ML20092N531
| ML20092N531 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/29/1984 |
| From: | Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| LBP-84-8, NUDOCS 8407030248 | |
| Download: ML20092N531 (62) | |
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UNITED STATES OF AMERICA 84 JUL -2 P 2 :20 NUCLEAR REGULATORY COMMISSION ll BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;
In the Matter of . ) f
) i TEXAS UTILITIES ELECTRIC .) Docket Nos. 50-445 !
COMPANY, et al.
) 50-446
. )
(Comanche Peak Steam Electric ) ;
Station, Units ,1 and 2) ) {
5 APPLICANTS' RESPONSE CONCERNING RECORDS RETRIEVAL I. INTRODUCTION [
On-January 30, 1984, the Licensing Board in the i captioned proceeding ' issued a Memorandum- ( Records .I
- Re trieval) , LBP-84-8, in which the Board disclosed its :
thinking about the adequacy of the record regarding "the computerization of certain deficiency records for construction and the adequacyc of the system for retrieving [
and utilizing these deficiency records." LBP-84-8 at 1. ,
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i In order to be fully responsive to matters we perceive to Ima of concern to the Board, we are filing along with this :
Memorandum a report' entitled " Records and Records I f
Retrieval." The Report, which is supported by affidavits, !
' provides evidence of how various types of records at t Comanche Peak are used,'and we ask that the Board receive i
it. ;
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70 248 840629 !
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0-K 05000445
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4 5 5 This response addresses specifically several issues regard.,J records and records retrieval which apparently I are of concern to the Board. It is based on the accompanying Report as well as on certain testimony t already before the Board. For the convenience of the Board and other parties, we have appended to the Report a ,
glossary of significant terms.
II. RESPONSES TO BOARD CONCERNS '
A. Utilization of Punchlists at CPSES In LBP-84-8 at 2-4, the Board referred to testimony by certain TUGCO and NRC witnesses and to an NRC Staff report of the final walkdown inspectione of the fuel building. In doing so, it suggested the following ;
questions concerning the use of punchlists at CPSES:
- 1. Does the use of punchlists attached to f inspection reports constitute compliance with 10 C.F.R. 50, Appendix XVI?
- 2. Why are punchlists not trended?
- 3. Why is there no procedural control or t historical record for punchlists?
Each of these questions is addressed below.
Criterion XVI. There are two types of punchlists in use at Comanche Peak, viz., inspection punchlists generally associated with a walkdown, and punchlists of ,
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. remaining work. The type to which the Licensing Board referred was an inspection punchlist; in particular, the Electrical Separation Deficiency Report.1 Use of the Electrical Separation Deficiency Report satisfies the requirement set forth in Criterion XVI that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and reported.
Deficiency repcrts are only one way it is satisfied at CPSES. Other ways Criterion XVI is satisfied include the use of irs and NCRs.2 Trending of Punchlists. Although the Electrical Separation Deficiency Report was used to identify items requiring correction as required by Appendix B, Criterion
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XV, Applicants did not trend this list. Applicant's approach to satisfying separation requirements was to perform both in-process and final inspections, with final inspections scheduled after areas or buildings were completed. This practice acknowledged the possibility that rework to assure correct separation at the end of
-construction could be required. Nevertheless this
. approach was considered to be more practical than 1
See Section Sections E.2.c. and E.2.e. of " Records and Records Retrieval" (" Records Report") .
2 ESA Sections E.2.b., and E.2.d. of Records Report.
r-attempting to maintain separation during bulk construction.3 Under these circumstances formal trending to determine the cause of incorrect separation and to prescribe corrective actions to preclude repetition was ;
unnecessary.4 The other type of punchlist used at Comanche Peak is not a quality related document. Rather, it is a list of outstanding work items required to complete the plant.5 There fore, Appendix B does not apply to these punchlisto.
Procedural Control or Historical Record. To respond fully to the Licensing Board's inquiry regarding the lack of procedural controls or historical records for ;
punchlists, it is egain necessary to distinguish between the Electrical Separation Deficiency Report, which is procedurally controlled and for which a historical record exsits, and other punchlists. The punchlists to which the Staff referred in Inspection Report 50-445/83-23 were the Construction Punchlist, the Completions Punchlist and the ,
l Master Punchlist. There are administrative directives 3 See, Hearing Transcript ( "Tr . ") at 7 884-88.
4 In response to,a request from NRC, Applicants have since begun formally to trend Electrical Separation Deficiency Reports. Tr. at 8539.
5 Records Report at E.2.e.
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governing these punchlists. These punchlists are not :
quality related records and do not fall under the scope of !
Appendix B.6 f B.- TUGCO's Purpose in Installing a Computer System for irs at CPSES In LPB-84-4, the Board at 3 noted that TUGCO's purpose in installing a computer system for irs did not appear in the record. That purpose is explained below.
First, TUGCO did not install a computer system for irs. Rather, it began to use existing computer facilities for this purpose. The computer services and facilities described in Section D.1 of " Records and Records Retrieval" are used to support a variety of construction and operations activities at CPSES. TUGCO's purpose in using these services and facilities for open irs was to establish a more efficient method of scheduling activities.7 The computer index as it was set up and is-being used today effectively enables open irs to be tracked and their status determined in a timely manner.
ASME irs continue to be logged, tracked, and closed using a manual system.8 i
6 Section E.2.e. of Records Report. !
7 Affidavit of Ronald G. Tolson Regarding Computerization i of Non-Conformances ("Tolson Affidavit"); October it , l 1982, at 2. i 8 Section E.2.e. of Records Report. ,
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6-C. Handling of Inspection Reports In LBP-84-8 the Board at 3-4, referring to Staff testimony,' raised several matters concerning the manner in which irs are handled at Comanche Peak. Those questions are as follows:
(1) Are irs properly dispositioned at CPSES?
(2) Why are hold tags not used for ira?
(3) Why is TUGCO engineering approval of "use-as-is" for an IR item not stated in writing?
Dispositioning of irs. irs are used to record the results of field inspections performed by QC personnel.
The results of these inspections are classified as either satisfactory (" sat") or unsatisfactory ("unsat") . A satisfactory (or closed) IR indicates that the subject of the inspection complies with al'1 design and construction requirements. Such an IR completes'the construction and inspection loop and documents work completion and acceptability.9 It is retained in the Permanent Plant Records Vault and will be permanently stored in the Operations Vault.10 An unsatisfactory or open IR is used to document that the component or area being inspected at that point in time requires additional work to satisfy design and 9 See Section E.2.b. of Records Report.
10 See Sections D.2.c and d. of Records Report.
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construction requirements.- There are several methods of closing-aa unsatisfactory IR. The required work can be completed or restored to design requirements following established procedures so that the status of the IR can be changed from unsatisfactory to satisfactory.
- Alternatively, Engineering can issue a CMC or DCA
' documenting its conclusion that an item reflected on an open IR can be used as is. Lastly, the QC inspector can
- issue an NCR .for engineering evaluation and in so doing close the unsatisfactory IR.Il This practice satisfies Criterion XV o f Appendix B, -which requires that measures be established to control materials, parts, or components
, which'do not conform to requirements in order to prevent their inadvertent use or installation.
The 'Use of Hold Tags. It is common practice in the nuclear industry to affix hold tags to nonconforming items g identified through the inspection process. Typically, the use of such tags is designed to provide a visible status
, i indicator. The use 'of' hold tage:is useful in connection with materials failing to meet all applicable requirements
.in order to assure that they are not inadvertently used in construction.
d
. 11 M Section E.2.b. of Records Report.
The use of hold tags, however, is not a regulatory requirement. ANSI N45.2 Section 15 (1971) states, as follows:
[T]he inspection and test status of items shall be maintained through the use of status indicators such as physical location and tags, merkings, shop travelers, stamps, or inspection records. The measures shall provide for assuring that only items that have passed the required inspections and e tests are used, installed or operated.
