ML20215H903
| ML20215H903 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, 05000000 |
| Issue date: | 10/27/1983 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Gilinsky, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML20213D283 | List: |
| References | |
| FOIA-84-21, TASK-AS, TASK-BN83-164 BN-83-164, NUDOCS 8705070140 | |
| Download: ML20215H903 (35) | |
Text
._.
Q bin
+IC, kit'd *h 4-ga w. ft. syw, q
$ n, s(*W
/
UNITED STATES Q,
m f
~,.
NUCLEAR REGULATORY COMMISSION
]
j WASHIseGTON. O. C. 206S4 OCT 2 7 883 r
b' 50-275/323 l
p C
MEMORANDUM FOR: Chaiman Palladino Ml* {f Commissioner Gilt:.:ky iY l
Commissioner Roberts Commissioner Asselstine Commissioner Bernthal FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
ALLEGATIONS CONCERNING DIABLO CANYON (BOARD NOTIFICATION NO.83-164)
In accordance with the procedures for Board Notification, the following infomation is being provided directly to the Commission.
{
Memorandum from T. W. Bishop (NRC) to D. G. Eisenhut (NRC),
" Recommendation for Diablo Canyon Board Notification
\\'
.re'garding allegations received October 19,1983", dated October 21, 1983.
The memorandum (Enclosure 1) transmits allegations (Enclosure 2) regarding certain QA/QC activities at Diablo Canyon. The scurce of these allegations is presently being treated as confidential and further staff action is pend-ing. The staff will determine whether the public release of this infoma.
tion would likely compromise the pending staff effort. Until such time, consistent with the procedures of the Commission's Policy Statement of August 5,1983 regarding Investigations and Adjudicatory Proceedings (46 Fed. Reg. 36358 Aug.10,1983), the staff has determined that and Enclnsure 2 should be provided only to the Commission and Boards for their in camera consideration. The staff will be avail-able to advise the Commission as to this determination. The other parties to the proceeding are being notified, by copy of this memor-andum (and Enclosure 1), that the staff is presenting'this infomation to the Commission and Boards.
.C,:
i..
.an.v, e t. ',..:.o. c.
Darrell G. Eisenhut. Director Division of Licensing
, Memo fra Bishop to h
(O.
Encl.1:
Eisenhut dtd 10/21/83 Encl. 2: Copy of Allegations Received 10/19/83 cet see Next Page h 50 g 0 070505 3j ARDE04-21 PDR
..o
.. - e
" : 2-cc:
Addressees - w/ Encl. 1,& 2 T. 5. Moore. ASLA8 - w/ Encl.1 & 2 W. R. Johnson, ASLA8 - w/ Encl.1 & 2 J. H. Buck, ASLA8 - w/ Enc 1 1 & 2 SECY - w/o Encl.2 w/o Encl.2.
OGC CT~
.1/a E..cl.2 E00 - w/o Encl.'2 Parties to the Proceeding - w/o Encl.2 i
e 4
. ~. m.
3 4
1
,h,*
ALLECATIEN D TA F[RM uKu'ctila'asdudT5av cMssIo'i" InettwCtsene en feverte esde
,CECEIVING OFFICE Docket Number (if applicable) 7, OIftk/ O C11re /.s.i
- 7 In an,e inen 2. er n sonens..=ee Ganansci OMlb 'l dd,b 2
';,, e' 3
9 3
~
- 2. Functionel Ares (s) Involved:
ICheek espreenese beetsell operatione onsite health and safety construction offsite health and safety
, safeguards
, emergency preparedness other tspecity) 3.
Description:
I h l L lt. l e le l M, I l /-I sl t I /l,c-1 < l.-1 SI I,$1 clel si I/t' le.'lal lAleli luir4 1,MI JIplc l-Lele;I le l,17 Isle I( 171 lA lol It-Isl<lnirl81 1.' It'le;l71/lF1/ IrinlTle t' IM I I I I I II IIIIIIIIIIIIIIIl'IIIIIIII
- 4. Source of Allegation:
Ichuk app, ope ete bass contractor employee security guard licensee employs s news media NRC employee private citizen organization tspecityl other tsp.cityl MM 00 YY
- 5. Date Allegation Received:
,/
j
[. L L' b Ib//t('l f ) *//G Q A (
l
- 8. Name of Individual in,e two initiste and test norr el Receivines Allegation:
- 7. Office:
g g ACTION OFFICE
- 5. Action Office
Contact:
Ineet two inielete end seen namel i
- 9. FTS Telephone Number:
4 4 3 3 g y 3
~
- 10. Status:
Icheck enel Open,if followup actions are pending or in progress Closed, if fo!!awup actions are completed MM 00 YY
- 11. Date Closed:
l l
C/?.
2 "'* *' k ':
1IIIIIII IIl l l l l l l l l l l IIIII lumn is so che,eci.,ei
[IIIl l l l l l l l l l l l l l l ll l l l l 1 h2.},,,,grgte M V
- 6 5 *A* O O J2 6,1 h
Ome.
v No-b.,
l J
. _ _.... ~ _.
Io Problem Statement Allegation f(s):, M 44
\\.
'~
A S No.(s):
RV S3 A %2-BNis):
M/A This document lists (or directly references) each allegation or concern brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered.
If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s).
(This can occur if, for example, a line concern was received in an interview).
Problem Statements (use extra sheets as necessary)
~
Allegation #
Verbatum ' Statement or Reference d b ' ' ' '
1.\\. P. F o i e.
vco,yect\\3 fejeC+'d tu dci.
re prts, Com:nent a ry 5=e ex %. dud ATc, M o. R.v - e As2. ca.b G Mi No n..
