IR 05000445/1980004

IE Insp Repts 50-445/80-04 & 50-446/80-04 on 800211-15.No Noncompliance Noted.Major Areas Inspected:Procedures for Controlling Changes to Approved Design Documents

ML19305E063
Person / Time
Site:	Comanche Peak
Issue date:	02/28/1980
From:	Brickley R, Crossman W, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19305E058	List: IR 05000445/1980004
References
50-445-80-04, 50-445-80-4, 50-446-80-04, 50-446-80-4, NUDOCS 8004220244
Download: ML19305E063 (8)

Text

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O u. S. NuCttiR RtGuuTORr C0xn1SS10N OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-445/80-04; 50-446/80-04 Docket No. 50-445; 50-446 Category A2 Licensee:

Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 Facility Name:

Comanche Peak, units 1 and 2 Inspection at:

Glen Rose Texas, Comanche Peak Site Inspection conducted: February 11-15, 1980 Inspector:

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~b R. H.'B(ickley, Princi' pal Inspector Date Vendor Inspection Branch Other 2-88-8 0

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Accompaning D. G. Breaux, Intern Inspector Date Personnel Vendor Inspection Branch Approved:

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if[ $v hh(9 C. J. Hal'e, Chief, Program Evaluation Section Date Vendor Inspection Branch w"

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W. A. Crossman, Chief, Projects Section,

' Date RC & ESB Inspection Summary Inspection on February 11-15, 1980 (Report No. 50-445/80-04; 50-446/80-04)

Areas Inspected:

Routine, unannounced inspection of activities involving field instituted design changes. The inspection involved thirty-two inspector-hours on site by one NRC inspector.

Results: No items of noncompliance were identified.

800.4220244

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DETAILS SECTION A.

Persons Contacted J. L. Ainsworth, Supervisor, Quality Engineering (TUGCO)

G. R. Hiler, Area Mechanical Engineer (B&R)

R. E. Holloway, Technical Services Supervisor (G&H)

B. J. Murray, Project Mechanical Engineer (TUSI)

J. K. Saltarelli, Piping Engineer (B&R)

D. G. Sutton, Civil Engineer (B&R)

• R. G. Tolson, Site QA/QC Supervisor (TUGCO)

A. Vega, Senior Engineer, QA Division (TUGCO)

R. B. Williams, Project Civil Engineer (TUSI)

• Denotes presence at the exit interview.

B.

Design Change Control 1.

Objectives The objectives of this area of the inspection were to verify that:

Procedures have been established and implemented for con-a.

trolling changes to approved design documents.

b.

Design changes are:

(1)

reviewed for the impact of the change (2) documented as to the action taken, and (3) transmitted to all affected persons and organizations.

The design changes are justified and subjected to review and c.

approval by the same groups or organizations as for the original design (see d. below for exceptions),

d.

When responsibility has been changed, the designated organiza-tion shall have access to the pertinent information, com-petence in the specific area of design, and an understanding of the requirements and intent of the original design.

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2.

Method of Accomplishment The preceding objectives were accomplished by an examination of:

i a.

Chapter 17.1 of the Texas Utilities Services Inc. (TUSI),

Comanche Peak Steam Electric Station (CPSES), FSAR to determine programmatic requirements.

b.

The following procedures from the project procedures manual:

(1) CP-EP-30 (Comanche Peak Project Engineering Organization)

Rev. 0 (2)

CP-EP-4.0 (Design Control General Requirements) Rev. 1 (3) CP-EP-4.1 (Design Planning) Rev. 1 (4)

CP-EI-4.1-1 (Field Support Design Group Design Control Instruction) Rev. 1 (5)

CP-EP-4.2 (Design Interface Control) Rev. 1 (6) CP-EP-4.3 (Design Input) Rev. 1 (7)

CP-EP-4.5 (Design Verification) Rev. 0 (8)

CP-EI-4.5-1 (Technical Services Instruction for Perform-ing Engineering Analysis of As Built Hanger Baseplates)

Rev. 0 (9)

CP-EI-4.5-2 (On Site Hanger Design Group Engineering Instruction) Rev. 0 (10) CP-EI-4.5-3 (Field Support Design Group Review Instruction for Field Analyzed Piping and Supports) Rev. 0 (11) CP-EP-4.6 (Field Design Change Control Procedure) Rev. 2 (12) CP-EI-4.6-1 (Field Design Change Control Instruction)

Rev. I and Rev. 2 (13) CP-EI-4.6 2 (Application of the CMC Form to Pipe Hanger Base Plates) Rev. 0 l

(14) CP-EP-13 (Field Support Design Group Document Control l

Procedure) Rev. 0 l

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(15) CP-EP-16.3 (Design on Hanger Design, Fabrication and Installation Activities) Rev. O c.