IRg are used for field inspection of fabricaied and/or installed materials. The QA program requires a records verification during which all applicable irs are closed.
Only after this verification is complete will the particular structure, system c.. component be " operated."12 There fore, irs serve the same purpose as hold tags in that until they are closed, the subject of the IR, cannot be operated.
Use-As-Is Approvals for irs. There is apparently a m inunderstanding as to the procedures followed concerning approvals by Engineering which permit an inspector to close an IR by using a component or area "as-is." When an unsatisfactcry IR is written, craft may request an engineering review. If Engineering concludes that the component or area can be used "as-is," it will prepare and sign a CMC or DCA documenting this conclusion. The CMC or 12 333 Section E.2.b. of Records Report.
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i DCA acts as the documentation of Engineering's approval to r I
use-as-is. Upon reinspection the IR will be changed from ,
unsatisfactory to satisfactory because the as-built I
-condition will conform to the as-designed condition.
Through this process, Engineering documents all approvals to use as-is a component or area noted on an IR as i unsatisfactory.13 D. Board's Site Visit and I Effort at Records Retrieval In LBP-84-8 at 1-3, the Licensing Board discussed its effort during a site visit to pull onto a computer screen an example of a nonconforming condition that had been detected in an inspection report. The Board then summarized its view of the record regard.ing use of the L
computer system at Comache Peak. L Site Visit. The actual work record at Comanche Peak consists of paper records which are not themselves on the computer system. To retrieve these records, various ,
indices and filing methods are used.14 In the case of NCRa, the index of open items has been computerized via the NCR Tracking Data Base and the index of closed items i has been computerized using A.R.M.S.15 F
E 3 See Section E.2.b. of Records Report. ;
14 Section D of Records Repor t .
15 Section E.2.d. of Records Report.
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Because the Board's request when it visited the site made reference to both the computer and an NCR, the clerk
, apparently interpreted.it as a request to demonstrate computer retrieval of the NCR index entry, not the retrieval of the actual NCR document.16 The January 30 Memorandan indicates that the clerk's interpretation may ,
have been inappropriate in that the Board apparently wanted the clerk to " pull onto the [ compt:ter] screen an unresolved nonconformance."17 As discussed above, such documents are not in the computer system.
In addition, because it was not clear whether the request was for a demonstration of the computer indexing capability of opened or closed NCRs, it is understandable that the Board was left with questions regarding the computer system.
To demonstrate the computer indexing capability of open NC Rs , three criteria have to be satified:
- 1. An authorized password must be used by an individual trained to access the NCR Tracking Data Base.
- 2. A terminal connected to George II/III must be used.
16 See Applicants' September 14, 1984, letter to the Board .
17 LBP-84-8 at 2.
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- 3. The computer programs operating the NCR Tracking data base must be' operational.18 Since the Permanent Plant Records Vault (which the Board i visited) does not receive NCRs until after they are closed
- and has no responsibility for retrieval of open NCRs, no !
.one on the PPRV staff has a password Which can access the f I
. NCR Tracking data base. Likewise, both' computer terminals [
-located in the PPRV, although identical to those Which access George II/III, cannot access George II/III since !
thAy~are connected'to the Operations Computer.19 All of j i
- these criteria would have been met if the Board's tour had i
-been directed to the appropriate NCR Coordinator rather than conducted at random.20 l I
.T To demonstrate the computer. indexing capability of [
closed NCRs, three criteria must be'satisifed:
{
'l. Ars authorized password must be used by an individual trained to access A.R.M.S.
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- 2. A terminal connected to the Operations Computer must be used.
l 3.' The computer programs operating A.R.M.S. must be operational.21 ;
18 .Section-E.2.d. of Records Report. l
- 19. See Fig. D-1 of Records Report.
I 20 Backup printouts for the NCR Tracking Data Base are !
also available through the NCR Coordinator in the !
event that the appropriate computer programs are not .
op' e rational. [
21 Sections- E.2.d. and E.4.a. of Applicants' R<eport.
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- 12 At the time of the tour, the'A.R.M.S. programs were not operational. Therefore, retrieval of closed NCRs was
. dependent on the backup system of going to the PPRV and pulling the paper record.22 State of the Record. The Licensing Board concluded in LBP-84-8 that Mr. Tolson's initial explanation regarding the computer system was incomplete. This observation does not appear to account for the fact that the. example being used to discuss records flow (electrical conduit separation) was a poor example of normal records processing 23 and that this example was being addressed hypothetically, in any event.24 Moreover, the Board apparently has equated testimony regarding Criterion XV with testimony regarding Criterion XVI. The Board cites Mr. Treby's cross-examination as designed to elicit whether the use of punchlists attached to irs satisfies Criterion XVI.25 In fact, that cross-examination begins at Tr. 8534, where Mr. Treby asks Mr.
22 See Section E.2.c. of Records Report.
23 Tr. 8548, 8550.
24 Tr. at 8537.
25 LBP-84-4 a t 1-2 citing Tr. at 8537.
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Tolson how punchlists are used to identify, evaluate and
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resolve non-conformances. This question suggested to Mr b
Tolson that Mr. Treby was addressing Criterion XV.26 ;,
E. Adequacy _and Reliability of Manual Records at CPSES
- In LPB-84-8, the Board at 3-5 referred to certain NRC f l
Staff witness testimony and raised questions concerning '
the adequacy.and reliability of manual records at CPSES. i JMun Board apparently also did so based on an NRC '
Inspection Report. Neither of these bases raises questions regarding the adequacy and reliability of manually tracked records.
The Inspection Report to which the Board referred i discusses a difficulty encountered with using the computer which occurred when site personnel attempted on an l experimental basis to expedite their task using the A.R.M.S. output. After it became evident that this was i not the most efficient way to complete their task, the !
task was completed' manually. The NRC Inspection Report i
did not . include any findings that there was a lack of success using the computer system.27 i
26 Compare this discussion with Tr. at 8538-39 regarding the trending of punchlists.-
27 See NRC Inspection Report 50-445/83-24 aa d 50-446/83-13~at 11-13.
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P In addition, Mr. Taylor's testimony cited by the l Licensing Board on page 5 of LBP-84-4 concerned the error !
i rates of inspectors actually performing an inspection, not ,
the reliability of manual records. Similarly, his testimony cited at page 4 of LBP-84-8 does not bear on ,
manual records under the purview of Appendix B. Mr.
Taylor was addressing the accuracy of the construction punchlist obtainable from the computer system. As i discussed earlier, this punchlist is not governed by ;
' Appendix B.28 ;
F. Adequacy of CMC Records at CPSES In LBP-84-8, the Board at 4, referring to certain ,
i testimony by. Mr. Taylor, noted a concern regarding the ;
r adequacy of CMC records at CPSES. Mr. Taylor stated !
clearly in his testimony that while there may be a large nunber of CMCs, there was no loss of document l
' accountability.29 In any event, CMCs are properly tracked !
at Comanche Peak through two, data bases, the "DCC:DB" and t the " DCA: DB . " Both of these data bases are described in I Applicants' Records Report.30 I 9
l-28 See Section E.2.e. of Records Report.
29 Tr. at 8959.
30 See Section E.4.b. of Records Report. I h
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v, III. CONCLUSION Applicants believe that these responses address fully matters identified by the Board in LBP-84-8. Accordingly, Applicants submit that the record regarding these concerns demonstrates that records and records retrieval are adequately maintained at Comanche Po k.
Re spectful submitted, j
Nichol Reynolds Sanfor ( S./
BISHOP,p.,hartman LIE qRMAN, COOK,
,, PURCE 1 &JREYNOLDS 1200 Seventeenth Street, N.W.
