ML20198C794
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Allegation' Category: QA/QC 2. Document Control 2.
Allegation Number: AQ-3 3.
Characterization:- It is alleged that the document control system "is totally out of control." (The NRC Technical Review Team (TRT) interpreted this general allegation to mean that the document control system utilized-procedures which did not conform to NRC requirements and/or that the imple-mentation of document control procedures was inadequate.)
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Assessment of Safety Significance: The TRT reviewed Texas Utility Electric Company (TUEC) and Brown & Root (B&R) procedures and the Final Safety Analysis Report (FSAR) commitments addressing document control. The TRT.
' compared these procedures and the FSAR commitments for compliance with the requirements of 10 CFR Part 50, Appendix B, and found them to be acceptable.
Although this allegation was general in nature, it was assessed for specific and generic implications. Chapter 17 of the FSAR requires that TUEC control design and procurement documentation for all safety-related hardware. These documents consist of instructions, procedures, drawings, and specifications and the changes to them.
In addition, these documents were to be reviewed for adequacy and approved for release by authorized personnel.
Prime contractors (i.e., Brown & Root and Gibbs & Hill) were required to establish measures to assure that changes to documents were
. reviewed and approved by the same organizations that performed the original review and approval.
These documents were also required to be distributed to and used at the location where the activity they prescribed was being performed.
There were~ five functional groups of controlled procedures and instructions at Comanche Peak Steam Electric Station (CPSES):
1.
TUEC QA/QC procedures and instructions for non-ASME, safety-related work. Document preparation and control was performed by TUEC~QA/QC.
2.
B&R QA/QC procedures and instructions for ASME Code work. Document preparation and control was accomplished by B&R.
3.
Comanche Peak Project Engineering (CPPE) procedures and instruc-tions governing all engineering disciplines ~ working for TUEC.
These documents prescribe procurement and engineering activity related to civil, mechanical, electrical, instrumentation and control, and piping and supports.
CPPE prepared, distributed, and controlled these. documents.
4.
Texas Utilities Generating Company (TUGCO) Nuclear Engineering (TNE) procedures and instructions providing the methodology for pro-cessing and documenting engineering documents and independent design reviews of component modification cards (CMCs) and design change authori-zations (DCAs) generated at the job site.
These procedures were pre-pared, distributed, and controlled by TNE.
5.
B&R construction procedures and instructions describing methods for accomplishing construction-related activities, such as welding, e605230051 860512:
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-fabrication, and installation of piping and supports, instrumenta-
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tion and controls, calibration,. warehousing, and coatings.
Both ASME t
and non-ASME construction activities were covered by these documents.
l They were controlled and processed by the document control center i-
.(DCC).
i The TRT evaluated the documentation control program for each of the five types of procedures described, individually as well as collectively. With L
the exception of the DCC, which used a computer printout for distribution control, the methodology for procedural control was basically the same.
Procedures and instructions, including revisions, were given a' title and a i
sequential number. Each procedure was reviewed to verify that the docu-ment was prepared, reviewed, and approved in accordance with prescribed directions or guidelines.
Controlled distribution consisted of either a complete manus) of procedures or copies of individual procedures accom-l panied by a transmittal letter. Whenever a procedure or change was pub-lished, distribution was provided in accordance with a prescribed list approved by management. The recipient signed, dated, and returned the r
transmittal letter to the issuing organization to assure procedural control.
Other recipients were issued uncontrolled copies which were not subject to f
subsequent revision distribution. The TRT reviewed numerous distribution
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lists and completed transmittal letters for compliance with these prescribed 1
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directions and found that they did conform to requirements.
To the extent l
that the allegation was concerned with the control of procedures and instruc-tions affecting quality, the allegation was not substantiated.
l The TRT then reviewed the system for the control of drawings and spect-i fications. The DCC is responsible for the maintenance, distribution, and i
accountability of' controlled design documents (drawings and specifications) and their changes.
