ML20209D399

Nuclear Safety Review Staff Rept, Followup Review of Quality Engineering Branch Records Investigation I-83-13-NPS

ML20209D399
Person / Time
Site:	Sequoyah
Issue date:	04/15/1985
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20209B481	List: ML20209B478 ML20209D185 ML20209D213 ML20209D369 ML20209D399 ML20209D487 ML20209D608 ML20209D651 ML20209D725 ML20209D776 ML20209D846 ML20209D901 ML20209D944 ML20209D976 ML20209E026 ML20209E079 ML20209E115 ML20209E150 ML20209E229 ML20209E290
References
R-85-07-NPS, R-85-7-NPS, NUDOCS 8702040473
Download: ML20209D399 (17)

Text

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l TENNESSEE VALLEY AUTHORITT NUCLEAR SATETY REVIEW STATT pi a

REPORT NO. R-85-07-NPS l

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SUBJECT:

FOLI4W-UP REVIEW OT QEB RECORDS INVESTICATION 1-83-13-NPS DATES OT REVIEV:

MARCH 18, 1985 - APRIL 15, 1985 N

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TEAM LEADER:

R. D. Stil1H DAIE 4

M TEAM HEMBER:

DATE R. C. CUISilAW N

O DAIE H. S. KIDD O

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0702040473 070129 PDR ADOCK 05000327 P

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TABLE OF CONTENTS s.

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1. Background.

2 i

11. Scope 2

l' III. Conclusions /Recounsendations 2

of Previously Identified Open Items........

l IV. Status 5

V. Details,.

5 A.

Corrective Action Management 6

l l

B.

Quality Engineering Branch 7

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M C.

Sequoyah Nuclear Plant 8

I Watts Bar Nuclear Plant i

D.

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E.

Vendor Manuals 9

4 V. Personnel Contacted l

10 VI. References.

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1. BACKGROUND Y;Y

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I The original ' Nuclear Safety Review St'aif (NSRS) investigation b!

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I I ' g',J 4' I-83-13-NPS ' found, that' vendor records assembled by the Quality

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Insineering Branch (QEB) were not being transmitted and incorporated p

into.the ' construction records for Sequoyah Nuclear Plant (SQN) as required by TVA procedures. It futher found that construction records

'8Q 2,.

sesociated.jwith-QEB source inspected procurements filmed and trans-(NUC PR) at SQN, were not mitted"to.ithe !Of fice of Nuclear Power f

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indexed to a flevel-sufficent to allow easy retrieval, and the com-

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1 pleteness.of records at both SQN construction and QEB was in question.

As the organizations involved in the collection, transfer, and receipt it was of the records exhibited interf acing problems at that time, recommended that, an interdivisional task force reporting to the Assistant General tianager (AGM) (Technical) be formed to correct the problems. identified and establish an effective records system.

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The implementation 'of the above recommendation was delegated to the

' ')l Design and Construction, further delegated tianager of" Engineering jointly to the Project fianagers for Bellefonte Nuclear Plant (BLN) and

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Watta Bar' Nuclear Plant (WBN) who established a task force chaired by l

T Through the efforts of that the Assistant tianager of Construction.

task force,' which was in existence between December 1983 and ' April

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1984,' considerable progress was made toward improving interdivision I consunications and the improvement of a records maintenance and e

N retrieval systes., '

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Of significance, the task force brought about a change in the require-meat that QEB, records be incorporated idto construction records and NUC PR identified those records it t transferred to NUC PR in total.

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'g required at the site for'immediate access (e.g., construction records),

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et those that could be retrieved within a few days and loested elsevbere o

within TVA (e.g. ' QF.B records), and those that could be forwarded to a Tederal records. repository (e.g.' vendor radiographs). Organizational ;(

assignments were made within the task force to effectuate the changes J,l O

t, in record locations and esse of retrievability,. procedures were pre-Unfortunately, the corrective o

pared,' and the task force disbanded.

actions were not totally effective.

o e.-

Since, disbandment'of the task force, individual organizational efforts l

were " underway b to' implement their assignments, and improvements in i

recorde *,wre.'seen by NSRS during this follow-up review; however, i t

i records retrieval systems were not yet complete. QE8 records for SQN NSS5f and' principal piping' contracts remained unverified for coeplete ',

Information: retrieval continues :

ness' and' lacked easy retrievabiltiy.

tin very dependent upon thd memories of people at SQN, VBN, and QE8' open items lef t by the task force were being followed as an ancillary d

function of the Office of Construction (OC) Quality Assurance Branch Itanagement" oversight of'.all individual efforts was not seen.'

(QAB).

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11. SCOPE j

The NSRS conducted a follow-up corrective action review of the fin associated with NSRS report 1-83-13-NP3.

(OE),

This review covered the activities of the Of fice of Engineering Ings and ' recommendations d

OC, and NUC PR regarding the accumulation, storage, transferring, an i h pro-retrievability of vendor and construction records connected w t

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curements requiring QEB source inspection.

This follow-up review i

included discussions with personnel and the review of selected recor at SQN, WBN, and QEB.

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III. CONCLUSIONS / RECOMMENDATIONS R-85-07-NPS-01, Manetter of Power and Engineering Appointment of a 8

Records Manager j

l Conclusion

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no upper management coordination entity was Throughout this review to resolve programmatic problems or to It appears that.

focal point for completion. during the task identified as a 4

establish priorities and schedules involvement that was present It m

force era has been lost through reorganizations and retirements.

the upper management i

nd,to is essential that tupper management:become involved once ass n a l

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lume o f -

lC continue' its involvement until such time as TVA's tremen ous vot system P

old vendor' records are in retrievable erder and.the presenappropriate'. rec placing ' neW'*vsaddr* records intoUthe'gsystem i

N detetts).

