ML20094A618
| ML20094A618 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/29/1984 |
| From: | Mary Walsh Citizens Association for Sound Energy |
| To: | |
| Shared Package | |
| ML20094A552 | List: |
| References | |
| OL, NUDOCS 8411060481 | |
| Download: ML20094A618 (217) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 El -5 All :59 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD rem
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In the Matter of I g;.:3,,p'jE.
I TEXAS UTILITIES GENERATING l Docket Nos. 50-445-1 COMPANY, et al.- l and 50-446-1 1
(Comanche Peak Steam Electric Station i Station, Units 1 and 2) l CASE'S SECOND PARTIAL ANSWER TO APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE REGARDING APPLICANTS' QUALITY ASSURANCE PROGRAM FOR DESIGN OF PIPING AND PIPE SUPPORTS FOR COMANCHE PEAK STEAM ELECTRIC STATION in the form of APFIDAVIT OF CASE WITNESS MARK WALSH
- 1. Applicants state:
"Each of the responsible design organizations for piping and supports at Comanche Peak has established procedures to implement the provisions i of 10 C.F.R. Part 50, Appendix B and ANSI N45.2.11 to their respective applicable functions in the piping and support design process.
(Affidavit Table IV.1)"
I disagree. Applicants state that each of the responsible design organizations) have established procedures to implement the provisions of 10 CFR Part 50, Appendix B and ANSI N45.2.11, but this statement
! cannot be so, based on the information already contained in the record l
of these proceedings. As will be shown in answer 5, the Applicants do not have any design control procedures in the field except to document what is in the field. This is not sufficient to comply with the requirements or intent of 10 CFR Part 50, Appendix B and ANSI N45.2.11.
8411060481 841030 gDRADOCK 05000445 1 PDR l
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- 2. Applicants state:
" Regulatory requirements and licensing commitments set forth in the license application are incorporated into design specifications by Gibbs & Hill for Comanche Peak for both piping (Class 2 & 3) and supports. These specifications are transmitted to the responsible design organizations for incorporation in their design process.
Similarly, Westinghouse has established a specification for the design of Class 1 (and Class 1 extension) piping. Westinghouse employed the Gibbs & Hill specification in its design of non-Class 1 auxiliary piping. (Affidavit at 16 (G&H), 25-26(W).)"
First of all, Applicants have refused to provide CASE with the specificationsreferenced/1/. Because of this problem, I am unable to answer this part of Applicants' Statements of Material Facts fully.
However, in particular, I am aware that the AISC is a requirement of Gibbs & Hill Specification MS-46A, the specification with which I am most concerned.
Applicants' Witness Mr. Finneran, in Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Loads, stated that Applicants are not required to follow AISC for welding design. However, AISC, at Section 1.17, refers back to AWS Welding Code for Welding for weld design, which Applicants have stated that they are not required to follow. If
/1/ See 10/4/84 letter from Applicants' counsel Mr. Horin to CASE President Juanita Ellis, page 2, second paragraph, where he states: "The material not provided generally involves matters the content of which are not relied upon in our motion, such as technical specifications (3, 4). . ." Gibbs & Hill Specifications MS-200 (all revisions) and MS-46A (all revisions) were the 3rd and 4th items, respectively, listed in CASE's 8/15/84 letter from Mrs. Ellis to Mr. Horin requesting documents on discovery; one or both of them are referred to on pages 16, 32, 39, 43, and 57 of Applicants' Affidavit.
See also 10/18/84 letter, page 2, from Mrs. Ellis to Mr. Horin advising that CASE has a complete copy of Rev. 5 of MS-46A obtained in the rate hearings and requesting confirmation of authorization from Applicants to reconsider and provide CASE with the original and other revisions of MS-46A.
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the Applicants intend to show that they meet regulatory requirements, they also need to show that they follow these requirements; for example, evaluating codes for their sufficiency (see 10 CFR Part 50, 4
Appendix A, Criterion 1) in regards to their welding, punching shear analysis, use of bearing connections when they should have used friction connections, just to list a few.
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- 3. Applicants state:
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"Each of the pipe support design organizations has incorporated the Gibbs & Hill specification applicable to the design of pipe supports into their' design process. This specification is incorporated into each organization's designs (including drawings, procedures,
, instructions and guidelines as appropriate) in accordance with established procedures. (Affidavit at 32-33 (NPS), 39 (ITTG) and 43-44 (PSE).)"
Same comments apply as for answer 2 preceding.
- . 4. Applicants state
"Each design organization has implemented design control measures which include verification and/or checking of the adequacy of each design, including the initial design of the piping or support prior to release of the design for construction. These measures include documentation
, of the design reviewer's findings and correction of the deficiencies by l the original designer. Each design organization also requires that the person performing design review may not be the same person who performed the original design, although he may be part of the same organization as the original designer. (Affidavit at 20-22 (G&H), 30 (W), 35-37 (NPS), 40-41 (ITTC), and 46-48 (PSE).)"
The Applicants have made two errors in the first sentence. The first one is that they do not keep the original initial design calculations (if they ever existed). This is demonstrated by the 3
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following: When I requested the original calculations for support MS-1-002-003-C72S, Applicants' counsel Mr. Horin stated that Applicants didnothavetheoriginalcalculations/2/.
The second point is that the verification of the initial designs are deficient when one recalls the 13 unstable main steam supports which were issued by Grinnell, for example (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition on stability).
In addition, to mention just a few items:
(1) The design procedure utilized by all three organizations in regards to the Richmond insert / tube steel /A307 bolt connection was deficient - none of the design organizations realized that the method utilized to determine the stress in the bolt was incorrect (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition regarding Richmond Inserts). Therefore, their procedures for this verification
" including the initial design of the piping or support prior to release of the design for construction," (emphasis in the original) was inadequate.
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2 See 8/20/84 letter from Applicants' Counsel Mr. Horin to CASE President
! Juanita Ellis, page 2, item 5, wherein he states that he is providing:
" Example calculations (prior to June 1982) by each of the pipe support design organizations (ITT, NPSI and PSE) regarding consideration of the adequacy of threaded rods and similar calculations for support MS-1-002-003-C72S (these calculations ,
provided for the main steam support are for the latest loads for this support. Previous calculations were not retained)."
(Emphasis added.)
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(2) The PSE Group utilized section properties from WTSI which never existed (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition on section properties).
(3) Applicants did not consider the friction effects when piping movement is less than 1/16", and as I showed, this can be the controlling factor in the design (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition on friction).
(4) Applicants did not provide any documentation which could verify that they had considered the reduction in yield strength due to welding on A500 Grade B tube steel in the original designs or subsequent designs (as discussed in CASE's Answer regarding A500 Grade B tube steel).
(5) Applicants did not consider the effects of gaps on seismic response (as discussed in CASE's Answer to Applicants' Motion for Suumary Disposition regarding gaps).
(6) Applicants did not fulfill their commitments to the FSAR in the original design calculations for the upper lateral restraint (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition on the upper lateral restraint).
(7) In Applicants' Motion for Summary Disposition on safety factors, Applicants are depending on new information rather
, than the original calculations (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition on safety factors).
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(8) Applicants, in their generic stiffness Motion, neglected to mention that all their original designs were based on generic deflection, not generic stiffness (as discussed in CASE's Answer to Applicants' Notion for Summary Disposition regarding generic stiffness).
(9) Applicants' original designs sometimes considered 'J-bolts as two-way restraints and sometimes they didn't, with no justification in the original design (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition regarding U-bolts acting as two-way restraints).
(10) Regarding differential displacements, it is not clear whether Applicants used original designs or a change by a Component Modification Card (CMC) (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition regarding differential displacements).
(11) Applicants did not consider the effects of cinching up U-bolts in the original designs or in subsequent remedies for instability (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition regarding cinching down of U-bolts).
(12) Regarding axial restraints, Applicants did not consider the l
effects of the moment within the pipe indacing additional -
loads into the restraint (as discussed in CASE's Answer to Applicants' Motion for Summary Disposition regarding axial
, restraints).
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For all of the items discussed in the preceding paragraph, it is apparent that the design procedures which were utilized in the original designs were deficient, the individuals utilizing the procedures did not have the necessary knowledge to identify and correct these design deficiencies, or management squashed or ignored all such concerns, as was the case with ITT Grinnell's response to G. Abe'le's Request for Information (as discussed in CASE's Answer to Applicants' Motion for
, Summary Disposition regarding stability).
Regarding Applicants' last sentence, in the initial design (i.e.,
that prior to issue for construction, the Applicants rely on a stringent design review; see Applicants' Affidavit at page 20-22), this criteria of design review is not supposed to stop after a drawing is issued for construction. The stringent design reviews which the Applicants allude to are required for all field changes and all such changes must be commensurate with the original design, as required by 10 CFR Part 50, Appendix B, Criterion III, last paragraph. As discussed in the following answers, it is obvious that Applicants are not in compliance with this Criterion.
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- 5. Applicants state:
"During the course of construction of the piping and support system changes in design of supports are virtually unavoidable.
Implementation of the changes are (sic) governed by established procedures and instructions. The most commonly employed method to implement such changes is through Component Modification Cards
("CMCs"). These changes are subject to design review, verification and approval in accordance with procedures commensurate with the design f
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s review process employed in the original design. With respect to design changes not initiated by field modifications, each organization also conducts design reviews of the change in a manner commensurate with the procedures for new designs. The design change control process for each organisation provides that the organisation which performed the original, design to also perform the design review of the design changes. (Affidavit at 50-56.)"
I agree with Applicants' first sentence.
I dis, gree with Applicants' second and third sentences, to the following extent, as discussed in greater detail later:
(1) The procedures and instructions at Comanche Peak are often not followed; (2) The procedures and instructions at Comanche Peak change so frequently that it is impossible for anyone to know what procedures and instructions should be followed when; (3) The controlled copies of procedures and instructions at Comanche Peak are not kept up-to'date; and (4) 'When the procedures and instructions at Comanche Peak are j followed, it often results in chaos because Applicants rely on all mistakes and errors being caught at the very end.
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~ Applicants' third sentence discusses Component Modification Cards (CMC's), and states that the most commonly employed method to implement changes in design of supports is through CMC's. However, Applicants
, have provided no documentation of this. When Cygna asked Applicants to p clarify exactly what " vehicles" were used at Comanche Peak to document design deficiencies, they were told H/:
- "[R.] Tolson and (D.] Wade explained that in addition to such documents as Nonconformance Reports (NCR's), Deficiency Review M/ See Attachment A hereto, Cygna Communications Report dated 5/10/84,
- under Subject of
- Corrective Action Systems.
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s l Reports (DRR's), Corrective Action Requests (CAR's), Significant Deficiency Analysis Reports (SDAR's), etc., other documents could
. be used to document design deficiencies. These documents are Computer (sic) Modification Cards (CMC's), Design Change Authorizations (DCA's), and Inspection Reports (IR's).
"Tolson explained that he didn't feel it was important relative to what you called the piece of paper, as long as the deficiency was documented."
- Cygna also asked Applicants how many CMC's and DCA's " existed from day #1 until now" (which was 5/3/84), "and how CES could easily determine which CMCs are design related?" Applicants response was f4,/:
"a. Current # of CMCs to date is 97894. (CMC #18,400 through 30,000 were not used) so actual # of CMCs issued to date is 86,294.
"b. 20,300 DCAs'and DC/DDAs have been issued to date.
4 "c. Approximately 36,000 CMCs issued are pipe support related and are not tracked by DCTG, and are not G&H design related.
"d. DCTG can identify which CMCs are pipe support engineering related if CES requires that information."
4 Cygna also " requested information relative to the number of i InspectionReports(irs)issuedatCPSES"f5,/. They received the following response:
- " Donna [Lewellen, TUSI] called me [S. Bibo, Cygna) per request of
' Tony Vega to supply me with requested information relative to the number of Inspection Reports (irs) issued at CPSES. Donna stated
- i. that between the 'old' IR system and the 'new' IR system there are in excess of 150,000 irs. She stated that the new system has a computerized log but that the old irs were manually logged. "Te old system contains about 100,000 irs. Donna explained that the number of irs given is her 'best estimate'."
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[ f4,/ See Attachment B hereto, Cygna Communications Report dated 5/3/84, l under Subject of: Review of CMCs.
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f5/ See Attachment C hereto, Cygna Communications Report dated 5/15/84, under Subject of t Inspection Reports.
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Because of the preceding information, it is not at all clear to me that Applicants' statement that the most commonly employed method to implement changes in' design of supports is through CMC's is correct.
As stated previously Applicants did not provide any documentation that
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this is true. .And from the information supplied by Applicants to Cygna (as contained in Attachments A, B, and C hereto), I am not certain that Applicants can support their statement and prove that it is true.
For the preceding reasons, I cannot agree with Applicants' third sentence.
Contrary :o Applicants' claims in the third, fourth, and fifth sentences, this is one area (and I'm sure there are others) where Applicants have had a total breakdown and complete loss of control of design acceptance (no engineering approval for any change).
Although I could go through each of many aspects of Applicants' procedures (such as DCA's), at this time I will concentrate primarily on CMC's, since Applicants have specifically discussed them. Since there are so many procedures and instructions to review, I have.
attempted herein to address the CMC program in some detail, as an illustration of Applicants' actual program. It is reasonable to assume that similar problems exist.in other aspects'of their QA program which
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! I have dot had sufficient time to thoroughly review and address.
l On page 52 of Applicants' Affidavit, it is stated regarding CMC's:
"It is important to note that the CMC process was intentionally devised to provide a means to permit the craf t to proceed with necessary modifications of the support without awaiting l
- incorporation of the CMC into the design and design review."
( (Emphasis in the original.)
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i As discussed in more detail later herein, Applicants' above
~ statement is questionable. Although the procedures apparently were later perverted to allow someone in the field to write up a CMC, then have the craft proceed with modifications of the support without awaiting proper approvals, it is not clear that this was the purpose when the CMC program was first initiated.
To give a brief historical view on the CMC program, I refer the Board to the first TUSI " Design Change Control" procedure, CP-EP-4.6, Revision 0, issued 8/13/79 (Attachment D hereto).
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The Purpose of Procedure CP-EP-4.6, " Design Change Control," is stated in Rav. O to be:
f "2.1 PURPOSE "This procedure establishes the method for control and
, documentation of design changes to approved design documents by the Comanche Peak Project Engineering (CPPF.) group.
I "This procedure will ensure that design changes are originated, reviewed and approved by qualified organizations
- having access to all pertinent background data. These
- organizations (sic) are identified, documented and subject to control measures commensurate with those applied to the original design." (Emphasis added.)
I assume that, instead of " organizations" in the last sentence in the preceding, Applicants intended " design changes." If this is correct, then it would appear that this was a legitimate attempt to
-comply with the provisions of the last paragraph of 10 CFR Part 50,
, Appendix B, Criterion III, and of ANSI N45.2.11 (Applicants' Exhibit p.
( 148, admitted at Tr. 5398, and Addition to Applicants' Exhibit 148, j l ..
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admitted following Tr. 7014), especially page 33, section 8. , " Design Change Control, first paragraph. (If my assumption is not correct, Applicants' wording does not make any sense.)
Section 3.3 (page 6 of 23) of Rev. O of this procedure discusses y the CMC Procedures utilized by TUSI (Texas Utilities Services Inc.).
It should be noted that CMC's are utilized for electrical, piping, instrumentation, and pipe supports. Section 3.3 discusses the CMC procedure for the single part (blue) CMC card; similar wording is contained in 3.3.4, the CMC procedure for the three part memo CMC card.
Section 3.3.1, item 1 (page 7 of 23), states:
. "1. Section 8- Approved By- The originating engineer shall approve the change and designate any other approvals required. Additional approval is required by the original design organization or their representative (see 3.2.3.b) prior to issuing the CMC unless specifically authorized by a CPPE procedure or instruction." (Empi.ases added.)
" NOTE: Refer to section 3.3.3 or 3.3.4 for other CMC
. approval criteria."
And section 3.3.3, " Alternate Four Day Distribution" (page 9 of
- 23) states, in part:
"After all required aprovals have been obtained in accordance with section 3.3.1.1, the CMC may, at the discretaion of originating engineer, be reproduced and distributed for construction . .." (Emphases added.)
l The above portion of this procedure appears to have met some of the requirements of 10 CFR Part 50, Appendix B, Criterion III, for design changes which occur in the field (i.e., the design change document will have approval from the originating engineer). This procedure requires approval by the originating organization prior to i
construction of any design change.
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Rev. 1 of CP-EP-4.6 (" Design Change Control Procedure- DCA's and CMC's") was issued on 11/20/79; Rev. I was substantively about the same as Rev. O, with the title and approval blocks dn the front changed).
Five months after Rev. O was issued (and a couple of months after Rev.
I was issued), Applicants issued Rev. 2, " Field Design Change Control Procedure," dated 1/31/80 (Attachment E hereto), which was a complete revision of CP-EP-4.6. It stated, in part:
"2.1 PURPOSE "To describe the method of documenting changes or deviations to specified design / construction requirements by authorized field personnel following release of engineering documents approved for fabrication or construction."
It is readily apparent by the statement of the purpose of this procedure that the Applicants no longer wanted design changes to be commensurate with the original design, as was stated in Rev. O. The Applicants now were allowing deviations to design documents without qualified organizations having access to all pertinent background data, as was stated in Rev. O. It appears that this led to complete reconfigurations of pipe supports which had no design calculations to verify their capacity.
Sections 3.2 " REVIEW AND APPROVAL," and Section 3.3 " DESIGN j VERIFICATION," of Rev. 2 replaced some of the wording which was l contained in 3.3.1(1) and 3.2.3(b) of Rev. O, and stated, in parr:
l "3.2 REVIEW AND APPROVAL
" Field orginated design changes / deviations shall be approved by the original designers designated site representative unless otherwise stated in formal engineering instructions supplementing 13 l
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3-this procedure. The Resident Engineer shall maintain written
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authorization of personnel designated as a 'G&H Design Representative' or design representative .cf any other vendor.
. Clarifications or design changes properly approved and issued by the original design organization require only the signature of the originating engineer / technician.
"DCA or CMC forms completed in accordance with the above requirements are approved for fabrication or construction when signed by the designated authorities." (Emphases added.)
"3.3 DESIGN. VERIFICATION
" Design changes / deviations shall be reviewed either prior to or after implementation by authorized personnel to confirm or
- substantiate that the change is acceptable from an engineering standpoint and consistent with the design basis (or input), FSAR commitments and applicable codes and standards. This review will normally be accomplished by the original design organization in accordance with established procedures although the provisions of Ref. 1-B may be utilized at the discretion of the Engineering and Construction Manager." (Emphases added.)
The last sentence of the first paragraph of section 3.2 above allowed all design documents that were issued for construction to have design changes approved by technicians and not the original engineer.
This is not in compliance with 10 CFR Part 50, Appendix B, Criterion III, last paragraph. This approval method allowed fabrication and f' construction to continue without consulting the original design i
organization as to whether ornot the change was consistent with the I design basis (or input), FSAR commitments, and applicable codes and standards.
ATTACHMENT.2 - CMC rora Completion, stated, in part:
"5. i. Section 8 - Approved By - The originating engineer /
technician shall approve the change and designate any l' other approvals required (see paragraph 3.2 of CP-EP-4.6). Prior to issuing the CMC unless otherwise specifically delineated by a CP-El instruction supplementing this procedure." (Emphases added.)
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"j. Section 9 - Distribution - If not predesignated, the engineer / technician preparing the CMC shall enter (on the front of the CMC) the name of each agency (and document control unaber) requiring distribution and shall indicate the number of required copies for each."
(Emphasis added.)
ANSI N45.2.11, Section 6.1, Design Verification /6,/, does not allow the originating engineer / technician to approve their own work, as is indicated in the above. It should be noted that this appears to be the revision of the procedure which allowed the "somewhat knowledgeable" individuals to make design changes. These design changes resulted in unstable supports which went uncorrected for three years, and undoubtedly would have gone completely uncorrected if Mr.
Doyle and I had not testified before the Atomic Safety and Licensing Board in these proceedings.
Rev. 3 of CP-EP-4.6, issued on 2/18/80, was basically the same as Rev. 2, except for a change in References. Then on 7/18/80, Applicants issued Rev. 4 of CP-EP-4.6 (Attachment F hereto).
Under Section 3.4, " DISTRIBUTION," of Rev. 4 (page 3 of 10), the following wording from the same section of Rev. 3 has been deleted:
"To the extent feasible, distribution should be shown on the face of the change / deviation document to facilitate implementation of site document control procedures."
This deletion lessened'the document control procedures.
And on Attachment 2, " CMC FORM COMPLETION," page 7 of 10, the wording has been changed as shown below:
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From Rev. 3:
"5. .j. Section 9 - Distribution - If not predesignated, the '
Engineer / Technician preparing the CMC shall enter (on a the front of the CMC) the name of each agency (and
- document control number) requiring distributica and shall indicate the number of required copies'fer each."
, (Emphasis added.)
From Rev. 4:
"5. j. Section 9 - Distribution - If not predesignated, the Engineer / Technician preparing the CMC shall entkr the name of each agency requiring an ' Engineering and Office Use Only' copy and shall indicate the number of required copiesfor;each." (Emphasis added.) '-
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It appears to se thatxApplicants lessened the requirements of this a
procedure from requirit:g distribution of controlled copies, to distribution to each assecy requiring an " Engineering and Office Use
\' Only" copy, which (it is a:r understanding)' is not controlled.
Applicants next issued Rev. 5 of CP-EP-v.6, on 8/5/80.(which was substantively about the same as Rev. 4). Then on 10/7.7/80, Applicants issued Rev. 6 of CP-EP-4.6 (Attachment G hereto). Included in the changes made to Section 3.2, " REVIEW AND APPROVAL," was the following:
From Rev. 5, Sectfan 3.2, second paragraph (page 2 of 10):
"DCA or CMC forms completed in accordance with the above requireeents are approved for fabrication or construction when signed by the designated authorities. Subsequent review and approval by the Original Design Organization shall be accomplished
- e.he provisions of Reference 1-A." (Emphasis added.)
bev. 6, Section 3.2, this second paragraph (page 2 of 10) has
' as follows:
att review and approval by the original design sation shall be accomplished per the provisions of Reference
. und 1-E."
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. - - - - . . - , - - - - - . . , . , - - , , . - - , , , , , , . - - . . - - - - - - , , , , - - - . . - , - - . - - - - - - - - - - - , , - - , - ~ - - . , . --- - - - -
It appears to me that Applicants have again lessen,ed the requirements of this procedure by deleting the provision that fabrication or construction is approved when the designated authorities sign the CMC (or DCA) forms, thus allowing fabricatioa or construction y
to proceed prior to such approval from the original design organization. This revision also clearly demonstrates the Applicants' intent not to consider the design basis (or inputs), FSAR commitments, or applicable codes and standards which were used in the original design prior to the design change.'
A major change which was made in Rev. 6 of CP-EP-4.6 was that they completely eliminated the following section which was contained in Rev.
5 at page 3 of 10:
n "3.7 INTERFACE CONTROL
" Changes / deviations to engineered items involving Design Engineer
, and vendor interfaces, such as equipment foundation details, shall be reviewed with both the Design Engineer and the vendor for compliance with design requirements prior to approval for fabrication or construction."
The preceding appears to me to be a necessary part of the procedure. It appears that Applicants also believed this to be true, since they had included " Identification of Interfaces" (Section 3.4.4,
-o Revs. O and 1, pages 11 and 12 of 23) or " Interface Control" (Section 3.7, Revs. 2, 3, 4, and 5, page 3 of 10) in the original and all previous revisions of this procedure. In fact, " Interface Control" was added back in Rev. 7 of CP-EP-4.6 (page 3 of 10) (Attachment H hereto),
with some changes which appear to have made the requirements less 4
stringent than in previous revisions (as indicated by the underscored portions of the following); an additional paragraph was also added:
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"3.6 INTERFACE CONTROL "Significant changas/ deviations to engineered items involving A/E and vendor interfaces for equipment foundation details shall be reviewed with both the A/E and the vendor for compliance with design requirements prior to approval for fabrication or
. construction." (Emphases added.)
" Formal documentation where vendor or A/E approval is required shall be accomplished in accordance with Reference 1-A and 1-B."
The next revision, Rev. 8, issued 9/22/83 (Attachment I hereto),
was a major revision (see especially sections 2.4.4, page 2 of 15; 3.1, pages 2, 3, and 4 of 15; 3.2.5, second paragraph, page 6 of 15; Attachment 1, page 7 of 13; and Figure 1, page 13 of 15). I will not attempt to detail each of the changes here, but will make only a few comments.
In this revision, for the first time, " Engineering Change Requests" are mentioned and discussed (see 2.4.4, 3.1, Attachment 1 and Figure 1). .These documents are defined as (page 2 of 15):
"2.4.4 Engineering Change Reauests "A document used to forward engineering, design, or technical information between engineering organizations for the purposes of initiating drawing revisions. The ECR is a communication /
interface document which does not authorize fabrication or construction." (First emphasis, title, in the original; remaining emphases added.)
The following wording regarding Engineering Change Requests (ECR's) should be noted:
"3.1.2 Specific Scope of ECR's "The specific scope of changes (i.e., systems, subsystems, areas, engineering documents, etc.) to be processed by ECR's shall be administratively defined by the CPP Engineering Manager."
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" NOTE: Changes critical to construction in terms of an immediate need for implementation may be exempted from the scope of ECR's on a case by case basis. Changes processed in this msnner shall be documented by DCA/ CMC; however, the change shall be authorized by specified engineering management personnel." (Emphases added.)
The inclusion of the exemption referenced above for "[c]hanges critical to construction in terna of an immediate need for implementation" in this QA/QC procedure appears to me to be contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion I, of independence from cost and schedule considerations.
-There is also what appears to be a significant change in wording for design verification between Rev. 7 and Rev. 8, which again lessens the requirements of the procedure:
From Rev. 7, Section 3.5, second paragraph, page 3 of 10:
"In the event the design verifiestion activities indicate the change / deviation is unacceptable, the reviewing agency shall notify the Engineering Manager / Discipline Field Engineer who will, on the area in question, place a ' Hold' or rescind and reissue the
, change / deviation. Any physical corrective action required in problem areas will be evaluated and formulated on a case by case basis." (Emphasis added.)
From Rev. 8, Section 3.2.5, second paragraph, page 6 of 15:
"In the event the design verficiation activitias indicate the change / deviation in nascceptable,'the reviewing agency shall notify the originating organization who say, on the area in question, place a ' Hold' or rescind and reissue the change /
deviation. Any physical ec;rective action required in problem areas shall be evaluated and formulated on a case by case basis." ,
(Emphasis added.)
1 The next revision to CP-EP-4.6, Rev. 9 (Attachment J hereto), was
'_ issued 11/4/83. Among the several changes were the following which I believe lessen the requirements of the procedure:
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Rev. 9 added the following wording to section 2.1 " PURPOSE" (page 1 of 15):
". . . Note, supplemental engineering procedures / instructions may
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be used to describe and implement alternate methods of design change control."
Regarding the use of Engineering Change Requests (ECR's), the following wording (as indicated by underscored portion) was deleted:
From Rev. 8, page 3 of 15:
"3.1.5.2 ASME Related: Stamping Complete "TNE shall categorize the proposed change as a major, mirar, or critical change and complete design control activities as specified in Reference 1-B. . ." (Emphasis added.)
From Rev. 9, page 4 of 15:
"3.1.5.3 ASME Related: Stamping Camplete "TNE shall complete design control activities as specified in Reference 1-B. . . "
The most recent revision to C2-EP-4.6 which was provided to CASE by Applicants was Rev. 10, issued 4/16/84 (Attachment I hereto); it appears to be substantively about the same as Rev. 9, at Isast insofar as CMC's are concerned.
Rev. O of Procedure CP-EP-4.6 does not allow the CMC to be used to document deficient construction practices. This procedure did not allow construction to continue and to be verifi;d acceptable later,
.much less three or four years down the road, when the Applicants are requesting an operating license for their multibillion dollar plant.
20
~
The CMC program, it appears to me (and I was under this ,
impression while I worked at Comanche Peak), initially was a tool which would allow engineering to accept a proposed field modification prior
- o construction. This is standard industry practice.
The problems with the CMC's were not a specific allegation by 4
myself or Mr. Doyle. They became an issue in these hearings after Applicants' Witness Mr. Finneran stated that "somewhat knowledgeable" field engineers had created unstable supports when utilizing the CMC's (see 9/15/82 Tr. 4953-4985, especially 4962/23-4963/5).
Since that notable statement was made, I have learned that the CMC's are not commensurate with the original design; i.e. , engineering 1
approval does not precede construction. The CMC's are used to document and resolve construction deficiencies as well as design deficiencies, as-built configurations, requests from engineering for field modifications, etc. For exaeple, in the attached 5/10/84 Cygna Phase 3 Communications Report (Attachment A hereto), which was discussed on page 8 herein, the following was stated:
"We asked to meet with D. Wade to clarify in our minds exactly what ' vehicles' were used at CPSES to document design deficiencies. Dave asked that R. Tolson be brought into the discussion.
"Tolson and Wade explained that in addition to such documents as-Nonconformance Reports (NCR's), Deficiency Review Reports (DRR's),
Corrective Action Requests (CAR's), Signficant Deficiency Analysis
- Reports (SDAR's), etc., other documents could ba used to document design deficiencies. These documents are Computer (sic -- should be Component) Modification Cards (CMC's), Design Change Authorizations (DCA's), and Inspection Reports (IR's).
"Tolson explained that he didn't feel it was important relative to what you called the piece of paper, as long as the deficiency was documented." (Emphases added.)
- f. ;
l l
As another example, the attached 5/24/84 Cygna Phase 3 Communications Report under Subject of " Inspection Reports" (Attachment L hereto) states, in part (last paragraph):
"In addition, it was explained that construction had the option of going to engineering and asking for DCA/ CMC to be issued to accept the unsatisfactory condition ('use-as-is'). QC would then be called to reinspect the item. The DCA/ CMC (issued by engineering) would serve an an engineering evaluation of the nonconformance with a disposition of 'use as is.'"
With all these uses for CMC's (not to mention the use of so many different types of documents for documenting design deficiencies), the Applicants have lost control of design changes in the field. They cannot pick up a CMC and say that this particular CMC was approved by engineering for a preposed field modification, or say the CMC was used to correct a design deficiency, or say whether the CMC created a design deficiency. The CMC program developed into a program in which field engineers, or construction personnel, were able to proceed with no design responsibility or repercussions just to get the plant built and no attention was given to whether or not the change was commensurate with the original design, whether or not it had safety significance (for instance, c; stable supports), or whether or not pressure was applied to the people who had done the original design to verify that the design change was acceptable.
This is an observation about which the NRC Resident Inspectors for Comanche Peak were concerned:
From NRC Region IV 1976 Trend Analysis (NRC Staff Exhibit 184, admitted into evidence at Tr. 2336), by Robert Stewart (see Tr. 2358):
22
"During the early part of 1976, it became apparent to the Principal Inspector that the effectiveness of the licensee's QA/QC Program was in a state of degradation as a result of a domineering and overpowering control by the contractor's site construction management."
From NRC Region IV 1979 Trend Analysis, pages 2 and 3, item f.
" Effectiveness of QA/QC Program" (NRC Staff Exhibit 195, admitted into evidence at Tr. 2336), by Robert Taylor (see Tr. 2358):
". . . What I have begun to see, but have difficulty proving, is that the Brown L Root construction philosophy is to build something any way they want to and then put it up to the engineer to document and approve the as-built condition. If the engineer refuses, he is blamed for being to (sic) conservative and not responsive to the client's needs. Thus the driving force behind my request for a special engineering audit of site operations. . .
". . . too often an installation clearly accomplished other than as originally designed and buildable has been approved by the licensee's on-site engineering arm as fulfilling requirements. In effect, the engineer has approved a nonconforming installation in advance of QC being called. QC is then signing for the as-built condition and the underlying problem is not addressed. . .
And from page 3, item g. Any Other Trends Indicative of Poor Performance of NRC Staff Exhibit 195:
". . . It seems likely to me that the licensee will use his full powers to be less open with us in the area of identified construction deficiencies than he has in the past. I think he will take maximum advantage of part 50.55(e) and the guidance to go through the necessary formalities but avoid, if at all possible, having to report to us. . ."
l And from NRC Staff Exhibit 181, NRC Region IV Inspection Report 50-445/80-25, 50-446/80-25, Systematic Assessment of Licensee l Performance for 8/1/79-7/31/*0 (admitted into evidence at Tr.
2336):
i l
l' 23
"g . - Effectiveness and Attitudes of Licensee Personnel in Complying with NRC Requirements Licensee Construction and Engineering Management - The NRC personnel stated that it appears there is a continuing tendency to engineer away construction problems rathe,r than enforce compliance to drawings and specifications. The licensee stated that he is taking several management actions with the engineering and construction personnel to alleviate this situation. The NRC personnel stated that there was no specific regulatory concern since safety does not appear to have been compromised as yet but could possibly be sometime in the future if appropriate actions were not taken as indicated above. .."
e (See also NRC Staff Exhibit 180, " Supplemental Testimony of William A. Crossman, Robert C. Stewart and Robert G. Taylor Regarding the Annual Assessments of the Applicants' Performance (Contention 5),"
and discussion at Tr. 2320-2327 and 2337-2378.)
In addition, the NRC's Construction Appraisal Team (CAT) Report (NRC Staff Exhibit 206, bound in following Tr. 6286) stated (page IX-7):
"The review of these CMCs and inspection documentation in the '
ASME area by the NRC CAT inspector also revealed that design changes are apparently initiated as a result of the performance of QC inspection. -These changes are then processed to accept the
'as-built' configuration, rather than modify the support to actually satisfy the design document in effect at the time of the inspection. These practices do not provide incentives to the crafts to properly construct in strict accordance with the design document." (Emphasis added.)
l l
In addition, Procedure CP-EP-4.6 has been revised 10 times in less i
than five years; Instruction CP-EI-4.6-8 has been revised 8 times in less than four years. Other procedures and instructions have been similarly revised. The changes to these procedures are not always l 24
^
specifically marked with lines to the side of the page and in some instances are almost complete revisions, thus making it difficult to
-determine what the specific changes are. In addition, the controlled copies of the procedures and instructions at Comanche Peak in the past have not always been kept up-to-date /7/. This makes it difficult for individuals to know which procedures and instructions they should be following at any given time.
At the bottom of page 50 of Applicants' Affidavit, they state:
"The majority of these changes are, however, of a minor nature."
The design guidelines for field modifications (CP-EP-4.6) does not t classify or restrict the extent of any of the field changes. It should be noted that it was not until two days after Applicants' affiants signed their 7/3/84 Affidavit that Applicants issued Rev. 8 to TUGC0 Instruction CP-EI-4.6-8 (referenced in Applicants' Affidavit at page
. 51), to which the following was added:
"3.2.1 . . .
"Guidlines outlining the complexity and type of design changes to be utilized by CMC's shall be established by the Chief Engineer (s)."
(Compare attached copies of TUGC0 Engineering Division Instruction CP-EI-4.6-8, Rev. 7, issued 9/21/83, Attachment M hereto, and Rev. 8,
, issued 7/5/84, Attachment N hereto, page 2 of 6.)
I could go on and provide ex. ample after example of field modifications which are major in nature compared to the original
/ 7,/ See NRC Staff Exhibit 206, CAT Report, bound in following Tr. 6286,
-page IX-3, next-to-last paragraph, last paragraph continued top of page IX-4, and first full paragraph on page IX-4; also, page IX-4, item (3)a, second paragraph, and first two paragraphs on page IX-6.
25
I design. A change which makes a support unstable, for instance, is a major change, as Applicants' Witness Reedy testified in September of 1982 (Tr. 4973/5-4974/5). Of the drawings which CASE received on discovery on the Cygna Report, all the calculations for each entire support were done after the support had been installed in che field.
The reason for this, I believe, was that the changes were so large that no previous calculation would have been meaningful. An example is CASE Exhibit 939, for support RH-1-010-003-S22R /8,/, on the sheet labelled 2 of 5; there were no original calculations provided, and under design changes it states:
"As the structure has been modified completely in the field with new NPSI - Hardware, review of the entire structure will be done."
The implication from CASE Exhibit 939, and because of all the major changes in other supports (without Applicants having provided the original calculations), is that there was no design effort prior to construction of the pipe supports because of the CMC program.
For all of the redsons stated above, Applicants' fourth sentence in their fif th Statement of Material Facts is not true. For the changes to be commensurate with the original design, design review must come prior to construction. The first sentence of Applicants' fourth Statement of Material Facts atates:
"Each design organization has implemented design control measures which include verification and/or checking of the adequacy of each design, including the initial design of the pipfug or support prior to release of the design for construction.' (Emphasis in the original.)
f8/ Copies of CASE Exhibit 939 were provided to the Board and parties with cross-examination documents supplied to Cygna by CASE on 3/19/84.
Please advise if we need to provide additional copies.
26
What is stated in Applicants' procedures regarding CMC's is not consistent with the first sentence in Applicants' fourth Statement of Material Facts (as quoted above); for Applicants' procedures to be consistent with that sentence, all design changes would have to be completed and approved by the original design organization-prior to release of the design for construction.
Applicants state in their Affidavit at the bottom of page 51:
"CMCs require approval by authorized field engineers before release for further action, i.e., construction and submittal for design review."
However, as discussed in the preceding (at page 14 of this pleading), with Rev. 2 of CP-EP-4.6, issued 1/31/80 (Attachment E hereto), this was changed to engineers / technicians.
At the bottom of page 51, continued top of page 52 of Applicants Affidavit, they state that authority for approving changes by CMC's "is granted to individual Field Engineers by the PSE Chief Engineer, and is based on each person's work performance and experience." Nowhere in Applicants' procedures have I found anything to substantiate that there are specific criteria for the granting of this authority, much less what the criteria are. In addition, one must wonder what criteria were used in allowing the "somewhat knowledgeable" and "somewhat inexperienced" individuals to make design changes which created instability and other problems (see discussions at Tr. 4958/13-4959/8, 4961/22-4963/6, and Tr. 6403/5-6404/25, which were also referenced at pages XXVI - 2 through -10 of CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations)).
27 r
l
i I
At the top of page 52 of their Affidavit, Applicants state:
"It is common practice for the field engineers to perform calculations, request STRUDL analyses or consult with Design Engineers in PSE to obtain reasonable assurance that the change made will be acceptable when it is design reviewed."
It should be noted that this is not stated to be a requirement, and the results are not retained.
At page 52 (first full paragraph) of Applicants' Affi:3avit, they state:
"It is important to note that the CMC process was intentionally devise.d to provide a means to permit the craft without awaiting incorporation of the CMC into the design and design review."
(Emphasis in the original.)
As discussed in the preceding (pages 10 and 11 of this Affidavit),
it appears that this statement is questionable, bas'ed upon the wording of the procedures.