Texas Utilities Generating Co. (TUGCO) Procedure CP-QP-16.0 (Nonconformances and Deficiencies) Rev. 2 d.

Brown & Root Procedures CP-CPM-6.10 (Inspected Item Removal i

Notice) Rev. 1, and CP-QAP-16.1 (Control of Nonconforming Items) Rev. 0

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TUGC0 QA Audit Report TCP-6 (Audit of Site Engineering e.

Activities)

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f.

The following Design Change / Design Deviation Authorizations (DC/DDA):

P (1) No. 2437 for drawing 2323-El-0601-01-S Rev. 2 dated April 13, 1978.

(2)

No. 2432 dated August 30, 1978, for specification 2323-MS-84 Rev. O dated August 5, 1978, stating that the required seismic calculations were needed for dampers CPI-VADPCK-

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01-04, CP2-VADPCK-01-04, and CPX-VADPCK-01-04. The in-spector verfied that the required calculations were

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supplied to TUGC0 by Gibbs & Hill Inc., Dallas via letters

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No. DAL-582 dated January 9, 1979, and DAL-769 dated

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May 25, 1979.

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(3) No. 4445 Rev. I for drawing 2323-SI-0630 Rev. 2 (4) No. 4483 Rev. 2 dated January 10, 1980, for drawing 2323-M1-

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0506-01 Rev. 11, 2323-M1-0507 Rev. 12, 2323-M2-0506-1 Rev. 3, and 2323-M2-0507 Rev. 3.

The inspector verfied that G&H had reviewed and approved the DC/DDA via their Design /

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Engineering / Change / Deviation Request (DECD) No. S-1421 Rev. 1.

(5) No. 4495 dated April 30, 1979, for drawing 2323-SI-0535 regarding rebar anchorage deficiencies. The inspector verified that G&H had provided, per letter No. GTN-21908 dated October 18, 1977, a procedure for determining the quantity and length of the additional reinforcing steel needed to supplement rebars with inadequate anchorage.

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(6)

No. 4471 dated April 26, 1979, for drawing 2323-SI-0624 Rev. 21.

The inspector verified that G&H had reviewed and approved this DC/DDA and documented their actions via TWX-11004 and DAX-862.

(7)

No. 4428 dated April 23, 1979, for drawings 2323-S-0718 and 2323-S-0720.

The DC/DDA Master Index indicated that G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. N-10537 dated June 22, 1979. A copy of the DECD was not in the TUGC0 files.

(8)

No. 4424 dated April 23, 1979, for drawing 2323-S-0744 Rev. 2.

The DC/DDA Master Index indicated that G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. S-11798 dated June 25, 1979. A copy of the DECD was not in the TUGC0 files.

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(9) No. 4420 dated April 23, 1979, for drawing 2323-S2-0549 Rev. 2.

The DC/DDA Master Index indicated that

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G&H had reviewed and approved this DC/DDA and documented their actions via their DECD No. S-11799 dated June 25,

1979. A copy of this DECD was not in the TUGC0 files.

g.

The DC/DDA Master Index issued by G&H showing the status

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or completion of G&H design review action.

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h.

The following Component Modification Cards (CMC):

l (1) No. 12921 Rev. O dated January 25, 1980, for drawing SW-1-027-007-J03R.

(2) No. 13138 Rev. O dated January 22, 1980, for drawing CS-1-250-003-553.

(3)

No. 13149 Rev. O dated January 19, 1980, for drawing CH-1-226-002-S43R.

(4)

No. 13183 Rey, O dated January 28, 1980, for drawing DD-1-016-018-S33K.