-s te /ed -s d es--
"b r.t-ca.a ct N12.c mspec.p o pere.
'r Date This Statement was Completed
.3/5/M d
A/.Is.d e T4.XnicalReviewer@gnature
.s
~
c4 ww p
ma %.4.
m %- g,w e
""*/,"*3" ALLEGATION CATA F2RM u s. wucuAWeou 7 yco n viow D/%/ 8S(
steenseisene on t w e.e.
w i
g e
RECEIVING OFFICE N
Docket Number (if applicable)
- 1. Focility(leel involved:
(Namel P3 l[d-A C (hivfCIO b
C
)
~
sn me,e een s. e n sensas, wane askanc
~
'd M. D i_ [3t'd, b $
5 I 7
- 2. Functlenal Ares (s) Involved:
onsite health and safety tcheek eponeestsee hemisse l operatione construction offsite health and safety safeguards emergency preparedness other tspeciM
- a. os.cription:
1/4 It li. li-l/13-I J ls ITIA Ii tr-I )I lIl-lirI<>l Isil<l 16l 1 I"I lalicIt I h Ifv1 l'il rli la li-Inic li Ic I,. I'/ I I Al
- Isi I e IIt 12,1 I plcIsl isI nit-li-Ir1r I Ir-liel Iole I"I ul It I I ILIPluj divl Isi cle te l N.Pl i I I I I I I I I I.I
- 4. Source of Alfegation:
(Chech.poroertete boel contractor employee security guard licensee employee news media NRC employee private citizen orgenlaation tse.cityl 1
other ts,.eity b 55.
N $*bI I- }
MM Do YY
- 5. Date Allegation Received:
g
[
g j
~
. g/. [y / ff g ['/ j'. 7. #1* 6 ?/.' / L(
- 8. Name of individual tmeet two insei.e..nd I : n.m.I Receiving Allegation:
- 7. Office:
(( q ACTION OFFICE f) t-k i l b(* l 1
~
B. Action Office
Contact:
in,. tw. inee.s..nd e..,n...g
- 9. FTS Telephone Number:
ylb 'S 3
7 3 3
- 10. Status:
Open,if followup actions are pending or in progress (ca
.n.,
Closed,if folioWup actione are completed MM oc vy
- n. nei. Clo..d:
l l
11.1 Document Nos.
f h
3 72 "'_**'k':
1IIIIIII I I I I I I I I l-l l IIIIIII to,..
s.
'Y bl IIIIIIIIIIIIIIIIIIIIIIII
_ l/
5:11l. > 3 m e.t-R \\/
A
.3 -A-C C 38
.. =
,,y w m-u us e g e - - {
g% hCr
- 21 (.daAmt M*,
sle4 Task: Allegations or Concerns Nos. 24 ATS Nos. RV83A28, RV83A33, & RV83A52 BN No.
N/A
~
RV83A46 83-164(10/27/83)
Characterization A site :antractor (H. P. Foley (HPF)); (1) r jected nonconformance reports withe.:. justification, (2) was not documenting nonconformance reports issued by field inspectors, (3) has incorrect procedures for voiding nonconformance reports, and (4) incorrectly rejected defective weld reports.
This characterization includes all of the above referenced allojations.
Implied Significance to Plant Ceston, Construction, or Operation The site contractor in question (H. P. Foley) has been responsible for'-instal-lation and modification of electrical, civil and mechanical design class 1 safety systems and structures which are necessary for the safe operation and shutdown of the plant.
Improper handling of nonconforming conditions could cause construction quality to be indeterminate.
Assessment of Safety Stanificance Td assess the overall control of nonconformances, as well as, the specific concernsthestaff;(1)reviewedapplicableHPFprocedures,qualitycontrol (QC) inspection reports and specific NCRs, (2) interviewed QA and QC inspect, ors m,
t
\\
'.a and (3) conducted a field inspection of various welding activities in the structural cable tray support and HVAC areas.
A review of the Otablo Canyon Power Plant Final Safety Analysts Report and contract specifications issued to HPF established that the QA program was required to comply with 10 CFR Part 50 Appendix 8.
The staff reviewed the HPF quality control procedures for specific disciplines (civil, mechanical and electrical) such as QCPC-7, QCPM-17, QCP-5A and QCPE-7 and cross-checked references to the nonconformance procedure QCP-3.
A review of the logs of inspection reports (!R's) and nonconformance reports (NCR's) identified that over 1925 NCRs acd 2156 irs had been issued to date against the 11 specifications issued to HPF.
The staff selected a sample of 130 NCRs and 10 irs for an indepth review.
These documents spanned the time perio'd from 1973 to the present and scoped problems identified in normal HPF inspection activities, as well as audit findings of PG&E and NRC. These documents ranged from the identification of programmatic problems, such as
. qualification of personnel, to specific hardware problems, such as concrete voids at a particular location.
Eight NCRs in the sample had been voided.
The staff reviewed these NCRs, examined the rationale for voiding them, and discussed the voiding of NCRs with QA management.
The HPF procedure provides for the voiding of NCRs as a procedural step and management"e n Pcises the control, as appropriate.
The staff agreed with the reasons for voiding the NCRs and deterrstned there.was no safety impact.