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Recomendation-It is recoueended that the Hansger of Fover and Engineering a anthority, and g

upper-level manager impowered with the responsibility,iated with the l

organizationg1 freedom to assure that records assoc 3

i t and.

procurement ~ and installation of QEB source inspected equ pm indexed, and l

c assembled, i verified for completeness, and future users of those i

materials ~are stored.for retrievability by ' present d future QEB O

records. ' That spointee's scope should include all past an d the establish-source inspected procurements for SQN, VBN, and BLN an f

U ment.of..,a schedu.,le fo.r co.op19 tion of.past records.

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IV. STATUS O.f FREVIOUS!.T IDENTIFIED OPEN ITEMS i l)

The memorandum transmitting report I-83-18 NPS to the ACH l

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l contained one broad recommendation.

reconmendation has l

each of the issues still requiring action, thatbeen div 4

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p.t Examine Findinas of NSRS Report (I-83-13-NFS?

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I-83-13-NPS-01, A.

and Take Necessary Steps to Identify Actions Required By the Line e

l Organizations (POWER. OEDC. OQA and OGit) tot Develop an Intearated Records System for QA Records that

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Will 8atisfy the Needs of NUC PR and OEDC NUC PR has identified the records required and subdivided them into three categories.

Those subdivisions are docu-mented in procedures and supplemented by memorandum for site-specific construction records. Assignments for records g

Records inden-responsibility have been made by procedure.

ing procedures have been prepared and are in various stages of implementation. A TVA task force was working on vendor manuals. This item will remain open untti the conclusions of the vendor manual task force have and reconusendations r

been evaluated by NSRS and more experience is gained by the Office of Power and Engineering (F&E) with the records indesing system.

(See sections V.A and V.E for details.)

Correct Implementina Deficiencies Identified in the 2.

j-g Laistina System i-Most of the major problems were found in this area.

e QE8 records were not adegustley indexed and there was a.

some concern regarding their cospleteness.

Efforts N

into the were under way to place completed contracts indexing format and have them filmed by established The.'moreivoluminobs -NSSS and principal piping-q*

RINS.

for' f

contracts!' were, still.'iunorganized and unverifled j

o completeness.

QE8 stated they would receive the highest future priority however, no schedule for com-pletion had been developed.

(See section V.B for 3

details.)

A11Sconstructioif' records $ forcSQM had been transferred 0

b.

A Records or >were, in..the., finst. stages Pof. filming.

Retrieval Indexing (RRI), system was prepared but, judged o

not. totally' ef fective'.because. It did' pot preclude the

?',,,L nee <1.t,o, rely..uponyi.tonellerge extenti the memo P

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,... : '.' key.. individuals

' for7 details.)

Construction records for WBN were being identified for

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transfer to NUC PR. An RR1 had been prepared and coe-l.

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munications between OE and NUC PR st VBN regarding active.

The mechanism f o r t'

records and indexing was selecting OC records systems for transfer, estab!!shing 8

less transfer priority, and records acceptability was formal than it should be to be ef f ective.

Records requested during this review were retrievable but this was dependent upon people's memories.

The level of p

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', indexing and cross reference espability described for the records when ultimately transferred to NUC PR

, should. reduce the people dependency and provide a very

'; usable set of construction records.

(See saction V.D

. Ior, details.). -

,d.'

Continued upper management coordination involvement at level capable of crossing organizational boundaries a

. is considered necessary until the problems are solved and records systems prove effective. This item remaina 5

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open. * (See section V.A for details.)

3.

. Provide Documentation Records to Each of the Operating

. Sites as Required by NRC Requirements and TVA Commitments

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QEB records are no longer required to be onsite. TVA proce-F dures and the Topical Report have been changed to reflect J. m that change.

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t An NCR (GEN QEB 8401) was written for VBN and B1JI identify-(

g ing noncomplisace with 10 CFR 50 Appendix B, criterion XVII,

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and ANSI N45.2.9 regarding QEB records' indexing and retriev-r!

,N ability.' NSRS found the specified corrective actions for

o that NCR had been accomplished.

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N Procedures exist to accomplish the transfer of records to

• I SQN.

These records are now or soon will be transferred.

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The retrievability of records is the subject of item V.A.2 above and will be followed and res'olved through activities

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associated with that item.

This item is closed.

(See r

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section V.B for details.)

4.

Clarify Ormentra*. tonal Responsibilities

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O With the exception of a clearly defined system for vendor i

manuals, organizational responsibilities have teen defined.

O This ites remains open pending the resolution of the vendor O

manual issue.' (See section V.E for details.)

e B.

I-83-13 NPS 02, Report Back to the OCH on the Planned Actions and t

ScheduleforCoe61etionofActions reports' were made by the Manager of OEDC to the ACH s

Two l f (Technical) regarding the implementation plans and schedules of g

OEDC and NUC FR.

The plans were predominately p'rocedural in nature and the schedules indicated when the revisions were to be The corrective action was less than adequate in that coepleted.

no schedule was provided that established when the records thee-i seless would be verified as complete and indexed for retriev-ability. At the time of this review the OC records traorfer for essentially coeplete and, therefore, no sch:dule is SQN was required. VBH by procedure has until six months af ter consercial 4

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operation of unit 2 to transfer records; however, a shorter time-

frame'is preferable by NSRS for those records systems that reach '

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i completion.. ' QEB, however, has not i:ompleted verification and c

. indexing of their records for SQM and WBN nor has QEB estabitsbed

. a schedule for doing so.' This ites remains opea. (See section V.B for, details.)

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DETAILS.!,:.

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A.

Corrective Action Management 1!$

I the origtnal investigation found interface problems between

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. 0E, OC, and N1]C PR impacting their assigned responsibliities, it

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was recommended that an upper management task force capable of

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' crossing divisional' boundaries be established to further quantify and solve problems identified in NSRS report I-83-13-NFS.