Further, it should be noted that there is no indication that any of Applicants' affiants were actually involved and have personal knowledge of what was intentionally done regarding the original CMC process; and none of Applicants' affiants is shown as the preparer or approver of the original or any revisions of TUSI Procedure CP-EP-4.6 (see Attachments D through K hereto), nor of the 9/2/80 original or 5/14/81 Rev. 1 of TUSI Instruction CP-EI-4.6-8, both of which are discussed by Applicants on page 51 of their Affidavit.
Applicants' procedures and instructions which I have reviewed do seem to indicate that the CMC process has been used to make changes in the field which led to deficient pipe supports, without first obtaining 28
I approval or consulting with those who have the responsibility for design. My review did not consider the consequences when the CMC's were used for piping, cable tray supports, instrumentation, or for other structures or systems. However, the results of my review of pipe o
supports calls into question all the other items which the CMC's were used for.
If Applicants did indeed intentionally devise the CMC process to provide a means to permit the craft to proceed with modificiations of supports without awaiting incorporation of the CMC into the design and design review, as they have stated is the case, this was a blatant and deliberate violation of 10 CFR Fart 50, Appendix B, Criterion III, and ANSI N45.2.11.
. This is also a violation of TUGCO/TUSI CPSES Quality Assurance Plan, Section 3.0, Design Control (pertinent portions of which are included as Attachment 0 hereto /9,/), which states, in part:
"3.0.3 Design Change
" Changes to the design are docummented, reviewed, and approved by
, the original designers commensurate with the controls applied to the original design. These controls extend to the disposition of field changes and nonconformances. Approved changes are incorporated into or identified on the original design document.
"The TUGC0 QA Division assures that the design process including design changes is performed in accordance with approved procedures. Gibbs & Hill and Westinghouse quality assurance l organizations audit their respective design organizations to j ensure compliance to approved procedures and instructions."
It should be noted that both these versions of the Plan were approved by an affiant to Applicants' Affidavit, D. N. Chapman.
l /9/ The attached portion is from the most recent version which CASE has, l dated 1/26/84. The exact wording for this particular section is also included in another revision which CASE has, dated 5/6/82.
29 -
l I
Since the Applicants have utilized this improper method of construct and design, and it is continuing, the audits which have been performed regarding these procedures are meaningless. They are meaningless because the audits have not identified this serious violation of NRC regulations and applicable codes.
Applicants state (page 52, last sentence of middle paragraph):
"In short, approval of the CMC by the authorized field engineer does not constitute approval of the changes as a design change, only a release to make the field change, subject to revision at any point by the support design organizations during the process of incorporating the CMC into the design and design review."
(Emphases in the original.)
Normally, the word " approval" on any controlled design document would be considered to be approval from the engineering organization, not approval from a "somewhat knowledgeable" individual. The approval is normally taken as approval from the original design organization.
This approval would be then commensurate with the original design and in compliance with NRC regulations and' applicable codes. It is unfortunate that the Applicants have misused the word " approval;" they have their meaning and the rest of the industry has a different meaning. (See also discussion at page 22 of the Walsh/Doyle Affidavit, CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue Regarding Stability of Pipe Supports.)
On page 52 of Applicants' Affidavit, first sentence, last paragraph, they state:
"The CPPE requirement that CMCs initiated by any discipline be de" rn reviewed either prior to or after release for implementation, is delineated in Section 3.2.5 of CP-EP-4.6,
' Field Design Change Control.'"
30
o I However, it does not appear that this was true until 1/31/80 when Rev. 2 was issued (see discussion at pages 12-14 herein).
There are other of Applicants' statements and procedures discussed in Applicants', Affidavit pages referenced as support for Applicants' Statement 5 which I would like to address. However, because of the limited time frame under which I am working, and the difficulty and amount of time required to thoroughly review the procedures and instructions obtained on discovery, I feel that I must at this time move on to the next Statement of Material Facts.
- 6. Applicants state:
"The as-built certification process for piping and support design provides assurance that the piping and support designs at Comanche Peak incorporate all design changes and that additional piping and support analyses ace performed, as necessary, to assure the adequacy of the as-built designs. These design changes are also subject to design review in a manner commensurate with the design control measures applicable to initial design.' (Affidaivt at 56-63.)"
I should point out at the outset that I have not reviewed any of the documents provided specifically regarding Gibbs & Hill or Westinghouse at the time of this Affidavit, and I am not addressing those documents here. There was simply so much information (supplied on discovery by Applicants in support of their Motion -- a stack about two feet tall) to go through that I decided in this Partial Answer to concentrate on only 3 of the 5 design organizations, with which I am most familiar: NPSI, ITT Grinnell, and PSE.
31
4 Since I have not reviewed all the documents, I cannot agree that Applicants' statements regarding Gibbs & Hill or Westinghouse are correct. In addition, it is my understanding that PSE and TNE are doing work which Gibbs & Hill used to do.
Regarding NPSI and ITT Grinnell, at page 60 of Applicants'
, Affidavit, they state:
The as-built certification processes performed by NPSI and ITT Grinnell for ASME Class 2 and 3 supports are very similar. The as-built certification process is conducted in accordance with CP-EI-4.5-4 ' Technical Services Engineering Instruction for Pipe Hanger Design Review and Certification' and in accordance with each organization's procedures. The NPSI work procedures governing this work effort are 3.1.6 'As-Built Design Review Procedure (ASME Class 2 & 3), 3.1.7 'As-Built Design Review Procedure (ASME Class 1), and 3.1.8 ' Procedure for Final
. Approval', which establish the methods for the review of the as-built support to the piping as-built analysis loads, and final certification of the support design by an authorized engineer.
For ITT, the procedures employed for this purpose are those used for the original design, discussed previously."
The ITT procedures were previously discussed on page 39 of Applicants' Affidavit, which stated:
"Q. Mr. Powers, what design specifications and requirements govern the ITTG support design process?
"A. Gibbs & Hill design specification MS-46A ' Nuclear Safety Class Pipe Hangers and Supports' is the controlling project design specification for pipe support design activities by ITTG. This specification is reviewed, accepted, and implemented in accordance with Section QCH-2.0 of 'ITT Grinnell Corp. QA Manual - Pipe Hanger Division' ('PHDQAM') and Section QCES-2.3.0 of 'ITT
~
Grinnell Corp. Engineering Services Quality Assurance Manual' l ('ESQAM')." /10/
i i
/10/ Applicants are refusing to provide CASE with Gibbs & Hill design ,
specification MS-46A on discovery (see discussion on page 2 and
- footnote 1 herein).
32
b l l
l l
At the bottom of page 61, Applicants refer to the final acceptance l of a support by stamping a BRH drawing " Vendor Certified" and signing the drawing. I believe that this vendor certified stamping process is a creature which the Applicants created to discredit the information which Mr..Doyle and I presented to the Board, and to mislead the Board into believing that we were just looking at preliminary design drawings. This was necessary because without additional verification beyond what Applicants had been doing, there was an obvious serious breakdown in their quality assurance program to assure that their pipe .'
supports could perform their intended function.
Based on what I know at this time, it appears that the reason this breakdown occurred is that the original design organization had an engineer approve the drawing and indicated that in the title block i
, under approval when it was issued to construction. But after the drawing was received onsite, they pasted over a new title block which indicated only drafting approval and not engineering approval. This change was not commensurate with the original design approval. All changes in the title block after that were drafting approval only. The Applicants did not have a procedure set up until 2/17/83 so that one I
could be certain that the drawing and the as-built. support had the approval of engineering and not just of draf ting. This new procedure came 7 months after I first testified before the Licensing Board.
In my review of documents in preparation of this Partial Answer, I attempted to determine whether or not the requirement existed that an f
33
l engineer ever sign off giving approval for the drawing. I did this by first reviewing TUSI Instruction CP-EI-4.5-4, " Technical Services Engineering Instruction for Pipe Hanger Design Review," Revisions 0, 1, 2, and 3; it appears that this requirement is not contained in them and that it was not included in this Instruction until Revision 4,
" Technical Services Engineering Instruction for Pipe Hanger Design Review and Certification," dated 2/17/83 (at Section 3.2.2), when the first mention was made of " vendor certified" (compare Revisions 3 and 4, Attachments P and Q hereto, respectively).
Section 2.4.2 of CP-EI-4.5-4, Rev. 3, referred to reference 1-A, which was shown to be CP-EP-4.5, " Design Verification." I then reviewed CP-EP-4.5. The most recent revision provided by Applicants, Rev. 1, dated 2/18/80, stated in item 3.4 "The design verification method, results and the verifier's approval shall be documented as described in subordinate instructions;" however, the subordinate instructions were not specified. I believe them to be CP-EI-4.5-4, which is discussed above. I therefore concluded that Applicants did not have a procedure set up until 2/17/83 so that one could be certain that the drawing and the as-buillt support had the approval of engineering and not just of draf ting.
This is further supported by the fact that while I was working at Comanche Peak, I had not heard of any vendor certification or vendor certified stamping program. I was aware that the supports were to be evaluated for the requirements of IE Bulletins 79-02 and 79-14 for the 34
I l
.~ ; \
l as-built condition. .The drawings which Mr. Doyle and I were concerned with were stamped "As-Built," leading me to believe that these supports were final design supports and constructed in the field with calculations already having been done to verify'that the support was acceptable. But the first time I ever heard of " vendor certified" drawings was during the September 1982 hearings.
Applicants did not refer to any " vendor certified" drawings in their prefiled testimony or their supplemental testimony regarding Mr.
Doyle's allegations for the September 1982 hearings /11/. In fact,
- in Applicants' prefiled testimony (Applicants' Exhibit 142), they refer to the "as-built" program (Finneran, page 25, A61), the final as-built piping and support verification program (Krishnsn, page 26, A62), "our as-built program" (Chang, page 28, A68), the final as-built analysis (Scheppele, page 33, A81), final piping and support system. ( page 34,
<. 083), a comprehensive as-built program and final ASME Code verification (Scheppele, page 34, A83), a comprehensive as-built program (Finneran,
, page 34, A84), the as-built program (Finneran, page 34, 085 and A85; and page 35,'086 and A86), and the final as-built piping and support analysis (Scheppele, Reedy, Chang, Finneran and Krishnen, page 36, A87). And in their Supplemental Testimony regarding Doyle Allegations
. (Applicants' Exhibit 142F, pages 6 and 7, 020 and A20), Mr. Finneran stated:
"Q20. Is it true, as Mr. Doyle has indicated, that a revision on
, a pipe support drawing that has been stamped 'as-built' indicates i that engineering review for the drawing is complete?
l l-l
/11/ See Applicants' Exhibits 142 (prefiled 9/3/82) and 142F, respectively, both aamitted into evidence on 9/14/82, at Tr. 4794.
35
- - . . .__ _ _ _ . - _ - . . . . _ _ _ _ ~ . _ _ , _ . . , . _ . _ . . . . , . _ . , , . _ . . _ - , _ _ _ . _ _ , . _ _ _ . , , - , _ .
g .. -
"A20. (Finneran) No. The approval block on the 'as-built' pipe support drawing signifies drafting approval only. It indicates only that all design changes have been incorporated into the pipe support drawing. To determine the status of the design review of a particular support, one must examine the design package for the pipe supports in the original design organization file. In addition, when the support has been finally reviewed to the 'as-built' piping analysis loads, the support drawing will be appropriately stamped and signed by a qualified engineer in accordance with program procedures. The documents that Mr. Doyle was referring to were not so stamped and signed by a qualified engineer." (Emphasis added.)
But, as discussed above, it appears that Applicants did not have a procedure set up until 2/17/83 so that one could be certain that the drawing and the as-built support had the approval of engineering and not just of draf ting. The procedure which did exist was CP-EI-4.5-4, which does refer to a design package, but this information (i.e.,
engineering approval) is not transmitted to the as-built construction drawing.
During the 9/16/32 hearings, Applicants presented Applicants' Exhibit 147, which was stamped " Vendor Certified Drawing;" it was Revision No. 4, dated 9/13/82 (see Tr. 5193/4-25; see also Tr. 5194-5202, 5295/5-5298/7, and'5305/8-5306/4). It is my belief that Applicants had not originally planned to include " vendor certified" drawings in their procedures, and that it was not until after I had testified and af ter Mr. Doyle had given his deposition that Applicants came up with t; tis " vendor certified" program.
This belief is based not only on the documents I have just reviewed for this Partial Answer, but is supported by the statements of l
36 l
t
then-NRC Senior Resident Inspector - Construction for Comanche Peak, Robert Taylor, during the May 1983 hearings (at Tr. 6404):
" JUDGE BLOCH: I'm sorry, but there is a question floating in my mind, which is whether you could reconcile the first answer with the second answer.
" WITNESS TAYLOR: Again I believe that is possible. Applicanc has as a result of their own findings, the allegations of Mr. Doyle and Walsh, and the SIT team findings, but largely of their own response in my view, has provided additional programatic controls primarily through the aspects of design review, what we now casually refer to as the VCD program, to eliminate the earlier phase errors of engineering.
"In other words, our iterative process." (Emphases added.)
Mr. Taylor refers to the Applicants' own findings as the reason the VCD program was established. However, these " findings" were not included in Applicants' Affidavit, nor has any evidence been presented to the Licensing Board to substantiate Mr. Taylor's claim in this regard. Mr. Taylor's reference to the NRC Special Inspection Team (SIT) findings is referring to the NRC Staff's investigation which came about becausc of the Walsh/Doyle allegations. Without the Walsh/Doyle allegations, there would have been no SIT team.
The SIT Report (NRC Staff Exhibit 207) was issued on 2/15/83 --
two days prior to the issuance of the procedure for what is now known as the Vendor Certified Drawing (VCD) program. On page 11 of the l Report, the SIT claims that they reviewed Instruction CP-EI-4.5-4. On pages 15 and 16, regarding steps 7 and 9, respectively, of the Applicants' iterative design program, the SIT refers to the supports being stasped " vendor certified." On pages 54 and 55, the SIT refers l
l
- 37 i
,_ -. _~ _._ ._ ___ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _
to " Inspection of Vendor Certified Supports." The SIT's position at the time of the SIT Reports was that all the supports but one from the Walsh/Doyle allegations were " interim designs," and not vendor certified. But the SIT Report neglected to inform the Licensing Board that there was no procedure in place for the VCD program at the time of their Report. What the SIT attempted to show was that the concerns that Mr. Doyle and I had were regarding preliminary designs, not final designs, and that a program was in place to correct all design deficiencies. This program was not in effect while I was employed at Comanche Peak, nor was it in effect while the SIT was at Comanche Peak.
This position which was taken by the SIT only demonstrates again the NRC Staff's position of being biased toward the Applicants (see also CASE's Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), pages XXVII - 35 through -39).
- 7. through 16.
I cannot agree with Applicants' Statements 7 through 16, since I have not had time to adequately review and address them or the information provided to back them up. I would have liked to have had additional time in which to address the specific Statements further.
As stated earlier in this Affidavit, the two-foot tall stack of documents, and the difficulty and amount of time necessary to review and analyze them, have made it impossible to adequately review and discuss all of them at this time.
38
g .. +
In addition, the Moard should consider all of the other CASE's Answers to Applicants' Motions for Summary Disposition as they pertain to Applicants' design and design QA/QC program, since there are numerous examples of breakdowns in their program contained in those Answers, which are too voluminous to repeat here. However, I corporate them herein by reference, and with additional time, CASE could provide
, a cross-reference to those Answers for the Board's convenience.
Further, the Board should consider all of the information contained in CASE's 8/22/83 Proposed Findings of Fact and Conclusions of Law (Walsh/Doyle Allegations), especially, but not limited to, Sections XIX, XXV,' XXVI, XXVII, XXIX, and XXX. It would have been necessary for me to have submitted a docitment similar in volume and content to CASE's_ Proposed Findings in. order to adequately address and answer Applicants' Motion for Summary Disposition. Obviously, this was not possible in the length of time available, but I b'elieve that CASE should be allowed to supplement this Partial Answer and ask that the Board allow us to do so.
39
gVh The preceding CASE's Answer to Applicants' Statement of Material Facts As To Which There Is No Genuine Issue was prepared under the personal direction of the undersigned, CASE Witness Mark Walsh. I can be contacted through CASE President, Mrs. Juanita Ellis, 1426 S. Polk, Dallas, Texas 75224, 214/946-9446.
My qualifications and background are already a part of the record in these proceedings. (See CASE Exhibit 841, Revision to Resume of Mark Walsh, accepted into evidence at Tr. 7278; see also Board's 12/28/83 Memorandum and Order (Quality Assurance for Design), pages 14-16.)
I have read the statements therein, and they are true and correct to the best of my knowledge and belief. I do not consider that Applicants have, in their Motion for Summary Disposition, adequately responded to the issues raised by CASE Witness Jack Doyle and me; however, I have attempted I to comply with the Licensing Board's directive to answer only the' specific statements made by Applicants.
.~
(Signed) Mark Walsh i
l STATE OF TEXAS On this, the }T day of (p , 1984, personally appeared Mark Walsh, known to me to be the person whose name is subscribed to the foregoing instrument, and acknowledged to me that he executed the same for the purposes therein expressed.
Subscribed and sworn before me on the 1k day of d ,
1984.9
,- t nnk_k Wo
" Etary Public in an'd*for the
, '( !j State of Texas
, y .' SAMUEC W. NESTOR My Com ission Expires: DM
+
, m $1k'
Communications
$ [tj g i ATTACHMENT A Report lillililllllllilillllllillllll compenr Texas Utilities a Teicon 10 conference neport -
' Job No.
Comanche Peak Steam Electric Station 84042 Independent Assessment Program - Phase 3 Date:
5/10/84 !
subsect Corrective Action Systems "** 12:50 p.m.
Place:
PSES
Participants:
of 3, gj g g, yjjjj CES D. Wade, R. Tolson TUSI Recured item Comments Action By We asked to meet with D. Wade to clarify in our minds exactly what " vehicles" were used at CPSES to document design deficiencies. Dave asked that R. Tolson be brought into the discussion.
Tolson and Wade explained that in addition to such documents as Nonconformance Reports (NCR's), Deficiency Review Reports (DRR's), Corrective Action Requests (CAR's), Significant Deficiency Analysis Reports (SDAR's), etc., other documents could be used to document design deficiencies. These documents are Computer Modification Cards (CMC's), Design Change Authorizations (DCA's), and Inspection Reports (IR's).
Tolson explained that he didn't feel it was important relative to what you called the piece of paper, as long as the deficiency was documented.
signeo. Of Page }
([ h /rg 1 Distnbution. N. Wi lliams, U. Wade, b. brace, 5. tilbo, 5. Ireby. d. L i ll s, Proj ect F i le
N Communications 3 ATTACHMENT B Report
!Il!!!Ill!!ll!!!I!!!!!!!!!!!!!
company: Conference Repon T * * "
Texas Ut111 ties x Project Job No.
Comanche Peak Steam Electric Station 84042 Date:
Independent Assessment Program - Phase 3 5/3/84 subject Time:
1:00 p.m.
Place:
Review of CMCs CPSES
Participants:
of Mike Strance TNE Shaid Ali TNE D. Smediev ,,
Cvona Aeouired item Comments Action By
- 1) Asked Mike how many CMCs and DCAs existed from day #1 until now, how they are numbered and how CES could easily determine which CMCs are design related?
His response was that:
- a. Current # of CMCs to date is 97894 (CMC
- 18,400 through 30,000 were not used) so actual # of CMCs issued to date is 86,294.
- b. 20,300 DCAs and DC/DDAs have been issued to date.
- c. Approximately 36,000 CMCs issued are pipe support related and are not tracked by DCTG, and are not G&H design related.
- d. DCTG can identify which CMCs are pipe support engineering related if CES requires that information.
signec. ' - Page of d/l) l' ld ff LLm
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leam 1 1 D'5tneut'on: __N._ Williams,J)._Made,_G._ Grace,_S. _B1 boJ._Iteby,_J. _El1i s, Project File
Communications .
[4(rjlfgj ATTACHMENT C Report lilllllllimmiiiiiiiiiiiiii Texas Utilities g Tek n Conference Repod Project Job No. -
Comanche Peak Steam Electric Station 84042 Independent Assessment Program - Phase 3 gfigfg4 Subject Time:
Inspection Reports 4:40 PM Place:
Rnenn Participants- of S Ribn rynna Donna l_ewellen THei ReQJted item Comments Action By Donna called me per request of Tony Vega to supply me with requested informatior, relative to the number of Inspection Reports (irs) issued at CPSES. Donna stated that between the "old" IR system and the "new" IR system there are in excess of 150,000 irs. She stated that the new system has a computerized log but that the old irs were manually logged. The old system contains about 100,000 irs. Donna explained that the number of irs given is her "best estimate".
We also discussed procedure CP-QP-18.00. Donna inforraed me that D. Lewell.
this procedure was up to revision 17. I asked her to send me revisions 12 thru 17.
l l
l Ssgned:
Page of yb /h ///#4f A ,
/dhb 1 1 D'"*"* N. Wilkiams, D. Wade, G. Grace. D. Smedley, S. Bibo, S. Treby, J. Ellis,
l ATTACHMENT D
.: . . zrEmS'/
E TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE
/~~ .
CP-EP-4.6 0 8-13-79 1 of 23 PREPARED BY /-
DESIGN CHANGE CONTROL -
APPR0iED BY -
V'1 l' 1o a - "=s 1-A TUGCO/TUSI CPSES QA Plan MST0ECh 9LE 1-B CP-EP-3.0, Corranche Peak Project Engineering Organization 1-C CP-EP-4.0, Design Control General Requirements 1-0 CP-QP-2.3, TUGC0 Operation Traveler 1-E CP-EP-5.0, Procedure for Field Procurement 2'0 GENERAL r -
2.1 PURPOSE FOR INFORilATION ONLY .
This procedure establishes the method for control.and documen-tation of design changes to approved design documents by the Comanche Peak Project Engineering (CPPE) group.
This procedure will_ ensure.that design changes .are jriginated,'
reviewed'and approved.by qualified organizations having' access' ?#
~. to^ all pertinent background data."2These' organizations are
' identified, documented and subject to control measures comen- e surate with those, applied to the original design.*}, .
2.2 SCOPE 2.2.1 Changes to design or construction documents may be originated by any of the project related engineering, construction, operating or quality assurance groups.
2,2.2 This procedure may be used to process requests for interpre-tation or clarification of design ancuments.
g g nIled)
~
2.2.3 to design ~or construction M (Changes..
'.in accor dance lwiththefollowins me hods:
Tt, y PPRV --
E TEXAS UTILITIES SERVICES INC. REVISION PAGE CP-EP-4.6 0 8-13-79 2 of 23 2.2.3.1 Design Change Authorization (DCA) will be completed in accord-ance with step 3.2 for:
- a. G&H Specifications and Drawings
- b. All Desigt. Ihanges Which Must be Transmitted Offsite
, for Vendor Acceptance
- c. G&H Design Changes Generated by DE/CD 2.2.3.2 Component Modification Card (CMC) will be completed in accord-ance with step 3.3,for:
- a. G&H Design Basis Drawing Changes Generated Onsite
- b. B&R Construction Drawings
- c. Vendor Design Drawings With Onsite Representative 2'.2.3.3 Field changes will-be accomplished in accordance with step 3.4 for: .
('-
- a. Changes to equipment or components already received onsite, including changes to NSSS equipment initiated by a Westing-house FCN or ECN.
- b. Changes to equipment or components where Comanche Peak Project Engineering is responsible for the change or designated as the design organization for the effected
. equipment in accordance with reference 1-C.
l c. Other changes where this procedure and documentation would help implement and control the change.
2.3 DEFINITIONS 2.3.1 Group Supervisor - Person responsible for a CPPE discipline specified in Reference 1-B, 3.0 PROCEDURE 3.1 PROCESSING DESIGN CHANGES 3.1.1 (Allrequestsjfor. changes';.to7desiinir. < 9 Tsha11 be received b ' > tN
%n't!
F his 4 d des}gnee ?p "~" y ' the'. appropri ata y
- PPRV
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. -e TEXAS UTILITIES SERVICES IN
C. PROCEDURE
REVISION PAGE 7 -
y-CP-EP-4.6 0 8-13-79 __
3 of 23
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3.1.2 The group supervisor will detemine 1f the design change is to be implemented as a field change to vendor supplied equipment.
Refer to Section 3.4 Implementation of a Field Change.
~~
3.1.3 The d5sigi~cha'nge rehesEwill be processed and documented by the CPPE_ staff engineer. designated in Step 3.1.1. Requests that are not acceptable will be returned to the originator.
+. .a
~
3.1.4 If frequired, ~the' CPPE itaff, engineer consults with:
- a. The original" design organization ('e.g. G&H) to detemine the acceptability and ccmplexity of the change and the level of design verification required.
~
An onsite vendor (if available, (e.g. Westing-b.
house) for implementation of field changes to vendor equipment.,
- c. 05er[v5 dors,Kr~equired.3
.-- 3.1.5 The appropeist.e' documentation is then completed in accordance with Step 3.2, 3.3 or 3.4.
3.2 DCA PROCEDURE 3.2.1 The Design Change Authorization fom (Figure 1) is completed as follows: -
- a. Authorization No. - Assigned by the Administrative Services Office when the DCA is ready for signature.
- b. (WILL) WILL NOT) Be Incorporated in Design Documents-Cross out the one that does NOT apply.
As a general rule, design changes to a specification I which are generic in nature and will affect future
{
work on a continuing basis shall be designated for
' incorporation as will one time changes to design drawings that can be delineated on the drawing. In i t.'.e case of a one time change to a specification .
requirement, the change will aormally rot be incor-porated. Clarifications and/or interp.re w U m s M volving design documents will nonna llj go
- porated into the design document. It 1 tr%gre. tM v c COP 3 c PPRV e .e-a -- w -n--.-,.-,e,-- -. - <-a-- - -----.-.,----,-.--r--
PROCEDURE REVISION PAGE TEXAS UTILITIES SERVICES INC. h5 E c ~
CP-EP-4.6 0 8-13-79 4 of 23 conized that specific guidelines covering every
- situtation cannot be delineated in this prece-dure; as such, it will be the responsibliliy of the originating engineer to excercise judgement and designate whether or not a change should be incorporated.
- c. Safety Related Document - Check the appropriate block.
- d. Applicable Spec /Dwg/ Document - Cross out the two wat do not apply.
1 List all documents and current revision number affected by the change.
- 3. Details - Provide information on the change under consideration using adequate descrip-tions or references to other documents which clearly illustrate the problem.and its re-solution and provide sufficient infonnation r- to the "as-built" configuration.
- s. _ .
For field changes to vendor supplied equip-ment see Section 3.4 for additional require-i ents. -
- f. Supporting Documentation - Reference support- -
ing documents such as telephone conversations, -
telexes, telecopies, DE/CD's, sketches, field change notices, etc.
3.2.2 Completed DCA's are assigned a number, logged and typed by the Administrative Services Office. Handwritten forms will be accepted in isolated cases where typing is impractical.
T3 .2.3) The DCA is then reviewed for technical =.cceptance by the re-sponsible engineering descipline and concurrence is indicated by signing and. dating the " Approved By" blanks as follows:
- a. Design changes shall be signed by the G&H Design '
Representative or his designee (the orginatino engineer if possible).
b.ahrReridi,rEn user shwg ,JF,@j,ATION
~
"Tauthorization o hers~onnel.hes<
"G&H Design Representative"'or ep es ^[i
!.tative of any other vendor.*: ,
, - . . - ~ . , m . ..a . 5 PPRV
l
. . . . . - _ . . . . . . - . . .. -- . . . 1 TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE I CP-EP-4.6 0 8-13-79 5 of 23
- c. Clarificatiens require only the signature of the ?
originating engineer.
3.2.4 DCA REVISIONS Revisions to a DCA will use Figure 1 and are filled out in accordance with Step 3.2.1 with the following exceptions:
- a. The same autharization number shall be used.
- b. The appropriate revision number shall be placed after the authorization number.
- c. Su'bsection 1.'B, Details, shall contain the following: -
"This revision voids and supersedes Design Change Authorization No. __,
Revision .
3.2.5 DISTRIBUTION ,
C a. Original to B&R Document Control b.
Administrative Services shall use the standard distribution specified in Figure 1. All copies shall be marked "For Engineering and Office Use Only".
- c. B&R Document Control shall be responsible for all onsite controlled distribution. Distribu-tiun shall be in accordance with distribution of the affected document.
3.2.6 VENDOR CONCURRENCE If the change requires vendor concurrence, the the follow-ing additional action shall be taken:
- a. The Adrainistrative Services Group shall prepare a "CPPA" letter (Figure 2) in tripl + ate- te m - ..
mitting the TUSI approved design to l requesting vendor concurrence to tha tch thirbpr MATION l
- b. The vendor :all indicate concurrenc change by signing .all three (3) cop < of (t'hefj ;j~ksy letter and making distribution of th end/1.k 4.
as indicated in r'igure 2. -
PPRV
E TEXAS UTILTTIES SERVICES IN
C. PROCEDURE
REVISION PAGE i
(
CP-EP-4.6 0' 8-13-79 6 of 23 o
I
- c. On receipt of the vendar acknowledgement, the ,
originating engineer shall be notified. If ex-ception is taken to the design change, the ex-pediting coordinator coordinates resolution of the outstanding item and initiates supplements required.
~3.3 CMCPROCEDURE~(SinglePart(blue)CMCCard)'
3.3.1 The Component Modification Card (Figure 3) is completed as follows:
NOTE: Refer to sections 3.3.3 or 3.3.4 as applicable.
- a. Serial No. - Prenumbered
- b. Section 1, Application - State generic category of work (e.g. mechanical equipment, electrical equipment, pipe, pipe supports, etc.).
Q,;Non-Q -~ Check *ap;ir~opfiate blo~ck. 7 b . Design' Change Check appropriate block. ~
- c. Section 2 Dwg. No. - Enter the complete mnber and revision of the affected design basis and/or construction drt. wings as follows:
- 1. Electrical, enter design basis drawing l , numbers.
- 2. Piping and Instrumentation, enter the design and construction drawing numbers.
~ ~
'3. " Pipe'~ Supports','edtir~thidesign' anicon ,'
' struction drawing numbers.'t; i
- d. Section 3 Line l'9./ Component No. - Enter the specific identification number of the component l to be modified; hanger number, spM . T.6, l-equipment number, or N/A as appli :a 1 , m M T S ,
- e. Section 4, Reason for Change - St i i concisely the reason for the chang l 9
- f. Section 5 Instructions - Describe h1'd accurately the change to be made.
W
E TEXAS UTILITIES SERVICES INC. PROCEDURE REVISIdN PAGE r' '
CP-EP-4.6 0 8-13-79 7 of 23 ,
- 1. Where there is no weld removed or added -
enter "N/A" in the appropriate blocks '
and describe the change.
- 2. For removal and/or addition of welds, .
. check the appropriate block and enter all weld numbers removed and/or added.
- 3. If, after the original issue of the drawing, a weld has to be removed and rewelded, the weld number will be changed to signify this by adding an "A" for the first cut out, "B" for the second cut out, etc., to the weld number, e.g. weld 6, reweld is 6A, and if 6A is removed and rewelded, it becomes 6B.
- 4. If, after the original issue of the drawing, an added weld is required, -
not a reweld of an existing weld; the new weld number will be keyed to the 0 -
io r or the two a==6 red ids aad suffixed by "1" for the first weld,
~
"2" for the second weld, etc. e.g. ,
if a weld is added between "1" and "2", the new weld will be "1-1".
- g. Section 6- Provide sketch indicating the existing and/or new arrangement when necessary for clarif-ication.
- h. Section 7- Requested / Prepared By - Enter the name (and department as required) of the individual preparing / requesting the modification.
~
- i. Section.
shall ap.8- Appr6v4d prove the ' change Byand .The 071ginating designate any ',other engineer
?- ~.
approvals required." Addltional approval .is'~re- '
' quired by'the origina1' design organization or-their representative. (see'3.2.3.b) prior to I
. issuing the. CMC unless specificallyj by a' CPPE proceduie~or', instruction.
[h g
~
NOTE: Refer to seEffiiii'~3.3!3'5r'3.3 CMC approva1' criteria.
- g i AT j'
f 4
W
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e
_~-----,...-.,..-_.-m.. ~ . _ _ _ . , , - . _ , . _ , - . _ , . . . _ . - _ . . . , . . . , . . . . , . , . . . - . , , , - . , , , , .
1 E
TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE c- CP-EP-4.6 0 8-13-79 8 of 23
~
- j. Section 9. Distribution - The engineer preparing ' - ' 1
'the CMC shall enter (on the front of the CNC) the name of each agency requiring distribution in addition to the controlled distribution made by DCC, and shall indicate the number of copies re-quired for each. Distribution of the single part (blue) CMC cards shall be as follows:
Refer to Section 3.3.4 for Three-Part Memo card distribution.
- 1. The group clerk will make copies for dis-tribution to the following agencies:
-TUGC0 Site QA
-Original' Design Organization ~-
-Field Support Design Group ,
The above copies shall be marked "For -
. Engineering and Office Use Only". -
C 2. If additionai copies are designated -in Block 9, it is the responsibility of the originating organization to reproduce and distribute the copies. These copies will
. be marked "For Engineering and Office Use Only".
, 3. The group clerk will the7 send the original
, or a copy to DCC where formal distribution j will be made. When a CPPE discipline re-tains temporary custody of the original single-part (blue) CMC card, an instruc-tion shall exist to provide document control, distribution and eventual trans-mittal to DCC.
~3.2.'2 Revisich'^of Single ~Part (Blue) CMC Cards 1
" Revision to a CMC card may be used by utilizing a new form (non-serialized) and filling it out as outl'nd " ma 1 d'1 with the following additions.
- a. The same serial number shall be usec
'NFORMATION i D '[f
- b. Tiie appropriate revision nurr.ber sh ,1b lace'd'j*?
( adjacent to the serial number. ' di ,
PPRV O
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. TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE CP-EP 4.6 0 8-13-79 9 of 23
- c. The CMC card shall contain the following state-
- ment:
"This revision voids and supersedes document Serial Ntsnber . Revision
- d. When an occasion arises where a CMC has been issued and for some reason that card is not needed, it must be voided. To void a CMC the original card must be revised and clearly marked " Void - Not Superseded".
3.3.3 Alternate Four Day Distribution The single part (blue) CMC card is congleted in accordance with Step 3.3.1, Section 1 through 8.
~
After al1' required' approvals have" been obtained in accordance with section 3.3.1.1, the CMC nay, at the discretion of origina-ing engineer, be reproduced and distributed for construction in the following manner:
I
- a. The reproduced CMC copies shall be stamped.in accordance with Figure 4 and signed by the ',
originating engineer or cognizant engineer.'
b'. Distribution shall be made to all parties requir-ed to perform and inspect the work.
- c. The original CMC, upon completion of. reproduction, l
shall be distributed through normal channels.
- 3.3.4 CMC Procedure (Three Part Memo CMC Card) , .
The Three-Part Memo CMC card is completed in accordance with Step 3.3.1, Sections a through j.1 Complete sections 8 and 9 on the CMC card in accordance with the following instruction:
, . _ - ~ ~
- a. Section 8, Approved By ,- The 'originiting engineer ~
shall approve the change and designate any other "
approvals required. Design changes shall include '
Japproval by the- original .d.esign. o"W'=Haa a-p SAfter the required approvals'have b<
- thWoFi in'ating' engineer may~ dist e C- (canary copy;toiconstruction ~ in o r v' Fw.,field work to proceed. ( -~ '^
. . u . - -
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I E
TEXAS UTILITICS SERVICES INC. PROCEDURE REVISION PAGE CP-EP-4.6 0 8-13-79 10 of 23 Section 9. Distribution -
b.
-Original (White) copy - routed to the original design organization representative for approval.
Approved originals are distributed in accordance with Step 3.3.1.j, Section 9.
-First (canary) copy - transmitted to construc-tion for use with working documents (e.g.
travelers, design drawings, FSE's etc.).
-Second (pink) copy - utilized by the Field Support Design Group.
3.3.5 Revision of Three-Part Memo CMC's
- a. Prior to distribution and/or separation of Three-Part CMC, minor corrections may be made by drawing a single line through the incorrect portion. The ,
engineer shall initial and date the correction.
. Once the Three-Part CMC has been distributed, cor-rections WILL NOT be permitted.
- b. Three-Part CMC's WILL NOT be revised. When a Three-Part CMC requires revision, a new Three-Part CMC form (with a new serial number) will be issued.
- c. The face of the new Three-Part CMC shall be stamped i
"This CMC supersedes and voids CMC number ,
revision .
- d. Three-Part CMC's that are written against a design
, document (drawings, etc.) that is already affected by previous design change (DCA, CMC already exists),
will be stamped "This CMC supersedes and voids CMC
, nimiber , revision .
3.2 FIELD CHANGES TO VENDOR SUPPLIED EQUIPMENT 3.4.1 Design changes that are to be implemented as field changes' ,
will be initiated by the responsible 9 4neering discigline j preparing a TUGC0 Operation Traveled (i p- ano o 7 l
accordance with reference 1-D. 1J fgg, .c.
3.4.2 The responsible engineerihg'~discipi O~
log of each fie.1d change including: .
?-
V c PPRV
4 TEXAS LI1'ILITIES SERVICES INC. PROCEDURE REVISION PAGE
-.g .
CP-EP-4.6 0 8-13-79 11 of 23
- a. Operation Traveler Number -
Date initiated b.
- c. Brief description and reference (including FCN)
- d. Completion date for field change
- e. Completion date for revision of plant docunen-tation, drawings, etc.
3.4.3 The operation Traveler Package shell contain attachments for all documentation required to implemnt the field change.
This shall include applicable infonnation in sections 3.4.4 and3.4.8. Refer to 3.4.9 for additional requirements for field changes to NSSS equipment initiated by a Westinghouse FCN or ECN.
3.4.3.1 When the quantity of documentation to be attached to the Operation Traveler is excessively large, selected portions of the documentation (eq. FCN cover sheets) may be attached, with the remainder of the documentation retained elsewhere.
The Operation Traveler must clearly indicate where the re-maining documentation is filed.
1.4.3.2 After the Ope" ration Traveler has been approved, the res-C/
ponsible engineering discipline may maintain a separate, easily accessible file for field change documentation that is not required to be continuously attached to the Operation Traveler. This file will become part of the Operation
! Trafeler Package at the completion of the field change. The Operation Traveler must indicate clearly where the docunen-tation is filed.
3.4.4 Identification of Interfaces The field change will be evaluated for impact with external and intern:1 interfaces, existing plant systems and other CPSES egineering disciplines. These interfaces will be docunented in writing and made part of the Operation Traveler Package.
~
- a. External interfaces with the vendor will include:
-identification of all applicable vendor design documents and drawings. ,
-identification of applicable veJMORMAT40N-tive, e.g. on site representa1 1v
~
LOPY PPRV
E TEXAS UTILITIES SERVICES IN
C. PROCEDURE
REVISION PAGE O. CP-EP-4.6 0 8-13-79 12 of 23 l ~
I
- b. It is the responsibility o'f the CPPE group super- -
visor implementing the field change to: '
- 1. Verify that each CPPE discipline reviews the field change package.
l
- 2. Identify all internal interfaces.