The staff, however, felt that Foley QA managdment could be more l
l l
l t
8
responsive to the individuals conc 1rns and communicate with the individuals
=
more effectively.
h, h{
I NCRs.were f ound in the records which were voided before the QCP-4 we revisd/
to procedu 4119 allow the voiding. However, these were handled t
manner a: 'le formal procedural steps and all had been logged in the records as having been volded. There did not appear to be any evidence of covering up the voiding.
The staff's review o'f over three parcent of all NCRs, irs, and othe'r specific inspection documents found that nonconformances were documented, and properly 1
administered. Although properly administered, the staff disagreed with the engineering resolution of one of the NCRs reviewed. The NCR concerned stud welding. The Engineering disposition did not recognize that a material (which was not r,ec'ognized in the welding procedure) was being welded. This staff finding is an apparent violation. The ifcenses will be required to perform expanded reviews in this area. This activity will be nonitored by the staff.
The action on eight NCRs/ irs were verified by the staff to have been completed by field inspections.
In addition, six work request job packages were reviewed, verified the activity inspection reports exastned and found satisfactory.
Interviews with HPF personnel veriff ed that they were familf ar with applicable procedures.
T&sk Allegation or Concern No. 66 resultad from the report by a concerned citizen that a QC inspector's wife indicated her husband had identifled that defective weld reports and that these were being wrongfully rejected by HPF management. The QC inspector was interviewed by the staff and did not 9
-a r
m
~
d corroborate the allegation. The QC inspector stated that his concern had dealt with the efficiency of work practices rather than with noncompliance with NRC regulations pr with PG&E's or HPF's procedures. The staff wil1 do further
,. investigation in this area, that is, a sampling of nonconformacces written by the individual will be reviewed and examined in the field. This action will be completed by January 18, 1984. The overall incidence of defective field welds has been addressed by staff examination of field weld quality in the routine program.
Some problems with weld quality have been identified but the necessary corrective action is being implemented through the staff followup of the violations.
In summary, the established program controls on voiding noncenformances has thus far been found to be adequately implemented and the investigation to date has not substantiated the allegations but further investigation is planned.
Staff Position
, Based on the information to date, the staff concludes that the,ontrol of c
voiding nonconformances complies with the QA programmatic requirements and has been properly executed by the licensee.
Specific violations were identified in the peripheral areas of (1) a nonconformance engineerint disposition (wrong welding procedure / material used)_
and (2) inadequate field executjon_of a disposition (undertorqued structural,
bolts). These will be pursued in the routine inspection program.
9 4
e 10 i
i t
i Action Required l
Further action is planned regarding examination of the named individual's
~
honconformance and inspection reports. The staff will monitor the additional i
Itcensee reviews.
i 1
I 1
I i
i
)
)
l l
i e
t l
l 11
N.
3 g-
=
Action Required Further action is planned regarding examination of the named individual's
~
henconformance and inspection reports. The staff will monitor the additional Itcensee reviews.
m
{
4 t
V ep N
L
.e engemune
- e O
+
9 11 m
g+,
= ~.. -
+*++-~4
~
~
6 M
hh:rrmddrw hA aJr h O.M gwy 133 Task: Allegations Nos. 24, 26, 46 & 66
~
ATS Nos. RV-83A28, RV-83A33, RV-83A46 & RV-83A52
^
Characterization: A site contractor (H. P. Foley) 1) rejected nonconformance reports without justification, 2) was not documenting nonconformance reports issued by field inspectors, 3) has incorrect procedures for voiding j
nonconformance reports, and 4) incorrectly rejected defective weld reports.
This characterization includes all of the above referenced allegations.
Implied Significance to Plant Design, Construction. or Operation:
The site contractor in question (H. P. Foley) has been responsible for installation and modification of electrical, civil anc mechanical design class 1 safety systems and structures which are necessary for the safe op'eration and shut down of the plant.
Assessment of Safety Significance: The strategy for resolution of these allegations or concerns was to inspect the compliance of the H. P. Foley (HPF)
QA program in regard to the control of nonconformances and verify the documentation, implementation and effectiveness of procedures for control of nonconformances.
The identification, documentation, review and disposition of a sample of nonconformances as well as certain specific (previously identified)
" problem" nonconformances were to be reviewed to assess the overall control of nonconformances as well as the specitTc concerns. The above was accomplished by the following:
1)
Review the H. P. Foley procedure which discusses the control and l
documentation of Nonconformance Reports (NCR) for compliance wit 10 CFR 50 50
Appendix B.
. e 6
h ae e
e
-o I
m e
4 e w e' WEDS O
e e
6 w..--
we.
m_.4 e
ma
- g
=
-e
r
.~
134 2)
Review Quality Control (QC) generated inspection reports to determine if identified nonconforming conditions were being documented by NCR j
3)_ Review NCR's generated by H. P. Foley to determine that NCR'suare being dispositioned in sccordance with applicable procedures, codes and the FSAR.
4)
Interview Quality Assurance (QA) and QC inspectors to determine if there exist any reluctance to write or if there are improperly disposition NCR's in accordance with procedure, 5)
Conduct a field inspection of various welding activities in the strugtural, cable tray support and HVAC areas.
A review of the Diablo Canyon Power Plant Final Sa'fety Analysis report and contract specifications issued to HPF established that the QA program was required to comply with 10 CFR Part 50, Appendix B.
The HPF Quality Control procedures for specific disciplines (civil, mechanical and electrical) such as QCPC.-7, QCPM-17, QCP-5A and QCPE-7 cross reference a nonconformance procedure QCP-3.
