ML20115A130

Defends Uncompromised Independence & Unviolated Protocol Re Independent Assessment Program Phase 1 & 2,per . Assessment Considered Independent of Util Influence & Responds Fully to Scope of Audit

ML20115A130
Person / Time
Site:	Comanche Peak
Issue date:	04/10/1984
From:	Shulman M CYGNA ENERGY SERVICES
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20115A132	List: ML20115A130
References
83090.005, NUDOCS 8404120156
Download: ML20115A130 (22)

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1G1 Canternia Street. Sete 1000. San Franc sco. CA 941115894 41529?.500 April 10,1984 83090.005 Dorrell G. Eisenhut Director, Division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Comanche Peak Steam Electric Station Independent Assessment Program, Phase I & 2 Job No. 83090 -

Reference:

Docket No. 50-455

Subject:

Letter of Merch 22,1984 .

f frem D.G. Eisenhut to Messrs. Kommerzelf of Cygno i

and Gary of Texas Utilities Generating Company

Dear Mr. Eisenhut:

Your letter of March 22,1984 and the transcript references contained therein have been reviewed and carefully considered. In neither instance referenced in your letter does Cygno consider its independence to have been compromiseil nor the intent of the protocol attached to your letter of September 23,1983 to Mr. Gary to have been deliberately violated. '--

Cygno recognizes that these reviews have come under increased public scrutiny. We also recognize thct the existing protocol may be subject to various interpretations. Although Cygno does not believe it hos violated the protocol, because of the heightened attention to this matter, we are adopting the most conservative interpretation of the protocol for purposes of all future activities.

As will be discussed in detail below, we do not believe that the fact that overnight notice for requested documents was provided during the course of a follow.on review should offect the quality of the audit. Cygno does not perceive this event as o reflection on the independence of its effort. With respect to the protocol attoched to your letter of September 23,1983, Cygno considers its contacts with TUCCO to have been necessary to conduct the review and I not in violation of the protocol. Finally, based on its separation from TUGCO and the '

procedures followed during the audit, Cygno nos always considered its ossessment to be completely independent.

. San Francisco Soston CNeago Pheniend WSN ZM[ .2 [

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Mr. Darrell G. Eisenhut April 10,1984 Director, Division of Licensing Page 83090.005 The questions raised, and Cygna's responses are os follows:

l. We understond-that Cygno gave the TUCCO advance notice of the documentation needed to conduct Cygne's review. These documents were

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then used to ascertain the accuracy of documentation control paperwork as well as the odequacy of control document distribution (Tr. 9368-9372)."

As of October 24,1983, the date of the event referenced at Tr. 9368 et seq., Cygna had already identified and documented four valid observations with respect to Design Change Control. Those observations are DC-01-01, DC-01-02, DC-01-03, and DC-01-04 (copies of the observctions are attached). These observations were originated on or before July 29, 1983. The subject observations were also validated prior to October 24,1983, the date of the.

event referred to os Tr. 9368 et seg. The action of October 24,1983 with respect to submitting a document list to TUCCO was for the purpose, as stated on the document itself, -

of a follow-up review of the implementation of corrective actions token by TUGCO. A copy of the list,"DCC - Follow-up Review" dated October 24,1983 is attached for your referehce.

e. The "DCC - Follow-up Review" list was submitted to TUCCO in the later part of the I offernoon. It was enticipated that the requested printouts would be made availcble early the following morning when the Cygna reviewers planned to commence the follow-up oudit.

Cygno considered the request to be a reasoncbie cudit procedure based on the facts thet:

1) the requested documents were not the exclusive basis for the ossessment; 2) there were a forge' number of design changes associated with the documents; and 3) the leod tirne ovcilable to provide printouts was short.

The purposes of the subject request were: (c) to determine whether the recently "-

implemented document control satellite system insured the availability of consistent CMC and DCA listings for control document holders, and (b) to determine whether the documents were being distributed using proper controls.

Regarding item (c) chove, consistent CMC and DCA listings for control document holders was ochieved by the use of a centralized data base. The centralized data base was accessed by

remote terminais located in the satellites. Implementation of the centralized computer data

base eliminated inconsistent listings since the satellite control points accessed the same data base through a remote terminal. Cygna's request for a listing of outstonding CMCs and DCAs was to assess whether TUGCO had implemented a system that eliminated inconsistencies between control document holders' listings and Document Control listings.

With respect to item (b), determining whether documents were being distributed to the satellites in a controlled menner, it was necessary to observe satellite operations and procedures, it was also necessary to assess whether the satellites maintained the required copies of documents within their control. Such surveillonce and ossessment was accomplished during this follow-up review.

