ML20198C933

From kanterella
Jump to navigation Jump to search
Partially Withheld Assessment of Allegation AQ-102 to Category Qa/Qc 2, Documentation Control Re Procedural Violations Not Reported for Determination of Reportability Under 10CFR50.55(e)
ML20198C933
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 8605230095
Download: ML20198C933 (4)
v • d • e


Text

a I

l 1

1. Allegation Category: QA/QC 2, Documentation Control
2. Allegation Number: AQ-102 ,
3. Characterization: There is a concern that a supervisor's action in a docu-ment control center (DCC) satellite resulted in procedural violations which were not reported to Texas Utilities Electric Company (TUEC) quality assurance (QA) representatives for the determination of reportability to the NRC as required by 10 CFR 50.55(e).*
4. Assessment of Safety Significance: This concern is related to a supervisor who reportedly-advised personnel that because information was entered into the computer they were not responsible for continuing to update the manual satellite log book, that they were not responsible for reporting errors detected in the computerized design change logs, and that personnel were never informed that the DCC cathode ray tube group (CRT) was to be notified when a document was requested through the DCC satellite.

In assessing the concern, the NRC-Technical Review Team (TRT) reviewed the TUEC procedures for controlling documentation within the DCC and its satel-lites, for the implementation of these procedures, and for reporting vio-lations per 10 CFR 50.55(e) . The TRT also reviewed the findings of the NRC Construction Appraisal Team (CAT) audit, NRC Region IV inspection reports and TUEC audits of the DCC, and conducted interviews with the DCC/

satellite and design change tracking group personnel.

Between February.and May 1983, both CAT and Region IV inspections identi-

-fled recurring documentation deficiencies. Typical deficiencies included drawings out-of-date by up to several subsequent issues and drawings which had incomplete title and revision blocks. On May 31, 1983, a Notice of Violation (50-445/83-18 and 50-446/83-12) was issued to TUEC for inadequate documentation control at Comanche Peak Steam Electric Station (CPSES)

(Criterion VI of 10 CFR 50 Appendix B). Substantial corrective action was required to correct the identified deficiencies. Part of the corrective action taken by TUEC was the establishment in August 1983, of the DCC '

satellites to issue and control design documents.

In August 1983, Brown & Root (B&R) established a monitoring team to audit the DCC satellites on a continuing basis. A charter for the team was delineated in procedure DCP-3. The TRT's review of the monitoring team's audit findings from August 1983 to July 1984, indicated that the recurring problem of drawing accountability was still an area of concern, but had

' been diminishing since of the monitoring team began reporting results to the assistant project manager in April 1984. The performance data pub-lished by the monitoring team in early April 1984 for Unit I satellites (306 and 307) showed defect rates of 30 percent and 10 percent respectively.

  • The topic of 10 CFR 50.55(e) reporting was previously mentioned in the D. Eisenhut letter to D. M. Spence, dated January 8,1985 on page 22, items C

& D (Attachment 3). The TRT subsequently learned that the procedure referred to in the letter was not the appropriate procedure for 10 CFR 50.ES(e) report-ability in the area of document control. Accordingly, this assessment super-sedes items.C & D in the letter.

8605230095 860512 PDR FDIA GARDE 85-89 PDR

By mid-May to early June, the defect' rates dropped to 5 percent and 1 per-cent. July's deficiency rate for both satellites averaged 1 percent.

Based.on the monitoring team's audit findings, the TRT-determined that document deficiencies existed in the DCC satellites from August 1983 to May 1984.

Based on interviews with the DCC and design tracking group personnel, the

-TRT determined that the portion of the concern regarding the satellite supervisor's actions, which resulted in procedural violations, was substan-tiated. According to.these employees, the supervisor did instruct employees not to challenge the computer, not to call the design change tracking group when discrepancies were identified in the computerized design change logs, not to notify DCC CRT of drawings the satellite obtained using the phone.

bank, and not to maintain certain manual design change logs. The TRT learned that this supervisor's employment was terminated in February 1984.

As noted above, the defect rate of 30 percent for satellite 306 was reduced to_5 percent by May and 1 percent by July. It is the TRT's view that the high defect rate for satellite 306 was attributable in part to the satel-lite supervisor's actions. (Details of the TUEC audit reports and the monitoring team audit findings are addressed in QA/QC Category 2, allega-tions AQE-9, AQ-17, 18, 42, and 58.) The TRT reviewed the nonconformance report (NCR) log books for 1983 and 1984. These NCRs were generated in accordance with CP-QP-16.0. Of the NCRs listed in the 1983 log book, 19 specifically dealt with document control procedural violations. The TRT found no evidence that an NCR was generated based on a satellite super-visor's actions.

To assess the portion of this allegation concerning "reportability," the TRT-reviewed site QA procedures dealing with general nonconformance report-ing and significant construction deficiency reporting, i.e. ,10 CFR 50.55(e).