In general, minor rework activities are to be documented on inspection repohts, for the specific activity, for welding, a Weld Inspection Sheet (WIS) documents the inspection following the rework. Nonconformances to HPF requirements are to be documented on Inspection Reports (irs) and nonconformances to the PG&E specification are to be documented on Nonconformance r
Reports (NCRs).
~ ~"-~
~
A review of the logs of irs and NCRs found some 1925.NCRs and 2156 irs had been
~
issued to date against the 11 specifications issued to HPF. A sample of 130 NCRs and 10 irs were reviewed in depth. These documents spanned from 1973 to mm,.
-*pme.,
w.-+-ww w+
e-
= - w-w - w aso.--e-m
-a='-***
the preser.t and scoped, problems identified in normal HPF inspection activities i
- e e
b 6
e O
C i
9 4
e mm e
6 e
l
,.4
.e ww a.
-c ee m.
=
H
-e-~we~****
e 135 as well as audit findings of the PG&E and NRC. These documents scoped the identification of programmatic problems such as qualification of per.sonnel as well as specific hardware problems such as concrete voids at a pailicular location.
Eight of these NCRs had been voidad for various reasons': Six work request job packages were inspected and the specific activity inspection reports within each were reviewed. The dispositions on eight NCRs and irs were verified in the field to have been as dispositioned.
The review of the NCRs, irs and other specific inspection reports.found that nonconformances were documented, dispositioned and approved as required by the procedures including PG&E approvals.
Interviews with personnel found that they appeared to be familiar with the procedures,. NCRs were found which were voided oefore the procedure QCP-3 was revised'tc allow such, however these NCRs were found to have been voided in accordance with QCP-3 rev. 7 and are documented in the NCR log as voided and also to have PG&E approval. ~
Al' legation No. 66 resulted from the report by a concerned citizen that a QC 1
inspector's wife indicated that her husband had identified defective weld reports and were being wrongfully rejected by H. P. Foley management.
Suosequently, the named QC inspector was interviewed by RV inspectors.
The QC inspector stated that his concerns had dealt with the efficiency of work practices rather than with noncompliance with NRC regulations or with the 4
PG&E's or HPF's procedures.
It should be noted, however, that ano'ther QC inspector interviewed in the investigation indicated that his nonconformance q
reports had been wrongfully voided by Foley management. This latter QC inspector's concern has been noted for future evaluation.
p
_,_._r,,
,___,y.
r 135.1 l
A review of NCR 8831R-34 indicates that QC had identified a welding procedure violation in that the traveler for connectin number 61SI-C1-13-73 R/2 contained a weld filler metal. issue record which showed that 1/8" diameter eTectrodes were us,ed rather than the 5/32" or 3/16" diameter electrodes. A review $of the appitcable Weld Inspection Sheet for weld numbers 73C thru 73J indicate that the weld procedure specification (WPS) to be used is WPS 5 & 10. Both WPSs do allow the use of the smaller diameter electrode and therefore would not a procedural violation.
However the PG&E Work Request contained in the connection package specifies that:
" Annulus-steel material and Class I platform material to be supplied per Spec. 8833." Specification 8833 titled " Structural Steel" states that: " Welded studs shall conform to ASTM A108-1015."
The NCR addresses work activity of these welded studs in containment and the fact that the original specification requirements to perform on the stud could not be made due to configuration problems.
l The HP Foley Engineering group and PG&E Engineering' group reviewed and approved the NCR, however neither organization identified the fact that the stud material used did not conform to the welding procedure specification (QCP-5A, WPS-5) material specification. The welds in question (weld nos. 73C, 73D, 73E, 73F, 73G, 73H, 73I and 73J) were completed and inspected by QC on 10/15/83 as documented on Weld Inspection Sheet for connection no. 73. This appears to be an item of noncompliance.
The concern here is that engineering both H.P. Foley and PG&E had reviewed the NCR which addressed electrode size and yet had not identified that the stud material was not in conformance with the stated weld procedure to be used.
~
= me,e-
_ mw+ e s e < m se.-
- -,==v m-
==~
+a.-
= = + -
r 135.2 Field inspections were conducted of structural welded connection made in plant, in addition bolted connections made by H.P. Foley were also inspected.
.j Seyeral connections in containment are discussed on a H. P. Foley Engineering Disposition Request (EDR) number 711 which address the inspection requirements of high strength bolted connections. EDR 711 relieves the torque inspection i
requirement and relies only on the QC inspection of the turn of nut method:
l Ouring a NRC requested inspection of connection numbers 6181C1-13,461 and 6181C1-13-462 3 1-1/8" A490 bolts were found to turn when the " job inspecting torque" was applied per Structural Steel procedure QCPC-7. These connections were QC excepted 8/18/83. This appears to be an item of noncompliance.
The concern here is that H. P. Foley engineering, when they review EDRs which change inspection requirements do not provide adequate review to insure that the l
work is in accordance with specification requirements.
0 in summary, the established program to control nonconformances was found to be implemented and the specific allegations were substantiated only in part. The dispositioning of NCR 8831R-34 appears to indicate that engineering did not do an adequate review in that it identified the stud material which was not per the weld procedure.
Staff Position: The staff position is that the control of nonconformances
~
complies with the QA programmatic requirements.
The review of NCR 8831R-34 indicates that welding procedure material requirements were not checked to insure that the correct procedure was being
. ew e % e -eur* - =
o used. Current engineering reviews, in the area of welding, may not be adequate to compliance with procedures.
l ee e
m 5
e i
(
De e
-6 6
6 o
9
=
=
_-a<=<w=w--e--%**
-.. % e.-
---%+
. ~.