(5) No. 10812 Rev. O dated October 31, 1979, for drawing BRF-SW-1-DG.

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(6)

No. 10832 Rev. O dated November 19, 1979, Rev. I dated December 7,1979, and Rev. 2 dated February 1,1980, for drawing BRP-CC-ISB-004 Rev. 7.

(7)

No. 10843 Rev. O dated December 3,.1979, and Rev. I dated January 16, 1980, for drawing BRP-RH-1-SB-04 Rev. 0 (8)

No. 10857 Rev. O dated November 12, 1979, Rev. I dated November 16, 1979, and Rev. 2 dated November 20, 1979, for drawing BRP-SFX-FB-003B Rev. 3.

(9)

No. 10877 Rev. O dated November 20, 1979, through Rev. 4 dated January 14, 1980, for drawing BRP-CH-X-FB-005 Rev. 2.

(10) No. 10920 Rev. O dated October 31, 1979, through Rev. 4 dated November 26, 1979, for drawings 2323-M1-0233 Rev. 5, 2323-M1-1103 Rev. 11, and BRP-SW-1-SI-005 Rev. 13.

(11) No. 13508 dated January 26, 1980, for drawing CC-X-013-002-A43R.

i.

TUSI memorandum (CMC Sign-Off Authorization) dated November 28, 1979, and other such memorandum to verify that authorized

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personnel had approved the CMCs listed under paragraph h. above.

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The following Nonconformance Reports (NCR):

(1) No. E-1497 (Cable Tray Hanger) dated June 18, 1979.

(2) No. M-1681 (Pipe Spool No. 6; Service Water) dated October 26, 1979.

(3)

No. M-1857 (Piping, C&VCS) dated December 7, 1979.

(4)

No. M-1874 (Piping, C&VCS) dated December 10, 1979.

k.

G&H letter No. GTN-20096 dated July 18, 1977, GTN-29770 dated August 31, 1978, and GTN-31475 dated November 13, 1978, authorizing G&H field personnel to approve nonconformances prior to their review and approval by the G&H Engineering Department.

1.

A draft copy of an engineering instruction (Procedure for Transmitting CMCs/DCAs for Design Review by Respective Original Design Organizations) dated February 5, 1980.

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3.

Findings a.

General (1) The examination of the report (paragraph B.2.e. above)

of a TUGC0 audit conducted early this year revealed that a thorough audit had been conducted of field design activities. A comparison of NRC identified procedural weaknesses with the audit findings revealed that they had been identified by the TUGC0 auditors. Management representatives stated that they were aware of the audit findings and were actively revising their procedures to

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eliminate the identified deficiencies.

A schedule for completion of these activities had not been established at the time of this inspection.

(2) The examination of the DC/DDAs and CMCs revealed that these two documents are being used for the following:

(a) Design changes initiated by the original design crganization.

(b) Field design changes resulting from interference problems.

(c) Design changes resulting from Nonconformance Reports (NCR) issued as a result of a construction error, an error in a vendor supplied item, construction damage, etc.

(3) The inspector was unable to determine from the DC/DDA and CMC forms that changes resulted from an NCR.

The NCRs presented to the inspector for examination did indicate that the disposition was via a particular DC/DDA.

With respect to NCRs, management representatives stated that a trend analysis program is under development. The initial areas to be covered are welding and records with additional areas to be identified later.

(4) Personnel approving DC/DDAs and CMCs had been properly authorize o

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(5) Although approved by authorized field personnel, CMCs No. 12921, 13138, 13149, 13183, and 13508 had not been design reviewed by the original design organization at the time of this inspection.

Time did not permit the verification of original design organization review for CMCs No. 10812, 10832, 10843, 10857, 10877, and 10929.

b.

Noncompliances None identified c.

Deviations and Unresolved Items None identified

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d.

Follow-Up Items t

A reinspection of the design change control activities shall be scheduled at a future time dependent upon completion of procedural revisions and their implementation.

C.

Managenient Interview An exit interview was held by the RRI with management representatives (denoted in paragraph A) on February 19, 1980.

The RRI summarized the scope and findings of the inspection.

Comments were generally for clarification only, or acknowledgement of the statements by the inspector.

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