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Mr. Darrell G. Eisenhut April 10,1984 Director, Division of Licensing Page 83090.005 As Cygna witness Williams testified, the documents requested on October 24,1983 were not for the purpose of detecting problems, and were not solely relied upon to determine whether TUGCO had resolved its problems with respect to occurate listings of CMCs and DCAs. That verification required on ossessment of the Design Change Tracking Group (DCTC) octivities i surrounding the development of a computerized logging system. A discussion of that effort is contained in Observation DC-01-01 and the Telecon of October 24,1983 (o copy of the Telecon is attached).

A more occurate statement of' Item I in your letter of March 22,1984 would be:

"Cygno requested TUCCO, in writing, to provide computer printouts related to specific drawings on on overnight basis. The request was port of a follow-up on previously recorded observations. The documents requested were used, in part, to determir.e whether the previously identified problems of document control and distribution were being corrected. .

Cygno did not rely solely on review of documents to ascertain whether either problem had been resolved."

Cygno otso maintains that requesting documentation in advance, as reflected in the ottoched b list, is on accepted audit procedure. This is especialy true where, os here, the response to the request is not the sole basis for the auditor's final determination.

"2. Based on the transcript (Tr. 9377-9382), it appears that Cygno did not follow the protocol attached to my letter to Mr. Gary dated September 23, 1983 with respect to notice of all meetings between TUGCO and Cygno."

Cygno does not believe that it hos violated the protocol of Septembet 23,1983. In reviewing .

the referenced portion of the transcript, Cygno interprets the items discussed as follows:

a. Communication with Gibbs & Hill: oil conversations and communications were handled in a procedure identical to that followed with TUCCO.

b. Technical Exchanges: oil such exchanges were either in writing or memorialized.in a "Telecon" as required by Porograph 2 of the protocol (copy of the protocol is attached). The portion of the protocol opparently questioned in the referenced portion of the transcript is Paragraph 2.

"2. Telecons may take piece between TUGCO ond Cygno technical staff to resolve open findings and discuss TUGCO's proposed corrective actions.

Telecon summaries will then be prepared by Cygno and placed on file per the protocol of Paragraph 1." .

Cygno has considered face-to-face exchanges to resolve individual technical issues to be comparable to Telecons.

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Mr. Darrell G. Eisenhut April 10,1984 l Director, Division of Licensing Page 4- )

83090.005 l l

Because a forge portion of the Cygno essessment was conducted on-site, face-to-face conver,sotions have taken place between TUCCO and Cygno technical staff concerning document requests, technical items and corrective actions. Cygno does not consider a request for documents to DCC to be a technical exchange. As testified by Cygna witness Williams, exchange of technical information was necessary to conduct the review. As stated, such exchcnges took place either through written requests, telephone conversations or, especially on-site, through face-to-face conversations. In ecch instance, the exchange was reduced to writing in the form of a "Telecon". Cygna believed that on interpretation of Peregrcph 2 of the protocol to allow a telephone conversation to exchange technical information followed by a written "Telecon" but not to allow the some conversation through a face-to-face exchenge of technical information followed by a written "Telecon" would picce on impractical burden on the auditor and did not reflect the intent of the protocol. The exchange of technical information between TUCCO and Cygna is both necessary and cppropricte so long cs it is documented. To construe any face-to-face conversation to be o -

" meeting" and requiring notice to all parties under Peregraph 3 of the protocol would have severely restricted the timely flow of technical information necessary to accomplish the reviews.

f Cygna recognizes that since underteking its review function, the emphasis of its review has chcnged due to its activities having been subjected to increasing public scrutiny. An activity originally undertaken to provide en cdditional assurcnce to NRC Staff has become a licensing issue where the examinction has been expended to require Cygno to justify, in o litigated hearing setting, accepted industry practices. In "Memorondum (Cicrification of Open issues)"

issued by the Board on Micrch 15,1984 it stated:

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"Fn 6. We are concerned that whenever Cygna relies on industry pfactice it be able to specify the scope of that practice. It also should be cble to obtain and review the engineering enolysis that supports the alleged practice. Then, and only then, will the Board know whether this practice comports with the appliccble reguictions and Code sections"(at pcge 4).

Cygna is not attempting to avoid its responsibilities and is fully committed to on in-depth, well planned, independent assessment. We are, however, concerned that the protocol of September 23,1983 is sufficiently ambiguous that it con be interpreted to the detriment of the review product. Cygno suggests that the applicable protocol be cicrified such that no question will exist as to the ogreed upon procedures for conducting on independent assessment.

During the interim, until such procedures have been developed, Cygna will odopt the most conservative interpretation of the existing protocol. Cygna will not engage in foce-to-foce conversation with TUCCO personnel of the technical level, except pursuant to peregrcph 3 of the existing protocol. Given the changing atmosphere in which our work is being performed, we do not consider a less conservative course of oction to be prudent at this time.

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Mr. Darrell G. Eisenhut April 10,1984 Director, Division of Licensing Page 83090.005 1

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You have asked for on assessment of whether Cygno considers its review to have been fully independent and the basis for that conclusion. Cygno considers its assessment to have been independent. Cygno has followed the independence criterio set forth in Appendix A to its report, Board Exhibit No. I in the Comanche Peak proceedings, and reaffirms the occuracy of that statement (o copy of that statement is attached).