The DCC has established satellites which distribute design documents to field personnel. These satellites provided controlled copies to craft personnel and the task force Paper Flow Groups (PFGs),
i Documents and changes were supplied to the satellites by the DCC.
In addi-j tion, DCC distributed controlled documents directly to several " controlled j
number recipients" (e.g., the ASME Hanger Task Force).
l Changes to controlled design documents were accomplished by DCAs which l
were used for both specifications and drawings, and CMCs, which were used i
principally for drawings. Upon their receipt, DCC distributed the design changes to the applicable satellites and controlled recipients.
For G&H j.
drawings and specifications (i.e., flow diagrams and composite drawings) i and safety-related vendor drawings, a computer system was used to process i
and control both the documents and the DCAs and CMCs affecting them. As new drawings, specifications, revisions, CMCs, and DCAs were received by DCC, the computer was updated accordingly.
Site generated drawings, revi-sions, CMCs and DCAs were tracked and processed in manual logs. After the documents had been logged (manually or automated), the documents were dis-i tributed. When the DCC satellite received a drawing, revision, CMC, or DCA, the affected documents checked out to craft personnel or the PFG were updated i
by satellite personnel. This process ensured that the document packages in use were maintained up to date. Drawings checked out to craft person-nel from the PFGs or directly from the satellites were returned at the end l
of the day.
Prior to issuance of documents to craft personnel from a satel-j lite, a computer or manual 100, as applicable, was checked to verify that 0-48 I.
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.m the drawing packages contained the appropriate revision and corresponding CMCs and DCAs.
After the document packages were returned to the satel-lites or PFGs, a package inventory was taken to confirm that all controlled documents were returned.
(The PFG's issuance and control of traveler pack-ages is assessed further in QA/QC Category 2, AQ-100 and AQ-123.)
The TRT reviewed the computer and manual document control program.
In the satellites, the computer or manual logs were compared to the actual con-tents of the package. Those packages reviewed by the TRT were found to be acceptable during the TRT's onsite review of this document control system.
Design change, distribution, accountability, and status were also reviewed and found to be acceptable.
(For further details of this review, see QA/
QC Category 2 AQ-16, 57, 59, 60 and 71.)
The drawing packages reviewed by the TRT were for ongoing or recently com-pleted packages used in the field by craft personnel. To evaluate the past performance of the document control program, the TRT reviewed the internal and external audit reports dealing with document control compli-The period covered by the audits was from September 1981 to July ance.
1984.
(The results of the TRT's review of these audits are contained in QA/QC Category 2, AQE-9, AQ-17, 18, 42, and 58.) During that period the -
document control system had undergone significant changes.
Prior to August 1983, there were no satellites, and DCC issued drawings, CMCs, and DCAs to file custodians, such as welding engineering, the pipe fabrication shop, quality control, and the hanger task force. These custodians were respon-sible for updating design documents and providing current changes to craft, QC, and other personnel performing work.
Based on TUEC audit reports, the NRC construction appraisal team (CAT) report, Region IV inspection reports, and an authorized nuclear inspector special inspection report (Ref.erences 7, 10, 11, and 12), DCC did not have adequate control of design documentation. As a result, satellites 306 and 307 were established for Unit 1 to issue controlled design docu-ments and changes to the craft personnel in August of 1983.
Five other satellites were created to service Unit 1 or Unit 2 personnel other than the craft personnel.
The TRT confined its assessment of satellite document control to Unit I satellites 306 and 307. A TUEC monitoring team was also established to audit the satellites document packages for adequacy.
Initi-ally, the monitoring team reported to the DCC supervisor; however, in March 1984, reporting was changed to the assistant project general manager.
The first performance data published by the monitoring team after this change was in early April 1984.
Satellites 306 and 307 had defect rates of 30 percent and 10 percent, respectively.
By mid-May to early June, the defect rates dropped to 5 percent and 1 percent. July's deficiency rate for both satellites averaged 1 percent. The monitoring team performed these audits on a continuing basis.
