ML20086F500
| ML20086F500 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/28/1977 |
| From: | NUCLEAR SERVICES CORP. |
| To: | |
| Shared Package | |
| ML16340E194 | List: |
| References | |
| NUDOCS 8312280107 | |
| Download: ML20086F500 (21) | |
Text
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f PROPOSAL FOR INDEPEtIDENT INTERNAL AUDli 0F PULLMA!4-KELLOGC'S EFFORTS AT DIABLO CAtlYON e
Prepared for:
.LMAN-KELLOGG i
NUCLEAR SERVICES CORPORATION 1700 Oct1 Avenue Campbell, cA 95003
-XA Copy Has Been Sent to PDR soty 28, 1977 PS-07277-605 73/2#0/0Y h
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TABLE OF CONTENTS (u
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1.0 INTROCUCTION 1
2.0 -SCOPE OF SERVICES, 3
3.0 QUALIFICATIONS AND EXPERIENCE 3
4.0 SCHEDULE 3
5.0 PRICE 4
6.0 TERMS AND CONDITIONS f
ATTACHMENT A: RESUMES ATTACHMENT B: QUALITY AUDITlHG SERVICES PROVIDED CLl!NTS OF NUCLEAR SERVICES CORPORATION
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e-IlO C l3 E N @ d.i!C C $ $ b C 9 0ilO I! Eel PROPOSAL FOR AN INDEPENDENT
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INTERNAL AUDIT OF PULLMAN-KELLOGG'S EFFORT AT DIASLO CANYON
1.0 INTRODUCTION
Nuclear Services Corporation is pleased to submit this proposal to internal audit of Pullman-Kellogg',s efforts perform an independent at Diablo Canyon.
This proposal delineates the scope of services, qualification, experience, and estimated cost for accomplishing the work requested.
The scope of this proposal complies with Pullman-Kellogg's inqui ry.
2.0 SCOPE OF SEPNICES The proposed independent internal audit would assess the status, adequacy, and effectiveness of the.follcwing functions for each cf
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the items listed, as appropriate:
items Functions Piping (field fabricated e
(1)' Receiving Inspection 2 di ame ter)
(2) Warehousing Piping Supports e
(3)
Installation Piping Snubbers and e
(4) Velding Snubber Settings
-(5)
Heat Treating Piping Restraints o
(6)
NDE Veld Rod o
(7)
Installation Inspection Nondestructive-
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(B) Testing Examined Material (9)
Records (excluding Primary Coolant System)
Fire Protection System e
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The audit scope.would include:
s (1)
Review of the overall cdequacy of the existing quality assurance program against current NRC requi rements.
(2)
Review of the implementation of the quality assurance program.
(3)
Review of the workmanship of field-fabricated and installed items.
e inter' al audit would consist of.the following:
The independent n
Pullman-(1)
Preparation of an audit plan and related checklists.
Kellogg will make available all the necessary documents and an au,dit coordinator.
(2) Three auditors for three weeks (15 working days) at Diablo
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Canyon-to perform the audit, rncluding entrance and exit interviews. " Time woul.d be spent at Diablo Canyon Power Station s
Unit 11. The audit would be performed jn accordance with the Nuclear Services Corporation and(Pacific Gas and Electric
-Company quality Assurance Programs) ##
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(3)
Exit interview with Pullpen-Kellogg's upper management to provide a summary overview of program effectiveness.
i' (4)
Preparation of the audit report at Campbell and submittal of the requested number of copies of the final report to Pullman-Kellogg management.
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3.0 QUALIFICATIONS AND EXPERICHCE selected to perform the work for Pullnen-Kellogg will The personnel have the full range of expertise necessary to perfcrm the audit.
Nuclear Services Corporation's audit team leaders are qualified to ANSI N45 2.23 and ANSI N45.2.12.
Auditors are selected depending Resumes upon the expertise required for the particular audit.
describing the background and experience of J. Veber, W. Rcwe, and G. Larsen are contained in Attachment A.
s Nu'elear Services Corporation has performed audits similar to the proposed work for many corporations. The quality auditing services B.
. that we have provided to our clients are listed in Attachment 4.0 SCHEDULE The Nuclear Services Corporation planning effort for this audi could commence in August 1977, with the audit conducted anytime The audit plan would be during late August or early September.
least one week in advance of the-submitted to Pullman-Kellogg at audit. The final audit report woulo be submitted to Pullman-Kellogg.within three weeks af ter the conclusion of the audit.
'50 PRICE The estimated costs of one individual for two weeks (audit preparation and report writing) and three individua.ls for three weeks (audit
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activity) are $29,200.
Huclear Services Corporation performs engineering and consulting services on a time and ruterials basis, with expenses billed at actual cost as established by the fee schedule and terms of this proposal.. Fees for the time of direct applied personnel vary with the level of skill required and are indicated on Nuclear Services k-3
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lli3CLCOE CI.'f[l!CC$ NO.U'ObOI"Oli Corporation's Standard Fee Schedule. The fee schedule is subject
'to annual review and adjustment, with c.ny necessary changes in r
race: becoming effective in January 1 of each year.
Nuclear
' Services Corporation's Fec Schedule for 1977 was used as the basis for this proposal. The Fee Schedule for 1977 will be provided upon request.
6.0 TERMS AND CONDITIONS Nuclear Services Corporation will invoice for services performed upon completion of the w6rk. Unles's other specific arrangements are made prior to invoicing, any amounts outstanding after thirty (30) days of receipt of invoice by the client will be subject to an interest penalty of one percent (1%) per month.
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NUCLEAR SERVICES CORPORATION Jack Veber STAFF CCHSULTANT Mr. Veber has more than 18 years' experience in the development, fab-rication, production, and testing of nuclear power reactor components, including fuel cladding, fuct assemblies, and heat exchangers. His experience includes materials and processes for development, fabrica-tion, and test of a prototype sodium-w ter heat exchanger meeting ASME Doller and Pressure Vessel Code requirements.
PROFES$10NAL EXPERIENCE Present Nuclear Services Cor: oration, Campbell, Califor'nia.
Staff Consultant.
Kanager, quality Assurance and Fnvironmental Services Department.
