DCL-84-080, Forwards Program Description for HP Foley Co Quality Records Review & Turnover,In Response to Questions Raised by NRC at 840119 Exit Interview

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Forwards Program Description for HP Foley Co Quality Records Review & Turnover,In Response to Questions Raised by NRC at 840119 Exit Interview
ML20149E550
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 02/29/1984
From: Schuyler J
PACIFIC GAS & ELECTRIC CO.
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20149D694 List:
References
FOIA-84-21 DCL-84-080, DCL-84-80, NUDOCS 8801130380
Download: ML20149E550 (12)
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DFh' 3/r/sy' 1 PACIFIC GAS AND EIaE C T R,I C C O M PANY NOWS l 77 BEALE STREET . SAN FRANCl$CO, CALkFORNIA 94106 . (415)783 473') . TWX 910 372 6587 e

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  • E a'*- February 29, 1904 PGandE Letter Wo: UCL-04-000 Hr. Jonn B. Hartin, Regional Administrator U. S. duelear Regulatory Cornission, Region V 1450 liaria Lane, Suite 210 Walnut Creek, CA 94596-5360 Re: Docket do. 50-275, OL-OPR-76 l

, uf ablo Canyon Unit 1 ,

SECf 84-61, Iteas 65 and 167

Dear Hr. Hartin:

At the January 19, 1904 exit interview at Diablo Canyon Power Plant, the HRC raised questions regarding contractor quality records. In response to those questions, Puandi is providing the enclosed description of the program for ti. P. Foley Company quality records review and turnover to PGandC.

With regard to Pullman Power Products ("Pullman") records, Pullman turned all quality records over to PGandi in 1977 and 1901. A small portion of these records has been returned to Pullman to facilitate modifications perfomed following the turnover.

Quality records of all other contractors have bee.n turned over to PGands.

Kindly acknowledge receipt of this material on tJfe enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely,b r- . . . . .. . g s e r Enclosure ,

cc: 0. u. Eisenhut H. E. Schierling -

Service List 8e01130380 840229 )

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PGandE Letter.No. DCL-84-080 ,

o ENCLOSURE PCandE RESPONSE ON FOLEY l

QUALITY ASSURANCE RECORDS I. REQUEST FOR INFORMATION I

On January 17 and 19,1984, representatives of NRC Region V requested Pacifie  !

Cas and Electric Company (PGandE) to describe the program for H. P. Foley i Company (HPF) quality records review and turnover to PGandE.

II. PROGRAM DESCRIPTION l The program for review and turnover of Unit I records from HPF to PGandE consists of the following elements:

A. Record Definition B. Record Review C.

D. Verification That Records Cover All Activities and Work Turnover Program -

E. Records Storage The d'etails of these elements, including a discussion of past and current practices, follows A. RECORD DEFINITION PGandE contract specifications -for HPF work require the contractor to retain i l

aul quality-related records for a period of ten years and contain a listing of  ;

typical types Appendix B. and categories of quality records consistent with 100FR50, At the end of this ten year period, the contractor is required to contact PGandE and obtain direction for records disposition. A typical  ;

specification disclosing records retention is attached (Attachment 1).

PGandE will provide additional written direction to HPF by March 5,1984, further dcfining quality records and identifying those records which are to be turned over to PGandE.

B. RECORD REVIEW

  • Foley quality records have been continuously reviewed by HPF and PGandE since 1970.

During the entire period of HPF involvement at Diablo Canyon, each HPF '

quality control (QC) discipline supervisor has been responsible for perforuing an independent performed technical in that record review of quality records associated with work discipline. This responsibility has continued until the present and is documented in HPF Procedure QCP-17. However, a significant change in record review methodology occured in June 1983. The details are provided in Section B.2.

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B.1 REVIEW OF HPF 1970 - 1977 RECORDS ,

Fros'1970During activities. to 1977, HPF's work this period,' the quality was limited to .,

electrical a on install*

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- corresponding documentation was continuously inspectedy PGandE's and audited b General Construction Quality Control (OC/QC) and Quality Assuran organisations.

ce (QA) installations, documentation packagas, and enents other qualit During that period, GC/QC performed 90 audits while QA perform .

