ML20198C704

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Partially Withheld Assessment of Allegations AQ-15 & AQ-89 to Allegation Category Qa/Qc 1, Design Process Re Altered Final Drawings & Field Changed Drawings Not design-verified by Gibbs & Hill
ML20198C704
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Bonnenberg R, Livermore H
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230040
Download: ML20198C704 (4)
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1. Allegation Category: QA/QC 1, Design Process
2. -Allegation Number: AQ-15 and AQ-89 f
3. Characterization: It is alleged that final design drawings were altered.

It is also alleged that " field changed" drawings were not design-verified by the originating design organization, Gibbs & Hill (G&H).

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4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed both'the Brown & Root (B&R) and Texas Utilities Electric Company (TVEC) procedures applicable to design verification and design change control. The TRT also discussed these procedures with the TUEC nuclear supervising engineer of project and engineering support, a quality assur-ance (QA) staff engineer, the document control center (DCC) supervisor, the project control manager, the Comanche Peak Project Engineering (CPPE) tech-nical service supervisor, and a CPPE staff engineer.

The TRT learned that both TUEC and B&R procedures required design reviews for all design change authorizations (DCAs), component modification cards (CMCs), and drawing revisions that affected the design of safety-related components. These procedures also identified G&H pipe support drawings which required verification of design changes. G&H drawings which may be affected by support configuration and/or location changes are: G&H hanger drawings (GHH), pipe layout drawings, and pipe . outing drawings which indi-cate seismic support locations.

The TRT found that all drawing changes, CMCs, and DCAs, for safety-related components were subject to design verification by G&H or by the appropriate vendor. G&H and vendor engineers are located onsite for this purpose.

The TRT determined that the TUEC and B&R design change control procedures satisfied the requirements of 10 CFR Part 50, Appendix B, Criterion III,

" Design Control."

The TRT found that responsibility for design verification was transferred to TUEC Nuclear Engineering (TNE) following the completion of the construc-tion design phase of the project. The TRT also found that TNE was respon-sible for the accounting of all DCAs and CMCs that were issued and was responsibile for assuring that design verification of all design changes had been accomplished and documented, except for design changes affecting pipe supports.

The TRT determined that the interface between G&H design and the piping support design was documented in procedures. Initially, the piping sup--

port vendor uses G&H piping composites to develop piping isometrics and hanger location drawings. (The TRT evaluation of vendor certification of drawings is contained in QA/QC Category 1, allegations AQ-21, 22, 119.).

These isometrics were not G&H drawings; therefore, changes to them were not subject to G&H review. However, DCAs and CMCs written against these piping isometrics can affect the G&H composites, and changes to them are subject to G&H design verification. The actual, installed configuration was documented on "as-built" drawings, which were then used by G&H for final stress analyses.

$0860512 0-43 GARDE 85-09 pg s

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M The TRT reviewed implementation of procedures for design verification by selecting and examining samples of CMCs, DCAs, and drawings to determine whether design verifications were correctly documented. The TRT selected 100 design change documents (CMCs) for review. Of this sample, 17 CMCs were void (not issued) and 49 affected hanger designs. The TRT reviewed the remain-ing 34 pipe CMCs for proper design verification. The TRT selected 42 DCAs from those issued and reviewed them for design verification. The TRT also reviewed 21 drawings for proper design verification using the drawing numbers TNE transmitted to DCC as a key. The sample exhibited proper design verification. Design changes made during all phases of construc-tion, up to and including operation, must be verified. In addition, design changes can be made to final design drawings as long as established proce-dures are followed and design verification is accomplished. The TRT review found no instance in which this was not accomplished.

5. Conclusion and Staff Position: Based on the review of applicable proce-dures and design records, along with interviews with TUEC and B&R person-nel, the TRT concludes that the alterations (changes) to final design draw-ings reviewed by the TRT were supported by adequate technical reviews and design verification was accomplished in accordance with 10 CFR 50, Appendix B, Criterion III, " Design Control." The TRT further concludes that the allega-tion concerning design changes not being design-verified cannot be substantiated.

These allegations have no generic implications.

In a meeting with the alleger on November 27, 1984, the TRT presented the results of the assessment of allegation AQ-15 and the TRT's conclusions.

There were no major items of disagreement, and no new concerns or allega-tions were identified. The alleger of AQ-89 could not be identified, thus no contact was made.

7. Attachments: None.

Reference Documents:

1. TUGC0 procedure CP-EP-4.5, " Design Verification."
2. TUGC0 procedure CP-EP-4.6, " Field Design Change Control."
3. TUGC0 procedure CP-EI-4.6.1, " Field Design Change Control Instructions."
4. TUGC0 procedure CP-EI-4.6.8, " Field Design Change Control for Large Bore Pipe Supports."
5. , TUGC0 procedure CP-EI-4.6-13.
6. TNE drawing update activities, April 1984.
7. TNE procedures THE-DC-1 through TNE-DC-21.
8. AQ-89: GAP Witness 0 #1.
9. AQ-15: A-5 letter March 7, 1984, Item No. 12, and GAP 2.206 Petition, March 19, 1984, Item No. 25.
10. SSERs for allegations AQ-21, AQ-22, AQ-44, AQ-119, and AQ-128.
11. A-5 interview, November 27, 1984, pp. 84-86.

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8. This statement prepared by: d2 6-7 R. W. Bonnenberg, TRT Technical Reviewer cms-/c/r.- /

Date Reviewed by: 2LarA2 de II H. Livermore, Date Group Leader Approved by:

V. Noonan, Date

. Project Director i

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