Washington, D. C. 20555 (202) 857-9817 Counsel for Applicants
' June 29, 1984 I
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4 TEXAS UTILIITES GENERATING COMPANY COMANCHE PEAK STEAM ELECTRIC STATION RECORDS AND RECORDS RETRIEVAL June 29, 1984 3
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4 TABLE OF COIFFBIFFS Page A. Introduction . . . . . . . . . . . . . . . . . . . . . 1
- 8. Overview of Quality Aswurance organization . . . . . . 3
- 1. Construction Quality Assurance /
Quality control . . . . . . . . . . . . . . . . . 3
- 2. Vendor Compliance . . . . . . . .. . . . . . . . 4
- 3. Quality Assurance Serviceo . . . . . . . . . . . . 5
- c. Overview of Organisation for Constructing CPSES . . . 5 D. Computer and Record Related Support Services and Facilities . . . . . . . . . . . . . . . . . . . . 7
- 1. On-Site Computer Services . . . . . . . . . . . . 7
- a. Data Processing Facilities . . . . . . . . . 7
- b. Computer Cata Integrity . . . . . . . . . . 9
- c. Computer Data Base Validation . . . . . . . 11
- 1. . Checks for Keying Errors . . . . . . . 11
- 2. 1004 Match of Manual Log a nd Computer Data Base . . . . . . . . 11
- 3. Activity Report to Record Comparison . . . . . . . . .. . 11
- 4. Electronically Linked Computer Data Bases . . . . . . . . . . 12
- 5. Records Monitoring Group . . . . . . . . . . . . . . . . . 12
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- 2. Record Centers. ................. 12
- 4. Document Control Center --
Construction . ............... 12
- b. Balance of Plant Vault . .......... 14
- c. Permanent Plant Record Vault . ... ... . 14
- d. Operations Vault . . .... ........ 15 ,
i E. Recorde Flow Progress ...............; 15
- 1. Introduction .................. 10
- 2. Recorde Flow During Construt tion .. ...... 16
- 4. Introduction . . ............. . 16
- b. Inspection Reports . ...... ...... 18
- c. Electrical separation Deficiency Report .... .... .... . to
- d. Non-conformance Reporte .. .. ...... 21
- e. Master Data Base . ............ . 24
- 3. Recorde Retention . . . . . . . . . . . . . . . . 26
- 4. Recorde Retrieval . . .............. 26
- a. Automated Recorde Management System ( A.R.M.S.) Data Base ..... .. . 26
- b. DCA and DCC Data Bases . . ........ . 28 01oesary of Terme
A. Introduction Texas Utilities Generating Company (TUGCO) is responsible for engineering, design, procurement, construction and quality assurance activities and will 4 operate the Comanche Paak Steam Electric Station (CPSES)
(FSAR, Section 17.0) . Gibbs & Hill (G&H) is the
-architect / engineer and Westinghouse Electric Corporation is the nuclear steam supply system supplier.
As shown in Figure A-1,' TUGCO is functionally divided into " Engineering and Construction" and " Operations" components for - the purpose of constructing and operating
'CPSES. TUGCO Engineering ~and Construction has assigned its. Construction Management ' organization responsibility for plant construction.. TUGCO Operations is responsible <
' for. plant operations following completion of construction a well as qudlity assurance for CPSES during construction.
As required by 10 C.F.R. Part 50, Appendix B, Criterion I,
. quality [ assurance is organizationally independent of-construction and has independence.from cost and schedule.
, s An' understanding'of how donstruction work is carried
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'outL at Comanche Peak through the~ Construction Management organization 1(iliustrated in Figure A-2) is essential to an understand [ng of document distIibution and records t
retrieval. The Construction Management organization includes the following: '
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i Figure A-1 !
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i TUGCO Functional Organization i
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l TEXAS i UTILITIES i GENERATING {
COMPANY !
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ENGINEERING f i
OPERATIONS &
CONSTRUCTION [;
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l i , COMANCHE PEAK !
l PLANT QUALITY CONSTRUCTION MANAGEMENT l OPERATIONS ASSURANCE (See Fig. B-1) . (See Fig. A-2) i I
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i Figure A-2 l i
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CPSES Construction Management Functional Organization j COMANCHE PEAK i CONSTRUCTION MANAGEMENT.
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l t PROJECT BUILDING ENGINEERING CONTROL / I W AG E NT MANAGEMENT PROCUREMENT
. ORGANIZATION MANAGEMENT (See Fig. C-1) 3 i 1 i PROJECT
- MANAGEMENT DOCUMENT l CONTROL CONTROL l SYSTEMS CENTER I
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o Engineering Management -- a TUGCO organization responsible for managing engineering activities.
o Buildi.sg Management Organization -- a TUGCO project organization created to facilitate construction and completion of major areas of the plant such as the reactor and auxiliary buildings.
o Project Control / Procurement Management
-- responsible for, among other things, the Document Control Center (Construction) which receives, processes,-distributes, and stores certain construction and design
, documents and the Project Management Control Systems which is responsible for operating computer systems which support. construction activities on site.
TUGCO's Quall'y t Assurance organization is discussed in Section B. TUGCO's Construction Management organization is discussed in Section C. Important computer and record related support services and facilities are described in Section D. These discussions provide the framework for the discussion in Section E of how work is documented and how this documentation is retained and retrieved. The scope of these discussions is l
congruent with inquiries suggested by the CPSES Atomic Safety and Licensing Board in its January 30, 1984, Board Memorandum (Records Retrieval), LBP-84-8 ("LBP-84-8").
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B. Overview of Quality Assurance Orgenization TUGCO's Quality Assurance organization is illustrated in Figure B-1. It is responsible for site construction quality assurance and control; vendor compliance; and quality assurance services, which include quality !
assurance audits, QA program review, and training. This -
organization has primary responsibility for providing quality assurance for CPSES (including the programs of the j vendors and organizations participating in the design and construction of CPSES) as described in Chapter 17 of the i
FSAR.
For purposes of responding to questions raised by the Board concerning document distribution and retrieval, only the site construction quality assurance / quality control, 1 vendor compliance, and quality assurance services components of the quality' assurance organization are i
relevant. These are the only components of the QA l organization directly involved with records of the type discussed in LBP-84-8. Each of these components is discussed below. ;
- 1. Construction Quality Assurance /Ouality Control TUGCO has overall responsibility for quality -
assurance / quality control activities during the l i construction phase at CPSES. This responsibility has been implemented through direct (No n-ASME) and indirect (ASME)
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Figure B-1 !
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TUGCO Quality Assurance Functional Organization f
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TUGC0 j QUALITY l ASSURANCE ;
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i I SITE VENDOR CONSTRUCTION QUALITY QUALITY ASSURANCE COMPLIANCE ASSURANCE / SERVICES ,
QUALITY CONTROL t
7_._______.____ ,
PERMANEhT ASME SCOPE PLANT RECORD OPEN PLANT BROWN & ROOT VAULT RECORD VAULT (PPRV) c :
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management of the quality assurance / quality control functions, as ' described in Chapter 17 of the FSAR.
Functional responsibilities assigned to the TUGCO site construction quality assurance organization include direct management of completed quality assurance records (both Non-ASME and ASME) . These records are stored in the Construction Permanent Plant Records Vault (see Section D). TUGCO Construction Quality Assurance also monitors the statusing and . tracking of incomplete Non-ASME Linspection records, which.are temporarily stored in an area referred to as the Open Plant Records' Vault or within
-the Building Management Organizations (see Section C).
2._ Vendor Compliance The. vendor eompliance group performs in-process and L
release inspections at the facilities of vendors providing safety-related components for CPSES. These vendor control-activities are in. addition to the quality control services required to be.provided'by the vendor (and as verified by
.the TUGCO audit function). As part of .these ' inspection
' activities, TUGCO vendor coinpliance personnel verify that vendor documentation (required by the procurement f pecifications) is complete and available to accompany a vendor's product to the CPSES project site.