Additionally, inspections HPF conducted its own extensive programand of records. to audits audits.

condacted some 600 audits of records activities.Indeed, in the period 19  ;

In1976.

in particular, a series of 18 audits of HPF records e manages were performed nt adequacy, and retrievability.These audits specifically centered on docum discrepancy reports. detailed technical reviews , including of electrical qualit '

or modifications; a however, some of the clericalveand/or findings admi prompted a furt' er review of records to verify proper record q uality. .

documented in a 90-page audit report.The y 1977review and has been of all rem were resolved without plant modification. Findings identified during this review PGandE to verify that HPF had properly identified and iFollow-up audits w action.

adequate documentation to support the anyon work.

quality as of the 3.2

_REVIEV 0F HPF 1977 - 1984 RECORDS _

In 1977 HPF's scope of work was enlarged to include the i and architectural installation. mechanical equipment, nstallation ofinstrumentati eous civil

,work, majority includingofTMI HPFrelatedactivities work. was concentrated on. electrical with modifications arising from them (detailed PCandE Phase I Final Report).

Corrective ssociated in the Ac During the period from 1977 through 1983,n HPF A and QC QA and PGa dE performed 358 documentation. audits of HPF's construction activitiese and associat d 9

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. . l peak o'f construction in August 1983) pro'apted ad ,

e that HPF quality records documented during this period were atfeguate ,

Accordingly, in the Spring of 1983, PGandE directed HPF to perform .

ew of a re and after September 1981.the technical and administrative adequacy o1 order to assure that all quality records completed during and after  !

increase in HPF work were included in the review.

applied both to previously-reviewed and accepted records closed betweenThis n September 1981 and June 1983 and to new reconis completed after Ju! .

not part of the sample used to draw conclusions con pre-September 1981 records. .

information concerning the adequacy of-all HPF quality reco work.

The review was divided into two parts--technical and administrative The

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technical review verified that quality records properly documented the .

Installation as described by current design docunents.  !

The administrative '

review verified that the records were properly prepared individuals. by qualified .

were properly sorrected, all blanks were filled, shects we numbered, and preper reference was made to proc .

records received proper management approval. qualified, initia B.2.1

_RESULTS OF HPF POST-SEPTEMBER 1981 RECORDS REVIE modes 3, 4, and 5 is now complete.The technical review of records r be reviewed for modes 2 and 1. Very few additinal records are required to records is approximately 35% complete.The administrative review of all quality l

,a total of 32 deficiencies. Both of these reviews have identified the identification physical of the following rework or modifications items which requireday require or mResoluti j i

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One electrical raceway support was added due to an overspan on.

condi 1 2.

identification numbers.Five electrical raceway supports required re-sten 3.

Cable traceability could not be readily established for 31 circuits .

The renainder of the findings were resolved without physical rework or modification.

physical inspection Resolution involvedofclarification and verification the adequacy and correction and of installations , of record

, in someinstallations.

plant cases, review and acceptance by Engineering of the as-built conditio 0318d -

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No significant systematic or generic problems were identified in this review.  :

i The one electrical raceway support ,which required physical work as a result of the review does not indicate any systematic, or generic problem when one considers the large number of installations for which quality records were ,'

reviewed. Nor did the electrical raceway support re-stenciling reprer.,ent a significant finding, since the physical work required was not necessary for the supports to meet all design requirements.

As for the cable traceability matter, this particular item had not previously been reviewed in detail. Accordingly, prior to power ascension, HPF will verify traceabi3 tty of all design Class I cable installations.