It was further ' recommended that the task force report. to the AQt (Technical).! Through a series of delegations a task force or

, committee was established under the chairmanship of the Assistant task force reporting to the c

• Manager of. Construction with the g

Project: Managers for VBN and BLN.

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Representation on the task force included a good cross section of y

,9 personnel froe OC and NUC PR and included representation for

'O office,of Quality Assurance (0QA) and periodically QEB.

g Through that task force NUC PR developed a three level system of records which was incorporated into procedure ID-QAP-11.1 and formed he basis for dividing records responsibilities.

QEB N

would retain, be responsbile for, and retrieve information froe Construc-O

. vendor records under their source inspection program.

tion:would assume respo.sibility for construction records asso-cisted with vendor products after the items were released for o

i shipos.at by,QEB.

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,,*In" addition,' the task force developed an indesing system for 4

O records to be transferred to NUC PR by each project office. That '

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indexing isystem was called.RRI, and generically procedura11:ed O

with input ' from both OE and NUC PR in OC QAF 17.2, " Records P,jRetrievalInstructions." Each project (SQN, VBN, and BLN) was to p* . l

'l't.. develop *' their own site-specific RRI.

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'!!;In' April 1984, the task force held its last meeting thus ternt-et:s, <: > -

existence.

On June 8, 1984, by scoorsadua, the

', b' nating its., Froject Hansgers for VBN and BLN requested the Hanager of F&

reassign responsibility for follow-up of R-83-13 NFS findings to OE.

The Manager of F&E did not concur in the transfer and further upper management involvement in this. issue could not be,

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identified.

Since there use no further upper management atten-tion given this project, LUsppears that schedules for coepletion of - QEB# records, ansvers.to programmatic prchless, and follow up

. of: taskiforce open itees '(which, vere being, tracked 'as an sec11-

" lary,'. function by the'0C QAB) remain unaddressed.

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i Vith reorganisations ; and retirements, the initially involved.

y upper management personnel are no longer in positions to assume responsibility of this important task.

While the Project Managers for VBN and BLN are still concerned and involved with

,14 the records associated with QEB source inspected vendors as they

, ' ')'

i pertain to their ' projects, their positions do not cover the entire OE, involvement in all nuclear plants. It would be appro-l priate to reassign'the overall responsibility of vendor records

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to a manager' organizationally capable of assuring that the

,j efforts of OE,.0C,"and NUC PR are coordinated and accomplished I

both., timely and effectively.

L B.

Quality Enaineerina Branch 1

Based on NSRS report 1-83-13-NFS a generic NCR (NCR GEN QEB 8t.ot)i was written stating QEB vendor records were not easily retriev-i able and that records were not transferred to the designated permanent storage location., The corrective actions specified for

'l that NCR.were accomplished, namely, procedares developed, people Q

, trained,tand permanent storage lecations redefined. Bowever, the i

O' ' j original problem regarding retrievablity was not solved.

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<. :, r s i. term their needs and

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,.QEB developed _an indexing systes suitable to it in QEB-EP 24.7.

Work began on processing approxi-defined,650 f t i.

e-3 mately of compl ted nuclear contract records in J

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!! arch 1984. A goal of 5 ft per week was established and highest priority placed upon SQN and VBN records. QEB employees were brought in from the field offices to assist in the effort.

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At the time of this review QEB had processed 126 f t of records

. O through February 28 1985 reflecting a processing rate of approximately 12.5 f t3. per, week.

Of those processed arproxi-l mately 37 percent' were for SqN and WBN, 28 percent for BrN and BIJE wit 4 the remaining 45 percent of the processing effort going.

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, toward records of deferred or cancell'ed nuclest pisate and fossil

• iplants.h 'While the' statistics show original goals and priorities o

, were/ not being met,' progress.was being made.

Two of the five QE5 ' sections' have 4 completed almost all of their records, one O

J 1 sectionj has' its records in order in hard copy, and another is Of con--

/... *,I piscing.ita priorities,primarily in the VBN, SQN area.f cgrit.toL j,

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.I I A forJ84N;and VBN whichchave not been. worked on since the original' i.

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!' NSR5 7tiaTe'stigation. '.1 QEB sanagement stated that increased

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hprioritywouldbe'placeduponthosecontractsandanewaddition

.i to the QE8 Enoxville. staff was coming from a field office to help i,

i

1. in that arse.r. i A-3 Reasons were given as to why the processing rate was not 5 f t per week (e.g., ) lack of personnel, other priority work, RItiS not i

able to keep up : however, no information was found that indi-cated OE management was avere that QEB precessing (verification

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of record completeness, indexing, and entering into R1HS) would

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'ATTACIDiENT E Page 9 of 16

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take twice as long as anticipated (i.e., four to five years) or that they concurred in the increased time. The original estimate Placed the processing ef fort at about two years excluding any.

j increase in the number of completed contracts.

In addition, there was no TVA upper management of ficial (discussed in section V.A above) to oversee progress or provide added impetus.

To evaluate the retrievability of records by QE8 for SQN, QE8 was requested to produce manufacturing data for a flow element in the unit I reactor coolant system. That information was produced in I

about two working days and, considering the type of information requested and nature of the request, NSR3 considers retrieval of that information to be outstanding. tlafortunatelyr;the retrieval of that'information:wse.not.due to the QEB'tecords' retrieval sys' t.es.. ":Itivas 'r'e't'rieved ' based'upon'what: people r(both present and former.,TyA.eeployees)eresembered. :That' exercise, highlights.three points k(g(,the, records t aref. currently retrievable but dependent:

6p"6Ge31eg. 2f p' coy 1FIshould"not' be ' considered 'a'd intes'ral part

• 'a'nd (3).' the" development ' of a retrieval' oE~a?Httleval+diffl'cdtt.

systees%111:be' pystee,-

o f9 Considering all the above, QE8 should take steps to assure that the NSSS and principal piping contracts are verified, indexed for

,p retrievability, and stored (either hard copy or RIHS) as soon as is reasonably possible to produce a quality, usable end product.

