ML20207Q082

Package Consisting of marked-up Allegation on Lack of Review by HP Foley for pre-Sept 1981 Records & Unqualified Value Issue

ML20207Q082
Person / Time
Site:	Diablo Canyon
Issue date:	01/20/1984
From:	Wong H NRC
To:
Shared Package
ML20207Q078	List: ML20207Q077 ML20207Q082
References
FOIA-84-744 NUDOCS 8701220082
Download: ML20207Q082 (15)

Text

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Allegation or Concern No. ----

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7,N No ._ ------

ATS No._

Characterization _ ,

H. P. Foley is not reviewing records in preparation for records 1981 are being turnover; only those recordg generated since September reviewed.

Implied Significance to Plant Design, Construction or Operation _

The lack of review by H. P. Foley of records before September 1981 leads to questions regarding the acceptability and completeness of records generated before September 1981. ,

Assessment of Safety Significance _

9.

The H. P. Foley Quality Assurance Manual,Section XVII, Revision

" Quality Assurance Records," provides "the cethods to assure sufficie

' documentation is prepared to provide objective evidence ' of the quality Paragraph 3.2 of Section XVII of items and the activities performed."

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states that " procedures shall specify responsibilities for transm t a 8

rs The o) 4 distribution, review, maintenance, and turnover or retention."

ed R m <t i oE$' governing H. P. Foley instructions for the document review and turnove rau.w rd z e e-e om> i (QAI) -

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"' of H. P. Foley records are Quality Ad.ministrative Instruct ons 1(Rev. 2), 2(Rev.1), and 3(Rev.1) and the applicable H. P. Foley a,a uw C-I

guidelines for structural H7AC, and instrumentation records. Although l

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H. P. Foley instructions and guidelines exist, the governing Quality l Control Procedure (QCP-34) is presently in draf t form and has not yet been approved by H. P. Foley or PG&E.

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The allegation that only those records generated after September 1981 will be reviewed in preparation o records turnover to PG&E was substan iated)in that H. P. Foley instructions (QAI-1, 2, and 3) do d

epecifically state that only records from September 1981 forward will be reviewed. The documentation turnover review as defined in QAI-1 and Phase I is to verify 2 will be performed in two parts, Phase I and II.

that inspection documents support the plant design and Phase II is to ,

be an administrative review for completeness and accuracy.

Based on an allegation that quality related documents were being stored in the attic of the H. P. Foley building (Building No. 15), the NRC e

inspector identified eight boxes which appear,/ to contain Class I .

p. f;/n quality records. It was not evident nor were the boxes identified that 4

would indicate that these records were a duplicate set of records. The .

1 l attic of the adjacent H. P. Foley engineering building was also l

surveyed by the NRC inspector and no quality related records were i

found. The preliminary review of the contents of the eight box'es indicates that approximately 244 of 1692 (14.4%) of the files are not

/;/sr duplicates and the original /,are not located in the H. P. Foley storage facility. Additional reviews will be performed to determine if the recordsareactuallyClassIrecordsandafur[herattempt to locate f the originals. The rest of the caterials in the H. P. Foley building attic is being inventoried by H. P. Foley personnel. Based on

discussions'with H. P. Foley personnel, any additional quality related jf.d e"&T -

records will be reviewed to determine whether the records are I' #^  !

dup 1icates or actually belong in the storage facility. [See also 7,3

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additional section on document control] (not part of allegation ,,, 7*

l writeup). ,

Based on discussions with H. P. Foley personnel (Quality Director, Quality Assurance Manager, Records Manager, and Document Turnover Supervisor), records generated prior to September 1981 had been subjected to only a minimal review, if any, from a documentation turnover perspective. At best, only a very limited clerical review had er week d@w been performed for a small portion of records (where inspection, forms specifically required a clerical check).

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Thirteen H. P. Foley QA Audit reports (Audits DTj.1 - 1.13) regarding

^^' O documentation completion for turnover to PG&E were reviewed by the inspector.

These internal H. P. Foley audits were performed from March .

1976 through August 1976. Seven of the 13 audits identified significant discrepancies (i.e., DT-1.3 and 1.4 noted 190 of 210 pull box file folders were found to be filled out incorrectly, 9 of 18 raceway file folders contain problems, in many cases Termination Inspection Report files contained supplementary records which made the termination inspection reports confusing and misleading). The seven audits are identified as DT-1.1, 1.2, 1.3, 1.4, 1.6, 1.7, and 1.8 and the audit items specified in the following:

DT-1.1 Items 4, 5, 7, 10, 13, 16, 17 1.2 Items 6, 7

t 1.3, 1.4 General Comment 1.6 Item (Page 4)

Item 1 and General Comment 1.7 1.8 Item (Page 2)

In addition, 8 of the 13 H, P. Foley audit reports recommended full file or drawer reviews to assure completeness and reliability of documentation (DT-1.2, 1.3, 1.4, 1.5, 1.7, 1.9. 1.10, 1.11).