Responsible for quality assurance programs for utilities, including audits of contractors and subcontractors, liaison with federal regulatory agencies, training and education sessions, and review of technical documents.
Served as
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the acting Quality Assurance Manager for two utilities and has served as audit team leader for a number of audits to evaluate management, quality assurance, fuel, cost effectiveness, equipment status, and subcontractor evaluations. Presented seminars on quality' assurance and audit training. Has worked with overseas firms to establish quality programs.
1967 - 1970 Atomics International Los Angeles, California.
Project Manager. Engaged in materials and processes research for the development, fabrication, and testing of a prototype sodium-water heat exchanger for the Fast Breeder Reactor Program. The heat exchanger was con-structed to Section li t, Class A of the ASME Boiler and Pressure Vessel Code; and a patent was granted for a tube-to-tube sheet welding process.
Formulated the quality assurance program and the material and process specifidations.
Responsible for technical direction; subcontract administration; vendor and customer liaison; coordinstion with the design, inspection, and manu-facturing departments; liaison with AEC agencies: and development of fabrication processes. Also engaged in the developmental effort associsted with uranium c.-5ide fuel for the Heavy Water Orgsnic Cooled Reactor concept.
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nr. Jack Vabar - Page 2 1966 - IS67 Combustion Encineerino, Windsor Locks, Connecticut'.
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Project Engineer.
Assigned as technics) representstive to Atomics international on the HVOCR Program.
Con-ducted developtrent programs for solid state bonding and the testing progr:ms to 4coluate the bonds.
Respon:ible for the specifications and vendor evoluction of' uranium dioxide. fuel pellets and zirconium cladding in support of the light water reactor effort.
1958 - 1966 Westinohouse Electric Corocration, Pittsburgh, PennsyIvania.
Project Engineer.
Engaged in the dzvelopment of faori-cation processes for manufacture of Zircaloy-cled PVR fuel elements.
Responsibls for the tschnical cuality of fuel elements for PVR Cors 2, including the requirements for the seed and. blanket fuel wafers, the development and welding of Zirealey spacer grids arid fuel' elements, and material testing and studies related to oxidation of Zircaloy.
EDUCATION M.S., Metallui. cal Engineering, Carnegie Institute of Technology, 1964 B.S., Metallurgical Engineering, Colorado School of Mines, 1958 PROFESS!CHAL AFFILIATIONS ^
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Registered Professional E'ngineer, Metallurgical Engineering, No. 1689, California
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Registered Professional Engineer, Quality Engineering.
. 1107, Cailfornia Member, Professional Engineering Society Member, American Society for quali ty Cont-ol Member,'American Nuclear Society Member, American Society for Metals
' PATENTS Patent awarded for tube-to-tube sheet welding head and fixture 12/17/76 i,
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NUCLEAR SERVICES CORPORATION G. William Rowe
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Mr. Rowe has over slxteen years of construction experience, with specia competence in project management for both the nuclear and industrial His positions included those of field engineer construction Industries.
il thru construction manager on varied and complex industrial and commerc a projects r6nging in cost from one hundred thousand to over fi-c hundred million dollars.
PROFESSIONAL EXPERIENCE Nuclear Services Corocration, Campbell California.
Presently assigned to Present Manager, Construction Services.
- the River Band Nuclear Project (Twin 1100 MW(e) EVR's)
.for Gulf States Utilities.
Provides construction management assistance to the utility's site staff and is in charge of the construction engineering department which coordin.ctes all A/E engineering activities, tem:orary facilities, security, subcontract evaluatlon, and performs construction
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anspection.
department provides constructicn program and schedule evaluation, subcontractor progress,. payment approval, and
- preparation of site progress reports to management.
Staff General Atomic Comoany, San Diego, California.
1974 - 1975 Designated as Site Manager for' Construction Engineer.
the proposed Sun Desert Huclear Pewer Plant Project for Responsible for San Olego Gas & Electr,1c Comoany.
architect / engineer coordina. ion on piping installation; steam generator Installation and removal methodst con-struction erection sequencing; review / evaluation of engineer / constructor studies; CPM schedule analysis for an 1100 MW(e) HTCR nuclear power plant.
1973.- 1974 Ralph M. Parsmat Comoany. Pasadena, California.
Engineer, Enrico Fermi 11 Nuclear Power Chief Mechani
.s (1100 MW(e) SVR) for the Octroit Edison Company.
Plant Responsible for the supervision and direction of piping, installation, small piping welding, mechanical equipment design effort, team leader for ASME "H" stamp prepara-tion and audits.
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Dechtel Corocration San Francisco, California.
k.i le;69 - 1972 Senior Field Engineer, Quane Arnold Nuclear Power Plant (550MW(c) Bun) for towa Electric.
Responsible for pipe Inst'allation scheduling, mechenical equipment installa-intake structure craft supervision (acting field
- tion, superintendent) and monitoring hydro-testing ef forts.
Daniel Construction Cemoany Greenville, South Carolina.
1965 - 1969 Project Manager, aluminum reduction plant.
Assistant Responsible to the Project Manager for field engineering, purchasing, scheduling, cost and subcentract management.
Lockheed Missiles and Space Corocration, Sunnyvale, California.
o 1960 1965 Manager - Fccilities Engineering.
Responsible for the coordination of construction activities of subcontractors involved in the expansion of Lockheed facilities in Sunnyvale, California.
'EDUfATION
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Mechanical Engineering, University of Vermont (2 years).
S.A., industrial Management, University of Vermont, 1960.
PROFFS$10NAL AFFILI ATIO?!S C*
Associate Member, American Nuclear Society License, General Engineering Contractor - State of California License, General Building Contractor - State of California Associate Member, American Society of Mechanical Engineers
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NUCL55R 55RVICES CORPORAIiON Ccrald J. Larser.
Stul0R CONSULTANT wL Mr. Larsen has over twenty yes. s of mechanicci and electrical engineering experience, with sixteen years broad spectrum of experience in c'ommercial test, operation and nuclear power plant design, engineering, construction, He is certified Lcycl lll to supervisc, direct, and perform naintenance.
engineering, construction, operational testing, operational support tervices, and HDE technical inspection and administration.
PROFESSIONAL EXPERIENCE Huclear Services Corocration, Campbell, California.