N C.

Sequoyah Nuclear plant M

OC at SQN had completed processing a'11 of its records. The gen-eral records (training, certification, etc.), had not been pro-y*

cessed at the time of the original investigation.

Since that investigation, the SQN RAI was developed and the general records r.

were indexed to it.

The records previously fileed on plant sys-3 tems remained as they were found during the original investiga-tion with some additional indexing.

g An 'RRI.had~been ' prepared.tonenhance NUC PR retrieval of OC records.s 11t/ was ' reviewed by NSRS J and' judged to be a good

- 3 description of the records available, but of;little value in locating;the records. Various pieces of equipment were selected by ' MSRS to demonstrate their records retrievability, it was

' found that recorda retrieval was dependent upon the collective memory of four individuals, a lot of searching, and not the retrieval system. Two of thoJe people were NUC If esployees and two were OC employees that would not have their present jobs in the near future.

It is understood that since SQN plant systems records have already been flined and the hard copy records destroyed, the task of developing or retrofitting an indesing 8

system is entremely difficult and in some cases' may not be justiftsble, llowever, the future usability of those records is dependent upon just such an effort (probably in scee cases a manual indesing on a f rame by-f rame bests). As SqN is down to four knowledgeable individuals, it appears leperative that addi-tional personnel resources be devoted to the indexing ef f ort.

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Ih The system for, vendor manuals was reviewed and found to be in

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good condition.i The manuals were inde.xed, systematically revised,

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and controlled.i A question was raised by NSRS regarding whether or not any of the manuals were considered one of a kind, and

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therefore, in.need of, fire proef storage. SQN agreed to evaluate q,

that concern.,p

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D.

Watts Bar Nuclear Plant Ir NUC PR and OC personnel at WBN were in the preliminary stages of

,,, I developing a system for the verification of records completeness, i.-

indexing, filming, and ultimate transfu of OC records.

At the time of this review very few records had been filmed and trans-ferred and most of those were being redone based upon the direc-tion given by the task force discussed in section V.A. and the RR1 developed by WBN. The RR1 was understandably not coeplete and will undergo revisions as new systems of records are prepared for transfer; however, the format of what ves prepared appeared descriptive enough to allow retrieval of information cataloged and filed nader that system. Both NUC PR and OC personnel were communicating 'about specific records systems and the level of indexing required. Current plans and enginates include 100 per-3 cent verification of records completeness and coeputer indexing of about three million entries on both document and folder level 3

indexing. One problem identified with the current approach was 4

the apparent informal structure of the transfer process wit.h ressed to identified interfaces, priority for transfers, and for-mal acceptance of the records for completeness, readsbility, and retrievability by NUC PR.

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At present, through NSRS requested OC documents on QEB source h

inspected contracts, the records retrieval systes at VBN con-h struction was determined to be very people dependent. All docu-ti mentation.reguested was found indicgting the required documenta-t 3

tion was onsite.i Based upon the future level of indexing in the

' ', 'j RIMS system, people dependency should be greatly reduced and time 3

for retrievability enhanced.

3 Vendor manuals were controlled very well. They were adequately indemed and revised.

• One problem regarding the lack of as built 7

drawingsifor the solid state reactor protection systen had been identified and'was in the correction process. No other vendor manual ' problema ' had been identified.

One enhancement to the vendor manual maintenance program was the identification of those plant procedures wherein the manual was referenced in the front of a manual. ' The supervison of document control and vendor manuale section identified several areas where the section was trying to improve its progrees.

E.

Vendor Manuals The currently appitcable procedures for OE, OC, and NUC TR vendor nanual control were reviewed. They were found to be selectively vague in that implied responsibilities rather than specific 8

'I responsiblities were assigned to each organization to perforu the same functions.

As a result it was unclear as to which organisation actually maintained control over vendor manuals.

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A task force was developing a new procedure regarding the main-tenance, of, vender manuals which should correct that problem.

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FEAS010fEL CONTACTED 3

A.

Office of Nuclear Power i

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l C. Cannon Records Officer, Document Control Unit N. H. McGuire QA Analyst, Quality Frojects Staf f 2.

' S.qN, j

R. C. Birchell Compliance Engineer D. L. Cowart Quality Surveillance Supervisor Y

J. R. Crisp Administrative Services Supervisor I

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. I.:H..Kabiti

' Support Services Supervisor f

G. 3. Kirk Compliance Supervisor pg D. 0.' Lockmiller Document Control Clerk

8. B. Hiller Regulatory Engineering y

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.O L. H. Nobles O&E Superintendent

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N P. R. Wallace Plant

• Manager N. H. Welch Information Systems Specialist j

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R. J. Blevins, Jr. Information Systems Specialist b

R. T. Chattin Administrative Services Supervisor i

R. L.

Drawing Unit Supervisor I

I, R..g.,; Eestherly Sauer

' Compliance Section Supervisor

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' ". B. 8.. W1111s i

O&E Superintendent 3

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8. ' Office of Engineering O

P. D.' Anderson' Document Clerk, QE8 Assistant Dhiston Hansger

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P.1 H.! D." Conne r "

.:7 Materials Engineer, QEB

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!;0..T.'Dilworth

, Director, Division of Engineering and Tec n ca

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• W. C.' Graves Administrative Officer, QEB 4

H. W. Enoa -

Materials Engineer, QE8 e

V. Koger i

Information Systems Specialist, RIMS J. F. Lewis Materists Engineer, QE8 r

C. L. O' Dell Chief, Information Hansgement Systems Staff J. W. Oravits Materists Inspector, QE8 J. L. Farris Chief,QE8 D. E. Seeleer Heterials Engineer, QE8 J. L. Snyder Section Supervisor, QEB J. H. Winebrenner Materists Engineer, QE8 9

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Office of Constructionff,y

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1. I,', Central Office 8.'