In addition to the organizational independence, Cygna would note that the following chorocteristics of the review itself reflect the independence of the process:

e Initial reviews were conducted by Cygno on-site personnel who collected the necessary review documents.

e All observations were generated internally and without TUCCO participation. ,

o Cygno conclusions were developed through a senior review team that was not associated with TUGCO, Cygna's on-site reviewers, or the physical conduct of the review itself. This provided a second layer of independent h -

review of Cygnc's activities and conc!vsions.,

e The independent assessment report was generated by Cygno personnel without TUGCO review.

Cygno does not believe its independence has been compromised in any way by either of the

items referred to in your letter of March 22,1984. Cygno's assessment has been entirely independent of TUCCO and its agents and has been based solely on the evoluotion and ..

Judgement of Cygno. All evoluotions, from the initial observation forward have been by Cygna with TUCCO being involved only to provide technical information. TUCCO has responded to the various observations by Cygno, but has not been involved in the deliberative process of the assessment.

Based on all of the above, Cygno considers its ossessment to be independent of TUCCO

( influence and to respond fully to the ogreed upon scope of the audit. Cygno recognizes the importance of protocol and would welcome on opportunity to discuss with the staff the development of on interpretation of the protocol that will cover all aspects of independent assessments. .

Ver uly yours, /

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d Michael N

/ImanP' Ntf Monoger, Western Region MNS:pm Enclosures 1

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WL w-rb' f.1 Si fCIS Mr. Darrell G. Eisenhut April 10,1984 Director, Division of Licensing 83090.005 Nicholas S. Reynolds, Esq. Mr. John T. Collins i Bishop, Liberman, Cook, Purcell & Reynolds' U.S. NRC, Region IV l 1200 Seventeenth Street, N.W. 611 Ryan Plaza Drive  !

Washington, D.C. 20036 Suite 1000 Arlington, Texas 7601I l Robert Wooldridge, Esq.

Worsham, Forsythe & Sampels Mr. Lenny Alan Sinkin 2001 Bryan Tower II4 W. 7th, Suite 220 OcIlos, Texas 75201 Austin, Texas 78701 Mr. Homer C. Schmidt Mr. B. R. Clements Manager - Nuclear Services Vice President Nuclear Texas Utilities Generating Company Texas Utilities Generating Compcny 2001 Bryan Tower Skyway Tower Dc!!as, Texas 75201 400 North Olive Street L.B. 81 Mr. H. R. Rock Dolics, Texcs 75201 Gibbs & Hill, Inc. -

393 Seventh Avenue . Peter B. Bloch, Esq.

New York, New York 10001 Chairmen, Atomic Sciety cnd Licensing Bocrd U.S. Nuclear Regulatory Commission

. Mr. A. T. Parker 4350 Ecst/ West Highway,4th Floor Westinghouse Electric Corporction Washington, D.C. 20814 P.O. Box 355 Pittsburgh, Pennsylvania 15230 Dr. Weiter bl. Jorden 881 W. Outer Drive Ms. Renee Hicks Ook Ridge, Tennessee 37830 Assistent Attorney General Environmental Protection Division Dr. Kenneth A. McCollom P.O. Box 12548, Capitol Station Decn, Division of Engineering Architecture an Austin, Texas 78711 Technology Okichoma State University ~

Mr. James E. Cummins Stillwater, Okichoma 74074 Resident inspector / Comanche Peck Nuclect Power Station . Stucrt A. Treby, Esq.

c/o U.S. Nuclear Regulatory Commission Office of the Executive Legcl Director P.O. Box 38 U.S. Nuclear Regulatory Commission Glen Rose, Texas 76043 Washington, D.C. 20555

- Mr. S. Burwell Mr. J. B. George Licensing Project Monoger Texas Utilities Generating Compcny U.S. Nuclear Regulatory Commission Comanche Peak Steam Electric Station 7920 Norfolk Avenue Highway FM 201 Bethesda, Maryland 20014 Glen Rose,' Texas 76043 Mr. H. Schmidt Mr. David H. Wade e/o Westinghouse Texas Utilities Generating Company 4901 Fairmont Avenue 400 North Olive Street, L.B. 81 Bethesda, Maryland 20814 Dollos, Texas 75201 Mr. David R. Pigoff Orrick, Herrington, & Sutclif fe 600 Montgomery Street Son Francisco, California 94111

Observation M (% L Record

!!!!!nitiiiiiiinuitiiiiiill Checklist No. DC-01-01 n evision No. O observation No. DC-01-01 sneet 1 or 1 orleinstea sy S. Bibo ,g g g este 7/29/83 naviewee ey P. DiDonato Qggg oste 7/29/83 1.0 Description The CPSES Document Control Center (DCC) does not maintain an accurate listing of design changes generated against drawings and specifications. This was substantiate-upon review of eighteen drawings, seven specifications and approximately 112

. associated design changes. These discrepencies are as follows:

Design Change Affected Document Missing from DCC Log Dwg. 2323-5-0800 DCA-12534 (Rev.1)

Dwg. 2323-El-0018-01 DCA-16858 Dwg. 2323-5-0801 DCA-713 Dwg. 2323-5-0825 DCA-7850 (Rev. 4) 2.0 Requirement CPSES Procedure Number DCP-3, "CPSES Document Control Program," 13.3.1 requires in part that a list of all active changes be maintained.