--- - - - = < - -
~ = = - --- -
lW M 6:
.~ 3' Task:
133
-- U g/g
,,Allegaticms Nec. 24, 26, 46 & 66 ATS Nos. RV-83A28, W-83A33, RV-83A46 & RV-83A?2 Characterization: A site mntrheter-(H. P. Foley).1) rejected ra_-w-A -a::e
-%u without justiff < aticn, 2) was_not ?P--Jdng ra-- JozmEin 1%G ~ ~~
issued by field inspectors, 3) has inc.uc.cact s - hes for voiding c
nonconfomance i=WLs, and 4) ira.cu.ctly rejected defective weld 1% s.
L 211s characterizatien includes all of the above referenced allegations.
Implied Sien474rance to Plant Design, Construction, or Operaticni 'Ihe site contractor in questicm (H. P. Ibley) has been r*=mn=4hle for installation and i
aedification of electrical _, civil and mechanical design class 1 safety systscs and structures 5hich are necessary for the safe operation and shut down of the plant.
i Assessment of Safety Signi74mnce: 'Ihe strategy for resolutica of these allegatices or ccccerns was to in= pact the M14ance of the H. P. Ibley (HPF)
QA program in regard to the control of nonconfomances and verify the documentaticm, inplenentaticri and effectiveness of prMnus for v 4Lvl of -
~
nonce'formances. 'Ihe iden+4fication, documentation, zwiew and d4=maiticn of a
=-1
of noncenfewmences as well as certain spac4f4n (prwiously idan+4+4=d)
" problem" rg-3 ifomances were to be reviewed to assess the overall control of rw-aformances as well as the = pac 4fic concerns. 'Ibe above was am14=had by the S11rwing:
1)
Rcnriew the H. P. Ibley st-73 he which d4==ses the -46uk. and -
1 Arvnnarttation of Nnrvvmfonnance WLii (NCR) for m14=ne= with 10 CFR 50
.r.
g lAppand4-n.
g t-st..
y f
2)
Review Quality Cbntrol (CC) generated in=partion uwLs to de+amina if
{
iden*474ad nonconfe ming conditicns were being d T W by NCR.
3)
Review NCR's generated by H. P. Ibley to de*amina thatf NCR's are being
~
dispositioned in accordance with applicable gv+%s, cadei ux! the FSTJt.'
y l'
l
[
4)
Interview Quality Assurance (QA) and CC inspovss to determine if there exist any reluctance to write er if there are i@wly d4=pesiticm NCR's in accc M m with rs%.
5)
(bnduct a field in5+;Licn of various welding activities in the structural, cable tray swL and HVAC areas.
A review of the Diablo Canyon Power Plant Final Safety Analysis uwL and centract apae474e=tions is==4 to HPP established that the QA program was required to ccuply with 10 CFR Part 50, A7and4x B.
The HPF Quality Control
~
- g..:M nes for = pac 4fic d4=e4p14naa (civil, mechanical and electrical) such as QCPC-7, QCPM-17, QCP-5A and OCPE-7 cross reference a rga.ubmance g&w.=
QCP-3.
In 9uuorsl, minor zwerk activities are to be &--
--nL=d cn in=partion
&=rELs, for the = pac 4 74e activity, for welding, a Weld In=partien Sheet (WIS)
& _ --ats the in=partien fn11=ing the rework.' Ncmcenfnmances to HPF requiu Ls are to be & _4 -nted on Tneraction %L (irs) and rsa.us
--a -s to the PG&E apacificaticm are to be th's LcTid cm Noncerf - -r+
kpcu.tm (NCRs).
A review of the logs of irs and NCRs found same 1925 NCRs and 2156 irs had been 4===d to data cinat the 11 =pacifie=tions issued to HPF. A sa'aple of 130 NCRs and 10 irs were reviewed in depth. 'mese <&ments g- - i frca 1973 to the g d., and W penh1-identified in nnmal HPF in5+2 Lien activities g'
- f.,.
.-._+
.. ~, -
f.;,
135
~
- as well as audit findings of the PG2 and NRC. 'Ihese
"-: --n'J
- - - --I the iden*474e=ticm of progrannatic problems such as qualificaticm of par +-+1 as well as
- --4 fin hardware problems such as cxmcrete voids at a par +4~1=*
~
locaticm. Eight of these NCRs had been voided for various reastms. Six wcdc request job packages were hi+M and the g=-4fic activity h% wi.
within each were reviewed. 'Ibe d4Witicns cm eight NCRs and irs sure varif4=d.
2-in the field to have been as d4==iticmed.
The review of the NCRs, irs and other =;=-4fic hW twis found that rcra.udormances were doctznanted, d4=msitioned and w ved as required by the s
pac-:+imes 4=-1nd4=y PGEE approvals.
Interviews with pursuusl found that they =p==W to be f=414 =v with the g - -%. NCRs were found which were voided before the r --A=
QCP-3 was
" revised to allow such, however these NCRs were found to have been voided in accordance,with QCP-3 rev. 7 and are documented in the NCR log as voided and
~
also to have PGEE wwal.
l Allegatica No. 66 resulted frt:m the twL by a _ ---
" citizen that a QC inWA's wife hdie=ted that her husband had identified defective weld rwL. and were being w.e
" 11y rejected by H. P. Foley managenent.