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,, ;j, A.'. C.' Kelley

,, Assistant Manager

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,;., J.'T. McGhee

. Unit Supervisor, Quality Assurance Branch

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'4R. A. Pedde Assistant Manager i

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! J. E. Wilkins Retired

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2+ ; 8E.

g D.'A. Bateson Staff Supervisor, Office and Civil l

Engineering Branch N. C. Shivers Engineering Aide, Of fice and Civil Engineering Branch i

3., VBN

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R.1V. Forster Supervisor, Instrument Engineering Unit i,

e'

. '. ' N. 5. Johnson Supervisor, Document control Unit i 6,

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.: 8.*A. Luck

. i. '

Engineering Aide, N5 Unit '

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..,' J.;E. Smith Supervisoe, Document Control Unit

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Office of Quality Assurance

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J. J. Knightly Supervisor, Documentation and Data Management J. A. Mcdonald Chief, Quality Improvement Staff S. L. Patton Records Officer

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VI. REIERENCES.

i O

I NUC Power Procedures

.i I'

39AU.IU QAP 6.2, " Vendor Manual Control," dated December 31, 1984 o

e o.*i 2.

ID QAP 17.1,'" Transfer of Quality Assurance Records," R4, dated

,1 July 10,'1984 o'

3.

NQAM ID QAP 17.1, " Transfer of Quality Assurance Records,"

l dated December 31, 1984 i

g *, j i,;..

f..iw'?q ; y:.4,i r...

.i t'

4.

ID QAP 17.2, " Quality Assurance Records for Design and Construc-I-l.,

tion,",,R1,;datedJune8,,1984 5.

NQAM ID QAP 17.2, " Quality Assurance Records for Design and

• j' Construction,"; dated December 31, 1984 6.

N-0QAM, FART !!!, Section 4.2, " Transfer of QA Records f rom OE I

and OC," dated October 12, 1984 7.

. VBM Administrative Services Instruction Letter D-18. " Retrieval of ASME Code Documents," dated January 9,1985 i

i 10 l

aE

_21 h I [k &_

.h n1Z E.,,,~.-

2,,,,,,,_

m

.a

8.

WBN'Adelaistrative Instruction 4.1, " Interface Responsibilities,"

$ N.0 I',I

',5?h; p

A9 6'g;,.;s,m ' '.

l, i.

,- t

.d Entineerina Procedures

.,, f ;

g 1.

QEB-EP' 24.37,"Produ:t Compliance Data and Quality Engineering th !

Records.- Processing and Disposal," dated January 22, 1982 i-2.

QEB-EP. 24.58, " dandling of Supplier Records," dated February 9,1979 b 6 ',; 6 -

n t;

s.

,q,,'. f.

Construction Procedures 1.

OC QAP,6.2, " Vendor Manual Control," dated September 3,1985 2.

OC QAP 17 " Quality Assurance Records," R3, dated October 1, 1984 j

/

3.

OC QAP 17.1, " Quality Assurance Records," RIO, dated October 1, 1984 I

4.

OC QAP 17.2, Records Retrieval Instructions," R1, dated October 1,

.]

f 1984.

i 5.

VBN Quality Control Instruction (QCI) 1.08-1, " Records Retrieval,"

so dated May 15, 1984 e

I g

N 6.

VBN QCI 1.40-3, " Universal System Prograa," R2,-dated October 12, 1984 S

Correspondence g

l o

1.

Hemorandus from H. J. Green to Charles Bonine dated August 10,

.i

,. s

.I 1983, "Bellefonte Nuclear Plant - Hierofilming and Cataloging of I

QA Records,", including attachments (DOC 830811 007) r.

Hemoren um f[C. L. O' Dell to Those' listed dated October 4,

.]

t' O

2.

1983,:," Vendor Records,,8tudy Team Heating Notice Third Meetin8" i

h o

e

- tt O

3.

Neoorandus from H. N. Sprouse to G. H. Kimmons dated October 17,

,~

1983, "Draf t Vendor Records Study Team Report" i

., t ' t.,Q."

f:.y'i,'l,'-

4...Hemorandus'from R. H. Pierce and W. R. Brown to Those listed

dated, November 3,1983, " Heating on Vendor Records" (F.DC831103701) q,j' g /,, q' '. '

,.m

. y 3. e.

tb. /:

5.

Mesorandum from J. A. Mcdonald to Those listed dated November 16, 1983,,n" Transmittal of Revision 1 to Quality Problee 83-25" e ;.'

i

'd'b

,s.

'N 6.

Hemorandum from Charles Bonine to L. S. Cox dated November 17, I

1983, " Transfer of WBN and BLN Site QA Records to NUC PR" i

l i

(DOC 83111700,1) i 7.

Memorandum free J. E. Wilkins to Those listed dated December 5, i

1983, " Transfer of Records from Construction to NUC FR" (DOC 831205 003)

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s l

's f e e

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1

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~

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Hemorandum f rom J. E. Wilkins to Those listed dated December 22, 1

8.

1983, " Transfer of Records from Constr,ction to NUC FR*

u (DOC 831212 005) 9.