- 3. Coordinate design activities across all internal interfaces.
- 4. Incorporate documentation crossing internal interfaces into the field change package.
- 5. Thoroughly review each field change to det-ennine its affe:t on other plant systems.
- c. Gibbs & Hill (N.Y.) will be identified as an external interface for all field changes where CPPE has been delegated design responsibility (reference 1-C, 3.1.1).
This is to allow review of the. field change for impact on overall CPSES design, including Unit 2. -
3.4.5 Detennine Scope of Field' Change (
- a. Identify design documents nd drawings that will re-quire revision and the method by which the revision will be accomplished.
- b. Identify paits required by field change that have not been supplied by the vendor.
- c. Determine documentation required for implementing the field changes, e.g. marked up series from vendor or site, revised drawing from GaH, etc.
- d. Detennine which organization is to implement, the design change.
- e. Detennine if construction testing is reautred =ad 7 who is to perform the tests. ,
. . . . my.- JNFOR ATION
- f. Submit to TUGC0 Quality Enginee of inspection and QC' hold point ing(r Tor sepeg{1 tto~
[
i .,
C. PPRV
REVISION SE -
PAGE TEXAS UTILITIES SERVICES INC. PROCEDURE g Cp-EP-4.6 0 8-13-79 L3 of 23 I
3.4.6 Evaluation of the Field Change -
9
- a. Verify the field change meets the requirements of the applicable purchase specification, design codes, re-gulatory guides, etc., that were used by the original design organization.
- b. Provide for any required design review by the applic-able design organization.
- c. 6etermine the impact on the construction schedule,
- d. Detennine the impact on the startup program and startup test program.
- e. Determine if any vendor warranties are affected.
The Procurement Management Group will interface ,
with the vendor when warranties and vendor QA are involved. Where the vende is to perfonn the de-sign review function, this must be clearly specified
. in writing. The originating engineer shall be noti ,
fied of vendor concurrence or exception.
3.4.7 Implementation
- a. Complete the Operation Traveler
-include step by step instructions in sufficient detail to implement the field change.
l -incicate QC hold points, inspections etc. , that require sign-off approval (Step 3.4.5.f) l l
-s'pecify the department responsible for each step.
- b. Attach any additional documentation to the Operation Traveler Package.
- c. Issue DCA's, CMC's and other required revisions to j design documents, including FSAR changes. FSAR changes i, will be sent to TUSI Lisensing Group in Dallas.
l l d. Submit completed Operation Travele w QA in c.wrdam.e
! with reference 1-D.
INFORMATION
- w. .
M OOry PPRV
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_ _ - . ,.m, _.,-.
TEXISUTILITIESSERVICESINC. REVISION PAGE PROCEDURE h5 E e
CP-EP 4.6 0 8-13-79 14 of 23 I
- e. Initiate revision of vendor drawings. -
- f. Submit completed purchase requisitions in accor-danc.e with reference 1-E.
NOTE: The Procurement Management Group will deter-mine the applicable purchase method.
3.4.8 Dociscentation
- a. Copies of approved TUGC0 Operation Travelers (with-out attachments) shall be distributed by the engineer-ing discipline group clerk. Each copy shall be stamp-ed "For Engineering and Office Use Only ".
- b. Standard distribution shall be:
~
-B&R Field
-G&H New York
-q&H Dallas
. -TUGC0 Operations, site .
-discipline engineering files (held until field i change drawing revisions are completed)
NOTE: additional distribution shall be indicated on the Traveler (eq. Westinghouse),
- c. At the completion of the field change (except drawing revisions) the original copy of the Operation Traveler shall be returned to the responsible engineering dis-cipline.
The Operation Traveler Package shall be checked for completeness, any additional documentation appended.
l and package fomarded to TUGC0 QA in accordance with reference 1-D. The completion date shall be recorded
, (step 3.4.2).
- d. A memo indicating completion of a field change will be distributed by the engineering discipline group cleri in accordance with step 3.4.8.b.
~
- e. Each engineering discipline shall pMadke!!y =h document and drawing revisions requ' rei %
changes. It is the responsiblity of ea H ~<m g'5 hM Ul4 discipline to expedite these revisic n r k l
completion (step 3.4.2).
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TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE h5 E 6 CP-EP-4.6 0 8-13-79 15 of 23
. I Field Changas to Westinghouse Equipment /
3.4.9 3.4.9:1 Field changes to W NSSS Equipment will be implemented or
. supervised only by W NSD personnel or on a case by case basis by their designee. All changes will be perfonned using the instructions as stated on the W " Field Change Notice" or by letter signed by W_ NSD site manager.
. 3.4.9.2 The requirements for Quality Review, Testing required and Data, will be designated on the a~pproved W Field Change Notice, Engineering Change Notice or W leiter. _
3.4.9.3
- An Operation Traveler for each FCN or W 1etter will be completed by the responsible engineering discipline to implement the requirements of 3.4.9.1 and 3.4.9.2.
I 3.4.10 Revisions to the Operation Traveler i 3.4.10.1 The Operation Traveler will be revised using the Opera-
- tion Traveler Revision Record (Figure 7) in accordance with step 3.3 of reference 1-D.
3.5 NON-AGREEMENT OF RESOLUTION OR CHANGE - CMC'S OR DCA'S 3.5.1 If the original design organization should disagree with the resolution of a particular change, they will notify the group supervisor (see 2.3.1), who will, on the area in question, place a " Hold" or recind and reissue the design change. Any corrective action required in these j j problem areas will be evaluated on a per case basis.
3.6 ' CHANGE APPROVAL ON WEEKENDS OR OVERTIME PERIODS 3.6.1 If a design change is required by the constructor on weekends or during overtime periods (times when CPSES Project Staffs are not normally on site), a contingent approval may in accordance with the following steps, be given:
3.6.2 Construction Management (Project Manager, Assistant Project Manager or Project Engineer) will obtain the '
necessary details required for the d=f; . ; .u. 3= ena h .
Eng[npring and Constr actgggg . ,
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TEXAS UTILITIES SERVICES INC. E
, PROCEDURE REVISION PAGE J
l CP-EP-4.6 0 8-13-79 16 of 23 l 3.6.3 The Engineering"and Construction Manager or his designee identified in Step 3.6.2, will review the change, make com-ments as required and approve or disapprove the request.
3.6.4 Construction management will document the telephone conversa-tion (including a description of the design change, coments given and disposition of the design change) and proceed in accordance with the disposition of the change, with the work -
in the field.
3.6.5 All required documentation for the change (DCA, CMC, etc.)
will be initiated on the next normal working day. The com-pleted ~ documentation described in Step 3.6.4 above shall be attached to and become a part of the change documentation (DCA, CMC,etc.).
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TEXAS UTILITIES. SERVICES INC. E Pi'.0CEDURE REVISION PAGE CP-EP-4.6 0 8-13-79 17 of 23 FIGURE 1
. . hy l of CNANOE PEAK SIDM EI.CTRIC STATIM DESIGi OIANGE MIDORIZATIN (WILI) (WILL NUT) BE INCDRPORATED #1DERI*ATIM 10.
IN DESIGN DOQNENTS SAFEIT REIATED DOGNEhT YES NO
- 1. DESCRIPTT W:
A. APPLICABIZ SPEC /DC/IDQNENT REV.
B. IETAILS 4
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j Gr.H Bepresentative Date
- 3. APPROVED BY:
uriginating anginee. unte
.. ST- S- inW: INFORMATION B6R Field (Original) (1)
C5H New York (1)
- Q7 hyN' ,
r GUI Dallas (1) ,- ,, g 4 *; l 11XZD Site @ (1) e .g.a. ame i FSDG Site (1) l D 7 '! il j I .* ' * * . .-
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ISSUE TEXAS UTILITIES SERVICES INC. ' PROCEDURE REVISION PAGE MTE CP-EP-4.6 0 8-13-79 18 of 23 I
FIGURE 2 ,
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i TEXAS UTILITIES SERVICE 3 Iht.
I P. & Best less . C& ass mess.133As me l CPPA .
I
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I CtPtANOIE PEAK STENi ELECTRIC'5TATION 1981-83 2300 !8W INSTALLATI0!t TRANSMITTAL OF -
DESIGN OIANGE AUTHORIZATION NO.
P. O. CP-l Jear 5fr:
l Enclosed please find three (3) copies of CPPA trans-
- s. sitting Design Change Authorization No. ____.
Please sign all three (3) copies of the cover letters retuniing one (1) copy to the undersioned; one (1) cc7y to Gites & Hill. Inc., to the
' attention of Mr. M. R. Rock, and retain one (1) complete with attactunents ter your files.
. If you have exceptions to the design chance or additional cost is 19volved.
clease attach a detailed listino of your exceptions an.d/or an itemized list of cost adjustments for our evaluation. If your procosal is found acceptable an appropriate supolament will be issued to you to allow work to courence.
If there are any questions or comuments, please contact this offica.
Very truly yours, i
N. R. Mc9ay Expeditino Supervisor
' " " " ~ ~ '
r ,,
H. R. Rock. IL 1A VEN00R'5 3.'LY AU K) iNi URMATiON r
R. E. Hollowev. IL. 1A j
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TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE O'-
CP-EP-4.6 0 8-13-79 20 of 23 1
FIGURE 4 '
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ISSdED FOR CONSTRijCTION FOR A PERICO NOT TO EXCEED 4 DAYS FROM THE FOLLOWING:
t o ,
DATE DI.SCIPLINE ENGR. .
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TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE
,.... TE O l CP-EP 4.6 0 8-13-79 21 of 23
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FIGURE 5 ,
TEXAS UTILmES GENERATING CO3fPANY acurm no so.
mmza amszcs ** L -
umum ams PRODUCI AssL*RANCE SITFERVISOR REY. DESC2IP*ICN/ AUTTIORm/ DIS POSITION DATE ULtI. CA/Oc
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PROCEDURE REVISION 5E PAGE TEXAS UTILITIES SERVICES INC.
CP-EP-4.6 0 8-13-79 22 of 23 FIGURE 6 , l TE:US LTJ.ITIES GENERATING CO3tP.tNY
.i t t . co .
PAGE OF OPERATT0ft TRAVELER l(CONT'D) PREPARED ST: QA/QC REVIEW:
DATE:
DEFT. OP. NO.4 0FE.M il0N .
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'O CP-EP-4.6 0 8-13-79 23 of 23 FIGURE 7 _ I t
TEXAS t.TILmES GENERATING CO3!P.OT RE0'O. DATE ei t.. 4 0.
OTY. REL. REL. DATE PAGE OF OPGATIOE TRAVELER PREPARG 87 QA/CC REVIEW:
DATE: .
OTHER UNIT _ STRUCTURE g CMTONE:ii_
NEAT GPt.U TiCN FITIAL OPERATiG'd PART/M RIAL / TAG. to.
SPECIFicAila;J MATERIAL ITPE
. Mme cAIAL PART O,... O, _
Om. DATE
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i f ATTACHMENT E O URE TEXAS UTILITIES SERVICES INC. REVISION PAGE
,n CP-EP-4.6 2 1-31-80 1 of 10 FIELD DESIGN CHANGE PREPARED BY _ _
CONTROL PROCEDURE g 7
- ..y
~ " ~ '
3 .,, . ', APPROVED BY '
h /// . ,
/ O[g a nner/n.k . ./ Z 1.0 ,
kEFERENCES
=
ril0iUKiliAL NLE 1-A CP-CPM-6.3, "Premration Approval, and Control l of Operatirn Travelers" l 1-B CP-EP-4.5, " Design Verification" l-C CP-EP-4.2, " Design Interface Control" 1-D CP-EP-4.4, " Control of Design Docunents" w c o:.t.o . .:.. x _. .7..-.,-
i 2.0 GENERAL , , cc , ,
~
2.1 'PUkPOSE -
DMED# Og To describe the method of documenting changes or deviations l to specified design / construction requirements by authorized I
field: personnel sfollowing' release of engineering docunients
. fapphivedifor fab'rication or construction.- *
' >.,,'.ibf6.s&; ' ~ ' '
~
l l 2.2 ' DEFINITIONS 5t.N NN2mC ' ---
'L- '
\ , 4521. qq:.".Ji -L:uui.n:' .-- - -.a. a -;u 2.2.1 -'Desigh" Change j ' ' ' '
j A design change is defined as a revision to engineering [ i specifications or drawings which affects the fann, fit o,r
., function of the affected structure, system or component.
- CUrfr91,~.,,: g ,--, -, -., .. - -
- - av .
2.2.2 // Deviation f ' *' "' ' ' '~' ~ 7 A deviation is defined as a depa F
, re 5 1 iec engineering requirement that dod!P RBt . o , fit or function of the affected st ture sy cnent.
%n m- , - ~.- p g m . ' Q ' jj, ~ "rl 2.3 RESPONSIBILITIES '
^ ~
The
- Eing fn' eeWn'g 'ind "Co ns trufti c'n Man'ag h sYovira11'te' sponsibility. for.~:the design'oi..the CP5Ea project. Authority (for' implementation of.this ~ procedure has been delegated to the Resident) Engineer and the Responsible $ Discipline Engi-neers'within his' organization. Further delegation of author-ity may'only be accomplished through fonnal engineering in-structions supplementing this procedure.
- - - - ~ - - - , - - - , -e , , - - . . . - - - - . - , - - - - - , , . - - - - - - - - - - -
,. TEXAS UTILITIES SERVICES INC. DURE REVISION 3E PAGE R
CP-EP-4.6 2 1-31-80 2 of 10 I
3.0 PROCEDURE 3.1 00CtMENTATION METHODS Changes / deviations to specified des'ign construction re. _ . .._ _
quirements shall be documented.1 Documentation may be either a Design Change Authorization (DCA) or a Component Modification Card (CMC). The respective foms are illu-strated in Figures 1 and 2. .
These fo ms are used to effect design changes / deviations originated by the Comanche Peak Project Engineering (CPPE)
. organization as well as to connunicate to the construction forces changes / deviations originated and properly approved
.by the original design organization.1 This latter usage is only to assure document legibility and as such the provisions of paragraph 3.3 of this procedure do or.may not apply. ,
The provisions of Ref.1-A may also'be used to connunicate changes / deviations originated by the original design orga-
, nization'provided document legibility can be assured and all
, applicable ~ design ' control measures'(including design veri-O w fication) have. been completed prior to ' implementation. -
~. ~.c,.. .. - --
i 3.2 REVIEW AND APPROVAL N Field originated design changes / deviations shall be approved
~
.- 9 *
, 'by the ' original designers designated 'sita representative
.. 4~
c unless otherwise stated in fomal engineering instructions s> *'-%..
.,c a supplementing this procedure. The Resident' Engineer shall ;
- > ,. . f * , maintain' written authorization ~of personnel; designated as a "G&H1 Design Representative",or, design representative of any 34 other vendor.* ' Clarifications or design changes properly
?f approved.and issued by the~ original design . organization require gy f, only the signature of the originating engineer / technician.
- ..DCA.or CMC fomic~oliisile'ted inTaidirdEie"^with'the above re- .
.Equitseents'are ~ approved .for: fabrication or construction when 3.3
>DESIGNsigned.by~the designated author.ities. NE0RMATl0 VERIFICA,T_ ION _ g m ,s;;: u i-y ; 46., , ,
[ sig changes /deviatioits shall be
?- ifor,'*afterTimplementation~ by authoriz i i ewpd r
,to confHim tc '
- 'v"" .~ . -
$i ,, .E 'or substantiate that the change is ac tab npfr% an 87111- 3 I~' N .-
[/ y' neering standpoint and' consistent w ) asis (or ;
/) I*y s* . input). FSAR connitments and applic ith ablethe tasjgny/
code 0and standards.
n #4 This review will normally be accomposnea oy sne oFTifinai s 's " design'organizationlin accordance with established procedures
./ although the provisions of Ref.1-B may be utilized at the
.. discretion of the Engineering and Construction Manager.
S .
b b b2[IM, . I r.
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- e
E TEXAS UTILITIES SERVICES INC. REVISION PAGE U
CP-EP-4.6 2 1-31-80 3 of 10 I
In the event that the design verification activities indicate that the change / deviation is unacceptable, the reviewing agency'shall notify the Resident Engineer who
.will, on the area in question, place a " Hold" or rescind
. .and reissue the' change / deviation.' Any physical corrective action required in problem areas will be evaluated and formulated on a case basis.
3.4 DISTRIBUTION ,
Distribution of field change / deviation documents shall be accomplished as required to fulfill the requirements of this procedure and to satisfy basic docunent control require-ments of interfacing organizations such as the design and construction groups. The provisions of Ref. 1-C and 1-D shall also be considered d en estabitshing distribution.
To the extent feasible, distribution should be shown on the face of the change / deviation document to facilitate ,~
. implementation of site doucment control procedures.
fs 3.5 , FORM. COMPLETION 1
~
.Detaile[i' instructions for completing DCA/ CMC fonns are _
given'inattachments}1and2,ofthisprocedure.
3.6 REVISION 5' Revisions to DCA/ CMC Fonns shall be accomplished as i described in attachments 1 and 2 of this procedure and shal1 be reviewed and approved as prescribed in paragraph
(. 3.2, above.
3.7 INTERFACE CONTROL' Changes / deviations to engineered items involving k/E and Vendor interfaces, such as equipment foundation details, shall be reviewed with both the A/E and the Vendor for compliance with design reauf r-nh nrint '
ito approval for fabrication or co m_.-- -
nst9{ g2 E N IG4 ww. .
P?.~ly
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- - -- - -- = . .
-I TEXAS UI'ILITIES SERVICES INC. PROCEDURE ISSUE pg REVISION
{ NUMBER DATE CP-EP-4.6 2 1-31-80 4 of 10 I
ATTACHMENT 1 DCA FORM COMPLETION The Design Change Authorization fom (Figure 1) is completed as follows: *
- a. Authorization No. - Assigned by the Administrative Services Office when the DCA is ready for signature.
- b. (WILL) (WILL NOT) Se Incorporated in Design Documents -
Cross out the on:: that does not apply. ,
As a general rule, design changes to a specification which are generic in nature and will affect future work on a continuing basis shall be designated for incorporation as will one time changes to design drawings that can be delineated on the drawing.
In case of a one time change to a specification requirement, the -
change will 'nomally not be incorporated. Clarifications and/or interpretations involving design documents will nomally not be incorporated into the design document. It is to be recognized that specific guidelines covering every situat!on cannot be de-b lineated in this procedure; as such, it will be the responsibility of the originating engineer / technician to exercise judgemer.t and designate whether or not a change should be incorporated.
- c. Safety Related Document - Check the appropriate block.
- d. Originator - Check the appropriate block. .
- e. Applicable Spec /Dwg/ Document - Cross out the two that do not apply,
- f. Details - Provide information on the change under consideration using adequate descriptions or references to other document (s) which clearly illustrate the problem and its resolution and pro-vide sufficient infomation to reflect the "as built" configura-tion.
- g. Supporting Documentation - Reference supporting documents such as telephone conversations, telaxes, telecopies. nren't itches.
field change notices, etc. ,
giq >
Completed DCA's are assigned a number andnh gged
,l
.Oli es i iv d strative
^
Services Office. Handwritten foms wi l accep ted cases, however typing is ' preferred. b Q
PPRV 1 .
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_ . . _ _ _ _ ._. ... . . _ _ . _ . _ _ _ . - . . - a --- --
/ TEXAS UTILITIES SERVICES INC. URE E REVISION PAGE C
CP-EPd.6 2 1-31-80 5' of 10 I
The DCA is then reviewed for technical acceptance by the responsible engineering discipline and concurrence is indicated by signing and dating the " Approved By" blanks as indicated in paragraph 3.2.
Revisions to a DCA will use Figure 1 and are filled out as described above with the following exceptions:
- a. The same authorization ntsaber shall be used.
- b. The appropriate revision number shall be placed after the authorization number.
- c. Subsection 1.B. Details, shall contain the following:
"This revision voids and supe'rsedes Design Change Authorization No. . Revision .
~
- d. If it is necessary to void or rescind a Design Change Authorization.
it should be done by a revision to the existing DCA. Subsection 1-B (Details) of figure I should contain the.following s'tatement "This revision voids Design Change Authorization No.
y and all revisions thereto and not superseded.
i l
- @03!!ATION COPY .
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TEXAS UTILITIES SERVICES IN
C. PROCEDURE
- REVISION PAGE
- NUfBER ~
1 CP-EP-4.6- 2' 1-31 6 of 10 I.
~
ATTAC)# TENT 2 '
rNC F0lWI CtmPLETION 3 The Component Modtffcation Form (Figur's 2) is completed as follows unless otherwise stated in engineering instructions supplementing this procedure.
- a. Serial No. - Prenumbered or as established through detailed appli-cation instructions supplement 1ng this procedure. _
- b. Section 1. Application - State generic category or work (e.g.
mechanical equipment, electrical equipment, pipe, pipe supports, etc.).
Weld Mod., Q Non-Q - Check appropriate block.
i -
Design Change Deviation - Cross out the one that does not apply.
Enter N/A if not a change or deviation to design.
4
- c. Section 2. Dwg. No. - Enter the complete number and revision of *
{; the affected design Ipsis and/or construction drawings as-follows:
- 1. Electrical, enter design basis drawing numbers. '
1
- 2. Piping and Instrumentation, enter the design and construction j . drawing numbers.
l l 3. Pipe Supports, enter the design and construction drawing numbers.
- d. Section 3, Line No./ Component No. - Enter the si:ecific identifica-tion mmber of the component to be modified; hanger number, spool number, equipment number, or N/A as applicable, etc.
i e. Section 4 Reason for Change - State briefly but concisely the
! reason for the change. If to implement a change p perly approved by the original designer clearly state this fact; e.g.; To imple-l ment DE/CD 8600).
i f.
l Section change to5.beInstructions made. - Describe completely and acen*=y=1y the L
l 1. Where there is no weld removed or a Oa R..4 N
' ~ , enuer i ;he appropriate blocks and describe n '
I r
- 2. For removal and/or addition of wd I app itte
' block and enter all weld numbers removed and/or added.
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( TEXASUk'II.ITIESSERVICESINC. DURE R
REVISION E
PAGE CP-EP-4.6' 2 1-31-80 7 of 10
.I
~ ~~
- 3. 'If, a'ftefthiiirIginallissue of _ tim BRP drawing. a weld has '
has to be removed and rewelded.- the weld neber will be",t ?
changed to's.ignify this.by adding an "A" for-the first cut out. "B" for_the second cut out, etc.; to the weld n eber, e.g.' weld 6.' reweld is,6A,and ' " '
if 6A is removed and rewelded,' '
~~ '
it becomes 68. 2
~ ~ ' ~
..a-.- .a
- 4. If. cfter the original issue of the BRP drawing, an added weld is required not a reweld of an existing weld; the new weld neber will be keyed to the lower of the two numbered welds and suffixed by "1" for the first weld, "2" for the second weld, etc. e.g., if a weld is added between "1" and "2" the new weld will be "1-1".
- 5. For component supports the r. ext sequent weld number shall be used.
NOTE: Items 3 and 4 apply to piping orily.
- g. Section 6 - Provide ske'tch indicating ~the existing and/or new arrangement wLen necessary for clarification. .
h'. Section 7 - Originator - Enter the name (and department as required) of the individual preparing the modification.
. Check appropriate block.
- f. Section_8. . AMoTeii'Bfi Thei iginating~eng1neer/ tech.
^
.;nician,shalljapprovethe. change' s u approvals _ required 1(see paragrap,'and h 3.2 of CP-EP-4.6). . designate
- Prior any.other '
'to' issuing the. CMC unless.otherwise.specifically delineated 3by]a'.'CP-EI; instruction.supplementingthis, procedure.?
- j. Section 9 - Distribution - If not predesignated, the engineer / technician preparing the CMC shall enter (on the front of the CHC) the name of each agency (and docu-ment control number) requiring distribution and shall indi-cate the number of required copies for each.
Revision to a CMC card may be accomplished by utilizing a new form (nonserialized) and filling it out as outlinuu euuve witn cne rosiowing
'dd'* "$-
INFORMATION
- a. The same serial number shall be used c.
b.
the serial number.
~
The appropriate revision number shal' g g ;gacent o PPRV_. -
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w
TEXAS UTILITIES SERVICES INC. REVISION fRE hSS E PAGE CP-EP-4.6 2 1-31-80 8 of 10 I
- c. The CMC card shall contain the following statement:
"This revision voids and supersedes document Serial Number
. Revision .
- d. When an occasion arises where a CMC has been issued and for some reason that card is not needed, it must be voided.
To void a' CMC the original card must be revised and clearly
- marked " Void - Not Superseded". -
INFORMTION 70 J.V u urn lg. PPRV l
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c_ _ . . _ . . . .. . - - - - - -- .
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ISSUE -
.. TEXAS UTILITIES SERVICES INC. PROCEDUPE REVISION g PAGE
.()-
~
CP-EP-4.6 i 2 1-31-80 9 of 10 l
. I filiEL.la.
Page i et 4
- i CINNOE PEAK STEM ELECTRIC STATIM .
DESI M CN m GE AUTHORIZATIM (WILL) (WId. NOT) BE INCORPORAT B AUTHORIZATION NO.
IN DESI M DDCW WT5 - -
I
' SAPETT RELATED DOCUNENT YES W I
GRIGINATOR: CPPE ORIGINAL DESIGIER !
- 1. M IPTTM
A. APPLICABLE SPEC /DWE/DOCIMENT REY.
B. DETAILS
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- 3. SIGNATURES:
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TEXAS UTII.ITIES SERVICES INC. PROCEDURE REVISION PAGE l TE b
CP-EP-4.6 4 7-18-80 1 of IC FIELD DESIGN CHANGE PREPARED BY: Ou
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1 CONTROL PROCEDURE APPROVED BY M M' %
l.0 REFERDICES . . . _
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1-A - CP-EP-4.7 " Control of Engineering / Design Review of Field Design Changes"
' l CP-EPd.i.2 "De5ign Verification" C~
1-C - CP-EP-4.0, " Design Control General Requirements" co """"
l FOR W ogi g gg
. 2.1 PURPOSE v!
T describe the method of documenting changes or deviations G/ to specified design /constructon requirements by authorized field personnel following release of engineering documents approved for fabrication or construction. ,
2.2 , DEFINITIONS .,
2.2.1 Design Change A design change is defined as a revision to engineering
( specifications or drawings which affects the form, fit,
- or function of affected structure, system or component.
2.2.2 Deviation A deviation is defined as a departure from a specified '
engineering requirement that does not affect the form, fit, or function of affected structure, system, or com-ponent.
2.3 RESPONSIBILITIES INFORMATION The Engineering and Construction Manager has oy1 sponsibility for the design of the CPSES projw:. 7' #) '
ity for implementation of this procedure has 14'
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to the Resident Engineer and the Group Supery" sors within his organization. Further delegation of authority may 3fD E\/
be accomplished through femal engineering instructions i i\ V supplementing this procedure.
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, TEXAS UTILITIES SERVICES IMC. PROCEDURE REVISION PAGE e~
CP-EP-4.6 4 7-18-80 2 of 10 3.0 PROCEDURE l l
3.1 DOCUMENTATION METHDOS Changes / deviations to specified design construction re-quirements shall be documented. Documentation may be either a Design Change Authorization (DCA) or a Component
. Modification Card (CMC). The respective forms are illus-4 trated in Figures 1 and 2.
These forms are used to effect design changes / deviations originated by the Comanche Peak Pro, ject Engineering (CPPE) organization as well ~as to coamunicate to the construction <
forces changes / deviations originated and properly approved by the Original Design Organization. This latter usage is j only to assure document legibility and as such, the pro-
! visions of Paragraph 3.3 of;this procedure do or may not .
apply. g f?f C p f m .e s.lM W :. a.:w a . s. n .s w'p;u;.-ggg .~
3.2 REVIEW AND APPROVAL ,'
j C' Field originated design changes /deviatians shall be approved by the Original Designer's designated site representative unless otherwise stated in fomal engineering instructions suppleenting this procedure. The Resident Er.gineer shall maintain written authorization of personnel designated as a :
"G&H Design Representative" or design representative of any '
i other vendor. Clarifications or design changes properly approved and issued by the. Original Design Organization re-
. quire only the signature of the Originating Engineer / Tech- #gC nician. .Such clarifications or design. changes shall be - g5 P
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,gefer_ enc _ed_or; attached. w
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DCA or CMC foms completed in accordance with the above re-quirements are approved for fabrication or construction when .
signed by the designated authorities. : Subsequent review and ,
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- approval by the Original . Design Organization shall. be accom '. "
'Plisgper
,s the' provisions,ofjeference'l-A.9 ?: ->
3.3 DESIGN VERIFICATION Design changes / deviations shall be revi Ie or after implementation by authorized pe rsorine(thyhk l, or substantiate that the change is accepta5Mf neering standpoint and consistent with t ' ' des r input) FSAR connitments and applicable c s rds. ,
m This review will nomally be accomplishet he Ori
_.. Design Organization in accordance with es tablishop ures --'
although the provisions of Reference 1-B may be uti :t
. the discretion of the Engineering and Construction Manager.
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TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE h33 TE CP-EP-4.6 4 7-18-80 J of 10 l I
- - In the event the design verification activities indi'cate the change / deviation is unacceptable, the reviewing agency shall I notify the Resident Engineer / Discipline Field Engineer who l l will, on the area in question, place a " Hold" or rescind and 1 reissue the change / deviation. Any physical corrective action !
required in problem areas will be evaluated and formulated on 1 a case by case basis.
3.4 DISTRIBUTION Distribution of field change / deviation documents shall be ac-complished as required to fulfill the requirements of this procedure and to satisfy basic document control requirements of interfacing organizations such as the design and construc-tion groups. The provisions of Ref.1-C shall also be con-si_dered when, established distribution. , ,
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3.5 FORM CO W LETION M ]i,i ,2 Detailed instructions for completing DCA/ CMC fonns are given
- - in attachments 1 and 2 of this procedure.
' ~ '
3.6 REVISIONS ,
Revisions to DCA/ CMC Forms shall be accomplished as described-ir. attachments 1 and 2 of this procedure and shall be reviewed
- and approved as prescribed in paragraph'3.2, above.
3.7 INTERFACE CONTROL
/ Changes / deviations to engineered items involving Design Engi- -
near and vendor interfaces, such as equipment foundation de-tails, shall be reviewed with both the Design Engineer and the i vendor for compliance with design requirements prior to approv-al for fabrication or construction. -
l INFORMAT10iN
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TEXAS UTILITIES SERVICES INC. REVISION PAGE PROCEDURE hI3U TE L.
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CP-Er-4.s 4 7-I8-80 4 of io l
, . ATTAC) MENT 1 -
DCA FORM COMPLETION The Design Change Authorization form (Figure 1) is completed as follows:
. a. Authorization No. - Assigned by the Administrative Services Office when the DCA is ready for signature.
- b. (WILL) .(WILL NDT) Be Incorporated in Design Documents - Cross out the one that does not apply.
As a general rule, design changes to a specification which are generic in nature and will affect future work on a continuing basis shall be designated for incorporation as will one time changes to design drawings that can be delineated on the drawing. In case of l a one time change to a specification requirement, the change will
! normally not be incorporated. Clarifications and/or interpretations involving design documents will nomally not be incorporated into -
the design documents. It is to be recognized that specific guidelines l* covering every situation cannot be delineated in this procedure; as such, it will be the responsibility of the Originating Engineer /
Technician to exercise judgement and designate whether or not a O ch as =aouid 6. iacorpor ted- .
- c. Safety Related Document - Check the appropriate block.
- d. Originator - Check the appropriate block. (The " Originator" of a DCA resulting from a DE/CD should be noted as the " Original '
! Designer").
! . e. Applicable Spec /Dwg/ Document - Cross out the documents that do not apply. ,
! f. Details - Provide infomation on the change under consideration j using adequate descriptions or references to other document (s) which clearly illustrate the problem and its resciution and pro-vide sufficient infomation to reflect the "as built" configuration.
- g. Supporting Docu"entation - Reference supporting documents such as _-
telephone conversations, telaxes, telecopies. OFn' . d.e. 1 field change notices, etc.. If the DE/CD is nFod fimdrtm 72 neering, the word " modified" shall be placed id" U ttr.11 number.
Completed DCA's are assigned a number and logged by ea ni ive Services Office. Handwritten forms will be acceptec V ses, however typing is preferred.
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TEXA5 UTILITIES SERVICES INC. PROCEDURE REVISION hI3U PAGE 4, TE CP-EP-4.6 4 7-18-80 5 of 10
, I The DCA is then reviewed for ' technical acceptance by the Group Super-visor and concurrence is indicated by signing and dating the " Approved By" blanks as indicated in paragraph 3.2.
Revisions to a DCA will use Figure 1 and are filled out as described 4th the following exmptions:
- a. .The same authorization number shall be used.
- b. The appropriate revision number shall be placed after the author-
- ization number.
- c. Subsection 1.8, Details, shall contain the following:
"This revision voids and supersedes Design Change Authorization No. . Revision .
- d. If it is necessary to void or rescind a Design Change Authorization, it should be done by a revision to the existing DCA. Subsection -
- 1-B (Details) of Figure 1 should contain the following statement "This revision voids Design Change Authorization No.
Q and all revisions thereto".
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TEXAS UTILITIES SERVICES INC. REVISION PROCEDURE hI3UTE PAGE
.O CP-EP-4.6 4 7-18-80 6 of 10 t
ATTACHMENT 2 , i CMC FORM C0ffLETION The Component Modification Fonn (Figure 2) is completed as follows unless otherwise stated in engineering instructions supplementing this procedure. C#
- The card shall be filled out using a black ink pen (or draf. ting pencil.. , .l
- a. ' Serial No. - Prenumbered or as established through detailed appli-cation instructions supplementing this procedure.
- b. Section 1. Application - State generic category of work (e.g. mech-anical equipment, electrical equipment, pipe, pipe supports, etc). .
Weld Mod., Q, Non-Q - Check appropriate block.
Design Change Deviation - Cross out the one that does not apply.
1 Enter N/A if not a change or deviation to design.
- c. Section 2, Owg. No. - Enter the complete nanber and revision of the' affected design basis and/or construction drawings as follows:
~
- 1. Electrical - Enter design basis drawing numbers.
- 2. Piping and Instrumentation - Enter,the design and construction drawing numbers f.or,.a11 design:changs/ deviations;'and constr .
ucti.,on drawing-.numbers.~;).for?
s ., n .,.s construction changes.
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- 3. Pipe Sup) orts'- Enter the construction drawing numbers.
. d. Section 3. Line No./ Component No. - Enter the specific identification number of the component to be modified;ispool number, equipment
- s number, etc. 'It.is,not required to' enter the pipe support number in ?
Pblock"3.? If a nut.1ber of items are affected, enter "see sketch", and
~
L show all ' changes in block 5.
! e. Section 4. Reason for Change - State briefly but concisely the reaion for the change. If to implement a change proper 1v marna uy tne nal Designer, clearly state this fact Te.
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Sectionto5,beInstructions - Describe complete]y cu i 1 l change made.
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- 1. Where there are no welds or material romoved or aid enter "N/A" in the appropriate blocks. . { U, f A 2. For removal and/or addition of welds an;a7or material, check the V
appropriate block and enter all weld numbers and/or Bill of Mat-erial item numbers removed and/or added. It is not mandatory .
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. ,. TEXAS UTILITIES SERVICES IltC. PROCEDURE REVISION PAGE-TE CP-EP-4.6 4 7-13-80 7 of 10
, to disposition tNe future use and/or storage requirements i for deleted material . -
- 3. If,'after the original issue of the BRP (piping) drawing, a weld has to be removed and rowelded, the weld number will re -
! changed to signify this by adding an "A" for the first cut
!~
out, "B" for the second cut out, etc., to the weld number, e.g., weld 6. reweld is 6A, and if 6A is removed and rowelded, it becomes 68. When stainisss steel items which have been -
welded previously are reused, the new weld identification shall be the next sequential letter of the item with the highest alpha-numeric weld number.
- 4. If, after the original issue of the BRP (ptping) drawing, an !
added weld is required not a roweld of an existing weld; the new weld number will be keyed to the lower of the two numbered i welds and suffixed by "1" for the first weld "2" for the
! second weld, etc., e.g., if a weld is added between "1" and j "2", the new weld will be "1-1" j NOTE: Items 3 and 4 apply to piping caly. -
) {' 5.
For component supports, the next sequential weld number shall .s
, be used any time a identified weld is cut. If a material item i on the component support is changed, then a new item number ,
j shall be assigned to the replacement piece.
l g. Section 6 - Provide a sketch indicating the new arrangement when necessary for clarification. When more than one CMC affects a draw- u, ing, care shall be taken to avoid conflicts between the CMC's. d l This block should include specifications of items added that are not 7; .
l / listed on the affected drawing. It should also show new weld locations, i n and all required working point dimer.sions (cut lengths for piping and 6 j hangers are not required) l
- h. Section 7 - Originator - Enter the name of the individual prepaiir.g
- the modification (for piping changes, also enter +" .: _ of tip foreman requesting the change). Check appF=op aja t i
- 1. Section 8 - Approved By - The Originating i nepr approve the change and designate any other Ptwa Paragraph 3.2), prior to issuing the CMC u - s p#f i
pec ca ly j delir,eated by a CP-EI instruction supplemen ; ._ ,, .. dure. . .k
- j. Section g - Distribution - If not predesigna ted, the % h T l nician preparing the CMC shall enter the nasg_gf aad equir-ing an " Engineering and Office Use Only" copy and shall indicate the number of required copies for each.
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TEXAS UTILITIES SERVICES IN
C. PROCEDURE
RE'/ISION PAGE TE
- cO CP-EP-4.6 , '4 7-18-80 8 of 10 .
- k. General - Extra sheets may be used where necessary to adequately cover .I the subject. All sheets must be marked with the CMC serial number -
and numbered page of .
- 1. Revisions to a CMC card may be accomplished by chang'ing the original form or by utilizing a new form (nonserialized) and filling it out .
as outlined above. The following additions shall be noted on the revised CMC, as applicable.
- 1. The same serial number shall be used.
- 2. The appropriate revision number shall be placed adjacent to the serial number.
- 3. If the reason for the revision is different from the original, enter the additional circumstances.in Block 4.
. 4. The CMC card shall contain the following statement:
"This revision voids and supersedes document Serial -
Number , Revision .-
b m. When an occasion arises where a CMC has been issued and for some reason that card is not needed, it mu*t be voided.
- 1. To void a CMC, the original card must be revised and clearly marked " Voided - Not Superseded".
2.: A: void CMC shall not'be reactfiated.
