j b.& ?l~ .m eY Y s o. ) w .E
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&*R'1WTW W'A Wp:C*,t W l @ a W C 4 EL y g s & g 7 Q @ g 1 W :52(g=QLQ-YrlQQ# Q -. :. -v.w. y l-@ a _ u.=, ,. my , a: p;p 4 g ym L L Ak2C R Z']1 T' O P "'" 9 O 't: - r " M " ' "~"' ' """'~;' I. ,a W TESTIMONY OF BP.tICE J. C0CHMN 1. My name is Bruce J. Cochran. I am presently egloyed by the Directorate of Regulatory Operations (RO) in Region II. Atlanta, Georgia. I am the Principal Reactor inspector for the Duke Power Comany, McGuire Nuclear Stetion. I graduated f rom the University of Miami in 1958 with a B.S. in riectrical Engineering. ?. As the Regula.ery Operations Inspector I regularly inspect the construction, design and procurenent activities for compliance with AEC regulatory requirements and PSAR comitments. th inspection ef fort includes the continuous evaluation of the development and inplementation of the quality assurance (QA) progran. O 3. The Nuclear Steam Supply System for the !)cGuire Station is supplied by Westinghouse Electric Corporation with the design, procure-enent, and construction for all structures and the balance of plant systems by Duke Power Company. Duke is also responsible for the devel-ment and irplementation of the QA prograr.. 4. The initial audit of the QA procram was performed in the Duke Power Conpany of fices in Charlotte, f; orth Carolina by a team of inspec-tors from the Region 11 office in March,1971. 5. Subsequently, inspections were perf orr(d of construction activ-ities granted under the exeT.ption to the construction perrit, in accor-dance with 10 UR 50.12, until the issuance of construction permits .g CPPR-83 and CPPR-84 for ficGuire 'lutlear Station Units 1 and 2 in February, 1973. De inspection consisted of detailed examinctions of QA records, l~n:
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~y' Ir~ b b ~' _-,,.v-.+,,_'g _ epJ' - y ~ 2-observation of construction activities, and interviews with personnel at the construction site and in the design engineering offices. 6. In January,1973. Duke Power Corpany reoroanized the Corporate QA organization with the appointment of a Corporate QA nanager and Department QA managers for the Construction Departr.ent, Design Engi-neering Department, Purchasing Department, and power Production De;o t-ment with the Department QA managers reporting to the Corporate QA manager on all matters relating to Quality Assurance. 7. The Construction QA manager has a staff of QA engineers and technicians to provide technical support to the QA engineers at the con-g struction site, and to develop QA procedures. The site QA engineer per-forms audit' of construction activities and QA records, evaluates the performance of QC inspectors, and monitors construction procedures for conforrance to code and regulatory requirements. 8. The Engineering Design Department consists of the Civil-Environmental Division, Li.ctrical Division, and Mechanical *iuclear Divi-sion with QA mensger from each Division reporting to the Departrent QA f manager. The Divisional QA canagers have stafis o' technicans and spe-cialists to perform surveillance over engineering activities and perforn )' i vendor inspections to qualify vendors to (a) supply nuclear grade products A and to (b) inspect the fabrication of purchased equiprent and material. [ w 9. All QA matters relating to procurenent activities are handled O by the Purchasing Department QA manager. t ./$ 4 .;Q ' ~
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- 10. The Depart. ment and Divisional QA managers schedul'e the Cor-I porate audits, select the auditors from representatives fron, each Depart-ment, except the Departroent of construction site to be audited. The i
auditors prepare the audit prucedure and submit it to the Departr*nt s a QA manaoers for approval. The audit report is submitted to the Corpor-ate QA manager who initiates action on identified deficiencies. i I
- 11. R0 has perfortred two unannounced inspections at the McGuire W
Construction site to evaluate the operation of the new QA organization. During the second inspection three apparent violations of the require-snents of 10 CFR 50 Appendix B were identified. Although cited against ) 4 other criteria, two of the violations were indirectly attributed to -{ O inadequate deficiencies in the present implementation of the new QA 1, organization. One violation (Criterion VI - Document Control) resulted ]d from insufficient review of design drawings by the engineering depart-Aj ~ ment. The other violation (Criterion X - Inspection) identified the 3 s lack of independence between inspection and construction activities. (% (see appended notice of violation). ry x e $1'$ .A( .J lb f,,-, ii1 'N) p ~. 2 -1 = h}}