3.0 Document Reference CPSES Procedure Number DCP-3, 13.3.1.

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4.0 Potential Design Impact If the Document Control system does not assure accurate distribution of design changes, the constructed configuration may not reflect the intended design, thereby impacting plant design.

Attachment

A. Observation Record Review l

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Texas Utilities Services, Inc.

Independent Assessment Program; 83090

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Observation ah m i Record Review

. linunnmmnmmunil Attachment A checkiist No. OC-01-01 R

• vision No. 1 Observation No QC.01 01 Sheet } of 3 Yes No Valid Observation X clo s e s X Comments 1.0 Probable Cause ,

Failure to implement procedures.

2.0 Resolution

• The identification of this observation acts as a confirmation of the document contro' problems previously known to Texas Utilities through the various reviews and audits performed at CPSES. In fact, prior to the Cygna Independent Assessment Program, Texas Utilities began planning a new document control program which would alleviate '

the inaccuracies inherent in the existing system. The implementation of this new system entails establishing tighter control over document distribution and an f accuratedesignchangetrackingsgstem. The major elements of the new system are:

a. Centralization of existing document distribution points (file custodians) into eight remote " Document Control Center (DCC) Satellite" stations,

b. Develop a computerized drawing and design change listing,

c. Perform a systematic verification of the computerized data base' to ensure accuracy. .. - ._

The centralization of the document distribution points has been instituted. A revie to determine whether the institution of this new system resolved the distribution control problems was conducted the week ending 10/28/83 by Cygna. The results of this review are documented on Observation Review Record DC-01-02, Rev.1.

The DCC computerized drawing and design change data base has been developed by the Texas Utilities Design Change Tracking Group (DCTG) using the Gibbs & Hill design verification tracking system as a base listing. Since the Gibbs & Hill system did not include piping and pipe support drawings, a manual tracking system continued to be used by DCC to control this group of drawings. Once the as-built drawings are completed, DCTG intends to add them to the data base as well, a wo..i.

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. Observation 4Mi Record Review tiimminiii!!iiniiiiii!!!

Attaehment A Checklist No. DC-01-01 Revision No. 1 i Observation No.DC-01-01 sheet 2 of 3 i

Yes No Valid Ob.orvation X j Closed X

. Comments

- The verification of this data base was conducted to check all Design Change Authorizations (DCA's) and Component Modification Cards (CMC's) issued. This check was conducted in two steps:

a. For DCA's. a' comparison of the Gibbs & Hill design verification tracking systen output and the DCTG design verification status output was conducted. This comparisen was accomplished by cross-checking the two sequential numerical' DCA lists to ensure that all DCA's were accounted for. Any discrepancies or voids.

were resolved by reviewing the actual DCA and the design verification checklist. Upon completion of this review, the DCTG data base was updated.

s b. For CMC's, all original design verification checklists (from G&M and Texas

' { Utilities site engineering) were merged and are being reviewed against the CMC's. Upon completion of this review, the TUSI data base will be updated to correct all discrepancies relative to the affected documents and design verification status.

Discussions with Texas Utilities personnel regarding the above mentioned data base development and validation process, a final issue review of all drawings (except structural and piping composites) is nearly complete. This review is being done by qualified discipline engineers who make a detemination as to whether design change-listed as outstanding have been incorporated into the drawings. Based on the resul-of the final issue review, the DCTG data base is updated to accurately reflect the drawing status.

Texas Utilities has initiated a " turnover" program to ensure that all design change i have been incorporated into the final plant configuration on a system by system basis. This includes numerous walkdowns by groups such as QC, Start-up, Completion and Operations, prior to the systen being accepted by the Operations Group (TUGCO).

The effectiveness of this " turnover" was verified by the Cygna walkdown of a completed system -- the Spent Fuel Pool Cooling System.