/
Subsequently, the named QC in5+rw was interviewed by RV b5+h. =. 'Nha QC inspector stated that his ccmcerns had dealt with the effie4=ey of wIork practices rather than with ncnccmpliance with NRC regulaticms or with the PG&E's or BPF's p _-:M n1ts. It shou.1d--be noted, however, that another QC in-;+rw interviewed in the investigation indicated that his ncmcenformance reports had been w.=,fally voided by Peley management. niis latter QC.
irgw's ernrum has been noted for future evaluaticm.
4*.
1.
b2 135.1
violatica in that the traveler for - Alin rumber 6181-Cl-13-73'R/2 ccmtained a weld f4llar metal issue record which showed that 1/8" diamter elect: redes were
~
used rather than the 5/32" or 3/16" diameter. electrodes. A,rwiew of the applicable Wald Tn=:=-ticut Sheet for weld rn=hars 73C thru 73J 4f4r =te that the '
weld p---% = par 4 fir atica (NPS) to be used is WPS 5 & 10. Both WPSs do allow.
b' the use of the maller di-
^A electrode and therefore would not ag suc.diu:.1 violaticn. However the PG&E Work Request cxm*=4nad in the ccrmection package
= pac 4 74== that:
"Annulu: ;t.el m**Hal and Class I platform ma+av4=1 to be-
~
{
supplied per Spec. 8833." apar-4 fir = tion 8833 titled "SEM Steel" states.
that:
" Welded studs shall ocmform to AS m A108-1015."
'D:a NCR addresses work activity of these welded studs in mntainment and the.
fact that the original = par 4f4 cation requi-6.5 to perform cri the stud could not be made due to =f4W% pr+1
}
- The HP Ibley Wnaaring group and PGEE Enminaaring group reviewed and wvv=1 i
the NCR, however neither organization iden*474ad the fact that the stud ma+=v4=1 used did not conform to the welding g_-: dave =pacif4r=ticm (QCP-5A, WPS-5) ma^ ----i =1 = par-ification. The welds in questicm (weld nos. 73C, 73D, 73E, 73F, 73G, 73H, 73I and 73J) were crupleted and in-T+ t i by QC en 10/15/83 as l
docmented en Wald in=:=-tien Sheet for 2 - + t.ica no. 73. This appeans to be
~
l an item of ra _--- 14 W
~
The concern here is that engineering.both H.P. Pbley and PGEE had reviewed the NCR dnicit addressed electrode size and yet had not identified that the stud material was not in ocriformance with the stated weld gc-:d 1. t6 he used.
..J t
- h..
h
~
- h. Q:
, L._
=
me. -.
e.-
-..-[,4..--*4
..,m
. -. u..
.y 2
,.. c..
135.2 t.;. :...
Field h5+ Lions were ocmducted of structural welded --- ;-tcm made in plant,
'j in addition bolted m Cdons made by H.P. Ibley were also in5+M Several connections in cen*=4== t are dimM cm a H. P..Ibley RT m==r45 i
MWticm Boquest (EDR) nuser 711 which address the inW4A requi..i ~
of.high.L-.vi.h bolted ---- ticms. EDR 711 relieves the L.u.d4=5+_i ica..._...
requi..
.t and relies caly cm the QC inspection of the turn of nut nethod.
I l
During a NRC requested inW of connectica rnunhars 6181C1-13-461 and -~
~'
f 6181C1-13-462 31-1/8" A490 bolts were found to turn when the " job inspecting y
torque" was applied per Structural Steel s -T"M QCPC-7. These " -t.icos c
l were QC meseptati 8/18/83. 21s appears to be an item of nemocnp14=n~.
[
j A
1 Se ccmoern here is that H. P. Fclay enginaarine, when they review EDRs which change ing-- i.ias requi -4L. do not provide adequate review to insure that the week is in.accordance with v474=tica requi -.is.
i In simmmy, the establ4N program to centrol 4--y---
fcumances was fcp:xi to be inplemented and the =p-4fic allega were subst Liated only in part. Se d4=p=i+4 ming of NCR 8831R-34 appears to indiate that enginaaring did not do l
an adequate review in that it identified the stud material which was not per the l
weld r -:=t Staff Position: 2e staff position is that the -4i.1.vl of Wormances s
ev =14== with the QA g ;----Lic x ei -.te.
5 p c-: + t = m a M =1 i
ne review of NCR 8831R-34 indicates that =1d4 requirements were not W to insure that the correct rh. was being i
E.
used. Ctarrant =-F-
- Mr reviews, in the area of =1d45, may not be adequate a
W. '
to m14-with procedures.
[-
._}.a..
' ~
~
wy.
w-w-----w-w-w-'~"w'www'w--w,qw"*
Q g(){C. +- t -:
4 7..-
- ~
e.
136
'Actieri Required: A review h1d be conduct:ad of all H. P. Ibley NCRs4 n the -
i dJ.%
area of sexuctural wading to insure that acas which ch-- w.1a4% r..-....
p or am+-d=1 requi
- a. are di-~-itiemed in accordance with rmw, y fir =tions and codes M
[ D ( ~.
o A/
M ~
~
w as ewe a-S 66C M
lI
==M d,.
/
A ytrse cAe.
I e
O 4
0 j
e 1
e I
o e
f O
1 e e.
we I
e %
e e
g e
e O
e i
f
' * ~
+..a i
l
,v.
- a.,e i
,,-m..
r,---,..-
,n,_-
._,.m,
-w-.~---..
w.'.
us.
.vs~
Violation
.-c,.
., c
. :..q.