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TEXAS UT11.ITIES SERVICES INC. ISSUE PROCEDURE REVISION PAGE l MTE
- 1 CP-EP-4.6 4 7-18-80 9 of 10 l f
FTGURE !.
Page 1 of COMANCHE PEAK STEAM ELECTRIC STATION O
, Pr3IGN CHANGE AUTHORIZATION
- (WILL) (WILL NOT) BE !.1CDRPORATED AUTHORIZATION NO.
. IN DESIGN DOCUMENTS i
! SAFETT RELATED DOCUMENT YES .10 ORIGINATOR: CPPE ORIGINAL Ot3!GNER I
- 't. XsCRIPTTon
t A. APPLICA8LE SPEC /DWE/ DOC' JIENT REY.
- 8. DETAILS
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! 2. -e'* " *""
INFORMATION r,thaiJ
- 3. SIGNATURES: $ $ k A. APPROVED Bf: me Design Aepresensative Kpte B. APPROVED B7:
originator Date i 4 STANDARO DISTRituffCM: .
ARMS (Original) (1)
- Oueitty Enstneering (1)
Tecnnical services for original Designer (tr CPPE originated) (!)
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COMPONENT MODIFICATION CARD (CMC) -
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3.0 PROCEDURE
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3.1 FORM COMPLETION NTjhh$ '
i P ')etailed instructions for. completing DCA/ CMC fanns are
.' ;./ > ,_ ) given in Attachments 1 and 2 of this procedure.
3.2 REVIEW AND APPROVAL Field originated design changes / deviations shall be ap-proved by the Original Designer's designated site repre-
. sentative unless otherwise stated in formal engineering instructions supplementing this procedure. The Engineer '
Ming Manager shall maintain written authorization 'of *"*7-- .
- MW personnel designated as a "G&H Design Representative" or design representative of any other vendor. Clar4<*::u ,,s or design changes properly appr":d ... i c
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- Original Design Engineer of the Originating Organization /Techhi recpig.g j a f.i p
tions or desigg:ha,n,ges shag g . ;
k g,b!3 J r l'ew and approval b) 1 e 1 es g ik.
- organizationshallbeaccomplishe{li '
rovisions -,
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' hy, N, of Reference 1-A andP" 4WCg;tgE2,Or27CM 1-B.
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TEXAS LTTII.ITIES SGVICES It:C. E pggg PROCEDURE REVISION
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CP-EP-4.6 6 10-27-80 3 of 10 3.3 DISTRIBUTION ,
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Distribution of field change / deviation documents shall be accom-p11shed as required to fulfill the requirements of this procedure L and to satisfy basic document control requirements of interfacing organizations such as that design and construction groups. The ,
.Jprovisions of Peference 1-C shall also be considered when estab- .
a' lish,ing distribution.
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3.4 REVISIONS Revisions to DCA/ CMC Fonns 'shall be ac:omplished as desc'ribed in attachments 1 and 2 of this procedure and shall be reviewed and approved as prescribed in paragraph 3.2, above. -
3.5 DESIGN VERIFICATION
. 7 -,.. .. .,.. ,.. ._
Design changes / deviations shall be verified either prior to, or f- after implementation by authorized" personnel, to c1nfirm or sub-t
.*.z ., stantiate that the change is acceptable from an engineerin 1
standpoint and consistent with the design basis (or input)g. FSAR .
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>C commitmer.ts and applicable codes and standards. This verifica-t G tion will normally be accomplished by the Original Design .. >
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, 60eganization in accordance with established procedures although the provisions of. Reference 1-D may be utilized at the discre-L
.It , tion of .the Engineering and Construction Manager.
, c.
In the event the design verification activities indicate the
.' I . change / deviation..is. unacceptable, the reviewing agency sha11 no-
.tify the
- on the ar,,Engineerin'g ea in 'questionIplace flanage.r/'aDiscipline
" Hold" orField rescind Engineer and reissue who will.
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, thce change / deviation. Any physical corrective. action required in problem areas will be evaluated and formulated on a case by I case basis. !
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C. PROCEDURE
REVISION PAGE TE CP-EP-4.6 6 10-27-80 4 of 10 ATTAC) MENT 1 7 l ' DCA FORM COMPLETION .
- The Design Change A'uthorization form (Figure 1) shall be completed as follows
. a. Authorization No.. - Assigned by the Administrative Services Office '
- when the DCA is ready for signature.
- b. (WILL) (WILL NDT) Be Incorporated in Design Documents - Cross out the one that does not apply.
I As a general rule, design changes to a specification which are '
generic in nature and will affect future work on a continuing basis 4 shall be designated for incorporation as will one time changes to I
- design drawings that can be delineated on the drawing. In ca's e of a one time change to a specification requirement, the change will normally not be incorporated. Clarifications and/or interpretations -
involving design documents will normally not be incorporated into i
the design documents. It is to be recognized that specific guidelines
- l covering every situation cannot be delineated in this procedure; as such, it will be the responsibility of the Originating Engineer /
! Technician to exercise judgement and designate whether or not a j- change should be incorporated. .
j c. Safety Related Document - Check the appropriate block.
- d. Originator - Check the appropriate block. (The ' Originator" of a DCA resulting from a DE/CD should be noted as the " Original
- Designer").
l j e. Applicable Spec /Dwg/ Document - Cross out the documents that do not apply,
- f. Details - Provide information on the change under consideration using adequate descriptions or references to other document (s) l % which clearly illustrate the problem and its resolution and pro-l vide sufficient information to reflect the "as built" configuration.
! g. Supporting Documentation - Reference supporting documents sbch as
( telephone conversations, telaxes, telecopies, DE/CD's, sketches, t field change notices, etc.. If the DE/CD is modified b -
i nearing, the word " modified" shall be plac WF01 l .
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. TEXAS UTII.ITIES SERVICES INC. PROCEDURE REVISIDN PAGE TE
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'CP-EP-4 6 . '6 in 97.nn 5 of.10 -
- n. VendorAction-Check,theappropriateblock. ,
lt Completed DCA's are assigned a number and logged by the Administra- .
tive Services Office. Handwritten forms will be accepted in iso-
. lated cases, however typing is preferred.
The DCA is then reviewed for technical acceptance by the Group Supervisor. Approval is obtained by signature and dating the ap-propriate blanks as indicated in paragraph 3.2.
Revisions to a DCA will use Figure 1 and are filled out as de-
, scribed with the following exceptions:
- a. The same authorization number shali be used. ,
- b. The appropriate revision number.shall be placed after the authorization number,
- c. 5,ubsection 3.8, Details, shall. contain the following:
"This revision volds and supersedes Design Change Authoriza-
~
tion No. .. , Revision .
O d. If it is necessary to void or rescind a Design Change Author. -
ization, DCA. it should be Subsection 3-Bdone (Details by)a ofrevision Figure 1to the existing should contain the following statement "This revision voids Design Change .
~
Authorization No. and all revisions thereto".
\
/
I e 3FORNAT,LON
- COPY .
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I 4 F i TEXAS UTILITIES SERVICES 1HC. REVISION PROCEDURE [TE PAGE O- CP-EP-4.6 6 10-27-80 6 of 10 l
I ATT M NT 2
- CMC FORM COW LETION The Component Modification Fom (Figure 2) is completed as follows unless othemise stated in engineering instructions supplementing this procedure.
The card should be filled out using a black ink pen or ,"cark" pencil. .
%Mt1
, a. ' Serial No. - Panubered, or as established through detailed appli-i cation instructions supplementing this procedure.
- b. Section 1. Application - State generic category of work (e.g. mech-anical equipment, electrical equipsent, pipe, pipe supports, etc).
j Weld Mod., Q. Non-Q - Check appropriate block.
? -
' Design Change Deviation - Cross out the one that does not apply.
Enter N/A if not a change or deviation to design.
l c. Section 2 Dwg. No. - Enter the complete number and revision of the
, affected design basis and/or construction drawings as follows:
iO
- 1. Electricai - Enter
- sign basis drawing number . -
i 2. Piping and Instrumentation - Enter the design and construction j drawing numbers for all design change / deviations; and constr- -
3 1
uction drawing numbers for, construction changes.
} ,
- 3. Pipe Supports - Enter the construction drawing numbers.
. d. Section 3. Line No./ Component No. - Enter the specific identification ,
' number of the component to be modified; spool number, equipment number, etc. It is not required to enter the pipe support number in
, block 3. If a number of items are affected, enter "see sketch", and show all changes in block 5.
p ,
l e. Section 4. Reason for Change - State briefly but concisely the reason for the change. If to implement a change pmperly approved by the j 0 nal Designer, clearly state this fact (e.g., To implement DE/CD
- f. Section 5, Instructions - Describe complet change to be made.
lyk l
- 1. Whem there are no welds or material r , r "N/A" in the appropriate blocks. l
- 2. For removal and/or a'ddition of welds o nd/or ma O.. appro,riate biock and enter aii weid r + %e -.1y:
a 2 2check
. rmc- tlp )
erial item numbers removed and/or added. It is not mandatory I .
9 +ey -
9 9 e pa
l J. ' -
TEXAS UTIl.ITIES SSVICES INC.
PROCEDURE REVISION PAGE TE
..<o _
rp ro.a A 4 10-77-80 7 of 10 to disposition the future use and/or storage requirements for ;
deleted material.
- 3. ' FOR PIP'IFE ONUI AND INTEGRAEHANGER'ATTACMENTSTIf', after the
, original issue of the BRP drawing, a weld has'to be removed and rowelded, the weld number will be changed to indicate -
same by adding an "A" for the first removal, "B" for the sec-ond removal, etc. to the weld numbers, e.g. , 'for the weld 6
.the first removal / reweld is 6A, and if 6A requires rework, the second removal / reweld i.s 68.
. p.
~
- 4. FOR~ PIPING 0NI.Yl When stainless steel materials are reused and the heat affected zone not removed, the new weld number
- will include the next sequential letter of the item with the highest numerical weld number. For example, if the pipe be-tween welds 7A and 8C is' deleted, and the remaining parts welded together, the 'n'ew' weld number will be 80,\ not 78.
- In the situation where weld 6A is cut and a pup' installed between the two pieces, the new welds will be numbered 68
, and 6A-1. *
.c , , , . . ~ ~ . ~ . . . .
?
^
- 5. iFOR PIFING.Olu.Y-lIf, after the original issue of the BRP ' ,
drawing, an added weld is required which is not a, reweld of v . an existing weld; the new weld will be keyed to the lower ,
of the two numbered welds and suffixed by "-1" for the first veld, "-2" for the second weld, etc.; if a weld is added be-tween weld "3' and "4", thei new weld will be "3-1". -
- 6. 'FORl0MPONENT' SUPPORTS 'For material item changes, a new a., item number shall'be' assigned to the replacement piece.
MRA ,
- g. Section 6- Provide a sketch indicating the new arrangement when necessary for clarification. When more than one CHC affects a i drawing, care shall be taken to avoid conflicts between the CMC's.
This block should include specifications of items added that are-not listed on the affected drawing. It should also show new weld locations, and all required working point dimensions -(cut lengths for piping and hangers are not required).
- h. Section 7- Originator- Enter the name of the individual pre -
the modification.(forgping' changes, forema 9 ng uld be' entered)r
. Wq gij ,
J .' Section 8- Approved By- Approval shall be c A with paragraph 3.2. ~ [ '
- . . , .e m - C, o i o -DTstrfbbo I skb5 n hh '
.. nician preparing the CMC 'shall enter the nanle of eac re-
-)
quiring an " Engineering and Office Use Only" , copy and a 1-dicate the number of required copies for eac). .
, e 1
l
TEXAS UTILITIES SERVICES IN
C. PROCEDURE
REVISION h3 E PAGE CP-EP-4.6 6 10-27-80 8 of 10
- k. General - Extra sheets may be used where necessary to adequately cover i the subject. All sheets must be marked with the CMC serial number -
and numbered page of .
1.
- Revisions form or bytoutilizing a CMCacard newmay formbe accomplishedand (nonserialized by) filling changing it out. the original as outlined above. The following additions shall be noted on the ,
revised CMC, as applicable.
- 1. The same serial number shall be used.
- 2. The appropriate revision number shall be placed adjacent to the serial number.
- 3. If the reason for the revision is different frosn the original, enter the additional circumstances.in Block 4.
. 4. The CMC card shall contain the following statement:
"This revision voids and supersedes document Serial Number . Revision .
1 m. When an occasion . arises where a CMC has been issued and for some reason that card is not needed, it must be voided. -
- 1. To void a CMC, tiie original card must be revised and clearly marked " Voided - Not Superseded".
- 2. A void CMC shall not be reactivated.
1
~ ~
NORMAT10h n
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E TEXAS UTILITIES S GVICES INC. PROCEDURE REVISION ,
.PAGE
. CP-EP-4.6 6 10-27-80 9 of 10 t .
y FIGURE 1. Page l'of .
l GNUGE PEAK SITJM ELECIRIC STATIN IESIW OIANGE XTDGIZATION Of!II) Of!IlIE) BE INGEPGUGID IN IESIW DOQMiNIS DCA W.
- 1. SAFEIY RELATED DOCLMiNT:
YES W .
- 2. GLIGINAKR: CPPE GLIGINAL DESIGElR .
- 3. IESCRIPTIN: .
A. APPLICABLE SPEC /WG/DOOSENT REY.
B. IETAILS l
l 1
i *
- O .
~
j, , ,4. SUPPORTDC DOCDENTATIN:
i
- 5. APPROVAL SIGIATURES:
A.
- GLIGINA20R: , , .I a a n--' M
[ ') "t [ VIM l t/lb B. EESIM REPRESENTATIVE:
j_
- 6. VENDOR ACTION
- REQUIRED NA f-E O
- 7. STANtnRD DISTRIBUTIW: a b Quality Engirwering (1 -
Ov Ts for orig. Design. (1 .
e
- e
.. O
. 8
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- . - 4
- s. . . . .
TEXAS utn.mES SERVICES IftC. PROCEDURE RE't!SinN PMiE TE CP-EP-4.6 6 10-27-80 loof 1C l
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I* ATTACHMENT H TEXAS UTILITIES SERVICES INC. PROCEDURE REVISION PAGE CP-EP-4.6 7 11 13.nti of 10 FIELD DESIGN CHANGE - ,'
PREPARED BY: #F4r/ r- '
CONTROL PROCEDURE APPROVED BY:
v s
1.0 REFERENCES
1-A CP-EP-4.7, "ControlofEngineering/
. . :. m , , -, ...
FieldDesignChange{,g
- .~,m. . . - -
1-B CP EI-4.6-3 " App 1tcation of the DCA Form to Procurement
. Documents" I m ;~m :::, 7 ~s, .,...... ..... , .. . . . - = . -
1-C CP-EP-4.0, " Design ~ Control General Requirements" ,
1-D CP-EP-4.5, " Design Verification" O
- = MST0EAL FILE To describe the method of documenting changes or deviations to specified design / construction requirements by authorized field personnel following release of engineering documents approved for fabrication or construction.
2.2 SCOPE Design change / deviations documented in accordance with the requirements stated herein are approved for fabrication or construction only when signed by the designated authorities.
- In addition, these measures may be used to comunicate or identify to construction forces those design change /devia-tions originated and approved by th Orioinal Design organization.
2.3 RESPONSIBILITIES Mi0MATIO'y -
The Engineering and Constructio rh b esponsi-bility for the design of the CP i jutho y for implementation of this procedure has been eTagate o the rh yithin hi s .
EngineeringFurther Manager and the Group Super @tharfty may'."on13 organization. dalegation of au be accomplished through formal engineering instrucuum upple-menting this procedure. - -
l l
- -},',, ..
i- -...
r
- i. TEXA5 UTILITIES SGYICES Inc. PROCEDURE REVISION PAGE TE
.O .
CP-EP-4.6 7 k1-13-60 2 of 10 2.4 DEFINITIONS ,
2.4.1 Design Change * . .
A design change is defined as a revision to engineering specifications or drawings which affects the form, fit.
or function of,affected structure, system or component. . ,
- 2.4.2 Jeviation -
A deviation is defined as a departure from a specified engineering requirement that dcas net affect the form, fit, or function of affected structure, system, or com '
ponent. .
2.5 DOCUMENTATION ,
Design changes / deviations to specified design / construe.
tion requirements shall be docunented by a Design Change ,
Authorization (DCA)' or a Component Modification Card ,
(CMC). The respective forms are illustrated in Figures O.
1 and 2.
3.0 PROCEDURE
, 3.1 FORM COMPLET!0N Detailed instructions for. completing DCA/ CMC fonns are given in Attachments 1 and 2 of this procedure. ,
3.2 REVIEW AND APPROVAL Field originated design change./ deviations shall be ap-proved by the Original Designer's designated site repre- ,
sentative unless otherwise stated in fonnal engineering c . .-
instructions supplementing this procedure. The Engineer-ing Manager shall maintain written authorization of personnel designated as a "G1H Design Representative" or design representative of any OUm, vencor. i i ichtions or design changes properly ap)ro Original Design Organization eq R
My hothe a gnatu 'e of the Originating Engineer /To y t a-tions or design changes shall r en c Fat 41a tif cN d.
- , .f Subset;uent review and approval 1 design e organization shall be accompli shed per g ptpvisions n .' .
of Reference 1-A and 1-B. F F l\ V v
, /
- . . . .. ..__ _ _.. _ _ . . . - . . . . .- .. . .: 1 . , ,
1 1
TEXA5 UTILTTIt$ SERV!CES INC. I PROCEDURE REVISION PAst
.e , ,,
Cp-Ep-4.6' 7 il-13-80 t 3 of 10 1
' ~
3.3 O!5TRIBUT!0N ,
. 1 Distribution of field change / deviation docuents shall be accom-
. p11shed as required to fulfill the requirements of this procedure and to satisfy basic document control requirements of interfacing.-
- organizations such as the design and construction groups. The
, provisions of Reference 1-C shall also be considered when estab ,
l lish.ing distribution.
- l 3.4 REV!$10NS .
I Revisions to DCA/ CMC Forma shall be accomplished as described in attachments 1 and 2 of this procedure and shall be reviewed and
!' approved as prescribed in paragraph 3.2. above. '
j ,
3.5 DE5!GN VERIFICAT!GI ,
- j. Design changes / deviations shall be verified either prior to, or
- after implementation by authorized personnel, to confirm or sub- t i i stantiate that the change is acceptable from an engineerin "
1 '
standpoint and consistent with the design basis (or input)g. FSAR ,
1 commiitments and applicable codes and standards. This verifica-l/q
- v
- tien will normally be accomplished by the Original Design .
Organization in accordance with established procedures although
! the provisions nf. Reference 1-0 may be utilized at the discre-
)
tion of ,the Engineering and Construction Manager.
l In the event the design verification activities indicate the !
! change / deviation is unacceptable, the reviewins agency shalino- ;
l *
. tify .the Engineeririg Jtpnagstr/ Discipline Field Engineer who will, i i on the area in question, place's '4old" or rescind and reissue i j ,- the change / deviation. Any physical corrective action required -
a in problem areas will be evaluated and formulated on a case by '
l
[;*;C.".CNN;Mpi,;sagg;;, .. .-
i I
i .
',.1.
- 4 3.6.,.T#!NTERFActCONTROL . - - .
i jN"
, - . 44 ~ Significant' changes / deviations to engineered items involving .
U W*'
/
e, '
u (NA/t/and ' vendor interfaces for,h WE equipment foundation details i shall be reviewed with boGEt e and the vendor for com- '
L / 3.g.b.9
- pliance with.. design requirementger,to " app ~roval. .for. fahr.i. l NM%d*k8'M%y$8!6 j{ ,
7 f
W- '
fp ernsTTescumentation'where vendor erlW ,hu re. - d i
l \* .
shall be acconolfshed'fn'accordance Mth <
3 l .
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TEXAS UTILTTIES SERVICES IN
C. PROCEDURE
REVISION SS E PAGE D . CP-EP-4. 6 7 11-13-80 4 of 10 9
ATTAC) MENT 1 . l DCA FORM COMPLETION .
The Design Change Authorization form (Figure 1) shall be completed as follows: ,
. a. Authorization No. - Assigned by the Administrative Services Office when the DCA is ready for signature.
- b. (WILL) (WILL NOT) Be Incorporated in Design Documents - Cross out the one that does not apply.
As a general rule, design changes to a specification which are generic in nature and will affect future work on a continuing basis shall be designated for incorporation as will one time changes to design drawings that can be delineated on the drawing. In case of I a one time change to a specification requirement, the change will normally not be incorporated. Clarifications and/or interpretations involving design documents will normally not be incorporated into the design documents. It is to be recognized that specific guidelines covering every situation cannot be delineated in this procedure; as such, it will be the responsibility of the Originating Engineer /
Q Technician to exercise judgement and designate whether or not a change should be incorporated. ,
1 l
- c. Safety Related Document - Check the appropriate block.
- d. Originator - Check the appropriate block. (The " Originator" of a DCA resulting from a DE/CD should be noted as the " Original Designer").
. e. Applicable Spec /Dwg/ Document - Cross out the documents that do not l apply.
l
- f. Details - Provide information on the change under consideration using adequate descriptions e references to other document (s) which clearly illustrate the problem and its resolution and pro-vide sufficient information to reflect the "as built" configuration.
- g. Supporting Documentation - Reference supporting documents such as l
telephone conversations, telexes, teleconi.e nrunen :';;;;;m ,
field change notices, etc. If the DE/CD in se# er gi-neering, the word " modified" shall be p la$) ali Di /CD
~~ number.
C COPY
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, . - . . - , , , - - . - _n---- - - - - ---,_ -, _ _ _ _ _ - - - - -
' ~
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i- -
~
C. PROCEDURE
REVISION PAGE .
6' ,,,
'CP- -EP 4 6 . 7 b-13-80!5of.10 h.- Vendor Action-Cfieck,the appropriate block. , i Completed DCA's are assigned a number and logged by the Administra- .
tive Services Office. Handwritten forms will be accepted in iso-lated cases, however typing is preferred. -
The DCA is then reviewed for technical acdeptance by the Group Supervisor. Approval is obtained by signature and dating the ap-propriate blanks as indicated in paragraph 3.2. .
4 . .
Revisions to a DCA will use Figure 1 and are filled'out as de,
'. scribed with the following exceptions:
- a. The same authorization number shali be used. ,
- b. The appropriate revision number shall be placed after the authorization number.
- c. 5,ubsection 3.B, Details, shall. contain the following:
!. "This revision voids and supersedes Design Change Authoriza-
., , tion No. . , Revision .
O d. If it is necessary to void or rescind a Desion Change Author- -
ization, DCA. it should be Subsection 3-Bdone (Details by)aofrevision Figure 1to the existing should contain
. the following statement "This revision voids Design Change .
. Authorization No. and all revisions thereto".
s .
INFORMATION ' .
~.
UMNOV d1 D . .
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l TEXAS UTILTi!ES SERVICES !!!C. PROCEDURE REVISION PAGE TE CP-EP-4.6 7 11-13-80 6 of 10 I
e ATTACHMENT 2 '
CMC FORM COMPLETION .
The Component Modificatior Fonn (Figure 2) is completed as follows unless otherwise stated in enginetzeing instructions. supplementing this procedure.
The card should be filled out using a black ink pen or " dark" pencil.
~
- a. ' Serial No. - Prerrumbered, or as established through detailed appli-cation instructions supplementing this procedure.
- b. Section 1 Application - State generic category of work (e.g. mech-anical equipment, electrical equipment, pipe, pipe supports, etc).
Weld tiod., Q. Nor:-Q - Check appropriate block.
Design Change Deviation - Cross out the one that does not apply.
Enter N/A if not a change or deviation to design.
- c. Section 2, Dwg. No. - Enter the complete number and revision of the affected design basis and/or construction drawings as follows:
O I. Electrical - Enter design basis drawing numbers.
- 2. Piping and Instrumentation - Enter the design and construction drawing numbers for all design change / deviations; ar.d constr-uction draw'ng numbers for construction changes.
- 3. Pipe Supports - Enter the construction drawing numbers.
- d. Section 3. Line No./ Component No. - Enter the specific identification number of the component to be modified; spool number, equipment number, etc. It is not required to enter the pipe support number in block 3. If a number of items are affected, enter "see sketch", and show all changes in block 5.
j e. ' Section 4. Reason for Change - State briefly but concisely the reason for the change. If to implement a change properly approved by the Original Designer, clearly state this fact (e.g., To implement DE/CD 8600).
( f.
Section 5 Instructions - Describe com change to be made.
ile g % % h t ie
- 1. Where there are no welds or mater ve d r ter l "N/A" in the appropriate blocks. , .l .
~. 2. For removal and/or addition of welds and/ ial, che :k the appropriate block and enter all wtid numbe or Rill af Mat.
erial item numbers removed and/or ovusu. At is not mandatory e
.-____-----____._.,e ~ ,n., . ,--e, .-. ,...-,...w. ,n- ,,n, , ,n,, --_.,,_w,. , , . . . , .
=
TEXAS UTILITIES SERVICES IN
C. PROCEDURE
REVISION PAGE'
. b "rp.rp.a g 7 TE 11 1Lan - 7 5f 10
,. I to disposition the future use and/or storage requirements for ,.
deleted material.
. ' 3. FOR PIPIfE ONLY AND INTEGRAL HANGER ATTACHMENTS- If, after the
, original issue of the BRP drawing, a weld has'to be removed ,
and rewelded, the weld number will be changed to indicate -
i same by adding an "A" for the first removal, "B" for the sec- j ond removal, etc. :to the weld numbers,ie.g.,'for the weld 6, :
.the first removal / reweld is 6A, and if 6A requires rework. - l the second removal / reweld is 68.
s
. i
- 4. FOR PIPING ONLY- When stainless steel materials are reused and the heat affected zone not removed, the new weld number will include the next sequential letter of the item with the highest numerical weld number. For example, if the pipe be-tween welds 7A and 8C is deleted, and the remaining parts ~
welded together, the new weld r. umber will be 80, not 78. ,
- j. In the situation where weld 6A is cut and a pup installed i
between the two pieces, the new welds will be numbered 6B
. and 6A-1. .
- 5. FOR PIPING ONLY .If, after the original issue of the BRP ~ ,\
O. drawing, an added weld is required which is not a. reweld of l an existing weld; the new weld will be keyed to the lower
' of the two numbered welds and suffixed by "-1" for the first weld, "-2" for the second weld, etc.; if a weld is added be- -
tween weld "3" and "4", the new weld will be "3-1".
- j.
- 6. FOR COMPONENT SUPPORTS- For material item changes, a ne'w l
item number shall be assigned to the replacement piece. ,
- g. , Section 6- Provide a sketch indicating the new arrangement when necessary for clarification. When more than one CHC affects a drawing, care shall be taken to avoid conflicts between the CMC's.
This block should include specifications of items added that are not listed on the affected drawing. It should also show new weld locations, and all required working point dimensions-(cut lengths for piping and hangers are not required).
'~
- h. Section 7- Originator- Enter the name of the rep ring the modification (for piping changesa Nig4 he phange-
. should be entered). .
}( p l-
- 1. Section 8- Approved By- Approval shal with paragraph 3.2. .
iTS(hpg ,
kl c'e ~ .
.F
.~
, J. Section 9- Distribution 'If not prede '
, th ineer/T'e h--
. nician preparing the CMC shall enter tl name o genc -
l quiring an " Engineering and Office Use ly" co .Mai n- i dicate the number of required copies for eacn. .
i l
- ..._. .. . . . - . . =. . - -- . ~...-- s ,
l
! .' _ .. 1
E TEXAS UTILITIES SERVICES IN
C. PROCEDURE
REVISION *PAGE CP-EP-4.6 7 11-13-80 8 of 10 , ,
.k. General - Extra sheets may be used where necessary to adequately cover the subject. All sheets must be marked with the CMC serial number '
of and numbered page .
- 1. Revisions to a CMC card may be accomplished by changing the original form or by utilizing a new form (nonserialized) and filling i.t out' s outlined above. The following additions shall be noted on the re, vised CMC, as applicable.
- 1. The same serial number shall be used. .
- 2. The appropriate revision number shall be placed adjacent to the serial number.
- 3. If the reason for the revision is different from the original ,
enter the additional circumstances in Block 4.
~
. 4. The CMC card shall contain the following statement:
"This revision voids and supersedes document Serial -
Number . Revision .
O m. when an occasion arises where a CMC has been issued and for some reason that card is not needed, it must be voided. * *
~
- 1. To void a CMC, the original card must be revised and clearly marked "Vofded - Not Superseded".
2., A~ void CMC shall not'be reactifated.
a
! iMFORhgTiOM O
(COPY av
- . . l
i
- 7
~
t .
TEXAS UTILITIES SERVICES If:
C. PROCEDURE
REVISION PAGE
, TE 0 -
CP-EP-4.6 .7 l11-13-80 9 of.10 .
q l
. HEELL. Pa** I of CtMMCMt PEAK $7 TAM (LECTRIC $TATION DESIGN CMMGE AUTHORIZATION ,
, tutLL) (utLL mT) Bt INCORPORATED IN Ot$!EN 00CLPOTS DCA NO.
- 1. sArtTT an.Aftp 00C:stnT: TE3 no
- 2. ORICI! RAT 3R: CPPC ORICIML Ot3!GNER
- 3. OtsCR!PTTon- .
A. APPLICA8LE SPEC /0WE/DDCLPUT REY.
B. OCTAILS
\ . . .
2 t
- 4. SUNCRf146 00C:M4*ATT0n:
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, A. ORIGIMTOR: DATE
- 8. DESIGN atPRtitNTATIVE: DATE
- 6. VDega TRan5MTTTAL RECWIRED, TE3 NO
- 7. STAADMD O!5M! BUTTON: ggmg A8M5 (Original)
. Outitty Engineering (1
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. ATTACHMENT I .
. TEXAS UTILITIES SERVICES INC.- PIOCEDURg REVISICBI .ISSDE PAGE
~ DhTE CIwRouzD CDer to. #f-N/ CP-EP-4.6 8 9-22-83 1 of 15 n ~ '
FIEID IESIGN CEANGE CDNITOL PREPARED BY I
APPICVED BY M- ~
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1.0 REFERENCES
.--1-B 'ItE Procedures Marmaal 41-C CP-EP-4.7 Cbntrol of Engineering / Design Daview of Field Design Changes !
1-D CP-EI-4.6-3 Agplication of the DCA Peca to Procurement Doctaments j 1-E C W .0 Design Cbntrol General Requirements i 1-F CP-EP-4.5 Design verification
^
2.0 GDERAL 2.1 PURPOSE -
To describe the method of documenting danges or deviations to
- specified d=airpi/w-Luction tsquirements by authorized field
! personnel following release of engineering e cuments _ approved
- (~ for fabrication x - Luction.' CMpediriisionsfais. established 3 -
i N/ sto assure ccupliance with.the requirements of Reference ~1-A.*J ~
- -.n.za m m _.a..~~~.~.- - -
2.2 SCIBE .! MjglL..-g.:-v-*+ Ms?w-*t't_fa-W*kt1.**F*M*4Wt*3KM'">9t~tv WA%N'y e..mu.
- 2 naa m.% A..n z.a.
7 M i change / deviations shall be .w-J h complete and a x C;3 ~
g# y,1$tedbrdesignatedauthoritiesasdescribedinthisinstruction. .
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gESPGISIBILITIES i
The Assi gMCP ES pro Autho ty ce ing tation
,, ,1s ,rocedure has been de1e,ated to me N.na.or oe Eneine-ine W subordinate engineering organizationsQ Further delegatim of ausority'say.be~m1_ished through formal engineering instruct supplementing this - = 4 M.
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2.4 1EFINITICMS ~e ,
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.1 b w'**84 2.4. h,ineerim Docume'nts js '
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,_ - wa3388 n9 -}L 1 g a , .,
C'. (distrucMhid specify design, C( h p.
a s, "syor mis h W irements' g;
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. TEXAS UTILITIES SERVICES INC. PROCEDURE REVISICH ISSUE PAGE DATE
- C N .6 8 9-22-83 2 of 15
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l 2.4.2 Design Change A rwision to engineering documents Wilch affects the fbra, fit, ce function of the affected struc*ure, system or couponent. IJ 2.4.3 Deviation-A departure fma a specified engineering requirement that does not affect the form, fit, or functicri of affected structure, system, .,.
OC ~v= == u -
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- , 2.4.4 Engineering Qiance Requests ;
, "_ ~ ' A document used to forward engineering, design, or tedinical informe- l ticri between engineering organizations fee the purposes of initiating 9-'
drawing revisions. She ECR is a ccumunication/ interface &cument which does not authorize fabrication oc construction. -
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! Design dianges/ deviations to specified engineering &cuments 7 shall be documanted by twision initiated by an Engineering ~ s ,'
, ,ciange Request: (ECR),fa Design Change Authorization (DCA), or ,
a Ozuponent Modification Card (CMC). The rydve focus and P*
O the application of each are further described below. M V
3.0 P9n N TETE n .- ,. ~ ~..-.a m - W 2.~. K 5 2. & l G ~+ ~
,. 3.1 "~"DGINEERING CBANGE IEQUESTS
. P.
3.1.1 General . . .
.x. -
~ 7 ECR's shall be .used by_CPPE Ei'iriitiate design changes to be ' ~4I I
. decismented by document revision 4 In addition,, design change .Jh 4
m- als~ forwarded by other~ceganizations such as umstinghouse Field '.'$ i Oiange Notices -(FCN's); TUGCD Design Change Requests (1DCR's) and j
. Gibbs & Hill Design / Engineering Change / Deviations (DE/CD's) any
< .- : r i^ be perwwaamd by ECR's.
y je } S, _'
v(g- ~?. 40pon ~ccupletionVttisi."cr..e,. .iginator,the ECR shall be fbtwarded_as -
specified hereini'for drawing'irw . tion v _ - - _'. , -- ign .
f.3eG., . .
. verification as ' required. -- 7
- -a INF09MA n g
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. 3.1.2 Specific Scope of ECR's .
' p;(1 , E . h Y.. : _
d changes;(i.e., tems g , ,
the specificacope of;7etc.Ftio be engineering h==rits, dag' gs 'timmeCR*e be n -
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t administratively ~~ defined~e. by:the2.a. CPP.B Uideirring
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- r. O tneedifbe)=p1mtaticu.'n.stiGitle'r\ i'ney be. ex- e npted n fma the scope of ' Njj i
( L 'ECR's on a' case by case basis. Osanges processed in this "f.,':e g
- c. ,menner shall be,,2cismented by DCA/3Cr however, the diange , #rk '
- .{% }
- shalljbe: authorized by;specified engineering management ;
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TEXAS UTILITIES SERVICES INC. PIOCEDURE REVISION ISSUE PAGE tmTE-b .. . ~ . . . _ .
CMP-4.6 8 9-22-83 3 of 15
- .w. . p 3.1.3 Ferm completion -
,/
Detailed instructions fbe empletion of the ECR fbts are specified per Attar 4==rtt 1. - ,
3.1.4 Request ;w vv.1 and Distribution ,
..- 3 .w ..,, b.- .
ECR's shall be approved by'lind'iM=la i designajted by the CPP Engineering Meneger.
- Igen approval, the ECR aball be fbrwarded as Fn11mm for disposition:
Secpe of BCR Responsibility 1
f a) Non-ASME Related M b) AEBE Related: Mi'tg Ccamplete ~ ' ~'"~' W .
, _.j' c) ASMC Related: Stamping Incomplete _
CPP Mechanical or IEC
"-'-* M Eng %
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5 3.1.5 niarnaition . . .
i .. __ _ .
3.1.5.1 len4ss,_Related 3 h The ECR shall be used by M as a design input to crzumance design control activities as defined per Reference 1-B. Upon ecupletion 1 of an engineering zwiew to identify design considerations (sud i as interiMeline zwiew, calculations, damage study, etc.,
- , impact), the ECR ehall be i-p ted into affected &ctaments l .- for facsel approval of the design change and design verification (if required). During the disposition process, the ECR may be i sodified with the involvement of the originator.
- Affected &ctanents shall be entered into the &cument control j program for distribution.
3.1.5.2 ASME'RalaEadi'Tstamping I
-- . . . .Complete 3, ,
W shall categorize-the rW &ange as a major, minor,. or critical change and cxamplete design control activities as specified in Reference _.14 CPPE shall participate in the analysis and pipe'aupport ' effort as defined in tha - M -. T
- interface documents. All CPPE activiti,e una in accordance with established'engineeri s v
h lo is curing the disposition process, the ECR' i th-
+ involvement of the originator. .
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l TEXAS UFILITIES SERVICES INC. PIOCEDURE REVISION ISSUE PAGE '
IRTE O, CP-EP-4.6 8 9-22-83 4 of 15
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3.1.5.3 ASIE Belated: Stasping Imlete 7 1he ECR shall be used by CPP Mechanical or I&C lihgineering as a basis fcr revising the engineering docismant'used in the certification process. The revised document shall be reviewed to determine if j stress re-enalysis _is regaired. If stress re-enalysis is required, i
the reviewing cra=nha*im shall coordinate the analysis and 4
. .1 initieta pipe support design activities as required. After re-analysis, or if no re-analysis is required, the revised document shall be forwarded to Tts for the completion of design control activities and. return. The above activies shall be accesplished in accordance with the engineering rwc.Asce/ instructions established to a:ritrol the design and design diange program.
Revised engin== ring documents shall be entered into the h==rit a:ritrol program.
l
- 3.1.6 Closure ,
a IICR disposition shall be documented per Figure 1.' Distribution cf the dispasitioned EC2t shall include the originator. Ittere O 2 required, t!)e responsible diapwition organization shall retain a
[%%%-ju;53:!:zLu,eeaba ks-:d'.%%%G? copy of the EQt for design control documentation.
3.2 DESIGN GANGE ADIIERIZATICNS & CDUQEINfyIFIO2 ION GRDS ~
1 g: 3.2.1 Pbra Omeletio_n . ,
Cc
' ,*% , Detailed instructions for completion of the DCAA3ec forms are ,
, t . grg " specified per Attachment 2 & 3.
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'IEXAS UfILITIES SERVICES INC. PROCEDURE REVISICE ISSUE . PAGE IRTE l
! CP-EP-4.6 8 9-22-83 5 of 15 3.2.2 Review and Approval -
Field originated design danges/ deviations shall be w vv=d by the original designer's designated site representative unless otherwise stated in formal engineering instructions supplementing this pcocedure. 'Ibe Engineering Manager shall maintain written l authorization of personnel designated as a "GrH Design Representative" or design representative of any other vendor. Clarifications or !
design changes properly wvved and fe=* by the original design ceganization require only the signature of the originating engineer /
tednician. Such. clarifications or design changes shall De referenced or attached. ' Design changes / deviations documented as described herein are approved for fabrication and cxanstruction only. In
, addition, these measures may be used to cxmnunicate or identify E to construction danges/devlations originated /ww.d by the
. _ .; criginal
,.. , - d,esign
. . ~ organi1*im. m,w-- ,v.t Subsequent review and w vv.1 by the original design organization~
i shall be mliM per the provisions of Deference 1-C and 1-D or THE.