Directs and Present Manager of Operating Plant Services.
supervises utility operational, support services and management of 30 to 40 engineers and technicians including maintenance, nendestructive examination, technical inspection services, including; refueling, and related construction for BWR and plant betterment, PWR applications.
General Electric Comeany_, Nuclear Energy Division, San 1961 - 1976 Jose, California.
1972 - 1976 Senior Project Engineer - Nuclear Projects' Department.
Overall technical and engineering direction on Perry 1 and 2 (BWR-6, MK-ill) Nuclear Power Plant.
- Develop, administer, and evaluate GE and Customer /AE component and systems to ensure ecmpletion of the proper design objectives and final project unique requirements for optimum safety, operations and conformance to construction requirements.
Develop specific plant designs to assist AE/ constructor Ensure in optimization of overall plant operations.
compliance to quality control requirements of NRC, ASME, ASTM, ASTN, AN5 t. 05HA, and local regula tory requi rements.
Integrate AE/ Customer /HRC requirements to project.
1970 - 1972 Warranty Service Engineer 1 - Atomic Power Equipment Project management of " turned-over" Department.
operating nuclear powcr plants and customer liaison for modifications and prodwet service, plant bettermant, overall plant operation.
Plannec, scheduled, supervised,
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- Cerald J. Larsan - Pcg31 and performed refueling, maintenance, inspection, and repair outages.
Ocsigned special equipment and tools for numerous operations.
Supervised CE personnel assigned to field construction, testing, and systems operational problems. Managed and coordinated the on-site activitics (30-40 engineers) of the Tsurugs fiuclear Station (Japan) ist refueling and maintenance outage.
Performed fuel-sipping and related Inspections.
Division Radiation Safety Representative.
Developed and integrated AE/ Constructor work on total plant.
Developed working relationships with Inter-department and intra-company responsibilitics.
Participated in marketing activities with potential customers and developed proposal engineering data.
1969 - 1970 Superintendent of Testing - TOP 0 - Nuclenor (Spain) Project.
Responsible for coordinating and performing construction and operational testing and adequacy of nuclear steam supply system and balance of plant systems.
- Planned, supervised, and scheduled construction activities and testing program with site-assigned GE personnel Ebasco (AE) personnel, customer technical staff, and vendor representatives.
Planned engineering requirements and supervised hydrostatic tests, nondestructive examination, and flushing reactor systems.
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Project Engineer / Reactor Operator - IGE Tarapur (india) 1967 - 1969 P roj ect. Assigned as APED engineering representative.
Installation inspection and functional testing of reactor servicing equipment and core components.
Supervised and trained customer and GE personnel for new fuel inspection and installation, removal, disassemoly and inspection of control rod drive mechanisms.
Supervised and performed construction and pre-operational verification of cendensate domineralizer, make-up water, of f gas, ni trogen make-up and radwas te sys tems.
Sup'ervised and performed QC/QA-NDE of the stress-corrosion repair program (retubing) of the secandary steam generators 8"..olving GE customer, AE, and vender personnel.
ter ior Operations Shift Supervisor
- passed AEC equivalent heactor Operators examination.
1966 - 1967 Operating Plant Engineer, Field Engineering, APED Engineering representative for Big Rock Point (Michigan) and KRB (Germany) nuclear power stations.
Provided engineering direction for resolvement of plant operating, maintenance, testing, system and ccmponent problems.
Responsible for, and supervised on-site activities, including:
construction, testing, troubleshooting, system better. ment repair programs,
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cerald J. Larsen - Pags 3 i nspection, refueling and maintenance outages, Irradiated fuel f'
ultrasonic, penetrant testing, and other nondestructive test inspections, failed fuci sipping and miscellaneous
,Ag, field problems.
1965 - 1966 Field Cnnstruction Engineer - KR* '(Germany) Project.
Provided guidance to customer for establishing long-term maintenance program planning.
Supervised construction, installation and pre-operational testing of plant process and control systems.
Supervised maintenance instructions and procedures for control rod drive mechaniscs and reactor tools and servicing equipment.
Performed nondestructive test inspections.
e 1961 - 1965 Engineerin) - Atomic Power Equipment Department.
Prepared opcrating procedures for JPDR (Japan) reactor (on-s i te).
Participated in new fuel inspection and reactor components inspection, testing, and installation.
Developed various construction, operating anc maintenance instructions, radiation control procedures and standards for reactors, including JPOR, PPLE Mumbolt Bay, Lowell Tech OPR, EVESR, etc.; provided on-site guidance to customer operating and maintenance personnel at the GKN (Netherlands) reactor.
H. L. Yoh Comeanv, Palo Alto, California.
1960 - 1961 Production Manager.
Supervised design engin'eering'and construction requirements for miscellaneous electro /
mechanical projects.
Developed QA/QC progrars and testing criteria for systems and components.
Developed sales and marketing efforts for engineering services.
1959 - 1960 Admiral Corocratlon, Project Engineer.
P,arformed laboratory design work of solid-state decoding equipment and field installation testing, and trouble-shooting for aircraft-controller transponder operations.
Developed Quality Cantrol procedures and methods to mili tary specification require-ments.
1957 - 1959 Svivenio Electric Comeanv_,
Technical Developn.ent Engineer.
Designed and fabricated laboratory test equipment for traveling wave tubes.
Supervised construction. installation, and testing of various microwave t.c equipment installation.
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7 ' 'Cerald J. Larsen - Pcgs. 4 Ford Motor Coenanv, 1954 - 1957 Performed construction, installation Plant Engineer.
and troubicshooting of electre/ mechanical conveyor Developed naintenance program for and process systems.
Perforced nondestructive operating plant equipment.
Coordinated construction, testing of installed equipment.
installation, and startup of vender-sutplied autematic paint system.
I 1950 1954 U.S. Air Force, Senior Armament Specialist (Airborne).
Combat crew Provided l
member on RS-29 and RS.-36 tactical aircraft.
instruction on systems to SAC pilots and in-flight Member of crew team for liaison anc qualification gunners.
acceptance testing of new aircraf t.
