ML20198D040

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Partially Withheld Assessment of Allegation AQ-110 to Allegation Category Qa/Qc 2, Document Control Re Destruction of Unit 1 Design Documentation by Document Control Ctr Prior to Unit Completion
ML20198D040
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230111
Download: ML20198D040 (4)
v • d • e


Text

1. Allegation Category: QA/QC 2, Document Control

2. Allegation Number: AQ-110
3. Characterization: It is alleged that Comanche Peak Unit I design documen-tation was destroyed by the document control center (DCC) prior to the completion of Comanche Peak Unit 1.
4. Assessment of Safety Significance: In assessing this allegation, the NRC Technical Review Team (TRT): (1) reviewed Texas Utilities Electric Company (TVEC) procedures and guidelines for the DCC, the paper flow group (PFG),

and TUGC0 Nuclear Engineering (TNE); and (2) contacted appropriate repre-sentatives pertaining to procedure and guideline implementation, issuance and handling of document packages, and QC procedures for inspection.

The allegation is divided into two areas of concern. Several months after the DCC computer was put into use, the DCC satellite clerks were instructed to destroy component modification cards (CMCs) and design change authoriza-tions (DCAs) within craft personnel drawing packages. The alleger believed that these CMCs and DCAs had not been entered in the computer prior to their destruction. The second area of concern was alleged to have occurred when Comanche Peak Unit I was near completien and the work effort was reduced. Instructions were given that a DCC satellite should throw away drawing packages for the parts of Comanche Peak Unit I that were complete.

The alleger believed that these files should not have been thrown away because craft personnel requested these fi,les at a later time and the files had to be reconstructed.

Since this allegation concerns those satellites providing document packages (CMCs, DCAs, and drawings) to craft personnel, the TRT concentrated its evaluation on the operation of the DCC satellites providing that service.

The TRT reviewed operating and administrative guidelines for the satellites and procedure DCP-3 to determine the criteria used by the satellites in maintaining document packages. The satellite's function was to provide craft personnel with a document package containing CMCs, DCAs, and drawings.

The satellite would verify, on a daily basis, that document packages were complete and contained the latest document revisions when the document l package was issued and returned at the end of the day. The TRT found no requirement, either within procedure DCP-3 or in the satellite guidelines, indicating that superseded documents were to be retained by the satellites.

In fact, the procedure and guidelines specifically required that the satellite delete, destroy, or void all superseded CMCs, DCAs, and drawings i

so that craft personnel would be working with the latest revision of the documents. (Further details of the operation uof the computer logs used

,- by DCC and its satellites are contained in QA/QC Category 2, allega-tions AQ-72 and 103).

The TRT reviewed DCC manual logs for the CMCs and DCAs, which were issued i in numerical sequence. At the time the TRT reviewed the CMC and DCA manual l logs, there were approximately 100,000 CMC numbers and 21,000 DCA numbers for which the DCC was accountable. The TRT estimated from a sampling of DCAs that approximately three percent were recorded in the DCA manual log l

8605230111 060512 PDR FOIA GARDEG5-59 PDR 0-75 l

as never having been issued. Approximately eight percent of the CMCs were never issued. The TRT then reviewed the hard copy document files for the CMCs and DCAs in the DCC and found that of the sample of 4200 CMCs and 1900 DCAs to be reviewed, 307 CMCs and 47 DCAs were not in the hard copy file.

To determine the accountability of these CMCs and DCAs, the TRT examined the manual logs and the computer. The TRT found that, with the exception of one DCA, all the CMCs and DCAs were either voided, never issued,.or were adequately accounted for. In one instance, DCA 14409 was listed in the computer but a hard copy was not found in the file; however, a hard copy was found within the DCC.

5. Conclusions and Staff Position: Based on the foregoing review, the TRT found that the destruction of permanent design records by the satellites was not substantiated. The documents destroyed were superseded, obsolete, or for completed work. In any case, documents maintained or destroyed by the satellites are only copies of a portion of the documents controlled by the DCC, which is the primary repository of all such design documents.

The TRT could not substantiate the allegation that destroyed documents were not entered in the computer prior to their destruction. Accordingly, this allegation has no generic implications.

A copy of the results of this assessment was transmitted by letter to the alleger.

7. Attachments: None.

Reference Documents:

1. Procedure DCP-3, "CPSES Document Control Program," Revisions 16 and 18.
2. Operating / Administrative Guidelines for DCC Satellites (Craft),

issued June 26, 1984.

3. Office Memorandum CPP-15,313, " Comanche Peak Steam Electric Station Administrative Guidelines for the Building Management Organization,"

dated March 2, 1984.

4. Statements from A-2, dated April 5, 1984, pages90-100 and A-61, dated May 1, 1984.
8. This statement prepared by: kb V. Wenczel,0TR N d[ d Date Technical Reviewer Reviewed by: h/ M-
  1. ~ 7~ \

H. Livermore, Date Group Leader Approved by:

V. Noonan, Date Project Director 4

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