3.2.3 Distribution
- O -
Distribution of field change / deviation documents shall be mlished t- 9 as red to fulfill the requirements of this procedure and to i satis
!t : basic document control requirements of interfacing organiza-
. , - :'? jU. tiens such as the design and constructicn groups. The provisions of
. ,jt? ReferenceQ-E[shallalsobeconsideredwhenestablishingdistribution.
3.2.4 Revisions Revisions to DCA/ CMC Ibuns shall be accomplished as described in -
F Atta&ments 1 and 2 and shall be reviewed and wvved as prescribed 3'
, in Section 3.2.2.
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1EXAS UFILITIES SERVICES INC. PICCEDURE REVISICH ISSUE PAGE
_DATE CP-EP-4.6 8 9-22-83 6 of 15 3.2.5 Design w rification .
1 Design danges/ deviations shall be verified either prior to, or after imp 1===ntation by authorized personnel, to confirst or substantiate that the dange is Wale front an engineering standpoint and consistent with the desip basis (ce input), PSAR commitments and applicable codes and standards. This verification shall:m11y be m11shed by the original design organization in accordance with established usuc.4:res although the provisions
. of Beference 1-F may be utilized at the discretion of the
~
Assistant a wj ct General Manager. .
In the event the desi p verification activities indicate the
/ deviation.is -*1e, the zwiewing agency shall the, originating organization who say, on the area in .N '
, question, plice a S*It:1d" or rescind and reissue the change / ".
deviation. , Any physical - .ctive action repired in problemi areas shall,be evaluated and for=1ated cm a case by case basis.
3.2.6 Interface control Significant changes / deviations to engineered items involving A/E ard vendor interfaces for equipment foundation details shall Q be zwiewed with toth the VE and the vendor for lance
, with design requirements, price to .w wv.1 fee f catien or
- w. -
. Fctual d3cumentation 4ere vendor or A/E appcoval is required shall be accomplished in accordane with Reference 1-C and 1-Df .[._~
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e TEXAS UrILITIES SERVICES INC. PIOCEDURE REVISIN ISSUE PAGE 1 RTE A
CP-EP-4.6 8 9-22-83 7 of 15 ATIACIMENT I .< I ECR EDIM CMPLETIN The Engineering Change Request Form (Figure 1) shall be a:npleted as follows:
- a. ECR No. - assigned by the responsible , site organization.-
- b. Safety Belated Doctament - Check appropriate block.
- c. Discipline - Designate appropriate Engineering organization. -
- d. Applicable Spec / Dwg / Document - Cross cut &cuments that do not apply. Specify all known affected or interfacirs engineering & cuments.
- e. Details - Prwide information cn the change tmder consideration using adequate descriptions oc references to other documents which clearly illustrate the problem and resolution. Attach the design documents marked 'to adequately show the change.
- f. Doctanentation - References ing &cuments such as Q esbane conversations, telexes, telecop es, sketches, Pms, DCAs,1DCRs, TDRs other ECRs, etc. '
.y',M^
Bandwritten forms will be awW in isolated cases; however, typing
.g . ;;is preferred.
At . .e - x 3 ffh 'w..1 - j?the. originator and date shall be pewided. Apptwal shall be -ptwided,
- c .
- A fc. ~ disposition responsibility assigned, ard the ECR forwarded for q disposition as indicated in Section 3.1.4.
Modifications required to the ECR in the dispositial es shall
- f. be indicated by roting the change en the EER. The change shall be initialed ce otherwise validated and dated. All involved parties should be identified in the validation.
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TT:XAS UTILITIES SERVICES INC. PIOCEDURE REVISICH ISSUE PAGE DATE CP-EP-4.6 8 9-22-83 8 of 15 AS"5CIDENT 2 . !
DCA FGM CCMPETIGI . ,
The Design Change Authorization fbra (Figure 2) shall be crupleted as follows:
- a. Authorization No. - Assigned by the responsible site organization.
- b. (WILL) (WILL ICT) Be Irmmm ted in Design Documents - Cross cut the one that does not apply.
As a general rule, design changes to a specification whicit are generic in a nature and will affect future work on a continuing basis shall be '
designated drawings that een be delineated en the drawing. Clarifications and/cc interpretations involving design dev,==rits will normally not be ir m m .ted into the design documents. It is to be recognized that specific guidelines covering every situation cannot be delineated in this stocedure, as sudt, it'will be the responsibility of the Originating Engineer /Ttchnician to exercise judgement and designate .
whether ce not a change should he irm.wm.ted. Note designation of ir m;-- d ht is for pi:eliminary use only.
- c. Safety Related h==rst - Check the w e late block. ,
- d. , Originator - Chedt the .w elate block. (The " Originator" cf a DCA resulting from a DE/CI) should be noted as the " Original Designer").
j e. Applicable specW="='st - Cross out the documents that do not apply.
Specify all known affected or interfacing engineering &cuments.
. f. Details - Provide information czt the change under consideration using adequate. descriptions or references to other document (s) which clearly
, illustrate the problem and its resolution and provide sufficient infonnation to reflect the "as-built" configuration.
- g. Supporting Documentation - Reference supporting doctaments such telephone conversations,' telexes, telemples, DE/CD' -
1.u -
1DCRs, 1DRs,.etc. If the EE/CD is undified
'--^~
l word " Modified" shall be placed adjacent to kM O
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.. .,g TEXAS UI'ILITIES SERVICES INC. PIOGDURE REVISIN ISSOE PAGE .
Dh1'E
- CP-EP-4.6 8 9-22-83 9'of 15 O
- h. Vendor Related Change - Check the appropriate block. If the "yes" block is checked, specify the applicable purchase ceder number. . I
! Handwritten forms will be accepted in isolated cases, however, typing is perferred.
The DCh is then zwiewed for tedinical acceptance by the designated personnel.
1 Approval is obtained by signature and dating the appropriate blanks as
- indicated in Section 3.2.2.
- m-, . : s n;,x.::w.::x.u,c;ym.gv.x; . .,;. p ,
xi In the event formal ===el and design verification'is required prior,to ,
issue, the DCA shall be forwarded to the responsible tion.
Ccaipletion of those activities by the respers.ible sation shall be indicated by signature and date in the " DESIGN REVIDi PRICR TO ISSW" bl*"k' . - .. . :,.w xy2 Dr. a L == x.:a.m
- c.v
? If fbemal .w M.y c. .w. . ...1 arid design verification is not reqpired prior to issue, :
the originator shall mark "Nk" in the "DESIM W, YIBt PRER TO ISSW" blank.
i tute "Nk" does not indicata sw w=1 and design verification is tot ~'
=*==T= itly regared.
- - zu m 7.xfM221.% m s u m;;=;a a t m rc x 2."ICA M :5 5 L... "-
Revisions to a DCA will use Figure 2 and are f411M out as described with the following =Tr=== , ..,.
) a. The same authorization raaber shall be used. -
- b. 1he ., late zwision ruauber shall be placed after the authorization number. .
l %
! c. Subsection }.B, Details, shall contain the fbliowing: ,
! "1his zwisien voids and supersedes Design Change Authorization No. , Revision .
l
- d. If it is necessary to void ce rescind a Design Change Authorization, it should be done by a rwision to the existing DCA. Subsection .
3-B (Details) of Figure 2 should contain the following statement :
"This zwision voids Design Change Authorization No. arid alli revisions thereto".
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TEXAS (FfILITIES SERVICES INC. PICCEDUltE 1EEVISIOi ISSUE - PAGE l
, DATE CW.6 8 9-22-83 10 of 15 )
O.-
ATIRCIMINP 3 -
- I CMC PGM CCMPLETIQi ,.
The %-.t Modification Pbra (Figure 3) is completed as follows unless
- otherwise state $ in engineering instructions supplementing this procedure.
1 The card should be filled out using a black ink pen ce " dark" pencil. '
- a. Serial No. - Prerumbered, ce as established through detailed application ;
instructions m 1 ting this r e ars. l
- b. Section 1, Application - State generic category of work (e.g. mechanical equipment, electrical equipment, pipe, pipe supports, etc).
weld md., Q, Itm-Q - Ched ., , late block.
Design Change Deviation - Cross cut the one that does not apply.
Enter WA ce leave blank if not a change ce deviation to design. .
{ c. Section 2, Dug. le. - Enter the ceplete rumber and revision of the t affected design basis and/cc construction drawings as follows: -
l .
, 1. Electrical - Enter design basis drawing rumbers.
.O 2. ,1,ing and Instr antatico - Ent.c the desi, and construcelon drawing rambers for all design dange/ deviations; and construction drawing numbers for constructism changes. -
- 3. Pipe SutW - Enter the construction drawing,rumbers.
3 d. Section 3, Line No./ - _ -- t No. - Enter the specidic identification rumber of the w-. to be undified; spool number, equipment
,. number, etc. It is not required to enter the pipe apport number.in blode 3. If a rumber of items are affected, enter "see sketch", and I show all changes in block 5.
- e. Section 4, Peason for Change -- State briefly but concisely the reason for the change. If to implement a change properly approved by original Design, clearly state this fact (e.g., Tb W1 &
- f. 5, Instructions - Describe cxzple y to ,e de.
- 1. ihere there are no isn1 dst cc anterial gthe *
."wA" in the appropriate blocks. _
- 2. Per removal and/or addition of welds and/ anteed i ;n- -late blod and enter all weld of l
,g. Material item numbers removed and/or added. t is rot sendatory V to disposition the future use and/or storage requirements for deleted material l_- ,
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, ... s TEXAS UTILITIES SERVICES INC. PICCEDGHE REVISICN ISSOE PAGE DRTE CP-EP-4.6 8 9-22-83 11 of 15
- 3. FCR PIPDG ONLY Ate INNGIAL HARGER MSCIBEINIS - If, after the original issue of BRP drawing, a weld has to be removed and rewelded, the weld I ruseber will be changed to indicate same by adding an "A" for the first <
renoval, "B" for the second removal, etc. to the weld rumbers, e.g., for the weld 6, the first renoval/rewald is 6h, and if 6A requires rework, the second renoval/ reweld is 6B.
- 4. FOR PIPING CMLY -1ehen stainless steel materials are re-used and the heat affected zone not removed, the new weld runabar will include the next sequential letter of the item with the highest runnerical weld rumber.
Per avample, if the pipe between welds 7A and 8C is deleted, and the remaining parts =1 dad together, the new weld russber will be 8D, not 7B. In tne siW*irm where weld 6A is cut and a pg installwi between the two pieces, the new welds will be russbered 6B and 64-1.
- 5. PIPDG CMLY - If, after the original issue of the BRP drawing, an added weld is required W11& is rot a roweld of an existing weld; the new weld will be keyed to the lower of the two rusubered welds and suffiand j -
by "-1" for the first weld, "-2" for the seco id weld, etc., if a weld j is added between weld "3" and "4", the new weld will be "3-1".
I
- 6. FOR CDIPCNENT SUPPORES - Per :saterial item danges, a new item rumber shall be assigned to the r=a1=- i piece.
1.
O. '
- g. Section 6- Provide a sketch indicating the new arrangement det necessary for clarification. men more than one CMC affects a drawing, care shall be -
taken to avoid conflicts between the OEC's. This block should include specifications of items added that are not listed on the Vfected drawing.
It should also show new weld 1ccations, and all* required working point dimensions (cut lengths for piping and hangers a::e not required).
, h. Section 7 - Originator - Enter the name of the individual preparing the modification (for piping danges, foreman requesting the change should be entered).
- i. Section 8 - Awn.wvd By - Approval shall be cbtained in accordance with Section 3.2.2.
- j. Section 9 - Distribution - If rot predesignated, the Engineer /Dechnician preparing the O c shall enter the name of ee d agency requiring an . .
" Engineering and Office Use Only" copy and shall indicate thef= -
of required copies for each.
E LM?0RWATION
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TEXAS UTILITIES SERVICES INC. PRXEDURE REVISION ISSOE PAGE DM'E CP-EP-4.6 8 9-22-83 12 of 15 b .
- k. General - Extra sheets may be used where necessary to adequately cover ;
the subject. All sheets mast be marked with the OGC serial ruseber and
- ntebered page of_.
J
' l. Revisions to a Oct may be m11shed by danging the original form or by utilizing a new foca (nonserialized) and filling it out as cutlined above. The following additions shall be noted cn the revised CMC, as applicable. '
- 1. She smee serial rsauber shall be.uesd.
- 2. 1he ~i seri [bsta twision
' number shall be placed adjacent to the
- 3. If the reason for the zwision is different from the criginal, enter the additional circumstances.in Block 4.
- 4. 1hs CIC shall contain the following statement:
"This revision voids and supersedes doo ment Serial Number , aavision .
- m. idhen an occasion arises where a QtC.has been issued and for scne O reason that card is not needed, it mast be voided.
- 1. 1D void a OEC, the original card must be revised and clearly marked l "Vbided - Not Superseded". -
I
- 2. A void CMC shall not he reactivated. ,
1 LNFORMATION l
COPY a PPRV
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- TEXAS UFILITIES SERVICES INC. PNXIIK2E REVISIW ISSUF. PAGE DATE
. CP-EP-4.6 8 g.22-83 13 of 15 i
O FIGIEE 1 (TYPICAL) .
REV. PAGE 1 OF
. I GMANOIE PEAK STEAM ELECTRIC SMTIGi ;
dNGINEERDG CHANGC REQUEST I
EG 10. 1
-1. ShPErY REIATED CHABGE: YES NO
- 2. DISCIPLDE: CPPE M
- 3. IESCRIPFIW: .
A. APPLIGBIE SPEC /DWG/DOCIMENF B. IEMIIS 4
C.. REMEN EGt QIANGE O. -
- 4. SUPPORfDG DOCtMENMTIW .
- 5. APPROURL SIGNRTURES: .
f A. GtL3INR2Gt DRTE
/
B. APP 50VED BY DATE .
C. DISPOSITIN BY M CPPME CPPI&C
- 6. DISPOSITIW: !
r A. aPPmvEo Amm D AS roru 1NFORM._ATh0M _
B. 3NIERDISCIPLDE REVIEN REQUIRsD: YES O
~
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- C. CBAWING & REVISIN AFFECTED BY ECR fawsuwnT.:CN Gt EICN
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BY: DATE p .e G
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0 0 1TlXAS UTILITIES SERVICES INC. '
PICCEDURE REVISION ISSUE PAGE DATE
' CP-EP-4.6 8 9-22-83 14 of 15 O...
~
PAGE 1 OF CDtANCIE PEAK STEAM ELECTRIC STATICN 7 IESIGi GANGE AUIBORIZATION l
(WILL) (WIII. NDf) BE INC.POEUCID IN DESIGN DOC [ MENT DCA NO.
- 1. SAFETY REIATED DOCIN NF: YES NO
- 2. CRIGINMOR: CPPE CRIGDEL DESIGNER
- 3. DESCRIPTICN:
A. . APPLICABIE SPEC /IMWDOCEMENT REV.
B. DETAIIS t .
O
- 4. SUPPORTING DOCIMENEATICN: ,
- 5. I APPROVAL SIGNATWES:
A.. .IGINMcR:
'- 50ggATt0E D
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B. DESIGi REPRESENDUIVE: M_
C. DESIGN REVIEN PRIOR TO ISSUE: \
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- 7. SDUCARD DISTRIBUTIGI: '
7 Aiur (ORIGINAL) (1)..
O caALITr ENGINEERING (1) ?
DCIG' FCR ORIG. DESIGN (1)
- j DCA EUBM 9-83 l
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1EXAS UFILITIES SERVICES INC. PICCIEURE < REVISION ISSUE PAGE DME
-. CP-EP-4.6 8 9-22-83 15 of 15 n
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REVISICH PAGE TEXAS UI'ILITIES SERVICES INC. PICCEDURE ~ ISSUE 7
i IRTE t-
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CmrROLLED QPY 10. M/~-So/ CP-EP-4.6 9 11-04-83 1'of 15 c
h FIEID IESIGN CBANGE CNIBOL PREPARED BY ,
APPROVED BY da/ -
4 1.0 REFEIENCES 1-A TUGCD/1USI QPs Plan 1-B THE Procedures Manual 1-C CP-EP-4.7 Control of Ihgineering/ Design Review of Field Design Chanaes 1-D CP-Ei-4.6-3 Applim tion of the DCA Form to Procurement Documents i
1-E CP-EP-4.0 Design Control General Requirements i 1-F CP-EP-4.5 Design verifi s tion F* n 2.0 m roR N agypygy y 7 2.1 ERPOSE
.w .. ww.
To h_h= the general method of &cumenting danges or deviations to i to specified design /ms.i. suction requirements by authorized field personnel follcwing release of engineering dmcuments awsw.d
., for fabrimticri or construction. These provisions are established ,'-
to assure mHance with the requirements .of Reference 1-A. Mate, supplemental ' engineering procedures / instructions nay be used to describe and inglement alternate methods of design dange control.
-- 2.. ,
- c. . - . .m _--
2.2 SCOPE Design dange/ deviations shall be aw wed when carplete and validated by designated authorities as described in this instruction.
- 2.3 RESPCNSIBILITIES .
i
- The Assistant Project General Manager has overall rwegibility for the design of the CPSES project. Authority for the implementation of this procedure las been delegated to the Manager of Engineering and subordinate engineering organizations. Further delegation of authority may be acccupli'shed through formal engineering instructions supplementing this y vcedure.
The Mtnager of Engineering r. hall as su hhhking -
mechanisms exist to provide positise contro of sp dissosition, and status'of h==nt _ a these measures. "
l .
i b 2.4 IEFINITICNS 1
- 2.4.1 Encineerino Documents PP?l* ,
As used in this procedure, h==nts approved for fabrication or ,
constructicn whicn scocify, design, engineering, and/or construction ^ f requirements (sucn als specifications and drawings). '
l .
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REVISICN ISSUE PAGE i TEXAS UrILITIES !ERVICES INC. PICCEDURE
- - - DATE .
L. .
j- CP-EP-4.6 9 11-04-83 2 of 15 i
f.
h-: 2.4.2 - Desian Chance .
I A revision to engineering documents which affects the fbra, fit, I
j
- or function of the affected structure, system or canponent.
2.4.3 Deviation A departure from a specified engineering requirement that &es net affect the form, fit, or function of affected structure, system, or component.
2.4.4 emineerino Omnae Beauests A document used to forward engineering, design, or tednical inforna-tion between engineering organizations for the purposes of initiating revisions to engineering documents. The ECR is a -mimtion/
interfam doctament whicf1 does not authorize fabricatim or construction activities.
l 2.5 DOC 3ENIRTICH I
i .hsign changes / deviations to specified engineering cbcuments shall be documented by revision initiated by an Engineering Change Request (ECR), a Design Change Authorization (DCA), or i
Q a c.---:--et. Modifimtion Card (CMC). The regdve forms and the applimtion of each are further described below.
! ' 3.0 PIrrmutE 3.1 DGINEERI!G CHANGE REQUESTS I 3.1.1 General U"R's shall be used by CPPE to initiate design changes to be documented by document revision. In addition, design change nn. ,- ==1= formrded by other organizations such as Westinghouse Field Ciange Notices (IQi's), TUGCD Design Change Requests (TDCR's) and Gibbs f Hill Design / Engineering Change / Deviations (DE/CD's) say be processed by ECR's.
Upon czmpletion by the originator,the ECR shall be formrded as .
specified herein for enginee &-,=-at h w=uon, approval, --
and design verification as reo. g j 3.1.2 Soecific Scoce of ECR's --
Q[
1he specific scope of cfianges (i.e. s;st ,3
\T tagy, reas, agneerirxJ documents, etc.) CR's shal be ;-
nistratively defined by theto be Diginee ger.
~
ICIE: Changes critial to construckiem ' " ;.oun of an innediate need for inplementation my fs exempted fran the scope of-ECR's cm sanner a shangase bv case tasis. - Qiances peccessed be @waanted by DCA/ CMC; however, the in change this shall be authorized by specified engineerinJ nanagement personnel.
- - .--e ..n---.- , , - - - , , . , - . . , . . , - - - - - - - - - , - . - , . - - . . ..-. ~ . . , - - - - . - - . - - - . , , . . , . , . - . . . - - - . . - . - . - - - - . - - - .
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TEXAS UfILITIES SERVICES INC. PROCEDURE REVISICH ISSUE PAGE DATE CP-EP-4. 6 9 11-04-83 3 of 15 l
l l
3.1.3 Fern Ctanletion
- Detailed instructions for cxmpletion of the ECR form are specified j per Attac.%nent 1.
3.1.4 Reauest Acoroval and Distribution l
! ECR's shall be awi.w 1 by individuals designated by the CPP Engineering Manager. Upon approval, the ECR shall'be forwried '
l as follows for dispositlen:
Secos of ECR Responsibility a) Non-ASME, BRP Related [? CPP Moctaanical Engineering b) Non-ASME, len-BRP Related DEC c) ASME Related: Stamping Complete THE d) AEME Related: Stanping Inocuplete CPP Mechanical or I&C Engineering
. 3.1.5 , Disposition -~~, - --- .
. . :. w- .
Q 3.1.5.1 Itra-ASME, BRP Related -
' The ECR shall be used by CPP Technical Services as a tasis for BRP r rwisien and relysis (as required). If the ECR alas affects
- -~ '
design &x:uments other than BRP's, CPP Technical Services will forwrd copies of .he ECR to the responsible organizations. These activities shall be accomplished in accordance with the engineering
, procedures / instructions established to control the design and
.,, design cfiange program. Revised design documents shall be entered N I hinto W3 the n nh==nt
- ~ _ control
....._, program. ,.,_ . _ . _ , _ . . __ ... .s .. . . . _
3.1.5.2 Itin-ASME, Ibn-BRP Related ^ ~ ~ ~ ~ ~ ~ ~~' ' ~~ ~~
The ECR shall be used by TNE to cxxanence design ctritrol activities as defi:md per Reference 1-B. Upcri completion of an enaineerirs rwiew to identify design cx:nsiderations (sudt as interdiscipline twiew, calculations, danage study, etc., imgact), the ECR shall be ir v wi ted into affected de=ats for fc sw..L sf the design change and design verifica o - - - - ~
the dispositiert process, the ECD wy [hl ' _w%Du ttM ng involvement of che originator. '
Affected h==nts shall be entered the e con 1 program for distribution. ,
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~"
3.1.5.3 ASME lulated: Stanqping Ccuplete ? .-
DE shan 'etaplete design control activities as specified in Beforence 1-B. CPPE shan participate in the amlysis and pipe support effort as defined in the THE-defined interface &acuments.
All CPPE activities shan be controned in accordance with established engineering rw e ares / instructions. During the dispasiticn process, the ECR may be modified with the involvement of the originator.
3.1.5.4 ASME Related: Stanping Inasuplete -
1he ECR shall be used by CPP Mechanical or I&C Digineering as a tasis !
for revising the engineering documer.t used in the cartification -
process. The revised document shall be reviewed to determine if stress rw-enalysis is required. If stress re-enalysis is required, the revie ring ceganization shall coordimte the amlysis and design activities as required. After initiate pipe or re-enalysts, yf no . re-amlysis is required, the revised document shan be formrded to DE for the ocupletien of design control i activities and return. The above activities shan be accenglished in accordance with the engineering sweare/ instructions established to control the design and design change program. .
Revised engineering documents sha n be entered into the M m e 1
control program.
- 3.1.6 Closure i
ECR disposition shan be documented per Figure 1. Distribution i of the dispositioned EG shall include the originator and DCIG. Where required, the responsible disposition organizatico shall retain a copy of the EG for design control documentation.
~ .
3.2 EESIGN GANGE ADIBORIZATIONS & CWPCNENT MCDIFICATIN CARDS '
3.2.1 Perm Ccapletion l Detailed instructions for completion of the are specified per Attactsment 2 & 3.
1MFORM s
COPY ppRY v
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TEXAS UfILITIES SERVIGS IlC. P90CEDUltE REVISICN ISSUE PAGE N ,
CN.6 9 11-04-83 5 of 15 3.2.2 Review and Accroemi s
/
Field origimted design changes / deviations shnu be em J by the origimi designer's desigmted site representative unless otherwise
- stated in fbraml engineering instructions mapplementing this Wi e. The Engineering Manager shnu unintain written
! i l authorization of personnel designated as a "GER Design Representative" i ce desip representative of any other vendor. Clarifications or
. design changes properly .yy.M and issued by the original desip ceganization re only the signature of the origim ting engineer /
te&nician. clarifistions or design changes shall ne referenced
.. oc attached. Desicm changes / deviations documented as described F berein are approved fbe 8mbrication and construction only. In
- addition, these ====>res say be used to comunaniste or identify to construction changes / deviations originated / approved by the original desip ceganistion.
- W=it review and approval by the origina!. design organistion ehall be amlished per the provisions of Reference 1-C and 1-D or '
Tts. ..
3.2.3 Distribution ,
l Distribution of field change / deviation cbcuments shan be acceedliahed .
as required to fulfin the requirements of this y --t're and to
- satisfy tusic docisment cxmtrol requirements of interfacing organiza--
I tions such as the design and <:enstruction groups. The provisions of Reference 1-E shan also be considered dan establishing distribution.
3.2.4 Revisions
. Revisions to DCA/OC Pbras shall be accomplished as described in Attachments 1 and 2 and shan be reviewed and ayy m.d as y.mibed
in Section 3.2.2.
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IEVISIGi TEXh8 UrILITIES ElRVICES INC. PICCEDUIE ISWE PAGE DNTE
~
L C > tP-4.6 9 11-04-83 6 of 15
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l 3.2.5 Design varification ,' ;
Design dianges/ deviations shall be verified either prior to, or
- after tation by authorised personnel, to confirm ce substa to that the change is acceptable fa an engineering standpoint and consistent with the design basis (or input), FSAR
- candtzents and applicable codes and standards. This verification shan normany be a ished by the origimi design organistion in accordance with as ished procedures although the provisions of References 1-8 cc1-F may be utilized at the discretion cf the Assistant *toject General Manager.
In the event the design verification activities indicate the change / deviation is wiaWWe, the reviewing agency shnu
! notify the origina organization dio any, on the area in j question, place a . " or rescind and relssue the diange/
l .
deviation. Any physical corrective acticn required in pechlem i areas shall be aseltanted and Samuhted en a case by case tasis.
l 3.2.6 Interface'Cbntrol t i p Sigrdficant dianges/ deviations to engineered items involving i v A/E and vendor interfaces for equipment foundation details shall-
! be reviewed with both the A/E ano. the vendor for ampliance with requirements, price to approval for fabrication or i
l Formal doctamentation dure vendor er A/E approval is required ,
I shan be acczeglished in accordance with Reference 1-C and 1-D.
I .
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. 1EXAS UFILITIES SERVICES INC. PROCEDURE REVISIGi ISSUE PAGE
. DATE
' CP-EP-4.6 9 11-04-83 7 of 15.
_. JEBCIDENE I I
ECR FGH CI3GUTIOi /
The Engineering Change Request Rn:nt (Figure 1) shall be ampleted as follows:
- a. ECR No. - assignad by the responsible site organization.
- b. Safety Related' Document - Check awwy61 ate bloc'c. -
- c. Discipline - Designate a w y ate l Engineering organization.
d Applimble Spec / Dwg / Document - Cross out cbcuments that do not apply. Specify all Jmown affected or interfacing engineering d)ctaments.. ,
- e. Details - Provide information cn the change under czmsideration l using adequate descriptions or references to other doctaments which clearly illustrate the problem and resolution. Attad the design h==rits marked to adequately show the change.
- f. Suggorting Doctamentation - References supporting documents such as A ' -
teleghone conversations, telexes, telecopies, sketches, PQis,
_ DCAs, 1DCRs, TDRs other ECRs, etc.
1 .
aandwritten forms will be aAW in isolated maes; however, typing is preferred.
The originator and chte shall be provided. Approval shall be provicL1, disposition responsibility assigned, and the ECR fonarrM for disposition as irdimted in Section 3.1.4.
Modifications required to the ECR in the disposition process shall be'indiated by noting the change on the BCR. The change shall be initialed or otherwise validated and dated. All involved sarties should be identified in the validation.
\MFOR p 0M COPY
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, TEXns UTILITIES SERVICES INC. PROCEDURE REVISION ISSUE PAGE y
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CP M .6 9. 11-04-83 8 of 15
- , l
' ATThCMENT 2
, i ,
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, s ,
j DCh ICEM'CO@LETICN The' Desih bange Authorization fbra (Figure 2) shall be ocupleted as follows:
. r .
.1 0 a. iAuthorization No. - Assigned by the responsible site organization.
(WIILi (WIIL IDf) Be Irm.u yu ted in Design *Documents - Cross out the
- b. I one that does not apply. l As a general rule,' design changes to a specifimtion which are generic in a nature and will affect future work on a continuing basis shall be designated dcavings that can be ' delineated on the drawing. Clarifications and/or interpretations involving design documents will normally not be incorporated into the design ecuments. It is to be zod that specific guidelines covering every situation cannot be nested
- in this hr as such it will be the res of the
- Originatk Engineer /Techn[cian to exercise j'*pcnsibili y mnarnt a designate whether or not a change should be ireyw-ted. Note designation --
of ir v6,v tion is for prelindnary time only.
O- c. S fety =2ated -e - Chee the , ute bloe. -
- d. Originator - Chad the an- g 'mte block. (The " Originator" of a DCh resulting frcut a DE/CD, should be roted as the " Original Designer").
i
- e. Applicable SpecW==rst - Cross out the documents that e not apply.
i specify all knut affected oc interfacing engineering documents.
, f. Details - Provide information on the change under consideration using
- adegante descriptions or references to other document (s) which clearly i illustrata the problan and its resolution and provide sufficient information to reflect the "as-built" cxx1 figuration.
- g. Supporting Doctanentation - Reference supporting doctanents such telephonc conversations, telaxes, telecopies, DE/CD's , ,
TDCRs, TDRs, etc; If the DE/CD is modified '
word " Modified" shall be placed adjacent CCPT e l
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. TERS UFILITIES SERVICES INC. PROCEDURE REVISICN ISSUE PAGE mrE CP-EP-4.6 9 11-04-83 9 of 15
- h. Vendor anlated Omnge - Check the awi.wi.iate block. If the."yes"
- block is checked,'specify the appli a ble purchase order number.
I Ihndwritten forms win be accepted in isolated cases,.howver, thng is perferred.
The DC4 is then reviewed for technimi acceptance by the designated personnel.
Approval is obtained by sigm ture ard dating the aws.wi. late blanks as indicated in Section 3.2.2. s In the event, forum 1 approval and design verification is required prior to issue, the DCA shan be formrded to the responsible organization.
Ccapletion of those activities by the responsible organization shan be indisted by signature and date in the " DESIGN REVIDF PRICR TO ISSUE" blank.
If fornal approval and design verifistion is not required prior to issue, the originatcc shall unck *1R" in the " DESIGN lE7IDi PRIN TO ISSUE" blank.
Note "lR" does not indiste approval and design verifimtion is not subsequently required.
Revisions to a DCA will use Figure 2 and are filled out as described with the following exceptions: -
O a. 2,; e authorization c shan be used.
- b. Die amwi. late revision ntauber ahn11 be placed after the authorization rusuber.
- c. Subsection 3.B, Details, shall contain the following:
, "This revision voids and supersedes Design Change Authorization It. , Revision .
- d. If it is necessary to void or rescind a Design Change Authorization, it should be done by a revision to the existing DCA. Subsection 3-B (Details) of Figure 2 should contain the following statement i "211s revisial voids Design Change Authorization No. s and all revisions thereto".
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texas UrILITIES SERVICES INC. P!CCEDURE REVISICN LLeUE PAGE DATE C M .6 9 11-04-83 10 of 15 f
o ATSCMENr 3 CNC FCEM COGLETIQi
~ -
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The CwEt Modification Foca (Figure 3) is otnple ed as follows miess otherwise stata$ in engineering instructions supplementing this puedure.
The card should be filled out using a black ink pen or " dark" gencil.
- a. Serial No. - Prenumbered, or as established through detailed application instructions supplementing this procedure.
- b. Section 1, Application - state generic category of work (e.g. mechanimi equipnent, electrical equipment, pipe, pipe supports, etc).
Wald Mod., Q, Non-Q - Check ayywysiate block.
Design Omnge Deviation - Cross out the ene that cbes not apply.
Enter N/A or leave blank if not a change or deviation to design.
- c. Section 2, Dwg. 2. - Enter the couplete number and revision of the affected design basis and/or construction drawings as follows:
- 1. . Electrical - Enter design tasis drawing nunbers.
- 2. Piping and Instrumentation - Enter the design and construction drawing numbers for all design change / deviations; and ccnstruction drawing mnbers for construction changes.
- 3. Pipe Supports - Enter the construction drawing nunbers.
- d. Section 3, Line No./C my Mat No. - Enter the specific identifimtion number of the ccuponent to be nodified; spool nunber, equipnent number, etc. It is not required to enter the pipe support number in block 3. If a nunber of items are affected, enter "see sketch", and show all changes in block 5.
- e. Section 4, Reason for C2iange - State briefly son for the change. If to implement a ctange r3mr3 ..
original Design, clearly state this fact e. g l'fi:DhhpTement.D i
8600). .
- f. Section 5, Instructions - Describe ccuplet and h ly I nge to be made. .
E
- 1. Dere there are no welds or naterial or h_-.
"N/A" in the aw6+61 ate blocks.
^
- 2. Per removal and/or addition of welds and/or naterial, check the aw6w61 ate block and enter all weld numbers and/or Bill of s' Material item numbers renoved and/or added. It is not aandatory to disposition the future use and/or storage requirements for deleted naterial.
TEXAS UTILITIES SERVICES INC. PICCEEXXIE REVISION ISSUE PAGE UGE i ,, CP-EP-4.6 9 n-04-83 11 of 15
- 3. PGL PIPIIG CNIX Ate INIB3RAL EntGER ATTAOBENTS - If, after the original
, issue of BRP drawing, a weld has to be removed and towalded, the weld I
, niamber win be danged to indiste ame by adding an "A" for the first >
4 removal, "B" for the second reenval, etc. to the weld numbers, e.g., fbr the weld 6, the first removal / reweld is 6A, and if 6A requires rework, ,
the second renoval/re eld is 6B. ,
- 4. FOR PIPING Ott2 - When stainless steel materials are re-used and the heat affected zone not renoved, the new weld nLauber will include the next l sequential letter of the item with the higinst numerial weld nLaber. ,
Per example, if the pipe between welds 7A and 8C is deleted, and the reenining garts w=1 dad together, the new weld number will be 8D, not 7B. In the situation where weld 6A is cut and a pup installed between the two pieces, the new welds will be numbered 6B and 6A-1.
- 5. PIPDG GLEE - If, after' the original issue of the BRP drawing, arm added weld'is required whidt is not a reweld of an existing weld; the new weld will be keyed to the lower of the two rasubered welds and suffixed by "-1" for the first weld, "-2" for the second weld, etc., if a weld is added between weld "3" and "4", the new weld win be."3-1".
X
- g. Section 6- Provide a sketch indicating the new arrangement den necesary for clarifistion. itan note than one OC affects a drawing, are shan be .
D taken to avoid conflicts between the OIC's. This block should include specifications of items added that are not listed on the affected drawing.
, It =hm1A also show new weld locations, and~all required working point dimensions. (cut lengths fcr piping and hangers are not required).
- h. Section 7 - Originator - Enter the name of the individal preparing the sodification (for piping changes, foreman requesting the change should be entered).
- i. Section 8 - Approved By - Approval shan be obtained in accordance with
- Section 3.2.2. ,
- j. Section 9 - Distribution - If not predesignated, the Engi n -
preparing the Oc shan enter the nsam of eacts a .
g%
" Engineering and Office Use Only" copy and shal i$ wi-of required copies for'each. 1L
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TEXAS UfILITIES SERVICES INC. PICCEDURE REVISION ISSUE PAGE DATE
,- CP EP-4.6 9 11-04-83 12 of 15 O .
- k. General - Extra sheets say be used where necesary- to adequately cover I
the subject. All sheets must be sarked with the OIC serial number and numbered gage /
of _ .
- 1. Revisions to a Oct say be accaglished by danging the original form ce by utilizing a new foon (nonserialized) arzt filling it out as outlined above. Se following additions shall be roted 'cn the revised CMC, as appliable.
- 1. Se same serial number shall be used.
- 2. De aw wslate revision number shall be placed adjacent to the serial number.
- 3. If the reason for the revision is different frcza the original, )
enter the additional circumstances in Block 4.
e
- 4. Se OIC shall contain the following statement:
"This revisicm voids and supersedes dev,mt Serial
! maber , Revision .
O ==n an ocasion arises where a OIC has been issued armi for scue reason that card is not needed, 'it must be voided.
- 1. 2 void a CMC, the original ard nust be revised and clearly narked "vtaided - Not Superseded".
! 2. A void OSC shall not be reactivated. -
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REVISION ISSUE PAGE '
EXh5 UTII.ITIES SERVICES INC. PROCEDORE
. DME N .6 9 11-04-83 13 of 15
. p. FIGURE I
\. . (TYPICAL)
REV. PAGE 1 OF I
G24ANGE PEAK STEAM ELECTRIC STM' ION .
4 ENGINEERING CBANGE REQUEST ECR 10.
- 1. SAFETY REEMEo GANGE: YES 10
- 2. DISCIPLINE: CPPE THE
- 3. DESCRIPTION:
A. APPLICABLE SPEC /DG[uGU.irii!NF ,
B. DEULIIS J
, C. REASCN ECR GANGE __
!O 4.
SUPPORTING DOCDEND& ION:
- 5. APPROVAL SIGRTURES: -
. A. GtIGINMOR DATE
/
B. APPIOVED BY DATE C. DISPOSITION BY 1NE CPPME CPPI
- 6. DISPOSITION:
A. ,Pmmo ,P o m o -
a c*'yT B. ==nn . REvISIm mECr BY EcR w , MIrICm '
FOR REJECTION: _ ng
\ WN #
\ 7 V
BY: DM'E C.;
ECR POIN -
10-tu l
+---- y--ww- - ---- Dyw'v-ww ww-w-ww-,wgw-,,,g-.--,y-mww,gr---mge-ww-ym-y,w-u--et-w-,y,-wem,iy,ye,-g-9mww. y-g----,
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TEXAS UTILITIES SERVICES INC. PICCEDURE RE'VISIN ISSUE PAGE DATE CP-EP-4.6 9 11-04-83 14 of 15
.. PAGE 1 OF GMANCIE PE5K STEAM ELECTRIC STATICN , !
DESIGN GANGE AUTHORIZATIW - /
(WILL) (WIIL ICT) IE INCGEORATED IN DESIGN DOCDENF DCh IC.