EDUCATION AA-SE, San Jose College, 1958 other courses and training completed:
Nuclear Reactor Technology Nuclear instrumentation Construction Management Radiation Protection Nondestructive Testing Process Control Therrodynamics Quality Control Courses and Seminars Professional Business Management Courses e
g, and Seminars PROFES$10NAL RECOGNITION Registered Professional Engineer (Nuclear N-310),
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I OUALITY AUDITlHC SERVICCS i
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PROVIDE 0 CCIENTS OF NUCLEAR SERVICES CORPORATIOli a
l Activitv Client i
Perform Audits of QA Program per Anchor / Darling Volve Company ASME Requirements i
Perform Vender Auditing and Surveillance t
l Boston Edison Company
. Activities Pilgrim Nuclear Power Station Perform Audits of QA Program per l'
Carolina Power and Light Company ASME Requirements i
I Central Nuclear de Valdecaballeros Perform Project Auditing Services Perform Program Audits of Major (Spain)
Participants
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Perform Audits of QA Program per i
Commercial Co,ntracting Corporation ASME Requirements Perform QA Program Evaluation DeLaval Enterprise Division
, Perform Records System Audit Duquesne Light Company Establish and implemen; a Site Auditing Program s
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Provide Fuel Fabrication QA/QC Exxon Nuclear Company Fuel Fabrication. Plant Auditing Perform internal Audits
.Freese and Nichols I
Perform Internal Audits Gulf States Utilities Perform Project Management Audits e
Perform QA Audits of A/E and NSSS Perform Audits of QA Program per l
Helwa Steel and Iron Products j
Jompany, Ltd.
(Japan)
ASME Requirements t
Perform Audits of QA Program per l
Hirats Valve Industry Company Ltd.
ASME Requirements i
.(Japan) 1
" Perform Pre-AEC Audit and Consultation H. S. Vright Construction Company Perform Audits of all Major Participant:
8 t ilinoi s Power Company Perform Internal Audits Audits Perform Project M:nagement Perform Aucits of Site QA Program B-1
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Develop Audit Procedures Indiana cnd Michigan Electric Company Perform Audits of QA Program per ITT-Barton ASME Requi raments Perform Management Audit Jersey Central Pow.r & Light Company Perform Audits of Suppliers Kernkraftwerk Leibstadt AG i
(Elektrowatt), (Swi tzerland)
Perform Audits of QA Program per l
Kubota, Ltd. (Japan)
ASME Requirements I,
" Perform Internal Audits Mason-Johnston and Associates, Inc.
Nakakt ts Seisakusho Co. (Japan)
Perform Audits of QA Program pe.r ASME Requirements Perform Audits of QA Program per Nippon Denkan Kogyo Co., Ltd.
ASME Requi rements (Japan)
Haneda Factory Kiryu Factory Yabu:vka Factory Osaka Factory C
Porthern States Pcwer Company and Operating QA Programs Perform Audits of Construction l
Monticello Nucicer Power Plant 0malia Public Power DistEict Perform Records System Audit Perform Vendor Auditing and Surveillance Pennsylvania Power and Light Company Perform Audits of Utility QA Program Susquehanna Steam Electric S.tation Perform Project Management Audits l-i Potomac Electric Power Corrpany Perform Vendor Auditing in Japan Perform Audits of Utility QA Activitics l
Perform QA Audits of A/E and NSSS I'
t Perform Vender Auditing in Japan i
l R.E.C. Corporation Perform Audits of QA Program per f
Remco Hydraulics Division ASME Requi rements Stanray Corporation Perform Management Audits Rochester Cas and Electric Company Perform Operating QA Program Audits Sacramento Municipal Utility District Perform Records System Audi t L-S_2 L
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O U C l 5 $ II 3 E 7?I5E 3 3 C O 2 9 'O. S IiO O Perform Audits of Various Major SNUPPS and Member Utilities Participants
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Kansas Gas'and Electric Company Northe.n States Pcwer Company Rochester Gas and Electric Company Union Electric Company Southern California Edison Perform Audits of QA Program per ASME Requirements Stone and Webster Engineering Perform Management Audits Corporation Toa Valve Company, Ltd.
(Japan)
Perform Audits of QA Program per ASME Requirements Perform Records System Audit Toledo Edison Company Utsue Valve Company, Ltd. (Japan)
Perform Audits of QA Program per ASME Requirements Perform Records System Audi l
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~' ' AUDIT Pl.All F0ll'Ali IllDEPil:D211T It!TEPJ:AL AUDIT Ol' PL'LLfM-KELLOGG'S DIABLO CAliYON PP.0 JECT 1.0 This audit plan describcs the agenda for review and audit of the Pullman Power Products Corporation (the Centractor) Project efforts at Diablo Canyon Huclear Units 1 ar.d 2.
e The purpose of this audit is to determine tI1 rough investigation 1.1 the adequacy of the Contractors performance of its functions as defined in the " Description of Wort:" contract document, quality assurance program description, codes, standards, and other related requirements especially appropriate to current practices and state-of-art.
Thc. audit is inten !cd to encompass the Contracters efforts frc=
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' contract initiation to the present and will include investigation of the ite=s discussed in the following paragraphs.
In'itiation of the Contractors Quality Assurance Program, e
'e codifications and revisions to the QA program, and the adequacy of the current QA program, e
Investigation and cvaluation of the Contractors organization; o
personnel qualifications; instructions, precederes, and drawings; document control; purchased material control and identification; special process control, nonconforming reporting and close-out; corrective action; quality assurance records including inspection, nonconforming materials, discrepancies and corrective action; audits.
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Contractors functional anplication of sc1ceted work
-including representative sampling of systen:s from cach unit.
' 2.0 Activitics expected to be audited will be in accordance with the following General Audit time schedule.
August 15,17, and 18 -. Review of Pullman-Kcilogg docum:nts.
August 1G -- Entrance Interview at Diablo Canyon with Pullman-Kellogg, PGT,E, and !!SC audit team.
August 22-24 -- Organization, personnel qualification and certi-fication programs, software systems (document centrol, nonconfonaances, etc.) and auditing program.
August 25 and 26 -- Feedwater System Unit #1.
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- 0' August 29.Qc Feedwater System Unit #2.
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August 31 and September 1 -- CVCS System Unit #2.
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September 2 -- RHR System Unit !1.