B.3 RDULINING REVIEW ACTIVITIES OF HPF RECORDS In response to questions from representatives of NRC Region V concerning HPF records review and turnover, PGandE proposes the following program for the remaining record review activity. The program is based upon the results of the post-September 1981 records review as discussed in Section B.2.1. This four-part program will provide added assurance that the quality records documenting HPF's work are of acceptable quality. The program includes .

reviews by HPF and PGandE and spans the e.ntire time period kasociated with HPF

  • work. Further, this program provides for both technical and administrative reviews of the records where appropriate. However, some categories of work have been excluded from further review as noted in Attachment 2.

1.

HPF post-September 1981 records review. HPF will revise the procedures for, the post-September 1981 records review program to enhance its effectiveness, and will complete the program prior to commercial operation. .

2. HPF pre-September 1981 records review. HPF will perform a detailed document review to assure that records were properly prepared. This will be done prior to commercial operation.

3.' HPF review of cable traceability. To provide further assurance of

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appropriate documentation of Class I cable installation, HPF will verify their traceability prior to power ascension.

4. PGandE records review. PGandE will perform a review of document packages turned over by HPF to assure they have been properly prepared. This review will include inspection, on a random basis, of construction items which are complete and accepted by HPF to verify that HPF quality records adequately document installation according to design documents.

The details of this four-part program follow. '

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B.3.1 HPF POST-SEPTEMBER 1981 RECORDS.REVIEV. ,

HPF will complete its post-Septeaber 1981 records review. .

been structured to the criteria and scope as described Thisin review has Attachment 2 Based

_ upon recordthe review review completed to date, the following changes are being made to procedures:

(1)

Clarification an NCR. of the definition of conditions which require issuance of (2)

Clarification of the definition of approval levels and documentation requirements for quality record changes and/or corrections.

(3)

Additional administrativetraining of HPF document analy sts in HPF's quality procedures.

, The following being taken: actions, which will be reviewed and approved ,by are PCandE (1)

PCandE will direct HPF to modify their Procedure QCP-3, Processin .

Control of Deviations and Nonconformances, to further clarify condition which require the issuance of a Nonconformance Report, including programmatic problems not directly associated with the quality of installation scheduled to beand their by completed related corrective March 15, 1984.

actions.

This item is (2) ,HPF instructions which outline the document review process will be changes or corrections to quality records. revised to specify the completed by March 15, 1984. This is scheduled to be (3)

HPF has incorporated into its training program for document analysts, specific directions which assure a uniform method of conducting document reviews.

Training materials, such as specifications and procedures as well as any discussion on applicable quality administrative instructions, are documented and placed in a training file for each individual.

The HPF prior review ofoperation.

to commercial records completed after September 1981 will be completed B.3.2 HPF PRE-SEPTEMBER 1981 RECORDS REVIEW HPF is performing a review of records completed prior to September 1981.

The criteria and scope of the review is provided in Attachment 2.

This turnover, HPFpriorreview has beenoperation.

to commercial initiated, and will be completed, including record An interim report on progress of the review, to including power ascension. any findings and their significance, will be provided prior

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.. . 1 B.3.3 _HPF REVIEW OF CABLE TRACEABILITY f

To provide assurance of appropriate documentation of Class I c'able '

installation, M will' verify tisceability prior to power ascension.,', This,  !

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_ gerification s'fforriri'11 Tai 5llid'e'TieTrew bfTaih~ pull paMei bf circuit, j

B.3.4 PCandE RECORDS REVIEW l

In addition to the HPF review, PCandE will perform its own administrative review of documentation packages turned over to PCandE by HPF. This review ,

will parallel the HPF record turnover and will include:

(1) Verification that all documentation packages listed on HPF's indez are included.

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, documentation packages have been artified by HPF (3) An audit of the documentation packages.

Each package in the vill be completely reviewed to ensure that the package contents are couplete, correct, legible, and included according to the package indez.

(4)

Cross-references will be developed of Foley NCRs to Foley work packages using PGandE's computer-based Records Management System (RMS). This work will be completed during entry of all contractor documents into the RMS.