- 1. ShETIT IELM'ED DOCEPENT: YES NO
- 2. CRIGINA2CR: CPPE CRIGINAL DESIGNER
- 3. DESCRIPTICN:
A. APPLICABIE SPEC /DW WDOCtMENT REV.
B. DemIIs
- O
- 4. SUPPORTING DOCDENIhTICN:
t-EnWMS' A
- 5. APPROUhL SIGOGURES:
A. GtIGINR2Gt: >
B. DESIN REPRESENTATIVE: Dd C. IESIGN REVIEN PRIOR '10 ISSUE:
- 6. VENDOR REIATED GANGE NO YES: P.O. NLMBER
- 7. SINEARD DISTRIBUTIW:
.O.:
w AIMS (ORIGINhL) (1)
QUALITY ENGINEERING (1)
DCIG FGL CRIG. DESIGN (1)
DCA POR4 9-83 i iA i g
Y 4.--
Iss0E TEXAS UfILITIES SERVIGS INC. PROCEDURE REVISICH PAGE tmTE C W .6 9 11-04-83 15 of 15 l
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ATTACINENT K-I. -
TUGCD ENGINEERING DIVISION PICCEDURE REVISICH ISSUE PAGE s/ >
CDNIROLLED G)PY 10 '[8/ CP-EP-4.6 10 4-16-84 1'of 15 I
FIEID DESIGN oncE CDNrax. = PARED sr /AlI8&r .
APPICVED BY Y en/ /
V 1.0' REFERENCES i
! 1-A TUGC0 m Plan
' 1-B 7tE Procedures Manual .
1 < CP-EP-4.7 Control of Ehgineering/ Design Review of Field Design O
- 8988 i 1-D CP-EP-4.0 Design Cbntrol General Requirements '
1-E CP-EP-4.5 posign Verification i
2o - FDR INFORMALON DEI 2.1 PURPOSE j Tb describe the general method of doctanenting changes or deviations
- to specified design /mnstruction requirements by authorized field
- personnel *ollowing release of engineering dscuments approved C, for fabrication or mnstruction. 1hese provisions are established i to assure a
- spliance with the requirements of Reference 1-A. Note, .
i supplemental engineering p6 w M ares / instructions may be used to describe and implement alternate methods of design dange control.
2.2 SCOPE j Design dange/ deviations shall be approved dwi conglete and validated by designated authorities as described in this instruction.
i 2.3 IESPONSIBILITIES .
1 The Assistant Project General Manager has overall responsibility for the design of the CPSES project. Authority for.the inglementation l.
of this r widare has been delegated to the Manager of ihgineering and subordinate engineering organizations. Further delegaticn of
, authority may be acconplished through formal engineering instructions :
i supplementing this p6w dare. .
- The Manager of thgineering shal acking mechanisms exist to provide pos tive161 St '4] %
disposition, and status of 9 6"*lsVuie'd,1 dd kh6qs 4 resu f , thes gy i measures, qf I
2.4 2.4.1 IEFINITICHS Engineering Documents
( ~b k
As used in this procedure, documen for fabrication or constructicn whis specify design, engineering, and/or construction requirements (such as specifications and drawings).
~
10G00 ENGINEERING DIVISIQi PICCEDURE ~ REVISION ISSUE PAGE De -
CP-EP-4.6 10 4-16-84 2 of .15
+
r 2.4.2 Design Ctvange A revision to engineering chetsments Wtich affects the fbne, fit, l ce function of the affected structure, systen or ccanponent.
2.4.3 Deviation.
A departure from a specified engineering requirement that does not I affect the fous, fit, or function of affected structure, systas, l
ce component.
- ~
2.4.4 Engineering Change Requests A document used to forward engineering, design, or te&nical informa-tion between engineering organizations for the purposes of . initiating
! revisions to engineering <bcuments. The ECR is a a:mununication/
interface document which does not authorize fabrication or
! aanstruction activities.
l 2.5 DOCIMENTATICN r Design changes / deviations to specified engineering documents l shall be doctanented by revision initiated by an Engineering
j i
{'. a Cm J. Madification Card -(CMC). The respective forme and the application of each are further described below.
l 3.0 PROCEDURE 3.1 DIGINEERING QiANGE REQUESTS -
3.1.1 General l
ECR's shall be used by CPPE to initiate design danges to be doctamented by 6==nt revision. In addition, design change proposals forwarded by other ceganizations sudt as Westinghouse Field l Change Notices (FQi's), TUGCD Design Change Requests (TDCR's) and Gibbs & Hill Design / Engineering Change / Deviations (DE/CD's) nay
~
be p - -M by ECR's. t Upon omspletion by the originator,the ECR shall t$t forwarded as specified herein for engineering document incorporation, al, and design verification as required.
3.1.2 Specific Scope of ECR's f
I The specific scope of changes (i.e. ,, ems- eas, engineering documents, etc.) to be , br ECR s be administratively defined by the CPP i
g Manager. '
'~
NOTE: Changes critical to constru need for inplementation may in teg()kan iM te exengted scope of ECR's on a case by case basis. processed in this manner shall be documented by DCA/CNC; however, the dange shall be authorized by specified engineering management personnel. ,
e n .,.m- .,-.-,,-ev- , - - ,-~enog ,--a,e,, ------,--e.. -.----,,,,wn-.-w,._- -
w,,m,--e-,-,,,,w-me ,m,,wn-,ww,ww-,-,,,n- --,----.,,,_u _m-,w,-~w,--,-----n-
l TUGCO DGINEERING DIVISICH PICCEDURE REVISION ISSUE PAGE
,. ERTE CP-EP-4.6 10 4-16-84 3 of 15 L
3.1.3 Rme Congletion' l l
Detailed instructions fbr czmpletion of the ECR form are specified per Attachment 1.
3.1.4 Request Approval and Distribution 4
a n 's shall be approved by individuals designated by the CPP Ihgineering Manager. Upon approval, the ECR shall be fbrwarded as follone for. dis;csition:
Scope of ECR Responsibility a) Ncn-ASME, BRP Relate! CPP Mechanical Engineering b) Non-ASBE, Itm-BRP Related 'D E
, c) ASDE Belated: Stamping couplete THE 4 d) ASME Related: Stanping Inocuplete CPP Mechanical or I&C Engineering 3.1.5 Disposition O .
'5*"-^'"'''****
I The ECR shall be used by' CPP Technical Services as a basis for BRP
! revision and re-analysis (as required). If the ECR also affects design dix:uments other than BRP's, CPP Technical Services will forward copies of the ECR to the responsible organizations. These j activities shall be accomplished in accordance with the engineering 3 procedures / instructions established to mntrol tha. design and design change progrue. Revised design documents shall be entered into the doctanent control program.
3.1.5.2 Non-ASME, Non-BRP Related l 'me ECR shall be used by 1NE to a:nmence design control activities i as defined per Reference 1-B. (4x:n coupletion of an engineering review to identify design considerations (such as interdiscipline review, calculations, damage study, etc., inpact), the ECR shall be ir-m teda into affected docunents for formal approval of the design change and design verification (if required). During the disposition process, the ECR may be modifi involvement of the originator.
Affected documents shall be enter program for distribution.
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- i l-TUGC0 ENGINEERING DIVISION PIOCEDURE RkV. ISION ISSUE PAGE r.
ID' CP-EP-4.6 10 4-16-84 4 of 15
[ 3.1.5.3 ASE Related: Stamping complete .
?
THE shall couplete design control activities as specified in Reference 1-B. CPPE shall participate in the analysis and pipe support effort as defined in the THE-defined interface doctanents.
All CPPE activities shall be controlled in accordance with established engineering procedures / instructions. During the disposition process, the ECR may be modified with the involvement of the originator.
l 3.1.5.4 ASE Related: Stasping Incomplete 1he ECR shall be used by CPP Mechanical or I&C Ehgineering as a basis i
for revising the engineering doctament used in the certification process. The revised document shall be reviewed to determine if stress re-analysis is required. If stress re-analysis is required, the reviewing organization shall anordinate the analysis and initiate pipe support design activities as required. After
- re-analysis, or if no re-analysis is required, the revised doctament
! shall be forwarded to THE for the ccepletion of design control activities axi return. The above activities shall be accomplished in accordance with the engineering procedure / instructions established j to control the design and design diange program.
2 Revised engineerirg duc.anents shall be entered into the h==st j control program. .
i 3.1.6 Closure ICR disposition shall be &)cumented per Figure 1. Distribution i
of the dispositioned ECR shall include the originator and DCTG. Where required, the responsible disposition organization shall retain a copy of the EG for design control doc.anentation.
i -
l 3.2 DESIGN QIANGE,AI7IHORIZATIONS & COMPCNENT MIFICATION CARDS 3.2.1 Form Concletion Detailed instructions for conpletion of the DCA/ CMC forms are specified per Attachment 2 & 3.
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r TJGCO ENGINEERING DIVISICN PIOCEDURE REVISICH ISSUE PAGE DATE E
'm CP-EP-4.6 10 4-16-84 5 of 15 l
- 3.2.2 Feview and Approval I Field originated design danges/ deviations shall be approved by the i original designer's designated site representative unless otherwise stated in formal engineering instructions supplementing this r vcedure. 'Ihe Engineering Manager shall maintain written aut.vrization
- of personnel designated as a "G&H Design Representative" or design representative of any other vendor. Clarifications-or
- design danges properly gproved and issued by the original design
- organization require only the signature of the originating engineer /
s tecnician. Sud clarifications or design changes shall be referenced
- or attached. Design danges/ deviations A tv'n=nted as described herein arc awwved for fabrication and construction cnly. In addition, these measures may be used to comninicace or identify to construccion danges/ deviations originated / approved by the original design organizatien.
h dt review'and approval by the original design oceanization shafl be acccmplished per the provisions of Reference 1-C or 24E.
h 3.2.3 Distribution .
O Distribution of field change / deviation cbcuments shall be accomplished as required to fulfill the requirements of this procedure and to satisfy basic &cument control requirements of interfacing organize.-
tions such as the design and construction groups. 'Ihe provisions of Reference 1-D shall also be considered when establishing distribution.
3.2.4 Revisiens Revisions to DCA/ CMC Ebrms shall be acconplished as described in Attacf1ments 1 and 2 and shall be reviewed an$ approved as prescribed in Section 3.2.2.
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'ItX300 DGINEERDG DIVISICN PIOCEDURE REVISION ISSUE PMIE
- m'rE 1
CP N .6 10 4-16-84 5 of 15 ~
5~ ~
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3.2.2' Review and Approval ,
i rield originated design changes / deviations shall be approved by the original designer's designated site representative unless otherwise stated in fbemal engineering instructions supplementing this-procedure. '!he Engineering Manager shall maintain written authorization of personnel designated as a "G4H Design Representative" or design representative of any other vendor. Clarifications w design changes properly approved and issued by the original design organization require only the signature of the originating engineer /
technician. Such clarifications or design danges shall be referenced f or attached. Design changes / deviations documented as described
- i. herein are approved fbe fabrication and aanstruction only. In addition, thase measures may be used to o:muunicate or identify to construction changes / deviations originated / approved by the original design organization, i '
L Subsequent review'and approval by the original design organization -
- shall be accomplished per the provisions of Reference 1-C or 'INE.
~
3.2.3 Distribution "
t* t . fC
,.".a. U..
Distribution of field change / deviation documents shall be accouplished
- as required to fulfill the requirements of this ps,3are and to
- satisfy basic <bcsanent aantrol requirements of interfacing organiza-
} tions such as the design an$ construction groups. 'Ibe provisions of .
Reference 1-D shall also be considered when establishing distrN*fon.
\' -, cry se - ~- e i 3.2.4 navisions Revisions to DCA/ CMC Porms shall be acannplished as described in l Atta s1 2 and shall be reviewed and approved as presce,ibed 4
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'!UGC0 DIGINEERING DIVISION PIOCEDURE REVISION ISSUk: PAGE
, IRTE-CP-EP-4.6 10 4-16-84 6 of 15 O.. .
, l 3.2.5 Design verification ,.
Design danges/ deviations shall be verified either gior to, or after implementation by authorized personnel, to confirm or substantiate that the dange is Wale fresa an engiceering standpoint and consistent with the design basis (or input), FSAR i caenitments and applicable codes and standards. 'this verification shall normally be acmeplished by the original design organization l in accordance with established reams although the provisions -
of Anferences 1-B or 1-E may be utilized at the discretien of the i
Assistant Project General Manager.
- In the event the desiya verification activities indicate the
! dange/ deviation is < Wale, the reviewing agency shall i notify the originating organisation de may, on the area in i question, place a " Hold" ce rescind and reissue the dange/
deviation. Any physical corrective action required in problem l areas dall be evaluated and flornulated on a case by case basis.
i 3.2.6 Interface Control
- n significant danges/ deviations to engineered items involving ,
(./ A/E and vendce interfaces for equipment foundatien c;etails shall
~
be reviewed with both the A/E and the vendor for compliance with design requirements, prior to approval for fabrication or I
czastruction.
i Formal &x:umentation Wure vendor or A/E approval is required ,,, _
j shall be acamplished in accordance with Reference 1-C. ,,,, ,, ,,, .s .
l ,q u. 3 . - ,
1 1
9
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- c. ._%_-..____....,,___,_m._,m._,-.,,,,,y.. . , _ . , . _ m ,, ..-mm., , _ _ ~,~~m.m-..,_,_,m
, TUGC0 ENGINEEIC3G DIVISION PIOCEDURE REVISION ISSUE .PAGE DATE A
C M P-4.6 .10 4-16-34 7 of 15 i
I AT50 BENT I -
ECR FDIM COMPLETI3i The Engineering Oange Request Form (Figure 1) shall be a:mpleted as fbilows:
- a. ECR No. - assigned by the responsible site organization.
- b. Safety Asiated Doci.snent - Check appropriate block.
I
- c. Discipline - Designate appropriate thgineering organization.
- d. Applicable Spec / Dwg / Document - Cross out &cuments that
- do not agply. Specify all knonri affected or interfac.ng j engineering &cusants.
< e. Details - Provide,information en the . change under consideration i using adequate descriptions or references to other documents which clearly illustrate the problem and resolution. .u; tach the desiga documents marked to adequately show the change.
j f. SpinJ Domanentation - References supporting documents sud as telephone conversations, telexes, telecopies, sketches, Fols, m
- DChs, TDCHm,1DRs other ECRs, etc.
1
- Handwritten fatas will be accepted in isolated cases; however, typing i is preferred.
4 The originator and date shall be provide. Approval shall be provided, disposition responsibility assigned, and the ECR forwarded for j disposition as indicated in Section 3.1.4.
j Nodifications required to.the ECR in the disposition process shall be indicated by noting the change on tte ECR. The danga shall l be initialed cr otherwise validated'and dated. All involved parties should be identified in the validation.
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l TUG 03 ENGINEERING DIVISICH HOCEDURE REVISION ISSUE PAGE tate CP-EP-4.6 10 4-16-84 8 of 15 l
i A25 cD err 2 -
DCA EDIN CCMPLETICN The Design Omnge Authorization form (Figure 2) shall be conpleted as follow:
- a. Authorization No. - Assigned by the responsible site organization.
- b. (WIIL) (WIIL 10f) Be Incorporated in Design Documents - Cross out the one that does not apply.
As a general rule, design changes to a specification sich are generic in a nature and will affect future work en a continuing basis shall be designated drawings that can be delineated on the drawing. Clarifications and/or interpretations involving design documents will noneally not be irm m teda into the design documents. It is to be recognized that specific guidelines covering every situation cannot be delineated in this procedure; as such, it will be the responsibility of the Originating Engineer /14chnician to exercise judgement and designate whether ce not a diange should be irms. pated. Note. designation of incorporatim is for preliminary time only.
- c. Safety Related h_==nt - Check the appropriate block.
- d. Originator - Check the appropriate block. (The " Originator" of a DCA resulting from a DE/CD should be noted as the " Original Designer").
. e. Applicable SpecW= ant - Cross out the @==nts that do not apply.
Specify all known affected or interfacing engineering documents.
f.
Details - Provide infctmation en the change under consideraticn using adequate descriptions or references to other h==nt(s) which clearly
' illustrate the problem and its resolution and provide sufficient information to reflect the "as-built" configuration.
- g. Syporting Documentation - Reference supportirs documents such as telephone aanversations, telexes, telecopies, DE/CD's, sketches, ECNs, TDCRs, TDRs, etc. If the DE/CD is modified by site engineering, the word " Modified" shall be placed adjacent to the DE/CD number.
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TUGC0 ENGINEERING DIVISION P10CEDURE REVISIN ISSUE PAGE DM'E
- CP-EP-4.6 10 4-16-84 9 of 15 I
\
Handwritten forms will be accepted in isolated cases, however,-typing is '
perferred.
The DCA is then reviewed for tedinical acceptance by the designated personnel.
1 Approval is obtained by signature and dating the appropriate blanks as-indicated in Section 3.2.2.
' In the event formal ww.1 and design verification is requiredt rior to issue, the D a shall be forwarded to the responsible organization.
Ccapletion of those activities by the responsible organizatio6 shall be indicated by signature and date in the " DESIGN REVIEN PRIOR TO ISSUE" blank.
If formal approval and design verification is not required prior to issue, mark "NA" in the " DESIGN REVIEN PRICR TO ISSUFblank. Note "NA" does not i
indicate ww.1 and design verification is not =+=arymtly required.
Revisions to a D a will use Figure 2 and are filled out as described with the fbilowing exrw*4~is: .
- a. 1he same authorization number shall be used.
v
- b. The appropriate revisicm number shall be placed after the authorization ntmber.
l c. Subsection 3.B, Details, shall contain the following:
{ "This revision voids and supersedes Design Change Authorization No. , Revision .
' d. If it is necessary to void or rescind a Design Change Authorization, it should be done by a revision to the existing DCA. Subsection j
34 (Details) of Figure 2 should contain the following statement "This revisicm voids Design Change Authorization No. and all
- revisions thereto .
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n1GO:) DGINEERING DIVISICN PIOCEDURE REVISION ISSUE PNE DATE A
CP-EP-4.6 10 4-16-64 10 of 15 N3 ;
CMC FCEM COMPT.ETICN
'Ihe C4 snt mdification Form (Figure 3) is ocupleted as follows miess otherwise stated in engineering instructions supplementing this procedure.
3 e card should be filled out using a black ink pen or " dark" pencil.
- a. Serial No. - Prenurbered, or as established through detailed application instructions supplementing this procedure.
- b. Section 1, Application - State generic category of work (e.g. mechanical equignent, electrical equipment, pipe, pipe supports, etc).
Weld 2d., Q, Non-Q - Check appropriate block.
Design Change Deviation - Cross out the one that &es ret apply.
Enter N/A or leave blank if not a change or deviation to design.
- c. Section 2, Dwg. N3. - Enter the cmplete number and revision of the affected design basis and/or mnstruction drawings as follows:
- 1. Electrical - Enter desiga b-=is drawing numbers.
- 2. Piping and Instrumentation - Enter the design ard construction drawing nuntr - 'or all design change / deviations; and construction drawing numbers for construction changes.
- 3. Pipe SwsL5 - Enter the construction drawing rambers..
- d. Section 3, Line No./ Component No. - Enter the specific identification nianber of thra couponent to be nodifiedt spool number, equipnent ntanber, etc. It is not required to enter the pipe support number in block 3. If a number of items are affected, enter "see sketch", and show all changes in block 5.
- e. Section 4, Beason for Change - State briefly but encisely the reason for the change. If to inplement a change properly approved by the Original Design, clearly state this fact (e.g., 'Ib inplement DE/CD 8600).
- f. Section 5, Instructions - Describe coupletely and accur .e ange to be made.
- 1. Where there are no welds or material r e ente "N/A" in the ow6wciate blocks.
- 2. For renoval and/or aldition of welds /or ma erial ecMe appropriate block and enter all weld numbers /an(d/or Bi1} g of Material item numbers renoved and/or added. It iss fbTrpandatory; to dirposition the future use and/or storage requfrL=tiehts for deleted material. '
- 1, * . --. .-
TUGCD DEINEERING DIVISICN- PICCEDURE REVISION ISSUE PAGE Dkrz
-A CP+1.6 10 4-16-84 11 of 15 r
- 3. FCR PIPDG ONL1r ABC INIEGRAL HANGER ATMCIDENIS - If, after the origina1J issue of BRP drawing, a weld has to be renoved and rowelded, the weld number will be danged-to indicate same by adding an "A" for the first removal, "B" fbe the second removal, etc. to the wid rassbers, e.g., fbr the mld 6, the first renoval/ reweld is 6A,'and if 6A requires rework,
- the .woond renoval/ reweld is 6B.
- 4. FOR PIPING CICf - When stainless steel anterials are re-used and the heat affected zone not removed, the new weld number will include the next sequential letter of the item with the highest numerical weld nunber.
- Fbe example, if the pipe between welds 7A and 8C is deleted, are! the L remaining parts welded together, the new weld nunter will be 8D, not
! - 7B. In the situation where weld 6A is cut arzt a pup installed between the tue pieces, the new welds will be numbered 68 and 6A-1.
l 5. PIPDG Qi!Z - If, after the original issue of the BRP drawing, an added weld is required dich is not a ruweld of an existing weld; the new i weld will be keyed to the lower of the two rsambered welds and suffixed by "-1" for the first weld, *~2" for the second wid, etc., if a weld j is added between weld "3" and "4", the new weld will be "3-1".
j Q g. Section 6- Provide a sket& indicating the new arrangement den necessary for clarification. 14en acre than one OC affects a drawing, care shall be i
taken to avoid conflicts between the otC's. This block should include i
specifications of items added that are not listed cm the affected drawing.
! It should also show new weld locations, and all required working point i
t dimensions (cut lengths for piping and hangers are not required).
- h. Section 7 - originator - Ilinter the name of the individual preparing the i andification (for piping changes, feremen requesting the change should j
i
. be attered).
i
- 1. Section 8 - Awa By - Appcoval shall be obtained in accordance with Section 3.2.2.
- j. Section 9 - Distribution - If not predesignated, the Ehgineer/ Technician i
propering the Oc shall enter the name of each agency requiring an l "Ilhgineering nd Office Use Only" copy and shall indicate the number of required copies for each.
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r I T0000 ENGINEERING DIVISION PICCEDURE REVISION ISSUE PAGE DM'E
'.n i- CP-EP-4.6 10 4-16-84 12 of 15 l
1 l k. General - Extra sheets may be used where necessary to adequately cover the subject. All sheets aust be marked with the CMC serial number and numbered page of .
! 1. Revisions to a CMC may be m'ished by changing the original form or by utilizing a new form (nonserialized) and filling it out as outlined above. Se following additions shall be noted m the revised Ott, as applicable.
- 1. The same serial rusuber shall be used.
! 2. Se appropriate revision number shall be placed adjacent to the serial rnsuber.
- 3. If the reason fbe the revision is different from the original, enter the additional ciremstances in Block 4.
, 4. The Ott shall contain the following statement:
"This revisim voids and supersedes hmt Serial -
Number , Revision .
C m. When an occasion arises where a OC has been issued and for some reason that card is not needed, it nust be voided.
j 1. Tb void a OC, the original card must be revised and clearly marked i
t
" voided - Not Superseded".
l 2. A void OC shall not be reactivated.
I
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i 'tDGCD DIGINEERING DIVISION PICCEDURE REVISION ISSUE PAGE
, , DhTE
! CP-EP-4.6 10 4-16-84 13 of 15 FIuum 1
' '*(TIPICAL) !
REV. PA 2 I 0F l l l
CDON3E PEhK stent! ELECTRIC SDd' ION I
- MCINEERDG CHANGE REQUEST l EOL NO.
.c s
- 1. ShrErY IEEATED CHANGE: YES 10
. 2. ' DISCIPLINE: CPPE ' DIE -
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- 3. DESCRIPTION:
I A. APPLICABLE SPEC /DiWDOCLMDir l B. DEIRILS '
l C. IEh83 70R CHANGE 4
- 4. SUPPOR:'DG EDCIMD7DLTION:
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l S. APPICVAL SIGUGURES:
I i A. GtIGINMOR DhTE B. APPICYED BY DME C. DISPOSITICN BY ' IRE CPPME CPPIEC
- 6. DISPOSITICN:
A. APP 50VED APP 50VED AS (COEN B. 15hWDG & BEVISIW AFFECTED BY ECR
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TUGCD ENGINEERING DIVISION PPnmv1qE ggVISIN ISSUE PAGE DNTE CP-EP-4.6 10 4-16-84 14'of 15
~
PA 2 1',OF i CDUMQlE PFAK STDM ELECTRIC SBTIQi IESIQi QiANGE ADIBORI2ATION (WILL) (WIIL NOT) BE INCCRPCEULTED IN DESIGi DOCGGNT DCh 10.
- 1. SAFETY IEZATED DOCIBGNT: YES NO
- 2. CRIGINMOR: CPPE ORIGDIAL DESIGER ,
- 3. DESCRIPTIGI A. APPLICABEE, SPEC /DG/DOCDIENT REV.
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. 5. APPICVAL SIQlMURES:
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'B. IMSIGI REPRESENDLTIVE: \
C .DESIGi RVIEW PRIOR '10 ISSUE:
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- 6. STNCARD DISTRIBUFICN:
AIDE (GtIGINAL) (1)
- h. GRLITY ENGDIEERDG DCIG EUR GtIG. EESIGi (1)
(1)
DCA roen 3-84 -
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f 10G00 B0GINEERING DIVI 3ICH PEX200RE REVISION ISSUE PI G CATE 1
- 1 O -
CP EP-4.6 10 4-16-84 15 of 15 1
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Communications M ATTACHMENT L Report
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t i llllllllll'!!11lll1111111ll111 company: Texas Utilities c
- coa 'X conte nce Repon
' 84042 Comanche Peck Steam Electric Station D *:
Independent Assessment Program - Phase 3 S/24/84
}
"'*' 000 p.m.
Inspection Reports Place:
COSES
. T. Vega, M. Welch, D. Hicks, C. Welch TUSl S. Bibo, N. Williams, D. Smedley Cygno 1
Reauin.a Comments Action ;y stem Cygno asked to meet with the above listed TUSI participants to discuss the use of In:pection Reports (IR) at CPSES.
We asked what the basic difference is between on NCR and on IR.
Tony Vega explained that basically NCR's get engineering review and IR's i are cleared by a "use os is" or nonstandard repair, then engineering would issue o DCA/ CMC. He stated that regardless of the document used, the i bottom line was that any unsatisfactory condition dispositioned "use os 1s"/"or repair" must receive on engineering evoluotion.
l Mr. Welch explained that if on attribute listed on on IR was deter' mined to l
be unsatisfactory, the GC inspector would make o determination that the
, condition should be " reworked." Construction would then rework the item I
in occordance with the document they originally used to install /fobricate, or use on established standard repair / rework procedsre. Once the item was corrected, QC would re-inspect using the attributes of the original IR, or o separate IR specifically generated to address the requirements of the standard repair / rework procedure. .
In addition, it was explained that construction had the option of going to engineering and asking for DCA/ CMC to be issued to accept the unsatisfactory condition ("use-os-is"). GC would then be colled to re-inspect the item. The DCA/ CMC (issued by engineering) would serve os on engineering evoluotion of the nonconformance with a disposition of "use os is."
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ATTACif1ENT !!
.. TE0ui UrII.ITIES SERVICES INC. INSTRUCTION REVISICN ISSUE PAGE CWTE CDiTRCILED CDPY IC.hM CP-EI-4.6-8 7 9-21-83 1 of 6 PIEID DESIGN OfANGE CONTROL PREPARED BY W}MOa %
~-
Oh '
FOR IARGE BORE PIPE SUPPORTS "s APP- or A
- w. F- 2 4
' sf 1.0 REFERECE 1-A CP-EP-4.6 Field Design Change Ccntrol
- 2. "" "
2.1 PURPOSE F0fl F 0 M AIiD1 O f.Y The purpose of this instruction is to set forth the authods bf sich the provisions of Reference 1-A are implemented by Pipe Support Engineering (PSE).
2.2 Score
, this instruction describes the handling of design changes to the point of design verification.
This instruction cbes not include design review or the securing of necessary original designer and/or verer approvals.
2.3 RESPCNSIBILITY The CPP Pipe Support Engineer (PPSE) is responsible for providing technical direction and administrative guidance to the PSE organization.
The delegation of authority to approve design changes made in accordance with this instruction is the responsibility of the Chief Engineer (s). Authority shall be granted on the basis of each person's work performance and experience.
Where a specific individual is designated by title in this instruction, it is understood that his designee can act in that official capacity.
IN:0RNAT06 .
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TEXAS UTII.ITIES SERVIGS INC. I WFRICTION DEVISION IS8UE PAGE E
e-C
- CP-EI-4. 6-4 7 9-21-83 2 of 6 4 3.0 DWFIGCNCN ,
3.1 EESIGN CHANGE ADIHORIZATION (DCA) FCIM i Se DCh foma shall be prepared in accordance with Reference 1-A, Attactuant 1. An individual authorized per Section 2.3 shall approve
- the sange. Sects approval shall release the change for construction.
Distribution shall be in accordance with " Standard Distribution" as
, proprinted on the DCA form. Additional distribution shall bu i indicated as recpired.
3.2 CDEDENF NCDIFICNTIOl CARD (OIC) 3.2.1 General Reauirements ,
OIC's shall be hawn from DCC by respective PSE clerks and drawn by '
individuals from the clerks ac rer3uirei. l
- the clerk shall maintain a log of each Olc issued. 21s log shall
, include the following information:
- 1 l s.., a. OIC serial Itatwe -
2
- c. Document /Drawir.
- c. OIC Criginator'gsNumber Initials Affected
- d. Date Issued OC's shall be peepared in accordance with Reference 1-A, Attachment j 2.
1
! An individual authorized per Section 2.3 shall gyrove the dange.
Sud approval shall release the change for construction.
3.2.2 Distribution of OC's 3 3.2.2.1 Pipe Support OC's shall be distributed u follows
- a. DCC 2 1 Copy
- b. Manger Package 7 1 c~y (Mun P is available) ~
- c. Melding Eng ring Substation ( '
l is not available) h/! e i
i,
- d. Noterial Control N -f .[tptscopy9 e.lirTDesip11eChange Control Group W{ ' 11Copy ,
/!
f.PsE OC .
-* Copy ;
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e L ._ ._ __ ~ ._ _ _ . , _ _ _ _ _ _ _ _ _ _ _ . _ _ . - _ _ _ . _ _ _ _ . _ - _ . - - - - . _ -
r TEXAS UTILITIES SERVICES INC. INSTRUCTION REVISION ISSUE PAGE g
O A. 3 of 6 CP-EI-4. 6-8 7 9-21-83.
Se followirq shall be indicated per Section 9 " Distribution" of the OC:
- a. hchnical Services 2 Cbpies
- b. Damage Study Group 1 Copy (for relocated supports on High Energy Lines) i Se clerk er responsible engineer shall enter the CC ranter en the weld data card when the hanger package is available ard shall enter the CC ruster in the appropriate design dange log.
i 3.2.2.2 Fire Protection Pipe Support QC's, which are in Grinnell scope, .l-shall be distributed as follows: I
- a. Grir nell - Site 4 Copies
- b. Hanger Fh-k-ge 1 Cbpy
- c. Material Centrol 1 Cbpy
- d. Support Design Package 1 Copy
- e. PSE OC File 1 Copy
. f. Design Change Tracking Group 1 Copy
- y. Se responsible ergineer or clerk shall note en the back of the controlled drawing the affecting CMC's and shall date and initial the entry. Se OC entry shall also be made en the appropriate design dange log.
' 3.2.3 CMC Retention -
me original CMC shall remain crs' file with PSE until such time as it
~
can be reasonably determined that the' OC will no ' longer require revision. At that time the original CMC shall be transmitted to TtKilnical Services.
3.2.4 OC Revisions l 3.2.4.12e original CMC may be revised by ocupleting the following:
- a. Se appropriate revision number shall be placed adjacent
! to the serial ranber.
l
- b. Changes to the OC shall be clearly marked e tuvision number and the revised are shall be h=11= ed wirreg%iP
m a .sJ .
1 COY .?
1 . ---- . .-
TEXAS UTILITIES SERVICES INC, INSTRUCTION REVISION ISSUE PAGE g
_. CP-EI-4.6-8 7 9-21-83 4 of 6
- c. All previous revisim marks shall be renoved. "
- d. The card shall contain the following statement: "Ihis revision voids and supersedes document serial number revisim
! 3.2.4.2 When deemed necessary because of the ccmplexity of the dange, a new CMC may be prepared depicting the required changes. The card shall contain the statement: "This CMC voids and supersedes &cument rumber revision "
3.2.4.3 Distribution of revised CMC's shall be in accordance with Section 3.2.2. The clerk shall enter the revision into the-hanger paczage and renove or void any outdated revisions. Iten the hanger M c is not available, the entry shall be made by the IE substation.
3.2.5 Nbidim CMC's When an occasion arises dere a OC has been irsind and is' no longer necessary, it must be voided. 1b void a QC it must be revised and clearly marked "vbid - Not Superseded." A CMC dich has been voided shall not be reactivated. Distribution of voided CMC's shall be 4
C in acmedana with Section 3.2.2.
3.3 FIEID MODIFIED HANGER SKEIG (ENHS) 3.3.1 Tb prepare a ENHS, a copy of the support draw :e marked
- clearly depicting the nece desian a nimum, PSE a'22 5"=d' *** ' 22 "*"'
i a. Material types and sizes $0Ri j \ . >3)
~
- b. Hardware requirements
- c. terking point dimensions (g'Q I/ d
- d. Wald type and sizes Q 3.3.2 PSE shall review existing design has thch the support drawing arxi incorporate ne===WoiEination into the FNHS. All. design danges affecting'Ge drawing shall be noted on the sketch with its disposition (i.e. voided or incorporated).
1-3.3.3 2m FNHS and any original CMC's shall be transmitted to Technical Services Mechanical Drafting (TSMD) for revision of the appropriate support drawing. Transmittal shall be, ,
accouplished by the standard form letter sham in Attachment 1.
Each transmittal letter shall be numbered sequentially.
t
I TEXAS UFILITIES SERVICES INC. INSTRUCTION REVISION ISSUE PAGE DATE A i L -
CP-EI-4.6 8 7 9-21-83 5 of 6 - l
't End transmittal letter shall be signed by an authorized PSE
, representative. Receipt of the transmittal letters shall be acknowledged by signing and datig by TSMD. A copy of the transmittal letter and INES shall be maintained by PSE. These files may be purged after the revised drawings are (===9 3.3.4 After inw6p6 tion of the design danges by TSMD, an authorized individual fresa PSE shall review the revised drawig to assure its accuracy. Upon acceptable review, the authorized individual shall initial and date the drawing authorizing its distribution. Drawings authorized herein are approved for fabrication and/or construction.
TSMD shall distribute drawings in accordana with established y6w dures/ instructions.
3.4 WEIDED AT20MENIS Special attention should be paid to any designs or design changes effecting welded attachments to pipe whid has been previously hydro-tested. According to the ASME Code, only the following welding can be perfoceed en previously hydro tested piping without requiring ratesting:
v 1. Full penetration welds for meterial up to 1/2" thick for lengths not to exceed 12".
- 2. Fillet welds with throat thicknesses up to 3/8" for lengths not to exceed 24".
- 3. Partial penetration welds with 36wvas up to 3/8" depth for lengths not to exceed 24".
In the event welding is specified which meets or_ exceeds the above criteria -(extracted from'NB-4436), the drawing or ' design change shall include a note similar to the following: "NB 4436 -
WEID CRITERIA MEr CR EXCEEDED." This note requirement shall not be retroactive.
h COM e- -
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TEXAS UTILITIES SERVICES INC. INSTRUCTI m REVISION ISSUE PAGE EATE
'G '
CP-EI-4.6-8 7 9-21-83 6 of 6 1
ATDOMENT 1 - TYPICAL TRANSMITIAL MDBER Tc: Mechanical Drafting / Welding, Engineering
Subject:
L-ssittal of Field Modified Hanger Sketches / Packages Attached for your action are the following Field Modified Hanger Sketches /
Packages and original QCs -
MARK }D. OCs .
i.
2.
3.
4.
' 5.
6.
7.
8.
9.
. 10.
11.
- 12. --
I': INFORMATION 15.
I lii 19.
20.
COPY PPRV Hanger Engineering Date '
" Received by Mecn. Drafting Date -
/' l Received by Welding Engr. Date I
l
.,--._.-_--...--.,.-.-.]
w 1
ATTACHMENT N j7tw151 TUGCDENGIN5ERING CN INSTRUCTION REVISION ISSUE PAGE
'CP-EI-4.6-8 8 7-5-84 1 cf 6 c:tifBOLIED CDPY 10 FIEID IESIGN CHANGE 03rrBOL . ./
~~
. PREP EY 4 .<. 6 r FOR IARGE IDRE PIPE SUPPCRIS ggg l APPICVED BY e -
i /
1.0 REFERENCE 1-A CP-EP-4.6 Field Design Change Control
'- "'"'"^'
FOR INFORMATION ONLY 2.1 PURPOSE 2e purpose of this instruction is to set forth the nothods by dtich the provisions of Reference 1-A are inplemented by Pipe Support Engineering (PSE).
. 2.2 ' SCOPE C 21s instruction describes the handling of design dwnces to the point of desian verification.
mis instruction does not include design review or the securing of necessary original designer and/or vendor approvals.
2.3 RESPONSIBILITY The CP Project Pipe Support Engineer (PPSE) is responsible for providing technical direction and administrative guidance to the PSE organization. .
The delegation of authority to approve design changes made in accordance with this instruction is the responsibility of the Chief Engineer (s). Authority shall be granted on the basis of each
. person's wrk performana and experience.
I Where a specific individual is designited by title in this instruction, it is understood that his designee can act in that official capacity.
NFORMATION l
COPY PPRV 6-
=. _ - . -. . .
__ - . _ . _ _ z_ . _ . ._ : :
. TUG 00 D3GINEERING DIVISION ' INSTRUCTION REVISION ISSUE PAGE DPCE
- .p CP-EI-4.6-8 8 7-5-84 2 of 6 u.
3.0 INSTRUCFICN ,
l 1 3.1 IESIGN OIANGE AUIHORIZATION (DCA) FCIDI h e DCA form shall be prepared in accordance with Reference 1-A, Attachment 1. An individual authorized per Section 2.3 shall approve .
the change. Sucf1.wwv.1 shall release the change for construction..
t Distribution shall be in accordance with " Standard Distribution" as preprinted cm the DCA form. Additional distribution shall be indica *ed as required.
3.2 COMPONDFF K)DIFICATION CARD (CMC) 3.2.1 General Reauirements CMC's shall be drawn from DCC by 4.nWive PSE clerks and drawn by individuals from the clerks as required.
The clerk shall naintain a log of each OC issued. Bis log shall include the following information:
- a. OC Serial Ntater b- b. Document / Drawing Ntanber Affected
- c. OC Originator's Initials
- d. Date Issued .
