IR 05000424/1985061

Insp Rept 50-424/85-61 on 860106-10,13-16 & 28-31 of Readiness Review Program,App D, Document Control. Violation Noted:Inadequate Pullman Power Products Drawing Control Corrective Action

ML20205P458
Person / Time
Site:	Vogtle
Issue date:	04/28/1986
From:	Belisle G, Moore L, Sinkule M, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P441	List: IR 05000424/1985061 ML20205P436
References
50-424-85-61, NUDOCS 8605210418
Download: ML20205P458 (14)

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ENCLOSURE Report Nos.: 50-424/85-61 Licensee: Georgia Power Company P.O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle Unit 1 Inspection Conduc ed: anuar 6-10, 13-16; 28-31, 1986 Inspector. _

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' pate ' Signed e Vf f If R. W: Wright w / Date Signed Approved by: ^@ f JJ G. A.'BelislePActing Section Chief Date Signed Division o R ctor Safety

% {c_ - N M. V. Sinku' c, Chief. Project Section 20 Ddte Sfgncd Division of Reactor Projects I

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8605210418 860505 PDR ADOCK 05000424 G PDR

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Enclosure 2 TABLE OF CONTENTS Topic Page Summary 3 Scope of Review 4 Methodology 5 Evaluation 6 Findings 13 Conclusions 13

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Enclosure 3

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V0GTLE ELECTRIC GENERATING PLANT UNIT 1 READINESS REVIEW PROGRAM APPENDIX D DOCUMENT CONTROL SUMMARY This report is an evaluation of Appendix D of the Vogtle Readiness Review Progra This program is being conducted as an initiative of Georgia Power Company (GPC) management to assure that all design, construction, and operational commitments have been properly implemented at the Vogtle Electric Generating Plant Unit 1. Appendix D, which is one of an anticipated eight appendices, presents a review and assessment of the program implemented by the Project Document Control Centers for the design, construction, and preoperational testing phases of the project. This evaluation was conducted to determine if the results of the program review on the Project Document Control activities presented in this appendix are an effective and accurate assessment of design, construction, and operational requirements; that these requirements are being properly implemented; and that the resolutions of findings identified in the appendix were j correc This evaluation was performed by NRC inspectors from Region I The evaluation was accomplished through a detailed ' review of'all sections of the appendix by: 1) verifying that the design and construction commitments listed in the appendix are correct and comply with Final Safety Analysis Report (FSAR)

requirements; 2) reviewing the appendix findings and evaluating the correctness of their resolution; 3) reviewing a comprehensive and representative sample of the records reviewed by the GPC Readiness Review Staff (RRS); 4) selecting and reviewing a comprehensive and representative random sample of records concerning Document Control Activities; and 5) reviewing prior inspection activity in this are During the review, it was apparent to the NRC inspectors that GPC management supported the program by active participation in the development and implementation of the program. This evaluation also indicates that the licensee's program review of a selected sampling of Document Control activities was comprehensive and that the subject program complies with NRC requirements and FSAR commitment One violation discussed in Region II Inspection Report .

50-424/86-15 and one unresolved item discussed in this report were identified by the NRC inspector An unresolved item is a matter which requires further

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information and investigation to determine if it is acceptable or may involve a i violation or deviation. These items are summarized below:

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Violation -

Inadequate Pullman Power Products Drawing Control Corrective Action Unresolved Item -

Verification of Corrective Action Specified for Readiness Review Findings (RRF) D-5, D-6, D-7, D-8