The TRT noted that B&R does not have a procedure (s) specifically address-ing significant deficiency reporting, as they consider 10 CFR 50.55(e) to be an NRC/ utility relationship rather than a contractor / utility relation-ship. Accordingly, the procedure governing 10 CFR 50.55(e) reporting is addressed only in TUEC procedure CP-QP-16.1, Rev. 5, "Significant Construc-tion Deficiencies." In reviewing this procedure, the TRT found that it lacks specificity regarding what is a significant breakdown in any portion of the QA program. In paragraph 2.3, technical failures (for example, design, construction, and performance deficiencies) are defined and iden-tified as to reportability. However, paragraph 2.3 defines a QA program reportable deficiency as: "A significant breakdown in any portion of the Quality Assurance Program conducted in accordance with the requirements of Appendix B."

The TRT reviewed both B&R and TUEC NCR procedures to determine if noncon-forming conditions were to be evaluated for 10 CFR 50.55(e) reportability.

B&R's nonconformance procedure (CP-QAP-16.1, revisions 20 and 21) states that nonconformance conditions are to be evaluated with respect to CP-QP-16.1, but no specifics are given. TUEC's nonconformance procedure CP-QP-16.0 (Revs 13 and 14) did not address the review of NCRs as potential candidates for 10 CFR 50.55(e) reporting or reference procedure CP-QP-16.1, "Signifi-cant Construction Deficiencies." CP-QP-16.1 does delineate in paragraph 3.5 that NCRs were to be reviewed to recognize and identify significant deficiencies, as defined -in paragraph 2.3, and as quoted above; however, this procedure, which is used to review NCRs, lacks specificity.

0-68

D As noted previously, the TRT's review of NCR log books for 1983 and 1984 did not reveal any NCRs based on actions of the satellite supervisor which resulted in procedural violations. However, it is the opinion of the TRT that the issue is not that TUEC was unaware of DCC procedural violations, but that the definition of a reportable deficiency in the QA program is too vague. None of the 19 NCRs documenting procedural violations appeared to have been reported to the NRC using 10 CFR 50.55(e) reporting. (The subject of untimely reporting of significant deficiencies to the NRC is addressed in QA/QC Category 7, allegation AQ-113.)

5. Conclusion and Staff Positions: The concern that the DCC satellite super-visor took actions which resulted in procedural violations was substan-tiated. The concern that TUEC DCC procedural violations were not reported to TUEC for potential reportability under 10 CFR 50.55(e) was not sub-stantiated. In the course of assessing this allegation, the TRT deter-mined that the TUEC definition of reportable deficiencies is too vague.

TUEC's NCR procedure lacks references and does not address correlation of NCRs to reportability under 10 CFR 50.55(e). The significant deficiency procedure lacks specificity as to what is a significant breakdown in any portion of the QA program or the mechanism for review of NCRs for potential reportability. This concern has generic implications in that significant quality program deficiencies could go unreported to the NRC.

The source of this concern was not an alleger; therefore, no exit inter-view was conducted.

7. Attachments: None.

Reference Documents:

1. Proc d'ure DCP-3, "CPSES Document Control Program," Revision 16, dated August 5, 1983.
2. Procedure CP-QP-16.0, "Nonconformances," Revision 14, dated July 2, 1984.
3. Procedure CP-EP-16.3, " Control of Reportable Deficiencies," Revision 3, dated June 15, 1984.
4. Operating Instructions DCC Satellites, dated October 24, 1983.
5. Operating / Administrative Guidelines for DCC Satellites (Craft), issue date: June 26, 1984.
6. Interoffice Memo 35-1195, H. A. Hutchinson Jr. to R. Scott, " Schedule -

Transition from Control Numbered Drawing Distribution to Satellite Controlled Distribution," dated June 16, 1983.

0-69

7. Office Memorandum, J. D. Hicks to R. G. Tolson " Comanche Peak Steam Electric Station CAT Inspection - Document Control, Ref. letter TUQ-1620," dated May 2, 1983.
8. Memorandum, TUG-1620, R. G. Tolson to Distribution, " Construction Appraisal Team Inspection," April 18, 1983.
9. Results of Investigation into Allegations Regarding Document Control at Comanche Peak by Law Offices of Bishop, Liberman, Cook, Purcell and Reynolds, dated July 19, 1984.
10. Procedure CP-QP-16.1, Revision 5, "Significant Construction Deficiencies."
11. TUGC0 Nonconformance Report Log Books for 1982 (NCR 82-00001 through 82-02387), 1983 (83-00001 through 83-03312), and 1984 (84-00001 through 84-01969).
12. Independent Assessment Program for Comanche Peak Steam Electric Station Final Report, prepared by CYGNA Energy Services, Volume 1 Section 3 and 4, dated November 5, 1983.
13. TUGC0 Deficiency Review Report Log - DRR 001 through DRR 063, dated April 15, 1982 through August 31, 1984.
14. NRC Office of Investigations Report 4-84-025, " Alleged Inproprieties and Potential Wrong Doing in the B&R Document Control Center."
15. Procedure CP-QAP-16.1, Revisions 20 and 21, " Control of Nonconforming Items."
8. This statement prepared by: [ /M &rl V. Wenczel, IRT f!S Date Technical Reviewer Reviewed by:

/

$4UfAdR&L V H. Liverrnore, h 'I W Date Group Leader Approved by:

V. Noonan, Date Project Director 0-70

[

Retrieved from "https://kanterella.com/w/index.php?title=ML20198C933&oldid=3008503"