- 3. Quality Assurance Services ;
I Quality assurance services is responsible for, among other things, auditing design and construction compliance activities. Design audits are performed both on site and at the offices of the Architect / Engineer or other .
contractors providing design services. It is also responsible for qualifying vendors, reviewing vendor <
quality assurance program manuals and performing vendor audits to-verify conformance to applicable requirements.
Each of these audit activities includes verification that required documentation is being maintained.
C. ' Overview of Organization for Constructing CPSES ,
Construction activity at CPSES (Unit 1) is being managed by up to four TUGCO Building Management Organizations (BMO) to facilitate completion of major portions of the plant.1 The four BMos are:
- 1. Reactor Building ,
- 2. Auxiliary Building
- 3. Safeguard and Diesel Generator !
Buildings
- 4. Electric Control Building and all other buildings and areas A typical BMO structure is depicted on Figure C-1.
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1 Prior to creation of the BMOs, construction activity at CPSES was managed on a plant wide basis by the Area Management Organization. A* work progressed and major plant structures neared completion, the BMOs replaced ;
Area Management as constructi' . or completions manager. l
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i Figure C-1 !
Typical CPSES Building Management Organization SITE COMANCHE PEAK CONSTRUCTION l CONSTRUCTION QUALITY MANAGEMENT ASSURANCE /
QUALITY CONTROL ,
l BUILDING MANAGER PLANNING PAPER FLOW SCHEDULING ENGINEERING CRAFT QA/QC
, GROUP l ADMINISTRATIVE I
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. _ . . _ . _ . _ . _ . , _ . . . . . _ . _ . _ , _ . . . . . _ _ . _ , . . _ . . _ . . _ . . - . _ - . _ . - _ ~ _ . . _ _ _ . .
f Each BMO is headed by a Building Manager. Reporting to the Manager are the following groups:
- 1. Planning / Scheduling / Administrative
- 2. Paper Flow
'3. Engineering
- 4. Craft The Planning / Scheduling / Administrative Group monitors L
construction progress and schedules work assignments as
.well as provides general administrative support. The .
Paper Flow Group (PFG) is responsible for preparing or obtaining, assembling, routing and tracking the documents required to perform work assignments in accordance with the established, approved project procedures. The Engineering Group provides the field engineering services needed for the completion 'of work assignments. The Craft Group performs the construction work needed to complete '
the various assignments.
TUGCO Quality Assurance has assigned certain of its representatives responsibility for the QA/QC work pertaining to each BMO. The Building QC organizations report to QA/QC Management and not to Construction Management.
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i D. Computer and Record Related Support !
Services and Facilities The record of work completed at CPSES consists of I paper records, some of Which have been photographed and reduced to microfilm for convenient storage. Retrieval depends on filing methods and indices. Some of the indices are manual (e.g., manual logs). Others are computerized. This section discusses (1) the computer (data processing) services used to index these records and r
(2) the facilities Where records are retained. The role i
of _these computer and records retention facilities in terms of records flow, retention and retrieval is ,
discussed in Section E.
- 1. On-Site Computer Services
- a. Data Processing Facilities At CPSES certain data processing-facilities are 3 used to support construction. Others are used to support operations. The facilities are illustrated in Figure D-1.
The computers supporting construction activities are operated by TUGCO's Project Management Control Systems i
(PMCS) organization.
The computer Which supports ;
1 operations (including its maintenance activities) is operated by TUGCO Operations and is located in a different ,
building from that housing construction computers. ,
Terminals Which access these computers are located at various work areas around the site, but they can access I
, .,.n- , --,--,-n---
s - + s._ 6 .+ -m
' Figure D-1 CPSES Computer Equipment Configuration i Construction Activities Support Operations l l terminals l l Data Genecal 350 l (George I)
I q l peripherals
- I 4
i I i
I
- terminals terminals
- l i l
) Data General 8000 Data General 8000 l j (George II) (George III) terminal i l i
i i
peripherals l
! l
. I I
l 1
- terminals Data General 8000
- I 1 I I l l I l peripherals terminals i l 2
- 0
{
I only.that computer to which they are connected. All I 4
terminals illustrated in Figure D-1 connected to the ,
computers (both construction support and operations ,
support)' are identical. Terminals connected to the l construction computers, however, cannot access the operations computer and'vice versa. '
Wue construction computers consist of a Data i General 350 (George I) and twin Data General 8000's (George II and George III) with associated terminals, tape
' drives, and' disc storage as shown. George I (accessed r
only by PMCS) is used primarily for program development l i
and keypunching. It is also used by PMCS keypunchers to [
type-data to be processed on other on-site computers when-this is requested. In this circumstance, the. tape prepared on George I is-physically transferred to George II or III or to the ~ operations computer (see below) .
I George II and George III are used to maintain and process administrative, engineering,. financial, procurement, -
construction and quality. assurance data associated with ;
-construction.
The' data processing load is distributed
' between' these computers each of which is capable of operating any of the programs. High speed printers, disc i storage and tape drives (i.e., peripherals) are shared.
I Terminals located around the site are used both for data entry and retrieval. i L ;
P
- , - , * , m----,r- , y - e-,-.e-, p- -
up-=v,c. ---wet----,rr --,,,-w.--ser,-vv -~n-- r- -g-y------e- --es---
9-The operations computer, formerly a Data General 330 and now a Data General 8000 with associated peripherals serves the needs of the operations staff. It ,
processes maintenance, scheduler, personnel, financial, ,
and other data associated with operations. It also processes certain computerized quality assurance data in the Automated Records Management System (A.R.M.S.)2
- b. Computer Data Integrity l
The integrity of the computer systems used at l'
CPSES is assured by computer security measures Which prevent unauthorized changes to programs and data.
Physical security is provided by locating computer [
hardware (with the exception of terminals and designated printers) in secure facilities that are protected to reduce the risk of damage by fire, heat, humidity, and dust. Access to these facilities is restricted to a small number of data processing operators. Terminals and designated printers are located in office areas which are subject to the physical controls provided for each area. ,
Access to the construction computers (George Il and III) is controlled by PMCS. PMCS uses CSCRIPT, a security program, to limit access to the various data bases in accordance with instructions and procedures of the organization responsible for each data base. It 2 A.R.M.S. is discussed below in a ,3nection with Site Construction Quality Assurance, t
- - . - , , - - - , . , --w -..- - , ,, _ . . , , , , , , - - , - - - . ,m - ,w - - ,
l 1
i i'
provides numerous levels of security. CSCRIPT can limit
?
access by a given user (password) to specific data bases l
l or portions thereof, to certain rights for handling data l (e.g., read'only, update only), to specific portions of l
computer records, or to combinations of these limitations. ,
The same CSCRIPT controls can also be applied to specific [
i terminals.. When a password is used to access George II and/or -III, it is compared to the profile (access ,
i f
- f. - limitations) programmed into CSCRIPT for this password.
l Jut exact match is required before processing can proceed.
- Administrative policies provide additional -
security. PMCS policies require that only the l
f<< organization responsible for a particular data base (i.e., I i
the data: base " owner") can authorize the-PMCS administrator to change programs or CSCRIPT security
? .
profiles. They also require the owner to establish a list [
of' people authorized to request. printouts. Authorized ;
i individuals must sign for requested printouts. The
=
- deletion of a password .from' CSCRIPT effectively denies access to those no longer authorized. !
To assure maintenance of computer data bases and i
programsDin the event of a computer system failure, L c ,
duplicate safeguard copies are made regularly and stored lon magnetic tapes.- -Access to these duplicates is [
t i
restricted to PMCS. '
i >
b k
t -M., , -,-c.- - -
, , , - , . n, . . , , , , , , , , _ . , , _ . _ _ . _ , _y,._..,y,_p.__s ., , , , . , . , , , . . , , , . , _ _ _ , .
