ML20198C897

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Partially Withheld Assessment of Allegations AQ-100 & AQ-123 to Allegation Category Qa/Qc 2, Document Control Re Procedural Violations & Release of Incomplete Documentation Packages by Paper Flow Group Employees
ML20198C897
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V, Winczel V, Winczes V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230090
Download: ML20198C897 (4)
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1. Allegation Category: QA/QC 2, Document Control
2. Allegation Number: AQ-100 and AQ-123
3. . Characterization: The. concern is that the paper flow group (PFG) employees violated procedure DCP-3 and released individual c;ocuments instead of a complete package (AQ-100), and that, when they were first established, the PFGs issued incomplete (partial) documentation packages (AQ-123). ,
4. Assessment of Safety Significance: The common issue of these concerns is that the PFGs issued incomplete (partial) documentation packages to craft personnel. In assessing this issue, the TRT reviewed procedures governing the activities of PFGs and the document control center (DCC), determined the relationship between DCC satellites and the PFGs, interviewed Texas Utilities Electric Company (TUEC) and Brown & Root (B&R) representatives '

regarding the PFG/DCC satellite interface for the distribution of traveler

-documentation packages, and verified implementation of procedures for the

-issuance and control of traveler packages by the PFGs.

The responsibility of the PFGs.for Unit 1, as prescribed by the admini-strative guideline for building management organizations (BMO), was to

/ obtain, prepare, assemble, route, and/or track the documents necessary to J perform tasks.in accordance with established and approved project proce-dures. From November 1983 to June 1984, four PFGs were established to distribute the documentation required to perform construction activities under an operations traveler package concept. The administrative guide-4 line and PFG implementing procedure CP-CPM-6.3, Rev. 10, defined a traveler as that documentation' required to perform a task.

I Each trave'ler included two packages. One package contained the construc-i tion, fabrication, and testing documents, such as startup work authori-zations, inspection reports, nonconformance reports (NCRs), and fabrication t

documentation (component or item to be constructed / installed, operation description, including methods and procedure, and required QC/ANI inspec-

-tion hold points, as applicable). The other package included referenced i drawings, component modification cards '(CMCs), design change authorizations l (DCAs), and a drawing log index.

When the PFGs were first established, the drawing package was supplied to the PFGs by the DCC satellites on an extended basis because of the satel-lites' remote locations. Whenever revisions to the drawing packages occur-red, updates were accomplished by satellite personnel for packages in the field er in the PFGs, depending on the location of the documents. The procedure governing DCC satellite control of drawing documents was DCP-3, Rev.16, '.'CPSES Document Control Program," which was separate from the PFG l procedure (CP-CPM-6.3). The PFG developed the fabrication, construction, l and testing package from documents received from weld engineering, quality, l planning and scheduling, maintenance, operations, etc. Both packages were I combined at the PFG to form the traveler, and included an inventory of the i documents constituting the traveler. This documentation was accounted for daily by the PFG, prior to its issuance to craft personnel and, again, when it was returned at the end of the shift or when the job was complete (whichever occurred first).

8605230090 860512

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0-63 l GARDE 85-89 .PDR i -. - -- -- - - . . - . . . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

In reviewing PFG procedure CP-CPM 6.3, Rev 10 and 11, the TRT found that the procedure did not specifically prohibit PFG's issuance of incomplete (partial) travelers.

However, the two packages that made up the traveler were controlled separately and as a unit. When the traveler was issued by PFG, it included a complete construction documentation package and a drawing package received from DCC. Therefore, the travelers issued to craft personnel were complete.

Starting in June 1984, the four PFGs were consolidated into one PFG, which was located near the satellite for Unit 1. At this time the practice of issuing both the construction documentation and referenced drawings to craft personnel was discontinued; craft personnel obtained construction, fabrica-tion, and testing documentation from the PFG for Unit 1 and the referenced drawing (including the CMCs and DCAs) directly from the DCC satellite.