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Enclosure 4 As stated in Appendix D, Document Control, this appendix was developed by three individuals having extensive specific expertise in drawing and data control, quality engineering, and quality assurance (QA). These individuals also had broad backgrounds in nuclear power plant activities. An appendix verification checklist was used during this activit This verification checklist was developed by taking into consideration problem areas identified from past audits performed by Bechtel Power Corporation (BPC), GPC QA, Institute of Nuclear Power Operations (INP0), Southern Company Services (SCS), Self-Initiated Evaluations (SIE) and the NRC. The document control and QA records control verification was conducted in three part In part I, project procedures were reviewed for implementation of commitments identified in the FSAR for both document control and QA records control. In parts II and III those comitments pertaining to document control and QA records control respectively were reviewed by comparing the source documents to the implementing procedures and commitments. The document types that were included in the document control review were drawings, field change requests (FCRs), design change documents, procedures specifications, and supplier dat In addition to the QA records review conducted, the construction requirements and maintenance of the records storage vaults were reviewed to ascertain whether they met commitments and implementing procedure Based on this three-part review, eight findings were identified by RRS. All findings were evaluated by the licensee to be violations with no safety concern Three findings involved outdated and inappropriate change documents that were available at the site work station. One finding concerned change documents that had not been properly identified or completely filled out. Two findings involved organizations responsible for supplying records to the Record Management System (RMS) not always implementing this responsibility. One finding concerned a needed procedural enhancement to further clarify a record retention commitmen The last finding involved dual storage requirements for calculations not being met due to the microfilming process falling behind schedul NRC inspectors reviewed Appendix D on site during January 6-10, 13-16 and 28-31, 1986. Approximately 189 inspector hours were used during this review. Review details are delineated in this report. As previously stated, one violation and one unresolved item were identifie It appears that these items will not represent significant programmatic weaknesse Details on these items are discussed in the main body of this repor . Scope of Review This review, which consisted of an examination of each section of Appendix D, was performed by inspectors from Region I Appendix D, Sections 1.0, 2.0, 4.0, 6.0, and 8.0 present data on the appendix scope, responsible organizations, program description, changes, and conclusions i regarding the assessment of the appendix, did not require as detailed a i review or evaluation as the other sections. The more significant aspects of I the appendix are in Section 3.0, 5.0, and These sections discuss licensee commitments and implementation, audits and special evaluations conducted, and appendix verification. Review of these sections included a detailed review of content and examination of items identified as findings

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l Enclosure 5 regardless of their final level of classification. The inspectors examined a sample of records reviewed by the RRS and also examined an independently selected sample of records to assess the thoroughness of the overall evaluation. Methodology used for this review and an evaluation of each section are presented in the following paragraph . Methodology t

The technical review and evaluation of Appendix D were conducted in the r Region II office during the week of December 16, 1985, and was supported by l onst te inspection activity during the weeks of January 6-10, 13-16 and 28-31, 198 The office review of Section 3.0 compared the applicant's accepted QA program licensing commitments with the (NUREG-0800) Standard Review Plan (SRP) positions, regulatory guides, industrial codes, and Vogtle FSAR document During the onsite inspections, the program description, Section D4.0 was reviewed to verify that responsibilities and work processes described therein, concerning the document /QA records control program for the participating project organizations, was being properly implemented as written. Bechtel Power Corporation (BPC), GPC, and Pullman Power Products

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(PPP, the mechanical equipment, piping and component contractor) project

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procedures were reviewed to confirm that they contained implementing requirements necessary to evaluate the adequacy of their document /QA records control program. Audit reports, applicable document /QA records control audit findings, and RRS findings were also reviewed to determine the significance of the problem areas identified and the effectiveness of the proposed or corrective actions take Bechtel Power Corporation Project Field Engineering Drawing / Document Control (BPC PFE-DDC) activities were not included in the verification process since the majority of documents they handle are distributed through the GPC Construction Drawing / Document Control-(GPC DDC) center; therefore, verification was accomplished by reviewing the GPC-DDC center activities. Additionally, minimal document /QA records control verification was performed on the GPC Nuclear Operations DDC center by the inspectors since these attributes were examined by the NRC during our review of Module The inspectors examined the RRS's original working checklists for the extent of detail and depth of review that was applied to the two project organizations and two site contractors selected for document control verification. The inspectors randomly selected and examined another major site contractor (PPP) for verification that current documentation data was being distributed and used during the construction of the plan The RRS's verification efforts expended on QA records control at the GPC Construction Document Review Section, GPC Nuclear Operations Document Center, BPC Document Control in Norwalk, CA. and Southern Company Services QA (SCS QA) were reviewed by the inspectors to confirm the adequacy and effectiveness of their programs. Numerous additional QA records that were