~
As a result of the inspection conducted on Novenber 29 - Decenber 8, 1983, and in accordance with Section.206 of the Energy Reorganization Act of 1974 and its inplementing regulation 10 CFR Part 21, the following violation was identified and. categorized in accordance with the NBC Enforcement Policy (10 CFR Part 2,
.4 Appeindix C), 47 FR. 9987 (March 9,1982)V Section 21.6 and 21.21(a) of 10 CFR Part 21, dated August 31, 1983, staten in part:
21.6 "E:ach innvidual, partnership, mrporation or other ent ii3 subin t t o He regulations in their past, shall post current copies of the follcwing doc.uments in a conspicuous position on any premises... (1) the regulation in this part, (2) Section 206...and (3) procedures adopted pursuant...."
21.21(a)
Each individual corporation, partnership or other entity subject to the regulations in this part shall adopt appropriate procedures...."
Contrary to the above, the Howard P. Foley Ca pany did not have the current copies of Part 21 and Section 206 posted nor were there procedures established to inplement 10 CFR Pa[rt.21.
'Ihis is a Severity Level 5 Violation (Supplement VII).
e eh e
b e
b
'e
- 17 y
r-.
d k
Task:
Allegation or Concern No.24 C
ATS No:
RV83A28, RV83A33, & RV83A52
- BN No:
RV83A46 83-164 (10/27/83) u Characterization A site contractor (H.P. Foley (HPF)); (1) rejected nonconformance reports without justification, (2) was not documenting nonconformance reports issued by field inspectors, (3) has incorrect procedures for voiding no.nconformance reports, and (4) incarrectly rejected defective weld reports. This characterization includem all of the above referenced allegations.
Implied Sianificance to Plant Design, Construction, or Operation Assessment of Safety Significance Staff Position
~
howgi (Vt a.
2
-- 1 l
l Action Required l
l W
e e
r 6>7 Al sz
_. _ _. _. zz..=, _ _
w rr flW M yte6 V Task: Allegation or Concern No. 24, 26, $6 ATS No.
RV83A28, RV83A33, RV83A46 & RV83A52' W No.83-164 (10/27/83) (for RV83A46)
Characterization A site contractor (H. P. Foley (HPF)); (1) rejected nonconformance reports without justification, (2) was not documenting Nonconformance Reports (NCR) issued by field inspectors, (3) has incorrect procedures for voiding nonconformance reports and (4) incorrectly rejected defective weld reports.
Implied Significance to Plant Design, Construction, or Operations Note:
The resolution of these issues was complete in SSER No. 21, however the text has been reformatted to clarify the issues and add additional information.to paragraph no. 4.
The site contractor in question (H. P. Foley) has been responsible for installation and modification of electrical, civil and mechanical Class I safety systems and structures which are necessary for the safe operation and shutdown of the plant. Improper handling of nonconforming conditions could cause construction quality to be indeterminate.
Assessment of Safety Significance
.e-e,,w e
e-
=
++w ow * **
~~
J l
i
\\
To assess the concerns, the staff:
(1) reviewed applicable H. P. Foley procedures, quality control (QC) inspection reports and specific NCRs; (2) interviewed Quality Assurance and Quality Control inspectors; and, (3)
. conducted a field inspection of various welding activities in the' structural c;sble tray support and Heating, Ventilating and Air Conditioning THVAC) areas.
A review of the Diablo Canyon Power Plant Final Safety Analysis Report and contract specifications issued to H. P. Foley established that the Quality Assurance Program was required to comply with 10 CFR Part 50, Appendix B.
The staff reviewed the H. P. Foley quality control procedures for the specific j,
disciplines (civil, mechanical and electrical) such as QCPC-7, QCPM-17, QCP-5A and QCPE-7 to assure reference to Nonconformance Procedure QCP-3.
The inspector's examination and evaluation of the allegations are as follows:
1.
H P. Foley rejected nonconformance reports without justification.
A review of the logs, of inspection reports (IR's) and nonconformance reports (NCR's) identified that over 1925 NCRs and 2156 irs had been issued against the 11 specifications issued to HPF. The staff selected a sample of 130 NCRs and 10 irs for an indepth review. These documents spanned the time period from 1973 to the present and identified problems in the normal HPF inspection activities, as well as audit findings by PG4E and the NRC. The subjects of these documents ranged from the
~~
identificationofprogrammsticpNblems,suchasqualificationof personnel, to specific hardware problems, such as concrete hids at a I
I particular location. All problems appeared to have been addressed and l
i
~ ~
~.1 1 E 7 T~
. lilZ1 i 1 Z l I 1 l
~ T 1.. i
..li i [
.. ~. _.1. __..T_ E l _,
adequately resolved. Based on this examination the staff concludes that nonconformances were not being rejected withou't justification.
i
- 2.
'H.
P. Foley was not documentina Nonconformance Reports issued by field inspectors.
The staff's review of over three percent of all NCRs, irs, and other specific inspection documents found that nonconformances were documented, and properly administered. Although properly administered, the staff disagreed.with the engineering resolution of one of the NCRs reviewed.
The NCR concerned stud welding. The licensee's engineering disposition did not recognize that a material not allowed by the. welding procedure was being welded. This staff finding is an apparent item of noncompliance which was discussed in SSER 21 (Nureg 0675 LD). Based on this examination, except for the item described above, the staff concludes that nonconformances were being properly dccumented and administered by the contractor (HP Foley).
3.-
H. P. Foley has incorrect procedures for voiding Nonconformance Reports.
/
The staff determined in their review of the 130 IR's referenced in paragraph 1 that eight NCRs in the sample had been voided. The staff reviewed these NCRs, amanised the rationale for voiding them, and discussed the voiding of NCRs with H.P. Foley's QA management.