Memorandum from G. H. Einusons to G. F. Dilworth dated January 5 1984, " Vendor Records - Interim Report," Administrative 1y Confidential

10. Memorandum from W. R. Brown and R. H. Pierce to Those listed dated January 10, 1984, " Vendor Records - Interim Report,"

Administrative 1y Confidental t

11. Memorandum from R. W. Cantrell to V. R. Brown and R. H. Pierce dated January 26, 1984, " Vendor Records - Interim Report,"

Administrative 1y Confidentini

12. Hemorandum from J. E. Wilkins to Those listed dated January 26, 1984, " Transfer of Records from Construction to NUC FR" l;

(DOC 840126 002)

I 10

13. Hemorandum froe Vera Roger to HJDS Tiles dated February 17, 1984, "HEDS-QEB-Supplier Record Files - Heeting Notes" g

(NED 840217 005) i e

14. Letter from NRC Region II (Verre111) to H. G. Parris dated N

March 13, 1984, " Inspection Report, WBN and BLN" (A02 840313 006)

15. Hemorandum from J. E. Wilkins to Those listed dated March 16, 1984, " Transfer of Records from Construction to NUC FR*

g (DOC 840316 006) o

16. Letter fro's L. H. Mills to J. P. O'Reilly, NRC, dated March 29, 1984, "Ratrievability of QA Records, WBN and 8LN" (A27 840329 006)

17. Memorandum from J. R. Lyons to J. E. Wilkins dated May 24, 1984,

" Vendor Records Reguirementa" (0QA 840524 402) o 0

18. Memorandum free J. A. Coffey to C. Bonine dated April 13, 1984,

" Transfer Request for Duration of Construction Records Generated

at SQN"y(DOC 840416 002)

19. Hemorandum from J. E. Wilkins tr. Those listed dated April 13 1984, " Transfer of Records from Construction to NUC PR" (DOC 840413 005) e Hemorandues from J. L. Parris to C. L. O' Dell dated April 16, 20.

1984, " Processing of QEB Suplier Records" (QE8 840416 004)

21. Hemorandum free J. L. Snyder to J. L. Parris dated April 24, 1984, "Honthly Activities" or

22. Hemorandum free John A. Rau1ston to L. H. Hille dated Herch 28, 1984, "VBH and BLN Retrievability of QA Records (NEB 840328 280) st_7 12 E-f.

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;j. es

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Nemorandum free J. P. Darling to V. R. Brown and R. M. Pierce l' k j j

23.

dated May 8,1984, " Vendor Records - Ffp 1 Report Action Item" (EDC440510701)

24. Memorandue from J. R. Lyons to J. E. Vilkins dated May 24, 1984,

'l

" Vendor Records Reguirements" (0QA 840524 402)

, j,.L Memorandum from V. R. Brown and R. M. Pierce to E. G. Parris

j dated June 6, 1984, " Vendor Manuals" (EDC 840607 702) j; 25.

l Memorandum from J. E. Vilkins to Those listed dated June 11, 1984, t-26.

" Transfer of Records free Construction to NUC FR" (Doc 840611 004)

Memorandums free J. L. Parris to J. A. Raulston dated June 25, 1984,

?

27.

"SQN, VBN, BLM - QEB Vendor Records Nonconformance Report" (QEB 840625 003)

Memorandum free James P. Darling to C. Bonine dated June 25, 28.

1984, " Transfer Reguest for Duration of Construction Records 4

Generated at VBN" (L68 840524 823) l

,o Memorsadue from J. L. Snyder to J. L. Partie dated July 3, 1984, b

29.

" Report of Activities" Letter free L. M. Mills to J. P. O'Reilly dated August 1,1984, 30.

g "Retrievability of QA Records" (A27 840801012)

Memorandum free J. L. Parris to Those li,sted dated August 28 31.

1984, "SQN, VBN, BLN - QEB Vendor Records - Nonconformance N

Report" (QEB $40828 005) 13, 1984, Memorandum free 8. A. Burt to Files dated November (VBN 841113 15 32.

"VBN - Microfilming and Indexing of QA Records" 3

19, 1984, O.

Memorandum free 8. A. Burt to Files dated November (VBN 841119 1 33.

3 wygg. Microfilming and Indexing of QA Records" O

14, 1984, Memorandus'fros 8. A. Burt to Files dated December (WBN 841214 O

34.

"VBN,, Microfilming and Indexing of QA Records"

...:s Memorandum from G. Vadevits to C. Bonine dated December 21, 1984, 35.

"VBN

,NRC Rait, Meeting Notes - 390/84-86" (WBN 841221 014) 26, 1984, Memorandum from M. Conner to QEB Files dated February

" Meeting Hinutes - Vendor Information and Configuration Control" 36.

(QEB 850226 001) l Miscellaneous _

Reactor Coolant Loop Data Package on Ites No. 1-068 L227-0002, 1.

flow Transmitter and Associated Assembly (VBN) 1 13 I

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U ATTACIDfENT E Page 16 of 16 I

2.

Data Package on Ites No. TVA MK-68-7. TV!. B/M-47#465-3, Orifice i

t

)

Plate and Transmitter for Unit 1 Reactor Coolant Loop (SQN) i 3.

Informal Note from J. L. Snyder to D. Smith dated March 27, 1985, " Recap of Study on Vendor Records" 4.

Contract Inventory Worksheets from QEB f_

5.

QEB Computer Inventory of Vendor Records Completed i

6.

PRIDE Data Description Form 7.

Miscellaneous Component Records Retrieved upon Investigator Request (SQN)

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ATTACHMENT F NSRS Investigation Report No. 1-86-129-SQN t

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ATTACHMENT F Page 1 of 7 TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT No. I-86-129-SQN EMPLOYEE CONCERN NO. SQP-6-002-001 g

SUBJECT:

SECOND FOLLOW-UP OF QEB RECORDS INVESTIGATION I-83-13-NPS DATES OF INVESTICATION:

February 6-14, 1986 INVESTIGATOR:

W. R. SIMONDS BATE #

REVIEWED BY:

.I 3 Ed j / J. C. CATLIN DATE APPROVED BY:

' M/E M D. STEVENS DATE 0

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TIACHMENT F Page 2 of 7 1.