Verification (DRRs). of all reviews will be documented on Document Review Reports During the review process, document packages and/or individual be referred to 11PF for corrective action.docu=ents identified as miss PGandE will perform follow-up reviews on the corrections of .the deficiencies noted and, if generic problems are apparent, they will be investigated and r.esolved.

Additionally, P0andE GC/QC will continue to i'nspect, on a random basis, construction confirm items which are complete and accepted by the contractor to the following:

(1) Installation meets latest design documents.

(2)

Inspect $on records are complete regarding inspection activities.

(3) Procedure and specification requirements are met.

(4)

Required backup documentation is supplied (e.g., weld records, megger test records, pull tension calculations). ,

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VERIFICA'fION THAT RECORDS COVER ALL ACTIVITIES AND WORK To verify that all required quality records are in place and a'vailable for '

transfer to PCandE, HPF will perform crosschecks between work initiation documents and existing quality records. This program will be controlled by

_ approved procedures prior to record turnover andtocompleted PGandE. for each work package and work activity D. TURNOVER PROGRAX I I

Previous direction to HPF regarding quality records turnover has been provided i

by PCandE correspondence. The following procedures and instructions provide additional direction for records turnovart (1) PGandE Quality Assurance Policy Statenent - Quality Assurance Manual,Section IVII, Quality Assurance Records.

(2) PGandE Procedure for Receipt, Review, Indexing, and Storage of Records , l Quality Assurance Department Records Management Handbook, Part II.

  • l In addition, the following procedures and instructions have been recently prepared to provide further direction for records turnover.

(1) General Construction Instruction QCFI-3, Document Review of Contractor Generated Records. i i

(2) ' General Construction Instruction QCFI-4, Contractor's Record Turnover.

(3) HPF Procedure QCP-34, Safekeeping, Processing, and Turnover of Quality Assurance Records (this procedure has been approved by PGandE).

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(4) HPF Quality Assurance Instructions (QAIs) implementing QCP-34. PGandE will review and approve those QAIs t'o ve'rify proper implementation of QCP-34.

In addition, a PCandE turnover task force has been established to review federal, industry, and PGandE documentation requirements regarding contractor records. This task force is currently creating a generic turnover interface procedure which outlines the QA Program records turnover requirenents. All existing turnover procedures and instructions will be reviewed and revised to l comply with the turnover interface requirements outlined in the generic turnover interface procedure.

E. RECORDS STORAGE Currently most HPF quality records are stored in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire-rated file cabinets. The HPF records storage building is being upgraded to include automatic halon fire suppression and alarus. The facility upgrade will be completed by March 31, 1984. In the interim', *a continuous security and fire watch will be posted in addition to the existing strict access control.

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After the facility has been upgraded, all completed HPF quality records will continue to be stored in 1 hour-fire rated file cabinets within the facility.

As HPF quality records are turnet over to PGandE, the records will be removed ,

from the EPF vault and stored in the CC/QC' records storage vau1% which meets the ANSI K45.2 9 aingle storage racility criteria. '

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pCandE Letter No. DCL-84-08u ATTACHMENT 1 ,

e The following quote, taken from PGandE specification 8802 is a typical section in PGandE specifications on the use' and maintenance of contractor records:

4.1"11 Records: Contractor shall use, collect, and maintain records and data essential to document the quality of material supplied and ,

work performed under this Specificatiou. Records are considered one of the principal forms af objective evidence of quality,and procedures shall assure that records are complete and reliable. All records shall be collected and filed at one location at manufacturing shops or at the work site. Records collected shall include, as a minimua, the followance drawings, specifications, ,

purchase orders, work orders, inspection reports, test reports, work performance records, work procedures, qualification records, for.  !

procedures, equipment and personnnel, nonconformance reports, ,

corrective action records, and audit records. Inspection and test reports shall indicate the nature of observations or tests, and i acceptable limits of observations or tests, the results, the type of -

nonconformances observed, and the identity of the observing personnel.  !