Subsequent H. P. Foley QA Audits of document turnover are detailed in letters from D. Parrish, Quality Assurance Manager (Toley) to L. E. Addlem:in, Senior Project Manager (Foley), dated December 21, 1976 and June 17, 1977. These two audits describe several documentation problems, such as: improperly completed inspection records; missing inspection documentation; open inspection records; de-termination requests issued before recorded terminations; circuit re-terminations without de-termination requests; splice wire traceability not .

available; incomplete work items; improper cable traceability numbers; and for reject items on inspection records, there is no evidence to 4

show that corrective actions were taken, there evidence of .

<=,4. A c i. t PG&E/Foley involvement to address overall question of records n ye u n t re -v completeness and accuracy?].

Documentation turnover reviews for II. P. Foley records (post September 1981) have been perfor=ed by H. P. Foley personnel since approximately l August 1983. Approximately 2300 Document Deficiency Notices (DDN) have been issued (as listed on the computer log sheets) and include l

deficiencies such as missing or incomplete inspection records, cable l-

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i traceabilit'y numbers not matching installation records, material traceability numbers not entered on records, and- improper drawing

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references. Although the vast majority of document discrepancies have

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not resulted in actual hardware deficiencies according to licensee personnel, the deficicacies identified indicate that the records do not i accurately reflect that all of the required inspections or installations performed. In addition, since relatively few Phase II reviews have been completed yet the number of document deficiencies identified will increase.

A review of PG&E audits of H. P. Foley documents for. turnover and document control indicate significant documentation errors in turnover documents and purchase orders (PG&E audits EA-5-76 and EA-7-76). Minor discrepancies were identified in audits EA-2-77, DCO-82-005, 'and DCO-82-045. In PG&E audit DC1-80-024,4 of 19 termination records were found to be incorrectly filed as incomplete when in fact the circuits

' had bee'n completed. ,

A review of electrical change order files showed many old change orders dating back to December 1974 were still open (i.e., Change Orders E-14

-15, -16. -34. -53, -54 through -58, -59, 14, 33, 34, 40, 72, 73, 75, 78, 82, 88, 89, 92, 93, 95, 98, 108, 129, etc.). In addition,'the old electrical change orders and field change orders are filed without the associated inspection documentation, therefore, caking it extremely difficult to determine the acceptability of work and inspection

( activities and records.

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A sample of eleven electrical change orders both open and closed were reviewed by the NRC inspector to' determine whether inspection records {

l c'xisted for these change orders sampled. Of the six open electrical l

j change orders (E-14. E-16, 286, 626, 698, and 564'), one conduit for .i change order E-14 has been deleted from the plant and for the other

., p/* ses five, inspection records were located in the raceway files. It samme ,

t that although work and inspection records chew the electrical change order to be completed, the change order log and the electrical change e

order files indicate the change orders to be open. Of the five closed electrical change orders (902, 922, 958, 987, and 1737), the conduit

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for, change order 987 was deleted f rom the plant and .for other four, inspection records were found in the raceway files. ,

During the NRC review of document turnover, it was noted by PG&E auditors that several DDN's identified deficiencies in records generated prior to September 1981. The H. P. Foley interof fice memo f rom J. Thompson, QA Manager, to Don Shealy, dated November 2,1983, ,

states that DDN's "for records prior to September of 1981 must be answered prior to turnover." In discussions with H. P. Foley personnel a full review of those DDN's which identify deficiencies in records generated prior to September 1981 would be performed to ensure that the deficiencies are resolved. The point to be. emphasized is that

deficiencies have been identified in the H. P. Foley pre-September 1981 records.

The PG&E review of contractor records is specified in PG&E Quality Control Instruction QCFI-3, Document Review of Contractor Generated Records, dated Dece=ber 2, 1983. QCFI-3 specifies in Section 4.0, a

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random 10%Jreview of the contents of the document packages to verify; (1) the contractor's QA/QC personnel signature or initial attesting to the completion and acceptability of the actiity, (2) completeness, I correctness, and legibility of the package contents by visual examination, and (3) a11 documents listed on the package index are included in the package. Those packages not in the 10% sample will be reviewed for ensure the contractor's index of documentation packages includes the packages under review. The PG&E review of turned over records can be characterized as only an administrative review of the reco7ds.