BACKGROUND A Nuclear Safety Review Staff (NSRS) follow-up corrective action,

investigation was conducted to determine the validity of an expressed employee concern received by Quality Technology Company (QIC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employeo Concern Assignment Request Form from QTC and identified as SQP-6-002-001, stated:

CONCERN: QA Records are not identifiable and retrievable. NSRS Investigation I-83-13-NPS identified problems in 1983 and NSRS Report R-85-07-NPS indicates g

problems not corrected in mid-1985.

OE, OC, and

. Nuclear Power Records are cited.

An NSRS follow-up review of Investigation I-83-13-NPS did find that corrective actions resulting from the original NSRS investigation had not been completely closed out.

The results of that follow-up review are documented in NSRS Report R-85-07-NPS (Ref. 1) along with a recommendation (R-85-07-NPS-01) that the Manager of Power and Engineering appoint a records manager to provide upper management coordination for resolution of the open items which had been identified.

II.

SCOPE A.

The scope of this investigation is defined by the concern of record. It is that problems previously identified by NSRS investigation I-83-13-NPS, and the c6eresponding follow-up review R-85-07-NPS, have not been corrected for Sequoyah Nuclear Plant (SQN).

B.

The scope included determination of status and progre'ss of the open items identified in I-83-13-NPS and R-85-07-NPS as they pertain to SQN.

C.

The scope of the follow-up investigation also included discussions with site and task force personnel who are actively involved in the resolution of these items.

III.

SUMMARY

OF FINDINGS A.

R-85-07-NPS contained recommendation R-85-07-NPS-01 which recommended that Power and Engineering (Nuclear) [P&E (Nuclear))

appoint an upper-level manager empowered with the responsibility, authority, and organizational freedom to assure that records i

associated with the procurement and installation of Quality i

Engineering Branch (QEB) source inspected equipment and materials are assembled, verified for completeness, indexed, and stored for retrievability. The recommendation further stated that the appointee's scope should include all past and future QEB source I

inspected procurements for SQN, as well as Watts Bar and Bellefonte, and the establishment of a schedule for completion of past records.

1 i

b.

. _ -. _ _ _._ _. _, _ -.. _ _ - - -.. _ _ _,., _. _ -,. - ~ _.. _ _ -.. _

d w.: -

ATTACHMENT F' Page 3 of 7 i

P&E (Nuclear) subsequently informed NSRS (Ref. 3) that an appointment had been made, and identified personnel who would provide assistance to the appointee. Following the appointment, meetings of the personnel were held on September 17, 1985, and December 16, 1985, to discuss resolution of the open items These -

identified in NSRS follow-up review Report R-85-07-NPS.

meetings are documented in references 4 and 13 along with specific action. items and schedules for resolution of the problems.

IV.

STATUS OF PREVIOUSLY IDENTIFIED OPEN ITEMS an Integrated Records System for Quality Assurance (OA)

A.

Develop Records That Will Satisfy the Needs of Nuclear Power (NUC PR) and Of fice of Engineering Desitn Construction (OEDC)

Paragraph IV.A.1 of R-85-07-NPS states that a TVA task force 1.

was working on vendor manuals at the time of the first NSRS follow-up review, however, two areas of concern were identified regarding vendor manuals as follows:

A question was raised by NSRS regarding whether any of the a.

in manuals were considered "one-of-a-kind", and therefore, This finding was addressed in need of fireproof storage.

paragraph V.C of the report.

Subsequently, ID-QAP-6.2 (Ref.15) was revised to require that those vendor manuals ut(11 zed as plant instructions will be maintained as QA records. This requirement, in combination with existing requirements of AI-23 (Ref. 16),

appear to establish adequate protection for vendor mcnuals i

for SQN.

The applicable procedures for vendor manual control were b.

found to be vague in the delegation of responsibilities.

A task force was developing a new procedure regarding the maintenance of vendor manuals which was expected to correct This finding was addressed in paragraph V.E the problem.

of the report. Subsequently, ID-QAP-6.2 (Ref.15) was revised to more clearly prescribe organizational responsibilities regarding the control of vendor manuals.

Paragraph IV.A.1 of R-85-07-NPS also states,that records 2.

indexing procedures had been prepared and were in various stages of implementation. It was further stated that this item will remain open until more experience is gained by P&E (Nuclear) with the records indexing system.

~f This matter 14 l

discussed in the following paragraphs.

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c.

ATTACHMENT F Page 4 of 7 Correct Implementinz Deficiencies Identified In the Existint System B.

Paragraph IV.A.2.s of R-85-07-NPS states that QEB records were 1.

not adequately indexed and that there was some concern At the time of the the first regarding their completeness.

NSRS follow-up review, efforts were under way to index and microfilm completed contracts; however, a schedule had not been Initially, a established for completing the overall task.

completion date of December 31, 1987, was set by the P&E for completing the overall task (Nuclear) task force (III.A)However, a recent commitment was for all projects (Ref. 4).

made that appropriate manpower resources will be expended to 1986, will be met for SQN ensure that a deadline of June 30, QEB is utilizing a four-step approach which includes identification, location, verify completeness, and (Ref. 13).

microfilming of the records,(Ref. 4).

Sequoyah has concurred with the parameters that QEB is using to

However, index their records (i.e., vendor / contract number).

site personnel normally must request the records by Unique Therefore,' efforts:are in progress Identifier Number (UNID).

to provide a cross-reference between UNID and ven numbers.

l is being investigated as the link to provide this This item remains open.

cross-reference (Ref. 6 and 13).

Paragraph IV.A.2.b of R-85-07-NPS states that all OC records J

for Sequoyah had been transferred.,or were 3n the final stages i

2.

l of microfilming at the time of the first NSRS follow-up review..

Microfilming of all the records underway at the time of theHowe review have been completed.

contract-related files and various other records were discovered by SQN-DCU personnel in warehouses vacated by OC, in SQN-DCU and addition to severhl flies at other locations.

