ML20198C974

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Partially Withheld Assessment of Allegation AQ-105 to Category Qa/Qc 2, Document Control Re FSE-159 Cable Tray Hanger Drawings Not Accompanied by Logs Showing Outstanding Design Changes
ML20198C974
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 8605230103
Download: ML20198C974 (4)
v • d • e


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1. Allegation Category: QA/QC 2, Document Control 2, Allegation Number: AQ-105
3. Characterization: It is alleged that after the FSE-00159 cable tray hanger drawings were switched from the civil / structural engineering group to the document control center (DCC), the drawings were not accompanied by logs that showed outstanding design changes against the drawings.
4. Assessment of Safety Significance:

The NRC Technical Review Team (TRT) established the period during which shift of control of generic FSE-00159

-fabrication and detailed assembly drawings occurred and reviewed the method of control before, during, and after this period. The TRT also determined which cable tray hanger components were fabricated during the period of transfer and reviewed the quality records associated with these components.

The TRT made this review to determine if the documents within the control of the civil / structural engineering group before the transfer, and within the control of DCC after the transfer, were current and accurate and avail-able to the craft personnel for performing work.

The TRT established that transfer of the FSE-00159 drawings commenced on December 23, 1983, and was completed on January 3,1984. The TRT determined that the drafting supervisor, civil / structural engineering group, super-vised the packaging of original drawings and their delivery to the DCC.

f Approximately 7000 drawings for Unit I were microfilmed during a 2 week effort, and these drawings were not checked out until microfilming and filing were completed. Based on the contents of the transmittal, the computer-based "DCC Current Drawing List" index was updated to reflect the latest revision of the FSE-00159 drawings at the time of transfer. If it became necessary for the FSE-00159 drawings to be revised by drafting during the period of processing the master into the DCC program (due to receipt of an approved Gibbs & Hill sngineering drawing revision), the revision was held in abeyance until the master drawing was returned to drafting. The revision was then processed in accordance with procedure ECP-10, " Cable Tray and Hanger Installation."

The TRT found that after control of the FSE-00159 drawings changed from the civil / structural group to the DCC, the logs identifying documents af-fecting the drawings did not accompany them. Such documents were design changes, such as component modification cards (CMCS) and design change authorizations (DCAs). The reason for the lack of logs was that the l FSE-00159 drawings depicted generic or typical configurations of an elec-l trical tray hanger. Callouts for the location and type of hanger to be installed on a cable tray were identified on the cable tray support plan drawing (for example, G&H drawing No. 2323-EI-0713-01-5, Cable Tray Support i

Plan, el 792-feet, 0 inches and 790 feet, 6 inches, Awx. and Electrical Construction Buildings). When a typical hanger could not be erected in the field in accordance with the FSE-00159 drawing; its configuration was changed to meet that location's needs using a DCA or CMC. The design change was then posted against the applicable support plan location, not the FSE-00159. Therefore, no " accompanying logs" to the FSE-00159 were neces-sary. The TRT found this practice to be acceptable.

8605230103 PDR FOIA 060512 CARDE85-89 PDR 0-71

To verify that the FSE-00159 drawings were adequately controlled by DCC, the TRT sampled 200 drawings to ensure that the computer data base, the drawings held by DCC, and the master drawings held by the drafting super-visor all were at the same revision level. The TRT found that all drawings were at the same level of revision. The TRT also reviewed FSE-00160,

" Cable Tray Hanger Index," an uncontrolled, cross-reference index of the hanger number, the FSE-00159 drawing revision number, and other cross-referencing information of concern to the drafting supervisor. The TRT found 7 errors in the 200 hanger drawings sampled. These errors were minor in nature.

The TRT reviewed all Brown & Root material requisitions for Comanche Peak ..

Steam Electric Station (CPSES) for the period of December 23,1983, to January 10, 1984, to establish which cable tray hanger components were fabricated and whether the proper revision of FSE-00159 drawings was used for the erection, fabrication, and construction of the cable tray hanger components. The TRT determined that no components were fabricated during the period December 23, 1983, to January 3,1984.

The TRT reviewed the operation travelers retained as permanent records in the CPSES vacit. These travelers served as the fabrication / installation inspection checklists for the work accomplished using the above fabricated components. The TRT detected no errors in the controlled document packages issued to craft personnel.

5. Conclusion and Staff Positions: Based on the assessment of the allegation, and a sample of FSE-00159 drawings under DCC control, the allegation was substantiated. However, the " accompanying logs" for FSE-00159 drawings were not necessary. The design changes were to a particular hanger in a unique loc ~ation and were not against the generic FSE-00159 drawing. There-ore, logging design changes against the cable tray support plan drawing is the accepted method of incorporating design changes. Accordingly, this allegation has generic implications.

The concerns and issues of this allegation came from an unknown source; therefore, no exit interview was conducted.

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7. Attachments: None.

c Reference Documents:

1. Document Control Procedure DCP-3, "CPSES Document Control Program,"

Revision 18, and superseded revisions.

2. Texas Utilities Services, Inc. Instruction CP-EI-40-3, " Instruction for Control of Design Documents," Revision 0.
3. Texas Utilities Services, Inc. Instruction CP-EI-4.6-7, " Field Struc-tural Engineering Group Instruction for Processing CMCs," Revision 2 and superseded revisions.
4. Texas Utilities Services, Inc. Instruction CP-EI-4.0-4, " Field Struc-tural Engineering Group Design Control Instruction," Revision 3 and superseded revisions.

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, 5. Texas Utilities Generating Company Instruction No. QI-QP-11.10-2,

" Cable Tray Hanger Instruction," Revision 27 and superseded revisions.

6. Texas Utilities Generating Company Instruction No. QI-QP-11.10-5,

" Cable Tray Hanger Reinspection," Revisicn 10 and superseded revisions.

7. Brown & Root Inc., CPSES Procedure No. CP-CPM 6.3, " Preparation, Approval, and Control of Operation Travelers," Revision 11 and superseded revisions.
8. Brown & Root Inc., CPSES Procedure No. ECP-10, " Cable Tray and Hangers Installation," Revision 8 and superseded revisions.
9. Texas Utilities Generating Company report " Records and Records Retrieval," dated June 29, 1984.
10. A-5 Interview of April 3, 1984, pp. 79-91.
11. A-5 Interview of August 1, 1984, pp. 79-84.
8. This statement prepared by: _b~

a 6!d V. Wenczel O Date

.TRT Reviewer Reviewed by: 4aca.y 4 V3 H. Livermore Date Group Leader Approved by:

V. Noonan Date Project Director 6

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