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Enclosure 6 formally transmitted to either the GPC Construction or GPC Operations vaults were selected by the inspectors for review to ascertain that these records were indeed received, handled in accordance with project procedures, stored, and maintained within an environment consistent with comitment . Evaluation The evaluation of each section of Appendix D is provided below. For each section, a description of each section, what was reviewed, and the basis of acceptance are provided, Section D1 - Scope This section discusses, to a limited extent, the boundaries to which the document control and QA records programs were evaluated by the RR The document control program was examined by the RRS for the proper issuance, control, and distribution of project documents such as procedures, specifications, and drawings, including changes theret ,

The RRS examined the QA records control program for the vault l ascertaining that it provided for proper indexing, storage, !

retrievability, and maintenance of records that included both vendor-supplied records and site-generated document This section was reviewed for background information only. No followup or evaluation of this section was required, Section D2 - Responsible Organizations This section describes the various organizations responsible for document and QA records control for engineering, construction, and operational activities conducted at Plant Vogtl GPC, BPC, SCS and 11 site contractors share this responsibility. The degree of involvement and responsibility shared by each, however, varies as mentioned in this sectio All of these organizations control their respective documents and QA records in accordance with written procedure This section was reviewed for background information and for a general understanding of the interfaces necessary between the various document and QA records control center l 1 Section D3 - Comitments and Implementation (1) The inspectors reviewed the 13 documents and QA record control comitments identified by the RRS in Table D3-1 to confirm that they were the same as those comitted to in the FSA (2) The RRS reviewed the historical file of project procedures (GPC Nuclear Operations, GPC Nuclear Construction, and GPC Project Engineering procedures summarized in Table D3-3) to determine I

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Enclosure 7 whether applicable document and QA record control commitments were contained therei >

Since Module 5, Operations Organization and Administration (already reviewed by NRC) overlaps Appendix D i.e., covering GPC Nuclear Operations document and QA records control, the NRC inspectors limited their procedural review of required comitments to the GPC nuclear construction and BPC engineering procedure These procedur:s were reviewed to verify that the FSAR commitments were correctly transposed into these project document (3) Chapter 17 of the FSAR states that the Design and Construction programs for document and QA records control concerning GPC, BPC, and SCS will conform to ANSI N45.2.9-1973, Draft 11, Rev. O, and ANSI N45.2-1971, Sections 7 and 18. Site contractors performing work at the VEGP control their documents and QA records in accordance with written procedures which are reviewed and approved by GP (4) The GPC Nuclear Operations document and QA records activities are controlled by commitments in Regulatory Guides 1.33 and 1.88 which endorse more current ANSI standards N18.7-1976 and N45.2.9-197 (5) The NRC Vendor Program Branch (VPB) periodically inspects Bechtel and Westinghouse, as well as the other major Architech/ Engineer j (AE) and Nuclear Steam Supply System (NSSS) firms, by examining their QA programs for document and QA records control. Inspection findings are issued as inspection reports (published quarterly as NUREG 0040) and may be the subject of an IE Information Notice or ,

Bulletin. Selective audits were reviewed by the inspectors to i verify implementation of an adequate document and QA records progra Review of this section by the RRS and NRC inspectors identified that Vogtle's licensing commitments and implementing documents comply with the FSAR, SRP, RGs, and industry codes and standard Section D4 - Frogram Description l l

This section of the appendix provides a description of the project i document control and QA records control programs. It also identifies the major project documents, records, and provides a brief summary of the manner in which these documents or records are processed. During the construction phase all approved engineering drawings, specifications, procedures, manuals, and equivalent vendor submitted documents are channeled through the GPC DDC center. Construction DDC personnel are responsible for:

Checking those documents received against their transmittal letter to ensure correct receip .