RIMS-Chattoonga personnel are working to microfilm these additional records and have completed filming about 36 cubic Manual indices will be established for these records pending resolution of problems associated with the Records feet.

' Microfilming is proceeding on an Retrieval Index (RRI) system.

10, 12, 13 and 14).

This "as-soon-as possible" basis (Ref.

item remains open.

I Paragraph IV.A.2.b of R-85-07-NPS also states that a RRI system was prepared but judged to be not totally ef fective at the time 3.

j of the first NSRS follow-up review.

a a

NUC PR personnel subsequently conducted a review of the RRI to 5

identify deficiencies and initiate recommendations to correct The NUC PR review confirmed that any problems (Ref. 4 and 7).

the RRI was deficient in several areas and recommendation made to identify all OC record types and develop detailed instructions for the retrieval of each record.

3..

--. n

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- e, ATTACHMENT F Page 5 of 7 The P&E.(Nuclear) task force (III.A) established to resolve the

.open items of R-85-07-NPS has taken the recommendations under consideration and has acted to establish a sub-task group to

" rework the SQN RRI using original RRI guidelines" (Ref. 13).,

The chairman of the sub-tesk group has met with cognizant

)

personnel and is proceeding with efforts to rework the RRI.

A date for completion of the task has not been set.

This item remains open.

Paragraph IV.A.2.d states that continued upper management 4.

coordination involvement at a level capable of crossing I

organization boundaries is considered necessary until the problems are solved and records systems prove effective.

This matter appears to have been adequately addressed by P&E (Nuclese) through actions discussed in paragraph III.A above.

C.

Clarify Ormanizational Responsibilities Paragraph IV.A.4 states that with the exception of a. clearly defined system for vendor manuals, organizational responsibilities have been defined. Subsequent revision of ID-QAP-6.2 (Ref. 15) appears to adequately prescribe responsibilities for vendor manual control as discussed in paragraph IV.A.1.b above.

Planned Actions _and Schedules for_ Completion of Action D.

Paragraph IV.B of R-85-07-NPS states that QEB had not completed verification and indexing of their records for SQN nor had QEB est:511shed a schedule for doing so at the tims of the first NSRS follow-up review. Actiuns taken on this matter are discussed in paragraph IV.B.1 above.

V.

CONCLUSIONS AND RECOMMENDATIONS A.

Conclusion I

l The employee concern is substantiated in that corrective action items shown in NSRS investigation I-83-13-NPS have not been completed for SQN. However, specific improvements have been achieved regarding vendor manuals, and work is steadily progressing toward the resolution of sthe remaining open items' identified by j

NSRS.

i B.

Recommendation I-86-129-SQN-01, Continue Monitoring NSRS should continue to monitor the status of open items from 1

I-83-13-NPS as they pertain to SQN.

[P3]

a 8

ATTACKHENT F Page 6 of 7 DOCUMENTS REVIEWED IN INVESTIGATION NO. I-86-129-SQN AND REFERENCES Informal Memorandum from K. W. Whitt to H. C. Parris, " Follow-up Review of 1.

Quality Engineering Branch (QEB) Records Investigation I-83-13-NPS -

Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS " dated

~

May 28, 1985 (A02 850529 010)

Memorandum from H. G. Parris to K. W. Whitt " Follow-up Review of Quality 2.

Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NFS," dated July 1, g

1985 (L16 850624 840)

Memorandum from H. C. Parris to K. W. Whitt, " Follow-up Review of Quality 3.

Engineering Branch (QEB) Records Investigation I-83-13-NPS - Nuclear Safety Review Staff (NSRS) Report No. R-85-07-NPS " dated August 14, 1985 (L16 850729 883)

Memorandum from R. A. Pedde to Files,NSRS Report R-85-07-NPS - Follow-up 4.

Review of QEB Records Investigation - I-R3-13-NPS." dated September 19, 1985 (Col 850919 004)

Memorandum from M. M. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS,"

5.

dated September 24, 1985 (L16 850924 833)

Memorandum from M. M. McGuire to R. A. Pedde, "NSRS Report R-85-07-NPS,"

6.

dated October 29, 1985 (L16 851029 887)

Memorandum f rom M. W. Hadacek to M. M. McGuire, "NSRS Report R-85-07-NPS,"

7.

dated November 13, 1985-(L16 851113 895)

Memorandum from R. D. Guthrey to James P. Darling, " Configuration Task 8.

Force - Activity Summary and General Assessment," dated August 8, 1985 (R25 850808 861)

Informal note f rom J. P. Vineyard to C. L. O' Dell regarding transfer of OC 9.

l

' records to NUC PR, dated June 28, 1985 (B25 850628 002)

Memorandum f rom Alva LaMontagne to Nancy Welch, " Office of Construction l

10.

1985 (A31 (OC) - Sequoyah (SEQ) Site Records," dated September 24, 850925 001)

Memorandum from M. M. McGuire to R. A. Pedde, " Action Item 9-17-3 of NSRS 11.

Report No. R-85-07-NPS," dated November 21, 1985 (L16 851121 802)

Memorandum from Alva LaMontagne to John Ed Hayes, " Microfilming Sequofah 12.

Construction Records," dated January 8,1986 (A31860108 051) l l

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Memorandum from H. A. Pedde to Files, "NSRS Report R-85-07-NPS - Follow-up.

13.

Review of QEB Records Investigation - I-83-13-NPS," dated January 9, 1986 (Col 860109 003)

Memorandum from Alva LaMontagne to Nancy Welch, " Office of Construction 14.

22, 1986 (OC) - Sequoyah (SEQ) Site Contract Records," dated January (A31 860122 051)

NUC PR Nuclear Quality Assurance Manual (NQAH), Part V Section 6.2 15.

(ID-QAP-6.2)," "Vendar Manual control," revision dated December 31, 1985 g-Sequoyah Instruction AI-23. " Vendor Manual Control," R21 16.

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