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September 6 and 7 -' Safety Injection System Un'it #1.
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September $d corning of the 9!h -- Containment Spray System Unit d-d/
and Component Cooling Water System Unit #/.
3 The systems review will inclu(e physical inspection and verification of installed components, welds, attachments, restraints, and the following aspects:
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Procuret.a.ent Specifications.
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Rocciving inspection of items including piping spool pieces, hangers, snubbers, anchors, valves, and support components, inspecting consumabics such as film, dye ponctrant, and NUE equipment, welding materials.
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Storage of components, noterials, constuiables.
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Installation, erection, fit-up, welding, cicaninD.
inspeciion, and testing.
At the end of cach day, the audit team will discuss the findings of th'at day and the schedule for the following day. A formal D
exit interview will be held the afternoon of September 9 The above identified schedule and activitics cay be revised depending on the find
.,s of the audit team.
e September 12, thru 30 -- Compilation and submission of forni audit report.
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- t October 24, 1977 NSC-QAS-KEL-003 N-77-072 Kr. Edward F. Cc: vin Chief Engineer / Quality Assurance Manager Pn11mma Power Produe:s Post Office Box 1007 f
Willia = sport, Pennsylvania 17701
Subject:
Audit Report of Diablo Canven Effert
Dear Mr. Carvin:
The audit, conducted under your cognizance, of the Diable Canyon verk af-fort has been~ ce=pl-*' wad is documented in the at: ached audi report.
Section VI, " Sun =ary," of the audit report contains the audit tea ='s ove:-
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all evaluation and conclusions concerning the work perfor=ed at Diablo To facilitate'co : active actions, as :nach deca 11 and as many Canyon.
specifics as possible have been included in the audi : sport, which ac-counts for the length of the report.
If any additional details are re-
. quired, do not hesitate to en11 me.
It is =y understanding that infor=ation to cenfir= the disposition of the audit findings by Pull:.an Power Products and eventually by Pacific Cas and Electric Co=pany will be trans:.itted to me.
As we discussed, a copy of the letter ::ans 1: ting the audit report f c= Pullman Power Products to Pacific Cas and Electric Company will be sufficies: to confirm your dispo-sition. The precise method of verifying Pacific Cas and Electric Conpany disposition was not defined, but you did co-4 t to requesting that Pacific Cas and Electric Company send me a copy of any official ce==unications con-carning their actions relative to the audit.
I trust that you have been ab1'a to obtain Pacific Cas and Electric Cor.pany's cencurrence.
, In behalf of the audit team, I would like to express c:y appreciation to
-all the Pull =an Power Produccc' personnel for their cooperation and to you for ycur personal attantion snd involvement in the audit.
Very truly yours, 6
[M
.iack Weber Audi: Tenn. Leader Attachment
s C.
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AUDIT REPORT 3
PULLMAN POWER PRODUCTS
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the sonorable Nunzio J. Falladino Chairman U.S. Nuclear Regulatory Comunission 1717 a street, u.w.
Meshington, D.C.
20555
[
Dear Mr. Chairman t
i on Septaber 21, 1983, I wrote to you regarding my concern that draft reports concerning quality assurance at nuclear plants under construction had been shared with licensees.
My letter noted that in one case, Diablo Canyon, the licensee was asked to comment on the draft report and was told by the NBC staff that any casuments would be considered in comasctica with finalising the report.
In your October 7,1983 response you==atamad a copy of Pacific Gas and Electric's (PGas) September 21, 1583 comuments on the draft report and a " revised draft working paper" -dated September 19, 1983.
The September 27, 1983 cover le ter to the revised (and final) draft report states that "...it does not reflect licensee casaments on
(
the July 19 draft."
l The original draft report, dated July 19, 1283, that was provided to PG&E for " review" purposes criticized PG&E's quality assurance i
cfforts in blunt, uncompromising terms.
In PG&E's September 21, 1983 letter to the NBC, it rejected musch of the criticism.
The final report contains few of the draft report's strongly negative conclusions and those which remain are couched in less critical language.
These circumstances are documented in the enclosed. chart, " Changes From i,
Draft to Final Case Study C Which Resulted in More Positive or Negative Treatment of the Licensee," prepared by one of the parties to the Diablo Canyon proceeding and furnished to the Snham.nittee.
According to this enclosure, there are literally dozens of instances of changes that have been :made to the final report.
Of far greater concern is the fact that changes in the final report, despite the l
disclaimer in the september 27 cover letter, appear to cater to l
the concerns expressed in PG&E's September 21, 7.983 letter.
A large number of altered or deleted statements correspond to PG&E's l
criticisms of the draft report.
Furthermore, virtually no change Y k fet CCMEE^X-3 PDR l
l The Honorable Nunzio J.
Palladino 4ovember 1, 198.1 Pcge 2 that appeared in the final report portrayed PGI.E in less favorable light than in t..o draft.
While I have not reviewed it in detail, the circumstantial evidence documented in the enclosed chart would appear to indicate that PG r.E ' s cosunents were in some wsy communicated to those who revised the draf t.
Even if this were not the case, it is disturbing to me that virtually all the changes between the draf t and final report had the ef fect of treating the licensee :nore leniently.
As I stated in my original letter to you on this subject, the MRC's practice of sharing draft reports to licensees under scrutiny has the potential of compromising the agency's objectivity.
At the very least it has led to the appearance of impropriety in this porticular case.
I believe that the changes made in the preparation of the final report warrant a full investigation.
Specifically, I would like to know why the draft report was consistently altered to reflect more favorably on the licensee and whether the licensee's comments were seen by, or otherwise communciated to, those who revised th,e report.
Additionally, I would like to be provided as soon as possible with all edited or " marked up" copies of the original draft, together with the identity of the individual or organization that cuggested the change.
Thank you for your attention to this matter.
Sincerely, EDWARD J..
Chairman, Su_ _
ittee on l
oversight end Investigations l
l Enclosure EJM:ibs l
l
...-....._,n_~n.