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Enclosure 8 Inputting pertinent document data into the Records Management System computer (NORMS) data bas Microfilming and printing required number of copies of the document for distributio Insuring that designated individuals on document distribution lists sign and date for copies of documents receive Auditing each entity onsite receiving controlled documents from GPC DD Construction site contractors, who are recipients of controlled documents, are required to have document control procedures which ensure that current data is being use The various document control centers for the different project organizations receive, store, and maintain QA records which provide objective evidence of the quality of work performed during design and construction preoperational testin During the construction phase, the GPC construction document review section receives, indexes, and stores QA records, including site generated documents and vendor

, supplied records. These records are subsequently transferred to i nuclear operations for storage and input into the RMS. The nuclear l operations Records Management System, maintained by nuclear operations, l provides an index of QA records and certain project documents and includes identification, retention, retrieval, and records forma The records storage facilities (vault), which was established by the project organizations, provide a means for storing QA records in a controlled environment to minimize deterioration or damage and to prevent los Review of this section confirmed that the program description is correct and in agreement with the FSAR and project requirement Section DS - Audits This section contains a review of the various audits and evaluations conducted by SCS, GPC, BPC QA personnel, NRC Inspection and Enforcement personnel, the Institute of Nuclear Power Operations (INP0) personnel, and a self-initiated evaluation (SIE) performed by off-project personnel from GPC, SCS and BP Problem areas identified by this review of audits / evaluations relative to document and. QA records control are tabulated as audit findings or observation The most significant past audit findings / observations from this listing were further identifie This information was used by the RRS in developing the verification scope and checklists used in the modul Review of this section indicates that it is an accurate presentation of the deficiencies identified against the audit progra _ .

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Enclosure 9 Section D6 - Program Changes The document control and QA records control procedures have been subjected to various changes as the project design evolved, as document control responsibilities changed, and as regulations and standards were updated or added to the project requirements. Additional changes resulted from NRC inspections, QA audits, and internal reviews. Review of these changes indicates the majority involve procedural clarifi-cation and enhancement of document and QA records processing.

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Three program changes, one involving expansion of the Project Field Engineering (PFE) organization and two concerning transfer of responsibilities were reviewed by the inspectors and RRS and the determination was made that these changes did not reduce the commitments in the program. These program changes are as follows:

Establishment of a PFE-DDC to control documents generated by this group.

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Construction and operations document control perscnnel now ascertain that DCN/FCR changes have been appropriately incorporated into design documents instead of GPC engineerin The responsibility and control of the automated records management program and associated micrographic functions were transferred

from construction DDC to operations DD Section D7 - Document Control /QA Records Control Appendix Verification This section describes the document control and QA records control program verification, resulting findings, and corrective actions. The Vogtle document /QA records control verification conducted by the RRS was performed in three parts in accordance with written checklist (1) Part 1 - Commitments / Procedures Part 1 of this appendix verification was performed by developing checklists from 10 CFR 50 Appendix B, Criterion VI and XVII; FSAR Sections 17.A.6, 17.1.6, 17.2.6, 17.1.17, and 17.2.17; ANSI N45.2-1971, N45.2.9 Draf t 11-1973; and Regulatory Guide 1.88 (operations only) requirements. Problem areas from past audit reports and related industry problems were also incorporated into the verification plans and checklist The RRS then compared these requirements with those contained in implementing procedures to verify, by objective evidence, that the commitments were adequat Examination of these same documents (with the exception of GPC nuclear operations documents which was done under Module 5) by the inspector confirmed that the work by RRS was acceptabl __- __- _ _ _ - _ __ -_ - _ _ _ _ _ _ _ _ - - - _ _ _ - _ - . - _ _ _ _ _ _ _ _ _ _ - _ _