Although not part of an allegation investig i, an examination of the a.' Fike o current, documentation review process was done by the NRC inspector and the following observations were made:

1. PG&E Quality Control Instruction, QCFI-3, Docueent Review of Contractor Generated Records, dated December 2,1983, specifies in ,

paragraph 3.1, tha applicability of the instruction to quality records identified by the PG&E Records Management Hand Book and generated by onsite contractors. However, the PG&E Records Management Hand Book has not yet addressed the bulk of H. P. Foley records. A contractor for PG&E is now in the process making recommendations regarding which records should be retained and defining the retention period. ,

2. There exists no H. P. Foley procedure to define the document reviews being done now and the documentation turnover to occur later. H. P. Foley Quality Control Procedure, QCP-34, QA Records,

for the safekeeping, processing and turnover of quality records, has not yet been issued, although the procedure is required by the H. P. Foley QA Manual,Section XVII. The draft form of QCP-34 reviewed did not specify which documents a final acceptance review would be done. In addition, a review of Attachment 1 to QCP-34 (draft) by the NRC inspector revealed that the H. P. Foley records p4 a c i les storage facility did have records (i[n _.; Lie box files, electrical process travelers and purchase orders) not listed in Attachment 1.

Attachment I has now been corrected to include these record packages.

3. The H. P. Foley document reviews are governed by H. P. Foley Quality Assurance Instructions (QAI's) which are not reviewed by 4 .

PG&E. Therefore, changes or revisions to the QAI's may also be made without PG&E approval. ,

4. The recently revised QAI-3, Rev. 1, dated January 11, 1984, now -

provides review and acceptance criteria to perform the documentation review for electrical circuit packages. Based on discussions with H. P. Foley document review analys s, there was not a substantial change from the reviews done prior to the <

issuance of QAI-3, Rev. 1 and the review now specified in iev. 1.

5. In discussions with the H. P. Foley Document Turnover Supervisor and in the inter-office ceco from J. Thompson to G. Boling, dated July 29, 1983, the document turnover review was to include a review for inspector certification fdisciplinetoperform inspections and that these reviews would be performed during the

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Phase II document reviews. E. P. Foley instructions do not l

identify this review as a Phase II review criteria. Based on

' discussions with H. P. Foley personnel, the inclusion of the review for inspector certification during Phase II will be specifically addressed in the document review instructions.  ;

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6. These does not exist PG&E or H. P. Foley instructions on the review of non-work related documents such as, welder or inspector .

I qualifications, calibration records, procedures, specifications, quality manuals, or QA audits.

7. QAI-1 and 2 refer to checklists which are comple'ted by the TA-c document analyst to record the attributes reviewed and 4e-acceptability of the document in the Phase II document review

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process. During the NRC review, it was noted that not all attributes were being fully reviewed (civil and mechanical documentation checklischandinthosecasescommentswere ,

provided by the document reviewer. Since some attributes did not properly reflect what was actually being reviewed (civil and mechanical checklist items I.D. II.B. III. A), comments had to be made. However, since the com=ents are the same for each package k the civil and mechanical areas, a ' general fevision being review,in of the checklists would simplify and clarify the acceptability of the documentation package. Based on discussions with H. P. Foley personnel, changes to the documentation checklists would be made to reflect the documentation review actually being performed.

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8. It was noted during the NRC inspection that the H. P. Foley document analysts were not allowed personal copies of their review instructions (QAI-1, 2, 3). Instead, copies were available for

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reference only nearby. This was done in order to maintain control j

over the number of copies made of the instructions during a time when the instructions were being changed or being tested.

However, since the instructions have been in use for a reasonable period of ti,me and the document review group is relatively small in number (13 document analysts), personal copies of these instructions will be made available to the document

> reviewers upon request. This is based on discussions with H. P. Foley personnel.

i 9.

Guidance on what materials are considered "gff-the-[helf

[ommercial[rade" is given in a letter from D. Rockwell, PG&E to However, it was F. Bourque, H. P. Foley, dated June 22, 1983.

identified by the NRC inspector that document analysts reviewing Based on Class I purchase orders were unaware of this letter.

discussions with H. P. Foley personnel, this letter will be .

In addition, a definition of provided to the document analysts.

"commerical quality" is given in Appendix A to H. P. Foley 31, 1983.

procedure QCP-2, Rev. 7, dated October

10. The H. P. Foley inter-of fice memo from L. Wilson to J. Thompson, dated October 17, 1983, regarding " mechanical signatures" states that as provided in Section 1-201(39) of the Uniform Commercial Code, "It is H. P. Foley's contention that any docu=ent bearing a manufacturer, vendor or supplier's na=e or symbol (logo) will be

considered signed." A broad interpretation of the inter-office memo could lead to the conclusion that any unsigned documents on Although this company letterhead will be considered signed.

interpretation was not the intent of the inter-of fice memo, the

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broad interpretation cannot be eliminated. -[:!cci

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Staff Position _ ,

1. The PG&E position on H. P. Foley quality records generated prior to September 1981 is provided in the transcripts of the onsite 17, 1984. It is the PG&E meeting between NRC and PG&E on January position that no additional reviews are necessary of the l

Additional NRC review pre-September 1981 H. P. Foley records.

regarding the quality of the pre-September 1981 records is necessary in conjunction with the evidence presented above.