,,-----,-,,-----------n.-
CHANGES Fr.OM DRAFT TO FINAL CASE STUDY C WHICH RESULTED IN MORE POSITIVE OR NEGATIVE TREATMENT OF THE LICENSEE Draft ~
Final Page Reference Language Language in PG&E Lette:
- 1. The Licensee had devel-Deleted (p.6}
1 oped a false sense of security with respect to its a
engineering capabilities. (p.8)
- 2. The Licensee's staff' Deleted (p.6) 2 resisted the imposition of management controls required for assurance of quality that were applied elsewhere in the company and/or on its contractors.
l 4 contributing factor may have been that many of the Licensee's top management had ocas out of the engineering function.
They had oon-fidence in it and did not impose the manage-ment controls required r
by the nuclear process. (p.6)
- 3. Further, and as previously.
Deleted (p. 6) 2 stated, the Licenses was frequently within a matter of months of bringing the plant into I
operation.
As pressure mounts to complete a project, shortcuts are often taken.
Actions that the Licensee might take over a longer run would be different than those taken when it appeared that the project would be codpleted in a short l
tinei'er if additional l
nuclear plants were planned.
As time went on, the Licensee abandoned plans for additional nuclear generating capacity.
Dratt Final Page Reference Language Language in PG&E Letter The Case C nuclear stattort would be its only nuclear capability in the near ters. (p.6)
- 4. Control of Purchased Control of Service 8
l Material, Equipment, and Contracts (was Services (was deficient].
deficient]. (p.8)
(p.8)
- 5. These factors include These factors include 1
. an atmosphere of
., the resistance contention between by engineering of the engineering and quality application of formal assurance. (p.9) quality assurance procedures. (p.9)
- 6. As a facility nears com-As a facility nears 3
pletion or is in a pre-ocepletion or is in a startup condition (as the prestartup condition Licensee's station was (as the Licensee's in the mid-1970s) and station was in the new or changed require-mid-1970s) and new or ments arise, thece is an changed requirements ever present tendency to arise, there is a shortcut procedures and tendency to accomplish to formalize action the activity and to later.
Such conditions formalise action later, increase the possibility such conditions, coupled of error. (p.9) with informal interface procedures, increase possibility of error. (p.9)
- 7. The Licensee and its Deleted (p.10) 3 consultants and con-tractors were just far t
enough removed from the customary levs1 of informality to promote the possibility of error and misunderstanding.
(p.10)
Draft Final Page Refe4 tct Language Language in PG&E Letter
- 8. Wh11e the Case Study Team The case study team was 4
was unable to establish unable to establish the the attitudes and relation-attitudes and relation-ships between engineering ships between engineering and the new quality and the new quality assurance director in assurance director during 1977, it is suspected those years (late 1976 and that the relationship was 1977]. (p.12) something less than con-structive (The new quality assurance director was reassigned in February 1979). (p.12)
- 9. The Licensee had a falso The Licensee had a high 5
sense of security with degree of confidence with respect to its engineering respect to its engineer-capability. (p.12) ing capability. (p.12)
- 10. Further, and as previously Deleted (p.13) 5 stated, the Licensee was within a few months of bringing the plant on line on several occasions.
M-Thus, actions that the
^
Licensee might take in a longer run would be dif-forent when it appears that project completion would be imminent, and no nuclear plants were anti-cipated in the near ters.
(p.13)
- 11. The Licensee's past exper-Deleted (p.13) ience with construction enabled them to proceed with the necessary controls in place and qualified people to keep them that way.
Construction of power plants was "old hat" and they Snow how to stay out of tr'o'uble and get the job done.
New QA/QC requirements were accommodated (referring to the Licensee's " failure to understand cnd appreciate the potential merit of a formal QA program"). (p.14)
Draft Final Page Refererace Language Language in PG&E Letter
- 12. There was no great exper-Deleted (p.15 )
ience in seismic matters in the Licensee's organt-sation, and there was r.o detailed scope of the work that the. Licensee spacified for its consultants. (p.15)
- 13. He (the Licensee's Vice Ne said these things were 6
President of Engineering) good for the staff to said these things were experience and it will good for his staff to be better for it when experience and it will be the project is completed.
better for it when the (p.16) project is ormpleted.
(se commented on a ausber of problems, mostly per-sonnel related that had arisen as a res, ult of this integrated matrix organi-e L
sation (the Project Comple-tion Tesal). (p.17) e y,
- 14. In the past, he (the Deleted (p.16) 7 N'
Nuclear Power Operations) h Licensee's Manager of eald, there had been auch wheel reinventing.
They started with a few of the required procedures and then flooded the place with records without having people to take care of them.
The QA guidelines had seemed to restrict the conduct of assuring quality and, thus, it was resisted. (p.17)
- 15. The fact that the Project The fact that the Project 8
Completion Team adopted the Completion Team adopted the A-E's quality assurance A-E's quality assurance pro-program is indicative of gram may be indicative of the Licensee's lack of the judgment that the understanding (or perhaps Licensee's methods of procedures) of how to apply applying QA to the design quality to the design /
process for nuclear plants construction process for needed improvement.
nuclear plants. (p.19)
(p.18) 4-
. ~
Drait Final Page Refert..ce Language Language in PG&E Letter
- 16. The Licensee, he (Project Deleted (p.19 )
Completion Engineering Manager] said, had good quality in each time frame since the job began in 1966.
As each of the new quality assurance initia-tives occurred, the Licensee responded, but it was more or less reaction.
(p.20)
- 17. It was admitted that the Deleted (p.21) 9 Licensee was slow to adopt all aspects of quality assurance. (p.24)
- 18. Further, the study Team Deleted (p.21) 9 made the comment that it appeared to them that the l
Licensee's engineering organisation appear.3d as
" prima donnas."
This was not disputed by the 2.
Licensee's upper manage-ment. (p.24)
- 19. Based on the results of Deleted (p.22) the IDVP reported by the Project Completion Team, one would not expect to find large numbers of quality-related problems in the design process.
(p.25)
- 20. The Manager of Nuclear Deleted (p.22)
Power Operations high-lighted the probles this l
I way; he said that the idea was perpetuated that, if one had the paperwork correct, one had a proper QA pr6 gram. (p.25) -
. =
Draft Final Page Refer ct Language Language in PG&E Letter
- 21. Whtie some of the top Deleted (p.26) quality control managers felt that Licensee employed j
[ sic] may have been less aggressive than desired, it is doubtful that certification of these
[ quality assurance / quality controll personnel woald.
have changed the situa-tion. (p.30)
- 22. Many of the management Deleted (p. A-1) 10 decisions over the years indicate an attitude of "do anything and every-thing to expedite bringing
)'-
the plant on line."