.,%,.-,_g, , _ ,,_,...r-=- e c re m s*
- c. Computer Data Base Validation Validation that information has been entered into'a data base accurately is the responsibility of the originating organization. Validation is accomplished in a number of ways, including the following:
- 1. Checks for Keying Errors
. Programs are designed to check for certain types of keying errors. When the operator is advised of a keying error the system will not allow the operator to
_7 continue until the error is corrected.
- 2. 100% Match of Manual Log and Computer Data Base Manual logs have been, and in some instances' continue to be, kept to index records at CPSES.
When a manual log is converted to a computerized data base, a one-to-one comparison is made of each element of the manual log and the computer data base.
- 3. Activity Report to-Record Comparison Activity reports (printouts of changes made to a computer data base during a specified period) are compared to the actual documents to validate the accuracy of changes made to the data base, i.e., to assure that the computer data base matches the record.
l L
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- 4. Electronically Linked {
Computer Data Bases !
~Certain related data bases (e.g., the !
. - ?
"DCC:DB" and "DCA:DB" data bases discussed in Section
-E.'4.b. of.this Report) are electronically linked so that a f change in one is automatically flagged in the other. !
- 5. Records Monitoring Group [
.The construction management organization '
includes a records monitoring group which spot-checks
^
computer index information against items in controlled records packages-in various records centers discussed
\
,below.-
l
. ir 2. Record' Centers
-[
-l There.are four record centers at CPSES which maintain ,
r
-the paper an'd microfilm records pertaining to construction I
[
and ope' ration of CSPES. These four record centers, the t
Document . Control Center - Construction, the Balance of i IPlant Vault, Ethe Permanent Plant Record Vault, and the j Operations Vault, are discussed below. ;
- a. Document Control Center - Construction i
The Document Control Center - Construction is i f
' responsible forscontrolling instructions, procedures-and f
drawings 1 required for plant construction. The DCC i
I I
k' i
, , - . . - - , . - . - . . .--.- _ . ,-,_,-...-,-,-..~---,,,,,,-.-....-_..--,,,--I
~
- 0. . '.
.13 - ;
)
(hereinafter referred to aus "DCC-Construction"), is part i
of the Project Control Procurement Management organization
- ('see Figure A-2).3 l
~
l The types of documents maintained by DCC- l Construction include the following: I
- 1. Drawings in microfilm aperture ,
card form; .
- 2. Specifications;
- 3. Construction procedures and a instructions; '
- 4. Vendor equipment instruction j manuals; ,
- 5. ' Design Change Authorizations i (DCAs);4 :
- 6. Component Modification Car'ds .
(CMCs).S In August, 1983, five DCC-Construction satellite i controlLcenters.were established to support more '
efficiently design, construction and inspection !
activities. These-satellite centers are primarily l
. discipline-oriented. Each separate center is devoted, !
with some overlap, to a different discipline, i e., civil, . ,
3 The DCC-Construction.should not be confused with the Document Control Center, commonly referred to as the [
Operations Vault, which is a part of TUGCO' Operations. l See FSAR, Section 17.2 and Section D.2.d. of this ?
Report for a discussion of the function of the .
. operations Vault. i 4 See Glossary for a description .of the purpose of DCAs.
i f
35 133 Glossary .for a description of the purpose of CMCs. )
l
~ , . - - _ . , , . . , , . _ - - . . . . . , , . . . . . .....-.c_.__._,...... %,. ...__,,,___._,,y,_...,,--, , , - . , ,
?
r P
I r
i electrical, instrumentation and control, mechanical and I
, pipe support. The satellites contain only copies of
' documents-distributed to them by DCC-Construction to [
i support the disciplines they service. ,
b '. Balance of Plant ' Vault l The Balance of Plant '(BOP)6 Vault receives, [
i indexes and stores documents generated during the j construction' of 'CPSES pertaining to non-safety related !
i components. This ' group _ is part of the construction f
organization.. i
- c. Permanent Plant Record Vault f t
The Permanent Plant Record Vault (PPRV) is a !
i TUGCO Quality Assurance facility Which serves as the prime l
.' repository for documents generated during plant l l' construction that reflect the actual conditions of-i completed construction or manufacturing activities for j safety relatedistructures, systems or components. Such I L (
- records are' referred to as verification records and are stored.in the PPRV. 'The PPRV is the prime data collection point.for the Automated Records Management System
.(A.R.M.S.)7 and is also the checkpoint'for the i
I ~6 Balance of Plant (BOP) as used by TUGCO in this context !
l refers to non-safety related systems and components l throughout the plant Which do not require QA/QC l inspection.- !
7 ' air.M.S. is discussed in Section E.4.a. of this Report.
, a . :. . . c _ _ _ . - - - , ~ . _ _ - , _ . . _ _ _ _ . _ _ _ _ . _ . . _ _ _ . , _ . . _ _ _ . _ . , . _ , . _ _ '
accountability _ of records prior to plant operation. PPRV records will~ eventually be turned over to the Operations
. Vault.
- d. Operations Vault The Operations Vault is in a permanent structure located on the southern side of the CPSES site. The Operations Vault is also known as the TUGCO Operations Document Control Center and is referred to as such in the FSAR. The Operations Vault is independent of the DCC- ,
Construction and its satellites which support construction activities. The Operations Vault will be the ultimate repository of records during the operational lifetime of the plant (except permanent plant drawings which will be retained by the cognizant engineering organization).
TUGCO currently. is in the process of transferring records generated during the manufacturing and construction phases to the Operations Vault.
E. Records Flow Process
- 1. Introduction An overview of the records flow process at CPSES is shown.in Figure E-1. Design-is initiated in engineering.
The resulting design documents (e.g., drawings) are transmitted to the Document Control Center-Construction i i
for distribution. Copies are distributed to the appropriate DCC satellite which acts as the control point.
/
Figure E-1 CPSES Work and Records Flow Process 4
PERMANENT l PLANT REC,0RD VAULT.c i
/\
/ N/
\ /\
) N/
' \ \ BUILDING ENGINEERING DOCUMENT
/ MANAGEMENT l
/ CONTROL CENTER ORGANIZATION i
i 4
1
\/
BALANCE OF
"" ~~
i PLANT VAULT l
4 i
i i
%/
1
) g/ gy g g OPERATIONS VAULT j 7 7 I
i 6 4
- ....-.-...m. _ . , _ . . . _ _ . . , ._....____...._m.. . _....._., ,..,_. . .m.__..._,_, - - . . _ - _ ,
l L
+. l f
t The various organizations which are responsible for I
[
activities supporting plant construction gather the documents required to complete the work. Upon completion of the work activity, records are distributed to various 4
records centers and control points. ;
I
- 2. Records Flow During Construction f
- a. Introduction ,
Drawings, specifications, procedures and design {
i change information required for construction are developed !
by TUGCO's architect engineer, field engineers and/or equipment-vendors. This information is transmitted to DCC-Construction which is responsible for the control and
[
eventual distribution of this information to those t
~
responsible for construction and' inspection.
Upon receipt of documents by DCC-Construction.
informa' tion such as document number, title, revision, etc., is entered.into appropriate indices. After the !
indexing information is entered, the dccuments are ?
-prepared.for filing. Specifications, procedures and ;
. instructions, correspondence, Design Change Authorizations [
(DCA), and Component Modification Cards (CMC) are filed ;
numerically. Drawings ~are microfilmed and their aperture ,
cards are filed by' drawing number. Revisions to drawings
{
are processed and filed in the same manner.
f
r The DCC satellite centers do not have any of the original documents stored in DCC-Construction. Copies of l main DCC documents are made and distributed to the satellite centers to support the work they service. The satellites maintain logs of each document or document I
package issued for' construction thus providing a means to [
- update the-documents in the event subsequent design ;
changes ~are required.