Each audit cycle lasted from 2 to 3 weeks.
Results were given to DCC, other auditees, and the assistant project general manager for review and corrective action implementation.
(For details of the significance of procedural violations in the DCC and satellites, see QA/QC Category 2, AQ-102.)
One finding of the monitoring team was that certain CMCs and DCAs remained in the drawing packages even though they were not required. An NRC special review team report, dated July 13, 1984, also identified this practice as 0-49
a weakness. DCC management subsequently eliminated unnecessary CMCs and DCAs from drawing packages.
This took effect May 9, 1984, resulting in a drop in the monitoring team's identified deficiency rate from 20 percent to 4 percent.
(Details of the implementation of the computer log system and deletion of extraneous CMCs and DCAs are addressed in Category 2, allegations AQ-72 and AQ-103.)
5.
Conclusion and Staff Positions:
The portion of the allegation concerning control of procedures and instructions was not substantiated. The portion of the allegation concerning the document control system not properly functioning in regard to drawings and specifications was essentially sub-stantiated for the period prior to July 1984.
From September 1981 until June 1984, numerous internal and external audits identified a recurring problem with document control.
It was not until April 1984 that CPSES management took effective corrective action.
Generically, the present program for controlling design documents, though cumbersome, is effective.
The significance of the document control deficiencies prior to July 1984 is that these deficiencies had the potential for contributing to problems in construction, installation, and inspection.
Such problems are addressed in QA/QC Category 8, AQ-50.
These concerns and issues were cited in a GAP petition which did not identify a specific alleger. Accordingly, the TRT did not conduct a close-out interview.
7.
Attachments:
None.
Reference Documents:
1.
ASME Section III, " Nuclear Power Plant Component."
2.
ANSI N 45.2, "QA Program Requirements for Nuclear Facilities."
3.
ANSI N 45.2.11, " Quality Assurance Requirements for the Design of Nuclear Power Plants."
4.
Procedures:
a.
B&R ASME Quality Manual, Section 7, " Document Control."
b.
DCP-3, Revision 18, "CPSES Document Control Program."
c.
CP-QP-7.1, Revision 8, " Issuance and Control of Quality Procedures and Instructions."
d.
- CP-QAP-6.1, Revision 6, " Preparation of QA Procedures and Instructions."
CP-EP-7.1, Revision 6, " Control QA Procedures and Instructions."
e.
f.
CP-EP-7.0, Revision 3, " Control of Engineering Procedures and Instructions."
g.
CP-EP-6.0, Revision 2, " Preparation of Engineering Procedures and Instructions."
h.
THE-AD-3, Revision 4, " Preparation of Procedures and Instructi6ns."
i.
THE-AD-4, Revision 6, " Control of Engineering Documents."
j.
CP-CPM-6.1, Revision 4, " Preparation and Approval of Construction Procedures and Instructions."
5.
B&R Construction Procedures Index, IM 27,857, dated October 2, 1984.
6.
Gibbs & Hill Specification Revision / Addendum Report, dated July 22, 1983.
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7.
Hardford Steam Boiler, Authorized Nuclear Inspector SIS Record for Monitoring QA/QC Programs, No. 361A, dated August 11, 1983;
Subject:
" Document Control Nonconformance."
8.
NRC, Comanche Peak Special Review Team Report, dated March 17, 1984, page 11.
9.
Allegation source, GAP 2.206 Petition, Item No. 15 dated March 19, 1984.
- 10. NRC, Construction Appraisal Team Report, dated April 1983, pages B-2 and VIII 6 and 7.
- 11. NRC, Region IV Report 50-445/83-24, Paragraph 9.
- 12. NRC, Notice of Violation 50-445/83-18 and 50-446/83-12, item 3.
8.
This statement prepared by:
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[ d![6 V. Wenczel4TRT Date Technical Reviewer Reviewed by:
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b ~7-b 7 H'. Livermore, Date Group Leader Approved by:
V. Noonan, Date Project Director i
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