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Enclosure 10 (2) Part 2 - Document Control Implementation The RRS examined approximately 2500 project documents (drawings, procedures, specifications, supplier data, and changes thereto)

which were randomly selected from five (GPC-Construction, BPC-Norwalk Ca., Cleveland, Pullman /Kenith-Fortson (P/K-F), and GPC-Electric QC) document control centers. These documents were reviewed to determine whether evidence existed throughout the design and construction phases that project documents were received, distributed, controlled, and available for use in compliance with Vogtle Project commitments and implementing procedure In addition to the above document review, the activities related to document control within the above mentioned project document control centers were observed by the RRS members as a part of the revie The inspectors reviewed the RRS's working copies of all available checklists and supporting backup data that was kept on the project in loose-leaf binders. The inspectors concluded that the RRS did an adequate audit of those contractors and project entities they selected for the document control review. The inspectors observed and examined the in-place GPC-Construction DDC center control The inspectors conducted an audit during January 10-13, 1986 of PPP drawing controls and reviewed GPC QA aucits, audit findings, and corrective actions implemented for their document control audits conducte The inspectors examined the GPC Document Control Audit Personnel (DCAP) findings concerning their audits of controlled drawings, procedures, and specifications assigned to the following site contractor organizations during the interim 1983-1985 when applicabl Pullman Power Products - Piping system fabrication and installatio Williams Contracting Inc. - Coatings application Walsh Construction Company - General Contractor (Civil)

Pullman /Kenith-Fortson - HVAC Installation Ingalls Iron Works Co. - Miscellaneous and structural steel fabrication and installation The inspectors concluded from this review that PPP drawing control measures for the most part were unacceptable between March 1983 and August 1985 by GPC's acceptance criteri Although appropriate levels of management were informed and corrective actions were implemented throughout the subject interim period consistent unacceptable error rates continued. The licensee was notified during the exit meeting conducted January 31, 1986, that in the inspectors opinion this non-effective corrective action

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S i ' Enclosure 11 over the given time span would constitute. a violation against 10 CFR 50, Appendix B, Criterion XVI; however, he would discuss this matter with his management further, prior .to making this :

final decision.. Consequently, the RRS was subsequently notified ~ ,

by telephone on February 7,1986 that this matter would be identified in Region II's Inspection Report -50-424/86-15 as 'a

violation entitled, " Inadequate PPP drawing control corrective

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action."

i The inspectors concluded from DDC observations, interviews with

! DCC supervisors and personnel, review of GPC-QA and DCC'past audit i findings, examination of the RRS methodology employed, typical 4 project organization entities chosen for review, and the RRS l resulting findings, that this sample verification was truly 1 indicative and representative of the Vogtle Project document .

1 control program. This verification revealed- that although the ,

i document control implementation program was by no' means without - "

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problems since 'its conception, the licensee learned from his mistakes and continually upgraded and enhanced the document control program. The RRS evaluated past audits and inspections and their associated findings and concluded that these findings *

have been adequately addressed by the Project and present no

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adverse affect to the safe operation of the plant. The inspectors

concluded that the Vogtle Project organizations have implemented an effective document control program.

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The GPC Construction Document' Review Section, GPC Nuclear

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Operations Document Control, BPC Norwalk Ca. Document Control, and

SCS QA/ Document Control centers were selected by the RRS for QA

records control revie As discussed in section. 3.g(1) the evaluation of Nuclear Operations had been completed in Module 5;

, therefore, the verification of Nuclear Operations was limited to inspection of the vault. construction and records environment

therein and that period audits were performed on these attributes.