Comanche Peak's Construction Management :
organization is responsible for construction planning and
. scheduling.' consistent with scheduled milestones, specific constru'ction work is accomplished through the use of work' packages or work _ processing documents.
The
[
affected cra ft obtains from the satellites or paper flow '
. groups, as appropriate,' design documents required to carry out apecific work.' Control of the . design documents is i
maintained through the satellites. :
I
_QA/QC obtains required design documents, i j
performs the' required inspections, and completes the necessary. inspection documentation. -Inspection documentation, including inspection reports and non-conformance reports, is discussed below.
3
(
3 j
- b. : Inspection-Reports An Inspection Report ("IR") is used to record field inspections performed by field QA/QC personnel. It- [
is a-ch'ecklist of inspection attributes and has an area for- recording any deviations identified during an inspection. It is completed to document the results of an inspection, regardless of whether the ' inspection f
identified any discrepancies. The status of irs has been and is monitored from the time they are assigned an IR i .
- numbe'r to the time they are closed and transferred to the -
- PPRV for storage. : Prior to the establishment of the i
Building Management Organizations, each non-ASME_QC t
discipline was responsible for tracking and closing the !
inspection reports within its scope of work.8 [
t In late 1983, steps were taken to centralize the i
. open IR monitoring ~ function so that the on-going tracking of . irs would be integrated with project scheduling and [
- 8 irs are used by ASME QC in connection with the ,
inspection of pipe supports, threading, and closure of non-conformance reports (NCRs ) . In these cases the IR would be part of a package which itself is tracked.
With respect to a pipe support, the hanger IR is part
- of the hanger package. Similarly, an IR documenting the inspection of threading would be part of the spool package. Lastly, . irs used for NCR closure ~are part of >
the NdWVpackage. A missing In in either a hanger or 1 spool package would be detected by document review and
- would cause an NCR to be generated. An IR used for NCR closure documents that closure, and without it, '
the NCR is not closed. In addition, irs are used to
-report unsatisfactory in-process inspections. These !
irs are tracked manually and are evaluated for trends ;
- adverse to quality. !
- r -, , eiy v. - * ,-ryv. -----,mwe----r---w , .c--1, - wry,w,-mm----v w e er m -- -----=--r*w- =-1-'---wr,rv vw ww -a - e r wvv
would more efficiently utilize resources. In the process of doing so, manual logs that had been maintained by each non-ASME QC discipline were audited. IR documents referenced in each log were accounted for, and their status (open or closed) was confirmed. The manual logs were then closed, and all information on open irs was entered into the Open IR Tracking Data Base. Thus the validity of the data in this computer data base was confirmed. About the same time, the BMOs were established. The "Open Plant Record Vault" (OPRV)9 was assigned responsibility to maintain QA accountability independent of the BMOs for open irs.
Unsatisfactory (or open) inspection reports document incomplete or non-conforming construction activities. In those instances where the quality control inspector and the craft determine that the work can.be brought into compliance by additional effort that does not require engineering evaluation and disposition, the work is completed, reinspected, and the inspection report is closed.
9 The "Open Plant Record Vault" is not, in fact, a vault that stores completed QA records. Ra ther , it is an organization concerned with monitoring open irs and NCRs within the non-ASME QA scope until their
! completion and transmittal to the PPRV. The OPRV is
, located in the main construction administration AE 11 ding.
t 4
(
i
i l
Where an open inspection report requires engineering evaluation and disposition, such evaluation is documented on an NCR, a.DCA, or a CMC. These documents ,
provide a record of identifying, documenting, resolving and ~ closing out the , unsatisfactory condition reflected on the IR.
As work activities are completed (following inspections), documents related to each activity are distributed to the appropriate records center. Design ;
i documents are returned to DCC-Construction. Inspection ;
reports, other safety-related quality assurance records (e.g., ASME N-5 data reports, weld data cards) and t
construction records are sent to the Permanent Plant Records Vault for indexing and filing. Records verification is being completed to assure that irs are closed. I c .' Electrical Separation Deficiency Report In certain areas of plant construction,
" deficiency reports" (or "punchlists") were used in
. addition to irs and NCRs. These lists were used to facilitate comunication between OC and Craft. A deficiency report was used during the walkdown of Unit 1, during which physical separation of electrical cables was checked. The walkdown teams consisted of electrical discipline representatives from engineering, construction
and QA/QC. When a separation deficiency was detected, it was noted on the Electrical' Separation Deficiency Report.
Craft later performed necessary corrective action after which the work.was then reinspected. When QC determined that an area was complete and acceptable, an IR was
. prepared listing all raceways inspected, and the relevant i
. portion of the deficiency report (s) were attached to the IR. The IR was then processed as discussed in the preceeding section. Both the IR and the attached deficiency report (s) constitute the record of completed work. There are procedural controls governing this list, and a historical record of it exists.
-d. Non-conformance Reports
- An NCR is used to document nonconforming conditions where the use of another document .is not specifically prescribed by inspection instructions.
The TUGCO NCR Coordinator reporting to TUGCO Quality Assurance is responsible foi monitoring unresolved (i.e., "open") NCRs related to non-ASME scope activities.
The office of the non-ASME NCR Coordinator is currently located in the main construction administration building.
Tha Brown & Root NCR Coordinator reporting to B&R Quality Assurance is responsible for monitoring open NCRs related
i
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i L' [
f i
to ASME scope. That office is located on the North Island (near-the main construction gate) away from the j
. administration building. r To find an open NCR, it is necessary to go to the office (ASME or non-ASME) monitoring the NCR.10 The
[
t format of the NCR number will indicate whether the item !
s falls within ASME or non-ASME scope and, therefore, will indicate which office monitors the NCR. At each step in f I
the disposition of an NCR, a copy is sent to the l t
appropriate office so that the status of the NCR is f i
- updated and to assure that its files reflect the current !
status of the NCR. If the number of the NCR is not known, I i
it is necessary to check both offices. i Both NCR offices use a numerical filing scheme f
for open NCRs. Therefore, if the NCR number is known, !
direct retrieval of the record from their file is the most efficient method to obtain the NCi In most cases, the l
NCR number is known from referenceJ to it on other records f (e.g. inspection reports) or indices (e.g., status f reports).
, If the NCR . number is not known, a variety of :
I sources are available to identify the number. Within the l ASME scope, NCR nunbers are manually logged at the time i
! 10 Closed NCRs are sent to the PPRV and may be retrieved j by using the Automated Records Management Systen Data (
Ba se ( A. R. M . S . ) discussed in Section E.4.a., below. i r
f
(_ "(
N; i s
9 v*
i 23 -
s N -
the 'non , conforming condition is identified and the NCR is issued. For each NCR, the-log includes an NCR number, description, trend chtegory, location information, and status for each step in' tiie disposition process. Similar information is also logged for non-ASME NCRs at the time the NCR is created.
The NCR logs have been automated using the Non-conformance Report Tra'cking Data Base. The programs for the NCR Tracking Data Base are processed on George II/III.
Access is restricted, via CSC'NIPT, to QA/QC staff working with the NCR Coordinator and to keypunch staff working in the computer center. The primary output from the computer system is a periodic status report of open NCRs. The'NCR Coordinator validates - the' ~a'ccuracy of this report by comparing it to the items on-file and distributes the report to all parties who have responsibility for closing items which are on the list. The list is used as the primary mechanism for identifying numbers of open NCRs for subsequent retrieval from the files. The keypunching staff has no need for this report'since they are not involved in retrieval, only data entry.ll 11 The only occasion when an NCR will be open and not
- appear on the status report is when it has been opened since publication of the report. Should this be the
! case, it is possible to ascertain the status of the
! NCR by looking in the appropriate NCR log book.
L
s It is possible to access the NCR Tracking Data EMae on the computer terminal. To do so the following conditions must be met:
- 1. a terminal connected to George II/III must be used.
- 2. an authorized password must be used by a trained individual. '
- 3. the computer programs must be operational.