CMC's shall be prepared in accordance with Reference 1-A, Attachment 2.
l An individual authorized per Section 2.3 shall approve the cisange.
Sucts approval shall release the change for construction.
Guidelines cittlining the cxmplexity and type of design cnanges to be utilized by CMC's shall be established by the Chief Engineer (s).
3.2.2 Distribution of CMC's 3.2.2.1 Pipe Support OC's shall be distributed as follows:
~
- a. DCC _1 %
- b. Hanger Package (Mien Package is available)
- c. Welding Engineering Substation ( '"0RM
.e W.N 'T is not available) / f
- d. Material Control ( '1
- e. HFT Design Change Control Group 1Jeopy b
- f. PSE OlC file 1
- PPRlpy
TUGCD ENGINEERING DIVISION INST 10CTION REVISION ISSUE' PAGE ERTE n
'C CP-EI-4.6-8 8 7-5-84 3 of 6
~
The following shall be indicated per Section 9 "Districution" of the '
. CMC:
- a. 'Inchnical Services 2 Copies
- b. Damage Study Grotp 1 Copy-(for relocated supports on High Energy Lines)
Se clerk or responsible engineer shall enter the OC number en the
! weld data card when the hanger package is available and shall enter the CMC rn=her in the appropriate design change log.
3.2.2.2 Fire Protection Pipe Support OC's, which are in Grinnell scope, shall be distributed as follows:
- a. Grinnell - Site -4 Copies
- b. Banger Package 1 Copy
- c. Material Control. 1 (byy
- d. Support Design Package 1 Copy
- e. PSE OC File 1 Copy
- f. Design Change Tracking Grote 1 Copy The responsible engineer or clerk shall rote en the back of the controlled drawing the affecting CNC's ard shall date and initial the b entry. 'Ihe CMC entry shall also be made en the w e late design change log.
3.2.3 OC Retentioa Tne original CMC shall remain on file with PSE mtil sucts time as it can be reasonably determined that the OC will re longer require revision. At that time the original OC shall be transmitted to Technical Services.
3.2.4 OC Revisions 3.2.4.12e original OC may be revised by cmpleting the following:
- a. Se appropriate revisicn number shall be placed adjacent to the serial number.
l b. Changes to the CMC shall be clearly marked with the revision rn=har and the revised area shall be ball w ,ei ~~
, l INFORMAT.10N COPY PPRV m
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TUGCX) ENGINEERING DIVISION INSTRUCTION REVISICH ISEUE PAGE DATE h CP-EI-4.6-8 8 7-5-84 4 of 6
- c. All previous revision marks shall be renoved. -
- d. Se card shall contain' the following statement: "This revision voids and supersedes docsanent serial number revisicn 1
3.2.4.2 Distribution of revised CMC's shall be in accordance with Section 3.2.2. Se clerk shall enter the revision into the hanger package and renove or void art' cutdated revisions. When the hanger. package
, is not available, the entry shall be made by the WE substation.
i 3.2.5 vbiding CMC's When an occasion arises where a CMC has been issued and is rc longer necessary, it must be voided. 'Ib void a CMC it must be revised and clearly marked " Void - Not Superseded." A CMC which has been voided shan not be. reactivated. Distribution of voided CHC's shall be in accordance with Section 3.2.2.
! 3.3 FIEID MODIFIED HANGER SKEICH (FMRS) ,
I-3.3.1 'Ib prepare a PMBS, a copy of the support drawing shall be marked V clearly depicting the necessary design changes. As a minimum, PSE shall provide the following information:
- a. Material types and sizes
- b. Hardware requirements
- c. Nbrking point dimensions
- d. Wald type and sizes 3.3.2 PSE shall review existing design danges sich may affect the support drawing and incorporate necessary information into the EMIS. All design danges affecting the drawing shall be roted on the sketch with its disposition ti.e. voided or ir%ratedJ.
3.3.3 The FMHS and any original CMC's shall be transmitted to Technical Services Mechanical Draftirq (TSMD) for revision of the appropriate support drawing. Transmittal shall te aca:miplished by the standard form letrer shown in Attachment 1.
Each transmittal letter shall be numbered sequentially. _ _ .
1 lNFORMATION COPY PPRV l t
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tix;CO ENGINEERING DIVISION. INST 3DCTICH REVISION ISSUE PAGE DATE-O
'. CP-EI-4.6-8 8 7-5-84 5 of 6 End transmittal letter shall be signed by an authorized PSE representative. Receipt of the' transmittal letters shall be
, acknowledged by signing and dating by TSMD. A copy of the transmittal letter and FNIS shall be maintained by PSE. These files may be purged after the revised drawings are issued.
3.3.4 After incorporation of the design changes by TSMD, an altho::ized individual from PSE shall review the revised drawing to assure its accuracy. Upon acceptable review, the authorized individual shall-initial and date the drawing authorizing its distribution. Drawings authorized herein are approved for fabrication and/or construction.
TSMD shall distribute drawings in accordance with established procedures / instructions.
3.4 WEEDED ATDOIMDFIS Special attention should be paid to any designs or design danges effecting welded attachments to pipe whid has been previously hydro-tested. According to the ASME Cbde, only the following welding can be performed on previously hydro-tested piping without requiring retesting:
- 1. Full penetration welds for material up to 1/2" thick for i
. lengths not to exceed 12".
I
- 2. Fillet welds with throat thicknesses up to 3/8" for i lengths not to exceec 24".
i t
- 3. Partial penetration welds with grooves up to 3/8" depth-for lengths not to exceed 24".
In the event welding is specified which meets or exceeds the
. above criteria (extracted fran NS-4436), the drawing or design change shall include a note similar to the following: "NB-4436 WELD CRITERIA MET OR EXCEEDED." This note requirement shall not be retroactive.
lNFORMAT10N i COP?
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'IUGCD ENGINEERING DIVISION INSTRUCTION REVISION ISSUE PAGE DATE D CP-EI-4.6-8 8 7-5-84 6 of 6 ATSCHMENT 1 - TfPICAL TRANSMITIE NJMBER
'Ib: Mechanical Drafting / Welding Engineering
Subject:
Transmittal of Field Modified Hanger Sketches / Packages Attached fcr your action are the following Field Modified Hanger' Sketches /
Packages and original CMCs MARK 20. CNCs i.
2.
3.
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7.
8.
9.
10.
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12.
13.
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M: INFORMATION i COPY PPRV.
Haoger Eng wee - Date Received by Mecn. Drafting Date L.-
Receivec cy Welcing F.ngr. Date
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0 COMANCHE PEAK STEAM ELECTRIC STATION
. QUALITY ASSURANCE' PLAN 4
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TEXAS UTILITIES GENERATING COMPANY TEXAS UTILITIES SERVICES INC.
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l TEXAS UTILITIES GENERATING COMPANT l
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flay 21, 1981 Statement of Authority "
This Quality Assurance Plan establishes the Comanche Peak Steam Electric Station (CPSES) quality assurance system to be used by Texas Utilities Generating Company in performing design, engineering, procurement, fabrication, and construction activites in conformance with the requirements of the United States Code of Federal Regulations, the ASME Boiler and Pressure Vessel Code, and other applicable industry codes and standards.
The authority to implement the requirements of this plan is delegated to'the Manager, Quality Assurance, who has the complete support of the company's management and will, by organizational arrangement, be kept free from cost and scheduling influences. -
His authority, as defined in the program, extends to all quality
( assurance activities performed by and for TUGCO. Decisions on such activities are made in the name of this company, and may be overruled only by the Vice President, Nuclear or the undersigned.
All persons associated with safety-related activities at CPSES should familiarize themselves with the policies, procedures, and guidelines established by this manual, and will be responsible for executing these requirements that are pertinent to their
- respective assignments.
R. K. Gary Executive Vice President and General Manager, TUGC0 i
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- f. 3i THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS I Certificate of Accreditation t
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i Number OWN - 120 This is to accredit t
TEXAS IRILITIES GENERATING COMPANY l 2001 BRYAN TOWER I DALLAS. TEXAS 75201 -
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as authorized to compleie FORM N-3 OWNERS DATA of The American Society of Mechanical Engineers for filing j with the enforcement authority having jurisdication at:
- COMANCHE PEAK STEAM ELFCTRIC STATION,~ UNIT el l GLEN ROSE, TEXAS I
( l in accordance with the applicable rules of the Boiler and Pressure Vessel Code of The American Society of Mechanical Engineers. The accredita-I tion granted by this certificate is subject to the provisions of the i
agreement set forth in the application. The System for which Form N-3 was signed shall have been built strictly in accordance with the provisions -
of the Boiler and Pressure Vessel Code of The American Society of l
, Mechanical Engineers.
l i THIS ACCREDITATION expires on MAY 26. 1985 l Authori:edon MAY 26. 1976
( RENFh'ED- APRIL 9, 1979 & APRIL 9, 1982 for t !
THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS by the BOILER AND PRESSURE VESSEL COMMITTEE l
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( {i Director, Accreditation
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f Fg s THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS t Certificate of Accreditation l
Number OWN 121 -
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I TEXAS UTILITIES GENFRATING COMPANY I 2001 BRYAN TOWER DALLAS, TEXAS 75201 a
l as authorized to complete FORM N-3 OWNERS DATA of l The American Society of Mechanical Engineers for filing u
with the enforcement authority having jurisdication at:
I
, COMANCHE PEAK STEAM ELECTRIC STATION. UNIT #2 GLEN ROSE, TEXAS
( in accordance with the applicable rules of the Boiler and Pressure Vessel Code of The American Society of Mechanical Engineers. The accredita-tion granted by this certificate is subject to the provisions of the I agreement set forth in the app!ication. The System for which Form N-3 was signed shall have been built strictly in accordance with the provisions of the Boiler and Pressure Vessel Code of The American Society of Mechanical Engineers.
THIS ACCREDITATIONexpireson "Av '6- Toa5 Authori:ed on MAY 26. 1976 foy, RENERED: APRIL 9, 1979 & APRIL 9, 1982 THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS by the BOILER AND PRESSURE VESSEL COMMITTEE
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Chairman
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Transmittal-84-01 l
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TUGC0/TUSI 'I CPSES 00ALI(Y ASSURANCE PLAN l
. APPROVAL AND IN5IRUCTIONS.
Approved h Manager,-Qualify Assurance th Date: 1/26/84 Page: 1 of 1 REMOVE AND DESTROY INSERT IN MANUAL Approval and Instructions Approval and Instructions dated 11/18/83 dated 1/26/84 List of Effective pages, Rev. 11 List of Effective Pages, Rev. 12 Section 1.1 Section 1.1 Page 2 of 3, Rev. 6 Page 2 of 3, Rev. 7 -
i
COMANCHE FEAN STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN
, ,4.%g SECTION:
N/A i -
TABLE OF CONTENTS
- 8/19/80
- y REVISION
PAGE OF i 2 Title STATEMENT OF AUTHORITY CERTIFICATES OF AUTHORIZATION APPROVAL AND INSTRUCTIONS TABLE OF CONTENTS LIST OF EFFECTIVE PAGES 4
TERMS AND ABBREVIATIONS 1
l 1.0 Organization i
1.1 Quality Assurance Division 1.2 Project Management -
2.0 Quality Assurance Plan i 2.1 Control of the Quality Assurance Plan
(
, 3.0 Design Control L 4.0 Procurement Document Control 5.0 Instructions, Procecures and Drawings 6.0 Document Control ,
7.0 Control of Purcnasea Items And Services 8.0 Identification And Control of items 9.0 Control of Construction Processes !
10.0 Examinations, Tests, ano Inspections 11.0 Test Control 12.0 Control of Measuring & Test Equipment 13.0 Handling, Storage, and Preservation 14.0 Examination or Test Status j
15.0 Nonconforming items f 16.0 Corrective Action
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COMANChiE MAK STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN f-~,% SECTION: N/A
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s TABLE OF CONTENTS DATE: 2/13/80
' 'g ( ,
REVISION : 1 of j PAGE 2 OF 2 17.0 Quality Assurance Records 17.1 Site Construction Quality Control Records 17.2 Record Retention and Storage :
18.0 Audits
, 19.0 Authorized Nuclear inspector i
20.0 Preservice inspection Program i i
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COMANCHE FEAK SiEAM ELECTRIC STAT /CN
, QUALITY ASSURANCE PLAN SECTION: N/A
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rj DATE: 1/26/84 List of Effective Pages REVISION: 12 -
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l PAGE 1 OF 1 Section Page Revision Statement of Authority 5/21/81 ASME Certificate of Accreditation OWN-120 Expiring 5/26/55 ASME Certificate of Accreditation 0WN-121 Expiring 5/26/85 Approval and Instructions 1 1/26/84
! Tables of Contents 1 5 Tables of Contents 2 1
- List of Effective pages 1 10 Terms and Abbreviations 1 3 Terms and Abbreviations 2 3 Terms and Abbreviations 3 3
! 1.0 1 4 1.0 2 2 1.1 1 3 l
1.1 2 7 1.1 3 0 1.2 1 6
{ Figure 1.1 1 8 Figure 1.2 1 8 2.0 1 0 2.1 1 3 3.0 1 2 4.0 1 1 4.0 2 3 5.0 1 -
2 6.0 1 2 7.0 1 3 8.0 1 0 9.0 1 4 10.0 1 0 11.0 1 0 12.0 1 1 13.0 1 0 14.0 1 0 15.0 2 0 16.0 1 0 17.0 1 2 17.1 1 0 17,.2 1 1 l
18.0 1 1 19.0 1 2 20.0 1 2
, , 20.0 2 1
COMANCHE FEAK STEAM ELECTRIC STAT /CN l QUALITY ASSURANCE PLAN SECTION: N/A i [,
% Terms And Abbreviations DATE: 8/19/80
~
,g#[ REVISION: 3 1 1 3 1
PAGE OF l Terms and Abbreviations A description of the terms and abbreviations used in this manual is provided below to clarify the intended meaning.
I I bid evaluat' ion - A fomal evaluation of proposals received in response to an inquiry to detemine the vendor to whom the purchase order will be awarded.
l closed items - Refers to a completed action or activity which has been signed
. off (approved) and dated.
- Code - The ASME Boiler and Pressure Vessel Code,Section III, XI.
corrective action - Any appropriate measure applied for the purpose of making unlikely the possibility of a recurrence of the initial discrepancy.
Examples are:
- a. Revision of procedures, practices, and/or design documents,
- b. Increased surveillance of procedures and practices,
- c. Work stoppage until problem situation is alleviated,
! d. Special training of personnel,
- e. Reassignment of personnel. '
, design review - Design review means the critical review of the design output I sucn as a crawing, calculation, analysis or specification, in order to provide further assurance that the actions leading to the output have been satisfactorily perfomed and the infomation included in the design output is correct and complete.
inouiry - A transmittal to a proposed vendor of the procurement package for a component, system, or structure, including drawings, specifications, quality assurance provisions and other requirements seeking bids.
insoection - The act of verifying the confomance of a material, structure, component or system to its requirements. Inspection is inclusive of examination and test.
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COMANCHE FEAK STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN g SECTiON 8 N/A
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'. r Terms And Abbreviations DATE: 3/31/83 s
\ [ g$ REVISION: 3 -
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nonpermanent quality assurance records - Those records which do not meet any of the criteria for permanent records.
nonconformance - A discrepancy, shortcoming, insufficiency or defect in !
characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate. Examples are:
1 j a. Physical defects,
- b. Failure to meet acceptance criteria, j c. Test failures, l
! d. Incorrect or. inadequate documentation,
- e. Deviations from prescribed processing, inspection or test procedures.
open items - Refers to an incomplete action.
j overall resconsibility for construction - The responsibility assumed by an organization for conformance to the project requirements when several organizations are involved. This includes the ov'erall responsibility for structural integrity and design when a component is contracted to a qualified organization. Assumption of overall responsibility by i TUGC0/TUSI does not negate the responsibility of a contractor performing design, procurement, or manufacturing functions for compliance with project requirements, nor does it relieve the Professional Engineer who certifies Design Specifications or Stress Reports of his responsibility.
Assumption of overall responsibility by TUGC0/TUSI implies responsibility for code andor contractual regulatory compliance and is not to be construed as involving legal liabilities.
permanent ouality assurance records - Permanent records are those which
) meet one or more of tne following criteria:
I a.
Those which would be of significant value in demonstrating capability for proper functioning of saftty related items.
b Those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying the item.
c.
Those which would be of significant value in determining the cause of an accident or malfunction of an item.
t l
( d.
Those which provide required baseline data for inservice inspection.
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COMANCHE FEAK S7EAM ELECTRIC STA77CN
\
j QUALITY ASSURANCE PLAN SECTION: il/A
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%s Terms And Abbreviations DATE: 3/31/83
\ h REVISION: 3 l c#'
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PAGE 3 0F 3 l
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pre-award evaluations - a review perfomed to determine a vendor's
, capability to supply this equipment or service in compliance with necessary quality assurance requirements. This may involve review of a l , vendor's history and experience or performance of actual survey at the i vendor's facility.
procedure - A document which describes or specifies how an activity is to l be performed.
i procurement documents - Those documents, including bidders lists, specifications, inquiries, proposals, and purcnase orcers, associated with procurement activities.
prooosal - An offering made by a prospective vendor in response to an inquiry. Propos'als will include a description of the vendor's quality assurance program.
purchasa order (or contract) - A contractually binding document that
(\ identifies and defines requirements which items or service.s must meet in order to be considered acceptable by the purchaser.
l quality assurance records - Those records 5tiich furnish documentary evidence of tne quality of items and of activities affecting quality.
recortable deficiencies - tionconformances .shich constitute a deficiency ss defined in 10CFR Part 50.55(e).
I revision - (to the CPSES QA Plan) - Any significant change to the QA Plan raanual.
specification - A concise statement of a set of requirements to be satisfieo by a product, a material or process indicating wherever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied.
vendors list - A listing of approved vendors that are considered qualified (
and are eligible to supply safety related equipment or services.
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COMANCM FEAK STEAM ELECTRIC STAT /CN j QUAUTY ASSURANCE PLAN
[;,%, SECTION: 1.0
( ..
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Organization and Resoonsibilities DATE: 3/31/83 i
s(
~ REVISION: 4 -
PAGE 1 ,0F 2
-e 1.0 Organization and Resoonsibilities The general responsibilities of the primary organizations involved in the design and construction of CPSES are described below:
I
- 1. Texas Utilities Generating Co. (TUGCO) has overall responsibility for design, procurement, construction and overall quality assurance.
Texas Utilities Services, Inc. (TUSI), as the Texas Utilities Company (TV) engineering service organization, has been designated by TUGC0 to have responsibility for engineering, construction and I procurement activities for CPSES. TUSI performs design and design verification activities on selected contracts. The design and design verification function on most contracts has been delegated to Gibbs & Hill, Westinghouse, and other contractors as required. TUSI performs a second level design review of these activities to monitor !
the performance of the contractors. TUGC0 audits TUSI and '
contractors to verify compliance with the requirements of the f TUGC0/TUSI Quality Assurance Plan and project requirements.
(
- 2. Westinghouse designs, engineers,, manufactures, and delivers the flSSS -
and furnisnes drawings and other related services. Westingnouse provides the QA program for the ilSSS structures, systems, and components.
- 3. Gibbs & Hill provides engineering services and design and procurement support services for the balance of plant, as requested by T'JS I . This includes providing conceptual design, design drawings l and specifications. Gibbs and Hill provides the QA program for QA activities within the Gibbs and Hill scope of work. The G5H QA program conforms with the overall TUGC0 QA program.
- 4. Brown & Root provides construction services to construct CPSES from l plans ano specifications provided by Westinghouse and Gibbs & Hill.
These services include receiving, handling, storage of material, erection, installation, procurement of materials as designated by TbSI, and administration of subcontracts to B&R. Brown & Root provides the QA program for ASME Code work and provides QA functions as requested by the TUGC0 QA Mar.ager. The B&R QA Program conforms with the overall TUGC0 QA program.
Figure 1.2 defines the interfaces that exist within and between the organizations participating in the design, engineering, procurement, and construction activities at CPSES.
f
l COMANCPE PEAK $7EAM ELECTRIC STAT /CN.
I g QUALITY ASSURANCE PLAN SECTION' 1.0 l I y --
4,
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Organization and Responsibilities DATE: 8/19/80 C
l j ~.g(s REVISION : 2 PAGE 2 OF 2 The TUGC0/TUSI organizations participating in the design and construction !
phase of nuclear power plants are shown in Figure 1.1. This chart 1 illustrates the structure and lines of reporting for each organization.
These are listed below and are described in the corresponding sections which follow:
1.1 Quality Assurance Division 1.2 Project Management I
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COMANCHE FEAK S7EAM ELECTRIC STAT /CN Aug QUALITY ASSURANCE PLAN SECTION: 1,1
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$ qgs j Quality Assurance Division DATE: 11/18/83 REVISION: 8 j
Mc/ PAGE 1 0F 3 1.1 Quality Assurance Division i
The Quality Assurance Division is responsible for the development,
- assurance of implementation, management, and surveillance of the j
i Quality Assurance Plan for TUGC0/TUSI nuclear power plant projects.
TUGCC retains responsibility for those portions of the QA Plan
' delegated to others. In these cases, the TUGC0 QA Division shall perform initial evaluation and subsequent audits of the contractor's QA programs.
The QA Division is independent from those TUGC0/TUSI organizations responsible for design, procurement, engineering, construction, and operation (see Figure 1.1). With quality assurance as the sole function of this organization, the TUGC0 Quality Assurance Tianager and his staff are. free from the responsibilities of cost and scheduling.
The QA Division has the freedom and authority to: a) identify quality problens; b) initiate corrective action; c) verify implementation of corrective action; and, d) control further processing, delivery, or 7 installation of a nonconfonning iten, deficiency, or unsatisfactory
( condition until proper disposition has been made.
The Quality Assurance fianager reports to the Vice President, Nuclear.
This' reporting arrangement assures that the QA ;4anager and his staff have direct access to the levels of management necessary to assure effective implementation of the QA Plan. The Quality Assurance :ianager has ultimate responsibility for the effectiveness of all quality
' related activities on the CPSES project and has "stop work" authority in the engineering, procurement, and construction phases of the project. Reporting directly to the Quality Assurance fianager are the:
e Supervisor - Quality Assurance Services e Supervisor - Vendor Compliance i
e Engineer - Special Projects l e Site QA Supervisor l The duties, responsibilities, and authorities of each Supervisor are described below. *
- a. Supervisor - Quality Assurance Services l 1 e
' Performs audits of TUGC0/TUSI, prime contractors, and vendors to assure that safety related work is perfonned in compliance with requirements.
e k Evaluates quality assurance programs, identifies weaknesses, and determines the adequacy of corrective action submitted by prime contractors and vendors.
I I
CCMANCHE PEAK STEAM ELECTRIC STAT /CN
$ QUALITY ASSURANCE PLAN
[--
g SECTION: 1.1 DATE: 1/26/84
~
3 Quality Assurance Division s
., , REVISION: 7 .
PAGE 2 OF . 3 I e Develops and maintains the CPSES QA Plan and the quality assurance, portion of the safety analysis report.
e Verifies and documents training of TUGCo quality assurance
- personnel.
s Assists others in the development of arograms and procedures.
a Reviews technical codes and standards for imoact on the Quality Assurance Plans and recommenos apcropriate changes.
e Prepares formal responses to items reported under 10 CFR 50.55(e) .
i '
- b. Supervisor - Vendor Compliance
{ i e Performs surveillance of hardware during inanufacture.
s Performs final release inspections of hardware before final shipnent is made.
- c. Supervisor - Quality Engineering e
Audits for compiiance with CPSES Technical Specifications.
i i s Reviews regulatory, industry, and project documents for QA impact and takes appropriate actions.
e Provides statistical expertise for design of acceptance sampling programs and evaluation of historical data.
i e
Idenfies QA criteria for purchasing activities.
e Reviews design engineering packages for major plant modifications.
e Assists QA Services on technical audits, e
Performs special projects as assigned by the Manager,
-Quality Assurance.
( e Provides technical / engineering support to Supervisor, Quality Assurance Services; Supervisor, Vendor Compliance; and Site QA Supervisor.
1 1
. COMANCHE PEAK STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN SECTION:
A,ug, 1.1 f
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Quality Assurance Division DATE: 10/18/83 0
REVISION:
i % cf PAGE 3 OF 3
- d. Site QA Supervisor e Supervises, cooroinates and assures implementation of the Quality Assurance and Quality Control Functions at the CPSES site.
e Assists the Manager. Quality Assurance in the development and imolementation of the Conanche Peak Quality Assurance Plan as
- .it relates to site construction and site engineering activities.
e Develops procedures and instructions necessary to assure implementation of QA and QC functions at the CPSES site.
s Is delegated the authority to stop work on site if required for resolution of quality related problems.
( 1 s Indoctrinates and trains site QA and QC personnel in i accordance with applicable codes and standards, j
e Assists the Manager, Quality Assurance in evaluating the overall effectiveness of the site Quality Assurance and Quality Control functions.
s Coordinates Quality Assurance and Quality Control functions with responsible :nanagement at the CPSES site.
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COMANCM FEAK STEAM ELECTRIC STAT /QV j QUALITY ASSURANCE PLAN e-g SECTION: 1.2 g' \
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{ DATE: 10/18/83 e r Project Management S 6 .
j FAGE 1 OF 1 1.2 Project Management The Vice President and Project General Manager is responsible for the
! coordination and control of the engineering, procurement, and e
- construction activities of the Comanche Peak Steam Electric Station Project. The Vice President and Project General Manager retains resconsibility for cost and schedule and is charged with insuring that TUSI, prime contractort, subcontractors, and vendors meet
' quality requirements during design and construction. The Vice President and Project General Manager reports to the TUSI Executive Vice-President.
The Vice President and Project General Manager has the authority to "stop work". in the engineering, procurement, and construction phases of the project.
The Vice President and Project General Manager reviews the status of the project with the TUSI Executive Vice-President, on a regular
{ i basis.
1.2.1 Assistant Project General Manager (TUSI)
The Assistant Project General : tanager is responsible for the Comanche peak Steam Electric Station design, engineering and procurement.
These activities are normally delegated to Gibbs & Hill, Inc., {\;Vg
'Jestinghouse and other contractors / vendors.
TUSI however retains overall responsibility for these activities and performs design @
functions as necessary. The Comanche Peak Assistant Project General p.>
flanager reports to the Vice President and Project General Manager.
His specific duties and respons ilities are as follows:
o Provides technical direction and administra~tive guidance to '
Comanche Peak Project representatives assigned to his group.
e Provides the interface between engineering, procurement and ccnstruction.
e Monitors the performance of the design, procurement and construction organizations as to functional and contractural intent.
e i Reviews and approves appropriate procurement documents that provide necessary services, equipment and material.
( e Has authority to "stop work" in the engineering, procurement and construction phases of the Comanche Peak Project.
L i
e i Is designated to act for the Comanche Peak Steam Electric Station Vice President and PG" in his absence.
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! COPIANCHE PEAK STEAM ELECTRIC STATION .
DNITS I and 2 I TUGCO/TUSI IDE OFFICE AND CPSES FIELD ORGANIZAil0N ,
- , for otlier than ASME Section 111 J',",dlu5l
- s. i FIGURE 1.1 Division I activity only Rev; 8 l 10/18/83 1U58 teetutive itEtt lettellve tite President vice President &
(vice President General Manager laIUGC0l
. I
- I Vice President.
- Iluclear i
I Health Manager Superviser Menaler Physics livtleer Ingineering & quality Supervisor Operettees Aemia. Services Asserence i'
ll01110 5" " h -
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ll4" Services lTeld
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I Vlte President
& Project General . Super
,,, ,viser .
) M*"*9
Compliente i
i lr l ! I I knager Superviser Asst. Project Plant Operettens Ovality -
Manager l I Aeninistrativt Engineerlag Iloclear & teatrol General Mgr.
Services F'""'r Menege g,,,,,g,,,
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l l l l . - SIle 04 Procure *eng Start.p . Supervisor Construttlen I"9 '
Manager gennager Menager 1
! He Project GA Menager l '
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COMANCHE FEAK STEAM ELECTRIC STAT /CN El QUALITY ASSURANCE PLAN gug, SECTION: 2.0 f; Quality Assurance Plan DATE' 7/1/78
- REVISION: 0 )
l PAGE 1 OF 1 2.0 Quality Assurance Plan '-
This manual describes the quality assurance system applicable to safety related design, procurement, and construction activities at the Comanche Peak Steam Electric Station. The Quality Assurance Plan documented by this manual and implementing procedures encompasses the activities performed by i TUGC0/TUSI, and those activities performed by prime contractors, subcontractors, and vendors. The Plan provides for accomplishing activities under suitably controlled conditions such as appropriate equipment, suitable environmental conditions, and assurance that prerequisites for an activity i
have been satisfied. The activities shall be documented by and accomplished
, in accordance with approved procedures, instructions, or drawings. A program has b.een established for quality assurance indoctrination and
, training which assures that the required level of personnel competence is achieved and skill is maintained in the perfonnance of quality related
{ activities. 14anagers ano supervisors are responsible for training to assure t
that personnel achieve and maintain the proficiency and qualifications l required for the quality-related activities performed.
C j
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e CCMANCHE FEAK STEAM ELECTRIC STATION QUALITY ASSURANCE PLAN SECTION: 2.1
{ ;
- g'%
Control of the Quality Assurance Plan DATE:10/18/83 r} VISION: 3 -
' J
- PAGE 1 OF 1 2.1 Control of the Ouality Assurance Plan 1
l The Manager, Quality Assurance shall be responsible for the l
preparation, revision, review, approval, and distribution of this Quality Assurance Plan. Requests for revisions to this manual shall be directed to the Manager, Quality Assurance. To assure the timely incorporation of proposed revisions, the cognizant managers and supervisors are responsible for requesting necessary revisions to the
, manual as the need is identified.
Distribution of this manual and subsequent revisions shall be controlled in accordance with approved procedures. Receipt of the manual or revisions shall be acknowledged by the holder of the manual.
Appropriate followup actions will be taken as necessary to assure acknowledgement has been received by the Manager, Quality Assurance. [,
i l The Authorized Inspection Agency shall review and accept proposed revisions to the CPSES QA Plan prior to their formal issuance.
( Should a holder's requirement for a manual cease due to ' transfer, i
retirement, tennination, etc., he shall return his copy promptly to the Manager, Quality Assurance.
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COMANCM PEAK STEAM El.ECTRIC STAT /CN QUALITY ASSURANCE PLAN f..%*
SECTION:
! Design Control 0/10/79
{ DATE:
5
,h
- - REVISION: 2
- PAGE OF j 3.0 Design Control l The design control process for CPSES begins with Gibbs & Hill, as Architect - Engineer, Westinghouse, as NSSS supplier and TUSI as Texas l Utilities Company's engineering service organization. Overall
! responsibility for construction however, remains with TUGC0/TUSI. The j , design control process is an ongoing function which includes design j criteria, design review, and design change. This process is carried out in accordance with established procedures.
' 3.0.1 Design Criteria The preparation, review, approval, and certification of design specifications are normally contracted to Gibbs & Hill and Westinghouse.
TUSI performs design and design verification activities on selected I
contracts. To the extent applicable, the design criteria will be i
consistent with that specified in the license application and will utilize the requirements of recognized codes, standards, and practices. The
( responsible design organization translates these design specifications l
into appropriate instructions, procedures, drawings, or specifications.
This function includes design' interface control as well as the generation, review, checking, approval and revision of design.and construction-l specifications, and design drawings.
, 3.0.2 Design Review l The responsible design organization reviews respective designs for confomance to design concepts. licensing design criteria, and regulatory criteria. The design reviews are performed by individuals or groups other than those who performed the original design. Changes to design specifications or documents are reviewed and approved by the same individual or group responsible for original review and approval.
[
3.0.3 Design Change l
Changes to the design are documented, reviewed, and approved by the original designers commensurate with the controls applied to the original design. These controls extend to the disposition of field changes and nonconformances. Approved changes are incorporated into or identified on
! the original design document.
The TUGC0 QA Division assures that the design process including design changes is performed in accordance with approved procedures. Gibbs & Hill and Westinghouse quality assurance organizations audit their respective design organizations to ensure compliance to approved procedures and
( instructions.
1
' COMANCHE FEAK STEAM ELECTMC STAT /CN 4 QUALITY ASSURANCE PLAN j $ SECTION: 4.0 j
( pK
- c. r Procurement Document Control DATE' 5/21/81 t( / REVISION: 1 -
c#'
PAGE 1 0F 2 l
4.0 ' Procurement Document Control Four principal organizations will be involved with the procurement of items anti certicas related to nuclear safety during design and l construction. These crganizations are:
'TUGC0/TUSI
'Gibbs 3 Fill ( Arcnitect-Encineer) i
- Westinghouse (Uuclear Steam Supply System Venoor)
- Brown & Root (Constructor)
TUGCO/TUSI retains overall responsiblity for assuring the adequacy of the procurement program.
Procedures shall identify the responsibilities and actions required of the
( organizations originating, reviewing, approving, and controlling procurement documents. These procedures shall require the procurement documents to specify as appropriate:
l i *The scope of work to be performed.
- Use of approved vendors.
,
- Technical requirements (by specifying or referencing) which shall J
I include the revision numbers of applicable drawings, specifications, procedures, instructions, codes, or regulations, and provide for identification of applicable test, inspection and acceptance requirements, or other special instructions.
- 0A Program requirements to be imposed on contractors which shall include the applicable portions of 10 CFR 50, Appendix B, and NA 4000 l or NA 3700.
! i l *Right of access which provides, as appropriate, for access to contractor facilities and records for inspection or audit by TUGC0 or its designated representative, and to access for events such as witness and hold points.
- The documentation required to be prepared, maintained, and submitted to. TUGC0/TUSI or its representative for review, approval, or j historical record. The time of submittal of this documentation and
(' '
{ the retention and disposition of quality assurance records which will not be delivered to TUGC0/TUSI shall be included.
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COMANCHE MAK 'S7EAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN SECTION: 4.0 1
+t*..
( .
, Procurement Document Control DATE 5/21/81
! i
~~ \ REVISION: 3
% ce 2 l PAGE OF 2 i
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- Provision for extending applicable requirements of the procurement '
l 1
documents to lower tier subcontractors and suppliers, including
! purchaser's access to facilities and records.
l l Procurement documents shall be reviewed to assure that the appropriate provisions mentioned above are included.
Changes to procurement documents, whether initf ated by TUGCO/TUSI or their representative, shall be subjected to the same decree of control as that utilized in the preparation of- the original document.
- The procurement organization shall verify that the procurement document has been reviewed and approved, and that Quality Assurance has approved the purchase order for safety related material, equipment or services
- prior to issuing.
l 4.0.1 Inquiry Preparation
( l The originating organization shall prepare an inquiry package for items to be procured using approved specifications and/or drawings, The inquiry i package shall contain applicable drawings and/or specifications. The specific issue dates and applicable addenda shall'be either attached or referenced.
The inquiry shall contain the minimum information specified by procedures and shall include or reference applicable quality requirements.
4.0.2 Bidder Selection Upon receipt of a properly authorized inquiry, the purchasing organization transmits the inquiry to bidders.
4.0.3 Supplier Selection l
The purchasing organization is responsible for the evaluation of proposals on bids originated. Proposals requiring engineering review shall be transmitted for evaluation as defined by applicable procedures. When a vendor proposal includes exceptions to quality requirements, it shall be submitted for review and evaluation.
4.0.4 Purchase Order The purchasing organization prepares and issues a purchase order after evaluation of commercial terms and considerations, and obtaining technical
( evaluation when required. A purchase order for safety related items shall not be issued to a vendor unless Quality Assurance has evaluated and accepted the purchase order. The QA reviewer will detemine whether 0A provisions are adequate and will determine any necessary pre-award evaluations consistent with the vendors activities in supplying equipment,
, materials or services.
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COMANCHE FEAK STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN
% SECTION: 5.0
(- ~
- * ,k
, Instructions, Procedures, and Drawings DATE' 5/21/81 a
' xf / . REVISION : 2 -
f j i PAGE 1 OF 1 I
j 5.0 Instructions, Procedures, and Drawings
! l The quality assurance actions accomplished under the CPSES QA Plan as
( , described throughout this manual shall be delineated in documented i instructions, procedures, drawings, specifications, checklists or manuals, as appropriate. Changes shall be reviewed for their effect on present instructions, procedures, and/or drawings. The Architect-Engineer, other contractors, or a TUGC0/TUSI organization may prepare, revise, review and internally approve documents associated with the cuality related activities 1 they will perform. These activities shall also he conducted in accordance with approved procedures.
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COMANCW PEAK STEAM ELECTRIC STAT /CN QUALITY ASSURANCE PLAN g SECTION: 6a r 4
_(, gs , Document Control DATE' 3/31/83 i
~ .h REVISION : 2
' PAGE 1 0F 1 l .
l l 6.0 Document Control i J i
The distribution and control of documents shall be accomplished as described in the applicable procedures. Controlled documents shall
' be reviewed for adequacy and approved for release by authorized personnel . These documents shall be distributed to and used at the location where the prescribed activity is perfomed.
Procedures require that each controlled document be identified on a distribution list showing all pertinent infomation regarding the 1
document such as the title, revision number, and the individual or organization to which the document has been distributed. A document
- receipt or manual insertion system shall be used to assure that initial issue and subsequent revisions are received by the
- controlled document holder.
i
< Changes to documents shall be reviewed and approved by the same k <
organization responsible for the original document or by the owner's designee. Distribution and control of revised documents shall be in the same manner as the original document except that superseded documents shall either be destroyed or clearly marked to avoid inadvertent use.
Gibbs & Hill, Westinghouse, and Brown & Root are responsible for j implementing quality assurance programs that ensure appropriate l
- documents are controlled and that changes required as a result of comments, nonconformances, or engineering work are incorporated into l revised documents. The quality assurance programs will be audited '
by TUGC0 QA to ensure conformance to these requirements. C-a l
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CCMANCHE FEAN STEAM ELECTRIC STAT /CN
. QUALITY ASSURANCE PLAN SECTION: 7.0
& ~
{ , pp% Control of Purchased Items and' Services DATE: 3/31/83 REVISION: 3 ,
i PAGE 1 0F 1 1
l 7.0 Control of Purchased Items and Services l
! Procurement activities associated with items procured off-site for installation are performed by TUGC0/TUSI or are contracted to Gibbs 3 l Hill, Westinghouse, or Brown & Root who are evaluated and qualified by TUGCO. Procurement documents are reviewed, approved, and controlled as described in Section 4.0. Receipt inspection of safety related items on site is perfomed in accordance with written procedures and checxlists.
' Procurement. source evaluation and selecticn measures include the
' selectic 1 of the Nuclear Steam Supply System Supplier, the Architect-Engineer, and the Constructor. Requirements for source evaluation and approval of vendors are specified in TUGC0 procedures.
( l Periodic evaluations are conducted to assure that the vendor's quality performance continues to warrant retention of his approved status.