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Observation 4e a a Record Review n!!mnm!nnnuitintiil Attachment A Revision No. }

Checklist No. DC.01-01 aneet 3 of 3 observation No.DC.01 01 l Yes No Valid Observation X Closed X Comment s As of October 24, 1983 the validation effort was approximately 85% complete. Cygna reviewed this system on October 24-26, 1983 to assure that the document control problems identified in this observation and observations DC-02 and DC-03 had been corrected.

l Cygna also reviewed the components of the new system and conducted a confirmatory i

review of its implementation, the details of which are described in the Observation Record Review for Observations DC-02 and DC-03. We have confidence that the newly developed computerized document listing is accurate with respect to design changes outstanding against effected design documents and tha adequate programs have been pt l

in place to assure that the plant is constructed in accordance with the design and

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• associated design changes. Therefore, this observation is considered closed.

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. Observation A L% i Record Illiiiiiiimiinnuiiiiiiiii cheemaist No. DC-01-02 R evision No. O oeservation No. DC-01-02 sheet 1 of 1 originated sy S. Bibo Jg onte 7/29/83 Reviewed sy P. DiDonato gjggg cate 8/5/83 i

1.0 Description The Design Change Log Books maintained by site file custodians did not include the posting of all design changes. This was substantiated upon review of the Document Control Center list of design changes against affected documents versus the site file custodian Design Change Log Books.

AFFECTED MISSING DOCUMENT DESIGN CHANGE LOCATION SPEC MS-208.1 DCA-14781 Purchasing SPEC MS-208.1 DCA-14026 (Rev. 2) Purchasing D'a'G 2323-El-0018-01 DCA-9222 (Rev.1) Electrical .

SPEC MS 46A DCA-11193 (Rev. 2) Purchasing

SPEC MS-46A DCA-11939 (Rev.1) Purchasing SPEC MS-46A DCA-14349 (Rev. 1) Purchasing

1. - SPEC MS 46A DCA-16383 (Rev.1) Purchasing SPEC MS-46A DCA-17620 Purchasing SPEC MS 46A DCA-13037 Purchasing SPEC MS-46A DCA-18073 Purchasing SPEC MS-605 DCA-10413 (Rev. 3) Purchasing SPEC MS-605 DCA-17849 Purchasing SPEC MS-605 DCA-17852 Purchasing 2.0 Requirement - - ...

. CPSES Procedure Number DCP-3 "CPSES Document Control Program 13.2.1.3 requires in part that site custodians post design changes which af fect their areas in their respective Design Change Log Books.

3.0 Document Reference

' CPSES Procedure Number DCP-3,13.2.1.3 4.0 Fotential Design Impact The design may be impacted if controlled document holders do not maintain the latest design information associated with documents.

Attachment

• A. Dbservation Record Review ,

Estent feelsted Estensive X Other (specify)

Texas Utilities Services, Inc. ,

Independent Assessment Program; 83090

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Observation gmi Record Review niimillimi!!ililil!miti Attachment A Rnisjon No.

Checklist No. DC-01-02 }

observation No.DC-01-02 anut i e' 2 Yes No Valid Observation X J

Clo s e d X Comments ,

1.0 Probable cause

< . Failure to implement procedures.

2.0 Resolution In order to verify the effectiveness of the steps taken by TUSI (see Observation Record Review 0C-01-01) and to assure that the concerns addressed in Observation DC-01-02 have been resolved, a follow-up review was performed by ,

Cygna at CPSES during the week ending 10/28/83. This verification ef fort consisted of reviewing twenty drawings at eight satellite locations (73 total drawings and 1005 corresponding design changes). The review process was as

, r follows:

1. Controlled distribution lists (ccmputerized) of selected drawings were requested from DCC and reviewed to ascertain which drawings were required to be on file at specific Document Control Center (DCC) satellite

. location.

2. A computer print-out of all design changes relative to each drawing was requested from DCC and reviewed to ascertain what design. changes were ...

issued against each drawing.

3. The files at each satellite location were then reviewed to assure that all t required drawings and their corresponding design changes were on file.

This review revealed that all DCC satellites contain all required drawings and the corresponding design changes. In addition, all design changes are posted against appropriate drawings via a manual design enange status log or the computerized design change status log. Prior to the institution of the data base merger and validation process described in Observation Record Review DC-

' 01-01, each DCC satellite was required to maintain manual logs of all design I

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Independent Assessment Program; 83090 l

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d iej t i Record Review iiittiilitiiiiiiiiiiiiiittitil Attaehment A R evision No. }

Cn.ekiist No. 0C-01-02 sh.. 2 of 2 Observation No.DC-01-02 Yes No Valid Obserystion X Closed X Comments changes. Although some manual logs are still maintained, DCC satellites now have the capability to ascertain information instantly frcrn the computer data base by remote terminals in the satellites.

In conclusion. Cygna is satisfied that adequate corrective / preventive action have been taken to resolve the concerns addressed in Observation 0C-01-02 and therefore, considers this observation closed.