Having determined the correct NCR number from one of the above sources, retrieval of the paper record is possible by going directly to the record files.
- e. Master Data Base The Master Data Base (MDB) was developed early in the project as a log to identify remaining construction work activities which could affect plant completion.
The MDB programs are currently processed on the George II/III .
computers. The log includes information identifying work items, the affected system or plant area, the initiator of the work item, the organization responsible for completion of the work and the status of the item (i.e., open or closed).
The MDB is used by management to
- 1. authorize the commencement of work;
- 2. track the status of work in progress;12 12 The MDB is not intended to be a comprehensive list of NC Rs , as that function is handled by the NCR Tracking Data Base discussed earlier. It should be noted, (footnote continued)
. =- .
i i
9 i
- 3. acknowledge the completion of work; and j
- 4. plan future work.
The primary output of MDB are printouts of selected i portions of the data base in the most efficient order required to facilitate work flow. For example, open work e items which affect a given system can be sorted and
_ printed by the responsible department to assure that required work.is completed prior-to the scheduled test system date. The. various printouts of outstanding work items are commonly referred to as "punchlists" (e.g. ,
Construction Punchlist, Completions Punchlist and the I Master Punchlist) .and should be distinguished from the
-t Electrical Separation Deficiency Report, described above.
- These punchlists are status documents and, although controlled by administrative procedures, are not GA documents.
As items are acknowledged to be complete as evidenced by the completion of required documentation, the
, status on the MDB is changed to " closed." Closed items ;
t will not' appear on punchlists, although a historical [
t report could be generated which would include only closed r
items.- i I
t (footnote continued from previous page) ,
however, that if the disposition of an NCR involves an open work item, that work item will be included in
I i
T
- 3. Records Retention .
TUGCO complies with the requirements of ANSI N.45.2.9-1974 (Draft'll) and the ASME Code,Section III e (1974) for collecting, storing and maintaining quality ;
assurance records for CPSES. These records include the following:
- 1. design
- 2. procurement
- 3. installation and construction
- 4. preoperational and startup test
- 5. operation phase'and activity records Some of these records are to be maintained for the life of the plant; o thers are considered non-permanent with minimum specified retention periods, depending on the record type. ,
- 4. Records Retrieval As noted in Section D, indices (including manual logs and indices generated from various computer data bases),
are used to facilitate retrieval of documents and records from record centers at CPSES. The more important of these indices and lists are discussed below.
- a. Automated Records i4anagement System (A.R.M.S.) Data Base The Automated Records Management System (A.R.M.S.) data base, a computer index of verification records, is used to facilitate retrieval of completed
O' l
, - i records. A verification record is any document that is .
retained as proof that permanent plant structures, !
systems, components and work functions are manufactured, installed, inspected or accomplished in compliance with !
E design and construction requi'rements.
TUGCO Operations is responsible for A.R.M.S.
The programs used by A.R.M.S. are processed on the ,
i Operations Computer. For QA verification records r
generated during plant construction, receipt by the PPRV triggers the process of A.R.M.S. indexing. First, a filing location-is assigned to the record. A coding step -
is performed to index lengthy records by consolidating the A.R.M.S. indexing information onto a single page coding sheet. For reasons of proximity to PPRV,. A.R.M.S. index data-is keypunched from the coding sheets or directly from QA records into the George I computer. Once a day, the key-punched data is collected on computer tape and delivered to TUGCO Operations and added to A.R.M.S.
Periodically an activity report is generated of changes made to A.R.M.S. during the previous key punching cycle.
The activity' report is compared item by item to the QA records to assure the accuracy of A.R.M.S. Differences detected at this point are corrected and appear on subsequent activity reports until A.R.M.S. and the QA records match.
_ _ - _ _ , . _ . , .- . , _ _ ~
Access to A.R.M.S. is restricted to one terminal in the PPRV, one terminal in the TUGCO QA offices in Dallas, terminals in-the Operations Vault, and terminals in PMCS. In addition, printouts are provided to authorized QA/QC individuals. Use of any of these sources will direct the requestor to the filing location of the records selected. Retrieval is completed by going to the appropriate file location and pulling the record.
- b. DCA and DCC Data Bases There'are two computer data bases used for control and distribution of documents received by DCC-Construction: "DCC:DB" and "DCA:DB. "
~
The DCC:DB is a computer data base that is used ,
to store information pertinent to drawings, specifications, procedures, and other materials. It is used by DCC to control, distribute and assure the accountability and traceability of these records. The data base includes information such as document number, revision number and the distribution list. This data base is controlled by DCC-Construction so that changes to the data base cannot be made without authorization by DCC-Construction management. Access to this data base is
r 1
t controlled by a CSCRIPT13 password so that unauthorized !
persons cannot access the data base to change the information it contains. :
The.DCA:DB is a data base for the control and distribution of design change information (DCAs/CMCs) . !
- This data base is a shared system between engineering and DCC-Construction with engineering having the authority and responsibility to make changes to the data base. The DCA:DB is electronically linked to DCC:DB so that when ;
i engineering information is entered into the'DCA DB, DCC-Construction is alerted to the fact that a change has been
~
made.to a' design document. When the actual design change document is received by DCC-Construction, it enters additional information into DCA DB such as a document ,
number and date. At this, point the design package can be.
released to the craft for construction. This system-was set up to assure that the latest design information and any changes are made available to the craft performing the i
construction work. Access to the data base is controlled i
by.the CSCRIPT password system described earlier. I 4
4 f
E
- 13. See discussion of CSCRIPT in Section D.I.b. of this l Report.
l
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GLOSSARY OF TERMS ,
i f
- 1. Accept (Use-As-Is) -- A disposition permitted for a non-conforming item when it.can be established'that
-the item is satisfactory for its intended,use. *
- 2. Activity Report -- Printouts of changes made to a i~
computer data base during a specified time period.
- 3. Aperture Card -- a piece of 35 mm microfilm mounted on a card used to store large records such as !
drawings and their revisions.
l
- 4. A.R.M.S. - Automated Records Management System -- A i computer index used to facilitate retrieval of completed documents. j
- 5. BMO - Building Management Organization -- A group !
chartered with the responsibility of completing j construction work within a specific area of the- !
plant. j.
l
- 6. BOP - Balance of Plant -- Non-safety related systems i and components throughout the plant which do not !
require QA/QC inspection.
2
- 7. BOP Vault -- A facility which receives and stores ;
l documents generated during the construction of CPSES l that . pertain to non-safety related components. ;
t
- 8. CMC - Component Modification Card -- A document that !
authorizes changes to a specific component or system. l A CMC is generally used to authorize drawing changes. !
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- 9. Corrective Action -- A measure taken to rectify conditions adverse to quality and, where necessary, }
to preclude repetition.
- 10. CSCRIPT -- A computer program used to administer '
security functions on the Geroge II/III computers.
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- 11. DCC - Document Control Center-Construction -- A facility which controls instructions, procedures and !
drawings required for construction. t 1
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computer data base that is used to assure ;
accountability and traceability of DCA's and CMC's. !
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- 13. DCC:DB - Document Control Center Data Base -- A computer data base that is used to assure accountability and traceability of controlled copies i of instructions, procedures and drawings required for construction. l
- 14. Deviation -- Departure from a previously approved method, sequence or standard.
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- 15. DCA - Design Change Authorization -- A document that authorizes changes to design documents. A DCA is generally used to authorize specification changes.
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- 16. Disposition -- A decision made by an authorized person of the action to be taken to resolve a non-conforming condition. This action can be either:
accepted (use-as-is), rework, repair or scrap.
- 17. Electrical Separation Deficiency List -- A list (now called Electrical Separation Deficiency Report) of electrical cables or raceways which do not meet required specifications for physical spacing.
- 18. " George" -- A slang term used to refer to various onsite computer equipment.