The current Independent Design Verification Program (IDVP) and establishing in 1982 the Project Completion Team under en architect-engineer's direction reflects this attitoder however, the extent to which these changes reflect a real commitment to as-suring quality rather than providing " cosmetics
- is not totally clear.
The apparent imbalance between
" construction" and "engin-eeeing" in assuring quality is considered to reflect some lack of commitment at the top levels of corporate l
l nanagement. (p.A-1)
- 23. There is evidence that Deleted (p. A-1) 10 when the Licensee initially set up its OA/QC program, they appointed an old line constr ' tion engineer to be Manager position.
- Also, the individual at the Licensee who knew the most about quality philosophy was transferred to another function. (p.A-2)
Draft Final Page Refers e
Language Language in PGLE Letter i
- 34. Corporate QA does audit Corporate QA audits factlities.on a periodic conatruction activities basist however, general on a periodic basis, but understanding by upper there did not appear to management would indicate
'be the same attention that they would not see the given to engineering need to audit from a man-activities. (p.A-1) agement standpoint.
There was much talk about engineering taking care' of its own problems as they arose, but did not indicate a formal program for corrective actions mainly a pereoanel function.
i (p.A-2)
- 25. Company personnel seem to At one time, QA appeared 11 j
be afraid of the concept to be a tera used to a
of Ok or QC having access describe an organization A'
to top management.
They required by regulations...
don't see any benefit /
(p A-1) reason.
They do not under-stand the concept.
"On" is.a term used to describe the organisation that they were required to organise, but really didn't need.
(p.A-2)
- 26. In the early days, cost /
Deleted (p.A-1) 11 schedule did override QA/QC functions.
The Licensee had auch pride in their abilities, bow-l ever, and felt that they were doing everything correctly.
There is such evidence to indicate that they were willing to admit their limitations and seek l-help for seismic work.
l (p. A-2)
. u
j i
oratt Final Page neterenci Language Language in PGr,E Lettet
- 27. There is evidence tha There are no observa-11 this is one acea (clearly tions for the present defined and properly organization; the implemented responsibility licer.see is aware that and authority] that was engineering CA should very weak in the early have been mors formal n
stages, and is one of the in the early program.
reasons for the Licensee's (p.A-2) present predicament.
There are no observations for the present organisa-tion, other than t are aware that this a d haet been more formal in the earlyprpras.
Tne Licensee a former S manager made the statement that the early requirements for responsibilities were e4 left to the organization responsible for work.
M This was a general con =
census.
Everybody sup=
,.y posedly understands the g@;.
requirements, but chose to O!!
take care of his own res-possibilities. (p.A-3)
- 28. The Licensee did not The Licensee apparently 11 understand the.need for did not fully eppreciate trained quality people the importance of staff-l in the beginning.
Many ing with experienced @
1e were put into personnel in the beginning.
ity functions without (p.A-3) trainin9.
The Engineering Manager a philosophy is th&t the people responsi-ble for the task are the i
l only ones capable of really getting it done.
He refuses to accept an independent organization watching his activities.
I He doesn't understand the l
concept.
In fact, the opposite of quality manage-ment seems to have happened.
The Corporate QA Manager does not appear to be
Draft Final Page Refest ce Language Language in PG&E Letter l very dynamic, and the former QA manager, who appears to be very know-ledgeable, was transferred.
(p. A-4 )
- 29. Many changes (presently]
Deleted (p. A-4 )
12 are made at the facility or plant that are not made en drawings.
This indicates a potential
~
problem with drawing changes, and a possible design change / review problem. (p.A-5)
'10. This factor (pronapt This factor seems to 12 raporting of Oh program be strongly sad effec-deficiencict] setse to tively supported at the be strocq1y and effwativwly constructica site. (p.A-4) supported e'4 the construo=
- tion site.
There is.e cencern, M: wever, about the effectiver.ess as earlier inspectiora and audits of matcritalsy-~
- )
suppliors, notably'one-supplier of. electrical system supporta. (p.A-6)
- 31. In the early days, this p$1eted (p.A-4) 12 (prompt reportingj was not done.
Tha Licer.see fully understards the need now.
(p.A-6 )
- 32. Changes are made at:the Deleted (p.A-4) facility / plant as required.
The Licensee seems to justify this by the fae:t that QC peopis are engineers,'and are often the people who did the design.
Therefore, they are capable / justified.
Many instances reflect that early-on engineers did not have their designs reviewed.
Changes are
-9_
s Draft Final Page Heterence Language Language in PG&E Letter raade as required and appear to be done informally. (p.A-7)
- 33. QC functions are performed QC functions are per-12 by the departments respon-formed by the departments I,
sible for the task.
This responsible for the task.
can work, but it is not a (p. A-5) common practice in soet organisations and is not in compliance with the intent of 10 C.F.R. 50 Appendix 5.
(p.A-7)
- 34. This case is a classic The engineering problems of " haste makes waste."
which have been so costly The engineering problems are suspected to have which have been so costly resulted, at least in appear to have resulted part, from very heavy at least in part from schedule pressures.
1 very heavy schedule Whether these pressure pressures.
This was
[ sic] were red or felt 76 extended to the initial was not established.
efforts at a design There was no indication verification program of inck of resources which produced an addi-applied to the project.
tional set of problems.
(p.A-5)
There were no indications of lack of resources cur-cently. (p. A-8 )
- 35. Early stages of the design Deleted (p. A-7) of the Licensee's plant were poorly documented.
There is an understanding within the Licensee that this was a bad mistake.
Present-day practices not reviewed. (p. A-10 )
- 36. There appears to be no The audit of the design 12 formalised program of process was probably not audits.
The audit program a strong emphasis or the has been very extensively design control procedure strengthened during the deficiency would have been past year, reflecting in noted.