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. Observation A L% i Record lilllillliiiiiiiiiiiiiiiiiiiil Checkilet No. DC-01-02 R evision No. O Observation No. DC-01-03 sheet 1 of 1 ortatnates my S. Bibo gg oste 7/29/83 noviewed sy P. DiDonato j $ g.j7 f e 7/29/83 1.0 Description An initial review of fourteen drawings disclosed that one (Gibbs & Hill drawing 2323-5-0801) was hot stamped "THIS DOCUMENT AFFECTED BY DESIGN CHANGES." A further sample of 20 drawings disclosed that four dr.awings lackti the required stamp.

2.0 Requirement Project Procedure Number DCP-3, "CPSES Site Document Control Program," Section 3.2.1.3 requires that the document file custodian stamp documents affected by design changes with "THIS DOCUMENT AFFECTED BY DESIGN CHANGES," prior to issuance.

3.0 Document Reference r-i CPSES Procedure Number DCP-3, section 3.2.1.3.

4.0 Potential Design Impact The design may be impacted if controlled document recipients are unaware that design changes have been issued against a drawing.

Attachment . . ,,

A. Observation Record Review Estent te ola te s E s t e ns6,e X l Other (Specif r)

Texas utilities Services, Inc.

Independent Assessment Program; 83090

1 Observation Record Review d(ni mmmnn=mm*"" Attachment A  !

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Rnisjon No.

Checklist No. DC.01 02 } f sheet of observation No.DC-01-03 1 1 Yes No Valid Observation X Closed X Comments 1.0 Probable cause Failure to implement procedures.

2.0 Resolution The DCC drawing tracking system described in the resolution to observatien 0C-01-01 is the governing reference for determining if a drawing is affected by design changes. When a drawing request is received in either document control or the satellite stations, the computerized / manual listing is checked to

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determine if there are any associated design changes. The drawing is stamped "THIS DOCUMENT AFFECTED BY DESIGN CHANGES," if applicable.

A follow-up review was performed by Cygna at the CPSES diaring the week ending 10/28/83. During the review process described in the Observation Record Review for DC-01-02, hard copies of 24 drawings were reviewed to verify that the stamp "THIS DOCUMENT AFFECTED BY DESIGN CHANGES" had been applied. The results of this review revealed that all hard copy drawings on file at DCC satellites . , ,

contained the required stamp.

In conclusion, Cygna is satisfied that adequate corrective / preventive action has been taken by TUSI to resolve the concerns addressed in Observation DC-01-02 and therefore considers this observation closed.

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Independent Assessment Program; 83090

Observation M Lt 6 i Record liiiiiiiiiiiiimiiiii!!!Illll checklist No. DC-01-01 Revision No. O oneervation No. DC-01-04 sheet 1 er 1 orielnetes my S. Bibo Rh Date 7/29/83 Revle ee ey P. DiDonato f 7j g j 7 p ate 8/19/83 1.0 Description The Field Design Change and Review Status Log, as maintained by the Design Change Tracking Groups (DCTG) was reviewed for compliance to Procedure CP-EP-4.7 " Control of Engineering / Design Review of Field Design Changes." The review disclosed: ,

1. .The DCTG status log did not accurately reflect all outstanding design changes listed (e.g. Specification 2323-ES-100. DCA-9695; 2323-5-0800 DE/CD's,DCDDA's,FICR's).

2. The DCTG status log does not accurately reflect the status of design change documents to be incorporated versus design changes not to be incorporated (e.g. DWG. 2323 5-0801, DCA-81 and DCA-92). .

3. The DCTG status log contains design changes entered against the incorrect affected document. (DCA-1803 was listed against another specification when it should have been listed against MS 205.1.)

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' 4 The DCTG status log identifies design changes as applicable to certain documents when in fact they have been voided.

2.0 Requirement Procedure CP-EP 4.7,13.3 requires that DCTG maintain a " Field Design Change and Review Status Log" in conjunction with Gibbs & Hill.

3.0 Document Reference CPSES Procedure Number CP-EP-4.7,13.3.

4.0 Potential Design !spect The design may be impacted if design reviews are overlooked.

Attachment A. Dbservation Record Review E s tent so astes sitensive A l otmee (speelfr)

Texas utilities Services, Inc. .

Independent Assessment Program; 83090

Observation g( ,i Record Review nmimmmaiimimi Attaehment A Cnechilst No. Rutelen No. 0 OC.01 01 sheet 1 et g Ob.orvatten No DC-01-04 Yes No Valid Cheervation X Closed - X Comments 1.0 Probable Cause Failure to effect.ively implement the DCTG computer system due to start-up problems.

2.0 Resolution ,

At the time of the Cygna Review, the DCTG status log was being developed from a copy of the Gibbs & Hill tracking system. In the early stages of development, its primary purpose was to status design reviews of design change documents

[,' even though Gibbs & Hill was responsible for performing this function. This review did not disclose any problems with the statusing of design reviews.

During follow-up reviews for other observations, Cygna did observe the development of an accurate status Itsting (refer to Observation Record Review to.0bservation DC-01-01). This listing now serves as the master listing of design changes and design review status for the Document Control center as well as DCTG.