2. (Document control is addressed in a separate section]

(PG&E and H. P. Foley)

3. There appears to be a lack of management h d ew : s / ~ b s u. ,

PG&E has control over the H. P. Foley document review process. g not defined to H. P. Foley, the specife quality records required by PG&E and H. P. Foley has not established a procedure which satisfies the H. P. Foley QA Manual for the safekeeping, The H. P. Foley processing, and turnover of quality records.

reviews are controlled by Quality Assurance Instructions which are not reviewed or approved by PG&E.

Inaddition,theQuality[

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Assuranc'e Instructions are deficient in not reflecting the actual document reviews being performed.

The instance of performing documentation turnover reviews without an approved procedure is an apparent violation of Appendix B, Criterion XVII and the H. P. Foley QA Manual,Section XVII, Rev. 9.

Action Required

t. Additional NRC review of pre-September 1981 quality records of H. P. Foley. m e. e y'.~

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,:3 Task: Allegation or Concern No.

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.i ATS No._  !!

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• ' I Characterization ,

H. P. Foley has procurred Class I materials and equipment from unqualified suppliers and these materials have been used or installed in Class I applications.

Ieplied Significance to Plant Design, Construction or Operation The use or installation of caterials or equipment by unqualified

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suppliers leads to the question of whether the supplied materials or equipment have been properly qualified in accordance with 10 CFR 50 Appendix B and site specifications.

Assessment of Safety Significance g (A/e # '

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[ Material supplied by PG&E/Foley has not yet been reviewed; PG&E to provide additional summary writeup on the status of this issue] )

A preliminary review of this issue indicates that: (1) H. P. Foley did not follow specification h802$ in that caterial had been procured from suppliersthat were not evaluated or qualified in accordance with T>

(2)

PG&E did not revise specification (f e }-to reflect ASNI N45.2.13 a change in the vendor qualification process which provided that PG&E would evaluate and quality suppliers, (3) onsite lists orovided to .-Q

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H. P. Foley of a .alified vendors did not match the lists maintained by PG&E, This issue appears to be a generic problem for this site and has been identified in 3 PG&E NCR's, No. DCo-83-SC-N003, dated April 21, 1983,

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• An ~ NO 31, A*N No. DCO-83-SC-N007, dated June 10, 1983, and No. _

g These three NCR's cover the procurement of Class I material by unqualified suppliers for PG&E purchases (DCO-83-SC-N003), contractor purchases by H. P. Foley and Pullman Power Products (DCO-83-SC-N007),

and PG&E NPO purchases (DCO _

• ).

The corrective actions for NCR DCO-83-SC-N007 regarding H. P. Foley purchases were reviewed. The letter f rom D. Rockwell, PG&E to D.

Bourque, H. P. Foley and P. Stieger, Pullman Power, dated August 22, 1983, requested a 100 review of Class I purchase orders initiated by the two contractors to be performed to determine if all suppliers were ,

qualified for those purchases requiring a qualified supplier. The list of "all such Class I purchase orders" was to be submitted by September 6,1983. Based on discussions with PG&E personnel (J.

Bratton, QC) it appears that a list was provided, but was subsequently lost on transmittal to PG&E offices in San Francisco. Approxmiately in mid-December 1983, it was finally realized that the list was indeed lostandH.P.Foleywasagainregejstedtoprovidethelist. However, no duplicate copies of the list could be found and a list provided by H. P. Foley of qualified suppliers on approximately Janauary 4,1984, did not provide the necessary information. As of this date (1/19/84)

PG&E has not yet formally infor=ed H. P. Foley of the information that

is required'by PG&E. It appears that no real steps towards resolution of this issue for H. P. Foley purchases has occurred since NCR-DCO-83-SC-N007 was initiated on June 10, 1983.

The seven month delay in pursuing any meaningful recolution of this issue for H. P. Foley purchases appears to be indicative of a failure to take timely and effective corrective actions. This appears to be contrary to the PG&E A Manual Procedure 10.1, Rev. O, dated February 9, 1981. Section .1 and 10 CFR 50 Appendix B, Criterion 16 for prompt identification, documentation, evaluation, resolution, and corrective action to prevent recurrence. .

Staff Position (Undetermined based on insuf ficient review of. material) - Concern on the lack of prompt corrective actions in the case of H. P. Foley.

1ction

\ Required

1. NRC needs to review PG&E/Foley/ Pullman procurement listing to determine root causes of the purchasing from unqualified suppliers.

2. NRC needs to review the corrective actions taken by -

PG&E/Foley/ Pullman for resolution of all three NCR's.

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