- 19. -Inspection -- A. quality control activity in which the conformance of materials, supplies, components, parts, appurtenances, systems, processes or structures to predetermined quality requirements is determined by examination, observation or measurement.
'20. IR - Inspection Report -- A document used to record field inspections performed by quality control personnel.
- 21. . Logs -- A manual or computer generated listing of ,
information in a logical sequence to facilitate access to and retrieval of records and documents.
- 22. MDB - Master Data Base -- A computerized list of work activities which are outstanding.
- 23. N-5 Data Report -- A record utilized by the installer of piping systems to certify that the installation of the system is acceptable and in accordance with the ASME Code.
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2 4. . Non-Conformance -- A deficiency in characteristic, documentation, or procedure that renders the quality Lof an item or activity unacceptable.
- 25. NCR - Non-Conformance Report -- One means of documenting a nonconformance.
- 26. N-5 Program -- A program developed by Brown & Root [
(as the holder of the ASME Code Certificate of
'suthorization) to describe the methods of conducting and documenting piping system installation in accordance with the ASME Code.
- 27. Open Items -- Those activities or items of work that need to be completed. ,
- 28. Operations Vault -- A facility within TUGCO l Operations which will be the ultimate repository of records during the operational lifetime of the plant.
29.. OPRV - Open Plant Record Vault -- A group responsible for the accountability of in-process inspection reports.
- 30. " Owner" of Computer Data Base -- ' The group which has the authority for controlling access and maintaining a computer data base. ,
- 31. PFG - Paper Flow Group -- A group responsible for ,
preparing, obtaining, assembling, routing and tracking documents required by a BMO to perform construction work activities.
- 32. PPRV - Permanent Plant Record Vault -- A facility which serves as the prime repository of completed QA verification records during construction.
- 33. Punchlist -- A generic term for any list of open items.
- 34. OA Record -- A document that furnishes evidence of the quality of items and/or activities af fecting quality. A document is considered to be a record when it has been completed and closed.
- 35. " Sat" -- A slang term used to identify an inspection !
checkpoint or report that has been completed L satisfactorily. '
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- 36. Satellite -- A subdivision of DCC-Construction which provides DCC services in areas convenient to construction workers.
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- 37. Tracking -- Monitoring the status of an item. L
- 38. Trending -- The evaluation of deviations or non-conformances by source and frequency as one basis for determining the need for corrective action to preclude repetition.
- 39. "Unsat" -- A slang term used to identify an inspection checkpoint or report indicating that i
construction of an item is incomplete or unsatisfactory.
- 40. Verification -- The act of assuring that an activity or condition has been implemented in conformance with the specified requirements.
- 41. Walkdown -- A' tour of an area of the plant done for a variety of reasons, including inspections and construction progress reports.
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f TELECOPIED FACSIMIIE i
MITER STATES F MERICA :
IMlLIJE MERATURY CSMSS198 l MFWE TIE ATENC SAFETT Als LICMSIM BGMB i
In the Mutter of )
) Docket.Nes. 50-445 and i TEIAS UTILITIES ELECTRIC ) 50-446
)
- CofrART. ~et~'~al. -
) (Applicattee for !
(Cosmeche Peak Steen Electric ) Operating Licenses) l Staties, Units I and 2) ) l i
AFFIDAVIT F LIMA M. RICHEN REGARDIM RECORD 5 AED RECOMS RETRIEVAL REPORT My name is Linda M. Richnen. I as employed by WestinWesse Electric ;
Corporation as the Manager of Records and Reseerde Services, Nuclear Services Integration Division headquartered in PittsburgW. PA. I received a Badelor's Degram in Mathematics from Clarion State University, Clarion. PA. in 1975 and a f Master's Depee in Library Science with emphasis on computers and inforention l science from the University of Illhis Urbana. IL in 1976.
I joined Westinghouse in August,1977 and have been involved with ,
information and records retrieval systems within the nuclear industry since that time. These activities included professional expertence and annagerial responsibility for nuclear records within the Westinghouse scope of supply for over 20 power plants. Since October,1983 I have served as a consultant and supervised a staff working on records related activities at the Comanche Peak Steam Electric Station.
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____,__________.__?-_____ _--
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. l As part of this activity I participated in the preparation of me attached !
report dated June 5; 1984 and entitled " Records and Records tetrieval". That l
\
report is true and correct to the best of my knowledge. information and_ belief. ,
i W kM = = =J _ {
L1osa n. Ricamen j Subscribed and sworn to before se tMs JrP% of June,1964 A "A O w m.rv r n. -
l unemet s.muca.semer remus !
seemeaut sank mr==== cause >
EV M $35968E K R 3907 f
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TEIECOPIED FACSDUIE i
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UNITED STATES OF AMERIC& l wt! CLEAR REGULATORY CONKISSION -
i BEFoEE.TER ATOMIC' SAFETY AMD LICIESING SQARD ;
)
In the Matter of ) Docket Nos. 50-445 and i
) 50-446 TEE &S UTILITIES ELECTRIC l COMPANY,31al. )
) (Application for !
) Operating Licenses) i (Comanche Peak Steam Electric )
station, Units 1 and 2) )
?
I AFFIDAVIT OF ROMALD 0. TOLSCE I maaAmozna ancoRos Ano maconos murmIEvan meront !
I, Ronsid G. Tolson, being first duly sworn, do depose and state as follows: I an employed by T0000 at the Comanche Peak Steam Electric Station. I have previously t'estified in (
l this proceeding regarding the QA p'rogram at Comanche Peak. l A statement of my educational and professional qualifications was received into evidence as Applicant's Exhibit 20. As part of my responsibilities as a TUGC0 employee I participated in (
l the preparation of the attached report dated June 29, 1984 and l hat report is true j antitled " Records and Records Retrieval."
I and correct to the best of my knowledge, information and belief. :
' u 1 Ronald G. TOIsoa County of somervell Subscribed and sworn to before .
State of Texas me this gl, day of June, 1984 ,
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' notary ann 11ev l
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s UNITED STATES OF AMERICA !
, NUCLEAR REGULATORY COMMISSION j BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L In the Matter of ) -
) ,
TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445 and i COMPANY, - _al.
et ) 50-446 (Comanche Peak Steam Electric ) ( Application for
- Station, Units 1 and 2) ) Operating Licenses) !
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Applicants' !
Responses Concerning Records Retrieval" and Applicants' Report i entitled " Records and Records Retrieval" in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid, this 29th day ,
of June, 1984: ;
I Peter B. Bloch, Esq. Chairman, Atomic Safety and i Chairman, Atomic Safety and Licensing Appeal Panel '
Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission t Commission Washington, D.C. 20555 ,
Washington, D.C. 20555 t Mr. William L. Clements Dr. Walter H. Jordan Docketing & Service Branch l 881 West Guter Drive U.S. Nuclear Regulatory ;
Oak Ridge, Tennessee 37830 Commission i Washington, D.C. 20555 Dr. Kenneth A. McCollom
- De an, Division of Engineering Architecture and Technology Stuart A. Treby, Esq. !
Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory ,
Mr. John Collins Commission ;
Regional Administrator, Washington, D.C. 20555 Region IV !
U.S. Nuclear Regulatory Chairman, Atomic Safety and j Commission Licensing Board Panel '
611 Ryan Plaza Drive U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C. 20555 i i
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9 Renea Hicks, Esq. Mrs. Juanita Ellis Assistant Attorney General President, CASE ,
Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Ellen Ginsberg, Esquire Austin, Texas 78711 Atomic Safety and Licensing Board Panel Lanny A. Sinkin U.S. Nuclear Regulatory :
114 W. 7th Street Commission Suite 220 Washington, D.C. 20555 Austin, Texas 78701 '
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~ SarMord L. Hartman t
cc Homer C. Schmidt Robert Wooldridge, Esq.
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