This evaluation program includes provisions for audit, surveillance, source inspection, and receipt inspection as necessary.
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COMANCHE FEAK STEAM ELECTn/C STAT /CN
- QUALITY ASSURANCE PLAN SECTION
- 8.0 f - %,
p Identification & Control of Items DATE:
7/1/73
{ REVISION : 0 1
PAGE 10F 1
)
8.0 Identification & Control of Items "
Appropriate requirements have been established to assure continuous and accurate identification and control of safety-related items and that the use of incorrect or defective items is prevented.
1 Procedures establish responsibilities and requirements for the
- identification and control of items. These proceaures provide that
' Requirements for traceability to appropriate documentation sucn as: procurement documents, manufacturing documents, drawings, specifications, inspection and test records, and nonconformance reports.
- Controls to assure that the correct identification of an item is
- verified and documented prior to release for fabrication, assemoly, j shipping or installation.
l ' Requirements which assure that the method or location of markings
{ { do not affect the function or quality of an item.
- Establishment of identification requirements by specifications, 1
drawings, procurement documents, instructions, or procedures during initial planning.
- Transfer of identification prior to division of an item to maintain identity.
Suppliers are required to establish and implement a documented program for inspecting, marking,
- identifying, and documenting items prior to use or storage.
Verification that items received on site meet the applicable identification requirements is accomplished during release or receipt inspection. '
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COMANCS:E PEAK STEAM ELECTRIC STAT /CN l
- i QUALITY ASSURANCE PLAN SECTION ' 9.'O l :
( ; .dsrN Q.
Control of Construction Processes DATE:5/21/81 l
g 1f g' REVISION: 4 .
l l
I PAGE 1 0F 1 9.0 Control of Construction Processes l Written procedures shall be prepared' to assure that construction processes !
including welding, heat treating, coating applications, nondestructive l examination, and concrete batching are accomplished by qualified personnel l
! using qualified procedures in accordance with applicable codes, standards, specifications, and other special requirements. These procedures describe the operations performed, the sequence of operations, the characteristics involved, the limits n' *Mse characteristics, process controls, measuring and test equipment utii bad, and documentation requirements.
Written procedures are also required to cover training, examination, qualification, certification, and verification of personnel as well as the
- maintenance of all required personnel records.
Procedures for control of construction processes are subject to review by TUGC0 QA on a case basis.
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COMANCHE FEAK STEAM ELECTRIC STAT /CN i ,
l QUALITY ASSURANCE PLAN g3 SECTION . 10.0 l
Examinations, Tests, and Inspections DATE: 7/1/78
( !
. .fi
'(
s REVISION : 0 t
l PAGE 1 OF 1 10.0 Examinations, Tests, and Inspections -
Examinations, tests, and inspections are performed at specific stages in the manufacturing, fabrication and installation activities to ensure that items meet the applicable specification, code, and regulatory i
requirements.
Planned, written procedures for in-process and final inspection are
! utilized by the prime contractors. TUGC0/TUSI reserves the right 'to review, disapprove, and perform surveillance or audits of the implementing procedures used by these organizations. TUGC0 uses the following criteria 1 in evaluating the proposed inspection methods:
, *0uties and responsibilities of personnel performing inspection are -
clearly estaolished.
' Qualifications of personnel performing inspections are commensurate with their duties and responsibilities.
{ .
- Documentation methods for inspection activities of each group are established (e.g., inspection forms, reports).
' Documentation control systems for identifying and distributing inspection documents are defined.
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- Planning of inspection sequence activities include the type of
! characteristics to be measured, the methods of examination, and the criteria.
{
l Sufficient inspections are conducted to verify conformance in areas rer.dered inaccessable by further processing. Process monitoring is utilized in lieu of inspection in those cases where inspection is impossible, disadvantageous, or destructive. Where required for adequate control, a combination of inspection and process monitoring is employed.
1 Hold points are established and enforced as required. TUGC0 and/or its representatives verifies by review of inspection reports, visits to vendor's' shops, and onsite surveillance that inspections are being performed and documented by personnel in accordance with approved procedures.
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1 COMANCHE FEAK STEAM ELECTRIC STAT /CN r
j
! QUALITY ASSURANCE PLAN SECTION:
l
+ps u g ,g
._, 11.0 g .g. Test Control DATE: 7/1/78
) ( REVISION : 0
%c M PAGE 10F 1 11.0 Test Control -
Test requirements and acceptance criteria are provided by the organization responsible for the specification of the item under test, unless otherwise designated. Such testing is performed in accordance with test procedures which incorporate or reference the test requirements and acceptance limits-l contained in the applicable design documents.
i l Test procedures include, as a minimum, the following:
i
- Test prerequisites such as:
I
- a. calibrated instrumentation
- b. trained, qualified, and licensed or certified personnel i c. preparation, condition, or completeness of item to be tested l d. suitable and controlled environmental conditions
- e. safety considerations
- Instructions for the testing method used; ,
- Required test equipment and instrumentation; l
- Test requirements and acceptance criteria;
- Hold, witness, inspection and data collection points; ,
- Methods for documenting or recording test data and results;
- Provisions for data collection.
The documented test results are evaluated against the predetermined acceptance criteria by authorized personnel. The acceptance status of the test is documented in accordance with Section 14.0. Discrepancies noted during the evaluation shall be documented and dispositioned in accordance with Section 15.0.
s
f, aad B.ECTMC STAT /CN
(
q QUALITY ASSURANCE f*LAN SECTION:
3 4' [ [3, Iontrol of Measuring & Test Equipment
~
DATE:
12.0 i
cv 5/21/81 REVISION: '
( -
1 -
.2.0 t
( PAGE 1 OF 1 Control of Measuring & Testent Equipm
.; l equipment shall have writOrganizations performing q ,
calibration, maintenance, and control. ten procedures ent to assure pro determination of which equipment is t t
- The procedures include a documentation of tests andthe calibration necessary for specific eo be controlle measure ments. quipment, and assurance of Measuring and test equipment is maintained showing marked the calibration or traceable to fcalibraticn records so calibration checking is necessary A schedule requency of calibration is of the equipment.
\ reissued until after satisfactory calib
, the equipment is returnedWhen and not 1
Measuring and test equipment is ration checking.
standards or accepted values of naturalcalibra elational standards exist physical constants.p to nationally re If no Measuring a test equipment found t, the basis ented.
for calib j nonconforming item. calibration sticker removed, an be determined Work performed that applicable with therethe discrepa n last te segregated calibration I an ecuipment since i quirements have been met.e considere I l'
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COMANCM FEAK STEAM ELECTn/C STA77CN i QUALITY ASSURANCE PLAN
&j g% SECTION: 13.0
.f'., Handling, Storage, and Preservation DATE:
7/1/73 REVISION : 0 .
PAGE 10F 1
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13.0 Handling, Storage, and Preservation -
The function of delineating special handling, preservation, storage, cleaning, packaging, and shipping requirements, as appropriate, in the design documents or purchase orders is performed by TUGC0/TUSI or is
{ delegated to Gibbs & Hill, Westinghouse, or Brown & Root as described in j Section 4.0.
' 30th TUGC0/TUSI and contractors shall establish and implement written procedures addressing the scope of their functions for cleaning, shipping, storage, packaging, preservation, and handling of safety-related items in accordance with design or procurement documents as appropriate. These procedures shall delineate measures which prevent degrading of an item through damage or deterioration. When necessary for particular items, i
special protective environments such as inert gas atmosphere, specific moisture c'ontent levels, and temperature levels shall be specified and provided.
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COMANCHE FEAK STEAM ELECTn/C STAT /CN QUALITY ASSURANCE PLAN SECTION: 14.0
.g Examination or Test Status DATE: 7/1/78 i j (
REVISION: 0 PAGE 1 OF 1 14.0 Examination or Test Status ~ ~
Procedures have been established to identify the examination or t.est status of safety-related structures, systems, and components. Elements of the status system include a controlled manufacturing and test operation in order to preclude the inadvertent bypassing of processing, inspections or tests, and to provide a positive identification of component status throughout manufacturing, testing, and inspecting by means of tagging, routing cards, stamping, manufacturing or test reports, labeling or other appropriate methods.
l Implementation of the status system extends through the preoperational test program.
Perfomance of this function is delegated as applicable to subcontractors and vendors and is audited by the respective prime contractor to assure that effective measures are being taken.
TUGC0 QA personnel monitor these activities, as applicable, to assure
{ proper and effective implementation.
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COMAACnE FEAK STEAM EL.ECTRIC STAT /CN i
- QUALITY ASSURANCE PLAN f-~ +
SECTICN 15.0
( ,
[ DATES 10/18/83 2
Nonconforming Items REVISION: 3
) PAGE 1 OF 2 15.0 Nonconforming Items The identification, documentation, segregation, and disposition of nonconforming materials, parts, or components, is outlined in written procedures. The measures utilized by contractors, subcontractors, and vendors are subject to review by TUGCO. The procedures, as a minimum:
e prevent inadvertent use or installation.
e require investigation of the nonconforming item, decisions on their disposition, and preparation of adequate reports.
e control forther processing, fabrication, delivery, or installation of items for which disposition is pending.
e
( assure that departures from design specifications and drawing-k req'uirements that are dispositioned "use as is" and " repair" are formally raported to affected organizations and TUGC0/TUSI management.
When required by specific procedures / instructions, items identified as unsatisfactory or incomplete and which can be corrected >within a reasonable period of time may be identified on an inspection report MI and/or deficiency report. A nonconformance report is used to document deficiencies unless another method is prescribed by a specific procedure / instruction.
h, t
Nonconfonnance reports, unsatisfactory inspection reports, and 1 deficiency reports are made available to TUGC0 for evaluation. In addition,11JGC0 QA assures that periodic evaluations of these reports are forwarded to TUGC3 management identifying trends adverse to g!
quali ty. yl
, i TUGC0 audits prime contractors to assure compliance.
In addition to beinn documented on a nonconformance report, inspection report, or deficiency report, items found during design and construction which are reportable under the provisions of 10 CFR )
50.55(e) are reported to the Manager, Quality Assurance or his designee i for reporting to the NRC. A reportable significant deficiency is a deficiency which, were it to have remained uncorrected, could have affected adversely the safety of operation of CpSES, and represents:
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CCMANCHE FEAK STcAM ELECTRIC STAT /CN s
j QUALITY ASSURANCE PLAN SECTION: 15.0
{ p+ --~ %,
Nonconfoming Items DATE: 10/30//0 REVISION: 0 i
' , c{# -
PAGE 20F 2
- a. A significant breakdown in any portion of the quality assurance - -
program; or,
- b. A significant deficiency in final design; or,
- c. A significant deficiency in construction of or significant damage to a structure, system or component; or,
- d. A significant deviation from perfomance specifications.
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1 COMANCHE FEAK STEAM ELECTn/C STAT /CN 9 ~
) QUALITY ASSURANCE PLAN SECTION: 16.0
{ %1 Corrective Action DATE:
7/1/78
[ REVISION: O PAGE 1 OF 1 16.0 Corrective Action ~
Documented measures are used to assure that conditions adverse to quality su:h as failures, malfunctions, deficiencies, and nonconformances, are promptly identified and corrected as soon as practicable, and that appropriate action be taken to correct the cause of the condition. The identification of significant conditions adverse to quality, the cause of the condition, and the corrective action taken is documented and reported
! as required by procedures. Responsibility for performing corrective action is assigned to contractors, apolicable subcontractors, and vendors I
so that each is alert to those conditions adverse to quality within his own area of activity. In the case of s.ignificant conditions adverse to quality, which are reportable to NRC under the provisions of 10 CFR Part 50.55 (e), measures are taken to assure that the cause of the condition is detennined and corrective action is implemented to preclude repetition.
Corrective action procedures require thorough investigation and documentation of significant conditions adverse to quality. The cause and corrective action is reported in writing to the appropriate levels of
{ managemer.t and to the purchaser. The corrective action applied is subject i
to review by TUGC0 and the prime contractor responsible for the original purchase specification. The acceptability of rework or repairs is verified by reinspecting the item as originally inspected and that the
, , reinspection is documented.
The occurrence and magnitude of deficiencies and nonconformances requiring' corrective action are evaluated during surveillance and at hold point l inspection and witnessing. Additionally, these areas are identified for audit purposes.
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COMANCS.E FEAK STEAM ELECTRIC STAT /CN l QUALITY ASSURANCE PLAN 4, SECTION: 17.0 1,
' [- '
1
{ . Quality Assurance Records DATE: 2/18/80 h
cff _ REVISICN : 2 -
PAGE 1 OF 1
~
17.0 Quality Assurance Records l TUGC0/TUSI, Gibbs & Hill, Westinghouse, Brown & Root, and other i
contractors shall prepare, maintain, (and where required, retain) quality assurance records as required. TUGC0/TUSI, Gibbs & Hill, Westinghouse and
{ Brown & Root shall specify permanent and nonpermanent records requirements i
in procurement documents as required by the Code and by the design
- specifications.
' Upon completion of an installation activity, the construction organization I shall transfer construction records to TUGCO. These records will be categorized per a preplanned index and retained at the plant site.
' The Authorized Inspector shall have access to all QA records and documents on file that are required by the Code.
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COMANClE FEAK STEAM ELECTMC STAT /CN P
l QUALITY ASSURANCE PLAN SECTION:
- 17,1
! k~g ug,,%
i
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Site Construction Quality Control Records DATE: 7/1/78 i ( REVISION : o l
l PAGE 10F 1 i .
1 17.1 Site Construction Quality Control Records -- -
Quality Control shall initiate, collect, and temporarily maintain required QC documents. These documents shall be filed and controlled. The Site QA Supervisor is responsible for the implementation of the on-site records control and filing system in accordance with a procedure.
Procecures/ instructions define the records required to be retained, and define the provisions required for suitable protection of records. Upon i
completion of an activity, the documents initiated are reviewed and the completed QA recorcs are then transferred for retention at the plant site.
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COMANCM FEAK STEAM ELECin/C STAT /CN l
QUALITY ASSURANCE PLAN p+ps urge,
--- SECTION: 17.2
'., Record Retention and Storage DATE: 4/16/79
( REVISION : 1
%;&r PAGE 1 0F 1 17.2 Record Retention and Storace 7 Quality Assurance records shall be stored under the conditions and for the period specified by the Code and by procedures. Records received or generated at the plant site shall be transferred to and stored in a records vault. The Site QA Supervisor is responsible for the storage and control of QA records and docuraents received at the records storage vault.
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CCMANChE FEAK STEAM ELECTn/C STAT /CN QUALITY ASSURANCE PLAN 1
[_. Audits SECTION: 18.0 DATE 5/21/81
{ s M.cey REVISION: 1 -
?
PAGE 1 0F 1 18.0 Audits l TUGC0 and its prime contractors perform planned and periodic audits, to verify compliance with all aspects of their quality assurance program and
, to determine the effectiveness of the program. TUGC0 audits the prime contractors, TUGC0/TUSI internal activities,- suppliers and vendors as necessary to provide an objective evaluation of the effectiveness of their programs, to determine that their prograins are in compliance with established requirements, methods and procedures, to detemine quality progress, and to verify implementation of corrective action commitments.
The auditing system used by TUGCO:
- Requires audit plancing documents be utilized to identify organizations to be audited. Frequency of audits will be detemined
- in accordance with provisions contained in TUGC0 Ouality Procedures.
- Requires auditors to be familiar with the type of activities to be audited and have no direct responsibilities in the area being audited.
I
- Provides auditing checklists or other objective guidelines to identify those activities which will be examined.
- Requires examinaticn of the essential characteristics of the quality l activity examined.
- Requires an audit report be prepared that notes deficiencies found.
- Requires the audit report be sent to management responsible for the area audited for review and corrective action for deficiencies.
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- Requires a response that documents corrective action taken as result of the audit.
I
- Requires reauditing of deficient areas when it is considered necessary to verify implementation of required corrective actions.
f TUGC0 maintains audit documentation on file.
f.
COMANCHE FEAK STEAM ELECTRIC STAT /CN l QUALITY ASSURANCE PLAN
' SECTION: 19.0 f.- Authorized Nuclear Inspector DATE: 4/16/79 l REVISION : 2 1
PAGE OF 19.0 Authorized Nuclear Insoector -
The Authorized Inspector shall have free access to all" records and work being performed where such reports or work fall within the scope of his duties and responsibilities. Such records and work shall include, but not be limited to: drawings, Certified Design Specifications, Data Reports, audit reports and Stress Reports, as well as their preparation or review as applicable. The duties of the Authorized Inspector shall be:
i *7erifying that the scope of work stated in the Owners Certificate j includes the work perfonnec and that required documents are properly filed.
- Certification of the N-3 Data Reports.
Stress Reports shall be reviewed in accordance with the Code and shall meet the requirements of the Design Specifications.
( !
The N-3 Form shall be prepared and certified by the Engineering and Construction Manager or his designee prior to the Authorized Inspector's i
review and acceptance. Certification shall include verfication that each Manufacturer or Installer was a holder of the appropriate Certificate of Authorization by the ASME and that all components, appurtenances and interconnecting installation welds comply with the ASME Code, as j applicable. A copy of the form, after being signed by the Authorized Inspector, shall be filed with the Enforcement Authority having jurisdiction at the plant site, along with all Data Reports from the Manufacturers and Installers.
4
?
N
COMANCHE PEAK - STEAM El.ECTRIC STAT /CN
. QUALITY ASSURANCE PLAN SECTION: 20.0
[" g .
DATE: 11/18/83 rg Preservice Inspection Program 2 .
j PAGE 1 CF 2 1 l
20.0 Preservice Inspection Program ~
I TUGC0 has overall responsibility for the perfomance and evaluation of the Preservice and Inservice Inspection requirements of Section XI of the ASME l Code (1980 Edition and later Addenda for Selected Activities). TUGC0 has l delegated authority for implementation of the Preservice Inspection Program as
- follows
- 1. Texas Utilities Services, Inc. (TUSI) has been delegated the authority to:
s Determine the appropriate Code Class (es) for each comoonent of the Comanche Peak Steam Electric Station; the identification of the system boundaries for each class of components subject to inspection; and the identification of components exempt from inspection requirements as pemitted by the Code.
i 4
s The design and arrangement of the system components to include allowance for adequate clearances for the conduct of the
{ j examinations.
e The development of plans and schedules for accomplishing the Preservice Inspection Program and the formal submission of the plans and schedules to TUGCo for filing with the enforcement and i
regulatory authorities having jurisdiction at the CPSES site, e Assure the development and preparation of written examination procedures and/or instructions, includt ng diagrams or system drawings delineating the identification and extent of areas of components subject to examination.
1 e Provide for evaluation of each preservice examination and test.
- s Assure that adequate records of inspection, examinations and tests performed, such as radiographs, diagrams, drawings, 1
inspection data, and personnel qualifications are developed and maintained prior to fomal submittal to the CPSES Records Vault, e Assure the preparation of all basic calibration blocks used for
' ultrasonic examination of components and the maintenance of the blocks prior ~ to formal submittal to TUGCO.
I i e Provide access for the Inspector (AflI) or examination personnel and equipment necessary to conduct the required examinations.
- e Assure the perfomance of necessary operations associated with repair or replacement of system components in the event
(
structural defects or indications are revealed that may require such repairs or replacements.
Em 1
COMANChiE FEAN STEAM ELECTRIC STAT /CN
! QUALITY ASSURANCE PLAN i
-M A% %
SECTION: 20.0 Preservice Inspection Program DATE: 2/18/80
{ .
REVISION: 1
- l
%c d[ [
l PAGE 2 0F 2 Develop and inaintain procedures and/or instructions that are required to implenent the applicable Quality Assurance Program i requirements of Sub-Section NA-4000 of the ASME Code.
)
i
- 2. Westinghouse, has been delegated the authority to:
Perform the required Preservice examinations and tests.
i Record the results of all examinations and tests.
Evaluate the results of all exaninations and tests on components and systems within their scope of supply (eg. Nuclear Steam Supply System) and perfonn or recomend required corrective actions.
Develop all basic calibration blocks used for ultrasonic examination of the components.
Assure that the qualifications of personnel perfonning examinations and tests comply with the applicable provisions of Section XI.
Develop and maintain a Quality Assurance Program conforming to the applicable portions of Sub-Section NA-4000 of the ASME Code for that portion of the Preservice Inspection Program under their scope of work.
' 3. Texas Utilities Generating Company (TUGCO) retains responsibility and authority for:
Filing of required plans and schedules with enforcement and regulatory authorities having jurisdiction at the plant site. l rification (through QA Division audit or surveillance) of compliance of the above delegated functions to the applicable provisions of Section XI.
Developing and maintaining an arrangenent with an Authorized Inspection Agency to provide inspection services required by Section XI.
Assuring that the recording of all inspection and exanination and test results provides a basis for evaluation and facilitates conparison with the results from subsequent examinations.
/
Retention of all inspection and exanination and test records, k calibration blocks, etc. as required for the service lifetime of the component (s) under examination.
r-
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ATTACHMENT P TEXAS UTILITIES SERVICES INC. INSTRUCTION REVISION PAGE C '
CP-EI-4.5-4 3 3-12-81 1 of '
TECHNICAL SERVICES ENGINEERING INSTRUCTION PREPARED BY. bb FOR PIPE HANGER DESIGN REVIEW g APPROVED BY ef
l.0 REFERENCES 1-A CP-EP-4.5 Design Verification 1-B CP-EI-2.1-1 Holds on Hanger Design Fabrication a 4 Installation Activities [4((
2.0 GENERAL 2.1 PURPOSE To establish a progran for design review of design changes for pipe supports for pipe 2-h" and over.
2.2 SCOPE
- This instruction shall apply to si ene n -
s e or off-site for , ned p ets 2.3 DEFINITIONS TS - Technical Services TSMO - Technical Services Mechanical Drafting Department TSDRE - Technical Services Design Review Engineer
- Technical Services File Cler TSFC
'h BRH - Brown & Root Controlled Han er wn HHL - Hanger Hold List 'j i , N.
2.4 RESPONSIBILITIES k# g 2.4.1 Mechanical Design Group Supervisor '*" '
. The Mee' . cal Design Group Supervisor who reports to the Engir.-e .ng Manager) is responsible for providing technical direction and' administrative guidance to the Comanche Peak Mechanical Design Engineering Group.
______________J
s .
I TEXAS Uf!LITIES SERVICES INC. INSTRUCTION REVISION n PAGE l
CP-Ef-4.5-4 3 3- 12-81 2 of 5 2.4.2 Technical Services Superviser The TS Supervisor is responsible for assuring that the -
design review is done in accordance with reference 1-A.
TS Supervisor shall keep a current file on the engineers
, authorized to perform design review.
TS Supervisor shall assure techniques and review reference material meets the qualifications of applicable codes.
2.4.3 Technical Services Design Review Engineer To perform and documant design review in accordance with the
. criteria established by the original design organizations.
Also, to document such reviews in accordance with the site established Design Review Cover Sheet.
2.4.4 Technical Services Mechanical Drafting Department ,
To compile and fcmard a hanger document package for .TSDRE
(. review. Also, to assure that documents in hanger package are not affected by HHL referenced in 1-B.
3.0 JROCEDURE 3.1 TSMD INPUT .
TSMO will compile hanger document packages for TSDRE rev'tew.
The packages will contain the following as applicable:
(1) An Engineering and Office use copy of the latest revision of the Brown & Root controlled hanger drawing (BRH).
(ii) Latest revision of applicable ve do % ((d'f ,
(iii) All valid site and off-site ger.er ~
affectingsubjectdesign. ($
f nYs #
(iv) Information relative to design cha g .g.motf#d hanger sketch, letter showing chan e in leagfq\'
The package will be fomarded to TSFC for r action.
9 e i -
l
__. . . _ ,_ _ _ . _ _ _ _ _ ~ . - _ _ . . _ . . - . . . . _ _ _ _ . _ - _ _ _ ,_ _ _ . _ -_ _ _ _ . - _ . _ _ , _ _ . _ _ _ . . . _ _ _ , _ _ . _ _ _ _ _ _ _
t TEXAS UTILITIES SERVICES INC. INSTRUCTION REVISION hI3UTE PAGE CP-EI-4.5-4 3 3 12 -81 3 of 5 !
i' 3.2 RECEIPTANDREVIE5l TSFC will acknowledge receipt of the packages and forward them -
to TSDRE. Basic flow of the packages within the Design Change Review Group will be in general accordance with the flow chart shown in attachment # 1. The flow chart is not mandatory.
However, the following criteria shall be met:
\
, A. Maintain a record of packages received and retained for i
- i. design review.- The record shall show the status of the i' design review process e.g. Clarification letter "TSDR" sent to field engineering, "STRUDL"/"Off-Si~te Analysis",
. hold for complex structures requiring detailed analysis, review complete, etc.
B. Design review will be performed by the authorized representatives of. the original design organizations in accordance with the respective design review programs. ,
3.2.1 Analysis ' Unacceptable
}
t If during design review, it is determined that a design change is unacceptable or requires further clarification, TSDRE will
- advise the affected parties by speed-letter (TSDR memo) which are issued, logged and tracked by 75DRE/TSFC. The resolution shall be documented in accordance with the appropriate engineering procedure / instruction.
3.2.2 Analysis Acceptable
. Completion of the Design Review will be documented on the Design
, Review Cover Sheet (attachment # 2). Applicable drawing (s),
affected design change (s), loading conditions and applicable design review criteria / codes will be noted on the cover' sheet.
Completed calculations, "STRUDL" analysis out put/off-site analysis out put and Design Review cover sheet as applicable will be maintained in a fire proof file cabinet.
3.3 COMPLETED HANGER PACKAGES:
y r. -
Design Reviewed hanger packages will b re r.
with a copy of the Design Review Cover he s
. p ??%
[-
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I
_ _ . _ _ _ _ . . _ _ _ _ _ - . _ _ . - _ _ . ,.- . . _ , ~ . _ . _ . ~ _ . . . ~ , . _ . . . - . . -
f * .
a l
i b TEXAS UTIl.ITIES SERVICES I!:C. IllSTRUCTIOil ION NE Attachment No. 1 CP-EI-4.5-4 l 3 3-12 -81 4 of 5 ,.
O TSMD Ptapaces As-Suilt -
henger pechage requiring assign Review .
M @ f
- Isrc recalves peekages (pks's) from
- 6ESIGN RITIEW N
@ t FLO'i CHART T5FC acksvledges receipt forwards *to TSDRE
. for scruciaising
@ f t
TSDRE ret'ura yks's to '
in En -
@ t
- n ISTC loss pkg's:
- 1) Retura to TSMD
_ 2) To_ TSDRE for reg ev ,,,, ,
~
,e
! To TSMD l _,,
.@ +
h review required.
, @ f ltack of info.
l TSD1 Design Review l .
@ t t@ i l Necacceptablel .l Acceptable l
@. t @ t TSDR mens w/ Return pks's w/
fix proposal to cale's to TSTC field engineerias
@ t h k T5FC logs, retains
- gg g, original cale's c implesomead i.e., @ (
new/rse.'d M etc.
^ T57C retu heck .
.. of Aluzu -
) .- c,
- 9p TEW -Tecludcal Serviad 4 hanical 3 rafting Deps. N# D-h2 737C TN'al Services FA Clark (for design review. k) \
T531 - T**=1 Servisee Design Review Dept. g)
J
. , M r Tacimical_5ervices Beeign Review Engineer , *)Or h' .t*
g .
. +
e
)
ISSUE f TEXAS tJTILITIES SERVICES IMC.
INSTRUCTION RMSM OATE Attachmerit No.2 I 3 bP-ET-.t.5-4 1 3-12 -81 15 of 5 __
c.p.s.e.s.
SMEET 0F FIPE RAJCE1 EEINEERI:1c DIVI 5103 O CAC n oT ===neu Ca.am-. C:no m T - . vu u ues CERD ST DATE FROJECT Comanche Peak */SKA 150p REY. _ Cec M.
Conditions 7% FY FZ 5t MY MZ
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~
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,o a . .es -
1 ., oP I .
z=rie cr i d $l ~ ~
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,.ated e
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..e m m m, ; , ,e.. .
See A Lug .TJ i ! 'Re y ,
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y See 5. A. toti l l lRev. a '
!ME3 }%# b Rev. e i TUB II, Rev. 2 O .
^s== s ud.as
=1. 1rr =a vt== 7'
! Suclear Class 1 2 3 MC
- 1. Appendia Z7II...........................I '
2.' AISC Steel Manua1...................... 3
- 3. Design'of 11gid Framas-Kleinlege1.......: I*
l 531.1
- s. stre.ita or te n n ....................'
,,g ,, m 1,,, s. 4.arst. er Zwecer=tnant structur......'
lamp. 'T i 6. Formulas ter stress a scrain-aoart......'
I f Temp 7. Beam Fo rmulas-G rif f el. . . . . . . . . . . . . . . . . . . ,
3F G 8. Structural Analysis.....................' ?
l Tor Component standard supports see 9. Design ef Welded Structures-81odgett. ...
Lsad capacity Data sheets EPL File No.1. Rev. 10. Hilti Kwik Bolt Design Manual...........
Engineeri:rg Standards - ES 1 2 3 &l5l6 7l Sl9 l 10l11 l12 13 ' I& 13 16 17118l19l*
l l l l l dO .
(
Sta.dardized Procedure - $7 1 l2 3 4 3 6I7 8 9 10 11 12I13!14!!5 '16
\II %\w ILdgRi ~
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' ' i Cr. so. a.v. t. ..x. V \
1 i
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, _ . . . . . . . . . .. . . . . . - . - - - - - -- - - - ~~* - -
, ATTACHMENT Q -
INSTWCTICN REVISICH ISSUE P/GE
'IEXAS UIILITIES SERVICES INC.
DATE CDTIROLI2L CDPY m. CP-EI-4.5-4 4 2/17/83 1 of 3 , [
ECENICAL SERVICES ,/ =
INGINEERIM INSTRUCTICN PREPARED BY 10 h' A POR PIPE EAEER EESIGN ' -T :
REVIEN AND CERTIFICATICH APPICVED BY t' . e F /4-U
.W #
/// ..
GENERAL REVISICN, REVISICN BARS Nor INCLUDED .
1.0 REFERENCES
1-A CP-EP-4.5 casign verification 1-B CP-EI-4.5-1 General Program for As-built Piping Verification }
2-FOR INFORMAIl0N ONC j
"'"""^'
~
2.1 PCRPOSE j2 ' ,
To establish a program for design review and vendor certification for large bore pipe supports.
2.2 SCCPE
'Ihis instructicn shall apply to design danges generated en site for ITT Grinnell and NPSI designed pipe supports only.
2.3 IEFINITIONS .
TSDRE 'Itchnical Services Design Review Engineering
'ISEC - Technical Services File Clerk --
~
PSE - Pipe Support Engineeri@
=o
'ISMD ' technical Services Mechanical traftino now
- - e e mero ned aanger Dr kNFORMATl0K VCDI - Vendor Certification Drafting Inst. t g S oCC - D==ent omeral Center D li A 2.4 RESPCts Iu2Im i
PPRV
'me CPP Mechanical Engineer (who swi.s to the Engineering Manager) is responsible for providire te<+nical directicn and *nktrative
, , guidance to the CPP Mechanical Engineering organization of sich .
the Technical Services Group is a part.
r,
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- Ex;s UrILITIES SERVICES .INC. INSTRUCTION REVISION ISSUE PAGE s
ME
. v
- , 1 CP-EI-4.5-4 4 2/17/83 2 of 3 6
1he Technical Services Group Supervisor is responsible for assuriq
- that activities within the purpose and scope of this instruction are czmpleted in accordance with the measures described herein.
the TsutE supervisce is responsible for isplementation of this instruction. She TSDIqE Supervisor shall coordinate work flow.
- =_=* the group, interface activities, and maintain-adequate tracking mechanisms to assure cositive control of activities addressed in. this instruction ln accordance with Reference A.
3.0 INSTRDCTION 3.1 IESIGN IIEVIEW 3.1.1 General
. Site generated design changes to vendor supplied pipe supports shall be reviewed for structural acceptability and ccupliance with apylicable code requirements. Review shall be performed l
by representatives of the original design organizations in accordance with their respective engineering Irograms. Design review may be done on-site or off-site at the pipe support vendor's
...? haen office.- -
4 3.1.2 Design Change Acceptable Design change doctanents found to ta acceptable shall be listed on the desigrr review cover sheet for input into the trackig system.
- Cover sheets shall be **W " Design Reviewed", signed and dated by the cognizant engineer. Ocspleted review packages shall i - be returned to the TSK for logging and storage.
j ,
3.1.3 Desian Chance Unacceotable ,
't PSE shall be notified by three part nuno of design changes found to be ur-@le. Menos shall be logged arx1 tracked by TSM.
- Engineering resolutiori by PSE shall ba in accordance with the 3 ,
t-- g inte engineering procedure /i eLuction.
. 3.2 VENDDR CERTIFICATION (Non-Cass 1 9_, ts) j 3.2.i General INFORMATl011 S, tpen ampletion of as-built stress analMnerFClasi*hpW j s supports within as-txtilt scope, as defimeil indieferenM-Bp ahn11 g, be reviewed to assure ampatibility betgfin_aL stress angysis
- and final support design. Supports shall then undercp a final l: heck
. ?, . , ,, to assure overall ocupliance with applibable e, and it .., vendae engineering requires =nts. I f
i
, ,.... u. . . . . . ..~ . . . . . . . - - . . . . . . . - - - - . -
pr N- TEXAS UIILITIES SERVICES JNC. INSTRUCTION. @ VISION ISSUE. PME - ..
.: CP-EI-4.5-4 4 2/17/83 3 of 3~ ,
3.2.2 Final Design Acceptable
.tsmitte - Acceptable hanger packages shall be tracri tted to TSMD to assure
,ed en applicable as-built information, as list: ' cn the VCDI, ma;r be a sha' is.w. gated into the final BRE. The bra thall be stanpic "Verdor.
.-.ed
. Certified" and, upon return to TSDRE,.si9n-d.by the designated -
vendor engineering representative.
1
. )d. Certified hanger packages shall be forwaul.d to TSIC for disposition.
.ju- > penger drawings shall be issued for distributicn by CCC ard certified re- i : e =1m1= tion sackages shall be stored in fi):e-proof cabinets or vaults.
s
} 3.2.3 Final Design Unaccectable -
3 hi
- i
'.i s thacceptable hanger packages shall be dispmitioned as cutlined in Section 3.1.3.
3.3 VENDCR CERTIFICATION (Class 1 Supports)
] 3.3.1 General v.:_ , . : Ut:en ccenpletion of as-built stress analysir. Class 1 pipe supports
-rf -a . . shall be reviewed at NPSI's hone office to assure ccznpatibility
~ . -p . . . =2 between final stress analysis and final suF5crt design. Class 1 m e- _ '. i suggerts shall undergo a final check to as:ure overall compliance
.it-4 with applicable cades, site, and vendor entineering requirements.
--t A stress report shall be prepared for each Class -1 support.
, g] 3.3.2 Final Desian Acceptable 4
13 VDCI's for acceptable hanger packages shall be transmitted frcm
. ;f. the NPSI bome office to site. 'Ihe hanger leckage shall be .trans-
-c mitted to TSMD to assure all applicable as -built information, as i -l- listed cm the VCDI, is incorporated into the final BR11. '1he BRH
.. p shall be stanged " Vendor Certified" and, u.xan retmn to TSDRE, signed
( ti- by the designated NPSI representative. A .rpy of the vendor
, e artified BRE is ritturned to the NPSI hane office. Upon receipt ' "
- of the certified BRE, the NPSI home office PE shall cxmplete his i t. .i review and certify the hanger stress repor - A mm a *- --- 22 M
- ' . ff
., .1 hanger stress 'reportsshcuing as-built sti -
.y to the site. h s.i[]jh j.Vl k l c O N s
- g CertifiedcClhas i hanger pacitages inc10itir rf
- . b _u . copy of thir certified hreport shall A fordakdedJ r.
, .1 . f r :. . disposition. Class 1.' hanger dcewings shali. I iqaph2k dis f f. .
ei i , 13cn oy DCC and certified strass reports shall be storairin fire- ~
proof cabinets or units.
PPRV
- -' 3.3.3 Final Desien Unacceptable
- 1
- ;. ..: d t- thacceptable Class 1 hanger packages shal.' t.s dscostnoned as et-lined in Section 3.1.3.
I e cMnec us.8c
'84 My Ah :58 UNITED STATES OF AMERICA grgg ,s ,
NUCLEAR REGULATORY COMMISSION 00CiNU,y~.,'$,(
BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of }{
}{
TEXAS UrILITIES ELECTRIC }{ Docket Nos. 50-445-1 COMPANY, et al. }{ and 50-446-1 (Comanche Peak Steam Electric }{
Station, Units 1 and 2) }{
CERTIFICATE OF SERVICE By my signature below,_I hereby certify that true and correct copies of CASE'S MOTION FOR ADDITIONAL TIME AND CASE'S SECOND PARTIAL ANSWER TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION REGARDING APPLICANTS' QUALITY ASSURANCE PROGRAM FOR DESIGN OF PIPING AND PIPE SUPPORTS FOR COMANCHE- PEAK STEAM ELECTRIC STATION have been sent to the names listed below this 30th day of October ,19 8;4 ,
by: Express Mail where indicated by
- and First Class Mail elsewhere.
- Administrative Judge Peter B. Bloch
- Nicholas S. Reynolds , Esq.
U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.
20036 Washington, D.C.
- Judge Elizabeth B. Johnson ,
Oak Ridge National Laboratory .
- Geary.S. Mizuno, Esq.
P. O. Box X, Building 3500 I Office of Executive Legal Oak Ridge, Tennessee 37830 Director .
. ._. __ U. S. Nuclear Regulatory ,
- Dr. Kenneth A. McCollom, Dean Commission .
Division of Engineering, Maryland National Bank Bldg.
Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Georgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland ^20814
- Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive- Board Panel
( Oak Ridge, Tennesse'e 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1
o: %
-l l
i l
e !
Chairman Renea Hicks, Esq.
Atomic Safety and Licensing Appeal- Assistant. Attorney General
- ' Board Panel Environmental Protection Division U. S.-Nuclear: Regulatory Commission Supreme Court Building Washington, D. C.. 20555- Austin, Texas 78711 John Collins
- Regional Administrator, R*.gion IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin 114 W. 7th, Suite 220 Austin, Texas 78701 Dr.. David H. Boltz
< 2012 S. Polk Dallas, Texas 75224 Michael D. Spence, President Texas Utilities Generating Company ,,
Skyway Tower 400 North Olive St., L.B. 81 ,
1, Dallas, Texas 75201 '
Docketing and Service Section (3 copies)- -
Office of the Secretary i
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 (JE, >
tkMrs.) Juanita Ellis, President CASE (Citizens Association for Sound Energy) .
1426 S. Polk l Dallas, Texas 75224 214/946-9446 l
F-f-
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