The audit program all likelihood that it was has been very extensively lacking previously.
strengthened during the (p.A-10) past year. (p.A-6) 10 -
Oraft Final Page Reference Language Language in PG&E Lotter
- 37. In the early days, audit The Licensee had a QA/QC 12 activities were probably program, but the problems not performed.
The they have experienced would
-l licensee had a quality indf,cate that they did not program, but the problems have an aggressive system j
they have experienced to verify implementation 1
would indicate that a in the design control j
continued system to verify
_acea.
WE audit reports implementation was non-gave the licensee good existent.
There is also reports on ecostruction evidence that early N K quality program implemen-audit reporta gave the tation.
(p.A-8) licensee good re ets on quality program lesen-tation when, in fact, this was not the case, based on a review of correspondence.
(p.A-10) 1 i
(
y l
1 c'
l 11 -
e t
'"y,'f' 3 ALLEGATION DATA FORM u s. uuctio nt cuteiony covwssion in.i..ci on.
..o.
RECEIVING OTF1CE ce um er eP NC8 W
- 1. Feellitylles) Involved:
IN.mel
" &'"lfg*u'fn,g, hIEBLb 0AM6M O O O_
_ O O 2
' S-2' Functional Areafs) Involved, ich.ca.ppropri.ie bournell operations cnsite health and safety
^
construction of fsite health and safety safeguards emergency preparedness other tsp. try) 3.
Description:
lslalelalcirlylclvl leltl4l lul;l~lsi l l IIIII I clelul elein.l~l sl l IIIIIIIIIIIIIIIl II IIIll IIIIl l l l l l l 1IIIIIII IIIll IIIIIl ll l l l l l l l l l l lll
~'
- 4. Source of AIIegation.
~
Ich.ek.ppropste bo.)
contractor employee security guard licensee employee news media NRC employee
, private citizen organiZalion (Sp. city) other (sp. city)
MM DD YY
- 5. Date A!!egation Received:
i I Jl2 2. l Tr 3 P a f_L A o ek a
- T
- d4
- 6. Name of individual Ints: two ini 1.1..no r..i n.m.)
n.
Receiving Allegation:
- 7. Of fice:
Mk#
Y "k ~ NA /2 /H 71 b4.}(A ACTION OFFICE M
- k. 4.
SCAR.Awo
- 8. Action Office Contaet:
In,. e o inii;.r..ng i.. n...:
- 9. FTS Telephone Number:
- 6 3
3 7 1
7
- 10. Status:
~
scheck ones Open, if fotfowup actions are pending or in progress Closed, if fotfowup actions are completed MM DD YY
- 11. Det. Closed:
l l
11.1 Document Nos.
( f "Ca'k'...;,3 IIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIIl l 'l l IIIIIIIIIII 1I.1 Mar)-hour Da otr.c.
Y..,
Number
- 13. Affegation Nurf er:te Rv-63
-A-O O 6 Y
,y-a l
Decenber 2,1983 Dr. Richard Kranzdorf, Spokesperson Concerned Cal Poly Faculty and Staff 160 Graves Avenue San Luis Obispo, California 93401
Dear Dr. Kranzdorf:
This is to acknowledge receipt of your. letter of Novenber 4,1983 to the Chairan of the U. S. Nuclear Regulatory Comission and attachnents thereto, expressing concerns regarding a lack of public confidence in emrgancy planning for the Diablo Canyon Nuclear Power Plant and icpedinents to evacuation of elemnts of the public in the event of a nuclear energency.
Thank you for the reasoned and docunented statenunt regarding your concerns.
They will serve as a basis for in and resolution of these concerns,.quiry, hopefully leading to a sound evaluation Please be advised that we have provided copies of your correspondence to the U. S. Federal Emrgency Managenunt Agency (FEl%), which has a specific assignment by Executive Order of the President to take the lead in' offsite radiological energency planning and response. Wa will work closely with FEMA. the State of California Office of Emrgancy Services, and cognizant local emrgency services elemnts in evaluating and resolving your expressed concerns.
Please feel free to contact us if you wish to provide further data reflecting on your concerns or if we my answer any questions regarding our handling of-the evaluation of your concerns.
Sincerely,
/S/ tzu.
h,,JohnB. Martin Regional Administrator ainwVW pa
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12L. L 1a.3.1at.y.....a1...12L...l ).a3.12L.J....1.aa x comune om macu see OFFICIAL RECORD COPY usam %
Task:
Allegation f ATS. No.
RV-83-A-0064 Characterization:
Lack of public confidence in feasibility of local emergency plans and impediments to public evacuation during an emergency.
Initial Assessment of Significance:
Substantiation of allega-tions could indicate that evacuation of the EPZ may not have been adequately evaluated, thus resulting in an inadequate emergen-cy plan finding by FEMA with potential adverse impact on the licensing of the DCNPP.
Source:
Letter from Dr. Richard Kranzdorf, as spokesperson for Concerned Cal Poly Faculty and Staff to NRC Chairman and Region V Administrator, 11/83 Approach to Resolution:
1.
Copy of correspondence provided to Region IX, U.S.
Federal Emergency management Agency (FEMA).
2.
FEMA will provide copies of Kransdorf correspondence to State of California Office of Emergency Services and San Luis Obispo County Emergency Services Office.
3 Dr. Kranzdorf initially notified by letter that his correspondence was
- received, is being evaluated, and that he will be notified of subsequent determinations pertain-ing thereto.
4.
FEMA is arranging a conference for the week of December 5,
- 1983, for discussion and resolution of Kranzdorf allegations. Participants to be NRC-RV, FEMA-IX, State of California Office of Emergency Ser-
- vices, and local County officials.
5.
Coordinate closely with FEMA to (j
resolve the specific allegations 1
~
- ~
and alleged substantiation therefor.
6.
Formulate with FEMA a response to Dr.
Kranzdorf regarding resolution of his allegations, and if appropriate, continuing actions.
Status:
FEMA is coordinating meeting / conference for week of Dece=ber 5, 1983
~
Review Lead:
Region V Support:
Region V-none presently envisioned.
FEMA-IX - not yet determined.
Estimated Resources:
Region V: 6 mandays (estimated)
FEMA-IX:
to be provided for and managed separately.
Estimated Completion:
Interim:
12/12/83 Final:
Cannot yet be determined e
U 2
.