H.P.
Foley Quality Control Procedure Q U -3 provides for the voiding of NCRs.
~~
Additionally, the inspector====ined NCRs which were written before QCP-3 was revised to formally control the voiding process. These NCR's were
~
\\
w.
l found to be appropriately voided and logged in the records. There did not appear to be any evidence to indicate that H. P. Foley management inappropriately voided Nonconformance Reports without justification. The
' staff agreed with the reasons for voiding the NCRs and determined there was no safety impact. The staff, however, felt that H.P. Foley QA management could be more responsive to the individuals concerns and communicate with the writers of the Nonconformance Reports, their*
rationale for voiding the Nonconformance Reports.
Based on this examination the staff. concludes the H. P. Foley Company has correct procedures for voiding Nonconformance Reports and has been
- j properly implementing their procedures. :
4.
H. P. Foley incorrectly rejected defective weld reports.
This concern resulted from a report by a concerned citizen wherein a QC inspector's wife indicated her husband had identified defective weld i
reports and that these were being wrongfully rejected by HPF management.
The QC inspector was interviewed by the staff and did not corroborate the t
l allegation. The QC inspector stated that his concern had dealt with the efficiency of work practices rather than noncompliance with NRC regulations or with PGGE's or HPF's procedures.
l l
l In December 1983, (after SSSR 21 was written), the Quality Control Inspector was again contacted and the staff was referred to eleven nonconformance reports prepared by the QC Inspector. A revi,ew was performed of these documents and ten of these reports were determiAed to I
l
\\
= = = =,
z =-
===n:
=
==-
= :. - -
i have been acceptably addressed and resolved. The eleventh nonconformance I
report was found to be undergoing licensee review. The staff's review of the eleventh report determined that no "significant safety problem had
'been identified. The staff examination and resolution of this allegation (RV-83-A0052) is documented in NRC Inspection Reports Nos. 5'0-275/83-36 and 83-41.
Staff Position Based on the foregoing information, the staff concludes that H. P. Foley procedures and policies for the control, voiding, dispositioning and administering of the Nonconformance Reporting system complies with the requirements of the contractor's and the licensee's Quality Assurance Program.
Action Required The licensee was informed that Notices of Violations will be issued by Region V in the areas of (1) engineering dispositioning of a nonconformance without realizing that the wrong welding procedure and material had been used, and (2) the discovery of untorqued structural bolts. Note: The untorqued structural bolt violation was discovered during the inspection of the stated allegations.
f 6
e e
4 1
- e
+ = = -
- ---*-- **~
~ " " * - " *
- ^
~
FILE o ov Task:
Allegation or Concern No. 26 l
l.
ATS No:
RV-83-A-0033 Characterization Foley didn't document NCRs issued by Field Inspectors.
Implied Significance to Plant Desian, Construction, or Operation Set Task Allegation or Concern No. 24 Assessment of Safety Significance See Task Allegation or Concern No. 24 Staff Position See. Task Allegation or Concern No. 24 I
Action Required See Task Allegation or Concern No. 24 O
e e
eas -
___7...
F I
f.6 C
Task:
Allegation or Concern No. 46 ATS No:
RV-83-A-0046 BN No.
Characterization H. P. Foley QA Procedures Voiding NCRs Incorrect.
Implied Significance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 24 Assessment of Safety Significance See Task Allegatica or Concern No. 24 Staff Position See Task Allegation or Concern No. 24 Action Required See Task Allegation or Concern No. 24 W
e
Task:
Allegation or Concern No. 66
{l n
I I n.-
U ATS No:
RV-83-A-0052 BN No:
N/A Characterization:
3-Defective Weld Reports Rejected by Foley.
Implied Sinnificance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 24 f
Assessment of Safety Significance i
i See Task Allegation or Concern No. 24 i
I Staff Position
[
See Task Allegation or Concern No. 24 Action Required
(
l See Task Allegation or Concern No. 24 G
if
D Q
Task: Allegation #25 ATS. No. RV 83A33 Characterization: Deficiencies in the use of Phillips Red Head anchors by a site contractor (HPFoley).
Initial Assessment of Significance: The potatially extensive use of achors, and the number of more general concerns expressed regarding this contractor, warrents evaluation of this allegation prior to exceeding 5% power.
Source: Contractor Employee (Confidential) 8/83 Approach to Resolution:
egion V:
1.
Review use of Red Head Anchors at Diablo Canyon,
,(
including)historicalactions(i.e.Responseto 4
Interviewcraft/QCpersonnel(20individualsk./g IEB 79-02 and licensing analyses.
9
}1 2.
3.
Inspect sample of anchors (100-200 anchors).
$ Y/s t$
rYc E
- P/s en f Q // su 4WM NRR: W"JWo k " "
A M $ U UW 30-a) R iew aga st NRC re uirement nd Ind str St dards.
b Req st addi onal info tion o audit c
Deve p staff osition a action qui d.
d e ss e.
gf.A y/ 6 e.r m f N 7 % sp d & awe /Y # N>
Status:
Region V review in progress including examination of the licensee's technical evaluation in this area. Additional information has been requested of the licensee.
Review Lead: Region V Support: NRR (Review of Licenser's technical analysis).
NRR-DE-MEB Support:
Estimated Resources: Region V: 5 man days NRR: 5 man days Estimated Completion: 12/9/83 Evaluations S
1/27/83 Final Evaluation 0
Q
_ __