Since the TRT was not on site prior to July 9,1984, it could not verify the PFG's issuances of complete travelers vs incomplete travelers during the timeframe of the concerns expressed. However, the TRT did examine a sample of PFG construction packages commencing with June 1984, which were issued-to craft personnel using the revised method of distribution. These documentation packages included 29 electrical, 20 mechanical, and 1 civil construction travelers. The TRT determined that these packages contained the required documentation to perform and complete construction tasks and that procedures assured that inspectors would perform inspections with complete document packages.

5.

Conclusion ano Staff Positions: Based on its assessment of these issues and concerns, the TRT could not substantiate that the PFGs issued partial traveler packages to craft personnel from November 1983 to June 1984.

  • Further, the TRT found that procedures were in place to preclude the issuance of incomplete packages during this period.

The source of these concerns and issues was not an alleger. Therefore, the TRT conducted no followup interviews.

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7. Attachments: None.

Reference Documents:

1. Procedure DCP-3, "CPSES Document Control Program," Revision 16, dated August 5, 1983.
2. Procedure DEI-10, " Processing of Special Distribution Schedule,"

Revision 0, DCN #1, dated September 1983.

3. Procedure DEI-12, "DCC/ Task Force Interface," Revision 0, dated February 9, 1984.
4. Procedure CP-CPM 6.3, " Preparation, Approval, and Control of Op-erational Travelers," Revisions 10 and 11.
5. Procedure QI-QAP-11.1-28, " Fabrication and Installation Inspection of Safety Class Component Support," Revision 25, dated June 11, 1984.
6. Procedure QI-QP-11.3-23, " Class IE Conduit Raceway Inspectior.s,"

Revision 11, dated March 6, 1984.

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7. Procedure QI-QP-11.3-24, " Class IE Cable Tray Raceway Inspections,"

Revision 10, dated March 21, 1984. l

8. Procedure QI-QP-11.3-26, " Electrical Cable Installation Inspections,"

Revision 22, dated June 8, 1984.

9. Procedure QI-QP-11.3-28, " Class IE Cable Terminations," Revision 20, dated February 8, 1984.
10. Procedure QI-QP-11.10-1, " Inspection of Seismic Electrical Support and Restraint Systems," Revision 25, dated May 18, 1983.
11. Procedure CP-QP-15.3, " Quality Engineering Review of Startup of Work Permits," Revision 2, dated January 6, 1984. .
12. Procedure CP-QP-18.0, " Inspection Report," Revision 20, dated August 9, 1984.
13. Procedure CP-QP-18.4, " Permanent Plant Record Receipt Control and Storage," Revision 2, dated December 2, 1980.
14. TUGC0 audit TCP-84-CPPA-35871 dated December 16, 1983.
15. Operating / Administrative Guidelines for DCC Satellites (Craft),

issue date June 26, 1984.

16. Operating Instructions DCC Satellites, dated October 24, 1983.
17. Comanche Peak Special Review Team Report, dated July 13, 1984.
18. Office Memorandum CPP-15,313, " Comanche Peak Steam Electric Station Administrative Guideline for the Building Management Organizations,"

dated March 2, 1984.

19. Initial Charter of Paper Flow Group for Unit 1.
20. Transmittal, " Executive Summary #1 of Monitors Group," dated May 2, 1984.
21. Office Memorandum CPPA-37,697, " Comanche Peak Steam Electric Station .

TUGC0 QA Audit TCP-84 Document Control Program Audit Response Evalua-tion," dated March 23, 1984.

22. AQ-100, Region IV Office of Investigations Report OI-R-4-84-013.
23. AQ-123, NRC Special Team Report, dated July 13, 1984, page 70.
8. This statement prepared by: -

. M V. L. Wenczel,UTRT d

Date Technical Reviewer Reviewed by: /4/edC - 6 "7- V H. Livermore, Group Leader Date Approved by:

V. Noonan, Project Director Date 0-65

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