Work performance records shall indicate acceptability of r the work and/or maiierial or necessary corrective action in cas'es of  !

nonconformances. All records shall be preserved by Contractor for use by Conpany for ten years. If Company has not requested custody i of the records and documents before the end' of the ten-year period, Contractor shall request disposition instructions from Company.

Until such time as they may be transferred to Company, the records  ;

and documents shall be available for inspection and review by '

Company and regulatory agencies. Upon request, duplicate copies of records by and documents Contractor for specific items shall be provided promptly to Constructor.

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PCandELetterNo.bCL-84-080 <

ATTACID(ENT 2 , '

CRITERIA AND SCOPE OF HPF REVIEW OF RECORDS I. CRITEllA A.

. All appropriate spaces on the records aball be filled in, pages shall be in numerical order, and the records package shall be complete.

B.

C.

All data on the records shall be clear and legible.

Signatures, initials and dates shall be authorized, approved, and affixed where required.

D.

Records shali be accurate and properly identified. Appropriate E.

inspection report references shall be affixed.

Records shall be indexed and packaged for turnover to PCandE.

Any problems identified will be promptly corrected in accordance with the

  • modified document review process procedures and, if required, will be '

documented in accordance with the modified nonconformaace procedure.

II. SCOPE Vith the exception of certain categories of records in specific time periods, all records will be reviewed. These exceptions include records of 16sta}1stions herformadee to thefor which extent other to necessary documents confirm validate proper installation plant operation and and/o maintenance.

from the review.The following is a list of record categories that are excluded A. Vire Terminations.

_ Performance is proven by instrument loop tests,

' electrical dry run tests, and startup functional tests. These tests are performed and documented by PGandE. Terminations are as-built and recorded on PGandE Engineering record drawings.

B. Vire Installation. Performance is proven by instrument loop tests, ilectrical dry run~ tests, megger teste, and startup functional tests, These tests are perforced and documented by PGandE. The as-built i

sonfiguration of circuits is recorded on PGandE record drawings. )

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C. Raceway Installation.

Project personnel to verify spacing,and location of supp9rts.All race

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The resulting recorded data were reviewed and accepted or modifications were issued. 's In 1983, Project personnel walked down all Design Class I raceways to verify separati'on of redundant circuite. Therefore, installations completed prior to 1982 are documented and known to be correct and no further review of these documents is planned. Records completei in 1982 and later will be reviewed.

D.

Raceway Support Installation. All raceway supports were walked down and as-built by Project personnel in 1982 and 1983. The resulting data were reviewed and accepted by Engineering or codifications were issued.

Therefore, all installations completed prior to 1982 are documented and known to be correct and no further review of these docu=ents is planned.

Records completed in 1982 and later will be reviewed. Velding and anchor bolt installation quality was not verified as a part of ,these walkdowns and engineering evaluations.. However, the quality of a6ehor bolt installations has been verified by other reviews and our findinEs are doeur.ented in letters to the NRC dated January 27, February 7, and Febr uary 16, 1984. Therefore,

! installations will be reviewed 11 welding records associated with these *.

E. HVJ C Duct Installation. The HVAC system has been tested by Project

%sonnel and consultants to verify air flows at all locations comply  !

wi';h design criteria. The results are documented. Also, startup tests have been performed, documented, and results accepted. The duct configuration and location are as-built and shown on PGandE dravices.

F. '_HVAC Support Installation.

All HVAC supports were walked down and as-built by Project personnel in 1982 and 1983. The resulting data were reviewed and accepted by Engineering or modifications were issued.

Therefore, all installations accomplished prior to 1982 are documented and known to be correct and no further review of these documents is Planned.

- Records completed in 1982 and later will be reviewed. Wolding and anchor bolt f.neta11ation quality was, not verified as a part of these walkdowns and engineering evaluations. However, the quality of anchor bolt installations has been verified by other reviews and our findings are docu:ented in letters to the NRC dated January 27, February 7, and ,

February 16, 1984. Therefore,'Wil welding records associated with these Tinata11ations will be reviewed.7 l

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