An assessment has been made by Cygna that the inaccuracter contained in the -

listing would not impact design. As a result of the Cygna review during the week ending 10/28/83, this observation has been closed. The basis for closure is the fact that the DCTG status listing has been totally verified (refer to Observation Record Review to Observation DC-01 01) as to content and accuracy.

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Independent Assessment Program; 83090

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Communications

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"'**** 83090 Comanche Peak Steam Electric Station Independent Assessment Program Date October 24, 1983 soiect: Status of DCTG/DCC Merger '"" 10:30 AM Comanche Peak Mike Strange Texas Utilities, TNE Nancy Williams Cygna ameen item Comments Act*09 Sy In preparation for Cygna's follow-uo audit of the Comanche Peak document distribution system, Mike Strange provided the following status of the DCTG data base clean-up activities. Since a

• majority of the Comanche Peak drawings and associated change documents'are now being controlled using the DCTG data base, the adequacy of the OCC tracking system now relies for the the trost

[ part on the accuracy of this data base. This discussien was held to help understand the effort being made to validate this indet.

All satellite DCC's have been provided with access to the OCTG

' computerized data base as part of the recent merger of DCC with the DCTG data base. All Gibbs & Hill and vendor drawings are currently included in the data base. The BRP and BRH!. draw'.ngs "

(piping and hanger location drawings, respectively); ind harger detail drawings are still tracked manually however. Trese

drawings are all included in the as-built program which ensures that the final drawing will accurately reflect the constructed 4 . condition. This effort is conducted on the site and was not part of Gibbs & Hill design verification scope. Since the original input for the DCTG data base was the Gibbs & Hill design verification tracking system, these drawings have not been added yet. As part of the system turnover from TUS! site engineering to TUGC0 operations, a QC as built drawing is generated for large bore systems which incorporates all design changes. Once this

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design package is complete, it will be added to the DCTG data base for tracking. No design changes will appear on the computer listing for this type of drawing. Small bore (Pt$) piping is

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ll1111111111111t!!!!1111111111 I"ci Y* s, ei.m comm at turned over in a similar manner except Texas Utilities has currently elected not to incorporate all change documents. As such, the final design package will include change paper which will be entered and tracked in the data base.

The data base validation process includes a check of every DCA _

and CMC issued. This check is being conducted differently for the DCA's than the CMC's as explained below. The different approaches were selected on an efficiency basis only.

In the case of DCA's, Gibbs & Hill has completed approximately 95% of the design verifications and has sent TUSI a finalized design verification computer output (October 21, 1983). Up to this point in time both Gibbs & Hill and Texas utilities were tracking the design verification effort. The DCTG was using this modified version of the Gibbs & Hill data base. Upon reciept of the finalized index, the TUSI THE Group began a comparison of the two computer listings. This check is being done using two sequential numerical lists to ensure that all DCA's were

• accounted for in the system. Any discrepencies between the listings or missing information is resolved by checking the hard copies of the DCA and design verification checklists. Finally, the TNE data base (DCTG) is updated if necessary.

Design verification of CMC's was performed by site organizations as well as Gibbs & Hill. Due to this split, it was considered most efficient to collect all the original design verification checklists. TNE is beginning the checking process by merging all

. of the checklists. The CMC's will then be numerically reviewed by blocks against the checklists. The DCTG computer data base will then be updated to correct drawing references and the status ~

of the design verification as required. Once the design verification is complete the CMC will be placed on a " freeze list" such that no further revisions will be permitted, thereby minimizing the number of active CMC's.

A final issue review will be done for all drawings except the ,

structural and piping composites. This review has been started. *

- and in some cases completed, for all unit 1 drawings. Each review is performed by a qualified discipline engineer who makes a determination as to ,which CMC's and DCA's have been incorporated into the drawing. Based upon this review, the DCTG data base is being updated to correctly represent the drawing and change document status. The approximate Unit 1 final issue review status is as follows: .

Flow Diagrams 100%

Instrumentation 100%

Architectural 901 Electrical 50%

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- - Communications

" Report o LM t i litill!!Il!HtHHfMHHHill nem comment. [77"Y, A recent decision has been made to require all changes and drawing revisions to be design verified prior to field issurance. Previously, construction was proceeding before ccmpletion of all verifications. This is only an economic risk since these verifications are being completed prior to start-up. There is an effort underway to turn all design verification tracking over to the site. In order to differentiate between future design modifications and the CMC's and DCA's still

. outstanding for the completion of Unit 2, an interface document tentatively called the " Engineering Change Request" (ECR) has been initiated. This document will be used to initiate a drawing change which is designed, verified and issued to the field.

-CMC's and DCA's will not be used by site personnel once the system is entirely turned over to TUGC0 Operations. Once a system has been turned over to TUGC0 Operations, a design change package tentatively called an " Engineering Change Notice," (ECN) will be used. This package will received a multi-discipline review. prior to issuance for construction. It will be .

procedurally controlled to allow for tagging of the system to be modified, final documentation of the completed modification, and close-out.

