ML20198C831
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- 1. Allegation Category: QA/QC 2, Document Control
- 2. Allegation Numbers: AQ-4, AQ-16, AQ-57, AQ-59, AQ-60 and AQ-71 3.. Characterization: It is alleged that the document control center (DCC) satellites were inadequately staffed, that documentation of design changes and drawings has been inadequate and unreliable, that design changes were not revised or maintained current by DCC in the satellites (a field exten-sion of the DCC), and that an accurate listing of design changes generated against drawings and specifications was not maintained.
- 4. Assessment of Safety Significance: These allegations were assessed against the document control system in effect in July, August, and September 1984.
(The NRC Technical Review Team [TRT] assessment of allegations concerning the document control system from August 1981 to July 1984 is contained in QA/QC Category 2, allegations AQE-9, AQ-17, -18, -42, and -58.)
The TRT reviewed 46 engineering drawings and specifications and their attendant design changes, as indicated by design change authorizations (DCAs) and component modification cards (CMCs). The TRT made this review to determine if documents within the control of the DCC and the Unit I satellite were current and accurate with regard to the following: (1) that drawings and specifications contained the most current. revision; (2) that all open design changes were identified, using the manual logs or the com-puter data base; and (3) that design changes reflected the most current revision in the logs or on the computer. The review also was made to verify the accuracy of the log and the computer revision levels by compar-ing them with the hard copies of the documents in the DCC files.
The TRT identified numerous errors associated with design documents con-trolled by the DCC/ satellite. Errors identified typically were as follows:
(1) design changes which had been incorporated were still shown as open; (2) design change revisions were not current, i.e., log (incorrect) vs hard copy (correct); (3) voided drawings were still shown on the computer; (4) design change references to drawing sheet numbers were incorrect or missing in the log vs the hard copy; and, (5)..no references were made in the design change log.to the affected document.
The TRT then evaluated the implied significance of the above errors by examining controlled document packages issued by the DCC/ satellites to craft and inspection personnel. These controlled document packages were examined by DCC/ satellite personnel for accuracy and completeness before
' being issued. Because the craft and inspection personnel had to account for'each controlled document when returning it to the DCC/ satellite at the end of each shift, they also checked the accuracy and completeness of each document package when it was issued to them.
The TRT's examination of issued document packages focused en all packages issued by satellite 307 (mechanical / instrumentation counter) from the beginning of the shift (7:00 a.m.) on July 26, 1984, until 12:30 p.m. This sample represented more than 90 percent of the packages issued by the mechanical / instrumentation counter, and more than 60 percent of all pack-ages issued by satellite 307 on that day.
8605230065 860512 0-53 PDR FOIA CARDE85-09 PDR
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During this examination, each design document and any changes to it were noted when these documents were issued to craft and inspection personnel.
The current revision of each design document was then verified by checking the aperture cards in the DCC. The current revision and the design docu-ment applicability of each design change were verified against the hard copy of each design change in the DCC files. The TRT examined a total of 179 document packages (this number does not include duplicate packages also examined) and 597 design changes associated with these document packages.
Errors similar to those identified above concerning documents within the control of the DCC and the satellite were identified; however, not a single error was found in the controlled document packages issued to the crafts and inspection personnel. The TRT attributed this absence of error to the numerous checks and verifications of each document that were made by both DCC and craft personnel immediately prior to its issuance.
-The process described above is consistent with the requirements of DCP-3,
' Rev. 18, "CPSES Document Control Program," and is followed for controlling quality documents onsite, except for pipe support (hanger) drawings and subsequent changes. The hanger task force functioned as a pseudo-DCC-satellite for hanger documents, but w s not staffed by DCC personnel. The procedural control of hanger documents was governed by DCP-3 and other construction procedures such as CP-CPM-9.10. " Fabrication of ASME-Related Component Support." Based on procedure reviews, document processing, and interviews of personnel, the TRT determired that the document control exer-cised by the hanger task force was not as rigid as that of the DCC and the satellites, but document accountability (complete and current documents in hanger packages) was equally effective.
In the TRT review of 90 documents that were in the hands of craft personnel, all were found to be complete and current; however, the same type of prob-lems identified in the DCC and the satellites were found in the TRT review j of hanger document control.
L j In assessing the allegation of inadequate staffing in the satellites (AQ-4), the TRT found there were no numerical requirements for staffing levels in the DCC or its satellites in the procedures. However, from
- interviews with document control personnel, it was learned that levels i; were adjusted, based on construction activity. The TRT's review of in-place procedures, controls, and DCC/ satellite responsibilities described above indicated that staffing has been adequate.
, 5. ' Conclusions and Staff Position: Based on the review of design documents,
- the TRT concludes that some errors do exist in the manual logs, the com-
- puter data base, and the files in the DCC and the satellites. However,
- j. numerous cross-checks and references are made by document control person-nel before any document is issued to ensure that the current revisions j with correct design changes are issued. The TRT examined a large, repre-sentative sample of controlled documents issued to the craft personnel and found no instance in which design changes or design documents were in-
- correct or not current. Although inaccurate document packages may find l their way to the craft personnel, multiple levels of checks and verifica-
! tions should minimize the occurrence of such errors and provide for early i detection when they do occur.
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The TRT was neither able to substantiate nor dispr ve the allegation of 1 inadequate staffing anJ resources during an earlier time period (AQ-4); '
however, present staf fing levels are acequate v.o support cra ft personnel needs.
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In a meeting with the alleger on November 21, 1984, the TRT presented n the results of the assessment of allegations AQ-li and AQ-4 with the TRT's ]
conclusions. No r.ew concerns or allegations were identified. An appoint- .
ment was made to discuss AQ-71 and a portion of AQ-16 with the cognizant J alleger; however, the alleger did not bep t .e appoir.tmet. AQ-57, AQ-59, -'!
and AQ-60 were not raised by allegers; therefore, ne formal closecu+ ;
interviews for these concerns and issues were conducted. -
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- 7. Attachments: None.
Reference Documents:
- 1. Procedure DCP-3, "CPSES Document Control Program," all revisions.
- 2. TUGC0 Nuclear Engineering Manual, specifically TNE-AD-4, " Control of Engineering Documents," Revision 4.
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- 3. AQ-16: A-2 March 7, 1984, letter, item No. 3; and A-5 item No. 1.
- 4. AQ-57: Q4-84-014 March 8, 1984, and A-15 testimony, pp. 23-25.
- 5. AQ-59: Q4-84-014 March 8, 1984, and A-15 testimony, pp. 46, 47, 53, 54.
- 6. AQ-60: Q4-84-014 March 8, 1984, and A-15 testimony, pp. 60-61.
- 7. AQ-71: A-2 statement and interview, pp. 54-74.
- 8. This statement prepared by: [ M _ 6!d 6 V. Wenczel,d Date j TRT Technical Reviewer Reviewed by: tw c,f. 2 6 5 f H. Livermore Date Group Leader
) Approved by: V. Noonan Date Project Director , i 1 i l 1 4
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