The RRS examined approximately 300 QA records for evidence that

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, they have been.and currently are being received and handled in accordance with project . procedures, and- stored- and maintained within an environment consistent with commitment The NRC inspectors examined the completed checklists and related

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RRS work effort performed on these QA record Although the number (300) of QA records comprising the selected sample was not extensive, the review that the majority of these records received was comprehensiv The NRC inspectors selected an additional 101 various construction and engineering discipline QA records ' plus five volumes of periodic inspection reports that had been transmitted at different

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Enclosure 12 time frames from the GPC construction vault to the GPC nuclear operations vault. These QA records were checked for their retrievability, completeness and legibilit Likewise, approximately 80 various construction discipline activity QA records that have been transmitted over the construction life of the project from various QC organizations to the GPC construction vault were examined for the same attributes. Additionally, five vendor submitted document packages were examined by the NRC inspectors in detail for assurance that the construction document review section personnel performed required reviews and checks necessary to assure complete QA documentation is on hand for all material / equipment as required by the purchase order specification and project procedure, No deficiencies were identified by the inspector In addition to the QA records review above, the evaluation of the area was based on direct observation of work activities of responsible personnel, interviews with supervisors, and employees by both the RRS and the NRC inspectors.

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Part 3 of the verification review of QA records program conducted by the RRS was considered adequat (4) RRS Findings and Corrective Actions The inspector's examination of the eight RRS findings determined that they appeared to be properly categorized, and the proposed resolutions to these findings were satisfactor The Project corrective actions for Readiness Review Findings (RRF)

D-1, D-2, D-3 (regarding outdated and inappropriate change documents) were verified complete and closed out in GPC QA Audit Report CP02-86/05. BPC-QA performed verification and close out actions for RRF D-4 (change notices containing administrative errors) by performing a surveillance on this item which is documented in QAs Surveillance Log, Page 66, dated November 19-26, 198 RRF D-7 remains open because Project Reference Manual Procedure B-4 was found not revised per the Project response. BPC QA 16itiated a corrective action report (CAR) RR-VS-85-01 dated November 15, 1985 to track this deficienc Discussions with responsible RRF tracking and followup QA personnel from BPC, GPC, and SCS revealed that verification of the Project responses to findings D-5, D-6, and D-8, were either partially complete or not performed to date in that this verification action was scheduled to be accomplished during the next routine audit / surveillance conducted in the subject are l Based on this incomplete status concerning verification of corrective actions to RRFs, the inspector has collectively identified this item as an Unresolved Item 424/85-61-01, i

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Enclosure 13 Verification of corrective actions specified for RRFs D-5, D-6, D-7 and D- . Findings One Unresolved item and one violation were subsequently identified by the NRC inspector The violation listed below is discussed in detail in NRC Inspection Report 50-424/86-1 An unresolved item is a matter which requires further information and investigation to determine if it is acceptable or may involve a violation or deviation. These findings will be pursued to resolution in future routine inspection Unresolved Item (UI 85-61-01) Verification of Corrective Actions Specified for RRFs D-5, D-6, D-7 and D-8 Violation Item (VIO 86-15-01) Inadequate PPP Drawing Control Corrective Action Conclusions Based upon the review of this appendix and independent review of documentation on site, the NRC concludes the following: Licensing commitments and implementing procedures comply with FSAR, SRP, Regulatory Guides and industry codes and. standards.

' The Vogtle project has implemented an effective document control i progra The Vogtle project has implemented an effective QA records control program, Although discreparcies have been found with both the document and QA l record control programs since their implementation, the licensee has promptly addressed, evaluated, and corrected the deficiencies as necessary, and continually upgraded and enhanced these program Review and evaluation of Appendix D by the NRC indicate that the review performed by the GPC RRS was sufficiently comprehensive in scope and depth to identify problem areas, and that the dispositions of findings were proper and satisfactory. The NRC findings which included a violation discussed in Region II's Inspection Report 50-424/86-15 and an unresolved item mention in this report do not represent a breakdown in the QA progra l The NRC furthermore believes that Appendix D accurately assesses the status of design, construction, and operational document /QA records control activitie This conclusion is based on information currently available to the inspectors and reviewer Should information subsequently become available which was not considered during this review or previous

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L inspections and which conflicts with earlier information. . it will . be evaluated to determine what effect it may have on the above conclusion e

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