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• SEP  : 1333

c: 3: no.: 50i45 Mr. R. J. Ga ry Executive Vice President .

and General Manager .

Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201

Dear Mr. Gary:

Sutje::: Comanche Peak Stearr. Electric Statien - Inde:enden: Assessne.:

Program 5y a letter dated Sectembe- 9,1983 Mr. H. C. Schmid: of Texas Utiti:tes Services Inc. (TU5!!, transmitted a revised proposal for an Indecencen:

Assessmen: Program (IAF) for Comanche Peak to be performed ty CYGNA.

~ne *;:0 s;a a.as reviewed the revised :re:: sal and fines i: :: be es::rs've -

r.te s a" cements c:n:ained in our le::er dated July 15, 1983 an: ::

c:. e-ts mice d;rirg the meeting :n Augus- IS,1953. Furthea, the revise:

-:::sti c:sfcms to the ;r: gram revisiens described by ycur staff an: C Y 3 *; *

f.  : *e nee:1ng en August- 15, 1983. In sa:rary, we find the eve-all c:je:: .e,

!:::e act :lan cf a::ier c be acce:tt:le; and 4f c ndu::ec effectiveiy we

e eve 1: will or: vide significant additi:nal evidence for jueging :ne

vality cf cesign an: c:nstruction at Cc anche Peak.

We also find CYGNA to be an acceptable contracter for the c:nduct of -nis

r: gram. Ycur staff and CYGNA should adhere te the cc: tocol descritec in the en:lesure. Should you have any cuestiens or neec clarification, ;itase cen:Act the Projec: Manager, 5. Bumell. - - .

ke 'c:k f rward te receiving :ne draft report for car review.

Sincerely,

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~ WY\ 1'k *,L 4L Darrell G. Eisenhut. Director Division of Licensing Office of Nuclear Reactor Regulation

Enclosure:

As stated .

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Enclosu-e COMANCHE PEAK STEAM ELECTRIC STATION - INDEPENDENT ASSESSMENT PROGRAM Protocol Governing Communications Between TUGC0 and CYGNA

1. Written recommendations, evaluations, meeting and telecen su maries, and all exchanges of corresponden:e. including drafts, between CYGNA and TUG ~3 will be ke:: en file by both TUGC0 and CYGNA. The file shall be access-ible to the NRC, and shall be maintained until issuance of the full power license for Comanche Peak Unit 1.

2. Telecons may take place between TUGC0 and CYGNA technical staff to resolve c:en findings and discuss TUG ~O's pre;csed corrective acti:ns.

Tele::n su=. aries will then be prepared by CYGNA and placed'en file pec

ne :r:::c:1 of paragraph (1).

3. .The NRC Projec: Manager (S. Eurwell) and the Chief, Reac: r Pr:jec:s Erar:"

No.1 in Regien IV (G. Madsen) shall be netified of all meetings be: ween

? TUGC0 and CYGNA t: afford them (or their re:resentatives) the op;cr: unity

- -  :: be : resent, as deemed necessary, and :: notify the public cf ne

. net: n;. In this regard. TUGC0 snall pr: vide a minimum of five cays acvance n:: ice : the NRC cf any such meeting. .

Tne NEC shall make reasonable efforts to notify the publi'c cf :ne ete:i g, but the inatility of any person to attend shall not be cause of delay or pest:enecen of the meeting. Any portion of such meetings which ceals with pr:prietary information may be closed to the public. Fee:in ninutes will be written and placed on file per the proteccl of paragra;h f!). .

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P e e- . - e au-see se**

• 1

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STATEMENT OF INDEPENDENCE This statement attests to the fact that Cygna Energy Services and the members of the Independent Assessment Program project team have no vested interest in the outcome of our effort to provide added assurance as to the adequacy of the Comanche Peak Steam Electric Station (CPSES) design process.

Cygna Energy Services has perfomed no engineering design work or construction services on the Texas Utilities' CPSES project, nor for any other Texas Utili-ties project. However, from October 4 to October 6,1982 Cygna conducted a seminar on general, probabilistic risk assessment for management and licensing personnel.

~

No member of the Cygna Project Team nor of the Cygna Energy Services corporate management has ever worked for Texas Utilities nor been associated with any e design activities on the CPSES project whil'e employed by any other I

organization.

No member of the Project Team or any corporate officer or any relative thereof owns stock in Texas Utilities.

~

I believe this satisfies the current NRC requirement's ' regarding the independence of the engineering firm.

?$ a~

Larry Ka.merzell [

l U/Glo Date Vice Wesident

' Texas Utilities Services, Inc.

A LM $ 4 Comanche Peak Independent Assessment Program Niilliitillililliititittilill Final Report, TR-83090-01, Rev. 0

.